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Issue Alert - 13-09-01

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Date:

Sep 11, 2013

Program Area:

Cash Assistance (Family Independence Program or FIP), Food Assistance Program (FAP), State Disability Assistance (SDA)

Issue Summary:

Verification of identity can be accomplished with a social security number data match.

Persons Affected:

Applicants for Cash Assistance (Family Independence Program or FIP), Food Assistance Program (FAP), Expedited FAP, and State Disability Assistance (SDA) benefits.

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 (MPLP) 611 Church Street, Suite 4A Ann Arbor, MI 48104-3000 (734) 998-6100 Fax: (734) 998-9125


Background

Applicants for Cash Assistance (FIP), Food Assistance (FAP) and State Disability Assistance (SDA), have to verify the identity of all group members.  Acceptable sources of verification are listed in Bridges Eligibility Manual (BEM) 221.  They include:  driver's license, state-issued identification, school-issued identification, health benefit identification, voter registration card, wage stub, etc.

 In practice, DHS has had the ability to use a computer data match between Social Security Administration records and name/social security number for each group member to verify identity.  However, such data match was not listed as an example in the DHS manuals.  As a result, it has not been used by caseworkers or clients as much as it could be.  This same issue has existed in Bridges Administrative Manual (BAM) 117 which deals with Expeditied FAP.  BAM 117 does not state clearly that a Social Security Administration computer match would suffice for verification of identity.  When caseworkers do not accept the data match as proof of identity, this may prevent or delay the benefits case from opening.  DHS applicants have been denied benefits because the applicant has not verified the identity of one or more group members – even though such members may have already had or been able to obtain a social security card.  When applicants try to get unnecessary documents this can create barriers to obtaining benefits.  Clients may be unable to find or pay for other types of identification, miss deadlines, or have their verification papers lost within DHS. 

What's Happening?

Effective October 1, 2013, state policy makes it clear that the Department of Human Services (DHS) will accept a Social Security Administration computer match that validates the Social Security number for a group member as proof of identity for that member.  This will simplify the process of providing identity for DHS applicants who already have a social security number.

 See Bridges October Policy Bulletin BPB 2013-014, which clarifies both the policies on proving identity for FIP, SDA and FAP (BAM 221) and BAM 117 for Expedited FAP by adding language.  The link to the bulletin is http://www.mfia.state.mi.us/OLMWeb/exf/BP/Public/BPB/2013-014.pdf

 The modified policies which are effective on October 1, 2013, contain the clarified language concerning Social Security Administration computer data match prominently.  See BEM 221 at http://www.mfia.state.mi.us/OLMWeb/exf/BP/Public/BEM/221.pdf and BAM 117 at http://www.mfia.state.mi.us/OLMWeb/exf/BP/Public/BAM/117.pdf.

 As an aside, after a group begins receiving Cash Assistance (FIP) or State Disability Assistance (SDA) benefits, the fee for a state identification card is waived by the Secretary of State.  The link to the SOS page that explains this is http://www.michigan.gov/sos/0,1607,7-127-1627_8668_9059-228283--,00.html.

Proof of mailings from DHS benefits can also help people verify where they live if they are trying to get an ID card. See www.michid.org  

What Should Advocates Do?

1.   Educate clients and community organizations that verification of identity should not become a barrier for applicants when a Social Security Administration computer match by DHS staff can verify identity of some or all group members.

 2.   Help clients communicate with DHS staff if verification of identity is a barrier to application processing and eligibility determination.

 3.   Help clients request and present information at administrative hearings if and when appropriate.

What Should Clients Do?

1.     If DHS tells you to provide a document to prove identity of a group member with a social security number, ask about the Social Security Administration computer match policy.

 2.   Talk to an advocate or call CCJ if DHS will not do a Social Security Administration computer match to verify identity of members in your group.

 3.   If your application is for Food Assistance, you can call CCJ’s toll-free Helpline at (800) 481-4989.

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.
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