Reporting Requirements

Revised July 1, 2024

Purpose:

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

• Clarifying Information and Worker Responsibilities

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

• Clarifying Information and Worker Responsibilities

Clarifying Information - WAC 388-418-0005

1. SSI / SSI-related medical benefits:

• Reporting requirements for SSI-related medical benefits don't apply to a person receiving SSI medical (S01). SSI recipients report changes to the Social Security Administration.
• A recipient of S01 medical and benefits from another program must report changes based on the requirements for the other program.

2. Reporting Requirements for Basic Food Simplified Reporting:
   
   1. Basic Food households must report when their income goes over 130 percent of the income poverty levels based on the number of eligible household members in their assistance unit. A household meets reporting requirements under simplified reporting when the household reports their income is above 130 percent of the income poverty level, but they remain eligible for Basic Food. The household doesn't have to report any other income changes until one of the following occurs:
      • The mid-certification review (MCR);
      • The eligibility review (ER); or
      • The household income is greater than 200 percent of the income poverty limit.
   2. Basic Food households must report when a member has a substantial lottery or gambling win. This information isn't subject to simplified reporting rules. Households must report this change by the 10th of the following month after receiving the winnings.
3. Reporting Requirements for State Supplemental Payment Program (SSP):
   SSP recipients don't have to report changes.
   We decide if someone is eligible for SSP based on information Social Security Administration (SSA) gives us through the State Data Exchange (SDX).
4. Taking action on changes:
   When we receive information about someone's circumstances, we must determine the impact on the person's benefits. This includes determining how the source of information impacts the actions we take on the household's benefits and whether we are required to act on it. Depending on the reporting circumstances, we may have to contact the household, contact other parties, or ask for proof of the household's circumstances under WAC 388-490-0005.
   1. Client Reports:
      
      • Take action based on changes the person reports. This includes when someone volunteers information after we contact them.
      • Get proof of a household's circumstances if they report:
        
        • A decrease in income that increases their benefits;
        • A change in expenses that increases benefits; or
        • For Basic Food, a change in expenses that increases food benefits and the expenses are questionable given their income and other circumstances.
   2. Third-Party Reports:
      
      • Information reported by anyone other than the household is a third-party report.
      • We must verify information reported by a third-party that conflicts with the information reported at application or recertification if the information is a reportable change.

• When information reported by a third-party doesn't conflict with information provided at certification, we must determine if the household is required to report the change based on their benefit program.
  • Hold the information until the next Mid-Certification Review or Eligibility Review, whichever comes first, if it's information the household isn't required to report.

For Basic Food only cases:

If the third-party report shows that we certified or recertified the case using significantly conflicting information, we must verify the report and make the necessary case corrections.  This may involve creating overpayments or making a fraud referral.

Example of information that conflicts with, but doesn't significantly conflict with, information used at cert:

Examples of information changing after cert:

c. Changes Verified Upon Receipt:

• Information reported from the primary source is "verified upon receipt". This information doesn't require secondary verification. Some examples include:
  • SOLQ;
  • UTAB;
  • A current employer; or
  • A landlord.
• Some verified upon receipt sources update ACES automatically and generate alerts for the change. We don't need to take action on these alerts.

d. A Lottery or Gambling Win:

• Information provided by the Washington State Lottery data match is verified upon receipt. Staff must take appropriate action to close the case if the client has winnings equal to or over the elderly or disabled resource limit for Basic Food. See Lottery or Gambling Disqualification for Basic Food.

e. Other Reports:

• Tickles or alerts from sources not verified upon receipt are considered third-party reports. Determine how to treat these tickles or alerts based on how we treat third-party reports.

f. Department of Corrections Reports and Incarceration: We have to act on Department of Corrections match tickles. These matches are from a primary sources, however, because the tickles are based on data we receive once a month, we must verify the tickles data.

Use FORS to determine whether the client is still incarcerated. Remove the incarcerated client from the basic food or cash household with adequate notice if they are incarcerated more than 30 days.

When the department verifies a client is incarcerated over 30 days, we suspend EBT benefits to prevent fraudulent use. Take the following steps when receiving notification that someone is verified to be incarcerated over 30 days:

• Submit a “Suspension of EBT benefits due to Incarceration” request
• Document the actions taken and reason for suspension of the EBT account
• Include canned text in the termination letter informing of the reason for termination and how to reactivate benefits

When a client contacts the department to report they are no longer incarcerated, request reactivation of benefits and document case action. Benefits will be available within 48 hours of notification they are no longer incarcerated. Contact to the department is also considered a request for reinstatement or application.

g. SSA Death Alerts

We must take action on alerts from SSA of a client's death. This information isn't considered verified upon receipt. Use DOH web portal to verify a client's death.

h. Information known to the department:

Information considered known to the department doesn't need verification to affect a household's benefits. The "department" is any agency under the Department of Social and Health Services including:

• Division of Child Support (DCS);
• Aging and Long Term Support Administration (ALTSA);
• Behavioral Health Administration (BHA);
• Developmental Disabilities Administration (DDA); and
• Facilities, Finance & Analytics Administration.

It also includes programs within ESA.

5. ABAWD reporting requirement:

A household must report when a non-exempt 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. Only ABAWDs in King County are subject to this requirement. 

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. When 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.

2. Changes a client voluntarily reports:
   • We must act on changes reported by the household even if they didn't have to report it 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 his monthly rent expense went from $300 to $500 monthly. The worker requests verification of this change as "questionable" because the total shelter costs ($500 plus utilities) are so close to Larry's monthly income. The worker updates the shelter costs after they receive proof of the expense.
   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 he is now employed, his worker must follow up to see how this impacts his Basic Food benefits.
3. Unverified changes that increase benefits:

   We ask for proof of a change if it increases a household's benefits. 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.

   • We don't update a household's case to increase benefits if they fail to give us requested verification of a reduction in income or an increase in expenses.

   • We don't close the case based on the household's failure to give proof of a change that would increase their benefits.

4. 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 ER notice is mailed to the client in the second to last month of their certification period, treat this form as a change of circumstances.
   2. On or after the ER notice is mailed to the client in 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.
5. 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.

6. AU member moves out of Washington:

   Washington state residency is a requirement 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 they are still eligible for benefits.

WORKER RESPONSIBILITIES - WAC 388-418-0007

1. During the application, recertification or eligibility interview:
   
   1. Tell clients what changes they must report and how much time they have to report the changes; and
   2. Explain how to report changes either in writing, online, by phone, or in person. (See RIGHTS AND RESPONSIBILITIES).
2. ​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:
      
      1. The details of the change;
      2. The date we learned about the change or the date the change was reported;
      3. The impact on benefits; and
      4. 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.
3. For Basic Food, if the household doesn't 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 Expense Page 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.

4. 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. Don't require verification of the new shelter expenses unless questionable.
   3. Make it clear that they don't 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.
5. If the client reports a move in writing or we receive returned mail with a new forwarding address on the envelope:
   
   1. Attempt to contact the household by phone. If successful, follow instructions in (4.) above.
   2. If unable to contact by phone and it's the month of an ER or MCR, don't send the household a general correspondence letter.
      
      1. Update the address;
      2. Re-send the return form(s) to the new address; and
      3. Wait to update shelter information until the ER or MCR.
   3. If unable to contact by phone and not in the month of an ER or MCR, send the household a general correspondence letter asking for the new shelter costs associated with the move.
      
      1. Make it clear in the letter they don't need to wait for the first regular rental or utility payment to tell us the amount(s); and
      2. Don't require verification of the new shelter expenses unless questionable.
   4. If the household responds to the letter:
      
      1. Update and document the new shelter costs in ACES; and
      2. Send notice to the household if there is a change in the benefit amount. Give advance notice if there is a decrease in benefits.
   5. If the household doesn't respond to the letter take no action. Verify new shelter expenses at the next review or MCR, whichever comes first.

Mid-Certification Reviews

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

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