MANAGEMENT EVALUATION REVIEWS Waves of Change BPRO May

MANAGEMENT EVALUATION REVIEWS Waves of Change BPRO May 2017

PURPOSE OF ME REVIEWS The purpose of the ME review is to ensure that the SNAP program is operated in compliance with federal regulations and policy. Ride the waves!

DOCUMENTATION When time constraints are placed on a job, one of the first things that goes out the door is documentation - which results in poor communication. Gnarly documentation is when someone else finds the information complete and specific enough to come to the same conclusion as you did. It answers the ‘who, what, where, when, and why’ certain information was used or disregarded in evaluating eligibility.

Expedited 10 cases INITIAL APPLICATIONS 30 day – 10 cases Extend Pend – 10 cases

EXPEDITED & 30 DAY APPLICATIONS ELEMENTS OF REVIEW ü Is the application date correct? Ø The actual date of application is matched against the application date in Va. CMS. ü Was the application screened timely? Ø The agency should screen applications for expedited entitlement while the applicants are present in the agency whenever possible. If the applicant is not present in the agency, agency staff must review the application on the day of receipt to determine the entitlement to expedited service processing. (Part II. B. 2) ü Was the application correctly processed as expedited/nonexpedited? Ø Determine whether or not the case was correctly identified during the screening process as eligible for expedited or non-expedited processing. ü Was the interview scheduled timely? Ø The agency is required to schedule an interview within 7 days for expedited applications and 20 days for non-expedited applications (Part II. D. )

EXPEDITED & 30 DAY APPLICATIONS (CONTINUED) ü Was the household given a verification checklist and, if so, was the household given at least 10 days to provide the verification(s)(Part II. D)? Ø Requested verifications are evaluated to ensure that the requests were not excessive. ü Was application approved timely? Ø Expedited applications must be processed within 7 days of the date of application (or date of discovery) (Part V. C) and non-expedited applications must be processed within 30 days of the date of application (Part II. E). ü Was the notice of action sent timely? Ø The Notice of Action must be sent within 7 days of the date of application (or date of discovery) for expedited applications and within 30 days of the date of application for non-expedited applications. ü Were benefits issued timely? Ø Determine the date the benefits were available to the client. Expedited benefits should be available to the client by day 7 (Part V. C); nonexpedited benefits by day 30 (Part II. E).

EXTEND PEND (EOO) APPLICATIONS ELEMENTS OF REVIEW ü Is the application date correct? ü Was the application screened timely? ü Was the application correctly processed as non-expedited? ü Was the interview scheduled timely? ü Was the household given a verification checklist and, if so , were all requested verifications required? Ø Since the application has been extend pended, the agency must have required further verifications in order to determine eligibility. If there is no evidence that a checklist was provided to the client, the case is incorrect. Ø The reviewer evaluates the verifications requested to ensure the requests are not excessive. If the verifications requested were not required and the client lost benefits for the month of application, the case is incorrect.

EXTEND PEND (EOO) APPLICATIONS (CONTINUED) ü Was the household given at least 10 days to provide the verification(s)? ü Was the application extend pended in a timely manner? Ø Applications must be extend pended on the 30 th day unless the 30 th day falls on a holiday or weekend and then the application must be extend pended on the next business day (Part II. F. 2). ü Is the effective date for the benefits correct? Ø Benefits for the second month of the application period should be prorated from the date the last verification was received (Part II. F. 2). ü Was the notice of action sent timely? Ø The Notice of Action must be sent within 60 days of the date of application. ü Were benefits issued timely? Ø Determine the date the benefits were available to the client; benefits should be available to the client by the 60 th day.

OTHER INFORMATION REVIEWED ü Applications are reviewed to ensure compliance with voter registration requirements. If the client indicates on the application that they would like to apply to register to vote, the agency must document that voter registration was addressed. ü Reviewer searches the case record for evidence that a SVES and e. DRS inquiry were completed at application. Ø The local agency must verify the Social Security number (SSN) of all household members reported by the household by submitting them to the Social Security Administration (SSA) through SVES (Part III. A. 1. i). Ø e. DRS inquiry must be made before the approval of an application and when new adult members are added to the SNAP household during the certification period (Part III. F. 1).

TSUNAMIS AT INITIAL APPLICATION When screening for expedited services, agencies are not using the information that works to the customer’s advantage – SUA or actual. Ø An application was screened as non-expedited based on the client’s statement that she pays $70 for utilities and on the application she stated she pays for heat and air conditioning. The utility standard should have been used in the screening instead of the $70. The shelter expenses would have exceeded income and the liquid resources which would have made the application eligible for expedited benefits. Ø One customer stated on her application that she paid $1464 in utilities. The agency screened the application allowing the SUA which resulted in a nonexpedited determination. For this situation, the agency should use the higher utility amount. The amount is questionable but the agency would schedule an expedited appointment and make an adjustment after the interview if necessary. Or the agency could call the client in order to complete the screening process.

MORE TSUNAMIS Change in circumstances from application to interview to eligibility determination – when, how, what? Nothing is documented. Must know how the EW got from there to here. Ø Application states $2000 in resources. Va. CMS shows $793 in resources. Ø Application indicates $550 in rent; no rent in Va. CMS. Ø Application states client pays $150 for utilities and no other household members mentioned on application. Va. CMS indicates client is receiving ½ of the SUA. Ø Support income listed on the application but no support income was counted.

TSUNAMIS (CONTINUED) Verification of medical expenses over $35. 00 in order to give standard medical deduction. Notice in Va. CMS suppressed and no copy of notice in case record or DMIS so it appears no notice was sent. No documentation that SVES or e. DRS inquiry was completed. Applications not screened on the day received. Interviews not scheduled timely. Appointment letter did not allow two mailing days prior to the date of the appointment (mailed 11/29; interview scheduled for 11/30).

TSUNAMIS PLUS SOME Applications not processed timely Ø Interview held on 7 th day and worker had ID. Application not processed until next day. Several applications – reviewer could not follow income determination Ø Copies of pay stubs in the case record but not used in income evaluation. Entering income into Va. CMS Ø Income not within projection period Ø Begin and End dates Ø Net income vs. gross income Ø Using pays that are not reflective in ongoing evaluation Ø Unearned income – changes to Social Security Income Ø Vacation pay, sick pay, holiday pay

HELPFUL INFORMATION If the reviewer notes any practices or procedures that appear to be out of compliance with SNAP guidance or policy, but that are outside the scope of the review, the reviewer will document what was observed and bring it to the agency’s attention. Dings (crack, hole, or fracture) in our surfboard!

NOTABLE DINGS Verifications need to be date stamped. Missing applications Cannot accept client statement for residence verification. Requesting excessive verifications with no documentation to explain why the customer’s statement was not accepted. Ø Shelter Ø Separate Household Status Ø Verification of address for a PA household Ø Daycare expenses Verify termination of income if it has occurred within 60 days of application. Verify benefits received from another state have stopped Calculation of child support income Ø Using a partial month as part of the income average

QUESTIONS?

Recertification completed – 10 cases RECERTIFICATIONS Did not recertify – 10 cases

RECERTIFICATIONS ELEMENTS OF REVIEW ü Was the Notice of Expiration mailed in a timely manner? Ø Households must receive the NOE no later than the last day of the next to the last month of the current certification period and no earlier than the first day of the next to the last month of the current certification period. Allow two days for delivery in addition to the postmark date (Part IV. C. 1). ü Was the interview scheduled timely? Ø The agency must schedule interviews to allow households sufficient time (at least 10 days) to provide necessary verifications to protect the household’s right to uninterrupted benefits (Part IV. C. 3). ü Was a NOMI sent if the client filed an application and missed the scheduled interview (Part IV. C. 3 & 6)? ü If applicable, was the household given a timely Verification Checklist? Ø The agency must allow households sufficient time (at least 10 days) to provide necessary verifications to protect the household’s right to uninterrupted benefits (Part IV. C. 4).

RECERTIFICATIONS (CONTINUED) ü Was the client assessed for entitlement to expedited processing if they filed a recertification application during the month after the certification period expired (Part V. A)? ü Was approval completed in a timely manner? Ø Applications filed timely (before 15 t h and client finishes necessary processing steps in a timely manner) should be processed prior to the end of the current certification period. Ø Applications filed untimely (after 15 t h ) or the household fails to complete any other portion of the recertification process timely, then the application must be processed by the 30 t h day after the filing date as long as the client has been given at least 10 days to provide verifications. Ø Applications filed early (month prior to end of current certification period), application must be processed prior to the end of the current certification period (will be more than 30 days). ü Was the notice of action sent timely ? Ø The local agency must provide households that have filed an application by the 15 th of the last month of their certification period with a Notice of Action by the end of the current certification period (Part II. I. 2 & Part IV. C. 5. a).

HOUSEHOLDS NOT RECERTIFIED ELEMENTS OF REVIEW ü Was the Notice of Expiration mailed in a timely manner? ü Is there evidence in the case record that a recertification application was received? Pearlings (surfboard nose dive) – ü Applications filed in the last month of the certification period or the month following the last month of the certification period were not pended; therefore, the system closed them as a “C 19” – did not recertify. ü Notice of Expirations not in the file.

PEARLINGS RECERTIFICATIONS ü Missed Interview Notice (MIN) was not sent for the scheduled interview missed on 12/15/16. The renewal application was received on 12/12/16. ü Notice of Expiration not mailed timely. ü No valid renewal filed. The renewal form submitted was not signed by the customer. The form was completed/signed by a friend who was not an authorized representative (there was no authorized representative for the case).

QUESTIONS?

TERMINATIONS 20 cases

TERMINATIONS ELEMENTS OF REVIEW Reviewer begins by researching the case to determine the date the change was reported or known to the agency and what type of change was reported. ü If applicable, did the local agency give the household a verification checklist? Ø The agency must allow households sufficient time (at least 10 days) to provide necessary verifications (Part XIV. A. 2). Ø The reviewer evaluates the verifications requested to ensure the requests were not excessive. ü Was the reason for the termination stated correctly on the notice? Ø Per USDA, if multiple reasons are listed, all must be correct.

TERMINATIONS (CONTINUED) ü Was the notice sent timely? Ø The household must receive written notice prior to any action to terminate benefits within the certification period. The advance notice period is 10 days and begins with the day following the date the notice is given or mailed to the household (Part XIV. D). ü Was the termination effective within the state’s timeframes? Ø 10 – 10 Agency has 10 days to act on a change, must give household 10 days to provide verification (if required), and must give household 10 days notice prior to termination (Part XIV. A. 2). ü Is the reason for the termination correct? Ø If the correct reason is not chosen when running eligibility, then the denial reason will not be correct and the notice will not be correct.

RIP CURRENTS TERMINATIONS § Agency failed to send a Notice of Action to terminate case for failure to complete an interview at renewal. § Changes/Terminations not processed timely Ø Recertifications not processed timely Ø Expedited applications with postponed verifications § Reason for termination incorrect (this results in incorrect notice also) Ø Terminated because net income exceeds limit but income entered into Va. CMS was incorrect. Ø Terminated because net income exceeds limit but household indicated there was a daycare expense which was not being allowed. With daycare deduction, household would not be over net income. Ø Benefits terminated no IR received but IR and all requested verifications were received before cut off. Ø Terminated for failure to provide verifications but no evidence that verifications were ever requested.

MORE RIP CURRENTS Excessive verifications requested Ø Agency requested notarized statement from landlord verifying how client paid shelter. Landlord provided statement that client works for him in exchange for shelter. Worker wrote on the note “not acceptable” and terminated benefits. Why? Ø Vendor payment statement from grandparents Ø Agency requested verification of unemployment income reported on IR when verification was available through VEC systems inquiry. (Copy in file indicates Active claim but agency failed to drill down to obtain verification of amount. ) § Several cases were questionable because the information indicated on the application was not reflected in Va. CMS and there was no documentation as to where the new or different information came from.

RIP CURRENTS CONTINUED § Documentation incomplete regarding how death was reported and verified. SOLQ/SVES is not sufficient verification. Independent/secondary verification is required. § Benefits terminated for no IR. No IR-Request for Action found in the case record or DMIS or IR-Request for Action not mailed timely. § Benefits terminated for no IR but IR in case record and received timely by agency.

DINGS There were several cases where the ME Reviewer’s evaluation of income did not match the income evaluation completed by the worker. It is possible that what the worker did was correct; however, without being able to replicate the evaluation, the ME Reviewer is required to correct the income calculation. Information in system does not match customer’s statement on application and there is no documentation to explain discrepancies. GNARLY DOCUMENTATION - When someone else finds the information complete and specific enough to come to the same conclusion as you did.

QUESTIONS?

DENIALS 20 cases

DENIALS ELEMENTS OF REVIEW ü Was the application screened timely? Ø The agency should screen for expedited entitlement while applicants are present in the agency when possible. If the applicant is not present in the agency, agency staff must review the application on the day of receipt to determine the entitlement to expedited service processing. (Part II. B. 2) ü Is the application expedited or not expedited? Ø Reviewer evaluates to see if the determination made by the agency was correct or not as this will determine the timeframe for processing the application. ü Was the interview scheduled timely? Ø Agency is required to schedule an interview within 7 days for expedited applications and 20 days for non-expedited applications (Part II. D) ü Did the local agency give the household a verification checklist, if applicable? ü Were all requested verifications required? Ø Reviewer evaluates the verifications requested to ensure the requests were not excessive. If the verifications requested were not required and the client was denied benefits for failure to provide the requested verification, the case is incorrect.

DENIALS (CONTINUED) ü Was the household given at least 10 days to provide verification? ü Was the action to deny taken timely? Ø The agency must send the denial notice as soon as possible, but not later than 30 days following the application date. (Part II. 2. E. 2) Ø Application must be extend pended on the 30 th day unless the 30 th day falls on a holiday or weekend and then the application must be extend pended on the next business day (Part II. F. 2). ü Was the notice accurate and timely (including EOO)? Ø Per USDA, all information given to the client on the notice must be correct (to include multiple denial reasons). ü Is the reason for the denial correct? Ø If the correct reason is not indicated when running eligibility, then the denial reason will not be correct and the notice will not be correct.

RECENT WIPEOUTS DENIALS Notice of Action not mailed for missed interview. Applications not screened timely Ø Action to extend pend was not taken on day 30 which also means notice was mailed timely. Incorrect denial reason (which makes the notice incorrect) Ø Application was denied excess net income. However, application indicated that the client had medical and shelter expenses, neither of which were evaluated as deductions. Ø Application denied for no interview because interview date was never entered into Va. CMS. Ø Application denied excess income. Application indicated zero income for month of application and SOLQ in file verified non-payment of SSA for month of application. No other income.

DINGS There were several cases where the ME Reviewer’s evaluation of income did not match the income evaluation completed by the worker. It is possible that what the worker did was correct; however, without adequate documentation and not being able to replicate the evaluation, the ME Reviewer is required to correct the income calculation based on the available information. SVES inquiry indicated possibility that client was entitled to dual enrollment (additional payment) but case record did not show evidence that EW completed a separate inquiry to verify possibility of additional income. Change in circumstances from application to interview to eligibility determination – when, how, what? Nothing is documented. Must know how the EW got from there to here. Ø Application stated rent would start in January but EW entered in Va. CMS for November.

DINGS (CONTINUED) § For applications filed by persons who claim that they have received SNAP benefits in another state, the agency must confirm that the individual is no longer receiving benefits in that state. Ø If the agency is not able to verify this by the end of the processing period and all other eligibility factors have been met, the agency must approve the application. The agency must continue to seek verification from the other state to minimize the overpayment period in case the individual continued to receive benefits in that state. Ø If duplicate participation occurs, the Virginia agency must file a claim for any benefits the household received while it also received benefits from the other state (Part II. E. 3). Excessive Verifications Ø Requested income, ID, SSN, and DOB for person not included in SNAP household on application

MORE DINGS When an application is denied for failure to provide verification, and partial verifications were provided, the agency is to inform the client on the denial notice what verification is still missing. An application was evaluated as non-expedited with a note indicating “incomplete income information. ” The application indicated no resources, no income, and no shelter. The initial screening should have been based on information available on the application and should have been screened as expedited with an interview scheduled within 7 days. Income figures entered incorrectly

WHAT IS GNARLY DOCUMENTATION? When someone else finds the information complete and specific enough to come to the same conclusion as you did.

QUESTIONS?

ABAWD CLOCKS Initial Applications – all 30 cases Recertifications – all 10 cases

ABAWD CLOCKS ELEMENTS OF REVIEW ü If th ere is any indication that the ABAWD participated in another state, was the part icipation evaluate d corr ectly? Ø The agency must address participation in another state towards the number of countable months if there is any indication from the application or interview that the member may have received SNAP benefits during the current 36 -month period (Part II. E. 3). ü Was t he start date of the ABAWD clock correct? Ø The 36 -month period is a fixed period from the first of the month in which a household is certified in Virginia (Part XV. A). ü Were clo ck s prope rly code d for each month for each participating ABAWD? Ø Any month in which an affected individual receives the full benefit month as part of a certified household will count toward the three-month limit. Ø Months in which a household receives prorated benefits will not count toward the three -month limit (Part XV. A). Ø Reviewer evaluates exemption codes to ensure they are correct. ü Is th e ce rtification pe riod cor rect as it applies to ABAWD po li cy? Ø Households in which any member is eligible for time-limited benefits may receive benefits for no more than four months. Benefits for the certification period will be allowed as one month of prorated benefits, if appropriate, and up to three countable months of time-limited benefits (Part IV. A. 2).

ABAWD TSUNAMIS The start date of the ABAWD clock incorrect. Ø Va. CMS clock started 12/2016. However, the customer had received benefits in ADAPT starting in 10/2015. The clock from ADAPT should have been brought over to Va. CMS. Ø The ABAWD clock started 12/2016; however, ABAWD turned 18 years old in December 2015. The ABAWD clock should start the first month after 18 th birthday (1/2016). Va. CMS should fix the problem of start dates being incorrect for individuals where initial eligibility is determined in Va. CMS.

ABAWD TSUNAMIS (CONTINUED) Clocks are brought over from ADAPT but the ADAPT clock is incorrect. Ø ADAPT clock started 4/2014 but client received benefits in 10/2013. Ø Benefits issued for 12/2016 but the clock was not started until 1/2017. Ø The clock started 4/2016. Application was denied. Client reapplied and first month of benefits was 10/2016. ABAWD clock started 4/2016 but should have started 10/2016. Ø The ABAWD clock started 9/2016 but there was no evidence that the client was receiving benefits at that time. Benefits began 11/2016. Ø The ABAWD clock expired 9/2016. When the client recertified, a new clock was not started. Ø The ABAWD clock did not start with the prorated month; the clock started with the first month the client received full benefits.

ABAWD DINGS If an ABAWD clock exists in ADAPT, it must be brought over into Va. CMS. Before adding a clock from ADAPT, always verify that the start date is correct. This includes searching the client’s SSN to verify if they received benefits on another case. When evaluating converted cases for the first time, always verify the start date that crossed over from ADAPT is correct. § Documenting specific information for each client and their clock will help someone else come to the same conclusion as you. (Ex: Why are they exempt? What happened to their exemption? )

QUESTIONS?

ARE WE DONE YET?

ADDITIONAL AREAS REVIEWED Claims Ø Established timely Ø Backlog of no more than 10% (LDSS has sufficient documentation to establish a claim but has failed to do so). Ø Sufficient documentation to support the claim Ø QC claims have been established Ø Claims are terminated in accordance with regulatory requirements. Electronic Benefits Transfer Ø Separation of Duties Ø Security of vault cards Ø Customer Training

ADDITIONAL AREAS REVIEWED (CONTINUED) Customer Service Ø Lobby Observation Ø Blind Testing Ø Two client contacts Civil Rights Ø Have all staff completed the yearly Civil Rights training? Ø Two Community Organization contacts Ø Appropriate signage in the lobby Ø Services for Non-English Customers Ø Services for Hearing Impaired Customers Ø Case Management – Does the reviewer see any signs of discrimination in the following areas: 1. Treatment of customers when they arrive at the agency. 2. How cases are assigned to workers 3. Documentation in case records

QUESTIONS?

ME REVIEW SCHEDULE Remaining Middlesex Goochland Richmond County Scott Amherst Franklin Nelson Fredericksburg City Page FY 2017 Bristol Lynchburg City Madison Petersburg City Craig Clarke Smyth Campbell Hampton

ME REVIEW SCHEDULE Fiscal Year Caroline Buchanan Gloucester Fauquier Henrico Wise Henry/Martinsville King George Washington Albemarle Portsmouth Fluvanna Bath Matthews Harrisonburg/Rockingham King & Queen Wythe Rockbridge/Buena Vista/Lexington Accomack King William Roanoke County Charlotte Suffolk 2018 Lunenburg Pulaski Sussex Warren Southampton Prince George Surry Rappahannock Richmond City Patrick Bedford Norfolk Nottoway Grayson Roanoke City Orange Russell Mecklenburg Chesapeake Culpeper Powhatan Lee Virginia Beach

NOW WE ARE DONE!!!