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Unclear Information

You must pursue and resolve certain “unclear information” you receive about the household. Unclear information is information that you cannot act on because you lack adequate verification. You may receive this information from the data exchange discrepancies (NHL and OWG), an employer, or a person claiming knowledge of the household’s circumstances.

When to pursue and resolve “unclear information”?
Federal Rules require us to pursue and resolve unclear information when it 

1.  significantly conflicts with the information used to certify SNAP or

2. is less than 60 days old and information that—if true—the household must report due to its reporting responsibilities.

Note: The 60 day clock runs from the reportable event to when DHS receives the unclear information. It does not apply to information that significantly conflicts with the information used to certify SNAP.

How to pursue “unclear information”?
Step 1: ​When you receive notice of any unclear information, determine if the reported information meets either of the two criteria above.
  • When the information does not meet these criteria, case note it for review at the next renewal.
  • When the information does require you to pursue and resolve it, send the household a Client Contact and Information Request (Form 08AD092E or ADM 92). You must allow the household 10 calendar days to respond and inform it that if it does not respond the benefit will close.
Step 2: Your next step depends on how the household responds.
  • When the household does not respond or provide adequate verification to resolve the unclear information, close the SNAP benefit. The closure reason is "FAILED OR REFUSED TO PROVIDE NECESSARY VERIFICATION WITHIN THE TIME ALLOWANCE (45)." Give the household an appropriate notice when taking this action.

Example 1:

Hugh receives food benefits. He is the only person in a change reporting household you certified on January 10. On March 1, you review a New Hire edit that shows he began working for the local gas station on January 17. It does not show Hugh’s rate of pay or how often he is paid. Is this unclear information that you have to pursue?

Yes, it is. Change reporting household must report changes in the source of income, and the New Hire is less than 60 days old. Send the Client Contact and Information Request (Form 08AD092E or ADM 92) to Hugh asking him to verify his income situation. If he does not respond in 10 calendar days, close his SNAP benefit effective April 1.

Example 2:

Lorena and her five-year-old daughter Lexi receive SNAP benefits. You certified their SNAP benefit without income because Lorena reported she had no income and was living with her father. They are in a semi-annual reporting household. Lorena called to let you know she has been working for a month. She reports earning $12 per hour for 40 hours per week. She receives biweekly pay. During the call, you ask Lorena to provide her last 30 days of pay verification and send a Client Contact and Information Request. After ten days, Lorena has yet to send her checks. What do you do? 

Lorena’s SNAP benefit must close. The gross income standard for a household of two is $1,784. The reported income, if true, exceeds that standard ($12*40=$480*4.3=$2,064). She reported income that as a semi-annual reporter she must report. Since you pursued this income but did not receive adequate verification, the benefit must close.

Example 3:

Janet receives SNAP benefits using W months. She is a semi-annual reporter. On May 5, she submits a Change in Household Circumstances Form (08FB038E or FSP-38). The Change Form indicates her employment ended on March 7. She does not provide termination verification. You first notice this form on May 14. Is the information less than 60 days old? Is it unclear information? 

The information is less than 60 days old. The clock starts when the change occurred and ends when this information arrives at DHS. It does not matter that you did not review it within 60 days. We must still evaluate it. Semi-annual reporting households must report when an ABAWD stops meeting the work rule, so this change is a change where you must pursue it as unclear information.

Example 4:

You certified Brie’s food benefit on January 18, 2019. Her SNAP benefit included Brie and her nine-month-old son William. On April 25, 2019, you receive an OIG (Office of Inspector General) allegation that reports Brie’s husband Frank has lived with her since they married in June 2018. The allegation reports that Frank works for a local car dealership. Does this report qualify as unclear information that you must pursue and resolve?

This OIG allegation is unclear information that you must pursue and resolve because it conflicts with information used at certification. The unclear information includes both the undisclosed household member and income. The 60 day clock does not apply to unclear information involving certifications. It only applies to situations that occur after certification in a non-report month.

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