1. WIC I NCOME E LIGIBILITY Idaho WIC Program – 12/2014 Reproduced From USDA Policy Branch WIC Income Eligibility Presentation (available 7/2014) Division of Public Health Idaho Department of Health and Welfare WIC is an equal opportunity employer and provider

2. I NCOME E LIGIBILITY G UIDANCE O BJECTIVES : Review what is considered income and how to determine the economic unit Identify how to document and verify income Review 30-day temporary certification procedures

3. I NCOME E LIGIBILITY G UIDANCE O VERVIEW : The WIC Income Eligibility Guidance Required implementation date of October 1, 2013 for States not in compliance Idaho WIC Program met all requirements, no policy changes required (IWPPM Ch. 4) Updated guidance/clarifications

4. I NCOME E LIGIBILITY G UIDANCE D ISCUSSION : What questions do you have about income eligibility?

5. I NCOME E LIGIBILITY G UIDANCE What is considered income? WIC guidelines define income as “gross cash income before deductions for income taxes, employees’ Social Security taxes, insurance premiums, bonds, etc.” Other cash income includes student financial assistance, such as grants and scholarships

6. I NCOME E LIGIBILITY G UIDANCE : L OANS Student financial assistance (loans or grants) intended to pay for room, board, or dependent care expenses are included as income Grants and scholarships excluded as income are listed in the IWPPM 4-B-10 Examples of excluded Pell Grants, State Student Incentive Grants, and National Direct Student Loans

7. I NCOME E LIGIBILITY G UIDANCE : L OANS Loans, either from a bank or from a personal resource (friend, church, etc.), are also excluded from income since these funds are only temporarily available and must be repaid

8. I NCOME E LIGIBILITY G UIDANCE : C URRENT VS. A NNUAL Generally “current” should mean The most recent income available to the applicant that accurately reflects their household’s financial circumstances Some flexibility in deciding to use an applicant’s current or annual rate of income, within reason Decision is not based on whatever makes a client eligible for the program, meaning if they do not have any changes to their current situation we cannot use annual

9. I NCOME E LIGIBILITY G UIDANCE : C URRENT VS. A NNUAL Idaho WIC does define “current income” as Income received by the household during the month (30 days) prior to the time the application for WIC benefits is made On a case-by-case basis we may need to consider other factors and look at more than 30 days Further guidance under IWPPM 4-B-9

10. I NCOME E LIGIBILITY G UIDANCE : C URRENT VS. A NNUAL ( CONT ’ D ) If the income assessment is being done prospectively, “current” should refer to income that will be available to the family in the next 30 days Example The sole supporter of the family has just been laid off but has been authorized to receive unemployment benefits for the next six months

11. I NCOME E LIGIBILITY G UIDANCE : R ESOURCE

12. I NCOME E LIGIBILITY G UIDANCE : C URRENT VS. A NNUAL ( CONT ’ D ) Examples when current income may be recommended The family where someone who is on a furlough or temporary government shutdown may have a lower income during that period, but have an annual income which would exceed the WIC income eligibility guidelines

13. I NCOME E LIGIBILITY G UIDANCE : C URRENT VS. A NNUAL ( CONT ’ D ) Examples when annual income may be more appropriate A family member who is on maternity leave Teachers who are paid on a 9-10 month basis and are temporarily on leave for the summer College students who work only during the summer months and/or school breaks Frequent and consistent overtime pay

14. I NCOME E LIGIBILITY G UIDANCE : S ELF -E MPLOYMENT Always use net income when determining eligibility for self-employed applicants Do not use gross income Use the applicant’s most recent IRS tax return Use the adjusted net income figure on the IRS tax return It is not our responsibility to challenge or recalculate that amount

15. I NCOME E LIGIBILITY G UIDANCE : A PPLICANTS R EPORTING Z ERO I NCOME Applicants declaring zero income should be prompted to describe in detail their living circumstances and how they obtain basic living necessities Food, shelter, medical care and clothing

16. I NCOME E LIGIBILITY G UIDANCE : A PPLICANTS R EPORTING Z ERO I NCOME ( CONT ’ D ) In most instances, applicants actually have income which may be “in-kind” and affect the size of the economic unit Example A young pregnant woman and her husband are both unemployed and report a household of 3 with no income They are not on another program that would make them income eligible It is determined they live with her mother and are meeting their basic needs with the mother’s income In this situation, they should be counted as a household of 4 and income determination would be based on the mother

17. I NCOME E LIGIBILITY G UIDANCE : I NCOME D OCUMENTATION "Documentation of income" means presentation of written documents Current pay or unemployment benefits Earnings statements W-2 forms with the corresponding income tax returns

18. I NCOME E LIGIBILITY G UIDANCE : I NCOME D OCUMENTATION ( CONT ’ D ) Applicants must provide documentation of income at certification Except in limited situations where documentation may not be available Examples Individuals who are homeless Families who recently experienced a fire or other disaster Applicants who work for cash

19. I NCOME E LIGIBILITY G UIDANCE : I NCOME D OCUMENTATION ( CONT ’ D ) It is acceptable to request a written statement from a reliable third party who has knowledge of the applicant’s income Example Staff of a social service agency, church or legal aid society, or employers

20. I NCOME E LIGIBILITY G UIDANCE : I NCOME D OCUMENTATION ( CONT ’ D ) If another form of documentation is used and not listed as an option to select in WISPr, staff should document what was used to determine eligibility somewhere in WISPr In limited circumstances, the applicant must sign the No Proof form specifying why he/she cannot provide the documentation of income

21. I NCOME E LIGIBILITY G UIDANCE : I NCOME V ERIFICATION Verification is a process whereby the information presented, such as pay stubs, is validated through an external source of information other than the applicant Federal WIC regulations allow (but do not require) the State or local agency to verify income FNS encourages verification of any questionable information in order to maintain the integrity of the Program

22. I NCOME E LIGIBILITY G UIDANCE : L ACK OF I NCOME D OCUMENTATION Applicants are required to bring the following documentation: Proof of income, identity and residency If an applicant fails to bring proof of income, the local agency must do one of the following: Schedule a new certification appointment or Certify the individual based upon a signed self- declaration (Rights, Responsibilities and Consent) for no more than 30 days

23. I NCOME E LIGIBILITY G UIDANCE : L ACK OF I NCOME D OCUMENTATION ( CONT ’ D ) If the applicant fails to provide the documentation within the 30-day time limit, the individual shall be determined ineligible for WIC If the applicant brings in the documentation within the 30-day period and is found to be eligible, the applicant should be certified for a full certification period, beginning with the date that WIC benefits were initially provided

24. I NCOME E LIGIBILITY G UIDANCE : L ACK OF I NCOME D OCUMENTATION ( CONT ’ D ) Under no circumstances can a second, subsequent 30-day certification period be used if the applicant fails to provide the required documentation of income The same policy applies to applicants who fail to produce documentation of residency and/or identity

25. I NCOME E LIGIBILITY G UIDANCE : What has worked well to avoid 30-day temporary certifications? How can WIC help ensure missing documents are brought in before the 30 day cert ends once a temporary certification has been given?

26. I NCOME E LIGIBILITY G UIDANCE : F AMILY /H OUSEHOLD /E CONOMIC U NIT Defined as “a group of related or nonrelated individuals who are living together as one economic unit" There can be more than one economic unit living under one roof The most important rule to apply to all applicants, including minors, is that an economic unit must have its own source of income Adequacy of the income, not whether the unit receives any in-kind benefits, should be the determining factor

27. I NCOME E LIGIBILITY G UIDANCE : F AMILY /H OUSEHOLD /E CONOMIC U NIT ( CONT ’ D ) In assessing “adequacy of income,” the actual living and support costs for the economic unit in that environment must be considered Example A pregnant woman who is sharing an apartment with her sister may be determined to be a separate economic unit from her sister IF the certifier can reasonably establish that she has a separate source of income and is paying her proportionate share of household, living and personal expenses

28. I NCOME E LIGIBILITY G UIDANCE : A DJUNCTIVELY E LIGIBLE For participants who are Income Adjunctively Eligible (AE) Verbal income report should be collected Additional proof of income should not be required or requested If they do not know their exact income Try to obtain their best estimate Zero should not be recorded nor should a No Proof form be completed You may need to use an estimate of their assistance (TANF, SNAP, etc.)

29. I NCOME E LIGIBILITY G UIDANCE : S UMMARY The WIC Income Eligibility Guidance: Covered existing FNS instructions and policy memos already available in the Idaho WIC Program Policy Manual. Discussed what income is, how to document participant income for eligibility, and economic unit determination. Clarified the number of temporary certifications allowed when an applicant lacks necessary income documentation

30. I NCOME E LIGIBILITY G UIDANCE : Questions? Thank you for your participation!