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Waivers

In 2012–2013, we completed a research study in which two states administered a demonstration project to eliminate interviews for a sample group of the population. The study did not present persuasive evidence to support elimination of the interview as a standard process. However, you may wish to consider two waivers that involve interviews: the interview waiver for elderly/disabled households with no earned income and the on-demand interview waiver.

Interview Waivers for Elderly or Disabled Households with No Earned Income

Several states have requested waivers to forgo the requirement to conduct an interview at recertification for households that have no earned income and in which all adult members are elderly or disabled, provided the household meets all other recertification requirements.

  • When approved, we allow states to waive the interview scheduling requirements. 7 CFR 273.2(e)(2) and 273.14(b)(3)
  • The household may contain children or disabled children, but the presence of disabled children is not a criterion for the household to qualify for the waiver.
  • These waivers typically require alternative procedures by which you must continue to interview any household in this category that requests an interview or in situations with outstanding questions or issues.
  • Under this waiver, interviews at certification are still required.
  • You must provide these households with appropriate information on the excess medical deduction so that these households know how to claim this deduction.

On-Demand Interview Waivers

Many states request waivers to conduct unscheduled interviews or on-demand interviews. Waiver of 7 CFR 273.2(e)(3) and 7 CFR 273.14(b)(3)(iii)

  • When approved, we allow states to waive the interview scheduling requirements. Instead of scheduling a specific date and time for an interview, you provide households the option to complete a telephone interview at their convenience within a specified time.
  • These waivers typically require alternative procedures by which households have the option to complete a telephone interview at their convenience within 10 days.
  • Households receive a notice informing them to contact a call center during normal business hours within a set number of days, typically 10 days.
  • You must send a NOMI to applicants who do not complete their interview within those 10 days.
  • The NOMI instructs applicants to call for their interview by the 30th day from the application date, or the application will be denied.

To ensure good customer service and applicant access, we typically approve these waivers only if you meet the following requirements:

  • Inform applicants that you will schedule the interview or provide a face-to-face interview on request.
  • Screen all applications for expedited service, and process expedited service applications following the applicable procedures.
  • Repeat the instructions for completing the interview in the NOMI, and inform applicants of the date their application will be denied or benefits terminated if the interview is not completed.
  • Ensure sufficient administrative automation controls are in place, so the terms of this waiver are implemented efficiently. You must monitor and adjust phone system performance and staff adequacy to serve incoming calls, with dropped calls, wait time, and call completion time to conform with industry standards.
  • Provide us with specific administrative data reports at regular intervals. These data allow states and FNS to measure the waiver’s effect on applicant access, average interview wait times, timeliness, customer service, and other aspects of the certification process.

On-demand waivers have potential benefits:

  • When you have the staffing capacity and system resources to implement this waiver effectively, the process can provide a convenient and customer-friendly way to conduct interviews, especially for working households.
  • This waiver can provide administrative relief by reducing in-office wait times and decreasing the no-show rate for scheduled interviews.

States that have demonstrated positive outcomes with this waiver attribute their success to the following practices, resources, and technologies:

  • Before waiver implementation, establishing a call center that is fully functional, appropriately staffed, has the system capacity to handle a large volume of calls and can measure key aspects of customer service.
  • Prioritizing customer service and preventing unreasonable interview wait times.
  • Placing incoming calls not immediately connected with an eligibility worker for interview into a queue.
  • Providing approximate wait times for callers placed into a queue, allowing the customer to decide whether they should remain on the line or call back later.
  • An organizational understanding that callers expect telephone wait times to be shorter than in-office wait times and that prolonged call wait times cost applicants time and money.
  • Providing access to language lines, or an alternative for non-English speaking applicants.
  • Developing a system to monitor calls that enables managers to review performance and workflow and to adjust staff levels as needed to decrease call wait times.
  • Providing an independent, alternative phone number for applicants who wish to request a face-to-face interview to reduce confusion and decrease the overall incoming call volume for the on-demand call center.

States that have encountered challenges with on-demand waivers that hinder successful implementation indicate the following issues:

  • Call centers that are not fully functional and that fail to provide sufficient access to the interview.
  • Call centers that share the same network/system or number as that of the general state or local offices, causing congested phone lines, prolonged wait times, and system crashes.
  • Call systems that allow for voicemails; listening to messages can be time-consuming, and the content can be difficult to interpret or mistakenly deleted.
  • Failure to provide applicants the opportunity to interview face-to-face.
  • Failure to properly screen all applications for expedited service and lack of effort to contact potential expedited service households for interview, resulting in timeliness issues.

Allow Videoconference Interviews

A few states have requested waivers to allow the state to offer videoconference interviews in addition to in-person face-to-face and telephone interviews.

  • These waivers typically require alternative procedures by which states offer the videoconference interview as an additional option but must grant an in-person face-to-face interview if the household requests.
  • You must provide households with a secure and private platform for completing the interview, clear instructions for how to access the platform, and a telephone number to contact if the videoconference is disrupted.
  • You also must ensure the technology is sufficient to implement the waiver and must monitor videoconference performance, including dropped or unreliable connections, to ensure clients can complete the interview.

For more information on interview policy, best practices, or waivers, you should contact your FNS regional office.