MR #21.21: Change in SNAP Eligibility for Residents of Certain Supportive Living Facilities

09/30/2021

Summary

• The policy and procedure change in this manual release is the result of a review conducted by Food and Nutrition Service (FNS) on Illinois' policy that allows individuals residing in certain Supportive Living Facilities (SLFs) to qualify for the Supplemental Nutrition Assistance Program (SNAP). This policy change impacts individuals residing in SLFs that are not covered under the FNS waiver to participate in SNAP. These individuals are considered residents of an institution and do not qualify for SNAP.
• On December 19, 2019, FNS approved a limited waiver to protect the status quo of residents living in already approved SLFs in Illinois, which allows these residents not to be considered residents of an institution for SNAP eligibility purposes. The Illinois Department of Human Services (IDHS) was permitted to continue to certify these residents for SNAP as long as all other eligibility requirements were met. On December 31, 2020, FNS extended the waiver through December 31, 2021. 
• A resident in a SLF must still be allowed to complete the application process and have their eligibility determined based on program rules, even if living in a SLF not covered under the FNS waiver.  The Office of Long Term Care - Medical Field Offices (MFOs) handles SNAP applications filed by SLF residents. 
• Effective with initial applications received on or after the date of this manual release, and for all initial and REDE applications currently pending, the MFO must review the list in WAG 04-05-04 to determine if the applicant is residing in a SLF that is covered under the FNS waiver for SNAP participation.  An individual residing in a SLF that is included on the list in WAG 04-05-04 qualifies for SNAP if all other eligibility factors are met.
• Review the list at Redetermination (REDE).  A resident who is active for SNAP and is residing in a covered SLF on the list continues to qualify for benefits at REDE if all other eligibility factors are met.
• The applicant is not eligible for SNAP if residing in a SLF that is not covered under the FNS waiver. The MFO must deny the application. The denial reason: The applicant is considered a resident of an institution PM 04-05-04.  No additional SLFs have been approved for SNAP participation.
• A resident who is receiving SNAP in a SLF covered under the FNS waiver loses SNAP eligibility if they later move to a SLF that is not covered. 
• The MFO worker should not routinely search for SLF cases just for the purpose of finding residents who are active for SNAP but live in a SLF that is not covered under the waiver. The MFO worker should review the SLF list and the living arrangement when changes are reported during the certification period and at REDE.
• The policy in this manual release does not apply to residents of group homes, such as a Community Integrated Living Arrangement (CILA) PM 05-05-00.

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Residents of Supportive Living Facilities SNAP Eligibility Background

• This manual release is being issued as a result of a FNS review of Illinois' policy that allows individuals residing in certain SLFs to qualify for SNAP. 
• On December 19, 2019, FNS approved a limited waiver to protect the status quo of residents living in already approved SLFs in Illinois. The waiver allows these residents not to be considered residents of an institution for SNAP eligibility purposes. IDHS was permitted to continue to certify these residents for SNAP as long as all other eligibility requirements were met.  On December 31, 2020, FNS extended the waiver through December 31, 2021.
• Only the SLFs on the list in WAG 04-05-04 are covered under the FNS waiver for SNAP participation.  A manual release will be provided with any additional updates to this policy.

Office of Long-Term Care - Medical Field Offices

• MFOs (Anna, Central, Downstate, North & Granite City LTC-SPC) is responsible for the processing of SNAP applications filed by residents residing in Supportive Living Facilities.
• Anyone requesting to apply for SNAP benefits must still be allowed to complete the application process and have their eligibility determined based on program rules. Unless the applicant agrees to withdraw, an application received from a resident of a SLF not covered under the waiver should not be automatically denied. The application should go through regular application processing procedures for an eligibility determination and the appropriate approval or denial notice should be sent to the applicant and/or their representative.

Initial Applications

For initial SNAP applications received on or after the date of this manual release, and for initial SNAP applications already pending from residents of SLFs, the MFO must:

1. Review the list of SLFs in WAG 04-05-04  to determine if the applicant is residing in a SLF covered under the FNS waiver.
2. Process the application:
   1. If the applicant resides in a covered SLF in WAG 04-05-04, the applicant is eligible for SNAP if all other eligibility requirements are met; but
   2. The applicant does not qualify for SNAP if the SLF is not included on the list. Deny the application. Reason: The applicant is considered a resident of an institution PM 04-05-04.

Redeterminations

For Redeterminations (REDEs) including REDEs that are already pending as of the date of this manual release, the MFO must:

1. Review the list in WAG 04-05-04 to determine if the resident is living in a SLF covered under the FNS waiver. 
2. Process the REDE:
   1. An individual who is active for SNAP and is residing in a SLF covered under the FNS waiver at REDE continues to qualify for benefits if all other eligibility factors are met; but
   2. If the SLF is not included on the list, then the applicant does not qualify for SNAP.  Deny the application of any applicant residing in a SLF not included on the list. The reason: The applicant is considered a resident of an institution PM 04-05-04

Changes During the Certification Period

• A resident continues to qualify for SNAP so long as they are living in a SLF covered under the FNS waiver and all other eligibility factors are met.
• A resident who is receiving SNAP in a SLF covered under the FNS waiver loses SNAP eligibility if they later move to a SLF that is not covered on the list in WAG 04-05-04. The MFO worker should not routinely search for SLF cases just for the purpose of finding residents who are active for SNAP but live in a SLF that is not covered under the waiver.
• Review the SLF list and the living arrangement when changes are reported during the certification period and at REDE.
• If during the review, it is determined the individual resides in a SLF not covered under the waiver, canceled or deny the case, whichever is applicable. The reason: The applicant is considered a resident of an institution PM 04-05-04.

Manual Revisions

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services