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Alternatively, a state could use a "rolling clock" under which the 36-
month period has no set beginning or ending point. Instead, it must be recalcu-
lated constantly for each affected individual. Whenever a state seeks to determine
an individual's eligibility for a month, it must analyze the individual's eligibility
status based on his or her receipt of benefits during the 36-month period beginning
three years before the month in question. Before each month's benefits are issued,
the state must determine how many months of food stamps have been received
during the three years immediately preceding that month. If someone has already
received three countable months of food stamps during those months, he or she is
ineligible. Thus under this method, the "clock" must be recalculated each month.
Because the legislation does not define whether a "fixed" or "rolling" clock is to be used,
this is a state option, at least for the several years until USDA issues final regulations on this
point. USDA has said that "[w]hen questions address provisions which cannot be answered by
direct reference to the law or regulations, State agencies should use their best judgment."¹
1.
Administrative Advantages of a "Fixed Clock"
Although no time-keeping system can remove the heavy burden that the time limits impose
on state food stamp agencies, a "fixed clock" offers significant administrative advantages. Under
a "fixed clock, the population can be divided into one of five statuses: (1) people who have used
none of their basic three months during the period; (2) people who have used one countable
month; (3) people who have used two countable months; (4) people who have exhausted their
initial three months of eligibility but who have not yet begun to use the second three-month period
available to those who have requalified through work;¹⁶ and (5) people who have both exhausted
their initial three months' of eligibility and triggered the second three-month period. 17 At the
beginning of each 36-month period, everyone would be in the first status. As the period
progressed, people would move up sequentially from one status to the next as they used months
of benefits; whenever someone used one of the three initial months of benefits or triggered the
second period of eligibility, he or she would advance from one status to the next. Once someone
reached the final status (having exhausted both potential periods of eligibility), his or her status
could not change until the beginning of the next 36-month period.
¹⁵Memo of Arthur T. Foley, Director, Program Development Division, Food Stamp Program, FCS, USDA
(October 3, 1996).
¹⁶This fourth group would include people who have used their initial three months of eligibility and left the
program voluntarily and those who were terminated after exhausting their three months of eligibility. It also would
include those who have performed the 80 hours of work in a 30-day period (or the one month of workfare) needed
to requalify for food stamps and who may have returned to the rolls while employed or in a qualifying employment,
training, or workfare program.
Unlike the initial three months of eligibility, the second three months of eligibility must be used in consecutive
months or not at all. 7 U.S.C. §§ 2015(o)(5)(C)(i) and (ii), as added by Pub. L. 104-193, § 824(a). Therefore,
once someone has begun to use the second three-month period, the state need no longer keep track of his or her
months receiving benefits. Thus, someone in the midst of the second three-month period will be in the fifth
category until the end of the 36-month period. So will someone who uses only one or two months of this second
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"ocrText": "6\nAlternatively, a state could use a \"rolling clock\" under which the 36-\nmonth period has no set beginning or ending point. Instead, it must be recalcu-\nlated constantly for each affected individual. Whenever a state seeks to determine\nan individual's eligibility for a month, it must analyze the individual's eligibility\nstatus based on his or her receipt of benefits during the 36-month period beginning\nthree years before the month in question. Before each month's benefits are issued,\nthe state must determine how many months of food stamps have been received\nduring the three years immediately preceding that month. If someone has already\nreceived three countable months of food stamps during those months, he or she is\nineligible. Thus under this method, the \"clock\" must be recalculated each month.\nBecause the legislation does not define whether a \"fixed\" or \"rolling\" clock is to be used,\nthis is a state option, at least for the several years until USDA issues final regulations on this\npoint. USDA has said that \"[w]hen questions address provisions which cannot be answered by\ndirect reference to the law or regulations, State agencies should use their best judgment.\"¹\n1.\nAdministrative Advantages of a \"Fixed Clock\"\nAlthough no time-keeping system can remove the heavy burden that the time limits impose\non state food stamp agencies, a \"fixed clock\" offers significant administrative advantages. Under\na \"fixed clock, the population can be divided into one of five statuses: (1) people who have used\nnone of their basic three months during the period; (2) people who have used one countable\nmonth; (3) people who have used two countable months; (4) people who have exhausted their\ninitial three months of eligibility but who have not yet begun to use the second three-month period\navailable to those who have requalified through work;¹⁶ and (5) people who have both exhausted\ntheir initial three months' of eligibility and triggered the second three-month period. 17 At the\nbeginning of each 36-month period, everyone would be in the first status. As the period\nprogressed, people would move up sequentially from one status to the next as they used months\nof benefits; whenever someone used one of the three initial months of benefits or triggered the\nsecond period of eligibility, he or she would advance from one status to the next. Once someone\nreached the final status (having exhausted both potential periods of eligibility), his or her status\ncould not change until the beginning of the next 36-month period.\n¹⁵Memo of Arthur T. Foley, Director, Program Development Division, Food Stamp Program, FCS, USDA\n(October 3, 1996).\n¹⁶This fourth group would include people who have used their initial three months of eligibility and left the\nprogram voluntarily and those who were terminated after exhausting their three months of eligibility. It also would\ninclude those who have performed the 80 hours of work in a 30-day period (or the one month of workfare) needed\nto requalify for food stamps and who may have returned to the rolls while employed or in a qualifying employment,\ntraining, or workfare program.\nUnlike the initial three months of eligibility, the second three months of eligibility must be used in consecutive\nmonths or not at all. 7 U.S.C. §§ 2015(o)(5)(C)(i) and (ii), as added by Pub. L. 104-193, § 824(a). Therefore,\nonce someone has begun to use the second three-month period, the state need no longer keep track of his or her\nmonths receiving benefits. Thus, someone in the midst of the second three-month period will be in the fifth\ncategory until the end of the 36-month period. So will someone who uses only one or two months of this second"
}