Waiver Ends: Adjustment to SNAP Interview Requirement for Initial Applications Ends 03/31/2022

Illinois Department of Human Services logo

03/30/2022

Policy Memo

Summary

  • This policy memorandum informs the Family Community Resource Centers (FCRCs) that the adjustment to waive the interview requirement for Supplemental Nutrition Assistance Program (SNAP) initial applications, including applications that qualify for expedited service will end 03/31/2022. This memorandum supersedes the interview adjustment policy for initial applications issued in, Waiver Continues Adjustment to the Interview for all SNAP Initial Applications and REDES Until Further Notice, dated 01/25/2022. This memorandum makes no change to the interview adjustments for redeterminations (REDEs).
  • All applicants who file an initial SNAP application on April 1, 2022, and after must have an interview. All mandatory verifications must be provided before benefits can be issued, unless expedited with postponed verifications. An applicant who qualifies for expedited service must have an interview and only identity must be verified before issuing 1 or 2 months of benefits. Other verifications may be postponed, if not provided with the application and available at the time of the interview.
  • FCRCs should continue to waive the interview requirement for SNAP REDEs when identity and all mandatory verifications have been provided with the application until further notice. The FCRCs will be notified when this interview process for REDEs is no longer in effect.
  • If the interview is waived, SNAP Work Registration (Form 2646) should be mailed to SNAP households whose members are nonexempt from Work Provisions (WAG 03-15-01). The worker will not be explaining it, but it contains the same language as what the worker would explain in the interview.  It should be documented in Case Comments that the form was mailed and the interview was not necessary due to the terms of the waiver.

This policy memorandum informs all Family Community Resource Centers (FCRCs) of a change in the requirement to conduct an interview with applicants who file initial applications for Supplemental Nutrition Assistance Program (SNAP) benefits. The Food and Nutrition Service (FNS) waiver that allows Illinois to adjust the interview requirement for initial applications, including expedited applications will end 03/31/2022. This memorandum supersedes the interview adjustment policy for initial applications issued in, Waiver Continues Adjustment to the Interview for all SNAP Initial Applications and REDES Until Further Notice, dated 01/25/2022. This memorandum makes no change to the interview adjustments for redeterminations (REDEs).

Initial SNAP Application Interview

  • FCRCs must conduct an interview with all applicants filing an initial application for SNAP benefits on April 1, 2022, and after. This includes applicants who file an initial application and qualify for expedited service.
  • Unless the applicant qualifies for expedited service with postponed verifications, the FCRC must request all mandatory verifications, including identity to determine eligibility before SNAP benefits are issued. 
  • First, attempt to call the applicant to conduct an interview. If the applicant cannot be reached by phone, send Appointment Notice (Form 267T) to schedule the interview appointment. At the interview discuss any verifications that are needed to determine eligibility with the applicant. Send Verification Checklist (Form 267 VCL) requesting the information. Allow 10 calendar days for the applicant to return the verifications. Whenever possible, use electronic sources to verify identity and any other verification that can be obtained through an electronic source such as, the State Online Query (SOLQ) and The Work Number (TWN).
  • If the applicant requests a face-to-face interview, the FCRC should explain that in lieu of a face-to-face, the interview will be conducted by telephone. This is necessary to protect the health and safety of the applicant and FCRC staff during the COVID-19 pandemic.

 Initial SNAP Application Interview (Expedited Service)

  • An interview must be held, and identity verified prior to the issuance of expedited benefits.
  • If the interview is held and all eligibility factors are verified to determine eligibility for SNAP, issue expedited benefits, run eligibility, and certify ongoing benefits.
  • If the interview is held and identity can be verified but other verifications are postponed, issue within the expedited timeframes:
    • 1 month of benefits if the application is filed before or on the 15th of the month; or
    • 2 months of benefits if filed after the 15th of the month. 

FCRC Pending Initial SNAP Applications as of March 2022

Initial SNAP applications that are currently pending as of March 31, 2022 may continue to be processed using the procedures established in policy memorandums, Adjustment to SNAP Interview Requirement Waived for Initial Applications and Redeterminations until Further Notice, dated 07/01/2021 and Waiver Continues Adjustment to the Interview for all SNAP Initial Applications and REDES Until Further Notice, dated 01/25/2022. This procedure only applies to initial applications, including expedited applications, that have been received in the FCRCs and are still pending as of March 31, 2022:

  • Do not require an interview for initial applications when:
    • identity is verified; and
    • all other mandatory verifications needed to determine eligibility are provided with the initial application.
  • An interview must be conducted when identity cannot be verified and/or:
    • mandatory verifications have not been provided to establish eligibility; or
    • the information is questionable.
  • Whenever possible, the FCRC should use electronic sources to verify identity and any other verification that can be obtained through an electronic source. 
  • An evaluation and analysis of the estimated SNAP households that have been impacted by these adjustments is required to be reported to FNS. In order to collect this data, FCRC staff are instructed to select "Home Visit" as the Interview Mode on the Individual Interview/Applicant- Details screen.

Interview Adjustment Continues for Redeterminations

Under the terms of the waiver, FCRCs may continue to waive the interview requirement at redetermination (REDE), when identity is verified, and all mandatory verifications are provided with the application. 

  • An interview must be conducted when identity cannot be verified and/or:
    • mandatory verifications have not been provided to establish eligibility; or
    • the information is questionable.
  • Whenever possible, the FCRC should use electronic sources to verify identity and any other verification that can be obtained through an electronic source. 
  • An evaluation and analysis of the estimated SNAP households that have been impacted by these adjustments is required to be reported to FNS. The FCRCs should continue to select "Home Visit" as the Interview Mode on the Individual Interviewed/Applicant- Details screen. 
  • The FCRCs will be notified when this interview process for REDEs is no longer in effect.

Rights and Responsibilities/Copies of the Application

Each FCRC has established a procedure to retrieve mail, print documents, and send other information from the FCRC. A copy of the Rights and Responsibilities, applicable program forms and brochures and a copy of the application (if a copy is requested) should be mailed to the customer. If an FCRC is closed, documents may be printed in the FCRC, and a designated person will pick up the documents from the FCRC for mailing.

Case Comments

Documentation in Case Comments is required. The worker should provide a detailed description of the household's circumstances. The detailed description should include any adjustments or exceptions made to the eligibility determination and case processing due to COVID-19. This includes any customer and advocate complaints. Case Comments should also include the worker's statement that the applicable program forms and brochures were mailed to the customer, including a copy of the program's Rights and Responsibilities and if requested, a copy of the application.

Form 2646

If the interview is waived, SNAP Work Registration (Form 2646) should be mailed to the SNAP household. The worker will not be explaining it, but it contains the same language as what the worker would explain in the interview. It should be documented in Case Comments that the form was mailed and the interview was not necessary due to the terms of the waiver. It is only to be given to non-exempt customers per WAG 03-15-01.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced:

Form 267T

Form 267 VCL

Form 2646