12 MONTH CERTIFICATION PERIODS ARE TOO LONG WITHOUT AN INTERIM REPORTING OF AT LEAST 6 MONTHS, 3MONTHS WOULD BE MORE APPROPRIATE.  PEOPLE MOVE TOO MANY TIMES, MOVE PEOPLE IN AND OUT, START JOBS, STOP JOBS, DRAW UNEMPLOYMENT AND STOP DRAWING BEFORE BEING REVIEWED.  

THEY HAVE TOO MANY CHANGES TO WAIT 12 MONTHS.

NEED TO GO BACK TO MAKING ALL CHANGES REPORTABLE. 

It is time to quit changing policy so much.  Leave the 12-month certification periods with the Interim Report.  Workers and customers are used to the reports.  Changing to 6-month certification periods with only an interview every other time amounts to the same thing as what we have so leave the 12 month periods in place.  With the growing caseloads 12-month certification periods make the most sense from a management point of view.  This would also still coincide with the certification periods for Medicaid and TANF.  It would be best to either have the client to report all changes and take action on all changes the same way or just don't report any at all.  Policy is getting too involved rather than being simplified.  For example:  dealing with changes in shelter costs that result from a move should not be any different than other changes in shelter costs.

It is time to quit changing policy so much.  Leave the 12-month certification periods with the Interim Report.  Workers and customers are used to the reports.  Changing to 6-month certification periods with only an interview every other time amounts to the same thing as what we have so leave the 12 month periods in place.  With the growing caseloads 12-month certification periods make the most sense from a management point of view.  This would also still coincide with the certification periods for Medicaid and TANF.  It would be best to either have the client to report all changes and take action on all changes the same way or just don't report any at all.  Policy is getting too involved rather than being simplified.  For example:  dealing with changes in shelter costs that result from a move should not be any different than other changes in shelter costs.

I think with the overwhelming job and the increased applicants, all these changes are way too much. I think all changes should be reported, certifications should be 12 months, and Interim Reports 6 months. Everything is so up and down, nothing is spelled out until workers are clear about what is going on, and that is where errors are occuring.

I feel that we need to continue with interim reporting every 6 months and certifications every 12 months. I don't believe that with the increased caseloads that most workers would want to have to complete interviews every 6 months.

I think clients should have to report all changes and send in verification of the changes. Too many policy changes are taking place regarding reporting changes and workers are not sure what procedure to follow.

I believe that the SNAP periods should remain as they are right now.  As Ms. Mercer mentioned, changing cert periods to six, but only interviewing at 12 is no different than what we are doing now.  The procedure right now flows well.  I am still relatively new compared to some workers, but having been doing this job since 2008, so I do not know any other way, but it seems to work.  I am for leaving things the way they are now.  Thanks.

These comments are in reference to the Intended Regulatory Action; 22 VAC 40-601 -70 SNAP Certification Periods.

In reviewing the purpose, need, substance, legal basis and alternatives several things come to mind. 

1. The statement under Need, “Eligible households will continue to receive the same amount of SNAP benefits if this proposed regulatory action is implemented….”, seem contradictory to the statement under Substance, “Eligibility workers may determine eligibility and benefit amounts for households based on the application and supporting documents…..”  The first statement seems to indicate that benefit amounts would not change regardless of the client’s current circumstances but the second statement indicates the worker would be re-determining eligibility and benefit amounts.  Additionally, the 2^nd sentence states the worker “may” be determining eligibility/benefits.  Is there a choice in the 2^nd instance as to whether the benefits continue in the same amount or if still eligible, continue in a different amount???

2. If a six month certification period requires the workers to track whether the review is an Eligibility Interview or a Desk Review, it is too cumbersome and unrealistic to expect the worker to do this especially in light of the increased applications and caseloads.  Special review codes should be implemented in ADAPT to aid workers in tracking recertification as either Eligibility Interview or Desk Recertification.

3. Under the Alternatives, the option of LDSS Agencies being allowed to choose between six month and 12 month certification periods would be a complete disaster.  I would agree with the statement that this is the “least preferred”.

4. Understanding that the requirement to have some sort of review/renewal/recertification/reapplication at six months is because the state operates under the “Simplified change reporting system” and noting that the Benefit Unit was given a six page document on how to handle changes under “Simplified Reporting”; somehow takes the SIMPLE out of simplified.  A six page document containing clarifying information directing the Worker on when, what, how and/or even if the worker should or should not act, and/or how to act, and/or whether you send an informal contact or a formal contact for needed verifications, and/or what to do or not do if the client does or does not respond (depending on how change is reported); all the while remembering to affect any other case carried in ADAPT, is numbing.  Sound simple?  Don’t think so.   Additionally, the Recipient/Client/Applicant is confused when the SNAP reporting requirements differ from those of other Program reporting requirements.   It is understood the minimal reporting requirements were implemented due (at least in part) to the State's high error rate but the fact of the matter is; the clients that always reported their changes continue to do so and the ones that never reported continue to fail to report even if it is a "reportable" change.        

The six month certification period for everyone  seems like a waste of time for the client and the worker alike when it is a stable unearned income household; i.e. SSA household whose shelter/expenses do not exceed their household income.  If the review requirement is changed to six month certifications is there a possibility for exclusion for certain households???

Is there no other choice for reporting requirements other than full reporting and this “simplified” reporting?  Is there no middle of the road abbreviated reporting requirements that would have more reporting  than the “simplified” process while allowing the worker to choose either a six or 12 month certification period based on the individual client’s situation?  Can we not empower the worker by allowing follow up on a change no matter how the change is reported? Can we not impose some consequences to the clients that do not respond or follow through with requested verifications?  Would this not be fairer to the clients that do report, understands and accepts the change to their benefits?  Does it seem reasonable to continue to issue benefits to someone in an ineligible institution while they give their card and PIN number to allow someone else to spend their benefits?  During these hard economic times would it not be a better use of our resources and the taxpayers’ dollars to ensure benefits are based on the best available anticipated evidence???

While there are pros and cons on both sides (12 month w/IR, 6 month/no IR; (can’t see any reason to allow individual agencies to operate under different procedures) and understanding how the workers within agencies individually differ in their opinions as to what works best; neither of the options seem preferable.  Are these the only USDA options? Can there not be a process that encourages clients to be responsible and accountable for their benefits while enabling the worker to do the job?  Would that not  empower both the worker as well as the client?    

Please keep 12 month cert periods and the interim report--it is a REAL time saver!

Having changes so often is overwhelming. My current caseload is 974 cases (Snap & Medicaid). Please keep the 12 month certifications with 6 month interim reports. Having the 24 month certification periods with 12 month interim report for SSA & SSI clients has helped us immensely at our agency. Also, I like the current rules for shelter expenses on the interim report so I am hoping that the new changes that are currently on hold do not come to fruition.

Keep the 12/24 cert periods and IR as is.  Tighten reporting requirements. Too much time is wasted trying to decide if it is a required reporting item; allow our clients to be responsible adults.  If a client is going to be untruthful it makes not difference how often or what must be reported. 

The current situation with 12/24 month cert periods works for most and it keeps the client from spending valuable resouces to attend an interview.  Most in our area do not like telephone interviews.

This seems to be a waste of time.  This proposal  will likely have minimal affect on Eligibility Workers...they will be required to perform similar work, only a different way.

The focus should be the lack of CLIENT responsibility currently mandated by the USDA / Department.  How can we honestly expect a person to become self sufficient when they can sit back and receive "free money" with a token effort?

Keep interim reporting as is.  I find that the easier lawmakers try to make it on the workers the more complicated it gets.  We need to make our clients responsible for reporting changes again.

 Please leave the Interim Report Process as it stands. The process has been in place for several years and was working well until the last couple of years when the constant changes to how the Report was to be processed kept changing. I'm all for making things better and simpler but it is obvious all this change is creating  confusion among  workers and of course this leads to errors.  It stands to reason that if we are confused ourselves how confused are the people we are serving about what is expected of them. Thank you for your time. 

 I feel that Interim Reports are a waste of the worker's time.  We spend more time sending the Interims back ond forth between worker & client and on the phone with the client ,explaining how to complete the report.  Local agencies are struggling for money/supplies, but yet, we are required to waste the supplies and money for postage that we don't have to process the Interims. 

I would rather go back to six months Recerts. At least then, we can see them face to face and get all the information completed at once without delaying the process and without having to send request after request to get a "completed" Interim.  Six month Recerts can potentially save localities a lot of money just by cutting down on the forms, envelopes, & postage that is required to send the Interims back & forth between worker & client.  I'm sure it could reduce the friction that client's obtain when we have to send them back multiple times to get a fully completed report.

The Interim Reporting requiremnt should be eliminated.  It is not client or Benfit Programs Specialist friendly and cause Quality Assurance errors and delayed receipt of benefits for the client.  There is also an additional expense to the agency in time spent by the BPS processing, copying, remailing and the postage cost involved.  Certification periods should run for a year with no monthly or interim reporting requirement.  Keep the current requirement for clients to report changes.  That is their personal responsibility and they need to be held accountable for not reporting mandated changes.

I think we should go back to the six month renewals

Please do not take away Interim Reporting. Please do not make any changes to the way Interim Reporting is currently been handled.

I think the certification period should be left at twelve months and the interims should remain the same.  I think the interim reporting form we currently are using should also remain the same.  The new form is very confusing!  The clients are aware the interim is coming and prepared for sending it back in (with current income) as long as you explain this at the initial SNAP interview. If we change to 6 month certification periods I really don't think eveyone will be able to handle their caseloads because they are already constantly growing.   

I totally agree with eliminating the Interim reporting. I think it is much easier to complete the renewal every 6 months and get the information from the customer then. Whether it is face to face or on the phone, we are talking to the customer and getting the information directly. With the Interim reporting, we are spending a lot of our time teaching the customer how to complete the form, some of the time sending the checklist or asking for more information and spending our time and supplies ( $$) on getting the customer to complete "one more thing" when in the renewal, the person is either face to face or on the phone ONE time. WE ask them to return the documents needed for verifications and they bring it back or send it in. 

A lot of time and money are being spent sending papers back and forth and asking the customer to do something else, sending checklists, teaching them to complete the form. We are spending a lot of time on the phone with the customer, sometimes several calls and it seems like a lot more time is being spent on the Interim reporting than I spend on Renewals. 

Please eliminate the Interim reporting and go to 6 month recerts.  

I think we should review SNAP like Medicaid, once a year. Make the client responsible to report changes during the year.  Also certifiy homeless households and households with zero income for 6 months.  This makes sense to me and would probably cut down on some of the unreported income situations.  The interim reports should be stopped.  They are time consuming, paper wasting and a postage expense.  The elderly and disabled clients that are on fixed incomes should not have to complete them.  Give them a break.  

Interim reporting should be kept in place. With current policy, the Benefit Program Specialist has the option to chose a 12mo certification with interim or a shorter certification based on the facts of the case.  For a household with a stable income, having an interim report in lieu of a full recertification is a better choice for the client as well as the agency as it is less time consuming for all involved. An interim report takes a 1/4 of the time to process verses a full recertification.  With growing caseloads and no increase in workers, we need to have the most efficient processes in place.

I think the 12 month cert period is good and should be left alone.  The IRF needs to go back to the orginial form, reporting earned income and no income customers.  Customers that are on SSA, SSI or other fixed income should not have to send in a IRF.  This alone should save money for the state and time and energy for the workers.

It is my opinion that the state of Virginia should continue to use twelve month certification periods and Interim Reporting. For those agencies that utilize a system where workers are divided into "Intake" and "Ongoing" units, going to a six month certification period will greatly increase the number of intake appointments. I realize that under the current procedures there are those housholds that "forget" to complete their renewals and still have to file a new intake application. however, I suspect that the number of those households will rise if we go to a six month certification period. I'm also concerned that those clients who work will have to take time off to complete an interview all the while we are expecting them to find and hold jobs. I understand that it would only be every six months, but some employers are not as cooperative as others.

Please consider if changing to ending Interim Reporting and having certification periods every 6 months the hardships on those that have vacancies in their agencies on a regular basis.  Some workers are having 30 - 40 Interims per month as well as a large number of recertifications and new applications.  Interim reports take less time to process than do renewals and applications.  Also please take into consideration that when interims come in prior to the month that they are due, customers are not waiting until the first of the month that they are due; therefore, information that should be reported is not.  Reports should not be returned until the month due.

With the caseloads increasing, I would much rather have clients complete IRs rather than seeing them every 6 months.  Some months now it's hard to schedule all your NOAs before the 15th.

The idea that the state would even consider doing away with interim reports boggles my mind.  The SANP caseload in the state has increased some 40 to 60 % since 2007 with no additional workers to handle these cases.  If we go to 6 month certs my agency will be physically unable to handle them.  We do not have enough hours in the day to see that many people or do that many extra phone interviews.  I realize that you are strictly looking at the SNAP program but the workers here have to do everything and our Medicaid numbers are going down hill everyday.  The interim report may be a little aggrevating to deal with when the customer does not turn it in.  But they are the same customers that will not turn in a review form or come in for an appointment and have to reschedule. I beg of you not to illiminate the interim report.

I DEFINATELY THINK WE SHOULD KEEP INTERIM REPORTING, MANY CUSTOMERS FORGET TO REPORT CHANGES AND NEED THIS TO HELP US KEEP UP WITH THE CHANGES. I FEEL IT WOULD BE VERY STRESSFULL TO HAVE ALL THE CUSTOMERS COME IN EVERY SIX MONTHS FOR A RECERTIFICATION, IT WOULD BE VERY OVERWHELMING ON THE EW'S AS WELL AS THE CUSTOMERS, WHO SOMETIMES FIND IT HARD TO GET INTO THE OFFICE ONCE A YEAR. SO I THINK WE SHOULD KEEP THE INTERIM REPORTS.ype over this text and enter your comments here. You are limited to approximately 3000 words.

The IR requirement should be eliminated.  It is too time consuming as customers do not complete reports,  some reports are not returned timely, required verifications are not submitted with the reports, reports are not signed and some reports are not returned at all. All of these things require extra steps in getting the reports completed for evaluation.  Often times, the reports that are submitted have to be handled over and over again in order to obtain information that is requiired.  I believe that interviewing the customer every 6 or 12   months will result in more accurate information being obtained and will cut down on expense as well as the time involved.  Conducting an inteview whether via telephone or face to face, in my opinion,  is best practice for payment accuracy.  If IR requirements remain in place, I do believe that a penalty should be invoked for late filing as it is for  filing a late recertification application.

INTERIM REPORTS HAVE CAUSED MUCH CONFUSION WHICH COULD LEAD TO ERRORS. A SIMPLE 6 MONTH CERTIFICATION APPLICATION AND TELEPHONE INTERVIEW WOULD BE MUCH SIMPLER AND QUICKER.

I feel the interim reports should end.  Alot of the workers time is spent on these interim reports more so at the first of the suspended month or the end of the suspended month,  this is due to the clients delay in providing a completed report form timely.  Many notices are sent on the 5th because the clients fail to provide their interim reports on time and they are down to the wire once they do provide the interim report and needed verifications.  The client then wants their benefits ASAP.  If they chose to keep the interim reports they need to limit the time allowed to return them, giving them a month and a half to return them is to long.  It should also be like a late recert and benefits be prorated, some type of penalty should exist.  I worry about a 6 month certification because of the large caseloads workers are currently handling.  There is a big need for more EW positions but no funding.  EW's are overloaded at present.  If 6 month certs come our way we would want to do more phone interviews but we do not do many now because of the need of Part A and B forms having to be completed and returned by the client.  Our clients need help with these forms, so they end up coming in for help with it.  It would be so nice if they eliminated these forms and just allowed us to call the client, do an interactive interview, print the statement of facts and the checklist and mail it to the client to sign and return, it makes it so much easier.  We average about 30 recerts a month and 30 interim reports per worker and we have 5 workers  They would each be seeing about 60 recerts a month and it would be impossible to schedule that many per month by the 15th of  the month.  Thank you for allowing my comments.

I would not like to see the state return to 6 mo renewals. The needed information can be gained from the IR and it is much less burden for the clients as well as the worker.  As the economy has weakened the caseloads of all workers have increased dramatically and the need to have face to face or telephone contact with all the people we now do by interim would just be totally unmanageable for already overloaded workers.

I have been doing this job for almost 15 years and have seen many changes and have experienced the increase in caseload size and way too many policy changes.  It is my opinion that we should leave 12 month certification periods with 6 month Interim Reporting in place.  Even if we see them more often it does not help us to decrease our error rates.  You will always have people who responsibly report changes whether you see them or they fill out a form and you will always have people who don't.  However, the ones who don't report changes are many times the ones who don't report changes even if you see them in person.  Going back to 6 month certification periods would only increase the worker's stress level trying to see that many more people in person.  Leave well enough alone.  People are going to be the people they are.  Some will be truthful and some not.  Changing the certifications period is not going to change that nor reduce errors.  Thank you for asking for our opinion.

Please do not change the Interim Report filing and Certification periods. I agree with some of the other posts that they should incorporate a penalty for a late Interim Reports as they do with the late Renewals.

I work primarily with the Aged, Blind, and Disabled population and I feel that the households with unearned income (SSA,SSI) it is a waste of the client's time and the worker's time to have them be expected to come in for 6 month renewals. I haven't had any issues with them completing the Interim Report, because most of the time they are just checking "No Changes" the whole way.

I know with Families and Children cases there are a lot more changes being reported. Maybe they just need to come up with a better policy on what needs to be reported and when.

If they could ever get the web portal for the client's in place I think that would be a good avenue for client's to report changes online that some how could be reported directly to their worker.

Keep the interim reporting as is. However, if any changes are to be made it should be with how the questions are asked on the interim report.  I suggest that you as questions like:  What is your rent expense?  List your bank accounts and how much money do you have in your account as of today? Who live in your home/apartment with you? Where do you get money from to pay your bills? Etc

Keep interim report as it is.  If we do away with interim reporting it would mean in our agency we would have about 40-50 renewal per month per worker.  With the work load we already have this woudl be very over whelming on the worker and on our clients.

Keep the 1 year certification period and 6 month IR. In ABD caseload most often not many changes in client's situation-fixed income. However, if there is a change then IR provides opportunity for reporting. Having said that, remove the policy that client gets to the end of the 2nd month before case auto closes. Our clients have to take some responsibilities over their lives and affairs. ABAWDS? 6 month cert period.

Workers must realize the government wants individuals and households to receive benefits; because of this they are making it easier for households to receive these benefits. Less reporting is now required for households, only if a household goes over the SNAP limit does this information need to be reported since the federal government want less information we should realize we need less information about the individuals /households. As long as the individual complete the interim and report their required changes on the interim, I feel we should keep this reporting factor in place. Inform your clients when they are in the office for a renewal on how to complete the interim form and let them know when to expect the paper in the mail.  

ALL Interim Reports should be eliminated.   Let the worker decide what type of certification period suits the household.  Simplified Reporting should be eliminated because the workers and Supervisors are constantly having to decide if what was reported is an action that must be taken immediately or acted on at Recertification/ Interim which ever comes first.  Lets go back to having the customer be responsible citizens and report all mandatory changes and let the workers do their job!       

I would like to keep the Interim Reports in place because the work load is so heavy.  I feel we can get more accomplished by having the Interim Report because we will not have to seen those client.  If you take out the report we will have to see more clients and harder for us to complete reviews for cut off.  An Interim with no income will take less time to complete verses a review with no income and seeing the client.

Returning to the 6 month recertification period requiring appointments would create greater stress on eligibility workers and agencies because of the high volume caseloads. Most likely producing an increase in poorly managed caseloads and more errors in casework.

Leave  the interim reporting in place! 

In order for workers to handle their caseloads and maintain payment accuracy, I reccommend the 6 month interim report ought to stay in effect.  Interim reports require the same changes be reported as a customer would have to report at a renewal interview; however they often require less time to process.  With the significant increase in caseloads and a committment to payment accuracy, eligibility workers and our customers would benefit from keeping the interim reporting policy.

I'd prefer that we didn't do the interim reporting nor the 6 month renewals but, out of the two, I choose that we do the interim reporting.  I do suggest that we not have to send that notice if the interim report is not returned.  I feel that we are "holding their hands" too much.  They have to be accountable and be responsible.  This just puts more work on the worker.

To whom it may concern:

I have been a Benefit Program Worker for 10 years.  As a result of the current economy situation, more individuals and families are forced to apply for benefits.  Where does that leave your workers?  I will tell you...it leaves us with more than doubled caseloads.  VDSS expects us to screen, interview, work in ADAPT, VAMMIS, SPIDER and now ANOAS systems, evaluate, answer phone calls, see clients, answer questions, deal with computer systems being up and down (such as today) and document, document, document!!!!  Look at the caseload numbers and you will see how much we have to do.  

Interim Reporting keeps the client from coming into the agency...which saves me a lot of time.  Please Please Please help us and don't hurt us by changing Certification Periods back to 6 months.  We need support and help.  I would much much rather process a form (Interim Report) than having to make the client come in for an interview.  

Thank you for your time,

Tammy Hunt

Benefit Programs Specialist 049

As a BPS worker for Richmond DSS I encourage this change from 12 month recertification periods to 6 month recerifications with removal of mandatory Interim Reporting due to the high number of cases in our agency closed and or suspended due to non-receipt of the Interim Report. Richmond Virginia currently has the largest caseload statewide. By removing the Interim Report as a requirement our agency will definitely better serve clients within the Richmond city limits due to a reduction in the amount of paperwork necessary to process cases within a timely fashion. This change will also assist surrounding counties such as Henrico and Chesterfield in meeting the needs of its clients in a simillar fashion.

I have 24 Interims this month, Nov. 2010 .Case loads have doubled with no extra help. Scheduling appointments for the 24  interims and  11 recerts would be 35 scheduled appointments  before the 15th of each month.  This is not including the Medicaid reports, Tanf reports ,all the changes clients have,not to mention the new cases coming in.

The interim reports, made a positive way of doing recerts by mail. Clients are use to this, and  are providing the verifications . With the gas prices and the lack of public transporation in our rural area,The clients couldn't make the appointment. This would lead to telephone interviews, which will lead to extra postage cost.  Keep the interims going and provide a little break for the workers!!!

I am currenclty in favor of going back to 6 month reviews.  There have been times that I have had to mail an Interim Report or Request for Information as many as 6 times to finally get the information needed for this report.  This is very coslty to the agency as well very time consuming for the eligibility worker.  A review of benefits every 6 months would end the back and forth of the mail , saving money and time.

Thank you.

Carol Roscher

Would like to see 6 month certifications for people with earned income as long as they can still do phone interviews.  Would like to see one year certifications for our aged, blind and disabled people. Their income does not usually change during the year and interim reporting for them and the workers is just a hassle and expense for paper and postage.

I am an eligibility worker at Halifax Dept of Social Services.  Over the past few years as the economy has gotten worse, our case loads for snap benefits (as well as TANF and Medicaid) have increased by 20 - 30%.  If you change the interim reporting requirements which do NOT require a Face to Face to interview to a Renewal Appointment, it will increase the burden significantly for our already over-loaded eligibility  workers.  Although Renewal appointments can if the client chooses, be done by phone, it still requires specific blocks of time to be set aside for clients to be interviewd by phone or in person (which is still how most are done).  To change from once per year to every 6 months, would double the amount of time we must set aside for renewal appointments which is already tight because we all have approximately 6-7 days per month set aside to see New applicants. 

Currently, we gather much the same infomration under the interim reporting requirements with the advantage that a person does not have to make a specific appointment time and come in to meet with the worker.  This all takes up much valuable time.  Instead, we can process the interim reports as they are mailed back in between our renewal and new applicant appointments.  This, in addition to processing approximately 200 energy assistance applications three times a year as part of our Energy Assistance Programs.

Please do not make this change.

The reports should be eliminated and 6 month recertification implemented. Interims are time consuming  & costly. Clients should be responsible for reporting ALL changes. They have to report for medicaid so why should one that is just receiving food stamps  be exempt from reporting.