- At the request of the Bureau of Training and Development (BTD), this manual release defines the difference between a Mid-Point Reporting SNAP Household and a Change Reporting SNAP household. The two types of SNAP households have different reporting requirements that the Family Community Resource Center (FCRC) must fully explain to the applicant to prevent errors and overpayments.
- IES determines if a case is in Mid-Point Reporting status or Change Reporting status upon approval for regular rolls. However, a worker must be able to identify a SNAP household's reporting status based on the information gathered during the interview so that they may inform the household of their reporting requirements at the time of interview.
- In addition to informing customers of their applicable reporting requirements, the FCRC must inform all customers of their rights, the application processing times, the verification process and the need to complete a timely recertification when notified that those benefits are ending.
- This manual release also includes a correction in PM 05-07-00, WAG 05-07-00, PM 05-07-02 and WAG 05-07-02 to clarify SNAP households who are not categorically eligible.
- At the request of the Bureau of Training and Development (BTD), this manual release defines the difference between a Mid-Point Reporting household and a Change Reporting SNAP household. It also clarifies that Simplified Reporting is a federal term that is referred to in Illinois as Mid-Point Reporting.
- To comply with a Food and Nutrition Service (FNS) Management Evaluation (ME), this manual release informs Family Community Resource Centers (FCRC) that in addition to informing customers of their reporting requirements, the FCRC must inform customers of their rights, the applicable application processing time, the verification process and the need to complete a timely recertification when notified of benefits ending.
Mid-Point Reporting (Simplified Reporting) Background
The Farm Security and Rural Investment Act of 2002 allows states the option to establish a Simplified Reporting System for SNAP. This allows certain SNAP households to have fewer reporting requirements which helps to reduce the volume of customer contact and paperwork received in the Family Community Resource Centers. States are also allowed to create their own name instead of using the federal term know as Simplified Reporting. In December 2015, Illinois implemented 12-month certification periods for all SNAP households and renamed its Simplified Reporting System from EZ REDE to Mid-Point Reporting.
- Explain the application process to the SNAP household including the application processing time-frames; and
- If approved, a Notice of Decision (Form IL 444-360c) will be mailed to household with information on their certification period, benefit amounts and who has been approved. Tell the applicant to read their approval notice to find out the certification period, reporting requirements and other important information about their case; or
- If denied, the notice will inform the household of the denial reason and right to appeal if they disagree with the decision.
- Also explain that approximately 60 days prior to the end of the certification period, Medical, Cash and SNAP Redetermination Notice, (Form IL444-1893) will be mailed to them to complete and return by the due date on the notice. This is for both Change Reporting and Mid-Point Reporting households. If the household does not recertify, Cash and/or SNAP benefits will end. A new application is required if the SNAP household did not receive benefits in the month following the month that their certification period ended.
Applicants Waiting for an Eligibility Determination
Applicants are to report all changes at the eligibility interview. Once the interview has been held, a change that happens after the eligibility interview and before the notice of decision must be reported within 10 calendar days after the date of the notice. When a change is reported by the customer, review the effect of the change on eligibility and benefit amount.
Mid-Point Reporting SNAP Households
A Mid-Point Reporting household is a regular roll:
- TANF case (with or without SNAP) and there is earned income to budget on the case; or
- a case in any program category with SNAP benefits except for the following:
- SNAP households whose adult members are all qualifying members and there is no earned income to budget on the case; or
- SNAP households residing in areas of the state where the SNAP Work Requirement Time-Limited Benefits policy is waived; or
- TANF cases with SNAP and there is no earned income to budget on the case.
Mid-Point Reporting Status
- The worker should explain that a SNAP household in Mid-Point Reporting status is approved for 12-months and redetermined every 12-months with an interim SNAP and TANF Mid-Point Report form completed in the 6th month of the household's certification period. and
- During the certification period, a SNAP household in Mid-Point Reporting status must report:
- when their gross monthly income exceeds the Gross Monthly Income Standard for the household size. Tell the household its Gross Monthly Income Standard. See PM 19-07-06; and
- complete the SNAP and TANF Mid-Point Report form when it is received and must answer all questions and report any changes in circumstance related to the questions asked on the form; and
- report when they receive a substantial lottery or gambling winning as a cash prize of $4,250 or more won in a single game:
- at REDE;
- Mid-Point Report; and
- By the 10th calendar day of the month after the month that the income or winnings are received during the certification period. A Mid-Point Reporting household cannot wait until the Mid-Point Report or REDE to report the receipt of substantial lottery or gambling winnings. See PM 07-04-21.
- Inform Mid-Point Reporting households of the requirement to complete, SNAP and TANF Mid-Point Report, (Form IL444-2890) in month 6 of the 12-month certification period. If Form IL444-2890 is not returned by the end of the 6th month, benefits will stop. If returned in the 7th month, benefits will be prorated from the date of receipt. If returned after the 7th month, a new application is required.
- At REDE approval, IES sends Redetermination Fact Sheet (Form 444-4769) with the Mid-Point Reporting requirements and the Gross Monthly Income Standard for the household size.
- For active cases that report earnings, update IES and certify the results. IES will enroll the case into Mid-Point Reporting status and centrally send Form IL444-4769 Redetermination Fact Sheet. Form 4769 describes the Mid-Point Reporting process and includes the SNAP household's Gross Income Standard for SNAP reporting purposes. IES sends Employment Checklist (Form IL444-3430) to all TANF cases.
- Act on reported changes that the Mid-Point Reporting household is required to report. For changes that the Mid-Point Reporting household is not required to report, only act on the information if reported by the SNAP household and the information is clear. If a reported change makes a case exempt from Mid-Point Reporting, remove the case from Mid-Point Reporting status at the next REDE. If additional information is needed, do not send a Verification Checklist (Form IL444-267) to request verification. Address the reported change at the next Mid-Point Report or next REDE, whichever is earlier.
- A Mid-Point Reporting household is not required to report an address change. If the household reports an address change or if an address change is received as a result of being reported to the Illinois Department of Healthcare and Family Services (IDHFS) medical programs, then the worker may act on the reported change. If the shelter expenses are unknown, the worker should send Verification Checklist (Form IL444-267). If the address change information is reported by any other outside entity, the worker should wait until the next interim Mid-Point Report is completed or the next REDE, whichever occurs first. A worker should not send Form (IL444-267) to request verification or information on changes that the Mid-Point Reporting household is not required to report.
Change Reporting SNAP Households
A Change Reporting SNAP household is a regular roll case that meets the following criteria:
- All adult members in the SNAP household are qualifying members and there is no earned income to budget on the case; or
- A TANF household with SNAP and there is no earned income to budget on the case; or
- Only when the Work Requirement Time-Limited Benefits policy is in effect, SNAP households whose county of residence is in a nonwaived area of the state. These cases are centrally converted from Mid-Point Reporting status to Change Reporting status. IES generates and mails Change in Reporting Requirements (Form IL444-3324) to the appropriate SNAP households to notify them of the change in their reporting requirements.
- Note: Regular rolls means that the case is approved for ongoing benefits during a 12-month certification period.
Change Reporting Status
- The worker should explain that a SNAP household in Change Reporting status must report the following changes within 10 calendar days of the date they learn about the change (PM 18-04-00). For income-related changes, the date the first payment is received (as a result of the change) is the date the customer learned about the change:
- When they get, change, or lose a job;
- When monthly earned income changes by more than $125;
- When the source of unearned income changes, or the amount changes by more than $125. The customer does not have to report changes in any cash benefit from the Department;
- A change in SNAP household size;
- A change in address and new shelter costs. Provide a customer with the opportunity to register to vote when a change of address is reported in person;
- A change in obtaining a licensed vehicle;
- For non-qualifying member households who are not categorically eligible (PM 05-07-00), report when total cash on hand, stocks, bonds, and money in a bank or savings account exceeds a total of $2,750;
- For qualifying member households who are not categorically eligible (PM 05-07-00), report when total cash on hand, stocks, bonds, and money in a bank or savings account exceeds a total of $4,250;
- For SNAP households that receive a deduction for child support payments, report when the order to pay child support changes or ends;
- Report a change in work hours that brings the individual below 20 hours per week, averaged monthly. Currently the entire State is exempt from the SNAP Work Requirement. See PM 03-25-00.
- For categorically eligible households (including SNAP households receiving TANF and SSI income) and noncategorical eligible households, report substantial lottery or gambling winnings won in a single game as a cash prize that exceeds $4,250. See PM 07-04-21, and PM 19-07-00.
- Give each Change Reporting SNAP household, Reporting Changes - SNAP (Form IL444-2777) when the household applies for benefits
- At the time of approval, send the SNAP household a SNAP Change Report (Form IL444-1978) and a non-postage paid return envelope.
- Act on changes reported by phone, in person, or in some other manner during the certification period just like those reported on the SNAP Change Report Form within 10 calendar days of the date a change is reported or discovered, including information from computer generated reports if the information reported on the report is considered clear information PM 18-04-03.
- When the customer uses Form IL444-1978 to report changes, always send them a new form with a non-postage paid return envelope
Determining a Household's Reporting Status
IES makes the determination of a household's reporting status (Mid-Point Reporting or Change Reporting) when the case is approved on regular rolls for ongoing benefits.
However, a worker must be able to identify a SNAP household's status based on the information gathered during the interview so that they may inform the household of their reporting requirements at the time of the interview.
Example 1: Ms. J is applying for TANF and SNAP for herself and two children. At the interview, Ms. J tells the worker that she is working part-time and provides her paystubs. Because Ms. J is applying for TANF/SNAP and has earned income, the case, if approved, will be in Mid-Point Reporting status. The worker explains the Mid-Point Reporting requirements to Ms. J.
Example 2: Ms. K is applying for TANF only. At the interview, Ms. K states she is working part-time and provides paystubs. Because Ms. K is applying for TANF and has earned income, the case, if approved, will be in Mid-Point Reporting. The worker explains the Mid-Point Reporting requirements to Ms. K.
Example 3: Mr. B, age 30, lives alone and is applying for SNAP. Mr. B states at the interview that he is not disabled and does not receive income from any source. The SNAP Work Requirement policy is not in effect in any Illinois county. If approved for SNAP, Mr. B will be in Mid-Point Reporting status. The worker explains the Mid-Point Reporting to Mr. B. If the SNAP Work Requirement policy was in effect in Mr. B's county of residence, his case would be in Change Reporting status.
Example 4: JT, age 65, and his wife, age 62, are applying for AABD and SNAP. At the interview, JT explains that he and his wife live alone and receive Social Security benefits. If approved for SNAP, JT and his wife will be in Change Reporting because all the adult members of the SNAP household are qualifying members, and the case does not have earned income. The worker explains the Change Reporting requirements to JT and his wife, and also provides the household with Reporting Changes - SNAP (IL444-2777). At the time of approval, the worker will send the SNAP household a SNAP Change Report (IL444-1978) and a (non-postage paid) return envelope.
Example 5: Mr. R, age 65 and his wife, age 62, live with their son who is age 18. The household is applying for SNAP benefits. At the interview, the worker is told that food is purchased and prepared together which makes this one SNAP household. Mr. R and his wife both receive Social Security benefits. Their son is employed 30 hours per week. Although Mr. R and his wife are adult qualifying members, their adult son does not meet the qualifying member criteria. The case also has earned income. Based on this information, the worker determines that if approved, this case will be in Mid-Point Reporting. The worker explains the Mid-Point Reporting requirement to Mr. R.
Example 6: Ms. L is applying for medical and SNAP for herself and her 5-year old daughter. At the interview, Ms. L states she is employed full-time and provides paystubs. If approved for SNAP, Ms. L's case will be in Mid-Point Reporting. The worker explains Mid-Point Reporting to Ms. L and the Mid-Point Reporting requirements.
Example 7: A, age 25, C, age 21 and T, age 30 are applying for SNAP. Food is purchased and prepared together. At the interview, the worker learns that the household members are unemployed and have no other source of income. Although all the members in the SNAP household are adults, they do not meet the qualifying member criteria. Based on this information, the worker determines that if approved for SNAP, this case will be in Mid-Point Reporting status. The worker explains the Mid-Point Reporting requirements to the SNAP household. If the SNAP Work Requirement policy was in effect in the county of residence, this case would be in Change Report status.
Example 8: Ms. G is applying for medical and SNAP for herself and her 3 year old twin girls. At the interview, Ms. G states she is unemployed and has no other source of income. She is staying with a friend until she can find employment and is currently living off her savings. Although Ms. G is the only adult SNAP household member, she does not meet the qualifying member criteria. Based on this information the worker determines that if approved for SNAP, Ms. G will be in Mid-Point Reporting status and explains the Mid-Point Reporting requirements to her.
Example 9: Ms. V is applying for TANF and SNAP for herself and her 3 children. At the interview, Ms. V states she is not employed and does not have any other source of income. Based on this information, the worker determines that if approved for TANF the case will not have earned income to budget. This case will be in Change Reporting status. The worker explains the Change Reporting requirements to Ms. V and also provides the household with Reporting Changes - SNAP (IL444-2777). At the time of approval, the worker will send the SNAP household a SNAP Change Report (IL444-1978) and a (non-postage paid) return envelope.
Note: An adult in the SNAP household who is age 60 or older is a qualifying member. If under age 60, then the adult must be at least age 18 or older and is receiving income from one of the following sources: Primary RSDI Retirement Benefits, Primary RSDI Disability Benefits, RSDI Benefits as a Disabled Widow/Widower or Disabled Child, Railroad Retirement Benefits, Veteran's Benefits, Federal, State, or Municipal Retirement, or Supplemental Security Income.
Viewing Reporting Status in IES
To view the reporting status of the SNAP household in IES, go to:
- Left-navigation and select Eligibility.
- Then select Eligibility Summary.
- Once the customer's information populates, click on the Benefit Period hyperlink to open the EDG.
- The SNAP - EDG Summary page will display the SNAP Reporting Type for the household.
Customer Rights and Responsibilities
The IDHS OneNet page used by workers to explain the Rights and Responsibilities to customers has been updated to comply with a Food and Nutrition Service (FNS) Management Evaluation (ME). Additional information about a customer's Rights and Responsibilities may be found in the Cash, SNAP and Medical Policy Manual in section PM 01. The Rights and Responsibilities must be explained to all customers.
Right to Appeal
It is the right of a person who applies for or receives benefits from the Department to be informed about the hearing process and their right to appeal and receive a fair hearing.
All customers have the right to inquire about our programs, file an application and have their eligibility determined without regard to race, color, religion, sex (including gender identity, and sexual orientation), national origin, age, disability, or political beliefs. A customer who feels that they have been discriminated against may file a complaint with IDHS Bureau of Civil Affairs and/or with the United States Department of Agriculture (USDA). Give all customers the, Your Civil Rights (IDHS 592) brochure.
Customers (or their representative) deserve to be treated with courtesy and respect. They have the right to file a grievance against an IDHS employee if they feel they were not treated fairly. Being treated with courtesy and respect includes the manner in which FCRC staff speak to customers and how they are made to feel when applying for benefits. This is mistreatment for a reason unrelated to the nondiscrimination statement.
Customers must provide proof that they qualify for our programs. Help the customer understand the programs and explain the eligibility factors (PM 02-07-03) that must be verified to qualify for benefits. Assist them in obtaining needed verifications if they request help.
Social Security Numbers
Explain to customers why their Social Security Number (SSN) is needed. An SSN is required by law for applicants seeking benefits. It will be used to gather information in computer matching systems to determine eligibility and benefit amounts. A customer may claim good cause for not having an SSN for a household member and may show proof that they have applied for a card through the Social Security Administration (SSA).
SNAP households are allowed certain expenses as a deduction when calculating the benefit amounts. Inform SNAP applicants during the interview that a failure to report or verify expenses will be seen as a statement by the SNAP household that they do not want to receive a deduction for the unreported expenses. Child support payments are subject to verification by computer matching with the records of the Division of Child Support Enforcement (DCSE).
If verifications are needed to determine eligibility, explain to the applicant what those verifications are and give examples of what can be used for proof. IES generates, Verification Checklist, (Form IL444-0267) with the name of the person who the verification is needed for, the applicable benefit program and examples of what can be used as proof. Allow an applicant 10 calendar days to provide verifications. Allow additional time if requested. Whenever possible use electronic sources to help the customer with the verification process.
Overpayments/ SNAP Penalties
Explain to SNAP applicants that regardless of whether an error is on their part or is an agency error, the overpaid benefit amount may be subtracted from their monthly benefit amount. Also inform the applicant of the SNAP penalties for providing false information or misusing benefits. See PM 23-02-02 and PM 23-06-03
Document in detail all case actions. Include what was explained to the applicant, the forms that were given and any verifications that were requested. If the case is denied, document the reason.
[signed copy on file]
Grace B. Hou
Secretary, Illinois Department of Human Services