Coalition meeting on Tuesday, June 26th
06/21/12
The next Food SNAP Coalition meeting is Tuesday, June 26th from 10 to Noon at St Francis House in Boston. The June agenda will include:
1. Update on Farm Bill 2012 deliberations: Brief summery of the amendments voted on by the U.S. Senate, the upcoming House deliberations (House Ag Committee mark up of Farm Bill 2012 scheduled for July 11th) and what we need to do in MA to protect benefits. Thank you all again for calling Senators Kerry and Brown and our Congressional Delegation members !!
2. Update on FY2012 State Budget: Brief discussion of the status of the Conference Committee and DTA/food program issues in play.
3. SNAP application processing: Follow up from meeting various Coalition members had with DTA Central regarding SNAP application concerns, review of DTA time frames for scheduling interviews, sending verification notices, etc.
4. SNAP immigrant eligibility refresher: Brief review of the key exemptions to the 5 year waiting period for legal permanent residents, parolees and battered immigrants (kids, disabled adults, work history) review of the eligibility of battered immigrants with pending VAWA petitions or pending applications for adjustment.
5. SNAP verifications and fraud related issues: Discussion of recent DTA guidance** re "questionable client information" and when DTA should ask for additional verifications and/or make a fraud referral.
** See DTA Hotline Q &A of May 2012 This June 2012 Hotline includes some scenarios of when DTA might seek more documentation and/or make a fraud referral. This June guidance does not cross reference other DTA guidance on verifications and what constitutes "questionable" information (Field Ops Memo 2010-29), nor review all the scenarios in which SNAP clients may have reasonable explanations for discrepancies between household income and claimed expenses. Situations where SNAP households often have expenses that exceed income include when the household just lost employment or other source of income, where the household is in arrears on rent or utilities, is borrowing against credit cards or from family or friends, is using up savings. SNAP applicants should be advised that DTA will ask how they are managing when household expenses exceed income. Additional proof should only required if the explanation provided is deemed to be inconsistent with other information the client has provided or other information in the case record or known to DTA. 106 CMR 361.620.
Time permitting, at the Coalition meeting we will also review the criteria for when a hearings officer may make a finding of "intentional program violation" (fraud) and the impact of an IPV on receipt of benefits. MLRI has been getting recent inquiries about SNAP households facing IPV disqualification hearings. An individual sanctioned for an IPV faces loss of benefits for 12 months for the first offense, longer if more. Anti-hunger advocates need to ensure clients give complete information on SNAP apps/recerts about all sources of income, expenses and information on all household members required (including those pesky 18 - 22 year old children who never left home and are mandatory household members regardless of sharing food). But advocates also need to understand that "discrepancies" in income vs expenses do not mean the client situation is necessarily fraudulent. Further, some alleged IPV cases can often be the result of misinformation/misunderstanding on reporting changes as well as the failure of DTA to record reported changes (failure to check voice mails, record verifications sent.) SNAP households should be advised of the importance of attending IPV hearings to challenge incorrect fraud claims, highlight DTA errors in the processing of their cases if that occurs, and try to protect themselves from loss of SNAP benefits and sanction. We will touch on some of the key issues around the IPV process and how you can best advise and protect clients.
See you on the 26th !!