The proposal is to require 6 month renewal periods with every other certification requiring an interview; therefore the worker is having some degree of contact with every SNAP household every six months. So what is the objective and what purpose does it serve? Data collection would be on a different form that the client would need to complete from scratch (not a preprinted interim report form), and the collection of information and verifications would be more frequent for a lot of households, especially the elderly and disabled households. So we are virtually exchanging one form for another--the renewal form (more cumbersome) for the preprinted interim report form(less cumbersome) at the six-month interval.

Under "NEED" the intent of the action states: 1) the need for the LDSS to send an interim report form would be eliminated, 2) the need for the LDSS to evaluate completed reports would be eliminated and 3) the need for the LDSS to close cases due to the recipient's failure to return the completed report would be eliminated. First of all, currently the LDSS does not mail the interim, the VDSS sends the report; secondly, the LDSS would only exchange evaluation of the interim report for a more extensive and time-consuming evaluation of a renewal; and thirdly the LDSS does not take action to close a case if the interim report is not submitted, the system closes the case. The costs and time associated with mailing renewals would significantly increase for the LDSS.

Under "Substance" the action states: Eligibility workers must notify households if an interview will be conducted at the same time households are advised that the cert period will expire. This action creates more work on the worker to track, complete, and send interview notices. I think most staff would agree that the overall processing of a renewal is more extensive and more time-consuming than the processing of an interim report.

When nterim reports were initially created the intent was for the worker to complete a "quick" review of the case to ultimately evaluate any major changes without having to complete an extensive evaluation. I think for the most part that objective has been achieved; however, if that process stands to be complicated by more "simplified reporting" (as initially proposed and then retracted in October) then nothing is to be gained by its continuation. In this instance workers would be better off with one set of rules for the evaluation of renewals. If the use of interim reports continue, it is imperative that the workers have simple concrete rules to follow, and not a maze of flow charts just to make, what should be, a simple decision.

Also, it is important to note the increased workload that will result for those workers who process primarily elderly and disabled households. Currently the worker completes an annual interim report and a renewal at 24 months, mainly because those households have very few changes that  would warrant more frequent reviews. If the policy changes to require a renewal every six months for these types of cases, the administrative cost hardly justifies the outcome. The work required to maintain these types of cases double as they must be dealt with twice per year as opposed to once per year.

Please keep Interim Reports (as is) as a simple means to review currently eligible SNAP households and please do not do away with 24-month certifications for elderly and disabled households.

At a time when workers are overwhelmed with the volume of cases for multiple programs, they need basic clear-cut rules, in "black & white" to follow. That is the easiet and most simplistic way of applying policies, ensuring payment accuracy, and consistency across the board.

Thank you for the opportunity to comment.