Mid Certification Reviews

Created on: 
Dec 21 2015

Revised July 31, 2017

WAC 388-418-0011 What is a mid-certification review (MCR), and do I have to complete one in order to keep receiving benefits? 


Clarifying Information -  WAC 388-418-0011

1. Review items for MCR:  The requirements for the MCR vary by program.  See below for elements that must be reviewed and updated, if changes have been reported:  

Cash Basic Food
Address Address
Deductions: legally obligated child support

Deductions:

  • Child support;
  • Shelter expenses (only if moved); and
  • Medical and child care expenses if applicable.
Disability  
Household Composition Household Composition
Income

Income (new source, start, stop, change in rate or hours) See 2.d.

Pregnancy
Resources

Do not address LAM during the MCR process.  See Verification section.

2.  MCRs with conflicting, missing, or previously unknown information:

a.  MCRs are either complete or incomplete.  Make every attempt to clarify conflicting or incomplete information.

b. If sections on the MCR are blank and there is no conflicting information on our cross matches, we can consider the MCR complete even with the blank section.

c.  Any information on the MCR or absent from the MCR report that conflicts with information found on various data cross matches must be resolved before the MCR can be considered complete.

c.  The MCR is considered incomplete until we have;

i.  All the needed information, and;

ii. Required verification to determine eligibility for month seven.  

See #3 a. and b. below for required verification.

d.  For CSD users, see CSD Procedure Handbook for MCRs.

EXAMPLE:

Mozzie’s MCR is due the end of May.  He lost the MCR form mailed to him but finds an ER online and submits that instead.  Mozzie says he is still only working 10-15 hours per week (no change in income).  He also checks the box on the ER form stating he is a student but doesn’t explain or indicate the type of school and how many credit hours he is taking (full time or less than half time).  The worker tries to call Mozzie to clarify his student status but he is not available to take the call.  Since Mozzie has no student exemption factors and is not working at least 20 hours per week, the worker must mark the MCR as incomplete and terminate benefits.  The worker adds some free-form text on the termination letter to inform Mozzie that he must contact us to clarify his student status.

EXAMPLE:

Jason’s completed Basic Food MCR form is received early in the sixth month. Jason reported no income and no changes. Spider shows Jason has earnings from a previously unreported source in the most recent work quarter.  (Income indicated is significantly less than 130% of FPL times 3 months.) The worker attempts to call Jason but is unable to reach him.

The MCR is processed as incomplete, documentation is added to the case explaining why and a MCR termination letter is sent requesting clarifying information regarding current employment status.

Jason comes into the local CSO in the middle of the sixth month to report that he is no longer employed with the company indicated and received his final check two months ago. Since earnings were not previously budgeted, verification of employment loss is not required as there is no currently budgeted income to remove.

Worker accepts client’s statement reinstates food benefits and MCR is marked as complete

3.   Required proof for the MCR:  We don't require proof of an increase in income deductions unless the deduction is questionable.  What proof a person must provide for us to count an MCR as complete depends on the benefits they receive.

a.  For Food MCRs:

i.  If the client's reported deduction isn't questionable, allow the increased expense.  If you have all other mandatory verifications, treat the MCR as complete.

ii.  If the deduction is questionable (for example; client reports household rent has gone up from $800 per month to $1600 per month), don't allow the increased expense without proof.  If you have all other mandatory verification, treat the MCR as complete and add text to the letter informing the person to provide verification of the change if they want it to be counted for benefits.  Leave the old deduction amount (if any) as is until the next eligibility review (ER) or until verification is provided.

iii.  The person does not have to answer questions about pregnancy, individuals with disabilities, health insurance, cash resources, vehicles, or utility costs.  These questions are not included on the Food-Only version of the MCR which is mailed to Basic Food and FAP households not receiving any cash benefits that require an MCR.

iv.  There is no requirement to provide verification of reported changes before we act on the changes unless there is a change in income that will increase the Basic Food/FAP benefit.  If the person does not provide verification of income that will increase the benefit do not make the income change, let the benefit continue at the current amount, and verify the income change during the next recertification.

v.  The person has the option to complete the MCR process by using the Food-Only MCR form with questions relating to food benefits only or the multi-program MCR form and only answer the questions needed for the food benefits.

vi.  Information reported that is not required for the MCR should be processed as part of the MCR effective in month seven if the MCR has been submitted timely (before benefits are closed for no MCR).

b.  For Cash MCRs:

i.  The form instructs the person to give us proof of the changes they tell us about on the MCR, except increases in deductions.  If a person doesn't include the verification with the MCR, consider whether the change affects benefits or is questionable before deciding whether the MCR is complete or incomplete.

ii.   If the client’s reported deduction isn’t questionable, allow the increased expense. If you have all other mandatory verifications, treat the MCR as complete.

iii.  If the deduction is questionable, don’t allow the increased expense.  If you have all other mandatory verification, treat the MCR as complete and add text to the letter informing the person to provide verification of the change if they want it to be counted for benefits. Leave the old deduction amount (if any) as is until the next eligibility review (ER) or until verification is provided.

iv.  Adult recipients of TANF must give us proof of their income even if their income hasn't changed.

v.  For a child-only TANF grant, the non-needy members do not have to provide proof of their income.

vi.  If the person reports no changes for Basic Food and TANF and the person did not give proof of their income, process the MCR as complete for Basic Food and incomplete for TANF.

vii.  Additional information reported that is not required for the MCR should be processed as part of the MCR effective in month seven if the MCR has been submitted timely (before benefits are closed for no MCR).

NOTE:

Even though we do not require TANF households to verify employment hours as a condition of eligibility, we must still verify and record employment hours. See Income Budgeting for information on how to record income and employment hours for TANF households.

 

EXAMPLE:

Bill's MCR is due in June. Sandy, his WorkFirst Program specialist verified his income and hours of work in April when Bill reported that his hours were reduced. If Sandy verified the income and hours to impact June benefits, we do not need to re-verify this information to complete the June MCR. If she verified the income and hours to impact an earlier month, we must re-verify the income and hours to complete the June MCR for TANF.

 4.  Applications or Eligibility Reviews (ER) received in the sixth month:

  1. Process the form as an MCR as described under WAC 388-418-0011.
  2. If extra information is reported (more information than is required for an MCR) then treat this information as a change of circumstance and consider the impact on benefits and the effective date of the change using adverse action/adequate notice rules under WAC 388-418-0020.
  3. Do not require the household to provide any more verification or information than is required for an MCR.
EXAMPLE:

Bob’s MCR is due the end of May.  Bob lost the MCR form mailed to him but finds an ER online and submits that instead.   The ER is received on May 26th.  The worker reviews the information on the ER and determines all items needed to complete the MCR are present and the worker marks the MCR as complete.  Bob reported a change in his student status.  The change is not questionable so the worker makes the change and processes this action as a change of circumstance effective July 1st.

NOTE:

If you approve an application on a related AU after deadline for the month an MCR is due, the benefits covered in the MCR will still close. Even though processing the application meets the requirement for the review, you must also reinstate the benefits that closed for no MCR.

5.  MCRs completed late:  If someone does not complete the MCR on time, ACES closes the benefits at the end of the sixth month (month MCR is due). We treat MCRs completed after the sixth month as described below:

a.  Completed by the last day of the seventh month: Process the MCR to determine ongoing eligibility for benefits and reinstate benefits if appropriate.

EXAMPLE:

Dee receives her MCR for Basic Food and TANF due on August 10th. She does not complete the MCR as required. Dee's benefits end on August 31st.  On September 8th, Dee completes her MCR over the phone and her worker gets proof of the changes she reports. Her worker reinstates Basic Food and TANF benefits effective September 1st.

NOTE:

If the household submits an Application for Benefits or an Eligibility Review by the last day of the seventh month and no other assistance program is being requested, you may treat the Application or Eligibility Review as an MCR.  If additional programs are requested see #7.

 b.  Received later than the seventh month: Document when you received the MCR and send the person an application for benefits.

EXAMPLE:

The Smiths have an MCR due on January 10th. They do not return the MCR form or complete the MCR over the phone.  ACES closes Basic Food on January 31st.  On March 4th, Mr. Smith turns in an MCR stating that there were no changes in their circumstances.  He has also attached proof of their income. Because they completed the review later than the end of February, we treat the MCR as a request for an application and send them a new application. The AU is not eligible for benefits for February. To receive benefits, the AU must complete the application process as described under chapter 388-406 WAC.

 6.  Applications or Eligibility Reviews received  in the seventh month:

  1. Process the form as an MCR as described under WAC 388-418-0011.  All information reported on the ER must be acted on even though the information may not be an MCR reportable item. 
  2. Do not require the household to provide any more verification or information than is required for an MCR.
  3. The household may specifically request we treat the application or ER as a new application for food.  There is no need to contact the household to ask how it wants to treat the application/ER if a responsible person in the household hasn’t already requested this in writing or verbally.  
  4. Expedited services can be considered if treated as a new application.  ACES should set a new, 12-month certification period.
  5. See ACES PROCEDURES for information on screening the application or eligibility review if we treat the document as a new application. 
NOTE:

If someone wants to complete the application process, or we cannot complete the MCR with the information we have available, we must act on the application for benefits.

7.   Requests to add a person on the MCR:  The MCR asks about people moving into the household and whether or not they want benefits for this person. 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.  Requests to add a program / program change on the MCR: For all programs, a person must complete a new application or ER form to add a program.  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.  Completing the MCR over the phone:

a.  You do not need a signed MCR form to count the MCR process as complete as long as you review the following with the client:

By completing this Mid Certification Review over the phone you’re stating the information you gave is true, correct and complete to the best of your knowledge. You know the information given may stop or reduce your benefits. You know it is a crime to incorrectly receive cash or food benefits by making a false statement on purpose or failing to report something you knew you should report. You understand if you provide information you know is incorrect, you could be criminally prosecuted. You understand penalties for intentionally breaking food assistance rules include disqualification, fines or imprisonment.  You understand if you don’t provide proof of income changes that increase your benefits for cash or food assistance, changes won’t be used to determine your benefits.

b.  It is a federal requirement for the SNAP periodic reporting (MCR) process to have the client acknowledge understanding of the statement above either by signing a form with the statement on it or providing verbal acknowledgment after the statement is read to them. Make a case note to document that the person acknowledged their understanding.

10.  MCRs completed in the local office:  We process MCRs completed in the local office based on the way we receive the report:

a.  Completed Forms:

An MCR form completed on paper or electronically is processed the same way we would process one received by mail or fax. The client must sign the form to acknowledge that they understand the information they provided for the MCR may reduce or stop their benefits.

b.  In Person Reports:

The in-person verbal report can't be used to complete the MCR requirement unless they also complete and sign the Statement of Understanding Form 02-611 or a copy of the MCR form printed from Barcode.

Worker Responsibilities -WAC 388-418-0011

  1. Working alerts, Barcode tickles, and checking other systems as part of processing the MCR:

To reduce the risk of payment errors, work related Alerts in ACES, Barcode tickles, and review systems such as SEMS as appropriate to ensure that the income you budget is based on the best available information.

NOTE:

Households do not have to report changes in the amount of their child support or child support pass-through payments between application and MCR. However, we must update this information as a part of completing the MCR. When working on an MCR for a case that could have child support income, be sure to check SEMS for recent payment information to determine what would be appropriate to estimate as income for ongoing months.


ACES PROCEDURES