MR #15.25: CAU Process for Determining Medical Exemptions for SNAP & Other Changes

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12/30/15

Summary

This manual release provides a policy clarification from the Food and Nutrition Service (FNS) to allow an exemption from the SNAP work rules when a person is responsible for the care of a child under age 6, or for an incapacitated person, even if the child or incapacitated person is not living in the home.
A customer with a temporary or chronic medical condition may have an illness or injury serious enough to prevent the person from working or participating in activities. This manual release adds policy that the Client Assessment Unit (CAU) will make the determination when the customer claims to be physically or mentally unable to work or participate in SNAP E&T after being determined to be nonexempt by the Human Services Caseworker (HSC).
SNAP customers are required to comply with the work provisions in PM 03-15-01, unless exempt. In addition to complying with the work provisions, some SNAP customers are required to meet the work requirement policy in PM 03-25-01, when the policy is in effect.
Currently the entire state is exempt from the SNAP work requirement policy through December 31, 2016. However, a nonexempt customer who would have to meet the work requirement is still required to participate in SNAP Employment and Training (SNAP E&T) where the program operates and provider slots are available (WAG 03-25-01).
At initial application and REDE, discuss with the customer their ability to work and to participate in SNAP E&T. When a customer states they are physically or mentally unable to work or participate in SNAP E&T, the Human Services Caseworker (HSC) will make the determination to exempt a person due to a temporary or chronic illness.
When the HSC determines that a customer is nonexempt, Item 73 is coded 9. A nonexempt customer must comply with SNAP E&T requirements where the program operates and provider slots are available (WAG 21-06-01). Any customer that requests the exemption after the HSC has determined them nonexempt will provide medical evidence to support their claim.
If at the assessment meeting or after being given a referral to an activity, the customer claims that they are physically or mentally unable to comply with the SNAP E&T requirements give Instructions to Client (Form 1721) and Form 183A, Medical Evaluation Physician's Report to the customer. Request on Form 1721 that Form 183A be completed by a physician, licensed or certified psychologist or psychiatrist and returned to the FCRC along with a copy of the customer's medical records within 30 days.
Form 183A and any medical records will be sent to CAU for determination. The customer is not allowed the exemption until a CAU decision is made that indicates they have a medical barrier. The HSC informs the customer that CAU will make the determination as soon as possible, however it may take up to 30 days. The customer is considered nonexempt but engaged until a CAU decision is made.
When a nonexempt customer fails to comply with a SNAP E&T requirement, the FCRC sends Form 2846G, SNAP E&T Conciliation Appointment Notice, to schedule a conciliation meeting. The conciliation process determines why a nonexempt SNAP customer failed or refused to comply with SNAP E&T requirements, determines whether good cause exists and provides the person with another chance to comply.
If Form 183A and/or medical records are not returned within 30 days schedule a conciliation meeting to determine if the customer has good cause for not complying with the request (PM 03-15-05, PM 21-06-10-d). If good cause exists, the HSC should assist the customer in obtaining the information. If good causes does not exist and the customer requests additional time to provide the medical information give the customer Form 1721 and allow an additional 10 days. If the customer fails to return the medical information within 10 days or fails to attend the conciliation meeting, impose a sanction.
If Form 183A is returned, the HSC completes Form 183B, Medical Evaluation Social Information and Form 183F, Client Assessment Unit Memorandum and sends the completed packet to CAU for determination via email, fax, U.S. Postal Mail or through the Inter-Office Mail. The HSC enters Item 80 Code 156 DRD with the month/year the customer claimed a barrier, and SUP. BY. 'P' to indicate a medical barrier request is pending. Enter code 2 in Item 73.
The edit to Item 80 code 156 DRD has been modified to allow the HSC to enter the code on Category 08 cases.
If approved, CAU will return their disposition to the FCRC on Form 183C, Client Assessment Unit (CAU) Decision, indicating the medical exemption approval and the Determination Review Date (DRD). If CAU approves, the HSC notifies the customer that they are approved for an exemption from SNAP E&T participation.
If requested by CAU, obtain any additional information from the customer and resubmit with the entire packet. If the customer does not provide the required additional information, do not resubmit to CAU. Consider the person able to work.
If CAU does not approve, send Form 1721 for assessment and activity component placement. If Vocational Rehabilitation Services is needed, CAU will indicate the need on Form 183C.
If Vocational rehabilitation is indicated, the HSC completes Form 2151 Referral Form, to initiate a referral, then scans and emails to Vocational Rehabilitation Services.
Vocational Rehabilitation Services schedules the customer for Intake. When a customer shows for the appointment, Vocational Rehabilitation Services will report compliance on Form 2151 and share the customer's plan with the FCRC. If the customer does not show for the appointment, Vocational Rehabilitation Services indicates on Form 2151 and returns to the FCRC.
With the implementation of the Affordable Care Act some SNAP customers who are required to comply with SNAP E&T are receiving SNAP on a 94 ACA case. A decision from CAU regarding a SNAP medical exemption does not affect the medical eligibility of customers on an 94 ACA case.
Form 183B, Medical Evaluation Social Information and Form 183A are revised.
Included with this manual release is a correction to WAG 17-05-02, Assigning a SNAP Approval Period.
This release also provides policy to allow a 12-month SNAP approval period for Refugee and Repatriate Assistance (RRA) cases. RRA (Category 00) cases are in Mid-Point Reporting and will receive a Mid-Point Report form to complete and return to the FCRC in the 6th month of their SNAP approval period.
At the request of the Bureau of Workforce Development, Form 2606D, Regular Earnfare Referral and Attendance Record is revised.

Policy Clarification
What's New in Policy
Work Provisions
Work Requirement and SNAP E&T
Physical or Mental Exemption Requested
1. Initial Applications and REDEs
2. Exemption Requested at Assessment or after Referral to an SNAP E&T Activity
How Does the CAU Process Work?
Item 80 Code 156 DRD
1. Review of Medical Barrier
Referral to Vocational Rehabilitation Services
Customers with Learning Needs Disability
Other Changes
MANUAL REVISIONS
Forms referenced:

Policy Clarification

This manual release provides a policy clarification from the Food and Nutrition Service (FNS) to allow an exemption when a customer is responsible for the care of a child under age 6, or for an incapacitated person, even if the child or incapacitated person is not living in the home.

What's New in Policy

A customer with a temporary or chronic medical condition may have an illness or injury serious enough to prevent the person from working or participating in activities. This manual release adds policy that the Client Assessment Unit (CAU) will make the determination for an exemption from SNAP Employment & Training (SNAP E&T) when the customer claims to be physically or mentally unable to work or participate in an SNAP E&T activity after the Human Services Caseworker (HSC) has determined them to be nonexempt at initial application or REDE.

Work Provisions

SNAP customers are required to comply with the work provisions in PM 03-15-01, unless an exemption reason is met (see PM 03-15-02).

Work Requirement and SNAP E&T

In addition to complying with the work provisions SNAP customers age 18 to 49 years old who receive SNAP only and SNAP customers age 19-49 years old in an adult only 94 ACA case coded with a K in Item 25 must meet the SNAP work requirement policy in PM 03-25-01, when the policy is in effect.

Currently the entire state is exempt from the SNAP work requirement policy through December 31, 2016. However, a nonexempt customer who would have to meet the work requirement if the policy was in effect is still required to participate in SNAP Employment and Training (SNAP E&T) where the program operates and provider slots are available in PM 21-06-01.

Physical or Mental Exemption Requested

Initial Applications and REDEs

At initial application and REDE, explain the work provisions to the customer and SNAP E&T participation requirements. If the customer states they are physically or mentally unable to work or participate in SNAP E&T, the Human Services Caseworker (HSC) will make the determination to exempt a person due to a:

temporary illness if there is medical evidence that the illness or injury is serious enough to temporarily exempt the customer; or
a chronic illness if a physician or licensed or certified psychiatrist, or psychologist finds that a physical or mental impairment, either by itself or in conjunction with age or other factors prevents the customer from working or participating in SNAP E&T. The receipt of disability benefits can also verify the exemption. See PM 03-15-02.

When the HSC determines that a customer is nonexempt Item 73 is coded 9. A nonexempt customer must comply with SNAP E&T requirements where the program operates and provider slots are available (WAG 21-06-01).

Exemption Requested at Assessment or after Referral to an SNAP E&T Activity

Any customer that requests a physical or mental exemption after the HSC has determined them nonexempt from SNAP E&T participation will provide medical evidence to support their claim. If at the assessment meeting or after being given a referral to an activity, the customer claims that they are physically or mentally unable to comply with the SNAP E&T requirements, give Instructions to Client (Form 1721) and Form 183A, Medical Evaluation Physician's Report to the customer and request that Form 183A be completed by a physician, licensed or certified psychologist, or psychiatrist and returned to the FCRC along with a copy of the customer's medical records within 30 days.
The HSC also explains to the customer that if they do not return Form 183A and/or medical records within 30 days, a sanction may be imposed. When a nonexempt customer fails to comply with a SNAP E&T requirement, the FCRC sends Form 2846G, SNAP E&T Conciliation Appointment Notice, to schedule a conciliation meeting. The conciliation process determines why a nonexempt SNAP customer failed or refused to comply with the SNAP E&T requirements, determines whether good cause exists and provides the person another chance to comply.
If Form 183A and/or medical records are not returned within 30 days, schedule a conciliation meeting to determine if the customer has good cause for not complying with the request (PM 03-15-05, PM 21-06-10-d). If good cause exists, the HSC should assist the customer in obtaining the information. If good cause does not exist and the customer requests additional time to provide the medical information, give the customer Form 1721 and allow an additional 10 days. If the customer fails to return the medical information within 10 days or fails to attend the conciliation meeting, impose a sanction.

NOTE: A decision from CAU regarding a SNAP medical exemption does not affect the medical eligibility of customers on an 94 ACA case.

How Does the CAU Process Work?

Form 183A, Medical Evaluation Physician's Report

When issuing Form 1721 and Form 183A the HSC also informs the customer that CAU will make the determination as soon as possible, however it may take up to 30 days. The HSC enters Item 80 Code 156 DRD with the month/year the customer claimed a barrier and Sup. BY. 'P' to indicate a medical barrier request is pending.
If Form 183A is returned, the HSC completes Form 183B, Medical Evaluation Social Information and Form 183F, Client Assessment Unit Memorandum.
Form 183A is revised.

Form 183B, Medical Evaluation Social Information

The HSC completes Form 183B, Medical Evaluation Social Information, based on the customer's statements, worker's observation, and other available information.

The application date must be provided. For active cases enter N/A.
Also provide a complete phone number, including area code, and
The client's complete work history, including
- dates worked,
- type of business,
- job title/description of duties, and
Reason job ended
Sign and date form

Note: For medical cases Form G, attachment to HFS 2378H Mail-in-Redetermination for Medical Benefits may be submitted to CAU in place of Form 183B.

Form 183B, Medical Evaluation Social Information has been revised.

Form 183F, Client Assessment Unit Memorandum.

Completely fill in customer data accurately on Form 183F, Client Assessment Unit Memorandum.

How to Send Form 183A and Medical Records to CAU

Prepare a packet with Form 183A, Form 183B, Form 183F and/or all related medical records. Only the top section of Form 183A should be completed by the HSC, even if medical records are attached and the doctor did not complete Form 183A. Send the completed packet to CAU by one of the following methods:

Scan and Email:

dhs.cau@illinois.gov.

Fax:

(217) 524-8142

U.S. Postal Mail:

Client Assessment Unit (CAU)

P.O. Box 19492

Springfield, IL 62794-9442

Inter-office mail:

Client Assessment Unit (CAU)

100 S Grand Avenue East

Springfield, IL 62762

CAU Requests Additional Information

The HSC obtains any additional information requested by CAU, such as medical information for the 12-month period preceding the application date. If the customer has been hospitalized, include follow-up notes from the treating physician, hospital records, including admission summary, discharge summary and reports of all tests such as CT, MRI, X-Ray, EKG, and laboratory findings.
Resubmit the additional information with the entire packet.
If the customer does not provide the additional information or assist in obtaining it, do not resubmit to CAU.

Form 183C, Client Assessment Unit Decision

If approved, CAU will return their disposition to the FCRC on Form 183C, Client Assessment Unit (CAU) Decision, indicating the medical exemption approval and the Determination Review Date (DRD).
The HSC notifies the customer that they are approved for an exemption.
If not approved, send Form 1721 to the customer for assessment and activity component placement.

Item 80 Code 156 DRD

The edit to Item 80 code 156 DRD has been modified to allow the HSC to enter the code on Category 08 cases to indicate that the customer has a medical exemption. If CAU determines that the customer has a temporary or chronic medical barrier enter the applicable code under SUP. BY. with the item 80 code 156 DRD date. Also enter a (2) in Item 73.

If CAU denies the temporary or chronic medical barrier delete the Item 80 code 156 DRD (P) and engage the customer in the appropriate SNAP E& T activity. Unless customer appeals CAU's determination, or there is additional medical information included, do not resubmit the same packet to CAU.

Review of Medical Barrier

Review the customer's medical condition when indicated by Item 80 code 656 DRD. Follow the same instructions as for establishing a medical barrier. When submitting the current medical evaluation forms, attach all previous CAU packets (including Forms 183A, 183B, 183C and related medical information) that relate to the medical condition. If CAU decides the customer continues to have a medical barrier, update the review month and year under PERSONS in Item 80 code 156 DRD as indicated on Form 183C.

Referral to Vocational Rehabilitation Services

CAU may make a determination for other services that may be beneficial to the customer. If Vocational Rehabilitation Services is needed, CAU will indicate it on Form 183C. The HSC completes Form 2151, to initiate a referral then scans and emails to Vocational Rehabilitation Services. Vocational Rehabilitation Services will schedule the customer for Intake. If the customer shows for the Intake appointment Form 2151 will be returned to the FCRC indicating compliance and the customer's plan. When the customer does not show for the Intake appointment Vocational Rehabilitation Services will indicate this on Form 2151 and return the form to the FCRC. The HSC sends Form 2846G and allows 10 days for the customer to respond. Impose a sanction if the customer does not respond.

Customers with Learning Needs Disability

While completing Form 4001A, Family Assessment Employment, with the customer and Form 4728, Learning Needs Screening, the HSC through observation and discussion with the customer determines if there is a needs barrier, such as a health issue, or an educational issue, such as difficulty in reading.

If the customer scores 11 or less the HSC will send customer to an activity.
If the customer scores 12 or higher complete, the caseworker will complete, scan and email Form 2151, Referral Form and Form 4020A, Checklist for Referral to initiate referral to Vocational Rehabilitation Services.

Other Changes

Included with this release is a corrected manual page WAG 17-05-02, Assigning a SNAP Approval Period that was included in Manual Release #15.21, Enrolling Household into Mid-Point Reporting with 12-Month Approval Periods, dated 10/15/15.
For Refugee and Repatriate Assistance (RRA) (Category 00) cases allow a 12-month SNAP approval period. RRA cases are in Mid-Point Reporting and will receive a Mid-Point Report form to complete and return to the FCRC in the 6th month of their SNAP approval period.
At the request of the Bureau of Workforce Development, Form 2606D, Regular Earnfare Referral and Attendance Record is revised.