SNAP: Eligibility, Certification, and Employment and Training Provisions of the Food, Conservation and Energy Act of 2008
2017-04-04 2011-06-29 2011-07-05 2011-07-06 2011-06-21 2011-07-05 2011-07-05 2011-07-06 2011-07-05
FNS-2011-0008-0128 FNS-2011-0008-0009 FNS-2011-0008-0060 FNS-2011-0008-0067 FNS-2011-0008-0002 FNS-2011-0008-0023 FNS-2011-0008-0043 FNS-2011-0008-0065 FNS-2011-0008-0039
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https://api.regulations.gov/v4/comments/FNS-2011-0008-0128 https://api.regulations.gov/v4/comments/FNS-2011-0008-0009 https://api.regulations.gov/v4/comments/FNS-2011-0008-0060 https://api.regulations.gov/v4/comments/FNS-2011-0008-0067 https://api.regulations.gov/v4/comments/FNS-2011-0008-0002 https://api.regulations.gov/v4/comments/FNS-2011-0008-0023 https://api.regulations.gov/v4/comments/FNS-2011-0008-0043 https://api.regulations.gov/v4/comments/FNS-2011-0008-0065 https://api.regulations.gov/v4/comments/FNS-2011-0008-0039
Suzanne Gina Evelyn Charles Keith Nicole Nuria Charles Lewis
Tryan Guillemette Njoroge Goolsby Angelety Leblnac Ortiz-vargas Goolsby Scott
In regards to 273.11How should the DAA return a prorated share of the benefit to the client?  This question is two-fold:  The regulations do not require that DAAs be a SNAP retailer, they can also be authorized as a treatment facility by other means.  Indiana currently has a DAA who is authorized as a treatment facility but is not a SNAP retailer, they therefore do not have a way to debit a daily amount, nor to credit the individual with any amount upon leaving the facility.  In any case, how would a return of benefits be issued via an EBT transaction? The SNAP recipient would not be returning merchandise as one may do at a grocery store or other retailer.  How would this be processed as a credit to the individuals EBT account? Has FNS considered only allowing a prorate share to be deducted each day?  This seems to be a more effective way of managing, particularly with DAAs who are quick to withdraw all of the benefits at once.  The state agencies can set their own requirements for how this process should be carried out, however, State Agencies are not always notified when an agency is designated by FNS as a DAA.  The notification form from FNS contains information telling the DAA they can withdraw all of the funds at once from the EBT account.  (iv) If the household has already left the DAA treatment center, and as a result the treatment center is unable to refund the benefits in accordance with this paragraph, the DAA treatment center.....must effect the refund from the treatment centers bank account to the households EBT account within 5 days  How is this to occur? How would money be transferred from an agencys bank account to a clients EBT account?  What action is taken if the agency does not comply with this requirement?  How is the client refunded their SNAP benefit if the agency does not comply? Will the benefit be replaced and will FNS pursue a return of the benefit from the agency? Since the state agency, per the regulation,  the state must ensure that the EBT design or procedures for DAAs prohibit the DAA from obtaining more than one half of the households allotment prior to the 16th of the month.  Shouldnt then, the instructions for how to carry out the DAA process with state clients, be delivered by the state, and not by FNS?  It has been noted that FNS is providing info to facilities designated by FNS as DAAs. that they may debit a maximum of one months benefits, below is copied from such an FNS letter:oA maximum of 1 months benefits may be debited from a clients Electronic Benefit Transfer (EBT) card at any given time, regardless of the clients benefit balance. The center is not entitled to more than a single months food stamp benefit. The Food and Nutrition Service and the State SNAP agency will monitor EBT transaction history at your facility and you may be required to provide inventory records substantiating food purchases made with SNAP benefits. [SNAP regulations at 273.11(e)(5)(ii)(A)  (B)] On behalf of Heartland Alliance, offering comments on UDSAs proposed SNAP regulation... The USDAs proposed regulations to reform the asset limit test of the Supplemental Nutrition Assistance Program are strong and much appreciated. We worked with CFED to include these changes in the 2008 legislation and are glad to see the regulations published.  Excluding tax-preferred retirement accounts and education savings accounts from the SNAP asset limit test enables families that currently or could receive SNAP benefits to save and build wealth for the future and improve their financial security.In addition to releasing these rules, the USDA should swiftly release detailed guidance for implementing these new regulations so that state agencies and caseworkers may properly identify all tax-preferred retirement accounts and education savings accounts and avoid improperly denying eligible individuals or households.Thank you for helping low-income households become banked and build wealth.Sincerely, Evelyn Njoroge in Massachusetts).Thank you for the opportunity to comment. Please contact Larry Goolsby at (202) 682-0100 ext. 239, lgoolsby@aphsa.org, with any questions.Tracy L. WareingKathie WrightExecutive Director, APHSAPresident, AASD  I was awarded $16 a month in food stamps, just what can you purchase with .50 a day in food stamps?Why is there not a minimum of say $50 a month?How do I find out what whom or who is/are entitled to? As in a listed scale, other than the monthly income base that is on the back of the award letter.Thank you.  The federal government needs to raise the asset limit on all benefit program for the disabled including food stamps, SSI, ssdi AND medicaid, medicare to $5,700.  We need to be able to have savings and afford basic needs to 5000,7000. Many people with disabilties can only work part time and that is not enough to afford rent and basic needs to live indepently. It is hard.  Just getting a section 8 voucher is tough. Its a struggle for us to make ends meet on section 8 alone.  The USDAs proposed regulations to reform the asset limit test of the Supplemental Nutrition Assistance Program are strong and much appreciated. We worked with CFED to include these changes in the 2008 legislation and are glad to see the regulations published.  Excluding tax-preferred retirement accounts and education savings accounts from the SNAP asset limit test enables families that currently or could receive SNAP benefits to save and build wealth for the future and improve their financial security.In addition to releasing these rules, the USDA should swiftly release detailed guidance for implementing these new regulations so that state agencies and caseworkers may properly identify all tax-preferred retirement accounts and education savings accounts and avoid improperly denying eligible individuals or households.Thank you for helping low-income households become banked and build wealth.Sincerely,Nuria Y. Ortiz Vargas, Esq. July 5, 2011Lizbeth SilbermannDirectorProgram Development DivisionFood and Nutrition Service3101 Park Center Drive, Room 810Alexandria, VA 22302Dear Ms. Silbermann:Following are comments from the American Public Human Services Association in response to the proposed rule of May 4, 2011, Supplemental Nutrition Assistance Program: Eligibility, Certification, and Employment and Training Provisions. The rule would implement provisions of the Food, Conservation and Energy Act of 2008 (FCEA, the farm bill) affecting certain portions of the Supplemental Nutrition Assistance Program.Income Exclusions and Deductions: Eliminating the Cap on Dependent Care Expenses, Section 4103We have particular concerns with the allowance of transportation costs for dependent care. We agree with the allowance in principle, but believe that the great variety of possible arrangements opens the door to errors, and requires an unwarranted amount of effort by the worker.Rather than requiring states to calculate actual transportation costs on an individual basis, FNS should establish a standard amount that states may use if they choose. Alternatively, FNS could allow states to develop their own transportation standards, with FNS approval of the amount, but in either case allow states to mandate use of the standard. As with utility standards, uniform use of a standard is simple, quick, and holds little risk for error.States should be allowed to use actual expenses if they prefer, but the regulation should specify that no verification of costs is required. Rather, documentation of client-declared costs should be sufficient to establish the amount of allowance, unless verification is needed because the amount is questionable.  States should also be allowed to use a variety of activity fees.   State Options from the FCEA: Expansion of Simplified Reporting, Section 4105   Certain states have established broad-based categorical eligibility that uses higher asset limits for th PROVERBS 15-16    838   Proverb of SolomonKing JamesAmplified16:3  Committ:  thy works unto the Lord, and thy thoughts shall be established. 1h. I have a complaint against:  information in Title: Revised Medical Criteria for Evaluating Mental Disorders (886P) DENIAL OF ASSOCIATED ADMINI STRATION JUDGE FOLEY. In addition to direct payments to the care provider, we propose to permit households to deduct other out-of-pocket costs that are part of the total cost of dependent care incurred by SNAP households and necessary for the household to participate in or maintain the care arrange ment. The following types of dependent care expenses would be deductible under this proposal:Transportation costs to and from the care facility; Activity fees associated with structured care programs. Only those expenses that are separately identified, necessary to participate in the care arrangement, and not already paid by another source on behalf of the household would be deductible. Under current SNAP regulations at Sec.  273.2(f)(2) and Sec.  273.2(f)(3), State agencies may require households to verify any dependent careexpenses and must verify any questionable information.Parents Advocates J.L.S. Advocates2DCA-05-6151,Thank you for contacting the Attorney Generals Office regarding I filed a Complaint with A. S. Weiner 1a-1b-1c-1d-1e-1f-1g. Our staff will process it as soon as possible and, if nece ssary, respond appropriately. We appreciate hearing from concerned citizens such as yourself. If you wish to keep abreast of the activities of this office, you may wish to consider a subscription to our electroniThe advocate has a duty to use legal procedure for the fullest benefit of the clients cause, but also a duty not to abuse legal procedure. The law, both procedural and substantive, establishes the limits within which an advocate may proceed. However, the law is not always clear and never is static. Accordingly, in determining