The CAO must determine what information must be verified. To do so, look at:
the information on the application;
NOTE: Birth certificates issued by Puerto Rico prior to July 1, 2010 are not valid and cannot be used to verify age for new applicants. The Government of Puerto Rico issued new and more secure birth certificates on July 1, 2010. No additional verification is required for a past or current recipient who provided a birth certificate issued prior to July 1, 2010. If a birth certificate is the only documentation that can be obtained to verify age, follow the process outlined in OPS 110201, Process to Obtain Birth Record Verification from Puerto Rico's Demographic Registry Office for Proof of U.S. Citizenship.
prior case information;
statements made by the person; or
information from automated sources.
NOTE: The CAO must scan and save pay stubs and employer statements used to determine eligibility and grant amount. This process must be followed at application, renewal, and SAR review and any time new earned income information is reported. Verification of actual hours worked is required to complete federal TANF reports. See Chapter 150.
The CAO must consider the person’s age, physical or mental disabilities, and other factors when requiring the person to prove his or her statements. Do not seek verification that the person is able to provide. Tell the person that help will be provided to the extent needed if requested.
When evidence from a person is inadequate, incomplete, or inconsistent or cannot be determined in view of other evidence, tell the person that additional evidence is required. Together, the income-maintenance caseworker (IMCW) and the person must determine acceptable sources for further evidence.
NOTE: To the extent possible under current regulation, apply Medical Assistance citizenship and identity verification to TANF applications and renewals. Do not deny or close TANF benefits if an applicant or recipient does not provide this verification. Use PA 1809, Citizenship and Identity Form, to verify citizenship and identity for TANF and Medical Assistance applicants or recipients. Do not delay or deny TANF benefits to a person or family that is cooperating to get acceptable Medical Assistance citizenship or identity documentation. See Medical Assistance Eligibility Handbook, Chapter 320, Chapter 322, and Chapter 378.
NOTE: Do not sanction an applicant or recipient who has cooperated with reasonable effort but cannot provide a Social Security number or date of birth of a putative father or noncustodial parent. Do not presume noncooperation if the person has given the putative father’s name and has not previously had the names of two putative fathers rejected by genetic testing. See Appendix E.
Traditionally, the applicant or recipient has had the burden of verification for all programs. But with the advent of electronic data sources and matches, CAOs must avoid unnecessary requests of verification from individuals and ensure that all available sources of information are utilized.
CAOs must:
Determine what information requires verification based on the benefit. (TANF, MA, or SNAP) and the action to be taken, (application, renewal, SAR, or whenever a change occurs). Use guidance in the program Handbooks, policy updates posted on OIM's MyDHS pages, and the Verification Guide.
Check the case record and Imaging Repository for verification that may have been already provided. When appropriate, use other available resources such as the Income Eligibility Verification System (IEVS) Data Exchanges, The Work Number, Pennsylvania Automated Child Support Enforcement System (PACSES), and Pennsylvania's Enterprise to Link Information for Children Across Networks (PELICAN) before asking the individual for verification.
Not close or reject a benefit if the verification of a deduction is not provided. Eligibility should be determined without allowing the deduction.
Not deny or close benefits if the CAO is unable to obtain verification electronically through automated sources but the individual is cooperating in providing the requested information. The CAO must make a collateral contact with anyone who can be expected to give reliable information.
The IMCW must make a plan with the person for getting the required proof within the following time frames:
30 calendar days from the application authorization date.
15 working days from a renewal interview date.
15 working days from the effective date of a change for an assistance payment. See Chapter 170, Section 170.5.
If a person has cooperated but cannot get acceptable evidence, the IMCW must make a collateral contact with a third party. When required, the IMCW must have the person sign a copy of the Authorization to Release Form (PA 4). See Section 178.4.
NOTE: Ineligible aliens who state they do not qualify for an SSN due to immigration status should not be referred to the Social Security Office. See Chapter 122.
Except in cases of suspected fraud, the IMCW must try to notify the applicant or recipient before contacting a third party for information about that applicant or recipient.
NOTE: It is important that the IMCW follow appropriate verification steps before making a referral to a front-end investigator from the Office of State Inspector General (OSIG). The person has the right and responsibility to provide verification of eligibility. The CAO staff has the responsibility to verify a person’s eligibility. For this reason, an OSIG referral should never be made for the purpose of providing routine verification.
If efforts of both the person and the IMCW do not get valid proof, the IMCW must make a reasonable judgment based on available evidence, credibility of the person, and validity of other supporting and conflicting evidence.
If the person fails to cooperate in providing verification, the IMCW must send a Notice to Applicant or an Advance Notice to a recipient with the following information:
A list of information not provided or action not taken.
The citation in regulation on which the information or action is based.
The help the IMCW provided in getting the information, if help was needed.
The case record must clearly establish eligibility or ineligibility. The IMCW must explain in the record any decision to require verification from additional sources or verification to clarify inconsistent information. The IMCW also must record the plans and time frames established with the person to get the proof.
The IMCW makes a referral to an OSIG front-end investigator only under the following conditions:
the IMCW has taken all required steps in the normal client verification process to retrieve necessary and acceptable information but cannot establish eligibility; and
evidence given by the person is not acceptable (not adequate, not complete, not consistent, or cannot be determined in view of other evidence); and
the IMCW suspects fraud.
The IMCW may make an OSIG referral when suspecting fraud in cases involving applicants for benefits including LIHEAP, recipients, or providers (for example, child-care vendors, employment and training vendors, and medical assistance providers).
In all cases where the IMCW suspects fraud, including recipient and provider cases, the IMCW should use the Office of State Inspector General Avoidance and Recovery System (OARS) to submit most investigation referrals electronically. (OSIG Electronic Processing of a Field Investigation Referral Desk Guide) The OSIG 12 Field Investigation Referral form and OSIG 12R Program Integrity Unit Referral form should be submitted to the OSIG electronically in OARS. TANF cases involving domestic violence (DV) will be reviewed by BOP before an electronic referral is made. (OPS Memo 17-12-04)
DV and confidential cases should use the paper process due to sensitivity of documentation and to ensure expedited decisions in these cases. For cases involving DV, CAOs should continue to use to submit these cases via the paper process. The OSIG 12 Field Investigation Referral form an OSIG 12R Program Integrity Unit Referral form available in DocuShare should be submitted to the OSIG via hardcopy.
NOTE: In the event of system issues impacting electronic referrals, the CAO will be notified via EMS to temporarily revert to the paper referral process until notified to return to using the electronic referral process.
OSIG investigators must report findings to the CAO and IMCW within five work days or must notify the CAO liaison of the need for an extension for investigations involving applications for initial benefits and renewals for continued benefits. See Appendix D for OSIG field investigation details.
NOTE: On cases where domestic violence is indicated the IMCW should refer to Appendix D .
NOTE: OSIG investigations do not affect the normal overpayment process or the OSIG investigation into referrals selected for prosecution review. The prosecution review process occurs after these investigations have shown that fraud or intentional program violation may have occurred.
The CAO must require verification of eligibility conditions at the application interview. Items to be verified include:
55 Pa. Code § 125.21(b) 55 Pa. Code § 125.24(c)
Common residence and family composition.
Compliance with Job Search requirements.
62 P.S.405.1(a.2)(1)
Gross income, including income to be deemed. See Chapter 150 and Chapter 155.
Income expense deductions. See Chapter 160.
55 Pa. Code § 183.94 55 Pa. Code § 183.98
The equity value and ownership of resources, including those available from legally responsible relatives (LRRs) and sponsors of aliens. See Chapter 140.
Special need items. See Chapter 138.
Alien status. See Chapter 122 , Chapter 178, Section 178.3, and Medical Assistance Eligibility Handbook Chapter 322, Section 322.21.
Social Security number (SSN) if not already verified by the CAO (SSN code 1) or validated by Social Security Agency (SSN code 6 or code 7). See Supplemental Handbook, Chapter 950.
The relationship of the specified relative to the TANF child, only if questionable. See Chapter 127.
Deprivation of a TANF child. See Chapter 129.
Cooperation with DRS in establishing paternity or pursuing support. See Chapter 131, Chapter 178,Section 178.3, and Appendix E.
School attendance of a child age 18. See Chapter 121.
Residence. See Chapter 123.
Identity of the applicant. See Chapter 120 and Chapter 178, Section 178.3.
Employment and training exempt or mandatory status for each budget group member. See Chapter 135.
Criminal status. See Chapter 104, Section 104.48.
62 P.S. 432(9) 62 P.S. 481.1
Conviction for welfare fraud. See Supplemental Handbook, Chapter 910.
62 P.S. 481(f)
Conviction for residency misrepresentation. See Chapter 104 and Supplemental Handbook, Chapter 910.
P.L. 104-193 Title I, Section 103 (SSA 408(a)(8))
Conviction for felony related to illegal possession, use, or distribution of a drug. This information is needed only if the person is required to cooperate with assessment or treatment for a drug addiction. See Chapter 104, Section 104.48.
If an existing record contains verification of information that is not likely to change, such as a birth date or Social Security number, the CAO must not require verification again unless a discrepancy exists.
If the applicant has cooperated with verification requirements, authorize or deny assistance no later than the 30th calendar day following the date the CAO received the completed application.
The CAO must not deny an application for lack of verification when the person has cooperated in providing proof and verification is pending from a third party. This includes certification of cooperation with the domestic relations sections.
NOTE: If UC benefits are expected to be delayed, complete the OIG 176-U and inform the applicant of the requirement to continue making efforts to apply for UC. See Supplemental Handbook Chapter 915, Section 915.63 Delayed Unemployment Compensation.
Exception: The person must verify the following items before authorization:
A Social Security number or completion of an application for a number, except for newborns.
Identity, if the person is not known to the worker.
If the CAO authorizes assistance pending verification from a third party, it must allow another 30 calendar days following the authorization date for the verification to be provided. The CAO must continue benefits for an additional 30 calendar days as long as the person cooperates in getting the required verification and the delay is due to a third party.
The CAO must deny benefits if the person refuses to cooperate in providing the required information.
The CAO must discuss past management of resources only as it affects present eligibility. The CAO must not require a detailed or exhaustive accounting. If a resource or parts of a sizable resource may still exist, the CAO must require the applicant to provide:
55 Pa. Code § 125.24(c)(7)(iii)
the type and location of the resource; and
proof of the present availability of the resource.
If the applicant fears physical danger or emotional distress or is unwilling to contact the resource, please follow the procedure in CAH 108.75. Verification of Eligibility Factors. Contact the Bureau of Policy (BOP) through the email resource account at RA-PWDFADVREVIEWS@pa.gov with any questions.
When processing a complete renewal, the CAO must verify the following:
55 Pa. Code § 133.23(a)(2)(ii)
Identity, if the person is not known.
Common residence, household, and family composition.
NOTE: Regulations do not require a specific form to verify household composition. The person may use a signed statement from a nonrelative or other knowledgeable source or a collateral contact. Document in the case record how household composition was verified.
Status of any reported criminal charges. See Chapter 104, Section 104.48;
Compliance with any reported summons or warrant. See Chapter 104, Section 104.48.
Gross, nonexempt earned or unearned income including deemed income.
Income expense deductions.
Resources.
Special need items.
Employment and Training exempt or mandatory status, program participation status, and activity in seeking work or training.
Newly obtained Social Security numbers.
Other eligibility factors, if a change has occurred or information is not consistent or questionable.
Plans for continuing care of a TANF child temporarily not residing with a specified relative.
Income of persons living with the budget group, income of an LRR living elsewhere, and income of sponsors of aliens, as determined under 55 Pa. Code 183.34, 183.35, and 183.91 through 183.93, if applicable.
The CAO must not verify information that is not likely to change, such as birth date or Social Security number, unless the review shows that current information may be incorrect or is not properly recorded.
55 Pa. Code § 133.23(a)(3)(iii)
The CAO must allow the person 15 working days from the renewal interview date to provide any requested verification.
Exception: The CAO must allow the person up to 30 calendar days to provide verification of a disability or incapacity.
If the person cooperates, but cannot meet the 15-day or 30-day deadline due to a third-party delay, the CAO must continue assistance. Allow more time for the evidence to be provided. Review cooperation and the person’s progress on getting documentation every 30 days.
If the person does not cooperate and does not provide verification, the CAO must do the following:
Provide the budget group with an Advance Notice advising of ineligibility and what is needed to establish eligibility.
NOTE: The CAO must not use an Advance Notice to make an initial request for verification. Use the Advance Notice only after the person has not complied with a verification requirement.
If the person does not provide the proof within the time frame on the Advance Notice and does not file a timely appeal, close the cash budget effective with the first payment day following timely notice.
The CAO must verify conditions of eligibility, need, income, and resource items when there is a change that affects eligibility.
When a change other than an income change is reported, the CAO must do the following:
Determine if verification is necessary, and tell the recipient what verification is needed.
NOTE: A face-to-face meeting is not required.
Complete a partial renewal of the budget group’s continued eligibility within 10 calendar days of the report.
When the reported change is an increase or decrease in income, the CAO must do the following:
Request verification.
Make a plan with the person to provide the requested verification within 10 days of the report or within 10 days of the receipt of the income, if the report is made before the receipt of the increased or decreased income.
55 Pa. Code § 133.23(b)(3) 55 Pa. Code § 133.23(b)(4)
If the person does not verify the change within the 10 day period, the CAO may increase or decrease the cash benefit. Use a best estimate of ongoing income based on the information provided by the recipient after proper notice under the following conditions:
Verification is not immediately available.
The facts given by the recipient are consistent and reasonable.
The change in the payment was approved by a supervisor before data entry.
There is a plan made with the recipient to give verification of the change no later than 15 working days following the effective date of the change to the assistance benefit. Close the cash budget with proper notice if the recipient does not give verification and does not claim good cause for not complying.
If the CAO determines that the above conditions do not apply, the CAO must serve proper notice to close the cash budget. If the household submits needed verification within 60 days following the benefits closure, TANF may be reopened without a new application. See [Section 179.2].
Example: Ms. Parris receives Cash Assistance for herself and her three children. On October 5, she reported to the CAO that her hours increased in September and her gross monthly income increased by more than $100. She also reported that the increase in hours will continue. The CAO asks Ms. Parris to provide verification of the change by October 15 or to contact the CAO if she cannot.
If Ms. Parris provides verification of the change in income by October 15, the CAO decreases her cash grant after proper notice.
If Ms. Parris does not provide verification of the change and does not contact the CAO to explain why she did not comply, then the CAO discontinues the cash grant after proper notice.
If Ms. Parris contacts the CAO and claims good cause for not complying, usually because proof is not immediately available, the CAO develops a plan with Ms. Parris to provide verification within 15 working days after the effective date of the decrease. The CAO changes the benefit amount, with supervisory approval and after proper notice, using information from Ms. Parris to determine a best estimate of continuing income.
If Ms. Parris fails to provide the necessary information in the established 15-day time period, the CAO discontinues the cash benefit with proper notice.
If Ms. Parris submits verification of the change within 60 days after cash closes, TANF may be reopened without a new application. See [Section 179.2].
When a person asks the CAO to close his or her budget, the CAO must determine the reason for the closing. If the closing is due to receipt of income from employment, support, or another source, the CAO must verify the date received and the gross amount. Note in the record if the reason for the closing is unknown or unverified. If the person reapplies, verify the information that was unknown at the prior closing. Also verify the current status of any resources that were available at closing.
The CAO must act on all reported address changes but must verify address only at application, renewal, and SAR review, unless the address change is questionable.
An applicant or recipient who files a timely appeal of an adverse action may submit new or additional evidence of eligibility at any time up to and including the fair hearing. The appellant is entitled to receive retroactive benefits if he or she provides information establishing that he or she was eligible for a cash payment.
55 Pa. Code § 275.4(a)(3)(v)(B)(I)
The appellant does not need to show that the CAO made a mistake in acting to terminate, deny, reduce, or suspend benefits.
When the appellant provides verification of eligibility, the CAO must do the following:
Determine if the appellant has provided acceptable verification of the eligibility factor at issue in the appeal.
Determine the date the eligibility factor at issue in the appeal was met.
If verification shows that the appellant met the eligibility factor on the date of the denial notice or on the effective date of the adverse action, restore benefits retroactive to the date of termination, denial, reduction or suspension, as long as all other eligibility factors are met.
If the verification establishes eligibility at a later date, restore benefits retroactive to the date the eligibility factor was met, as long as all other eligibility factors are met.
Examples:
Mr. Smith applied for benefits on February 2, but was unable to verify that the market value of his second car was less than the book value. Mr. Smith's total resources were more than the resource limit. On February 10, the CAO issues a notice denying Mr. Smith's application.
NOTE: The full value of Mr. Smith's first vehicle is exempt from consideration as a resource.
On February 28, Mr. Smith files a timely appeal. Before the hearing, he gives the CAO a statement from a mechanic showing that his car was worth only $200 when the mechanic saw it on February 1. The value of his countable resources is now less than the limit. The CAO authorizes assistance retroactive to February 10 if Mr. Smith meets all other eligibility conditions.
NOTE: If the statement said the mechanic saw the car on February 27, the CAO would authorize assistance retroactive to February 27, the date Mr. Smith first met the eligibility condition at issue in the appeal.
On January 3, Mrs. Jones did not attend a scheduled renewal interview. On January 5, the CAO provided her with an Advance Notice explaining that benefits will end effective January 20. On January 25, Mrs. Jones filed a timely appeal. On February 1, before the hearing, she completes the renewal and provides all required information to establish continued eligibility. The CAO takes back its January 5 termination notice and restores benefits retroactive to January 20.
Updated July 26, 2018; Replacing January 25, 2017