Work Registration ABAWD the Upcoming 36 Month Fixed

Work Registration, ABAWD, & the Upcoming 36 Month Fixed Period

Objectives • Define and understand SNAP Work Registration • Learn how to properly code and update work registration and IMPACT (E&T) referral fields on AEIWP • Define and understand ABAWD • Understand the importance of explaining and offering the SNAP voluntary E&T program at each interview • Understand how an ABAWD can regain eligibility and the one time 3 month extension • Understand ABAWD Compliance tracking and manual changes to AEABA • Learn about the upcoming ABAWD 36 month fixed period

What is Work Registration? • Work registration means that a person is making themselves available for work and E&T because they are applying for or are receiving Supplemental Nutrition Assistance Program (SNAP) • SNAP Federal Regulation requires that work registration status is determined for ALL SNAP applicants and recipients • In Indiana, the person who signs the application is agreeing to the terms of work registration for all persons on the application

Indiana: Voluntary or Mandatory Work Registration State? Voluntary Work Registration • Only ABAWDs are referred to IMPACT • ABAWDs are allowed 3 non-compliant months prior to being discontinued (This is not a sanction) Mandatory Work Registration • All mandatory work registrants are referred to IMPACT • All mandatory work registrants would be sanctioned after 1 missed appointment Indiana is a voluntary WR State

Code 01 vs. Code 03 Code 01 Code 03 • 01 is a mandatory work registrant code. However, individuals are not referred to IMPACT • 03 Able-Bodied Adult Without Dependents (ABAWD) is a mandatory work registrant code. The individual is referred to IMPACT and is subject to time limited benefits

How to Code AEIWP • AEIWP is composed of a Work Registration (WR CODE) Code and a Referral code (REF CODE) • WR Code indicates the work registration status • REF Code indicates whether the client will be referred to IMPACT

What are the Work Registration Exemptions? 06 Child under age 16 11 Incapacitated 08 Age 16 or 17 and is not the AG payee, or is the AG payee and attends school or an E&T program at least half time 13 Needed to care for incapacitated individual (does not have to live in the home) 20 Referred to TANF IMPACT and no other exemptions apply 09 Student enrolled at least half time 15 Employed 30 hours per week OR earning the equivalent of 30 hours times the federal minimum wage (includes School Employee Under 10 Age 60 or older 18 Caretaker of a child under age 6 Contract –Migrant/Seasonal Farm Workers) 21 Receiving Unemployment 22 Participating in a drug/alcohol treatment program

Code 18 Reminders • Clients with dependent children under age 6 are exempt from SNAP WR • In a two parent case with a common child, only one parent may receive the code 18 designation for a common child • Dependent children’s age must be checked on AEIID prior to entering the 01 or 18 code for the parent • AEIID must be checked at each authorization if the 18 SNAP WR exemption code is on AEIWP to ensure there is still a child under age 6

IMPACT • IMPACT stands for “Indiana Manpower Placement and Comprehensive Training” and represents the State’s Employment and Training Program (E&T). IMPACT is the cooperative effort of the Family and Social Services Administration (FSSA), the Department of Workforce Development (DWD), the Department of Education (DOE), and various other service agencies that offer employment and training services for TANF and SNAP individuals • Services are designed to assist individuals in overcoming employment barriers due to poor education, absence of marketable skills, or lack of support services including transportation and clothing

Referrals to IMPACT The referral code on AEIWP indicates whether a person will be referred to Employment and Training (E&T/IMPACT) • The only individuals who are automatically referred to IMPACT are ABAWDs • NOTE: It is important to use the appropriate code as the referral code determines whether an IMPACT appointment will be scheduled for a SNAP recipient

How to Code ABAWD AEIWP ABAWDs should always be coded 03/03 on AEIWP

FS Referral Codes 00 -Exempt – FS no longer a mandatory program 03 -Mandatory ABAWD individual 16 -Exempt – Pregnant 3 rd Trimester 23 -Exempt – Does not have adequate transportation 24 -Exempt-Cost of participation exceeds reimbursement limit 25 -Exempt from WR but wants to volunteer for FS IMPACT

Codes 23 and 24 • IMPACT can request a 23 or 24 referral code be entered on AEIWP if they are unable to provide a level of supportive services that would allow the individual to participate in IMPACT services. This is rare and the request for these codes MUST come from the IMPACT provider through the regional e-mail box

• Mandatory Work Registrants MAY NOT: o Voluntarily quit a job without good cause o Voluntarily reduce work hours below 30 per week without good cause

SNAP Volunteer for E&T • Anyone who is a SNAP recipient may volunteer for E&T IMPACT services. When working with individuals who are unemployed, or under employed, encourage them to take advantage of IMPACT services regardless of their work registration status. Supportive services (i. e. transportation and clothing) are available to anyone who is volunteering for employment and training through SNAP, as well as the services that IMPACT provides to assist with employability This must be explained and offered

Referring a Volunteer

When to Check and Modify AEIWP Work Registration Codes Report of School Attendance AG Comp Employment Report of /Income Pregnancy Change Report of Disability/ Incapacity

ABAWD(s)

ABAWD Information Notify ABAWD individuals and explain time limited benefits, how to maintain eligibility, and how to regain eligibility if it is lost All ABAWDs are offered an opportunity to participate in a free employment and training program (IMPACT) which can assist them with becoming employed, improving current employment and maintaining eligibility for SNAP Individuals who choose not to participate in IMPACT may choose to find another employment and training program in the community, or become employed at a minimum of 80 hours per month to maintain compliance with ABAWD requirements

To Maintain Eligibility an ABAWD Must: • Work an average of 20 hours per week for a total of at least 80 hours per month; or • Participate in IMPACT (other approved community program) at a minimum of 20 hours per week; or • Combination of work hours and employment training program hours averaging 20 hours per week; or • Participate in Community Work Experience Program (CWEP) for the appropriate number of hours, based on the formula of allotment divided by Federal minimum wage ($192/7. 25=26), not an average of 20 hours per week

Time Limited Benefits • ABAWDs are limited to receiving 3 months of SNAP benefits within a fixed 36 month period unless they are complying with work requirements • Compliance verification is the responsibility of the client • Thirty-six month fixed clock ▫ Clock began July 1, 2015 ▫ Clock ends June 30, 2018 ▫ New period begins for all participants July 1, 2018 After 3 months of not meeting work requirements, clients become SNAP ineligible-this is not a sanction-and cannot be cured by contacting IMPACT

Mentally & Physically Fit For Employment Determining a client’s mental and physical fitness for work: • Staff observation-a state merit worker must make the final decision. This can be a referral from IMPACT for state worker to determine • Client provided documentation from a medical professional that verifies that they are unable to work • Client being verified as Medically Frail on AEHP 2 -for this to be valid, the medically frail determination must be current on AEHP 2: • Client must currently be on HIP and have a frail determination on AEHP 2 • AEHP 2 only displays when clients’ HIP is active • The “Frail” field does not verify that the client is medically frail. Look for a “Y” in the “SW” field to verify that the client has been determined to be medically frail. • Refer to: Flash Bulletin Medically Frail and IMPACT Status (09/09/2016) If the client is determined mentally or physically unfit for employment then AEIWP should be coded with “ 11”

Compliance Tracking

WR and Ref codes on AEIWP must be correct Do not change a ABAWD’s coding if they begin to work 80 hours per month ABAWDs can remain eligible indefinitely if compliant ICES tracks compliance via AEIWP, AEISE, AEIEI, and AEINC, and automatically updates AEABA AEIEI/AEISE must have the correct begin and end dates. If client fails to verify the end of employment, leave income in case and change hours to “ 1” Accurate hours must be entered on AEINC and AIESE. Do not record a flat 120 hours on AEISE Pending AEINC may cause ICES to populate AEABA with a “W”. Once income is verified (or not verified) check AEABA to see if corrections are necessary

Pending AEINC Scenario Client states working an average of 25 hrs per week. AEINC is pended for verification of income and hours. Verification is returned and indicates client is working an average of 18 hrs per week, AEINC is updated. However, because the previous pending information indicated that client was working more than the required 20 hrs average for a ABAWD, AEABA could have populated a “W” for the pending month. AEABA needs to be checked to make sure it updated correctly once the correct/verified hours were entered on AEINC for that particular month. If AEABA did not update correctly, then a manual update will need to be completed. Also check AEABA if client does not provide verifications as we need to make sure AEABA is keeping a correct record for client’s compliance and noncompliance months.

Coding on AEABA These codes are used on AEABA The Z should only be entered if instructed by the SNAP Policy Dept. The numbers of instances where the Z code was used must be counted and reported to FNS by SNAP Policy.

Coding on AEABA (cont) • If a code does not exist on AEABA for a given month, it is because the client was not coded as an ABAWD on AEIWP Remember on AEABA Never Enter a Code on months where there wasn’t one prior • When troubleshooting AEABA, check AEIWP history for that month to ensure client was coded as an ABAWD

Manual Changes to AEABA • Only a SEM can manually change AEABA • If a manual change to AEABA is requested by the IMPACT provider, it must be sent via email to the regional mailbox • If the client verifies compliance through work or IMPACT participation late in the month, a manual update to AEABA is required for that month • If client is within their 3 month eligibility period and verifies working an average of 80 hours per month for a previous month, then the month in question would need to be manually updated on AEABA

Manual Changes to AEABA (cont) SEMs are responsible for all manual changes. Each change must be thoroughly reviewed before implementation. ICES will not override a manual change. View history screens of AEIWP and AEABA to ensure accurate updates. NOTE: AEABA will not be changed due to client’s untimely report of incarceration during months they were considered to be non-compliant. It is the client’s obligation to report this change timely to prevent being coded as noncompliant for those months.

Regaining

Non-compliance • Non-compliant months do not have to be consecutive • Once client has 3 rd “M”, client will be scheduled for closure in a mass change run by ICES-reason code 826 • CSAH does not follow the client. When trying to determine if/when a client was scheduled for an IMPACT appointment, you must check all cases that the client has been in while coded as 03/ABAWD on AEIWP • They are NOT sanctioned and therefore cannot “cure” the sanction. They are ineligible until they a. ) regain eligibility or b. ) the 36 month period ends or c. ) they become exempt

How to Regain Eligibility? An ABAWD may regain eligibility after 3 months of non-compliance: • Client can become employed at 80 hours per month and remain employed and reapply. If client meets all eligibility requirements, they would be considered eligible. This eligibility lasts as long as client maintains employment of at least 80 hours in a 30 day period • A client who is involved in an approved employment and training program (NOT IMPACT) for at least 80 hours in a 30 day period and remains in the employment and training program, could be considered eligible upon reapplying • Client can become exempt from work registration (must be verified) • The 36 month fixed period can end a new one begins • Through a one time 3 month extension

How to Determine the One Time 3 Month Extension Client’s benefits were discontinued after 3 months of non-compliance Client has reapplied Client verifies employment that was at least 80 hours within a 30 day period while ineligible Client has lost employment Client is not subject to voluntary quit penalty

When To Consider a 3 Month Extension • A client is only denied with the 826 WORK REQUIREMENT NOT MET code one time • Any subsequent denial would be made with the 829 WORK REQUIREMENT NOT MET, 80 HRS IN 30 DAYS code. The 829 code prompts you to consider a 3 month extension – Ask the question: “Has the client worked 80 HRS IN 30 DAYS? ” If you answer yes, investigate further to determine 3 month extension eligibility. Thoroughly document CLRC with the results

If Eligible for One Time 3 Month Extension SEM Capability Only • The first Fail (F) month should be changed to an N – Do not change any other months (do not add W for month client worked) • Month of application would be prorated on AEABA if appropriate with a “P” • 3 consecutive months after pro-rated month would be manually coded “X” • “X” codes must always be coded as 3 consecutive months

Regaining Eligibility Through a Community Program Clients who are non-compliant with ABAWD requirements should NOT be referred to IMPACT • They can attempt to work with Division of Workforce Development, or another E&T community based program of their choice, but there is not a specific program to which we can refer them • Clients would be responsible for verifying hours of participation • The program details would need to be sent to SNAP Policy for approval

• The S 43 edit is built into AEABA as a reminder that an “active” code (C/W/P/J) requires that the previous F be changed to an “N”. ICES will then be able to enter another “F” if the client becomes non-compliant again

ABAWD Inquires About Closure • Client may call in and express desire to comply, or report that they are compliant • Client should be advised about how eligibility can be regained • If client questions why they are being closed, check AEABA for accuracy • If the client is reporting working during a previous period of eligibility, DO NOT change AEABA to reflect working and DO evaluate whether a benefit recovery referral is necessary • DO NOT refer to IMPACT. If a client calls in after receiving notice of discontinuance during 3 rd non-compliant month should not be referred to IMPACT. will not have time to become compliant mid way through the 3 rd month of non-compliance – If the client reports that they are working, verify employment through normal procedures

ABAWD Upcoming 36 Month Fixed Period

The 36 Month Fixed Period After the expiration of a fixed 36 month period, a previously non-compliant ABAWD regains eligibility The initial 36 month, fixed period will end on June 30, 2018 The new 36 month, fixed period will begin on July 1, 2018

36 Month Fixed Period Timeline Once the new ABAWD 36 month fixed period begins, NO changes should be made to AEABA months from July 1 st 2015 through June 30 th 2018 without consulting SNAP Policy

Change in the 36 Month Fixed Period • If an individual is an ineligible ABAWD within an open, eligible AG, they will become eligible again on July 1, 2018 – A process is being worked on with ICES to ensure this occurs and that these individuals are again referred to IMPACT

Scenario for Open AG with excluded ABAWD My sister and I are part of the same SNAP AG, however, my sister is now a excluded member due to not complying with ABAWD requirements and using her 3 noncompliance months. I remain eligible due to meeting the ABAWD compliance as I work 22 hours on average per week. Once the new 36 month fixed period starts on 7/1/2018, my sister will regain eligibility and receive 3 months of noncompliance without reapplying.

Compliance Tracking in the New 36 Month Fixed Period • Compliance tracking for ABAWDs begins again on July 1, 2018, which means that someone who already has 1, 2 or 3 non-compliant (M) months in June will begin their NEW 3 months in July and be offered another chance to comply with IMPACT – This means that some ABAWDs will receive up to 6 months of noncompliant eligibility in a row WITHOUT having benefits discontinued

Scenario for 6 Month Noncompliance Eligibility An ABAWD Whose noncompliance months run for April, May and June of 2018 Might not be discontinued They may receive their new 3 noncompliance months beginning the upcoming 36 month fixed period on 07/01/2018.

Compliance Tracking in the New 36 Month Fixed Period (cont) • “Unused” months of eligibility in the current (July 1, 2015 – June 30, 2018) 36 month period are NOT carried over into the next period – Every 36 month period allows for only 3 M’s – Individuals who have previously lost eligibility due to ABAWD non-compliance within the current 36 month period and who are NOT in an open AG, would begin the ABAWD time limits again when/if they reapply

Scenario for Closed AG for Non-Compliance Let’s use the previous example with my sister However, in this scenario, my sister and I had separate AG’s at the time she was closed for noncompliance Once the new 36 month fixed period begins on 07/01/18, my sister will need: To reapply Be referred to IMPACT if still an ABAWD Her ABAWD time limits will restart, can be noncompliant for 3 new months

Scenario for “Unused” Non. Compliance Months • Client has received 2 noncompliance months in the current 36 month fixed period, • The remaining “unused” noncompliant month will not be carried over to the new/upcoming 36 month fixed period beginning on 07/01/18. • Client will restart the new fixed period with a new opportunity for 3 non-compliance months. ABAWDs can only receive 3 noncompliance months (or 3 “M’s” on AEABA) in a 36 month fixed period. “Unused” Non. Compliant Month Carry Over

AEABA and the Prior 36 Month Fixed Period • Once the new ABAWD 36 month fixed period begins, NO changes should be made to AEABA months from July 1 st 2015 through June 30 th 2018 without consulting SNAP Policy

For more Information on Work Registration, ABAWD, and the Upcoming 36 Fixed Month Period please see Program Policy Manual passages beginning with PPM 2438. 00

Questions? Please contact: • Tammy Maples • Tammy. Maples@fssa. in. gov • 317 -234 -9504 Or • Suzanne Tryan • Suzanne. Tryan@fssa. in. gov • 317 -234 -8708