NORTH DAKOTA DEPARTMENT OF HUMAN SERVICES
BISMARCK, NORTH DAKOTA
August 16, 2007

AMENDED IM 5016

TO:		County Social Service Directors
Economic Assistance Policy Regional Representatives
Economic Assistance Policy Quality Control Reviewers

FROM:	Blaine Nordwall, Director, Economic Assistance Policy

SUBJECT:	Temporary Assistance for Needy Families (TANF) Transition Assistance

PROGRAMS:	Temporary Assistance for Needy Families, Low Income Home Energy Assistance Program, Food Stamp Program, Medicaid and Child Care Assistance Program

EFFECTIVE:	August 1, 2007 for new TANF applications received on or after August 1, 2007 and the benefit month of September, 2007 for ongoing TANF cases

RETENTION: 	Until Manualized

THIS IM IS BEING AMENDED TO PROVIDE POLICY CLARIFICATION AND INCORPORATE A TWO STEP PROCESS FOR PAYMENT OF TRANSITION ASSISTANCE SPECIAL ALLOWANCES. THE CHANGE IN THE PAYMENT METHOD WILL PREVENT A DELAY IN REIMBURSEMENT OF CHILD CARE EXPENSES INCURRED.   

THE TWO STEP PROCESSING OF TRANSITION ASSISTANCE SPECIAL ALLOWANCES IN AN OPEN CASE CONSISTS OF:

1)	SPECIAL ALLOWANCES FOR JOB RETENTION AND TRANSPORTATION WILL BE PAID PROSPECTIVELY.

2)	REIMBURSEMENTS FOR VERIFIED CHILD CARE EXPENSES, HEALTH INSURANCE PREMIUMS AND THE HEALTH TRACKS INCENTIVE WILL BE PROCESSED AS SPECIAL ALLOWANCES AND PAID AS A SUPPLEMENT  IN THE MONTH INCURRED.

If a family was not on Transition Assistance in the month in which verified child care expenses were incurred, the child care expenses may be paid in the Child Care Payment system, if all other child care requirements have been met (i.e. there is a child care application and a provider who meets CCAP requirements).

Senate Bill 2186 (2007) created a new section to Chapter 50-09 of the North Dakota Century Code, establishing a Transition Assistance program.  The program must provide benefits for up to six months following the loss of benefits under section 50-09-29, due to earnings from employment; remain ineligible due to earnings from employment; be paid directly to recipients using a debit card; and meet all requirements to be considered “assistance” for purposes of title 45, Code of Federal Regulations, part 260, section 31.

Purpose

TANF Transition Assistance promotes job retention by providing an extended period of cash assistance to qualified TANF households; further assisting households in attaining self-sufficiency; thereby eliminating the need for future government benefits.  

Policy

Families that cease to be eligible for TANF due to excess income, and who meet the requirements of Transition Assistance, may continue to be eligible for TANF benefits for up to six months without making further application for TANF.  Transition Assistance provides a safety net of financial support to qualifying TANF households during this six-month period, provided all TANF eligibility requirements continue to be met.

All existing TANF rules apply to Transition Assistance cases except for the following: 

1.	A family may not receive Transition Assistance and a “regular” TANF and/or Kinship Care benefit in the same month.

2.	A Diversion Assistance case failing for excess income is not eligible for Transition Assistance.

3.	Only recipients become eligible for Transition Assistance.  Transition Assistance is not applicable in a TANF application month.
 
4.	The time limited percentage earned income disregard will not increment during a Transition Assistance month.

5.	There is no case closure/reapplication requirement when transitioning from “regular” TANF to Transition Assistance or from Transition Assistance to “regular” TANF.

6.	Allowable income deductions addressed under Section 400-17-55-45, “Allowable Expenses for Each Portion of TANF Benefit,” are not applicable to Transition Assistance. 

7.	The disqualification penalty, applied to a voluntary job quit or voluntary refusal of an offer of employment or training for employment, is limited to, “there is ineligibility of the individual for the benefit month in which the job quit/refusal occurred.”

8.	Outstanding overpayments will not be recouped from a Transition Assistance benefit.

9.	A Transition Assistance benefit will not be pro-rated.

Families who were eligible under TANF for at least one month immediately preceding the month, in which the family became ineligible, may remain eligible for continuing TANF benefits under Transition Assistance.  Transition Assistance is an extension of an ongoing TANF case that fails for excess income.  A computation in the Vision system identifies earned income as the sole reason for the excess income failure.  If the excess earned income failure is not due to the receipt of an extra check, the TANF household is eligible for Transition Assistance, except for the following:  

1.	Child only cases where the caretaker(s) have a participation of ‘DA’ (Disqualified Alien), ‘MP’ (Minor Parent’s Parents) ‘OU’ (Out), ‘SS’ (SSI Recipient), ‘DI’ (Disqualified JOBS) or ‘ST’ (Stepparent). This means all other cases where the caretaker(s) are 'IN', 'DD' (Drug/fleeing felony/parole/probation violators), 'DF' (Disqualified Fraud), 'DM' (Disqualified Child Support), or 'OH' (Out of Home) may be a Transition Assistance case.
a.	If an ongoing Transition Assistance case has caretaker(s) that were 'IN' and become 'DA', 'MP', 'OU', ‘SS’, ‘DI’, or 'ST', the Transition Assistance case must be closed. 
Example:  A caretaker that was receiving Transition Assistance has a participation code of 'IN'. If the caretaker starts receiving SSI assistance, the participation code would change to 'SS'.

b.	If there are two caretakers in a case and only one of the caretakers becomes one of the above participations, the case may remain a Transition Assistance case. 
Example:  Transition Assistance case with both parents in the household and one parent incapacitated.  The participation code for both parents would be ‘IN’. The incapacitated parent starts receiving SSI and the participation code changes to ‘SS’, the family will continue to be Transition Assistance eligible.

c. If an ongoing Transition Assistance case has caretaker(s) that were 'IN' and become 'DD', 'DF' or 'DM', and a JOBS sanction is imposed, the Transition Assistance case must be closed. 
Example:  A caretaker that was receiving Transition Assistance has a participation code of 'IN'. The caretaker is disqualified due to fraud and the participation code changes to ‘DF.’  If a JOBS sanction is also imposed on the ‘DF’ caretaker,  there is no eligibility for Transition Assistance and the case must be closed.  

A TANF household may receive up to six months of Transition Assistance.  The months may be consecutive or non-consecutive.  There is no limit on the number of months a household can receive Transition Assistance in the TANF  60-month lifetime count; however, the maximum number of consecutive months for Transition Assistance cannot exceed six months.  A Transition Assistance case may close after receiving six consecutive months of Transition Assistance or the household may remain eligible for ongoing assistance under “regular” TANF, provided all eligibility requirements continue to be met.     

When a Transition Assistance household fails or refuses to comply with TANF eligibility requirements, the Transition Assistance case must be closed.  See Section 400-17-100, “Closing Cases and Timely Notification” for additional information.  Upon reapplication for assistance, eligibility for the household will be determined under “regular” TANF or Diversion Assistance.  

A Transition Assistance benefit consists of special allowances.  The portion of the Transition Assistance benefit determined Unreimbursed Public Assistance (UPA) is the special allowance provided to promote job retention.  

When a Transition Assistance benefit is paid, the case cannot be switched from Transition Assistance to “regular” TANF when reworking the paid benefit month. The paid benefit will determine all applicable counts such as the six-month maximum for Transition Assistance.  

A JOBS Status Change (SFN 323) form must be created whenever there is a change in eligibility from “regular” TANF to Transition Assistance or from Transition Assistance to “regular” TANF.  The JOBS Status Change form must be provided to the JOBS Coordinator.
   
Special Allowances  

Transition Assistance offers special allowances available to qualifying TANF households.  Special allowances may be paid in any month in which Transition Assistance is received.  Special allowances for Transition Assistance consist of: 

1.	Child Care – cannot exceed the maximum allowable of:  

$460 from birth up to 2 years of age (through the month of their 2nd birthday)
$440 for 2 and 3 year olds (through the month of their 4th birthday)
$420 for 4 and 5 year olds (through the month of their 6th birthday)
$400 for 6 up to 13 years of age (through the month of their 13th birthday)

Requests for payment of child care provided to children between 13 and 18 years of age will require current, medical evidence from a physician, psychologist, or clinical specialist that clearly confirms the need. 
 
Requests for payment may not be made for the cost of dependent care provided to a child by that child’s stepparent or parent who lives in the home occupied by the household.  Requests for payment may not be made for the cost of dependent care provided by the caretaker relative’s child or stepchild who is under twenty-one years of age, unless:
•	the provider of dependent care does not live in the home occupied by the household;
•	the provider of dependent care is at least eighteen years of age;
•	the provider of dependent care was not claimed as a dependent on the most recent federal income tax return filed by the caretaker relative;
•	a bona fide relationship of employer and employee exists between the caretaker relative and the provider of dependent care; and
•	the provider of dependent care is not a member of the caretaker relative’s household.

A child care payment must be rounded to the nearest dollar.  (If 50 cents or over, round up.  If under 50 cents, round down.)  The child care expenses must be verified using a signed and dated SFN 616, “Child Care Billing Report.”    Transition Assistance has no requirement to utilize child care providers who are licensed, registered, self-certified or approved.

Child care expenses incurred for work, education, training, or a combination of all three may be paid under Transition Assistance.  Child care expenses are reimbursed to the caretaker and paid as a supplement through the Vision system in the  benefit month they were incurred.  Payment will be up to 100% of the amount owed, based on the age of the child, up to the maximum allowable child care rate. 

2.	Job Retention – a monthly special allowance of $200.00 will be paid to households containing at least one eligible caretaker.   

3.	Health Insurance Reimbursement – the cost of a premium for health and hospitalization insurance carried by members of the Transition Assistance household may be paid. See Section 400-17-19-20, “Health Insurance Premiums.” 

4.	Health Tracks Reimbursement – Transition Assistance recipients that complete the Health Tracks screening are eligible for $25.00 per child. 
See Section 400-17-25-25, “ND Health Tracks, Early Periodic Screening, Diagnosis, and Treatment.”  

5.	Transportation – a transportation allowance of up to $125.00 per month may be paid.  The amount of the transportation allowance will be determined through the JOBS Program and identified on the Employability Plan.  See Section 400-20-40-20, “Transportation Assistance.”

Special allowances for job retention and transportation will be paid prospectively.  Reimbursements for verified child care expenses,  health insurance premiums and the Health Tracks incentive will be processed as special allowances and paid as a supplement in the month incurred. 
     
Policy Examples

1.	When processing an ongoing TANF case, which fails due to excess income, if the excess earned income failure is due to the receipt of an extra check, the TANF case is suspended.  If the excess earned income failure is not due to the receipt of an extra check, the TANF household is eligible for Transition Assistance. 

Example:  A family received “regular” TANF for benefit months of 07/2007 & 08/2007.  On 08/10/2007, the household submits the monthly report for benefit month of 09/2007 along with verified income and child care expenses from 07/2007.  Processing the benefit month of 09/2007 in an ongoing “regular” TANF case, which includes two deprived children under the age of two years.  The household fails TANF eligibility due to excess income.  Vision performs a second computation to identify earned income as the sole reason for the excess income failure.  The worker determines the excess earned income failure is not due to the receipt of an extra check, so the TANF household is eligible for Transition Assistance.  The worker edits to the Supportive Services/Special Allowances window and selects the Transition Assistance check box and creates applicable Transition Assistance special allowances of $200 job retention, $1000.00 ($500/child) child care (identified on SFN 616-Child Care Billing Report) and $125.00 transportation allowance (identified on the Employability Plan).  Eligibility Process is rerun and the benefit month of 09/2007 is authorized as Transition Assistance, with the benefit issued amount consisting of the combined sum of special allowances.

Child care expenses are reimbursed to the caretaker on Transition Assistance and paid as a supplement in the  benefit month they were incurred.  Because the benefit month of 07/2007 was a “regular” TANF month, the child care expenses for 07/2007 may be paid in the Child Care Payment system as a TANF benefit at 100%, if all other child care requirements have been met (i.e. there is a child care application and a provider who meets CCAP requirements).  

On 09/10/2007, the household submits the monthly report for 10/2007, along with verified income and child care expenses from 08/2007.  When processing the future benefit month of 10/2007, the household is determined eligible for Transition Assistance.  Child care expenses are reimbursed to the caretaker on Transition Assistance and paid as a supplement in the  benefit month they were incurred.  Because the benefit month of 08/2007 was a “regular” TANF month, the child care expenses for 08/2007 may be paid in the Child Care Payment system as a TANF benefit at 100%, if all other child care requirements have been met (i.e. there is a child care application and a provider who meets CCAP requirements).      

On 10/10/2007, the household submits the monthly report for 11/2007, along with verified income and child care expenses of $1000 from 09/2007.  When processing the future benefit month of 11/2007, the household is determined eligible for Transition Assistance and special allowances for job retention and transportation are authorized.  Child care expenses are reimbursed to the caretaker on Transition Assistance and paid as a supplement in the  benefit month they were incurred.  Because the benefit month of 09/2007 was a Transition Assistance month, the worker will edit to the Supportive Services/Special Allowances window in 09/2007 and create the child care special allowance in the amount of $1000 ($500/child) and issue a supplement.  

Note:  Because the two deprived children were less than two years of age, the maximum allowable child care payment for that age group is $460 per child.  Even though the total child care expense incurred was $1000.00 and this amount was created for the child care special allowance, Vision will reduce the payment for the child care special allowance from $1000.00 to $920.00 to meet the age based, child care maximum requirement under Transition Assistance.

2.	Transition Assistance months may be consecutive or non-consecutive.  

Example:  A family received Transition Assistance for 09/2007 and 10/2007.  The HH Comp Process is run for the benefit month of 11/2007. When editing to the Supportive Services/Special Allowances window after running HH Comp Process for 11/2007, the Transition Assistance check box remains unchecked; however, special allowances are copied forward but remain hidden from view until the Transition Assistance check box is checked.  The worker edits to the Income window to update the income, as the household’s earnings from employment decreased significantly.   When running Eligibility Process for 11/2007, the benefit month no longer fails for excess income; rather the benefit month passes “regular” TANF due to the decrease in income.  Vision will automatically delete the special allowances copied forward to the Supportive Services/Special Allowances window and the benefit month is authorized as Open for “regular” TANF for 11/2007.

3.	A Transition Assistance case may close after receiving six consecutive months of Transition Assistance or the household may remain eligible for ongoing assistance under “regular” TANF, provided all eligibility requirements continue to be met.

Example:   A family received Transition Assistance for benefit months of 09/2007 through 02/2008 (six months).  When processing the benefit month of 03/2008, the status reason of Maximum Transition will display on the Eligibility Summary window. The following processing options are available, based on household circumstances: 
•	If the benefit month fails for excess income, not due to the receipt of an extra check, the Transition Assistance case will fail for reason of Maximum Transition and must be authorized as Close. 
•	If the benefit month fails for excess income, due to the receipt of an extra check, the benefit month is authorized as Suspend under “regular” TANF, with an informational status reason displaying of Maximum Transition.   
•	If the household’s income decreased significantly for the benefit month and the month passes “regular” TANF, the month is authorized as Open under “regular” TANF, with an informational status reason displaying of Maximum Transition.  

4.	When a Transition Assistance benefit is paid, the case cannot be switched from Transition Assistance to “regular” TANF when reworking. 

Example:   A family received Transition Assistance for benefit months of 10/2007 and 11/2007.  On 11/10/2007, when the household submits the monthly report for benefit month of 12/2007, it’s reported two deprived children moved into the household on 11/05/2007.  The two children are added to the case and the Transition Assistance benefit month of 11/2007 is reworked.  With the addition of the two deprived children to the benefit month, the household’s standard of need increases and the case no longer fails for excess income.  Since the Transition Assistance benefit was previously paid for 11/2007, a new fail reason Elig TA/Inelig TANF will display on the Eligibility Summary window.  Vision will allow calculation of this “regular” TANF budget but will set the benefit issued amount to zero ($0).  An informational edit will display on Benefit Authorization window, “Cannot authorize a regular TANF benefit in a TA month. Authorize zero TA benefit.”  The case will be reauthorized as Transition Assistance with a zero benefit.

Note:  The household may be eligible for a supplemental payment under Transition Assistance for 11/2007 if either of the two deprived children completed a Health Tracks screening in 11/2007 and special allowances for the Health Tracks Reimbursement were created in 11/2007. 

When continuing with this case to process the benefit month of 12/2007, with the addition of the two deprived children for budgeting purposes, the case may now pass “regular” TANF and the month would be authorized as Open under “regular” TANF. 

5.	Reworking a paid Transition Assistance benefit month may result in an overpayment. Transition Assistance overpayments may be recouped from “regular” TANF benefits; however, “regular” TANF overpayments and/or Transition Assistance overpayments will not be recouped from Transition Assistance benefits as the benefit consists of special allowances.  TANF policy does not allow recoupment from special allowances:  

Example:  A family received Transition Assistance for 10/2007 and 11/2007.  On 11/10/2007, when the household submits the monthly report for benefit month of 12/2007, it’s reported the PI quit a job on 11/02/2007 10/22/2007 without good cause.  Transition Assistance is reworked for 11/2007 10/2007 to impose a job quit penalty.  The job quit penalty applicable to Transition Assistance is limited to ineligibility of the individual for the benefit month in which the job quit occurred.  Since Transition Assistance doesn’t provide a benefit based on the Standard of Need calculation, the PI’s needs cannot be removed for budgeting purposes when reworking the month of the job quit.  However, the special allowance for job retention provided to the household must be deleted from the Supportive Services/Special Allowances window, resulting in a $200.00 overpayment for the Transition Assistance household in the benefit month of 11/2007 10/2007.  The overpayment is authorized and a recoupment plan is established.  When processing the benefit month of 12/2007, income received the month of the job quit is used for budgeting purposes.  Due to the loss of income disregards,  earnings from employment continue to cause the case to fail for excess income so the household remains eligible for Transition Assistance for 12/2007.  Even though there is an existing overpayment authorized with a recoupment plan, Vision will not recoup from the Transition Assistance benefit for 12/2007, as TANF policy does not allow recoupment from special allowances.  

6.	A Transition Assistance benefit will not be pro-rated.

Example:   A family received Transition Assistance for benefit months of 10/2007 and 11/2007.  On 11/10/2007, when the household submits the monthly report for benefit month of 12/2007, it’s reported two deprived children moved into the household on 10/05/2007.  The two children are added to the case effective 10/05/2007 with a late report date of 11/10/2007.  The paid Transition Assistance benefit month of 10/2007 is reworked.  Vision defaults the TANF Request Date for the two children on the Application Dates window to 10/05/2007.  With the addition of the two deprived children to the benefit month, the household’s standard of need increases and the case no longer fails for excess income.  Because of the late reporting penalty, the participations of the two deprived children added to the case are set to ‘OU’ when reworking 10/2007.  (Vision will allow workers to create special allowances for these ‘OU’ children, but will not allow payment of the special allowances due to the late reporting penalty.)  Since the Transition Assistance benefit was previously paid for 10/2007, the new fail reason “Elig TA/Inelig TANF” will display on the Eligibility Summary window.  The case will be reauthorized as Transition Assistance with a zero benefit.

Note:  Child care expenses incurred in 10/2007 by the household for the two  children who returned home, may be paid under the Child Care Payment system as  a TANF payment at 100%, if all applicable CCAP requirements are met (i.e. there is a child care application and a provider who meets CCAP requirements).    

When continuing with this case to rework the paid benefit month of 11/2007 with the addition of the two children, workers must enter a TANF Request Date of 11/01/2007 for the children on the Application Dates window.  Due to the late reporting penalty, Vision recalculates the entire household’s eligibility start date to the late report date of 11/10/2007 (start dates can be viewed on HH Comp Summary window).  Since the Transition Assistance benefit was previously paid for 11/2007, a new fail reason “Elig TA/Inelig TANF” will display on the Eligibility Summary window. Even though it appears on HH Comp Summary that Vision is pro-rating the household’s benefit based on the late report date, a Transition Assistance case cannot be pro-rated and the case will be reauthorized as Transition Assistance with a zero benefit. 

Note:  Vision will allow workers to create special allowances for these children in 11/2007 and will allow authorization of the special allowances as a supplement.  Even though it appears Vision is pro-rating the household’s benefit based on the late report date, the special allowances created as a Transition Assistance supplement will not be pro-rated.  

7.	TANF households that include participations of DA, DD, DF, DI and DM are eligible for Transition Assistance; however, a household member with a DA, DD, DF, DI or DM participation is ineligible to receive the job retention special allowance. 

Example (DA=Disqualified Alien):  A family received “regular” TANF for 11/2007 with PI’s participation of DA (deprived children are U.S. citizens).  On 11/10/2007, the household submits the 12/2007 monthly report and verification of earnings, which have increased significantly.  Based on the increased earnings reported by the household, not due to the receipt of an extra check, the “regular” TANF case fails for excess income and it’s determined the household is eligible for Transition Assistance for benefit month of 12/2007.  Because the PI’s participation is DA, the PI is ineligible for the job retention special allowance and the transportation allowance (JOBS Program not applicable to DA participations); however, the remaining special allowances may be paid as applicable.  This household may remain eligible for continued Transition Assistance up to the maximum of six consecutive months before it closes for Maximum Transition, provided all eligibility requirements continue to be met.  

Example (DA=Disqualified Alien):  A TANF household consisting of two caretakers, one with a DA participation and the other with an IN participation, received “regular” TANF for 11/2007. On 11/10/2007, the household submits the 12/2007 monthly report and verification of earnings, which have increased significantly.  Based on the increased earnings reported by the household, not due to the receipt of an extra check, the “regular” TANF case fails for excess income and it’s determined the household is eligible for Transition Assistance for benefit month of 12/2007.  The caretaker with the IN participation is eligible for special allowances of job retention and transportation.  This household may remain eligible for continued Transition Assistance up to the maximum of six consecutive months.

Note:  In a child only case where the caretaker has a DA participation, the household is not eligible for Transition Assistance.  A DA participation is ineligible for the job retention special allowance and the transportation allowance (JOBS Program not applicable to a DA participation).  Because job retention and transportation are the only two special allowances paid prospectively, the TANF case must be allowed to fail for excess income and a closure authorized.

Note: If it’s determined the household doesn’t have a need for any of the three remaining special allowances, the Transition Assistance checkbox should be unchecked, Elig Process should be rerun and the ongoing TANF case should be allowed to fail for excess income and authorized as close.   

Example (DD & DF=Disqualified Drug/Fleeing Felons/ Parole or Probation Violators/Fraud):  A family received “regular” TANF for 11/2007 with PI’s participation of either DD or DF.  On 11/10/2007, the household submits the 12/2007 monthly report and verification of earnings, which have increased significantly.  Based on the increased earnings reported by the household, not due to the receipt of an extra check, the “regular” TANF case fails for excess income and it’s determined the household is eligible for Transition Assistance for benefit month of 12/2007.  Because the PI’s participation is either DD or DF, the PI is ineligible for the job retention special allowance; however, the remaining special allowances may be paid.  This household may remain eligible for continued Transition Assistance up to the maximum of six consecutive months before it closes for Maximum Transition, provided all eligibility requirements continue to be met. 

Note:  If the DD or DF participation includes an active JOBS sanction, the PI DD or DF participation is ineligible for the job retention special allowance and the transportation allowance. Because job retention and transportation are the only two special allowances paid prospectively, the TANF case must be allowed to fail for excess income and a closure authorized.

Example (DI=Disqualified JOBS):  A family TANF household consisting of two caretakers with IN participations,  received “regular” TANF for 11/2007.  On 11/10/2007, the household submits the 12/2007 monthly report and verification of earnings, which have increased significantly.  A recommendation for sanction is received from JSND on the PI and imposed effective with benefit month of 12/2007.  The PI’s participation changes to DI.  Based on the increased earnings reported by the household, not due to the receipt of an extra check, the “regular” TANF case fails for excess income and it’s determined the household is eligible for Transition Assistance for benefit month of 12/2007.  Because the PI is sanctioned for JOBS noncompliance for 12/2007, the PI is ineligible for the job retention special allowance and the transportation allowance; however, the remaining special allowances may be paid during the Sanction Penalty Month of 12/2007 and the remaining caretaker with the IN participation is eligible to receive the job retention special allowance and the transportation allowance.  If the PI fails to successfully complete a POP prior to 12/31/2007, the Transition Assistance case will close for Sanction Progression.  

Note:  In a child only case where the caretaker has a DI participation, the household is not eligible for Transition Assistance.  A DI participation is ineligible for the job retention special allowance and the transportation allowance.  Because job retention and transportation are the only two special allowances paid prospectively, the TANF case must be allowed to fail for excess income and a closure authorized.

Example (DM=Disqualified Child Support):  A family received “regular” TANF for 11/2007.  On 11/10/2007, the household submits the 12/2007 monthly report and verification of earnings. which have increased significantly.  A  “Custodian Not Coop” alert is also received in Vision on 11/10/2007.  The worker imposes a child support sanction effective with benefit month of 12/2007 and the PI’s participation changes to DM for 12/2007.  Based on the lower standard of need due to the Child Support sanction increased earnings reported by the household, not due to the receipt of an extra check, the “regular” TANF case fails for excess income and it’s determined the household is eligible for Transition Assistance for benefit month of 12/2007.  Because the PI is sanctioned for child support non-cooperation for 12/2007, the PI is ineligible for the job retention special allowance; however, the transportation remaining special allowances may be paid during the Sanction Penalty Month.  If the PI fails to resolve the child support non-cooperation issue prior to 12/31/2007, the Transition Assistance case will close for Sanction Progression.  

Note:  If the DM participation includes an active JOBS sanction, the PI DM participation is ineligible for the job retention special allowance and the transportation allowance.  Because job retention and transportation are the only two special allowances paid prospectively, the TANF case must be allowed to fail for excess income and a closure authorized.  

Vision System Processing

NOTE:  Transition Assistance processing will be available in the Vision System on 08/06/2007.  If workers suspect a TANF case will fail for excess income when processing the benefit month of 09/2007, it is recommended these cases be held and processed after Transition Assistance processing is available in the Vision System on 08/06/2007.

The Caseload List will identify Transition Assistance cases as TANF cases. Transition Assistance cases are considered TANF cases, just as Kinship Care and Diversion Assistance cases are considered TANF cases on the Caseload List.  

In order for an ongoing “regular” TANF case to be processed as Transition Assistance, the “regular” TANF case must fail for reason of excess income.  The Vision system has been enhanced to complete a second computation to identify earned income as the sole reason for the excess income failure.  If the excess income failure is not due to the receipt of an extra check, the TANF household is eligible for Transition Assistance: 
 
1.	Supportive Services/Special Allowances window – added the Transition Assistance check box field.  Select this check box if the TANF case is to be processed as a Transition Assistance case.

o	The Transition Assistance check box is disabled when the benefit month is prior to 09/2007.
o	The Transition Assistance check box remains unchecked and disabled during a TANF application month.
o	The Transition Assistance check box remains unchecked and disabled the month following the application month and for all subsequent months of Transition Assistance until HH Comp/Elig Processes are run for the first time
o	The Transition Assistance check box remains disabled in a Diversion Assistance case.
o	The Transition Assistance check box remains disabled in a  TANF/Kinship Care case. 
o	The Transition Assistance check box remains disabled in the seventh benefit month, following six prior consecutive months of Transition Assistance.
o	The Transition Assistance check box remains checked, but disabled in a Transition Assistance benefit month that has paid.

2.	Create Supportive Services/Special Allowances window – a new Category of Transition Assistance is added with the Types of Child Care, Job Retention, Health Insurance Reimbursement, Health Tracks Reimbursement and Transportation within this Category.

o	JOBS Supportive Services Category is not available for a Transition Assistance case.
o	Special Allowances Category is not available for a Transition Assistance case.
o	Transition Assistance special allowances are copied forward upon running HH Comp Process; however, remain hidden from view until the Transition Assistance check box is checked. 
o	Transition Assistance special allowances copied forward will automatically be deleted if the future benefit month is authorized determined eligible as Open for “regular” TANF.
o	Participations of DA, DD, DF, DI or DM are ineligible for the Job Retention special allowance.  
1.	If attempting to create the Job Retention special allowance for these participations, an error message displays, “Invalid participation code for the client for the type selected.”

3.  	Eligibility Summary window – when Transition Assistance check box is selected on the Supportive Services/Special Allowances window, a status reason of  Elig Transition will display on the Eligibility Summary window. 
 
o	A new status/fail reason of Maximum Transition will display on the Eligibility Summary window when processing the seventh month. 
o	A new fail reason of Elig TA/Inelig TANF will display when reworking a paid Transition Assistance benefit month and the month passes “regular” TANF after reworking.

4.  	TANF Budget Detail window – Transition SA+ field is added to the budget in the right hand column just below the Diversion SA+ field.

o	A new Inquiry option of Transition SA Summary is added to the drop down menu.  
o	TANF TLP Disregard will not increment for Transition Assistance months.
o	The income amounts from the first column of the Transition Assistance budget will still be calculated and displayed on the budget, but any other supportive services will not be calculated or displayed on the budget.  Only the new Transition Assistance special allowances will be displayed on the budget as the Benefit Issued Amount.

5.	Transition SA Summary dialog – displays the amounts for all five Transition special allowance types and the combined total of the five amounts.

6.	Benefit Authorization window – a new informational edit will display when reauthorizing a Elig TA/Inelig TANF benefit month. 
o	Cannot authorize a regular TANF benefit in a TA month.  Authorize zero TA benefit.  

7.	TANF Benefit History window – changed the DIV column heading to DIV/TRAN. Under the DIV/TRAN column heading, Diversion Assistance cases will be identified with a D and Transition Assistance cases will be identified with a T.  

8.	Alerts – a new alert indicating the sixth month of Transition Assistance will be created at the beginning of the 6th month. 
o	SIX MONTHS OF TRANSITION RECEIVED, CASE WILL CLOSE THE END OF THIS MONTH    

9.	Notices – subforms addressing Transition Assistance have been added to the TANF Application Approval, the Notification of Benefit Decision and the TANF Closure.  

Food Stamps

Sections Affected:	430-05-50-20-10 – Unearned Income 
430-05-50-25-15 – Reimbursements for Past or Future Expenses

Unearned Income 430-05-50-20-10

Unearned income includes, but is not limited to:

1.	Assistance payments such as TANF, including Diversion Assistance and TANF Transition Assistance (Job Retention portion of the payment).

Exception:
 
JOBS supportive services and TANF special allowances that represent a reimbursement are not counted as income.

When there is a reduction in a TANF benefit due to failure to perform a required action or for IPV and an overpayment is being recouped, the gross amount of the TANF grant must be counted as income if the individual was receiving food stamp benefits at the time the penalty was imposed.

Reimbursements for Past or Future Expenses 430-05-50-25-15
 
Reimbursements for past or future expenses are excluded if they do not exceed actual expenses. The worker will not consider a reimbursement to exceed the expense unless the provider or the household indicates that it is excessive.
 
Reimbursements for normal household living expenses such as rent or mortgage, clothes or food, are a gain or benefit and are not excluded. To exclude these payments, they must be specifically for an identified expense, other than normal living expenses, and used for the purpose intended.
 
When a reimbursement, including a flat allowance covers multiple expenses, it is not required that each expense be separately identified, as long as none of the reimbursement covers normal living expenses. 

Examples:

a.	Reimbursements for job or training-related expenses such as travel, per diem, uniforms, and transportation to and from the job or training site. 

b.	JOBS supportive services and TANF special allowances, including Diversion Assistance and TANF Transition Assistance special allowances, which represent a reimbursement. 
	
c.	Reimbursements for out-of-pocket expenses of volunteers incurred in the course of their work.

d.	Medical or dependent care reimbursements.

e.	All TANF child care payments.

f.	Child Care Assistance Program payments.

g.	Tribal Work Experience Payments (TWEP). The incentive portion of TWEP payments is disregarded. Any amount over the incentive is unearned income.

h.	Nutrition for North Dakota Day Care Children, a United States Department of Agriculture (USDA) approved program to pay eligible in-home day care providers for food purchased for day care children.

i.	All income, allowances, and bonuses received as a result of participation in the Burdick Job Corps Program.

Child Care Assistance Program

Sections added/affected:  400-26-07-05 – Certificate Time Frames
			    400-26-20-10 	- Income Exclusions

Certificate Time Frames – 400-26-07-05

EXCEPTION TO ONE MONTH CERTIFICATE:
Clients who are transitioning from TANF Transition Assistance to a TANF grant may request child care help from the Child Care Assistance Program when they return to TANF.  

If the client does not have an open CCA case, an application must be completed.  Because there may be only one month of need for CCAP, the worker must complete a certificate for only the month of child care the client needs.  

Since TANF Transition Assistance considers child care incurred  two months prior, the child care paid will be two months prior.  

Example:  The client received Transition Assistance in October 2007.  In November 2007 the client is eligible for TANF.  The child care being considered in making the determination of TANF eligibility is September child care.  Issue a one month certificate for September.  

If in December the client is no longer eligible for TANF and is back on Transition Assistance, leave the CCA case open, but place it in suspend status.  The case will be left in suspend status in case the client again returns to TANF.  

The client receives Transition Assistance in December, January and February.  In March the client is on TANF and needs January child care paid.  The Child Care Assistance case has remained in the suspend status. The worker issues a one-month certificate for January, and pays the January child care.  The worker leaves the case in active until it is determined if the client will be on TANF in April. 

The client is on TANF in April and the worker issues a one-month certificate for February.  The worker pays February child care and leaves the Child Care case in active status.  In March the client is on Transition Assistance.  The worker changes the status in the Child Care Assistance case to suspend.

As long as the client continues to switch from Transition Assistance to TANF and back to Transition Assistance, the client should be left in suspend status.

	Example: 
The client has a current open CCAP case and all the CCAP requirements are met.  The client’s current certificate for TANF at 100% ends at the end of August.  The client has been an on-going TANF client for the last two years.

The client received TANF in August and September.  Using August income in September, it is determined that the client will receive Transition Assistance in October 2007.  The August child care will be paid in the CCAP system, using TANF for the grant type.  No certificate needs to be added as the client has a current certificate at 100%.

During October using the September income, it is determined that November 2007 the client is eligible for TANF.  The September child care will be paid in the CCAP system using the TANF grant type.  Since there is not a current certificate, a one-month certificate will be issued for September.

During November using October income, it is determined that the client is back on Transition Assistance in December.  The October child care will be paid as a supplement to the Transition case for October.  Leave the CCA case open, but place it in suspend status in case the client again returns to TANF.  

During December using November income, it is determined that the client will be eligible for in Transition in January.  The November child care will be paid in the CCAP system using the TANF grant type.  Since there is not a current certificate, a one-month certificate will be issued for November.

During January using December income, it is determined that the client will be in Transition in February.  The December child care will be paid as a supplemental Transition payment for December.

During February using January income, it is determined that the client will be eligible for TANF in March.  The January child care will be paid as a Transition supplement for January.  

During March using February income, it is determined that the client would be eligible for TANF in April.  The February child care will be paid as a Transition payment for February

During April using March income, it is determined that the client will be eligible for TANF in May.  The March child are will be paid in the CCAP system with a TANF grant type.  A one-month certificate will be issued for March.

As long as the client continues to switch from Transition Assistance to TANF and back to Transition Assistance, the client should be left in suspend status when the client is in Transition Assistance.  

The following graph depicts the months listed above and how the child care was paid.

 	
Month of Grant	Grant Type	Month used to determine grant for this month 	Where is Child Care Paid for the month used to determine the payment?	When	
August	TANF	June	CCA computer	July	
September	TANF	July 	CCA computer	August	
October	Transition	August	CCA computer	September	
November	TANF	September	CCA computer	October	
December	Transition	October	Oct Transition supplement	November	
January	Transition	November	CCA computer	December	
February	Transition	December	Dec Transition supplement	January	
March 	TANF	January	Jan Transition supplement	February	
April	TANF	February	Feb Transition supplement	March	
May	TANF	March	CCA computer	April	

Child Care Assistance Processing Clarifications

A TANF client has had the TANF child care paid in the child care payment system.  The TANF client is now on Transition Assistance.  Change the client’s status in the child care payment system from “A” active to “S” suspend.  The status is left as “S” suspend in case the client switches from Transition Assistance back to TANF.   If that occurs, change the client’s status in the child care payment system from “S” suspend to “A” active.  If there is not a certificate covering the TANF month, the worker will issue a one month certificate for the TANF child care that will be covered in the child care payment system.  If the client remains in TANF the next month, issue another one month certificate.  Continue as needed.

If the client, after one or many months on TANF, switches back to Transition Assistance, change the client’s status from “A” active to “S” suspend.

Because the client may switch back and forth from Transition Assistance to TANF during an indefinite period of time, there will be a seven-month consecutive time limit to the length of time a case can be in suspend status. 

Income Exclusions – 400-26-20-10

40. Diversion assistance, all vendor payments and reimbursements for Diversion assistance.  Transition Assistance payment and supplements.

Low Income Home Energy Assistance Program (LIHEAP)

Sections Affected:	415-25-05-30 – Income Not Counted 
Delete #9 (because it is similar to # 13) and renumber all. Change #14 to reflect TANF Transition
415-25-05-20-20 - Other Income 
Change #1 to reflect TANF Transition

Income Not Counted 415-25-05-30

 9.	JOB incentive payments.
9.	The value of free or reduced shelter costs that are received as a part of an employment agreement (no option), a gift, or through a governmental housing assistance program.
10.	The first $100 of monthly board and room payments; or the first $25 of monthly "room only" payments (See 415-25-05-45).
11.	Children's earned income (See 415-25-05-50).
12.	The special needs portion of a TANF grant.
13.	Reimbursement for transportation, day care, and other employment or training costs under JOBS.
14.	TANF Transition Special Allowances such as Health Insurance reimbursement, Transportation allowance and Health Tracks reimbursement 
Other income 415-25-05-20-20
1 .    TANF, Diversion Assistance and TANF Transition Job Retention income. 

Medicaid

TANF Transition Assistance Payments are excludable income for Medicaid.  TANF Transition Assistance will be included in the definition of TANF.  

510-05-05 – Definitions
Temporary Assistance For Needy Families (TANF)
A program administered under North Dakota Century Code Chapter 50-09 and Title IV-A of the Social Security Act. References to TANF include TANF Kinship Care Assistance, Diversion Assistance, and Transition Assistance.

If you have questions, please contact your Regional Representative.