MR #21.03: SNAP Work Requirement - New 3 Year Period and Other Miscellaneous Policy Clarifications

Illinois Department of Human Services Logo

01/12/2021

Summary

  • This manual release updates the 3-year fixed period for the SNAP Work Requirement in the Cash, Medical and SNAP policy manual. The new 3-year fixed period begins January 1, 2021 and ends December 31, 2023. The entire State continues to be exempt from implementing the SNAP Work Requirement Time-Limited Benefits policy due to Illinois' high unemployment rate. Waiver approval was granted by Food and Nutrition Services (FNS) from 07/01/2020 through 06/30/2021.
  • To comply with two Food and Nutrition Service (FNS) Management Evaluation (ME) findings this manual release: 
    • adds policy on how a self-employed individual who is under-employed is determined to be meeting the SNAP Work Requirement, if the policy was in effect. 
    • clarifies policy on the use of SNAP Work Registration Notice (Form 2646) and stresses the importance for the Human Services Caseworker (HSC) to review the Eligibility Summary Screen to determine if accurate Work Provision (PM 03-15-02) exemptions have been given.

SNAP Work Requirement - New 3 Year Period

The entire State continues to be exempt from implementing the SNAP Work Requirement Time-Limited Benefits policy due to Illinois' high unemployment rate. Waiver approval was granted by Food and Nutrition Services (FNS) from 07/01/2020 through 06/30/2021. The SNAP Work Requirement limits an able-bodied adult age 18-49 years old to 3-months of SNAP benefits in a 36-month period. In Illinois, the 36-month period is a fixed 3-year period that begins 01/01/2021 through 12/31/2023. This manual release  updates the 3-year period in the Cash, Medical and SNAP policy manual. No Illinois county should be enforcing the SNAP Work Requirement Time-Limited Benefits policy. Staff will be notified if there is a change in this policy.

IES System Changes

IES system programming changes to update the Time Limited Clock with the new 3-year period and other related work requirement changes are currently being made. The Time-Limited Clock screen and any other appropriate work requirement screens will be updated systematically. Workers should not attempt to make changes to any of the work requirement screens. The entire State is currently exempt from the SNAP Work Requirement Time-Limited Benefits policy through 06/30/2021. The Family Community Resource Centers (FCRCs) will be notified prior to implementation of any policy changes and system related changes in a manual release.

Miscellaneous Policy Clarifications

As a result of two Food and Nutrition Services (FNS) Management Evaluation (ME) findings, this release provides policy clarification on the following:

When is a Person Employed or Self-employed Meeting the SNAP Work Requirement?

When the SNAP Work Requirement Time-Limited Benefits policy is in effect, it will be necessary to determine if an employed or self-employed individual is exempt from meeting the SNAP Work Requirement or is only meeting the requirement.

  • A person who is employed or self-employed 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 SNAP Work Requirement.
  • An individual who is employed or self-employed working an average of 20 hours per week (80 hours monthly) or earning at least the Federal minimum wage ($7.25) multiplied by 80 hours ($7.25 x 80) = $580 is meeting the Work Requirement by working the required number of hours. The individual must report when their hours fall below 20 hours per week.

Note: The entire State is exempt from the SNAP Work Requirement Time-Limited Benefits policy 07/01/2020 through 06/30/2021. Staff will be notified if there is a change in implementing this policy.

Give and Explain SNAP Work Registration Notice (Form 2646)

  • As a reminder to all Family Community Resource Centers (FCRCs), all SNAP recipients who are not exempt from Work Provisions (PM 03-15-01) must register for work. For SNAP eligibility purposes in Illinois, giving each member in the SNAP household who does not meet a Work Provision exemption in PM 03-15-02  SNAP Work Registration Notice (Form 2646), along with the HSC completing the IES screens to indicate that the individual is nonexempt from Work Provisions serves as registering the individual for work. The HSC should review the Eligibility Summary Screen to determine if accurate Work Provision exemptions have been given. Do not refer the individual to the Illinois Department of Employment Security (IDES) to register for work.
  • The HSC must complete Form 2646 at initial application or redetermination (REDE) for each nonexempt individual in the SNAP household and whenever an exempt individual becomes nonexempt. Enter the case information on Form 2646 including the name of the nonexempt individual.
    • Explain the reason why the form is being given to the person. As a condition of eligibility for SNAP benefits, each SNAP household member not exempt for one of the reasons in PM 03-15-02 must comply with the Work Provisions (formerly known as work registration) in PM 03-15-01.
    • Upload a copy of Form 2646 to the Electronic Case Record (ECR) and document in Case Comments which SNAP household member was given Form 2646 and the method of how it was given.
    • Complete the IES screens to indicate that the individual is nonexempt from Work Provisions. The HSC should review the Eligibility Summary Screen to determine if the appropriate exemption has been given.

 Manual Revisions

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Form Referenced:

Form 2646