PM 18-04-03: Cooperation in Verifying Unclear Information or Unreported Changes

Reported Changes in General

When a Food Assistance (SNAP and State Food) household reports a change, including changes reported at a redetermination (REDE) and the Mid-Point Report (MPR), the Family Community Resource Center (FCRC) will review the effect of the change on the household's eligibility and benefit amount and take the appropriate action. FCRC staff are required to act on reported changes if clear and verified upon receipt.

Reported Changes with Unclear Information

During the certification period, the FCRC may receive unclear information about changes in the Food Assistance household's circumstances from which it cannot readily determine the effect on the household's continued eligibility for Food Assistance benefits. The FCRC may receive unclear information from a third party or from the Food Assistance household itself. Unclear information is:
- information that is NOT verified upon receipt; or
- information that is verified but the FCRC needs additional information to act on the change.
If the information is verified upon receipt and no additional information is needed to act on the change, the information is considered clear. The FCRC will take the appropriate action on the reported change.
The FCRC may follow-up with a Food Assistance household to provide information (that is not required to be reported) on a voluntary basis if that information would result in an increase in benefit, but may not take adverse action if the household does not respond.
If the household reports a physical address change within Illinois but does not specify if a change of shelter costs occurred, the FCRC must follow up, see the section below titled: "Reported Physical Address Change Without Reported Shelter Costs."

Example: Mr. A lives applied for Food Assistance and was approved on 05/22/24, he lives alone. A separate household with only Ms. B in it files a timely MPR on 07/02/24 and only reports a change of address on the form. The new address matches Mr. A's address. No information has been submitted by either party regarding relationship or household status. The change reported by Ms. B is considered unclear information. The addition of a household member must be reported at MPR and since their addresses match but Question #2 on the MPR was answered 'No', the information provided is both unclear and questionable and must be followed up on. The worker calls Ms. B but does not make contact. The worker then sends a VCL for both proof of address and for Ms. B to make contact with the FCRC.

When to Act on Unclear Information

The FCRC must follow-up with the customer to clarify and/or verify unclear information received during a Food Assistance household's certification period if it:

Is required to be reported according to the reporting status assigned to the household and is less than 60 days old relative to the current month of participation; or
The unclear information presents significantly conflicting information than what was provided by the customer at the last Food Assistance application, REDE or MPR.

If the information is not required to be acted on because it does not meet one of the above conditions, a case comment is completed with the details of the information. The unclear information will be followed up on at redetermination or Mid-Point Report, whichever comes first.

The Food Assistance household may provide verification of unclear information that it was not required to report on a voluntary basis, however the FCRC should not request information if it does not meet one of the above conditions.

Reported Physical Address Change Without Reported Shelter Costs

When a Food Assistance household reports a change in physical address within Illinois but does not specify if a change of shelter costs (housing and utility costs) have occurred in conjunction with the address change, IDHS must follow-up on this information to determine if there is a change in shelter costs due to the address change.

The Request for Shelter Costs Due to Address Change Notice will be systematically sent to active Food Assistance households when a change to the physical address has been made on the case but the housing and utility costs have not been updated. It is a voluntary form and negative action is not taken if it is not returned.

If the Request for Shelter Costs Due to Address Change Notice is returned, task 5229 - SNAP Courtesy Notice will be created in the Ready to Certify Queue for worker follow-up.

Note: IDHS has received approval from Food and Nutrition Service (FNS) to allow the shelter costs to remain on the Food Assistance case even if the household fails to respond to the Request for Shelter Costs Due to Address Change Notice. Workers must also ensure that cases who have had their physical address updated to a state other than Illinois have their Food Assistance benefits cancelled so that unnecessary correspondence is not sent.

Procedures for Acting on Undeliverable Mail

All Undeliverable Mail received in the FCRC should be manually scanned and uploaded with a task in the Changes/Misc. Queue.

During their certification period, Mid-Point Reporting households do not have to report an address change, however if a new address is found on the Undeliverable Mail it should be used to update the household address.

Change Reporting households are required to report a change of address during their certification period. Information received on Undeliverable Mail/unreported address changes for Change Reporting households must be acted on immediately.

See WAG 18-04-03 for how to act on Undeliverable Mail.

Note: When a Verification Checklist sent in relation to a Prisoner or Death Data Crossmatch is returned as Undeliverable Mail, cases in both Food Assistance reporting types are required to comply.

When to Act on Unclear Information Received from Data Crossmatches

FCRCs must act on all information received from a Prisoner or Death Data Crossmatches. The FCRC must follow-up with the Food Assistance household to clarify and/or verify the information reported to determine the effect on the household's circumstances before taking an adverse action, regardless of the IES match, see WAG 03-23-01.
For all other data crossmatches the FCRC must follow-up with the customer to clarify and/or verify unclear information received during the certification period if it:
1. Is required to be reported according to the reporting status assigned to the household; and is less than 60 days old relative to the current month of participation; or
2. Appears to present significantly conflicting information than what was provided by the customer at the last Food Assistance application, REDE or MPR.

Note: This procedure does not apply to Prisoner or Death Crossmatches.

Unclear Data Crossmatch Information Fewer Than 60 Days Old

When the FCRC receives unclear information that is fewer than 60 days old relative to the current month of participation that indicates a change in household circumstances that should have been reported, the FCRC will send a Verification Checklist to the customer to clarify and/or verify that the information reported in the data match is accurate.
The FCRC will send a notice to request contact with the customer for clarification and verification if the unclear information appears to present significantly conflicting information about the household's circumstances from that used at the time of certification. The FCRC must follow-up with the customer when information becomes known that conflicts with what was reported on the application and during the interview, see WAG 18-04-03.
If the unclear information indicates that there was a change in household circumstances, but not a change the household was required to report, the FCRC will follow up on the information at the redetermination or Mid-Point Report, whichever is earlier.
See WAG 18-04-03 for procedures.

Note: The 60 days is not in terms of when the crossmatch is received. The customer information in the data crossmatch cannot be more than 60 days old relative to the current month of participation.

Unclear Data Crossmatch Information More than 60 Days Old

The FCRC will not act on the information or require the household to provide information until redetermination or Mid-Point Report, whichever comes first, if the information:

Is more than 60 days old relative to the current month of participation; or
Was not required to be reported; or
Does not present significantly conflicting information from that used at the time of certification.

See WAG 18-04-03 for procedures.

Request for Contact/Cancellation Notice Procedures

The following procedures are only applicable when the unclear information requires immediate follow-up with the customer.

The FCRC will send a Verification Checklist to the household. The notice will advise the household of the verification it must provide or the actions it must take to clarify its circumstances and the consequences if the household fails to respond to the notice.
The FCRC will allow the Food Assistance household 10 days from the date of the written request to respond and clarify its circumstances either by telephone or through correspondence with the required verifications, if needed. If the household responds to the notice request and provides clear information, the FCRC will act on the new circumstances within 10 days, as appropriate.
If the Food Assistance household does not respond to the Verification Checklist, or does respond but refuses to provide clear information to clarify its circumstances, a notice of adverse action will be sent to the household. Except when verification is requested for an expense, benefits will be canceled if the household fails to provide the requested verifications within the 10 days. If the household later cooperates, see PM 19-04-00 for restoring benefits policy.