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piece of verification (and longer if necessary if the household is attempting to
cooperate). In addition, current section 273.2(g)(3) prohibits denying a household
until the thirtieth day after the application is filed even if the household has
received 10 days to provide a specific document. The proposed rules omit this
protection, too. The current regulation was written to curb what had been the
widespread practice of automatically denying applicants after ten days regardless
of whether they were trying to obtain the required verification. This proposed
change in the rules could pose particular problems for immigrants, who may need
more time to get certain documents from government agencies or from overseas.
3.
Rules that Apply Specifically at Recertification that would Terminate
Recipients who are Attempting to Cooperate
C
Terminating food stamps to households that are trying in good faith to
cooperate. Current section 273.14(e)(2) states that if a household files a timely
application for recertification at the end of its certification period but "fails to take
a required action" such as appearing for a scheduled interview, the food stamp
office may deny the case immediately or may wait until the end of the household's
expiring certification period or until the end of 30 days.
This already is a harsh rule that is particularly unsuited for serving the working
poor and other households with special needs whose ability to appear at interviews
or provide documents may be limited by other competing considerations. It
provides for terminating food stamps to households that may be trying in good
faith to cooperate but that are unable to do so. It also appears to conflict with 7
C.F.R. § 273.2(d)(1), which prohibits denying the applications of households that
have failed but not refused to cooperate. (Since an application for recertification is
itself an application, it is unclear which regulation would take precedence.) If the
household is not refusing to take a required action, the state should not be able to
deny the its application for recertification and terminate its food stamps until 30
days have passed and certainly not before the end of the household's current
certification period.
The proposed rules, however, would go still farther and make the rule significantly
worse. The proposed rules would create additional risks that eligible households
would be denied and lose food stamp benefits for innocent failures to meet
procedural requirements. Current section 273.14(e)(2)(iii)(A) provides that if a
food stamp office elects to send a notice of denial immediately (rather than after 30
days or at the end of the current certification period) to a household that has
submitted a timely application for recertification but failed to take some other
required action (such as making an interview or meeting a verification time frame),
the food stamp office must reinstate the household without requiring a new
application if the household takes the required action within 30 days of application.
Under these circumstances, the household would get the full amount of food
stamps to which it otherwise would be entitled. The proposed rules, however,
18
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"ocrText": "PPI Intern1 - feb29fsregs_access.doc\nPage 18\npiece of verification (and longer if necessary if the household is attempting to\ncooperate). In addition, current section 273.2(g)(3) prohibits denying a household\nuntil the thirtieth day after the application is filed even if the household has\nreceived 10 days to provide a specific document. The proposed rules omit this\nprotection, too. The current regulation was written to curb what had been the\nwidespread practice of automatically denying applicants after ten days regardless\nof whether they were trying to obtain the required verification. This proposed\nchange in the rules could pose particular problems for immigrants, who may need\nmore time to get certain documents from government agencies or from overseas.\n3.\nRules that Apply Specifically at Recertification that would Terminate\nRecipients who are Attempting to Cooperate\nC\nTerminating food stamps to households that are trying in good faith to\ncooperate. Current section 273.14(e)(2) states that if a household files a timely\napplication for recertification at the end of its certification period but \"fails to take\na required action\" such as appearing for a scheduled interview, the food stamp\noffice may deny the case immediately or may wait until the end of the household's\nexpiring certification period or until the end of 30 days.\nThis already is a harsh rule that is particularly unsuited for serving the working\npoor and other households with special needs whose ability to appear at interviews\nor provide documents may be limited by other competing considerations. It\nprovides for terminating food stamps to households that may be trying in good\nfaith to cooperate but that are unable to do so. It also appears to conflict with 7\nC.F.R. § 273.2(d)(1), which prohibits denying the applications of households that\nhave failed but not refused to cooperate. (Since an application for recertification is\nitself an application, it is unclear which regulation would take precedence.) If the\nhousehold is not refusing to take a required action, the state should not be able to\ndeny the its application for recertification and terminate its food stamps until 30\ndays have passed and certainly not before the end of the household's current\ncertification period.\nThe proposed rules, however, would go still farther and make the rule significantly\nworse. The proposed rules would create additional risks that eligible households\nwould be denied and lose food stamp benefits for innocent failures to meet\nprocedural requirements. Current section 273.14(e)(2)(iii)(A) provides that if a\nfood stamp office elects to send a notice of denial immediately (rather than after 30\ndays or at the end of the current certification period) to a household that has\nsubmitted a timely application for recertification but failed to take some other\nrequired action (such as making an interview or meeting a verification time frame),\nthe food stamp office must reinstate the household without requiring a new\napplication if the household takes the required action within 30 days of application.\nUnder these circumstances, the household would get the full amount of food\nstamps to which it otherwise would be entitled. The proposed rules, however,\n18"
}