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SNAP Policy Alert: New policy on "unaccessed SNAP and cash benefits" - DTA now taking benefits "off line" or "expunging" them

We are writing to alert you to two recent Operations Memos where DTA has decided that when SNAP benefits are not being used fast enough or are "un-accessed" - DTA has a process for first taking the SNAP benefits "offline" and, if they remain un-accessed, eventually taking them away permanently through "expungement." In addition, DTA has a shorter time frame for "expunging" unused cash assistance benefits. 
 
Operations Memo 2014-8 states that when SNAP benefits have "not been accessed for at least 4 months", the client will get a SNAP warning notice that tells clients they need to use their SNAP benefits within 180 days (6 months) or those benefits will no longer be available but that clients can ask for the benefits back (see Attachment A of the Ops Memo).  If the SNAP benefits are still not used at the end of 6 months, DTA will start taking the benefits "off line."  If the recipient does not use the benefits for a total of 365 consecutive days, then DTA will "expunge" the SNAP benefits - and they will be gone forever. For cash benefits, the time frame is much shorter--any cash benefits not accessed after 90 days are expunged.  Ops Memo 2014-8 emphasizes that if the household contacts DTA requesting restoration of the off-line benefits, DTA must restore those offline benefits within 48 hours. No verifications or forms are required to restore offline SNAP benefits. 
 
Operations Memo 2014-9 explains how case managers should handle restoring offline SNAP benefits or requests to restore expunged cash benefits. It also includes sample "Request to Restore Benefits" notices for cash and SNAP. Remember, clients do not need this form to get their SNAP benefits back "online"--they just need to tell their case manager at DTA.  Under this policy, DTA will NOT restore SNAP benefits that were expunged after 365 days of non-use, unless DTA made a mistake. A SNAP household can always get back her "off line" benefits any time and for any reason, but not once they are "expunged."  A cash recipient can request restoration of expunged cash benefits where the household verifies a temporary absence of less than 90 days, hospitalization or an emergency that prevented using the benefits for 90 days.
 
Why are SNAP or cash benefits not used right away?
  • Some SNAP recipients get the minimum $15 amount and often report they save up the amount to do a mega shop at a discount store (like BJs or CostCo), versus using the small amount at a corner store.
  • Some SNAP recipients are approved for benefits but not aware they were approved - for example, the EBT card never arrived in the mail and they did not know to contact DTA to find out what happened. This sometimes happens with the Bay State CAP SSI cases.  Or, the household lost the card and may be too embarrassed or frustrated to contact DTA for a replacement (keep in mind DTA can only charge a $5 fee against their EBT account if the card was received and actually used, and even then there are good cause waivers of the fee in DV situations.)
  • Some SNAP recipients are elderly and disabled and need help food shopping. They may not be aware they can get an "authorized representative" to help them shop and who can get a second EBT card ( the SNAP recipient can keep their own card too - they do not need to give up control of their benefits!). Here's a link to the DTA Authorized Representative Forms in English and Spanish.  A SNAP or cash assistance recipient can appoint a neighbor, friend or community group to receive a second EBT card to help with food shopping. (Note, a client is not required to give up use of their own EBT card just because they have an authorized rep. DTA can issue two EBT cards to the same EBT account).
We need your help tracking problems with this new DTA policy:
 
We've received a number of calls from individuals affected by this policy, including clients who have not been able to reach their workers to report they still need the benefits as well as individuals who have disabilities or other difficulties using their EBT cards to regularly go food shopping.  We'd like to know what Coalition members are hearing in the field. These policies are basically intended to identify recipients who may have moved out of state, died or no longer need their SNAP or cash benefits, as well as help persons who may need the benefits but have a hard time using them.  However, these new procedures may be harming SNAP or cash recipients who have valid reasons for not using their benefits immediately. The Operations Memos are confusing and these new policies may create new  access barriers for recipients who need help using benefits and/or cannot reach their DTA workers to get their benefits put back on line.  We will discuss these new "off-line" and "expungement" policies more at Tuesday's Boston SNAP Coalition meeting, March 28th from 10 to Noon, St Francis House.
 
Please contact your Local Legal Services office, or contact Vicky Negus (617 357 0700 x 315) or vnegus@mlri.org if you need help with cases where clients received offline benefit notices and who have been unable to resolve offline SNAP or cash issues with DTA.