Treatment of Payments Under the American Rescue Plan Act of 2021 for SNAP, Cash, and Medical

 

09/07/2021

Policy Memo

Summary

• The American Rescue Plan Act of 2021 (the Act) was signed into law on March 11, 2021. The Act amends certain provisions put in place by the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The amended provisions in the Act provide for an extension of unemployment assistance, additional recovery rebates (Stimulus payments), and changes to the Child Tax Credit for 2021. This policy memo provides guidance to staff on how to treat payments received due to the Act.
• The Pandemic Unemployment Assistance (PUA) payments, Pandemic Emergency Unemployment compensation (PEUC), and the $300 Federal Pandemic Unemployment Compensation (FPUC) payments will be extended through September 6, 2021.
• For determining SNAP, cash and medical eligibility, PUA and PEUC are considered non-exempt unearned income. FPUC is exempt as income and from consideration as resources in the month of receipt and the following 9 months. Receipt of FPUC may affect a noncategorical eligible household's eligibility after 9 months if the payments cause the household to exceed the resource limit. After 9 months, total resources would need to be verified before taking an action to cancel benefits for exceeding the resource limit.
• Section 9601 of the Act amends the Internal Revenue Code to authorize additional $1400 rebate (Stimulus) payments to eligible individuals, including children, similar to those authorized under the CARES Act. These rebates are exempt as income in the month of receipt and as a resource for 12 months following receipt for SNAP, cash and medical eligibility. Verification is not needed for these payments at the time of receipt, unless questionable.  Receipt of these payments may affect a noncategorical eligible SNAP household's eligibility and eligibility for non-MAGI medical after 12 months if the payments cause the household to exceed the resource limit. After 12 months, total resources would need to be verified before taking an action to cancel benefits for exceeding the resource limit.
• Section 9611(a) of the Act makes the Child Tax Credit fully refundable so that it is available in full to children in families with low or no earnings. This provision increases the maximum credit to $3,000 per child or $3,600 for children under the age of six and extends the credit to 17-year-olds. These changes only apply to calendar year 2021. Whether received as an annual credit or in the form of advance payments, consider as exempt income in the month of receipt and an exempt resource for 12 months following receipt for SNAP, cash, and medical eligibility. Verification is not needed for these payments at the time of receipt, unless questionable.  After 12 months, total resources should be verified before taking an action to cancel benefits for exceeding the resource limit

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American Rescue Plan Act of 2021

The American Rescue Plan Act of 2021 (the Act) signed into law on March 11, 2021 amends certain provisions put in place by the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The amended provisions in the Act provide for an extension of unemployment assistance, additional recovery rebates (Stimulus payments), and changes to the Child Tax Credit for 2021. This policy memo provides guidance to staff on how to treat payments received due to the Act.

Extension of Unemployment Benefits

The Pandemic Unemployment Assistance (PUA) payments, Pandemic Emergency Unemployment compensation (PEUC), and the $300 Federal Pandemic Unemployment Compensation (FPUC) payments will be extended through September 6, 2021. These payments should be treated for each program as follows:

• Pandemic Unemployment Assistance (PUA)

  • SNAP

  • Pandemic Unemployment Assistance (PUA) provides unemployment benefits to people who do not otherwise qualify for unemployment compensation and is provided for under Section 2102 of the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act; P.L. 116-136), as amended. PUA is budgeted as non-exempt unearned income when determining eligibility for SNAP.

  • Cash Programs

  • PUA is budgeted as non-exempt unearned income when determining eligibility for AABD cash and TANF programs.

  • Medical Programs

  • PUA is budgeted as non-exempt unearned income when determining eligibility for all Medical programs.

• Federal Pandemic Unemployment Compensation (FPUC)

  • SNAP

  • Federal Pandemic Unemployment Compensation (FPUC) provides an additional $300 weekly compensation on top of regular unemployment compensation provided by State law. This includes the initial payments of $600, the additional $300 payments, and the $100 Federal mixed earner unemployment compensation payments, all are  provided for by Section 2104 of the CARES Act, as amended. The Consolidated Appropriations Act of 2021 (P.L. 116-159) exempts FPUC from consideration as income and from consideration as a resource in the month of receipt and the following 9 months for the purposes of determining SNAP eligibility.  After 9 months, total resources would need to be verified before taking an action to cancel benefits for exceeding the resource limit.

  • Cash Programs

  • FPUC benefits should not be budgeted and are considered exempt unearned income AABD cash and TANF programs.

  • Medical Programs

  • FPUC is not budgeted and is considered exempt unearned income for all Medical programs.

• Pandemic Emergency Unemployment Compensation (PEUC)

  • SNAP

  • Pandemic Emergency Unemployment Compensation (PEUC) provides additional weeks of unemployment benefits to people who exhaust their regular unemployment compensation and is provided for under Section 2107(g) of the CARES Act, as amended. PEUC is budgeted as non-exempt unearned income when determining eligibility for SNAP.

  • Cash Programs

  • PEUC should be budgeted and is considered non-exempt unearned income AABD cash and TANF programs.

  • Medical Programs

    PEUC is budgeted and considered non-exempt unearned income for all Medical programs.

2021 Recovery Rebates (Stimulus) to Individuals

Note: For all programs verification is not needed for these payments at the time of receipt, unless questionable. After 12 months, total resources should be verified before taking an action to cancel benefits for exceeding the resource limit.

Child Tax Credit Improvements for 2021

Note: For all programs verification is not needed for these payments at the time of receipt, unless questionable. After 12 months, total resources should be verified before taking an action to cancel benefits for exceeding the resource limit.

SNAP Households Not Categorically Eligible

• Any part of the FPUC remaining after 9 months and/or the $1400 rebate (Stimulus) payments and child tax credits remaining after 12 months is considered an available resource for noncategorical eligible SNAP households. A noncategorical eligible SNAP household includes:

• Verification is not needed for these payments at the time of receipt, unless questionable. After 12 months, total resources should be verified before taking an action to cancel benefits for exceeding the resource limit

How to Enter in IES

• A separate income record for the FPUC, Recovery Rebates (Stimulus), and the Child Tax Credits must be added to ensure IES budgets correctly.
• On the Unearned Income Details screen, "Other Exempt" should be selected for the Unearned Income Type. On the Unearned Income Pay Details screen, "Other Acceptable" should be selected for the Pay Verification.
• Workers must also include a Case Comment to identify each payment individually and the amount, included with the following statement, "Other Exempt income due to the American Rescue Plan Act of 2021." This will ensure the unearned income is budgeted and documented properly for all programs.
• Additional information on the calculation of the FPUC unemployment benefits can be found in Policy Memo, Treatment of Payments Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) for Cash, Medical, and SNAP, dated 05/13/2020.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Theresa Eagleson

Director, Healthcare and Family Services

Forms referenced: