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PPI Intern1 - feb29fsregs_access.dod Page 35 produce proof of having made a large number of job contacts before cash assistance can be authorized, applicants likely will not, on many occasions, have submitted their proof of job contacts by the thirtieth day. If the food stamp office believes it can postpone action on the family's food stamp eligibility until it can also act on the family's TANF application, many needy households are likely to face much longer waits for food assistance. Comments should oppose the removal of this provision. F. Denials Because of Confusion Resulting from the Organization of the Rules C Prohibition on durational residency requirements. Current section 273.2(f)(1)(vi), governing the verification of residency, provides that "No durational residency requirement shall be established." Section 273.3(a) would continue to prohibit durational residency requirements. But without a cross- reference to that provision in the verification rules, it could be missed by many eligibility workers, resulting in improper denials. C Applications for Social Security numbers (SSNs). Food stamp rules require that all members of a household that will receive food stamps either have an SSN or have applied for one. 7 C.F.R. § 273.6. Current section 273.2(f)(1)(v) provides that "[a] completed SSA Form 2853 shall be considered proof of application for an SSN for a newborn infant." USDA proposes to delete this language, arguing that it duplicates section 273.6. 65 Fed. Reg. 10867. This is incorrect: section 273.6 nowhere mentions the SSA Form 2853. Comments should recommend an explicit reference to that form in one section or the other to ensure that eligible households are not denied benefits by eligibility workers that are not familiar with which SSA forms demonstrate an application for an SSN. C Joint applications. Proposed section 273.2(j)(1)(ii) states that "households that apply jointly for TANF or SSI and food stamps and whose food stamp eligibility depends on their categorical eligibility status must be issued benefits from the beginning of the period for which TANF or SSI benefits are paid or the original food stamp application date whichever is later." This is the current rule as well. Although technically sound, it raises the risk that some eligibility workers will believe that they can or should delay providing food stamps to households that qualify without regard to categorical eligibility if the household is also applying for benefits from a TANF-funded program or SSI. For these households, the eligibility worker could provide food stamps only from the date the other benefits were authorized rather than from the date of application for food stamps. With many states requiring extensive job searches and other activities prior to authorizing benefits under their TANF-funded programs, TANF benefits might not be authorized until long after the date of application. Indeed, if this policy was misapplied to persons applying jointly for food stamps and SSI disability benefits, the applicants could have to wait months to begin receiving food stamps. 35

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    "ocrText": "PPI Intern1 - feb29fsregs_access.dod\nPage 35\nproduce proof of having made a large number of job contacts before cash\nassistance can be authorized, applicants likely will not, on many occasions, have\nsubmitted their proof of job contacts by the thirtieth day. If the food stamp office\nbelieves it can postpone action on the family's food stamp eligibility until it can\nalso act on the family's TANF application, many needy households are likely to\nface much longer waits for food assistance. Comments should oppose the removal\nof this provision.\nF.\nDenials Because of Confusion Resulting from the Organization of the Rules\nC\nProhibition on durational residency requirements. Current section\n273.2(f)(1)(vi), governing the verification of residency, provides that \"No\ndurational residency requirement shall be established.\" Section 273.3(a) would\ncontinue to prohibit durational residency requirements. But without a cross-\nreference to that provision in the verification rules, it could be missed by many\neligibility workers, resulting in improper denials.\nC\nApplications for Social Security numbers (SSNs). Food stamp rules require\nthat all members of a household that will receive food stamps either have an SSN\nor have applied for one. 7 C.F.R. § 273.6. Current section 273.2(f)(1)(v)\nprovides that \"[a] completed SSA Form 2853 shall be considered proof of\napplication for an SSN for a newborn infant.\" USDA proposes to delete this\nlanguage, arguing that it duplicates section 273.6. 65 Fed. Reg. 10867. This is\nincorrect: section 273.6 nowhere mentions the SSA Form 2853. Comments\nshould recommend an explicit reference to that form in one section or the other to\nensure that eligible households are not denied benefits by eligibility workers that\nare not familiar with which SSA forms demonstrate an application for an SSN.\nC\nJoint applications. Proposed section 273.2(j)(1)(ii) states that \"households that\napply jointly for TANF or SSI and food stamps and whose food stamp eligibility\ndepends on their categorical eligibility status must be issued benefits from the\nbeginning of the period for which TANF or SSI benefits are paid or the original\nfood stamp application date whichever is later.\" This is the current rule as well.\nAlthough technically sound, it raises the risk that some eligibility workers will\nbelieve that they can or should delay providing food stamps to households that\nqualify without regard to categorical eligibility if the household is also applying\nfor benefits from a TANF-funded program or SSI. For these households, the\neligibility worker could provide food stamps only from the date the other benefits\nwere authorized rather than from the date of application for food stamps. With\nmany states requiring extensive job searches and other activities prior to\nauthorizing benefits under their TANF-funded programs, TANF benefits might not\nbe authorized until long after the date of application. Indeed, if this policy was\nmisapplied to persons applying jointly for food stamps and SSI disability benefits,\nthe applicants could have to wait months to begin receiving food stamps.\n35"
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