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Title 7: SNAP Page 8 Iowa Department of Health and Human Services Employees’ Manual Chapter H: Adjustments Claims Revised October 11, 2024 Intentional Program Violation (IPV) Claims Trafficking-Related Claims Legal reference: 7 CFR 273.18(c)(2) Policy: The Department of Inspections, Appeals, and Licensing establishes an IPV claim when an overissuance occurs as a result of a trafficking-related offense. (For a definition of “trafficking,” see 7-A, Definitions.) Base the amount of the claim on: ▪ The person’s admission. ▪ The amount identified in the adjudication. ▪ The amount identified in the documentation that is the basis for the trafficking determination. Agency Error (AE) Claims Legal reference: 7 CFR 273.18(b) Policy: Establish an agency error (AE) claim when Department action or failure to act caused an overpayment. Examples of AE errors are: ▪ Failing to act timely on a change the household reported that would have reduced benefits, whether the household was required to report the change or not. ▪ Incorrectly calculating the household’s income or deductions, or otherwise issuing an incorrect benefit amount. ▪ Incorrectly issuing duplicate benefits. ▪ Continuing benefits after a household’s certification period has expired. Months an AE Claim Covers Legal reference: 7 CFR 273.18(c)(1), 441 IAC 65.21(1), Bliek v. Palmer, 102 F.3d 1472 (8th Cir. 1997) Policy: Calculate the amount of an AE claim back to the month when the error occurred, but not beyond 12 months from the date the overpayment was discovered. Do not include any month before February 2007. AE claims for months before February 2007 were forgiven as part of the Bliek lawsuit settlement. Procedure: If an overpayment occurred at application or recertification due to an agency error, calculate a claim from the beginning of the certification period. If a household receiving ongoing benefits reported a change but the agency did not act on the change within the required period, complete a claim starting the month the change would have been effective if the agency had acted timely.