MR #22.03: Change in Procedure for Budgeting the Earned Income of a Child Receiving SNAP

Illinois Department of Human Services logo

02/09/2022

Summary

  • This manual release implements a change in the budgeting procedures for a child who has earnings from employment or self-employment and is receiving Supplemental Nutrition Assistance Program (SNAP) benefits.
  • The earned income of a child is exempt for SNAP if:
    • age 17 or under; and
    • attending elementary or secondary school; and
    • is under the parental control of a SNAP household member.
  • All three requirements must be met to exempt the income.
  • Currently, the Integrated Eligibility System (IES) automatically includes a child's previously exempt earned income in the SNAP budget for the first full month that the exemption criteria are no longer met. The procedure to automatically budget previously existing earned income without knowing the household's current circumstances may not be an accurate eligibility determination of benefit amounts.
  • Due to a Food and Nutrition Service (FNS) Management Evaluation review of the automated process and guidance provided, the Eligibility Rules in IES have been modified to prevent the system from automatically budgeting a child's earned income that was previously entered and determined to be exempt. The child's earned income must be current to budget for SNAP. New system conditions/validation messages have been added to certain IES Data Collection Screens to ensure that the Circumstance Start/Change Date (CSCD) and the Reported On date are updated.
  • System changes are effective 12/01/2021.
  • At initial application, the Human Services Caseworker (HSC) should only request verification of the child's earnings if age: 
    • 18 in the month of application; or
    • 17 and will turn age 18 by the first regular roll month; or
    • 17 and does not meet the education and/or parental control requirements by the first regular roll month.
  • When the benefit request is for SNAP only, and the child will turn age 18 after the first regular roll month, do not request verification of earnings for the child. To prevent IES from pending for verifications for a SNAP only case, select "Other Acceptable"  as the source of verification. 
  • When the request is for SNAP and another program such as medical, the child's earned income may need to be verified. When the earned income is verified and entered in the system, IES excludes the income in the SNAP calculation when it does not meet the criteria to be budgeted. 
  • For active cases, earnings of a child should be reported and acted upon based on the household's reporting status as either Change Reporting or Mid-Point Reporting. Change Reporting and Mid-Point Reporting SNAP households are not required to report a change in a child's age, education or parental control status. However, based on reporting status, both household types have a requirement to report a change in income.
  • If the earned income is currently in the system, IES will continue to exclude the child's previously exempt earned income from the SNAP budget until it is updated with information that is within 30 days of the child losing exemption status or the next Change Reporting household's redetermination or a Mid-Point Reporting household's interim Mid-Point Report or redetermination (whichever occurs first), unless a change in the child's status is reported to the Family Community Resource Center (FCRC) during the certification period. If new income is added and the CSCD is within 30 days of the child's birthdate and the exemption criteria is no longer applicable, IES will automatically budget the income for SNAP.
  • For newly reported income, the HSC must review all income on the case to determine if any income has ended previously and to determine if previous exempt income exists for a child.  If the income has ended, the HSC should update with an end-date. If the income continues, send Form 267 VCL to verify the current income. Once the current income is verified, the CSCD and Reported On date must be updated in order to budget the income. A Change Reporting household is required to report a change in earned income by more than $125 during the certification period. Do not routinely contact a Change Reporting or Mid-Point Reporting household during the certification period for the sole purpose of checking the child's status and/or requesting income verification because child has turned age 18 and the household has not reported the change on their own.

This manual release implements a change in the budgeting procedures for a child who has earnings from employment or self-employment and is receiving Supplemental Nutrition Assistance Program (SNAP) benefits,

Earned Income of a Child

  • The earned income of a child is exempt if:
    • age 17 or under; and
    • attending elementary or secondary school; and
    • is under the parental control of a SNAP household member.
  • All three requirements must be met to exempt the child's income.

Current IES System Functionality

Currently, if a child's earned income is entered in the Integrated Eligibility System (IES) that meets the criteria to be exempt, it is excluded from the SNAP budget. IES will automatically begin budgeting the child's previously exempt earned income for SNAP the first full month that the child no longer meets the exemption criteria. This procedure may not accurately reflect the household's current circumstances as the income may have changed since it was last reported and verified, or the child may not be working, or is no longer in the home.

IES System Functionality Changes

Due to a FNS Management Evaluation review of the automated process and the guidance provided, the Eligibility Rules in IES have been modified to ensure that a child's previously exempt earned income is not automatically included in the SNAP budget when the child turns age 18 or when the other exemption requirements are no longer met. A child's earned income must be current to budget for SNAP. New validation messages have been added to certain IES Data Collection Screens to ensure that the Circumstance Start/Change Date (CSCD) and the Reported On date are updated.

Initial Application

Verification of the child's earned income at initial application should only be requested if age:

  • 18 in the month of application; or
  • 17 and will turn age 18 by the first regular roll month; or
  • 17 and does not meet the education and/or parental control requirements by the first regular roll month.

SNAP Only

  • When benefits are SNAP only and a child will turn age 18 after the first regular roll month, do not request verification of earnings for the child. If the customer provides or submits this information, the Human Service Caseworker (HSC) is to enter the information in IES and select "Other Acceptable" as the type of verification.
  • Do NOT enter earnings for a child and select "Client Statement" to generate a 267 VCL for verification of the child's earnings if the applicant does not provide or submit at the time of the interview. The earnings are not needed if the child is not age 18 at the time of application and will not turn age 18 by the first regular roll month.

SNAP With Other Benefits

  • When the request is for SNAP and another program, such as medical, and the child will turn age 18 after the first regular roll month, the earned income for the child may need to be verified for the other program.
  • If the income is not provided or submitted during the interview, the worker should generate a 267 VCL by selecting "Client Statement" as the type of income verification in IES to request the income for the child for the other program. If income is verified, enter the income in IES under the child's name, and make sure the education questions are answered correctly. IES will know to exclude the income of a child for SNAP, as it does not meet the criteria to be budgeted. Workers should check the SNAP income budgeting tab in IES to make sure the income is excluded for this child. 
  • If income is not provided for the other program, take the appropriate action based on program's policy. Approve SNAP, as income for the child who is turning age 18 after the first regular roll month is not required.

Case Comments

The HSC should complete a detailed case write-up for any action taken on the case.

Reporting Requirements

  • For active cases, earnings of a child should be reported and acted upon based on the household's reporting status as either Change Reporting or Mid-Point Reporting.
  • The HSC must explain the applicable reporting requirements to each Change Reporting and Mid-Point Reporting household at the time of application. SNAP households are not required to report a change in a child's age, education or parental control status. However, based on the reporting status, both household types have a requirement to report a change in income.
  • A Change Reporting SNAP household is required to report:
    • when the household's monthly earned income changes by more than $125 during the certification period; and
    • all income changes at the redetermination.
  • A Mid-Point Reporting SNAP household is required to report:
    • when the gross monthly income exceeds the Gross Monthly Income Standard for the SNAP household size during the certification period; and
    • at the time of completing the interim SNAP and TANF Mid-Point Report (Form 2890), a change in the source, or the income amount by $125 from the last monthly income used to calculate benefits for the household; and
    • all income changes at the redetermination.

Existing Exempt Income

  • If the earned income is currently in the system, IES will continue to exclude the child's previously exempt earned income from the SNAP budget until it is updated with information that is within 30 days of the child losing their exemption status or the next Change Reporting household's redetermination, or the Mid-Point Reporting household's interim Mid-Point Report or redetermination (whichever occurs first), except in the following condition:
    • A change in the child's status is reported to the FCRC during the certification period; and
    • New income has been added or existing income record is updated and the CSCD is within 30 days of whatever exemption was lost; then
    • IES will automatically budget the income for SNAP.

Newly Reported Income

For newly reported income, the HSC must review all income on the case to determine if any income has ended previously and to determine if previous exempt income exist for a child. If the income has ended, the HSC should update with an end-date. If the income continues, send Form 267 VCL to verify the current income. Once the current income is verified, the CSCD and Reported On date must be updated in order to budget the income. A Change Reporting household is required to report a change in earned income by more than $125 during the certification period. Do not routinely contact a Change Reporting or Mid-Point Reporting household during the certification period for the sole purpose of checking the child's status and/or requesting income verification because child has turned age 18 and the household has not reported the change on their own.

New System Conditions/Validation Messages

  • The system conditions below determine if a child's income will continue to be excluded or when it will begin to be included in the SNAP budget. When a change is reported, the HSC must update the appropriate Data Collection Screens and the CSCD and Reported On dates in order for the system to correctly apply the conditions to the eligibility determination,
    • CSCD of individual's earned income record is greater than or equal to the individual's 18th birthdate - 30 days.
    • CSCD of individual's earned income record is greater than or equal to the CSCD of the change to Parental Control - 30 days.
    • CSCD of individual's earned income record is greater than or equal to the CSCD of the change to Education Status - 30 days.
  •  An error message will display if the Data Collection Screens, CSCD and Reported On date are not correctly updated.

Data Collection - Relationships - Details

If a HSC updates the Relationship - Details screen to indicate that an individual is no longer exercising parental control over another individual in the SNAP household and selects 'Add' but does not update the CSCD and Reported On dates, the following validation message will display:

You have indicated that (individual) no longer acts as a parent toward (individual). Please update the CSCD and Reported On date of this relationship change.

Data Collection - Education - Details

When the HSC updates an individual's education status to 'Not Enrolled' or updates that the child no longer meets the SNAP education status, and selects 'Save+Continue' or 'Save+Previous', without updating the CSCD and Reported On dates, the following validation message will display:

You have indicated that (individual) is no longer enrolled in elementary, middle, or high school, or no longer meets attendance requirements. Please update the CSCD and Reported On date of this education change.

Data Collection - Self Employment - Pay Details 

When a HSC updates an individual's self-employment income record by adding a new pay record or modifying an existing pay record and selects 'Save+Continue' on the Pay Details screen but does not update the CSCD of the income record, the following validation message will display:

You have updated (individual) self-employment income record. Please update the CSCD and the Reported On dates of the income record before proceeding.

Data Collection - Employment - Pay Details

When the HSC updates an individual's employment income record by adding a new pay record or modifying an existing pay record, or by updating loss of employment to 'Y', and selects 'Save+Continue' on the Pay Details screen but does not update the CSCD and the Reported On dates of the income record, the following validation message will display: 

You have updated (individual) employment income record. Please update the CSCD and the Reported On date of the income record before proceeding.

PM 08-04-01-g
WAG 08-04-01-g

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms referenced:

Form 267 VCL

Form 2890