The changes in this interim rule are primarily designed to improve Program operations and monitoring at the state and institution levels and, where possible, to streamline and simplify Program requirements for state agencies and institutions.
This memorandum is to reiterate and clarify current policy governing intentional program violations as set forth in the Food Stamp Program regulations.
The following memo represents our position on the question of whether the head of household may be held responsible for an IPV when the household member that committed the IPV cannot be determined.
The head of household may not be held "automatically" responsible for trafficking the household's benefits if there is no direct evidence identifying him/her as the guilty party. However, OGC was also supportive of holding the head of household responsible when there was sufficient circumstantial evidence to show his/her complicity in the violative act.