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State of Wisconsin |
Release 26-01 |
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. |
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 CARES 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.
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 USCIS 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, SSA (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:
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 migrant 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.
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).
7 CFR 273.2(f)(1)(vi)
Address, Wisconsin residency, 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.
| 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:
| 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. |
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 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.
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 FPL 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:
If the IM worker becomes aware of information that causes household composition to be questionable for an ongoing case, they must:
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.
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.
This 10-day period is known as the refutation period. The refutation period may only be shortened when either of the following events occur:
Once the DOD status is verified or successfully disputed, the discrepancy or match can be resolved.
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.
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.
National Accuracy Clearinghouse (NAC) queries for duplicate participation must be conducted at application, renewal, and when a person is added to a FoodShare food unit (see Section 3.3.1.3 Relationship Rules). NAC queries will be completed for ongoing members through an automated monthly match process.
Before a NAC query can be conducted for an individual, their SSN and Wisconsin residency must be verified. The identity of the primary person on the case must also be verified.
When a match is found, the household must be notified, giving them the opportunity to refute the match before any action is taken to deny, end, or reduce benefits. The due date for members to provide a response follows FoodShare verification rules (see Section 1.2.1.2 Request for Verification). When a match results in denial, closure, or reduction of benefits, a notice of decision must be sent to the household informing them of the decision.
NAC Matches
Initial match information received from the NAC is not considered verified upon receipt. Once the match is identified, any additional information received directly from the matching state or territory, whether via the NAC or direct contact, is considered verified upon receipt and must be acted upon by Wisconsin. If the additional information from the other state would result in a closure or denial, negative action must not be taken for FoodShare until the household responds or the given due date, whichever comes first.
At application, renewal, or person add, the household must provide proof that benefits in the other state or territory have ended.
During the monthly match process and when other states or territories query NAC, the household must provide proof of Wisconsin residency to confirm Wisconsin is the correct state for SNAP eligibility.
When a household verifies their Wisconsin residency following a monthly match or match initiated by another state, Wisconsin benefits must remain open, and this verification must be entered into the case record as the final disposition for the match. Once the final disposition is entered in Wisconsin’s case, the other matching state must take the necessary action to terminate SNAP eligibility in their state.
If there is a conflict between the information provided by the household and another state or territory, benefits must be issued based on the household’s statement that benefits were not received in the other state or territory. However, if duplicate benefits are issued, the household will be responsible for the repayment.
Priority Service, Expedited Benefits, and NAC Matches
When an application or a late renewal is found to be eligible for priority service and/or expedited issuance, and residency, SSN, and the primary person’s identity have been verified within the expedited processing window, the NAC must be queried for all individuals in the food unit before benefits are issued. If the NAC query criteria is not met and the household qualifies for expedited issuance, the NAC query will be postponed like other verification (see Section 2.1.4.2 Verification Requirements for Expedited Services) when the SSNs for all members are provided and the primary person’s identity is verified.
If the query results in a match showing that any individual(s) in the household are receiving benefits in another state or territory, the application is no longer eligible for priority service and reverts to a standard 30-day application.
| Note | An exception to this policy applies when at least one member of the household resides in a shelter for victims of domestic violence. If the match is found only for the member living in a domestic violence shelter and the household meets all other FoodShare eligibility criteria, the household remains eligible for expedited benefits despite the pending NAC match. |
Deeming and NAC Matches
Individuals excluded from an assistance group due to a failure to respond to notification of a NAC match will be included in the food unit as a pro-rated deemer.
Vulnerable Individuals
If someone is a vulnerable individual, states must take steps to not disclose information about their location obtained through NAC matches. A vulnerable individual, for the purpose of the NAC, includes, but is not limited to:
Benefit Recovery and Intentional Program Violation
If a NAC match is identified at application, renewal, or person add, and the agency issues duplicate benefits without taking action on the NAC match, this is considered a non-recoverable agency error overpayment. If residency was verified at application, renewal, or person add, and FoodShare benefits are subsequently ended due to a NAC match in another state, this is not an error, and no benefit recovery is required.
If a NAC match is identified through the monthly matching process or via another state’s query, and the individual verifies current Wisconsin residency, they must continue receiving SNAP benefits in Wisconsin. The other state will be considered the state of duplicate issuance and is responsible for taking appropriate action to terminate eligibility and recoup any duplicate benefits issued if they fail to terminate the ongoing eligibility resulting from the match.
Fair Hearings
Households whose eligibility is denied, closed, or reduced as a result of an action related to a NAC match have the right to request a fair hearing once the action is taken on their case and the final disposition is entered.
This page last updated in Release Number: 26-01
Release Date: 04/15/2026
Effective Date: 04/15/2026
Notice: The content within this manual is the sole responsibility of the State of Wisconsin's Department of Health Services (DHS). This site will link to sites outside of DHS where appropriate. DHS is in no way responsible for the content of sites outside of DHS.
Publication Number: P-16001