M E M O R A N D U M

TO: EES Program Administrators

FROM: Sandra Kimmons

DATE: 6/28/16

SUBJECT: Implementation Instructions - KEESM Revision #77

This memo provides implementation instructions and information for the following July 1, 2016 policy changes in the Kansas Economic and Employment Services Manual (KEESM).

Questions Answers: July 2016 Changes (Except Child Care items covered in Section II below)

1. All TANF, Child Care and Food Assistance Programs
   
   
   1. Identity verification – See Summary of Changes I, A, 1, and KEESM section 1322.1 (5).
      
      Effective July 1, 2016 all adults in the assistance household, those required to be included by the program’s assistance planning rules, will need to have their identity verified for eligibility purposes for new applications and recertification’s if not previously verified.
      
      For this provision, adults are generally defined as anyone 18 years of age or older or those who are legally emancipated, but would not include an 18 year old who is categorized as a TANF child due to pursuing their high school diploma or its equivalent.
      
      
      1. At Application
         
         All adults in the assistance household will need to verify their identity, acceptable documents are described in Appendix Item A-12 and KEESM 1322.1 #5. Any document which reasonably establishes identity may be accepted and no requirement for a specific type of document, such as a birth certificate, will be imposed. If no such document is available, a collateral contact may be made and documented in the case file.
         
         Expedited applications must always verify the identity of the person making the application, however, the worker may, if necessary, postpone identity verification of other adults in the assistance household.
         
         If identity verification is not provided for an adult in the assistance household within 10 days from the written request for information, the application will be denied. See KEESM 1414.2 #3 for policy related to verification subsequently received.
         
         Examples
         
         
         1. John applies for Food Assistance and TANF for his family, which includes John, his wife, his 7 year old son, and his 18 year old daughter who is still a high school student. Verification of identity would be required for John, his wife, and his 18 year old daughter to process the Food Assistance application. This verification is not needed for the 18 year old for the TANF application because she will be considered a child on that case.
            
            
         2. Ada applies for TANF for her 3 year old grandchild. Ada’s husband also lives in the home. Verification of identity is only needed for Ada because she is the person making the application. The verification of identity for her husband is not needed because he is not the person who made the application and he is not on the case or required to be on the case with TANF assistance planning rules.
            
            
         3. George applies for Food Assistance for himself. He lives with an unrelated roommate and he certifies that they prepare and purchase their meals separately on the application. Only George’s identity must be verified because his roommate is not on the case or required to be on the case with assistance planning rules.
            
            
      2. At Review
         
         For recertification’s beginning July 1, 2016, verification of identity is required for all adults in the assistance household if the verification is not already in the case file or identity is not documented as verified.
         
         
      3. Changes
         
         If an existing household member turns 18 during the certification period, staff will need to request ID verification. If the verification is not provided within 10 days from the written request for information, the assistance case will be closed providing timely and adequate notice.
         
         
   2. Lottery crossmatch
      
      Beginning July 1, 2016 DCF will conduct a monthly crossmatch with Lottery winners of at least $5,000 in Kansas who are in a TANF, Child Care, or Food Assistance household. The case actions needed for any matches found will be conducted by DAB EES staff. This policy is not expected to impact field staff duties.
      
      
2. Child Care
   
   Questions Answers: July 2016 CC Changes (Except KEHS/CCP covered in II, D, below.)
   
   
   1. Twelve (12) Month Eligibility: See Summary of Changes II, A, 3, 4, 6, 10, 12, 14, 15, and KEESM sections 1424, 2810, 2831, 2835, 7340, 7640, 9370, 9374, 10021.1.
      
      For child care applications approved on or after July 1, 2016, all eligibility periods will be set for twelve months. Review periods are not to be shortened to match other programs. Note that families continue to be responsible to report changes within 10 days, and EES staff are to act on those changes, updating plan hours, income and family share except as noted below. Child care assistance must remain open for 12 months except:
      
      
      1. When a parent/caretaker experiences either a temporary or non-temporary loss of employment or cessation of participation in an approved job training or education plan, including TANF or FA work program assignments (even if penalized for non-cooperation), except as noted in item b below. In these cases, assistance will be continued at the same benefit level (same hours and same family share deduction) for 3 months following the month the change occurs, unless that three month period would extend beyond the current review period. If less than three months remain in the review period, the extension would be until the end of the review period. This would also apply for parents/caretakers whose hours of employment drop below the required hours, or are self-employed and are no longer earning at least the federal minimum wage per hour. At the end of that 3 month period, these cases will be closed unless the parent/caretaker reports that they have resumed employment or self-employment that meets the minimum requirements or participation in an approved education plan. See KEESM 2835 for requirements to approve an education plan.
         
         For cases in which assistance is continued for three months, the three month period will begin with the next calendar month following the date of the temporary loss or cessation. The client will be advised in writing of the three month continuation. That notice will advise them that they must provide proof of again meeting the requirement by a date early in the last of those three months. An alert will be set on the case for that date, and if no proof of meeting the requirement has been received, the child care case will be closed effective the last day of that third month. Note: The extended period of eligibility will not go beyond the end of the original 12 month eligibility period, so could potentially be only one or two months. Eligibility must be re-determined at the end of the 12 month eligibility period.
         
         
      2. When a recipient loses employment, or their employment drops below the minimum hours or earnings requirement, or they stop attending an approved education or training program and they indicate that they do not intend to look for employment, increase hours of employment, increase earnings or resume attendance in an approved job training or education program. These cases will be closed allowing for timely and adequate notice.
         
         
      3. When a recipient fails to cooperate with child care program eligibility requirements (i.e. failure to cooperate with Child Support Services, failure to cooperate with fraud investigations, or failure to provide requested information needed to determine ongoing eligibility). These cases will be closed allowing for timely and adequate notice.
         
         
      4. When a recipient moves out of state. These cases will be closed allowing for timely and adequate notice.
         
         
      5. When a recipient requests verbally or in writing that their case be closed or a plan for a particular child be terminated. These cases or plans will be closed allowing for adequate notice only.
         
         
      6. When a recipient is admitted to an institution. These cases will be closed allowing for adequate notice only.
         
         
      7. When a recipient’s whereabouts are unknown and agency mail directed to them have been returned by the post office indicating no known forwarding address or an out of state address. These cases will be closed allowing for adequate notice only.
         
         
      8. When the agency has factual information confirming the death of a client. These cases or plans will be closed allowing for adequate notice only.
         
         
      9. When a recipient has accepted assistance in another jurisdiction and that fact has been established by the jurisdiction previously providing assistance. These cases will be closed allowing for adequate notice only.
         
         
      10. When a recipient is no longer using a DCF approved child care provider. These cases or plans will be closed allowing for adequate notice only.
          
          
      11. When a recipient stops using their child care benefits. These cases will be closed automatically by the system after two months of inactivity, allowing for timely and adequate notice.
          
          
      12. When a family for whom verification was delayed at initial eligibility subsequently fails to provide the required verification. These cases or plans will be closed allowing for timely and adequate notice.
          
          
      13. When a household reports an income change that results in countable income that exceeds 85% of the State Median Income (SMI) for that household size. See Level XII on the Monthly Family Income and Family Share Deduction Schedule (KEESM appendix item F-1). These cases will be closed allowing for timely and adequate notice.
          
          
      14. When no eligible child remains in the home, the cases will be closed allowing timely and adequate notice.

      Examples:

      1. Mary applies for child care assistance on July 1 for her 4 year old child while she is employed. Mary already has an ongoing Food Assistance case which is due for review in December. If all eligibility requirements are met and the child care application is approved, the case will be set for a review of child care eligibility in June of the next year. The food assistance may be redetermined at this time to establish a new matching review period, but the child care review cannot be shortened to match the existing food assistance review.
         
         
      2. Susan has an ongoing child care case and she is employed 35 hours per week. She timely reports on August 23rd that her hours at work have been cut to 20 hours per week. Her child care case will remain open with no change in plan hours and Susan is advised that she has three months (September, October and November) to work on meeting the 28 hour per week work requirement. Note that this is not considered as a negative change as benefits remain the same, so does not require timely notice. Susan is sent a notice advising her that she must provide proof that she is meeting the requirement by November 6th so that a determination can be made regarding continued eligibility. An alert will be set on the case to close it effective November 30th unless proof has been provided that work requirements will again be met by the end of November. If the case is closed at the end of that time, a closure notice will be required.
         
         
      3. Lisa applies for child care assistance on August 6th for her 3 year old child while she is employed as a paraprofessional in an Early Education classroom. She knows that she will only need care from August through May, as she will no longer be employed in the summer. Because she is only temporarily unemployed and plans to return to work at the school when school is back in session, child care assistance will continue through the next August because she will receive 3 months of child care subsidy beginning the month after she will no longer be employed, which will be May. Because the review is due in July, the worker will set this plan up for 12 months, which results in Lisa only receiving 2 months of extended eligibility before a redetermination of her eligibility for August is completed.
         
         
      4. George receives TANF and is working with Employment Services. He received child care for his 2 year old son so he may participate in his assigned activities. George’s Career Navigator finds out in August that he is no longer attending his activity. The Career Navigator attempts to contact George, but George does not return any phone calls. A first-time penalty is applied to the case following the appropriate procedures. The TANF penalty is applied for September, as there is time for timely and adequate notice. George’s child care is allowed to continue to 3 months (September, October and November) under the EM subtype with zero family share. Child care benefits will continue to be paid for the same hours as he received in August. George is sent a notice advising him that he must provide proof that he has an allowable child care need, including a work program assignment to cure the penalty, by November 7th. An alert will be set on the case to close it effective November 30th unless proof has been provided that George has an allowable need by the end of November.
         
         
      5. Same situation as example #4 above, except this is a third time penalty and George will be ineligible for TANF for one year, from September through the next August. At the time of TANF closure, George’s child care will be allowed to continue for three months as stated above. In July, George reapplies for TANF and wants to cure his penalty. JO Child care will be approved for the number of hours determined by work program staff, and the case will be set up with a 12 month eligibility period. If George cures his penalty and is again approved for TANF, his child care hours will be adjusted for the next month for the hours needed for his work program assignments. If George fails to cure his penalty, the child care plan will again be allowed to continue under the EM subtype for three months after his TANF application is denied for failure to cure the penalty. At that time George will be notified of the extension and that he must provide proof of meeting a qualified need for child care by a date early in the last month of the extended period in order to continue receiving child care assistance. An alert will be set on the case to close it effective the last day of the three month extension unless George has provided proof that he has an allowable need by the end of that month.
         
         
      6. Rose receives food assistance and child care assistance for her 2 year old child while she is employed. Rose contacts the DCF office on July 1st to let them know that she has begun her maternity leave on July 1st and will be receiving her last paycheck on July 15th. She will be on maternity leave until September 1st without any pay. The worker keeps the hours on the plan the same and allows it to continue for 3 months (August, September and October) with the same family share. The worker also takes appropriate action on the food assistance case, adjusting income and adding the newborn child. Rose is sent a notice advising her that she must provide proof that she is meeting the work requirement by October 7th. An alert will be set on the case to close it October 31st unless proof has been received that work requirements will again be met by the end of October. If the case closes, the dependent care expense for Food Assistance may need to be adjusted.
         
         
      7. Same situation as example #6, but when Rose notifies DCF that she has begun her maternity leave, she also applies for TANF. Her TANF application is approved, so child care needs to be changed to the JO subtype for the three month extended period and there will be no family share deduction applied The worker will also need to change the income and dependent care expense on the Food Assistance case. As in example #6, Rose is sent a notice advising her that she must provide proof by October 7th that she be meeting the work requirement by the end of that month. An alert will be set on the case to close it October 31st unless proof has been received that work requirements will again be met by the end of October.
         
         
      8. Hillary receives child care assistance for her 4 year old child while she is employed. Hilary has been working for a temporary agency. Hillary is notified on August 10th that her temporary assignment has ended and the agency does not have a new assignment for her at this time. The agency has told Hillary that they value her services and will consider her when a new need arises. Her child care will remain open and Hillary is advised that she has three months (September, October and November) to work on meeting the 28 hour per week work requirement. Hillary is sent a notice advising her that she must provide proof that she is meeting the requirement by November 7th. An alert will be set on the case to close it effective November 30th unless proof has been provided that work requirements will again be met by the end of November.
         
         
      9. Same situation as example #8 above. Hillary provides proof on November 25th that she has a new assignment from the temporary agency starting that day for 30 hours per week. Her child care case has already been closed effective November 30th. The child care case will be reopened effective December 1st for the remainder of her 12 month review period, and her new income and hours information will be used to determine her benefit amount and family share deduction.
         
         
      10. Diane is a TANF recipient and a mandatory work program participant. She needs child care for her 2 year old while she completes her work program activities. She is assigned to a six week training program beginning August 1st, and needs 150 hours of child care for August and 70 hours for September. It is not known at this time what assignments might be made after that. Child care is opened with 150 hours for August and 70 hours for September. Child care will be continued for three months (October, November, and December) at 70 hours per month. Diane will be notified when her training program ends that her child care will end December 31st unless she is again participating in an assigned activity or verification is received that she has obtained employment. A rule of thumb would be that in initially setting up a child care plan, if we know that the number of hours needed for the next month(s) is different, the plan will be set up with those changes. The three month extension of child care will be based on the most recent month in which the activity ended or will end.
          
          
      11. Same situation as #10 above except the activity started in mid-August and the need for care was 70 hours in August and 150 hours in September. The three month extension would be based on 150 hours per month. After the case is initially set up, the number or hours cannot be decreased, but could be increased if the assigned activity warrants it.
          
          
      12. Same situation as #10, except Diane’s assignment is a 2 week activity and she needs 70 hours of child care for August. Child care will be approved with 70 hours for August. Child care will be continued for three months (September, October and November) at 70 hours per month, and Diane is notified from the beginning of the three month extension as in example #10.
          
          
      13. Jackie is a TANF recipient and obtains employment for 25 hours per week. Her child care plan is written for November through the next October – JO child care since TANF remains open. In December, Jackie gets a raise (no change in hours), and that increase puts her over income for TANF. She gets 5 months of work incentive payments for January through May, then TANF is closed. Her child care will be changed to EM child care, and she’ll get two months (June and July) with no family share and without having to meet the 28 hour work requirement. Before the end of those two months, if employment remains less than 28 hours per week, Jackie will be notified that her child care will be extended for three months August, September and October, but she will be assigned a zero family share, and her case will be closed at the end of October unless at review, she provides verification that she is meeting the 28 hour per week work requirement.
          
          
      14. Same situation as #13 (with eligibility period November through the next October), except Jackie gets the raise in February. In this situation, the 5 months of work incentive would be March through July. The two months of EM child care with no family share and without having to meet the 28 hour work requirement would be August and September. The extended period of time to allow her to attempt to meet the 28 hour work requirement would only be the month of October, as eligibility would have to be re-determined in the 12th month in order for her to continue to receive child care
          
          
      15. Erin applies for child care for her 12 year old son in December. Her son will turn 13 in May and there is no concern about his ability to care for himself when he turns 13. If all other eligibility requirements are met, Erin’s child care will be approved for December through the next November. The worker will need to enter the “Y” coding in the “Over Age 12 Approved” on the CHCP screen so that Erin’s son can continue to receive child care past the month of his 13th birthday.
          
          
   2. Graduated Phase out of Assistance: See Summary of Changes Appendix section.
      
      For all child care reviews processed on or after July 1, 2016, if the household’s countable income exceeds 185% of the Federal Poverty Level (FPL), but is less than 85% of the State Median Income (SMI), child care will be approved for a 3 month transition period and closed at the end of that period. A twelfth level has been added to the Monthly Family Income and Family Share Deduction Schedule (KEESM appendix item F-1) with the 85% SMI income limits. Family shares for these families will be the same as those with incomes within the range for Level 11. If the previous family share was less, the worker will need to enter the maximum allowable income for Level 11, and change the family share to the increased amount.
      
      Cases approved for the three month transition period will only be closed prior to the end of that period when one or more of the circumstances listed in A. above are met.

   Examples:

   1. Jody had an ongoing child care case for her two children, ages 1 and 3 (a three person household). She had countable income of $2,400 per month, and had a family share of $177. During the last month of her certification period, Jody received a promotion at her work and a pay raise resulting in countable income of $3,800 per month. When her review was processed, the new income was used and Jody was over the 185% of the FPL, but remains under 85% of SMI. Benefits will be approved for a 3 month period using countable income of $3108 (the maximum for Level 11 on the F-1 schedule) and her family share is increased to $243, the same as Level 11 on the F-1 schedule. The worker logs all actions and the reason for the income amount entered. (The system would have determined the case to be over income if the actual amount had been entered.)
      
      
   2. Same situation as example #1 except Jody received the promotion in the sixth month of her 12 month certification. Jody’s eligibility will continue for the 12 months of her original eligibility period, and income will need to be entered on INEL as the maximum allowable income for level 11 and the family share deduction adjusted to the higher amount. When her review is completed at the end of that 12 month period, if income remains over 185% of FPL but less than 85% SMI, she will be approved for the three month phase out period using the maximum income and family share deduction for level 11. The worker logs all actions and the reason for the income amount entered. (The system would have determined the case to be over income if the actual amount had been entered.)
      
      
   3. Child Care for FA E&T Participants:See Summary of Changes II, A, 6, and KEESM section 2835.
      
      Current policy allows child care for mandatory Food Assistance Employment and Training (E&T) work program participants. Effective May 16, 2016 (the date the Hope 2 bill became law), child care will be allowed for both mandatory and voluntary E&T participants while waiving the minimum work hours requirement. If, however, there is another adult in the household who is not participating in the E&T program, he or she must meet one of the other qualified need reasons (i.e. employed 28 hours or more per week).
      
      When a Food Assistance E&T participant requests child care, the child care application will be processed by the FA E&T staff. These cases will be identifiable on KsCares by the GT or MO coding shown on the CAMA screen. If a child care case is open with this coding, any action taken on the case should be done by E&T staff. E&T staff will maintain the child care program until 90 days after they obtain employment, at which time the case will be transferred to the purple team.
      
      
   4. Kansas Early Head Start / Child Care Partnerships: See Summary of Changes II, A, 7 and 8, and KEESM sections 2835 and 2860.
      
      Questions and Answers: July 2016 KEHS/CCP Changes
      
      Effective July 1, 2016, the Child Care Subsidy Program will enter into partnerships with Kansas Early Head Start (KEHS) grantees. With these partnerships, participating families will submit applications for child care assistance with the help of the KEHS grantees. The application will be completed by the family and submitted through the KEHS grantee, and will be accompanied by a referral form from the KEHS grantee that clearly indicates that the family is participating in the partnership program. The KEHS grantee will determine eligibility based on KEHS eligibility standards and guidelines, and will indicate on the referral form that this determination has been completed. Note that the KEHS determination is not a final determination, as DCF staff will need to check to ensure that the family has no outstanding non-cooperation issues with fraud investigations or child support services before eligibility is approved.
      
      It should be noted that these families may or may not meet the 28 hour per week work requirement, but will be participating in activities as assigned by the KEHS grantee for a minimum of 30 hours per week. These activities will be monitored by KEHS, and DCF will be notified by KEHS if the family’s participation in the partnership should end.
      
      The referral form will also indicate the start date for the child care plans. The start date will be the date the referral is received in the DCF service center, except the initial round of applications. Those applications will start coming in June 20th, but the start date cannot be earlier than July 1, 2016. When the application and referral are received in a DCF service center, the application is required to be processed within 7 (seven) calendar days of receipt of the application and referral. This includes those received before July 1, 2016. If there are no outstanding non-cooperation issues with fraud investigations or with child support services, DCF staff will accept the eligibility determination of the KEHS grantee for all other aspects of eligibility, the application will be approved and child care plans for the KEHS child(ren) will be written for 40 hours per week unless it is indicated on the referral form that a higher number of weekly hours is needed. The reason code EH will be used for child care plans for all children on these cases.
      
      Child care assistance for families in which any of the children needing assistance is participating in the KEHS partnership will be approved with no family share deduction, therefore income need not be entered on INEL. It must be logged that this is a KEHS/CC partnership and there is no family share deduction. For children on these cases other than the EHS children, child care hours will be approved as follows:
      
      
      • 40 hours per week for non-school age children who need full-time care (i.e. a four year old who is not in pre-school, Head Start or pre-kindergarten)
        
        
      • 20 hours per week Sep-May/ 40 hours per week June-Aug for children who are in school part time (i.e. preschool, Head Start of half-day kindergarten)
        
        
      • 10 hours per week Sep-May/ 40 hours per week June-Aug for children who are in school full time.

      Additional hours may be approved for any of these children if justification for the additional need is provided. This information will be included on the referral form.

      Generally, these cases will come to the attention of DCF staff upon receipt of the application and referral forms from the KEHS grantee. However, it is possible that a grantee may submit a referral for a family with an ongoing child care assistance case. When this does occur, the case will be processed within 7 calendar days of receipt of the referral, and the effective date of any related case changes will be the date of receipt by DCF of the referral form.
      
      It will be the responsibility of the parent to share copies of notices and requests for information with the KEHS grantee.

   Examples:

   1. Betty and 3 month old daughter are enrolled in the Kansas Early Head Start Child Care Partnership. Betty needs child care to attend school and work. The local DCF office receives an application from Betty with a referral form from the KEHS/CC Partnership for Child Care Assistance. The referral form indicates that identity, citizenship and income eligibility have been determined and that she is enrolled in Early Head Start Child Care Partnerships. Betty has already passed almost all eligibility factors as determined by the KEHS/CC partner and DCF must only check to ensure that there are no non-compliance issues with CSS. Betty does not have any prior referral to CSS. Betty and her child do not have TANF, so the case is set up with an EM subtype. Income is not entered on the system as there is a 0 family share. The referral indicated that Betty needed 40 hours a week in care, so the worker used 172 hours for all complete CC months. The first month was prorated to the application date. The reason for child care code is EH (Early Head Start). The form indicates the DCF provider and the provider ID. The case is set up with a 12 month child care plan. A CSS referral is made for the case using the information provided in the application. Client is notified by NOA.
      
      
   2. Jean and her 1 year old son are enrolled in the Kansas Early Head Start Child Care Partnerships. Jean also has an older child in the home who is in school full time and needs childcare after school and on days when school is not in session. The referral form indicates that Jean needs 40 hours of care per week for the 1 year old and 10 hours of care per week for the school age child. The DCF worker checks and finds that Jean has no outstanding non-cooperation issues with fraud investigation or child support. Child care is approved for 172 hours for the 1 year old (40 x 4.3) and 43 hours (10 X 4.3) for the school age child for the months of Sep-May and 172 hours for the months of June-Aug., using the EH reason code for both children. There isn’t a family share applied for the family.
      
      
   3. Same situation as example #2, except the referral form indicates that Jean needs 50 hours per week of child care for the 1 year old and 20 hours per week for the school age child. The referral form also shows justification for the need for those additional hours. Child care is approved for 215 hours per month for the 1 year old and 86 hours per month for the school age child for the months of Sep-May and 215 hours for the months of June-Aug. if it is indicated that 50 hours per week is needed for the school age child during summer.
      
      
   5. Maximum Allowable Resource Limits: See Summary of Change II, A, 9, and KEESM section 5140.
      
      Effective July 1, 2016, the maximum allowable non-exempt resources of all members of a family group applying of child care assistance is ten thousand dollars ($10,000). This resource limit will be applied for all applications processed on or after July 1, 2016. For ongoing cases, resources will be reviewed and the new limit will be applied at the next review or case change, resulting in the new resource limit being applied to all cases no later than July 1, 2017.
      
      
3. Food Assistance
   
   Work Registration Requirements: See Summary of Change IV, A, 1, and KEESM section 3100 (1) (a).
   
   Each Food Assistance household member ages 16-59 who are not exempt from work requirements is required to register for work.
   
   Effective July 1, 2016 at application and recertification all nonexempt members in the Food Assistance household must have the individual pertinent work requirements explained to them. The Food Assistance Work Registration Requirements, Appendix item E-26, must be given or mailed to each food assistance household that includes a nonexempt household member.
   
   The following individuals are exempt from work requirements per federal regulations:
   
   
   • Persons who is age 17 or younger or who is age 18 and working toward attainment of a high school diploma or its equivalent.
     
     
   • Persons required at home to take care of another household member whose condition does not permit self-care
     
     
   • Persons employed, including self-employment, with earnings equal to minimum wage multiplied by 30 hours weekly
     
     
   • Persons disabled, ill, injured or incapacitated for more than 30 days.
     
     
   • Caretaker personally providing care for a child under the age of six
     
     
   • Persons receiving unemployment compensation
     
     
   • Participants in a drug addiction or alcohol treatment program
     
     
   • Persons subject to and complying with TANF work requirements
     
     
   • Adult student enrolled at least half-time in school, training, or institution of higher education
     
     
   • Persons over age 60
     
     
4. TANF and Employment Services: 
   
   
   1. TANF Time Limits – See Summary of Change VI, A, 1, and KEESM sections 1111, 1412.3, 2240, 2241, 2242, 2243, 2243.1, 2260.12, 3130.2, 3310.4, 3410, and 3220(4).
      
      Effective July 1, 2016 the TANF time limit will change from 36 months to 24 months with a possibility of an extension to 36 months if hardship status is granted.
      
      Note: The time limit policy does not affect caretaker relative cases when the caretaker is not receiving benefits for themselves.
      
      
      1. At Application
         
         All TANF applicants must be notified of the reduction in lifetime limits from 36 months to 24 months. This information will be shared during the interview and the household should be told how many TANF months they have previously used. Any family group that contains at least one adult member who has received TANF for 24 calendar months will not be eligible for TANF after 7/1/16. If an adult applicant is currently receiving SSI, but this adult has received 24 TANF months in the past, the application will be denied if the adult is part of the family group. Use code 24 on AFED and send notice A230 for denials. Enter 24 for the PRAP code next to both the program and the client.
         
         Changes are made so the system will create time limit alerts and send notices at the 12th, and 18th month beginning towards the end of July. New applications which previously received 18 or more months of TANF will get the 18 month time limit alert and notice. New cases, those approved after 7/1/16, are closed at 24 months unless a hardship is granted. New cases will not be granted the 6 month transitional period that ongoing cases will be allowed, see below.
         
         Example 1: John applies for TANF on July 24, 2016 for his family. His wife has received 26 TANF months in the past. During the interview, the 24-month time limit will be discussed and it will be explained that the family has exceeded that limit and their application will be denied. The immediate needs of the family will be discussed and appropriate community referrals will be made. The worker will process the application, deny it with the 24 code on AFED and send the A230 denial.
         
         
      2. Ongoing Cases
         
         Ongoing cases for implementation of this policy are defined as those that were open before 7/1/16 and continued to remain open until 1/31/17. If an ongoing case is closed for a reason that requires a new application, they will be treated as new applications as explained in the application section and subject to the 24 month time limit. Cases that reach their 36-month time limit in June 2016 or before will still be closed at the end of June 2016 for reaching that time limit and will not get additional months. Ongoing TANF cases with 18 or more months of TANF used in July 2016 will be allowed up to an additional 6-month transitional period ending 1/31/17, not to exceed 36 months of TANF, which will be used to notify and assist impacted recipients in preparations needed to ease their transition off of assistance. Non-hardship cases that reach 36 months after July 2016 will close after the 36th month and will not receive the full 6 month transitional period. The denial/closure code of 36 shall be used on AFED for cases closed before January 31, 2017 due to reaching the 36th month. Notice A430 or A431 (if they have Food Assistance) shall be sent. The verbiage in these notices will reflect the new 24-month time limit. Enter 36 for the PRAP code next to both the program and the client for non-hardship cases reaching 36 months after July 2016.
         
         If an ongoing case that is being allowed the six month transitional time does not cooperate with employment services then they will be closed and will not be eligible for TANF support services. If they reapply, they will be subject to the 24 month TANF time limit.
         
         Ongoing cases where the only adult is receiving SSI and is coded SS on SEPA will also be closed 1/31/17 if they had reached 36 months before they were coded SS. These cases will manually be sent a notice by DCF Administration at the end of June 2016 informing them of this upcoming closure as system generated letters will not be sent to them. If they are coded SS before the 36th months workers will keep these open if they remain eligible even if they have reached 24 TANF months. This consideration is allowed as a majority of these cases show that a hardship had been granted in the past.
         
         If a case has an adult coded SS before the 36th month is reached and the case is closed and a new application is required for any reason in the future, the case will be subject to the new application rules and will be denied if the adult has received more than 24 months TANF. This would also apply in situations where a review is not submitted in a timely manner and is treated as initial applications as defined in KEESM 9340.
         
         System generated letters (X088) will be mailed towards the end of June 2016 to all households that will be closed in January 2017 or sooner, with the exception of those currently receiving SSI with more than 36 TANF months. The notice will let them know that if their case does not have an existing hardship established before 7/1/16 and has 24 or more TANF months used by January 2017, then their TANF case will be closed by 1/31/17. Their non-hardship case may close sooner if they reach their 36th month. The notice will let them know that if their case does have an existing hardship established before 7/1/16 and has 36 or more TANF months used by January 2017, then their TANF case will be closed by 1/31/17. Their hardship case may close sooner if they reach their 48th month. They will be told in June 2016 that they can contact their local DCF office about an extension of cash benefits if they will not reach 36 months TANF assistance by January 2017 and they meet an approved hardship.
         
         System generated alerts will be created at this time for all cases that will need closed January 31, 2017. The denial/closure code of 24 shall be used on AFED for cases closed effective January 31, 2017. The denial/closure code of 24 shall be used on AFED for cases closed due to reaching the time limit after January 2017, even when hardships are granted and they have received more than 24 TANF months. Notice A430 or A431 (if they have Food Assistance) shall be sent. The verbiage in these notices will reflect the new 24-month time limit. Enter 24 for the PRAP code next to both the program and the client. I.
         
         
         1. Closure protocols for cases over 24 months:
            
            All cases will be closed 1/31/17 if they have 24 or more months of TANF used, with the exception of those granted hardship status up to 36 months.
            
            In December 2016, a report will be produced and sent to the regions with all cases which have reached 24 or more months of TANF used in January 2017. This report and the system generated alerts from July 2016 may be used to close the cases which have reached 24 months TANF, unless a hardship from 24 to 36 months was granted. After this report, the system generated alerts should be utilized.
            
            Example 2: Linda has an ongoing TANF and Food Assistance case for her family. She has 24 months of TANF used as of July 1, 2016. At the beginning of July 2016, she receives the system generated notice informing her of the changes. Her case will be eligible for the six-month transitional period. During this six-month period, she will continue working with the employment services staff to obtain employment and connect with community resources to address any outstanding needs. She does not require hardship consideration, so when staff works the report they received in December they will close her assistance January 31, 2017 using the code 24 on AFED and they will send the A431 as the family has an open Food Assistance case. The code 24 is entered on PRAP next to both the client and the program.
            
            Example 3: Darrell is the only adult in his household and has an ongoing TANF case for his family. He has 25 months of TANF used as of July 1, 2016. At the beginning of July 2016, he receives the system generated notice informing him of the changes. His case is eligible for the six-month transitional period. Darrell continued working with employment services. In November 2016, Darrell started having severe pains in his side which impacted his cooperation with employment services. His employment services worker encouraged him to go to the doctor regarding the pain. He was diagnosed with inoperable kidney cancer. At the end of November, his employment service worker determined he needed a hardship extension as he now needed to apply for social security. The hardship indicator of DS was placed on PRAP. When staff received the report in December of cases needing closed at the end of January, his case was not closed due to staff realizing the hardship was granted on the case and he only had 31 TANF months in January 2017. Darrell was able to receive SSI benefits within 3 months as his condition was deemed so serious that he obviously met disability standards. On the TANF case he was coded SS and the time limits no longer impacted the TANF case that remained open for his children as he was coded SS before reaching 36 months. When an adult is an SSI recipient receiving TANF for their children their months do not count towards the limit in Kansas (see Appendix item E-4).
            
            
         2. Closure protocols for cases that reach 36 or more months:
            
            Cases that reach 36 months will need closed at the end of the month they hit 36 months unless a hardship extension was granted before 7/1/16. If a hardship from 36 to 48 months was granted before 7/1/16, the case may continue to 1/31/17 if the hardship continues to be appropriate for the case. New hardships extending TANF months from 36 to 48 months shall not be granted after 7/1/16, but hardships may be granted extending TANF months from 24 to 36 months.
            
            All cases with more than 36 months TANF used must be closed January 31, 2017. Special attention should be paid to cases granted a hardship before 7/1/16 from 36 to 48 months. As soon as possible, Employment Services staff will utilize the A808 with these hardship cases to schedule an appointment to review the change in the time limit and discuss a plan to transition them off of assistance by January 31, 2017. Cases without a hardship should continue being closed for the 36-month time limits using A430 or A431 closure notices, which will reflect the new 24-month time limit policy.
            
            In October 2016 a report will be produced and sent to the regions of all TANF cases with more than 33 months TANF to allow staff to continue closing the cases that will be at 36 months TANF in a timely manner. A similar report will be produced in November 2016 and sent to the regions with all TANF cases which have used more than 34 months TANF.
            
            Example 4: Jessica has an ongoing TANF and Food Assistance case for her family. She has 32 months of TANF used as of July 1, 2016. At the beginning of July 2016, she receives the system generated notice informing her of the changes. Jessica receives her 36th TANF month in November 2016. She does not require hardship consideration, so staff will close her assistance November 30, 2016 using the code 36 on AFED and they will send the A431 as the family has an open Food Assistance case. Staff is aware of the need to close this case because of the time limit alerts on the system and the October 2016 report. Staff enters 36 on PRAP next to both the program and the client.
            
            Example 5: Jody has an ongoing TANF and Food Assistance case for her family. She has 37 months of TANF used as of July 1, 2016 due to a hardship extension. At the beginning of July 2016, she receives the system generated notice informing her of the changes. In the middle of July she receives the A808 indicating an appointment to review her hardship status and discuss her plan to transition off of assistance by January 31, 2017. During the meeting it is determined that she will continue the hardship through January 2017 due to a pending social security claim related to mental health issues. Jody’s employment services worker works closely with Jody’s mental health provider and legal representation for her disability claim to prepare a plan for her once TANF ends. Her case is closed January 31, 2017.
            
            

            Ongoing Case with No Hardship Chart

            Months of TANF received on 7/1/16	Close on	Reason (Used to track Changes due to New Policy)
            18	January 31, 2017	Use Denial/Closure Code 24
            19	January 31, 2017	Use Denial/Closure Code 24
            20	January 31, 2017	Use Denial/Closure Code 24
            21	January 31, 2017	Use Denial/Closure Code 24
            22	January 31, 2017	Use Denial/Closure Code 24
            23	January 31, 2017	Use Denial/Closure Code 24
            24	January 31, 2017	Use Denial/Closure Code 24
            25	January 31, 2017	Use Denial/Closure Code 24
            26	January 31, 2017	Use Denial/Closure Code 24
            27	January 31, 2017	Use Denial/Closure Code 24
            28	January 31, 2017	Use Denial/Closure Code 24
            29	January 31, 2017	Use Denial/Closure Code 24
            30	January 31, 2017	Use Denial/Closure Code 36
            31	December 31, 2016	Use Denial/Closure Code 36
            32	November 30, 2016	Use Denial/Closure Code 36
            33	October 31, 2016	Use Denial/Closure Code 36
            34	September 30, 2016	Use Denial/Closure Code 36
            35	August 31, 2016	Use Denial/Closure Code 36
            36	July 31, 2016	Use Denial/Closure Code 36

            
            
            

            Ongoing Case with Hardship Chart

            Months of TANF received on 7/1/16	Close on	Reason (Used to track Changes due to New Policy)
            30	January 31, 2017	Use Denial/Closure Code 24
            31	January 31, 2017	Use Denial/Closure Code 24
            32	January 31, 2017	Use Denial/Closure Code 24
            33	January 31, 2017	Use Denial/Closure Code 24
            34	January 31, 2017	Use Denial/Closure Code 24
            35	January 31, 2017	Use Denial/Closure Code 24
            36	January 31, 2017	Use Denial/Closure Code 24
            37	January 31, 2017	Use Denial/Closure Code 24
            38	January 31, 2017	Use Denial/Closure Code 24
            39	January 31, 2017	Use Denial/Closure Code 24
            40	January 31, 2017	Use Denial/Closure Code 24
            41	January 31, 2017	Use Denial/Closure Code 24
            42	January 31, 2017	Use Denial/Closure Code 36
            43	December 31, 2016	Use Denial/Closure Code 36
            44	November 30, 2016	Use Denial/Closure Code 36
            45	October 31, 2016	Use Denial/Closure Code 36
            46	September 30, 2016	Use Denial/Closure Code 36
            47	August 31, 2016	Use Denial/Closure Code 36
            48	July 31, 2016	Use Denial/Closure Code 36

   
   
   2. Failure to Cooperate with Fraud Investigation – See Summary of Changes V, A, 1, and KEESM sections 11221.2 and 3410.
      
      
      1. Effective July 1, 2016, when an adult fails to cooperate with a fraud investigation, there is ineligibility for all members included on the program being investigated until cooperation has been established in the fraud investigation. The worker conducting the fraud investigation will notify the purple team for the office if there is a need to take action on a specific case. This ineligibility will exist for mandatory and non-mandatory household members that are participating in the program being investigated. The worker will need to close open cases for all members on the program being investigated. Code PRAP NF (Non-cooperation with Fraud) on both the program and the person. For TANF, the non-cooperation shall also be indicated on INDA with the adults name to alert future workers of the need to cooperate before benefits may be issued. Ineligibility will result even if the non-cooperating adult is a cash excluded member, such as an SSI recipient or an ineligible non-citizen. Ineligibility is only applied to the program being investigated. If there is a fraud investigation for the child care case only and the adult does not cooperate, this will not impact an ongoing TANF case. An ongoing case can be reinstated with no proration of benefits, if the adult cooperates in the month following the month of closure. If assistance is terminated for refusal to cooperate and they reapply prior to cooperation, the application is to be denied. It is recommended that new applicants who previously failed to cooperate with a fraud investigation be allowed 10 days to cooperate prior to a denial determination, unless the applicant clearly states that they have no plans to cooperate. If they cooperate after the application has been filed and before the time limit has expired on the application, benefits are to be pro-rated from the date of application.
         
         The following notices have been created:
         
         A214 – TANF Denial, Fraud Non-Coop
         
         A419 – TANF Closure, Fraud Non-Coop
         
         A479 – TANF CLOSURE/FA Change-Fraud Non-Coop
         
         C918 - Childcare Fraud Non-Cooperation Disqualification
         
         Example 1: Joy receives child care for her 2 children. The agency received a hotline referral stating that the father of both children moved into the home six months ago. The fraud investigator looked up the driver’s license for the father and it was the same address that Joy used on her employment verification. Postmaster letters were provided showing that they both received mail at that same address. A request for income verification for the father was mailed. This verification was not provided. The agency closed the case for failure to provide, as the agency could not determine if there was a need for child care or if they were income eligible without the employment verification for the father. A closure notice, C918 was mailed informing the family of the program closure. PRAP is updated with the NF (Non-cooperation with Fraud) code next to both the program and the person. Overpayments were calculated for the past months the father appeared to have been in the home, a demand letter was mailed, and the case was referred to legal.
         
         Example 2: Helen is a grandmother who has a TANF case which includes only her 2 grandchildren. The agency received a hotline referral stating that the children’s mother is living in the home. The fraud investigator requested an interview with Helen to discuss the matter and Helen verbally refused. It was determined that she was not cooperating with the fraud investigation. The fraud investigator documented the information in the electronic file and emailed the purple team to take action. The purple team closed the TANF case for the two grandchildren because Helen refused to cooperate. A419 was mailed and PRAP was updated with NF (Non-cooperation with Fraud) code next to both the program and the person. INDA is updated with the information so that it will be easy to see if Helen reapplies for benefits.
         
         Example 3: Ralph submits an application for TANF with his 3 children on it. While interviewing Ralph, the worker finds a past journal entry indicating he had a prior non-cooperation with a fraud investigation. The worker let’s Ralph know that he will need to cooperate with the fraud investigation before he may be eligible for assistance again and give him the contact information. The worker gives Ralph 10 days to cooperate using the request for information form. All other verification is received. On the 7th day, Ralph contacts the office to notify them that he has provided the documentation that was requested in the past as part of the fraud investigation. The fraud investigator confirms that Ralph is back in cooperation with the fraud investigation and the documentation confirms that there wasn’t any fraud in the past. The worker processes the case as normal, prorating benefits back to the application date.
         
         
   3. Work Program Requirements for Applicants – See Summary of Change VII, A, 2 and 3, and KEESM sections 2121, 2251, 3100, 3100.1, 3120, 3130, &3130.2 .
      
      All TANF mandatory work program clients are now required to complete the Self-Assessment form (E-6) and the online Employment Services orientation tutorial prior to being approved for TANF unless they are exempt. A client that is enrolled in Job Corps is exempt from completing the Self-Assessment form and the online orientation tutorial. A client that requires a translator to communicate in English will be required to complete the self-assessment but will be exempt from completing the online orientation tutorial. The Self-Assessment form (E-6) can be found in the Appendix of KEESM.
      
      If the self-assessment forms and orientation certificates are not provided for all TANF mandatory work program clients on the case, the TANF application will be denied.
      
      When a client comes into the local DCF office to apply for TANF, the client will be entered on the tracker. The client will then be given a self-assessment form to complete and will be directed to a computer where they can view the orientation tutorial prior to being interviewed. The client will print the certificate of completion at the end of the orientation. The certificate will print at the front desk. The client will be interviewed after receiving the certificate. The worker will collect the self-assessment form and the orientation certificate with the application. The worker will review the self-assessment form for completion and clarify any discrepancies or inconsistencies found during the interview. The self-assessment form and the orientation certificate will be scanned to Image Now under Applications as they are eligibility requirements.
      
      Example: Jane Smith comes into the local DCF office. She tells the person at the front desk that she is applying for TANF. The client is given a self-assessment form and directed to a computer when she can view the orientation tutorial. When Jane finishes the tutorial and the self-assessment form, she returns to the front desk to pick up her certificate of completion. The worker is notified that the client is ready to be seen. The worker takes the application, the certificate of completion, and the self-assessment form from the client. The worker completes the interview and reviews the self-assessment for completion and clarifies any discrepancies found on the form.
      
      If the client requires a translator to communicate in English, the worker interviewing the client will complete the self-assessment form during the interview process with the assistance of the translator. The work program case manager will be responsible for reviewing the information from the orientation with the client within 90 days of the approval of TANF.
      
      If there are mandatory work program clients in the home that are not present at the interview, the client will be given a self-assessment form for each person and an information sheet on how to complete the online Employment Services orientation tutorial. The client will be given a request for information informing them that they have 10 days to provide the self-assessment forms and the orientation certificates. When the forms and certificates are provided, the worker will review the self-assessment forms for completion and call the client to clarify any discrepancies or inconsistencies found. The self-assessment forms and orientation certificates will be scanned to Image Now under Applications and the work program eligibility criteria will have been met.
      
      If the self-assessment forms and the certificates are not provided by the deadline, the application will be denied for failure to meet work requirements.
      
      If a TANF application is mailed to the client, it should include a self-assessment form for each mandatory work program client and an information sheet on how to complete the online Employment Services orientation tutorial.
      
      If a TANF application is mailed to or dropped off at the local office without the required self-assessment forms and orientation certificates, the self-assessment forms and an information sheet on how to complete the online Employment Services orientation tutorial will be sent by the eligibility worker. The client will be sent a request for information informing them that they have 10 days to provide the self-assessment forms and the orientation certificates. The application will be pended until all the forms and certificates are provided. When the forms and certificates are provided, the worker will review the self-assessment forms for completion and call the client to clarify any discrepancies or inconsistencies found. The self-assessment forms and orientation certificates will be scanned to Image Now under Applications and the work program eligibility criteria will have been met.
      
      If an online application is received in the local office, the self-assessment forms and an information sheet on how to complete the online Employment Services orientation tutorial will be sent by the eligibility worker. The client will be sent a request for information informing them that they have 10 days to provide the self-assessment forms and the orientation certificates. The application will be pended until all the forms and certificates are provided. When the forms and certificates are provided, the worker will review the self-assessment forms for completion and call the client to clarify any discrepancies or inconsistencies found. The self-assessment forms and orientation certificates will be scanned to Image Now under Applications and the work program eligibility criteria will have been met.
      
      If the self-assessment forms and orientation certificates are not provided for all TANF mandatory work program clients on the case, the TANF application will be denied.