COVID-19 Suspension of Audio Recording for a Signature includes Redeterminations (REDEs)

Illinois Department of Human Services logo

03/03/2022

Policy Memo

Summary

  • The Illinois Department of Human Services (IDHS) is operating under a Food and Nutrition Services (FNS) waiver approval that allows an adjustment to the Supplemental Nutrition Assistance Program (SNAP) regulations which require an audio recording of a telephonic signature.
  • A previous policy publication indicated that the adjustment only applied to initial SNAP applications. See policy memorandum, COVID-19 Suspension of the Audio Recording for a Signature is Extended after November 2020 until Further Notice for SNAP Applications, dated 12/03/2020.
  • This memorandum is to inform the Family Community Resource Centers (FCRCs) and the Application for Benefits Eligibility (ABE) Customer Call Center of a policy clarification recently received from FNS about the waiver terms. FNS has clarified the IDHS waiver approval allows the suspension of the audio recording for a signature and the acceptance of verbal attestation for both initial and redetermination (REDE) SNAP applications that are submitted without a signature. An interview must be conducted for unsigned SNAP initial and REDE applications that are received over the phone or by paper application.
  • For both initial and REDE SNAP applications, an evaluation and analysis of the estimated number of households affected by this adjustment is required to be reported to FNS. In order to collect this data, FCRC staff are instructed to select "PRS" as the Type of Contact on the Case Comments - Detail screen. To ensure that the data collected is accurate, "PRS" should only be used for this COVID-19 exception.
  • If the application is received "unsigned" and the customer cannot be reached by phone to obtain verbal attestation, the application is "invalid" without a signature. Return the application with a note advising the customer to either contact the office to conduct an interview or sign the application and return it. If a signed paper application is returned, conduct an interview, if needed.
  • This adjustment process is to be followed for both initial and REDE SNAP applications until further notice.

The Illinois Department of Human Services (IDHS) is operating under a Food and Nutrition Services (FNS) waiver approval that allows an adjustment to the Supplemental Nutrition Assistance Program (SNAP) regulations which require an audio recording of a telephonic signature. The adjustment is approved under the Families First Coronavirus Response Act and is consistent with what is practicable under actual conditions in areas affected by the COVID-19 Public Health Emergency.

COVID-19 Telephonic Signature Process

  • Due to a recent clarification on the terms of the waiver, this memorandum is being issued to the Family Community Resource Centers (FCRCs) and the Application for Benefits Eligibility (ABE) Customer Call Center as a follow-up to the policy guidance that was previously published in COVID-19 Suspension of the Audio Recording for a Signature is Extended after November 2020 until Further Notice for SNAP Applications, dated 12/03/2020, which stated the adjustment to the telephonic signature was limited to SNAP households who submitted initial applications without signatures over the phone or by paper application.
  • The FNS waiver approval allows IDHS to suspend the audio recording for a signature and to accept verbal attestation for both initial and redetermination (REDE) SNAP applications that are submitted without a signature over the phone or by paper application.
  • An interview must be conducted for unsigned SNAP initial and REDE applications that are received over the phone or by paper application.
  • This adjustment allows customers to call the FCRC in the event that there are system issues with the ABE Call Center or Alton Call Center and a telephonic signature cannot be obtained.
  • In addition, community providers can take applications over the phone from applicants and then submit to the FCRC without having to first send to the applicant for signature.
  • This adjustment process is to be followed for both initial and REDE SNAP applications until further notice.

Evaluation

For initial and REDE SNAP applications, an evaluation and analysis of the estimated number of households affected by this adjustment is required to be reported to FNS. In order to collect this data, FCRC staff are instructed to select "PRS" as the Type of Contact on the Integrated Eligibility System (IES) Case Comments - Detail screen. To ensure that the data collected is accurate, "PRS" should only be used for this COVID-19 exception.

FCRC Required Action

If an initial or REDE application is received over the phone or a paper application is submitted without a signature:

  1. The Human Services Caseworker (HSC) must contact the customer to conduct a telephone interview. If the HSC is able to reach the customer by phone, document the customer's verbal attestation of COVID-19 on the application.
  2. When conducting the interview, select "PRS" as the Type of Contact on the Case Comments - Detail screen. This selection is necessary to collect the data needed to report to FNS.
  3. At the end of the interview, explain to the customer the reason for the verbal attestation. Explain the customer's rights and responsibilities. Summarize the information to which the customer assents and allow a verbal signature from the customer.
  4. Document the summary in IES Case Comments to demonstrate that the customer has signed the application. This establishes the date of application. Include:
    • the customer's name, date and time of application; and
    • a summary of the information to which the customer verbally assents; and
    • the customer's responses indicating agreement or disagreement; and
    • any relevant complaints from the customer or advocates.
  5. If the application is received "unsigned" and the customer cannot be reached by phone to obtain verbal attestation, the application is "invalid" without a signature. Return the application with a note advising the customer to either:
    • contact the office to conduct an interview; or
    • sign the application and return it. An interview will be scheduled when the signed paper application is returned, if needed.

Case Comments

For initial and REDE SNAP applications, document in IES Case Comments the interview date, time, reason for denial and any other relevant case information.

Other Application Requirements

FCRC staff must continue to comply with all other applicable interview and signature requirements. Paper applications with signatures and online applications with electronic signatures must still be accepted.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced: