SNAP: Denials: Withdrawal of an Application

Policy 340:50-3-1(c)(2)

SNAP policy states “ … a household may voluntarily withdraw its application at any time prior to the determination of eligibility.” The withdrawal must be documented in FACS case notes stating the reason for the withdrawal, if any stated by the household, and that contact was made with the household to confirm the withdrawal. In addition, the household shall be advised of its right to reapply at any time.

Some staff is of the understanding that a client can withdraw an application after the worker determines the household does not qualify for SNAP benefits. If the worker tells the household they may not qualify for benefits and states the reason why (i.e. income is in excess for household size), an eligibility determination has occurred and the application must be denied (i.e., code ’03-excess earned income’) rather than withdrawn. Staff should never instruct a client to withdraw the application for SNAP benefits. A withdrawal request should be an action the client initiates for the client’s own reasons. A suggestion by staff to the client to withdraw the application should never occur.

Example #1:
A worker begins to interview the client, and by looking at information provided by the client determines the client is not eligible for benefits due to: income, resources, alien status, or any other reason. The worker then tells the client they are not eligible due to the information provided. What action should be taken on this application? Can the worker suggest the client sign or request the application be withdrawn?

Answer: Since the worker has made an eligibility determination, the client cannot be instructed to withdraw the application. The application must be denied for the reason that makes the household ineligible for SNAP benefits. This means if the household earned income is over the maximum standard for the household size, the worker should take action to deny the application using ’03-excess income’. The appropriate notice is sent to the household.  FACS case notes must be updated with the income verification used to make this determination and the reason why the application is denied. The worker cannot ask the household to withdraw the application.

Example #2:
A non-elderly/disabled household comes in to apply for benefits. During the expedited screening process, the client declares income in excess of the income limit for the household size the worker informs client of the income guidelines. The client states that they do not wish to provide income verification. As the client does not wish to provide income verification or proceed with the interview, the worker will deny the case using reason “Clients Request Because of Employment (46A).” The worker will sufficiently document in case notes that the client did not wish to proceed with the eligibility process.

Example #3:
Client completed the interview and needs to provide verification of terminated income. Two days later the client called the worker to state she has obtained a new job and requested her application be withdrawn. The worker explained the client could still be eligible for the month of application due to terminated income being the only income considered for that month as the new income will not be received until the middle of next month. The client still insisted to have the application withdrawn. In this instance the application is denied per client’s request based on employment. The worker should take action to deny the application using reason code ’46A- Client’s request because of employment’ as the client initiated the withdrawal for her own reasons.

Staff should be cautious in giving clients determinations of eligibility information during the interview, as additional verification might change the decision shared during the interview. This is especially true for those households with elderly/disabled members as the net SNAP income must be computed to determine SNAP eligibility. This cannot be done without documentation of all allowable deductions, such as out of pocket medical expenses. Making a determination of ineligibility during the interview without all verification can lead the client to believe he/she should withdraw the application.

Example #4:
Worker has completed the face-to-face interview with the client. An ADM-92 is given to the client requesting verification. The client asks how he/she would know if he/she is eligible. The worker should explain to the client that eligibility cannot be determined without the requested verification. If, after the verification is provided, and it is determined the client is not eligible, a notice will be issued to the client.

Although it may appear the client is ineligible based on stated income and expenses, the worker must request all necessary verification prior to making an eligibility determination.

When an application is withdrawn, the client waives his/her right to a fair hearing. For this reason, staff should never encourage the withdrawal of the application as this could be part of the written explanation by the client. The client has a right to request a fair hearing when an adverse action is taken.

Please direct any questions to the SNAP Mailbox at afs.snap@okdhs.org

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