Sources of Verification 430-05-20-55-15

(Revised 06/01/15 ML3440)

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IM 5367 Use of Federal Data Services Hub (FDSH) For EA Programs

 

Acceptable sources of verification include documentary evidence, collateral contacts, home visits and system interfaces.

 

Documentary Evidence

Documentary evidence is written confirmation of a household’s circumstances and must be used as the primary source of verification for all items except residency and household size. If the household cannot obtain documentary evidence, the worker may require collateral contacts or do a scheduled home visit. Residency and household size may be verified through any other source of verification.

 

Examples:

Wage stubs, rent receipts and utility bills.

 

Acceptable verification is not limited to any single type of document and may be obtained from the household or another source.

 

Whenever documentary evidence is insufficient to make a determination of eligibility or benefit level, the worker must pend the application and request sufficient verification from the household.

 

Collateral Contacts

A collateral contact is a verbal confirmation of a household's circumstances by an individual outside the household and are used when documentary evidence is insufficient or incomplete. The collateral contact may be either in person or over the telephone. The worker must rely on the household to provide the name of any collateral contact. The household may request assistance in naming a collateral contact.

 

A collateral contact can be any third-party verification of the household's statements. The worker is responsible for obtaining verification from acceptable collateral contacts, which include but are not limited to:

 

Once the household has supplied the name of a collateral contact or has asked the worker for assistance in locating a collateral contact, the worker must promptly contact the collateral contact or otherwise assist the household in obtaining the necessary verification.

 

When the collateral contact designated by the household is unacceptable, the worker must ask the household to name another collateral contact or substitute a scheduled home visit.

 

The county should only disclose the information that is absolutely necessary to get the information being sought. The county should avoid disclosing that a household has applied for SNAP and should not disclose any information provided by the household. Counties should not suggest that a household is suspected of any wrong doing.

 

In directly contacting a collateral contact, the worker must always identify themselves by name, position and the name of the county social services office. In doing so and then inquiring about a particular client by name, the contact may be able to determine that the client is applying for assistance. This does not constitute a violation of confidentiality.

 

If the collateral contact requests information about the recipient’s status, the worker must refuse the inquiry and briefly explain the confidentiality requirements.

 

Verification obtained in non-written form must be documented in the case file.

 

Home Visits

Home visits are used on a case-by-case basis when documentary evidence or collateral contacts are insufficient or cannot be obtained. A home visit must be scheduled in advance with the household.

 

System Interfaces

Workers have access to the following interfaces that are acceptable types of verification:

When the return NUMIDENT file is processed, the following indicators display in the NUMIDENT field on Client Profile in TECS with the results of the match:

• Blank – means the information has not been sent to Social Security Administration

• I – Invalid match for social security number

• S – Sent to Social Security Administration for verification

• V – Valid match for social security number

If the indicator is ‘I’ (invalid) the SSN, name, date of birth or sex of the individual was an invalid match with the SSA information.

When the worker receives one of the following alerts, a valid or active SSN has not been provided.

• SSN Invalid

• SSA has different SSN for client, a valid SSN has not been provided.

• More than 1 SSN at SSA

The worker must send Notice F419 to the household requesting verification of a valid active social security number. If the household does not respond the case continues until review. Verification of the SSN is required at the next review.

When the worker receives one of the following alerts, information entered into TECS may be incorrect or the individuals NUMIDENT record at SSA has incorrect information

• SSN Invalid – sex does not match

• SSN Invalid – DOB does not match

• Sex & DOB do not match SSA

• Name does not match SSN

TECS may be incorrect or the individuals NUMIDENT record at SSA has incorrect information. The worker should check the information entered into TECS for accuracy. If the worker is unable to determine if the information in TECS is accurate, the worker must contact the household (via phone or F419) to determine the correct date of birth or sex and then correct the information in TECS. If the worker contacts the household by phone, the contact must be thoroughly documented in the narrative. If the worker is not able to clarify the information, it needs to be clarified as part of the next review.

Federal regulations require SNAP to match against the Office of Child Support Enforcement (OCSE), National Directory of New Hire (NDNH).

Each month a file of adults included on applications and reviews approved in the prior month will be sent to the NDNH. Individuals with employment record(s) in the prior month will be returned and used to generate a hit in TECS. Eligibility workers will receive an alert on the fourth working day of the month informing them of the hit. These hits serve as a lead for SNAP to determine if income was reported and correctly considered in determining eligibility. The hits cannot be acted on for other programs. If the verification is obtained for SNAP, the verification can be used to determine if income was reported and correctly considered for other programs.

If the employment was reported by the household and/or in the case file, the eligibility worker must ensure that the verification was used correctly in determining eligibility. If the verification is not in the case file, the following steps must be used to verify the hit.

  1. The worker must use the information provided in the hit (employer name and address) to obtain verification from the employer. If the verification is received, any necessary corrective action must be taken allowing for advance notice.
  2. If the employer fails to provide the verification within 30 days, the worker must send the F814 – Claims/Required Verification allowing the household 10 days to provide the verification. If the verification is received, any necessary corrective action must be taken allowing for advance notice.

If the case is closed and the household fails or refuses to respond to the request, the worker must document in the case file that there is an outstanding claim issue. If the household applies at a later date, the household must cooperate by providing the information necessary to calculate the claim. If the household continues to fail or refuse to provide the information, the application must be denied.

If the case is an ongoing SNAP case and the household fails or refuses to respond to the request, the worker must send the F401- Failure to Provide Information. The case will close at the end of the advance notice period. The worker must document in the case file that there is an outstanding claim issue. If the household reapplies at a later date, the household must cooperate by providing the information necessary to calculate the claim. If the household continues to fail or refuse to provide the information the application must be denied.

If the household responds and indicates they need assistance in obtaining the information, the worker must attempt to obtain the information from the appropriate source. If the appropriate source fails to respond and provide the needed verification, the worker must complete the claim based on the best information provided by the household. The worker must document the attempt to verify income, income used and how it was arrived at.

NDNH hits must be processed and entered on the NDNH Tracking Results Screen (NDTR) within 45 days of the received date on the National Directory of New Hire (NADO) screen in TECS. The appropriate fields on the NDTR screen relating to the action taken must be completed as this information is required by Federal Regulations. These fields include:

Federal regulations strictly limit the use and disclosure of information received through NDNH to purposes directly related to the administration of SNAP. NDNH information must be safeguarded and MAY NOT be released to any agency or individual, including the applicant or recipient. DO NOT print or include NDNH information in case files. Information that specifically addresses where the hit came from (OCSE NDNH) or the source of the information (employers) CANNOT be included in the:

Request for verification, notification of findings and narrative documentation may include reference to information received through a computer match.

Federal law requires that each employee be aware of the unauthorized access and disclosure of information received through a computer match from the NDNH.

The Department maintains a fully automated audit trail of information obtained through the NDNH. The audit trail will track when the alerts and hits are generated along with the completed tracking results.

The state and county social service offices must immediately report breaches of access and disclosure requirements applicable to NDNH information to:

NOTE: Disclosure means information given to another agency or individual who does not require the information to determine eligibility for SNAP.

The record must include:

Any person who knowingly and willfully violates access and disclosure requirements is subject to an administrative penalty (up to and including dismissal from employment), and a fine of $1,000 must be imposed for each act of unauthorized access to, disclosure of, or use of information in the NDNH.

Narrative/Documentation

Casefiles must be documented to support eligibility, ineligibility, and benefit level determinations. Documentation must be detailed to permit a reviewer to determine the reasonableness and accuracy of the determination.

 

Where verification was required to resolve questionable information, the worker must document why the information was considered questionable or at a minimum, indicate where the inconsistency exists, and what documentation was used to resolve the questionable information.

 

The worker must document the reason why a collateral contact or home visit was needed.

 

The worker must also document the reason a collateral contact was unacceptable and an alternate requested.

 

Good documentation habits save time. Documentation need not be lengthy and no specific format is required but it must address the following: