MR #21.14: Clarifying Policy on When to Issue Expedited Benefits for 2nd Month

05/24/2021

Summary

• This manual release provides policy clarification received from Food and Nutrition Services(FNS) on when to determine if an applicant qualifies for expedited service for the 2nd month following the month of application and the processing timeframes.
• IES has been modified to evaluate expedited service appropriately for the 1st and 2nd month. System changes are effective 04/21/2021.

• The first month of the certification period is the first month that a SNAP household is determined eligible for the program when an initial application is filed (PM 13-02-05). When determining eligibility for an initial application and expedited service, consider eligibility factors for the month of application and the following month. A SNAP household can be considered eligible for the program even if the benefit amount is determined to be zero due to proration.
• A SNAP household is not entitled to expedited service unless it is eligible for benefits in the first month of its certification period. A SNAP household is considered eligible for benefits if the benefit amount is greater than zero.

1. When a SNAP household is determined eligible for the program, but not entitled to expedited service in the month of application, certify the household within 30 days from the date of initial application under regular SNAP processing rules. The application month is the first month of the certification period.
   • Example: Mr. B files a SNAP application on 03/24/2021 for his family as a Program Add through ABE. On the expedited screening, income is reported as $4,188 for the month of application. Housing costs is $500 plus the Air Conditioning/Heating Standard. His Job ended and last pay received on 03/21/2021. The application is processed on 04/13/2021 and assigned a certification period 03/01/2021 through 02/28/2022. The household is eligible for $21 in March, the first month of its certification period.
   • In the above example, the household is not entitled to expedited service in the initial month of certification due to the income but is eligible for benefits. The application is processed under regular SNAP processing rules. The second month is not evaluated for expedited service.
2. For a SNAP household that is ineligible for the program in the month of application, but is eligible and qualifies for expedited service for the following month, benefits must be made available no later than the 5th calendar day from the date the application is filed, or the 1st working day of the 2nd month, whichever is later. The following month is the first month of the approval period
   • Example 1: Mr. Z files a SNAP application on 03/27/2021 and includes a copy of his driver's license, pay stubs, and a rent receipt. He reported no income when answering the expedited screening questions in ABE. The case is routed to the expedited queue. While reviewing the application, the HSC learns that the Mr. Z was employed but his income ended on 03/26/2021. The HSC calls Mr. Z for an interview to discuss his job ending and financial management. During the interview, Mr. Z states that he lost his job and will be living off his savings until he is notified of his eligibility for unemployment benefits. When eligibility is run, it is determined that Mr. Z is ineligible in March for the SNAP program due to his income exceeding the gross income standard. Since Mr. Z is ineligible in the month of application, eligibility must be determined for the following month before a negative action can be taken to deny. IES evaluates April for expedited service and determines that benefits should be expedited. Benefits for April should be made available no later than the 5th calendar day from the date the application is filed or the 1st working day of the 2nd month, whichever is later. Mr. Z's certification period is 04/01/2021 through 03/31/2022. If Mr. Z could not be reached by phone, then the HSC would send Appointment Notice (Form 267T) to schedule an interview within the expedited timeframe. If the household reschedules the interview or calls for an interview in time to meet the expedited timeframe, the interview must be completed, identity verified, and benefits must be available to the household by the 5th calendar day or the 1st working day of the 2nd month, whichever is later.  If the interview is not completed by the household in time to meet the 5-day timeframe, the household loses its entitlement to expedited service and the application is processed within the normal 30 days of the date of application. If the household completes the interview and is found to be entitled to expedited service, the date of discovery is the date of the interview and benefits must be issued within 5 days.
   • Example 2: Ms. J lost her job and files a SNAP application on 03/26/2021. Ms. J was determined ineligible for March because her income for the month is over the gross income standard. Income of $313 is projected for April and is less than her housing costs. Since Ms. J is ineligible for March, eligibility must be determined for April before a negative action can be taken to deny. IES evaluates April for expedited service and determines that benefits should be expedited. Benefits for April should be made available no later than the 5th calendar day from the date the application is filed or the 1st working day of the 2nd month, whichever is later. The certification period is 04/01/2021 through 03/31/2022.
   • In the above examples, the 2nd month is evaluated for expedited service because the household is ineligible for the month of application but eligible for the following month. The following month is the first month of the certification period. This can occur when the household has income over the standard in the initial month of application, but the job has ended. Eligibility must be determined for the second month before a negative action to deny can be taken.
3. Expedited service for the 2nd month does not apply to SNAP households who are eligible for the month of application (but not entitled to benefits due to prorating the initial month's benefits to zero) and are eligible for the following month. The household must be certified within 30 days from the date of initial application under regular SNAP processing rules. The month of application is the first month of the certification period.
   • Example: Ms. L files a SNAP application on 03/31/2021. Ms. L is eligible for the program in the month of application however the benefit amount is prorated to zero based on the number of days left in the application month. Eligibility is determined for the second month but is not evaluated for expedited service because Ms. L is eligible in the application month but not entitled to benefits due to proration. The certification period is 03/01/2021 through 02/28/2022. The month of application is the first month of the certification period.

IES System

IES has been modified to correctly identify applications that potentially qualify for expedited service and to evaluate the second month when an application is determined ineligible for the month of application including applications received after the schedule cut-off.

Manual Revisions

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced: