State of Wisconsin Department of Health Services

Release 24-01 April 3, 2024

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1.2.3 Non-Financial Verification

1.2.3.1 Identity Verification

7 CFR 273.2(f)(1)(vii)

At the time of application, verify the identity of the primary person (if not already verified). If an authorized representative applies on behalf of the food unit, then verify the identities of both the authorized representative and the primary person.

Note	A complete Appoint, Change, or Remove Authorized Representative form (F-10126) must be on file for an authorized representative designation to be valid. The completed Authorized Representative form meets the ID verification requirement, so no additional verification is required.

Identity is the only verification required to process expedited benefits.

Identity may be verified when the SSA data exchange returns a verified SSN code, through readily available documentary evidence, or through a collateral contact (see Section 1.2.6 Suggested Verification Sources and Section 1.2.2.2 Collateral Contacts). Any documents that reasonably establish the primary person's and/or authorized representative's identity must be accepted. No requirement for a specific type of document, such as a birth certificate or photo ID, may be imposed.

Primary persons who are undocumented immigrants are not required to verify their identity.

Note	If the primary person’s identity was verified for another program of assistance, do not re-verify the applicant’s identity. Identity is to be verified only once.

1.2.3.2 Social Security Numbers Verification

7 CFR 273.2(f)(1)(v)

Social Security numbers (SSN), or proof that application has been made for an SSN, must be provided for all household members applying for FoodShare, including newborns. Do not deny benefits pending issuance of an SSN if you have documented an SSN application was made. Failure to provide an SSN or proof of application for an SSN will result in denial of FoodShare benefits for that individual.

IM workers receive an alert when an SSN entered in CARESClient Assistance for Reemployment and Economic Support does not match the SSN verified by the Social Security System (WTPY). In these cases, verify if possible with a third party source and contact the Social Security Administration.

If the agency determines that a food unit member or applicant has refused to provide or apply for an SSN, that individual is ineligible to participate in FoodShare Wisconsin.

Exception for newborns: see Section 3.13.1.3 SSN Application for Newborns.

1.2.3.3 Immigrant Eligibility Verification

7 CFR 273.2(f)(1)(ii)

Verify the immigration status of all non-citizen FoodShare applicants (see Section 3.12.1 Citizenship and Immigration Status). If a non-citizen does not want the IM agency to contact USCISUnited States Citizenship and Immigration Services to verify their immigration status, the IM agency must give the applicant the option of withdrawing the application or participating without that member. An undocumented immigrant is ineligible until acceptable documentation is provided unless the local agency has submitted a request for verification and is awaiting a response from USCIS, SSASocial Security Administration (verification of work quarters), or another federal agency.

Verify citizenship only when the statement about an individual’s citizenship is questionable. A claim of citizenship is questionable when:

1. The claim is inconsistent with statements made by the applicant,
2. The claim is inconsistent with information on the application or previous applications,
3. The claim is inconsistent with information received from another source, or
4. The person does not have an SSN.

Do not discriminate on the basis of religion, race, ethnic background, political beliefs, or national origin when deciding if a claim is questionable. Do not target groups such as migrantany person who temporarily leaves a principal place of residence outside of his state and comes to this state for not more than 10 months in a year to accept seasonal employment in the planting, cultivating, raising, harvesting, handling, drying, packing, packaging, processing, freezing, grading, or storing of any agricultural or horticultural commodity in its unmanufactured state farm workers or American Indians for verification. A surname, accent, or appearance that seems foreign is not enough reason to question citizenship.

In addition, if an immigrant is applying for benefits on behalf of another person you may, under federal law, only verify the status of the person who will be receiving the benefits.

1.2.3.4 Disability Verification

7 CFR 273.2(f)(1)(viii)

Verify the disability status of all food unit members applying for FoodShare who are claiming to be disabled (see Section 3.8.1 Elderly, Blind, or Disabled (EBD) Individuals).

1.2.3.5 Wisconsin Residency Verification

7 CFR 273.2(f)(1)(vi)

AddressAddress refers to the actual place where the household resides. • An address is required to be provided unless a household is homeless, a migrant, or newly arrived in Wisconsin. Verification of address is not required. • A household does not have to reside in a permanent dwelling. • A household may use a general delivery address when it applies. Contrast this with "residence" in the glossary., Wisconsin residencyResidency refers to Wisconsin residency and not the mailing address. Contrast this with address in the glossary., and household composition are separate and distinct eligibility factors with different verification requirements (see Section 3.2.1 Residence).

Verification of the primary person's Wisconsin residency is required at application and, if questionable, at renewal for FoodShare eligibility, with an exception for homeless individuals and migrant workers.

Wisconsin "residency" refers to residing or living in Wisconsin but is not limited to any specific type of housing, place of residence, living arrangement, or address.

• State residency is a condition of eligibility that can be verified through a number of acceptable documents from the applicant, a collateral contact, or another source, and must not be limited to a single type of document.
• If the address on the application is not a fixed Wisconsin address, such as an address provided for mail only, and there is no additional information presented at the time of the interview to verify that the applicant resides in Wisconsin, the IM worker should attempt to obtain verification of state residency, unless the individual is exempt from the residency verification requirement.
• Applicants or households already receiving other programs of assistance, such as BadgerCare Plus, have already been determined to be living in Wisconsin. No further action is required to determine if the applicant is a state resident.

Note	Persons on vacation in Wisconsin are not residents of Wisconsin.

 

Example 1

Mary is applying for FoodShare. She refuses to provide any information regarding where she is living. Mary claims she is not homeless, not a migrant worker, and she is not participating in the Safe at Home program. Mary only provides a PO Box for her mail. No other information on Mary’s application establishes her Wisconsin residency. Mary’s application should be pended and a request for verification sent.

 

Example 2

Trent is currently open for health care. On November 13, Trent completes a program add for FoodShare. When the worker starts to process the new FoodShare request, all the information collected from the health care application is in the case. Wisconsin residency is verified and not questionable due to receiving health care. Receiving another program of assistance is a valid verification source for Wisconsin residency.

 

Example 3

Joe was homeless at the time of his application. When Joe is completing his renewal (month six), he reports he is no longer homeless and provides his Wisconsin-based address. There is no need to request verification of Wisconsin residency since he states he is living in Wisconsin and there is no indicator this would be questionable.

 

Example 4

Bethanie’s household consists of herself and her two children. The children are currently open for health care. When Bethanie completes a program add for FoodShare, her Wisconsin residency is not questionable (it is verified) because it is not questionable her children live with her, and they are already receiving health care.

Exception

Residency verification isn't required for:

• Applicants newly arrived in Wisconsin in the past 30 days.
• Homeless persons (see Section 3.2.1.3 Homelessness).
• FoodShare members temporarily absent from the food unit (see Section 3.2.1.2 Temporary Absence).
• Migrant worker applicants (see Section 2.1.4.3 Eligibility for Migrant Workers).

Note	Applicants that have arrived in Wisconsin recently, within the last 30+ days, may not have documentation to verify residency. The IM worker should use their discretion and assist with obtaining verification, along with using the best available information when appropriate to verify residency.

Questionable at renewal

An IM worker may become aware of information that makes Wisconsin residency questionable at the time of renewal. For example, a new hire match is received showing the current employer is out of state and the member address listed with the employer is out of state. Clarify the information received through the data exchange with the member and pend for verification if necessary.

Example 5

Susan reports a change of address and new employment at her renewal. Her new employer is located in Illinois, but the address on her pay stub matches the address she provided. State residency is not questionable.

1.2.3.6 Address Verification

Verification of address is not required for FoodShare eligibility.

Address refers to the actual place where the household is living or receiving mail. Verification of address is not required.

• An address is required to be provided at the time of application unless a household is homeless, a migrant, or newly arrived in Wisconsin.
• A household does not have to live in a permanent dwelling.
• A household may use a general mailing address.

An address must be provided in order to set a FoodShare filing date.

An applicant can give a general mailing address and the application filing date will be set if the application also includes the applicant’s name, and signature. If an address is not given on the application, the application is not valid and cannot be used to set the filing date unless the applicant is homeless, migrant, or has recently moved to Wisconsin and does not yet have a fixed mailing address. If the applicant is homeless or migrant, the application must include a name, date, and signature to set the filing date.

1.2.3.7 Household Composition Verification

Household composition affects eligibility. If the household composition is determined questionable, verification is required.

Note

FoodShare applicants and members are required to report changes in household composition at application, renewal, and upon submission of a six-month report form (SMRF), or when a change in household composition would result in additional income that would cause the food unit’s total income to exceed 130% of the FPLFederal Poverty Level for their reported food unit size (see Section 6.1.1 Change Reporting for All Food Units (Simplified)). A report of a change in address does not necessarily make household composition questionable.

CARES Processing: Household Composition

If information is presented at application that causes household composition to be questionable the IM worker must:

• Enter a "Q?” in the Household Composition Verification field on the General Case Information page to pend FoodShare.
• Initiate a Front End Verification if appropriate.

If the IM worker becomes aware of information that causes household composition to be questionable for an ongoing case, they must:

• Enter a "Q?” in the Household Composition Verification field on the General Case Information page to pend FoodShare and add text to the verification checklist to explain to the member the information that needs to be clarified.
• Make the appropriate updates to the case when the information is provided by the member.
• Change the Household Composition Verification field to "QV" if there is no response from the member by the verification due date.

1.2.3.8 Student Eligibility Exemptions

Exemptions to the student eligibility policy are verified by using an enrollment letter, financial aid papers, letter from the school, or any other applicable document. IM workers should not require a specific type of verification.  

1.2.3.9 SSA Death Match

When an SSA data exchange indicates that an eligible applicant or member has died, and the IM agency has not received any other information to confirm the death, the applicant or member, or a person with knowledge of the applicant or member’s circumstances, must be allowed 10 days to respond to a Date of Death (DOD) letter prior to benefits being impacted. This is to prevent benefits from being terminated or reduced solely based on a DOD data exchange.

• For ongoing cases, the once eligible member for whom a death match was received will still be considered to be alive. Benefits for the member or others on the case will not be changed or pended for the date of death during this time. Other verifications, such as earned income, should be requested as necessary. Benefit changes due to changes in eligibility will still need to be processed.
• For an application, person add, or renewal, the worker must wait at least 10 days for a response before confirming eligibility.

This 10-day period is known as the refutation period. The refutation period may only be shortened when either of the following events occur:

• A person with knowledge of the member’s circumstance confirms the DOD.
• The DOD is disputed.

Once the DOD status is verified or successfully disputed, the discrepancy or match can be resolved.

1.2.3.10 Huber Law

Applicants and members who are incarcerated but allowed to leave jail under the Huber Law can become or remain eligible for FoodShare if the reason for the release is to return home to care for their minor children (see Section 3.2.1.2.2 Incarceration and Huber Law Prisoners).

To qualify for the Huber Law exemption, verification that the applicant or member is returning home to care for minor children is required. Verification may include court documents, jail documents, or other written or verbal verification provided by court or jail staff (see Section 1.2.6.1 Required Verification to Determine Eligibility).

If the verification shows that the person is allowed to leave jail under the Huber Law for a different reason, they are not eligible for the Huber Law exemption. 

1.2.3.11 Vital Records Death Match

When a definitive match is received from the Wisconsin DHS Vital Records data exchange, the date of death is considered verified on receipt of the match. 

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Publication Number: P-16001