MR #20.17: Entire State Exempt from SNAP Time-Limits

Illinois Department of Human Services Logo

09/02/2020

Summary

This manual release provides policy that exempts the entire State from the SNAP Work Requirement Time-Limited Benefits policy. It includes some updated page references to change Community Work to Community Service and Community Workfare as appropriate to be consistent with the Voluntary SNAP Program.
H.R. 6201, Families First Coronavirus Response Act, Title III - Section 2301, temporarily suspends the work and training requirements for SNAP during the COVID-19 crisis. This temporary suspension began 04/01/2020 and continues to be in effect until the public health emergency declaration by the Secretary of Health and Human Services based on the outbreak of COVID-19 is lifted.
Although the temporary suspension is still in effect, the Illinois Department of Human Services (IDHS) applied for a waiver exemption due to a rise in Illinois' unemployment rate. Food and Nutrition Services (FNS) has approved this waiver request which allows Illinois to waive the time-limit in DuPage County and Cook County and the 90 other counties that would have been impacted once the suspension was lifted. As a result of the waiver the entire State is exempt from the SNAP Work Requirement Time-limited benefits policy.
FNS approval is effective for one year (July 1, 2020 - June 30, 2021), or until the date at which the new waiver standards become effective under FNS' final rule, whichever occurs earlier. Staff will be notified if there is a change in this waiver approval.
CN 20.21/CN 20.21S (pdf), SNAP Work Requirement Time Limited Benefits Ends in Cook County and DuPage County, will be mailed to SNAP recipients subject to time-limited benefits no later than September 04, 2020. These households have been centrally changed from Change Reporting status to Mid-Point Reporting status. Redetermination Fact Sheet (Form 4769) is centrally generated with the conversion to inform the household of their new reporting requirements.

Temporary Suspension of the SNAP Work Requirement

The SNAP Work Requirement Time-Limited benefits policy began in DuPage County January 01, 2018 and expanded to Cook County effective January 1, 2020.
H.R. 6201, Families First Coronavirus Response Act, Title III - Section 2301, temporarily suspends the work and training requirements for SNAP during the COVID-19 pandemic. This temporary suspension began 04/01/2020 and continues to be in effect until the public health emergency declaration by the Secretary of Health and Human Services based on the outbreak of COVID-19 is lifted.
In addition to the suspension of the work and training requirements by the Federal government, Illinois issued policy to permit SNAP recipients subject to time-limited benefits in DuPage County the ability to claim Good Cause for the month of March 2020, if they were unable to comply with the SNAP Work Requirement due to the COVID-19 crisis. DuPage County recipients who had already received 3 months of time-limited benefits and were not currently active for SNAP due to not regaining eligibility were allowed to file a new application for benefits effective 04/01/2020, under the exception granted by Food Nutrition Services (FNS) due to the COVID-19 crisis.
For Cook County, a 12 percent exemption was applied to the month of March for nonexempt customers living in Cook County who would have lost eligibility for April due to not meeting the Work Requirement.

COVID-19 Impacts the Unemployment Rate in Illinois

Many Illinois residents are no longer employed or are underemployed causing a spike in Illinois' unemployment rate as the COVID-19 pandemic continues to impact local areas across the State.
While temporary suspension continues to be in effect, Illinois requested waiver approval from Food and Nutrition Services (FNS) to exempt the Cook County, DuPage County and 90 other additional counties that would have been impacted if the time-limit was enforced when the suspension is lifted. Due to Illinois' high unemployment rate approval of the waiver allows nonexempt customers in the entire State to be exempt from the SNAP Work Requirement Time-Limited Benefits policy. FNS has approved the waiver request effective 07/01/2020 through 06/30/2021.

SNAP Work Provisions

SNAP customers who are required to meet the Work Provisions may still claim Good Cause and should not be sanctioned in instances where the employer may have closed their business or reduced the work hours of employees in order to comply with certain health and safety guidelines enforced in Illinois due to COVID-19.

Client Notice

CN 20.21, SNAP Work Requirement Time Limited Benefits Ends in Cook County and DuPage County, will only be mailed to SNAP households with a member who would be required to meet the work requirement, if not for COVID-19 restrictions. These households have been centrally changed from Change Reporting status to Mid-Point Reporting status. Redetermination Fact Sheet (Form 4769) is centrally generated with the conversion to inform the household of their new reporting requirements.