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?