03/10/2025
Summary:
- The refusal to cooperate with a Quality Control (QC) review sanction period begins on the first day of the ongoing eligibility month of cancellation and goes through the 125th calendar day following the end of the Federal Fiscal Year (FFY) in which the case was originally sampled. The penalty period is the 125-day portion of the sanction period that goes from October 1st through February 2nd.
- All household members of any SNAP or State Food EDG on the non-cooperating individual's case during the review month will have their Food Assistance benefits cancelled.
- The sanction period will follow all adult household members receiving Food Assistance who are age 18 or older. If they reapply for Food Assistance with a different household, SNAP and State Food EDGs will be denied for failing to cooperate with a QC review.
- All SNAP and State Food EDGs on a case that include a sanctioned adult household member age 18 or older added to it will be cancelled for failing to cooperate with a QC review.
- Non-cooperating households may cooperate with the QC review at any time, they do not have to serve the entire sanction period but must cooperate and reapply to regain Food Assistance benefits or reapply after the sanction period ends.
- If a sanctioned household reapplies after the 95th day of the penalty period (January 04 and after), they must cooperate with QC, reapply and re-verify all factors of eligibility to regain Food Assistance benefits, see PM 02-07-03.
Quality Control Review
QC reviews are conducted by the Bureau of SNAP Integrity (BSNAPI) on SNAP households that have received SNAP benefits for the sample month being reviewed. A SNAP household selected for a QC review is required to cooperate in order to continue to receive SNAP benefits, see PM 01-03-03.
Sanction and Penalty Periods for Refusing to Cooperate
Sanctions for refusing to cooperate with QC start with the first day of the ongoing eligibility month of cancellation and go through 125 calendar days of the subsequent Federal Fiscal Year (FFY) that the case was sampled in, or until they cooperate with the QC review. The FFY runs from October 1 through September 30 of any given year. The 125th day will be February 2nd.
The penalty period portion of the sanction period is the 125 calendar days following the end of the FFY in which the case was originally sampled in. The penalty period will be October 1st through February 2nd.
Example: Household X receives SNAP for the month of 06/2024. BSNAPI selects household X for a QC review with 06/2024 being the sample month. Household X refuses to cooperate with the QC review on 06/12/2024. Their benefits are cancelled and the adult(s) are sanctioned starting with 07/01/2024 and going through 02/02/2025. They must cooperate and reapply for benefits to regain benefits, if they reapply anytime between 01/04/2025 - 02/02/2025, they must also verify all factors of eligibility for Food Assistance.
Example: Household Y receives SNAP for January 2025 and is selected by BSNAPI for a review in that sample month. Household Y refuses to cooperate on 01/25/2025 and their benefits are cancelled starting 03/01/2025. Their penalty period of 125 days starts with 10/01/2025 and goes through 02/02/2026. They must cooperate and reapply for benefits or reapply after the sanction period ends to regain benefits, if they reapply anytime between 01/04/2026 - 02/02/2026, they must also verify all factors of eligibility for Food Assistance.
See the table below for Sanction Periods based on example QC Sample Months and Non-Cooperation Dates.
| QC Sample Month |
Non-Cooperation Date |
Sanction Period |
Federal Fiscal Year |
Penalty Period |
| 03/2025 |
03/01/2025 |
04/01/2025
-
02/02/2026
|
10/01/2024
-
09/30/2025
|
10/01/2025
-
02/02/2026
|
| 03/2025 |
03/16/2025 (after cutoff ) |
05/01/2025
-
02/02/2026
|
10/01/2024
-
09/30/2025
|
10/01/2025
-
02/02/2026
|
| 10/2025 |
10/01/2025 |
11/01/2025
-
02/02/2027
|
10/01/2025
-
09/30/2026
|
10/01/2026
-
02/02/2027
|
Note: The QC Sample Months and Non-Cooperation Dates above are only provided as examples. BSNAPI may review a case in any month of the year and Non-Cooperation Dates may land on any day of the month.
Persons Sanctioned
When a SNAP household refuses to cooperate with BSNAPI on a QC review, all members of any SNAP or State Food EDG during the sample month in question will have their Food Assistance benefits sanctioned, including children. The sanction will only follow all adult members to any SNAP or State Food EDG they become a member of.
Example: Marcos receives SNAP with his two year old son Mel. Marcos has refused to cooperate with a QC review, their SNAP is cancelled, and the household is sanctioned. Mel's mother gets permanent custody of him and adds Mel to her SNAP case. Mel is a child under 18 years of age, therefore the sanction does not follow him to the new household. Mel and his mother can receive SNAP benefits.
Marcos moves in with his mother and they buy and prepare food together, therefore she adds him to her SNAP case. The sanction follows Marcos and his mother's SNAP case is cancelled.
Reapplication Without Cooperation
Households sanctioned for failing to cooperate with a QC review who reapply for Food Assistance benefits without cooperating and before their sanction period ends will be denied for Food Assistance benefits.
If a sanctioned individual reapplies for Food Assistance on a different case with different household members before cooperating and before their sanction period ends, all of the SNAP and State Food EDG members on the new case will be denied and/or cancelled for Food Assistance.
Example: Al failed to cooperate with a QC review on 10/11/2024, he's sanctioned starting with 11/01/2024 until 02/02/2026. Al reapplied for SNAP on 01/01/2025, but he has still not cooperated with the QC review. His request for benefits is denied, he must cooperate and reapply or reapply after the sanction period ends. Al's failure to cooperate occurred at the beginning of the FFY, therefore the 125 day penalty period will not start until 10/01/2025.
Regaining Benefits
To regain benefits the sanctioned household must cooperate with the QC review and then reapply for benefits or reapply for benefits after the sanction period has ended.
Sanctioned households can cooperate anytime with a QC review, but must reapply after cooperation in order to regain benefits. Cooperation is determined and recorded by BSNAPI.
Sanctioned households who reapply after the 95th of the penalty period (January 04 and after), must cooperate with QC, reapply and re-verify all factors of eligibility to regain Food Assistance benefits, see PM 02-07-03.
Manual Revisions
[signed copy on file]
Dulce M. Quintero
Secretary, Illinois Department of Human Services
