72. What is interim or semi-annual reporting?
“Semi-Annual Reporting” and "Interim Reporting” are basically the same thing. SNAP recipients approved for a one-year certification period with semi-annual or interim reporting need only report changes to DTA twice a year (semi-annually). While some households have to report changes within 10 days of when they happen, households certified with a semi-annual or “interim” reporting period do not.
There is one very important exception to this rule: You must report during the six-month period if your income— including income of anyone who moves into your household— goes over the gross income limit for your household. 106 C.M.R. § 366.110(C)(3). See Appendix B: Income and Benefits Standards, Charts 2 and 3, for the gross income limits. If your income goes above the gross income limits, you must report this change right away—within ten (10) days after the change occurs. When you are approved for semi-annual/interim reporting, DTA will send you a notice explaining the rules and what level of income you must report.
The households usually assigned semi-annual/interim reporting are households that have earned or unearned income or a history of income—other than income from TAFDC or EAEDC cash assistance or self-employment—and homeless households. 106 C.M.R. § 366.110(C).
Reporting changes even if not required
Even though you are not required to report changes (as long as your income stays below the gross income limit), it may help to do so. If your income goes down or expenses go up, DTA is required to act on the information you report and increase your SNAP benefits. 106 C.M.R. § 366.110(C)(4)(a)(2). On the other hand, if you report an increase in income or decrease in rent or other expenses, DTA will not reduce your benefits during the semi-annual/interim reporting period. Your benefits will continue at the initial amount for the reporting period, as long as income remains below the gross income limit. 106 C.M.R. § 366.110(C)(4)(a)(1). This is the best of both worlds! Again, the only time DTA can stop benefits is when your gross income goes above the gross income test for your household.
Example: Suzyn is put on interim reporting and is not required to report any changes on her SNAP case for the next five months. The first month of her semi-annual period, she was working 30 hours a week. The second month, her employer reduced her time to 20 hours a week. If Suzyn reports the drop in earnings, DTA will recalculate her SNAP benefits using her lower wages. Suzyn will get more benefits because she reported the change in income. Her benefits will stay at the higher level, even if her employer increases her hours next month.
Example: Suzyn (above) is still working 30 hours a week but takes on another job for an additional 10 hours a week. Suzyn is also paying less rent as she was just approved for a subsidy. Her total gross earnings are still below the gross income test (200% FPL) for her family of four. She reports to DTA both the increased income and reduced shelter cost changes. DTA will not reduce her SNAP benefits until the start of the next interim reporting period. DTA will then recalculate her benefits at the next reporting period using the income and expenses she reports at that time.
What happens at the end of the semi-annual/interim period
Before the end of your six-month semi-annual/interim period, DTA will send you an interim reporting from to update your case. This form will be preprinted with the information about your household that DTA has in its records. You should update the information in the form, fill in any blanks (like your earnings) and send it back to DTA with required proofs (including your most recent pay stubs). You do not need any interview during the interim reporting unless DTA decides something is questionable.
If you do not send this form back or your benefits may stop. If you send in the interim report form late, DTA will treat it as a new application and can reopen your SNAP case - but the benefits will be prorated as of the date they received the report. However, if you got the interim report in on time, but you don't get the proofs in on time - you can still get your SNAP case reopened back to the date it was closed as long as you get the proofs in within 30 days. Bottom line: send in the report even if you don't have all of the proofs.
Which households do not have semi-annual/interim reporting
- Households where all members are elderly or have disabilities and have no earned income, or households which have never had any income source;
- Households where one or more members get TAFDC and must submit monthly income reports, or get TAFDC under a time-limit extension;
- Households with self-employment income; and
- Households getting five months of Transitional Benefits Alternative (TBA), after which they should then go on semi-annual reporting.
- It is a good idea for a household to report changes in income or expenses even if on semi-annual/interim reporting. If household income goes down or expenses go up, DTA will increase the benefits. However, if the income is higher or expenses lower, DTA will not lower the SNAP benefit amount (unless the income exceeds the gross income limit).
- For any households subject to an overpayment for failure to report a change in income or household status, be sure to check if the household was on or should have been on semi-annual/interim reporting. There is no overpayment for failure to report changes during the semi-annual period, unless the income exceeded the gross income limit.
- Able bodied adults without dependents (ABAWDs) should be put on semi-annual/interim reporting if they have income or a history of income, or are homeless. Because ARRA suspended the ABAWD work rule, these individuals are not required to be on change reporting.
Additional Policy Guidance on Semi-Annual or Interim Reporting:
- DTA will reopen SNAP benefits if missing verifications received within 30 day period after case closed as long as interim report received timely; if interim report was late, interim report becomes new SNAP application and benefits prorated. Transitions Hotline Q &A (March 2012)
- Self-employed households and households with no current earned or unearned income cannot be put on interim reporting. Transitions Hotline Q&A (Dec. 2011).
- DTA must act on changes in household size or other non-financial changes during interim reporting period even if it reduces SNAP benefits. Transitions Hotline Q&A (Sept 2011).
- Policy reconfirms one-year certification period (“annual reporting”) with interim (semiannual) reporting obligation for SNAP households with earned and unearned income. Ops Memo 2011-31 (July 6, 2011) and Ops Memo 2011-43 (Sept. 12, 2011).
- If household reports loss of income or increased expenses during semi-annual period, DTA must act to increase SNAP even before report due. Transitions Hotline Q&A (Aug. 2011).
- Re-certification forms pre-filled with household member information, address, shelter costs, child care, medical expenses; no need to re-verify most eligibility factors or expenses that have not changed. Ops Memo 2012-55 (Dec. 2012) and Field Operations Memo 2010-03 (Jan. 19, 2010).
- New verifications are not required if no changes reported in household expenses at USR time. If a change in expenses (shelter, medical) is reported without documentation, the expense will be zeroed out in the calculations. F.O. Memo 2010-55 (Nov. 23, 2010), Transitions Hotline Q&A (Nov. 2005).
- Applicant awaiting decision on Unemployment Insurance claim should still be put on semi-annual reporting; worker should open the case without counting the UI income if decision on UI claim not made by day 29. Transitions Hotline Q&A (Apr. 2004).