Mid Certification Reviews

Revised January 31, 2024

WAC 388-418-0011 What is a mid-certification review (MCR), and do I have to complete one in order to keep receiving benefits? 

• Clarifying Information and Worker Responsibilities

Clarifying Information - WAC 388-418-0011

1. A mid-certification review (MCR) is:
   1. A request to confirm current circumstances or report changes to determine continued eligibility for benefits and to calculate ongoing monthly benefits;
   2. Due six months into a 12-month certification period unless:
      1. The assistance unit has a certification period six months or less, or
      2. All adults in the assistance unit are elderly or disabled and have no earned income.  
         1. Basic Food cases in a 36-month certification, period originally certified as ESAP, will have MCRs for the remainder of the certification period due in months 12 and 24. See Elderly Simplified Application Project (ESAP)

2. Review items for MCR:  
   The requirements for the MCR vary by program.  See below for elements that must be reviewed and updated:  

4. Required proof for the MCR:  We don't require proof of an increase in income deductions change unless it's questionable. The verification a recipient must provide to count an MCR as complete depends on the benefits they receive.
   
   1. For Food MCRs:
      

      1. If the recipient's reported deduction isn't questionable, allow the increased expense.  If you have all other mandatory verifications, treat the MCR as complete.

      2. If the deduction is questionable (for example; client reports household rent has gone up from $800 per month to $1600 per month), don't allow the increased expense without verification.  If you have all other mandatory verification, treat the MCR as complete and add text to the letter informing the person to provide verification of the change if they want it to be counted for benefits.  Leave the old deduction amount (if any) as is until the next eligibility review (ER) or until verification is provided.

      3. The recipient doesn't have to answer questions about pregnancy, individuals with disabilities, health insurance, cash resources, vehicles, or utility costs. These questions aren't included on the Food-Only version of the MCR mailed to Basic Food and FAP households not receiving any cash benefits that require an MCR.

      4. There is no requirement to provide verification of reported changes before we act on the changes unless there is a change in income that will increase the Basic Food/FAP benefit.  If the recipient doesn't provide verification of income that will increase the benefit don't make the income change. The benefit continues at the current amount, and verify the income change during the next recertification.

      5. If the recipient is exempt from Work Registration due to this income that may change their exemption status. We must take action to determine the recipient's Work Registration status.

      6. If a mandatory ABAWD participant reports this change, we must determine if the reported changes will impact their participation status.

      7. If there isn't enough information to determine Work Registration or ABAWD participation status, we must send a request for information.

      8. The recipient has the option to complete the MCR process by using the Food-Only MCR form with questions relating to food benefits only or the multi-program MCR form and only answer the questions needed for the food benefits.

      9. Information reported that isn't required for the MCR should be processed as part of the MCR effective in month seven if the MCR has been submitted timely (before benefits are closed for no MCR)

         NOTE: 

         When an MCR includes both an unverified change resulting in decreased benefits and an unverified change causing an increase in benefits, act upon the change causing the decrease without verification, but don’t make the change to increase benefits if verification isn’t provided with the MCR.   See Effective Date - Change of Circumstances

          

         EXAMPLE: 

         Cheyanne’s MCR is due in July. They provide an MCR on 7/18 and report both a job quit and new job, without verifying the end of the old job. Cheyanne’s MCR is processed and August benefits are determined using both the newly reported income and the existing income from the previous job as the income decrease isn’t verified.  The MCR is complete and the worker includes canned text MCR05 – Food $ Decreased not verif indicating the reported decrease in income wasn’t processed as the change wasn’t verified.

   2. For Cash MCRs:

      1. The form instructs the recipient to verify the changes they tell us about on the MCR, except increases in deductions.  If they don't include the verification with the MCR, consider whether the change affects benefits or is questionable before deciding whether the MCR is complete or incomplete.

      2. If the recipient’s reported deductions aren't questionable, allow the increased expense. If you have all other mandatory verifications, treat the MCR as complete.

      3. If the deduction is questionable, don’t allow the increased expense.  If you have all other mandatory verification, treat the MCR as complete and add text to the letter informing the person to provide verification of the change if they want it to be counted for benefits. Leave the old deduction amount (if any) as is until the next eligibility review (ER) or until verification is provided.

      4. Adult recipients of TANF must give us proof of their income even if their income hasn't changed.

      5. For a child-only TANF grant, the non-needy members don't have to provide proof of their income.

      6. If the recipient reports no changes for Basic Food and TANF and didn't give proof of their income, process the MCR as complete for Basic Food and incomplete for TANF.

      7. Additional information reported that isn't required for the MCR should be processed as part of the MCR effective in month seven if the MCR has been submitted timely (before benefits are closed for no MCR).

5. Applications or Eligibility Reviews (ER) received in the sixth month:
   
   1. Process the form as an MCR as described under WAC 388-418-0011.
   2. If extra information is reported (more information than is required for an MCR) then treat this information as a change of circumstance and consider the impact on benefits and the effective date of the change using adverse action/adequate notice rules under WAC 388-418-0020.
   3. Don't require the household to provide any more verification or information than is required for an MCR.

6. MCRs completed late:  If someone doesn't complete the MCR on time, ACES closes the benefits at the end of the sixth month (month MCR is due). We treat MCRs completed after the sixth month as described below:
   
   1. Completed by the last day of the seventh month: Process the MCR to determine ongoing eligibility for benefits and reinstate benefits if appropriate.

2. Received later than the seventh month: Document when you received the MCR and send the recipient an application for benefits.

7. Applications or Eligibility Reviews received in the seventh month, or annually for cases with a 36-month certification period:
   
   1. Process the form as an MCR as described under WAC 388-418-0011.  All information reported on the ER must be acted on even though the information may not be an MCR reportable item. 
   2. Don't require the household to provide any more verification or information than is required for an MCR.
   3. The household may specifically request we treat the application or ER as a new application for food.  There is no need to contact the household to ask how it wants to treat the application/ER if a responsible person in the household hasn’t already requested this in writing or verbally.  
   4. Expedited services can be considered if treated as a new application.  ACES should set a new, 12-month certification period.
   5. See ACES PROCEDURES for information on screening the application or eligibility review if we treat the document as a new application. 

8. Requests to add a person on the MCR:  The MCR asks about people moving into the household and whether or not they want benefits for this person. See below to decide if you need an application or Eligibility Review (ER) form to add the new person to the current benefits:

9. Requests to add a program or program change on the MCR: For all programs, a recipient must complete a new application or ER form to add a program.  When recipients report changes that makes them ineligible for the active cash program but eligible for another cash program, verify the change and process the cash program change without a new application or ER form unless it's required for other reasons.  See CSD Procedure Handbook – Change of Circumstances Processing (For staff only) for procedures. 

10. Completing the MCR over the phone:
    
    1. You don't need a signed MCR form to count the MCR process as complete as long as you review the following with the recipient:

2. It is a federal requirement for the SNAP periodic reporting (MCR) process to have the recipient acknowledge understanding of the statement above either by signing a form with the statement on it or providing verbal acknowledgment after the statement is read to them. Document that the recipient acknowledged their understanding. A signed MCR Statement of Understanding form isn't required to complete the MCR when an application or eligibility review is used in place of the MCR.

11. MCRs completed in the local office:  We process MCRs completed in the local office based on the way we receive the report:
    
    1. Completed Forms:
       An MCR form completed on paper or electronically is processed the same way we would process one received by mail or fax. The recipient must sign the form to acknowledge that they understand the information they provided for the MCR may reduce or stop their benefits.
    2. In Person Reports:
       The in-person verbal report can't be used to complete the MCR requirement unless they also complete and sign the Statement of Understanding Form 02-611 or a copy of the MCR form printed from Barcode. The MCR Statement of Understanding form isn't required when a signed application or eligibility review is used in place of the MCR form.

For information on when a former ESAP client is required to submit annual MCRs, see Elderly Simplified Application Project (ESAP).

Worker Responsibilities -WAC 388-418-0011

1. Working alerts, Barcode tickles, and checking other systems as part of processing the MCR:

To reduce the risk of payment errors, work related Alerts in ACES, Barcode tickles, and review systems such as SEMS as appropriate to ensure that the income you budget is based on the best available information.

ACES PROCEDURES

•  See Eligibility Review / Recertification Process - Mid-certification reviews.