How Vehicles Count Toward the Resource Limit for Cash and Food

Clarifying Information - WAC 388-470-0070 

1. To be considered a vehicle, the transportation device must have a motor. If it doesn’t have a motor, it’s considered personal property.
2. To determine the fair market value of a vehicle, check the current value as listed in the Kelley Blue Book at https://www.kbb.com/or JD Power at https://www.jdpower.com/cars. The amount owed on the vehicle is subtracted from the value to determine the amount of equity the person has in the vehicle. The equity value of the vehicle is the countable resource amount.
3. The entire value of one vehicle, used by the assistance unit as a means of transportation, is excluded.
4. If a client in the assistance unit has a physical disability, an additional vehicle they use for transportation can be excluded
5. Even though motor homes are generally considered vehicles, we don’t treat them like vehicles for cash assistance. We treat motor homes the same way we treat real property. See WAC 388-470-0045 for how to treat real property.
6. To determine if a vehicle should be considered a motor home, use this definition:

A motor home is a vehicle that’s designed to provide temporary living accommodations for recreational, camping, or travel use. It’s built on or permanently attached to a self-propelled motor vehicle chassis, or on a chassis cab or van, that’s an integral part of the completed vehicle.

 Clarifying Information - WAC 388-470-0075

1. Categorical Eligibility:

   We don't count a client's vehicles as a resource if their AU is categorically eligible (CE) for Basic Food under WAC 388-414-0001.

2. Resources of ineligible AU members:

   Resource rules apply to all AU members. This includes someone who is an ineligible member of the AU under WAC 388-408-0035.

3. What counts as a vehicle for Basic Food:

   The following items are not considered vehicles for Basic Food:

   These items are considered personal property.

   • Motorized children’s cars/trucks;
   • Utility trailers such as horse trailer; or
   • Campers.
4. Leased Vehicles:

   We do not count leased vehicles toward the assistance unit's resource limit.

5. Vehicle used to transport a physically disabled AU member:
   1. We can exempt one vehicle for each physically disabled AU member. The disability does not have to be permanent to qualify for the exclusion.
   2. Use prudent person to determine if the person is physically disabled.
   3. If the person does not appear to be physically disabled but they claim that they are, ask them to provide verification from a physician. In circumstances that appear questionable, please contact CSD Headquarters, Office of Programs and Policy, Program Manager assigned to the program for assistance to determine if the exemption is appropriate.
   4. If a temporary disability ends, the vehicle exclusion for transporting a disabled member also ends.

 Worker Responsibilities - WAC 388-470-0075

1. Use the following chart to help you decide how to treat a vehicle:

   For the following types of vehicles:	Fair Market Value - FMV Test	Equity Test
   Producing Income	Exempt	Exempt
   Used as a home	Exempt	Exempt
   Transporting a disabled household member	Exempt	Exempt
   Carrying fuel for heat or water for home use	Exempt	Exempt
   Value is inaccessible (sale would produce $1500 or less)	Exempt	Exempt
   One licensed vehicle per adult household member	FMV - $4,650 = Excess Value	Do Not Apply Equity Test
   Any other licensed vehicle a household member under age 18 drives to work, school, training, or to look for work	FMV - $4,650 = Excess Value	Do Not Apply Equity Test
   Additional Licensed Vehicles	Use the greater of:
   FMV - $4,650 = Excess Value	FMV - $ Amount Owed = Equity Value
   Unlicensed Vehicles	Do Not Apply Fair Market Value Test	FMV - $ Amount Owed = Equity Value

2. Determining the value of a vehicle:

   1. Use the trade in value from Kelley Blue Book online to determine the value of the vehicle. You will need to enter the mileage and the condition. Use the greater amount of the client's actual mileage or 12,000 miles x age of the car in years.
   2. If the vehicle is not listed in Kelley’s, you may use the NADA hard cover to determine value. The on-line NADA free website should not be used by State agencies for vehicle valuation.

      Food & Nutrition Services Administrative Notice 99-37:”To determine if the low retail value on the NADA free website is equivalent to a vehicle's wholesale value we compared the NADA low retail value with the wholesale or trade-in values listed on other websites for several different vehicles. In every case the NADA low retail was well above the wholesale value on the other websites (as well as the wholesale value in the NADA paper blue book). The differences between the NADA low retail values obtained thorough its free website and the wholesale values from other sources were so significant (in some cases the difference was well over $1,000) that we have determined that the NADA free website may not be used by State agencies for vehicle valuation.”

   3. If the client disagrees with the information from Kelley Blue Book or NADA hard cover, ask the client to verify the true value of the vehicle from a reliable source.

3. Amount Owed:

   Accept the client’s statement of the amount the client owes on a vehicle unless you have a reason to question what they state. If the statement is questionable, ask the client to verify the amount they owe.

4. Vehicles with $1,500 or less equity:

   Exclude a client's vehicle for Basic Food when they would not get more than $1,500 out of the vehicle if they were to sell it.

   1. Use the current fair market value of the vehicle would be whatever price the AU could sell it for at present and in its present condition. Do not use the purchase price the client bought the car for unless the client could actually sell it for this amount.
   2. If you determine a value for the client's vehicle and the client disagrees with the value, give them the opportunity to verify the true value from a reliable source. This includes sources as mechanics, used car dealers, junk dealers etc.
   3. Subtract any amount the client legally owes on the vehicle if they were to pay the loan off today. Do not use the contract amount that includes interest over the period of the loan.
   NOTE:

   The equity someone has in a vehicle changes with the payments the client makes as well as the changing resale value of the vehicle. A vehicle you exclude for having equity of $1,500 or less at one point may count as a resource at some point in the future. Review the equity value at each recertification.

   EXAMPLE:

   A three-person Basic Food unit AU contains a ten-year-old child who has a physical disability. The AU has four vehicles in their names:

   • 1988 Ford Taurus with a FMV of $1,240. Nothing owed;
   • 1988 Hyundai Excel with a FMV of $125. Nothing owed;
   • 1999 Ford Mustang with a FMV of $7,955 - $6,455 owed; and
   • 2001 Mitsubishi Galant with a FMV of $8,550 - $2,400 owed.

   In this example, exclude the Mitsubishi Galant because it is needed to transport the disabled child. Exclude all the other vehicles because the AU has equity of $1,500 or less in each car.

   EXAMPLE:

   A two-person Basic Food unit AU has one vehicle in their name:

   • 1993 Mazda RX7 Coupe with a FMV of $9,625. - $4,200 owed;

   In this example, we can't exclude the vehicle based on use or the client's equity in the car. Subtract $4, 650 from the FMV of $9,625 and count $4,975 toward the client's resource limit for Basic Food . The AU is not eligible for Basic Food.

   EXAMPLE:

   A one-person Basic Food unit AU has two vehicles. The client uses one vehicle for their taxi business (the Ford) and the other vehicle for their personal use:

   • 2001 Ford Crown Victoria with a FMV of $9,725 - $1,900 owed;
   • 1987 Porsche 944 Coupe with a FMV of $2,125. Nothing owed.

   In this example, exclude the Ford because the client uses it to produce income. Exclude the Porsche because the FMV is less than $4,650.