72. What is interim or semi-annual reporting?
“Interim reporting” or “semi-annual reporting” are basically the same thing: SNAP recipients approved for a one-year certification period with semi-annual or interim reporting period need only report changes to DTA twice a year, or semi-annually.
There is one very important exception to this 6 month 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, Charts 2 and 3. So, if your gross income before taxes 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 interim reporting, DTA will send you a notice explaining the rules and level of income you must report.
The households with interim reporting are households that have earned or unearned income or a history of income and homeless households. 106 C.M.R. § 366.110(C). This does not apply to households that receive TAFDC or EAEDC cash assistance, even if working, or are self-employed.
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)(5)(a)(2).
On the other hand, if you report an increase in income or decrease in rent or other expenses, under current rules, DTA will not reduce your benefits during the interim reporting period unless your income exceeds the gross income level. Otherwise, your benefits will continue at the initial amount for the reporting period. 106 C.M.R. § 366.110(C)(5)(a)(1). Again, the only time you are required to report changes is when your gross income goes above the gross income test for your household size (including new household members with income or a smaller household if someone left).
Example: Suzyn and her 3 kids are on “interim reporting.” She 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 at a local day care center. 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. Her total gross earnings are still below the gross income test (200% FPL) for her family of four. She calls her SNAP worker to report the increased income but 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.
Can DTA act on other information they get to change my SNAP benefits?
Under certain situations, DTA can make changes to your SNAP benefits during the middle of your 6 month interim reporting period, even if you did not report a change. DTA may adjust your benefits if they receive information from a reliable primary source that impacts your eligibility.
For example, DTA can adjust your SNAP benefits if they get confirmed information about the death of a family member through the Dept. of Public Health Vital Records, the removal of a child by the Dept. of Children or the incarceration of a family member from Dept. of Corrections. DTA can also act on information from SSA about a change in SSI or Social Security benefits. This information, from the primary source, is considered “verified upon receipt.”
Sometimes there are errors with these data matches. If your SNAP benefits decrease and nothing in your household has changed, contact an Advocate.
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 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.
About a year after your SNAP case is approved (6 months after your interim report) you will need to complete a recertification form, have an interview with your case manager and send in updated verifications. See Question 69 (How long will I get benefits before I have to reapply?).
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 generally will not lower the SNAP benefit amount. DTA will lower or terminate your SNAP benefits if your income exceeds the gross income limit, you report a change in who lives in your household or if they have received information from a data source that is “verified upon receipt”.
- 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.
Additional Policy Guidance on Semi-Annual or Interim Reporting:
- When DTA receives returned mail for semi-annual reporting households, address is updated and household will need to verify at interim report or recertification. Case should not be closed. Ops Memo 2013-13A (March 28, 2013).
- DTA will recalculate and possibly decrease of SNAP benefits when DTA obtains information considered “verified upon receipt” or when client reports household composition change. Ops Memo 2013-41 (July 26, 2013).
- DTA automated matching with Mass Lottery Commission, county prisons, Mass Dept. of Corrections and DPH/SSA/US Dept. of Commerce for death matches. Ops Memo 2013-27 (June 14, 2013).
- 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).
- 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).