MR #20.05: Cook County Implements SNAP Work Requirement January 2020

02/05/2020

Summary

• The SNAP Work Requirement limits able-bodied adults age 18 to 49 with no dependents, disabilities or other work exemptions to only 3 months of SNAP benefits in a 36 month period, if certain work rules are not followed. The 36 month period is a 3 year fixed period (January 1, 2018 through December 31, 2020).  SNAP recipients who must comply with the Work Requirement or face the loss of SNAP eligibility after receiving 3 months of SNAP benefits are referred to as ABAWDS (able-bodied adults without dependents).
• The SNAP Work Requirement was first implemented in DuPage County in January 2018 and continues to be in effect in the year 2020.
• Starting January 1, 2020, SNAP recipients residing in Cook County, who are age 18 through 49 and have no dependents, disabilities or any other work exemptions will be limited to 3 months of SNAP benefits, if they do not work or volunteer to do a work activity to meet the requirement. Each month that the individual does not meet the requirement counts as an unmet month. This means that nonexempt SNAP recipients residing in Cook County, regardless of Office of Choice are now at risk of losing SNAP eligibility as early as April 2020, if certain work rules are not followed. In order to receive SNAP benefits ongoing a nonexempt customer must be meeting the Work Requirement monthly.
• January 2020 is the first countable month for the ABAWD Time-Limit Clock to tick as unmet for SNAP initial applications, REDES and active cases of nonexempt customers residing in Cook County (regardless of Office of Choice), who receive their regular monthly benefit amount and are not meeting the Work Requirement in the month of January. A regular benefit is the monthly SNAP allotment that is calculated in the eligibility determination for the household to receive each month. A SNAP application prorated benefit month does not count towards the 3 months.
• A nonexempt customer who receives 3 regular months of SNAP benefits (January, February, March) and is not meeting the Work Requirement in each of those months, loses their eligibility for SNAP effective for April 2020. 
• Only the individual who is not meeting the Work Requirement is ineligible for benefits. When the SNAP EDG has only one member, IES cancels SNAP effective for the 4th month when 3 months of SNAP benefits are received and the Work Requirement was not met. When a SNAP EDG includes more than one person, IES disqualifies the ineligible person for SNAP. Form 360c, Notice of Decision is generated to the household with the appropriate reason.
• If eligibility is lost after receiving 3 months of SNAP benefits, a customer must regain eligibility by meeting the Work Requirement in a 30 consecutive day period prior to the date of application or request to be added back to an active case, whichever is applicable. To be approved for benefits a customer must show proof that they can maintain eligibility by meeting the Work Requirement for the required number of hours either through work, a work activity or a combination of both. There is no limit to the number of times a customer may regain eligibility.
• A customer who is able to regain and maintain eligibility for SNAP ongoing and later loses eligibility, qualifies for 3 additional months of SNAP. The 3 additional months are consecutive and available one time only in the 3 year fixed period. To qualify for SNAP again the customer must regain and maintain eligibility. Otherwise, the customer remains ineligible for benefits until the new 3 year period begins, or they become exempt.  
• CN 19.13/19.13S, Notice of Federal SNAP Work Requirement Changes and SNAP Work Requirement Fact Sheet (Form 3674), was mailed to nonexempt SNAP customers living in Cook County around 12/13/19 to notify them about the change.
• IES centrally converted active SNAP households residing in Cook County with a member subject to the SNAP Work Requirement from Mid-Point Reporting status to Change Reporting status on 11/27/19. Form 3324, Change in Reporting Requirements was systematically generated and mailed to the customer informing them of their new reporting requirements.
• For new applicants and whenever an individual becomes nonexempt, the HSC must give SNAP Work Requirement Fact Sheet (Form 3674) to the customer and explain the SNAP Work Requirement policy. Explain the ways in which the customer can meet the Work Requirement. Give the customer SNAP Employment and Training Program brochure (DHS 4538). Inform the customer that volunteering for the SNAP Employment and Training Program (SNAP E&T) is an option for meeting the Work Requirement. 
• The SNAP Work Requirement policy is only in effect for nonexempt customers who live in DuPage County and Cook County and their Office of Choice that serves those customers.  All other Illinois counties are waived from implementing SNAP Work Requirement policy. However, an Office of Choice of a SNAP recipient who is a DuPage County or Cook County resident is responsible for determining and monitoring eligibility of a customer who must comply with the SNAP Work Requirement policy.

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1. SNAP Work Requirement
2. Customer Notification
3. Certification Periods and Reporting Status
4. Helping the Customer Meet the SNAP Work Requirement
5. FCRC to Establish a Resource and Referral List
6. Office of Choice
7. Who Must Meet the SNAP Work Requirement?
8. What is the SNAP Work Requirement?
9. How to Meet the SNAP Work Requirement
10. SNAP E&T Voluntary Program
11. Community Work/Workfare
12. Customer Self-Initiated Activity
13. SNAP Customers Working for the 2020 Census
14. Verification of Work Activity and Hours
15. Good Cause
16. Sanctions
17. Who is Exempt from the Work Requirement?
18. Eligibility Limits - Three Countable Months of SNAP Benefits
19. Starting the ABAWD Time-Limit Clock
20. Overriding the ABAWD Time - Limit Clock
21. Maintaining Eligibility
22. When Does Eligibility End?
23. Regaining Eligibility
24. Additional 3 Consecutive Months of SNAP
25. Medical Exemptions
26. Change in ABAWD Status
27. Case Transfers
28. Supportive Services
29. Case Comments
30. Form Revisions
31. Manual Revisions

SNAP Work Requirement 

• Effective January 1, 2020, SNAP Work Requirement will be implemented in Cook County. This means that SNAP recipients residing in Cook County who are able-bodied adults without dependents (ABAWDS) age of 18 to 49, and do not have a disability or other work exemption are now eligible for only 3 months of SNAP benefits in a 36 month period, if they do not comply with the special SNAP work rules. The SNAP Work Requirement applies to the county where the individual resides, regardless of Office of Choice.
• The current 36 month period is a fixed 3 year period that began January 1, 2018 and ends December 31, 2020. 
• The SNAP Work Requirement was first implemented in DuPage County in January 2018 and continues to be in effect for nonexempt SNAP recipients through December 31, 2020, regardless of Office of Choice.
• DuPage County is now a SNAP employment and training county due to having a SNAP to Success Provider. SNAP customers may volunteer to participate in SNAP E&T, including those individuals subject to the SNAP Work Requirement policy.

Exempt/Waived Areas

All other counties in the State, except for Cook County and DuPage County, are waived from implementing SNAP Work Requirement  policy. Customers who were once mandatory for SNAP employment and training participation, even though time-limited benefits were not in effect in their area, are no longer required to participate, but may volunteer for the program. SNAP E&T sanctions are no longer imposed on customers participating in SNAP E&T. All participants are considered volunteers.

Customer Notification

Active Cases

CN 19.13/CN 19.13S, Notice of Federal SNAP Work Requirement Changes and SNAP Work Requirement Fact Sheet (Form 3674), were mailed to active SNAP households living in Cook County around 12/13/19 to tell them about the change in work rules and to provide them with the opportunity to seek employment, voluntarily engage in a SNAP E&T activity or perform community work.

New Applicants

For new applicants, the HSC must give SNAP Work Requirement Fact Sheet (Form 3674) to the customer, explain the SNAP Work Requirement policy and how the requirement can be met. Inform an applicant that volunteering for the SNAP E&T Program is one way of meeting the Work Requirement. Provide the customer with SNAP Employment and Training Program brochure (DHS 4538).

Child Turning Age 18

IES centrally generates and mails Form 2293 to the SNAP household 60 days prior to the birth date of a 17 year old child who is turning 18 years old (and there is no other child in the SNAP household under the age of 18 that would exempt household). The notice tells the SNAP household that a member has been identified as a person who may now need to meet the Work Requirement. If the child's birth date is on the first day of the month, the ABAWD Time-Limit Clock will tick for the month. If the child's birth date is on the 2nd day of the month or later, the ABAWD Time-Limit Clock will tick for the following month (first full month that the child is age 18).

Certification Periods and Reporting Status

IES assigns a 12 month approval period to all SNAP approvals. SNAP households with a member subject to the SNAP Work Requirement policy are Change Reporters. If a nonexempt person is not meeting the Work Requirement after receiving 3 months of benefits, IES will systematically cancel SNAP for a one person SNAP household or disqualify the ineligible person when there is more than one member.

Active Cases

On 11/27/19, active SNAP households with a member meeting the ABAWD criteria were centrally converted from Mid-Point Reporting status to Change Reporting status. At the time of conversion, IES generated Change in Reporting Requirement (Form 3324) and mailed to the appropriate SNAP households notifying them of the change in their reporting requirements.

Initial Application/REDEs

The HSC should insure that IES is approving a SNAP household with a member subject to SNAP Work Requirement in Change Reporting status. At the interview, inform the customer of their reporting requirements. A SNAP household in Change Reporting status is required to report changes within 10 calendar days of the date they learn about the change. A Change Reporting household is not required to report their work activity monthly, unless there is a change in the work activity, even if they are subject to the Work Requirement policy.

Helping the Customer Meet the SNAP Work Requirement

• A nonexempt customer is not required to work or engage in an activity to receive their 3 months of SNAP benefits. However, it is important that the customer understands the requirements and the potential loss of SNAP eligibility if they do not comply. To prevent a month from counting as a month of not meeting the Work Requirement, the customer would need to work or do a work activity for the required number of hours in that month. A customer who is not meeting the Work Requirement by the third month is at risk of losing SNAP eligibility.
• At the interview or whenever an exempt customer becomes nonexempt, explain and discuss the Work Requirement policy to ensure that the customer understands the impact that it has on their eligibility and/or the eligibility of other members within their SNAP household who are must comply with the Work Requirement policy. Encourage a nonexempt customer to seek work (paid or unpaid), or engage in a work activity for the required number of hours monthly to prevent the loss of benefits. Issue the appropriate forms:
  • SNAP Work Registration Notice (Form 2646). When Form 2646 is issued to a nonexempt individual and the IES screens are completed accurately to reflect their work status, the customer is considered to be registered for work as required by the SNAP Program. The FCRC should not send a customer to Illinois Department of Employment and Security (IDES) to register for work. 
  • SNAP Work Requirement Fact Sheet (Form 3674).
  • Change in Reporting Requirements (Form 3324).
  • Any other applicable activity forms.

Document in Case Comments, the details of the discussion, including decisions made, any verifications requested or referrals made to outside entities.

FCRC to Establish a Resource and Referral List

In addition to keeping a list of contracted Providers in the county, each FCRC should create an updated Resource Directory and establish a referral list of public or not-for-profit agencies and organizations within their community that will help the customer engage in Community Work, or a Work Experience activity. The FCRC must seek other referral sources to ensure that a customer has every opportunity to meet the Work Requirements and maintain their SNAP eligibility.

Office of Choice

• The Office of Choice of a DuPage County or Cook County SNAP resident is responsible for enforcing the SNAP Work Requirement policy for a customer whose case is serviced outside of their county of residence. The Office of Choice is responsible for determining and monitoring the customer's eligibility for SNAP, ensuring that the customer is meeting the Work Requirement and that the ABAWD Time-Limit Clock is accurate. Assist the customer with any resources that are needed to help them meet the Work Requirement.
• While active for SNAP, the county of residence FCRC and the Office of Choice are to work together to provide any assistance that is reasonable to help a nonexempt customer maintain eligibility by obtaining at least a 20 hour per week job, or informing them of the opportunities available in the voluntary SNAP E&T Program, or referring the customer to other community organizations where they can perform a work activity for the required number of hours. If needed, an assessment of the individual should be completed to determine if there are any barriers that would prevent them from being employable. Based on the individual's specific needs, make a referral to the appropriate community partner.

Who Must Meet the SNAP Work Requirement? 

SNAP recipients residing in a nonwaived area of the State must meet the SNAP Work Requirement, if they are:

These individuals are referred to as able-bodied adults without dependents (ABAWDs). ABAWDs are a targeted age (18-49) group of people within the SNAP Work Provision population. An ABAWD is a work registrant and must comply with both the general Work Provision rules (PM 03-15-01) AND the SNAP Work Requirement policy when it is in effect in a nonwaived area.

Note: The nonwaived areas of the State subject to the SNAP Work Requirement policy are Cook County and DuPage County.

What is the SNAP Work Requirement?

The SNAP Work Requirement limits a nonexempt SNAP customer who is an able-bodied adult without dependents (ABAWDs) age 18 to 49, to only 3 months of SNAP benefits in a 36 month period, if certain work rules are not followed. The 36 month period is currently a 3 year fixed period in Illinois that began January 1, 2018 and ends December 31, 2020.  A nonexempt customer is not required to work or engage in a work activity to receive their 3 months of SNAP benefits. But once the 3-months of SNAP benefits are received the individual is no longer eligible for benefits, if they did not work or do a work activity to meet the Work Requirement monthly.  An application prorated month of SNAP benefits does not count towards the 3 months. If there is a month where the individual did not comply with the requirement without good cause then that month counts  towards the 3 months. When there is a total of 3 countable months (unmet), the individual is ineligible for benefits.  The 3 months do not have to be consecutive.

How to Meet the SNAP Work Requirement

A nonexempt SNAP customer can meet the Work Requirement by: 

ABAWD Definition of Working

For ABAWDs, working is defined as one of the following:

• Work in Exchange for Money
  • The HSC must determine if a customer who is employed or self-employed is working the required number of hours to be exempt from meeting the Work Requirement or is only meeting the requirement.
    • A customer who is employed or self-employed working 30 hours or more per week or earning weekly wages at least equal to the Federal minimum wage ($7.25 ) multiplied by 30 hours is exempt from the Work Requirement policy.
    • A customer that works an average of 20 hours per week (80 hours monthly) is meeting the Work Requirement by working the required number of hours. The customer must report when their hours fall below 20 hours per week.

• Work in Exchange for Goods or Services (in kind)

  • Receipt of income in kind meets the Work Requirement, if a person is actively engaged in work for 80 hours or more per month.
    • Example: Ms. G applies for SNAP in March. She does not have income. She states that she lives in a motel room and does not have any expenses. She cleans the motel rooms daily for the motel owner in exchange for her living there rent free. The motel owner provides a statement that Ms. G works 80 hours per month. Ms. G meets the Work Requirement by working 80 hours a month in exchange for the motel room.

• Unpaid Work

  • Volunteer work, such as community work for the required number of hours per month meets the Work Requirement.

SNAP E&T Voluntary Program

• Any SNAP recipient may volunteer to participate in the SNAP E&T Voluntary Program, except a SNAP recipient who receives TANF. It is no longer a requirement to hold a provider slot open for an ABAWD. Volunteering for the SNAP E&T program is an option for those customers who must comply with the Work Requirement policy. 

Community Work/Workfare

• The required number of hours to do community work or workfare is based on the household's SNAP benefit amount divided by the State minimum wage ($9.25), if services are through a SNAP E&T Provider. The work hours may be performed by one nonexempt member of the SNAP household or if more than one nonexempt member, an agreement can be made to share the work hours as long as the required number of hours are worked.
• Workfare placement must be through an SNAP E&T Provider. The customer cannot self-initiate Workfare placement.
• Use Form 3673, SNAP Work Requirement (SNAP E&T Counties) Community Work Verifications to verify community work hours. Use Form 4019, Participation in Community Work Program to verify workfare hours at a local government unit.
• Form 3673 and Form 4019 must be completed and signed by a representative of the organization. The customer is responsible for returning their completed form back to the FCRC. The HSC should select the appropriate work activity in IES.

Note: Form 3673 is currently under revision.  Until the revised versions of the forms are available, staff should use Form 3673 for customers who are assigned to a SNAP E&T Provider. The SNAP calculation for the benefit amount divided by the State minimum wage is on Form 3673 to determine participation hours. For customers who are not engaged with a SNAP E&T Provider, use Form 3675. Form 4019 is currently under revision. Staff will be notified when the forms are available.

Customer Self-Initiated Activity

• A customer may self initiate work at community-based organizations, churches, or other organizations for the required number of hours. Use Form 3675 to verify participation and hours.
• If the customer self-initiates placement doing community work outside of a SNAP E&T Provider, the required number of hours is an average of 20 hours per week (80 hours per month).
• A Provider or outside entity may do a reverse referral to the FCRC.
• Form 3675 must be completed and signed by a representative of the organization. The customer is responsible for returning their completed form back to the FCRC. The HSC should select the appropriate work activity in IES.

Note: Form 3675 is currently under revision.  Until the revised versions of the forms are available, staff should use Form 3673 for customers who are assigned to a SNAP E&T Provider. The SNAP calculation for the benefit amount divided by the State minimum wage is on Form 3673 to determine participation hours. For customers who are not engaged with a SNAP E&T Provider, use Form 3675. Staff will be notified when the forms are available.

SNAP Customers Working for the 2020 Census

• SNAP customers temporarily employed with the U.S. Census Bureau for the 2020 Census are exempt from the Work Requirement if working 30 hours or more per week or earning weekly wages at least equal to the Federal minimum wage ($7.25 ) multiplied by 30 hours.
• A SNAP customer that works an average of 20 hours per week (80 hours monthly) with the U.S. Census Bureau for the 2020 Census is meeting the Work Requirement. The customer must report when their income stops or the hours fall below 20 hours per week.
• The income received from the U.S. Census Bureau for the 2020 Census is exempt for SNAP but must be entered in IES correctly so that IDHS can gather this information to report to Food and Nutrition Service (FNS). See MR#20.02: 2020 Census Short Term Employment, dated 01/14/2020 for more information on the 2020 Census and how to enter the income into IES.

Verification of Work Activity and Hours

• A customer remains eligible to receive SNAP each month as long as he or she continues to work, or participates and complies with a SNAP E&T activity or community work for the required number of hours monthly.
• Verify the number of hours the customer is expected to work or participate in an activity at the time of initial application, REDE, or whenever an exempt customer becomes nonexempt. Once it is verified, do not require the customer to provide verifications monthly. Based on their Change Reporting status, a customer must report changes to the FCRC within 10 calendar days of the date they learn about the change (PM 18-04-00). This includes when they are no longer participating in an activity, or are no longer working, or when their work hours drop below 20 hours per week. The HSC must take action within 10 calendar days of a reported change (PM 18-04-05). A change in work status can also be reported by the Provider or community partner. However, it is the customer's primary responsibility to report changes. The HSC should determine if the reported change has an impact on the customer's eligibility for benefits and make the appropriate changes to the ABAWD Time-Limit Clock or the person's exemption status, if needed.

Good Cause

A customer who is meeting the Work Requirement by working an average of 20 hours per week but misses some work for good cause can still be considered as having met the Work Requirement, if it is temporary and the job is still retained. Good cause includes circumstances beyond the customer's control, such as an illness, a household emergency, or lack of transportation.

Sanctions

SNAP E&T Sanction

SNAP E&T sanctions are no longer imposed on participants in the SNAP E&T Program. All participants are considered volunteers in the program.  A nonexempt customer who volunteers to participate in SNAP E&T to meet the Work Requirement is subject to a countable (unmet) month, if they stop participation and they are not meeting the Work Requirement through another option.

Work Provision Sanction

A work sanction may still be imposed when a nonexempt SNAP customer is noncompliant with a Work Provision (PM 03-15-01)

Who is Exempt from the Work Requirement?

1. First, determine if the customer qualifies for an exemption under the Work Provisions PM 03-15-02. A customer who is determined exempt under the Work Provisions in PM 03-15-02 is also exempt from the SNAP Work Requirement policy.
2. If a customer does not meet an exemption under the Work Provisions, determine if the individual meets the additional Work Requirement exemptions:

  3.  The individual is exempt from the SNAP Work Requirement, if  one of the above criteria is met.

Note: Everyone who is age 18-49 is exempt if there is a child under age 18 in the SNAP household. A SNAP household is defined as a one household member or  several household members that purchase and prepare food together.

Example: The SNAP household consists of Mr. D, age 45, Mrs. D, age 35, and Ms. R, age 30 and her 3 children who are under age 18. Mr. D, Mrs. D, Ms. R and her 3 children all purchase and prepare food together. This is one SNAP household. Because Mr. D and Mrs. D are members of the same SNAP household with children under the age of 18, they are both exempt from the Work Requirement.

Eligibility Limits - Three Countable Months of SNAP Benefits

• A nonexempt customer's eligibility is limited to three months of SNAP benefits in a 36 month period, if he or she is not meeting the Work Requirement and does not qualify for an exemption. The 36 months is a fixed period that started January 1, 2018 and ends December 31, 2020.
• For Cook County, the Work Requirement policy is effective January 2020. A SNAP application prorated benefit month does not count toward the 3 months. The 3 countable months do not have to be consecutive. Once 3 countable (unmet) months have been received a nonexempt customer remains ineligible for the remainder of the 3 year period, unless he or she regains eligibility or becomes exempt.
• A month is counted as an unmet month when a nonexempt person receives a regular month of SNAP benefits and:
  • is not meeting the Work Requirement; and
  • does not meet an exemption from the Work Requirement; or
  • does not verify an exemption from the Work Requirement, if needed.

Starting the ABAWD Time-Limit Clock

• The SNAP Work Requirement applies to all initial applications, REDEs and active cases of customers residing in Cook County AND at their Office of Choice.

• The HSC must answer a question in IES, "Is there a SNAP unit member age 18-49 potentially subject to the SNAP work requirement?", correctly in the "Time Limited Section" of the "Non-Financial Question Summary" screen. IES will default to (No), if the question is not answered. This may result in the person not being properly identified as an non exempt ABAWD. The question should be answered (Yes) if the individual meets the ABAWD age criteria, even if the individual qualifies for an exemption. Once the question is answered (Yes), additional screens will display to allow the HSC to make an eligibility determination for an exemption. If an individual is exempt but later becomes nonexempt, the HSC must remember to change the previous response to the Gate Post question when removing the exemption and prior to certifying the case.

• January 2020 is the first countable month for the ABAWD Time - Limit Clock to tick as unmet for any nonexempt customers who reside in Cook County and are not meeting the Work Requirement. If a nonexempt person receives 3 regular months of SNAP for January, February and March and does not meet the Work Requirement during any of those months, eligibility for SNAP ends effective April 2020. The 3 months do not have to be consecutive.
• It is important that the HSC reviews the ABAWD Time-Limit Clock when changes are reported to ensure that it accurately reflects a met or unmet month for the customer. IES determines an ABAWD at the individual level. An individual who is a mandatory participant displays on the IES EDG Summary page. When eligibility runs the ABAWD Time - Limit Clock will count, unless the month is shown met.
• IES automatically sets the ABAWD Time-Limit Clock as unmet at the schedule cut off prior to the countable month, except for the application month. The HSC must do an override to prevent a month from counting toward the time-limit, if appropriate.

Example: Mr. Q s applies for SNAP on 03/20/2020 and the HSC processes the application on 04/01/2020. At the time of application Mr. Q is not meeting the Work Requirement. March is an application prorated month.

Eligibility Month	IES Actions	Action Date is Schedule cut off for the application month. For the month of application the ABAWD Time-Limited Clock will count the month met/unmet on the day the application is processed.
04/01/2020	ABAWD Month 1 (Unmet)	04/01/2020
05/01/2020	ABAWD Month 2 (Unmet)	04/15/2020
06/01/2020	ABAWD Month 3 (Unmet) and Mass Change Trigger Closure created	05/15/2020
07/01/2020	SNAP Closure	05/16/2020 (Processing effective July, schedule cut-off 06/15/2020

Overriding the ABAWD Time - Limit Clock

In order to set the ABAWD Time-Limit Clock functionality for implementation for Cook County effective January 2020, the Clock will be set to tick at schedule cut off in December 2019 for active SNAP cases that contain a customer identified as an ABAWD (age 18-49), who does not have an exemption, or is not engaged in a work activity, or not employed for the required number of hours (number of hours is a mandatory field in IES). January will default to unmet for these individuals. 

It may be necessary to do a manual override of the ABAWD Time-Limit Clock, if a customer responds to CN 19.13 and the FCRC learns that the customer qualifies for an exemption, or is working for the required number of hours but had not reported it. It may also be necessary to override the ABAWD Time-Limit Clock during the certification period due to changes in the customer's circumstances (meeting or not meeting the requirement or becoming exempt).

On the "Nonfinancial Time-Limited SNAP" screen, answer (Yes) to the question, "Is there a SNAP unit member (age 18-49) potentially subject to the SNAP work requirement?" By answering (Yes), additional screens will display. On the "SNAP Work Requirement - Details" screen, complete the SNAP Work Requirement Dates section. Save and continue to the "Time-Limited SNAP - Clock" screen, remove the date for the month that requires the override. Indicate the appropriate Override Reason. The Override Reason must be entered but will NOT be saved. The Override reason must be added to Case Comments. Save and continue. Run eligibility and certify.  

Maintaining Eligibility

In order to continue ongoing eligibility for SNAP a nonexempt customer must meet the Work Requirement monthly so that the 3 months are not counted as unmet months.

If an individual is exempt for the month, the month is not considered as a countable unmet month. It makes no difference when within the time frame that the three months of participation are used. The 3 countable months do not have to be consecutive.

When Does Eligibility End?

Only the individual(s) NOT meeting the Work Requirement is ineligible for benefits.

• For a single person SNAP only case, IES will cancel SNAP effective for the 4th month, if a customer has received 3 months of SNAP benefits and the Work Requirement was not met. IES will send Form 360c to inform a customer of the cancellation.
• When the SNAP household includes more than one person, only the person(s) who did not comply with the Work Requirement are ineligible for SNAP. IES will disqualify the person for SNAP.

Example 1: Ms. L applied for SNAP 01/20/2020. The HSC gives Ms. L the SNAP Work Requirement Fact Sheet (Form 3674) and explains the Work Requirement policy. Ms. L does not meet a Work Requirement exemption reason. She is not employed and does not want to do community work or be referred to other resources. Ms. L is eligible to receive SNAP for January, February, March, and April only. January is a prorated month. Ms. L's 3 countable months are February March and April. Her SNAP benefits are canceled effective May 2020 for not meeting the Work Requirement. Unless, Ms. L becomes exempt or regains eligibility by meeting the Work Requirement, she is ineligible for SNAP benefits until 01/01/2021.

Example 2: Mr. H has an active SNAP case and is certified through March 2020. He was sent CN19.13,  Mr. H is not exempt and is not meeting the SNAP Work Requirement. He received his 3 months of SNAP benefits January, February and March. Mr. H files a REDE application in March. His application is denied because he is not meeting the work requirement. He must regain eligibility by meeting the Work Requirement or become exempt before he is eligible to receive SNAP again in the 3 year period.

Example 3: Ms. K is certified through June 2020. Ms. K is not exempt. She is eligible for January, February, and March. She contacts the FCRC in March and states in February she did community work at her local church for 20 hours per week and provides proof. She did not do any work in January or March. Ms. K used 2 months of her time-limited benefits when she did not comply with the requirement. The HSC must manually override the month of February by correcting the ABAWD Time Limit Clock to show the Work Requirement met in February. If Ms. K does not comply in April she will use her 3rd month of eligibility and IES will cancel her case effective May 2020.

Regaining Eligibility

An individual who has lost SNAP eligibility by exhausting their 3 months of SNAP benefits may regain eligibility at any time.

A person may regain eligibility by fulfilling the Work Requirement during a 30 consecutive day period prior to the date of application by working or participating in a work activity for the required number of hours or by meeting a criterion for exemption or when their 36 month clock is reset in the next 3 year period.

To regain eligibility an individual must in a 30 consecutive day period prior to the date of application:

• work (paid or unpaid) an average of 20 hours per week (80 hours per month); or
• volunteer to take part and comply with one of the following SNAP E&T activities, if available: Basic Education, Vocational Training, Work Experience, Community Work, Earnfare for the required number of hours; or
• take part in an approved workfare program of a local governmental unit for the required number of hours; or
• do community work at agencies, churches, or other organizations in the community for the required number of hours; or
• any combination of the above for the required number of hours monthly. 

An individual remains eligible to receive SNAP in the following month as long as he or she continues to work the required number of hours, or participates and complies with community work, or a workfare program for the required number of hours.

Example: Mr. J received his 3 months of SNAP benefits (January, February and March). Mr. J did not meet the Work Requirement during those 3 months and lost SNAP eligibility effective April. Mr. J becomes employed on May 10th and must work a total of 80 hours within the next 30 days in order to regain eligibility for the next benefit month. He must be able to maintain eligibility to be approved for SNAP benefits.

Once an individual's case is canceled a new application must be filed to begin receiving SNAP again. If an application is received, determine if the individual has regained eligibility. The individual qualifies when the requirement has been met and the person is otherwise eligible for SNAP. A person who starts work or starts a work program can reapply for SNAP as soon as he or she has worked or participated 80 hours in a 30 day period and it is determined that the customer will continue to meet the requirement. The individual must show proof that during the month (30 consecutive day period), they have worked or participated in an activity for the required number of hours to regain eligibility and that they will continue to work or participate in the activity to maintain eligibility. Proof may be check stubs or the completion of an applicable activity form that indicates that the individual has completed the required hours.  

Example: Ms. B has received her 3 months of SNAP benefits January through March. She did not meet the Work Requirement for those months and her eligibility for SNAP ended effective April 2020.  Ms. B starts a job on June 1st and works 20 hours per week. Ms. B applies for SNAP on July 1 and provides pay stubs showing she has worked 80 hours for a 30 consecutive day period prior to the date of application and is still employed. Ms. B has regained eligibility and is maintaining eligibility by still being employed. She is eligible to be approved for SNAP ongoing.

• A new application is not required when a member of a SNAP unit is removed from the case for failing to meet the Work Requirement. The household must request that the member be added back to the case and he or she must meet all other eligibility requirements. Add the person to the case the month following the month that the change was reported.
• When a SNAP application is filed and the person has used all months of eligibility in the 3-year period they must verify that they have regained eligibility in a 30 consecutive day period prior to the date of application. In order to be eligible to receive SNAP the individual must be able to show proof that they can maintain eligibility before the application is approved. There is no limit on the number of times a person may regain eligibility.

At reapplication, an individual who has received 3 months of SNAP benefits and has not met one of the Work Requirements in a 30 consecutive day period prior to the date of application is ineligible for SNAP. The resources of the person are counted in their entirety for the remaining eligible SNAP household members. A pro-rated share of the ineligible person's income is budgeted.

Additional 3 Consecutive Months of SNAP

A person who regains and maintains eligibility but later stops meeting the Work Requirement is eligible for an additional 3 consecutive months of SNAP. The period begins on the date an individual first notifies the FCRC that they are no longer meeting the requirement. An application prorated month does not count as one of the 3 months. The additional 3 month period runs for 3 consecutive countable months regardless of whether or not the person receives benefits in all 3 months. The second 3 consecutive months is issued only one time in any 3 year period.

Example: Mr. J received his 3 months of SNAP benefits January through March. His case was canceled effective April 2020. Mr. J reapplies for SNAP June 1, 2020. He regained eligibility by working 80 hours in May and is still employed 25 hours per week. Mr. J is approved for SNAP effective June. On August 1, 2020, Mr. J reports that due to it being seasonal work his job ended on 07/31/2020. Mr. J's 3 consecutive months of SNAP are August, September, and October. FCRC staff must cancel Mr. J's case effective for November 2020. Notice of Decision (Form 360c) is centrally sent informing Mr. J that he longer meets the Work Requirement. Unless Mr. J regains eligibility again or becomes exempt, he is no longer eligible for benefits until January 2021. August is the first month that Mr. J did not meet the Work Requirement.

Medical Exemptions

Temporary Illness

The HSC exempts a person who has a temporary illness if there is medical evidence provided by the customer or other evidence that the illness or injury is serious enough to temporarily exempt the customer. When an illness or medical condition is obvious through observation, the HSC can make the determination to exempt the individual without requiring verifications. Evidence for temporarily exempting a customer includes, but is not limited to:

• observing a cast on a broken leg; or
• receipt of Workers' Compensation; or
• knowledge of a scheduled surgery or recuperation from surgery.

If a temporary exemption from the Work Requirement is allowed due to a medical condition, the HSC must set a task as a reminder to follow up with customer prior to date that the exemption is expected to end. The task should be set in advance to allow time for the HSC to request verifications from the customer and the customer time to return any verifications that are needed for an extension.

Note: Minor ailments and injuries such as colds or rashes are not normally serious enough to exempt a person.

Chronic Illness

The FCRC exempts a person who is mentally or physically unable to work due to a chronic illness if a medical provider or service provider finds that a physical or mental impairment, either by itself or in conjunction with age or other factors, prevents the customer from working, participating in SNAP E&T, or other countable activities. The receipt of disability benefits can also verify the exemption, regardless of the percentage of disability or level of payment, such as SSI, SSA, Railroad Retirement, AABD, or VA, or receipt of a government or a private temporary or permanent disability benefit.

Chronic Homelessness

A person who is homeless (PM 06-04-02) does not automatically qualify for an exemption from the SNAP Work Requirement policy. Individuals who have been homeless for an extended period of time and have a mental or physical condition that may have occurred as a result of experiencing chronic homelessness may qualify for an exemption, if this condition would hinder them in being employable. The HSC should determine if an individual may be struggling with a condition that was either caused or worsened by their homeless circumstances. These conditions may prevent an individual from being job ready, such as obvious mental or physical issues, substance abuse issues, or living in an unsuitable environment for an extended period of time that may lead to medically untreated personal health issues with hygiene, skin, foot or dental issues. The determination of chronic homelessness may be made by the HSC, a homeless shelter provider or other qualified individual.

Verify the Exemption

• If an individual's disability is not obvious to the HSC or the individual is not receiving a disability benefit, the HSC should request that the customer provide proof from a medical professional or service provider.
• Verification can be obtained via written statement or by using SNAP Work Requirement Request Medical/Service Provider Unfit to Work Determination (Form 2340). This is an optional form. Verification may be accepted from a physician, physician's assistant, nurse, nurse practitioner, designated representative of the physician's office, a licensed or certified psychologist, a social worker; a counselor or staff person at a drug and alcohol program, or a social worker or staff person at a homeless or domestic violence services provider or shelter; or any other medical personnel determined appropriate.
• Document the proof used to support the exemption in Case Comments.
• Establish an exemption review date based on the information obtained and the customer's condition. When a person with a temporary illness exemption becomes physically and/or mentally fit, change their work exemption status to nonexempt, unless another exemption reason applies.

Change in ABAWD Status

• A change from a nonexempt person who is not meeting the Work Requirement to a person who is exempt from the Work Requirement is effective the month the change is reported.
  • Example: Ms. T is active for SNAP and is required to meet the Work Requirement starting January 2020. Her 3 months are January, February and March. SNAP benefits will end April 2020 if she does not meet the Work Requirement in each of the 3 months. She reports on February 5, she is pregnant. Ms. T's ABAWD status changes to exempt effective February (month of report). The HSC updates Ms. T's ABAWD Time Limit Clock to show that only January is counted should be counted as a month that Ms. T did not meet the Work Requirement.
• The status of a person meeting the Work Requirement changes to not meeting the Work Requirement in the month in which the nonexempt person becomes noncompliant and is considered a countable unmet month.
• Document in detail the reason for the change in status in Case Comments.

Case Transfers

The SNAP Work Requirement policy applies to nonexempt customers whose place of residence is in Cook County or DuPage County, regardless of where their case is serviced.

Supportive Services

Supportive services may be provided to a customer in an approved SNAP E&T activity. A customer is eligible to receive supportive service payments in advance to enable them to take part in an activity.

Case Comments

An HSC is required to include case comments whenever action is taken on a case. IES Case Comments are a major factor in establishing the history or record of a customer's eligibility and accounts for actions taken on the case. Case comment history begins with the initial eligibility determination and continues throughout the "life" of the case. A detailed narrative helps anyone reviewing the case, such as Quality Control, Auditors or other FCRC staff to understand previous actions taken on a case and ensures correct case action outcomes. Key information for case comments include:

• Dates and reasons for contacts by, or on behalf of, the customer.
• Actions taken, decisions made, and information received that affects eligibility, benefit level.
• A clear explanation of all negative actions taken on the case.
• Referrals offered, requested or accepted by the customer.
• Significant observations that can help clarify a customer's circumstances that will assist other staff in delivering customer service.
• Confirmation that Rights and Responsibilities were explained to the customer.

More specifically for a customer who must meet the Work Requirement, Case Comments should include the customer's work status, documentation that the Work Provision and Work Requirement rules were explained to the customer and the exemption allowed, if appropriate, any reported changes and actions that affect the customer's countable (met or unmet) months, including the reason for an override. Documentation should be in sufficient detail to permit a reviewer to determine the reasoning and accuracy of any case action.

Form Revisions

All SNAP E&T and Work Requirement forms are being reviewed for any needed revisions. Staff will be notified when the forma become available,

Manual Revisions

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms reference:

CN 19.13/CN19.13S

Form 360C

Form 2293

Form 2340

Form 2646

Form 3324

Form 3673

Form 3674

Form 4019

DHS 4538