SR 07-09 Dated 10/06

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SUMMARY

This SR releases the implementation of the New Hampshire Employment Program (NHEP) "Sanction Clock," as mandated by RSA 167:82,V(f). NHEP financial assistance benefits will terminate for the entire assistance group when any NHEP cash applicant or recipient has been in a sanction status for 3 months in a 12-month period. Once terminated for this reason, the individual must reapply for assistance, fully comply with NHEP requirements for two full weeks, and meet all other program requirements, before eligibility can be redetermined. The sanction clock will not apply to Unemployed Parent (UP) cash recipients. Form 221, NHEP Pamphlet, was updated to include the sanction clock policy.

Additionally, Form 220, Notice of Failure to Meet Work Requirements, and its associated instructions, were revised to better align with changes released in SR 06-12, dated 10/06.

POLICY

Beginning with sanctions occurring in October 2006, NHEP financial assistance benefits for the entire assistance group will terminate for cases including NHEP cash recipients who have been under any level of NHEP sanction in any 3 of the last 12 months. The 3 months do not have to be consecutive and the sanction clock will not apply to UP cash recipients.

After being closed due to the sanction clock, individuals may re-apply for NHEP financial assistance. Before eligibility can be redetermined however, applicants must:

·   fully comply with NHEP work requirements for two consecutive weeks; and

·   meet all other program requirements.

Any period in a calendar month that an individual spends in sanction counts as 1 month towards the sanction clock, and the 12-month look-back period begins 12 months prior to the current month.

Note: Child support sanctions are not counted towards the sanction clock. Only NHEP work program sanctions are counted towards the sanction clock.

Form 221, NHEP Pamphlet, was updated accordingly.

HEIGHTS CHANGES

A new screen entitled "Sanction Clock" tracks the months an individual has been in any level of a NHEP sanction over the previous 12-month period. On the last business day of the month, New HEIGHTS will identify all individuals with a current NHEP sanction who now have 3 months on the sanction clock within the current 12-month look-back period. NHEP financial assistance will then terminate and a closing notice of decision (NOD) will be automatically mailed to these individuals. New denial reason "Sanctioned for 3 months in last 12 months," and the following text will be added to the NOD generated due to the sanction clock: "You or someone in your household has reached the limit of 3 months in sanction within a 12-month period."

Note: The sanction clock screen will also display a row for any month a person has been

under sanction since 11/2005. However, only months in sanction beginning

with 10/2006 will actually be used in the "3 sanctioned months" count.

POLICY MANUAL REVISIONS

Revised Family Assistance Manual Topics

Section 808.15   Orientation

Section 808.35  Sanctions for Voluntary Quit Or Failure/Refusal to Cooperate with NHEP Work Program Participation Requirements

FORMS REVISIONS

Form 221, NHEP Pamphlet, was revised to include information about the sanction clock policy released in this SR. The current stock of this form must be exhausted before the new version is printed.

WP0012, New HEIGHTS generated letter Failure to Meet Work Requirements, was revised during the release of SR 06-12, dated 10/06. These revisions included the following new text about the sanction clock:

Note: Your case will automatically close if you have been in a sanction status at ANY level for a total of 3 months in the previous 12-month period. The 3 months do not have to be consecutive!

Additionally, related revisions were made to Form 220, Notice of Failure to Meet Work Requirements, to better align with changes released in SR 06-12:

·   Text related to the scheduling and rescheduling of an NHEP Orientation was removed as the NHEP Orientation is no longer a work requirement, but a condition of eligibility;

·   Text related to the NHEP sanction conciliation process was removed from the form as this process was obsoleted with the release of SR 06-12; and

·   Text was added to clarify that all good cause claims must be accompanied by documentation.

The current stock of this form must be exhausted before the new version is printed.

Form 220(i), Instructions for Form 220, was also revised to better align with the changes described above:

·   This form is no longer used as a back-up for New HEIGHTS-generated client letters CS0015, Work Program Reschedule Interview, and CS0021, Work Program Reschedule Interview. Both of these client letters were generated to schedule and reschedule participants for an NHEP Orientation, and both were obsoleted during the release of SR 06-12 when attendance at the NHEP Orientation became a condition of eligibility for financial assistance;

·   Information related to scheduling and rescheduling work program appointments was updated to reflect that this now only applies to the Food Stamp Job search program;

·   Text related to the NHEP sanction conciliation process was removed; and

·   Text was updated to explain the different time limits that an individual has for claiming good cause for non-cooperation with NHEP or the Food Stamp Job Search program.

IMPLEMENTATION

On February 28, 2007, New HEIGHTS will run a mass change to close NHEP financial assistance grants for assistance groups who have accumulated 3 months on the sanction clock since October 2006. NHEP financial assistance grants will not automatically close for cases that are pending. An exception report generated following the mass change will identify those cases that did not close due to pending status. When these cases are re-run through SFU, New HEIGHTS will determine when the case should close based on the confirmation day and the ANP.

CLIENT NOTIFICATION

Several one-time mailings were generated to clients to notify them of changes released in SR 06-12, dated 10/06, including two separate letters that were mailed in August 2006 explaining the new sanction clock policy.

In mid-February, New HEIGHTS identified 48 individuals who had accumulated at least 2 months on the sanction clock since October 1, 2006. Although each of these individuals would have received at least one WP0012, the New HEIGHTS-generated letter explaining the 3-month limit on sanctions within a 12-month period, State Office staff additionally telephoned these recipients on February 13, 2007 to notify them of this policy.

Additionally, information about the sanction clock is now included in the NHEP Power Point presentation shown at all NHEP Orientations.

TRAINING

Trainings on the sanction clock policy were provided to District Office Supervisors, Family Services Specialists, and DOMOs between September 18-25, 2006. Trainings for NHEP Team members were held on September 19 and 20, 2006. Additionally, the sanction clock policy was reviewed at the Supervisor’s meeting held on February 22, 2007.

FORMS POSTING INSTRUCTIONS

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 Division of Family Assistance 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 http://www.dhhs.nh.gov/DHHS/DFA/LIBRARY, effective Monday, April 2, 2007.

This SR, and printed pages with posting instructions, will be distributed under separate cover to all hard copy holders of the Family Assistance and Forms Manual.

DFA/MPM:s