605-4 C.     RURAL INTERVIEW POSTPONEMENT

Federal regulations provide Alaska the authority to implement certain procedures for efficient and effective administration of SNAP in rural areas of Alaska. One such allowance is the postponement of SNAP interviews for households residing in rural areas, allowing households to receive an initial SNAP benefit while awaiting their scheduled interview.

1. Eligibility for Rural Interview Postponement

Caseworkers may apply the Rural Interview Postponement when each of the following conditions are met:

• The applicant household resides in an area designated as Rural I or Rural II as outlined in Addendum 1;

• Cold Call attempts to the household to interview have been made and were unsuccessful; 

• Scheduling an interview would fall outside of either the 7-day expedited or 30-day standard application processing timeframes outlined in SNAP MS 601, or the recertification processing timeframes outlined in SNAP MS 604-3(B); and

• All required eligibility factors are verified and there is no questionable information which may impact eligibility and which requires an interview to resolve.

A household which meets these criteria may have their interview postponed and receive an initial SNAP allotment while awaiting their scheduled interview.

Questionable information may be the basis upon which an interview is not postponed. A household which receives SNAP benefits while the interview is postponed and then fails to participate in a scheduled interview may provide the basis for the caseworker to find the household's circumstances questionable for future applications.

A household that has received a Rural Interview Postponement can receive additional Rural Interview Postponements except when:

1. The household last received SNAP benefits while their interview was postponed; and,

2. The household failed to attend their scheduled interview; and,

3. The case was closed for failing to participate in an interview; and,

4. The household did not contact DPA to reschedule and complete the interview within timeframes.

After a household successfully completes a SNAP interview, it becomes eligible to receive Rural Interview Postponements again for future applications and recertifications.

2. Initial Applications

In order to postpone a required interview for SNAP applicants that reside in a rural area, caseworkers must:

1. Verify each of the following eligibility factors prior to authorization:

• Identity of the applicant as outlined in SNAP MS 602-1(C);

Note:

When the SNAP applicant household meets expedited service criteria, the interview may be postponed by solely verifying the SNAP household members' identity in order to meet the 7-day processing standard. See SNAP MS 605-3(B)(2) for expedited service verification requirements.

• Alaska residency as outlined in SNAP MS 602-1(B);

• IPVIntentional Program Violation Status;

• Alien Status of any household member who is not a U.S. citizen as explained in SNAP MS 602-1(D);

• Gross countable income as outlined in SNAP MS 602-3;

• Allowable deductions outlined in SNAP MS 601-4(A)(2); and

• Questionable information as explained in SNAP MS 601-4(C).

If the caseworker cannot verify all required factors of eligibility, the interview cannot be postponed and must be processed following normal expedite/non-expedite SNAP timeframes.

2. Authorize the household and send the appropriate notice of postponed interview. The application filing date will determine how many months are issued when the interview is postponed.
   
   Households applying by the 15th of the month: The caseworker will authorize the initial month allotment and send appropriate notice to the household. When the interview is postponed and the first month allotment is issued, the interview must be completed before the second month issuance is authorized. The case will be closed at the end of the first month using adequate notice if the household fails to participate in an interview. The interview must be scheduled with time to allow for any pended verification needed to make an eligibility determination.
   
   Households applying after the 15th of the month: The caseworker will authorize both the prorated initial month allotment and the second month allotment simultaneously and send the appropriate notice to the household. The postponed interview must be completed before the third month allotment is authorized. The case will be closed using adequate notice at the end of the second month if the household fails to participate in an interview.
    

3. Complete the scheduled interview.
   
   The interview must be completed before any further benefit months are issued.
   
   Any changes reported at the interview must be treated as a Report of Change received during a certification period, as outlined in SNAP MS 604-4(A). Adverse Action rules apply to any additional information that the household reports at interview, such as income from a new source. If verification is required for any changes reported at interview, benefits will be authorized and issued during the pend period.
   
   If the caseworker discovers that the household did not report information on their application that should have been included, such as unreported income, they will need to examine any issued months for potential overpayments. See SNAP MS 607-1.
   
   When the client fails to complete their scheduled interview, the case will be closed with adequate notice. Adverse Action rules are met for this closure action by the initial Rural Interview Postponement notice which specifies the approval is only for one or two months, and that benefits will end if the interview is not completed.
   
   Application requirement timeframes outlined in SNAP MS 601-2(C)(5) apply. Households contacting DPA to reschedule or complete their interview after the 60th day will be required to apply with a new application.

Example: Expedite Application filed on or before the 15th

An expedite-eligible household residing in a rural area applies for SNAP on March 3rd. The caseworker unsuccessfully attempts to contact the household by phone and determines that scheduling an interview within the expedited timeframe is not feasible. The caseworker has sufficient verification to authorize benefits under Expedited Service and Rural Interview Postponement policies.

The initial month's SNAP allotment is authorized, and the household is notified of the postponed interview, the scheduled interview date and time, and the requirement to complete the interview in order to continue receiving benefits after the one-month period.

Example: Application filed after the 15th 

A household residing in a rural area applies for SNAP on January 16th. The caseworker unsuccessfully attempts to contact the household by phone and determines that scheduling an interview within the standard processing timeframe is not feasible. The caseworker has sufficient verification to authorize benefits under the Rural Interview Postponement policy.

The initial and second-month SNAP allotments are authorized, and the household is notified of the postponed interview, the scheduled interview date and time, and the requirement to complete the interview in order to continue receiving benefits after the two-month period.

Example: Household fails to attend postponed scheduled interview

A rural household applies for SNAP benefits and receives 1 month of SNAP while the interview is postponed. The household then fails to attend their scheduled interview. The case is closed and the household is sent the appropriate SNAP closure notice using adequate notice.

Example: Household reschedules and completes missed postponed interview after 30 days but within 60 days

A rural household applies on January 1st. A caseworker utilized the Rural Interview Postponement, authorizes 1 month of benefit, sending notice to household of the 1 month approval and scheduled interview date and time. The scheduled interview is missed, the caseworker closes the case with adequate notice and sends the appropriate closure notice.

The household contacts DPA on February 6th, within 60 days of the application filing date, and completes the postponed interview. Since the delay is household-caused and beyond the 30th day from application, the case will be reopened from the date the household completed the interview. If determined eligible, benefits for February will be prorated from February 6th, and certified for a full certification period.

Example: Household participates in scheduled interview, no verifications needed

A household receives a rural interview postponement of 1 month of SNAP benefits and attends their scheduled interview. The caseworker completes the interview and obtains verification of any changes reported at interview. The household does not consist solely of aged or disabled individuals with no earned income, and the case is authorized for the remainder of the standard 12 month certification period.

Example: Household participates in scheduled interview, verifications needed

A household receives a rural interview postponement and receives 2 months of SNAP benefits while their interview is postponed. The household completes their required interview timely.

During the interview the household reports that one member has begun working a new job. This report is treated as a Report of Change received during the certification period and is subject to Adverse Action rules. The caseworker is unable to obtain verification of the new employment at interview, so the case is authorized to continue receiving SNAP benefits at the previously authorized amount, and the case is soft-pended for the required verifications. Benefits will continue until the agency verifies the household is ineligible or the household has failed to provide the requested verification following Adverse Action rules outlined in SNAP MS 604-5(B).

3. Recertification Applications

In order to postpone a required recertification interview for a SNAP household which resides in a rural area, caseworkers must:

1. Verify all required factors of eligibility for recertifications as outlined in SNAP MS 604-3(E) prior to authorization.
   
   If the caseworker cannot verify all required factors of eligibility, the interview cannot be postponed and must be processed following normal recertification processing timeframes.
    

2. Authorize the household and send the SNAP Approved Rural Area - One Month Only - Interview Needed (F118) notice.
   
   Only the first month of the new certification period may be authorized while the interview is postponed.
    

3. Complete the scheduled interview.
   
   The interview must be completed before any further benefit months are authorized.
   
   Any changes reported at the interview must be treated as a Report of Change received during a certification period, as outlined in SNAP MS 604-4(A). Adverse Action rules apply to any additional information that the household reports at interview, such as income from a new source. If verification is required for any changes reported at interview, benefits will be authorized and issued during the pend period.
   
   If the client fails to complete their scheduled interview, the case will be closed with adequate notice. Adverse Action rules are met for this closure action by the initial Rural Interview Postponement notice which specifies benefits are approved for one month only and will end if the interview is not completed.
   
   If an interview is not completed before the effective date of closure, a new application will be required if the household wishes to continue receiving SNAP benefits.

Note:

When an interview is postponed for a recertification application and is then closed for no interview, the case will be closed. If the household contacts DPA to complete their interview after the effective date of closure, they will be required to reapply with a new application.

Example: Recertification Interview Postponed

A rural household is due for recertification and submits a timely recertification on August 3rd for September benefits. On August 31st a caseworker pulls the recertification, attempts to cold call the household and is unsuccessful. The caseworker has all necessary verifications and no information on the recertification is questionable. Scheduling the interview would be outside the timeframe for timely agency action, so the caseworker applies the rural interview postponement, authorizes benefits for September only, notifies the household of their benefit amount for the initial month of the new certification period, the date and time of their scheduled interview, and that their benefits will end if the required interview is not completed.

Example: Household fails to participate in scheduled interview and does not contact DPA before effective date of closure 

A rural household receives a rural interview postponement on their recertification for September benefits, receives one month of benefit for September only, and later misses their scheduled interview. The case is closed effective the end of September, and the household is notified with adequate notice of the closure.

If the household contacts DPA in October, after the effective date of closure, they will be required to reapply with a new application if they wish to receive SNAP benefits again. They may not receive another Rural Interview Postponement until they successfully participate in a SNAP interview.

Example: Household reschedules and completes recertification interview before effective closure

A rural household receives a rural interview postponement on their recertification for June benefits, receiving benefits for June while their interview is postponed. The household fails to attend their scheduled interview, and the case is closed effective the end of June using adequate notice.

On June 29 the household contacts DPA, and a caseworker is able to complete the interview with the household that same day. No additional verifications are required and the household is determined eligible. The household is approved for the remaining 11 months of the new certification period.