Other Helpful Information – Non-Compliance

1.                 Child Support (CSS) Non-Compliances

As of August 1, 2018, the communication process between CSS and EES has been automated. For detailed information on the sequence of events for this automation, see CSS NON-COMPLIANCE TIMELINES. For detailed information on how/why the CSS Non-Compliance records are created based on the Program and/or Person Status, see CREATION OF A CSS NON-COMPLIANCE.

A.  CSS NON-COMPLIANCE TIMELINES

There are two timelines for Child Support Non-Compliance creation/updates depending on when the information is received from CSS (before timely notice deadline or after). The tables below provide additional information:

CSS Non-Compliance Timeline Before Timely Notice

CSS Non-Compliance Timeline After Timely Notice

CSS Non-Compliance Timeline Before Timely Notice

Sequence of Events:

·         When CSS staff indicate a person is not cooperating or cooperating on the CADS screen in KAECSES-CSE, communication is sent to KEES via the CSS interface that evening.

·         KEES creates the non-compliance or updates the non-compliance record(s) with compliance information on the Eligibility Non-Compliance page, runs EDBC to determine appropriate eligibility, and sends notification (NOA) to the consumer (if applicable) that same evening.

CSS Non-Compliance Timeline After Timely Notice

Sequence of Events:

·         After Timely Notice, when CSS staff indicate a person is not cooperating or cooperating on the CADS screen in KAECSES-CSE, communication is sent to KEES via the CSS interface that evening.

·         KEES creates the non-compliance or updates the non-compliance record(s) with compliance information on the Eligibility Non-Compliance page that same evening, but EDBC is not run. This ensures that a reduction of benefits after timely notice is prevented.

·         The day after come up month is available, Batch EDBC runs to determine appropriate eligibility and notification (NOA) is sent to the consumer (if applicable) that same evening.

·         For Active Food Assistance cases, EDBC is always run for the month after the change was reported. If this EDBC results in a reduction of benefits, a Read Only EDBC is produced and no notification is sent to the consumer.  Batch EDBC then runs for the come up month on the next business day to allow for timely and adequate notice and the appropriate NOA is sent to the consumer.

NOTE: During this time period it is possible to not see full case action completed on a case for up to 7 days (Please reflect this timing in any communications with the consumer in order to manage their expectations, especially when the benefit is being reestablished).

B.      CREATION OF A CSS NON-COMPLIANCE

Child Support (CSS) Non-Compliance records are created differently in KEES depending on whether the Program and Person are Active vs Non-Active. See below for additional information:

TABLE A

TABLE B

EXAMPLES

TABLE A

This table contains information on data used by KEES to create the non-compliance record when the Program and Person are Active (exception Active minor parents).

NOTE: Two non-compliances are set for TANF and/or Child Care, one for each program regardless if the consumer is receiving assistance for that program. This keeps the tiered penalties in sync.

TABLE B

This table contains information on data used by KEES to create the non-compliance record when the Program and Person are not Active, or if the person is an Active minor parent.

NOTE: Two non-compliances are set for TANF and/or Child Care, one for each program.

EXAMPLES

1.       Ongoing TANF, Food Assistance, and Child Care case. CSS indicates non-cooperation on CADS on 3/5/2018. Three non-compliance records are created, one for each program. See the chart below:

The table above applies to Scenarios A, B, C, and D below:

A.      Cooperation before penalty period ends for TANF and Child Care and Food Assistance is Active:

The non-compliant person cooperates on 5/15/2018, which is prior to the end of the 3-month ineligibility period for TANF and Child Care. The updated noncompliance record is visible in KEES on 5/16/2018 as shown below:

Since Food Assistance is still Active, KEES runs EDBC for 06/2018 and the Batch EDBC results will display on the EDBC List page on 5/17/2018. A change NOA is sent if applicable.

B.      Re-application for TANF prior to penalty period ending:

The consumer submits an application for TANF and Child Care on 5/18/2018. The Eligibility Worker checks the Eligibility Non-Compliance page. The consumer has a non-compliance with an end date; therefore, staff will need to click the View button for the Eligibility Non-Compliance List page to display the non-compliance.  The Eligibility Worker sees the non-compliance period is ending 6/30/2018 and the consumer has cooperated but remains ineligible. The Eligibility Worker runs EDBC for the application month of 5/2018. The application is denied by KEES with a status reason of ‘Child Support – 1^st Penalty’.

C.       Active Food Assistance and the consumer cooperates in the same month non-cooperation is applied:

The non-compliant person cooperates on 3/19/2018, which is prior to the end of the 3-month ineligibility period for TANF and Child Care.

Since Food Assistance is still active, KEES runs EDBC for 4/2018 and 5/2018 to take timely notice and positive change into consideration.

NOTE: If the consumer reaches out to EES after the noncompliance is updated but prior to EDBC being ran by batch then staff can run EDBC, this will NOT result in a task. Batch EDBC will still run on the planned dates and if no benefit change from the user ran EDBC than no new NOA will be generated.

D.      Child Support Worker retracts initial non-cooperation:

Child Support Worker realizes on 3/8/2018 that the non-compliance was set inaccurately and needs to retract the non-compliance. CSS does not have the ability to remove a non-compliance from their system. Instead, they indicate the consumer is complying in the CSS system and a compliance date is sent to KEES. Staff should not manually update the record until the compliance date has been added to the non-compliance record in KEES. CSS will notify EES of the retraction via the local EES office inbox. Once the compliance date is in displaying on the Non-Compliance Detail page the Eligibility Worker should Remove the non-compliance for all program records and re-run EDBC for 04/2018.

2.       Ongoing Food Assistance Case. CSS indicates non-cooperation on CADS on 4/10/2018. Since TANF and Child Care are not active programs a non-tiered non-compliance record is created. See chart below:

The non-cooperating consumer submits an application for TANF and Child Care on 6/25/2018. The Eligibility worker checks the Eligibility Non-Compliance List page in KEES and sees this individual has an active non-compliance with CSS. The household is given 10 days to cooperate with child support. If the consumer does not comply then EDBC should be ran for 6/2018 and will result in a denial status reason of ‘CSS Non-Coop’.

NOTE: If the non-compliance would have occurred prior to August 1, 2018 then the worker would need to create the non-compliance records for TANF and Child Care as shown above.

3.       Application received for TANF, Child Care, and Food Assistance on 3/22/2018. This case was converted to KEES as discontinued and did not require any post conversion clean up. TANF, Child Care and Food Assistance are approved. CSS receives the referral from KEES and sees that the consumer already has a non-cooperation status on CADS. CSS sends an email to the local EES office inbox. The Eligibility Worker adds the appropriate non-compliance type and reason to KEES on the non-compliance page and runs EDBC.

NOTE: If the non-compliance occurred prior to the July 2015 mandate for Food Assistance than a non-compliance record for Food Assistance is not needed.