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SNAP Policy Update: DTA issues new "automated" procedures on DOR earnings matches and SSNs that will affect SNAP or cash assistance households

DTA has issued new guidance, Operations Memo 2014-24, that changes how DTA confirms information they get about a SNAP or cash recipient's new job, an increase in wages or a problem with a Social Security number (SSN).  DTA typically gets wage information from the Department of Revenue (DOR) and SSN information from the Social Security Administration (SSA). 
 
The main change in policy effective March 17, 2014 is that the information sharing between these two agencies is more automatic than before, and applicants and recipients will be asked to verify personal information that appears different between DTA and the DOR and SSA government data bases. This means that some SNAP or cash clients will receive letters from DTA asking them to resolve DOR or SSA information that does not match up or is "discrepant". These notices are sent by the BEACON computer system without the case manager requesting them. Further, BEACON will be programmed to automatically terminate or deny benefits if the DTA case manager neglects to timely "check off" that the match discrepancy has been resolved (see pg 4 of the Ops Memo).  
 
Mismatched or discrepant information could be due to many things - ranging from the employer giving incorrect information to DOR about wages or start date of work, DTA staff entering the wrong Federal Employer Identification Number (FEIN) or wrong start date in the BEACON computer system, SSA making a mistake entering identification information (such as date of birth or name spelling). Or, the difference in information could also be due to a client failing to report or giving inaccurate information (for example, forgetting to update DTA or SSA about a name change or start of work). 
 
Attached are two sample letters clients may receive.  
 
Here are some important things to keep in mind:
  • The federal and state SNAP and cash assistance regulations limit the scope of a sanction to the household member who refuses or fails to cooperate with the SSN requirements, not the entire SNAP or cash household. The Operations memo says that the entire household may be terminated or denied. This may be illegal.
  • It is critical to confirm with the case manager that he or she received the information and "dispositions" or resolve the match in order avoid the automatic BEACON case closure. Once these DOR or SSA match notices are sent to clients, the SNAP or cash assistance case will close automatically unless DTA case managers "check off" that the problem was resolved. 
  • SNAP households who are certified for 12 months and put on "interim" or semi-annual should not be getting the DOR Employment Verification notice (Attachment A) for new wages or increased wages received in between their semi-annual reporting periods - unless their gross income goes above 200% FPL.
  • SNAP households not on "interim" reporting should not get these notices unless they have earned income that changes more than $100 per month or unless the problem is with an incorrect FEIN. Households on "change reporting" are typically elder/disabled households certified for 24 months, and other households not on "interim reporting." 
  • Some clients may also show up in a DOR New Hire match -  even though they never got a new job, or did a 1-2 day job training but were then let go by the employer. Sometimes employers list individuals as "new hires" with DOR but do not correct that information if the job falls through or does not continue beyond Day 1. 
  • SSA and DTA may have discrepant information on a client due to a name change or mistake in data entry.  Other times, a parent and child with the same first and last name can get confused in the SSA SSN system. Sometimes SSA takes a while to correct information. Government agencies managing large amounts of data are not 100% perfect!
  • SNAP or cash recipients can ask their DTA case manager for help if they are confused about the notices, or cannot get the verifications needed: the case manager can check if the employer uses "The Work Number" (to see if current wage information is available); make a "collateral contact" directly to an employer to resolve mismatched information; or help a client get documents needed to resolve mismatched SSN information with SSA. 
Please flag any cases where clients receive these notices and are confused about what to do next, unable to verify the information requested, unable to get help from DTA to secure verifications. Flag cases of client who were terminated/ denied benefits - even though they provided information to their DTA case manager that was not acted on.  Contact Vicky Negus (x 315) or vnegus@mlri.org with cases that you believe were erroneously closed/denied. We want to monitor this carefully to ensure that otherwise eligible SNAP and cash households are not erroneously denied benefits.