DTA SNAP Policy Updates on Income Matches- The Work Number and Unemployment Insurance

In the past six weeks, DTA has issued over a dozen 2013 “Operations Memos” announcing policy changes to the SNAP and cash assistance programs.  The following DTA Operations Memos affect verification of income. Please let us know if you see any problems with implementation in your SNAP advocacy work. (This is one of a series of emails on recent policy changes.) 

1.       Verification of wage information through The Work Number – Operations Memo 2013-33: 

DTA now has access to real-time employer information about wages and dates of employment through an on-line entity known as The Work Number. This is a private service employers use to track and report employment information about an individual’s work status and wages for credit checks, benefits eligibility, etc.  It is generally available to employees who need proof of income or W-2 forms as well.  As Ops Memo 2013-33 notes, nationwide over 30% of employers are using The Work Number for employee information, typically larger employers like Wal-Mart, Target, FedEx, McDonald’s, Stop & Shop. You can search alphabetically here to see if a particular employer participates (although this may not be a complete list, and sometimes the parent company has a different name than the local business).

DTA is now able to access employment information (most recent wages, start and stop date of employment) this for SNAP and cash assistance clients whose employers participate.  DTA will get a match from The Work Number at application, recertification, interim reporting and other times. This can reduce the verifications DTA needs for SNAP clients whose employers participate.  If DTA gets wage info through The Work Number, the notice of SNAP approval or denial should state that.  Note: Earnings of a child under 18 in school do not count, nor do earnings under work study, SCSEP, Youthbuild, VISTA - see 106 CMR 363.220 363.230

Does a SNAP applicant need to provide wage stubs?  Maybe not!  Ask the client if she knows if his/her employer uses The Work Number, or check the link above.  (If a small employer, likely not.)  Whether or not the SNAP applicant knows, DTA automatically checks all SNAP and cash household members through The Work Number. If DTA gets the wage information, the VC-1 should not ask for the same earnings.  

While workers should be able to get information directly from The Work Number, DTA must also give clients a copy of anything in their case record (see pg. 8 of Ops Memo). If the employer does not participate, DTA will ask for wage information from the client or should offer to do a third party “collateral contact” if the household cannot get the wage information from the employer.

 2.       Verification of Unemployment Insurance (UI) Benefits or UI On-line  – Operations Memo 2013-29:   

 DTA and the Division of Unemployment Assistance have improved the data available to DTA to verify receipt and amount of UI benefits.  While DTA has always had access to the DUA data, it has often been delayed or inaccurate.  DUA has improved its on-line UI system and DTA has improved access to the UI information (also called UC) including the date, amount, frequency, expected duration of the UI claim, dependent care allowance and any UI money withheld (for ex, for child support obligations).  Ops Memo 2013-29 includes sample screens now available to DTA workers in a “Job Aid” provided to all DTA staff.

Under the SNAP and cash rules, UI income unfortunately not “earned” income – meaning that the household does not get the 20% earned income disregard.  However, if a UI claimant is paying out legally obligated child support, the child support taken out does not count for the gross income or net income SNAP tests

Does a SNAP applicant need to prove UI benefits?  NO! DTA should be using the UI Online screen for UI benefits verification all the time.  If the UI claims information provided by the client is different from the DUA information on line, DTA is supposed to contact DUA directly to resolve “discrepant” information (see pg 5 of Memo). DUA is supposed to respond within 3 days of the DTA inquiry (for example, the SNAP applicant claims the UI benefits have not started or the UI amount is different on the screen than the SNAP applicant states).   

Note: DTA should also be verifying receipt of child support through the DOR Child Support portal, and verifying Social Security (RSDI) and SSI directly through the SSA systems portals (SDX and BENDEX).  DTA should not routinely ask SNAP applicants or recipients to produce verification of these unearned income sources unless the SSA or DOR systems are down for some reason.  Please let us know if clients are being sent VC-1s asking for this information.