Appendix C: Recoupment

Recoupment is a recovery method in which an individual’s benefits are reduced to repay an overpayment claim.

The individual has the right to appeal recoupment through a Departmental fair hearing, except when recoupment is ordered by a court.

The CAO will appear at any fair hearing on recoupment.

The rate of recoupment will be as follows:

If the amount of the SNAP allotment is reduced to less than $10 or $0 because of recoupment, CIS will issue the benefit for less than $10. If recoupment would eliminate the benefit entirely, CIS records the actual recouped amount and OARS sends the individual a Suspension of SNAP Benefit notice (OIG 720) for the $0 benefit month.

If the semi-monthly assistance benefit is reduced to less than $5 because of recoupment, CIS will issue a benefit for less than $5 (the cash minimum payment requirements are not applicable in these situations). If recoupment reduces the semimonthly cash assistance benefit to $0, the individual will receive Non-money payment (NMP)  Medical Assistance.

The OIG is responsible for initiating, monitoring, and controlling recoupment through the following computer systems:

NOTE:  For OARS and CIS inquiry information, refer to system manuals “Using OARS and Using CIS,” on the OIM Intranet.

Recoupment will continue until the claim is fully paid or until benefits are discontinued. If a case is suspended for a late semi-annual reporting form and is later reinstated, recoupment will continue.

If the individual’s benefits are discontinued, or if he moves to another budget group, the OIG may try to recover the claim through other means. Options are:

 

The CAO is responsible for notifying the OIG in the following recoupment situations:

Recoupment Begins

Cash Assistance

OARS will begin recoupment by sending the individual the following forms:

NOTE:  The court may specify the rate of recoupment.

Upon receipt of the OIG 740 or 742, the CAO will:

1. Determine if the individual’s SNAP allotment should be adjusted.

2. File the OIG 740 or 742 in the case record. Retain for three years, or until replaced by a later recoupment notice, or until recoupment has been completed.

NOTE:  Do not send an advance or confirming notice to the individual regarding the recoupment action and the subsequent reduction in the benefit amount. The OIG notices serve those purposes.

SNAP recoupment

If the court does not order an individual to repay an overpayment claim through recoupment, the individual must select one of the following options to repay the claim.

If an individual fails to respond to the initial demand notice, or select a payment option, or appeal the claim, the OIG will recover the claim through recoupment.

The OIG will begin recoupment action by sending the individual one of the following notices:

SNAP Recoupment Prosecution Notice (OIG 718) OR SNAP recoupment Court-Ordered Installments (OIG 719). The OIG 718 or 719 is sent to the individual in a prosecution case when the court has ordered recoupment. The type of notice which is sent depends on the court order. The court orders the rate of recoupment. OARS will send a copy of the OIG 718 or OIG 719 to the CAO.

NOTE:  The individual does not have the right to appeal through a Departmental fair hearing in cases of court ordered recoupment.

 

Upon receipt of a OIG 711, OIG 714, OIG 718, or OIG 719, the CAO will:

1. Update the SNAP computation pages in the case record to record the recoupment amount; and

2. File the OIG notice in the case record and retain for three years.

NOTE:  Do not send an advance or confirming notice to the individual regarding the recoupment action and the subsequent reduction in the benefit amount. The OIG notices serve those purposes.

 

Recoupment Completed

When the total claim amount has been recovered, recoupment ends. OARS monitors recoupment and is responsible for increasing the cash assistance benefit or SNAP allotment when recoupment has been accomplished.

Cash recoupment completed

When cash recoupment is completed, OARS will:

1. Send the individual a Final Recoupment Notice (OIG 749). The OIG 749 notifies the individual that the claim was paid in full.

2. Send a copy of the OIG 749 to the CAO.

 

The OIG 749 notifies the CAO that recoupment has ended. Upon receipt of the OIG 749, the CAO will:

1. Recompute SNAP to reflect the increased allotment, if necessary

2. File the OIG 749 in the case record and retain for 120 days.

Case Closed Before Total Overpayment Recouped

If the CAO closes a case before the total claim has been recouped, recoupment will end. However, since the claim has not been fully repaid, recoupment must be started again if cash assistance or SNAP benefits are reopened. CIS alerts OARS that the case is closed. OARS will:

1. Send the individual one of the following forms:

2. Send a copy of the OIG 748 or the OIG 723 to the CAO.

If the case is closed under one record number and reopened under another record number in the same county, the CAO will send a memo to the OIG. The memo should specify as the subject “Restart Recoupment.”

The memo must contain the old case number; the new case number; if the overpayment under the old case number was for cash, SNAP, or both; and if cash, SNAP, or both have been reopened under the new case number.

Case Reopened Which Has Unpaid Claim Previously in Recoupment

CIS will alert OARS when a closed case, which has an unpaid claim that was previously being recovered through recoupment, is reopened. OARS will:

1. Send the individual a Recoupment Restart Notice (OIG 752). The OIG 752 notifies the individual that recoupment will be resumed.

2. Send a copy of the OIG 752 to the CAO.

The OIG 752 notifies the CAO that recoupment is being restarted. Upon receipt and review of the OIG 752, the CAO will:

1. Recompute the SNAP benefit allotment if the cash overpayment was not caused by an IPV.

2. File the OIG 752 in the case record and retain for three years or until the claim is paid in full.

NOTE:  Do not send an advance or confirming notice to the individual regarding the recoupment action and the subsequent reduction in the benefit amount. The OIG notices serve those purposes.

Change in Case Data

OARS will obtain changes in address from CIS. The CAO does not notify the OIG of any changes in case data.

Exception: The CAO will notify the OIG if a case with a claim being recovered through recoupment is closed under one record number and reopened under another record number. See instructions under Case Reopened Which Has Unpaid Claim Previously in Recoupment.

NOTE:  If the individual who caused the overpayment leaves the overpaid budget group or household, recoupment can continue from the members who remain in the overpaid budget group or household.

Appeals

The individual may appeal recoupment when he receives the notice that recoupment will begin.

Exception: The individual does not have the right to appeal through a Departmental fair hearing if recoupment is court ordered.

If an individual wants to appeal, the CAO will:

1. Help the individual complete a written request for a fair hearing.

NOTE:  Any request for a fair hearing on cash recoupment must be in writing. An oral request is not sufficient.

2. Complete and process the ARRC Claim Change Form (PA 1001) to update the data on an overpayment referred through the ARRC System.

3. Refer the individual to the OIG if he has a question about recoupment of the overpayment. The OIG’s toll-free telephone number (1-800-932-0935) is listed on the OIG recoupment notices.

 

If the individual files an appeal before the deadline date shown on the recoupment notice, the recoupment action will stop until the hearing is held and a decision is handed down. The Bureau of Hearings and Appeal notifies the OIG of the appeal. OARS will:

1. Send the individual one of the following notices that indicate recoupment has been suspended because of the appeal:

2. Send a copy of the OIG 745 or OIG 721 to the CAO.

 

The OIG 745 or the OIG 721 alerts the CAO that recoupment has been suspended and that the CASH assistance or SNAP allotment will not be reduced. When the CAO receives the OIG 745 or the OIG 721, the CAO will:

1. File the OIG 745 in the case record until a decision has been reached on the appeal. File the OIG 721 in the case record and retain for three years.

2. Recompute the SNAP benefit allotment if the individual has appealed cash recoupment, and a reduced amount of cash assistance was used in computing the SNAP allotment. The cash benefit will not be decreased because of the appeal.

3. Write “Under appeal” in the case record to indicate that the SNAP recoupment amount is not being deducted from the SNAP allotment.

4. Attend the fair hearing, to present testimony and evidence as to how the overpayment occurred, and how the SNAP overpayment was computed.

 

The Bureau of Hearings and Appeals will send the CAO, OIG, and the individual a written notice of the hearing decision. If the decision is in favor of the individual, recoupment will not start. The CAO will note in the case record that the individual’s appeal was upheld. Complete and process the ARRC Claim Change Form (PA 1001) to update the ARRC System.

If the decision is in favor of the Department, OARS will start recoupment by sending the individual a Recoupment Notice – Fair Hearing Decision (OIG 751) for cash assistance or a SNAP Recoupment Start Notice – Appeal Denied (OIG 722) for SNAP, and send a copy to the CAO. Upon receipt of a OIG 751 or a OIG 722, the CAO will:

1. Recompute the SNAP allotment if the cash overpayment being recouped was not caused by an IPV.

2. Update the SNAP computation pages in the case record to note the recoupment amount.

3. File the OIG 751 or OIG 722 in the case record and retain for three years or until the claim is paid in full.

NOTE:  Do not send an advance or confirming notice to the individual regarding the recoupment action and the subsequent reduction in the benefit amount. The OIG notices serve those purposes.

Multiple Claims

The OIG can recover only one claim at a time through recoupment in a particular program. If a case has multiple claims or an additional claim is established while one claim in the case is being recouped, the OIG will attempt recovery of these claims through voluntary recoupment or direct collection from the individual.

Inter-County Transfer

When a case is transferred to another county, the losing county will use reason code 099 to close the budget. OARS will learn from CIS that the budget was closed.

OARS will not have any information about the new case number assigned in the receiving county. For recoupment to resume under the new case number, the receiving CAO will send a memo to the OIG. The memo should specify as the subject “Inter-County Transfer, Restart Recoupment.” The memo must contain the old county and case number; the new county and case number; if the overpayment under the previous county and case number was for cash, SNAP, or both; and if cash, SNAP, or both have been reopened under the new county and case number.

Reissued March 24, 2006, replacing December 15, 2003; reviewed March 16, 2012