SR 22-29 Dated 09/22

 

STATE OF NEW HAMPSHIRE

DEPARTMENT OF HEALTH & HUMAN SERVICES - Bureau of family assistance (bfa)

INTER-DEPARTMENT COMMUNICATION

 

FROM:

OFFICE OF THE ADMINISTRATOR IV, BFA Debra Sorli

 

BFA SIGNATURE DATE:

September 2, 2022

 

AT (OFFICE):

Bureau of Family Assistance

 

TO:

All BFA Staff

 

SUBJECT:

Heating/Cooling (AC) Standard Utility Allowance

 

EFFECTIVE DATE:

June 23, 2022

 

SUMMARY

 

This Supervisory Release (SR) releases a change to the SNAP Heat & Utilities Standard to align with federal regulations, which specify a household is entitled to such a deduction if the household incurs a cooling charge separate and apart from the household’s rent or mortgage payment. The new name for this deduction is the Heating/Cooling (AC) Standard Utility Allowance (HCSUA) and this deduction is allowed for all households who are charged for heating or air conditioning expenses as a separate charge from rent/mortgage.

 

FORMER POLICY

NEW POLICY

The Heat and Utilities Standard allowed the full SUA for households who incur heating and/or cooling costs that were separate from the household’s rent or mortgage

The Heat and Utilities Standard is now called the Heating/Cooling (AC) Standard and allows the full SUA for SNAP.

Households who were responsible for paying electrical costs and used an AC were not allowed the Heat & Utilities Standard.

Households who are responsible for electrical costs and run an AC are now allowed The Heating/Cooling (AC) Standard (formally called Heat and Utilities Standard).

 

POLICY

 

7 CFR 273.9(d)(6)(iii)(A-C) gives states the option to develop standard utility allowances to be used in place of actual costs in determining a household’s excess shelter deduction. Since New Hampshire has chosen this option and has implemented a standard with a heating component, that same standard must also include a cooling component, meaning the same deduction must be made available to households that incur heating or cooling expenses separately from their rent or mortgage, and to households that receive Low Income Home Energy Assistance Program (LIHEAP) payments. Any household that pays toward air conditioning (either central or room AC) as a separate charge from rent/mortgage is entitled to receive the Heating/Cooling (AC) SUA. This includes households who pay a separate charge specifically for the AC (for example, the landlord charges an extra $15/month to install and use an AC) and households who pay for their electric bill and use an AC.

 

At every interview and recertification, ask the household if they are responsible for air conditioning charges separate from rent/mortgage, including an increase in electricity costs, in the past 12 months. Air conditioning expense is verified with an electric bill or shared shelter form, along with the client’s written or verbal statement confirming they are responsible for air conditioning costs. In order to prevent QC errors, it is very important to document in case comments that the client has been asked if they pay for AC.

 

NEW HEIGHTS & NH EASY SYSTEMS PROCEDURES AND IMPLEMENTATION

 

New HEIGHTS Update(s)

 

New HEIGHTS will update the Standard Utility Allowance screen to change the question “Does your household pay for heat?” to “Does your household pay for heat/cooling(AC)?”. If this question is answered ‘Yes’ and verified, the Heating/Cooling (AC) SUA will be allowed.

Air conditioning will also be added to the list of examples of what to send for proof of utility expenses on the verification checklist.

 

This change will happen at the end of September, 2022. In the meantime, FSSs should continue to ask about cooling/AC and, if the client is responsible for this, answer Yes to “Does your household pay for heat?” then document this clearly in case comments.

 

NH Easy Update(s)

 

There are no updates to NH Easy.

 

DESCRIPTION OF REVISIONS MADE TO FORMS

 

A new version of BFA Form 768, Shared Shelter Arrangements, is being released with this SR for use immediately. This form has been translated to Spanish. Changes to the form include adding air conditioning as a utility expense and adding a line at the bottom of the form for the lease holder signature, along with formatting changes to enhance readability and provide more space for clients to enter information. BFA Form 768(i) has also been updated accordingly. The current versions of BFA Form 768 and 768(Sp) should be recycled and the new versions used immediately. A Certificate of Destruction has been included in this SR.

 

BFA Form 775, Rental Verification Request, has been updated to move the question “Does this tenant pay excess usage fees for heating? Cooling?” from the section for subsidized housing to the top section that is to be completed for all types of housing. The current version of this form should be recycled and the new version used immediately. A Certificate of Destruction has been included in this SR. The New HEIGHTS generated form AE0010 Rental Verification Request has been updated to reflect the same change.

 

All forms identified in this SR are available in the DHHS Warehouse and can be ordered using current forms reordering procedures, via the Quarterly Forms Order (QFO). The forms are also available electronically, for Department staff only, in the DFA Folder on the N: Drive as of September 1, 2022. The forms will also be available on NH Easy September 1, 2022.   

 

The Spanish translation of Form 768 may be printed from the DFA folder on the N: Drive or from NH Easy. If a larger supply is required, contact the Supervisor of the Policy Development Unit.

 

POLICY MANUAL REVISIONS

 

Revised Food Stamp Manual Topics

Table I                            SNAP Deductions

Section 603.09              Other Allowable Deductions – Shelter Deduction

Section 603.09              Other Allowable Deductions – Utility Standards

Section 603.11              Verification of Deductions

Section 611.05              Income of Disqualified and Excluded Individuals

 

IMPLEMENTATION

 

The policy changes released in this SR are effective immediately. Please begin using the new versions of Form 768 Shared Shelter Arrangements and Form 775 Rental Verification Request immediately. Updated manual pages will be available in the online manual on October 1, 2022.

 

CLIENT NOTIFICATION

 

On June 23, 2022 a one-time letter was mailed to approximately 8500 open SNAP cases with either the 2-Utility SUA or Electric-Only SUA advising the recipient if they are billed for air conditioning costs separate and apart from their rent or mortgage they should provide verification of that expense. A copy of this letter is attached for reference. No further client notification is needed or planned.

 

TRAINING

 

No special training is planned or needed.           

 

FORMS MANUAL POSTING INSTRUCTIONS

 

Remove and Destroy

Insert/Replace

 

BFA Form 768, Shared Shelter Arrangements,

BFA SR 20-25, 10/20

1 single-sided sheet

 

BFA Form 768(Sp), Shared Shelter Arrangements

BFA SR 20-25, 10/20

1 single-sided sheet

BFA Form 768, Shared Shelter Arrangements,

BFA SR 22-29, 09/22

1 single-sided sheet

 

BFA Form 768(Sp), Shared Shelter Arrangements,

BFA SR 22-29, 09/22

1 single-sided sheet

DFA Form 768(i), Instructions for DFA Form 768,

DFA SR 14-15, 12/14

1 double-sided sheet

 

BFA Form 775, Rental Verification Request

BFA SR 19-29, 10/19

1 double-sided sheet

BFA Form 768(i), Instructions for BFA Form 768,

BFA SR 22-29, 09/22

1 double sided-sheet

 

BFA Form 775, Rental Verification Request

BFA SR 22-29, 09/22

1 double-sided sheet

DISPOSITION

 

This SR may be destroyed or deleted after its contents have been noted and the revised manual topics released by this SR have been posted to the On-line Manuals.

 

DISTRIBUTION

 

This SR will be distributed according to the electronic distribution list for BFA policy releases. This SR, and revised On-Line Manuals, will be available for agency staff in the On-Line Manual Library, and for public access on the Internet at https://www.dhhs.nh.gov/sr_htm/sr.htm, effective October 1, 2022.

 

BFA:sh

 

CERTIFICATE OF DESTRUCTION

I certify that all copies of BFA Form 768, 768(Sp) and 775 have been destroyed.

District Office Administrative Supervisor:

 

District Office:

 

 

 

Return this certificate to the BFA Policy Development Unit, 129 Pleasant St, Brown Bldg, 3rd Floor, Concord, NH 03301 after the instructions in the SR have been carried out, but within ten (10) days from receipt of this SR.