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

PM 18-04-03.

Act on Reported Changes 

Act on Reported Changes in General

The FCRC must act on reported changes in general. When a SNAP household reports a change, including changes reported at REDE or Mid-Point Report, review the effect of the change on the household's eligibility and benefit amount and take the appropriate action. If additional information is need to determine eligibility, send a 267 VCL to request verifications.

Act on Reported Changes with Unclear Information

• During the certification period, the FCRC may receive unclear information about changes in the SNAP household's circumstances from which it cannot readily determine the effect on the household's continued eligibility for SNAP. The FCRC may receive unclear information from a third party or from the SNAP household itself. Unclear information is defined as:
  • information that is NOT verified; or
  • information that is verified but the FCRC needs additional information to act on the change.
• Send a 267 VCL notice to follow-up with the customer when information is received and is unclear. See section below titled 267 VCL/360C Notice for notice text. Some examples of when information may be unclear and require follow-up are below.

Example 1: Ms. G is active for SNAP in Change Reporting. Ms. G reports on Form 1978, Change Report Form, a friend moved into the household but does not provide any other information about the friend, such as name, date of birth, social security number or income. The HSC needs further information to act on the case appropriately. The HSC sends Ms. G Form 267 VCL to request the information needed to add the individual to SNAP.

Example 2: Mr. T is in Mid-Point Reporting. His Mid-Point Report (Form 2890) was returned by the post office as undeliverable. Mr. T has not reported an address change. He is not required to report the change since he is in Mid-Point Reporting. Since it is unclear as to whether Mr. T has moved, the FCRC must send a 267 VCL request for contact and allow 10 days for Mr. T to respond before canceling his SNAP case.

When mail is returned as undeliverable, send the 267 VCL to the last known address (if there is forwarding information on the returned envelope, send to the forwarding address) before canceling the case. Send Form 360C with the appropriate cancellation reason. See PM 03-02-03-a, PM 18-04-03.

Example 3: Ms. L and her husband are active for SNAP in Change Reporting. Ms. L reports on Form 1978, Change Report Form, that her husband has started a job at ABC Construction. She does not report any information regarding his hours of work or his rate of pay. The HSC needs this information to determine the household's continued eligibility for SNAP. The HSC sends Ms. L Form 267 VCL to request the employment information.

Information Verified Upon Receipt/Additional Information Needed

If the information is considered verified upon receipt but additional information is still needed to act on the change appropriately, then the information is considered unclear.

Example 1: The HSC was notified via the customer's statement that another person joined the household. The person's name, DOB and SSN was provided. The customer's statement is considered verified upon receipt, but the HSC does not know how the household's total monthly income may have been changed with the addition of this new person. The HSC sends a 267 VCL to the household for further information and/or verification from the household to provide paystubs to make the appropriate changes to the case.

Example 2: Mr. H is in Mid-Point Reporting. He receives SNAP with his wife and two children. Mr. H completed a SNAP REDE on 11/10/18. On the REDE form and at the interview Mr. H stated that the household did not have income. They are unable to pay their shelter expenses. On 03/22/19, the HSC receives a data crossmatch which shows Mr. H has earned income that started in February. This income is under the Gross monthly Income Standard for a household size of 4 and Mr. H is not required to report it. The information does not conflict with what Mr. H reported at REDE as he was not working at that time. The HSC marks the task as complete. Mr. H is required to report his income on his next Mid-Point Report (MPR), unless his gross monthly income exceeds the Gross Monthly Income Standard prior to the receipt of the Mid-Point Report.

Example 3: Ms. Z is in Mid-Point Reporting. She completed a SNAP REDE on 11/10/18. Ms. Z reported no income. and stated during the interview that she did not have income. On 03/27/19, the HSC receives a data crossmatch showing Ms. Z started work in February and his gross income exceeds the Gross Monthly Income Standard for a household size of 1. This information does not conflict with what was reported at REDE as Ms. Z did not have income at that time. However, Ms. Z is required to report that her gross monthly income exceeds the Gross Monthly Income Standard for one person. The HSC sends a 267 VCL to follow-up with Ms. Z on the unreported income and files an overpayment. The task is marked as complete.

Information Verified Upon Receipt/No Additional Information Needed

Take the appropriate action, if the information is verified upon receipt and no additional information is needed to act on the change.

Example: The HSC received a data match from the Social Security Administration (SSA) that a SNAP customer's SSA was increased within the last 60 days. The case was excluded from Bendex and was not updated. The HSC takes action to make the appropriate changes to the case since the information is considered verified from SSA and the impact on the household is clear.

When to Act on Unclear Information Received from Data Crossmatches

• FCRCs must act on all information received from a prisoner or death data crossmatch or undeliverable mail/unreported address changes.
• For all other data crossmatches, send a 267 VCL to the customer to clarify and verify (if necessary) unclear information only if it:

• • Example: Mr. B is active for SNAP as a Change Reporter (PM 18-04-00). His recent issuance of SNAP benefits was in June. On June 5, the FCRC receives information from a data crossmatch that is fewer than 60 days old relative to the current month of participation (June) that indicates Mr. B's income had increased by $200 in May. The HSC sends Mr. B a 267 VCL to follow-up because Mr. B was required to report when his income increased by $100 or more. If the information had been older than 60 days relative to the current month of participation (June) the HSC would not send a 267 VCL but instead wait until the next redetermination.
• Follow-up with the customer when information becomes known that conflicts with what was reported on the application and during the interview.
  • Example: When completing the application and at the interview, Mr. T indicated that he did not have income.  The FCRC receives information from a data crossmatch that Mr. T is employed and was working at the time of application and the interview. The HSC sends a 267 VCL to request contact with Mr. T for clarification of his employment status and verification if needed.
• If the unclear information indicates that there was a change in household circumstances, but not a change the household was required to report, follow up on the information at the next Change Report household's REDE or Mid-Point Report household's REDE or Mid-Point Report whichever is earlier.

Note: This policy change applies to both Change Reporting households and Mid-Point Reporting households.

Unclear Information More than 60 Days Old

Do not act on information from a data crossmatch or require the household to provide information until the next Change Report household's REDE or the next Mid-Point Report household's REDE or Mid-Point Report (whichever is earlier), if the information:

1. is more than 60 days old relative to the current month of participation and was not required to be reported; or
2. does not present significantly conflicting information from that used at the time of certification

Example: Ms. C is active for SNAP in Mid-Point Reporting. Her most recent SNAP issuance was in the month of June. The FCRC receives information outside of Ms. C's Mid-Point Report that is fewer than 60 days relative to the current month of participation (June) that indicates she received a pay increase effective January but the increase did not result in Ms. C becoming ineligible based upon gross income being over the gross income standard for the household size or the increase is not within 60 days of the current month or participation. The FCRC is not required to send a 267 VCL to follow-up with the customer. The FCRC will address the issue at the next Mid-Point Report or REDE, whichever is earlier.

Determining When to Act on Unclear Information Received from a Data CrossMatch

Follow the procedure below to determine when to act on a Data CrossMatch. This procedure does not apply to Prisoner or Death Matches or information received on undeliverable mail/unreported address changes.

Data Match Information	Action to Take
Step One Does the information received significantly conflict with the information used to approve the application?	If Yes, follow-up with the SNAP household by sending a 267 VCL requesting contact and verifications, if needed. See instructions below under the heading 267 VCL/360c notices. If No, then proceed to Step two.
Step Two Is the information received something the SNAP household is required to report based on their assigned reporting status?	If Yes, proceed to Step three. If No, then the FCRC should not act on the information or require the SNAP household to provide information until the next Change Report household's REDE is due or the next Mid-Point Report household's REDE/Mid-Point Report is due, whichever is earlier.
Step Three Is the information less than 60 days old?	If Yes, follow-up with the SNAP household by sending a 267 VCL to request contact and verifications, if needed. See instructions under the heading 267 VCL/360c notices. If No, then the FCRC should not act on the information or require the SNAP household to provide information until the next Change Report household's REDE or the next Mid-Point Report household's REDE/Mid-Point Report is due, whichever is earlier.

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

267 VCL/360C Notices

Request proof when it is discovered that the SNAP household did not report a change or if information is unclear.

1. Send the SNAP household a manual 267 VCL to request specific verification.
   • Include the following: "We have received information that conflicts with information that you have previously provided. You must respond to this notice and provide the information that is requested within 10 days from the date of this notice. If you do not respond and provide the information within 10 days, your SNAP benefits will be discontinued." "Hemos recibido información que entra en conflicto con la información que nos ha proporcionado con anterioridad. Debe responder a este aviso y proporcionar la información que se solicita dentro de los 10 días siguientes a la fecha de esta notificación. Si usted no responde y proporcionar la información dentro de 10 días, se suspenderán sus beneficios de SNAP".
   • The 267 VCL notice should inform the SNAP 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.
   • The notice request allows the household 10 days from the date of the written request to respond and clarify its circumstances either in person by telephone or through correspondence with the required verifications, if needed.
   • If the SNAP household responds to the notice request and provides sufficient information, act on the new circumstances within 10 days, as appropriate.
2. If the household does not respond to the 267 VCL notice request, or does respond but refuses to provide sufficient information to clarify its circumstances, complete a manual Notice of Decision (Form 360c). Use the following reason: "Your benefits are being canceled because you failed to provide the requested information/verification as requested in our notice dated" (use the date the 267 VCL was sent to the SNAP household). "Sus beneficios se están cancelando porque no proporcionó la información y / o la verificación según lo solicitado en nuestro notificación de fecha" (use the date the 267 VCL was sent to the SNAP household.

Procedures for Acting on Unclear Information from a Prisoner or Death Crossmatch

The above procedures do not apply to prisoner or death data matches or information received on undeliverable/returned mail.

1. (IES) Receives information about customers who may be deceased or incarcerated. If IES is able to confirm exact matches it will auto-process the match. When an exact match cannot be confirmed automatically, worker intervention is required.
2. (FCRC) Must follow-up on all data matches received on incarcerated or deceased persons, or undeliverable/returned mail. For SNAP, a 267 VCL must be sent to the customer prior to taking a negative action on the case to ensure that the data source is correct, regardless of the IES exact match. Include the following on the 267 VCL:
   • "We have received information that conflicts with information that you have previously provided. You must respond to this notice and provide the information that is requested within 10 days from the date of this notice. If you do not respond and provide the information within 10 days, your SNAP benefits will be discontinued."
   • "Hemos recibido información que entra en conflicto con la información que nos ha proporcionado con anterioridad. Debe responder a este aviso y proporcionar la información que se solicita dentro de los 10 días siguientes a la fecha de esta notificación. Si usted no responde y proporcionar la información dentro de 10 días, se suspenderán sus beneficios de SNAP".
3. The 267 VCL notice must clearly explain what information the SNAP household must provide and the consequences of failing to respond to the notice.
   • For households subject to Change Reporting, if the household does not respond to the 267 VCL regarding the crossmatch, or does respond but fails to provide sufficient information to clarify its circumstances, send Form 360c to cancel the entire SNAP case. A Change Reporting household is required to report changes within 10 calendar days of the date they learn of the change (PM 18-04-00).
   • For Mid-Point Reporting households, if the household does not respond to the 267 VCL regarding the crossmatch or does respond but fails to provide sufficient information to clarify its circumstances, remove the individual from SNAP and adjust benefits accordingly. For a single person case, cancel SNAP. Send Form 360c to notify the household of the adverse action. A Mid-Point Reporting household is not required to report when someone leaves the household, therefore adverse action is only taken on the ineligible person listed in the crossmatch. If the ineligible person is the head of household, a new application should be completed for the remaining eligible persons.
4. If the household does not respond to the 267 VCL notice request, or does respond but refuses to provide sufficient information to clarify its circumstances, complete a manual Notice of Decision (Form 360c). Use the following reason:
   • "Your benefits are being canceled because you failed to provide the requested information/verification as requested in our notice dated" (use the date the 267 VCL was sent to the SNAP household).
   • "Sus beneficios se están cancelando porque no proporcionó la información y / o la verificación según lo solicitado en nuestro notificación de fecha" (use the date the 267 VCL was sent to the SNAP household.
5. When the SNAP household has not reported an address change and the 267 VCL is returned as undeliverable mail, send the notice of adverse action to the last known address provided by the household with the appropriate cancellation reason. Do not send the notice of adverse action to the DOC facility.
   • Example: The FCRC receives a Prisoner Data Match indicating Mr. B is incarcerated. Mr. B is a one person SNAP household in Change Reporting. He has not reported any changes in his circumstances to the FCRC. The FCRC sends Mr. B a 267 VCL notice to his last known address to request contact for clarification and/or verification of the unclear information (PM 18-04-03). The 267 VCL is returned as undeliverable mail. The FCRC sends the notice of adverse action to Mr. B's last known address indicating that his SNAP benefits will be canceled. The case is canceled because the client cannot be located and eligibility cannot be determined due to the undeliverable mail. The information received from the data match is unclear information since there was no contact with the client to confirm his circumstances.
6. If it is verified that the person is incarcerated, make the appropriate case changes based on the household's reporting status.
   • Example: Ms. K, her husband BJ, and their son T are in Mid-Point Reporting for SNAP. In October, the FCRC receives a Prisoner Data Match indicating BJ is incarcerated. If BJ is incarcerated, the Mid-Point Reporting household is not required to report it. The FCRC is required to act on the data match by sending the household a 267 VCL requesting contact for clarification of the unclear information reported on the data match. It is considered unclear information because the data match indicates a change in household circumstances that the household has not reported and the FCRC does not know if the information is correct. Ms. B responds to the 267 VCL within 10 days and reports that BJ has been incarcerated since August. The FCRC removes BJ from SNAP. Form 360c is sent notifying the SNAP household of the removal of BJ and the reduction in SNAP benefits. There is not an overpayment because the Mid-Point Reporting household was not required to report that the household member left the home.
7. When a Death Crossmatch is received on an individual, send a 267 VCL to confirm if the information on the report is accurate. If it is verified that the person is deceased, make the appropriate case changes based on the household's reporting status. If the 267 VCL is returned as undeliverable or the household does not respond send Form 360c to the last known address with the appropriate cancellation reason.
   • Example: In October, the FCRC receives a Death Crossmatch on a member of Ms. J's household who may have passed away in July.  Ms. J is in Change Reporting status and has not reported any change in household circumstances. The FCRC sends a 267 VCL notice to Ms. J to clarify if the information received in the data match is accurate. Ms. J contacts the FCRC within 10 days and states her son died in July. The FCRC makes the appropriate changes to remove the son from the SNAP case and sends Form 360C notifying the household of the change in benefits due to the removal of a household member.
8. If it is learned that the individual is not deceased or incarcerated, enter the appropriate source of data that was used to make this determination and manually close the task.