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Supplemental Nutrition Assistance Program

Letter to State Welfare Commissioners on Ensuring Food Stamp Nutrition Benefits During TANF Program Changes

January 29, 1999

Dear Commissioner:

The Administration is committed to ensuring that all eligible low-income households have access to vital Federal nutrition assistance programs such as the Food Stamp Program (Program). The Program, which provides nutrition assistance benefits to more than 19 million eligible individuals nationwide, is the cornerstone of our efforts to guarantee a healthy and nutritious diet to all low-income families. Due to welfare reform and to today’s strong economy, many households are finding employment and leaving the Temporary Assistance for Needy Families (TANF) program. We want to continue to work together to ensure that policy innovations in TANF do not inadvertently result in diminished access to nutrition assistance for those who still need assistance, including working families.

Recently we polled all State food stamp agencies to find out if they are complying with food stamp application processing regulations. We learned that most State agencies are continuing to encourage individuals to apply for food stamps even if they have been diverted from applying for TANF. They are continuing to process food stamp applications even if individuals have been denied TANF. Moreover, they are continuing to keep eligible individuals on the food stamp rolls after they have left TANF. Finally, many State agencies have taken special steps to avoid improperly denying or delaying food stamp receipt by providing special training for eligibility workers and/or sending notices to local offices reiterating the need to follow food stamp application processing regulations.

While most of the feedback has been positive, your continued cooperation with federal law will ensure that low income families have the opportunity to apply for food stamps and receive benefits to which they are entitled. We want to highlight several circumstances when State agencies need to pay particular attention to the food stamp application processing regulations.

  • Application for Benefits: Many States are diverting individuals from going on TANF rolls. Individuals may be required to engage in job search prior to filing an application for TANF. These same pre-application requirements for TANF cannot be applied to food stamps. Therefore, in these instances, it is particularly important that the State agency make sure that applicants are fully aware of their right to file an application for food stamps.
  • Processing the Application: Some States hold applications for TANF until the applicant has completed the pre-application requirements. In these circumstances, it is imperative that you continue to process the food stamp application and screen it for expedited service despite the delay in processing the TANF application.
  • Determining Eligibility: In some circumstances, an applicant may get a job during a TANF-required job search and may subsequently be denied TANF based on his or her earnings. Or, the applicant may accept a lump sum diversion payment in lieu of monthly benefits. In these circumstances, State agencies must make a separate eligibility determination for food stamps. The earnings may not be enough to make the applicant ineligible for food stamps, or may not be received until the month after the month of application, in which case the applicant may still be eligible for food stamps in the month of application. Also, the TANF diversion payment may be excludable for food stamp purposes as a one-time lump sum payment.
  • Continuing Food Stamp Benefits When TANF Benefits are Terminated: The TANF rolls are falling because many individuals are moving into the workplace. As this continues to occur, State agencies should not automatically terminate the food stamp benefits as well. In some cases, a State agency may have enough information to simply adjust the food stamp benefit amount. In others, the State agency may have enough information to terminate the food stamp benefits. However, if the State agency does not have enough information to make a determination either way, it should request additional information from the household. Some States have "exit interviews" for families leaving TANF. Since an interview is already taking place, and if the individual is willing, the State agency may want to consider doing an unscheduled food stamp recertification at this time. This would allow the State agency to explore the individual’s circumstances in depth and would save the individual from having to come in the following month for a separate food stamp interview.
As mentioned above, most State agencies have not reported any problems in these areas. However, because of the seriousness of this matter, I encourage you to review your procedures and to make sure that individuals denied, diverted from, or terminated from TANF are fully considered for food stamps and receive benefits if they are entitled.

The Food Stamp Program serves a vital role in helping families move to self-sufficiency. Welfare reform and the strong economy have enabled millions of people to enter the workforce and leave cash assistance behind. However, working poor families continue to need support after leaving the cash assistance roles. Even people working full-time at minimum wage and taking advantage of the maximum Earned Income Tax Credit may find themselves substantially below the poverty line and can benefit substantially from receiving food stamps. Food stamps can be vital to their well-being. To this end, I appreciate your continued cooperation in ensuring that these individuals have access to the Food Stamp Program.

If you have any questions, or need additional information, please call your Food and Nutrition Service Regional Administrator.

Sincerely,
/SIGNED/
Samuel Chambers, Jr.
Administrator

Identical letters sent to commissioners in all State food stamp agencies


Last modified: 11/30/2011