Per the new regulation, households would not have to file an interim report but would have to file an application:
Interim report is front and back of one sheet of paper and comes pre-filled with household information. Current recertification application Part A and B forms contain six pages, do not come pre-filled with household information, ask questions not currently required for SNAP and are less “user friendly” for customers to understand and complete.
The intent of this regulatory action is to (1) eliminate the need for the LDSS to send an interim or periodic report form, (2) eliminate the need for the LDSS to evaluate completed reports, and (3) eliminate the need for the LDSS to close cases due to the recipient’s failure to return the completed report:
1. Currently the State DSS mails the initial interim report to the customer and the LDSS mails all recertification applications. If the requirement for mailing an interim report is replaced with the requirement to mail recertification applications and the LDSS retains responsibility for sending recertification applications, the costs for paper, envelopes, postage, manpower to prepare and mail, etc. will increase substantially for locals.
2.The need for LDSS to evaluate completed reports would be replaced with the need for LDSS to evaluate recertification applications. This is only replacing one need with another for the local worker.
3.The need for LDSS to close cases due to recipient’s failure to return a completed report would be replaced with the need for the LDSS to close the case when the recipient did not return the completed recertification application. Again, only replacing one need with another. Additionally, under current requirements, a recertification application filed after the certification period end date requires an expedited screening. If the same rules remained in place, this too would be an additional need on the local eligibility worker while at the same time decreasing the amount of benefits the household would be entitled to receive due to proration.
This regulatory action will set at six months the maximum certification period for households eligible for SNAP benefits in order to avoid periodic reporting requirements mandated by federal regulation.
At a time when caseloads are soaring and local eligibility workers are struggling to keep up with the demand for all benefit programs, eliminating the 24 month certification period will require eligibility workers to handle a portion of their case load twice as often.
The increasing caseloads, constantly changing policies, lack of consistent policy between programs and lagging technology makes it difficult for eligibility workers to maintain accuracy and timely processing. The increased demands will at some point make more consideration for the eligibility worker necessary to maintain high quality workers and commitments to excellence. Overall, this change does not seem to be one that benefits the recipient and could actually make the eligibility workers’ job more difficult. Please reconsider.
