Multi-Program Periodic Report Forms

Some state agencies have adopted a version of simplified reporting (SR) for other programs, such as Medicaid and the Temporary Assistance for Needy Families Program (TANF), and are using multi-program report forms for the various programs, including SNAP. A question has been asked whether multi-program reporting forms that request information required by the other programs but not by SNAP are permitted under SNAP regulations.

Use of a multi-program periodic report form is acceptable provided that it:

• Complies with SNAP regulations and policy concerning the information that SNAP households are required to report;
• Contains the features required to be included on a SR periodic report form; and
• Affords SNAP households the option of answering only those questions relevant to SNAP.

A brief discussion of these criteria follows.

SNAP SR Reporting Requirements

SNAP regulations at 7 CFR 273.12(a)(5) require SR households to report certain items on their periodic reports. These items appear at 7 CFR 273.12(a)(l)(i) through (vii). Included among the reportable changes are liquid resources over the $2,000 limit and acquisition of licensed vehicles not fully excludable under SNAP regulations. The Food and Nutrition Service (FNS) issued guidance on April 13, 2009 to not require SR households to report these resource changes in states that certify households under statewide categorical eligibility or use TANF vehicles rules.

Periodic Report Features

Among the provisions included in the SNAP final rule, published on Jan. 29, 2010 (75 FR 4912), which codified in the regulations program changes mandated by the Farm Security and Rural Investment Act of 2002, were new requirements for SR periodic report form, which are described at 7 CFR 273.12(b)(2). These new provisions for SR periodic forms must be implemented by state agencies by Aug. 1, 2010 and must:

• Be written in clear, simple language;
• Meet SNAP bilingual requirements;
• Specify the date that the report form is due;
• Explain the consequences of submitting a late or incomplete report;
• Explain the verification that households must provide;
• Inform the household where to call for help in completing the form;
• Include a statement to be signed by the household that the changes may result in reduction or termination of benefits;
• Briefly describe SNAP fraud penalties;
• List the changes in deductions that the state agency will postpone acting on, if the state has chosen that option; and
• If social security numbers (SSNs) are required, explain the state's authority and purpose in requiring SSNs, how SSNs will be used, and the effect of not providing SSNs.

Option to Answer SNAP Questions Only

While there is no restriction in the SNAP regulations that prohibits a state agency from using a multi-program report form, the report form must contain language that clearly affords the SNAP household the option of answering only those questions relevant to SNAP. Thus, the report form must clearly delineate those questions that are required for SNAP reporting purposes. This policy is based on the regulatory requirement at 7 CFR 27 3 .2(b)(l)(ix), which concerns multi-program applications.

Lizbeth Silbermann
Director
Program Development Division