SR 98-51 Dated 12/98

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SUMMARY

This SR releases policy and forms necessary to support the statewide implementation of the New HEIGHTS computer system and the Electronic Benefit Transfer (EBT) and Electronic Funds Transfer (EFT) systems. Pilot implementation of New HEIGHTS and EBT/EFT occurred in the Concord District Office catchment area beginning August 3, 1998.

 The New HEIGHTS system name is an acronym for "New Hampshire Empowering Individuals to Get Help Transitioning to Self-sufficiency." New HEIGHTS is designed to be the replacement for the Department of Health and Human Service’s (DHHS) Eligibility Management System (EMS).

 The EBT/EFT system is an entirely new concept in benefit deliverance, and will eliminate the issuance of food stamp coupons and most paper checks.

 Unlike the current paper-based issuance system, in which eligible individual recipients are mailed "hard copy" checks or coupons, EBT authorizes electronic availability for recipients to financial assistance benefits and/or food stamps from an "account" which is accessed by the client with a magnetic stripe debit card.

 Although this SR, and most client information, uses the terms "EBT accounts," EBT does not literally establish discrete accounts, like regular personal checking or savings bank accounts, in the name(s) of recipients. Rather, for all intents and purposes, it authorizes recipients, through the New HEIGHTS eligibility and benefit determination process, to access certain amounts from the Department’s account. However, for simplicity’s sake, this SR uses the terms "EBT account" throughout. From the viewpoint of the recipient, EBT will appear to function like a personal account in that access is individualized and controlled by the use of a Personal Identification Number (PIN) chosen privately by the recipient.

 EFT is the method of delivering only financial assistance benefits through a common direct deposit into the bank account of a client, Authorized Representative (AR), vendor, or provider.

Upon conversion to New HEIGHTS, EBT will be the default method of cash benefit issuance unless the casehead makes a formal request for EFT issuance. See EFT and Statewide Conversion below.

BACKGROUND

Replacement of the Eligibility Management System (EMS) with New HEIGHTS

Since its implementation on May 3, 1978, EMS has been challenged by rapidly changing program requirements as well as the introduction of new programs. EMS is both technically and functionally deficient, and faces the distinct possibility of system failure by not being year-2000 compliant. Also, in order to accommodate various program eligibility requirements, it has become necessary to implement numerous manual procedures to compensate for weaknesses in the system. New HEIGHTS has been designed to eliminate most manual procedures currently required under EMS. Policy changes included in this SR are necessary to support program enhancements or requirements which were not practical under EMS and were delayed until they could be included in New HEIGHTS.

Electronic Benefits Transfer

New Hampshire has joined the Northeast Coalition of States (NCS), which includes all of New England and New York, to implement the EBT system as the primary method of benefit issuance under New HEIGHTS. Public Law 104-193, The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996, requires all states to implement an EBT system for the issuance of food stamp benefits no later than October 1, 2002, and encourages states to implement an EBT system as soon as practicable. Federal food stamp regulations at 7 CFR 274.12 contain the detailed requirements for implementation, including the requirement to pilot test the EBT system before statewide implementation. Even though implementation is not required until October 1, 2002, the Department chose not to delay implementation of EBT in order to take advantage of the early incentive pricing structure offered to the NCS by the EBT contractor. In addition, the cost to the State of issuing EBT benefits is much less than the cost of issuing paper checks or food stamp coupons.

If a client receives both financial assistance and food stamps, two separate "accounts" will be established by the system, with access to each "account" through one card. This is required by federal food stamp regulations since EBT food stamp benefits can only be used to purchase eligible food items. Use of the EBT card is controlled by a private 4-digit personal identification number (PIN).

EBT cash assistance recipients are allowed 4 free cash withdrawals every month. Each use over and above the 4 free withdrawals will cost the recipient $0.85 per transaction. This fee is automatically debited from the EBT cash account. By law, recipients cannot be charged a fee to access EBT food stamp benefits.

Electronic Funds Transfer

EFT provides the clients with total control of their financial assistance benefits, and provides the State with a far less expensive pricing structure than either EBT or common paper forms of financial assistance benefits. At this time, client participation in EFT is voluntary, but clients who have personal bank accounts should be encouraged to use EFT as the method of benefit issuance for financial assistance only. Under New HEIGHTS, vendors, such as landlords, who receive regular disbursements from the assistance payment of a client are required to receive that payment through EFT.

Policy Changes Associated with New HEIGHTS Case Processing

Definition of "Case," "Standard Filing Unit (SFU)," and "Assistance Group (AG)"

With the advent of New HEIGHTS, the terms "case" and "assistance group" take on new meanings when described in conjunction with the "standard filing unit" concept used in New HEIGHTS.

A Case includes all those individuals who are:

 members of Assistance Groups, defined as case members determined to be potentially eligible to receive benefits together under an assistance program,

 non-members of AG's but who have some other status in an SFU (e.g., deemer),

 totally excluded from any AG or SFU but still listed as an individual in the case, or

 individuals in a case who do not actually live in the household but who are associated with the case in some way (e.g., alien sponsor, community spouse, or community dependent).

To determine or redetermine which case members are associated with specific categories of assistance within a case, New HEIGHTS uses a Standard Filing Unit subsystem. Based on the policy governing the programs of assistance for which an application is being filed, SFU’s are "built" for the case by New HEIGHTS. The SFU’s are then evaluated for eligibility and have budgets calculated by New HEIGHTS.

 The SFU includes all members of the AG and other case members whose income and/or resources and/or needs may be considered in determining the AG's eligibility and calculating the AG's benefits.

 Case members may be members of the SFU without being included in the AG. For example, in NHEP/FAP, when a parent's income is deemed to a minor parent, the minor parent and his/her child are members of both the SFU and the AG, for determination of need, but the parent is only a member of the SFU.

Definition of Interactive Interview

An interactive interview is the application process during which a department employee asks a client questions from a variety of New HEIGHTS screens, and records client answers directly into the system. Applicants at the District Office may experience two interactive interviews: Client Registration (CR), and Application Entry (AE), the actual eligibility interview conducted with a Case Technician. This is a significant change in the philosophy and practice of eligibility interviewing from the current EMS-based process, in which District Office staff review the lengthy paper application, conduct a face-to-face interview with the applicant, and then later enter the information gleaned from the application, interview, and supporting documentation into EMS. In the interactive interview concept, interviewing, data entry, and case processing are combined into one face-to-face experience.

In both interactive interviews, New HEIGHTS is programmed to "schedule" detailed screens in a logical sequence based upon the client’s answers to questions prompted by more general screens. At the conclusion of any interactive interview, New HEIGHTS produces various client documents for signature and retention in the case file, and other documents to assist the client in meeting verification requirements. Additional hard copy versions of client documents and forms may be given to the applicant before or during the interactive interview.

Interactive Interview Process - CR

The New HEIGHTS CR function is used to initiate a Request for Assistance (RFA) under certain programs of assistance administered by DHHS. Most applicants will have an interactive interview as part of the CR function. CR functions both as a screening mechanism to determine potential program eligibility and as the initial information-gathering mechanism to formally begin the application and face-to-face interview process (if required by policy). CR also assigns an official RFA number (which takes the place of the EMS "case number"). Individuals applying using the Form 800P, Application for Medical Assistance for Low Income Children and Pregnant Women, or 800Q, Application for the Qualified Medicare Beneficiary Program, are not mandated to have a face-to-face interactive interview.

At the conclusion of the CR interactive interview, but before a Filing Date is entered, the worker conducting the CR interview prints new Form 800H, HEIGHTS Application Form, from New HEIGHTS for review with the applicant.

 If the worker and the applicant determine that there are no errors or omissions of information on the Form 800H, the applicant is then instructed to sign the Form 800H.

 If the worker or the client determine that there is an error or omission of information on the Form 800H, the worker must return to the appropriate CR screen and perform the necessary data entry changes. The Form 800H is then reprinted by the worker and reviewed and signed by the applicant.

 As soon as the Form 800H has been signed, the worker must enter the Filing Date in New HEIGHTS (if this has not already been done), sign and date in the space provided, and place it in the case file. If the client requests a copy, a second copy can be printed from New HEIGHTS.

Note: Once the Filing Date is entered, the application becomes official and New HEIGHTS does not allow changes to the RFA in CR. If this occurs before the Form 800H is reviewed with the applicant and errors or omissions are detected on the Form 800H, changes to the Form 800H will be made by the worker to the hard copy document and initialed by both the client and the worker. Changes requested after Form 800H is signed and the Filing Date entered may be made by the Case Technician during the AE eligibility interview. See Interactive AE Eligibility Interview with a Case Technician below.

Early Intervention Interview (Child Support)

If case circumstances warrant an Early Intervention interview with a representative of the Division of Child Support Services (DCSS), the worker conducting the CR interview will attempt to schedule this prior to the AE interactive Eligibility Interview with a DFA Case Technician. Every attempt should be made to schedule the client for the next available DCSS Early Intervention worker in an effort to provide "same-day service."

Interactive AE Eligibility Interview with a Case Technician

Following the CR interview, most clients are required to participate in a detailed interactive AE eligibility interview with a Case Technician. In most circumstances, both CR and AE will occur in the same interview setting, presenting a "seamless" interview experience for the applicant.

 During the AE interview, Case Technicians will explore all aspects of eligibility with applicants for the programs of assistance requested. Even though New HEIGHTS identifies required fields on each screen, Case Technicians must also make every attempt to complete all pertinent optional fields.

 During the AE interview, if the client requests an additional program of assistance not requested in CR, the Case Technician must make the appropriate entry on the Program of Assistance screen in New HEIGHTS and print another Form 800H for the client’s signature. This revised Form 800H is retained in the case record along with the initial Form 800H to preserve a record of the official Filing Date of the new program of assistance.

 At the conclusion of the AE interview, New HEIGHTS produces new Form 811H, Eligibility Interview Summary. Case Technicians and applicants are required to review the Form 811H together, and applicants must also initial each item on the signature page before signing it. If the applicant or the Case Technician discovers an error or omission in the Form 811H, the Case Technician must return to the appropriate New HEIGHTS screen, enter the appropriate data and reprint the form 811H for the client to review and sign.

Case Technicians will continue to provide all other required forms and program information pamphlets as appropriate.

Alignment of Redeterminations

The redetermination schedule for households containing multiple assistance groups is aligned under New HEIGHTS so that all eligible AG’s within the case are redetermined at the same time. A redetermination is conducted for all assistance groups in the case whenever the assistance group with the most frequent redetermination schedule is required to conduct a redetermination.

EXAMPLE

An assistance group, consisting of a mother, father, and 2 children aged 8 and 11 apply for and are found eligible for food stamps for the household and "KidsCare PLUS" medical coverage for the children. One parent is employed and the other is collecting unemployment compensation. Although medical coverage is permitted a 12 month redetermination period, food stamp policy requires a certification period of no more than 4 months for this household due to the uncertain nature of the household’s income. Therefore, New HEIGHTS will align the redetermination/recertification for all programs at 4 months (or sooner, if so indicated by the Case Technician).

Minimum Assistance Payment

 Policy currently requires a $1.00 minimum financial assistance benefit to be issued to those clients who have specified that any or all of their assistance be paid to a vendor. New HEIGHTS can issue the entire benefit to a vendor, if the client chooses to do so.

 In addition, policy currently requires a $1.00 minimum semi-monthly check to be issued to those clients who have been overpaid and whose grant is being recouped for the overpayment.

 The New HEIGHTS system has been designed to issue the exact amount that the client is entitled to receive after the recoupment has been subtracted, even if it is less than $1.00.

 Under New HEIGHTS, the recoupment amount must not reduce the amount of the assistance payment to less than $0.00.

Refusal to Cooperate with Quality Control

These requirements are associated with ineligibility due to a client’s refusal to cooperate with a quality control review. Currently, clients can be found ineligible for not complying with a quality control review, but the period of ineligibility or requirements for reapplication are not clearly described in current rules or federal regulations.

 Under New HEIGHTS, refusal to cooperate with a quality control review will result in ineligibility for the assistance group in the program under review. If the assistance group’s program selected for review is Medicaid, refusal to cooperate will also result in the assistance group’s ineligibility for financial assistance. The period of ineligibility continues until the earlier of:

 The client’s compliance with the quality control review requirements; or

 The end of the federal reporting period during which the quality control review was conducted.

When the period of ineligibility has expired, the client must reapply for assistance.

Child Care Income Cost of Doing Business

The $11 per month per child cost of doing business for individuals who provide child care in their own home is eliminated under New HEIGHTS for financial or medical assistance. Cases with this income use the standard self-employment methodology for determining the cost of doing business. Some clients’ actual cost of doing business may be greater than the current $11 standard, while others may be less. As the Food Stamp program currently treats child care income as self-employment income, this change permits consistent treatment of this income across programs.

TANF Deprivation: Simplified Definition of Unemployed

Under New HEIGHTS, deprivation of parental support based on the unemployment of the principal wage earner (PWE) is determined to exist if the PWE is currently working less than 100 hours per month on average, and expects to continue working less than 100 hours per month on average, using a best estimate, regardless of initial or continuing eligibility determination. This simplified definition eliminates the determination of work hours based on initial versus continuing eligibility, whether or not the PWE worked more than 100 hours in the past 30 days but less than 100 hours in each of the past 2 calendar months, etc.

Assistance Group Composition for "Split" SSP/TANF Cases

Prior to release of this SR, applicants for or recipients of state supplement payments (SSP) -- Old Age Assistance, Aid to the Needy Blind, or Aid to the Permanently and Totally Disabled -- or related medical assistance, had their needs, income, and resources excluded from the eligibility determination of other family members applying for assistance under TANF, and vice versa.

Cases of this nature typically consist of a disabled spouse or parent applying for APTD, and a nondisabled spouse and/or children applying for TANF. Under previous policy, only the adult category spouse/parent’s income would be counted in determining that individual’s eligibility for SSP or related medical assistance. Only the TANF family members’ income would be used to determine their eligibility for money payment or TANF related medical assistance. Further, it has been DFA practice that, if the adult category spouse or parent was eligible for Medicaid In and Out, his or her needs were not counted in the related TANF case for at least one 6 month redetermination period, even if the individual never met the spenddown. Further, the individual could remain in the separate adult case so long as he or she was able to meet the spenddown the majority of the time.

Although this policy was generally beneficial to clients, the Department has been out of compliance with federal and state law, which require that the income and resources of spouses and parents be considered 100% available, spouse to spouse (for all categories) and parent to child (for TANF and TANF-related medical assistance), unless the spouse, parent, or child is receiving a financial assistance benefit under Title XVI of the Social Security Act (SSI or SSP).

Effective with this SR:

 Include all parents and children residing together in the same TANF financial or medical assistance group unless the parent or child is receiving SSI or SSP.

 Consider the income and resources of TANF spouses and parents to be 100% available, spouse to spouse and parent to child, unless the spouse, parent, or child is receiving a SSI or SSP.

 Do not include the needs, income, and resources of the TANF applicant/recipient adult in the SSP case if the two adults are not legally married.

 Include the needs, income, and resources of a parent who has applied for SSP, or has applied for or is receiving SSP related medical assistance, regardless of marital status, in the TANF assistance group, unless the parent is receiving SSI.

Note: Policy at FAM 611.04, Determining Budgetary Units for Medical Assistance Programs, has not changed when calculating individual eligibility for medical assistance. See EXAMPLE #4 below.

The following examples illustrate how the revised policy impacts eligibility.

Example #1: Spouse Financially Eligible for SSP

Dad, applying for APTD cash and medical assistance, has $300/month Social Security Disability Income (SSDI). Mom, who has $300/month unearned income, and child, are applying for TANF cash and medical assistance. There are no resources.

 While the APTD medical decision is pending, New HEIGHTS will include the Dad in the TANF cash and MA assistance group, resulting in a denial of TANF cash and the establishment of a TANF MA In and Out case. The child will be opened as a KidsCare PLUS case of 1, with both parents’ incomes counted.

 If a positive APTD medical determination is rendered on Dad, eligibility for APTD cash assistance will be recalculated, using only Dad’s income. When the APTD cash case opens, Dad will be excluded from the TANF case. If Mom reapplies for TANF cash assistance, eligibility for the Mom and Child would be determined without regard to Dad’s income, resources, or needs.

Example #2: Spouse Financially Ineligible for SSP

Mr. Green, applying for APTD cash and medical assistance, has $600/month Social Security Disability Income (SSDI). Mrs. Green, who has no income, and their child, are applying for TANF cash and medical assistance. There are no resources.

 While the APTD medical decision is pending, New HEIGHTS will include Mr. Green in the TANF cash and MA assistance group, resulting in a denial of TANF cash and the establishment of a TANF MA In and Out case for the two parents. The child will be opened in a KidsCare PLUS assistance group, with both parents’ incomes counted.

 In this example, even if OHM finds Mr. Green to be disabled, because his income is in excess of the standard of need for 1 person ($508), he is ineligible for APTD financial assistance. Therefore, his needs and income will continue to be included in the TANF and KidsCare PLUS assistance groups.

 If OHM finds him to be disabled, Mr. Green is categorically eligible for APTD. New HEIGHTS will calculate Mr. Green’s eligibility for APTD medical assistance, including the needs and income of both Mr. and Mrs. Green. Comparing assistance group income to the standard of need for two persons, Mr. Green would be determined eligible for APTD categorically-needy medical assistance.

Example #3: Previously Eligible "Split Case"

Prior to New HEIGHTS implementation, Mom, who has $700 SSDI, has been in a separate APTD-MA In and Out case because she regularly met her spenddown. Dad and child, who have no income, have been open in a TANF financial and medical assistance case. Under the revised policy, because neither spouse is receiving SSI or SSP, New HEIGHTS will recalculate eligibility by including the needs, income, and resources of both spouses in each case, resulting in the closing of the TANF financial assistance case and the establishment of

 an APTD In and Out assistance group (AG) of 2 (Mom as "eligible adult" and Dad as "counted adult"),

 a TANF In and Out AG of 2 (Mom as "counted adult," Dad as "eligible adult," and child as "excluded child"), and

 a KidsCare PLUS case AG for the child (Dad and Mom both considered "counted adults" and the child as "eligible child").

Example #4: "Split Case," Parents Not Married

Prior to New HEIGHTS implementation, Mom, who has $700 SSDI, has been in a separate APTD-MA In and Out case because she regularly met her spenddown. Dad and child, who have no income, have been open in a TANF financial and medical assistance case. Under the revised policy, because neither parent is receiving SSI or SSP, New HEIGHTS will recalculate eligibility, resulting in the closing of the TANF financial assistance case and the establishment of

1. a continuation of Mom’s APTD In and Out AG of 1, counting only her income and needs because she and Dad are not spouses, with a spenddown of $179;

2. a TANF categorically needy MA AG of 3, including both parents and the child. This attempt will "fail," since including Mom’s income puts the family in excess of the payment standard for 3 of $550. When this happens, New HEIGHTS will retry eligibility using policy in 611.04 for determination of SFU and AG size and will produce

 a KidsCare PLUS AG for the child, counting parents’ and child’s incomes;

 a TANF related MA AG of 1 for Dad, using only his income but including Mom and Child in the SFU. Because Dad has no income to count, he is eligible as TANF categorically needy MA;

 a TANF related MA AG of 1 for Mom, using only her income but including Mom and Child in the SFU. Because Mom’s income is over the PIL for 3, she is found TANF medically needy MA, with a 1 month spenddown of $48.

Note: Current policy regarding applicability of medical expenses to spenddowns has not changed. The medical bills of anyone identified by New HEIGHTS as part of the budgetary unit may be used to meet all spenddowns in the case.

Clients still retain the choice to apply for any category of assistance they wish to receive. However, due to the revised assistance group composition and deeming policy, District Offices must inform clients how the choice of category will affect their eligibility.

TANF Work Program Sanctions and Earned Income Disregards

Effective with this SR, individuals sanctioned for failure to comply with a TANF work program requirement, regardless of sanction level, will continue to receive the appropriate earned income disregard for their case. Previous policy continued the former JOBS program policy of eliminating employment-related disregards for individuals sanctioned for noncompliance. However, since sanctions for TANF are financial only (not removal of the individual from the assistance group as was the case under the JOBS program), and because the philosophy of the work program is less punitive and more supportive of work efforts, continue to allow the appropriate earned income disregard in determining financial eligibility for TANF cash or medical assistance.

Expansion of Expedited Food Stamp Delivery Timeframes from 5 to 7 days

The Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) increased the timeframes within which food stamp applicants eligible for expedited service must receive their benefits to 7 days. This change was programmed into New HEIGHTS, and was released for the Concord District Office pilot implementation in SR 98-41, retroactively effective to August, 1998. This expanded timeframe now applies to all expedited food stamp applications received in any District Office on or after the effective date of this SR.

TANF 30-day Continued Absence

Current policy requires that if 30 days of continuous parental absence has not been verified by the time of the initial eligibility interview, but is anticipated, assistance is granted if all other eligibility factors are met. Policy further states that the first assistance payment must be directed to the District Office to allow time to verify that the 30-day requirement has been met.

Under New HEIGHTS and EBT/EFT, directing the initial benefit to the D.O. is no longer necessary. New HEIGHTS will not issue a benefit until the proper entry has been made on the appropriate New HEIGHTS screen indicating that the requirement for 30 days of parental absence has been met. Once this entry has been made, the New HEIGHTS Benefit Issuance function will process the assistance payment during the overnight batch run. The client must be informed that if EBT is their method of benefit issuance, the benefit will be available on the next day. If EFT is the method of benefit issuance, an additional day is required to process the benefit transaction with the client’s bank.

EXAMPLE

Mary Smith applies for NHEP cash assistance on August 12 and provides all verifications except Form 773 certifying 30 days of continuous absence of her child’s father. She signs Form 773 on September 2. Although otherwise eligible for a cash assistance benefit on August 30th, New HEIGHTS will not issue that benefit because the 30 days of continuous absence requirement has not been met.

On September 2, the Case Technician enters the absent parent verification information into New HEIGHTS. New HEIGHTS Benefit Issuance processes the information on the night of September 2, and Mary’s cash assistance benefit for the payroll period August 16 to August 30 is made available to her via EBT on September 3.

Electronic Benefit Transfer (EBT)

Primary Method of Benefit Issuance

Effective with this SR, EBT is the primary issuance method for financial assistance and food stamp benefits statewide.

Exceptions:

 EBT is not the method of issuance for nursing facility clients who receive a supplemental payment for a personal needs allowance. Nursing facility clients will continue to receive that payment in the form of a check, unless EFT is requested by the client or AR.

 Other individuals or client representative agencies, such as Conservators, Legal Guardians, representatives of the Office of Public Guardian, or individuals with disabilities that affect their ability to use EBT, may need to receive checks based on special or unusual circumstances. Decisions on these circumstances will be made on a case-by-case basis in consultation with DFA State Office.

Benefit Issuance Dates

 EBT financial assistance will be issued on the 15th and the 30th each month, even if the payroll date occurs on a weekend or holiday.

Exception: For the 12/15/98 payroll only, benefits will be available in the EBT account on Monday, December 16, 1998.

 Monthly EBT food stamp benefit allotments will be available on the 5th of each month, beginning with the January, 1999 major run.

Exception: Food stamp cases opened or reopened on or after the December 1 or December 7, 1998, statewide implementation dates will receive December benefits via EBT. Food stamp cases open at the time of the statewide conversion from EMS will receive December food stamp benefits in coupon form, and their first EBT issuance in the January, 1999 major run.

 EFT financial assistance and paper checks follow the same issuance dates currently used for checks. If the 15th or the 30th of the month, or the last day of February, falls on a weekend or a holiday, EFT payments or checks are issued on the preceding state business day.

EBT Card Activation

Clients control the use of the EBT by the 4-digit PIN.

 Individuals served by the eleven non-pilot District Offices who are open and receiving financial assistance or food stamp benefits prior to the 11/13/98 EMS card issuance pre-conversion run will be mailed an EBT card and pre-assigned PIN in separate mailings on December 4, 1998 and December 7, 1998 respectively.

 Recipients who have already received an EBT card and pre-assigned PIN in the mail must come to the District Office to change the pre-assigned PIN. Existing AR’s who currently receive the client’s benefits will also receive an EBT card and PIN as part of the conversion.

 Applicants determined eligible after the 11/13/98 EMS card issuance pre-conversion run will not be mailed an EBT card. These individuals must come to the District Office to pick up the EBT card and activate it by selecting a PIN of their own choosing. District offices will be given a report of all cases opened after the pre-conversion EMS run, but before conversion to New HEIGHTS. These clients will be notified that they must come to the District Office for card pick-up and activation.

Exception: If the client is homebound and unable to come into the District Office for EBT card pick-up and PIN activation, District Office EBT staff must contact the Bureau of Data Management for a Control Number for PIN activation over the telephone. In this instance, the client calls the EBT customer service center at 1-888-997-9777, provides the Control Number and activates the card by selecting a PIN over the telephone.

Note: Individuals involved in the determination of eligibility, including Case Technicians and DFA Supervisors, are prohibited by federal regulations from assisting clients in the EBT card activation and PIN selection process. The system has been designed only to allow support staff to perform this function.

Authorized Representatives and EBT

Applicants and recipients may choose an AR to assist in the EBT process by so designating on revised Form 778, Authorized Representative Declaration. Specifically, AR’s may be designated to receive and access benefits on behalf of the recipient by obtaining and activating their own EBT card, or to obtain the EBT card for the recipient but convey the card to the recipient for activation. In both AR situations, the PIN is the controlling factor.

 A client or AR obtaining an EBT card at the District Office must present proof of identity before being given the EBT card.

 An AR designated to receive benefits on behalf of the recipient must obtain his or her own EBT card at the District Office and select his or her own PIN.

 The client may also permit the AR to perform the card activation at the District Office with the PIN provided by the client to the AR.

Note: Although it is a recipient’s right to choose an AR for this purpose, this practice should be discouraged whenever possible, as it contains the potential for AR abuse. Recipients must be advised that any funds misused by AR’s will not be replaced (see Replacement of EBT Benefits below).

Deactivation and Return of EBT Benefits from Unused EBT Accounts

Case Technicians must advise the client at the initial eligibility interview and at each redetermination that if the EBT card is not used for a period of 90 days, any financial assistance or food stamp benefits remaining in the EBT account will be removed from the EBT account and no longer available for spending. No Advance Notice Period (ANP) is required. In the client information brochure Form NCSNH0118, EBT: How To Use Your EBT Card to Get Your Food Stamp and/or Cash Benefits, clients are also notified of this policy.

Exception: If the client requests that their food stamp benefits be returned to their EBT account within 270 days of account inactivity, the benefits are re-deposited. However, financial assistance will not be returned after the first 90 days of account inactivity.

Replacement of EBT Benefits

Case Technicians must advise the client at the initial eligibility interview and at each redetermination that the client is responsible for the security of the EBT card and that EBT benefits will not be replaced if:

 The EBT card is used by an unauthorized individual anytime after it has been activated at the District Office; or

 The client or AR has already used the EBT card to access the EBT cash or food stamp account.

Exception: Any EBT benefits lost due to unauthorized use of the EBT card must be replaced if both the EBT card and PIN were mailed to the client as part of the statewide implementation and caseload conversion mail-out, and reported as never received. Case Technicians should also advise clients not to keep their EBT card and PIN together, and not to write their PIN on the card or its protective card sleeve.

Advise any client who reports unauthorized use of their EBT card to cancel the card through the toll free EBT customer service number by calling 1-888-997-9777.

Replacement of EBT Cards

An EBT card is reissued to the client or AR if reported by the client as lost or stolen. A client must first cancel the card through the toll free EBT customer service number by calling 1-888-997-9777.

If a client requests a reissuance of an EBT card which is believed to be damaged, District Office staff responsible for EBT must first determine if the card is actually damaged. The client or AR must provide District Office EBT staff with the actual card for determination of damage. If the card’s magnetic stripe can still be read by the District Office’s magnetic card reader, the card is not replaced. If the card’s magnetic stripe cannot be read, the District Office processes the request for a replacement card.

Cash-out of EBT Food Stamp Benefits

If an EBT food stamp recipient moves to a non-EBT state, the EBT food stamp benefits are converted to EBT cash benefits through New HEIGHTS. A client whose case has already been closed does not need to reactivate the case to request conversion.

 The client must make the request for conversion in writing, and must provide his or her new out-of-state address.

 The worker then verifies if this is a non-EBT state (CT, MA, RI and VT are all EBT states, while ME anticipates EBT implementation by 4/1/99).

 If the client’s new address is in a non-EBT state, conversion is done.

 If the client’s new address is in an EBT state, conversion is denied. Recipients in any EBT state may use their card to purchase eligible food stamp items so long as the EBT account is active.

 Cashed-out food stamp EBT benefits are accessed in the same manner as any other cash EBT benefit by using the EBT card at an Automated Teller Machine (ATM) displaying the appropriate QUEST logo. Detailed instructions for use of the EBT card at ATM’s are included in the client EBT brochure, Form NCSNH0118.

Exception: If an EBT food stamp recipient moves to state that does not participate in the QUEST system, whether an EBT state or not, the individual may not be able to access either food stamp benefits or cash benefits using his or her New Hampshire EBT card in that state.

 Advise the client that his or her benefits may not be accessible in the individual’s new state of residence. Convert EBT food stamp benefits to the EBT cash account and advise the individual to access those benefits prior to leaving the state; or If requested, convert EBT food stamp benefits to cash in the form of a paper check. Mail the paper check to the client’s verified new address.

For additional assistance in determining the EBT status of any state, contact the New HEIGHTS Help Desk at (603) 271-8427 or, toll-free, 1-800-852-3345, extention 8427. Currently, 33 states are piloting or have fully implemented EBT systems.

Electronic Funds Transfer (EFT)

Suitability of Accounts/Client Authorization for EFT

A client, AR, or protective payee who chooses EFT as the method of benefit issuance for financial assistance can only receive EFT if they have an open checking or savings account. The client, AR or protective payee must complete Form EFT-R to complete the authorization for EFT. Form EFT-R summarizes the client and bank identifying information contained in New HEIGHTS, as supplied by the applicant during the interactive interview, and contains a space for a client signature to authorize EFT.

EFT can only be made to an account which can receive deposits through the bank’s electronic address, known as the "transit and routing number." This number is a series of coded entries contained on the bottom of a check or a checking account deposit form. All in-state checking accounts are capable of receiving EFT.

 New HEIGHTS contains the "transit and routing number" for all New Hampshire banks. If EFT is requested and the account is an in-state checking account, the client, AR or protective payee only needs to complete the Form EFT-R to authorize EFT.

 If the client, AR or protective payee uses an out-of-state bank not contained in New HEIGHTS, the client must complete Form EFT-R and provide a voided, blank checking account deposit form or voided check from the specific account designated to receive EFT. The Case Technician should then contact the New HEIGHTS Help Desk with the information provided by the client in order to add the new bank information into New HEIGHTS.

 Clients may request EFT to a savings account. However, since some savings accounts are not capable of receiving EFT, especially some passbook savings accounts, the client, AR or protective payee is responsible for providing any other documentation from the bank which shows that the savings account can receive an EFT transaction in addition to the bank’s "transit and routing number."

EFT and Statewide Conversion

 Financial assistance applicants who are determined eligible after statewide implementation and conversion to New HEIGHTS may choose to receive their initial benefits through EFT.

 Financial assistance recipients open and receiving at the time of implementation and conversion, who will be converted automatically to EBT, may select EFT for their cash assistance payments at any time after the December 1 or December 7, 1998, implementation of New HEIGHTS.

 Recipients may designate only one account for EFT deposits. Recipients may not split EFT payments between separate accounts, unless an amount is being deposited into the account of a vendor payee.

Replacement of EFT Cash Benefits

There is no provision for replacement of cash benefits deposited into the client's personal account via EFT and then subsequently withdrawn by unauthorized persons. Advise recipients not to designate an account for EFT if it is jointly owned with a nonassistance group member, or provide joint ownership to an account after EFT has been established, since EFT benefits used by the joint owner will not be replaced.

 Cash benefits deposited into the wrong account as a result of bank error will become an issue between the client and his/her bank. In this instance, the bank is responsible to correct the error within its network.

 Cash benefits deposited into the wrong account due to incorrect EFT information entered into New HEIGHTS will be reissued to the correct client account upon notification to the District Office. Recovery of the money erroneously deposited into the wrong account will be pursued by the State's depository bank.

 If the bank rejects an EFT, reissue financial assistance benefits through the EBT cash account until the reason for the bank rejection has been corrected. Provide written notice of the rejected EFT and the alternate EBT issuance if the reason for the rejection cannot be corrected prior to the next regular assistance payment issuance date.

Vendor Payments

The portion of the assistance payment authorized by the client as a vendor payment will be made only as an EFT deposit to the account of the vendor. Inform the client that vendor payments cannot be implemented if the prospective vendor refuses or fails to provide all information necessary to process EFT.

 An authorization document, Form AE0023, Information to Process EFT Request Form, is printed out of New HEIGHTS and sent to the vendor, requesting identifying information for the vendor, as well as a tax identification number (EIN or SSN), bank name and address, transit and routing information for the account into which the payment will be made, and a signature authorizing EFT.

 For purposes of statewide implementation, all currently enrolled vendors associated with clients in the 11 non-pilot District Offices have been contacted via a series of letters and informed of the change in process and procedures.

 Vendors were advised of the new requirement that effective December, 1998, all vendor payments must be done via EFT, and were given the necessary forms to establish EFT payments effective with statewide implementation.

 Clients with vendor payments were also notified that their vendors were being contacted for this information to process the payments under EFT. The client notice also advised clients that if the vendor did not comply, the vendor payment would cease and the client would receive the full amount of the assistance payment.

Effective with the December 15, 1998 payroll, no vendor payments will be made unless EFT authorization is on file.

Exception: DFA emergency assistance payments made to a provider will be processed as an EFT if the provider is already a known vendor receiving EFT vendor payments. If the provider is not a known vendor, the Case Technician should attempt to obtain the provider’s banking information to process the payment as an EFT. Otherwise, the provider is paid by check if the emergency assistance payment would be delayed by inability to obtain the provider’s banking information for EFT purposes.

Bank-Rejected EFT

If a bank rejects an EFT, benefits will be issued via EBT until the reason for the bank’s rejection has been corrected. If the recipient has not previously been issued an EBT card, one will be produced and sent to the District Office for client pick-up.

Note: Recipients who had previously been issued an EBT card, but destroyed the card in anticipation of EFT, must contact the District Office and request issuance of a new EBT card.

Before benefits can be issued via EFT, New HEIGHTS will generate a "pre-note" or an advance test of the EFT to the bank.

 If the bank cannot receive the pre-note, New HEIGHTS will send an alert to the Case Technician to correct the error. No notice is sent to the client.

 If the error cannot be corrected prior to the pull-down date for the financial assistance semi-monthly payroll, New HEIGHTS will produce a written notice to the client about the rejected EFT and the alternate EBT issuance. The Case Technician must switch the benefits issuance method from EFT to EBT on the Assistance Group Benefit Issuance screen in New HEIGHTS.

FORMS

This section discusses new forms developed for the pilot implementation and now released in final form for statewide use, current forms revised to conform with New HEIGHTS and EBT/EFT, and obsoleted versions of certain forms discussed in this SR. A future SR will discuss the numerous other paper forms either now produced automatically as part of New HEIGHTS or no longer needed.

New HEIGHTS Forms

For the pilot implementation, SR 98-50 released several new forms, unique to New HEIGHTS or EBT/EFT, along with their instructions. In most cases, these forms were adapted from existing forms (e.g., Form 778H), and were given the existing form’s number with the suffix "H" appended. Most these pilot forms and their instructions are being re-released by this SR unchanged except for a revised SR number and release date. These include Forms 800H, 800HC, 800HP, 811R, 811H, 811S, EFT-R and AE0023, and Client Brochure NCSNH0118 (6/98).

Forms 800H and 800HP

The Form 800H, HEIGHTS "Application" Form (HAF), is printed out during New HEIGHTS CR function. This form can also be printed from the Program of Assistance screen by Case Technicians during the AE interview.

Note: The title of the form as it is printed out of New HEIGHTS is "Application," but it does not replace the Forms 800 or 800P. New HEIGHTS screens simply refer to this form as the "HAF."

 Whenever the Form 800H is printed from the New HEIGHTS CR function, the worker must enter the Filing Date on the Conclude CR Interview screen in order for New HEIGHTS to track this as a valid application. After the Filing Date is entered, no changes can be made to the RFA in CR.

 If the worker prints the Form 800H for the applicant’s review prior to entering the filing date, the 800H must be reprinted after the filing date has been entered so that the current date is reflected on the form. New Form 800H is reviewed with and signed by the applicant at the conclusion of CR.

This SR also releases Form 800HP and its instructions. Form 800HP is a paper version of the Form 800H used only in the event of power outage or system failure.

Form 800HC

Form 800HC, Application Information Overview, is a separate paper document given to a new applicant at the time of the CR interview. It was adapted from the cover sheet attached to the front of the existing Form 800, and incorporates minor terminology changes resulting from New HEIGHTS and EBT/EFT. As with other application-related forms designed for New HEIGHTS, this form is not used for applications for medical assistance using Form 800P or 800Q. Additional supplies of the 800HC will be kept in the interview rooms.

The Case Technician signs the back of the Form 800HC only after completion of the interactive eligibility interview to indicate that the applicant has completed the application process.

Forms 811H and 811S

Form 811H, Eligibility Interview Summary, replaces the existing manual data collection process using the Form 811, Eligibility Determination. However, current Form 811 is not being obsoleted at this time, since it can be used in conjunction with manual application procedures required by a power outage or system failure or when an application interview is conducted off-site, such as during a home visit.

 Form 811H is produced by New HEIGHTS following any initial or redetermination AE interview with the Case Technician. This form is "built" by New HEIGHTS from all pertinent eligibility information provided by the applicant during the interview.

 The Form 811H is reviewed with and signed by the client at the conclusion of the interactive AE interview.

 The last page of Form 811H contains a list of "Statements of Understanding." These mirror similar statements contained on page 6 of the revised Form 800 that inform applicants of such policies as assignment of support rights, prohibitions on benefit receipt by fugitive felons, lump sum income treatment, and various confidentiality, verification, and fraud-related issues. In addition, the following new statement has been added to the last page of Form 811H:

"I understand that for food stamp benefits, to receive a deduction for receipt of child care expenses, rent or mortgage payments, utility or other shelter expenses, child support paid to a non-household member, or medical expenses (only for the elderly and disabled), I must report and provide verification to my caseworker. Failure to report or verify any of the above listed expenses, or of receipt of fuel assistance, could mean that I will receive less food stamp benefits each month, and will be seen as my statement that my household does not want to receive a deduction for the unreported or unverified expense."

This statement does not reflect new policy, but was added as a clarification of existing practice and to more fully inform applicants of the consequences of failure to verify all deductions.

This SR also releases Form 811S, Eligibility Interview Summary Signature Page, and its instructions. Form 811S is a paper version of the last, or signature, page of Form 811H and is used only in cases that preclude normal production and printing of Form 811H, such as power outage or system failure.

Form 811R

Form 811R, Your Rights and Responsibilities, was modeled after the rights and responsibilities notice attached to the back of the Form 800. It is a separate paper document given to applicants at the CR interview and reviewed by the Case Technician at the conclusion of the interactive AE interview. Additional supplies of the 811R will be kept in the interview rooms.

Forms EFT-R and AE0023

Form EFT-R, Information Required To Process Electronic Funds Transfer (EFT) - Recipient, is a 2-part NCR form used to collect banking information from a recipient necessary to process EFT. This form must be completed, even though the recipient’s account has been entered into New HEIGHTS resource screens. This form serves as the recipient’s written authorization for DFA to make EFT into the recipient’s personal bank account.

Form AE0023, a variation of Form EFT-R, requesting the same information, is produced by New HEIGHTS, along with the Alternate Form W-9 and the request for its completion, and sent automatically to vendors. Since it is essentially the same form, no facsimile is attached to this SR.

Client Brochure NCSNH0118 (6/98)

As part of the EBT contract, a brochure, entitled EBT: How To Use Your EBT Card to Get Your Food Stamp and/or Cash Benefits, has been produced for agency use in training clients. This brochure must be given to clients whenever an EBT card is obtained by a client, AR, or protective payee at the District Office. Since this brochure was produced by the contractor for the Northeast Coalition of States (NCS), it does not contain a standard form number. However, on the bottom of the back cover, the contractor has printed their version of the form, NCSNH0118 (6/98), which can be used for identification and reordering. Form NCSNH0118(i), Instructions for Form NCSNH0118, is being released by this SR.

Revised Forms

Forms 778 and 778(i)

Form 778, Authorized Representative Declaration, and its instructions, are being revised and released by this SR to replace both the current Form 778 and Form 778H, which was developed for pilot implementation of EBT, and their instructions. Revised Forms 778 and 778(i) in actuality duplicate the format and content of pilot form 778H and its instructions. In doing so, it officially obsoletes Form 778H and its instructions.

Form 778 is used by applicants and recipients to choose an Authorized Representative (AR) and to specify the role of the authorized representative in the EBT process. It allows clients to specify that AR’s may be designated to receive and access EBT benefits on behalf of the recipient by obtaining and activating their own EBT card, to obtain the recipient’s EBT card but convey the card to the recipient for activation, or to perform the card activation for the recipient at the District Office with the PIN provided by the client to the AR.

Form 800

The current Form 800, Application, has been revised to reflect changes to the application process related to the statewide implementation of New HEIGHTS and EBT/EFT. Form 800 is still used to apply for assistance at locations outside the District Office, and may be used in the event of a power outage or system failure. Revisions to Form 800 include:

 The addition of EBT information to the authorized representative section on page 1;

 The revision of Section 1 on page 2, HOUSEHOLD MEMBERS, to now include separate sections for Adults Household Members and Children Household Members, as well as additional relationship information;

 Revisions to the tear-off cover page and the tear-off YOUR RIGHTS AND RESPONSIBILITIES NOTICE page to reflect New HEIGHTS and EBT/EFT and to mirror Forms 800HC and 811R, respectively; and

 Revisions to page 6, formerly titled IMPORTANT INFORMATION -- PLEASE READ BEFORE SIGNING and now entitled STATEMENTS OF UNDERSTANDING -- PLEASE READ BEFORE SIGNING, to reflect New HEIGHTS and EBT/EFT and to mirror the last page of Form 811H, Eligibility Summary.

Forms 800R(Adult) and 800C(Adult)

Currently, there are 4 different forms used for the mail redetermination/recertification process:

 Form 800R(Adult), sent from State Office with the form 800C(Adult) cover letter to certain recipients of adult category financial or medical assistance with a related food stamp case;

 Form 800R(PL), sent from State Office with the form 800C(PL) cover letter to recipients of KidsCare PLUS medical coverage without food stamps;

 Form 771, sent manually by District Offices to certain adult category financial or medical assistance recipients without food stamps; and

 Form 771a, sent manually by District Offices to redetermine eligibility for nursing facility care.

In an effort to balance the requirements of New HEIGHTS with the need to acquire adequate information to redetermine eligibility, the following changes to forms have been made:

 Forms 800R(Adult) and 800C(Adult) were revised based on Forms 800RH, Application for Redetermining Eligibility for Assistance, and 800CH, Cover Letter, which were developed for the Concord District Office pilot implementation. Beginning with statewide implementation, revised Forms 800C and R(Adult) will be sent to all adult category households, with or without food stamps, that qualify for mail redetermination.

 Form 771 is formally obsoleted by this SR.

 Current forms 800R(PL) and 800C(PL) will continue to be sent to recipients who are eligible to receive this form for mail redetermination.

 Current Form 771A will continue to be sent to nursing facility care recipients.

Note:  For statewide implementation, the decision was made to "push ahead" by 1 month all required redetermination/recertifications in the 11 non-pilot offices, both mail and face-to-face, beginning with those scheduled for December, 1998. This means, for example, that redeterminations currently due in December, 1998 will be rescheduled for January, 1999, those for January rescheduled to February, 1999, and so forth.

Revised NHEP Work Program Forms

Several billing forms used by New Hampshire Employment Program (NHEP) work programs’ clients or providers of support services, and their instructions, have been revised to reflect changes in employment and training support services billing processes under New HEIGHTS and BRIDGES. In addition, formatting and editing revisions have been made to Form 221, the New Hampshire Employment Program pamphlet.

Revisions common to the NHEP billing forms released by this SR include a new space in which the client or provider must enter an "ETS Service Request Number," replacement of the EMS Individual Number (ID) with the New HEIGHTS "Recipient Identification Number (RID)" and the CIS "Provider Number" with the "Provider Resource ID" assigned by BRIDGES, and the removal of the sections formerly used to indicate the "Activity" associated with the support service and for an "Authorizing Signature." The ETS Service Request Number is a unique 10-digit number generated by New HEIGHTS when the NHEP team member enters a support service for an activity. This number is sent to BRIDGES and is used to link the New HEIGHTS authorization to incoming bills. With support services authorized on New HEIGHTS, it will no longer be necessary for staff to review and sign off on bills, with one exception: transportation for job search must be reviewed and signed off by the NHEP team member.

Form 221

Form 221, New Hampshire Employment Program, is an informational pamphlet provided to applicants for NHEP financial assistance and other interested parties. It gives a comprehensive overview of the NHEP work program requirements, including the two NHEP work program components, temporary exemptions from participation, support services available, and compliance requirements and penalties for noncompliance. Revisions to this pamphlet include: updating of policy, reformatting of sections to make the text flow more logically, text editing to improve readability, and the addition of the toll-free telephone numbers for NHEP team offices.

Form NHEP255

Form NHEP255, Employment and Training Support Services Payment Request Invoice, has been revised to include spaces in which the services provider must enter an "ETS Service Request Number," and to remove the Activities section and the space for an NHEP Authorizing Signature.

Form NHEP256

New Form NHEP256, Mileage Reimbursement Request Invoice, is a two-part NCR form used by NHEP participants to bill the Division for reimbursement for mileage expenses incurred for travel associated with approved work and training activities. In addition to the inclusion of the ETS Service Request Number to the Form, the Form has several significant differences from current Form 256:

 Form NHEP256 contains a section entitled Destination Log. Participants are required to record, in the spaces provided, an accounting of each trip made during the billing week in pursuit of the approved activity by entering the date, start location and end location, total number of miles, reason for the trip, and if mileage claimed was roundtrip. This section was added to the Form to gather empirical data for reporting and accounting purposes.

 A checkbox has been added for clients requesting mileage reimbursement for the Job Search activity, who now must attach copies of Form NHEP223, Employer Contacts. If attaching Form NHEP223, participants do not need to complete the Destination Log section.

 The "Activity" section has been deleted. Clients are no longer required to indicate the Activity for which the travel was part, since this information is now contained in the ETS Authorization in New HEIGHTS.

 Much of the identifying information, such as individual recipient identification number, has been relocated to a box at the top right of the Form. "NHEP Office" has replaced "District Office," and a Key Name field has been added. The Key Name, as with other forms keyed at BDM, is the first 5 letters of the individual’s last name. In addition, the Social Security Number, located next to the Signature line, is now that of the participant instead of the casehead.

Form NHEP256A

Form NHEP256A, Public/Private Transportation Carrier Provider Invoice, now includes the ETS Service Request Number. In addition, "Recipient Information" has been relocated to the body of the Form, and "NHEP Address" has been added to the top section. Finally, the "Activity" and "NHEP Representative Payment Authorization Signature" sections have been removed.

Form NHEP257

Form NHEP257, Tuition Payment Request Invoice, has been revised to include the ETS Service Request Number and to remove the "Activity" and "Authorization for Payment" sections.

Special Transition Procedures for Use of Previous Versions of NHEP Work Program-Related Forms

Concord NHEP received a supply of the new Forms in late October. NHEP team sites other than Concord received an initial distribution of the revised forms during the week of November 23, 1998. In addition, All NHEP teams received detailed instructions on transitioning cases from EMS to New HEIGHTS and on appropriate Forms usage based on presence or absence of authorization(s) on New HEIGHTS. A summary of these procedures follows.

Note: It is crucial that these procedures be followed in order to avoid payment rejection and delays for participants and providers of support services.

Participants Authorized for Support Services On or After the Effective Date of this SR

Participants authorized in New HEIGHTS for Support Services on or after the effective date of this SR must be provided with the new forms and instructed to use them exclusively.

Note:  Once one authorization for services has been entered into New HEIGHTS, all services must be authorized. When a participant is authorized for support services on New HEIGHTS, attempts to bill for payment using the previous versions of these Forms will be rejected by BRIDGES.

Participants Active in NHEP as of the Effective Date But Not Yet Authorized for Support Services in New HEIGHTS

Until such time as participant support services and Employability Plan information have been entered into New HEIGHTS, NHEP staff must continue to provide NHEP work program participants with current form 256, dated November, 1996, and current NHEP forms 255 and 257, dated October, 1997, and 256a, dated July 1998, and to instruct these participants to use these versions exclusively. As staff enter on-going support services requests into the New HEIGHTS, care must be taken to provide the participant with the new versions, to instruct them in their use, and to direct the participant to discontinue use of older versions immediately.

PROCEDURES

Expedited Food Stamp Cases in the Concord District Office Pilot Opened in Laconia

During the last week of July, 1998, immediately prior to the implementation of the New HEIGHTS pilot in the Concord District Office, EMS was no longer available to Concord District Office workers. The decision was made to open all expedited food stamp cases processed in Concord during the last week of July, 1998 in the Laconia District Office, in order to provide timely benefits to eligible applicants. Effective with statewide implementation for Laconia on December 7, 1998, those Laconia cases comprising households living in the Concord catchment area must be transferred back to the Concord District Office.

Final Shut-Down of EMS

At 12:00PM (noon) Friday, November 20, 1998, data entry into EMS will be shut down for the Manchester, Nashua, Portsmouth, and Rochester District Offices.

 These Offices must continue to take applications, changes, interview applicants, etc., through November 30, when neither EMS or New HEIGHTS is available for data entry by these offices.

 These Offices must hold all but expedited food stamp applications until December 1, 1998.

At the close of business on Tuesday, November 24, 1998, EMS will be shut down for data entry in its entirety for all District Offices.

 Expedited food stamp applications received Wednesday November 25 require special processing for all District Offices (except Concord).

 Expedited food stamp applications received between Monday November 30 and Friday December 4 require special processing for the Berlin, Claremont, Conway, Keene, Laconia, Littleton, and Salem District Offices.

All affected District Offices received detailed instructions under separate cover for processing expedited food stamp applications received during transition to statewide implementation.

Cases Awaiting Transfer to or from the Concord District Office Pilot

SR 98-50 released interim policy stating that, effective with the July 24, 1998 conversion run (which converted Concord District Office EMS cases to New HEIGHTS), no case transfers were permitted, either to or from the Concord District Office, for the duration of the pilot implementation project.

Effective with this SR:

 There will be no case transfers to or from any District Office during the first two weeks of statewide implementation. Case transfers among the eleven non-Pilot offices may resume at that time unless directed differently by DFA State Office.

 Case transfers of Concord District Office pilot cases held pending statewide implementation will take place according to a schedule developed to accommodate the demands on all staff attendant to statewide implementation. District Office Supervisors will be advised under separate cover of the exact schedule for transfers to and from the Concord District Office.

UNRELATED POLICY CLARIFICATIONS AND TECHNICAL CORRECTIONS TO THE MANUALS

In addition to the revisions to the AAM, FAM, and FSM necessitated by New HEIGHTS and EBT/EFT, the following clarifications and technical corrections unrelated to policy released in this SR are being released.

FAM 109.13, Concurrent Receipt of Financial Assistance, has been added to the FAM. This policy was contained in the original Public Assistance Manual (PAM) for all financial assistance programs, but was inadvertently omitted from the FAM when the PAM was converted to the FAM and AAM in 1994. The policy states that individuals may not receive financial assistance from more than one program administered by DFA at the same time.

A further clarification is included in new Section FAM 109.13, and has also been added to AAM 109.15, Concurrent Receipt of Financial Assistance, that if an individual is receiving financial assistance under one program of assistance, such as NHEP, then becomes eligible for financial assistance under a different program, such as APTD, and chooses to accept the latter financial assistance, no payments may be made under the new program for any months in which financial assistance has already been received under the first program, regardless of whether the prior benefits are voluntarily refunded to the state.

FSM 121.03, Applicant Delay, and FSM 129, Pending Information, have been revised to reflect a long-standing FNS waiver. The waiver permits DFA to deny applications if applicants do not comply with verification requirements within 10 days of the verification request (providing that the DO has given the applicant any assistance requested in obtaining verifications). FSM 129 has been revised to reflect this waiver. The waiver also states that if the individual complies after the denial, but before the 30th day, DFA must reactivate the application and provide benefits back to the original Filing Date of the Request for Assistance. This requirement has been missing from the FSM and has been added to FSM 121.03.

FAM 123, Benefit Delivery Timeframes, has been revised to include the requirement that individuals applying for financial assistance must be eligible in all respects on the day the first payment is issued in order to receive cash benefits. This policy was contained in the old Public Assistance Manual (PAM) for all financial assistance programs, but was inadvertently omitted from the FAM when the PAM was converted to the FAM and AAM in 1994.

FAM 217.01, When Separate Medical Assistance Groups are Required, has been revised to eliminate a spurious reference to receipt of ANB financial assistance.

FSM 201, Program Requirements, has been revised to change the reference from "financial and medical assistance" to "food stamp benefits."

AAM 411, Real Property, has been revised to correct a typographical error that could lead to misapplication of policy. In the table listing "Type of Property," the entry referring to property that is "Permanently Occupied" has been corrected to refer to property that is "Permanently Unoccupied."

AAM 419.03, Determining the Protected Resource Amount, has been revised to eliminate ambiguity in the discussion of the appropriate standard to use in setting the protected resource amount for the community spouse of an institutionalized individual.

FSM Chapter 400, Vehicles, has been revised to correct an error in the subsection discussing "Income-Producing Vehicles." Currently, the entry erroneously states that, to qualify for excluded resource status, a vehicle used to produce income must annually produce income consistent with its fair market value, be necessary for work-related long distance travel, and be used primarily (over 50% of the time) for income-producing purposes. Federal regulations, however, require only that the vehicle meet at least one of those conditions. The entry has been revised to state that to qualify for excluded resource status, a vehicle used to produce income must annually produce income consistent with its fair market value, be necessary for work-related long distance travel, or be used primarily (over 50% of the time) for income-producing purposes.

FAM and FSM 500, Burial Funds, has been rewritten to correct an inadvertent word substitution made when this policy was revised in SR 98-10. Previous to SR 98-10, the policy correctly stated the treatment of these resources to allow the exclusion of one burial contract, up to a maximum of $1500, per assistance group member. SR 98-10, in the course of an unrelated change, incorrectly changed the text to read "one burial fund." The text has been revised to return the word "contract" to the treatment policy.

FAM 500, Lump Sum Income, has been extensively rewritten to accurately reflect current policy and procedures relating to the treatment of lump sum income for TANF financial assistance and to remove obsolete references to AFDC and EMS.

IMPLEMENTATION

Statewide implementation of New HEIGHTS will begin December 1, 1998 for the Nashua, Manchester, Portsmouth, and Rochester District Offices, and December 7, 1998 for the Berlin, Claremont, Conway, Keene, Laconia, Littleton, and Salem District Offices. Unless otherwise specified, all policies released by this SR are effective on those dates. All policies in this SR were released in the Concord District Office by SR 98-50, effective August 3, 1998, with the exception of the "split case" policy revision, which was released retroactively in Concord by SR 98-47.

CLIENT/VENDOR NOTIFICATION

 A notice to all clients (except Concord District Office clients) was mailed on staggered dates during the month of November, 1998, providing a brief description of anticipated changes associated with statewide implementation of New HEIGHTS.

 Notice was sent to all vendors statewide in June, 1998, requesting banking information necessary to process EFT. Clients with vendor payments were also notified that their vendors were being contacted for this information to process the payments under EFT. The client notice also advised clients that if the vendor did not comply, the vendor payment would cease and the client would receive the full amount of the assistance payment upon implementation of New HEIGHTS and EBT/EFT.

 A notice to all clients (except Concord District Office clients) was mailed on November 16, 1998, providing a brief description of anticipated changes associated with statewide implementation of EBT.

 A notice to all retail food merchants participating in the Food Stamp Program in New Hampshire was mailed on November 9, 1998, providing a brief description of anticipated changes associated with statewide implementation of EBT.

 Following the statewide conversion run of EMS to New HEIGHTS, EBT cards will mailed to all clients (except Concord District Office clients) on December 4, 1998. The EBT card mail-out also will include the client brochure, How To Use Your EBT Card..., and a notice about the separate mailing of PIN’s on December 7, 1998.

Copies of client notices are included with the hard copies of this SR.

TRAINING

New HEIGHTS training for staff in the eleven District Offices affected by this SR began on August 24, 1998. Case Technicians received 5 days of training, while other Department staff received less based on their need and anticipated use of New HEIGHTS.

EBT training for EBT card issuance procedures in the Bureau of Data Management occurred on July 17, 1998. EBT training for EBT card issuance staff in the eleven District Offices affected by this SR occurred on October 1 and 2, 1998.

EBT training for clients will provided by the University of New Hampshire, Cooperative Extension Service, beginning on December 14, 1998. The frequency and schedule of this training varies between the eleven District Offices affected by this SR. The District Offices will receive a separate notification of this schedule.

Further training will be provided to individual staff on an as needed basis. Written instructional material was provided to all who attended both New HEIGHTS and EBT training. District Office staff also received self-directed training protocols to reinforce the 5 day "hands-on" training.

FORMS MANUAL POSTING INSTRUCTIONS

FORMS MANUAL POSTING INSTRUCTIONS (Continued)

FORMS MANUAL POSTING INSTRUCTIONS (Continued)

FORMS MANUAL POSTING INSTRUCTIONS (Continued)

*At the time these forms were sent to print, statewide implementation of New HEIGHTS was expected to be October 3, 1998. Subsequently, there was a second postponement to November 2, 1998, and then a third to the final effective dates indicated in this SR. Therefore, the initial printing of these forms will contain incorrect release dates. However, as the policies related to these formshave not changed since the print orders were made, no negative impact or confusion for clients or providers is anticipated. Subsequent reorders of these forms will correct these release dates.

OBSOLESCENCE OF SR’S 98-41, 98-47, AND 98-50

The SR officially obseletes 3 SR’s that released policy for the Concord District Office pilot implementation only: SR 98-41, New HEIGHTS Pilot Update: 7 Day Time Frame for Expedited Food Stamps, SR 98-47, Revised Assistance Group Composition and Deemed Income Policy ..., and SR 98-50, Release of Policy and Forms Relating to Pilot Implementation of New HEIGHTS and EBT/EFT. Concord District Office and State Office DFA staff who retained SR 98-50 as directed may now remove/delete and destroy any retained copies as desired.

DISTRIBUTION

This SR will be distributed according to the electronic distribution list for DFA policy releases. This SR, and On-line Manuals, will be available for agency staff in the On-Line Manual Library, and available for public access on the Internet at http://www.state.nh.us/dhhs, effective December 1, 1998.

This SR will be distributed in printed form according to the hard copy narrative distribution list for the FAM, AAM, FSM, and Forms Manuals.

Note: Due to the volume and complexity of revisions made to the Manuals, and the subsequent length of time that will be required to print revised hard copy pages, holders of the hard copy manuals will receive the printed SR in advance of the revised pages for the manuals they hold.

DISPOSITION

This SR may be deleted or destroyed after its contents have been noted and its posting instructions carried out.

DFA/RQY/PJD:s

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CERTIFICATE OF DESTRUCTION

I hereby certify that all copies of Form 221, SR 97-41/November 1997, Form 778, SR 94-5/January 1994, Form 800, SR 97-8/March 1997, Form 800C(Adult), SR 96-48/November 1996, and Form 800R(Adult), SR 96-48/November 1996, have been destroyed.

Office Manager:    District Office/NHEP Site    

Return this certificate to DHHS Stock Control, 6 Hazen Drive, Concord, NH 03301, after the instructions in the SR have been carried out.