Policy Memo (204.92 KB)
| DATE: | December 8, 2022 |
| POLICY MEMO: | Quality Control Policy Memo 23-03 |
| SUBJECT: | Review Clarification for Cases with Back-to-Back Certification Extensions in 2020 or 2021 |
| TO: | All SNAP State Agencies All Regions |
The Food and Nutrition Service (FNS) determined there are Quality Control (QC) cases in the fiscal year 2022 active frame with back-to-back certification period extensions that have been treated inconsistently by QC reviewers. This memo is intended to clarify the QC procedures for cases that were impacted by these extensions.
The relevant authorities and adjustment periods under which certification period extensions were allowed are: the Families First Coronavirus Response Act (PL 116-127) (FFCRA) adjustments permitted by FNS beginning in March 2020; options allowed by the Continuing Appropriations Act, 2021 and Other Extensions Act (PL 116-159) (CR) beginning in October 2020; and the return to FFCRA adjustments permitted by FNS as early as April 2021.
Back-to-back certification period extensions for households were permissible, provided that the extensions either did not exceed 6 months total or, if they did, were provided under different statutory authorities or adjustment periods. Therefore, the existence of back-to-back certification period extensions does not automatically indicate that a case was ineligible. QC reviewers must determine when and under what authority or adjustment period each extension was granted to determine whether a case was ineligible.
Cases that received multiple back-to-back certification period extensions provided under the same statutory authority or adjustment period are ineligible if the extensions totaled more than 6 months. For example, if a case received a 6- month extension under FFCRA in April 2021, then was extended again without a recertification in October 2021, the case would be ineligible after the second extension. However, for cases such as this, that received back-to-back extensions under the FFCRA adjustment period exceeding 6 months total from April 2021 to December 2021, QC reviewers should apply a variance exclusion pursuant to regulations at 7 CFR 275.12(d)(2)(viii).
The attachment to this memo informs QC reviewers how to proceed with the review of cases affected by back-to-back certification period extensions and how to identify whether a case was eligible or ineligible.
State agencies with questions should contact their respective regional office representatives.
| Rachel Frisk Director Program Administration and Nutrition Division Supplemental Nutrition Assistance Program |
Sasha Gersten-Paal Director Program Development Division Supplemental Nutrition Assistance Program |