WAG 03-02-03-d: NAC Duplicate SNAP Assistance

PM 03-02-03-d

National Accuracy Clearinghouse (NAC)

All states administering SNAP must comply with implementing the NAC interstate data matching system by the year 2027. The following is a list of states who have implemented NAC. This list will be updated with additional states as they 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

Matching or Initiating State

The NAC Results - Details Page - NAC Match Information section displays information about the match as well as the contact information for the matched state. Match status displays whether the match is open or closed (resolved). Displays whether Illinois is the initiating or the matching state.

• To be the initiating state means that Illinois first initiated the call to NAC when they find someone requesting in Illinois is already receiving in another state.
• To be the matching state means an individual has already received benefits in Illinois for a benefit month in which the individual has either applied or also received in another state.

Duplicate SNAP Assistance/Vulnerable Individuals

• Shelter residents who are receiving SNAP as a member of the same household as the abuser may get duplicate SNAP if no longer living with the person who abused them. The location and case information of the person(s) must not be shared.
• A vulnerable individual, for the purpose of the NAC, includes but is not limited to, persons 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.
• If the resident of the shelter is included as a member of the household containing the abuser, the resident can apply for and receive SNAP benefits as a separate household if all other eligibility criteria are met. Benefits are prorated from the date of application. Do not deny or discontinue benefits to the resident because the person and their children have not been removed from the former household timely
• Do not consider the income, resources and expenses of the former household. Jointly held resources are considered exempt if accessibility also requires the consent of the abuser.
• If the head of household moves into a shelter, remove all the other members from the SNAP case, except any children that reside with the head-of-household in the shelter. Benefits may continue to be issued to the household's existing Link account, if the head-of household has possession of the Link card then benefits can be accessed. If the head of household does not have the Link card, issue a new card.
• If a member other than the head of household resides in the shelter remove the member and anyone else that moved with the member from the SNAP case. Take a new SNAP application for the member(s) residing in the shelter. When the case is approved, issue a new Link card to the applicant.
• Take prompt action to ensure that the former SNAP household's case reflects the change in the household composition and any other applicable change that affect the benefit amount. The location and all other case information about the sheltered individual must remain confidential. Do not verbally release or include in any notices the location or case information of the person and their children. Send IL444-0360 if benefits are reduced, or canceled.

NAC and Expedited Service

• 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. Verify that the out of state SNAP case is closed before issuing expedited SNAP benefits in Illinois, unless a vulnerable household. 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. Take action to resolve the NAC match before issuing SNAP benefits in Illinois.
• When residency and SSN cannot be verified within the expedited processing timeframe, postpone verifications 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.

Review the NAC Match Information at Interview

• To prevent duplicate SNAP participation, review the NAC match information with the applicant during the  interview and when adding a new member to the SNAP household.

Nightly NAC Batch Upload

Note: NAC will prevent a PARIS match because it looks for duplicate assistance prior to it occurring. PARIS looks at duplicate assistance after it occurs.

NAC Interface

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 Screen 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.

• 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.
• When a positive match from a NAC query is received at initial application, REDE, Program Add or Member Add, take action to resolve the match and notify the other state of the initiated action within 10 calendar days from the date the match is received. Determine the appropriate action to take on the matched individual based on the verification provided to support eligibility to receive benefits in Illinois.
• 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.
• If at 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.
• Notice of Decision (IL444-0360C) is sent at application and when a ,ember is added to the SNAP household for failure to respond to the NAC notice.

Note: A NAC match is not considered verified upon receipt

Establishment of Duplicate Assistance Claims

If the former household receives benefits for the shelter residents for more than one-month, initiate claims action against the former household for any duplicate benefits which it received because the residents were not removed timely.

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.