Action | SNAP Certification Periods |
Stage | NOIRA |
Comment Period | Ended on 11/10/2010 |
These comments are in reference to the Intended Regulatory Action; 22 VAC 40-601 -70 SNAP Certification Periods.
In reviewing the purpose, need, substance, legal basis and alternatives several things come to mind.
The six month certification period for everyone seems like a waste of time for the client and the worker alike when it is a stable unearned income household; i.e. SSA household whose shelter/expenses do not exceed their household income. If the review requirement is changed to six month certifications is there a possibility for exclusion for certain households???
Is there no other choice for reporting requirements other than full reporting and this “simplified” reporting? Is there no middle of the road abbreviated reporting requirements that would have more reporting than the “simplified” process while allowing the worker to choose either a six or 12 month certification period based on the individual client’s situation? Can we not empower the worker by allowing follow up on a change no matter how the change is reported? Can we not impose some consequences to the clients that do not respond or follow through with requested verifications? Would this not be fairer to the clients that do report, understands and accepts the change to their benefits? Does it seem reasonable to continue to issue benefits to someone in an ineligible institution while they give their card and PIN number to allow someone else to spend their benefits? During these hard economic times would it not be a better use of our resources and the taxpayers’ dollars to ensure benefits are based on the best available anticipated evidence???
While there are pros and cons on both sides (12 month w/IR, 6 month/no IR; (can’t see any reason to allow individual agencies to operate under different procedures) and understanding how the workers within agencies individually differ in their opinions as to what works best; neither of the options seem preferable. Are these the only USDA options? Can there not be a process that encourages clients to be responsible and accountable for their benefits while enabling the worker to do the job? Would that not empower both the worker as well as the client?