Consideration of Deductions Not Received at Certification

It has come to our attention that there is confusion over the Quality Control application of the certification policy that allows state agencies to disallow deductions when the households fails to provide requested verification or fails to report an expense after being advised that failure to do so would result in the loss of a deduction. Attached for your reference are three certification policy memos on this subject dated 12-18-1998, 10-17-2005 and 2-25-2008 which provided guidance on this policy. The policy is being inappropriately handled in the following two circumstances by QC reviewers:

1. Some reviewers are using verified deductions that were excluded in accordance with certification policy in Comparison I when establishing the actual verified sample month circumstances. Comparison I considers the actual verified circumstances of a case and is used to compare the benefit allotment using those circumstances to the allotment authorized for the sample month. Using the deductions that should be excluded could cause cases to go through a more thorough examination than standard QC review would require or could cause the inappropriate exclusion of errors.
2. In Comparison II some states when faced with variances that have to be included have been pursuing verification of deductions that the households are not entitled to receive based upon what happened at certification (households did not report or provide verification). We have found that reviewers are inappropriately doing this in order to find offsetting deductions to errors identified during the QC review. An example of this is when a case has identified variances in income that need to be included, and the state decides to pursue medical expenses for the case, even though the household was not entitled to a medical deduction because the household had not reported or provided the necessary verification to receive the deduction. Inappropriately using deductions that the clients are not entitled to receive to offset other errors that are identified would result in underreporting of the States error rates.

Both of these situations would result in an inaccurate determination of the states error rate and would impact the accuracy of the National average. Therefore, this is to clarify that an excluded deduction should not be used in the Comparison I calculation for cases where a deduction was not provided at certification or recertification because the client failed to verify the expense or failed to provide the information needed to receive the deduction when the appropriate statements exist on the state’s application.

Furthermore, in doing Comparison II, the reviewer cannot seek out information to offset other identified variances by using information that is related to a deduction that was not received at certification or recertification when the client failed to verify the expense or failed to provide the information needed to receive the deduction when the appropriate statements exist on the state’s application.

In this situation, the client loses entitlement to the subject deductions and the increased benefits they could produce. This is and has been SNAP certification policy. The FNS 310 Handbook will be updated to reflect this the next time revisions are issued. The following are revised paragraphs for Comparison I. Please use these in place of the current language in the FNS 310 Handbook.

621 Comparison I. The first comparison is of an allotment computed based on the actual, verified budget month circumstances for items entitled to be considered in the benefit calculation to the authorized allotment. The reviewer must not determine whether there are any variances for the purposes of this comparison.

621.1 Using actual, verified income and deductions for the budget month for items entitled to be considered in the benefit calculation, the reviewer must compute an allotment. This figure must include any relevant annualized or prorated amounts, and any applicable standard (i.e., SUA, homeless shelter standard, etc.). As appropriate, income received on a weekly or bi-weekly basis must be converted to a monthly figure.

621.2 Then the reviewer must compare the allotment amount computed in 621.1 to the amount the eligibility worker authorized for the sample month.

621.3 If the difference between these two allotment amounts is $25 or less, the error determination process is over. There is no error in the allotment amount authorized for the sample month. The reviewer must use the actual verified budget month circumstances for completing column (2) of the computation sheet and must enter Code 1 in Item 8 of the Form FNS-380-1.

621.4 If the difference between these two allotment amounts is greater than $25, the reviewer shall proceed to Comparison II.

John Knaus
Acting Director
Program Accountability and Administration Division

Attachments

• FSP Policy Clarification: Deduction Language on Application and Reported Changes