Final rules regarding the Food Assistance Program were published in the Federal Register on August 13, 2012. Three rules are mandated by this rule. The Food and Nutrition Service believes that it is important to standardize matching procedures to provide quality service to all applicants and participants, while ensuring that benefits are issued only to qualified individuals and households. By mandating these matches, FNS and State agencies contribute to the success and integrity of the Program, garnering public support and user confidence in the Program. Implementation of two of the rules is required by November 1, 2012. The third rule regarding eDRS, is not required to be implemented until February 13, 2013, so it will be addressed at a different time. This policy memo addresses the Prisoner Verification System and the Deceased Matching System.

1. Prisoner Verification System – This rule requires States to establish systems and take periodic action to ensure that an individual who is detained in a Federal, State or local penal, correctional, or other detention facility for more than 30 days shall not be eligible to participate in the Food Assistance Program. The rule requires states use the prisoner data received from the Social Security Administration. Kansas already matches with the Kansas Department of Corrections and that match will continue, therefore we are getting prisoner information from anyone incarcerated in Kansas. The Social Security match will give us prisoner information from all over the country. State agencies are required to match all adults18 and older against the Social Security prisoner information at application and review. Per KEESM 1434, independent verification is required prior to taking adverse action on the food assistance case.

Implementation

Ongoing cases – Starting in October 2012, EES CO will do a quarterly match of the SSA database of all adults 18> coming due for review in the next three months (November, December, January). The report will contain any hits from the SSA database showing any active food assistance recipients that show in a correctional facility with an open ended release date within the current or prior year. The report will be in Excel, will be sorted by worker ID and Region, and will be sent to the field via e-mail to the regular report distribution list. Staff processing reviews will be required to review this list and resolve any matches with second party verification at the time of the review.

To verify that the person is still in the correctional facility, a contact with the facility will be required. Staff are encouraged to use the following on-line resources because in the past contact data within the SSA databases for the prison has not been found to be current.

A master list of most states prisoner information has been gathered and is available at the following link: http://www.inmatesplus.com/. Note that not all states are included in this list and if a state is not included, a contact with the correctional facility will be needed to verify the person’s current status. In addition, county jails are NOT included in the above. A contact with the local county as listed on the report will be required.

The 6 states that do not have inmate locators yet are: Alaska, Delaware, Hawaii, Louisiana, South Dakota and Wyoming.

Also, we found that Alaska, Delaware, Hawaii, Louisiana and Wyoming use VINELink the online version of VINE (Victim Information and Notification Everyday), the National Victim Notification Network. South Dakota has a phone number on their website you can call.

There is also a Federal Bureau of Offenders website: http://www.bop.gov/locations/index.jsp

The Excel report will contain the name of the facility and necessary contact information, if the on-line information above is not helpful. These reports will continue on a quarterly basis providing matches for upcoming reviews. Also review KEESM section 1434 regarding computer matching and second party verification.

For ongoing cases, negative actions to close a case (1 person household) or to remove a member who is verified to be in a correctional facility, must be taken after third party verification. Per KEESM 1432, adequate notice is required to reduce or terminate food assistance benefits. See item (4).

Applications - Starting in October and running monthly thereafter, for new applicants, a report will be done of recent applications that that include an adult (18>) that matched SSA prisoner data and have open ended release date in the current or prior year. Because staff have up to 45 days to process an application, the October report will reflect SNAP applications submitted in August now showing approved in KAECSES. The November report will be of September SNAP applications that were approved, etc. Staff are required to review this list and verify the prisoner’s status with the correctional facility as noted above. This activity will be completed by the Purple Team for offices that have implemented the BPM process. The report will again be in Excel and sorted by worker ID and Region.

For both of the above processes, monitoring from Central Office will also be done to insure that actions are taken as appropriate as these matches are mandated by Federal food assistance regulations.

Because prisoner matching on a regular basis with SSA is a new process for Central Office, the October reports may not be available at the same time as regular monthly reports are produced due to the work effort involved in getting them ready.

2. Death Match- The rules require a match using the SSA database at application and no less frequently than every 12 months. In Kansas, we already do a monthly match with the KDHE death file, catching deaths that occur in Kansas. The SSA match will give us out-of-state deaths. The rules do not require that death match results be verified prior to approval for benefits, so the match will occur after approval. All household members will be matched. As indicated for the prisoner match, death match results have to be independently verified per KEESM 1434.

   Implementation - In addition to the KDHE death match information, every TPQY sent is a death request and every TPQY returned is a death response. The following information pulled from the KAECSES user manual describes when automatic TPQY requests are generated:

   1. When review lists are generated for the AF, FS, GA, CI, MP and MS programs, a TPQY is generated for the following individuals if a BENDEX record has not been received in the last thirteen months:
      
      
      • All individuals coded IN on SEPA for the MS and GA programs.
        
        
      • Any spouse coded DI on SEPA for the MS and GA programs.
        
        
      • Any individual who has SS or SI income on the UNIN screen for any of the above-mentioned programs.
        
        
      • Any spouse coded OU on SEPA for only the MS_HC and MS_AC programs.
        
        
   2. When an individual turns 64 years, 9 months of age, but only if no MEIN record exists for that individual. This will provide timely update on the MEIN screen as individuals become eligible for Medicare.
      
      
   3. When a program is registered on REAP for each individual coded CO or CN with an SSN, but only if no BENDEX or TPQY record has been received for that person within the last 30 days thirteen months.
      
      
   4. When an individual with an SSN is added to a case through CLIM, but only if no BENDEX or TPQY record has been received for that person within the last thirteen months.
      
      
   5. When a user completes an initial MEIN screen.
      
      
   6. When a BENDEX record is received indicating any Medicare information has changed from the previous BENDEX record.

   Staff members may initiate a manual TPQY request whenever they have a business need to see if updated information is available from SSA for an active program participant or household member. For the elderly and disabled population with 24 month review periods, a TPQY will also need to be sent manually at time of the 12 month report form.
   
   A desk aide is included with this policy memo that highlights where on the TPQY record, SDX record, and BENDEX record staff can find the death information. The desk aid can also be found on the EES Training website under Training By Topic.
   
   Most deaths of Kansas residents occur in Kansas, so we anticipate very few matches from the TPQYs that have not already been acted upon with our Kansas death match. However, federal regulations require we do the match and review results for necessary case actions. Monitoring of the death match results from the SSA database will also be done to insure that appropriate case actions are being taken.
   
   Reviewing TPQYs after approval, review and 12 month report form are the responsibility of the Purple Team in offices that have implemented the BPM process.
   
   For ongoing cases, negative actions to close a case (1 person household) or to remove a member who is verified to be in a correctional facility, must be taken after third party verification. Per KEESM 1432, adequate notice is required to reduce or terminate food assistance benefits. See item (2).