|DATE:||June 21, 2023|
|SUBJECT:||Supplemental Nutrition Assistance Program (SNAP) – Use of Information Received from Other Public Assistance Programs|
|TO:||All SNAP State Agencies
This guidance clarifies how the Supplemental Nutrition Assistance Program (SNAP) may use information it receives from other public assistance programs that are part of the same state agency. The Food and Nutrition Service (FNS) understands there are questions regarding when this information may be used to update SNAP cases, and when additional steps are needed before making a change.
For SNAP purposes, the state agency is the organizational entity (or entities) responsible for administering SNAP, Temporary Assistance for Needy Families (TANF), and the other federally aided public assistance programs2. States must include TANF as part of the defined state agency but have discretion on which other assistance programs are included. FNS recognizes that many states include Medicaid, child support, and other human service programs as part of the defined state agency. This definition also applies to states with decentralized operations to administer programs (such as county-administered states).
Information SNAP obtains from another program within the state agency is considered verified since it has already been reviewed and used to make updates for the other program. Therefore, no further verification is required. SNAP must then evaluate the information to determine if the impact on the SNAP case is clear, or if additional information is needed to act on the change during their certification period.
If the impact is clear, the state agency must update the SNAP case in accordance with program requirements for acting on changes at 7 CFR 273.12(c). If the impact is unclear, the state agency must follow the process outlined at 7 CFR 273.12(c)(3)(i) to determine how to pursue additional clarification of household circumstances. SNAP would wait to request additional information from the household until the household’s next recertification or periodic report, if applicable, unless the information SNAP received from the other program significantly conflicts with the information it used to certify the household or is fewer than 60 days old and something the household was required to report.
FNS understands that programs within the same state agency may be unable to share information due to operational limitation. The process outlined above only applies when SNAP receives the information. Once SNAP receives the information, the state must follow 7 CFR 273.12(c) to take appropriate action.
The following examples and enclosed flowchart illustrate how to apply this policy.
SNAP and Medicaid are part of the state agency. Medicaid reviews and updates a participant’s address based on a result from the National Change of Address database. Medicaid shares this information with SNAP. SNAP considers the information verified and updates the address for SNAP purposes without further verification (as long as it is not unclear). Note: In the case of an address change, SNAP must examine potential changes in shelter costs arising from the change. Whenever a change of address is reported and shelter costs are not provided, SNAP must issue a notice to the household advising that their SNAP benefits will be recalculated without the excess shelter deduction.
The state’s TANF office receives a report of a newborn added to the household. TANF verifies the report and updates the TANF case. SNAP receives the report from TANF, and the state agency must then add the newborn to the SNAP household. This change would take effect no later than the first allotment issued 10 days after the date the information is received. Note: The state agency shall not delay the certification for or issuance of benefits to an otherwise eligible household solely to verify the Social Security number of a household member.
As with any update, the state agency should properly notate the case file for any changes made or information reviewed and held until the next certification action.
FNS recognizes that which public assistance programs are included in a state agency will vary from state to state and depend on each state’s unique systems and organizational features. Even within a state agency, sharing information across programs can be challenging and what information can be obtained by SNAP can change. It is essential to routinely review and share this policy with eligibility workers and update protocols alongside system enhancements.
As state agencies continue modernizing and further integrating programs using system and technology improvements, FNS encourages state agencies to prioritize how these efforts can streamline customer service through information sharing. These goals, as the Executive Order: Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government outlines, are key to lessening state workloads and improving program access. When done appropriately, data sharing reduces the burden on the state agency and the SNAP household by eliminating the need to report the same information to multiple programs and reduces requests for information from households. State agencies with questions should contact their respective regional office representatives.
Program Development Division
2SNAP rules define public assistance as meaning any of the following programs authorized by the Social Security Act of 1935, as amended: Old-age assistance, Temporary Assistance for Needy Families (TANF), including TANF for children of unemployed fathers, aid to the blind, aid to the permanently and totally disabled and aid to aged, blind, or disabled.