09/04/2020
Summary
This manual release provides policy clarification from Food and Nutrition Service (FNS) on two frequently asked questions and is effective with the date of this release.
- Question 1: If a customer presents verifications such as a driver's license or paystubs via cell phone, can they be considered adequate verifications for the Supplemental Nutrition Assistance Program (SNAP) if the item(s) is identifiable to the customer?
- Answer 1: Documentary evidence should be the primary source of verification when possible. If the customer does not have the actual item, the Family Community Resource Center (FCRC) must accept any reasonable documentary evidence provided by the household that adequately proves the statements on the application.
- Question 2: Can the Family Community Resource Center (FCRC) deny and close a SNAP application based solely on the applicant's unverified statement of household income?
- Answer 2: A SNAP application cannot be denied and closed based solely on an unverified statement of household income.
To be consistent with SNAP, the policy in this manual release also applies to the Temporary Assistance for Needy Families (TANF) and to the Aid to the Aged, Blind or Disabled (AABD) Cash programs.
Introduction
- This manual release provides policy clarification from Food and Nutrition Service (FNS) on accepting verifications via cell phone and the requirement to verify income before denying a SNAP application due to the household's income being over the income standard.
- To be consistent with SNAP, the policy in this manual release also applies to the Temporary Assistance for Needy Families (TANF) and the Aid to Aged, Blind or Disabled (AABD) Cash programs.
Accepting Verifications via Cell Phone
- Recognizing the advancement of mobile technology, Food and Nutrition Service (FNS) has provided guidance on accepting verifications via cell phone. Documentary evidence should be the primary source of verification when possible. Documentary evidence is the actual item itself, such as a driver's license or paystubs.
- If the customer is claiming not to have the actual item, the Family Community Resource Center (FCRC) must accept any reasonable documentary evidence provided by the household that adequately proves the statements on the application.
- For example, due to the advancement in mobile technology many employers have made changes to their payroll process. Issuing electronic pay verification instead of giving the traditional pay stubs to employees can be a cost savings to the business as well as method for the employee, such as a homeless individual, to easily store and maintain important documents. 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.
- Verifications received via Cell Phone are acceptable for TANF and AABD Cash programs.
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 Human Service Caseworker (HSC) should not request that the customer email any documents to their own individual email address.
Document in Case Comments
The HSC must document in Case Comments if verifications are used via cell phones. 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.
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.
Example 3: Ms. K is applying for SNAP and TANF for herself and her child. During the interview Ms. K states she is employed part-time at C & C Hair Salon and is paid every weekly. When asked for her paystubs for the last 30 days, Ms. K explains that she is temporarily living with a friend and only keeps the personal items that are needed for herself and her child at the friend's home. 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. K'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. K 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.
Income Must be Verified Before Denying a SNAP and/or Cash Application for Income Over the Standard
- Food and Nutrition Service (FNS) provided clarification regarding the requirement to verify a SNAP household's non-exempt income prior to denying an application due the income being over the income standard for the household size. An HSC cannot deny a SNAP EDG based solely on the applicant's unverified statement of household income
- If a household states on the SNAP and/or Cash application or during the interview that its income exceeds the gross income limit, the HSC must still 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.
AABD and TANF Cash Programs
If a household states on the TANF or AABD Cash application or during the interview that its income exceeds the gross income limit, the HSC must still pursue verification of income and continue the application process with the household.
If the household fails to provide timely verification of income, the HSC can deny the TANF or AABD cash 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 benefits based on exceeding the gross income limit.
Documentation in ECR and Case Comments
The HSC 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 an 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. A denial on a case is not valid for excess income if the ECR and Case Comments does not support the denial through documentation/verification of the household's income.
Note: This manual release does not change budgeting policy for SNAP and/or Cash. All income must be verified and the amount and source documented in the ECR. Income from the last 30 days is still used to determine eligibility.
Manual Revisions
[signed copy on file]
Grace B. Hou
Secretary, Illinois Department of Human Services
Forms Referenced:
