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COMMENT DUE DATE:  

February 15, 2018

DATE: 

January 16, 2018

Laura Brown Adult and Family Services 405-521-4396

Dena Thayer, Programs Administrator 405-521-4326

RE:  

APA WF 18-50

It is very important that you provide your comments regarding the DRAFT COPY of policy by the comment due date. Comments are directed to *STO.LegalServices.Policy@okdhs.org

The proposed policy is  Permanent .  This proposal is subject to Administrative Procedures Act

A public hearing is scheduled for 10:00 a.m. on February 21, 2018, at DHS, Sequoyah Memorial Office Building, 2400 N. Lincoln Boulevard, Oklahoma City, Oklahoma 73105, Room C-48.Anyone who wants to speak must sign in at the door by 10:05 a.m.

SUBJECT:CHAPTER 50. SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM

Subchapter 3. Application Process

340:50-3-2 [Amended]

Subchapter 5. Non-Financial Eligibility Criteria

Part 1. Household Definition

340:50-5-10.1 [Amended]

Part 5. Students, Strikers, Resident Farm Laborers, Migrant Households, Sponsored Aliens, And School Employees

340:50-5-48 [Amended]

Part 7. Related Provisions

340:50-5-64 [REVOKED]

Part 9. Work Registration

340:50-5-85 through 340:50-5-87 [AMENDED]

340:50-5-88 [REVOKED]

340:50-5-89 [AMENDED]

340:50-5-90 through 340:50-5-91 [REVOKED]

340:50-5-92 [AMENDED]

340:50-5-93 [REVOKED]

340:50-5-94 [AMENDED]

340:50-5-95 through 340:50-5-96 [REVOKED]

Part 10. Able-Bodied Adult without Dependents[NEW]

340:50-5-100 through 340:50-101 [NEW]

Part 11. Supplemental Nutrition Assistance Program Employment and Training Program [NEW]

340:50-5-106 [NEW]

Subchapter 7. Financial Eligibility Criteria

Part 3. Income

340:50-7-29 [Amended]

Subchapter 9. Eligibility and Benefit Determination Procedures

340:50-9-5 [Amended]

Subchapter 11. Special Procedures

Part 1. Households Entitled to Expedited Services

340:50-11-3 [AMENDED]

Subchapter 13. Fair Hearings and Quality Control [AMENDED]

340:50-13-1 [REVOKED]

340:50-13-3 [AMENDED]

340:50-13-4 [REVOKED]

Subchapter 15. Overpayments and Fraud

Part 1. Overpayments

340:50-15-6 [AMENDED]

(Reference WF 18-02)

SUMMARY:The proposed amendments to Chapter 50, Subchapter 3 amends the rule to:(1) add clarifying language regarding when a postponed interview must be completed and the worker's responsibility to inform applicants of the household's responsibility to cooperate with Supplemental Nutrition Assistance Program (SNAP) Quality Control (QC); (2) clarify the civil rights complaint process; and (3) update the party responsible for taking action when a household refuses to cooperate with a QC review.

The proposed amendments to Chapter 50, Subchapter 5 amends the rules to: (1) add to the list of persons disqualified from receiving SNAP food benefits, those failing to meet work registration requirements; (2) update fleeing felon information to add the four-part criteria that establishes fleeing felon status and remove staff instructions; (3) define "actively seeking," when determining if a person is considered a fleeing felon or a probation or parole violator; (4) add work registration requirements for migrant farm laborers; (5) revoke the work requirements section in Part 7, regarding able-bodied adults without dependents (ABAWDs) in order to move the rule to issued Part 10 for ABAWD rules; (6) add legal citations and add or remove policy citations; (7) update terminology; (8) update work registration requirements, loss of work registration exemption status, and failure to comply information; (9) update work registration information to add information regarding: (a) the worker's responsibility to explain the work registration statement and each household member's responsibility; (b) good cause provisions; (c) what is considered suitable work; and (d) an age limit work registration exemption; (10) clarify that a refugee participating in a refugee-specific training program meets student exemption criteria; (11) update work registration information regarding employed persons, Temporary Assistance for Needy Families (TANF), and unemployment insurance benefits (UIB) exemptions and, when failure to comply may apply; (12) change the work registration disqualification from a household to an individual disqualification; and (13) revoke and move information to another Section regarding:(a) ABAWD work requirements; (b) work registration disqualification periods; (c) the SNAP Employment and Training (E&T) Program Section; and (d) voluntary quit determination information, verification requirements, and ending a voluntary quit disqualification period; (14) update voluntary quit rules to:(a) add information regarding reduction of work effort; (b) increase the number of hours a person must have worked from 20 to 30 hours before the voluntary quit provision applies; (c) revoke information regarding the head of household as it applies to voluntary quit so the disqualification penalty is the same for any adult household member that voluntarily quits a job; and (d) update good cause provisions as they relate to voluntary quit and reduction of work effort; (15) revoke information duplicated in another Section; (16) change two Section titles; (17) update voluntary quit disqualification information to:(a) clarify information regarding application of the disqualification period for participating households; (b) add information regarding when to certify a household applying in the last month of the penalty period; (c) add information revoked from 340:50-5-95 regarding ending a voluntary quit disqualification; (d) correct when the penalty period starts for applicant households; (d) remove inaccurate information regarding overpayments and information regarding head of household as it applies to a voluntary quit penalty that is no longer applicable; and (e) update terminology for consistency throughout the Section; (18) clarify and simplify language; (19) move and revise ABAWD rules from Part 7 to issued Part 10 to:(a) add that an ABAWD meets work requirements when he or she works and participates in a work program for 20 or more hours per week; (b) add information to explain the general ABAWD rule including benefit time limits; how to determine countable ABAWD months in Oklahoma and from other states; how Oklahoma measures the 36-month time period; worker and ABAWD responsibilities; (c) remove exemptions from ABAWD work requirements that are considered work registration exemptions; and (d) revise information regarding how an ABAWD regains eligibility after he or she receives three-countable months of food benefits; and (e) explain how the Oklahoma Department of Human Services (DHS) applies and tracks the 15 percent exemption from countable ABAWD months allowed by Food and Nutrition Services (FNS); and (20) move SNAP E&T Program rules from Part 9 to issued Part 11; and add worker responsibility information.

The proposed amendments to Chapter 50, Subchapter 7 amends the rule to:(1) add to the list of persons disqualified, thosefailing to meet work registration requirements; and (2) remove worker instructions regarding the imposition of an intentional program violation penalty and duplicative information regarding allowable expenses for ineligible household members.

The proposed amendments to Chapter 50, Subchapter 9 amends the rule to:(1) require action to be taken when a household member is identified as a disqualified or an ineligible person; (2) require verification to be provided before benefits are increased; (3) update change reporting rules for semi-annual reporters to the tenth of the month, following the month the change occurred; and (4) update rule citations.

The proposed amendment to Chapter 50, Subchapter 11 amends the rule to:(1) add legal citations and clarifying information; (2) correct information regarding how to consider income from a new source for the application month; and (3) update terminology.

The proposed amendments to Chapter 50, Subchapter 13 amend the rules to:(1) add Quality Control to the Subchapter title; (2) revoke complaints of alleged discriminatory practices as this information was updated and moved to Subchapter 1; (3) update SNAP quality control (QC) rules to:(a) add legal citations; and (b) explain parameters of the QC review process and sampling plan; (4) update terminology, the divisions and agencies responsible for parts of the process, and the steps taken when a client refuses to cooperate with the SNAP QC review process; and (5) revoke a no longer applicable Section.

The proposed amendment to Chapter 50, Subchapter 15 amends the rule to:(1) change the number of days a claim must be delinquent before a Treasury Offset Program (TOP) referral is made; and (2) update terminology.

PERMANENT APPROVAL:Permanent rulemaking is requested.

LEGAL AUTHORITY:Director of Human Services; Section 162 of Title 56 of the Oklahoma Statutes; Sections 273.1, 273.2, 273.7, 273.10, 273.11, 273.12, 273.18, 273.24, and 275.10 through 275.13 of Title 7 of the Code of Federal Regulations; and 31 U.S.C. § 3716(c)(6).

Rule Impact Statement

To:Programs administrator

Legal Services - Policy

From:Patrick Klein,Director

Adult and Family Services

Date:December 18, 2017

Re:Chapter 50. SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM

Subchapter 3. Application Process

340:50-3-2 [Amended]

Subchapter 5. Non-Financial Eligibility Criteria

Part 1. Household Definition

340:50-5-10.1 [Amended]

Part 5. Students, Strikers, Resident Farm Laborers, Migrant Households, Sponsored Aliens, And School Employees

340:50-5-48 [Amended]

Part 7. Related Provisions

340:50-5-64 [REVOKED]

Part 9. Work Registration

340:50-5-85 through 340:50-5-87 [AMENDED]

340:50-5-88 [REVOKED]

340:50-5-89 [AMENDED]

340:50-5-90 through 340:50-5-91 [REVOKED]

340:50-5-92 [AMENDED]

340:50-5-93 [REVOKED]

340:50-5-94 [AMENDED]

340:50-5-95 through 340:50-5-96 [REVOKED]

Part 10. Able-Bodied Adult without Dependents[NEW]

340:50-5-100 through 340:50-101 [NEW]

Part 11. Supplemental Nutrition Assistance Program Employment and Training Program [NEW]

340:50-5-106 [NEW]

Subchapter 7. Financial Eligibility Criteria

Part 3. Income

340:50-7-29 [Amended]

Subchapter 9. Eligibility and Benefit Determination Procedures

340:50-9-5 [Amended]

Subchapter 11. Special Procedures

Part 1. Households Entitled to Expedited Services

340:50-11-3 [AMENDED]

Subchapter 13. Fair Hearings and Quality Control [AMENDED]

340:50-13-1 [REVOKED]

340:50-13-3 [AMENDED]

340:50-13-4 [REVOKED]

Subchapter 15. Overpayments and Fraud

Part 1. Overpayments

340:50-15-6 [AMENDED]

(Reference WF 18-02)

Contact:Laura Brown 405-521-4396

A.Brief description of the purpose of the proposed rule:

Purpose.

The proposed amendments to Chapter 50, Subchapter 3 amends the rule to:(1) add clarifying language regarding when a postponed interview must be completed and the worker's responsibility to inform applicants of the household's responsibility to cooperate with Supplemental Nutrition Assistance Program (SNAP) Quality Control (QC); (2) clarify the civil rights complaint process; and (3) update the party responsible for taking action when a household refuses to cooperate with a QC review.

The proposed amendments to Chapter 50, Subchapter 5 amends the rules to: (1) add to the list of persons disqualified from receiving SNAP food benefits, those failing to meet work registration requirements; (2) update fleeing felon information to add the four-part criteria that establishes fleeing felon status and remove staff instructions; (3) define "actively seeking," when determining if a person is considered a fleeing felon or a probation or parole violator; (4) add work registration requirements for migrant farm laborers; (5) revoke the work requirements section in Part 7, regarding able-bodied adults without dependents (ABAWDs) in order to move the rule to issued Part 10 for ABAWD rules; (6) add legal citations and add or remove policy citations; (7) update terminology; (8) update work registration requirements, loss of work registration exemption status, and failure to comply information; (9) update work registration information to add information regarding: (a) the worker's responsibility to explain the work registration statement and each household member's responsibility; (b) good cause provisions; (c) what is considered suitable work; and (d) an age limit work registration exemption; (10) clarify that a refugee participating in a refugee-specific training program meets student exemption criteria; (11) update work registration information regarding employed persons, Temporary Assistance for Needy Families (TANF), and unemployment insurance benefits (UIB) exemptions and, when failure to comply may apply; (12) change the work registration disqualification from a household to an individual disqualification; and (13) revoke and move information to another Section regarding: (a) ABAWD work requirements; (b) work registration disqualification periods; (c) the SNAP Employment and Training (E&T) Program Section; and (d) voluntary quit determination information, verification requirements, and ending a voluntary quit disqualification period; (14) update voluntary quit rules to:(a) add information regarding reduction of work effort; (b) increase the number of hours a person must have worked from 20 to 30 hours before the voluntary quit provision applies; (c) revoke information regarding the head of household as it applies to voluntary quit so the disqualification penalty is the same for any adult household member that voluntarily quits a job; and (d) update good cause provisions as they relate to voluntary quit and reduction of work effort; (15) revoke information duplicated in another Section; (16) change two Section titles; (17) update voluntary quit disqualification information to:(a) clarify information regarding application of the disqualification period for participating households; (b) add information regarding when to certify a household applying in the last month of the penalty period; (c) add information revoked from 340:50-5-95 regarding ending a voluntary quit disqualification; (d) correct when the penalty period starts for applicant households; (d) remove inaccurate information regarding overpayments and information regarding head of household as it applies to a voluntary quit penalty that is no longer applicable; and (e) update terminology for consistency throughout the Section; (18) clarify and simplify language; (19) move and revise ABAWD rules from Part 7 to issued Part 10 to: (a) add that an ABAWD meets work requirements when he or she works and participates in a work program for 20 or more hours per week; (b) add information to explain the general ABAWD rule including benefit time limits; how to determine countable ABAWD months in Oklahoma and from other states; how Oklahoma measures the 36-month time period; worker and ABAWD responsibilities; (c) remove exemptions from ABAWD work requirements that are considered work registration exemptions; and (d) revise information regarding how an ABAWD regains eligibility after he or she receives three-countable months of food benefits; and (e) explain how the Oklahoma Department of Human Services (DHS) applies and tracks the 15 percent exemption from countable ABAWD months allowed by Food and Nutrition Services (FNS); and (20) move SNAP E&T Program rules from Part 9 to issued Part 11; and add worker responsibility information.

The proposed amendments to Chapter 50, Subchapter 7 amends the rule to: (1) add to the list of persons disqualified, thosefailing to meet work registration requirements; and (2) remove worker instructions regarding the imposition of an intentional program violation penalty and duplicative information regarding allowable expenses for ineligible household members.

The proposed amendments to Chapter 50, Subchapter 9 amends the rule to: (1) require action to be taken when a household member is identified as a disqualified or an ineligible person; (2) require verification to be provided before benefits are increased; (3) update change reporting rules for semi-annual reporters to the tenth of the month, following the month the change occurred; and (4) update rule citations.

The proposed amendment to Chapter 50, Subchapter 11 amends the rule to: (1) add legal citations and clarifying information; (2) correct information regarding how to consider income from a new source for the application month; and (3) update terminology.

The proposed amendments to Chapter 50, Subchapter 13 amend the rules to: (1) add Quality Control to the Subchapter title; (2) revoke complaints of alleged discriminatory practices as this information was updated and moved to Subchapter 1; (3) update SNAP quality control (QC) rules to:(a) add legal citations; and (b) explain parameters of the QC review process and sampling plan; (4) update terminology, the divisions and agencies responsible for parts of the process, and the steps taken when a client refuses to cooperate with the SNAP QC review process; and (5) revoke a no longer applicable Section.

The proposed amendment to Chapter 50, Subchapter 15 amends the rule to:(1) change the number of days a claim must be delinquent before a Treasury Offset Program (TOP) referral is made; and (2) update terminology.

Strategic Plan Impact. The proposed amendments achieve DHSgoals by continuously improving systems and processes and improving communication with DHS clients and staff.

Substantive changes.

Subchapter 3. Application Process

OAC 340:50-3-2 is amended to:(1) add clarifying language regarding when a postponed interview must be completed and the worker's responsibility to inform households of the civil rights complaint process and their responsibility to cooperate with SNAP QC; and (2) update the party responsible for taking action when a household refuses to cooperate with a QC review.

Subchapter 5. Non-Financial Eligibility Criteria

Part 1. Household definition

OAC 340:50-5-10.1 is amended to: (1) add to the list of persons disqualified from receiving SNAP food benefits, those failing to meet work registration requirements; (2) update fleeing felon information to add the four-part criteria that establishes fleeing felon status and remove staff instructions; and (3) add definition for "actively seeking," when determining if a person is considered a fleeing felon or a probation or parole violator.

Part 5. Students, Strikers, Resident Farm Laborers, Migrant Households, Sponsored Aliens, And School Employees

OAC 340:50-5-48 is amended to add work registration requirements for migrant farm laborers.

Part 7. Related Provisions

OAC 340:50-5-64 is revoked and the information is moved to OAC 340:50-5-100.

Part 9. Work Registration

OAC 340:50-5-85 is amended to update work registration information to add: (1) the worker's responsibility to explain the work registration statement and each household member's responsibility; (2) good cause provisions when a household member fails or refuses to comply with work registration requirements; and (3) what is considered suitable work.

OAC 340:50-5-86 is amended to:(1) add an age limit work registration exemption; (2) clarify that a refugee participating in a refugee-specific training program meets student exemption criteria; and (3) update work registration information regarding employed persons, TANF and UIB exemptions and, when failure to comply may apply.

OAC 340:50-5-87 is amended to:(1) update loss of work registration exemption status and failure to comply information; and (2) add length of disqualification periods that were removed from OAC 340:50-5-88.

OAC 340:50-5-88 is revoked and the information is moved to OAC 340:50-5-106.

OAC 340:50-5-89 amends voluntary quit rules to: (1) change the Section title; (2) add information regarding reduction of work effort; (3) increase the number of hours a person must have worked from 20 to 30 hours; (4)remove information regarding the head of household so the disqualification penalty is the same for any adult household member that voluntarily quits a job; (5) add information revoked from OAC 340:50-5-91 regarding when a voluntary quitdetermination must be made; (6) add still applicable information revoked from OAC 340:50-5-93 regarding required verification; and (7) simplify and clarify language.

OAC 340:50-5-90 is revoked because the head of household determination is no longer necessary as it applies to voluntary quit or work requirements because DHS is changing to an individual instead of a household disqualification penalty.

OAC 340:50-5-91 is revoked and the information is moved to OAC 340:50-5-89.

OAC 340:50-5-92 is amended to: (1) simplify and clarify good cause provisions for voluntary quit; (2) add reduction in work effort; (3) remove information regarding the head of household; and (4) add a legal citation.

OAC 340:50-5-93 is revoked as required verification is moved to OAC 340:50-5-89.

OAC 340:50-5-94 amends the voluntary quit disqualification penalty period rule to: (1) add information regarding: (a) reduction of work effort; (b) application of the disqualification period for participating households; (c) when to certify a household applying in the last month of the penalty period; and (d) ending a voluntary quit disqualification revoked from OAC 340:50-5-95; (2) increase the number of hours a person must have worked from 20 to 30 hours before the penalty applies; (3) change the penalty from a household to an individual disqualification period; (4) correct when the penalty period starts for applicant households to match federal regulations; (5) remove inaccurate information regarding overpayments and information that is no longer applicable regarding head of household as it applies to a voluntary quit penalty; and (6) update terminology for consistency throughout the Section.

OAC 340:50-5-95 and 340:50-5-96 are revoked and the information is moved to OAC 340:50-5-94.

Part. 10. Abled Bodies Adults Without Dependents (ABAWDs) work requirements and time limits

OAC 340:50-5-100 is issued to:(1) move information revoked from OAC 340:50-5-64 to this Section; (2) add information to explain that an ABAWD meets work requirements when he or she works and participates in a work program for 20 or more hours per week; (3) add information to explain the general ABAWD rule including: (a) benefit time limits; (b) how to determine countable ABAWD months in Oklahoma and from another state; (c) how Oklahoma measures the 36-month time period for receipt of countable ABAWD months; and (d) the worker's and ABAWD's responsibilities for ensuring accurate food benefit issuance; (4) remove exemptions from ABAWD work requirements that are considered work registration exemptions; and (5) revise information regarding how an ABAWD regains eligibility after he or she receives three-countable months of food benefits.

OAC 340:50-5-101 is issued to explain how DHS applies and tracks the 15 percent exemption from countable ABAWD months allowed by FNS.

Part 11. Supplemental Nutrition Assistance Program Employment and Training (E&T) Program

OAC 340:50-5-106 is issued to move SNAP E&T Program rules from Part 9 and add worker responsibility information.

Subchapter 7. Financial Eligibility Criteria

Part 3. Income

OAC 340:50-7-29 is amended to: (1) add to the list of persons disqualified, failing to meet work registration requirements; and (2) remove worker instructions regarding imposition of an intentional program violation penalty and duplicative information regarding allowable expenses for ineligible household members.

Subchapter 9. Eligibility And Benefit Determination Procedures

OAC 340:50-9-5 is amended to: (1) require action to be taken when a household member is identified as a disqualified or ineligible person; (2) require that verification be provided before benefits are increased; (3) update change reporting rules for semi-annual reporters to the tenth of the month, following the month the change occurred; and (4) update rule citations.

Subchapter 11. Special Procedures

OAC 340:50-11-3 is amended to:(1) add legal citations and clarifying language; (2) correct information regarding how to consider income from a new source for the application month; and (3) update terminology.

Subchapter 13. Fair Hearings and Quality Control

OAC 340:50-13-1 is revoked as rules regarding complaints of alleged discriminatory practices was updated and moved to Subchapter 1.

OAC 340:50-13-3 is amended to update SNAP QC rules to: (1) add legal citations; (2) explain QC review process parameters and the sampling plan; and (3) update: (a) terminology; (b) which divisions and agencies are responsible for parts of the QC process;: and (c) the steps taken when a client refuses to cooperate with the QC review process.

OAC 340:50-13-4 is revoked because the information is no longer applicable.

Subchapter 15. Overpayments and Fraud

OAC 340:50-15-6 is amended to: (1) change the number of days a claim must be delinquent before a TOP referral is made; and (2) update terminology.

Reasons.

The proposed amendments throughout the Subchapters amend the rules to:(1) make policy easier to understand for clients, Adult and Family Services (AFS) staff, and the public; and less error prone for staff by reordering and renaming information, adding taglines, and clarifying and simplifying information; and (2) remove confusing, incorrect, and no longer applicable information.

Most of the proposed amendments to update the SNAP work registration, voluntary quit, and ABAWD rules are made to comply with corrective action requirements included in the ABAWD Management Evaluation and Employment and Training Management Evaluation received in November, 2016.

The proposed amendment to add the four-part criteria that establishes fleeing felon status and defines the term "actively seeking," when determining if a person is considered a fleeing felon or a probation or parole violator, is added to comply with federal regulations and a Food and Nutrition Services memo issued in June, 2017.

The proposed amendment to remove the term head of household as it applies to work registration and voluntary quit disqualification penalties and to apply an individual instead of a household disqualification penalty are made to reduce errors and make the penalty less punitive, as allowed by federal regulations.

The proposed amendment to update change reporting rules for semi-annual reporting households to the tenth of the month, following the month the change occurred is made to align with changes made last year for annual reporting and change reporting households.The change was intended to also be made for semi-annual reporting households, but did not occur as planned.AFS received a 2016 waiver approval from FNS to make this change.

The proposed amendment to change the number of days a claim must be delinquent before making a TOP referral is made to comply with changes made to Section 3716(c)(6) of Title 31 of the United States Code (31 U.S.C. § 3716(c)(6)).

Repercussions.

If the proposed amendments are not implemented, rules will remain error prone and may lead to increased federal error rates due to benefit processing delays or to benefit under or over-issuance.

If the proposed work registration, voluntary quit, ABAWD, fleeing felon, parole or probation violator, and TOP referral amendments are not implemented, AFS will remain out of compliance with federal regulations.

Legal authority.Director of Human Services; Section 162 of Title 56 of the Oklahoma Statutes; Sections 273.1, 273.2, 273.7, 273.10, 273.11, 273.12, 273.18, 273.24, and 275.10 through 275.13 of Title 7 of the Code of Federal Regulations; and 31 U.S.C. § 3716(c)(6).

Permanent rulemaking approval is requested.

B.A description of the classes of persons who most likely will be affected by the proposed rule, including classes that will bear the costs of the proposed rule, and any information on cost impacts received by the Agency from any private or public entities:The classes of persons most likely to be affected by the proposed amendments are households applying for, or receiving SNAP food benefits and, AFS staff.The affected classes of persons will bear no costs associated with implementation of the rules.

C.A description of the classes of persons who will benefit from the proposed rule:The classes of persons who will benefit from the proposed amendments are households applying for or receiving SNAP benefits and AFS staff.

D.A description of the probable economic impact of the proposed rule upon the affected classes of persons or political subdivisions, including a listing of all fee changes and, whenever possible, a separate justification for each fee change:The proposed amendments do not have an economic impact on the affected entities.There are no fee changes associated with the proposed amendments.

E.The probable costs and benefits to the Agency and to any other agency of the implementation and enforcement of the proposed rule, the source of revenue to be used for implementation and enforcement of the proposed rule and any anticipated effect on state revenues, including a projected net loss or gain in such revenues if it can be projected by the Agency:The probable cost to DHS includes the cost of printing and distributing the rules, which is estimated to be less than $20.The proposed amendments will result in enhanced delivery of services to households applying for or receiving SNAP benefits and may decrease staff errors.

F.A determination whether implementation of the proposed rule will have an impact on any political subdivisions or require their cooperation in implementing or enforcing the rule:The proposed amendments do not have an economic impact on any political subdivision, nor will the cooperation of any political subdivisions be required in implementation or enforcement of the rules.

G.A determination whether implementation of the proposed rule will have an adverse economic effect on small business as provided by the Oklahoma Small Business Regulatory Flexibility Act:There are no anticipated adverse effects on small business as provided by the Oklahoma Small Business Regulatory Flexibility Act.

H.An explanation of the measures the Agency has taken to minimize compliance costs and a determination whether there are less costly or nonregulatory methods or less intrusive methods for achieving the purpose of the proposed rule:There are no less costly or non-regulatory methods or less intrusive methods for achieving the purpose of the proposed amendments.

I.A determination of the effect of the proposed rule on the public health, safety, and environment and, if the proposed rule is designed to reduce significant risks to the public health, safety, and environment, an explanation of the nature of the risk and to what extent the proposed rule will reduce the risk:Implementation of the proposed amendments will reduce health risks for households applying for or receiving SNAP food benefits by changing the work registration and voluntary quit disqualification penalty to an individual instead of a household disqualification period, facilitating the delivery of benefits and services to persons who are in need by clarifying and simplifying rules, and complying with federal regulations.

J.A determination of any detrimental effect on the public health, safety, and environment if the proposed rule is not implemented:If the proposed amendments are not implemented, there may be a detrimental effect on the health of households applying for or receiving SNAP benefits because rules will not be in compliance with certain federal regulationsand staff may not process benefits as quickly and accurately as possible.Failure to issue correct benefit amounts may lead to under issuance of client benefits or overpayments the client must repay.

K.The date the rule impact statement was prepared and, if modified, the date modified:April 20, 2017; modified July 26, 2017; modified December 18, 2017.

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