WIC Income Eligibility

1. Division of Public Health Idaho Department of Health and Welfare WIC Income Eligibility Idaho WIC Program – 12/2014 Reproduced From USDA Policy Branch WIC Income Eligibility Presentation (available 7/2014) WIC is an equal opportunity employer and provider

2. Income Eligibility GuidanceObjectives: • Review what is considered income and how to determine the economic unit • Identify how to document and verify income • Review 30-day temporary certification procedures

3. Income Eligibility GuidanceOverview: • The WIC Income Eligibility Guidance • Required implementation date of October 1, 2013 for States not in compliance • Idaho WIC Program met all requirements, no policy changes required (IWPPM Ch. 4) • Updated guidance/clarifications

4. Income Eligibility GuidanceDiscussion: • What questions do you have about income eligibility?

5. Income Eligibility Guidance • What is considered income? • WIC guidelines define income as “gross cash income before deductions for income taxes, employees’ Social Security taxes, insurance premiums, bonds, etc.” • Other cash income includes student financial assistance, such as grants and scholarships

6. Income Eligibility Guidance: Loans • Student financial assistance (loans or grants) intended to pay for room, board, or dependent care expenses are included as income • Grants and scholarships excluded as income are listed in the IWPPM 4-B-10 • Examples of excluded • Pell Grants, State Student Incentive Grants, and National Direct Student Loans

7. Income Eligibility Guidance: Loans • Loans, either from a bank or from a personal resource (friend, church, etc.), are also excluded from income since these funds are only temporarily available and must be repaid

8. Income Eligibility Guidance: Current vs. Annual • Generally “current” should mean • The most recent income available to the applicant that accurately reflects their household’s financial circumstances • Some flexibility in deciding to use an applicant’s current or annual rate of income, within reason • Decision is not based on whatever makes a client eligible for the program, meaning if they do not have any changes to their current situation we cannot use annual

9. Income Eligibility Guidance: Current vs. Annual • Idaho WIC does define “current income” as • Income received by the household during the month (30 days) prior to the time the application for WIC benefits is made • On a case-by-case basis we may need to consider other factors and look at more than 30 days • Further guidance under IWPPM 4-B-9

10. Income Eligibility Guidance: Current vs. Annual (cont’d) • If the income assessment is being done prospectively, “current” should refer to income that will be available to the family in the next 30 days • Example • The sole supporter of the family has just been laid off but has been authorized to receive unemployment benefits for the next six months

11. Income Eligibility Guidance: Resource

12. Income Eligibility Guidance: Current vs. Annual (cont’d) • Examples when current income may be recommended • The family where someone who is on a furlough or temporary government shutdown may have a lower income during that period, but have an annual income which would exceed the WIC income eligibility guidelines

13. Income Eligibility Guidance: Current vs. Annual (cont’d) • Examples when annual income may be more appropriate • A family member who is on maternity leave • Teachers who are paid on a 9-10 month basis and are temporarily on leave for the summer • College students who work only during the summer months and/or school breaks • Frequent and consistent overtime pay

14. Income Eligibility Guidance:Self-Employment • Always use net income when determining eligibility for self-employed applicants • Do not use gross income • Use the applicant’s most recent IRS tax return • Use the adjusted net income figure on the IRS tax return • It is not our responsibility to challenge or recalculate that amount

15. Income Eligibility Guidance:Applicants Reporting Zero Income • Applicants declaring zero income should be prompted to describe in detail their living circumstances and how they obtain basic living necessities • Food, shelter, medical care and clothing

16. Income Eligibility Guidance:Applicants Reporting Zero Income (cont’d) • In most instances, applicants actually have income which may be “in-kind” and affect the size of the economic unit • Example • A young pregnant woman and her husband are both unemployed and report a household of 3 with no income • They are not on another program that would make them income eligible • It is determined they live with her mother and are meeting their basic needs with the mother’s income • In this situation, they should be counted as a household of 4 and income determination would be based on the mother

17. Income Eligibility Guidance: Income Documentation • "Documentation of income" means presentation of written documents • Current pay or unemployment benefits • Earnings statements • W-2 forms with the corresponding income tax returns

18. Income Eligibility Guidance: Income Documentation (cont’d) • Applicants must provide documentation of income at certification • Except in limited situations where documentation may not be available • Examples • Individuals who are homeless • Families who recently experienced a fire or other disaster • Applicants who work for cash

19. Income Eligibility Guidance: Income Documentation (cont’d) • It is acceptable to request a written statement from a reliable third party who has knowledge of the applicant’s income • Example • Staff of a social service agency, church or legal aid society, or employers

20. Income Eligibility Guidance: Income Documentation (cont’d) • If another form of documentation is used and not listed as an option to select in WISPr, staff should document what was used to determine eligibility somewhere in WISPr • In limited circumstances, the applicant must sign the No Proof form specifying why he/she cannot provide the documentation of income

21. Income Eligibility Guidance:Income Verification • Verification is a process whereby the information presented, such as pay stubs, is validated through an external source of information other than the applicant • Federal WIC regulations allow (but do not require) the State or local agency to verify income • FNS encourages verification of any questionable information in order to maintain the integrity of the Program

22. Income Eligibility Guidance:Lack of Income Documentation • Applicants are required to bring the following documentation: • Proof of income, identity and residency • If an applicant fails to bring proof of income, the local agency must do one of the following: • Schedule a new certification appointment or • Certify the individual based upon a signed self-declaration (Rights, Responsibilities and Consent) for no more than 30 days

23. Income Eligibility Guidance:Lack of Income Documentation (cont’d) • If the applicant fails to provide the documentation within the 30-day time limit, the individual shall be determined ineligible for WIC • If the applicant brings in the documentation within the 30-day period and is found to be eligible, the applicant should be certified for a full certification period, beginning with the date that WIC benefits were initially provided

24. Income Eligibility Guidance:Lack of Income Documentation (cont’d) • Under no circumstances can a second, subsequent 30-day certification period be used if the applicant fails to provide the required documentation of income • The same policy applies to applicants who fail to produce documentation of residency and/or identity

25. Income Eligibility Guidance: • What has worked well to avoid 30-day temporary certifications? • How can WIC help ensure missing documents are brought in before the 30 day cert ends once a temporary certification has been given?

26. Income Eligibility Guidance: Family/Household/Economic Unit • Defined as • “a group of related or nonrelated individuals who are living together as one economic unit" • There can be more than one economic unit living under one roof • The most important rule to apply to all applicants, including minors, is that an economic unit must have its own source of income • Adequacy of the income, not whether the unit receives any in-kind benefits, should be the determining factor

27. Income Eligibility Guidance: Family/Household/Economic Unit (cont’d) • In assessing “adequacy of income,” the actual living and support costs for the economic unit in that environment must be considered • Example • A pregnant woman who is sharing an apartment with her sister may be determined to be a separate economic unit from her sister IF the certifier can reasonably establish that she has a separate source of income and is paying her proportionate share of household, living and personal expenses

28. Income Eligibility Guidance: Adjunctively Eligible • For participants who are Income Adjunctively Eligible (AE) • Verbal income report should be collected • Additional proof of income should not be required or requested • If they do not know their exact income • Try to obtain their best estimate • Zero should not be recorded nor should a No Proof form be completed • You may need to use an estimate of their assistance (TANF, SNAP, etc.)

29. Income Eligibility Guidance: Summary • The WIC Income Eligibility Guidance: • Covered existing FNS instructions and policy memos already available in the Idaho WIC Program Policy Manual. • Discussed what income is, how to document participant income for eligibility, and economic unit determination. • Clarified the number of temporary certifications allowed when an applicant lacks necessary income documentation

30. Income Eligibility Guidance: • Questions? • Thank you for your participation!