Adjustment to SNAP Interview Requirement Waived for Initial Applications and Redeterminations until Further Notice

Illinois Department of Human Services logo

07/01/2021

Policy Memo

Summary

  • This policy memorandum informs the Family Community Resource Centers (FCRCs) that the adjustment to the Supplemental Nutrition Assistance Program (SNAP) interview requirement will continue to be waived for initial applications, including expedited and redeterminations (REDEs) filed in the month of June 2021 and subsequent months until further notice.  The FCRCs will be notified when this interview process is no longer in effect.
  • In an effort to help States cope with the effects of COVID-19 and its impact on the SNAP application process, Food and Nutrition Services (FNS) is allowing the Illinois Department of Human Services (IDHS) to continue to adjust the SNAP interview requirement for initial applications and REDEs prior to the issuance of SNAP benefits so long as identity is verified and all other mandatory verifications are provided with the application to determine eligibility.
  • A SNAP household whose identity cannot be verified and/or mandatory verifications to establish eligibility are not provided with the initial application or REDE does not qualify for the adjustment and must have an interview.  This includes when there is questionable information.  Follow regular SNAP application processing procedures.  Complete data collection and schedule an interview for the customer.

COVID - 19 Waiver Approval Overview

Previous Food and Nutrition Services' (FNS) waiver approvals, authorized under Section 2302 of the Families First Coronavirus Response Act (P.L. 116-127), allowed the Illinois Department of Human Services (IDHS) to adjust the interview requirement only for initial applications, including those that met the expedited criteria from March 2020 through August 2020 as well as October 2020 through March 2021.  IDHS did not have FNS' approval to waive the interview requirement for applications filed in September 2020.  See Policy Memo, SNAP Interview Required for all Initial Applications filed in September 2020, dated 09/03/2020.  

Effective with SNAP applications filed April 2021 through June 2021, IDHS was granted approval to continue to waive the interview adjustment for initial applications and allowed to waive the requirement for redeterminations (REDEs).  An applicant who files a REDE prior to April 1, 2021 must still have an interview and must provide all verifications needed to determine eligibility prior to benefits being issued.  Adjustment to the SNAP Interview Requirement Waived for Applications filed in January 2021, February 2021 and March 2021, dated 01/19/2021, provided for an adjustment to the interview for initial applications only prior to April 1, 2021.

Adjustment to SNAP Interview Requirement Continues

This policy memorandum informs the Family Community Resource Centers (FCRCs) to continue to waive the interview requirement for initial applications, including expedited and REDEs filed in the month of June 2021 and after until further notice.

  • Do not require an interview for initial applications, including expedited or REDEs when:
    • identity is verified; and
    • all other mandatory verifications needed to determine eligibility are provided with the initial application or REDE.
  • Conduct an interview when identity cannot be verified and/or:
    • mandatory verifications have not been provided to establish eligibility; or
    • the information is questionable.

Face-to-Face Interview

  • If a customer requests a face-to-face interview, the FCRC should explain that in lieu of a face-to-face, the interview will be conducted by telephone.  This is necessary to protect the health and safety of the customer and FCRC staff during the COVID-19 pandemic.
  • Send the customer an Appointment Notice (Form 267T) with the scheduled interview date and time. If the interview is missed, IES will generate the Notice of Missed Interview (Form 267L) the following day after the requested interview is missed. The Notice of Missed Interview informs the client that they need to complete the interview by the 30th day following the date of application.
  • IES generates Notice of Decision on SNAP Application Missed Interview (Form 360R) to deny applicants who receive a Notice of Missed Interview and fail to complete the interview by the 30th day.
  • For initial applications denied on the 30th day due to a missed interview, the applicant must file a new application (PM 17-04-03-d).
  • If the applicant completes the missed interview by the 30th day after the approval period ends, reopen the REDE application (PM 19-03-08).

Expedited Households

  • A SNAP household that qualifies for expedited service is not required to complete an interview prior to approval so long as identity and all mandatory verifications are provided with the application to establish eligibility. If all eligibility factors are verified to determine eligibility for SNAP, issue expedited benefits, run eligibility, and certify ongoing benefits.
  • When the applicant qualifies for expedited service, but
    • identity cannot be verified; and/or
    • mandatory verifications have not been provided to establish eligibility; or
    • the information is questionable:
  • First, attempt to call the client to conduct an interview and obtain verifications. If the client cannot be reached by phone, send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications as needed to establish eligibility.
  • If the interview is held and identity can be verified but other verifications are postponed, issue benefits within the expedited timeframes.  Issue 1 or 2 months of benefits based on when the application is filed (before or on the 15th of the month or after the 15th of the month).
  • Whenever possible, use electronic sources such as SOLQ to establish identity.

Non-expedited Households

  • For non-expedited households, an interview is not required so long as identity is verified, and all other mandatory verifications have been provided with the application to determine eligibility. If all eligibility factors are verified to determine ongoing eligibility for SNAP, approve benefits. Run eligibility and certify ongoing benefits.
  • Conduct an interview when:
    • identity cannot be verified; and/or
    • mandatory verifications have not been provided to establish eligibility; or
    • the information is questionable.
  • Send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.

What are Mandatory Verifications?

Any verifications needed to establish eligibility for the case such as residence, income (including self-employment), or citizenship.  See PM 02-07-03-l, PM 02-07-04, PM 02-08-03, PM 02-08-03-a, PM 02-08-03-b, PM 02-08-03-c, PM 19-03-04.

There may be instances where verification is provided with the application, but an interview is still necessary to discuss unclear information or financial management with the applicant.  The following are some scenarios of when an interview would be necessary.

Example 1: On 04/01/21, Ms. T filed an initial SNAP application via ABE, requesting benefits for herself, her spouse and two children. On the application, Ms. T indicated earned income of $800 for herself and unemployment benefits of $300 weekly for her spouse. She answered that her children were Lawful Permanent Residents (LPR) and did not indicate the status for herself or her spouse.  She only provided a social security number for herself.  The application was submitted without verification of income, citizenship, and social security numbers.  Since only the application was submitted, the HSC must conduct an interview and request any verifications needed to determine the household's eligibility for SNAP.  Once the interview is held, the HSC may use available electronic sources to help with verifying the household's eligibility.  The HSC documents the details of the interview in Case Comments.

Example 2: Mr. B completed and mailed Request for Cash Assistance - Medical Assistance - Supplemental Nutrition Assistance Program (Form 2378B) to the FCRC.  The application was registered as a SNAP request on 04/01/21.  The HSC reviews the application and determines that Mr. B provided his address, signed, and dated the application and answered all the questions related to SNAP. Mr. B lives alone.  He provided his date of birth, social security number and is a U.S. Citizen. He does not have income.  He only has $200 in liquid assets. His monthly mortgage payment is $1,500 and he pays for all utilities (heat, electric, water, trash) which is currently around $800 total. A copy of his driver's license was submitted with the application.  Mr. B appears to qualify for expedited service. However, since Mr. B does not have income there is unclear information about Mr. B's ability to pay his mortgage and utility expenses.  His available resource is less than his expenses. The HSC must conduct an interview so that Mr. B can provide an explanation to the unclear information and financial management.  During the interview Mr. B states that he lost his job in November 2020. He does not qualify for unemployment benefits.  He has been living off the money in his bank account and only has $200 remaining.  He states he is 2 months behind in his mortgage payments and utility bills. Mr. B has provided an explanation to the unclear information and to financial management (PM 02-08-03-c). No additional verification is needed.  Mr. B provided his driver's license with the application which verifies his identity.  The HSC may proceed to process Mr. B's application as expedited. He is allowed the $1,500 monthly mortgage payment and the Air Conditioning/Heating Standard. The HSC documents the details of the interview in Case Comments.

Note: Mr. B only has to be billed for the mortgage and utility expense. He does not need to be paying the expense for it to be allowed as a deduction for SNAP.

Example 3: Ms. S filed an initial request for SNAP benefits for herself and three children through the ABE portal on 04/01/21.  The names, date of birth, social security numbers and citizenship status was provided for everyone applying for benefits.  Ms. S listed monthly earned income of $2,900 for herself and liquid assets of $4,000.  Ms. S indicated on the application that her job ended March 25, 2021 due to a job quit.  She does not indicate why she quit the job. Her rent is $800 monthly and she is billed for electric and water.  She submitted a copy of her driver's license and the paystubs received in March. Although it appears that Ms. S may have provided all the information to process her application, it is unclear as to why Ms. S quit her job.  The HSC must conduct an interview first, so that Ms. S can provide an explanation to the unclear information about the job quit and the electric utility expense.  During the interview, Ms. S states her employer reduced her hours to less than 20 hours per week due to COVID-19. She also states that she paid her rent, water and electric (which includes heat and air-conditioning) with her income from work. Ms. S has explained the unclear information. No other verification is needed.  The HSC determines that Ms. S has good cause for quitting the job per PM 03-15-03.  She also qualifies for the Air-Conditioning/Heating Standard. The HSC documents the details discussed in the interview in Case Comments, runs eligibility, and certifies the case.

Rights and Responsibilities and Copies of the Application

Each FCRC has established a procedure to retrieve mail, print documents, and send other information from the FCRC.  Copies of the Rights and Responsibilities and a copy of the application (if a copy is requested) should be mailed to the customer.

For FCRCs that remain closed, these documents can be printed in the FCRC and the designated person will pick up the documents from the FCRC for mailing.

Case Comments

The HSC must complete a Case Comment entry. Case Comments should include an adequate description of the household's circumstances and any adjustments or exceptions made to the eligibility determination and case processing due to COVID-19, including any customer and advocate complaints.  Case Comments should also include that the rights and responsibilities and a copy of the application (if requested) were mailed to the customer.

Evaluation

An evaluation and analysis of the estimated SNAP households that have been impacted by these adjustments is required to be reported to FNS.  In order to collect this data, FCRC staff are instructed to select "Home Visit" as the Interview Mode on the Individual Interview/Applicant- Details screen.

Desk Aid - COVID-19 Adjustment to the SNAP Interview Process

  QUESTION   ANSWER
When is a SNAP interview NOT required for expedited service?

At initial application when an applicant qualifies for expedited service PM 02-08-01 and:

  • identity is verified; and
  • all mandatory verifications, such as residence, income, including self-employment income, citizenship have been provided with the application to determine eligibility.

If all eligibility factors are verified to determine eligibility for SNAP, issue expedited benefits, run eligibility and certify ongoing benefits.
When should the applicant who qualifies for expedited service be contacted for an interview?

When the applicant qualifies for expedited service but:

  • identity is not verified; and/or
  • other verifications have not been verified to determine eligibility; or the information is questionable.

Whenever possible use electronic sources, such as SOLQ. Attempt to call the applicant to conduct an interview and obtain verifications.

If unable to reach by phone, send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.

If the interview is held and identity can be verified, but other verifications are postponed, issue benefits within the expedited timeframes.

Issue benefits for:

  • 1 month, if the applicant applies on or before the 15th of the month; or
  • 2 months, if the applicant applies after the 15th of the month.

Do not delay issuing benefits just because all other verification has not been provided at the time of the interview.
VERIFICATIONS
What is meant by mandatory verifications other than identity? Any verifications needed to establish eligibility for the case such as residence, income, including self-employment, citizenship.
If a 267 VCL is needed for any verification, like income, residency, or questionable data should the worker (once this is discovered) stop data collection and try and reach the customer for an interview? Yes, if the applicant can't be reached by phone, an interview should be scheduled.
If an interview is required, and the applicant only returns verifications instead of complying with the interview requirement, is the application denied?
  • Yes, if the applicant is required to have an interview, then they must comply with the requirement.
  • The application is denied for missed interview on the 30th day.
NON-EXPEDITED
When is a SNAP interview NOT required for non-expedited households?

When the applicant's:

  • identity is verified; and
  • all other mandatory verifications, such as residence, income including self-employment, citizenship have been provided with the application to determine eligibility.

If all eligibility factors are verified to determine ongoing eligibility for SNAP, approve benefits. Run eligibility and certify ongoing benefits.
When should a non-expedited applicant be contacted for an interview?

Conduct an interview when:

  • identity cannot be verified; and/or
  • mandatory verifications have not been provided to determine eligibility; or
  • the information is questionable.

Send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility
What if the applicant who is required to have an interview only returns verifications and does not respond to the interview request?
  • If the applicant only returns verifications but does not respond to having the interview, the application is denied on the 30th day.
  • If the interview is held and the applicant qualifies for expedited services, begin expedited processing timeframes.
See PM 02-08-02-a, PM 02-08-02-b.
When an application is submitted and is later denied for missed interview, should it be reopened when or if discovered or questioned by the customer? No, if the application was denied on the 30th day and the applicant did not comply with the interview requirement, a new application is needed.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced:

Form 267L

Form 267T

Form 267 VCL

Form 360R