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reviews are not scheduled for every month, eligibility workers may call a recipient
in for a new review at the first sign of trouble in a work or training program.
Some states treat these reviews as full redeterminations, allowing eligibility
workers to make any change they see as appropriate in the household's benefits.
Tying food stamp certification periods to these reviews would effectively mean
that many households would have to reapply for food stamps every month. This
would effectively dismantle the concept of a fixed certification period during which
a household is entitled to continued receipt of benefits SO long as its circumstances
do not change.
C
Conforming food stamp certification periods to the timing of reviews of
Medicaid eligibility. At the same time states are discouraging and restricting
access to cash assistance, many are adopting eligibility procedures designed to ease
low-income families' access to Medicaid. These include long intervals between
eligibility reviews as well as simplified application forms and limited verification
requirements. To the extent that food stamp eligibility procedures remain tied to
those of cash assistance programs, food stamp participation is likely to suffer from
the effects of states' efforts to reduce their cash assistance rolls. Conversely, to
the extent that food stamp and Medicaid eligibility procedures can be coordinated,
states may be willing to apply some of their simplified Medicaid procedures to
food stamps as well.
The proposed rules, however, would delete current section 273.10(f)(3)(ii), which
allows food stamp offices to conform a household's food stamp certification
period to the interval between its required redeterminations in Medicaid. Although
this provision did not require food stamp offices to take such action and thus is
not technically necessary, comments should urge that the final rules restore this
provision. Indeed, the final rules should go further and encourage states to
conform the review schedules in the two programs by waiving any other
limitations on the length of food stamp certification periods (except for the
statutory twelve-month limit for households not composed entirely of elderly and
disabled members) where a state conforms to Medicaid practice. The final rule
also should allow for extending the food stamp certification period a reasonable
time in such cases if the Medicaid review is postponed. Comments should
therefore criticize proposed section 273.10(f)(5), which would change current
practice by prohibiting states from extending a certification period once it has
been established.
C
Allowing states to waive some face-to-face interviews for all households. One
positive feature of the proposed rules would allow states to limit face-to-face
interviews to once per year for all households, regardless of individual hardship.
Proposed section 273.2(e)(1). An increasing number of states are waiving face-to-
face interviews for Medicaid; this change brings the Food Stamp Program into
closer conformity with the other major state-administered entitlement program
serving the working poor. Comments should support giving states broad
40
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"ocrText": "PPI Intern1 feb29fsregs_access.dod\nPage 40\nreviews are not scheduled for every month, eligibility workers may call a recipient\nin for a new review at the first sign of trouble in a work or training program.\nSome states treat these reviews as full redeterminations, allowing eligibility\nworkers to make any change they see as appropriate in the household's benefits.\nTying food stamp certification periods to these reviews would effectively mean\nthat many households would have to reapply for food stamps every month. This\nwould effectively dismantle the concept of a fixed certification period during which\na household is entitled to continued receipt of benefits SO long as its circumstances\ndo not change.\nC\nConforming food stamp certification periods to the timing of reviews of\nMedicaid eligibility. At the same time states are discouraging and restricting\naccess to cash assistance, many are adopting eligibility procedures designed to ease\nlow-income families' access to Medicaid. These include long intervals between\neligibility reviews as well as simplified application forms and limited verification\nrequirements. To the extent that food stamp eligibility procedures remain tied to\nthose of cash assistance programs, food stamp participation is likely to suffer from\nthe effects of states' efforts to reduce their cash assistance rolls. Conversely, to\nthe extent that food stamp and Medicaid eligibility procedures can be coordinated,\nstates may be willing to apply some of their simplified Medicaid procedures to\nfood stamps as well.\nThe proposed rules, however, would delete current section 273.10(f)(3)(ii), which\nallows food stamp offices to conform a household's food stamp certification\nperiod to the interval between its required redeterminations in Medicaid. Although\nthis provision did not require food stamp offices to take such action and thus is\nnot technically necessary, comments should urge that the final rules restore this\nprovision. Indeed, the final rules should go further and encourage states to\nconform the review schedules in the two programs by waiving any other\nlimitations on the length of food stamp certification periods (except for the\nstatutory twelve-month limit for households not composed entirely of elderly and\ndisabled members) where a state conforms to Medicaid practice. The final rule\nalso should allow for extending the food stamp certification period a reasonable\ntime in such cases if the Medicaid review is postponed. Comments should\ntherefore criticize proposed section 273.10(f)(5), which would change current\npractice by prohibiting states from extending a certification period once it has\nbeen established.\nC\nAllowing states to waive some face-to-face interviews for all households. One\npositive feature of the proposed rules would allow states to limit face-to-face\ninterviews to once per year for all households, regardless of individual hardship.\nProposed section 273.2(e)(1). An increasing number of states are waiving face-to-\nface interviews for Medicaid; this change brings the Food Stamp Program into\ncloser conformity with the other major state-administered entitlement program\nserving the working poor. Comments should support giving states broad\n40"
}