3325 Enumeration | SNAP

Georgia Division of Family and Children Services
SNAP Policy Manual

Policy Title:

Enumeration

Effective Date:

November 2019

Chapter:

3300

Policy Number:

3325

Previous Policy Number(s):

MT-31

Updated or Reviewed in MT:

MT-57

Requirements

An individual must be enumerated (e.g. provide a social security number (SSN) in order to be included in the assistance unit. An individual, who is not applying for food stamps and who does not provide an SSN, may be designated as a non-applicant. A non-applicant is not required to provide an SSN but is required to provide other information that may affect the eligibility of the other applicant AU members such as income or resources. A non-applicant is not eligible to receive food stamp benefits.

Basic Considerations

Enumeration is the process by which an SSN is obtained and validated.

Providing an SSN is voluntary; however, AUs applying for food stamp benefits must provide an SSN or apply for an SSN for each AU member in order to receive benefits. Verification of the SSN is not required in order for an individual to be included in the AU.

The AU’s statement of SSNs may be accepted for individuals who have been assigned an SSN. Individuals who provide SSNs prior to certification, recertification, or as a reported change are entered in the Gateway system and are validated through the Social Security Administration’s (SSA) system.

SSNs are used to secure information from other data bases to achieve the following purposes:

facilitate mass changes in federal benefits
request and exchange information on individuals through IEVS (e.g. discover unreported income or resources)
prevent duplicate benefits
verify accuracy and/or reliability of information reported by the AU.

Duplicate SSNs

If an individual reports more than one SSN that has been assigned to him/her, the individual must be referred to SSA to resolve the discrepancy. All duplicate SSNs must be entered in the system.

The AU must report the correct and primary SSN to the agency upon resolution with the SSA.

Obtaining SSNs for AUs

An AU member who does not have or does not know his/her SSN must apply for one with the SSA.

The AU is referred to the SSA and must be informed of its responsibility to submit documents that verify age, identity, and citizenship such as birth certificates, driver’s license, etc. to apply for an SSN.

SSN for A Newborn

If an AU is unable to provide proof of application for a newborn’s SSN, the AU must provide the SSN or proof of application for the SSN at the next review or within 6 months following the month the baby is born, whichever is later.

Enumeration is not required in the first month of Food Stamp Program participation for applications subject to expedited application processing.

Good Cause

Good cause may be established for failure to meet the enumeration requirement. Good cause is established when it is determined that the AU member has made every effort to obtain an SSN but has been unable to do so because of the inability to obtain the necessary documents required by the SSA. The county office must make every effort to assist the AU in obtaining the documents needed to complete the enumeration process.

Good cause includes but is not limited to the following:

documentary evidence or collateral information that the AU member has applied for an SSN and had not yet been issued a number
the inability of the AU to obtain the necessary documents required by the Social Security Administration. Example: inability to obtain a birth certificate.

Because SSA makes provisions for mail-in applications in lieu of applying in person, good cause does not include the following:

illness
lack of transportation
temporary absence from the home.

Enumeration Sanctions

Refusal to meet the enumeration requirement, which includes refusal to resolve discrepancies identified during the SSA validation process, results in an automatic determination of non-compliance for the AU member.

An AU member who does not meet the enumeration requirement is sanctioned and is ineligible to be included in the AU.

An individual who is considered to be a non-applicant is ineligible and is excluded from the AU.

The earned or unearned income and resources of the ineligible AU member or non-applicant are counted as household income to determine the AU’s eligibility and benefit amount for the other applicant AU members.

Refer to 3620 Budget for an AU with Individuals Who Fail to Comply with Enumeration Requirements.

Compliance

The individual complies with enumeration requirements when verification of the application for an SSN is provided, an SSN is provided, or any discrepancies are resolved.

Procedures

The following charts outline procedures for obtaining and recording an SSN in the case record:

[@chart-3325-1] .Chart 3325.1 - Enumeration

IF AN AU MEMBER	THEN
is currently in the system with an SSN	compare system number with the applicant/recipient’s (A/R) statement.
knows the SSN at the interview	go to Person LUW. On Person Details screen in the Demographic Information section, enter SSN in the SSN field (leave blank to request). Choose appropriate selection from dropdown in SSN verification field.
does not know the SSN at the interview but is able to obtain it	issue a verification checklist to request that the SSN be provided within 10 calendar days. When the A/R provides the SSN, enter the SSN in the system.
has multiple SSNs	refer AU member to the Social Security Administration (SSA) to resolve the discrepancy. enter all known SSNs in the system. Inform the AU of the responsibility to report the correct and primary SSN to the county office upon resolution with SSA.
is enumerated at birth by a medical facility	request the SSN at the next review or within 6 months following the month the baby is born, whichever is later. If the SSN has not been received, request the SSN at each review thereafter.
never had an SSN OR had an SSN but the number is unknown	refer the AU member to SSA to apply for a new or replacement SSN. Follow these steps: Inform the AU of its responsibility to submit original or certified copies of documents that verify age, identity, and citizenship (e.g., birth certificates, drivers' licenses, etc.) to SSA with the application for an SSN. Allow the AU 10 calendar days to verify application for an SSN. If verification is provided, document that it has been received and upload the verification in the Document Imaging System (DIS). Request the SSN at the next review. If the SSN has not been received, request the SSN at each review thereafter. If verification is not provided, determine if good cause exists. If good cause exists, contact the AU monthly to monitor good cause. If good cause does not exist, the non-enumerated individual is not included in the AU.

IF AN AU MEMBER

THEN

is currently in the system with an SSN

compare system number with the applicant/recipient’s (A/R) statement.

knows the SSN at the interview

go to Person LUW. On Person Details screen in the Demographic Information section, enter SSN in the SSN field (leave blank to request). Choose appropriate selection from dropdown in SSN verification field.

does not know the SSN at the interview but is able to obtain it

issue a verification checklist to request that the SSN be provided within 10 calendar days.

When the A/R provides the SSN, enter the SSN in the system.

has multiple SSNs

refer AU member to the Social Security Administration (SSA) to resolve the discrepancy.

enter all known SSNs in the system.

Inform the AU of the responsibility to report the correct and primary SSN to the county office upon resolution with SSA.

is enumerated at birth by a medical facility

request the SSN at the next review or within 6 months following the month the baby is born, whichever is later. If the SSN has not been received, request the SSN at each review thereafter.

never had an SSN

had an SSN but the number is unknown

refer the AU member to SSA to apply for a new or replacement SSN.

Follow these steps:

Inform the AU of its responsibility to submit original or certified copies of documents that verify age, identity, and citizenship (e.g., birth certificates, drivers' licenses, etc.) to SSA with the application for an SSN.
Allow the AU 10 calendar days to verify application for an SSN.
If verification is provided, document that it has been received and upload the verification in the Document Imaging System (DIS).
Request the SSN at the next review. If the SSN has not been received, request the SSN at each review thereafter.
If verification is not provided, determine if good cause exists.
If good cause exists, contact the AU monthly to monitor good cause.
If good cause does not exist, the non-enumerated individual is not included in the AU.

Use the following chart to determine required action when good cause is established, or the enumeration requirement is met following non-compliance.

Chart 3325.2 – Good Cause in Enumeration
IF	THEN
good cause is established at application processing OR good cause is established when an individual join the AU	Document the following: The AU’s statement of the reason for noncompliance The reason for establishing good cause The offer of assistance in obtaining needed verification. Include the individual in the AU. Monitor good cause assertion on a monthly basis by the following methods: Contact the A/R in writing, in person, or by telephone AND Document the current status of the good cause determination.
the non-enumerated individual meets the enumeration requirement OR establishes good cause	Document that the enumeration requirement has been met. Add the AU member to the case effective the month following the month in which the enumeration requirement is met, or good cause is established.
good cause assertion is denied OR the AU member initially complies with enumeration but refuses to resolve discrepancies identified during the SSA validation process	Document the following: The AU’s statement of the reason for non-compliance The reason for denial of the good cause claim The offer of assistance in applying for an SSN. Do not include the non-enumerated individual in the AU. If at application, approve application for the other AU members. Issue a notice to the AU. Include the following information in the notice: The reason for the action The eligibility and benefit level of the remaining AU members The action the individual must take in order to be added to the AU.
the AU member is currently receiving benefits AND good cause for non-compliance no longer exists	Document the reason good cause no longer exists. Issue timely notice to the AU. The notice must include the following information: The reason for the action The eligibility and benefit level of the remaining AU members The action the individual must take to be added to the AU. Remove the non-enumerated individual from the AU effective the month following the month timely notice expires.