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FOOD AND NUTRITION SERVICES MANUAL

GENERAL PROCEDURES & REQUIREMENTS FNS 105 PRUDENT PERSON CONCEPT

1 Change #1-2021 May 1, 2021 FS 105 Prudent Person Concept Change #1-2021 May 1, 2021

105.01 PRUDENT PERSON CONCEPT The policies and procedures throughout this manual are intended to be a guide for Food and Nutrition Services (FNS) certification and are broadly written within the limits imposed by the Food Stamp Act of 1977 and the Supplemental Nutrition Assistance Program (SNAP) regulations. A. Policy contained in this manual is intended to be sufficiently flexible to allow the caseworker to exercise reasonable judgement in executing his/her responsibilities. B. It is impossible to write procedures that cover every possible situation that arises during the daily maintenance of FNS cases. In this regard, the concept of the “prudent person” is helpful to the caseworker. The term refers to the reasonableness of the judgements made by an individual in a given situation. C. In making a certification decision, the caseworker should ask themselves if their judgement is reasonable, based on experience and knowledge of the program. For example, if the client’s statement of incurred shelter expenses are out of line with the amount of income and/or resources available to the client, the caseworker must ask for an explanation prior to certification. D. Similarly, it is the caseworker’s responsibility to exercise judgement in determining if a given number of individuals who apply for benefits as a single household do in fact meet the FNS Program’s household concept. E. If the caseworker encounters a problem in a specific case that he feels may necessitate a change in policy or the development of new policy, they should refer the matter to their supervisor. 1. If necessary, the supervisor will refer the problem to the appropriate state support staff. 2. In some cases, it may be necessary for state support staff to refer a question for further research with the United States Department of Agriculture’s (USDA) Regional Office. F. If a case situation only applies to a specific case, or to a limited number of cases, and is generally covered by existing policy guidelines, the caseworker should make a judgement that they can defend as reasonable and prudent and document the case record. NOTE: Use of the prudent person concept does not replace required actions of the FNS caseworker, nor does it eliminate any eligibility requirements for the FNS unit.