MR#25.04: New Interstate Duplicate SNAP Participation Clearinghouse – NAC

Illinois Department of Human Services Logo

01/09/2025

The Agriculture Improvement Act of 2018 (Farm Bill) required Food and Nutrition Services (FNS) to establish an interstate duplicate participation National Accuracy Clearinghouse (NAC) system to prevent multiple issuances of Supplemental Nutrition Assistance Program (SNAP) benefits to an individual by more than one state agency simultaneously. NAC only monitors for duplicate participation of SNAP benefits and no other programs.
Currently only Iowa, Louisiana, Missouri, Montana, and Utah, have implemented NAC but all states must comply by 2027. Kentucky will implement in January 2025. Pennsylvania, Alabama, Tennessee, and Arkansas are anticipated to implement later in the year 2025. A manual release, Heads Up, and IES alert will be provided to inform staff as other states join the NAC.
The Illinois Department of Human Services (IDHS) will implement effective 01/15/2025. The Integrated Eligibility System (IES) and the Application for Benefits Eligibility (ABE) have been modified with the functionality to perform a NAC match with the other states participating in the process.
Notice of SNAP Participation Match in Another State (IL444-0267 NAC) has been created to notify customers of the out of state match and to request verifications of the closure in the other state if applying or actively receiving in Illinois.

National Accuracy Clearinghouse (NAC) System
Implementation in Illinois
Nightly NAC Batch Upload
NAC Interface
NAC Clearance
Notice of SNAP Participation Match in Another State (IL444-0267 NAC)
Notice of Decision (IL444-0360)
Expedited Service
Case Comments
Establishment of Duplicate Assistance Claims
Integrated Eligibility System (IES) Changes
Application for Benefits Eligibility (ABE) Changes
Form Revisions
Manual Revisions

National Accuracy Clearinghouse (NAC) System

The Agriculture Improvement Act of 2018 (Farm Bill) required Food and Nutrition Service (FNS) to establish an interstate data system, known as the National Accuracy Clearinghouse (NAC) to prevent the issuance of duplicate Supplemental Nutrition Assistance Program (SNAP) benefits to the same individual simultaneously.
State agencies administering SNAP must provide information about participants to the NAC, conduct matches against the NAC to discover and prevent interstate duplicate participation, and take appropriate action when matches are found. NAC information can only be used for preventing duplicate participation in SNAP. The information cannot be used for other purposes or programs. The individual's name, Social Security Number, and residency is used for matching.
Currently only the states listed in the table below have implemented the NAC process. Kentucky is expected to implement in January 2025 with Pennsylvania, Alabama, Tennessee, and Arkansas implementing later in the year. All states are expected to comply by the year 2027. A manual release, Heads Up, and IES alert will be provided to inform staff as additional states join the NAC.

States	Implementation Date
Iowa	02/05/24
Illinois	01/15/25
Kentucky	01/27/25
Louisiana	04/29/24
Missouri	03/18/24
Montana	02/05/24
Utah	05/20/24

Implementation in Illinois

NAC is a system automated process in Illinois that will be implemented effective 01/15/2025. The Integrated Eligibility System (IES) and the Application for Benefits Eligibility (ABE) have been modified with the functionality to perform a NAC match with the other states that have implemented the process.
Workers will be provided with the training to understand the details of the match so that they may be able to discuss the findings with the customer and take the appropriate action.
Since a NAC match can only be made with those states that are participating in the NAC process, workers must continue to contact states that have not yet joined the NAC process, if necessary, to assist customers applying for benefits in Illinois and need help in verifying benefit closures in another state.

Nightly NAC Batch Upload

IES checks nightly to see who is receiving SNAP benefits in Illinois for the current calendar month and uploads that information to the NAC database to ensure that other states do not issue benefits to the same individual.
When another state initiates the query and has a match with an individual receiving SNAP in Illinois, Notice of SNAP Participation Match in Another State (IL444-0267 NAC) is systematically generated by IES and mailed to the SNAP household's Illinois address or if not systematically sent, a task is generated for a worker to go through the driver flow and send the NAC notice.

Note: NAC will prevent a PARIS match because it looks for duplicate assistance prior to it occurring. PARIS looks at duplicate assistance after it has occurred. Workers will need to continue a work a PARIS match for states that are not in the NAC.

NAC Interface

IES retrieves nightly any newly created matches from the NAC website and updates IES systematically.

NAC Clearance

A NAC clearance can only be triggered if the SSN, identity, and residency of the individual has been verified. The NAC will run when a request for SNAP benefits is made in Illinois at application, REDE, or when a member is being added to the SNAP EDG. When Illinois initiates the query, NAC is systematically triggered on one of the following pages when the worker goes through the driver flow:
- Program Request Summary; or
- Individual Demographics Summary; or
- Eligibility Summary; or
- Redetermination Review Summary.
Which page NAC will trigger on depends on the case, but it will be triggered before the SNAP EDG can be certified. Workers can also manually trigger the clearance on the Clearance Results page and the Out of State Benefits - Details page.
With the exception of expedited benefits, NAC will only be triggered if the SSN, identity and residency have been verified. The Out of State Benefits page will appear in the driver flow with information automatically populated. IL444-0267 NAC is systematically sent to the SNAP household for proof that the Out of State Benefits have been closed.

Notice of SNAP Participation Match in Another State (IL444-0267 NAC)

Two versions of IL444-0267 NAC have been created with a special indicator to use specifically for the NAC process.
- For new applicants, the notice is generated when Illinois initiates a query with the other states at the SNAP application, REDE, and when a member is being added to the SNAP EDG.
- For individuals who are active on a SNAP EDG in Illinois, a notice is generated during the certification period when another NAC state has initiated a query and finds a match with the same individual. This version also serves as the notice of adverse action.
Similar to a verification checklist, the IL444-0267 NAC explains to the SNAP household that information was received from the NAC data match, the name of the matched individual, what is needed to resolve the NAC match, acceptable verifications, due date, and instructions on how to return the information.
One task is created if both a regular IL444-0267 VCL and a IL444-0267 NAC notice are received together. When eligibility is run on a case, the verification checklist record is created in IES when the Out of State Benefits - Details page has SNAP and the verification that is selected is 'National Accuracy Clearinghouse (NAC) - Match'. The notice is triggered by the worker confirming the verification checklist information on the Verification Checklist - Summary page after the Eligibility Summary and before Certification.
Both versions of IL444-0267 NAC allow the SNAP household 10 calendar days to respond to the notice. No adverse action to deny, cancel or reduce SNAP benefits based on information received from the NAC alone can be taken until the information has been verified and the individual has been provided notice of the match and an opportunity to respond to the notice.
When a positive match from a NAC query is received at application, REDE, or when adding a member, action must be initiated by the FCRC to resolve the match and notify the other state of the initiated action within 10 calendar days from the date the match is received. The FCRC must resolve the match to determine the appropriate actions to take on the case. To resolve the match the FCRC must verify if the matched individual is eligible to receive benefits in Illinois.
If at the application, REDE, or when a member is being added, the SNAP household fails to respond to the NAC notice and the match could not be resolved:
- Deny the application, if a one member SNAP household; or
- If there are multiple members in the SNAP household and the matched individual is not the head of household, determine eligibility for those members who are not part of the NAC match and have met all other eligibility requirements; or
- If the NAC match is on the head of household, deny the entire case. A new application may be filed by the other members.
If during the certification period, the household fails to respond to the NAC notice, only the matched individual, unless it is the head of household, is ineligible for SNAP. The case is canceled if the match is the head of household, and it cannot be resolved.
If at the SNAP application, REDE, or a member is being added or during the certification period, it is determined that the matched individual is not a resident of Illinois and should not receive benefits, take the appropriate action to deny, cancel or remove the individual person from the case.

Note: A NAC match is not considered verified upon receipt. Verification is still needed to resolve the match.

Notice of Decision (IL444-0360)

A new NAC notice reason has been created for the Notice of Decision (IL444-0360C) for denials at application and program adds when the action is taken because the SNAP household failed to respond to the NAC notice:
- The household's eligibility cannot be determined due to failure to provide information on SNAP participation from another state. What can you do? If you complete your interview and provide the requested information within 60 days of your SNAP application, we can use the application you already submitted. If you do not, you will have to submit a new application. This action agrees with policy statement(s) contained in PM 17-04-03-c.

Expedited Service

NAC does not change SNAP expedited service policy. For Expedited benefits, only identity is required to be verified. The NAC process will still allow expedited benefits to be approved without actual proof of residency and SSN. The worker must still verify that the out of State SNAP case is closed before issuing expedited benefits in Illinois. In this instance, the NAC will trigger before allowing ongoing benefits to be approved. A NAC match cannot be done more than once a day if it was a successful call.
When identity, residency, and SSN can be verified within the expedited processing timeframe and the NAC query results in a match of an individual in the household currently receiving benefits in another state, expedited service timeliness standards no longer apply. The FCRC must take action to resolve the NAC match before issuing benefits.
When identity is verified but the worker is unable to verify residency and SSN within the expedited processing timeframe, the worker must postpone verification and make expedited benefits available to the household no later than the 5th calendar day following the date the application is filed and resolve the NAC match before additional benefits are issued.
Expedited service standards continue to apply if the individual is considered a vulnerable individual.

Case Comments

Document in Case Comments all instances of matches and the actions taken to resolve them. Due to the sensitive nature of domestic abuse situations, all case information and the location of the customer must be kept confidential. Document in Case Comments if it is a vulnerable household. Do not release location of the household or case information.

Establishment of Duplicate Assistance Claims

A lack of timely action or noncommunication between states cannot delay the benefit determination for an individual. The state that fails to meet the timeliness requirement for responding to a NAC match will be considered responsible for any duplicate assistance that occurs. That state is responsible for the establishment and collection of the claim.

Integrated Eligibility System (IES) Changes

IES Home Page

A new Search By option called NAC Match ID has been added to the IES Home page. The NAC Match ID is a unique identifying number associated to a NAC match that permits a search to be done for individuals by their NAC Match ID, which is found within the new NAC Results - Details page. After entering the NAC Match ID, the worker is navigated to the Individual - Summary page where they can review case information. Workers will use this match ID when another state contacts them regarding the NAC match.

Household Contact Information Page/Vulnerable Individuals

A new question with an accompanying drop-down menu has been added to the Household Contact Information page with the option to select Yes, No or Blank, to capture whether any household member identifies as a Vulnerable Individual. This question, Could a household member be placed in danger if their location was shared? is mandatory for SNAP only at application and REDE and will trigger a flag on the Case Error Reduction page if left unanswered. The household's statement is acceptable verification.
The response to the Vulnerable Individual question from this page is sent to the NAC database. When a change is made to the Vulnerable Individual question the value will be submitted to NAC. If a NAC match is created for an individual in another state, the other state will not reveal the location of the person.
A vulnerable individual, for the purpose of the NAC, includes but is not limited to, persons including men who would be endangered by the dissemination of their information, regardless of their age or gender, such as a:
- resident of a shelter for battered persons and children; or
- resident of a domestic violence shelter; or
- person who self-identifies as fleeing domestic violence at any point during the:
  - application process; or
  - REDE; or
  - certification period; or
  - addition of a new household member.
Individuals who are in these types of situations and are receiving SNAP as a member of the same household as the batterer may get duplicate SNAP if they are no longer living with the abuser. The location of a vulnerable individual or household should never be shared for purposes outside of NAC. See PM 05-09-00.

Note: FNS guidance clarified that all provisions related to persons fleeing domestic violence applies to all victims of domestic violence, regardless of gender or sex. This includes men who are victims of domestic violence that are residing in shelters for battered women and children.

Redetermination Review Summary Page

A new Household Information Summary section was added to the Redetermination Review Summary page. The new section includes columns to indicate Vulnerable Individual, contact phone numbers, language preferences, and mailing address.

There is also a new drop-down menu asking if the worker would like to review the Household Information Details page. The information in the Household Information Summary Section is populated from the Household Contact Information page.

EDM Box Ready to Certify

Three existing tasks will have a new NAC special indicator when generated for NAC related reasons. These tasks will be routed to the Ready to Certify Queue.

Verification Checklist (VCL)	If a VCL (IL444-0267 NAC) is created by selecting the National Accuracy Clearinghouse (NAC) - Match from the Out of State Benefits - Details page, a Verification Checklist task with the NAC special indicator will be generated.
Verification Checklist Overdue	When the VCL is generated, and the customer does not submit proof, a VCL Overdue with the IL444-0267 NAC is generated.
Proof Out of State Benefits	When verification of Out of State benefits has been received.

Five new tasks have been created:

National Accuracy Clearinghouse	Individual Not Found
National Accuracy Clearinghouse	Update Needed
National Accuracy Clearinghouse	Overlapping Record
National Accuracy Clearinghouse	New Match
National Accuracy Clearinghouse	Response Received Only the National Accuracy Clearinghouse -Response Received task will be routed to the Ready to Certify Queue. The National Accuracy Clearinghouse - Response Received task is generated when the other State responds to the request.

EDM Changes/Misc Queue

The NAC - New Match task will be routed to the Changes/Misc Queue. This task is created when any new NAC match has been identified by the batch.

New Match task	If IES successfully creates the Verification Checklist systematically, the task will be systematically marked as complete.
New Match with a "New" status	Indicates a worker must manually run eligibility to generate the Verification Checklist because eligibility was unable to run systematically.

EDM Inbox IPV Queue

Three new tasks have been added to the IPV (Intentional Program Violation) Queue. The new tasks will generate within the IPV Queue. Only designated workers will be processing these tasks.

National Accuracy Clearinghouse	Individual Not Found: This task is generated when individual information is received from NAC in the response, but IES is not able to locate the individual.
National Accuracy Clearinghouse	Update Needed: This task is generated when Illinois is not able to submit the response back to NAC (failed batch call).
National Accuracy Clearinghouse	Overlapping Periods: When benefits from out of state are reported for the same individual, benefit type, and state from any source other than NAC. Verified out of state benefits for the same individual, benefit type, and state for the overlapping period are received from NAC.

Clearance Results

A new NAC clearance has been added to the Clearance Results page called National Accuracy Clearinghouse (NAC) - SNAP Duplicate Match. An Action Icon will open up the National Accuracy Clearinghouse Results - Details pop up window.

National Accuracy Clearinghouse Results - Details Page

This screen can be accessed from the:

NAC Icon on the Out of State Benefits - Details page; or
the Icon on the NAC section of the Clearance Results page; or
the "Run Date" hyperlink on the Data Exchanges page; or
by the hyperlink on the Procedural Wrap Up page.

The page has four sections:

Search Criteria Section	When no match is found only the Search Criteria Section will display with a message stating "no matches found for this individual. It contains the identifying information on the individual that was found at the time of the search.
NAC Match Result Section	Only displays if a match is found. This is information received from the matched state about the individual's case in that state. The Match ID in this section should be used in Search By on the IES Home page.
NAC Match Information Section	The Match Status indicates whether or not it is an open match or if it has been closed. Initiating or Matching state indicates which state initiated the call. If Illinois is the initiating State, that means that Illinois first initiated the call to NAC. If Illinois is the matching State, that means another State first initiated the call to NAC. To be the matching state means the individual is already receiving SNAP in Illinois
NAC Match Resolution Section	This section displays the status update of the actions taken by a state on the match. Once a match is initiated, the matching state has 10 days to follow up on the match and provide their initial actions.

Invalid Match

In some instances, an invalid match may be because the individual isn't actually receiving duplicate assistance but had a NAC match, as a result of identity theft or a typo in the information submitted to NAC.

Vulnerable Individual	Sent to NAC from the Household Contact Information Page
Initial Action and Invalid Match	Sent to NAC from the Procedural Wrap Up page IES systematically creates the initial action, the worker confirms Yes on this page. The worker can initiate an invalid match on the Out of State Benefits page.
Final disposition	Sent to NAC from the Certification page when the case is certified

Data Exchanges

A new NAC section has been added that will retrieve historical information only. To access current information NAC must be triggered in Data Collection. The "Run Date" hyperlink will navigate the worker to the National Accuracy Clearinghouse Results - Details page.

Crossmatch/Priority Action List Information

A new National Accuracy Clearinghouse (NAC) - SNAP Duplicate Assistance Match section was added to this screen and is accessed from the following document/task titles:

National Accuracy Clearinghouse - Individual Not Found
National Accuracy Clearinghouse - New Match
National Accuracy Clearinghouse - Response Received
National Accuracy Clearinghouse - Update Needed
National Accuracy Clearinghouse - Overlapping Records

State hyperlink leads to the National Accuracy Clearinghouse Results - Details page.

Name hyperlink leads to the Individual - Summary page.

Match ID is only hyperlinked for those with the role SEBT user group and leads to the NAC website.

Out of State Benefits - Summary

New columns have been added to the table. If a match is found from the NAC Match Database IES will systematically create a new record and queue the page in driver flow. Any record systematically created by NAC cannot be deleted. New features include:

Valid Match	Displays a Green Icon when a valid match is made or a Red Icon to indicate an invalid match.
Vulnerable Individual Column	Displays whether an individual has been labeled as vulnerable, indicating there is sensitive information on the next page. If the other state has a record of the individual identifying as vulnerable the Received Benefits End Date, State Verification and Updated On fields will be hidden. If attempting to edit a Valid Match individual who identifies as Vulnerable, a pop-up window will display: Attention - The individual is considered vulnerable. DO NOT share the matched State for this individual. To proceed to the Out of State Benefits - Details page select OK.
Benefit Received	Displays the type of Out of State benefits. For NAC it will always be SNAP.
Benefit Amount	Amount of TANF benefits received.
Updated On	Displays the date the record was last updated.

Out of State Benefits - Details

If a match is found from the NAC Match Database, IES will systematically create a new record and queue the page in the driver flow. Data prefilled from the NAC clearance cannot be altered, with the exception of the verification field and the dates. A NAC Icon has been added at the top of the screen that triggers the NAC clearance.
A new field Identified as Vulnerable Individual in Other State has been added with the drop-down values of Yes or No. This is information received from the other State indicating that the individual self-identified as Vulnerable.
New verification values of National Accuracy Clearinghouse (NAC) - Match and National Accuracy Clearinghouse (NAC) Disposition Verified are both systematically selected with the prefilling of the page. A worker cannot choose and if an attempt is made it will display a message to choose another source.
- National Accuracy Clearinghouse - Match: This is what generates the Verification Checklist in the NAC process when it is not an acceptable verification source. It can be changed by the worker to a verified value when the customer provides proof of out of state benefits ending.
- National Accuracy Clearinghouse - Disposition Verified: An acceptable source that resolves the NAC match. This is confirmation received from the other state through NAC that either they closed their SNAP case, or the match was invalid.
A new Invalid Match Details section will only display if entering the page by selecting the Edit Icon on an existing record. This section can be completed systematically by NAC or manually by a worker. If the section is completed systematically, then all the fields will be disabled.
- This section includes:
  - Invalid Match: YES, enables the rest of the fields within this section.
    - Invalid Match Reason drop down values are:
      - Incorrect Client Information: A mistake was made, and the individual's identifying information was incorrectly entered.
      - Potential Identity Theft
      - System Error
      - Other: If selected, must give an explanation in the comment box.
Benefits Denied in Other State: A worker cannot select. It will be selected by the system when the final disposition of the other State is Benefits Denied. The match will be treated as invalid since SNAP isn't actually being received in the other state.
Invalid Match Verification: How the invalid match reason was verified. If an acceptable verification value has been selected by a worker in this drop-down, the rest of the fields in this section become disabled.
NAC - Disposition Verified: A worker cannot select this one, this is only prefilled by the system when we get a response from NAC that the match is invalid.
Out of State Agency Contact: The worker receives confirmation from other State that the match is invalid.
Other Acceptable: The customer provides acceptable proof.

Procedural Wrap Up Changes

A new section, the National Accuracy Clearinghouse Actions for Match Submission to FNS/NAC has been added to the Procedural Wrap Up page. The NAC section will only be visible on this page when data is required to be sent to NAC otherwise it will be blank. The following fields are contained on the page.

Matched Individual	Displays name of the individual for whom the Match Resolution will be submitted to NAC.
State	The name of the other matched state.
Match ID	Will be hyperlinked to NAC Result Details pop-up page.
Invalid Match	Displays Yes/No option.
Initial Action	Displays the initial action taken by the worker.
Final Disposition	Displays the final disposition taken by the worker. This is submitted to NAC upon certification of the case on the Certification page.
Is action to be sent, correct?	This will be a drop down with a mandatory Yes/No option. When Illinois is the second state to take action, and the other state has already closed the match, then a warning message will display to inform the worker that this information will be sent to NAC and the match will be closed. If a worker selects No, they will not be able to progress and will need to update Data Collection accordingly. After clicking [Next], the worker cannot change the match data and it will be available as read-only.

Application for Benefits Eligibility (ABE) Changes

ABE Registration Information

There is a new question added in the Apply for Benefits Module to capture if an applicant is a Vulnerable Individual: Could you or a family member be placed in danger if your location was shared?. The question is not mandatory and is at a household level. The drop-down menu option is Yes or No. The Hover Over Text Icon defines Vulnerable Individual to the customer.

Prior to determining your eligibility for benefits, we need to make sure any members listed on your application are not already receiving benefits in any other States. We share information with other State Agencies regarding who is applying for SNAP in Illinois. If a member of your household is identified as receiving benefits in another State, that household would be notified that the identified member is applying for benefits in another State. By telling us that your household contains someone that could be placed in danger if your location is shared, we would notify the other State not to share that the application was made in Illinois.

Renew My Benefits Module - Gatepost Question

The Vulnerable Individual question has been added in the Renew My Benefits Module. The question displays what is already on the Household Contact Information page. If the question has not been answered, this field will display: Not Answered. The hover over text Icon defines Vulnerable Individual to the customer.

Report My Changes Module - Address or Phone Number Change

The Vulnerable Individual question has been added in Report My Changes Module. The question is not mandatory and reads the same as in the other modules, including the same hover over text.

Case Summary Page

A new button was added to Case Summary page, Submit Out of State Benefit Verification. The button will be enabled if there is a NAC Verification Checklist pending on the case for any household member and will take the customer to the List of Proof of Documents for Out of State Benefits page where they can see the list of documents to respond to the NAC Verification Checklist. If the customer submits proof of out of state benefits by selecting this button, the Proof of Out of State Benefits task will be created with the NAC special indicator.

Document Type & List of Proof of Documents for Out of State Benefits

This is a new Application Benefits Eligibility (ABE) page that the customer is prompted to when they click the Submit Out of State Benefit Verification Button on the Manage My Case (MMC) Home page. The Notice of SNAP Participation Match in Another State is displayed to the customer. A list of acceptable verifications is provided so the customer knows what they can submit along with their application. There is a new Proof of Out of State Benefits section with acceptable verification being Statement or Letter from Other State.

Form Revisions

Request for Cash Assistance - Medical Assistance - Supplemental Nutrition Assistance Program (SNAP) (IL444-2378B), and Medical, Cash and SNAP Redetermination Notice (IL444-1893) are being revised to ask the vulnerable individual question.
When a customer misplaces the IL444-1893 that was mailed to them, reprint the IL444-1893 in IES Correspondence - View History which contains the case information and barcoding. A blank paper version is also available in the OneNet Forms Library. A SNAP and TANF Mid-Point Report (IL444-2890) cannot be used as a REDE application.

Manual Revisions

Dulce M. Quintero

Secretary-Designate, Illinois Department of Human Services

Forms referenced:

IL444-0267 NAC

IL444-0267 VCL

IL444-0360C

IL444-1893

IL444-2378B