Letter to Regions Modifying Status Reporting and Offering Quarterly
Reporting to All States
July 14 1999
Subject: FSP - Modifying the Status Reporting Waiver
and Offering the Quarterly Reporting Waiver to all State Agencies
To: Regional Administrators All Regions
As you know, Food and Nutrition Service (FNS) has been working closely
with our many partners and stakeholders to improve service to working
families. We are pleased to announce the Administration’s
approval of an Agency policy initiative which will enhance program access
for low-income working families. We are now prepared to approve
State agency requests to:
Implement a quarterly reporting system for households with earned
income, and allow quarterly reporting of unearned income for such households.
Modify the existing status reporting policy to allow 6-month certification
periods as opposed to 3-month certification periods.
Modify the existing status reporting policy to increase the reporting
threshold from $25 to $100.
As more families move from welfare to work and the proportion of the
caseload with earnings rises, we are concerned that the increased income
fluctuations put States at greater risk of food stamp QC error and make
it more difficult for States to serve working families. We believe
that a quarterly reporting system for households with earned income offers
the following advantages:
Access to nutrition assistance for working families, especially families
with children, will be improved as wage earners can obtain food stamps
without visiting the food stamp office as often.
States will be able to process changes in food stamp household circumstances
with greater accuracy and timeliness.
Households with earned income will have more clearly defined reporting
Current Food Stamp Program regulations at 7 CFR 273.12 require
certified households to report changes in the sources of income and in
the amount of gross monthly income of more than $25 dollars. As
you know, for several years we have been approving waivers of these requirements
for earned income that are in accordance with three options discussed
in the proposed rule, “Anticipating Income and Reporting Changes,”
published December 17, 1996. In addition, four States have waivers
which permit them to use a quarterly reporting system which requires households
to submit a report in the 3rd month of the quarter which is used to determine
benefits for the following quarter. Quarterly reporting, however,
is not one of the options discussed in the proposed rule. FNS stopped
approving requests for quarterly reporting in 1995 but is making this
change now to help address the barriers faced by States in serving working
State agencies that already have status reporting waivers with 3-month
certification periods can simply notify the regional office in writing
that they will be instituting 6-month certification periods for some or
all households currently covered by the waiver. Likewise, State
agencies which have implemented waivers increasing the reporting threshold
from $25 to $80, may notify the regional office that they will be further
increasing the reporting threshold to $100.
State agencies desiring to apply for a quarterly reporting waiver must
do so using the regular waiver request process. We have outlined
below the essential questions each State agency needs to answer in its
waiver request. We believe this minimal information will enable
us to respond quickly to each request, to process such requests fairly
and consistently, and to provide a uniform data base to share with State
agencies seeking technical assistance in implementing a quarterly reporting
Which households with earned income will the waiver cover?
Will the report cover earnings only or other types of income?
When will the State agency mail the report form to the household and
when should the household return it?
What will happen if the household does not timely submit the quarterly
What period of time does the quarterly report cover (e.g., just the
current month’s situation, or information from the past 2-months
and anticipated circumstances for the third)?
How does the State agency intend to determine the allotments for the
next quarter (e.g.,will they be determined prospectively based on information
reported on the quarterly report or retrospectively)?
What verification procedures will the State agency use (e.g., does
a recipient send in just the current month’s pay stubs as verification,
or pay stubs for all the months covered in the quarter)?
How, if at all, will the State agency adjust quality control procedures?
How will the State agency determine the effectiveness of the waiver?
We hope that modifying the status reporting waivers and extending the
quarterly reporting waiver will simplify reporting requirements for both
State agencies for low-income working families. In addition, this
new policy initiative demonstrates our commitment to providing State agencies
greater administrative flexibility and to harmonizing Agency policies
with effective State agency error reduction strategies.
Please work closely with your State agencies to develop their waiver
requests or modifications. If you have any questions, or need additional
information, please call Patrick Waldron of my staff at 703-305-2805.
/S/ Bonny O'Neil, for
Susan Carr Gossman
Food Stamp Program