, DEPARTMENT OF HUMAN SERVICES

Economic Assistance and Employment Supports and Housing and Support Services Divisions

COVID-19 2020 Questions and Answers re: Cash and SNAP Programs

COVID-19 Questions and Answers Version 17 – 11/25/2020 1

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Contents Applications............................................................................................................................................................ 3

Appeals ................................................................................................................................................................... 9

Case Reviews .......................................................................................................................................................... 9

Client Access........................................................................................................................................................... 9

DWP to MFIP Conversion ..................................................................................................................................... 16

Disqualifications ................................................................................................................................................... 16

EBT........................................................................................................................................................................ 17

Emergency SNAP and Pandemic EBT ................................................................................................................... 18

Employment Services and SNAP E&T................................................................................................................... 24

External Communications .................................................................................................................................... 32

Funding................................................................................................................................................................. 32

Income and Budgeting ......................................................................................................................................... 32

MAXIS ................................................................................................................................................................... 38

MFIP Extensions ................................................................................................................................................... 39

Overpayments ...................................................................................................................................................... 40

Processing Changes and Negative Actions........................................................................................................... 42

Reviews and HRFs................................................................................................................................................. 54

Students ............................................................................................................................................................... 63

Unemployment Compensation ............................................................................................................................ 66

Verifications and Client Signatures ...................................................................................................................... 73

Training................................................................................................................................................................. 81

Key: Questions highlighted in yellow have been added. Questions highlighted in blue have been revised. CASH answers refer to MFIP, DWP, GA, MSA, RCA and Housing Support.

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Please see the COVID-19 Guide for Eligibility Workers for more detailed policy and system procedures

Applications 1. Question: Is the DWP Employment Plan requirement waived to approve applications?

Answer: Given that the Diversionary Work Program is intended to provide intensive job search services to divert families from MFIP, in a period of rapidly escalating unemployment, the program is unlikely to benefit any applicants. Enroll all applicants for cash assistance directly on the Minnesota Family Investment Program.

2. Question: Are there any ideas out there to give paper applications to clients without having people come into the office? This is especially important for rural areas where internet access is poor.

Answer: Paper applications can be put anywhere. For example, they can be put at libraries, grocery stores and anywhere else that the public may go. Counties and tribes are welcome to share ideas that you are doing. Please email them to DHS.SNAP-PAC.QA@state.mn.us.

Workers are able to complete applications over the phone with the client. Workers should ask all the questions on the CAF and have the client answer verbally. Worker should review all rights and responsibilities that they are required to cover during an interview. On the signature line write that this application was completed by phone, the date of the phone application and the phone number of the client. Workers should then send a copy of the completed application to the client. In the interview CASE/NOTE indicate clearly on the first line that the application was accepted over the phone and a verbal signature was accepted..

3. Question: If a signature is not present on an application, can we accept a client's verbal statement and add this to CASE/NOTEs?

Answer: A verbal signature is acceptable. CASE/NOTE the action taken. If an application is completed over the phone, on the signature line write that this application was completed by phone, the date and time of the application and the phone number of the client. CASE/NOTE the signature was received verbally.

4. Question: Do we still need to complete a face-to-face interview for cash programs?

Answer: No, do not require a face-to-face interview for cash programs at this time.

5. Question: What is the effective for accepting verbal applications over the phone?

Answer:

CASH: March 20, 2020. SNAP: March 1, 2020

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6. Question: A client who previously closed for 100% sanction has reapplied. Do they need to work with ES for 30 days to regain eligibility for cash assistance?

Answer: No. Participants have good cause due to the public health emergency and do not need to meet the 30 day compliance requirement for eligibility.

7. Question: How do we handle verifications for applications? Are we required to request verifications using the normal 10-day requirement or should we approve applications with verbal attestation so clients can get same-day approvals?

Answer:

CASH: Verify as much as you can electronically or through phone calls with third parties, such as employers. Allow signed personal statements as permitted under Combined Manual 10.03 – (Verification Cooperation and Consent) from applicants or participants. When you cannot get third party verifications electronically or through phone calls, use self-attestation for any required verification. This can be written or verbal attestation and should be documented in case notes. SNAP: Verbal verifications cannot be used as this time. Follow the current procedures for verifying mandatory and non-mandatory verifications found in all chapters of the Combined Manual 10 (Verifications). Complete the following steps:

1. Attempt to obtain verifications from the client either through mail or electronically if your office is closed.

2. If you are unable to obtain verifications directly from the client, obtain an authorization for release signature from the client to obtain the verifications through phone calls to third party sources.

3. If after all attempts to obtain the verification from the client and/or a third party source do not work, you can accept a client's written statement as verification as a last resort. Other than for immigration verifications, please see below for more informaiton.

8. Question: Should eligibility workers still send referrals to Employment Services?

Answer: Yes, however, participants have good cause for non-compliance due to the public health emergency.

9. Question: Specifically for CASH, if we do not receive the needed verifications (not even verbally), do we still deny at 30 days?

Answer: Yes, if you are not able to attain the verifications (including verbal attestations), deny the case. Attempt to verify as much as you can electronically or through phone calls with third parties, such as employers or landlords. When you cannot obtain verifications, use self-attestation for ANY required verification. Case note any verbal verifications received. Please see verifications section below and the Immigration Status Verification section of the COVID-19 Guide for more information regarding the reguired SAVE immigration verification process.

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10. Question: Household moved to Minnesota on 03/25/20 from Oregon. The agency confirmed that SNAP benefits in Oregon ended on 03/31/20 and no TANF was received. Should the 30-day residency requirement be waived during the COVID-19 public health emergency?

Answer: No changes have been made to the residency requirement for MFIP, DWP and GA (CM 11.06.09 – State Residence – 30 Day Requirement).

11. Question: We have applications that have been pending since before the COVID-19 scare started. Are we to go back and review all pending cases and push them through if they meet the minimum requirements? If not please tell us what application date this starts on.

Answer:

CASH: For applications that remain pending or are pended after March 20, 2020, you can use the new requirements for verifying information to process the application. Do not reinstate applications that have been denied previous to March 20, 2020. SNAP: At this time, there are no changes to verification requirements policies.

12. Question: Normally, if a client isn’t able to stay for an interview (or sent in their application), we send an appointment letter. If the client does not attend the scheduled interview, we send a Notice of Missed Interview. My questions are:

a. Is anything changing regarding notice requirements? Answer: Cash: No changes are being made with the interview process. An interview is allowed over the phone in all situations. SNAP: No changes are being made to notice requirements. Continue to schedule interviews and send NOMIs if clients do not attend.

b. If changes are not being made to notice requirements, how are workers determining what date to use for the appointment time, when all applications are mailed or faxed in, or submitted online? Answer: Notice requirements are not changing at this time. Follow your agency's procedures for scheduling interviews and sending NOMIs.

13. Question: Our Agency is working from home and does not have access to printers. There is not a way for us to type on the electronic version of CAF in eDocs, will case notes re: verbal signature suffice?

Answer: You should follow your agency’s process for processing CAFs over the phone. Document your process in CASE/NOTEs.

14. Question: Letter A states: "County, tribe, and community partner eligibility workers may complete an application over the phone when a potential applicant calls and expresses a need for help with cash. Eligibility staff should ask the caller if they wish to apply for assistance. If yes, complete the Combined Application Form (CAF) on the phone with the applicant, and CASE/NOTE that the applicant confirmed the accuracy of the information." If a call comes into an office at 4:15pm and our office closes at 4:30

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PM, can we set a PND1 application by filling out the CAF1 the date of the call and set the phone interview for the next business day?

Answer: Yes; capture the information you need to set the application date (CAF 1). Make sure to case note.

15. Question: If a client calls to say they want to apply for benefits, but we can’t call them back until the next day to fill out the CAF and complete the interview, is the date of application the date the client called to originally request benefits or the date we call them back to complete CAF and interview?

Answer: The information needed to set the date of the application is CAF page 1 which includes the client's name, address (or homeless indicator) and a verbal signature. The date of the application in this case would be the date the county agency or Tribal nation obtains this information.

16. Question: Can Office Support Staff (OSS) complete an application on the phone?

Answer: Office Support Staff (OSS) are able to assist applicants with setting the date of an application and filling out the entire CAF with the applicant over the phone. The OSS is allowed to take a verbal signature over the phone for application purposes only, and cannot complete the interview to determine eligibility for programs.

17. Question: Do we need a verbal signature from the client to set the date of the application?

Answer: A verbal or physical signature is needed to set the date of the application.

18. Question: Is it a requirement that counties and tribes have to offer a verbal application for SNAP and Cash programs?

Answer: Yes.

19. Question: Can we accept an unsigned CAF with all questions answered and accept a verbal signature during the interview?

Answer: CASH: Yes. The application date would be set once the verbal signature is given. SNAP: Yes, they can do this and then the county or tribal eligibility workers can complete the interview and get the electronic signature during the interview.

20. Question: SSA has closed their offices and limited services due to COVID-19. The SSA is not accepting new applications for SSN at this time. Therefore, some applicants, including people with refugee status, asylum status, Iraqi & Afghani Special Immigrant Visa, Victims of Trafficking, and Cuban/Haitian Entrants are not able to provide proof of applying for a SSN. How do we proceed in processing their application?

Answer: Good cause can be granted for not applying for a Social Security Number at this time and the participant can receive benefits, if they meet all other eligibility requirements. On the STAT/MEMB panel use the verification code "A" (Applied for SSN). Follow the guidance in POLI/TEMP TE02.08.081 (DAIL Message – SSN Not Verified) when using this code.

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21. Question: If an applicant is over income for cash (and we did a phone application with verbal signature and verifications) and eligible for SNAP, can we approve or do we need a signed application for approval since it is no longer MFIP? If so, what is the date of the application since we cannot take an application over the phone for SNAP?

Answer: Effective March 1, 2020 and ongoing, a verbal signature can be accepted for the client to apply for SNAP. If a cash application was taken verbally prior to being able to accept a verbal SNAP application, call the client and confirm that the client would like to add SNAP to their application. Be sure to ask the client any SNAP related questions if they were not asked during the cash application interview. CASE/NOTE the date, time and client's phone number of the verbal signature and verbal answers given for the SNAP related questions asked.

22. Question: For cash programs, have any of the requirements to apply for SSI been lifted or has the timeline been extended at all (can we give the 6 months to do so)?

Answer: The requirement to apply for other maintenance benefits has not been lifted for cash programs. Clients should still apply for SSI if they are able to do so. However, workers should apply good cause exemptions if clients are unable to obtain necessary medical appointments, documentation, or interact with Social Security Administration staff due to limited access as a result of the public health emergency. Do not delay approving cash benefits; approve cash benefits and inform the applicant that they should apply for SSI.

23. Question: Application was received today, 3/31/20, and the participant is requesting cash and claiming he will be doing out-patient treatment. Do we need to obtain a medical opinion form to verify he is unable to work? Or do we accept his self-attestation?

Answer: GA: No changes have been made to GA basis of eligibility. Follow the provisions in CM 13.15.12 (GA Basis - Placement in a Facility). All other cash programs: Verbal verifications are acceptable.

24. Question: Can an agency approve MFIP without allowing client time to provide completed child support referral forms? Verbal verifications can be accepted for MFIP at this time due to COVID-19, can child support referral forms also be verbally completed?

Answer: Yes, child support referral forms can be completed verbally. Clients are not required to complete child support referral forms prior to applications being approved. (CM 10.18.01 – Mandatory Verifications – Cash Assistance).

25. Question: For Cash, Bulletin 20-68-12 directs us to “ask the caller if they wish to apply for assistance” and if so, complete a phone interview and accept verbal signatures, verbal attestation and third party verifications. Can we direct people to the online CAF, ApplyMN, mail or email a CAF to the applicant?

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Answer: Clients have the right to choose how they wish to apply for benefits. Complete the application with the caller if they wish to apply immediately.

26. Question: How should we conduct an interview if we receive an application but the applicant does not have access to a phone?

Answer: DHS encourages counties and tribes to be flexible with completing interviews at this time. Please work with your county or tribal administrative office for a solution on how to handle interviews in these situations.

27. Question: The DHS instructions state that the client signature space on the CAF should be annotated with the Date, Time, and current phone number of the client as a way to represent that they have signed verbally. However, the eDocs version of the CAF wants an ID for the electronic signature. If we put in the client’s name, date, time, and phone number as a signature, the form prompts our workers for an email address and then it wants a password for the signature ID. Once that ID has been created, it is the same ID for all CAFs, so if a worker completes a new CAF with a new client and goes to complete the electronic signature for the client on the form, it populates the previously created ID (with the previous client’s name, date, time, and phone number). Is there another way to annotate the verbal signature with the client on the CAF in these situations?

Answer: If you are unable to annotate the date, time and phone number from the client on the CAF, please include the worker's signature in the client signature field and the worker signature field. Indicate the date, time and phone number of the verbal signature in CASE/NOTEs.

28. Question: Are we able to accept verbal applications for the Emergency General Assistance (EGA) and Emergency Assistance (EA) Programs?

Answer: Yes.

29. Question: How do we process an application for MFIP and Uncle Harry Food Support (UHFS) in regards to verbal attestation of verifications? Would we need actual verifications for UHFS but can accept verbal attestation of verifications for MFIP?

Answer: UHFS and SNAP have the same verification requirements. In the situation listed above, verbal attestations can be accepted for MFIP, but they cannot be accepted for UHFS.

30. Question: Have any other requirements for EGA and EA been waived due to the COVID-19 pandemic aside from being able to take a verbal application and signature?

Answer: Requirements for EGA and EA are determined by each county or tribe. Follow your county or tribal EGA plan or EA policies.

31. Question: Can you clarify if Eligibility Workers can help clients complete the application or recertification if the clients are having trouble completing this? Prior to COVID-19, we were told that OSS staff can help clients complete an application, but that eligibility workers should not due to a conflict of interest.

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Answer: Eligibility workers and OSS Staff can assist clients with completing an application/renewal over the phone. See the COVID-19 Guide for more information on processing verbal applications.

32. Question: Does the Lost Wages Assistance program count as liquid assets when determining if a client is eligible for Expedited SNAP? Answer: Yes this counts as an available resource as clients have access to this money to help meet their food needs.

Appeals 1. Question: What do agencies do about scheduled appeals where workers are working remotely without

cell phone access at this time? Can they be rescheduled?

Answer: If a participant or county representative is unable to attend, follow the current appeals good cause process.

Case Reviews 1. Question: Will SNAP Quality Control (QC) and Management Evaluation (ME) relax their case review

requirements at this time?

Answer: The ME team will not be reviewing ABAWDs this year. In addition, the SNAP ME will be reaching out to the agencies currently participating in the 2020 SNAP-ME review to discuss any changes to the process. QC is currently conducting all interviews over the phone and will not be reviewing cases in March, April and May. There are no other changes to the case review process at this time.

2. Question: Do we have any information if CASH audits will continue or what the plan is for them?

Answer: PC&A is continuing the normal audits of HC, TANF, CCAP, GA, Housing Support, and MSA. They will make changes in how errors or deficiencies are determined according to the effective date of the new changes and processes.

3. Question: How will TANF case file reviews be done?

Answer: TANF reviews will be conducted in the same manner as they have previously been, and will take into account any policy or procedural changes that have been implemented during the COVID-19 state of emergency.

Case files are randomly selected based on whether there were federal work participation (WPR) hours reported in the month of review. If hours are reported in MAXIS or WF1, the hours must be documented and verified in the case files (WF1 EDS). Any information about documentation/verification, activity logs, work hours, and good cause should be case noted in Workforce One.

Client Access 1. Question: Are considerations being made to waive months on MFIP during this peacetime state of

emergency?

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Answer: Yes, considerations are being made at the federal level. However, at this time, we are not waiving the TANF time limit.

2. Question: What is the name of the law that was recently passed by Congress?

Answer: The Families First Coronavirus Response Act (Public Law 116-127). It was signed into law on March 18, 2020.

3. Question: What if counties or tribes do not have a drop box outside for clients to drop paperwork off?

Answer: DHS is encouraging counties and tribes to set up a drop box if they do not have one. Counties and tribes that use drop boxes should share the details of how they are used so the information can be shared statewide. Please email any information you would like to share to DHS.SNAP-PAC.QA@state.mn.us. In addition, if you would like a letter from DHS encouraging that you have a drop box we can provide that.

4. Question: Some food banks are closing due to safety concerns. Will there be more funding available for SNAP to cover the increase needs due to these closures?

Answer: The Minnesota Food HelpLine (1-888-711-1151) can connect individuals and families to food shelves, meal programs, and food resources in their community. You can also find a listing of food shelves, meal programs, and other food resources on the Hunger Solutions Minnesota website.

The Families First Coronavirus Response Act includes:

• A general provision that allows the Department of Agriculture to approve state plans to provide emergency SNAP benefits to households with children who would otherwise receive free or reduced-price meals if not for their schools being closed due to the COVID-19 emergency. In order to be eligible, the child’s school must be closed for no less than 5 consecutive days.

• $500 million for the Special Supplemental Nutrition Program for Women Infants and Children (WIC) to provide access to nutritious foods to low-income pregnant women or mothers with young children who lose their jobs or are laid off due to the COVID-19 emergency.

• $400 million for The Emergency Food Assistance Program (TEFAP) to assist local food banks to meet increased demand for low-income Americans during the emergency.

• In the event of a COVID-19 public health emergency declaration by the Secretary of Health and Human Services and a COVID-19 emergency or disaster declaration by a state, the Secretary of Agriculture:

o shall provide, at the request of a state agency, emergency allotments to SNAP households to address temporary food needs not greater than the applicable maximum monthly allotment for the household size, and

o may adjust issuance methods and application and reporting requirements to be consistent with what is practicable under actual conditions in affected areas.

The Minnesota Legislature has approved $9 million for the Minnesota Food Shelf Program to address food banks, food shelves, and transportation needs during the COVID-19 pandemic.

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5. Question: Can a county social service agency close completely to the public?

Answer: The state has not yet issued guidance on this. This is a county decision at this time. Please refer to Governor Walz Emergency Executive Order 20-20 for Critical and Essential and your county or tribe for further guidance.

6. Question: Are there issues with eligibility workers working from home?

Answer: DHS does not have an issue with this. Be sure that you are following data privacy laws, ensuring participants' information is protected.

7. Question: If a client's case is converted from DWP to MFIP without the MTAF, will these months count against the TANF time limit?

Answer: Yes, any months a client receives MFIP will count against their TANF time limit, unless they meet a reason to not have a month count.

8. Question: Are we still approving significant changes?

Answer: Yes.

9. Question: During the COVID-19 emergency, can a client use a significant change more than twice in 12 months?

Answer: Not at this time.

10. Question: Can a Case manager from our Public Health unit be the client’s SNAP authorized representative without anything in writing from the client - just a verbal confirmation from the client?

Answer: There are three types of AREPS: 1) A person authorized to act on behalf of a household in the application and reporting process, 2) A person authorized to obtain a person’s SNAP benefits on their own EBT card, and 3) A person authorized to use the SNAP benefits on the client’s EBT card. This answer applies to AREPs designated in #2 and #3 above.

The client should choose someone they trust to access their EBT benefits. The designated AREP cannot be disqualified for an Intentional Program Violation, be a person involved in the certification or issuance processes of SNAP eligibility, or be a retailer who are authorized to accept SNAP benefits. This designation can be made verbally over the phone. Please review the COVID-19 Guide for steps in how to complete this process and what information must be given to the client and the newly designated AREP.

11. Question: Can SNAP clients now use their benefits to buy diapers and toilet paper. Is this true? If yes, can they start using their benefits now for these items or do we need FNS/USDA approval?

Answer: No changes have been made to what clients can use their SNAP EBT benefits to purchase. For a list of items that can be purchased with SNAP EBT benefits, see the Eligible Food Items article on FNS' website.

12. Question: For the 15% increase for Housing Support, is any action needed for workers to approve this?

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Answer: Workers do not need to take any action regarding the temporary 15% increase. The increased payments to Housing Support providers will be issued directly to providers and tracked by DHS outside of MAXIS and MMIS. Specific information regarding the issuance, allowable expenses, and tracking of the temporary 15% increase will be communicated to providers by the county or tribal Housing Support contact person who oversees their Housing Support agreement.

13. Question: We received a phone call from a participant who is currently active on SNAP, stating that she was told she is also eligible for emergency SNAP. I am really confused as to what she is referring to, other than expedited. She is not eligible for expedited since she is currently active. Is there another program for SNAP out there that we are missing?

Answer: This is a program that is approved by FNS to increase the SNAP allotment to the maximum amount for the unit's size. This has been approved for a two month time period. DHS is issuing these supplements to clients. No action is needed from workers at this time.

14. Question: For sanctioned MFIP cases for March and April should they continue to be vendor paid?

Answer: Continue vendor payments however, if the client requests the vendoring to stop, you may remove the vendor payment for the next available month.

15. Question: Are we waiving mandatory vendor payments for MFIP drug felons during the COVID-19/public health emergency?

Answer: Policy surrounding mandatory vendor payments for drug felons has not changed. (CM 11.27.03 – Drug Felons and 24.09 – Protective and Vendor Payments)

16. Question: When we removed the MFIP sanctions and issued supplements for 3/20 and/or removed the sanctions for 4/20, we coded EMPS with the “UN” code allowing “good cause” for noncompliance and removed the sanction.

a. Should we continue to leave the “UN” code on EMPS for these cases after the sanction removal actions were completed? OR should EMPS be updated again once the sanctions are removed?

Answer: The UN code on EMPS does not come into play when curing sanctions for good cause. If UN was entered solely to remove a sanction, remove it from EMPS. Good cause reasons for failure to comply can be found in the Combined Manual 28.18 (Good Cause for Non-Compliance – MFIP/DWP), 28.18.01 (MFIP Good Cause – Caregivers Under 20), 28.18.02 (MFIP Good Cause – Child Care) and 30.12.06 (RCA Employment Services Good Cause Claims). Refer to “J” in Bulletin 20-68-12C.

b. We were directed to code the EMPS as “UN” to convert all DWP pending and active cases (for 5/1/20) to MFIP. We were instructed to leave that code on the EMPS even after the conversion. “UN” would be used to give a person an MFIP extension reason who otherwise might not be eligible due to more than 60 months of MFIP or their other extension reason is expiring. Are there other reasons we would use the “UN” code on the EMPS? Maybe for reasons that would affect the case or reports such as WPR or Self-support Index?

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Answer: During the public health emergency, the UN code can be used as follows:

• to convert a case from DWP to MFIP. Refer to “I” in Bulletin 20-68-12C; • for FSS eligibility or; • as an extension reason if no other extension category applies.

c. Will the “UN” in EMPS help the State with reports or to determine actions needed after the current emergency changes end?

Answer: Yes, we are maintaining this coding in order to pull data on these cases (prior to the public health emergency there were only 12 cases in UN statewide).

17. Question: For Housing Support, if a client is at home with family for an extended visit (past 18 days) due to COVID-19, do we continue to keep the client open on Housing Support even if it is past the 18 day hold bed stay? If yes, will we be issuing overpayments later then?

Answer: Housing Support payments for people who are temporarily absent due to offsite quarantine, isolation, as well as hospitalization due to COVID-19 or other non COVID-19 conditions, are eligible for extension beyond the current absent day limit of 18 days or 60 days in a calendar year. These reasons for temporary absences do not require prior county approval. Case note the reason for any absences extended under these circumstances and do not issue overpayments.

The client obligation and state payments toward room and board do not change during the extended absence period.

This change is authorized for up to three months, effective immediately. Workers should direct their questions on this temporary absence policy to dhs.dhs.grh@state.mn.us.

18. Question: Could a client receive SNAP benefits while still receiving Housing Support benefits but temporarily living at home with a family member (extended stay) due to the COVID-19 absence day policy waiver?

Answer: Yes. If the client is within the ages of 18-22 years old they would be a mandatory unit member with their family in which they are temporarily residing. If the client is 22 years old (birth month) or older and can purchase and prepare food by themselves they may be eligible for SNAP as a household member of 1 and only their income would be counted towards the SNAP benefit amount. Please make sure to have a FMED panel and DISA panel if applicable. No updates should be made to the SHEL panel since the client is temporary absence in the Housing Support setting and is still paying the client obligation or the lease agreement amount monthly.

19. Question: Will there be any changes to the Cash asset policy during COVID-19 Emergency? Specifically will any retained stimulus or Federal Pandemic Unemployment Compensation be excluded for any length of time?

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Answer: The Federal CARES Act payments should not be counted as an asset if retained. If there are any case specific questions related to this, please submit a PQ.

The Federal Pandemic Unemployment Compensation of $600 per week is counted both as unearned income and should also be counted as an asset if retained.

20. Question: In regards to the Online Purchasing Program, will cash assistance also be able to be used for online purchasing for items? Such as diapers or toilet paper?

Answer: No. Cash benefits cannot be used for online purchasing.

21. Question: Do we know when the waivers for cash programs are set to end?

Answer: Waivers will be in place for the duration of the public health emergency.

22. Question: The RCA extended eligibility bulletin #20-06-01 policy mentioned extending active cases and requalify individuals previously on RCA. Can someone who was never on RCA qualify for this extension, too?

Answer: Yes. Individuals who became RCA eligible on or after April 1, 2019 may qualify for the temporary RCA eligibility extension through September 30, 2020.

These are two examples where people not previously on RCA may qualify for RCA under this extension.

Example 1: An 18 year old refugee adult child with an entry date of 04/05/2019. Was on MFIP and attending full time High School. Turned 19 in June 2019. He is not continuing with school. The adult child is RCA eligible starting July 2019, the adult child is eligible to be review for the RCA extended policy from date of application through September 30, 2020.

Example 2: An asylum seeker was granted asylee status on April 20, 2019, but was never on RCA because she was working and did not need RCA. Now, during the COVID-19 health emergency, she lost her job. She is eligible to be review for the RCA extended policy from the date of application through September 30, 2020.

23. Question: During the public health emergency, can we automatically approve all GA applicants using the unemployable basis of eligibility?

Answer: No. DHS Bulletin #20-68-12C states that during the public health emergency, all MFIP households reaching their 60th month should be designated as unemployable. This provision does not apply to the GA program. To receive GA, applicants must meet a basis of eligibility. This must be verified according to section C of Bulletin 20-68-12C. No applicant is “automatically eligible” for GA.

24. Question: Are people released from incarceration due to a COVID-19 medical condition potentially eligible for GA?

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Answer: People with a COVID-19 conditional medical release from incarceration are potentially eligible for GA under the performing court ordered service basis. The conditional medical release document is sufficient verification, or you can accept the client’s self-attestation.

25. Question: Is DWP program expected to return and if so when?

Answer: Yes, DWP is expected to return. The current peacetime emergency is set to end December 14th, however, we do not know if it will be extended or for how long. Once the peacetime emergency ends there will be a 60-day wind down period when additional guidance will be provided.

26. Question: Our County typically administers the required random UA testing for SNAP/Cash once a year (it has been September the last 2 years). Are there any exceptions to this during the COVID-19 peacetime emergency?

Answer: No changes have been made to the Drug Felon policy. Follow your county procedures.

27. Question: If someone was in a sanction on their 60th month, can they come back in during COVID and apply for MFIP? And, be eligible?

Answer: The answer depends on when the case’s 60th month was. The DHS public health emergency waiver went into effect on 03/20/20. That means if the case was sanctioned:

• In the 60th month prior to the public health emergency and the family reapplies during the COVID-19 waiver period, then the family will not be eligible as the closure is considered a statutory permanent disqualification for MFIP. The sanction should also be reviewed for good cause.

• In the 60th month during the COVID-19 waivers period that started 3/20/2020, then the family should not have been sanctioned. Therefore, this sanction should be removed and the family will be eligible by granting good cause for failure to comply during the waiver period. Approve MFIP if all other eligibility criteria are met.

If you have case specific questions, please submit a PolicyQuest.

28. Question: If someone is due for a child support good cause redetermination, we send the documents but do not receive anything back, is it denied or do we do something else during the peacetime emergency?

Answer: Child support good cause redeterminations are not covered by the COVID-19 waivers. Follow normal procedures. This is determined at the county level.

29. Question: Can clients receiving $0 in SNAP benefits receive FDPIR at the same time or can they only receive SNAP due to receiving E-SNAP supplements?

Answer: Clients cannot receive E-SNAP and FDPIR at the same time.

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DWP to MFIP Conversion 1. Question: The bulletin states to convert all DWP cases to MFIP by May 1st if they meet eligibility

requirements. If they do not meet MFIP eligibility requirements, do we keep them on DWP through their 4th month even if that extends past May 1st?

Answer: If the client is not eligible for MFIP beginning May 1st, do not convert the case from DWP but allow the family to receive their 4th month of DWP benefits. An auto-close job will run and close the case after 4 months of DWP eligibility.

2. Question: If by converting DWP to MFIP it reduces benefits since the client is employed, should we still convert the case to MFIP?

Answer: Yes. Beginning May 1st, 2020, we will only look at MFIP eligibility.

3. Question: Client was approved for DWP prior to guidance to open MFIP. Now the client is receiving $442 per week unemployment, she was receiving a full DWP grant, do we open MFIP for May and fiat the income out?

Answer: If the client was approved for DWP and is not eligible for MFIP, continue on DWP. If the client is eligible for MFIP, convert the case. Refer to the COVID-19 Guide for how to process this case.

4. Question: Should eligibility workers be FIATing the funding for those clients that would otherwise be Federal funded and receiving DWP? Currently they switch to State funding when FIATing to convert the case from DWP to MFIP.

Answer: No, eligibility workers should not be FIATing cases. Follow the instructions in the COVID-19 Eligibility Worker Guide for converting cases from DWP to MFIP.

Disqualifications 1. Question: Client is pregnant and applying for SNAP. She is the only person in the household and is

disqualified until August. Are we changing any disqualification rules due to COVID-19?

Answer: No rules are changing for SNAP disqualifications at this time.

2. Question: I have a case that has a disqualification set to start for 4/20 for member 01 due to signed IPV.

Answer: Policy on disqualifications remains unchanged. Follow CM 25.24.06 (Disqualification for Fraud).

3. Question: We have a case that was disqualified due to fraud in March and the disqualification is scheduled to begin 4/2020. Is there any impact on those cases? Should we continue to implement the disqualification or should that be delayed?

Answer: CASH: Yes, continue to implement the disqualification. SNAP: No changes are being made to the rules regarding disqualifications at this time.

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4. Question: If we have clients that are currently disqualified due to fraud. If they try to reapply for programs should we continue the disqualification or will the time be waived due to the current situation?

Answer: Disqualifications are not being waived at this time.

5. Question: The Guide states what override reason to use for closing SNAP after 10-day cut-off but not what reason to use for DWP. Which of these should be used?

Answer: May benefits have been issued. Follow the process outlined in the COVID-19 Worker Guide to convert cases from MFIP to DWP for June and ongoing.

6. Question: Do voluntary quit rules still apply for SNAP?

Answer: The policy for voluntary quit has not changed. However, during the COVID-19 pandemic good cause can be granted for a multitude of related reasons. This can include but is not limited to being at high risk and not feeling safe at work. If you are unsure if good cause can be granted, please submit a Policy Quest.

7. Question: Is a fraud disqualification required to close, deny, or reduce SNAP and/or CASH benefits or just a finding of fraud? Version 5 of the Q&A does not specify a disqualification is required but does refer to Bulletin #20-68-12C which does indicate a disqualification is required.

Answer: You can decrease benefits due to a fraud DISQ allowing proper notice.No changes have been made to the disqualification policy. Please see CM 25.24.06 (Disqualification for Fraud) and 25.24.07 (Disqualification for Illegal Use of SNAP) for more information on how to disqualify someone for fraud. If you have a case specific fraud question related to COVID-19, please submit a Policy Quest.

EBT 1. Question: With offices closed to the public, are there any changes to our obligation to issue EBT cards

for expedited cases that don’t have active accounts?

Answer: If a county or tribal office is closed to the public but the agency needs to issue a card immediately agencies should mail the EBT card to the client. See the SIR Announcement on 03/24/2020 for more information.

2. Question: Are there any options for clients to purchase groceries online if they are at high risk and do not want to go to the store?

Answer: Clients can use their SNAP benefits to purchase groceries online through Amazon or Walmart. Below are some details about the Online Purchasing Program:

• The online option is only available with the two currently approved retailers; Amazon and Walmart. Retailers must go through an approval process with FNS. Retailers who are interested in

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becoming approved by FNS should visit https://www.fns.usda.gov/snap/retailer-requirements-provide-online-purchasing for more information.

• Cash assistance cannot be used to purchase items online – only SNAP benefits can be used for online purchasing of eligible foods.

• Clients will need to use their PIN when purchasing groceries online. • Participants will need to pay for delivery fees and taxes (if applicable) with another electronic

payment source (credit card or debit card, PayPal). Clients will need to check pickup options and delivery availability for their area with each specific retailer.

• Neither SNAP or cash benefits can be used to pay for fees of any type, such as delivery, service, or convenience fees.

• Online EBT will remain a permanent option that SNAP recipients may choose to purchase food items. • More information about creating an online account through Amazon can be found on Amazon's

website. • Clients must use https://grocery.walmart.com/ to purchase groceries online with their EBT card from

Walmart. • More information is available for the public here: https://mn.gov/dhs/snap-changes/#sect2.

3. Question: Can a case manager from our public health unit use a client's EBT card to purchase groceries for them if the client is in isolation/quarantine? If so, can they use the client's card without getting an additional card for themselves?

Answer: Yes. The client would need to contact their county or tribal eligibility worker and request to have the case manager added as an AREP.

4. Question: Can you mail someone authorized to use a client's SNAP EBT benefits on their behalf an EBT card from the county or tribal office?

Answer: No. Counties and tribes can only issue a card for the head of household if they meet the criteria for agency issuance in the EBT Cheat Sheet on SIR. All other cards must sent via mail from ebtEDGE.

5. Question: We have a client that is worried he can’t get out to spend the cash on his EBT card. Is there a way to stop cash benefits from being cancelled during this stay at home time?

Answer: No, refer to POLI/TEMP TE16.03 (EBT – Aging of Benefits). Clients do have the option to set up direct deposit to have the Cash deposited into their bank accounts. This can be changed back to having the benefits issued on their EBT cards at any time. See TE02.11.111 (Client Direct Deposit) for more information.

Emergency SNAP and Pandemic EBT 1. Question: What are the new SNAP programs for COVID-19?

Answer:

There are two new programs, Emergency SNAP (E-SNAP) and Pandemic EBT (P-EBT).

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-E-SNAP allows all SNAP and Uncle Harry Food Support (UHFS) units who are not currently at the maximum allotment to receive additional food benefits. The additional benefits is the difference between what they already received, and the maximum allotment for their assistance unit size. The supplement is currently available for March – November and may be extended. The program for these supplements is Emergency SNAP, or E-SNAP. The maximum benefit amounts can be found at CM 22.12.01 (How to Calculate Benefit Level – SNAP/MSA/GRH). DHS staff will administer the supplemental benefits and no action is needed from workers at this time. Here are some of the details about the program and the issuance of the supplements:

• The increase in benefits will be issued by DHS staff as a supplement through the use of MONY/CHCK. DHS will start by issuing supplements one month at a time. Once the supplemental benefits are issued, DHS staff will:

o Post the following CASE/NOTE on each case:

A supplement was issued today in MONY/CHCK for the difference between the maximum SNAP allotment for this household size, and the actual benefits issued to this household. This food benefit will be available on the households EBT card the day after approval. No action is needed by the eligibility worker related to this additional benefit.

o Issue a SPEC/MEMO to each household with the following text for March:

You are receiving additional SNAP benefits allowed under the federal Families First Coronavirus Response Act signed into law on March 18, 2020. This additional benefit will not count against any other public assistance benefit that you are receiving. The benefit was issued on your existing EBT card, and must be used only for food.

o Issue a SPEC/MEMO to each household with the following text for April and ongoing:

SNAP You are receiving additional SNAP benefits allowed under the federal Families First Coronavirus Response Act signed into law on March 18, 2020. This additional benefit will not count against any other public assistance benefit that you are receiving. The benefit was issued on your existing EBT card, and must be used only for food. For your benefit amount, please check your EBT account through the EBT cardholder portal, EBT FIS App, or by calling the EBT customer service number located on the back of your card.

MFIP Food You are receiving additional SNAP benefits allowed under the federal Families First Coronavirus Response Act signed into law on March 18, 2020. This additional benefit will not count against any other public assistance benefit that you are receiving. The benefit was issued on your existing EBT card, and must be used only for food. For your benefit amount, please check your EBT account through the EBT cardholder portal, EBT FIS App, or by calling the EBT customer service number located on the back of your card. Due to the current public health emergency, you do not have to report changes or submit monthly Household Report Forms for MFIP. You have the right to report

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changes that would allow your benefits to be increased. You will not be held responsible for any cash assistance overpayments caused by local agency, DHS, or system errors.

• If a case already received the maximum allotment for their unit size for the month the supplement is issued they will not be eligible for E-SNAP.

• DHS will continue to provide updates on issuance for ongoing months through SIR announcements.

• Information regarding Minnesota's E-SNAP issuance plan will be updated on the DHS Website.

P-EBT is a new program authorized by the Families First Coronavirus Response Act (FFCRA) that provides assistance to families of children eligible for free or reduced-price meals dealing with school closures. Below are details about the program: • The issuance of these benefits is being automated by MN.IT staff at the Minnesota Department of

Human Services. There is no action needed from eligibility workers at this time. • Clients who were approved for and receiving SNAP or MFIP benefits on March 18 will receive a

one-time payment of $325 per every child in their unit age 5-18 (Age 5 by 09/01/2019). These clients do NOT need to apply for P-EBT benefits. If clients were approved for SNAP or MFIP after March 18, even if they applied for benefits prior, they will not be eligible for this automatic issuance.

• The P-EBT issuance will be issued based on the household composition approved in March. This includes children that were approved on the case in March but have since moved out of the home. If there were children not added to the case until after March, even if they were added retroactively, the client will not be eligible for additional benefits for those children through the SNAP/MFIP automatic issuance.

• The P-EBT issuance includes cases where the unit only received the MFIP Housing Grant or received prorated SNAP or MFIP benefits. This does not include SNAP cases that are eligible for $0 in benefits.

• Eligible SNAP and MFIP participants will automatically receive these benefits on their EBT card. Due to time constraints, no notice will be sent to clients notifying them of this payment. However, the following CASE/NOTE will be entered when a client is approved for these benefits:

P-EBT Issuance A P-EBT benefit has been issued on this case for all eligible months. This food benefit will be available on the household’s EBT card the day after issuance. No action is needed by the eligibility worker related to this additional benefit. Following Federal COVID-19 rules, the household benefit is determined by the Federal reimbursement value of school meals for each eligible child in the household. Participants can check the amount of the P-EBT benefit through the EBT cardholder portal, the FIS EBT App or by calling the EBT Customer Service line listed on the back of their EBT card.

• These payments will not show on MONY/INQD. • P-EBT recipients can only use these benefits to purchase eligible food items. A list of eligible food

items can be found on the Food and Nutrition Services' website.

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• No overpayments should be cited for these benefits, even if the unit was incorrectly determined as eligible for SNAP or MFIP in March.

• If a family was not approved for and receiving SNAP or MFIP on March 18, but had children receiving free or reduced-price school lunches/breakfasts during the school year, they can complete an online application for P-EBT here: https://mn.p-ebt.org/en/. They have until July 31 to apply. Families eligible for P-EBT benefits through this application process will receive the benefits on a separate card, known as a "P-EBT card." The P-EBT card can be used just like SNAP benefits loaded onto an EBT card. It takes 30 days from the date the family applies to receive this card.

• Families that did receive P-EBT through the SNAP/MFIP automatic issuance, but did not receive it for a child due household composition changes can apply online for P-EBT benefits for that child. They will need to answer "No" to the first question (Did your household receive SNAP/FS/EBT food benefits or Minnesota's Family Investment Program (MFIP) benefits in March 2020?) to let them proceed with the application. They should also be instructed to only list the children that they did not receive P-EBT benefits for on this online applications.

• DHS has also received approval from USDA to expand the P-EBT program to children in Pre-K. o The Pre-K student must have been enrolled in a district Pre-K program that were receiving

free/reduced school lunch prior to the COVID-19 pandemic. o Families will need to use the online application to complete an additional application for

these children if they did not list them on their initial application, or did not receive benefits for these children with the SNAP/MFIP issuance. Note: Head Start participants do not qualify for P-EBT benefits.

• Minnesota has also extended P-EBT to provide an additional food benefit through the summer. This program is known as Summer P-EBT and will issue a one-time benefit of $100 per child. These benefits were issued in August. There are two ways to qualify for this program: o Families with children ages 3-18 that were on SNAP or MFIP from 03/18/2020 – 07/31/2020

will automatically receive this benefit on their current EBT card. These benefits were issued the week of 08/17/2020.

o Families that apply and qualify for the $325 per child P-EBT benefits will also automatically receive these additional funds on their P-EBT card. These benefits were issued the week of 08/24/2020.

• Families with questions about P-EBT benefits can contact the P-EBT hotline using the webform located here: https://edocs.mn.gov/forms/DHS-7330-ENG.

2. Question: How many cases will be impacted by E-SNAP benefits?

Answer: Approximately 134,000 cases.

3. Question: How will E-SNAP benefits be calculated?

Answer: E-SNAP benefits will be calculated by taking the maximum allotment for the unit size and subtracting this from what the unit already received in the benefit month. For example, for a unit of two

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the maximum allotment amount is $355. If the unit is receiving $300 in benefits already, they will be eligible for the supplement (E-SNAP) amount of $55 ($355 - $300).

4. Question: Will cases with $0 benefits that are active also be eligible for E-SNAP?

Answer: SNAP cases with $0 benefits will be issued E-SNAP benefits. The amount of the E-SNAP benefit will be the maximum amount of SNAP benefits for their unit size and is listed in CM section 22.12.01 (How to Calculate Benefit Level – SNAP/MSA/GRH) If clients who are receiving $0 benefits no longer have an EBT card, they can contact ebtEDGE at 1-888-997-2227 to request a replacement card.

5. Question: Will E-SNAP benefits be issued through a check or onto the client's EBT card?

Answer: It will be issued on the client's EBT card.

6. Question: If a client receives pro-rated benefits will they also be eligible for E-SNAP?

Answer: Yes, they will also be eligible for the E-SNAP supplement. For example, if a unit of one person applied on March 20 and received prorated benefits of $30, they would be eligible for $164 ($194 - $30) E-SNAP supplement for March.

7. Question: When calculating SNAP overpayments for any months that E-SNAP supplements were issued do we include what the client received in these months for their regular SNAP benefits, or do we also include the E-SNAP benefits?

Answer: Do not include the E-SNAP amount the client received when determining overpayments.

8. Question: Will recoupments be taken out of the E-SNAP benefits?

Answer: Recoupments will happen on regular SNAP benefits. However, when the E-SNAP benefits are issued, no money will be recouped from this supplement to pay towards a claim.

9. Question: Will children still receive P-EBT benefits even if they already received SNAP?

Answer: Yes.

10. Question: If someone who is deceased had E-SNAP benefits issue, can these be cancelled or do the benefits just need to age off the EBT card?

Answer: These benefits cannot be canceled. They will eventually be expunged from the EBT card. See POLI/TEMP TE16.03 (EBT – Aging of Benefits) for more information.

11. Question: Will E-SNAP supplements for clients receiving MFIP food be based on the maximum MFIP food allotments or the maximum SNAP allotments?

Answer: The E-SNAP supplements will be based on the maximum SNAP allotment.

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12. Question: Do workers need to do anything with cases that received E-SNAP benefits for March but they moved into a Long Term Care Facility but the case could not be closed for March?

Answer: Evaluate the case and determine if SNAP should be closed for future months if it has not already been closed. For the E-SNAP benefits, no action is needed at this time. In these cases, they were eligible for E-SNAP benefits but if the benefits are unused they will eventually be expunged. There are no overpayments for E-SNAP benefits. See POLI/TEMP TE16.03 (EBT – Aging of Benefits) for more information.

13. Question: Is E-SNAP being issued to state funded SNAP recipients (MFAP)?

Answer: Yes E-SNAP benefits will be issued for MFAP recipients. We will send a SIR announcement once these benefits are issued.

14. Question: Does a disqualified SNAP unit member count for the household size to determine what amount of E-SNAP benefits to issue to a household? (Example: Household size is 3, but the applicant is a disqualified unit member. Was E-SNAP based on the maximum household size of 2 or 3).

Answer: The E-SNAP supplement was based on the eligible unit size approved in the benefit month. For the example above, the amount would be based on the household size of 2.

15. Question: If we discover that a client is due a supplement for any months that had E-SNAP benefits issued and the client already received the E-SNAP supplement, should we still issue this supplement?

Answer: Do not issue supplements for these cases. CASE/NOTE that a supplement was not issued due to the client receiving E-SNAP benefits.

16. Question: Can E-SNAP benefits be used to pay off a pre-existing SNAP claim if the client has requested to do so? If so, can a verbal signature be accepted on the DHS-5675 form?

Answer: Yes, please see TE16.21 (EBT Voluntary Repayment on Claims) for more information.

17. Question: Are home school children eligible for P-EBT benefits?

Answer: If they were open on MFIP or SNAP on March 18, 2020 then they would receive the P-EBT issuance. If they were not open on SNAP or MFIP on March 18 then they would not be eligible for P-EBT benefits through the online application process.

18. Question: If parents of children that qualify for P-EBT due to receiving free or reduced lunches at school, share custody of the children, which household will benefits be issued to? Is it a first come first served basis or do you follow a tax filing status of who claims the children on their taxes?

Answer: The parent that provides majority of the meals should apply for P-EBT benefits for that child. If both parents apply, then the benefits will be available to the parent that applies first.

19. Question: Are P-EBT benefits available for state funded SNAP cases?

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Answer: Yes. These were already issued to cases eligible on March 18, 2020 on May 29, 2020.

20. Question: Can families that received free meals from the school during the COVID-19 pandemic, but not before, receive P-EBT benefits?

Answer: There are two ways for families to qualify for P-EBT benefits: 1. Receiving SNAP/MFIP on 03/18/2020 with children on the case ages 5-18 (age 5 as of

09/01/2020). 2. Have children in a district pre-K program or school aged children ages 5-18 receving free/reduced

meals prior to the COVID-19 pandemic. These families need to apply online to determine if they are eligible. If the family did not have children receiving free/reduced meals prior to the COVID-19 pandemic, they would not be eligible for P-EBT benefits, unless they met the first criteria listed above.

21. Question: If a person is added to a case retroactively, can a case receive additional E-SNAP benefits?

Answer: No additional E-SNAP amounts will be issued. The E-SNAP payment is based on the unit size that was approved in that budget month. For example, if a child moved into the client's home April 15, but was not added to the case until June, then the E-SNAP payment for May will be based on the unit size approved in the month of May. No additional E-SNAP payments will be issued in May. However, the E-SNAP amount in June will be based on the larger unit size with the child added to the case.

22. Question: If a client receives E-SNAP in more than one state at once, should an overpayment be issued for the E-SNAP received in Minnesota.

Answer: No, do not establish overpayments for the E-SNAP benefits.

23. Question: Do suspended MFIP cases still receive E-SNAP benefits?

Answer: Yes, these cases still receive E-SNAP benefits.

Employment Services and SNAP E&T 1. Question: What types of Wi-Fi are acceptable for security purposes when using WF1?

Answer: Security procedures are unchanged regarding accessing DHS/DEED systems such as MAXIS/WF1. ES agencies should check with their agency IT person and/or their county regarding accessing MAXIS/WF1 to ensure that security procedures are in place whether they are accessing it from their home Wi-Fi or a public Wi-Fi network.

2. Question: What is guidance around sanctions? Shall we not impose sanctions/cure existing sanctions, or cure on a case by case basis?

Answer: Minnesota statute (256J.57, subd. 1, clause (6)) recognizes an emergency situation as a good cause reason for failure to comply. The federal and state declarations of emergency apply to all Minnesotans. Do not impose sanctions on MFIP or RCA households and do not disqualify any DWP

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households during the public health emergency. Remove sanctions and issue supplements for March and do not impose new sanctions beginning 04/01/2020.

3. Question: Is it acceptable to conduct orientations and case management over the phone? Examples include utilizing the phone, email and texts. Text messages may include job leads, job fairs, upcoming trainings, community resources and appointment reminders. They will not include any identifiable information, will not be done using personal cell phones and will not include any Business Sensitive Information or Protected Health Information.

Answer: This is acceptable and is the type of flexibility we are encouraging at this time. Refer to the memo sent out 03/17/2020 for MFIP/DWP and to the e-mail sent out 3/16/2020 for SNAP E&T.

4. Question: What is the guidance around activities, participation hours and log collection? Can we relax the participation requirements, if so, in what ways?

Answer: Follow current guidelines about participation and compliance. Allow flexibility around how logs can be turned in, for example via a photograph of the log and as a text attachments instead of a physical paper mailed in. Remove current sanctions and do not impose new sanctions during the public health emergency.

SNAP E&T providers are encouraged to move participants into case management-oriented activities such as Supervised Job Search and Supervised Job Search Training. SNAP E&T does not have a minimum hourly requirement and all SNAP E&T ABAWDs have been granted good cause for the duration of this emergency. Providers are encouraged to focus on maintaining contact, supporting participants’ motivation to work, and informing and enrolling new SNAP recipients who may need support at the conclusion of this emergency.

5. Question: Since schools are closed statewide can this be considered good cause for non-compliance?

Answer: If school closing creates any good cause reasons for failure to comply as outlined in the Combined Manual 28.18 (Good Cause for Non-Compliance – MFIP/DWP), 28.18.01 (MFIP Good Cause – Caregivers Under 20) , 28.18.02 (MFIP Good Cause – Child Care) and 30.12.06 (RCA Employment Services Good Cause Claims) good cause exists.

SNAP E&T participants have been granted good cause.

6. Question: It will be challenging to get updated Medical Opinion Forms for existing extensions/FSS clients. Can those be extended for a period of time if up for review? What about for new extensions/FSS?

Answer: We recognize the challenge with getting updated Medical Opinion Forms for existing FSS clients. We recommend extending their current eligibility and reviewing again in 6 months. For extension cases, since the face-to-face assessments cannot occur, accept self-attestation from the client to extend current Medical Opinion Form if applicable and maintain current coding on DISA and EMPS. If no extension category is identified, extend under Unemployable through the duration of the public health emergency. Code “Member Meets Hard to Employ Category” field on EMPS with “UN”. On TIME, code Extension Reason as “05”. Create a TIKL for six months to review their status for a continuing extension.

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If a family is due to have their extension reviewed for continuation during the public health emergency, automatically renew their extension if you believe their situation remains unchanged. Extend DISA end date out six months, if needed based on extension reason. If there is question about whether they continue to qualify under their current extension reason, submit a PQ. Do not delete existing DISA panels or remove SMC or Needed in Home coding from EMPS because this may impact their eligibility for the Housing Assistance Grant.

If a family who has already used 60 months of MFIP or TANF assistance applies for MFIP, find them eligible for extended MFIP under the unemployable category if documentation is not available for another extension reason.

7. Question: For DWP plans, can we use a text message for a client to confirm they are agreeing to the program requirements?

Answer: We are allowing verbal signatures at this time. Employment Counselors should review the EP with the client over the phone and note in the signature box that the EP was reviewed “by phone” and the date it was reviewed. A copy should be sent to the client. And this should be case noted. Current DWP cases should be converted to MFIP by 05/01/2020.

8. Question: How can clients continue to get their work participation hours if schools are closed?

Answer: If a client cannot complete their work participation hours as listed in their employment plan due to schools being closed, this is considered good cause for non-compliance. See good cause reasons outlined in the Combined Manual 28.18 (Good Cause for Non-Compliance – MFIP/DWP), 28.18.01 (MFIP Good Cause – Caregivers Under 20), 28.18.02 (MFIP Good Cause – Child Care) and 30.12.06 (RCA Employment Services Good Cause Claims).

9. Question: For new DWP applicants, can we extend the period to get the employment plan back to eligibility workers so we do not disqualify participants that are in the 10 day window? We will be doing our process via mail/return postage mail?

Answer: There will be no new DWP applicants during this time. All new applicants who would be DWP eligible will be deemed unemployable and be approved on MFIP. We are allowing verbal signatures for EPs at this time. Employment Counselors should review the EP with the client over the phone and note in the signature box that the EP was reviewed “by phone” and the date it was reviewed. A copy should be sent to the client and this should be case noted.

10. Question: For individuals who were previously mailed a NOITS with compliance due post waiver date, do we still impose a sanction or do we case note/approve good cause?

Answer: Do not impose sanctions on MFIP or RCA households and do not disqualify any DWP households during the public health emergency. CASE/NOTE that good cause was granted due to the public health emergency.

11. Question: What should we do for participants who need to be enrolled and who have a sanction pending or are currently in sanction for failing to meet with worker and develop a plan? We know we need to be

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offering to meet electronically/via phone to cure this but should they remain in sanction or be sanctioned for not doing the enrollment/plan piece?

Answer: Do not impose sanctions on MFIP or RCA households and do not disqualify any DWP households during the public health emergency. Remove sanctions and issue supplements for March and do not impose new sanctions beginning April 1, 2020.

12. Question: For new referrals what do we do if someone does not follow through with meeting electronically/over phone to develop a plan and enroll in the program?

Answer: Participants have good cause for non-compliance through the duration of the public health emergency.

13. Question: What are we to do with new enrollees? Are we to write plans as we would normally but then allow for good cause when/if they aren't able to comply?

Answer: Correct. Continue to develop plans as normal and allow good cause for noncompliance through the duration of the public health emergency.

14. Question: The commissioner temporarily waived a requirement for MFIP participants experiencing family violence to meet with both an employment counselor and a family violence specialist if the family violence specialist cannot be reached. The commissioner also directed employment counselors to avoid requiring activities that participants indicate would be dangerous in their situation, such as face to face meetings. (Is this second statement specific still to those experiencing family violence or to any/all MFIP participants?)

Answer: This statement refers to participants who have the Family Violence Waiver or who are pursuing the Family Violence Waiver. For face to face requirements for all participants, refer to the memo sent out 03/17/2020 for MFIP/DWP and to the e-mail sent out 3/16/2020 for SNAP E&T.

15. Question: Is the COVID-19 an appropriate reason to use the Holding activity option for MFIP or RCA participants who are unable to complete their activities at this time due to everything closing?

Answer: Counties and tribes have the discretion to decide how to use the holding activity in Workforce One. If participants are not able to complete the activities in their Employment Plan, grant good cause and keep those activities open.

For SNAP E&T, providers may use the holding activity but are reminded that this activity is not considered a reimbursable activity. As always, participants who fall out of contact for 30 days or more must be exited from SNAP E&T.

16. Question: How do we provide support services when our offices are closed?

Answer: Agencies should develop an interim policy for how to make support services available to participants during this time. If you are a contracted agency, work with your county, Tribal Nation and community partners to develop these processes. If you are a SNAP E&T provider contracted with DHS, please let us know if you plan to alter your support service process.

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• Bus/gas cards may be mailed to participants. Participants do not need to physically sign for the card but receipts must be tracked. This could be a digital acknowledgement from the participant followed by a case note in WF1. Participants may come to providers to pick up support services where necessary and appropriate health precautions should be taken.

• For SNAP E&T purchases of items online to be delivered to participants is acceptable but receipts must be maintained and costs must be reasonable and necessary.

• Track all expenditures closely. Since the current situation will require flexibility and creativity it is important to keep accurate and detailed notes to back up expenses.

• Carefully case note all support service needs. This will assist your agency in demonstrating that costs were reasonable and necessary.

17. Question: How should we work with participants who are still working but whose childcare center has closed?

Answer: All participants have good cause and should not be sanctioned for the duration of the public health emergency. If there is alternate child care available, work with the participant to enroll in the new child care center.

18. Question: Should we scan blank forms in EDS if we get a verbal signature? We want to make sure documents are not missing for audits.

Answer: No, do not scan blank documents into EDS. Thoroughly case note that you received a verbal verification.

19. Question: Will the Self-Support Index be waived for 2020?

Answer: No.

20. Question: Do ES workers need to send status updates to lift March and April sanctions or will Eligibility Workers do this automatically?

Answer: This process varies by county. ES workers should send status updates to lift March and April sanctions already imposed for good cause to ensure that the client receives a supplement for those months. ES workers may also utilize MAXIS Inquiry access to determine if the sanction has already been lifted by the Eligibility Worker.

21. Question: What do we do with participants who won’t enroll (attend overview, complete an initial appointment)?

Answer: Participants have good cause for not attending overview or developing an Employment Plan. Do not sanction participants and lift all current sanctions as of 3/2020.

22. Question: Can we verbally confirm participation hours?

Answer: Yes. Thoroughly case note that you obtained confirmation of participation hours from the participant over the phone.

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23. Question: Should Employment Plans be written as Reduced Hours – Good Cause for the duration of the public health emergency?

Answer: If you are developing a new Employment Plan and the participant is unable to meet the minimum hourly requirement due to COVID-19, then a Reduced Hours – Good Cause Employment Plan would be appropriate. You may also grant good cause without a Reduced Hours – Good Cause Employment Plan in place.

24. Question: Should we send in notices to end CCAP for clients who are no longer doing activities?

Answer: No. Continue to inform the child care worker of changes, including any temporary breaks or if an activity has ended. Child care workers will determine continued eligibility and service authorizations for CCAP.

25. Question: Although support funds cannot be used for groceries, is ES allowed to issue Target/Walmart cards to help with rising cost of kids being at home. Like an emergency card of up to $100 per household to help with essentials?

Answer: Follow agency and county policies regarding support services. Refer to ESM 12.6 for more information about allowable expenditures for employment services.

26. Question: Will participants who transition from one FSS extension category to Unemployable (due to an MOF that cannot be obtained) still receive the housing grant?

Answer: We recommend extending their current FSS extension category and reviewing again in 6 months OR at the next recertification, whichever occurs first. This will maintain their MFIP eligibility, including the MFIP Housing Assistance Grant.

If there is question about whether they continue to qualify under their current extension reason, submit a PQ. Do not delete existing DISA panels or remove SMC or Needed in Home coding from EMPS because this may impact their eligibility for the Housing Assistance Grant.

27. Question: Should we notify participants that we do not need them to turn in job logs (or other activity logs)?

Answer: No, advance notification is not required. If activity logs are submitted, case note and track the hours as normal. If participants do not submit logs, grant good cause, and do not impose a sanction. Case note the actions.

28. Question: Our understanding is that we are to write plans as we normally would and allowing good cause for non-compliance. However, it seems like the counties Eligibility Workers can and are referring applicants as Unemployable? So that would mean a FSS enrollment? We’ve asked that Ups are not referred as unemployable as there are many activities we can help with and work with them on during this crisis that do not require any face-to-face contact with us or employers.

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Answer: We are maintaining this coding due to the ability to quickly pull data on these cases (prior to the public health emergency there were only 12 cases in UN statewide). All activities are allowed under an Unemployable plan and can be opened in WF1. The MFIP-FSS track is not a holding category. All participants (except those with a child under the age of 12 months who have chosen to take the exemption) should have an employment plan that is appropriate for the participant.

29. Question: Will the new COVID-19 sanction changes be through the end of the year or is it still a work in progress?

Answer: The sanction changes are in effect for the duration of the public health emergency. We will let everyone know through the various communications protocols, such as e-mail, bulletin, SIR announcement, and ES Advisory when an update is needed. Refer to section K of Bulletin #20-68-12C.

30. Question: If someone was in sanction status before the COVID-19 pandemic, will the sanction be reinstituted after the pandemic emergency is lifted?

Answer: No. After the COVID-19 public health emergency ends, in order to impose a sanction, you will need to follow normal sanction procedures.

31. Question: As the waivers are phased out, is there any talk around individuals who express continued concern for participation/employment/job search due to either having an individual who falls into the vulnerable category in their homes or in their close family circle. Will we just apply good cause, or does that need to be documented?

Answer: At any time Employment Counselors may grant good cause for any of the reasons listed under CM 28.18 (Good Cause for Non-Compliance - MFIP/DWP). If the good cause is likely to be long-term (>90 days), then efforts should be made to obtain a Medical Opinion Form to determine FSS eligibility. NOTE: For the duration of the public health emergency, clients may provide self-attestation in place of a Medical Opinion Form.

32. Question: Since providers are not serving DWP participants, can staff time that was originally allocated to the DWP budget continue to be billed?

Answer: Yes. If you need to make adjustments to your contract or biannual service agreement, reach out to DHS.

33. Question: The new DWP applicants are moving directly to MFIP. So, the Eligibility Specialists are coding them as FSS Unemployable even though they are capable and want to work. We are getting FSS mismatches. Should we make our EPs to match the FSS?

Answer: No. The Employment Plan should reflect the client’s actual circumstances, so there is no need to update the EP to match this FSS code.

34. Question: We have individuals who developed a Family Violence Waiver in October and November 2019. Their 6 month review of their Family Violence Waiver due by March 31 and April 30.

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Appointments have been offered over the phone or other contact method with the option to connect with an Advocate from the local Women's Shelter. Does the FVW extend during the length of the peacetime emergency, or if there is no response to scheduled phone meetings can the FSS/FVW reason be removed due to no FVW review?

Answer: If you are unable to connect with the participant to review the FWV, connect with the DV advocate to discuss if the FVW is still appropriate for the participant. If the DV advocate believes it is still appropriate, continue the FVW for the duration of the public health emergency. If the DV advocate determines the FVW is no longer appropriate, end the FVW. If there is case specific questions, please submit them in a PolicyQuest.

35. Question: Our county has cases that are post-60 “unemployable” due to pandemic. These people are starting to ask when this ends and what will happen? Will there possibly be say, a 30 day period to job search once DHS says that this category is no longer an extension reason?

Answer: These cases should continue to be reviewed to see if the participant meets another extension reason. The current peacetime emergency is set to end December 14th, however, we do not know if it will be extended or for how long. Once the peacetime emergency ends there will be a 60-day wind down period when additional guidance will be provided.

36. Question: Will MFIP sanctions resume? Our ES provider has a number of MFIP clients who have not completed the enrollment process.

Answer: No. This waiver is still in place while there is a peacetime emergency. The current peacetime emergency is set to end December 14th, however, we do not know if it will be extended or for how long. Once the peacetime emergency ends there will be a 60-day wind down period when additional guidance will be provided.

37. Question: Will Employment Services for MFIP begin again now that recertifications and Combined Six-Month Report Forms are being sent?

Answer: The requirement to work with Employment Services is not waived. Employment Service referrals should still be sent and Employment Services Providers should still be working with clients.

38. Question: Our MFIP employment provider just contacted us stating WF1 is forcing closures of MFIP referrals that are 180 days old. Our provider has attempted to contact these clients, however, clients are not getting back to them. For all the cases closing does the Eligibility Worker have to do a manual referral in WF1?

Answer: Yes, WF1 referrals are only valid for 180 days. Agencies need to accept referrals within seven days of receiving it. During the peacetime emergency, it is recommended that agencies accept and enroll referrals on the same day. There is no requirement to meet with a participant prior to enrollment. If a WF1 referral expires and a new manual referral is sent when a MAXIS case is already active, the link between WF1 and MAXIS is broken and new status updates will not be reflected in WF1.

39. Question: For MFIP, should we be using the Unemployable extension category BEFORE using banked months?

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-Answer: Yes, for the duration of the peacetime emergency we should be extending participants under the unemployable category. Once the peacetime emergency is over, evaluate them for banked months.

40. Question: In the past, homeschooling children, including assisting with children who may be using distance learning, has not been a countable Employment Services (ES) activity. Can the time spent on helping children with school work be counted as participation hours during peacetime emergency?

Answer: Homeschooling, distance, and hybrid learning, any of these hours spent helping children with school work can be included in the EP and tracked under the “Other” activity in WF1. Child care hours can be requested for these hours as long as it is included in the EP. The hours will not count towards the Work Participation Rate. If the participant does not meet the hourly requirements do not sanction them due to good cause during the health crisis.

41. Question: According to Version 14 of the recent DHS COVID-19 Q&A, it's stated that clients assisting children with Distance/Hybrid Learning can receive child care assistance for this approved activity on their Employment Plan. Please clarify what activity code we would use and can such hours be applied toward WPR for clients assisting children with education requirements?

Answer: The appropriate Workforce One activity type for this activity is ‘Other’. These hours do not count towards the WPR.

External Communications 1. Question: Will DHS continue to host calls or webinars to address ongoing questions from counties and

tribes?

Answer: Yes. DHS will continue to host a webinar once per week. If you have questions about these meetings, please email DHS.SNAP-PAC.QA@state.mn.us.

Funding 1. Question: Will there be more funding for Emergency Assistance/Emergency General Assistance?

Answer: The state legislature is looking at options for funding. At this time, we do not have additional funds available but will release more information when it becomes available.

Income and Budgeting 1. Question: Clients are calling asking for more SNAP due to their job ending, can we prospectively budget

zero income for next month when we do not know how long they will not be working?

Answer: Follow current prospective budgeting policies that can be found in the Combined Manual 22.03.01.03 (Prospective Budgeting – SNAP Provisions). For instance, when the unit is unsure of the amount of income or when it will be received, count only the income that the the county agency or Tribal Nation and the client are reasonably certain will be received during the certification period. Document this information in MAXIS CASE/NOTEs. For verification procedures follow Combined Manual 10 (Verification) and 10.03 (Verification - Cooperation and Consent). We will provide additional guidance once we have it available.

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2. Question: Do we have any information on Census workers and budgeting their income and budgeting changes to their income?

Answer: This is still considered counted earned income. The budgeting and verification requirements have not changed. There were two SIR announcements posted on how to treat this income. They were posted on 02/04/2020 and 02/13/2020.

3. Question: For self-employment, clients are currently not able to switch from the taxable method to the 50% of current gross income method until recertification. Can we waive this requirement?

Answer: CASH: We are not waiving this requirement at this time. Clients can switch to the 50% if there is a major change. See the Combined Manual 17.15.33.03 (Self-Employment – Convert Inc. to Monthly Amt – Cash) and see the definition of major change in the Combined Manual 2.39 (Glossary – Lump Sum..). SNAP: We are not waiving this requirement at this time. Clients will need to continue to use the taxable method until their next recertification.

4. Question: SNAP applicant states she must pay $25 per week to hold their spot at daycare while she is laid off due to COVID-19 and is home with the children. Q1: Is this an allowable deduction on the SNAP budget? Q2: If so, does the reason for lay off need to be verified? Q3: If lay-off turns out to not be caused by COVID-19, is it still an allowable deduction?

Answer: If the client is temporarily laid off due to COVID-19 and the business is not being considered essential, this can be allowed as a deduction. If the client is permanently laid off, then this can be allowed as a deduction if they are looking for work. Accept a client's verbal statement regarding the reason for the layoff or that they are job searching to receive the deduction. In addition, dependent care deductions do not need to be verified unless questionable. Document the information the client provided verbally in CASE/NOTEs. Verification of the job ending is a mandatory verification for SNAP eligibility, but is not needed for the dependent care deduction.

5. Question: Client works for a restaurant. They are going to pay their employees Emergency Pay of 50% of their income during the COVID-19 Emergency if their employee does not have scheduled hours for a week at a time as they are paid weekly. They will be taking taxes and other deductions except arrears from the pay. Is this unearned or earned income for SNAP?

Answer: Count this as earned income.

6. Question: For MFIP, are we using retrospective budgeting or prospective budgeting?

Answer: There have been no changes to the budgeting cycle. (CM 22.06 – How and When to Use Retrospective Budgeting, CM 22.03.01 – Prospective Budgeting – Program Provisions).

7. Question: Should we be budgeting Unemployment Compensation if clients have not yet started payments but have received their potential benefit notices? Or, if at time of interview they have not received a payment, do we not budget this?

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Answer: Do not budget Unemployment Insurance income until the client actually starts receiving it. Follow the guidance in the bulletin and COVID-19 Guide for case specific processing steps.

8. Question: If we receive an application for SNAP or Cash where the client's self-employment business has been suspended due to COVID-19 and they are unsure when they can resume working, do we budget $0 until they can return to work?

Answer: In this case, it is to the client's benefit to choose the 50% method to budget their self-employment income. If they do choose this method, budget $0 in anticipated earnings. CASE/NOTE the verification received, the conversation with the client and why no self-employment income was budgeted ongoing. The unit will need to follow their reporting requirements to report when there are changes to their income.

9. Question: The cases that were set to close for HC, it looks like DHS did take the end dates out as planned. However, for the Medicare Savings Program it looks like those caught in the buy-in run and SSA will have Medicare premiums taken out of their social security checks. Should we now include that expense in the SNAP budget until they go back on the buy-in?

Answer: No. The restoration process happened after the CMS file was sent showing these cases closed, for March, their Medicare premiums will be taken out of their March checks. However, they should be picked up for buy-in in the next file to CMS. Workers can look in RBUY/RBYB in MMIS and there should be new request dates. They will be reimbursed retroactively. Expenses reimbursed by another source are not allowed as medical expense deductions. No Medical Deduction needs to be created for this one month change because these cases will be put back into the buy-in process. No action is needed for SNAP on these cases.

10. Question: Should one-time Federal CARES Act payments of $1200 per person and $500 per dependents be counted as income?

Answer: CASH: No. The one-time check is not counted as income. SNAP: This is considered a lump sum. Lump sums do not count as earned or unearned income. If the unit has the check amount available in their bank account or in cash when they apply for SNAP, this counts as a liquid asset when determining expedited SNAP processing and eligibility.

11. Question: The Non-custodial Parent (NCP) lost their job so there may not be any Child Support payments for a while. If we can verify this and it results in an increase in benefits, can we budget this change (prospectively for SNAP and maybe retrospectively for MFIP)? Does Child Support require the NCP to apply for Unemployment Insurance? If yes, how long does it take for this to be redirected to child support payments that are shown in PRISM?

Answer: CASH: Yes, budget the change according to standard budgeting cycle policy. CASE/NOTE all actions taken. SNAP: Budget the change for the next available month. CASE/NOTE the verification received, the conversation with the client or child support officer about the amount that is anticipated to continue, which in this case is $0, and why no further child support payments were included in the budget. CASH and SNAP: Check with the Child Support Officer regarding details for the NCP's case.

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12. Question: What is the Fresh EBT payment of $1,000? Does everyone receive it? How would we know that the client has this and how do we verify it? Is it counted as income for Cash and SNAP programs? If so, why is this payment counted, but other COVID-19 relief payments are not counted?

Answer: Fresh EBT is an app that people can sign up for when they have an EBT card to check the balance on their phone. Fresh EBT is partnering with GiveDirectly to give $1,000 cash to anyone that signs up for the app and registers for the payment. Funds are limited, so not everyone will receive these funds. Recipients are selected at random. More information about this program can be found here.

CASH: This is counted as income in the month received and an asset if retained two months later. This income is counted because it is not considered a local, state or federal government relief payment. Clients need to report if they have received this at application time. This is the only time they would need to report it since there are no reporting responsibilities during their certification time. The payment can be verified through verbal attestation.

SNAP: USDA Food and Nutrition Services (FNS) has provided guidance that this is counted as unearned income to the unit in the month that it is received. For applications, enter this in the PIC on STAT/UNEA on the "Income Received" side and enter "1" as the payment frequency. For ongoing cases, clients are to follow their reporting requirements to report this income. Following prospective budgeting policies, since this is a one-time payment it should not be adjusted in the budget ongoing. CASE/NOTE the conversation with the client about receiving these payments. Verification is only needed at application time and can include an award letter, a screen shot from the app or any other form that verifies when they received this $1,000 payment. If the client reports this income during their certification period verification is not needed since it is not anticipated to continue. CASE/NOTE the conversation with the client.

13. Question: The cities of Minneapolis and St. Paul have additional grants that family households or small businesses could apply for, and if eligible could get additional funds. Are these counted for Cash and SNAP programs?

Answer: These payments do not count for SNAP or Cash programs (See Executive Order 20-42).

14. Question: The Lower Sioux Reservation is issuing General Assistance Payments of $600 per month and an additional relief assistance payment of $840. Should this income be counted or excluded?

Answer: Both of these payments are known to be tribal relief funds related to COVID-19 and do not count as income for SNAP or Cash programs (See Executive Order 20-42).

15. Question: All adult members of the Mille Lacs Band tribe will receive COVID-19 stimulus checks of $1500. Does this income count for Cash and SNAP?

Answer:

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Any tribal relief funds related to COVID-19 do not count as income for SNAP or Cash programs (See Executive Order 20-42).

16. Question: The Lower Sioux Reservation has a program called GAP (General Assistance Program) in which they issue $600 per month. Should this income be counted or excluded?

Answer: The GAP payments are covered by Executive Order 20-42 and are not counted.

17. Question: How do we count loan payments from the Paycheck Protection Program?

Answer: This loan is considered part of the business income and expenses. We do not count loans as income. Follow current self-employment policy when budgeting income when the owners pay themselves from their own business.

18. Question: The $400 Fond du lac tribal per capita payments from June-December 2020 has changed the funding source to include COVID-19 Relief funds. Are these payments excluded for Cash and SNAP?

Answer: Yes, these payments are excluded for Cash and SNAP effective May 1, 2020.

19. Question: If the client is paid weekly or biweekly, how do we handle the fifth or third paycheck in those months when the client would be scheduled to receive one?

Answer: The client is not required to report this information. Follow guidance in the COVID-19 Worker Guide under MFIP, GA and MSA Budgeting. This also includes RCA.

20. Question: Is the new PIC Coding for MFIP, GA and MSA necessary for budgeting Child Support on Retro MFIP cases where CS income is received monthly from the system? It is a lot of steps for income we know will be updated monthly.

Answer: Continue to budget Child Support payments as usual with information received from DAIL messages. When budgeting Child Support payments, no PIC coding is necessary for cash programs.

21. Question: With the new guidance on budgeting income for MFIP, GA & MSA cases in Version 4 of the Worker Guide (page 14), I’m wondering if we should be budgeting Uncle Harry FS in this same method of averaging monthly income (using the “prospective monthly income” amount from the PIC window) instead of budgeting actual income in the retro budget (often old income as they are not currently reporting monthly).

Answer: Yes. Use this guidance for budgeting income for Uncle Harry FS cases.

22. Question: Some refugee and asylee clients reported they received assistance from a community- based agency to help with their emergency needs. Does this funding count as income for cash and SNAP programs?

Answer: No. In Minnesota, agencies that are part of the Resettlement Network (see DHS 7587Y) may issue client emergency funds related to COVID-19 emergencies. This could be help with housing, utilities, equipment for distance learning, or a variety of other things. The assistance may be issued to any of the

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populations eligible for Resettlement Network Services, including those with Refugee status, Asylum status, Special Immigrant Visa, Victim of human trafficking certification, Amerasian status, Cuban or Haitian entrant status. See CM 11.03.18 (Non-Citizens – People Fleeing Persecution) and CM 11.03.30 ( Non-Citizens – Traffkicing Victims).

This emergency support is federally funded through the Office of Refugee Resettlement (ORR), and is intended to provide extra support to eligible people for needs that have arisen as a result of the COVID-19 public health emergency. The funding is administered through the DHS Resettlement Programs Office (RPO) and its network of community partners. These payments are earmarked and are paid directly to the vendor. The client does not receive any of the funds.

23. Question: Does the Resettlement Network COVID-19 emergency support mentioned above count as a use of emergency assistance toward the county emergency assistance request?

Answer: No. These two types of emergency assistance funding are separate. Emergency support through Resettlement Network Services should not be considered in determination of county emergency assistance.

In Minnesota, agencies that are part of the Resettlement Network (see DHS-7587Y) may issue client emergency funds related to COVID-19 emergencies. This could be help with housing, utilities, equipment for distance learning, or a variety of other things. The assistance may be issued to any of the populations eligible for Resettlement Network Services, including those with Refugee status, Asylum status, Special Immigrant Visa, Victim of human trafficking certification, Amerasian status, Cuban or Haitian entrant status. See CM 11.03.18 (Non-Citizens – People Fleeing Persecution) and CM 11.03.30 ( Non-Citizens – Traffkicing Victims).

If client with an eligible status applies for county emergency assistance and has not used nor does not know about the emergency support through the Resettlement Network Services (RNS), please refer them to the closest Resettlement Network Services location listed on DHS-7587Y.

24. Question: Is the COVID-19 Housing Assistance program counted as income for the Cash and SNAP programs?

Answer: This is not counted as income for the Cash programs and SNAP. This is excluded due to the Executive Order 20-42.

25. Question: How should we count the Lost Wages Assistance payments of $300 per week?

Answer: These payments do not count for MFIP, DWP, GA, MSA, RCA, EA, EGA, CCAP and SNAP. If a client reports receiving this income, document this conversation in CASE/NOTEs.

For Housing Support:

• Count Lost Wages Assistance payments for recipients with an Adult budget type. • Do NOT count Lost Wages Assistance payments for recipients with all other budget

types.

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Detailed instructions on how to process impacted Housing Support cases will be added to the worker guide as soon as possible.

26. Question: Currently some tribes have switched their Per Capita payment funding sources to Tribal COVID-19 relief payments. Do these payments still count as income?

Answer: Tribal COVID-19 relief payments do not count as income for the Cash programs or SNAP. Once the funding source switches back to regular Per Capita payments, they will start counting as income again.

27. Question: The city of St. Paul is issuing $500 per month to 150 families already enrolled in Collegebound and are impacted by COVID-19. More information about this program can be found here: https://www.twincities.com/2020/09/03/st-paul-mayor-carter-city-will-give-500-monthly-to-150-families-in-guaranteed-income-pilot/. How is this income treated for Cash programs and SNAP?

Answer: This income is excluded for Cash programs and SNAP.

28. Question: Housing Support - 6 month reporters – Per slide 25 of the 5/26/20 Housing Support Financial worker training, 6 month reporters do not have increases during their 6 month certification period. Please confirm that Unemployment compensation, even if reported, would not change budgets for clients that are 6 month reporters.

Answer: A person who is receiving Unemployment Compensation should not be a six-month reporter. Unemployment Compensation is considered unearned income and the budget should change. Please submit a Policy Quest for case specific questions. See CM07.03.02 – Six-Month Reporting.

MAXIS 1. Question: How are workers supposed to code the verification fields when a client's written self-

attestation is used? For example, if an employer is closed and verification cannot be obtained that the client is no longer working there. Should it be "Other" and then a CASE/NOTE?

Answer: If a client's written self-attestation is accepted as verification, use the verification code on the panel that indicates "other." Clearly state in CASE/NOTEs that a client's written self-attestation was accepted as verification. As a reminder, a client’s statement is not considered a collateral contact.

2. Question: For new applications that would have been DWP that need to now be approved as MFIP, how do we code MAXIS?

Answer: Use the code of "UN – Unemployable" on STAT/EMPS in order to get MFIP eligible results if no other Unlikely to Benefit or FSS category applies [CM 08.06.24 – DWP Conversion or Referral to MFIP]. Maintain this coding for the duration of the public health emergency.

3. Question: While updating a case we will have to also update the JOBS panel even though we do not have updated information due to no HRFs — what should we do?

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Answer: Update the JOBS verification code to “4 – Other”. Update both retrospective and prospective sides with the corresponding pay check dates – or just update the months. Leave the income the same. Document in case/notes what was completed on the JOBS panel.

4. Question: Will the state extend hours that the state systems are available so that we can allow flexible work hours into the evening and weekends?

Answer: Starting the week of 04/13/2020 MAXIS and MEC² will have extended availability as follows:

• Monday – Saturday from 6:00 AM – 8:00 PM • Sunday 12:00 PM – 8:00 PM • Exception: There are some days at the beginning and end of the month when MAXIS

and MEC² will only be available until 7PM. See the updated TSS Production Calendar for more information.

5. Question: If system availability hours are expanded, are Help Desk and MN.IT staff going to be available after hours for questions and security issues?

Answer: The TSS Help Desk hours will not be changed at this time, however DHS will be monitoring and adjusting availability as needed.

6. Question: With MAXIS hours being extended, are the extended hours on Saturdays and Sundays considered business hours for processing purposes (Dates of Application, due dates for verification requests, etc.)?

Answer: No, these are not considered business days.

7. Question: The RCA extended bulletin #20-06-01 policy did not explain how to update RCA Participation Status within WREG, how would we code that in MAXIS?

Answer: During the COVID-19 public health emergency, participants have a good cause exemption from RCA employment requirement. Code RCA Participant Status = {14 Exempt, Exper Personal Or Family Crisis}. Do not enter a Referral Date or RES Provider Info. If participant chooses to participate in RES, then code RCA Participant Status = {01 – Mandatory}, enter the Referral Date, and complete the RES Provider Info following normal processing.

8. Question: Should we be creating a STAT/LUMP panel for the stimulus checks for SNAP/CASH?

Answer: No. This income is not counted for cash programs or SNAP and does not need to be tracked in MAXIS.

MFIP Extensions 1. Question: What about MFIP extension cases with an expired Medical Opinion Form (MOF)? Would they

be able to stay open and if later found to not have an extension reason, will overpayment be changed?

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Answer: Continue the extension under the current extension reason, if that situation still exists. Additionally, add the UN - Unemployable coding to EMPS and approve MFIP. If there is question about whether they continue to qualify under their current extension reason, submit a PQ. No overpayments will be charged if someone is approved under this category during the COVID-19 emergency.

2. Question: Do we still need to send in an extension form to the extension team for participants reaching their 60th month?

Answer: This process varies from county to county. Eligibility workers have been instructed to allow extension to continue either as they stand currently or under the Unemployable category.

3. Question: Are considerations being made for families that apply for MFIP but have used their 60 months to be eligible or would the same extension rules apply?

Answer: If a family who has already used 60 months of MFIP or TANF assistance applies for MFIP, find them eligible for extended MFIP under the unemployable category if documentation is not available for another extension reason.

If a family is due to have their extension reviewed for continuation during the public health emergency, automatically renew their extension if you believe their situation remains unchanged. Extend DISA end date out six months, if needed based on extension reason. If there is question about whether they continue to qualify under their current extension reason, submit a PQ. Do not delete existing DISA panels or remove SMC or Needed in Home coding from EMPS because this may impact their eligibility for the Housing Assistance Grant.

4. Question: Can the face-to-face meeting requirement 180 to 60 days prior to MFIP closing be waived to determine if a client meets an extension?

Answer: Do not require face-to-face interviews at this time.

5. Question: If someone is unable to meet hour requirements for the employed extension due to COVID-19 closures, how does this affect the extension? Does it stay open indefinitely because they have good cause for not meeting hours, or is it still just 30 days to find a new job??

Answer: During this period of time, participants who lose employment should be considered unemployable due to the emergency situation. Participants whose hours are reduced can be granted good cause.

Overpayments 1. Question: Should we be computing overpayments for months prior to the COVID-19 emergency in which

we now have the documentation on file?

Answer: Yes, continue to calculate overpayments and enter claims into the system following current policies and procedures.

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2. Question: Is the MF-FS portion of agency error overpayments still collectible during the COVID emergency? Or are these waived as well as the cash portion?

Answer: Yes, the MFIP-FS portion of agency error overpayments is still collectible. See more details about overpayments in the COVID-19 Guide.

3. Question: Should MONY/CHCK supplements for 3/2020 sanctions be applied to current overpayments if applicable?

Answer: Yes. Refer to CM 25.09 (Correcting Underpayments) and TE02.08.025 - RESTORED BENEFITS APPLIED TO A CLAIM.

4. Question: Will overpayments happen in the future for cash programs? For example, some clients have continued to work full-time but haven't been reporting their income. Will they be allowed to collect the entire MFIP grant while they are working full-time and could be over income limits for MFIP?

Answer: No, overpayments will not be cited as a result of waivers that are in place for the duration of the public health emergency. Clients are not required to report changes at this time.

5. Question: For cash programs there are currently no reporting responsibilities during a client's certification period. If the agency discovers later that a client had income they did not report that would ave resulted in an overpayment should overpayments be cited?

Answer: During the peacetime emergency, all income is required to be reported at application and recertification. If the income was not reported on the initial application, an overpayment should be cited. If the income started when they weren’t required to report it, there is no overpayment.

If you later find out there is income, you need to verify the income and once verifications are received include the income in the next available month’s benefit calculation. If the verifications are not received TIKL to follow up at the next recertification.

6. Question: If we request the income information for an MFIP overpayment from the client and it is not returned, should we be citing a full overpayment for the benefits received or should we be using the income information from DEED if available?

Answer: For MFIP/Cash: During the peacetime emergency, all income is required to be reported at application and recertification. If the income was not reported on the initial application, an overpayment should be cited.

If the income started when they weren’t required to report it, there is no overpayment.

If you later find out there is income, you need to verify the income and once verifications are received include the income in the next available month’s benefit calculation. If the verifications are not received TIKL to follow up at the next recertification.

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7. Question: Cash – GA & Housing Support - Reporting – clients are not required to report changes. If we learn after the fact about clients that received unemployment compensation, the additional $600/$300 extra, or other income, such as trust disbursements, RSDI eligibility, etc., during the no reporting waiver, do we charge overpayments for Cash programs for the month/s the income was received, both GA and Housing Support, if it wasn’t reported by the client, or was reported by the client after the fact?

Answer: During the peacetime emergency, all income is required to be reported at application and recertification. If the income was not reported on the initial application or the last recertification, an overpayment should be cited to the client. If the income started when they weren’t required to report it, there is no overpayment. Whether there is an overpayment of not, verify the income and include in the next available month’s benefit calculation. If the verifications are not received TIKL to follow up at the next recertification.

Processing Changes and Negative Actions 1. Question: Are there any changes to 10-day cutoff?

Answer: No changes have been made to our processing deadlines at this time.

2. Question: Auto-close notices for 04/01/2020 were not sent. Will they be sent?

Answer:

CASH: No. We are asking at this time that workers do not take negative actions on these cases as the client did not receive the appropriate notice of adverse action for the month of April. Cases already approved to close prior to 10-day cut-off (and the announcement to not take negative action for 04/01/2020) will still close. No additional action is needed at this time. SNAP: Auto-close notices were not sent for April. However, any expedited SNAP cases that were approved with postponed verifications will auto-close for 04/01/2020. Also cases that were set to close for other reasons, will still close for 4/1/2020. New negative actions cannot be taken for April since it is past 10 day notice.

3. Question: For cases that were already approved to close for 04/01/2020, do we need to approve these cases to stay open? For example, if mandatory verifications were not returned, if the client is ineligible or moved into a facility?

Answer: No. These cases will remain closed as of 04/01/2020. No additional action is needed at this time.

4. Question: If a client requests their case be closed, can we close the case?

Answer: Yes, close the case for the next available month, allowing for proper notice. Please see the Combined Manual 26.12.09 (Adequate Notice) and 26.12.18 (Cash Cut-Off Notice).

5. Question: For SNAP: Application was approved Expedited with postponed verifications and verifications were not submitted, do we continue to let the case close for April?

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Answer: Yes, the case will still auto-close for April 1, 2020. No further action is needed at this time unless the client provides the mandatory verifications to prevent the case from closing.

6. Question: Can we still close SNAP for May to approve MFIP cash and food?

Answer: Yes, you can still close SNAP to approve a MFIP cash and food package. No changes to imposing negative actions for SNAP have changed at this time.

7. Question: Are there any reasons why a case should close?

Answer: Yes, for cash, case closure reasons are outlined in corrected bulletin 20-68-12C:

CASH: Closure of cash cases should occur in the follow situations. • The household moves out of Minnesota. • A fraud disqualification occurs. • A client requests closure.

MFIP case closures should also occur in the following situations. • Member 01 leaves the household, including for incarceration (unless they meet temporary

absence – CM 14.09) • A pregnant woman on MFIP with a “pregnant woman basis” reports that her pregnancy did

not result in a live birth. • No children remain in the household, including when the youngest child in the household

turns 18 or 19 and has graduated. • Counted income exceeds the MFIP transitional standard.

RCA case closures should also occur in the following situations. • The entire household begins receiving SSI. • The RCA unit becomes MFIP eligible. • The eight-month timeline has been exhausted. • Counted income exceeds the RCA income standard. • Participant leaves the household, including incarceration and death.

GA case closures should also occur if the participant: • Becomes eligible for SSI or other maintenance benefits • Violates the drug felon policy • No longer meets a GA basis of eligibility • Leaves the household, including incarceration and death.

MSA case closures should also occur if the participant: • Violates the drug felon policy • No longer meets a MSA basis of eligibility (i.e. they no longer receive SSI) • Leaves the household, including incarceration and death ((unless they meet temporary

absence – CM 14.09)

Housing Support case closures should also occur when a client reports that they are no longer living in their Housing Support setting.

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SNAP: No changes have been made to the negative action policies for SNAP.

8. Question: If a client calls to report that the children have moved out of the home and the case is no longer eligible for MFIP/DWP, should we close the case?

Answer: Yes.

9. Question: When adding people to MFIP, do we add them and their income as normal and only approve new results if there would be an increase to benefits? For example, a baby is born and we are adding newborn and newborn's father - newborn's father has income that would result in a decrease to the MFIP grant. Add the baby and Father but not approve the new results?

Answer: Follow the usual process for adding members to the MFIP unit, but do not require an addendum and allow for verbal verification when documentation is not available [CM 08.06.06 – Adding a Person to the Unit – Cash]. Approve new MFIP eligibility results including the new member and any income reported.

10. Question: I have a suspended MFIP case for April. Would they stay suspended unless they send in documentation showing a reduction in income?

Answer: Yes, the case will remain suspended for April and should be reviewed for May. If there is a reduction in income the participant can verbally attest to this; no documentation is needed. CASE/NOTE actions taken.

Should this case close for May if there is no reduction in income? Yes.

Note: MAXIS will allow additional suspension months until a new approval is completed. The housing grant will continue to be issued to eligible households during suspension. It is important that the Eligibility Worker take action on this case for May.

11. Question: How should workers handle the results of a fraud investigation—especially if it causes a negative action?

Answer: No changes have been made to this policy. Act on the results of the fraud investigation.

12. Question: MFIP CASE – child is approved for SSI. First payment 4/1/20. Can this child be removed from MFIP and added Uncle Harry Food for May?

Answer: Yes, in this situation it would be appropriate to remove the child from the MFIP household and evaluate for Uncle Harry food benefits.

13. Question: What should we be doing with cases that had active SNAP and recently added MFIP? We are tracking to close SNAP for 5/1/2020 and approve MFIP food and cash however this would generally mean less food therefore would be a negative action.

Answer: Follow usual procedures and approve MFIP for May.

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14. Question: If we find client has an active felony warrant can still impose a negative actions?

Answer: No changes have been made to the policy about fleeing felons. Having an active felony warrant does not necessarily mean someone is a fleeing felon. Follow the guidance CM 11.27.09 (Fleeing Felons) and POLI/TEMP TE02.08.187 (Fleeing Felon).

15. Question: Case was transferred to Yellow Medicine County based on reported address. Receiving county is aware that this address is Project Turnabout, excluded time facility where recipient receives more than 50% of meals from the institution. Can receiving county terminate SNAP next available month due to institutional residence?

Answer: No changes have been made to imposing negative actions for SNAP at this time. Close the case the next available month, allowing for proper notice.

16. Question: Do we continue to make changes to Uncle Harry Food Support (UHFS) as we receive updated information and decrease the benefit accordingly?

Answer: No changes have been made to imposing negative actions for SNAP at this time. You can continue to decrease UHFS benefits as changes occur, allowing for proper notice.

17. Question: For SNAP can you work the CSES DAIL messages as we normally do and close the case if changes in anticipated child support income puts the unit over the gross income limits?

Answer: Yes, you can continue to process CSES DAIL messages following normal policies and procedures. No changes have been made to this policy.

18. Question: We have a mother and child open on MFIP. The child was placed into foster care and is Title IV-E eligible. If we do not close MFIP on this case, the child cannot be opened on IV-E Foster care. Can we still close MFIP for no basis of eligibility?

Answer: Close MFIP in this case so the child can receive Title IV-E.

19. Question: What if an MFIP participant had income in March that you know would have put them over for May—do you close them?

Answer: Refer to the revised bulletin 20-68-12C for a list of case closure reasons. Yes, you can close the case if you anticipate that their income will continue and they are over income due to counted income. However, if the client is at risk of a reduction in hours or possibly losing their job due to the current health crisis, we would recommend suspending for May, TIKL to contact the client to update their April income (verbal verification is allowed) and then determine if the case should close or be reopened.

20. Question: What do we do when MFIP Relative Care is open Grandma with grandchild and now the biological father is back in the home? Policy states that Grandma can no longer receive MFIP Relative Care and dad should be applying for assistance with the children on his case. Do we close the relative care case so dad can apply?

Answer: In this case, grandma is no longer eligible due to no children remaining in her MFIP household. Close relative care and have dad apply.

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21. Question: Can a cash (all cash programs) be closed for date of death?

Answer: Refer to the revised bulletin 20-68-12C for list of case closure reasons.

22. Question: Can a decrease in cash benefits be issued due to date of death of a unit member?

Answer: Yes.

23. Question: If a client open on MFIP starts receiving Unemployment Insurance in April and child support that puts them over income. Would we close for May as the household is over income this month or would we be updating to close for June?

Answer: This depends on if the participant is prospective or retrospectively budgeted as to when the income would result in a participant being closed for over income. You may close a participant whose household’s counted income exceeds the MFIP transitional standard.

24. Question: Client is a Drug Felon and has a current 1st occurrence failed UA still in place for failure to consent to a UA 11/17. We have no indication or documentation that she has resolved this be passing a UA since. The client would typically have a 30% sanction and her cash portion of MFIP vendored. However, temporary guidance states to not impose sanctions due to client's inability to comply during the Covid-19 Public Health emergency. Does this temporary guidance apply to Drug Felons who fail a UA as well?

Answer: There have been no changes to the drug felon policy.

25. Question: The new Q&A says we can close an MFIP case if they are over income. Can we suspend the case for one month before closing? In this case our client received CS that is making her over income for May but will likely go back down making her eligible for June.

Answer: Yes, suspension rules have not changed. After the initial months, suspend a case in the payment month if it is not income eligible in the corresponding budget month and you do not expect the excess income to continue. If the excess income will continue for more than 1 month, close the case. (CM 22.18 - Suspensions)

26. Question: Are we closing MFIP retrospectively for over income?

Answer: Prospective and retrospective budgeting has not changed. If the retrospective income puts them over the income limit, assess whether or not MFIP needs to be suspended before closing the case.

27. Question: (GA) If a client moves from independent living to a facility, can the grant be decreased to PN grant from community grant?

Answer: Yes, the grant should be decreased to the Personal Needs Allowance.

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28. Question: We understand that we are to approve an increase to MFIP benefits in 05/2020 if client reports a change to income however we are unsure how to do this. The client has a reduction in hours from 50 hours/pay period to 30 hours/pay period.

a. What are we to put in retro side so MAXIS reads correctly?

Answer: If this is on a retrospective budgeting cycle, retrospective budgeting applies. Use actual March wages to budget for May 2020. If this is on a prospective cycle – prospectively budget what you and the client anticipate will continue on-going. Client can request significant change, if applicable.

b. Client is also receiving Unemployment income. How/What do we need to enter in the PIC -Anticipated income?

Answer: MFIP does not read information entered in the PIC pop-up window. For prospectively budgeted MFIP cases, if you choose to update the PIC, enter what they are anticipated to receive on an on-going basis AND the same information has to be entered on the UNEA panel. Retrospectively budgeted MFIP cases use actual income. On the UNEA panel, enter what they actually received in the retrospective month and the prospective month can mimic the retrospective side or it can be anticipated income. CASE/NOTE actions taken.

29. Question: How do we process New Hire matches for Cash programs? We are thinking that we can contact the unit to obtain verbal verification. However, what should be done if we cannot get a hold of the client?

Answer: Contact the unit to obtain verbal self-attestation as verification. You can also continue to verify this information electronically and through third parties, such as employers when the client has verbally requested you assist with obtaining the verification through this method. Document the verification received in CASE/NOTEs. If you are unable to reach the unit, request any verifications needed using the DHS-2919 (Verification Request Form). If verifications are not received using these methods, do not close the case, except for the reasons listed under section F of Bulletin #20-68-12C. TIKL to follow up at the client’s next recertification.

30. Question: How should agencies be handling changes in child support for MFIP cases?

Answer: There have been no changes in how Child Support DAILs should be handled. Follow current policy as outlined in CM 17.15.03 (Child and Spousal Support Income).

31. Question: How do we process returned mail for Cash programs? Do we send out the request for contact? Also, does the process change depending on the reason for the returned mail (e.g., address unknown, forwarding address in another state, forwarding address in a different county, etc.)?

Answer: Use the current process as outlined in POLI/TEMP TE02.08.012 – Returned Mail Processing to attempt to verify the information, but do not close the case except for the reasons listed under section F of Bulletin #20-68-12C. If the returned mail has an out-of-state forwarding address, follow the

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current process as outlined in POLI/TEMP including closing the case with proper notice as moving out of state is one of the closure reasons listed on the bulletin. Workers should include a WCOM for the client to contact the agency if the information is incorrect.

32. Question: Can we can close MFIP if someone does not respond to a request for verification, using the DHS-2919 regarding a New Hire match?

Answer: No, you cannot close MFIP for failure to provide verification. Refer to section F of Bulletin #20-68-12C for a list of case closure reasons. If the household fails to provide the verification, set a TIKL to follow-up at their next recertification.

33. Question: Are we able to take negative action and/or close for cash cases in which fraud is determined? If not, we will be able to cite overpayments for incorrect payments received specific to fraud during this crisis?

Answer: Yes, if the client is found to have committed fraud, you can decrease and/or close the case. Refer to section F of Bulletin #20-68-12C for a list of case closure reasons.

34. Question: Can a worker close a case if a client voluntarily requests the case to close?

Answer:

CASH: Yes. This is a closure reason listed in Bulletin #20-68-12C. SNAP: No changes have been made to the case closure policies.

35. Question: Can we take negative action on an MFIP case where FPI found the non-custodial parent residing in the client's household and the client has not submitted verifications that were requested prior to cut off?

Answer: No, you cannot close an MFIP case for failure to provide verifications, nor can you close the case for failure to cooperate with the FPI investigation. Refer to section F of Bulletin #20-68-12C for a list of closure reasons.

37. Question: We have clients who are open on MFIP and have turned in one paystub and we are unable to use year to dates to verify the remaining income. They have not reported that the job has ended and we have sent a request for the second paystub, but it was not received by 10 day cutoff. Do we close the MFIP case as we do not have the requested paystub or do we enter the paystub we do have and leave the other paystub gross amount from the previous month? The client does not have to report the income, but has sent in a paystub, how do we proceed if the client turns part of their information in, but not all?

Answer: Monthly reporting is not required at this time. You may attempt to get verification through all available methods, however, failure to verify income is not a closure reason.

38. Question: Can workers still disqualify clients if they fail to comply with the QC review process?

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Answer: Yes. No changes have been made to this policy.

39. Question: We have a few retro GA to MSA cases to process as the client(s) have begun receiving SSI. What actions should we take?

Answer: If a participant becomes eligible for MSA, close GA and open MSA. Determine eligibility for retro MSA benefits if an interim assistance recovery has occurred, or if the client repaid past assistance.

40. Question: I have a MFIP Extension case where the client is living in subsidized housing, with a disability verified. The disability verification expires this month, which would result in a decrease in benefits due to the housing grant and housing subsidy. If the agency is unable to reach the client for verbal attestation, should the MFIP benefit be decreased, or follow the general guidelines that no negative actions are to be taken on cash cases at this time?

Answer: Refer to the “MFIP Extensions” section of the COVID-19 Guide for Eligibility Workers. There would be no negative action in this specific case. Refer to Bulletin #20-68-12C for information on when negative action can be taken.

41. Question: IEVS Matches on DAIL/DAIL for SNAP and CASH programs: a. Should we send difference notices?

Answer: CASH: Yes. SNAP: Send the client the DHS-2919 (Verification Request Form) along with the IEVS notice requesting verification of the income.

b. Should we close programs if client fails to return difference notice? Answer: CASH: No. The client can provide written verification or the worker can accept verbal attestation of the information from the client. If you cannot get ahold of the client to confirm this information, do not close the case. SNAP: Yes.

c. If no, should we resolve the match? With what coding? Answer: CASH: If the IEVS match overlaps with a new application/recertification, do not resolve the match until you’ve received written or verbal verification from the client. Applicants are required to report all income and changes immediately during the application period. For ongoing cases where the IEVS match does not overlap with a new application/recertification, if no verification is received, resolve the IEVS match with code “BO – Other” (see IEVS Guide, page 13), and TIKL to follow up at the next review. . SNAP: The case can be closed if the client does not respond.

d. If we're not supposed to send difference notices or close, should we be tracking these cases? Answer: Please see the answers above on how to track these cases.

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42. Question: What should Counties and Tribes do with individuals that have a PARIS Match for Cash/SNAP and have not responded to the request for contact?

Answer: CASH: Counties and Tribes should resolve PARIS matches only through state/tribe-to-state/tribe interactions. The participants should not be required to gather documentation or get it to the county or tribe. Workers should set a TIKL for 30 days to follow up on PARIS match requests from other states and tribes. SNAP: No changes have been made to the policies for processing PARIS matches. See POLI/TEMP TE02.08.180 (PARIS Match Timeline and Data Selection), POLI/TEMP TE02.08.181 (PARIS DAILS and Alerts), POLI/TEMP TE02.08.182 (Accessing and Resolving PARIS Matches) for more information.

43. Question: When re-determining SNAP because MFIP closed, if we accepted verbal attestation of verifications from the client for cash, do we now need to obtain a different form of verification to approve SNAP?

Answer: Yes, additional verification may be needed to re-determine SNAP when MFIP closes, depending on the verbal verification received for MFIP. For example, proof of income is a mandatory verification for SNAP and SNAP cannot accept verbal attestation of income. Please see more information in CM 05.09.06 (When not to Require Completion of an Application) and TE02.08.143 (Food Support When MFIP Closes) for more information on converting cases to SNAP when MFIP closes.

44. Question: Can we close a cash case due to IEVS non-cooperation?

Answer: No. Refer to section F of Bulletin #20-68-12C for a list of case closure reasons.

45. Question: Our MFIP work provider is still meeting with clients on their employment plans. They are getting information from clients and relaying that to the agency. Can we act on those changes?

Answer: Yes. Treat information reported to ES workers the same as “client reporting.” Please refer to the definition of “County Agency” in CM 2.13 (Glossary: Conciliation…). Refer to the COVID-19 Guide for Eligibility Workers on how to obtain verifications and process changes.

Examples: a. Client informed their job counselor that they started a job. Job counselor reported that to us.

Can we contact client to get updated information?

Answer: Yes.

b. Client informed their job counselor that they started to receive UC benefits. Can we check and start using that income in determining the clients MFIP grant?

Answer: Yes.

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46. Question: We are looking for more information on HIRE matches for the cash programs. If client does not respond to a request for information and we take no action and TIKL to follow up at next review, can we resolve the HIRE message at this time with NA, no action taken?

Answer: Yes, resolve the HIRE match with code “NA – No Action Taken”.

47. Question: Should workers still send out IEVS differences notices for SNAP and Cash if the match is for Medical Assistance only?

Answer: Yes a difference notice should be sent out after you review the case. If the household has not reported the income, you may need this information to re-determine SNAP and Cash benefits.

48. Question: For Cash and SNAP cases, if we have information of a change to the case that would increase benefits, are we to act on this information even if the client is not required to report the information during COVID-19? For example, if we know that an employer is closed should we follow up with the client to determine if the earned income ended and if the client should apply for Unemployment Compensation?

Answer: It is good customer service to reach out if you have information that could benefit the client. Refer clients to Other Maintenance Benefits including referrals to apply for Unemployment Compensation when applicable.

49. Question: When given the monthly child support DAIL messages, do workers apply the information (retro) to their MFIP cases, leave the other income data alone (but change anticipated pay dates if needed to avoid STAT edits) and approve new results?

Answer: Yes.

50. Question: What should we do with SNAP cases where the client reports their unemployment has ended, but they have not returned to work? Do we need to verify that their employment has ended? If their unemployment has ended but they refuse to return to work, will they be sanctioned?

Answer: To determine how to proceed with the case, verify that the job has ended completely and that the unemployment has ended. Before implementing a sanction, determine if the client meets another work registration exemption. If they are exempt from Work Registration update the coding in MAXIS, do not impose a sanction. If they are not exempt, at this time, grant good cause for not returning to work. See CM 28.21 (Good Cause – Non-Compliance – SNAP/MSA/GA/GRH).

51. Question: Question on MFIP cases that were suspended in June due to UI & Cares Act and now closed for July as they were over income for 2 months in a row. Can they complete a significant change after July 25th when the Cares Act ends versus having to reapply for MFIP assistance? In reviewing the cases that were over income for July many may be eligible for MFIP again when the $600 Cares Act ends. We would like to make the process easier for families so they do not need to reapply and start the process over. This impacts so many individuals it may also overwhelm workers and delay intake times if all families need to reapply.

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Answer: Significant change can only be requested when MFIP is active or suspended. If the MFIP case is closed for July, there is no significant change eligibility. See CM 8.06.15 (Removing or Recalculating Income), 22.18 (Suspension) and TE02.13.11 (Significant Change).

52. Question: I checked version 7 of the Q&A - #30 on page 38 regarding CS DAIL messages indicates no change in how CS DAILS should be handled for MFIP – however, I thought we were not able to take an adverse/negative action on a case. We have an MFIP case that started receiving CS in May and is a retrospectively budgeted MFIP case. a. Would be we able to update the MFIP for 7/20 to include the CS if it reduces the benefit?

Answer: Yes, update July 2020 MFIP case with May CS income.

b. Do we continue to retrospectively budget CS income based on CS DAIL messages each month and make changes to the benefit amount

Answer: Yes, continue to retrospectively budget CS income based on CS DAILS received monthly.

53. Question: If a client had a SNAP recertification due for 6/20 (which there would not have been a recertification due to COVID) do we just continue to allow the medical deductions that were budgeted from the 6/19 recertification until they have a recertification to process?

-OR-Should we be ending the medical deduction – even if this causes a decrease in benefits? -OR-Is there something different workers should be doing?

Answer: If no changes have been reported by the client, continue to budget the medical deductions. If a non-recurring expense was budgeted over the remaining months in the client's certification period, the calculation of this deduction needs to be adjusted, if known, following proper notice requirements. If a change is reported, treat it as the client reporting a change during their certification period. See CM 18.12 (Medical Deductions) and 10.18.02.03 (Non-Mandatory Verification – SNAP).

54. Question: If a client reports a non-recurring medical expense to their worker now and chooses to average the expense over the remaining months of their certification period, what is the certification period we should use in the calculation?

Answer: Calculate the expense based on the current certification period the client has. Create a DAIL/TIKL for the recertification month to follow up on this expense, in the event that the recertification is extended. If the recertification is extended, adjust the calculation of the expense at that time.

55. Question: The worker guide makes it sound like we can approve decreases to cash programs (like if a client reports an increase in income but is not over the income limit) but the bulletin and Q&A say not to impose any negative actions except specific closure reasons. Which is correct?

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Answer: Actions to decrease benefits can be approved if information is received and verified. However, only follow through with closing a case for the specific reasons outlined under section F. Only act on information that is verified.

56. Question: According to the Covid-19 Guide, DHS is working guidance on processing changes that are not reported by the client, but known to the agency through other sources. Are there any updates to this policy? Example, known to Social Workers that children are no longer in the home and this change was reported to the Social Worker. Can we close MFIP due to there no longer being an eligible child in the home?

Answer: There are no updates to the known to the agency policy. For this example, if you have all the needed verifications to decrease the MFIP grant without requesting additional information, you may process the change. If the change results in a case closure, you cannot close MFIP unless it is one of the closure reasons listed in section F of Bulletin 20-68-12C. No eligible child is a case closure reason for MFIP.

57. Question: For cash cases when processing PARIS matches, if the other states verifies that there is no open programs there and the MN EBT card is being used in Minnesota can we clear the match as "RV" (Residence Verified)? Same with medical, if no open program in the other state, can we just clear it RV? (And not have to set up a TIKL for 30 days.)

Answer: Counties and Tribes should resolve PARIS matches only through state/tribe-to-state/tribe interactions. The participants should not be required to gather documentation or get it to the county or tribe. If it has been verified that the applicant is not receiving benefits in another state, then that is sufficient to clear it as RV – Residence Verified.

58. Question: If a convicted drug felon on MFIP does not return a signed DHS-2243A, General Authorization for Release of Information, should we close them? If so, would we use STAT/PACT?

Answer: A verbal attestation and signature can be used, however, a DHS-2243A is not required. There have been no changes to drug felon policy.

59. Question: Client moves and is now living with someone and does not meet lives alone MSA criteria. Income is over shared household standard. Can we close the case for not meeting MSA eligibility requirements?

Answer: No, the client still meets a basis of eligibility. If the client were to lose basis of eligibility, then the case may be closed.

60. Question: For GA. If client is now working enough hours that puts them over the GA standard, would we be able to close GA because they no longer have a basis of eligibility because they are able to work suitable employment?

Answer: Unless there is verification that the client no longer meets the basis of eligibility, the case should not be closed.

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61. Question: For GA, if we have clients who have reported returning to work, can we take action on that and possibly approve a decrease in benefits or close the case?

Answer: You can act on that information as long as it is verified. Once verified, you can increase or decrease benefits for the next available month, allowing for proper notice. However, you can only close the case for one of the reasons listed in bulletin 20-68-12C and under question #7 of this section. For GA, this does not include closing for being over the income limits. You can, however, process an increase or reduction in benefits (including to $0).

62. Question: I have an MFIP client requesting a significant change for September. She is receiving regular UC benefits each week and may also receive the $300 per week from Lost Wages Assistance (LWA) program, which includes a Lump Sum of these payments from August. How should this be processed since the date of when she will receive LWA is currently unknown?

Answer: LWA payments are not counted for MFIP. Process significant change requests as normal based on counted income the household is expected to receive in the payment month.

63. Question: If an MFIP participant fails to comply with a fraud investigation, can MFIP be closed? The bulletin references allowing closure for fraud disqualification, but isn’t specific about failure to comply with the investigation.

Answer: No, failure to comply with a fraud investigation is not a closure reason for MFIP. If a verification request for inconsistent information has been sent, TIKL to follow up at the next recertification

Reviews and HRFs 1. Question: Do we still need to review HRFs, CSRs and recertifications 04/01/2020 and 12/01/2020 that

have already been submitted to determine if there is a positive change reported to the case?

Answer:

CASH: Yes. Refer to the COVID-19 Guide for Eligibility Workers on how to act on these changes. SNAP: MAXIS did not autoclose cases for no review for April and December. Review all changes reported on the forms. Since it is past 10 day notice and negative actions cannot be processed for April or December benefits only process changes that increase benefits for April or December. Process changes for May and January as usual, allowing for proper notice. There would be no overpayments for April or December due to the reviews not being processed prior to 10 day cut off.

2. Question: For SNAP: Are we supposed to be approving all reviews for April and December? Example: If Cases were already closing prior to 10 day for not submitting verifications do we continue to let them close?

Answer: Yes, these cases will close April 1, 2020 or December 1, 2020. No further action is needed at this time.

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3. Question: For SNAP: For the Household Report Forms (HRFs) that were being tracked and were set to close the 17th when they were not submitted do we continue to leave those closed since we do not have any income verified?

Answer: Any case approved to close for April 1, 2020 will still close. No further action is needed at this time.

4. Question: Case has an ER due for May, 2020 and the client submits a CSR with proof of income and shelter costs. How do we proceed? Are we supposed to update REVW panels at this time?

Answer: Treat the CSR received like a change report form. Update the case according to the changes reported and verifications received as they are "known to the agency". Set the ER date out to November, 2020, and update the CSR date for May, 2021.

5. Question: If someone has a SNAP recertification do we request information without the interview? Did they receive a renewal form?

Answer: Auto-close was held for any SNAP case that had a CSR or recertification for April and December 2020 that was not provided. HRFs were not sent for May – January, 2021 and CSRs and recertifications were not sent for May – August 2020 and January – February, 2021. If the client provides a HRF, CSR or recertification, treat the client as reporting any changes as a change reported during the client's certification period. See the COVID-19 Guide for more information on processing changes.

6. Question: I received HIRE DAILS today for an active SNAP case. I requested verifications and gave the client-10 days to respond. The client also has a SNAP recertification for May, 2020, which we are aware at this time is not required due to COVID-19. If HIRE DAILS are unresolved after 10 days have been given, are we able to close SNAP for May, 2020?

Answer: Yes, close the case allowing for proper 10-day notice. Update the STAT/REVW panel. Set the recertification date to November, 2020 and the CSR date to May, 2021 if the unit is subject to six-month reporting requirements.

7. Question: CS DAILS received today and the UNEA panels were updated. The client has a SNAP CSR for May, 2020, which we are aware at this time is not required due to COVID-19. Do we just leave the income that has been previously budgeted in JOBS and just update the pay dates (to clear STAT edits) and approve increase/decrease SNAP for May, 2020?

Answer: If the change in the Child Support income is expected to continue, approve the change (increase or decrease) for May, 2020. CASE/NOTE the information received, the conversation with the client or child support worker about anticipated child support income and what was used in the budget and why. Update the STAT/REVW panel with the next CSR date of May, 2021. Do not update what was budgeted for the earned income unless the client has reported changes that are anticipated to continue. The pay dates on the face of the STAT/JOBS panel will need to be updated to clear any STAT edits.

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8. Question: For MFIP, are we to be waiving all HRF and other requirements and just continuing to approve? If we do have things come in, do we still require verifications? Should we be approving negative actions?

Answer: MFIP units who are monthly reporters are not required to complete Household Report Forms (HRFs) and verify/confirm their income each month. If a client does report a change, attempt to contact the client to get verbal verifications. Contacting clients can be completed by phone, e-mail or teleconference. If this fails, send out a request for verification using the DHS-2919 (Verification Request Form) and allow the client 10 days to return the verification. If client contacts the agency, verify as much as you can electronically or through phone calls with third parties, such as employers or landlords. When you cannot obtain documentation, use self-attestation for ANY required verification. Approve new results based on reported and verified information (follow COVID-19 verification procedures), even if it results in a reduction in benefits. If you do not receive all information needed to update the case, TIKL for six months. Do not close the case for failure to verify reported information. Follow the list of case closure reasons outlined in Bulletin 20-68-12C.

9. Question: For MFIP, with no HRF’s being sent out, we are not receiving earned income to verify if they are over income. How would we determine if they are over income when we don’t know their income?

Answer: Clients are not required to report income or complete monthly Household Report Forms (HRFs). Assume currently budgeted income continues, unless the client reports a change. If a client reports that their income is now over the counted income for the program, close the case if the household’s counted income exceeds the MFIP transitional standard. If the client reports a reduction in income, approve an increase in cash benefits. If the client reports an increase in income, approve a reduction in MFIP benefits. In the situation where we have suspended cases it will be the responsibility of the worker to reach out to the client to determine if the case is once again eligible or should close after the suspension month. CASE/NOTE the action taken.

10. Question: We are being asked to set the recertification date out six-months. However, Health Care does not want the renewal dates changed. How do we process this in MAXIS?

Answer: Code "I" on STAT/REVW for Health Care. This will then not require you to update the date when updating the review date for cash programs or SNAP.

11. Question: Should we still impose sanctions for drug felons?

Answer: No changes have been made to the drug felon policies and procedures at this time.

12. Question: Medical expenses were reported and verified in April, trying to update the case for May but a renewal is due. How do we process the medical expenses change since the May recertification was not sent?

Answer: Since recertifications were not sent for May, process the change in the medical expenses as a change the client reported during their certification period. Following the guidance in CM 10.18.02.03 (Non-Mandatory Verifications – SNAP) for processing medical expense changes during the unit's certification period. If the unit reported and verified the change in April, process the change for May. In order to avoid any edits for May since a recertification was due but not sent, update the review dates on

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the STAT/REVW panel. Update the next recertification date to six months from the current recertification month, which in this case would be November, 2020. Update the six-month review date (if the unit is subject to six-month reporting) to one year from the current recertification month, which in this case would be May, 2021. CASE/NOTE all actions taken on the case.

13. Question: If the agency approved to close a case for 04/20 due to no HRF, CSR, Recertification, when processing a change prior to the implementation of the COVID-19, should the agency be re-opening these cases if the only reason for the closure was no HRF, CSR, or Recertification?

Answer: If the case closure for April was only because the unit did not provide a HRF, CSR or Recertification, reinstate the case with no proration.

• If a recertification was due for April, update STAT/REVW with "U" and update the review dates. Update the "Date Received" field with 04/01/2020. Update the recertification date to October, 2020. For SNAP and Housing Support, if a recertification was due for April, update the recertification date to October, 2020 and the CSR date (if the unit is subject to six-month reporting) to April, 2021.

• For SNAP and Housing Support, if a CSR was due for April, update STAT/REVW with "U" and update the review dates. Update the "Date Received" field with 04/01/2020. Update the CSR date to April, 2021. Update the recertification date to October, 2020.

• Even though the review dates are being extended, eligibility will be reviewed in six-months. • If a HRF was due, update STAT/MONT with "U." Update the "Date Received" field with

04/01/2020. CASE/NOTE all actions taken on the case. • See the case examples below:

Ex: MFIP closed for 04/20, due to processing a March HRF after 03/08/20.

Answer: Reinstate the case for April with no proration. Update STAT/MONT with "U." Update the "Date Received" field with 04/01/2020.

Ex: SNAP closed 04/20 due to no recertification, due to processing a SNAP increase in March based on a reported change.

Answer: Reinstate the case for April with no proration. Update STAT/REVW with "U" and set the recertification date to October, 2020. Update the "Date Received" field with 04/01/2020. Update the CSR date (if the unit is subject to six-month reporting) to April, 2021.

• If the closure was also due to other factors, such as failure to provide requested verifications, would the case remain closed?

Answer:

CASH: If you do not hear from the client about the case closure, the case remains closed. The reason being is that the case would have needed to be closed by 10-day cutoff (03/19/2020), which was prior to the instructions from DHS being released (03/23/2020) about not imposing negative actions for April. If the client contacts you about their case closure, you can accept verbal attestation from the client to reinstate the case. SNAP: The client would need to meet all the criteria in CM 05.09.06 (When Not to Require Completion of an Application) to be reinstated.

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14. Question: I have a client who requested we do a complete May MFIP recertification process – interview, verifications, everything is here and complete. Based on the COVID-19 Guide I should set recertification for next 6 months. In this situation, is it appropriate to process the May MFIP recertification the regular way and set recertification for 5/2021, rather than 6 months?

Answer: If a client requests to complete a recertification, completes the interview and submits all required verifications without using verbal attestation and/or a verbal signature, the recertification date can be set out for one year. If verbal attestation is used for any required verification, set the recertification date out six months.

15. Question: Will June recertifications and Combined Six-Month Reviews (CSRs) be sent out for June?

Answer: No. These will not be sent. Please see the COVID-19 Guide for more information about how to process a case if the client provides a recertification or CSR and/or reports a change.

16. Question: Will June renewal paperwork be sent out for GA or MSA cases and what is the procedure for those cases?

Answer: No. See the 4/27/20 SIR announcement titled “GA, MSA, GRH, MFIP & SNAP ER & SR Dates Pushed Out” for more information.

17. Question: What do I do with cases showing up on REPT/MONT or REPT/REVW for 6/20?

Answer: No actions are needed at this time. If you receive a HRF or review, follow the guidance in the COVID-19 Guide for processing the case.

18. Question: Do we need to send a 12-month contact letter for the ones due in August for SNAP cases that are certified for 24 months?

Answer: Send the 12-month contact letter for these cases. No changes have been made to this policy.

19. Question: For cash, if we approve a new application that would normally require monthly reporting, the third month of eligibility (the first retro budgeted month) shows up on REPT/MONT, even though HRF’s are not being required for eligibility for monthly reporters right now. (i.e. 4/20 and 5/20 are prospective months, 6/20 is retro budgeted and shows on MONT for 6/20). How are we to resolve these cases on REPT/MONT?

Answer: If working off REPT/MONT to switch the case to retrospective budgeting in the 3rd month, update the JOBS and any UNEA panels as instructed in the “MFIP, GA, and MSA Budgeting” section of the COVID-19 Guide for Eligibility Workers. Then update the MONT panel with “U.” The “Date Received” field can be the date you processed and approved the case.

20. Question: Will recertifications be sent for September?

Answer: Yes, reviews will be sent for September for cash and food programs. This includes Combined Six-Month Report forms.

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21. Question: Will Six-Month Reviews be sent for September?

Answer: Yes. Any program that has a Six-Month review due for September will be sent.

22. Question: Will Household Report Forms be sent for September?

Answer: No.

23. Question: Will the waiver request for continued telephone applications and verbal signatures for SNAP apply to recertifications for September - November also?

Answer: Yes. This also applies for Combined Six-Month Report Forms.

24. Question: When will REPT/REVW be available to view how many cases have reviews for September?

Answer: This report will be available for September starting 08/01/2020. DHS is also working to create a report to post to SIR.

25. Question: Can counties assist other counties with their high numbers of renewals/recertifications?

Answer: Yes, if you are able to determine a way to help, you can help process recertifications for other counties.

26. Question: If the waiver for phone applications, recertifications and verbal signatures continues, will workers be expected to contact clients that don’t return their recertification or Combined Six-Month Report Form for September - November?

Answer: Follow your county or tribal procedures for processing recertifications and Combined Six-Month Report Forms for September - November. If the client contacts you regarding their recertification or Combined Six-Month Report Forms, you can accept a verbal recertification or Combined Six-Month Report form in the same way you accept verbal applications.

27. Question: Currently we can’t close cash cases if the client doesn’t provide requested information. For the renewals for September – December, will cases close if the client doesn’t provide the renewal form, follow through with an interview or provide the requested verifications?

Answer: Yes, these cases will close for September – November. The auto-close process was stopped for December renewals that were not provided and the certification period will be extended six months. You can accept a verbal recertification or Combined Six-Month review and the client's verbal signature. For Cash, you can accept verbal verifications from the client to process the review until the end of the public health emergency.

28. Question: Are reporting responsibilities still waived for cash programs during the client's certification period if they had a recertification or Combined Six-Month report for September - November?

Answer: Once the recertification or Combined Six-Month Report forms are complete, reporting responsibilities are waived until the next review or the end of the peacetime emergency, whichever comes first.

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29. Question: For Cash (specifically GA or MSA) if they report being over income for GA or MSA, can we close them at recertification then because we are processing a recertification? Or because the waivers are still in place for Cash programs--this would not be a reason on the list of acceptable closures?

Answer: The case could close at recertification if all documentation or verifications are not received. Verbal attestation and verbal signatures can still be used.

30. Question: If we take self-attestation for someone applying for GA and then receive a Medical Opinion Form that is not signed by a qualified medical professional are we supposed to request another Medical Opinion Form or continue to use the client's self-attestation for not being able to work for the six months until client has a recertification?

Answer: Clients may self-attest that they are unable to work during this time until their next recertification. No action would be taken on a Medical Opinion Form that was not signed by a qualified medical professional and a new form would not need to be requested.

31. Question: Are we able to take negative actions on SNAP and Cash cases that have Combined Six-Month Reviews (CSRs) or Recertifications for September - November? For example, if the unit has an increase in income and that puts them over the income limits, can we close the case for September?

Answer: Information verified at recertification can be used to decrease benefits or close a case. Failure to complete a recertification will result in case closure for September - November.

32. Question: When completing cash renewals for September - November, are we able to close cash cases for reasons other than those listed in the guide? For example, if an MSA client had change that put them over the income guidelines for MSA, we couldn’t make the change to close their MSA due to COVID-19. Now we are doing their renewal for 9/20, and they are still over income for MSA, can we close them for that reason while processing the renewal?

Answer: Yes, clients must be found eligible at recertification. State waivers remain in place. For example, clients may self-attest for any required verification for Cash programs.

33. Question: 1) For someone who has a September ( and ongoing months ) SNAP/MSA recertification, and the client wants to keep their recertification dates the 'same' (so they don't need to do a MSA recertification in 6 months), do we mail the 2919 requesting verification of bank accounts or do we take a verbal attestation? 2) Would we do the same for those receiving GA who also have 'dual' recertifications due for September and ongoing months?

Answer: See the COVID-19 Guide for when to set the next recertification date. When processing recertifications, you can accept verbal attestation from the client verifying their assets or they can complete the DHS-6054 (Signed Personal Statement About Assets for Cash Programs).

34. Question: What should workers do if they are unable to fill out the Combined Six-Month Review (CSR) online and do not have access to the paper versions? In addition, should workers be signing the CSR when they complete the form with clients over the phone?

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Answer: The Combined Six-Month Review Form is now fillable through eDocs. If for some reason you are unable to complete the CSR due to it not being fillable online, note the answers the client provides over the phone on a separate document. Indicate the date, time and phone number that the answers provided from the CSR were provided by the client over the phone and documented on a separate document in CASE/NOTEs. A worker signature on the CSR is not required if the CSR was accepted over the phone, but you must indicate somewhere on the form (if possible) and in CASE/NOTEs that the client's information was received over the phone and add your worker name and ID.

35. Question: For units that qualify for a 24 month certification period (per CM 09.03 – Length of Certification Periods and TE02.08.165 – SNAP Aged/Disabled 12 Month Contact) that had their certification period extended by six months, what is the next recertification date once their current recertification is processed? For example, if the unit was originally scheduled to have their recertification April, 2020 but had it extended to October, 2020, once that recertification is processed should the next recertification date be April, 2022 (18 months out) with a 12 month contact in April, 2021?

Answer: Once the October, 2020 recertification is processed, set the next recertification date out 18 months. In the example above, the next recertification date would be April, 2022 and the 12 month contact would be April, 2021.

36. Question: When completing recertifications for Cash programs for September - November, should verification requests (DHS-2919) be sent out or should eligibility workers request verbal verifications/self-attestation via phone? What should this process look like? Does this apply outside of recertifications?

Answer: When completing recertifications, use the DHS-2414 not the DHS-2919. This process is laid out in the COVID-19 Worker Guide under the section titled ‘Combined Six-Month Reviews and Recertifications’. Outside of recertifications you can use the DHS-2919 to request verifications.

37. Question: Cash Recertifications – If there is a recertification that was turned in late and verifications are needed, the DHS-2414 isn’t going to allow 10 days for the client to return those before case closure. Do we take their verbal attestation and approve right away, or how would you handle these cases?

Answer: For recertifications that are turned in late or processed late, follow the steps outlined in the COVID-19 worker guide for processing recertifications. You should attempt to get verifications, allow for 10-days and accept verbal attestation as a last resort, only if verifications are not submitted.

38. Question: Are there any exceptions to waiving the recertification interview during the peacetime emergency?

Answer: Housing Support, GA, and MSA do not require a recertification interview. For MFIP and SNAP cases, the interview can be waived. See the COVID-19 Guide for more information on processing recertifications when the interview is waived.

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39. Question: At the SNAP Live Stream on 11/4/20 they stated effective immediately no interviews are required for SNAP & MFIP recertifications. a. What do we do with those that we couldn't reach for the required phone interview in October

for 11/20 Recertifications?

Answer: Review these recertifications to determine if all mandatory verifications were provided and if any information needs to be clarified. If no verifications are needed and no information needs to be clarified, these recertifications can be processed. If verifications or information needs to be clarified, send the client the DHS-2414 indicating what the client needs to provide to complete the recertification.

b. What do we do with those that we haven't processed at all that were submitted before 11/1/20 and SNAP is now closed?

Answer: See the information above. If you can approve the recertification, reinstate and do not pro-rate benefits. If you need verifications or to clarify information, send the client the DHS-2414 indicating what is needed to complete the recertification.

40. Question: Do workers still need to send interview letters and Notices of Missed Interviews (NOMIs) for recertifications now that the recertification interview can be waived?

Answer: No, interview letters and NOMIs do not need to be sent.

41. Question: If we are not doing an interview for SNAP and Cash, what are we doing in regards to going over the Rights and responsibilities? Per CM 09.06.06 we are required to go over all of the forms/handouts from CM 05.12.12.01. How are we do make sure we are going over all of these without an interview?

Answer: These forms do not need to be reviewed verbally at recertification time.

42. Question: We have also run into several recertifications where the client marked yes to income but the household has changed jobs several times. This is concerning for accuracy and overpayments. This results in a hardship for the households and extra work for the agency. It also compromises the relationship a family has with the agency. Can agencies choose to still do interviews to avoid overpayments?

Answer: No, interviews should not be completed at this time. If information needs to be clarified with the client, then the client should be contacted. Prior to assessing for overpayments, remember to determine if a client was required to report the change during their certification period. As a reminder, for Cash programs, clients do not have any reporting responsibilities during their certification period.

43. Question: If we are processing a SNAP recertification for December, have interviewed, needed verification, but sent the DHS-2414, do we need to now send the DHS-2919 to show the return date of 10 days later? The DHS-2414 indicates they have until the end of the month to provide info.

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Answer: No, you do not need to send the DHS-2919 if you have already sent the DHS-2414. In order to close the case for not providing mandatory verifications for SNAP, make sure they have had 10 days to return verifications before you send the Notice of Adverse Action.

Students 1. Question: I have an appeal on the 30th for MAXIS. Member 01 wants her daughter, Member 03 to be a

part of the household although the daughter was attending college away from home. Previously when she was at college she would have been listed under multiple residences (CM 14.12 – Units for People with Multiple Residences) and the daughter's main residence would have been college so Member 01 would have remained a unit of 1. Now due to COVID-19, her daughter is back at home with Member 01 and completing college courses online.

a. Would students that don't meet the criteria from CM 11.18 (Students) remain ineligible students at this time?

Answer: Yes, students who do not meet any criteria in CM 11.18 (Students) remain ineligible students.

b. Would a student who was completing work study and is no longer able to as the school campus is closed remain an eligible student?

Answer: A student who is still receiving work study payments, even if they are not able to physically perform their work would be considered to still be participating in work study and would still be an eligible student. However, if the student’s work study position has ended AND they are no longer being paid for this position then they would lose eligibility for the month following the month in which the position/payments ended.

c. Would good cause per federal regulations apply to students who are no longer participating in work study? If so, would they then be eligible students?

Answer: Students enrolled at least half time in a regular program at an institution of higher education must meet an exemption in CM 11.18 (Students) in order to be eligible for SNAP. At this time Federal SNAP policy does not allow good cause to be applied to student’s who have lost their work study jobs as a result of the COVID crisis. See answer to “b” above.

2. Question: If a student was an ineligible student while at school (did not meet any of the criteria found in CM11.18), but has moved home due to COVID-19 closures, are they now eligible for SNAP?

Answer: No, an ineligible student who is either A) continuing to participate in school through online learning, or B) intending to return to school for the summer or fall term would still be considered an ineligible student, unless they now meet one of the criteria found in CM 11.18 (Students). Eligibility workers should check CM 11.18 and confirm that the student does not now meet one of these criteria.

If the student is not continuing to participate in school AND does not intend to return to school then they are no longer considered a student. Eligibility should be determined on a non-student basis.

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3. Question: If a student was an eligible student while at school but has moved home due to COVID-19 closures, are still eligible for SNAP?

Answer: Yes, with some exceptions. A previously eligible student who is either A) continuing to participate in school through online learning or B) intending to return to school for the summer or fall term would still be considered an eligible student. However, eligibility workers should also evaluate household income eligibility first.

However, if the student had established eligibility by A) working 20 hours or more each week or B) participating in work study and they are no longer able to continue these activities they will become an ineligible student at the end of the month in which the activity ends. Ultimately, the student would still need to meet one of the criteria found in CM 11.18 and eligibility workers should review CM 11.18 for any other exemptions before determining that a formerly eligible student is no longer eligible. NOTE: Students who are continuing to receive work study payment through the end of the school term are considered to be participating in work study until those payments end.

4. Question: If a student is applying for SNAP and does not meet any other exemption in CM 11.18 but has decided to participate in SNAP E&T, can they now be eligible?

Answer: Yes, if their enrollment in SNAP E&T has been verified by an E&T provider then they would be considered to be meeting one of the criteria found in CM 11.18 (Students). This means that they would need to continue to comply with the agreed upon employment plan which their SNAP E&T provider will monitor.

Students in programs intended to last 2 years or less who apply for SNAP and do not meet other exemptions outlined in CM 11.18 should be referred to a SNAP E&T provider who can determine their eligibility for SNAP E&T. Counties should work with their local providers to identify best referral methods during this emergency. Counties are encouraged to refer participants to any E&T provider who is best equipped to receive referrals and most likely to meet the participants’ needs. A list of local E&T providers can be found on the SNAP E&T website.

5. Question: If a student already enrolled in E&T is no longer able to participate in their school program due to campus closures and/or lack of digital learning options or capacity, what activity should E&T providers enroll the student in?

Answer: If the student intends to return to school in the summer or fall, E&T providers should consider this as a similar scenario to how they would handle a summer or winter break. Students should remain enrolled in their education/training component and must continue to make contact with the provider at least monthly in order to remain in compliance. This contact must be case noted at least once each month. However, they are not required to attend classes, job search, or other participate in any other activity.

Providers may allow support services for these participants, but those support services must be directly related to supporting their return to classes or maintaining any activity they are doing with the E&T provider. Providers are encouraged to maintain contact with the student and use these contacts as an opportunity to discuss long-term school and career planning.

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If the student does not intend to return to school, but does wish to continue to receive support through E&T for job search, job readiness, education or training, providers should enroll them in the relevant activity.

6. Question: Can we continue to enroll students already receiving SNAP, in E&T?

Answer: Yes, for students who are enrolled in a qualifying education program and participating in online learning you can continue to enroll them in E&T following your normal process. You may also enroll students who are receiving SNAP without E&T participation on the same basis as you would enroll any other SNAP recipient. For students in qualifying programs who are not able to participate in school due to COVID-19 but who do intend to return to their classes in the summer or fall, they should be enrolled in the educational component that best reflects educational program.

7. Question: A student was receiving SNAP because they were working 20 hours or more each week. They have now lost their job, but are still participating in classes online and were told by eligibility that they must participate in E&T in order to be eligible. What should the E&T provider do?

Answer: This student can be enrolled in E&T to receive support while they complete their schooling. However the E&T provider must verify that their program of study meets the E&T requirements and provide verification of intent to enroll to the eligibility worker. If the student fails to follow their employment plan and is exited from E&T, the provider must inform the eligibility worker.

8. Question: We are seeing a few applications from adult students (still attending on-line), and wondering if there will be any changes/allowances made for eligible student criteria for SNAP due to COVID? In some instances, they were working 20 hours per week prior to COVID19 affecting their jobs, but have either had hours reduced or jobs have ended completely. If they don't meet one of the other eligible student criteria, are these students going to still be considered ineligible students when they're not able to work due to COVID19 closures? Our county also does not have SNAP E&T, so we have not been able to use the option of sending them there to have their schooling approved.

Answer: At this time there are no planned changes to student eligibility for SNAP. Students who lose their jobs as a result of COVID-19 will become ineligible students if they do not meet any other criteria in CM 11.18 (Students). DHS is aware that this is a significant issue for these students and has passed this concern on to federal policy staff. Counties and tribes that do not operate or pass through funds for SNAP E&T (formerly FSET) may have providers in their area who are contracted with DHS or DEED to provide services. The SNAP E&T website includes a map listing providers by county and counties still encountering issues accessing E&T are encouraged to reach out to Anastasia Polda, SNAP E&T Supervisor at Anastasia.polda@state.mn.us.

9. Question: Are higher education students still subject to student requirements for SNAP at this time? Are there any waivers to allow students to be eligible for benefits who would otherwise maybe not be eligible?

Answer: Students in higher education are still subject to the same requirements. We are continuing to work to identify other avenues to address students in need of food access.

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10. Question: If students were working 20 hours a week prior in college but are no longer working now due to COVID 19 and apply for Unemployment Insurance, would they now meet an exemption to be an eligible student?

Answer: Students who lose their jobs as a result of COVID-19 will become ineligible students if they do not meet any other criteria in CM 11.18 (Students). DHS is aware that this is a significant issue for these students and has passed this concern on to federal policy staff.

Unemployment Compensation 1. Question: Are CASH applicants still required to apply for unemployment to be eligible for CASH and does

that need to be verified before CASH can be approved?

Answer: Yes, CASH applicants should still apply for Unemployment Insurance (UI) (CM 12.12 – Applying for Other Benefits). Do not delay approval of an application while waiting for a decision from DEED regarding the UI application; do not require proof of UI application prior to approving benefits; if the client appears to be eligible for UI, inform the client that they must apply for UI in order to remain eligible for cash. If the client states that they are unable to apply for UI, submit a PQ. Refer to the “Unemployment Insurance” section of the COVID-19 Guide for Eligibility Workers.

2. Question: Is the Federal Pandemic Unemployment Compensation of $600 per week counted for cash and SNAP programs?

Answer: This is counted as unearned income.

3. Question: How do we verify the Federal Pandemic Unemployment Compensation of $600 per week?

Answer: CASH: Follow the verification requirements outlined in Bulletin 20-68-12C. SNAP: Use the worker portal to verify the applicant is receiving Unemployment Compensation along with public knowledge that everyone eligible for and receiving Unemployment Compensation will also receive the Federal Pandemic Unemployment Compensation of $600 per week. CASE/NOTE the conversation with the applicant and the verification used.

4. Question: If the Federal Pandemic Unemployment Compensation of $600 per week puts the unit over the income limits, can we close SNAP or Cash?

Answer: CASH: The case can only close if it meets criteria listed in Bulletin 20-68-12C. SNAP: No changes have been made to the policies and procedures for imposing negative actions for SNAP cases. If the $600 per week income puts the unit over the gross income limits, close the case the next available month, allowing for 10-day notice.

5. Question: How do we code MAXIS with the Federal Pandemic Unemployment Compensation of $600 per week? Is it a separate UNEA panel?

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Answer: Yes. When entering in Unemployment Compensation in MAXIS, create two STAT/UNEA panels. One STAT/UNEA panel will be for the ongoing regular Unemployment Compensation payments the client receives. The other STAT/UNEA panel will be for the Federal Pandemic Unemployment Compensation payments of $600 per week.

6. Question: Client applied for Unemployment Insurance: • Account Status=Active • UI Report shows that the client they received benefits that they should not have received • Overpayment balance=$230.93 • Payment Status=Not Eligible

Will this client get the Federal Pandemic Unemployment Compensation of $600 per week?

Answer: If you are unsure of the results you are finding in the Unemployment worker portal, follow up with your client for more information. DHS confirmed with DEED that if someone is not eligible for Unemployment Compensation, they will not receive the Federal Pandemic Unemployment Compensation of $600 per week.

7. Question: If a family is approved for MFIP and is prospective for March and April, the household then reports a household member started receiving Unemployment Insurance on 4/10, how is that budgeted? They are not receiving a HRF. Are they monthly reporters and still in retro budgeting, so the increase could change their June grant or are they prospective and we’d change the budget with 10 day notice for May? How would the same question apply to SNAP?

Answer:

CASH: Although monthly reporting requirements have been waived per Bulletin 20-68-12 during this public health emergency, the budgeting cycles remains the same. Refer to CM 22.06 (How and When to use Retrospective Budgeting) and CM 22.03.01 (Prospective Budgeting Program Provisions). Follow the instructions in the "Unemployment Insurance" section of the COVID-19 Guide for Eligibility Workers. In this situation April benefits were prospectively budgeted. For May this case will likely flip to retrospective budgeting, in this case use March income and for June use April income. Set a TIKL to budget the Unemployment Income in June. CASE/NOTE. SNAP: SNAP only uses prospective budgeting. If the client started receiving Unemployment Insurance, update the budget for May with this income and reduce or terminate benefits, allowing for 10-day notice.

8. Question: Does a client need to re-apply to get the Federal Pandemic Unemployment Compensation of $600 per week if their Unemployment Insurance has already been exhausted?

Answer:

CASH: Clients do need to pursue an extension of their Unemployment Insurance. Clients should log into their online account at uimn.org to find out if they are eligible for an extension. SNAP: Refer clients to their online account at uimn.org to see if they are eligible for an extension.

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9. Question: If someone is receiving Unemployment Insurance can we take that as verifying the end of employment?

Answer: No. Just because someone is receiving Unemployment Insurance does not mean that they are no longer working at that job. It may mean that they had a reduction in hours or are receiving it for another job that has ended. Verification that employment has ended is still needed. For Cash programs, this can be accepted through verbal attestation from the client. For SNAP, verbal attestation cannot be accepted from the client. However, the client can provide a verbal signature of release to contact the employer to obtain this verification.

10. Question: For applications for Cash and SNAP that are pending, when do we start counting the Federal Pandemic Unemployment Compensation of $600 per week? Is it the date of the application or the date of the SIR announcement on 04/15/2020?

Answer: Start budgeting the income the date someone starts receiving Unemployment Compensation. Everyone receiving Unemployment Compensation will also receive the Federal Pandemic Unemployment Compensation of $600 per week. The $600 per week started for the benefit week of 03/29/2020.

11. Question: Some of our participants who were employed (Casino) are now receiving Unemployment Compensation due to the closure. They are not required to report their compensation for Cash programs, correct?

Answer: Clients are not required to report changes in income, however, this income is known to the agency and will be counted as unearned income.

12. Question: Should the workers re-open Cash and SNAP cases that are closing for May due to being over the income limits with the receipt of Unemployment Insurance? The cases being closed are due to the clients reporting the receipt of UI.

Answer: No, if the case is closed for over-income, the case should remain closed. If circumstances change, the client may reapply.

13. Question: How do we treat the back payments clients receive when their UC application was pending and then gets approved? They receive all this income at once. Is it considered a Lump Sum?

Answer: Cash: Count income on the date it was received. SNAP: This is considered unearned income in the month it is received. Since SNAP uses prospective budgeting this large payment is not anticipated to continue ongoing and should not be used in the budget ongoing. Only the weekly payments that are anticipated to continue should be used in the budget ongoing.

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14. Question: If a client is receiving regular Unemployment Compensation (UC) payments and the Federal Pandemic UC payments of $600 per week and is about to exhaust their payments, should we put an end date on the regular UC payments and then continue to count the $600 per week Federal Pandemic UC?

Answer: You should end payments when they are no longer receiving UC. The CARES Act created three new temporary federally funded unemployment compensation programs to respond to the economic effects of the Coronavirus Disease 2019 (COVID-19). They are:

1. Pandemic Unemployment Assistance, which provides benefits for up to 39 weeks to individuals who are not eligible for regular UC or extended benefits and who have been COVID-impacted with regard to their unemployment (minus any weeks of regular UC and Extended Benefits (EB) the individual received);

2. Pandemic Emergency Unemployment Compensation, which provides up to 13 weeks of benefits, through December 31, 2020, to individuals who have exhausted their rights to regular state or Federal UC benefits; and

3. Federal Pandemic Unemployment Compensation, which provides an additional $600 per week to individuals who are collecting regular state or Federal UC, through weeks of unemployment ending on or before July 31, 2020.

Please see the COVID-19 Worker Guide for more information on processing these Unemployment Compensation assistance payments.

15. Question: What should we do if clients state they are not receiving the Federal Pandemic Unemployment Compensation of $600 per week?

Answer: The Federal Pandemic Unemployment Compensation (UC) of $600 per week payments started the week of 03/29/2020 and there is no delay between receiving the regular UC payments and the $600 per week payments. Clients will not see the $600 issued in their online UC account. It goes directly into their bank account or on their Reliacard. Therefore, they may not report that they are getting this money if they do not check the balance in their bank account or their Reliacard. If you have a client reporting they are not receiving the $600 per week Federal Pandemic Unemployment Compensation (UC) complete the following steps:

• Check the UC portal (if not checked already) to ensure that clients are approved and receiving regular UC benefits, to confirm they are also getting the $600 per week.

• Confirm with the client that they do not see an additional payment of $600 per week in their bank account on their Reliacard.

• If the worker portal shows the client is receiving regular UC payments and the client still does not see any payments of $600 per week, please submit a Policy Quest. When submitting a Policy Quest do not list the person’s full name or SSN, instead provide the person's MAXIS reference number.

16. Question: The Federal Pandemic Unemployment Compensation (UC) of $600 per week ends in July. If a MFIP case is in a retro budgeting cycle, then July income is counted for September benefits. Guidance states to to TIKL for August to update the case but for MFIP would a TIKL need to be created for September to remove the income for October benefits? Could a client request significant change for August and September?

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Answer: Set a TIKL in August to check when the client’s UC payments will end. Once it’s confirmed that the UC has ended, you may need to set another TIKL to remove the UC payment from the MFIP grant if the grant is retrospectively budgeted. There have been no changes made to the significant change policy.

17. Question: Staff received a UBEN matching reporting Unemployment Compensation. The client did not report it to the agency. How should we proceed to resolve this match? Can we call the client to confirm they are receiving Unemployment Compensation and resolve the match?

Answer: Refer to the COVID-19 Worker Guide for information on how to process Unemployment Compensation.

18. Question: Will workers receive a DAIL message when a client starts receiving Unemployment Compensation?

Answer: Workers may receive a UBEN match. Please see CM 10.24 (Income and Eligibility Verification System) and 10.24.03 (IEVS Match Type and Frequency) for more information about these matches. Refer to the COVID-19 Worker Guide for information on how to process Unemployment Compensation.

19. Question: I have an MFIP case that is retrospectively budgeted. The client is now receiving Unemployment Compensation (UC). Looking prospectively for June and July, she is over income due to the $600 weekly Federal Pandemic UC. However, she appears to be retrospectively eligible for June due to not receiving UC until the end of April. Should this case stay retro budgeted?

Answer: There have been no changes to the budgeting cycle. (CM 22.06 – How and When to Use Retrospective Budgeting, CM 22.03.01 – Prospective Budgeting – Program Provisions).

20. Question: Instruction for the Federal Pandemic Unemployment Compensation of $600 per week state that the income will end in July, 2020 but to contact the client in August. If the income is ending in July, would they be able to provide information to us for us to remove this in the budget for August?

Answer:

MFIP, DWP, GA, MSA, RCA and SNAP:

Since the client is still receiving income in July, the TIKL should be created in August to confirm the income has ended. DHS will provide more instructions on how to process the ending of this income when it gets closer.

Housing Support:

Please see the COVID-19 Guide for more information on how to process cases that are receiving this UC.

21. Question: Does the RCA extended eligibility bulletin #20-06-01 policy affect how we treat the $600 Unemployment Income and stimulus?

Answer: No. RCA income policy is not impacted by this waiver. Refer to the COVID-19 Worker Guide and COVID-19 Questions and Answers for how to treat the unemployment income and stimulus payments.

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22. Question: How do we determine if Unemployment Compensation (UC) payments are back payments due to the application pending and being approved and not clients delaying to request their payments? Why are these payments considered a lump sum for SNAP and how is it treated in the application month?

Answer: Clients that have an application for UC pending are instructed to continue to request benefits each week. Once their application is approved, they receive payment for all the weeks they were requesting benefits at one time. This shows as weekly payments in the Worker UC portal as being paid on the same date. Once the UC application is approved, clients will continue to receive payments each week that they request benefits and are eligible. For SNAP, the large payment is considered unearned income in the month of receipt. Since SNAP uses prospective budgeting this large payment is not anticipated to continue ongoing and should not be used in the budget ongoing. Only the weekly payments that are anticipated to continue should be used in the budget ongoing.

23. Question: How should we budget the Federal Pandemic Unemployment Compensation (FPUC) of $600 per week for August cases and new applications? It is set to end the week of July 25th. Will there be a report provided for workers to review and update cases?

Answer: For new applications, only budget the $600 per week Federal Pandemic Unemployment Compensation (PFUC) in the month of July. 07/31/2020 should be used as the end date on STAT/UNEA. For SNAP, see POLI/TEMP TE02.05.55 (Processing FS Applications – Income Ends). For ongoing cases DHS has a report of all cases receiving UC to be reviewed and updated that can be found here: UPDATED July Report of Individuals with UNEA for UI. Complete the following steps when updating each case:

1. In the footer month of August: a) Enter an end date of 07/31/20 on the UNEA panel for the FPUC income. b) Remove the income from the PROSP side, but leave the income on the RETRO side. c) Remove all information on the SNAP Prospective income calculation (PIC) pop-up window

2. Confirm that client is still receiving ongoing UC payments using the UC portal. Update income as needed on the UNEA panel for regular UC.

3. Send the case through background. Approve SNAP and cash benefits for August ongoing. 4. For cases in RETRO budget cycle, create a TIKL to update and reapprove benefits for October. 5. Create a CASE/NOTE to document all actions taken on the case.

For Housing Support cases that were suspended due to receipt of Federal Pandemic Unemployment Compensation payments:

1. Remove the additional UNEA panel after the end of the Federal Pandemic Unemployment Compensation period.

2. Confirm that the client is still receiving ongoing UC payments using the UC portal and update income as needed.

3. Send the case through background and approve changes for the next available month. 4. Create a CASE/NOTE to document all actions taken on the case.

24. Question: What about UC cases where they will have a bunch of back payments since the UC took so long to approve? Will they receive the Federal Pandemic Unemployment Compensation payments of $600 per week in August?

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Answer: Clients that requested UC benefits for any weeks from 03/29/2020 – 07/25/2020 and received payments for these weeks, will also receive the FPUC of $600 per week. This could be paid in August, if there is back pay for a pending UC application or if the client requested benefits for these weeks late. The worker portal will show the weeks requested and the dates paid. For ongoing cases, follow the guidance already issued above in question #23. For new applications, budget the income the unit received in the application month.

25. Question: Wondering about SNAP cases that were closed effective 07/01/2020 for being over income due to the $600.00/week in Federal Pandemic UC? Can we reinstate these cases for August or do they need to reapply?

Answer: You cannot reinstate a case the month after closure. The case would have to be eligible in the month of July to be eligible for a reinstatement.

26. Question: If a client has been receiving UC benefits since March 24th and now their benefit amount is going to run out mid-September, should they be applying for the Pandemic Extended Unemployment Compensation (PEUC) – a 13-week extension of unemployment benefits for workers who have exhausted their regular unemployment benefits. For cash programs, should we be sending out "Apply for other maintenance benefits" form to inform them of this?

Answer: Yes, clients must apply for benefits they may be eligible to receive, including Unemployment benefits, to remain eligible for cash programs. If their application is pending, follow the guidance in the COVID-19 Worker Guide.

27. Question: What is the policy regarding supplements of SNAP and Cash for clients who received Unemployment Compensation (UC) and the Federal Pandemic Unemployment Compensation (FPUC) of $600 per week but these payments are now established by DEED as overpayments? For these cases, should we go back and issue supplements since the client paid back their UC?

Answer: Since the client received the UC and PFUC income in the months that were budgeted for the Cash programs and SNAP, supplements should not be issued. However, if you have a case specific situation where you think a supplement should be issued, please submit a Policy Quest.

28. Question: If someone is about to exhaust their UC benefits, how should we prospectively budget them receiving an extension? Do we need to wait and check if they qualify, or just continue to budget their weekly amount for an additional 13 weeks?

Answer: Clients will receive a link in their UC online account to apply for an extension a week before their benefits will end. As long as the client applies using this link and continues to request benefits each week they will continue to receive benefits with no interruption. Continue to budget the client's regular UC benefit amount. TIKL to follow up on the case before 10-day cut off and review the UC Worker Portal to determine if anything has changed. Remind the client to follow their reporting responsibilities (for SNAP) and that they can report a reduction in income for any program.

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Verifications and Client Signatures 1. Question: What are the protocols for signatures and verifications given our state of emergency? The

options we are considering are mailing forms for signatures, mailing and having participants send a photo of signatures, or can staff indicate on forms that it was discussed via phone?

Answer: CASH: You can accept verbal signatures and verifications from clients. CASE/NOTE the verification used. SAVE is the required third-party verification system for immigration status. Please see the Immigration Status Verification section of the COVID-19 Guide for detailed instructions. SNAP: You can accept verbal signatures but verbal verifications cannot be accepted at this time. CASE/NOTE the date, time and client's phone number when you accept a verbal signature. Please continue to utilize mail, email and any other method of electronic communication your county agency or tribal nation has available to obtain client signatures.

2. Question: For people that do not have access to technology, can we extend the verification time frames?

Answer: CASH: You can accept verbal verifications from a client. CASE/NOTE the verification used. SAVE is the required third-party verification system for immigration status. Please see the Immigration Status Verification section of the COVID-19 Guide for detailed instructions. SNAP: There is no change to verification time frames at this time.

3. Question: If a client reports their job ended or their hours are reduced, do we still need to obtain verification from the employer or can we accept a client's statement? This can be challenging because the employer may not be available.

Answer: CASH: You can accept verbal verification that employment has ended. CASE/NOTE the verification used. SNAP: Please continue to utilize all methods available at your county agency or Tribal Nation to obtain verifications that employment has ended. Use a combination of public information, documents, and applications for unemployment insurance, and other available information to verify the situation. When a client cooperates but you still cannot find an adequate source of proof, work with the client to find the best available information. Get a signed statement from the client attesting to the correctness of the information. Do not deny benefits because you cannot get proof if the client has made all reasonable efforts. Review Combined Manual 10.03 (Verification - Cooperation and Consent) for more information.

4. Question: How are counties and tribes communicating electronically with clients to get signatures? Via email? Is that secure?

Answer: It is up to counties and tribes on how they are communicating electronically with clients. Whether this is via Skype, tele-conference, or e-mail. Each county and tribe is responsible for securing their email if they are using this to communicate with clients.

5. Question: Clients on MSA get a special diet provision and it decreases their SNAP benefits because they are getting extra cash. Clients have to recertify special diets at recertification. Can that be waived at this time?

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Answer: This requirement cannot be waived. However, you can accept an applicant's verbal statement of the special diet for MSA if no other verification is available. At recertification, you can continue to use existing MSA special diet verification if the client is not able to provide an updated verification.

6. Question: We received notice from the local SSA office that they will no longer be responding to 3rd party requests for information (including our requests) due to short staffing. Does this mean if there are inconsistencies or missing information from SOLQ-I we should default to information provided by the client?

Answer: CASH: You can accept a client's verbal statement as verification. CASE/NOTE the verification used. SNAP: Please continue to utilize all methods available at your county agency or tribal nation to obtain verifications. Use a combination of public information, documents, and other available information to verify the situation. When a client cooperates but you still cannot find an adequate source of proof, work with the client to find the best available information. Get a signed statement from the client attesting to the correctness of the information. Do not deny benefits because you cannot get proof if the client has made all reasonable efforts. Review Combined Manual 10.03 (Verification - Cooperation and Consent) for more information.

7. Question: If I cannot obtain verification electronically and I am unable to call a third party on the phone with the client, can I take verbal self-attestation as verification?

Answer: CASH: You can accept a client's verbal statement as verification. CASE/NOTE the verification used. SAVE is the required third-party verification system for immigration status. Please see the Immigration Status Verification section of the COVID-19 Guide for detailed instructions. SNAP: SNAP cannot accept verbal statements from client as verifications. Use a combination of public information, documents, and other available information to verify the situation. When a client cooperates but you still cannot find an adequate source of proof, work with the client to find the best available information. Get a signed statement from the client attesting to the correctness of the information. Do not deny benefits because you cannot get proof if the client has made all reasonable efforts. Review the Combined Manual 10.03 (Verification - Cooperation and Consent) for more information.

8. Question: The Work Number response takes five days. Should we wait to use this or take the client's verbal statement as verification prior to getting a response?

Answer: CASH: You should not wait for the Work Number response to approve benefits. You can accept a client's verbal statement as verification. CASE/NOTE the verification used. SNAP: SNAP cannot accept verbal statements from client as verifications. Please use the Work Number when possible or other public information to verify employment information. When a client cooperates but you still cannot find an adequate source of proof, work with the client to find the best available information. Get a signed statement from the client attesting to the correctness of the information. Do not deny benefits because you cannot get proof if the client has made all reasonable efforts. Review Combined Manual 10.03 (Verification - Cooperation and Consent) for more information.

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Note: DHS can help your agency set up an account to receive expedited responses from The Work Number. Supervisors, please contact DHS.SNAP-ME.QA@state.mn.us for assistance with this process.

9. Question: This is a general question regarding verification for MFIP and other cash programs due to the verification waiver as referenced in Bulletin 20-68-12. Under Page 2A Applying for Assistance and Interviews of the bulletin regarding phone interviews, it states that we can waive phone interviews to allow application. The reason that this will allow same day approvals. Under Page 2 C Verifications of the same bulletin it talks about using various means of getting verifications and using verbal attestation if other means of verification or not available. This seems confusing. How are we to handle verifications for applications? Are we to request verifications using the normal 10-day requirement or should we approval applications with verbal attestation so clients can get same-day approvals?

Answer: Phone interviews are not being waived. Face-to-face interviews are being waived at this time. Verify as much as you can electronically or through phone calls with third parties, such as employers. Allow signed personal statements as permitted under Combined Manual 10.03 (Verification – Cooperation and Consent) from applicants or participants. When you cannot get third party verifications electronically or through phone calls, use self-attestation for any required verification. This can be written or verbal attestation and should be documented in case notes. SAVE is the required third-party verification system for immigration status. Please see the Immigration Status Verification section of the COVID-19 Guide for detailed instructions.

10. Question: Do we still require IAAs for GA and Housing Support at this time?

Answer: Yes, IAAs are still required. DHS accepts electronic signatures or verbal consent to the IAA. When verbal consent is given, the worker should case note that. The Social Security Administration has confirmed that they will accept electronic signatures on the IAA, effective immediately.

11. Question: We have a case that is pending for 30 day residency for MFIP/DWP. Some verifications have come in but not all. Do we waive the requirement for getting in their verifications that were requested and approve on the 30th day?

Answer: Verify as much as you can electronically or through phone calls with third parties, such as employers or landlords. When you cannot obtain verifications due to conditions resulting from the current public health emergency, use self-attestation for ANY required verification. Case note. If you are not able to attain the verifications (including verbal attestations), deny the case.

12. Question: Do I need to run a SAVE inquiry to verify immigration status?

Answer: Yes, SAVE is the third-party verification that must be completed for all noncitizens, and individuals with naturalized or derived citizenship. Please see the Immigration Status Verification section of the COVID-19 Guide for detailed instructions.

13. Question: Are there any changes to the SNAP policies about using the Work Number to verify income?

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Answer: County agencies and tribal nations are to use The Work Number (TWN) to verify client income when the client is unable to obtain income verification needed or the information provided is inconsistent. An authorization to release is not required to use the Work Number. It is the client’s responsibility to provide verification of income. They have multiple options available by which to verify this (not just the Employer Verification form) and they need to be allowed the opportunity to decide which option to choose. This involves sending the client a verification request form and allowing 10 days for the client to provide the requested verification. It is the agency’s responsibility to assist if the client requests assistance. At this point, when the client has indicated they need assistance in obtaining verification, the agency can use the Work Number. If the client contacts you to request assistance before the end of the 10 day period mentioned above, you do not have to wait the full 10 days before sending the Work Number request. You can also let the client know (during an intake for example) that you have access to the Work Number system and can obtain verification on their behalf, but again, this is just one of their options. If receiving a verbal request by a client to use the Work Number, be sure to document in CASE/NOTEs.

14. Question: For GA, the client would still need to meet a basis of eligibility. Are we still requiring paper verification for this? For example, someone who states permanent or temporary illness, do we still need a MOF or Dr’s statement? Or can we take verbal attestation?

Answer: Clients still need to meet a basis of eligibility to be eligible for GA. For new applications, you can accept verbal attestation as verification at this time. For recertifications continue to use the existing verifications on file, even if expired. TIKL to follow up and obtain verification at the client's next recertification.

15. Question: The Q&A states that IAAs are still required for GA and Housing Support. It also states that SSA is accepting electronic signatures. What if client is not able to electronically sign and can only give verbal consent? Will SSA accept these IAAs? Should we track these to obtain at a later date if not able to get electronic signatures?

Answer: If clients are not able to sign the IAA, they can verbally consent to the IAA and the county should include this information in CASE/NOTE AND track these to obtain a written or electronic signature at a later date. Counties can sign the IAA electronically.

16. Question: We have employees working for Grand Casino Hinckley, which is one of the bigger employers in our county. Now the casino has closed so clients are reporting they are temporarily not working. They have not “stopped working” or “terminated employment” during this time but are currently not working. Would we need to verify the income has ended for SNAP for each employee at Grand Casino or do we just use their attestation? Should we just update the STAT/JOBs panel with $0 and hours prospectively since clients have not terminated employment but are temporarily not working?

Answer: Verification that the client is currently not working is needed to update the budget. A verbal signature of release can be accepted to contact the employer for verification if this is available. If a verbal signature of release is accepted, CASE/NOTE the date, time and client's phone number of when the verbal signature of release was obtained. If the entire Casino is closed and nobody is working there to

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confirm that the client is temporarily not working, utilize this public information for verification that the client is not currently working. When updating the budget, budget $0 prospectively on STAT/JOBS since the client has not stopped working at the job completely but is temporarily not working. CASE/NOTE the verification received, the conversation with the client about temporarily not working and why no income was budgeted ongoing. Follow the instructions in the COVID-19 Guide for when to implement the change, based on when the client reported the change and when it was verified.

17. Question: Do we still need a Professional Statement of Need for Housing Support clients that currently require one under policy?

Answer: Yes, for new applications (to meet basis of eligibility), you can accept verbal attestation of disability at this time. For recertifications, continue to use the existing statement of need on file, even if expired. TIKL to follow up and obtain verification at the client's next recertification. In order to be eligible for supplemental services, a county designee can approve the Professional Statement of Need if another type of qualified professional is unavailable.

18. Question: Can we use self-attestation for relationship verification?

Answer: Yes, see Bulletin 20-68-12C items B and C.

19. Question: During the MFIP interview, the client and worker discuss in great detail about the balance in accounts, vehicles, and earned and unearned income information. If the client says they will email in the proofs that we just discussed as they would prefer that the worker does not try to contact third parties on their behalf should the worker still continue to complete the Verification Request Form (DHS-2919) and mail it to request verification? How long does the worker actually ‘wait’ for these proofs? Can the worker process the MFIP right after the phone interview and not have to wait or ‘touch’ the case so many times before it can be processed?

Answer: Follow the procedures for verification in the COVID-19 Worker Guide. Verbal attestation is sufficient for all required verifications. Refer to the guide for more information about how to process applications.

20. Question: The COVID-19 Worker Guide says that a client’s written statement can be accepted for SNAP as a last resort if the client and the agency are unable to obtain verifications from the source. If a client is unable to read or write, how to we obtain a written statement from them? Before COVID-19, we would have these clients come into the office to assist them in writing this statement. Can the agency write up the statement and have the client verbally sign it, or do we need to mail the statement to the client to be signed and returned?

Answer: If an applicant or recipient cannot read or write, follow a similar procedure for obtaining a verbal signature for an application. The worker will write the statement and the client can verbally attest/acknowledge what the worker wrote is true. Document the date, time and phone number used to obtain the client's verbal signature of the worker's statement in CASE/NOTEs.

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21. Question: If a client is requesting significant change for an active/ongoing MFIP case (completely unrelated to COVID-19, just so happens the household had jobs ended prior to the public health emergency), do we need to have proof of the income ending prior to processing a significant change? Or can we take the client verbal attestation as to what the final pay dates were, as we can with a new application? Example: client was paid biweekly, and would have normally received two paychecks, but the job ended and he only received the one paycheck in the month, but there is no verification on file.

Answer: There have been no changes made to the significant change process. Refer to TE02.13.11 – Significant Change. Also refer to section C of Bulletin #20-68-12C on how to verify information.

22. Question: Can we accept verbal signatures for interim assistance agreements? Can they be signed electronically?

Answer: Yes. Verbal signatures are acceptable for both interim assistance forms. The Social Security Administration approved DHS to accept electronic signatures from clients and agencies on the SSI Interim Assistance Agreement (DHS-1795), which has been updated so clients and agencies can sign it electronically. The Interim Assistance Agreement (DHS-1795A) has been updated to accept electronic signatures from clients and agencies.

23. Question: Client did not respond to New Hire verification request. Can we use The Work Number to verify the income and budget accordingly for Cash and SNAP?

Answer:

CASH: No. You have not yet had a conversation with the client about utilizing the Work Number as a method to verify this information. If the client does not respond to a request for verification, TIKL to follow up at the client's next recertification. SNAP: A conversation with the client needs to happen to discuss the income they are reasonably certain will continue in the future. The client needs to respond to the request for verification. If they do not, after allowing 10-days, close the case the next available month allowing for 10-day notice.

24. Question: If a client is using Tax method. CM 17.15.33.05 (Self-Employment, Determine Countable Monthly Income – SNAP) states we need business taxes for the most current tax year that were filed within the last 12 months. Because the tax filing deadline was extended to 7/15/2020 this year we are encountering cases that want to continue to use the tax method, but do not have 2019 filed. Should we continue to use taxes filed from previous year?

Answer: Yes, you can continue to use the 2018 tax forms.

25. Question: Can we accept verbal signatures for interim assistance agreements? Can they be signed electronically?

Answer: Yes. Verbal signatures are acceptable for both interim assistance forms.

The Social Security Administration approved DHS to accept electronic signatures from clients and agencies on the SSI Interim Assistance Agreement (DHS-1795), which has been updated so clients and

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agencies can sign it electronically. The Interim Assistance Agreement (DHS-1795A) has been updated to accept electronic signatures from clients and agencies.

26. Question: Minor parent requesting MFIP, is not living with parent, can we waive the proof of relationship to who they are living with or waive need for living situation approval?

Answer: There have been no changes made to the living arrangement criteria for minor parents. We are not waiving the proof of relationship, but this can be verified through verbal attestation. The need for living arrangement approval has not been waived.

27. Question: Can custody for MFIP relative care be self-attested to?

Answer: Yes, you can use self-attestation for any required verification.

28. Question: Is self-attestation of verifications that are allowed for MFIP also allowed for the MFIP food portion?

Answer: Yes.

29. Question: For GA, if a client self-attests that they are unable to work as a basis of eligibility but then turns in a Medical Opinion Form (MOF) that states they are able to work without limitation to hours, does the client still meet a basis of eligibility?

Answer: Clients can self-attest that they meet a GA basis. A MOF is not required. A MOF that indicates the client does not meet a GA basis does not override the client’s self-attestation.

30. Question: Is self-attestation accepted for a medical extension for GA and SNAP (Work Registration Exemption)? If so how long are we extending the medical extension for (6 months, 90 days)?

Answer: The self-attestation for GA would be good until the next recertification. For SNAP, if the injury/illness was observed in order to make the client meet the "unfit for work" Work Registration exemption then this is also acceptable until the next recertification, or until the client reports changes, whichever comes first.

31. Question: We have been pushing out the dates for new medical statements for Cash programs as we had been instructed to let it continue. We are now getting notices that DISA is ending in 60 days (October). Should we be requesting new medical statements from the client or continue to push the dates back?

Answer: Send the request for a new medical statement or professional statement of need at recertification. If a client is unable to get new documentation, accept their self-attestation.

32. Question: What if there are discrepancies between a medical statement or a professional statement of need and what the client has self-attested to?

Answer: If there are discrepancies between documentation and the client’s self-attestation, submit a Policy Quest.

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33. Question: Are MFIP monthly reporters still unable to sign and date the CAF before the last day of the reporting month, or if this is waived right now due to the COVID-19 processing guidelines?

Answer: Monthly reporting requirements are currently waived during the peacetime emergency. For MFIP units not subject to monthly reporting [all MFIP units during the peacetime emergency], the CAF can be signed and dated by the caregiver(s) any time after the date MAXIS mailed the recertification packet. See CM 09.06 (Recertification Process).

34. Question: If a client is emailed the DHS-2919 (Verification Request Form) is the county or tribal agency still required to send this form through the mail to the client?

Answer: The form still needs to be mailed even if it is sent to the client via email. CASE/NOTE that the form was emailed and mailed to the client. As a reminder, follow your agency's procedures for ensuring data privacy when emailing clients.

35. Question: Do the verbal signatures provisions for SNAP and Cash programs apply to appointing a new AREP authorized to apply or act on the client's behalf? Specifically, could a client appoint an AREP on a verbal application by having both the authorized representative and the client on the phone for the interview so that both could provide their verbal signature and consent?

Answer: Yes, verbal signatures can be used to appoint a new authorized representative. CASE/NOTE the date, time and phone numbers of the client and the authorized representative of when the verbal signatures were received. Be sure to review authorized representative designation at recertification time to determine if anything has changed. Note: This is different than appointing someone to use a client's SNAP benefits on their behalf. See the COVID-19 Guide for more information.

36. Question: When we obtain a verbal signature from a client as an authorization of release should we be saving a copy of the blank release with a note on it that the signature was given verbally, or is it sufficient if we CASE/NOTE that they gave verbal permission for us to contact the employer?

Answer: Follow your county or tribal procedures for how to include forms in the case file when possible. Regardless of whether or not the form is in the case file, CASE/NOTE the date, time and phone number that the verbal signature of release was provided. Also CASE/NOTE the relevant information on the release form that the client is verbally signing.

37. Question: If a participant has an expired MOF that has been extended due to COVID-19 policy and submits a new MOF (in paper form or by verbal attestation), should it be acted on?

Answer: Yes, if the participant submits a new/updated MOF, this information should be acted upon. NOTE: Verbal attestation is acceptable for the duration of the public health emergency.

38. Question: A client applied for MFIP and did not want to self-attest to verifications for income or assets. They have not sent in any verifications. Can we still deny this at 30 days?

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Answer: Assuming the DHS-2919 was sent for this application and that efforts have been made to assist the client with obtaining any needed verifications, this would be considered non-cooperation with the application process. The application should be denied if the client does not provide verifications.

39. Question: On MFIP cases that typically require calendars does DHS want us to send 2919 and calendars? If not returned we are unable to close? If returned and the child(ren) are no longer with that household more than half of the time we are able to close MFIP?

Answer: Yes, send the DHS-2919 and calendars. Self-attestation can be accepted for any required verification. Failure to return verifications is not a closure reason for MFIP, however, the case can be closed for no children remaining in the household, including when the youngest child in the household turns 18 or 19 and has graduated.

40. Question: We have experienced that there are financial institutions who will not accept verbal signatures on releases to determine asset values. Any suggestions to help with this? Do we just take self-attestation and not worry about getting proof from financial institutions?

Answer: You do not need to verify assets for SNAP. For Cash programs, you can accept either a verbal attestation from the client or they can complete the DHS-6054 (Signed Personal Statement About Assets for Cash Programs). See CM 10.03 (Verification – Cooperation and Consent) for more information.

Training 1. Question: Are there any updates to training or new employees?

Answer: Please see the announcement on 03/17/2020 for further information about training. If you have any questions please contact Tracy Scott at Tracy.K.Scott@state.mn.us.

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