NARRATION, NARRATION, NARRATION!

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1 On Target Other Income on the Work Number August 2017 The work number is a great resource available to verify income. In addition to providing us with a history of the participant s income we can also see overtime, commissions, bonuses and other income that is paid out for the year. Hopefully we are familiar with overtime, bonus and commission income but what is other and how should it be addressed? AUGUST 2017 CONTRIBUTORS Catherine McDonald Dawn Myers Jeff Hodges Kris Rash Child Care Policy Analysts SNAP Policy Analysts TANF Policy Analysts Quality Control SSP Training Unit Program Management Evaluators INSIDE THIS ISSUE NARRATION, NARRATION, NARRATION! Anytime there is information that needs clarification, such as what OTH income is we should be having a conversation with the participant. We should be addressing what the other pay is for and could include the following questions. Let s start by identifying the type of income it could be. Rule out the other type of income known. State you have regular income, bonuses, overtime and commissions (if applicable). Ask what other types of payments they receive. For example you can ask: Is this for a reimbursement? Then go on to identify the frequency of this other pay: Is it received regularly? Finally, ask if they expect this pay to continue: Do you anticipate receiving this kind of pay in the future? Remember, if it isn t narrated it didn t happen. Cases and narration are reviewed by many people around the state and by federal partners, these can include: Quality Assurance, Quality Control (QC), hearings, Administrative Law Judges (ALJ) and various other entities. What may be common knowledge to you or your branch may not be common in other areas. This is why it is important to clearly narrate the conversation you had and specifically what was seen on the screen including what other etc. income was determined to be and how each of the types were addressed or excluded when calculating income, SNAP eligibility and benefit. If it is missing and the case is reviewed there errors could be cited because there is no way for the person looking at the case to determine if the income was treated and calculated correctly. A good narration addressing questionable and conflicting information is the best way you can support your eligibility decision. Other Income on the Work Number Back to School 2 New Way To Access SSP Reports I narrated the income was representative: Why is that an error? Correction to July front page Article TANF Filing Date and Interview: Denying benefits in the Initial Month and Approving in the following Month In the Weeds 4 How do we find available SNAP forms? Job Separations and TANF Eligibility

2 2 Back To School With summer coming to the end and September around the corner offices will see increase number of students applying for SNAP benefits. Higher education student who is attending school at least half time, and between 18 and 50 years old must meet additional student criteria: Be physically or mentally unfit for employment Be a paid employee working an average of at least 20 hours a week Be self-employed at least 20 hours a week and receive countable weekly earnings of at least the federal minimum wage times 20 hours (after allowable cost) Be awarded, assigned, and will perform work-study job in the current term or semester Be responsible for the care of a child in the filing group under age 6 or age 6 to 11 (must meet additional criteria de-pending on one or two parent household) A few things to keep in mind when determining eligibility for a student. A student of higher education residing in a dormitory or other living situation with meal plans is ineligible for SNAP program benefits. A new student who is registered but will not start classes the month after eligibility is determined, is not consider higher education student. This does not apply to a student who is on summer break. A student who is on summer or other school vacation break, retains a status of higher education throughout the school vacation break and will have to meet student criteria. For additional information, please go to the Family Services Manual, SNAP-E. and SNAP Tiny Training Students. New Way to Access SSP Reports On June 12, as a SSP staff member, you were given access to the SSP Business Intelligence (BI) Center. The BI Center is the new central web location for all SSP reports. We hope you ve had the opportunity to take a look at the new site and become familiar with the layout and design. Benefits of the BI Center include: All SSP staff now have access to reports which means no more inter-office distribution. Audience filters makes it easy to find exactly what s needed at every level. The Search feature allows search by key words or report names. The Home page announcements highlight new reports or other important information. SSP staff can access current and historical reports all in one location. Over the past month, OBI has continued to reports while simultaneously adding them to the BI Center. Starting August 1, OBI will discontinue ing these reports. Instead, you will begin receiving an once a week on Fridays indicating which reports you can expect to receive the following week. You can review the SSP BI Center Calendar on the home page of the BI Center. This calendar will show you the next time you can expect to see each report posted to the site. Access the SSP report home page: To share feedback or questions, please SSP.Reporting@state.or.us. Our SSP Mission is to provide a safety net, family stability and a connection to careers that guide Oregonians out of poverty.

3 I Narrated the Income was Representative: Why is that an Error? Have you ever received an error for not using a month s worth of representative income, only to look up the case and see you narrated the customer reported the income was representative? The culprit is probably the application. Scenario: Lee submits a 415F application for SNAP benefits with a DOR and Filing Date 6/0/17. On the application, he reports working 5 hours per week for Novel Idea Books and Gifts. He submits paystubs dated 6/05/17 showing 68.5 hours worked x $11 = $75.50 gross EML and 6/19/17 showing 47 hours x $11 = $517 EML and is seen for intake on 7/0/17. The worker enters the following into the narrative, under financial eligibility: Paystubs used for income verification: 6/05/17 $ /19/17 $517 = $1270.5/2 = $65.25 x 2.15 = $ EML. Customer reports income is representative and gross YTD includes all OT, commissions, shift differentials and other income. From the perspective of a reviewer or lead worker, this is an error. Why, when it includes the income calculation, addresses all income types and the worker narrated the customer said the income was representative? Because there is a discrepancy between what s reported on the application (5 hours per week) and what s showing on the paystubs (4.25 and 2.5 hours per week). This is a situation where the quality of the conversation and narration are key. Here are some questions to consider: What was different in the 6/19/17 pay period? Was Lee out sick a few days? Have his hours reduced? Since Lee reported working 5 hours per week, we need to understand why there are fewer hours showing on one of his paystubs. The 6/19/17 paystub doesn t appear representative. If his hours have not reduced, he ll need to provide an employer statement or the paystub received prior to 6/05/17, if representative, to meet the month s worth of income verification requirement. If hours have reduced, Lee will need to provide an employer statement as one paystub isn t enough to verify income. Remember, narration is important to explain your calculation. The worker can provide great customer service and avoid a pend, by calling the employer, unless the individual would rather provide an employer statement on their own, in which a pend notice would be given or mailed to the participant. The same would apply if the hours on the application are reported to be lower than those showing on the paystubs. The participant could be anticipating a reduction in work hours we need to explore, or may be picking up more hours due to a change in circumstance since completing the application. Either way, a clear narration resolving the discrepancy is needed to ensure an accurate certification and benefit amount. Correction to July s Front page Article: TANF Filing Date and Interview: Denying Benefits in the Initial Month and Approving Benefits for the Following Month Is a new application required? No. The same application can be used, but the participant must review the application for any changes and re-sign the application. The application would need to be stamped with the new filing date, and the worker would narrate how the new filing date was established using the prior application and any changes submitted. Is a new interview required before approving benefits the following month? Yes. The TANF program requires face to face appointments. Only when a documented hardship preventing the participant from attending their appointment can the intake be completed over the phone.

4 In the Weeds The legalization of Marijuana in 2014 has generated revenue, economic growth and jobs for Oregonians, including for the families that we serve. In a 2017 study commissioned by the Oregon legislature is was estimated that the industry paid out $15 million in wages to the approximate 5,776 employees working in the industry. That is a lot of employment opportunities for our participants! It also creates some unique situations to consider when processing changes when the participant reports that they have gained employment in the marijuana industry. Oregon is among many other states to legalize recreational and medical marijuana. On the Federal level marijuana remains illegal. Our programs can depend on funding from the Federal government, state government or a combination of both. Since the Federal government doesn t recognize this industry as legal our participants may not be eligible for additional benefits due to their employment in this industry. TANF is a partially federally funded program. Due to this we are not able to allow EP or JPI payments for our customers transitioning off of TANF due to employment in the marijuana industry. If you are working with a participant who has expressed interest or is working on a plan to gain employment in this industry it is good customer service to let them know that they may not be eligible for these extra payments. Providing our participants with information about programs and benefits rules and limitations empowers them to make the best decisions for their families. The SNAP program is federally funded. We have a couple areas that have generated questions. The first pertains to our participants who have gained employment in the marijuana industry and are now over income for TANF benefits. In addition to considering EP and JPI we also want to determine if the case meets the criteria for transitional benefits (TBA), this gives the family 5 months of protected eligibility where their case is basically frozen for 5 months with only the income coded on the case that was there the month TANF closed. TBA eligibility is determined based on the participant going over income for TANF, this means that a customer CAN be eligible for TBA while employed in the marijuana industry. As long as the household has met all TBA requirements they will be eligible for TBA and we can update FCAS and allow them their 5 month protected eligibility period. ABAWD has already rolled out three counties. This means that when we are considering ABAWD hours both volunteer and paid work we need to be aware of how we are going determine ABAWD eligibility when the participant is working in the marijuana industry. Let s look at some different scenarios that may come up: Question?: If a participant is bartering for marijuana in exchange for work can they be allowed credit for their hours? Answer: No, ABAWD is a federal program and marijuana is illegal at the Federal level (regardless of State legalization) Question?: The participant is working in a dispensary as an unpaid volunteer. Both the employer and the participant state that this position could result in full time employment. Can we give them BF credit for these hours? Answer: No, we cannot consider these hours as acceptable participation hours for the same reason as the above Question?: What if the participant is a paid employee of the marijuana shop but they are not working enough hours or earning enough money to be exempt? Would the hours count towards a BF step: Answer: Yes, the hours of paid employment can count towards participation. Enter the hours in the BF step. 4 How do we find available SNAP forms? This link is found in the Family Services Manual (FSM)-Snap Section (6) and staff can access any kind of form they may need! The most frequent or most commonly used forms are located at the top of the worker guide. There are different categories such as Applications, Pending s, and Client Forms. In addition, there is numerous helpful forms listed in the miscellaneous section. Worker Guide SNAP 1: Forms Used in the SNAP Program

5 5 Job Separations and TANF Eligibility Several questions have come up in the field recently about job separations and TANF eligibility. To be eligible for TANF, a caretaker relative must not be separated from employment they were hired to or worked 100 hours or more per month, due to voluntary quit or self-caused termination without good cause, in the 120 days prior to the DOR. This means a conversation with the caretaker relative is needed to determine what employment situations they had during this time and whether any of them meet the requirement to be considered. Example: Jean applies for TANF with a DOR and Filing date 7/0/17. No income is listed on the application and she has not marked the box indicating she s had a job separation in the last 0 days. She reports her rent is $550 and she paid it this month with savings, but doesn t know how she ll pay it next month. Does the worker need to explore job separation? Yes, as it s an eligibility requirement that must be addressed. The worker asks Jean when she last worked and Jean shares she left her job two months ago where she was working in a dental office 0 hours per week. This is within the 120 day prior to the DOR and the circumstances of the job separation must be considered when determining TANF eligibility. The worker asks Jean what happened with her employment and Jean shares her child care provider moved unexpectedly, leaving her without care, and she couldn t keep her job. Does Jean have good cause for the voluntary quit? Not necessarily. It depends on her unique situation, which includes her personal situation as well as that of the community. More information is needed to determine, through additional questions and community knowledge. How much child care is available in the community? How much notice did the provider give? Was anyone available to care for the children until a new provider could be found? What steps did the customer take to find a new provider? Does the child have disabilities or high needs behaviors that could impact availability of care? All of these things should be considered before making a decision on good cause, which is when a reasonable person, exercising ordinary common sense, would leave work. For caretaker relatives with disabilities, it s important to consider whether it would be reasonable, given the characteristics and qualities of the individual s reported impairments. If the answer is yes, the customer has met good cause requirements. Don t forget to NARRATE your findings, conversation with the participant and employer, etc. They didn t tell the truth about their job quit! Do I close TANF and code ESD? No. If information is received at a later time that suggests the customer didn t have good cause, the good cause determination stands. We don t reverse the decision. The worker can, however, refer to the investigations unit for follow up if they believe an eligibility requirement was reported falsely. There are some questions that can help with determining more accurate good cause determinations: What would your boss say about your employment separation? Do you believe they would give you a good reference? Do you think they would hire you again? These are just a few, but a best practice is to ask each other. You doing the work every day are the true experts and likely have additional go to questions for determining the circumstances around, and whether good cause applies, to even the most difficult to determine job separations. Remember granting good cause for employment separation doesn t remove the requirement to pursue UC. Be sure to look for valid UC claims available to our participants.