BPRO FALL CONFERENCE OCTOBER 2014 The Work Requirement Clock HICKORY DICKORY DOCK The Work Requirement The Work Requirement provisions are found in the SNAP guidance manual, Part 15, Chapters A, B and C. Prior to October 1, 2013, residents of all Virginia localities had been exempted from the Work Requirement since April 2009. Effective October 1, 2013, the Work Requirement came back into effect for all Virginia localities; however, effective May 2014, 23 localities in Virginia became exempt. Coding E7 codes should not be in place after October 2013 for any nonexempt locality. For the 23 exempt localities, there should be no E7 from October 2013 until May 2014, at which point the E7 would be used. Exempt Localities Effective May 2014 to April 2015, residents of the following localities are exempt from the Work Requirement: Brunswick, Carroll, Charlotte, Danville, Dickenson, Franklin City, Galax, Grayson, Greensville/Emporia, Halifax, Henry/Martinsville, Lunenburg, Mecklenburg, Page, Patrick, Petersburg, Prince Edward, Smyth, Surry, Sussex, Williamsburg The Clock The Work Requirement clock tracks the status of household members in the age range, 18 to 50. It is a tracking system in ADAPT. It is also used to queue the sanction screen to disqualify members who have used up their time limited benefits. Work Requirement Codes ABAWDS CODE TABLE ABAWDS PROVISION APPLIED - NOT EXEMPT 1ST 3 MOS ALREADY RECEIVED 1ST 3 MONTHS OF BENEFITS ABAWDS PROVISION APPLIES - NOT EXEMPT 2ND 3 MOS ALREADY RECEIVED 2ND 3 MONTHS OF BENEFITS EXEMPT - WORKING AT LEAST 20 HRS/WK EXEMPT - ACTIVE IN AN APPROVED WORK PROGRAM EXEMPT - A DEPENDENT CHILD UNDER 18 IS IN THE SNAP HH EXEMPT - PREGNANT EXEMPT - MEDICALLY CERTIFIED AS UNABLE TO WORK EXEMPT - EXEMPT FROM WORK REGISTRATION EXEMPT - LOCALITY WAIVED FROM REQUIREMENT EXEMPT - UNDER AGE 18 OR OVER 49 NO BENEFITS REC-D (TRACKING ONLY - INVALID STATUS CODE) PRORATED MONTH (PRORATED MONTH AND IS NOT COUNTED AS ONE OF THE Y1 OR Y2 THREE MONTH TIME LIMIT) BENEFITS REC'D IN ERROR-EXCEEDS MAX Y1 OR Y2 MONTHS (TRACKING ONLY - INVALID ABAWDS STATUS CODE) LOST EXEMPTION. NO OTHER EXEMPTION MET. NO OVERISSUANCE AS NOT REQUIRED TO REPORT * Y1 * YX * Y2 * YZ * E1 * E2 * E3 * E4 * E5 * E6 * E7 * E8 * NB * PM * IM *LE The Work Requirement The Work Requirement must be addressed for all household members at application, reapplication, recertification, interim report, and when a change occurs. The Work Requirement The work requirement mandates that all persons who are able to work must be working or actively engaged in a work activity in order to receive SNAP benefits. ABAWDS Work Requirement is commonly referred to as: ABAWDS – Able Bodied Adults Without Dependents The Work Requirement Unless an exemption to the work requirement exists, individuals may receive SNAP for only three months during a thirty-six month period. Y1 These three months are known as Y1 months. There can be only 3 Y1 codes used in each 36 month clock period. Regaining After Y1 months have been exhausted an individual can receive a second “set" of benefits, BUT ONLY after periods of employment, provided eligibility has been regained. Y2 The regained months are Y2 months. There can be only 3 Y2 codes used in each 36 month clock period. General Provisions In order to receive benefits beyond three months, a non exempt able-bodied household member must: General Provisions Work for cash wages in any amount or for in-kind goods or services for 20 hours or more per week, averaged monthly General Provisions Participate in and comply with requirements of an employment services program operated by the Department of Social Services, other than job search, for 20 hours or more per week or for the number of hours assigned for the work experience component as calculated by the household’s allotment divided by the federal minimum wage General Provisions - Participate in and comply with nondepartmental (DSS) work programs for 20 hours or more per week -Serve in an unpaid, volunteer capacity for a public or private agency, at a minimum, for the number of hours that is equal to the household’s allotment divided by the federal minimum wage -Any combination of the above General Provisions If the member was unable to work and is able to show good cause, the member will meet the Work Requirement as long as the absence is temporary and the member retains the job. E1 A person working 20 hours or more per week must report if their hours fall below 20 hours per week Per Part 14, Chapter A. Who is exempt from the Work Requirement? Any person who is: -under age 18 -50 and over Who is Exempt? Any adult member of a SNAP household that has a child under age 18 included Example SNAP household consists of the following members: John age 22, Mindy age 17, Gina age 38, Holly age 45 Joan age 29, George age 21 and Ruth age 34. Who is Exempt? Because Mindy is under 18, all members of the SNAP household are exempt from the Work Requirement. Who is Exempt? Any person who is medically certified as mentally or physically unable to work A pregnant woman Who is exempt? Any resident of an exempt locality There are 23 exempt localities in Virginia Who is Exempt? Any person who is otherwise exempt from work registration as outlined in Part 8.A.1 including: An attendant for an incapacitated person Applicants for and recipients of Virginia unemployment benefits Participants in drug or alcohol treatment and rehab programs Students enrolled at least half time in an institution of higher education who meet the special criteria of part 7, E. Students enrolled at least half time in any recognized school or training program. 18 Work Requirement does not apply until the month following the month the person turns 18. 50 Work Requirement no longer applies the month following the month the person turns 50. PM Months in which the household does not receive a full month’s allotment due to proration will not count toward the 3 month limit. Any month in which a person receives the full benefit month as part of a certified household will count toward the 3 month limit. Y1 Y1’s are the first set of months received for time limited benefits. There can never be more than 3 Y1 months used during a fixed 36 month period. They do not have to be used consecutively. Y2 Y2 months are the second set of time limited benefits. In order to be eligible for Y2 months, a person has to regain eligibility. Regaining eligibility means that a person must have worked 80 hours in a 30 day period while not in a Y month. Y2 months must be used consecutively. Y2 Unless questionable, the work that was performed to regain eligibility does not have to be verified. We must document the place of employment, the time of employment and the number of hours worked. The Clock The work requirement clock is a 36-month fixed period It begins the first month a case is certified in Virginia for any household member in the age range Since the period is fixed, the clock stays in place and must be updated (if the person reapplies) even when no benefits are received The Clock When the 36 month clock ends, the next clock will begin the month after the previous clock ends, for persons who are active SNAP recipients. For persons not active when the clock ends, a new clock will start in the month the person reapplies. The Clock ALL individuals in the age range must have a clock—even if the person is exempt or meeting the provisions of the work requirement. Example George and Joan both receive SNAP and both are SSI recipients. George is 28 and Joan is 25. The receipt of SSI make each of them exempt from the Work Requirement. However, each of them must have a clock until they reach age 50. Clock Clock follows person from HH to HH. Months with no benefits will be coded as NB PM Months where a household receives prorated benefits, or months in which the household does not receive an allotment because benefits are prorated to zero will not count toward the 3 month limit. They will be coded as PM months. Work Requirement Codes ABAWDS CODE TABLE ABAWDS PROVISION APPLIED - NOT EXEMPT 1ST 3 MOS ALREADY RECEIVED 1ST 3 MONTHS OF BENEFITS ABAWDS PROVISION APPLIES - NOT EXEMPT 2ND 3 MOS ALREADY RECEIVED 2ND 3 MONTHS OF BENEFITS EXEMPT - WORKING AT LEAST 20 HRS/WK EXEMPT - ACTIVE IN AN APPROVED WORK PROGRAM EXEMPT - A DEPENDENT CHILD UNDER 18 IS IN THE SNAP HH EXEMPT - PREGNANT EXEMPT - MEDICALLY CERTIFIED AS UNABLE TO WORK EXEMPT - EXEMPT FROM WORK REGISTRATION EXEMPT - LOCALITY WAIVED FROM REQUIREMENT EXEMPT - UNDER AGE 18 OR OVER 49 NO BENEFITS REC-D (TRACKING ONLY - INVALID STATUS CODE) PRORATED MONTH (PRORATED MONTH AND IS NOT COUNTED AS ONE OF THE Y1 OR Y2 THREE MONTH TIME LIMIT) BENEFITS REC'D IN ERROR-EXCEEDS MAX Y1 OR Y2 MONTHS (TRACKING ONLY - INVALID ABAWDS STATUS CODE) LOST EXEMPTION. NO OTHER EXEMPTION MET. NO OVERISSUANCE AS NOT REQUIRED TO REPORT * Y1 * YX * Y2 * YZ * E1 * E2 * E3 * E4 * E5 * E6 * E7 * E8 * NB * PM * IM *LE LE LE is the code used for lost exemption. It is used when someone loses an exemption but is not required to report the change. It is used retroactively to capture the change, but not penalize the person. LE Example Mary, age 36, receives SNAP along with her five year old son Sam. Mary has been certified for one year, January 2014 to December 2014. Mary would be coded as an E3. She comes in for her renewal on December 10 and reports Sam no longer lives with her and left the home on August 8. LE Example, Continued This was not a change that Mary was required to report. Based on that, her clock will read January to August E3, September to December LE. Because the change was not required to be reported, there will be no penalty to the person. LE Case certified August 2013 to July 2014. Household reports loss of a job on April 16. The job ended March 15. No exemption to the work requirement. Coding would be: Oct 2013 to March 2014 – E1, April – LE, May to July 2014 – Y1. Sanctions code YX After a client has used up their 3 Y1 months, the ABAWD status code should be changed to YX. A sanction screen will be automatically prompted in ADAPT for the individual for completion. Y2 Remember Y2 months must run consecutively and must not be changed! YZ After a client has used up their 3 Y2 months, the ABAWD status code should be changed to YZ. A sanction screen will be automatically prompted in ADAPT for the individual for completion Tip Months in which a household is eligible to receive benefits but does not actually participate do not count toward the three month limit. Y2 After receipt of the Y2 months, a nonexempt member is not eligible, unless they meet an exemption or begin a new 36 month period. Tip Months for which a household repays benefits received in error will not count toward the three month limit once the household repays the claim in full. Certification Periods Individuals who do not meet an exemption and are subject to the Work Requirement should be assigned a three or four month certification period. The four month cert period is used only if the first month is less than a full benefit amount caused by proration. Cert Period If the household contains a member that is subject to the Work Requirement, a three or four month certification period must be assigned. If prorated benefits are not issued, the cert period may be no more than 3 months. Cert Period example For example, if you had a snap HH with an SSI recipient, but their spouse was subject to work requirement, you would assign a three month or four month cert period If a person receives SNAP benefits during the current 36 month period from a different locality or state, those months must be taken into consideration Per Part 2, Chapter E of the SNAP manual. Remember the clock starts the month a person is certified in Virginia. Y1 months have been exhausted. Client starts to work before the cert period ends and is working 20 hours or more per week, now meets a work requirement rule and can be certified for a normal cert period, without having to regain eligibility. Y1 months have been exhausted. Client starts to work after the cert period ends and works fewer than 30 hours per week, client must regain eligibility. Y1 months have been exhausted. Client starts to work after the cert period ends and works 30 hours or more per week, the person meets the Work Registration exemption and is exempt from the Work Requirement. Y1 months have been exhausted. Client has been off SNAP and comes back in but does not meet an exemption and is not working, client would have to do 80 hours in a 30 day period to regain eligibility in order to get Y2 months. Y1 months have been exhausted. Client was working when cert period expired. Client has been off SNAP and now comes in and is working 20 or more hours. Client meets the 20 hour work rule and can be certified for a normal cert period. Y1 months have been exhausted. Client was not working when cert period expired. Client has been off SNAP and now comes in but is not working. He does not meet an exemption. He must regain eligibility before he is eligible for Y2 months. Tip A household member disqualified due to the Work Requirement has their income prorated to the rest of the household. Changes must continue to be reported for these household members. Change If someone subject to the Work Requirement and not exempt is added to an ongoing case, an alert must be set to disqualify that household member after the 3rd Y1 or Y2 month is used. ADAPT should generate an alert at the beginning of the 3rd month. An advance notice is required. Corrections Please take the time to correct the Work Requirement clock on a case you work on. It can make a difference if QA pulls the case between a correct case and an error finding. It can impact a client not receiving SNAP benefits that they are entitled to, and vice versa. Time for Questions Thank you for your time! Lisa Colandene-Nouri SNAP Consultant Northern Regional Office Virginia Department of Social Services 540-347-6325 lisa.colandene-nouri@dss.virginia.gov