SNAP Renewal Before the Last TBA Benefit Month
7 CFR § 273.28(a)-(b) and (h) & 7 CFR § 273.32
The EDG may apply for SNAP renewal at any time during the TBA benefit period, and have their TBA benefits end. Complete the following actions if the EDG applies for SNAP renewal before the last month of the TBA benefit period:
- Schedule an interview.
- Provide a W-1348, Proofs We Need, identifying the verifications the EDG must provide for the renewal. Allow the EDG 10 days to provide the required verification.
Note: If the EDG applies for TFA during the TBA benefit period treat the TFA application as a SNAP application. Follow joint application requirements.
Processing the Renewal
7 CFR § 273.28(c)-(d) and (f)-(g) & 7 CFR § 273.32
Process the renewal within 30 days from the application file date if the EDG completes the renewal process.
Begin the new benefit period the first day of the month following the month the renewal application was filed if the EDG is SNAP eligible. Issue a full month’s benefit.
Example: The EDG applied for renewal in the 3rd month of their TBA benefit period. The first month of the SNAP benefit period begins in what would have been the EDG’s 4th month of TBA.
Deny the EDG’s SNAP renewal application if they are ineligible. However, continue the EDG’s TBA through the end of the TBA benefit period.
SNAP Benefit Higher than TBA
7 CFR § 273.28(g)
Issue a supplement if the EDG is eligible for a higher amount of SNAP benefits for the first month of the new SNAP benefit period and the TBA benefits were already issued.
Example: The EDG applied for SNAP renewal on July 25, during the 3rd month of their TBA benefit period. The TBA benefits are $125. The renewal was completed timely on August 15. The new SNAP benefit period begins August 1. The SNAP benefit amount is $200. Issue a $75 supplement for the month of August.
SNAP Benefit Lower than TBA
7 CFR § 273.28(e)
Encourage the EDG to withdraw its SNAP renewal application and continue to receive TBA through the end of the benefit period if the SNAP benefit amount is lower than the TBA benefit amount. Inform the EDG that they will be responsible to pay back benefits if the renewal cannot be processed by the end of the month they requested it.
If the EDG doesn’t wish to withdraw its renewal application, complete the renewal and issue the lower SNAP benefit for the first month of the new SNAP benefit period.
Note: If the renewal isn’t completed before the first month of the new SNAP benefit period, and the EDG receives the higher TBA benefit amount, establish a Inadvertent Household Error (IHE) claim for the overissuance.
Exception: Establish an Agency Error (AE) claim when the Agency doesn’t complete the renewal timely. See Agency Caused Delay.
Agency Caused Delay
7 CFR § 273.28(c)(1)-(2)
Take the following actions if the agency did not complete the SNAP renewal determination within 30 days of the application file date:
- Continue to process the renewal and do not end TBA during the 5-month benefit period if the SNAP renewal is not processed within 30 days of the application file date.
- Provide a full month’s benefit for the first month of the new SNAP benefit period. Or
- Establish an AE claim beginning with the month after the renewal application, if the EDG chooses to continue the renewal when it results in a SNAP benefit decrease.
EDG Caused Delay
7 CFR § 273.28(d)
Deny the SNAP renewal at the end of the 30 days if the EDG fails to complete a required action. Continue TBA through the end of the TBA benefit period.