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Questions and Answers Regarding the Food Stamp Program (FSP)
Certification Provisions of the Farm
Bill |
General
Question 1: Will there be a hold harmless period for quality
control (QC)?
Answer: For the mandatory provisions, the State
will be held harmless for 120 days from the mandated implementation date.
For the optional provisions, the State will be held harmless for 120 days
from the date the provision was initially implemented.
Section 4101 - Encouragement of Payment of Child Support (effective
October 1, 2002)
Question 4101-1: To be excluded, do child support payments have
to be court-ordered?
Answer: Yes.
Question 4101-2: To be excluded, does the household actually
have to pay the child support?
Answer: If determining
eligibility prospectively, the household must reasonably anticipate paying
child support.
Question 4101-3: Under this option, do States treat child
support arrearages as excluded income?
Answer: Yes, for
court-ordered payment of arrearages.
Question 4101-4: Do the same provisions that currently apply to
income deductions apply to income exclusions, such as deducting/excluding
child support payments made to a person outside the household for a child
inside the household?
Answer: Yes, the same provisions that
currently apply to income deductions apply to income exclusions, including
situations in which court-ordered child support payments are made to a
parent outside the household for a child that has returned to the
household.
Question 4101-5: If the person paying child support is a
disqualified/ineligible household member, is the entire amount of the
child support payment excluded from the ineligible member's income before
his/her income is prorated to the remaining eligible
members?
Answer: Yes. When a State chooses this option, it
decides that it will not count a household's child support payment as
income.
Question 4101-6: If the State opts to treat child support
payments as an income exclusion, how does this affect the 20 percent
earned income deduction?
Answer: We will address this issue in a
proposed rule. The State has discretion until a final rule is issued. In
this situation, there are a number of possible methods for calculating the
20 percent earned income deduction. One method is for States to calculate
the deduction based on a household's total earned income, without
subtracting the child support exclusion from its earned income. This
method produces an earned income deduction that reflects a household's
actual costs of earning income and is likely to be less error prone than
other methods. Other methods are possible.
Question 4101-8: What general guidance can the Food and
Nutrition Service (FNS) provide to States in developing a simplified
method?
Answer: We recommend that States use prior payment
history as an indicator of future payments by averaging a series of past
monthly payments to determine the anticipated amount of future payments.
The State has the discretion to set the length of history to be used in
this method. In situations in which payments either have just begun or
there is no reliable history of payments, we recommend that the
eligibility worker (EW) be provided with the discretion to determine the
anticipated amount of the payments.
Question 4101-9: As part of its simplified method for
determining child support deductions/exclusions, is the State required to
ask the household about anticipated changes?
Answer: No. The
State has the discretion in this matter.
Question 4101-10: After the State determines a household's child
support payment using its simplified method, is the household required to
report a change?
Answer: It depends on the household's reporting
requirement. Under 7 CFR 273.12(a)(4), a household is only required to
report a change in the child support obligation. Under simplified
reporting, there is no reporting requirement for child support if the
State continues to treat child support payments as an income deduction.
However, if the State opts to treat child support payments as an income
exclusion, there are a number of possible approaches to establishing
household reporting requirements. Generally, households are required to
report all income, and the EW determines whether reported changes affect a
household's eligibility or benefit level. In States that use both a
simplified method and simplified reporting, this general approach may
result in a monthly reporting requirement for households whose eligibility
depends on the allowance of a child support income exclusion. One
alternative approach is for the EW to: (1) provide each household with an
individualized reporting threshold, which would be the sum of the monthly
gross income limit for the household and its child support exclusion
amount ; and (2) direct the household to report when its income exceeds
this limit. Other alternatives are possible.
Question 4101-11: After the State determines a household's child
support payment, is the State required to act on a change reported by the
household?
Answer: Yes, with the following two exceptions: 1)
the State has opted not to act on changes in this deduction; and 2) the
deduction decreases, the household has simplified reporting, and the State
is prohibited from reducing the household's allotment.
Section 4102 - Simplified Definition of Income (effective October 1,
2002)
Question 4102-1: What types of income are excluded under
Temporary Assistance for Needy Families (TANF) and Section 1931 of the
Social Security Act (i.e., Medicaid) programs?
Answer: This
varies by State. Each State should be able to identify the specific TANF
and medical assistance (MA) programs in its State that provide income
exclusions that may also be used for FSP purposes under this
provision.
Question 4102-2: Under this provision, may States exclude
adoption assistance income from the definition of
income?
Answer: If the income is provided under Title IV of the
Social Security Act, it must be counted. Otherwise, it may be
excluded.
Question 4102-3: Although this option clearly does not apply to
court-ordered child support payments, what about voluntary or direct
support payments?
Answer: We will address the issue of non-court
ordered support in a proposed rule. The State has discretion until a final
rule is issued.
Question 4102-4: Does FNS intend to propose in regulations that
"contributions" be designated as a type of income that is essential to
fair determinations of FSP eligibility and benefit
amounts?
Answer: We will address this issue in a proposed rule.
The State has discretion until a final rule is issued.
Question 4102-5: Why has FNS requested that States provide their
FNS regional offices with lists of the specific types of income that will
be excluded under this provision?
Answer: We need to know this
information to avoid misunderstandings in Federal QC reviews, as well as
to assist us in the formulation of a proposed rule.
Section 4103 - Standard Deduction (effective October 1, 2002)
Question 4103-1: What if a State cannot implement the provision
by October 1, 2002?
Answer: If a State fails to implement the
provision on October 1, 2002, and a household was entitled to a higher
standard deduction than it received, the State must issue restored
benefits to the household.
Question 4103-2: How are ineligible and disqualified members
treated when determining the proper standard deduction amount for the
household's size?
Answer: We will address this issue in a
proposed rule. The State has discretion until a final rule is issued.
However, we believe that the intent of the law is to base household size
for the purpose of determining the standard deduction as equal to the
number of eligible household members.
Question 4103-3: For larger households, is there a negative
adjustment to the allotment if the household size decreases during the
certification period?
Answer: As discussed under Section 4106,
States are required to act on changes in household size during the
certification period. When a State acts on such changes, larger households
could see a reduction in their monthly benefits as a result of a drop in
the size of their standard deduction.
Section 4104 - Simplified Utility Allowance (effective October 1,
2002)
Question 4104-1: Are States required to have a mandatory
standard utility allowance (SUA) in order for this provision to be
applied?
Answer: Yes.
Question 4104-2: For States that already have mandatory SUAs, is
this provision optional?
Answer: Yes.
Question 4104-3: Does this provision mean that when two or more
households share a residence each household may receive the full SUA,
limited utility allowance (LUA), or telephone standard, for which it
qualifies?
Answer: Yes.
Question 4104-4: Is there no longer a requirement for prorating
the SUA for households living in either shared living quarters or public
housing?
Answer: Correct. The provision eliminates the current
requirement to prorate the SUA when households share living costs.
Question 4104-5: Does this provision affect residents in public
housing? For example, would a household that incurs an energy surcharge
for having a separate freezer be eligible for the SUA?
Answer:
The provision allows States to use the heating/cooling SUA for households
in public housing with shared meters who are only charged for excess
utility costs. Nevertheless, to qualify for a heating/cooling SUA, the
household still has to have a heating or cooling expense. There may be
situations in which households in public housing do not have a
heating/cooling expense.
Question 4104-6: Do all other existing rules regarding receipt
of Low Income Home Energy Act (LIHEAA) assistance or the LUA, such as
requiring two utility expenses to receive the SUA, remain the
same?
Answer: Yes. We are not presently contemplating any policy
changes in this area.
Section 4105 - Simplified Determination of Housing Costs (effective
October 1, 2002)
Question 4105-1: What is the difference between what is
currently allowed as a homeless shelter allowance and the new
provision?
Answer: Under current regulations, the States could
develop their own standard amount or use the standard provided by us.
Under Section 4105, however, States must use $143 a month. The new
provision is essentially the same as current regulations. Current
regulations at 7 CFR 273.9(d)(6)(i), implemented in the final rule on
Noncitizen Eligibility, and Certification Provisions of Pub. L. 104-193,
as amended by Public Laws 104-208, 105-33, and 105-185, published on
November 21, 2000 at 65 FR 70133, already provide States the option of
using a standard shelter deduction (i.e., a deduction from net income) for
homeless households.
Question 4105-2: What verification will be required to prove
that homeless households had shelter expenses during the month? Most
notably, what does QC examine?
Answer: Current regulations at 7
CFR 273.2(f)(2)(iii) provide verification requirements for the homeless
household shelter deduction. The regulations state that if a homeless
household has difficulty in obtaining traditional types of verification of
shelter costs, the EW must use prudent judgment in accepting claims of
shelter costs that appear to be reasonable. QC reviewers will attempt to
verify the actual circumstances of the homeless household, and will cite a
certification error if the household received the deduction but was
ineligible for it. If the QC reviewer has difficulty obtaining
verification of the actual circumstances of the household, the deduction
is allowed if it appears likely from available information that the
homeless household is eligible for it.
Question 4105-3: What qualifies as "extremely low" shelter
costs?
Answer: Current regulations at 7 CFR 273.9(d)(6)(i), as
well as Section 4105, permit the State to deny the homeless household
shelter deduction to households with "extremely low shelter costs." We did
not define "extremely low shelter costs" in the regulations and are
unlikely to do so in the future. States, therefore, should use their own
discretion in determining what constitutes "extremely low shelter
costs."
Question 4105-4: May the State opt to use the standard shelter
deduction of $143 for most homeless households but use actual shelter
costs for homeless households with high shelter costs?
Answer:
Under current rules at 7 CFR 273.9(d)(6)(i), homeless households may
choose to claim actual shelter costs and receive a deduction for excess
shelter expenses under 7 CFR 273.9(d)(6)(ii) rather than claim the
homeless household shelter deduction if actual shelter costs are higher
and verified. Note that under current rules, it is the household's option
whether to claim actual shelter costs rather than the standard, not the
State's option.
Section 4106 - Simplified Determination of Deductions (effective
October 1, 2002)
Question 4106-1: Do States have the flexibility to apply this
provision to only certain deductions or certain types of
households?
Answer: As specified in the law, States must act on
reported changes of residence and earned income. Otherwise, until
regulations are issued, States have the discretion to apply this provision
to only certain deductions and certain types of households. It is unlikely
that we will seek to limit this flexibility in proposed regulations.
Question 4106-2: Will the household's reporting requirements
change in States that choose this option?
Answer: This provision
does not address household reporting requirements. Until a final rule is
issued, the reporting requirements under current regulations, as modified
by section 4109 of the Farm Bill, remain in effect. However, we will
consider waivers of the requirements of 7 CFR 273.12 as necessary to
facilitate implementation of this option.
Question 4106-3: May a State act on changes in only one
direction, e.g., only act on reported changes that increase the
household's allotment but not on changes that would decrease
it?
Answer: We will address this issue in a proposed rule.
However, we will likely propose in regulations that if a State chooses to
act on reported changes for a particular deduction, it must act on changes
in both directions, i.e., it must act on changes that both increase and
decrease benefits. Congress did not anticipate that this provision would
affect program costs. However, it will affect costs if States are
permitted to act on changes in only one direction.
Question 4106-4: May States ignore reported changes in household
size that affect the standard deduction?
Answer: States must act
on reported changes in household size. Although a State that chooses this
option is not technically required to act on a corresponding change in the
household's standard deduction, it is likely that the State's data system
would automatically recalculate the standard deduction when it processes a
reported change in the household's size.
Question 4106-5: Under this provision, States must act on
reported changes in earned income. What deductions are affected by changes
in earned income?
Answer: A reported change in earned income
will affect the amount of a household's earned income deduction and may
affect the computation of the shelter deduction. Additionally, a change in
earnings could have an impact on a household's child support or dependent
care deduction. The State agency could choose not to act if the household
voluntarily reports changes in the amounts of these expenses.
Section 4107 - Simplified Determination of Resources (effective
October 1, 2002)
Question 4107-1: Under this provision, what resources may States
exclude under the simplified definition of resources?
Answer:
States will exclude all resources currently excludable under the
provisions of Section 5(g) of the Food Stamp Act of 1977, and may also
exclude certain currently non-excludable resources they do not consider
when determining eligibility for TANF cash assistance or medical
assistance (MA) under Section 1931 of the Social Security Act. Under this
option, States may not exclude cash, licensed vehicles, amounts in
financial institutions that are readily available, or other resources, as
determined by FNS through regulations, that are essential to fair
determinations of food stamp eligibility and benefit amounts unless they
are already excluded under Section 5(g). In the absence of such
regulations, States should exercise their good judgment in identifying
resources that should not be excluded.
Question 4107-2: What types of resources are excluded under TANF
and Section 1931?
Answer: This varies by State. Each State
should be able to identify the specific TANF and MA programs in its State
that provide resource exclusions that also may be used for FOOD STAMP
purposes under this provision.
Question 4107-3: States are not allowed to apply this provision
to licensed vehicles. Is the provision in Public Law 106-387 that allows
States to use a TANF program's vehicle rules for food stamp purposes still
in effect?
Answer: Public Law 106-387 is still in effect.
Question 4107-4: If a TANF cash assistance program excludes all
resources and the State withdraws this program, does the FSP withdraw the
exclusion as well?
Answer: Yes. When a TANF cash assistance
program is withdrawn, the State should review its remaining TANF cash
assistance programs to determine which resource exclusions will be used
for food stamp purposes.
Question 4107-5: If a TANF cash assistance program provides a
resource exclusion for Individual Retirement Accounts (IRAs), may the
State also exclude IRAs as resource for food stamp
purposes?
Answer: We will address this issue in a proposed rule.
The State has the discretion until a final rule is issued. However, if
IRAs are excluded as a resource for FSP purposes, the State must show that
these funds are not readily available to the household.
Question 4107-6: If a State has several MA programs with
different types of resource exclusions, may the State choose which
resource exclusions they wish to use for food stamp
purposes?
Answer: States may only exclude resources not
considered in determining eligibility for MA programs under Section 1931
of the Social Security Act. If a State operates more than one MA program
under Section 1931, the State may choose which resources exclusions to use
for food stamp purposes.
Question 4107-7: Why has FNS requested that States provide their
FNS regional offices with lists of the specific types of resources that
will be excluded under this provision?
Answer: We need to know
this information to avoid misunderstandings in Federal QC reviews, as well
as to assist us in the formulation of a proposed rule.
Section 4108 - Alternative Issuance Systems in Disasters (effective
May 13, 2002)
Question 4108-1: Will a disaster plan with a cash-out component
be approved?
Answer: Yes, as long as the cash option is used
only as a last resort and we are satisfied that all other alternatives are
fully depicted in the plan.
Question 4108-2: Will FNS have paper coupons available if a
State needs them?
Answer: No. States cannot rely on FNS to
provide coupons for use in a disaster. FNS will cease printing coupons in
the near future. In addition, with full implementation of electronic
benefits transfer (EBT) system, there will no longer be an infrastructure
to support the use of coupons.
Question 4108-3: If EBT is down and there are no coupons, what
alternative is there other than cash?
Answer: To date, EBT has
proven to be effective in most disaster situations. We believe this
provision provides for the use of cash in situations in which the use of
EBT would be ineffective. However, as noted above, FNS considers the
issuance of cash during a disaster to be a last resort.
Question 4108-4: Who will make the determination to use cash in
lieu of EBT?
Answer: We will make that determination based on a
State request and after consultation with the State.
Section 4109 - State Option to Reduce Reporting Requirements
(effective October 1, 2002)
Question 4109-1: May States opt to implement this provision
anytime on or after October 1, 2002?
Answer: Yes.
Question 4109-2: Current regulations provide this option to
households with earned income. Does this new provision simply extend this
option to households without earned income?
Answer: Yes.
Question 4109-3: May States continue to use this option only for
households with earned income?
Answer: Yes. States may identify
the types of households to be included in simplified reporting.
Question 4109-4: What types of households are excluded from this
provision?
Answer: Households that have no earnings and in which
all adult members are elderly or disabled, households in which all members
are homeless, or households that include migrant and seasonal farmworkers
are excluded.
Question 4109-5: A State may choose this option if it requires
the household to report "less often than every three months." What does
this mean?
Answer: The law provides States with more flexibility
than provided under current program rules. Consequently, States now may
choose to have a reporting period of four, five, or six months.
Question 4109-6: Under this option, is the household required to
report when its income has risen above the gross income
limit?
Answer: Yes.
Question 4109-7: If a categorically eligible household reports
that its income has risen above the gross income limit, is the household
required to continue to report its income every month?
Answer:
The State has the discretion in this matter.
Question 4109-8: May States choose this option and also choose
the option that pends action on reported changes in some
deductions?
Answer: Yes. Until a final rule is issued, the
reporting requirements under current regulations, as modified by section
4109 of the Farm Bill, remain in effect. If a State needs further guidance
regarding how to implement these two options, it should contact its FNS
regional office for assistance.
Question 4109-9: What guidance can FNS provide with respect to
simplified reporting and able-bodied adults without dependents
(ABAWDs)?
Answer: We recommend that States not put ABAWDs in
simplified reporting for the following reasons: 1) If the ABAWD is subject
to the three-month time limit, the State will have to remove the ABAWD
before the next recertification or interim report; and 2) The household
must report a change in ABAWD status.
Question 4109-10: What changes in ABAWD status is a household
required to report?
Answer: The household must report a decrease
in hours worked below 20 hours weekly. When a household member is
designated as an ABAWD and its eligibility depends on working 20 hours,
the household has to report if the ABAWD's hours drop below 20 hours
weekly. In situations in which the last child in household either leaves
the household or turns eighteen years of age, the household is not
responsible for reporting changes in ABAWD status, because the household
has not been advised of its ABAWD reporting requirements. However, this
does not apply to situations in which ABAWDs are improperly informed about
their reporting requirements.
Question 4109-11: If an ABAWD was working 20 hours weekly and
became temporarily incapacitated and could not work, what would happen
under simplified reporting?
Answer: Although regulations at 7
CFR 273.12(a)(1)(vii) do not address reporting of ABAWD status,
regulations at 7 CFR 273.12(a)(1)(viii) require ABAWDs subject to the time
limit in 7 CFR 273.24 to report when their work hours fall below 20 hours
weekly. Consequently, regardless of whether ABAWDs are in incident or
simplified reporting, they still have a reporting requirement under this
provision.
Question 4109-12: The "Questions and Answers on Noncitizen
Eligibility and Certification Provisions Final Rule (November 21, 2000)"
policy memorandum, which is available on the FNS website , contains
questions and answers about simplified reporting. Are these questions and
answers still valid?
Answer: The web address is: http://www.fns.usda.gov/fsp/rules/Memo/00/NCEP_Q_As.htm
The
previously issued questions and answers provide useful guidance with the
following exceptions. Questions A-1, A-2, and A-3 on earned income are no
longer relevant. Question E-3 on six-month reports should take into
account that the State now may require an interim report any time after
the third month up to a date around the end of the sixth month.
Section 4114 - Availability of Food Stamp Program Applications on the
Internet (effective November 13, 2003)
Question 4114-1: When the State has multiple websites, does the
food stamp application have to be available on all its
websites?
Answer: The application must be available on at least
one State website.
Question 4114-2: Does this provision require States to accept
applications through the Internet?
Answer: No. This provision
only requires that the State's application be available online so that
external users can access it.
Question 4114-3: Does this requirement apply to a State that has
an outside contractor maintain its website?
Answer: Yes.
Section 4115 - Transitional Food Stamps for Families Moving from
Welfare (effective October 1, 2002)
Question 4115-1: How do current regulations at 7 CFR
273.12(f)(4), regarding the types of households ineligible for the
Transitional Benefits Alternative (TBA), apply to Section
4115?
Answer: Section 4115 is less restrictive than current
regulations. Consequently, except for households that are currently
disqualified from TANF and/or the FSP, the State has the discretion to
identify the types of households that are ineligible for TBA.
Question 4115-2: Is a household eligible for TBA if the TANF
participation and food stamp certification periods end at the same
time?
Answer: Yes. If a household's TANF participation and food
stamp certification periods end at the same time, the State may extend the
household's food stamp certification period and provide transitional
benefits for up to 5 months.
Question 4115-3: If a household loses TANF because it no longer
contains an eligible child and as a consequence a household member is
designated as an ABAWD, may the State still opt to provide the household
with TBA for a five-month period?
Answer: Yes. The law does not
require an analysis of their ABAWD status.
Question 4115-4: If new or increased income causes the loss of
TANF, is the income counted in determining the transitional
benefit?
Answer: New or increased income that causes the loss of
TANF would not be counted in calculating the transitional benefit, unless
the State opts to act on information from another program in which the
household participates. To calculate the transitional benefit, the State
must use the prior month's food stamp budget. For example, a household
reports new earnings in the middle of February. Because of the adverse
action timeframes, the March TANF payment and food stamp benefit are not
changed, but when the change is processed the family becomes ineligible
for TANF. The transitional food stamp benefit would be based on the March
food stamp budget minus the TANF payment but not including the new or
increased income.
Question 4115-5: In addition to changes due to information from
another program, may a State opt to act on other reported
changes?
Answer: No. Section 4115 allows adjusting the
transitional benefit due to the loss of TANF and to information from
another program in which the household participates. In addition, the
household may reapply and be certified for benefits.
Question 4115-6: If the State becomes aware of an error in the
TANF benefit and/or the food stamp allotment, either at the time of
calculating the transitional benefit or later, should the transitional
benefit be adjusted to correct the error?
Answer: When TBA
begins, the State must recalculate the household's budget less TANF to
determine the household's transitional benefit. Both the State and the
household are to be held harmless for inaccuracies in the transitional
benefit that are due to prior errors in the food stamp benefit if the
transitional benefit is correctly computed based on the benefit during the
final month of TANF receipt, even if this benefit was not correct.
However, the State and the household may be liable for errors in allotment
amounts prior to the TBA period. If EWs make errors in the transitional
benefit amount due to improperly subtracting the TANF payment amount or
not accounting for information received from other assistance programs
(State option), the State must make appropriate changes. In such instances
the provisions of 7 CFR 273.17, 7 CFR 273.18, and 7 CFR 275 continue to
apply. If the State determines that errors are due to improper reporting
by the household in the past, the State has the discretion to terminate
the household from TBA and redetermine its eligibility.
Question 4115-7: How should the State handle situations in which
a household member moves out of a TBA household and either reapplies as a
new household or is reported as a new member of another
household?
Answer: The Food Stamp Act strictly prohibits
duplicate participation. Consequently, the State must adjust both
households' allotments in accordance with 7 CFR 273.12(c).
Section 4401 - Partial Restoration of Benefits to Legal Immigrants
(various effective dates)
Question 4401-1: Do EWs still have to determine whether an
immigrant is legal and qualified?
Answer: EWs must continue to
determine if a noncitizen is eligible according to the criteria set forth
at 7 CFR 273.4(a). However, as stipulated at 7 CFR 273.4(b)(2), when an
individual indicates unwillingness or inability to document immigration
status, EWs must cease further verification efforts. Such an individual is
ineligible.
Question 4401-2: Does the provision on disabled immigrants apply
to elderly immigrants?
Answer: No, unless they are also
disabled.
Question 4401-3: Does the term "disabled" include temporarily
disabled household members, such as those receiving worker's
compensation?
Answer: To be considered disabled, the household
member must be receiving disability benefits as outlined in the definition
of "elderly or disabled member" in 7 CFR 271.2, which does not include
worker's compensation.
Question 4401-4: Does it matter if an immigrant has been in and
out of the United States during the five-year residency
period?
Answer: No. The Conference Committee bill removed the
term "continuously" from the language of the provision.
Question 4401-5: Under these provisions, will there be
immigrants who gain eligibility and then lose it again?
Answer:
Yes. For example, an immigrant child who has been here fewer than 5 years
may become eligible as a child, then become ineligible at age 18, then
eligible again after gaining 5 years of residency.
Question 4401-6: Are immigrant children eligible for benefits
until the month after they turn 18 years old?
Answer: We will
address this issue in a proposed rule. The State has discretion until a
final rule is issued.
Question 4401-7: What about deeming?
Answer: The law
only changes deeming requirements for children. On October 1, 2003, the
deeming requirements for immigrant children are eliminated. However, the
indigent rules in 7 CFR 273.4(c)(3)(iv) will apply to many lawful
permanent residents who become eligible under Section 4401, but who have
neither naturalized, nor meet the requirement for 40 qualifying quarters
of work.
Question 4401-8: How do the deeming requirements apply in
situations in which both an adult and a child have the same
sponsor?
Answer: We will address this issue in a proposed rule.
The State has discretion until a final rule is issued. However, there
already is a procedure for determining deeming amounts when a sponsor has
multiple sponsored aliens (7 CFR 273.4(c)(2)(v)). The State may follow
this procedure for determining how much to exclude when the deeming
requirements for immigrant children are eliminated.
Question 4401-9: How should States handle situations in which
immigrants apply for benefits before they are eligible? Do States have a
responsibility to track these people?
Answer: For ineligible
members of on-going households, we recommend that States have some means
to identify these members and to certify them by the statutory dates. For
ineligible households, we recommend that States provide applicants with
general notices about when to return to apply. For ineligible households
that apply in the month before they become eligible, we recommend that
States deny benefits for the month of application and certify the
household for subsequent months in accordance with current regulations and
policies.
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