From: Griffin, Laura ‐ FNS Sent: Tuesday, January 29, 2019 1:41 PM To: FNS Regions  Subject: QC Q&A and waiver (revised) Importance: High 

 As we start the process of returning from the lapse in funding, there are issues that continue to be relevant for States—and in fact are quite time sensitive.  Please find attached, two items:  

Q&A document for QC questions from the States 

Blanket waiver related to February issuance and State sampling plans (referenced in the Q&A document) 

 These need to be distributed to States today.  Please let me know when they have been sent.  If you have any questions, please let us know.    Thanks,  Laura for Jessica  

January 29, 2019

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1. Is there any guidance coming soon on the January and February 2019 Quality Control (QC) Sampling process?

January 2019 cases should be reviewed following normal QC procedures at 7 CFR part 275. FNS will provide a blanket waiver to exclude the early issued February benefits from QC review. States that select their active sample frame from a list of households certified for benefits will review only the January issuance for that household if the household received both a January and February benefit in January 2019. States that select their active sample from a list of households issued benefits may have to select additional cases if under sampling occurs for January to ensure they select enough January cases in the sample. Additional information will be provided in the forthcoming memo from FNS transmitting the blanket waiver for QC review of February early issued benefits. FNS will provide further guidance on QC procedures for cases issued February benefits under current certification regulations (cases that did not receive early issued benefits for February) soon. States must still meet their minimum annual sample size as required in the SNAP regulations (7 CFR 275.11) in order to ensure the validity of fiscal year 2019 payment error rates. Thus, each State may need to oversample from upcoming months to compensate for the cases included in this waiver, in order to ensure the minimum annual sample size is met. 2. Will States be held harmless for errors made as a result of the early distribution? Will states be

held harmless for errors if a recipient’s eligibility status or benefit amount changes subsequent to the early issuance?

January 2019 cases should be reviewed following normal QC procedures. States will not be required to conduct QC reviews on the cases that received an early benefit issuance for February. FNS will provide a blanket waiver to exclude the early issued February 2019 benefits from QC review. However, States must take action to update the household’s benefit amount if it changes subsequent to the early issuance to ensure the household receives the correct benefit amount for February and in future months. If a change is made to the case that indicates that the household is entitled to an increased February benefit, the State should issue a supplement to the household. If the change indicates that the household’s February benefits require a decreased benefit, the State should make the change and follow FNS claims regulations. There will be no hold harmless period provided if these cases are sampled in a subsequent month. State are expected to continue to follow program regulations to ensure the integrity of the program. 3. We are now running into problems completing QC cases due to the shutdown of certain Federal

offices. We can’t get verification from the HHs and can’t contact any of the Federal offices affected by the shutdown. The FFY 2018 SNAP QC transmission deadline was on 01/23/19 and we have some FFY 2018 cases that still need verification from Federal sources in order to complete. What should we do about these cases?

FNS will grant an extension of the January deadline for cases that are pending verification from Federal sources and for cases pending Federal action to unlock the case for completion. The extension will allow States 15 days from the date of the issuance of this document. FNS will make any necessary changes in SNAP QCS to reflect this extension. 4. If a household that received an early issuance for February reports a status change between

January 20 and January 31 that will impact February benefits, will the State be held harmless for

January 29, 2019

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QC errors? Also, what about an expedited case that comes in after January 20th? If there is no change to the current federal government situation and the State falls outside of the 7-day approval window, will the State incur a QC error?

States will not be required to conduct QC reviews on the cases that received an early benefit issuance for February. FNS will provide a blanket waiver that will exclude the early issued February 2019 benefits from QC review. States must follow applicable regulations and guidance regarding establishing claims or issuing supplements to correct any under or over issuances provided for February. There will be no hold harmless period provided if these cases are sampled in a subsequent month. New applications eligible for expedited service should be processed under expedited timeframes. As indicated in Question 1 of our January 14th Q&A (Q&A #2), States should continue working case actions as normal. 5. With the shutdown, there was no one in the office to approve changes to the QCS system to allow

data entry to complete SNAP QC reviews that were previously entered as incomplete. My State needs someone from FNS to approve changes in SNAP QCS to allow data entry to complete SNAP QC reviews that were previously entered as incomplete. Understanding that there is not staff available to do this, can we be granted an extension of the January 23, 2018 deadline for these cases?

FNS will grant an extension of the January deadline for cases that are pending verification from Federal sources and for cases pending Federal action to unlock the case for completion. The extension will allow States 15 days from the date of the issuance of this document. FNS will make any necessary changes in SNAP QCS to reflect this extension.

6. How will the shut-down impact the FNS QC re-reviews of State QC cases? Will the States still be

given 20 days to request arbitration on federal differences? FNS will revisit and re-evaluate arbitration timelines now that we have resumed regular operations.