M E M O R A N D U M

TO:                 EES Program Administrators

FROM:           Dr. Carla Whiteside-Hicks, PhD. - EES Director

DATE:           March 19, 2026

SUBJECT:    Implementation Instructions - KEESM Revision 126

This memo provides implementation instructions and information for the following March 30, 2026, policy changes in the Kansas Economic and Employment Services Manual (KEESM).

Effective March 30, 2026, the obligation for utility expenses must be verified at the time of initial application, review, and when a change is reported, including changes reported at Interim Report or 12-Month Report. Utility expenses include:

• Heating and/or cooling expenses
• Water/sewer/garbage (if billed separately for these expenses, they count as only one for Food Assistance purposes)
• Electricity (not used to heat or cool)
• Telephone
  

If the expense cannot be verified at the time of processing, a 10-day request must be sent to the household. If the expense verification is not provided, the agency shall determine the household’s eligibility without providing a deduction for the unverified utility expense. At initial application, if the verification of the expense may delay the household’s approval, and no other information is needed, the worker shall advise the household that eligibility and benefit level may be determined without a deduction for the claimed but unverified utility expense obligation. If the household chooses to proceed with this option, the worker must document the action, and the following standard copy and paste text must be added to the Notice of Approval:

• Your Food Assistance application was approved without utility expense(s) per your request. Expense verification can be provided at any time and added to your assistance case.
• Su solicitud de asistencia alimentaria ha sido aprobada sin incluir los gastos de servicios públicos tal y como usted solicitó. La verificación de gastos se puede proporcionar en cualquier momento y agregar a su caso de asistencia.
  

If the household has verified a portion of the utility expenses, the worker shall allow the utility allowance based on the verified expenses. If the household provides the missing verification during the certification period, the household’s benefit level will be redetermined. The household will be entitled to the restoration of any benefits lost as a result of the disallowance of the expense only if the agency failed to allow the household 10 days to verify the expense, and the individual did not request that their case be processed without the expense. Any increase in benefits shall be provided the month following the month the missing verification is provided.

Acceptable verification of utility expenses includes documentation that reasonably verifies the household is obligated to pay, such as:

• Copy of the utility bill(s) within 60 days of receipt of bill
  • Note: A copy can be pulled from the individual’s LIEAP case and imaged to the Food Assistance case.
• Collateral contact to utility vendors
• Current lease agreement specifying that utility bills are the responsibility of the client

NOTE: If eligibility for the SUA is based on receipt of a qualifying LIEAP payment that was received out of state, receipt of the LIEAP payment must be verified.

Examples:

1. The applicant reports on the application that the household is responsible for heating and cooling expenses. During the interview, the applicant is unable to provide verification, and collateral contacts are unsuccessful. A request for information is sent to the applicant, allowing 10 days to provide the information. The applicant does not provide the verification, so the benefit determination is made without allowing the utility expense.
   
   
   • Same scenario as above, but the application is expedited. The application will be processed by postponing verification of the utility expense and using client statement for the application month per KEESM 1415.3(1). If verification is provided, ongoing months are processed using the verified expense. If verification is not provided, the expense will be end-dated, and ongoing months are processed without the expense.
     
     
2. The applicant reports on the application that the household is responsible for water and telephone expenses. The applicant provides verification of the telephone expense but is not able to provide verification of the water bill and collateral contact with the city’s water department is unsuccessful. The applicant states they need benefits as soon as possible and asks if benefits can be processed today. The worker informs the applicant that the application can be processed without the expense if they would prefer. The client confirms they would like the application to be processed today without the utility expense. The application is processed with only the telephone utility allowance, and the approval notice is appended with the required standard copy and paste text. The worker informs the applicant that verification can be provided at any time, and the expense can be added to the Food Assistance case for the following month.
   
   
3. The recipient reports on the review application that the household has moved and is now responsible for the heating and cooling expenses. The worker notices that the household was previously allowed the telephone standard and asks the recipient during the interview if they can provide verification of the heating and cooling utility expense obligation. The recipient cannot provide the verification during the interview, and collateral contacts to the vendors are unsuccessful, so a request for verification is sent, allowing the household 10 days to provide the information.
   
   
   • If the household provides the information to verify the utility expenses, the review will be processed, allowing the appropriate utility standard.
   • If the recipient does not provide the information, zero utility expenses will be allowed.

4. The recipient reports on the Interim Report that, in addition to their telephone, their landlord is now requiring that they be responsible for their water bill. Collateral contact is unsuccessful, so a request for verification is sent, allowing 10 days to provide the verification.
   
   
   • If the household provides the information to verify the additional utility expense, the Interim Report will be processed allowing the appropriate utility standard.
     
     
   • If the recipient does not provide the information, only the previously verified utility expenses will be allowed.
     

5. The recipient reports no changes on the 12-Month Report form. The worker compares reported information on the 12-Month Report form to information in the eligibility system, finds no changes, and has all the information needed to process. The 12-Month Report form is processed.
   
   
6. During the certification period, a recipient reports that they now have a phone and are required to pay the bill. The recipient does not have verification of this change on hand and would need to obtain the information and provide it later. This information is unclear as it is not information that must be reported per simplified reporting requirements, and needs further information to act on the change. The worker informs the recipient that the agency can reach out to the vendor to attempt to verify the expense, but the individual states they would prefer to bring the verification themselves. The recipient is advised that they can provide verification at any time, but the expense will not be added until the agency receives the verification. The worker documents the unclear information in the journal using established procedures so that it can be properly followed up on at the Interim/12 Month Report or review. If the verification is later provided, the change will be made the month following the month the verification is received.

Q&A - available to staff only.