Change of Circumstances - TOC

Purpose:

This chapter describes what changes a client needs to report, how changes affect the monthly benefit level and what actions are needed. This chapter contains the following sections:

Reporting Requirements

Created on: 
Jan 05 2015

Revised January 12, 2015

Purpose:

WAC 388-418-0005 How will I know what changes to report?

WAC 388-418-0007 When do I have to report changes in my circumstances?


Clarifying Information - WAC 388-418-0005

1.  SSI / SSI-related medical benefits:

  • Reporting requirements for SSI-related medical benefits do not apply to a person who receives SSI medical (S01).  Changes for SSI recipients are reported to the Social Security Administration.
  • If someone receives S01 medical and benefits from another program, they must report based on the requirements for the other program.

EXAMPLE:  A family receives S01 medical, TANF, and Basic Food benefits.  S01 medical does not follow the same reporting requirements as SSI-related medical (i.e., S02).  The family must report changes based on the cash reporting requirements.

2.  Reporting Requirements for Basic Food Simplified Reporting:

Basic Food households must report if their income goes over 130 percent of poverty based on the number of eligible household members in their assistance unit.  Once a household reports a change in income and is certified eligible above the 130 percent poverty level, the reporting requirements under simplified reporting have been met and the household doesn't have to report any other income changes until:

a.  The mid-certification review (MCR);

b.  The eligibility review (ER); or

c.  Until the household income increases to an amount greater than 200 percent of poverty, whichever comes first.

3.  Reporting Requirements for State Supplemental Payment Program (SSP):

We decide if someone is eligible for SSP based on information Social Security Administration (SSA) gives us through the State Data Exchange (SDX). A person does not have to report changes for SSP.

4.  Taking action on changes:

When we receive information about someone's circumstances, we must determine the impact on the person's benefits. This may include contacting them, contacting other parties, or asking for proof of their circumstances under WAC 388-490-0005.

a.  Client Reports:

  • Take action based on changes the person reports. This includes when someone volunteers information after we contacted them.
  • Get proof of a person's circumstances if they report:
    • A decrease in income that increases their benefits; or
    • Expenses that increase benefits and the expenses are questionable given their income and other circumstances.

b.  Third-Party Reports:

  • If we receive information from a third party about someone, follow-up on the information to decide how it impacts the person’s eligibility and benefits.
  • This may include contacting the person, contacting other parties, or asking for proof of their circumstances under WAC 388-490-0005.

c.  Alerts Verified Upon Receipt:

  • An interface that automatically updates the ACES case record is "verified upon receipt".
  • We do not need to take action on alerts the interface automatically updates in ACES.

d.  Other Alerts:

  • We do need to take action on alerts that are not verified upon receipt.
  • Work alerts that are not verified upon receipt to decide how the information impacts the person's eligibility and benefits.
  • This may include contacting the person, contacting other parties, or asking for proof of their circumstances under WAC 388-490-0005.
NOTE: EXCEPTION TO THIRD-PARTY REPORTS PROCESS: If a financial worker receives potential change information from a WCCC child care worker, the financial worker should: a. Not contact the AU about the change; b. Act on the change only if they have proof of the change from the WCCC eligibility system or child care worker, even if it reduces benefits; and c. Set an alert to get verification of the change at the next recertification if no proof was previously received.

5.  ABAWD reporting requirement:

With the statewide ABAWD waiver ending December 31, 2015, people must report when a non-exempt ABAWD receive benefits in the AU and the ABAWD's hours of employment drop below 20 hours per week. This includes when the non-exempt ABAWD is the head of household for Basic Food. 

People in most counties of the state are still exempt from ABAWD work requirements.  People must report if an ABAWD's hours drop below 20 hours per week in the following areas:

  • King County
  • Snohomish County
  • Pierce County (Except those living in Lakewood and Tacoma)

Worker Responsibilities - WAC 388-418-0005

The DMS E001 tickler uses EBT transaction data to identify EBT cash or food clients who may no longer be living in Washington because they are consistently using their benefits out of state.  Out of state EBT transactions are defined as any EBT purchase, ATM withdrawal or manual voucher transaction at a non-Washington site that requires the use of an EBT card as part of the transaction.  W hen this occurs, the residency may be questionable. 

Follow the E001 tickler handling process described in the CSD Procedures Handbook.


Clarifying Information - WAC 388-418-0007

  1. When a change happens:

    Non-Income Changes

    The date of a change is normally the date a change happens. Examples of this include the date:

    • Someone gets married;
    • A newborn comes home from the hospital; and
    • Someone moves to a new home.

    Income Changes The date of an income related change is the date someone receives income based on the change. Examples of this include the date:

    • On the first paycheck that reflects a wage increase; and
    • On the person's first paycheck for a new job.
EXAMPLE:  Sandy is hired for a new job on May 31st. She starts work on June 10th. Her first paycheck is July 5th. Because this is a change in income, we count the date of Sandy's first paycheck on July 5th as the date of the change.   If Sandy must tell us about the change based on her reporting requirement under WAC 388-418-0005, she must tell us about this change by August 10th. · If Sandy reported this change earlier, we would act on the change based on when we expect her to receive the income.
EXAMPLE: Nick is hired for a new job on May 1st. He receives his first paycheck on June 1st. Nick must report this change of employment status and income by July 10th.
EXAMPLE: Stacey receives TANF and Basic Food. She had her employee evaluation on October 1st. Based on this evaluation, Stacey gets a promotion and a $1.25 hourly wage increase. The wage increase takes effect October 15th. She will receive the first check showing this increase on November 10th. Because this is a change in income, we count the date of Stacey's first paycheck on November 10th as the date of the change. - Stacey must report this change to us by December 10th. - If Stacey reported this change earlier, we would act on the change based on when we expect her to receive the income.
  1. Changes a client voluntarily reports:
    • If people report a change, we must act on the change they report even if they didn't have to tell us about the change under WAC 388-418-0005. This includes asking for more information or proof of a change when we can't tell the impact on their benefits.
    • For Basic Food, under simplified reporting rules, clients do not have to report when they move until recertification or until the mid-certification review, whichever comes first. If they voluntarily report a move between mandatory reports or for another program, they must provide their new shelter costs. The new shelter costs do not need to be verified unless questionable. See "Worker Responsibilities" (4.) and (5.) below.
    EXAMPLE Larry receives Basic Food only. He calls and reports that his monthly rent expense went from $300 to $500 monthly. Larry's worker Bob chooses to verify this change as "questionable" because the $500 plus utilities are so close to Bob's monthly income. After he receives proof of the expense, Bob updates the shelter cost for Basic Food.
    EXAMPLE Ian receives TANF and Basic Food. He leaves a message with his worker reporting that he started a job and would like to close his TANF benefits today. Ian's worker closes TANF benefits based on the request. Since Ian reported that he is now employed, his worker must follow up to see how this impacts his medical and Basic Food benefits.
  2. Unverified changes that increase benefits:

    If a client reports a change that would increase their benefits because of a decrease in income, we ask for proof of the change. We only ask for proof of an increase in expenses if the expenses are questionable. We increase the AU's benefits based on the effective date rules under WAC 388-418-0020.

    • If we have asked for verification, and they fail to give us proof of a reduction in income or an increase in expenses, we do not update their case to increase benefits.
    • We also do not close the case based on their failure to give proof of a change that would increase their benefits.

  3. Changes someone reports on an application or eligibility review:

    People may report a change in their circumstances on an eligibility review form or an application for benefits. If you receive an application or eligibility review form:

    1. Before the fifteenth day of the second to last month of their certification period, treat this form as a change of circumstances.
    2. On or after the fifteenth day of the second to last month of their certification period, treat this form as a request for review or recertification. See ELIGIBILITY REVIEWS AND RECERTIFICATIONS for procedures.
    3. In the month before the mid-certification review is due, use the information on the application / review form to complete the MCR for any related programs.
    4. For medical, you may use an application or review at any time to update the medical certification period.
    5. For handling additional applications received before initial application is processed see "Clarifying Information" #4 under WAC 388-406-0010 .
      EXAMPLE Susan's Basic Food certification period ends on July 31st. She turns in an Eligibility Review form for Basic Food only on May 31st. Because Susan turned in the ER before the 15th of the month before the month her certification period ends, we treat the form as a change of circumstance report.
  4. Temporary absence of an AU member: If an AU member is temporarily out of the home:
    • For cash and medical assistance, follow the rules in WAC 388-454-0015 to determine if the person is still eligible for benefits.
    • For Basic Food, follow the rules in WAC 388-408-0035 to determine if the person is still eligible for benefits.

  5. AU member moves out of Washington:

    People must be state residents to be eligible for most programs. If an AU member or the entire AU leaves the state, follow the rules in WAC 388-468-0005 to determine if the person is still eligible for benefits.

WORKER RESPONSIBILITIES - WAC 388-418-0007

  1. During the application, recertification or eligibility interview:
  1. Inform clients what changes they must report and how much time they have to report the changes;
  2. Explain how to report changes either in writing, by phone, or in person. (See RIGHTS AND RESPONSIBILITIES); and
  3. Give them a DSHS 14-076(X), Change of Circumstance form, and a return envelope to report changes. ACES automatically mails the DSHS 22-297, How to Report Changes with the award letter.
  1. When people report a change or when you learn of a change:
    1. Ask for more information or proof if needed. See LETTERS for the rules and the process on asking someone to take an action or give us information.
    2. Take action on the information using the effective date rules in WAC 388-418-0020.
    3. If we averaged their income under WAC 388-450-0215, recalculate this source of income if you expect this change to last at least a month beyond when you learn of the change.
    4. Document:
      • The details of the change;
      • The date we learned about the change or the date the change was reported;
      • The impact on benefits; and
      • The effective date for any change in benefits.
    5. Send written notice about the change based on requirements in LETTERS even if the benefits do not change.
  1. For Basic Food, if the client does not report a change in medical expenses, but you learn about a change:
    1. Do not contact the AU about the change;
    2. Act on the change only if you can get proof of the change from someone other than the AU; and
    3. Set an alert to get proof of the change at the next recertification. Update the MEDX screen in ACES once you get proof of the medical expenses.
    4. Document in the ACES narrative whether or not we should use the medical expense at the next recertification.
NOTE: If you later approve medical assistance that covers a person's medical expenses, delete the medical expenses on the MEDX screen and recalculate the person's Basic Food benefits.
  1. For Basic Food, when the client voluntarily reports a move in person or on the phone:
    1. Ask for the new out-of-pocket share of shelter costs associated with the new residence.
    2. Do not require verification of the new shelter expenses unless questionable.
    3. Make it clear that they do not need to wait for the first regular rental or utility payment to tell us the amount(s).
    4. Update and document the new shelter costs in ACES.
    5. Send notice to the client if there is a change in the benefit amount. Give advance notice if there is a decrease.
  2. If the client reports a move in writing or we receive returned mail with a new forwarding address on the envelope:
    1. First, attempt to contact the client by phone. If successful, follow instructions in (4.) above.
    2. If unable to contact by phone, send the client a general correspondence letter asking for the new shelter costs associated with the move.
      • Include a statement in the letter warning the client that the old shelter deduction will be removed from the budget and benefit will be recalculated using no shelter costs if new expenses are not reported within 10 days;
      • Make it clear in the letter that they do not need to wait for the first regular rental or utility payment to tell us the amount(s); and
      • Do not require verification of the new shelter expenses unless questionable.
    3. If client responds to the letter:
      • Update and document the new shelter costs in ACES; and
      • Send notice to the client if there is a change in the benefit amount. Give advance notice if there is a decrease in benefits.
    4. If client does not respond to the letter:
      • Do not close the BF AU;
      • Remove the old shelter costs; and
      • Send advance notice to the client if there is a change in the benefit amount.
NOTE: Do not use a "Request for Information" letter as this letter requires a BF AU closure if the client does not respond.

Mid-Certification Reviews

For information on mid-certification reviews, please see the Mid-Certification Reviews section.


 

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Effective Date - Change of Circumstances

Created on: 
Nov 09 2015

 

Revised February 4, 2016

WAC 388-418-0020 How does the department determine the date a change affects my cash and Basic Food benefits?


Clarifying Information - WAC 388-418-0020

1. Advance notice:

  •  LETTERS to determine advance notice time limits.

2. Overpayments due to not reporting or reporting late

See BENEFIT ERRORS and BENEFIT ERRORS – BASIC FOOD OVERPAYMENTS for information on how to set up an overpayment when someone did not report a change timely or when we did not make the change timely.

If someone does not report a change in circumstances required under WAC 388-418-0005, we determine if a client has an overpayment for each program based on that program’s reporting requirements.

·  For Basic Food, the household must report changes as required under WAC 388-418-0005(2)(a).

·  If a Basic Food assistance unit would not have to report the change based on the AU's circumstances, we do not set up an overpayment even if the household had to report a change for another department program.

3. Mass changes

Examples of mass changes include:

Changes to allotments or payment standards

Changes to income standards

Changes to the Basic Food maximum shelter deduction

Cost of Living Adjustment (COLA) to SSI, Social Security, or VA benefits

Changes to the standard deduction for Basic Food

Changes to utility allowances for Basic Food

 

Worker Responsibilities - WAC 388-418-0020

1. Temporary changes in income:

When a client reports a change in income that we do not expect to last at least a month beyond the month they reported the change, do not change their benefits. This includes having income over the gross income limit for Basic Food. Instead, take the following steps:

a. Document the reported change, that the change is not expected to last at least a month beyond the date the client reported the change; and

b. Leave the person's benefits unchanged.

NOTE: If you expect the change to last at least a month after the month the change was reported, adjust the person's income for the change. If we averaged this income, you must re-calculate the averaged income based on this new information.
EXAMPLE: On September 19th, Sue reports that her hours have increased because her co-worker is on medical leave through October 15th. We would not re-calculate Sue's income based on this report because the change won't last through the end of October.
EXAMPLE: On November 14th, Dan reports that he will be working full time for the holiday season through January 1st. We re-calculate Dan's income based on this report because we expect the change to last at least through the end of December.

2. Changes that cause an increase in benefits:

  • We require proof of a decrease in income before we update benefits based on the reported change if the change will increase the household's benefits. We decide when to change benefits based on whether or not they provide the proof we asked for within ten days.  If they take more than ten days to provide this proof, we increase benefits starting the month after the month we received the proof even if they request more time to give us the proof.
  • If a change is reported through the online system on a weekend or holiday, the change is considered reported to the department on the first business day following the date the client entered the change online.  We increase the benefits starting the following month.  So if the client enters a change into their CBA on Saturday, March 30, the change would not take effect until May benefits.  We consider the change received Monday, April 1.
     
  • We require proof of expenses that will increase Basic Food benefits only if the expense is questionable.
     
  • When cash assistance benefits increase because someone starts paying shelter costs, we adjust the cash benefits in the same month that the change was reported if proof was provided timely. We do this instead of waiting until the following month. If the proof was not provided timely, then we follow the regular rules for the effective date of the change.
     
  • If a person leaves a community residential facility or a medical institution after the first of the month and they have been receiving CPI monies per WAC 388-478-0045 or 388-478-0040, the effective day for the change in benefits is the day they leave the facility.  

    Benefits are determined by dividing the grant amount by the number of days in the month. The remainder is multiplied by the number of days left in the month counting the date of discharge. The CPI is divided by the number of days in the month and the remainder is multiplied by the number of days the person was in the facility. The two sums are added together and the CPI amount is subtracted from the total.

EXAMPLE: Sam and his family receive TANF assistance. Up until October 1, Sam had no rent obligation, so the family was receiving a supplied shelter grant. Beginning October 1, he started paying $200 a month in rent. He reported and verified this change to the CSO on October 10th. Instead of waiting to increase his cash benefits in November, the change in the TANF grant standard takes effect in October, which is the beginning of the month that the change was reported and verified.
EXAMPLE: Tommy is receiving Aged, Blind or Disabled (ABD) cash. He was receiving a supplied shelter grant because he was living rent free at his brother’s house. On December 1st, his brother starts charging him $100 a month for rent. Tommy is not required to tell us about this change due to simplified reporting. He tells the CSO about the change on February 10th. He verifies the new shelter obligation on February 15th. The office makes the changes and supplements Tommy’s February cash grant, instead of waiting until March. This is because he was not required to report the change, but when he did, he verified timely.
EXAMPLE: Sheri and her child receive TANF assistance. They were receiving a supplied shelter grant. In September they moved and started to pay rent. Sheri reported this on September 5th, but she did not provide proof of the change as requested until October 15th. Her payment standard for TANF will change from the supplied shelter standard to the full shelter standard beginning in November (the month after the month we received the verification).

EXAMPLE: Bill is in an ARC (Adult Residential Care facility) and is receiving CPI, $38.84. He is released from the facility on April 10th and will be responsible for paying shelter costs. He is eligible for a supplemental payment of $210.11 calculated as follows:

$339 divided by 30 = $11.30

$11.30 x 21 = $237.30

$38.84 divided by 30 = 1.29

$1.29 x 9 = $11.65

$237.30 + 11.65 = $248.95 which rounds up to $249.00

$249.00 – 38.84 = $210.16 (ACES issues the exact amount for the BEG)

If Bill were going into supplied shelter, the same equation applies with the supplied shelter amount being used.

NOTE: If someone reports a change that would increase their benefits, but fails to provide the needed proof, we do not update the case to increase the AU's benefits. We also do not terminate the AU's benefits based on the missing proof. We continue to use the previous income and expenses until the next review / recertification.
NOTE: A reported one-time medical expense may have a different effective date as a deduction depending upon how the person chooses to have it budgeted.

3. Changes that reduce benefits:

When people report a change that will reduce their benefits, make the change to reduce their benefits (with advance notice). Do not require proof of the change. We will verify this information at the next eligibility review / recertification.

4. When someone reports multiple changes at one time:

When clients report multiple income-related changes at the same time, review each change separately to decide how the change impacts their eligibility and benefits.

EXAMPLE: Rebecca did not receive her March TANF or Basic Food benefits because she moved in February and did not report this change. Her mail was returned, "Moved, left no forwarding address". Her benefits closed without advanced notice on the last day of February.  On March 3rd, she reports her new address. In addition, Rebecca reports a new job. Reinstate her TANF and Basic Food back to March 1st. Give Rebecca 10 day's advanced and adequate notice regarding any benefit changes from the new job. Any reductions to her TANF and Basic Food would be effective in April.
EXAMPLE: Charles lost his job. He applied for TANF benefits and was approved. The first change is that Charles lost his job. The second is that he now receives TANF.  Charles losing the income from his job is a change that increases benefits. If Charles gives us proof of the change timely, we increase his benefits effective the first of the next month.  The second change was that he started to receive income from a new source. This is a change that decreases benefits. We reduce benefits effective the month after the change when this meets advance notice requirements.

5.  For Basic Food: When a newborn's date of birth is between the application date and interview date:

The newborn is eligible for benefits in the month of application effective the date of birth.  However, ACES does not correctly prorate benefits in the month of application when the newborn's application date is different than the rest of the household members.  When finalizing the case, you will need to exclude the baby in the first month and manually create a BEG to supplement the newborn's portion.  The supplement amount is the difference between what the household is eligible to receive with and without the newborn, prorated from the date of birth.

To determine the BEG amount, take the following steps:

  1.  Determine how much the household is eligible to receive if the newborn was in the household at the time of application.
    •  Screen the newborn onto the Basic Food AU.  Use the date of birth as the application date.
    •  Go through "Start Interview" and "Process Application Months" as usual.
    •  Go into "Finalize" and start the finalize process.  Even though you screen the newborn in as of the date of birth, ACES 3G will open everyone (including the newborn) from the original application date.
    •  Make note of the benefit amount on the Food Eligibility Details screen for the month of application and back out (don't finalize!).   
  2. Determine how much the household is eligible to receive without the newborn in the month of application.
    •  Go into "Process Application Months" in the month of application only and code the newborn as a non-member on the Basic Food AU ID screen.
    •  Go into "Finalize" and finalize the case.
    •  The amount for the month of application should exclude the newborn.  The amount for the on-going months should include the newborn.
  3.  Take the difference between the amounts in Step 1 and Step 2 and divide by the number of days from the application date through the 30th.
    •  We always assume a 30-day month.
    •  Count the application date as day "one".
  4.  Multiply the result from Step 3 by the number of days from the newborn's date of birth through the 30th, and round down.  This is your BEG amount.
    •  We always assume a 30-day month.
    •  Count the newborn's date of birth as day "one".

EXAMPLE: A husband and wife apply for Basic Food on 07/10/10.  The wife gives birth on 07/20/10 and reported this information during their interview on 07/25/10.  The worker screens the newborn onto the AU.  After going through Steps 1 and 2, the worker determines that in the month of application, the household is eligible for $250 as a household of three (including the newborn) and  $180 as a household of two (excluding the newborn).  The worker finalizes the case and approves benefits as a household of two for the month of application, and a household of three for the rest of the certification period.

To figure out the BEG amount, the worker follows Step 3 and 4:

  • $250 - $180 = $70
  • $70 ÷ 21 days (from 07/10 through 07/30) = $3.33 per day
  • $3.33 x 11 days (from 07/20 through 07/30) = $36.63
  • The worker creates a BEG for $36.

NOTE: For information on how to create a BEG, see Benefit Error Group (BEG) in the ACES User Manual.

6.  For Basic Food: When someone (other than a newborn) moves into the household between the application date and interview date:

If someone moves into the household between the application date and interview date, that person is eligible for benefits effective the application date, along with the rest of the household members.

7.  Requests to add a person to an open case:  When cash assistance benefits increase because a person is added to an assistance unit, use the effective date rules for applications in WAC 388-406-0055. See below to decide if you need an application or Eligibility Review (ER) form to add the new person to the current benefits:

  Cash Assistance

If someone asks to add an adult to their cash benefits, have the person complete an application or ER.

  • For cash, the responsible adult members of the AU must sign the application or ER.
  • We do not need a new application / ER form to add a child to TANF/SFA AU.
  Basic Food

 

We do not need a new application / ER form to add someone to the AU.

 

 

8. Changes that cause a cash program change:

When clients report changes that makes them ineligible for the active cash program but eligible for another cash program, verify the change and process the cash program change without a new application or ER form unless it is required for other reasons.  See CSD Procedure Handbook – Change of Circumstances Processing (For staff only) for procedures. 

Examples:  Mary is receiving ABD and reports that her 9 year old child has moved back into her home.  Mary meets all eligibility requirements for TANF.  Verify that the child has returned to Mary’s home and terminate ABD with advance and adequate notice.  Screen in a TANF AU using procedures found in CSD Procedure Handbook – Change of Circumstances Processing (For staff only).    
Using the same scenario as above but Mary reports that the child’s father, Robert, also moved back into her home.  Since we are also adding an adult to the assistance unit, an application or ER form will be needed with the signatures of all responsible adult members of the AU.  Please see the table in #7 above for more details about when an application or ER form is needed.    

9.  Return Mail:
If you receive returned mail for someone and there is a new or forwarding address, take the following steps:

a. If the client's new address is in the State of Washington; refer to Worker Responsibility #5 for WAC 388-418-0007 in the Reporting Requirements section of the EAZ Manual.

b. If the client's new address is out of state, terminate benefits without advance notice as described in WAC 388-458-0030 (3)(b).

Note: When mail is returned by the post office, and there is no new or forwarding address, HIU will dispose of the envelope.

c. No other action is necessary until the household makes contact at the next eligibility,  or mid-certification review.

ACES Procedures

 

  See Interview
Add a Person: See Add a Person
Add a Program: See Add a Program
Update AU / Client Data: See Update Assistance Unit / Client Data
Terminating an AUs / Client's Benefits: See Close Assistance Unit / Client
Adverse Action: See Update Assistance Unit / Client Data
See Deny an Assistance Unit / Client
Trickling and Sprouting: See Trickle and Sprout