Library: Policy

340:50-3-3. Verification

Revised 9-15-21

(a) General verification standards. Verification is the use of documents or third party information to confirm the accuracy of statements made on the application. Refer to Oklahoma Administrative Code (OAC) 340:50-5, for non-financial verification criteria and OAC 340:50‑7 for financial eligibility verification criteria. When the household must provide documentation to verify eligibility before receiving or continuing to receive benefits, the worker provides the household with Form 08AD092E, Client Contact and Information Request, that lists required verification and gives the household at least 10-calendar days to provide the verification. • 1

(b) Mandatory verification. The worker must verify the eligibility factors in (1) through (11) of this Subsection before certifying a household initially applying for Supplemental Nutrition Assistance Program (SNAP) food benefits for a normal certification period, per Section 273.2(f)(1) of Title 7 of the Code of Federal Regulations (7 C.F.R. § 273.2(f)(1)). When the household is eligible for expedited service processing, the worker may postpone verifying eligibility factors, other than identity, when they cannot be verified within the seven-calendar day period, per OAC 340:50-11-5.

(1) Able-bodied adults without dependents (ABAWD) subject to the time limit. When there is an ABAWD subject to the food benefit time limit living in the home, the household must verify the hours the ABAWD works or participates in a work program and, if there is an indication that the ABAWD received food benefits in another state, the number of countable months received there, per 7 C.F.R. § 273.24 and OAC 340:50-5-100.

(2) Citizenship and alien status. The household must verify the citizenship or alien status of household members, per OAC 340:50-5-67.

(3) Disability. A household member's disability must be verified, per OAC 340:50-5-4 when it affects SNAP eligibility.

(4) Gross nonexempt income. The gross nonexempt income of all household members must be verified, per OAC 340:50-7-29 and OAC 340:50-7-30. However, when attempts by the household and the worker to verify the income are unsuccessful because the person or organization that provided the income fails to cooperate and other sources of verification are unavailable, the worker uses the best available information to determine household income.

(5) Household composition. The household must verify household composition, when questionable, per OAC 340:50-5-1 through 340:50-5-3.

(6) Identity. The identity of the person submitting the SNAP application must be verified, per OAC 340:50-5-65.

(7) Legal obligation to pay child support. Prior to allowing a deduction for legally-binding child support payments, the legal order and payment amounts must be verified, per OAC 340:50-7-31(a)(5).

(8) Medical expenses. A medical expense deduction is only allowed for household members meeting the definition of elderly or disabled, per OAC 340:50-5-4. Before allowing a medical expense deduction, the household must verify medical expenses exceeding $35 per month, per OAC 340:50-7-31(a)(3).

(9) Residency. The household is required to verify it resides in Oklahoma, per OAC 340:50-5-66.

(10) Social Security number (SSN). Each household member must provide his or her SSN to participate in SNAP, per OAC 340:50-6-68.

(11) Students. When a household member claims to be physically or mentally unfit for purposes of the student exemption, per OAC 340:50-5-45, and the unfitness is not evident to the worker, verification may be required. Appropriate verification may consist of receipt of temporary or permanent disability benefits issued by governmental or private sources, or of a statement from a physician or licensed or certified psychologist.

(d) Documenting case files.

(c) Sources of verification. Sources of verification that may be used to establish eligibility include, but are not limited to, (1) through (8) in this subsection, per 7 C.F.R. § 273.2(f)(4).

(1) Documentary evidence. The worker uses documents, whenever possible, as the primary source of verification for all items except residency and household size. Documentary evidence consists of a written confirmation of a household's circumstances. Examples of documentary evidence include wage stubs, rent receipts, and utility bills. • 2

(A) Although documentary evidence is the primary source of verification, the worker cannot limit the type of verification to a single document. The verification may be obtained from the household or another source.

(B) When information from another source contradicts statements made by the household, the household is immediately afforded the opportunity to resolve the discrepancy.

(C) When documentary evidence cannot be obtained or is insufficient to make an eligibility determination or benefit level, the worker uses alternate verification sources, such as collateral contacts and home visits.

(2) Collateral contacts. The worker has the responsibility to verify all factors of eligibility for food benefits that may require one or more collateral contacts. The client's signature on the food benefit application, mid-certification renewal, or Form 08AD060E, Request for Release of Information, grants the necessary authorization for securing required information or verification. • 3

(A) A collateral contact is a verbal confirmation of a household's circumstances by a person outside the household. The collateral contact may be made in person or by phone.

(B) The acceptability of a collateral contact is not restricted to a particular person, but may be anyone able to provide an accurate third party verification of the household's statement. Examples of acceptable collateral contacts are:

(i) employers;

(ii) community action groups;

(iii) migrant service agencies;

(iv) neighbors of the household;

(v) landlords;

(vi) social services agencies; or

(vii) other persons outside of the household.

(C) When the collateral source is one that requires written authorization before supplying information to Oklahoma Human Services (OKDHS) and the applicant or recipient's signature on the application or mid-certification renewal does not suffice, the worker obtains the appropriate household member's signature on Form 08AD060E, Request for Release of Information.

(3) Home visits. A home visit may be used as verification on a case-by-case basis only when documentary evidence is insufficient or cannot be obtained from other sources and the visit is scheduled in advance with the household.

(4) Discrepancies. When the worker receives unverified information from a source other than the household that contradicts the household's statements, the worker gives the household a reasonable opportunity to resolve the discrepancy prior to determining eligibility or benefits. The worker may choose to verify the information directly and contact the household only when verification efforts are unsuccessful.

(5) Use of State Data Exchange (SDX) and Beneficiary and Earnings Data Exchange (BENDEX). The worker may verify Supplemental Security Income benefits (SSI) through SDX and Retirement, Survivors, and Disability Insurance (RSDI) benefits through BENDEX or through verification provided by the household. • 4 The worker may also use SDX and BENDEX data to verify other SNAP eligibility criteria except date of death. • 5 When the SSI or RSDI income reported by the household differs from the amount shown on SDX or BENDEX or is unavailable, the worker gives the household the opportunity to verify the income from another source.

(6) Mandatory use of Income and Eligibility Verification System (IEVS). OKDHS must obtain information through IEVS, per procedures specified in 7 C.F.R. § 272.8 and (A) through (C) of this paragraph to help verify the household's eligibility and benefit level. • 6

(A) OKDHS must obtain:

(i) wage and unemployment insurance benefits information from the Oklahoma Employment Security Commission;

(ii) SSI, RSDI, federal retirement, and net earnings from self-employment, wages, and retirement income payments from the Social Security Administration; and

(iii) unearned income information from the Internal Revenue Service.

(B) OKDHS may exchange information with agencies in other states that administer Temporary Assistance for Needy Families, Medicaid, food benefits, unemployment compensation, or a state program administered under a plan approved under Title I, X, or XIV, or XVI of the Social Security Act.

(C) The worker takes action to close, deny, or reduce benefits based on information obtained through IEVS that is considered verified upon receipt, per (e) of this Section, unless the information is questionable for a particular household. When IEVS information is questionable or not verified upon receipt, the worker obtains additional verification from the household or from the income or benefit source before taking action, per (f) of this Section for applications or OAC 340:50-9-5(i) during the certification period.

(7) Mandatory use of the Systematic Alien Verification for Entitlement (SAVE). Households are required to submit documentation for every alien applying for SNAP benefits so OKDHS can verify their immigration status through the Alien Status Verification Index (ASVI). SAVE is maintained by the United States Citizenship and Immigration Services (USCIS). • 7

(A) When immigration status verification is required, the worker gives or sends Form 08AD092E, Client Contact and Information Request, to the household to provide an acceptable document within 10-calendar days. When the worker:

(i) gives the household at least 10-calendar days to provide the documentation before the 30th day of the application period and the household fails to do so, the worker: • 8

(I) denies the application when immigration status documentation is required for all household members; or

(II) certifies SNAP food benefits for all eligible members and denies benefits for the members whose immigration status has not been verified; or

(ii) does not give the household at least 10-calendar days to provide the verification before the 30th day of the application period and the household is otherwise eligible, the worker must certify SNAP food benefits by the 30th day for the household, including the alien whose status is not verified.

(B) When the household provides alien documentation, but SAVE does not confirm the validity of an alien's documents or there is a significant discrepancy between the data provided by SAVE and the information provided by the household, OKDHS submits Form USCIS G-845, Verification Request, and a photocopy of the alien's document to USCIS for further verification. The worker does not delay, deny, reduce or close the alien's food benefits pending a response from USCIS when the alien is otherwise eligible for benefits.

(C) SAVE may also be used to confirm if an alien has a sponsor who signed a legally binding affidavit of support, per OAC 340:50-5-67.

(8) Food stamp disqualification (FSD). OKDHS uses the FSD transaction to determine if a household member is disqualified for SNAP food benefits due to fraud at application, certification renewal, and when adding a household member to the SNAP benefit. When a household member is disqualified in Oklahoma or another state, the FSD transaction shows the date the disqualification began and the length of the disqualification. • 9

(d) Responsibility for providing verification.

(1) Household responsibility. The household has primary responsibility for providing documentary evidence to support statements made on the application or certification renewal and to resolve questionable information. Households may supply documentary evidence in person, by mail, fax, or email, or through an authorized representative.

(2) Worker responsibility. The worker assists the household in obtaining this verification provided the household cooperates with the worker. The worker's assistance may range from explaining how or where to obtain proof to obtaining proof when the applicant is unable to do so.

(A) The worker accepts reasonable documentary evidence provided by the household and is primarily concerned with how adequately the verification confirms statements on the application.

(B) The household is not required to provide multiple sources of verification when the household provided information that adequately supports the statements on the application. However, the worker may require the household to provide additional verification when the existing verification is incomplete or questionable.

(C) Whenever documentary evidence is insufficient to make an eligibility decision or cannot be obtained, the worker may phone a collateral contact or make a home visit, per (b)(2) or (3) of this Section.

(D) An application is never denied solely because a person outside of the food benefit household fails to cooperate in providing information, verification, or other help needed to process an application. Disqualified or ineligible persons are considered members of the food benefit household for this provision.

(e) Information considered verified upon receipt. Information considered verified upon receipt is information that is not questionable or unclear and the provider is the primary source of the information. For example, RSDI and SSI income verified with the Social Security Administration (SSA) or unemployment benefits verified by the Oklahoma Employment Security Commission (OESC) through data exchange are considered verified upon receipt because SSA and OESC are primary sources. • 10

(f) Questionable information. Prior to certification, the worker must verify questionable factors of eligibility, including all factors affecting household composition, only when they affect a household's eligibility and benefit level, per 7 C.F.R. § 273.2(f)(2). For example, the worker may determine that additional verification is required when the household reports its expenses exceed its income prior to deductions. • 11

(1) Questionable information. To be considered questionable, the information on the application must be inconsistent with:

(A) statements made by the applicant;

(B) other information in the case record; or

(2) Documentation. There must be documentation as to:

(A) the reason the information was considered questionable;

(B) what documentation was used to resolve the questionable information; and

(3) Determination. When determining if information is questionable, the worker bases the decision on each household's individual circumstances.

(g) Documentation. Case records must be documented in detail to support eligibility, ineligibility, and benefit level determinations.. • 2

(h) Verification required during the certification period. Refer to OAC 340:50-9-5 for information regarding required verification when changes occur during a certification period.

(i) Verification required at certification renewal. At certification renewal, the household must verify:

(1) income when the income source changed or the income amount changed by more than $50. The worker does not verify income when the source or amount of income has not changed or changed by $50 or less, unless the information provided is incomplete, inaccurate, inconsistent or outdated;

(2) new or previously unreported medical expenses when a household member(s) is eligible for the medical expense deduction, per OAC 340:50-7-31. The worker also verifies recurring medical expenses that changed more than $25 since certification or the most recent certification renewal. The worker does not verify total medical expenses when the amount claimed by the household has not changed or changed by $25 or less, unless the information provided is incomplete, inaccurate, inconsistent, or outdated;

(3) any changes in a household member's legal obligation to pay child support, the obligated amount, or the legally-obligated child support amount paid by a household member to or for a non-household member, including payments made to a third party on behalf of the non-household member.

(A) The worker verifies the household's child support obligation and payment information through Child Support Services (CSS) when possible, unless the household disagrees with the amount provided by CSS.

(B) When child support payment information is not available through CSS or the household disagrees with the amount shown, it must provide other verification to verify any changes in the legal obligation to pay child support, the obligated amount, and the amount paid to a non-household member before this deduction may be given.

(C) When the child support obligation and payment amount has not changed, the worker verifies child support information only when the information provided is incomplete, inaccurate, inconsistent or outdated;

(4) newly obtained social security numbers;

(5) a household member's work hours when he or she is subject to work requirements, per 7 C.F.R. § 273.24 and OAC 340:50-5-100; and

(6) any other information that changed since initial certification or the most recent certification renewal when it affects eligibility.

INSTRUCTIONS TO STAFF 340:50-3-3

Revised 9-15-21

1. The worker completes Form 08AD092E, Client Contact and Information Request, listing the verification needed to determine eligibility and gives or mails it to the household. The worker only checks the items required for that household based on program specific policy. For example, the worker does not check resources when resources are not a factor of eligibility or self-employment when the household did not report that someone in the household was self-employed.

(1) When the household fails to provide all or part of the requested verification, the worker does not send a new Form 08AD092E.

(2) When the worker requests verification not listed on the original Form 08AD092E, he or she must provide a new Form 08AD092E giving the household at least 10-calendar days to provide the additional information.

(3) When the client contacts the worker to check on the status of the application, the worker verbally informs the client of any required verification still needed and that the application will be denied by the 30th calendar day following the application date if the verification is not provided.

(4) In order to provide better customer service, the worker may initiate a call to the client to inform him or her of the verification that is still needed, and what day is the 30th calendar day following the application date. The worker may resend the original Form 08AD092E when he or she is first able to explain why it is being sent and there is a reasonable period of time for the household to receive the form and respond.

(5) The worker must record all face-to-face, verbal, and written household contacts in Family Assistance/Client Services (FACS) Case Notes including:

(A) the date of the contact;

(B) whether the contact was face-to-face, verbal, or in writing;

(C) the name of the person contacted;

(D) whether the contact was worker or client initiated; and

(E) when verbal:

(i) any information provided by the client regarding eligibility;

(ii) what the worker advised the client regarding outstanding verification, if applicable;

(iii) whether the worker resent the original Form 08AD092E or sent a new Form 08AD092E requesting additional verification; and

(iv) any other information the worker gave regarding the application process and time frame.

2. The worker records in FACS case notes:

(1) a description of the verification provided and receipt dates;

(2) dates and amounts of all income received by the household;

(3) how income and deductions were computed to arrive at the household's countable income; and

(4) what, if any, information provided by the household was considered questionable, and how the worker resolved any such discrepancies.

3. (a) The household typically designates the name of the collateral contact. The worker may designate the collateral contact or ask the household to designate a different collateral contact or provide an alternate form of verification when he or she does not expect the one designated by the household to be able to provide an accurate third party verification.

(b) When talking with collateral contacts, the worker avoids disclosing that the household applied for food benefits and only discloses enough information to get the needed information.

4. (a) Beneficiary and Earnings Data Exchange System (BENDEX). BENDEX provides verification of Retirement, Survivors, and Disability Insurance (RSDI) benefits and Medicare entitlement. To view, enter BEN space RSDI claim number. Review Quest article "IMS: BENDEX Income Codes." Field B07 contains the Social Security claim number.

(1) When using BENDEX to verify RSDI benefits, the worker drops any cents from the gross benefit amount in BENDEX Field B27 and uses only the whole dollar figure. For example, round $349.50 to $349.00.

(2) When a person is dually entitled to receive RSDI benefits under two Social Security claim numbers, the person may receive benefits under one or both claim numbers.

(A) When the person receives a combined benefit, BENDEX displays two records for the person. Each record displays a "D" for dual entitlement in Field C21 and the cross referenced Social Security claim number in BENDEX Field B20.

(i) The worker counts the income displayed under the BENDEX record with a current pay (CP) payment status code in Field B20. The person receives the combined RSDI benefit amount under this Social Security claim number.

(ii) The worker does not count the income displayed in the BENDEX record with the adjusted for dual entitlement (AD) in payment status code Field B20. The AD means the person does not receive income under this BENDEX record.

(B) The benefit issuance process used by the Social Security Administration may cause a $1 or $2 difference in the actual payment made to a person who receives combined benefits.

(C) When the person receives benefits under both Social Security claim numbers, each BENDEX record displays a CP in the payment status code Field B20. The worker adds the whole dollar figures in Field B20 together and drops the cents to arrive at the person's RSDI benefit. For example, when one record shows $202.51 and the other shows $361.23, the worker adds $202 to $361 to arrive at the person's countable income of $563.

(b) State Data Exchange System (SDX). The SDX file contains data for Supplemental Security Income (SSI) applicants and recipients that is viewed by entering SDX space Social Security number (SSN). When using SDX to verify SSI income, the worker rounds the amount shown to the nearest dollar. For example, 1¢ to 49¢ is rounded down and 50¢ to 99¢ is rounded up. Review Quest articles "How to Read SDX Screens," "State Data Exchange (SDX) Payment Status Codes," "State Data Exchange (SDX) Resource Codes," "State Data Exchange (SDX) Miscellaneous Codes," and "Resolving a SDX Discrepancy."

(c) SDX list (SDL). The SDL transaction is a shortcut that reduces keystrokes and provides a history list of the current and previous SDX records. To view, enter SDL space SSN. To view a particular record, move the cursor to the line of the record date selected, type SDX, and press the enter key.

5. The data exchange discrepancies called "prisoners" (PRS) and "date of death" (DOD) are available from the Social Security Administration (SSA) and appear as alerts on G1DX. Whenever the worker receives one of these alerts, he or she must attempt to confirm the accuracy of the information before taking action as the information may be old or incorrect. SSA receives and sends information to DHS for:

(1) PRS from some, but not all prisons, jails, other penal institutions or correctional facilities, certain mental health institutions, and various third parties, including media sources. SSA maintains this data to identify Supplemental Nutrition Assistance Program clients who 'are currently' or 'have been incarcerated'. The worker accesses the incarceration dates by typing PRS next to the SSN on the G1DX results and hitting enter. A detail screen displays with incarceration dates; and

(2) DOD from State Departments of Health. The G1DX screen displays the date of death for persons reported as deceased by SSA, but appear to be receiving Oklahoma Human Services (OKDHS) benefits.

6. Automated data exchange with other agencies provides OKDHS with information regarding the household's benefits, wages, taxes, Social Security numbers, and current addresses. The system compares information obtained electronically with data stored within OKDHS electronic records to determine if there are discrepancies that need to be addressed with the household. The worker is responsible for reviewing data exchange information at application, mid-certification renewal, and certification renewal. Refer to Oklahoma Administrative Code (OAC) 340:65-3-4 for information regarding data exchange screens.

7. The worker accesses the Alien Status Verification Index (ASVI) through a web-based online system. Online responses are returned for the initial and additional verification inquiries. The worker images and files the online verification number or entire verification record in the case record or copies and pastes the information into FACS case notes.

(1) Initial verification responses are returned in three to five seconds. Initial verification is initiated when at least one of the documents in (A) through (J) of this paragraph appears to be valid, is available, and has an A-number of A0000001 through A59999999, A70000000 through A79999999, or A90000000 through A9999999. Documents include forms:

(A) I-551, Permanent Resident Card;

(B) I-797A, Notice of Action, issued to an applicant as a replacement Form I-94;

(C) I-766, Employment Authorization Document;

(D) I-327, Permit to Reenter the United States;

(E) I-571, Refugee Travel Document; or

(F) I-94 or I-94A, Arrival/ Departure Record endorsed, in a foreign passport, for persons younger than 1 year of age.

(2) The worker uses the same website to request additional verification as initial verification or submits Form G-845, Verification Request, to the United States Citizenship and Immigration Services (USCIS). The website method is preferred since a response is returned in three-federal business days as opposed to a 10-business day paper response time using Form G-845.

(3) The worker initiates additional verification immediately, when:

(A) the person provides documents that appear counterfeit or altered;

(B) there is no A-number on any document;

(C) an A-number in the A60000000 or A80000000 series appears on any document;

(D) any USCIS fee receipt other than I-687, Application for Status as a Temporary Resident, is presented; or

(E) Form I-94 in a foreign passport has an endorsement processed more than one year ago from the current date.

8. When immigration status documents were needed and not provided timely for all household members, the worker uses FDENY to deny the food benefit application. When all other eligibility factors were verified except immigration status and some household members do not need to provide immigration status documents, the worker certifies the eligible household members and enters an "O" for "Income and resources are considered in benefit computation-Individual Not Included" in the "status" field and a "21" for "ineligible or undocumented alien" in the "reason" field of the Household tab in the Family Assistance/Client Services Eligibility Notebook.

9. For food stamp disqualification (FSD) information, review Quest article "Disqualifications (FSD Transaction)." To display the FSD screen, enter FSD space SSN.

(1) The FSD is indicated on the PY screen so a separate transaction is not necessary when the PY transaction is used first.

(2) When fraud is determined for the Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) this information is updated on the FSD screen.

(3) For SNAP rules, refer to OAC 340:50-15-25 and 340:65-9-4 for TANF Program rules.

10. (a) Types of information considered verified upon receipt include, but are not limited to:

(1) Beneficiary and Earnings Data Exchange System (BENDEX), from the Social Security Administration (SSA);

(2) Supplemental Security Income (SSI)/State Data Exchange System (SDX), from the SSA;

(3) Systematic Alien Verification for Entitlements (SAVE), from the United States Citizenship and Immigration Services (USCIS);

(4) Unemployment Insurance Benefits (UIB), from the Oklahoma Employment Security Commission (OESC);

(5) workers' compensation documents from Workers' Compensation Court;

(6) changes in household composition reported by the household; and

(7) actions processed for food benefits or other OKDHS programs affecting food benefit expenses, such as:

(A) a decrease in the child care family share co-payment, resulting in a smaller dependent care deduction; or

(B) the determination of an intentional program violation.

(b) Examples of information that are NOT verified upon receipt are:

(1) Oklahoma Wage Link (OWC and OWL), quarterly wage match data, unless criteria per (i)(2) and (4) of this Section applies;

(2) wage data obtained from BENDEX, unless criteria per (i)(2) and (4) of this Section applies;

(3) New Hire List (NHL) matches. For example, an NHL data exchange message is received during a non-report month indicating a household member started working. When counted, the income would decrease the food benefit. However, because the information is NOT considered verified upon receipt, the worker does not take action to decrease food benefits in a non-report month, unless the NHL screen shows the person's salary or rate of pay and scheduled hours and the projected monthly income may make the household over income, per OKDHS Appendix C-3 or criteria per (i) of this Section applies;

(4) changes in shelter and utility costs. For example, when the client reports the rent decreased from $1000 to $600 per month in a non-report month it does not cause a decrease in benefits, as this information is NOT considered verified upon receipt; and

(5) a prisoner's (PRS) or date of death (DOD) data match from SSA as information may be old or incorrect. This is considered unclear information per (i)(4) of this Section.

11. When the worker determines that information is questionable, he or she must explain why the information is considered questionable and how the worker resolved any such discrepancies in FACS case notes.