WAG 19-03-04: Verifications

PM 19-03-04

1. Make sure that the amount of housing costs (rent, mortgage, property taxes, State and local assessments, and homeowner's insurance) reported by the customer at the SNAP REDE is documented in the case record. Verification of housing costs is not required.
2. See PM 02-08-03 when verification is required at the SNAP REDE. Issue Form 267T, Appointment Notice to schedule an interview. Use the 267 Verification Checklist (VCL) to request any required verifications. Be sure to review electronic sources prior to requesting verifications. Only the information that is needed should be requested from the customer.  See sections below for "Accepting Verifications via the Customer's Cell Phone", when a customer claims that the only source of verification is on their cell phone and "Verify a SNAP Household's Income before Denying a SNAP Application." The gross monthly income of the SNAP household must be verified before an application for SNAP can be denied for income being over the income standard for the household size (WAG 13-01-01-a). A SNAP application cannot be denied based solely on the applicant's statement of the household's income.
3. During the SNAP REDE interview, issue a second 267 VCL if:
   • the customer comes to the interview, but does not provide the requested verifications, or
   • there are additional verifications that are needed which were not requested on the first 267 VCL. 
   • When requesting additional verification, repeat steps 2 and 2a. Allow 10 calendar days for return of the information. 
4. If the customer does not provide verifications other than proof of an expense, deny the SNAP REDE application.

   Example: Mr. A files an SNAP REDE application on 08/14. On 08/18, during the SNAP REDE interview, he reports that he receives Veteran's benefits.

   The caseworker completes a 267 VCL to request proof of income. Mr. A has until 08/28 to provide the information.

   Mr. A does not provide the requested information by the 08/28 due date. On 08/29, the worker denies Mr. A's SNAP REDE application. 

5. If the SNAP household does not provide proof of an expense for which verification is required, approve the SNAP REDE application without allowing a deduction for the expense. Do not deny an application for failure to verify an expense. Document the reason why the expense was not allowed.
6. SNAP households entitled to the Standard Medical Deduction remain eligible for the deduction if they state that their medical expenses continue to exceed $35.  Do not verify expenses exceed $35 unless their statement is questionable.
7. SNAP households that choose to use actual medical expenses because they exceed the Standard Medical Deduction must verify the actual expenses. If the unit verifies that medical expenses exceed $35 but fails to verify total monthly medical expenses, allow the appropriate Standard Medical Deduction.  If the unit fails to verify any medical expenses, the unit is not entitled to a medical expense deduction.

Accepting Verifications via the Customer's Cell Phone

• Use documentary evidence as the primary source of verification when possible. Documentary evidence is the actual item itself, such as a driver's license or paystubs. When a customer is claiming not to have the actual item, accept any reasonable documentary evidence provided by the household that adequately proves the statements on the application and clearly identifies the item as belonging to the customer.
• Electronic pay verification from an employer may be accepted as proof of income. A customer who only has a photo copy of their paystubs on their cell phone may submit the photos to verify income. To be acceptable, the verification must contain sufficient information to identity the customer and what is needed to determine eligibility. Sufficient pay verification includes the customer's name, employer name, number of hours worked, pay frequency, pay dates, gross income/net income, and deductions. All income must be provided and budgeted correctly.

Email Cell Phone Verification to FCRC General Mailbox

When the customer's only source of proof is on their cell phone, it should be emailed to the FCRC's General mailbox where it can be uploaded to the Electronic Case Record (ECR). The HSC should not request a customer to email any documents to their own individual email address.

• Example 1: Ms. J is in a homeless shelter and is applying for SNAP. During the interview Ms. J states she is employed part-time at TB Diner and is paid weekly. When asked for her paystubs for the last 30 days. Ms. J explains that due to her living arrangement she has only a few personal items. She states it is easier and more secure to keep photo copies of paystubs and other documents on her cell phone. The HSC reviews Ms. J's paystubs from the last 30 days and determines that all the necessary information is on each paystub needed for the last 30 days. The HSC tells Ms. J to email her paystubs from the last 30 day to the FCRC's General Mailbox. The verification is uploaded to the ECR and HSC documents in Case Comments.
• Example 2: Mr. B is applying for SNAP. He is employed with ABC company and is paid twice a month. During the interview Mr. B states his employer does not provide paystubs. Instead he receives an electronic pay verification statement on his cell phone for each pay period. The HSC reviews the pay verification and determines that Mr. B has the appropriate pay verification from the last 30 days and tells him to email it to the FCRC General Mailbox. The verification is uploaded to the ECR and HSC documents in Case Comments.

Document in Case Comments

• Document in Case Comments the verifications being used to determine eligibility, including verifications obtained from the customer's cell phone.
• Case Comments must be documented with information to support eligibility, ineligibility, and benefit level determinations. Documentation should be sufficient in detail to permit a reviewer to determine the reasonableness and accuracy of the determination.

Verify a SNAP household's Income Before Denying a SNAP Application

• The HSC must verify a SNAP household's non-exempt income prior to denying a SNAP application due to the income being over the income standard. for the household size. The SNAP EDG cannot be denied and closed based solely on an unverified statement of household income.
• If a household states on the SNAP application or during the interview that its income exceeds the gross income limit, the HSC must pursue verification of income and continue the 30-day application process with the household.
• If the household fails to provide timely verification of income, the HSC can deny SNAP benefits for failure to provide verification. If the household provides timely verification that shows its non-exempt income exceeds the gross income limit, then the HSC can deny SNAP benefits based on exceeding the gross income limit. This only applies to households that are subject to the gross income limit.
  • Example: Mr. J applies for SNAP for himself, his wife and 3 children. At the interview Mr. J states he is employed and earns around $4,500 monthly. The gross monthly income standard for a household of 5 is $4,149. The HSC does not have proof of Mr. J's income at the time of the interview to determine if it actually exceeds the gross monthly income standard for a household of 5. The HSC gives Mr. J a 267 VCL to request his paystubs and allows 10 calendar days for return. If Mr. J returns his paystubs the HSC can determine if his income exceeds the standard and may deny the application for that reason. If Mr. J does not return his paystubs the application is denied because he failed to provide verification and eligibility cannot be determined.

Document in ECR and Case Comments

• The FCRC must upload verifications to the ECR and document in Case Comments information to support eligibility, ineligibility, and benefit level determinations. Documentation should be sufficient in detail to permit a reviewer to determine the reasonableness and accuracy of the determination.
• A negative action taken by the HSC is only "valid" if the information in the ECR and the documentation in Case Comments supports the negative action, as well as the reason for the negative action that was presented to the household.