59. How to keep getting food stamps (certification periods)
Food stamp recipients must “recertify” eligibility in order to keep continuously receiving food stamps. To do this, they must complete a new application before the 15th of the month when their certification period will end. [MPP § 63-504.61; 7 C.F.R. § 273.14(a); ACL 13-18.] In California, most households are on a 12-month certification period. Some households with elderly and disabled members are on 24-month certification periods. Counties cannot waive or extend the recertification period for workload or budget reasons. ACL 11-57. California received a waiver from FNS that permits the shortening of certification periods for CalFresh households at any time to align with the other programs (CalWORKs, Medi-Cal). ACL 13-08.
Notice of recertification
The food stamp office must send recipients a notice giving them a chance to reapply before their food stamps stop. [7 C.F.R. § 273.14(b)(1); MPP § 63-504.61.] For the rare situation in which someone is certified for 2 months or less, the notice of approval must also be accompanied by the “NEC” notice (notice of expiring certification. ACL 13-18. The notice must tell them [[7 C.F.R. § 273.14(b)]:
- (A) The date when their certification period ends;
- (B) The date by which they must submit an application for recertification on order to receive uninterrupted benefits ;
- (C) The consequences of failure to apply for recertification in a timely manner;
- (D) Notice of the right to receive an application form upon request and to have it accepted as long as it contains a signature and a legible name and address;
- (E) Information on alternative submission methods available to households which cannot come into the certification office or do not have an authorized representative and how to exercise these options;
- (F) The address of the office where the application must be filed;
- (G) The household’s right to request a fair hearing if the recertification is denied or if the household objects to the benefit issuance;
- (H) Notice that any household consisting only of Supplemental Security Income (SSI) applicants or recipients is entitled to apply for food stamp recertification at an office of the Social Security Administration;
- (I) Notice that failure to attend an interview may result in delay or denial of benefits; and
- (J) Notice that the household is responsible for rescheduling a missed interview and for providing required verification information.
To reapply, most applicants need an interview. All counties are now required to waive the in-person interview, unless the person wants one that way. ACL 12-26. (ACL 12-26 overrides the prior letter, implementing for limited populations and/or to recertification. See ACL 83-32 and ACL 09-62.) Whether in-person or by phone, counties can opt to provide “on demand” interviews, where clients can have the interview done any time in a 2 week (10 business day) period.
Previously, households were required (with some exceptions, below) to have a face-to-face interview at the welfare office to renew (recertify) the food stamps application. The state regulations now provide that counties may opt to waive the face-to-face interview for Quarterly Reporting households and for households with elderly or disabled household members. However, a face-to-face interview must be conducted 1) when requested by the household or the household’s authorized representative, 2) when the county determines it is necessary to verify conditions of eligibility, or 3) when the client is in the office submitting an application and wishes to complete the interview. MPP § 63-300.41.
If the face-to-face is waived, the household can have a telephone interview instead. The telephone interview would follow the procedures established in MPP § 63-300.45. Otherwise, general interview procedures would apply. (See the section of this guide about the interview process for related details.)
The county must waive the face-to-face interview if all household members are 60 or older, or disabled. MPP §63-300.42. It may waive the face-to-face (in addition to the above waiver), if coming in person would be a hardship for the household. MPP §63-300.43. If the county cannot do a telephone interview because it must verify eligibility factors, it can do a home visit; it must schedule this visit in advance with the household.MPP § 63-300.45.
As with the initial application, recipients will also need to give the food stamp office verification at recertification as well. The County request for verification must include examples of what proof will suffice and state that the county can help in gathering the verification. MPP § 63-300.37; 7 CFR §273.2(c)(5).
Breaks in assistance
If applicants reapply before the 15th day of the last month of their certification period, and remain eligible, the food stamp office must make sure that the food stamps keep coming without any break. [7 C.F.R. § 273.14(d)(2); MPP § 504.61(a).]
If the food stamp office finds that recipients continue to qualify for food stamps, it will recertify them and give them a new certification period. [MPP § 504.61(a).]
If the household submits the recertification application late (after the 15th day of the last month of the certification period), they may have a delay in getting their benefits. This could also occur if they do not turn their verification in on time or if the county does not have enough time to process the recertification before the period end. Since the county cannot issue benefits beyond the certification period, the benefits will be provided upon completion of the whole process, which may result in a break in aid. Households applying for a new certification period can get expedited (emergency) food stamps, if they qualify, because the recertification is not processed in time to avoid a break in aid. [MPP § 63-504.61(a).]