Assess whether identity proofing exceptions are being abused (7cee62)

SITUATION Identity proofing exceptions are sits with TANF work-requirement monitor because a recoupment that would make a household homeless hit a state SNAP agency after an EBT skimming wave. Evidence is recoupment aging versus collectability; write the Public Benefits Recoupment and Policy option that extract can carry.

DECISION TANF work-requirement monitor in a state SNAP agency after an EBT skimming wave must choose Pay or continue / Recoup / Deny / Hold using recoupment aging versus collectability after a recoupment that would make a household homeless.

HYPOTHESES TO TEST 1. TANF work-requirement monitor can defend Pay or continue from recoupment aging versus collectability after a recoupment that would make a household homeless in a Public Benefits challenge. 2. TANF work-requirement monitor cannot defend Pay or continue from recoupment aging versus collectability; Recoup is what the extract actually supports after a recoupment that would make a household homeless. 3. A recoupment that would make a household homeless never reached the population in recoupment aging versus collectability — reopen intake, do not close identity proofing exceptions are. 4. Two facts in recoupment aging versus collectability after a recoupment that would make a household homeless conflict for TANF work-requirement monitor; hold this Recoupment and Policy file.

ANALYSIS REQUIRED 1. Match household facts in recoupment aging versus collectability to the rule that pays the benefit. 2. Trace the notice and appeal path TANF work-requirement monitor must preserve. 3. Test eligibility, recoupment, and improper-payment facts in recoupment aging versus collectability after a recoupment that would make a household homeless. 4. For this Public Benefits Recoupment and Policy file, read recoupment aging versus collectability against a recoupment that would make a household homeless and write the one fact that would move identity proofing exceptions are for TANF work-requirement monitor.

RECOMMENDATION Choose Pay or continue / Recoup / Deny / Hold on this Public Benefits / Recoupment and Policy packet (recoupment aging versus collectability after a recoupment that would make a household homeless). The follow-on Recoupment and Policy action is what TANF work-requirement monitor does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Public Benefits option on identity proofing exceptions are, then the evidence in recoupment aging versus collectability, then the action for TANF work-requirement monitor - Hypothesis scorecard against recoupment aging versus collectability: supported / rejected / untestable - Regulatory or exam hook Recoupment and Policy would cite - Recoupment and Policy finding in recoupment aging versus collectability that a second reviewer can re-perform