106 CMR 365.120
Determining Eligibility and Benefit Level
(A) PA households shall be allowed to apply for SNAP benefits at the same time they apply for
other assistance. However, the household's eligibility and benefit level shall be based solely on
SNAP eligibility criteria and the household shall be certified in accordance with notice,
timeliness, and procedural requirements of the SNAP regulations. If a household's intent to
apply for SNAP benefits is unclear, the worker shall determine at the interview, or in other
contact with the household, whether or not the household also wants a PA application processed
for SNAP purposes.
(1) Joint Application Form. The TAFDC application and the EAEDC application shall
contain all the information necessary to determine a household's SNAP eligibility and benefit
level. These joint applications shall also have a place for the household to indicate if it does
not wish to apply for SNAP benefits. The applicant shall not be required to fill out any
additional application form for SNAP purposes.
(2) Single Interview Requirement. The worker shall conduct a single interview at initial
application for both cash assistance and SNAP purposes. PA households shall not be
required to see a different worker or otherwise be subject to two interview requirements to
obtain the benefits of both programs. Following the interview, the application may be
processed by separate workers to determine eligibility and benefit levels for SNAP and cash
assistance. A household's eligibility for a SNAP out-of-office interview does not relieve the
household of any responsibility for a face-to-face interview for cash purposes.
(3) Verification Standard.
(a) For households applying for both cash assistance and SNAP, the verification
procedures described in 106 CMR 361.600 through 361.660 shall be followed for those
eligibility factors that are needed solely for purposes of determining the household's
eligibility for SNAP benefits. For those factors that are needed to determine eligibility
for both cash assistance and SNAP, the worker shall follow cash assistance verification
requirements. However, in no case shall the worker delay the household's SNAP benefits
if, at the end of 30 days following the date the application was filed, the applicant has
provided sufficient verification to meet the verification for SNAP purposes, even if there
is insufficient verification to meet the cash assistance verification rules.
For example, a family applies for TAFDC and SNAP. The applicant timely submits
verification of income and all other verification necessary for SNAP purposes. However,
the applicant does not prove relationship which is necessary to establish TAFDC
eligibility. In this case, the SNAP assistance shall not be delayed or denied because of
the household's failure to comply with a TAFDC eligibility requirement.
(b) A household may be denied SNAP and cash assistance at the same time (based on
the cash assistance processing standards) when all of the following conditions have been
met:
1. The Department has provided the household with a statement of required
verification and has assisted the household in obtaining verification, as necessary;
2.
The Department has informed the household of the appropriate processing
standard, in writing, at the time of the application and notified the household at the
interview of the date by which any missing verification must be provided; and
3. The household has failed to provide verification of an eligibility factor that is
required for both cash assistance and SNAP.
For example, if a family applies jointly for cash assistance and SNAP and fails
to submit income verification by the cash assistance processing date, cash assistance
and SNAP would be denied on the same day because income verification is required
for SNAP as well as for cash assistance.
If the household provides the missing verification within the initial 30-day period,
the Department must provide benefits from the date of application. If the household
does not provide the missing verification or complete the application until the second
30 days, the Department must provide benefits from the date the household
completes the application or furnishes the missing verification. If more than 60 days
has elapsed from the date of initial application, the household would have to reapply
for SNAP benefits.
(4) Timeliness Standard. The worker must make the SNAP eligibility determination in
accordance with all the timeliness standards and procedures specified in 106 CMR 361.700
through 361.960, unless the household has failed to provide verification of an eligibility
factor required for both cash assistance and SNAP benefits in accordance with 106 CMR
365.120(A)(3)(b).
(a) As a result of differences in application processing procedures and standards, the
worker may have to determine SNAP eligibility prior to determining eligibility for PA
payments. Action on the SNAP portion of the application shall not be delayed nor the
application denied on grounds that the PA determination has not been made.
(b)
Households whose PA applications are denied but who have provided all
verifications necessary to determine SNAP eligibility shall not be required to file a new
SNAP application. They shall, however, have their SNAP eligibility determined or
continued on the basis of their original joint application and any other documented
information obtained subsequent to the application that may have been used in the PA
determination and that is relevant to SNAP eligibility or level of benefits.
(B) Asset Standards for PA Households. Asset standards for PA households shall be
determined as specified in 106 CMR 363.110: Asset Eligibility Limits.
(C) Income Standards For PA Households.
(1) Countable Income. All income received by the PA household, including the cash grant,
special allowances and all other income (unless excluded in accordance with 106 CMR
363.230: Excluded Income) shall be counted in determining the household's eligibility for
SNAP benefits.
(2) Income Exclusions and Deductions. PA households will receive only the income
exclusions and deductions provided in SNAP policy. The income exclusions and deductions
allowed under cash assistance programs for the purposes of grant calculation shall not be
allowed in determining income for SNAP purposes.
(3) Special Allowances, Retroactive Lump Sum Payments and Protective Payments.
(a) Special Allowances. Special allowances, except for one-time payments (e.g., the
clothing allowance for TAFDC children) or vendor payments, are treated as countable
income. This income may be averaged over the certification period or on a variable basis
of issuance to cover the period when the allowance is received.
(b) Retroactive Lump Sum PA Payments. Retroactive lump sum payments are excluded
as income and counted as an asset in the month received. If a PA client's first payment
is delayed beyond the first month of eligibility, the retroactive portion of that check is
considered a lump sum payment. For example, if a household applies in November and
is eligible in November but receives its first check in December to cover both months,
only the December benefit amount is considered as income.
(c) Protective Payments. Protective payments are any portion of the cash grant that is
legally obligated and otherwise payable to the PA household, but diverted by the
Department to a third party for a household expense (e.g., vendor rent). Protective
payments are countable as income when determining SNAP eligibility and benefit level.