Page 2

2

3. The Department shall also report the following information: participant ID and, when applicable, a vulnerable individual flag. All information shall be reported in accordance with procedures provided by FNS. Eligibility Workers must comply with SNAP 301-1 in instances where a Social Security number is not available.

a) A vulnerable individual flag is used to identify when precautions must be taken to protect the individual's information in the event of a match. A vulnerable individual can self-identify during the application or recertification process or may be identified by the Department on a discretionary basis using the criteria in section 3(b) of this policy.

b) A vulnerable individual, for the purpose of the NAC, includes but is not limited to, those who would be endangered by the dissemination of their information, regardless of their age or gender, such as a resident of a shelter for battered women and children, a resident of a domestic violence shelter, or a person who self-identifies as fleeing domestic violence at any point during application, recertification, certification, or addition of a new household member. Vulnerable individuals should be marked as “living in a domestic violence shelter” in CHIMES. Please see the NAC Interface Business Process

4. The Department shall maintain the security, privacy, and accuracy of information submitted to the NAC, including ensuring that information provided to the NAC follows the standards and procedures provided by FNS and only includes active SNAP participants.

Use of Match Data: 1. Prior to conducting a NAC query at application, recertification, or the addition of a household member, the Department shall follow verification procedures described in SNAP 303-1 for Social Security numbers and SNAP 103-5 for residency and identity. After following these verification procedures, The Department shall conduct a NAC query on the individual applying, recertifying, or being added to a household.

2. When the Department receives a positive match from a NAC query at application, recertification, or when adding a household member:

a) The OPA shall have 10 days from the date the match is received to initiate action to resolve the match and notify the other State agency of the initiated action.

b) The Department must resolve the match to determine the appropriate actions to take on the case. To resolve a match, the Department may use information known to the Department, must verify any questionable information in accordance with SNAP 1501-1, and must notify the individual of the match. The Department may not take any action to deny, terminate, suspend, or reduce SNAP benefits based on information received from the NAC until the information has been verified by the Department and the individual has been provided notice of the match and an opportunity to respond to the notice, in accordance with SNAP 103-5.