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represent an accurate picture of the household's income (such as out-dated pay
stubs) or identification papers that appear to be falsified." Current section
273.2(f)(5)(ii) contains a similar requirements.
Here again, the proposed rules are less clear. Proposed section 273.2(f)(4)
requires the food stamp office to "afford the household an opportunity to verify
the information using alternate means" before making a collateral contact. It is
unclear, however, what would constitute an "opportunity" for the household to
verify the information on its own. Comments should urge that the final rules
require that households be given at least ten days to produce a specific piece of
documentary evidence before the food stamp office resorts to a collateral contact
unless the household agrees that it is unlikely to be able to obtain documentary
verification or prefers to have the food stamp office make a collateral contact.
C
Designating the collateral contact. Since collateral contacts can compromise a
household's privacy, low-income households will naturally have a strong interest in
whom the food stamp office calls if a collateral contact is to be made. One
neighbor may be discreet; another a malicious gossip. A worker may be willing to
trust his or her immediate supervisor with the knowledge that he or she is receiving
food stamps but feel the risk of discrimination is too great if a higher-level manager
is contacted.
For this reason, the 1978 regulations forbade collateral contacts without the
household's permission (although failure to grant permission could result in a
denial of benefits if other means of verification could not be found). As amended
by the Reagan Administration, section 273.2(f)(5)(ii) currently provides:
The State agency, generally, shall rely on the household to provide the
name of any collateral contact. The household may request assistance in
designating a collateral contact. The State agency is not required to use a
collateral contact designated by the household if the collateral contact
cannot be expected to provide an accurate third-party verification. When
the collateral contact designated by the household is unacceptable, the
State agency shall either designate another collateral contact, ask the
household to designate another collateral contact or to provide an
alternative form of verification, or substitute a home visit.
This limits the food stamp office's authority to reject the household's suggestion of
a collateral contact to cases where the household's nominee is likely to be
uninformed, unreachable, or unreliable. The household thus is given the greatest
possible opportunity to limit disclosure of the fact that it has applied for public
benefits.
The proposed rules provide far weaker protection in this area. Proposed section
273.2(f)(4) allows the food stamp office to select a collateral contact if the
46
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"ocrText": "PPI Intern1 - feb29fsregs_access.dod\nPage 46\nrepresent an accurate picture of the household's income (such as out-dated pay\nstubs) or identification papers that appear to be falsified.\" Current section\n273.2(f)(5)(ii) contains a similar requirements.\nHere again, the proposed rules are less clear. Proposed section 273.2(f)(4)\nrequires the food stamp office to \"afford the household an opportunity to verify\nthe information using alternate means\" before making a collateral contact. It is\nunclear, however, what would constitute an \"opportunity\" for the household to\nverify the information on its own. Comments should urge that the final rules\nrequire that households be given at least ten days to produce a specific piece of\ndocumentary evidence before the food stamp office resorts to a collateral contact\nunless the household agrees that it is unlikely to be able to obtain documentary\nverification or prefers to have the food stamp office make a collateral contact.\nC\nDesignating the collateral contact. Since collateral contacts can compromise a\nhousehold's privacy, low-income households will naturally have a strong interest in\nwhom the food stamp office calls if a collateral contact is to be made. One\nneighbor may be discreet; another a malicious gossip. A worker may be willing to\ntrust his or her immediate supervisor with the knowledge that he or she is receiving\nfood stamps but feel the risk of discrimination is too great if a higher-level manager\nis contacted.\nFor this reason, the 1978 regulations forbade collateral contacts without the\nhousehold's permission (although failure to grant permission could result in a\ndenial of benefits if other means of verification could not be found). As amended\nby the Reagan Administration, section 273.2(f)(5)(ii) currently provides:\nThe State agency, generally, shall rely on the household to provide the\nname of any collateral contact. The household may request assistance in\ndesignating a collateral contact. The State agency is not required to use a\ncollateral contact designated by the household if the collateral contact\ncannot be expected to provide an accurate third-party verification. When\nthe collateral contact designated by the household is unacceptable, the\nState agency shall either designate another collateral contact, ask the\nhousehold to designate another collateral contact or to provide an\nalternative form of verification, or substitute a home visit.\nThis limits the food stamp office's authority to reject the household's suggestion of\na collateral contact to cases where the household's nominee is likely to be\nuninformed, unreachable, or unreliable. The household thus is given the greatest\npossible opportunity to limit disclosure of the fact that it has applied for public\nbenefits.\nThe proposed rules provide far weaker protection in this area. Proposed section\n273.2(f)(4) allows the food stamp office to select a collateral contact if the\n46"
}