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Issue Alert - 07-02-03 Revised

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Date:

Apr 17, 2007

Program Area:

Family Independence Program (FIP)

Issue Summary:

Beginning February 1, 2007, Extended Family Independence Program (EFIP) will provide $10 per month for 6 months to certain working families whose FIP cases otherwise would close due to earnings

Persons Affected:

Families that become ineligible for “regular” FIP because of earnings

For More Information:

Center for Civil Justice 320 S. Washington, 2nd Floor Saginaw, MI 48607 (989) 755-3120, (800)724-7441 Fax: (989) 755-3558 E-mail: info@ccj-mi.org

Michigan Poverty Law Program 611 Church Street, Suite 4A Ann Arbor, MI 48104-3000 (734) 998-6100 (734) 998-9125 Fax


Background

The Family Independence Program (FIP) provides cash assistance to very low income families with children.  When a family’s earnings increase, they may become ineligible for FIP because their budgeted income is over the allowable level.  

 

In order to avoid monetary penalties from the federal government, Michigan must ensure that 50% of the work eligible families on FIP are in countable, work-related activities for a required number of hours each week.  This is known as the “federal work participation rate requirement.”

 

By keeping working families on FIP, Michigan will increase its work participation rate and be less likely to suffer federal penalties. 

The interim policy bulletin announcing the EFIP benefit is Program Policy Bulletin 2007-003, available online at http://www.mfia.state.mi.us/olmweb/ex/PP-2007-003.pdf.

What's Happening?

Effective April 2007, the EFIP policy is in Program Eligibility Manual item 519, DHS bulletins and policy manuals are available online at http://www.mfia.state.mi.us/olmweb/ex/html/ or by using the quick link at the Michigan Poverty Law Program (MPLP) website, http://mplp.org/.  Look for the relevant manual (or the bulletin log) under the Financial Assistance heading.

 

Beginning February 1, 2007, families that become ineligible for FIP because of earnings will qualify for Extended FIP (EFIP) benefits of $10 per month for 6 months, if the amount of child support that they expect to receive is less than $60 per month.   The families must meet all other FIP eligibility requirements, including Work First requirements when applicable.  In addition, DHS will terminate EFIP if they know that no one in the group has earnings.

 

When a family is transferred from “regular” FIP to EFIP, DHS must determine whether they remain eligible for Low Income Family (LIF) Medicaid or whether they must be transferred to Transitional Medicaid (TMA).  

 

While the family is on EFIP, they do not have to report changes in income or family composition.  However, they must meet all other FIP eligibility requirements.  DHS will monitor expected child support to determine whether the family becomes ineligible for EFIP because child support is expected to exceed $60 per month.

 

Although there will be a 48 month time limit on receiving FIP benefits beginning October 2007, months in which the individual is working and complying with their Family Self-Sufficiency Plan will not be counted toward the 48 months.  Because families on EFIP are working and must be in compliance with their Family Self-Sufficiency Plan, the months they receive EFIP should not count toward the 48 month lifetime limit.   

 

Advantages of EFIP eligibility include:  eligibility for 100% of the Child Care assistance payment rate; eligibility for Direct Support Services; categorical eligibility for energy assistance.   

 

Disadvantages include:  potential for work/Work First sanctions for job quit, termination of employment based on absenteeism or misconduct, failure to comply with Work First, etc.

 

If DHS becomes aware of changes  (either because the family chooses to report them or because information is received from another source), DHS must determine whether the family continues to be eligible for EFIP.  If the family’s income goes down or a new member is added to the group, and it appears the family will the family is eligible for regular FIP, DHS will request any necessary verification and will return the family to regular FIP once verification is received.  If the reported change means that no group member has earnings, the family must provide verification to establish FIP eligibility, or their cash assistance will be terminated.  

 

When the family’s 6 months of EFIP ends, DHS will not redetermine eligibility for continued FIP.  The family will have to report and verify the change in circumstances that makes them eligible for regular FIP in order to continue receiving FIP at the end of the 6 month EFIP period.  Families whose EFIP ends till have to re-apply if they believe they continue to be eligible for FIP because of reduced income or larger family size. 

 

If the family has been on LIF Medicaid during the EFIP period, DHS will redetermine their eligibility for Medicaid using the usual Medicaid redetermination process.  Families that think they may be entitled to continued FIP should check the “Cash assistance” box on the application, as well as the “medical assistance” box, when they seek redetermination of Medicaid.  

 

If the family has been on TMA, they will continue to receive TMA for another 6 months after EFIP without a redetermination.

 

What Should Advocates Do?

Make sure community organizations are aware of the new EFIP benefit.

 

Make sure families on EFIP understand the pros and cons of staying on EFIP and the pros and cons or reporting changes.

 

Makes sure families do not lose Medicaid prematurely because they are transferred to TMA instead of LIF Medicaid.

 

Makes sure families know they should re-apply for FIP before their 6 months of EFIP ends if their circumstances have changed and they believe they should remain eligible for FIP.

 

Finding Help

Most legal aid and legal services offices handle these types of cases, and they do not charge a fee. You can locate various sources of legal and related services, including the free legal aid office that serves your county, at MichiganLegalAid.org. You can also look in the yellow pages under "attorneys" or call the toll-free lawyer referral number, (800) 968-0738.