Adjusting SNAP Interview Requirements Due to COVID-19

04/08/2020

Policy Memo

Summary

• As authorized by Section 2302 of the Families First Coronavirus Response Act (P.L. 116-127), Food and Nutrition Services (FNS) is allowing an adjustment in requiring a SNAP household to be interviewed prior to the approval of benefits. This adjustment applies to all initial applications, including expedited, requiring an interview from March 01, 2020 through May 31, 2020.
• An interview is not required when an applicant qualifies for expedited service and their identity is verified along with any mandatory verifications needed to establish eligibility. A SNAP household whose identity cannot be verified, or mandatory verifications have not been provided does not qualify for the adjustment and must be processed under normal SNAP application processing procedures.
• For non-expedited SNAP households, an interview is not required at initial application provided that the applicant's identity is verified and all other mandatory verifications have been completed. Conduct an interview if identity and/or verifications have not been provided with the application.
• Whenever possible use electronic sources to verify identity.
• FNS has determined these adjustments to federal regulations on the interview process to be consistent with what is practicable under actual conditions in areas affected by the COVID-19 Public Health Emergency.
• FNS requires an evaluation and analysis of the estimated number of households affected by these adjustments to the interview process. 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. 

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As authorized by Section 2302 of the Families First Coronavirus Response Act (P.L. 116-127), FNS is allowing an adjustment to requiring a SNAP household to be interviewed prior to the approval of benefits. The adjustments are to the interview requirements for initial applications, including expedited, from March 01, 2020 through May 31, 2020

Expedited Service Interview

• This adjustment applies only to those applicants at initial application whose identity can be verified and mandatory verifications to establish eligibility have been provided.
• The HSC is not required to conduct an interview with applicants that qualify for expedited service when identity can be verified, and all verifications needed to establish eligibility have been provided. Process the application without requiring an interview.
  • For SNAP households that apply on or before the 15th of the month, assign a one-month certification period, or assign a normal certification period if all verifications are provided.
  • If the SNAP household applies after the 15th of the month, assign a two-month certification period, or assign a normal certification period if all verifications are provided.
• Make sure expedited SNAP benefits are available to eligible households no later than close of business on the 5th calendar day after the application date or the date it becomes known that the household qualifies for expedited services.
• A SNAP household whose identity cannot be verified and/or verifications to establish eligibility are not provided with the application does not qualify for the adjustment and must be processed under normal SNAP application processing procedures. Complete data collection and schedule an interview for the customer

Initial Applications

• This adjustment to the interview requirement is limited to SNAP households for which mandatory verifications have been provided and identity can be verified.
• An HSC is not required to interview a SNAP household at initial application provided that the:
  • applicant's identity has been verified; and  
  • all other mandatory verifications have been completed.
• Contact the household and conduct an interview, if any information on the application is questionable and cannot be verified. Send Verification Checklist (Form 267 VCL) to request any needed verification. 
• If the household cannot be reached by phone to conduct the interview, send the Appointment Notice (Form 267T) to schedule the appointment and request any needed verifications. Make every attempt to verify household circumstances through data matching.
• Upload verifications into IES and document in Case Comments.

Face-to-Face Interview

• If a customer 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 customer and FCRC staff during the COVID-19 pandemic.
• Send the customer an Appointment Notice (Form 267T) with the scheduled interview date and time. If the interview is missed, IES will generate the Notice of Missed Interview (Form 267L) the following day of when the requested interview is missed. The Notice of Missed Interview informs the client that they need to complete the interview by the 30th day following the date of application.
• IES generates Notice of Decision on SNAP Application - Missed Interview (Form 360R) to deny applicants who receive a Notice of Missed Interview and fail to complete the interview by the 30th day.

Evaluation

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. 

Case Comments

Case comments should include an adequate description of the household's circumstance and any adjustments or exceptions made to the eligibility determination and case processing due to COVID-19, including any customer and advocate complaints.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms referenced:

Form 267T

Form 267L

Form 360R