January Recertification for extended SNAP (FS43) and SNAP Mass OTI's for February Benefits, PFS19267568 (Published February 21, 2019)
The CAO must follow these steps to figure out a household's eligibility for SNAP benefits:
7 CFR § 273.10(a)(1) & 7 CFR § 273.21(a)(2)
Determine the household’s eligibility to participate.
Determine the benefit amount for eligible households.
The CAO must always determine eligibility using prospective budgeting (PB) to get the benefit amount. (See Chapter 567.)
55 Pa. Code § 501.11(a)
There are three questions asked to determine eligibility:
Does the household meet all of the nonfinancial and resource criteria?
Is the total gross income equal to or less than the gross income limit in Chapter 568, Appendix A? (This applies to all households except categorically eligible households and households with elderly or disabled members.)
7 CFR § 273.9(a)(1)
Is the net income, after all deductions, equal to or less than the net limit in Chapter 568, Appendix A? (This applies to all households except categorically eligible households.)
7 CFR § 273.9(a)(2)
The CAO must complete the prospective determination of eligibility to participate at the following times:
55 Pa. Code § 501.11(a)
At initial application
At the six-month SAR review
At each renewal
When there is a change in household circumstances that may affect eligibility
If a household is eligible to participate, the CAO must prospectively determine the benefit amount for the issuance month.
55 Pa. Code § 501.11(d)
For PB, the CAO must use anticipated income, expenses, and circumstances for the issuance month to determine eligibility and the benefit amount for the issuance month.
7 CFR § 273.10(a)(1)(ii) & 7 CFR § 273.21(g)(2)
When calculating income, the CAO must round down each monthly income or deduction calculation ending in 1 to 49 cents and round up calculations ending in 50 to 99 cents.
55 Pa. Code § 501.9(c)
The net income determines the benefit amount according to the basis of issuance tables (see Chapter 568, Appendix B)
NOTE: SNAP households with three or more members may be entitled to benefits of at least $2. If the computation results in a benefit of $1, $3, or $5, round it up to $2, $4, or $6, respectively.
.7 CFR § 273.10(e)(2)(ii)
A categorically eligible SNAP household does not have to meet the gross or net income limits. (See Chapter 512.)
7 CFR § 273.2(j)(2)
The CAO must use the following rules to figure out the benefit amount:
A one-person or two-person categorically eligible household must always receive at least a $23 benefit, regardless of how high the net income is for the household.
7 CFR § 273.10(e)(2)(ii)(C)
55 Pa. Code § 501.9(b)
A categorically eligible household of three or more persons must receive the benefit listed for the net income according to the basis-of-issuance tables (see Chapter 568, Appendix B).
7 CFR § 273.10(e)(2)(iii)(A)
Some categorically eligible households of three or more persons may not receive a payment even when they entitled to benefits.
Because there is no minimum benefit for households of three or more, some categorically eligible households of three or more members may not receive a SNAP benefit, even when they are eligible on the basis of income.
The SNAP benefit may not be increased if a household member fails to comply with any federal or state welfare program requirement and the noncompliance reduces, suspends, or terminates the welfare program benefits. This is called the Riverside Rule.
7 CFR § 273.11(k)
The rule applies only to SNAP recipients who also receive a cash benefit from a federal or state welfare program based on financial need, such as TANF or GA.
NOTE: The Riverside Rule does not apply when the Work Support Component (WSC) cash assistance closes for failure to keep an appointment with the contractor. The rule also does not apply when an applicant refuses to sign the WSC AMR.
If a WSC recipient is sanctioned for noncompliance with WSC requirements, the CAO must change the program status code from WSC to TANF before changing the sanctioned person's status in eCIS to DS (disqualified specified relative). Then the rule applies.
The CAO must base the benefit on the income that would have been continued if there had not been noncompliance.
A four-person cash assistance/SNAP household does not comply with support requirements. For cash assistance, the CAO removes the parent from benefits and reduces the cash benefit by at least 25%. For the SNAP benefit, the CAO bases the income on the family size allowance (FSA) for four persons and a four-person SNAP household size. The CAO applies the support requirements to the cash assistance program only.
An SSI parent in a cash assistance/SNAP household does not comply with support requirements. The CAO reduces the cash assistance grant by at least 25%. The CAO closes the cash assistance case, because the support being paid is higher than the reduced cash assistance grant. The CAO computes SNAP benefits using the same income the household received before the TANF support sanction. The CAO does not include the current support being paid, because the cash assistance grant is being counted.
A parent in a cash assistance/SNAP case fails to comply with support requirements and is removed from the cash assistance grant. When the cash assistance/SNAP benefits end, the household applies at another district’s CAO office. The parent still refuses to cooperate with support requirements. The CAO applies the Riverside Rule, because the person was receiving assistance at the time of the violation and the reduction, suspension, or termination. The SNAP penalty continues for the period of the cash assistance program sanction. This also applies to intercounty transfers.
If a person fails to comply with a SNAP requirement, the SNAP penalty also applies.
The head of a four-person cash assistance/SNAP household refuses to provide or apply for a Social Security number for a minor household member. The CAO removes the minor member from the cash assistance and SNAP benefits and reduces the cash assistance benefit to a three-person FSA. The SNAP benefit is based on the income on a four-person FSA and a three-person SNAP household size.
A mother with two children under 18 quits her job without good cause. She is a mandatory participant for the cash assistance and SNAP employment and training (E&T) programs. This is her second violation. She is removed from the cash assistance benefit for at least 60 days and from the SNAP benefit for three months. The CAO bases the SNAP benefit on the presanction earned and unearned income for two persons for two months. For the third month, it bases the SNAP benefit on actual earned and unearned income for two persons.
NOTE: The SNAP E&T provisions take precedence, because the sanction period for a second violation under SNAP is longer than the second violation sanction period under the cash assistance rules. (See Section 535.53.) This example shows the minimum disqualification period for breaking this rule.
If the household is sanctioned under the E&T provisions or any program requirement applicable to both the cash assistance and SNAP programs, there must be an individual assessment to decide whether the penalty applies to both programs.
Example: A mother with two children, ages 10 and 13, refuses to attend required orientation sessions. She is a mandatory enrollee for cash assistance and SNAP and is removed from the cash assistance and SNAP benefits. The SNAP benefit is based on the FSA for three and a two-person benefit.
If there are changes in the household not related to noncompliance, such as a decrease or increase to income or household size, the CAO must take the appropriate action but continue the penalty for noncompliance.
7 CFR § 273.11(k)
A four-person household receiving a three-person FSA because of noncompliance reports wages from part-time employment and reports that a minor child has returned from foster care custody. The cash assistance benefit is the FSA for a four-person household with adjusted income. The SNAP benefit is based on the income on a five-person FSA with adjusted income, the wages, and a four-person SNAP household size.
A mother receives TANF for her four children. She is under an E&T sanction for a minimum of 60 days and receives a three-person FSA. During the sanction period she reports that she is working 10 hours a week and that her son, Max, is out of foster care and living with her. The CAO adds Max to the cash assistance grant and adjusts her income from employment. The SNAP benefit is based on a five-person FSA (with adjusted wage income) and a four-person SNAP household.
If the reason for noncompliance is settled under the federal or State welfare program, the CAO must lift the ban on increasing SNAP benefits. If the person becomes ineligible for cash assistance during the period of sanction for some other reason or the person’s cash assistance case is closed, the CAO must also lift the ban on increasing SNAP benefits. However, if the household voluntarily requests the closing of the cash assistance benefit, the penalty is continued on the SNAP benefit for as long as the penalty for noncompliance would have continued under the cash assistance program.
A two-person household has not complied with the time requirement for adding a newborn to the grant. The newborn is removed from the cash assistance benefit. The mother is not eligible for cash assistance, because there are no other children and she failed to comply with the cash assistance program requirements. For SNAP, the CAO bases the income on a two-person FSA and a two-person SNAP household size. The CAO continues the case until the renewal date initially established under the cash assistance program requirements. At renewal, if cash assistance is not authorized and there is no other income, the CAO reviews the SNAP household as a two-person household with no income.
A mother receives TANF for herself and a newborn daughter. She does not give the CAO information necessary to verify the eligibility of her daughter within the grace period. The CAO closes the TANF case, because the newborn is ineligible for continued cash assistance and there are no other dependent children. The SNAP benefit is based on a two-person FSA and a two-person SNAP household. The penalty continues until the renewal date first established under the cash assistance program. If cash assistance is not authorized and there is no other income, the SNAP household is reviewed as a two-person household with no income.
Updated November 3, 2022, replacing September 8, 2022