Effective Date - Change of Circumstances

Created on: 
Nov 09 2015

 

Revised December

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).

·  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

Mass changes are changes to eligibility rules.

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:

  1. 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
  2. Leave the person's benefits unchanged.
  3. If the client is an ABAWD, we must determine if participation is met for each month (see Worker Responsibilities WAC 388-444-0030- Verifying Participation).

    1. If the client is now meeting participation when they were not before, document. Advise client of continued participation requirements.
    2. If the client is temporarily unable to meet participation, see Good Cause
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 Client Benefit Account (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.
     
  • 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 388-478-0006, the effective date for the change in benefits is the day they leave the facility. ACES calculates the benefit amounts as follows:  
  1. Divide the new grant amount payment standard by the number of days in the month.
  2. Multiply this amount by the number of days left in the month counting the date of discharge.
  3. Divide the CPI grant by the number of days in the month. 
  4. Multiply this amount and the remainder is multiplied by the number of days the person was in the facility.
  5. Add the amounts from #2 and #4 together.
  6. Subtract the CPI grant from the total #5. The two sums are added together and the CPI amount is subtracted from the total.

EXAMPLE: Billie is in an ARC (Adult Residential Care) facility and is receiving a CPI of $38.84 as an TANF recipient. Billie is released from the facility on April 10th and is eligible for a supplemental payment calculated as follows:

  1. $450 (benefit amount) divided by 30 (number of days in the month) = $15
  2. $15 x 21 (number of days left in the month, counting date of discharge) = $315
  3. $38.84 (CPI) divided by 30 (number of days in the month) = $1.29
  4. $1.29 x 9 (number of days the person was in the facility for the given month) = $11.61
  5. $315 + $11.61 = $326.61 which rounds up to $327
  6. $327 – 38.84 = $288.16 (ACES issues the exact amount for the BEG)

EXAMPLE: Charlie is an ABD recipient, who has been in an Adult Residential Treatment facility (ARTF) and receiving CPI $38.84. Charlie graduates and moved into clean and sober housing unit on October 13th and eligible for a supplemental payment calculated as follows:

  1. $450 divided by 31 = $14.52
  2. $14.52 x 19 days left in the month = $275.88
  3. $38.84 divided by 31 = $1.25
  4. $1.25 x 12 days in facility = $15.03
  5. $275.88 + 15.03 = $290.91 rounded up to $291
  6. 291 - 38.84 = $252.16 (ACES issues the exact amount for the BEG)
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.

If the client is an ABAWD, consider how a change in their hours or income could impact their work registration status. If verification of participation is required, request it.

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.

EXAMPLE: Rico is returning to work after a temporary incapacity. Rico lives in a non-waived area and is now identified as a non-exempt ABAWD. Although we do not need income verification to decrease benefits, we do need work verification to determine if Rico will meet participation 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 supplement for 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 supplement 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: 

  1. For Cash Assistance: 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, unless the applicant is an ABAWD attempting to requalify.

 

  1. For Food Assistance: For Food Assistance: In a case of an ineligible ABAWD client regaining eligibility in an active AU:

See How do I lift an Able-Bodied Adult Without Dependents (ABAWD) disqualification for a client on an active Basic Food AU?.

The client is eligible to receive a supplemental payment for the time they are eligible in application (requalifying) month.  To process the supplement:

EXAMPLE: A husband and wife apply for Basic Food on April 10th.  Currently the husband is active on the AU. The wife is an ineligible ABAWD on the AU. They are re-applying for benefits because she is now participating in a WIOA program and met her requalification hours on April 20th.
  1. Determine how much the household is eligible to receive if the wife was an eligible household member.
  2. Determine how much the household is eligible to receive without the wife. 
  3. The worker determines that in the month of application (requalification), the household is eligible for $355 as a household of two (including the wife) and $194 as a household of one (excluding the wife).  The worker finalizes the case and approves benefits as a household of one for the month of application (requalification), and a household of two for the rest of the certification period.
  4. Take the difference between the amounts in Step 1 and Step 2 and divide by the number of days from the requalification date through the 30th.
    • We always assume a 30-day month.
    • Count the requalification date as day "one".
  5.  Multiply the result from Step 3 by the number of days from the requalification date through the 30th, and round down.  This is your supplement amount.
    • We always assume a 30-day month.
    • Count the requalification date as day "one".
  6. To figure out the supplement amount, the worker follows steps 4 and 5.  

$355 - $194 = $161

$161 ÷ 30 days (from 04/01 through 04/30) = $5.3667 per day

$5.37 x 11 days (from 04/20 through 04/30) = $59.03

The worker creates a BEG for $59.

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

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