State of Wisconsin Department of Health Services

Release 24-01 April 3, 2024

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2.1.3 Interviews

2.1.3.1 Scheduling the Interview

7 CFR 273.2(e)(3)

Agencies must make every attempt to schedule interviews to ensure that an initial FoodShare eligibility determination can be completed within the 30-day processing time frame. Priority Service interviews must be completed (see Section 2.1.4 Expedited Service at Application).

FoodShare applicants have the right to complete a face-to-face or phone interview (see Section 2.1.3.5 Telephone Interviews). If an applicant requests a face-to-face interview, the interview is typically held at the local office but may be held at a mutually acceptable location such as the applicant's residence.

If a home-based certification interview is scheduled with the applicant or member, a hardship must exist (including but not limited to) and must be case commented:

• Illness
• Transportation difficulties
• Care of a household member
• Hardships due to residency in a rural area
• Prolonged severe weather
• Work or training hours that prevents the household from participating in an in-office interview

Agencies are required to schedule and provide written notice of an interview for an initial FoodShare application. Notice of the interview must be in writing and mailed to the applicant unless the notice cannot be received by the applicant prior to the date of the interview. Verbal notification of the interview is only allowable if an interview letter cannot be received prior to the interview and only if the agency provides this information directly to a responsible adult household member. If verbal notice is provided the agency must document in case comments that a verbal notice was provided, the name of the person who received the verbal notice, the date and time of the interview, and whether the interview will be conducted by telephone or face-to-face.

If the applicant is physically present when the appointment is scheduled, the agency must provide the applicant a printout of the written notice.

The IM worker must make two attempts to contact the applicant or an adult member of the food unit at the time of the scheduled interview. If the first attempt to contact the food unit is unsuccessful, make a second attempt 15 minutes after the first call. If the second attempt is unsuccessful, the IM worker must document in case comments that they were unable to contact the food unit at the appointment time, that the follow-up call was made, and the length of time between calls. Send the Notice of Missed Interview (NOMI), directing the food unit to contact the agency to reschedule.

NOMI requirements must be met if the applicant or member misses the interview.

The agency must notify each applicant or member who misses the application or renewal interview that they missed the scheduled interview and that the applicant or member is responsible for rescheduling a missed interview. The use of Client Scheduling in CWWCARES Worker Web will ensure that the NOMI is generated by CWW and sent to the applicant or member (see Process Help, Section 1.8.9.7 Automated NOMI for FoodShare). If Client Scheduling is not used, a NOMI must be manually issued by the local agency. A copy of the agency notice must be scanned to the electronic case file. Agencies may not deny an application prior to the 30th day after the application filing date if the applicant fails to appear for the first interview.

For applicants who miss a scheduled appointment and contact the agency to reschedule within the 30-day application processing period (see Section 2.1.2 Application Processing Time Frame), the agency must schedule another interview.

An application must not be denied prior to the 30th day, unless the interview has been completed, even if other information has been reported on the application that would make the FoodShare assistance group ineligible.

On-Demand Interviews

Wisconsin received federal approval for a waiver that allows IM consortia to implement an on-demand, or unscheduled, interview model. Under the on-demand interview model, FoodShare applicants and renewing members may call their IM agency to complete the required FoodShare interview during the agency-designated FoodShare on-demand hours.

A consortium must apply this model across all agencies within the consortium. An on-demand interview must be offered at both application and renewal. A consortium implementing the on-demand interview model must continue to provide scheduled face-to-face or telephone interviews upon request.

All FoodShare applications must be screened for priority service and expedited issuance. A consortium must meet the following application and renewal processing standards:

• Priority service applications: IM workers must make at least two attempts to contact an applicant to complete the interview on the same business day the application is received or by the end of the next business day. IM workers must continue to meet all priority service processing standards.
• Standard 30-day applications: IM workers must make at least two attempts to contact an applicant to complete the interview on the same business day the application is received or by the end of the second business day following the day it was received.
• Renewals: On-demand interviews must be offered for all renewals when received. IM workers must make at least two attempts to contact a member to complete the interview on the same business day the renewal is received or by the end of the fifth business day following the day it was received.

A worker should make two contact attempts, at least 15 minutes apart, to complete the interview. If the worker is unable to connect with the applicant or member during these attempts, pend for interview.

Exception

Sometimes two contact attempts are not possible such as when there is a disconnected phone, or if the applicant is unavailable and specifically tells the worker not to call them back if they connect on the first attempt. See below for alternative processing.

When an applicant or member is contacted during the first attempt:

• If the first contact is made and the worker connects with the applicant and the applicant cannot complete the interview at that time, schedule the interview at an agreed upon date and time and send the scheduled interview notice. No other contact attempt is required as this contact meets the On-Demand requirement.
• If the first contact is made and the worker connects with the applicant, but the applicant cannot complete the interview at that time, and an interview cannot be scheduled at an agreed upon date and time (because they do not want to schedule an appointment at that time or because they state they will call back at another time), the worker should pend for an interview. This meets the On-Demand requirement, and no additional contact attempt is needed.

Notice of Interview for On-Demand Interviews

If an IM worker is unable to complete the interview at the time they contact a household as described above, the IM worker must send a Notice of Interview. For on-demand interviews, the Notice of Interview language will be generated on the verification checklist (VCL). The household has nine calendar days from the VCL mailing date to call and complete the FoodShare interview. The Notice of Interview provides instructions to complete the interview. If the last day of the on-demand interview time frame falls on a weekend or CARES holiday, the due date will be the next business day. The on-demand interview timeframe of “10 days to call to complete” will not be adjustable in CWWCARES Worker Web. Verification due dates for other types pended after the interview will continue to be based on policy requirements and IM worker action.

2.1.3.1.1 Notice of Missed Interview (NOMI) Requirements

Application:

Not expedited

The agency must send a separate NOMI letter to each applicant who does not meet the criteria for expedited issuance and misses the scheduled interview appointment. The NOMI letter must inform the applicant that they missed the scheduled appointment and are responsible for rescheduling the interview. If the applicant contacts the agency within the 30-day application processing period, the agency must schedule a second interview. The application may not be denied due to an incomplete interview prior to the 30th day after the application filing date.

Expedited regular

A NOMI must be sent when the household misses the interview that was scheduled, and a second interview cannot be scheduled within the seven-day expedited processing period due to household delay.

Expedited with postponed interview

Effective June 1, 2020, the FoodShare interview may no longer be postponed. The interview must be completed prior to initial benefit issuance for all applications.

On-demand interview

If an applicant does not complete the required FoodShare interview by the last day of the on-demand interview time frame specified on the VCL, a NOMI will automatically be generated from CWWCARES Worker Web. The NOMI will include the date by which the interview must be completed and will indicate that the household will not get FoodShare benefits if the interview is not completed.

If an interview is scheduled using Client Scheduling, the NOMI will be automatically generated when a scheduled interview appointment is missed.

Renewal:

Language contained in the CARES generated Renewal Notice and closure notice meets NOMI requirements, therefore an additional NOMI letter does not have to be sent if the member misses the scheduled interview appointment.

On-demand interview

If a member does not complete the required FoodShare interview or verification requirements before adverse action of the renewal month, a Notice of Termination with NOMI language will automatically be generated from CWWCARES Worker Web. The notice will include the date when the member’s FoodShare benefits will end due to not completing the required interview and will indicate that the member should call the agency to complete the interview.

2.1.3.2 Completing the Interview

7 CFR 273.2(e)(1); 7 CFR 273.2 (b)(4)(iv)

The interview needs to be completed by a responsible adult applicant, member of the food unit, or an authorized representative. If the applicant is an individual under age 18, the youth must be the primary person, emancipated or homeless and not under the care and control of another adult in order to complete the interview.

During an interview, the agency must not simply review the information that appears on the application but must explore and resolve with the applicant all unclear information. The interviewer must also advise applicants of their rights and responsibilities during the interview.

Although CWWCARES Worker Web provides a means for an individual to apply for several programs of assistance, FoodShare eligibility must be based solely on the requirements and regulations governing the FoodShare program. Applications for FoodShare may not be denied solely on the basis that an application to participate in another program has been denied. Similarly, ongoing FoodShare benefits may not be terminated solely because benefits from another program have been terminated. During an interview, the interviewer must advise applicants for joint W-2/FoodShare that W-2 requirements do not apply to FoodShare and households that lose or decline W-2 benefits may still qualify for FoodShare.

The agency must ask the applicant, member, or authorized representative to identify all household members and their relationship to each other, and if they share food.

Providing Social Security numbers (SSNs) (see Section 3.13.1 Social Security Number (SSN) Requirements) for each household member is voluntary. However, failure to provide an SSN will result in the denial of FoodShare benefits to each applicant or member failing to provide an SSN. Although SSN and immigrant status information is not required for household members not applying for benefits, the agency must determine if the non-applicant household member has income or assets that affect the applying applicants' eligibility. If so, that information must be provided and verified in order to determine FoodShare eligibility for the applicant(s).

The agency must ask applicants and members to provide ethnicity and race information for all food unit members. Applicants and members are not required to provide a response for ethnicity or race in order to complete an application or receive a decision about their program eligibility or benefits; individuals may provide information on ethnicity, race, both, or neither.

Agencies must inform individuals that responses may be used to help improve the State of Wisconsin’s public assistance programs and ensure the program will not discriminate based on ethnicity or race. This may include reporting ethnicity and race data to federal agencies or sharing ethnicity and race information with managed care organizations to support monitoring of health disparities.

2.1.3.2.1 Required Interview Topics

All FoodShare interviews must include a discussion of the following items in addition to standard financial and non-financial eligibility criteria:

• Use of SSNs (see Section 3.13.1 Social Security Number (SSN) Requirements)
  • A SSN is required for each individual requesting benefits unless they meet a religious exemption.
  • SSNs are used for data matching. Data matches are used to check that you can get and keep getting benefits.
• FoodShare rights and responsibilities (see Your Rights and Responsibilities for FoodShare (F-10150B)).
• Appropriate application processing standard time frames for non-expedited (see Section 2.1.2 Application Processing Time frame) and expedited benefits (see Section 2.1.4 Expedited Service at Application).
• Applicable change and simplified reporting requirements (see Section 6.1.1 Change Reporting for All Food Units (Simplified)) at the time of the interview.
  • How changes can be reported.
  • What changes must be reported.
  • When changes must be reported.
• Six-month reporting (see Section 6.1.2 Six Month Reporting Requirement) or renewal (see Section 2.2.1 Certification Periods (Renewals)).
  • How to obtain assistance in completing the Six-Month Report Form (SMRF).
  • When the Six-Month Report Form (SMRF) will be sent.
  • When the report form is due.
  • Consequence for failing to file a report.
  • Changes that must be reported on the Six-Month Report Form (SMRF):
    • Address, and shelter and utility costs associated with a new residential address
    • Household composition
    • Income
    • Substantial Lottery or Gambling Winnings
    • Court-ordered child support payments for a non-household member
• QUEST card information
• Explanation of FoodShare Basic Work Rules (see Section 3.16.1 FoodShare Basic Work Rules) and FoodShare Work Requirements (see Section 3.17.1 FoodShare Work Requirements for ABAWDs), if the food unit includes an applicant or member subject to a work requirement.
  • IM workers must identify which applicant(s) or member(s) are subject to FoodShare basic work rules and FoodShare work requirements and provide the following information:
    • An explanation of each work rule and applicable work requirement.
    • Information on exemptions from each applicable work rule and work requirement.
    • An explanation of the process to request an exemption, including contact information to request an exemption.
    • FoodShare rights and responsibilities.
    • What is required to maintain eligibility under each work rule and applicable work requirement.
    • Consequences for failure to comply with each work rule and applicable work requirement.
    • An explanation of the process for requesting good cause, including examples of good cause circumstances and contact information to initiate a good cause request.
    • Information on the FoodShare Employment and Training Program (FSET) and benefits of FSET participation if the food unit includes an individual subject to the FoodShare Work Requirements.
    • Information on the status of the time limit of the FoodShare Work Requirement if the household lives in an area or on tribal lands where the time limit of the FoodShare Work Requirement is suspended.
  • The appropriate sections of the "FoodShare Basic Work Rules and FoodShare Work Requirements Script for IM Workers" must be read to meet the above requirements.
• Discuss the FSET program and offer voluntary referrals to FSET to eligible FoodShare members.
• At the end of the call, the "Reporting Requirements Call Script" must be read.

2.1.3.3 Signature

7 CFR 273.2 (b)(1)(iii)

A signature is required to indicate that all the information provided is true and complete and that the food unit understands their rights and responsibilities. Only one signature is needed for a FoodShare application or request. The applicant, authorized representative, or an adult member of the food unit can provide a signature in written, verbal, or electronic format via:

• An electronic signature*,
• On the completed CWWCARES Worker Web generated Application Summary,
• On the FoodShare Wisconsin Application (F-16019A or F-16019B), or
• A telephonic signature.

*An electronic signature can be accepted from any electronic signature software or other electronic source. Examples include DocuSign, eSign, ACCESS, etc.  

For a signature to be valid from an individual under age 18, the youth must be the primary person, emancipated or homeless, and not under the care and control of another adult.

A signature is required when a Six Month Report Form (SMRF) is submitted. 

It is not necessary for an applicant's signature to be witnessed by an agency representative for a FoodShare application or renewal to be considered complete. However, the signature of a witness is required when the application is signed with a mark. The witness may be another adult or an IM worker. A copy of the FoodShare applicant or member's case summary showing that a telephonic signature was collected will be stored in the electronic case file.

Any adult food unit member or a food unit's authorized representative may sign the FoodShare application, renewal, or six-month report form.

Example 1

Eve applies and sets the filing date for FoodShare. Jule, Eve’s roommate, who is also an adult, completes the intake interview and signs the case summary signature page. The FoodShare application is valid because Jule is a responsible FoodShare assistance group member.

Exception

An individual declared incompetent by a local, state, or federal court can’t sign an application. Their representative or guardian will need to complete and sign the application. An applicant who has a designated guardian (guardian of the estate, guardian of the person and the estate, or guardian in general) can't complete and sign the application. Only the guardian can complete and sign the application or appoint another representative.

2.1.3.4 Telephone Interviews

7CFR273.2(e)(2)(i - ii)

Applicants or members who request a face-to-face interview must be granted one.

IM agencies should be conducting most interviews by telephone unless an applicant or member requests a face-to-face interview.

Telephone interviews do not exempt the applicant or member from verification requirements (see Section 1.2.1 Verification Introduction).

2.1.3.5 Completing Telephone Interviews

A filing date must be set for all new FoodShare requests (see Section 2.1.1.4 Setting the Filing Date).

At the start of the telephone interview, explain that if a written or electronic signature is not on file, a signature will need to be collected in order to set the filing date for an application or to establish a request for continued benefits in the case of a renewal. If the member is not willing to provide a telephonic signature, a written signature will be accepted but the worker needs to inform the member this may cause a loss and delay of benefits until the signature is received by the agency. Document the agreement and understanding in case comments (see Section 2.2.1 Certification Periods (Renewals)).

A signature is needed before the agency can certify the food unit for benefits. The date the signature is received for an application sets the filing date. A signature is needed to recertify a food unit for continuation of benefits at the time of renewal.

See Section 2.1.3.2 Completing the Interview for required interview topics.

2.1.3.6 Post Interview Process

If verification is needed after the interview, mail out a verification checklist and send it to the applicant or member with instructions to provide the listed documents to the local agency within 20 calendar days or by the end of the application or renewal processing period, whichever is later. The agency must always provide the applicant with a copy of the case summary after the interview is complete.

If the food unit claims deductible expenses during the interview, the food unit must verify certain claimed deductions or the deduction will not be allowed (see Section 1.2.4.5 Expense Verification). If verification of the deductions is not provided, do not allow the deduction and do not close the case.  

Applications

At the end of the telephone interview, the agency must record the telephonic signature if they do not already have a written, telephonic, or electronic signature, and then generate a copy of the case summary to be mailed to the applicant. The applicant must review the case summary and notify the agency within 10 calendar days if corrections are needed.

If a telephonic signature is not provided at the time of application, inform the applicant during the interview they must sign the case summary and return it or an application document to set the filing date for FoodShare. The application is not complete, and a filing date is not set until a signature is on file. The application should pend for the signature.

Renewals

At the end of the renewal interview, collect a telephonic signature if a written, telephonic, or electronic signature has not already been collected. If the member refuses to provide a telephonic signature, instruct the member that you will be mailing the printed case summary to them for their signature. In this situation, the case summary needs to be signed and returned to the agency within 10 calendar days or by the end of the renewal processing period, whichever is later. The renewal is not complete until the signed case summary signature page is returned to the agency.

If the signed case summary is not returned within the 10-day period or by the end of the renewal processing period, whichever is later, the case needs to be closed for failure to return the FoodShare renewal signature.

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Publication Number: P-16001