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Perhaps not surprisingly, some states have begun to talk about assigning one-month
certification periods, with all of the administrative burdens that this entails, for each person
subject to the time limits.²⁰ Given the sheer number of calculations required by a "rolling clock,"
this provision is likely to be highly error-prone and to be more costly to administer.²¹
2.
Advantages of a "Fixed Clock" to Recipient
A "fixed clock" would present several advantages to recipients as well. First, it would
encourage state agencies to assign them longer (two- or three-month) certification periods. For
this population in particular, the recertification process can be burdensome. Some of these
individuals may have so little money that even the cost of travel to the food stamp office affects
their budgets. Others may have living arrangements where they cannot count on getting mail
promptly about the recertification or may otherwise become confused about their appointment.
Research has shown that substantial numbers of eligible people fall through the cracks in the
recertification process.
Second, a "fixed clock" will allow food stamp offices to tell people who have exhausted
their eligibility when they again can qualify for three months of food stamps. Under a "rolling
clock," the message often will be much more complicated: someone may qualify for one month at
one time, for another month some time later, and for a new second three-month eligibility period
at still another time. Many recipients will have difficulty following, or remembering, such intricate
instructions. Because many members of the population subject to the time limits qualify for no
other benefits administered by welfare offices, once they have been terminated from food stamps
they will have little reason to return unless they understand that they will again qualify for food
stamps.
Finally - and of particular importance - a "fixed clock" will in a substantial number of
instances allow low-income people to return to the food stamp program sooner than a "rolling
²⁰For people who have used none of their initial three months of eligibility, or for those beginning the second
three-month eligibility period, a certification period of less than three months would be inappropriate since the
individual could not lose eligibility in less than three months. Federal regulations require certification periods of at
least three months except "when the household cannot reasonably predict what its circumstances will in the near
future, or when there is a substantial likelihood of frequent and significant changes in income or household status."
7 C.F.R. § 273.10(f)(4)(ii).
21 Some people have raised questions about how terminations would work under a "fixed clock" during the first 36-
month period. This should not be a concern. Section 824(b) of the welfare law provides that, during the first three
months that the time limits are in operation, the preceding 36-month period shall be considered to begin on the
date the clock begins to operate in the state and end with the month prior to the month for which eligibility is being
determined. Thus for the first three years, a "fixed clock" and a "rolling clock" will require terminations in exactly
the same cases. As is discussed in the text, however, the "fixed clock" will be substantially easier to administer and
to automate. In addition, after the initial three years, the "rolling clock" will become much more complicated to
administer and will deny food stamps to significant numbers of people who would have qualified under a "fixed
clock." USDA concurs that there is no question that either a "fixed clock" or a "rolling clock" will require
terminations during the next three years of people who have received three months of food stamps during that time
when they were not working, in a work program, exempt or subject to a waiver.
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"ocrText": "8\nPerhaps not surprisingly, some states have begun to talk about assigning one-month\ncertification periods, with all of the administrative burdens that this entails, for each person\nsubject to the time limits.²⁰ Given the sheer number of calculations required by a \"rolling clock,\"\nthis provision is likely to be highly error-prone and to be more costly to administer.²¹\n2.\nAdvantages of a \"Fixed Clock\" to Recipient\nA \"fixed clock\" would present several advantages to recipients as well. First, it would\nencourage state agencies to assign them longer (two- or three-month) certification periods. For\nthis population in particular, the recertification process can be burdensome. Some of these\nindividuals may have so little money that even the cost of travel to the food stamp office affects\ntheir budgets. Others may have living arrangements where they cannot count on getting mail\npromptly about the recertification or may otherwise become confused about their appointment.\nResearch has shown that substantial numbers of eligible people fall through the cracks in the\nrecertification process.\nSecond, a \"fixed clock\" will allow food stamp offices to tell people who have exhausted\ntheir eligibility when they again can qualify for three months of food stamps. Under a \"rolling\nclock,\" the message often will be much more complicated: someone may qualify for one month at\none time, for another month some time later, and for a new second three-month eligibility period\nat still another time. Many recipients will have difficulty following, or remembering, such intricate\ninstructions. Because many members of the population subject to the time limits qualify for no\nother benefits administered by welfare offices, once they have been terminated from food stamps\nthey will have little reason to return unless they understand that they will again qualify for food\nstamps.\nFinally - and of particular importance - a \"fixed clock\" will in a substantial number of\ninstances allow low-income people to return to the food stamp program sooner than a \"rolling\n²⁰For people who have used none of their initial three months of eligibility, or for those beginning the second\nthree-month eligibility period, a certification period of less than three months would be inappropriate since the\nindividual could not lose eligibility in less than three months. Federal regulations require certification periods of at\nleast three months except \"when the household cannot reasonably predict what its circumstances will in the near\nfuture, or when there is a substantial likelihood of frequent and significant changes in income or household status.\"\n7 C.F.R. § 273.10(f)(4)(ii).\n21 Some people have raised questions about how terminations would work under a \"fixed clock\" during the first 36-\nmonth period. This should not be a concern. Section 824(b) of the welfare law provides that, during the first three\nmonths that the time limits are in operation, the preceding 36-month period shall be considered to begin on the\ndate the clock begins to operate in the state and end with the month prior to the month for which eligibility is being\ndetermined. Thus for the first three years, a \"fixed clock\" and a \"rolling clock\" will require terminations in exactly\nthe same cases. As is discussed in the text, however, the \"fixed clock\" will be substantially easier to administer and\nto automate. In addition, after the initial three years, the \"rolling clock\" will become much more complicated to\nadminister and will deny food stamps to significant numbers of people who would have qualified under a \"fixed\nclock.\" USDA concurs that there is no question that either a \"fixed clock\" or a \"rolling clock\" will require\nterminations during the next three years of people who have received three months of food stamps during that time\nwhen they were not working, in a work program, exempt or subject to a waiver."
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