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North Carolina

33 be terminated due to exhaustion of state or federal time clocks or failure to comply with paperwork or procedural requirements if all other eligibility requirements are met. Suspension of all sanctions against individuals and families currently in sanction status due to non-compliance with child support enforcement and/or failure to meet the work requirements will allow these individuals to apply and receive benefits during the COVID- 19 emergency declaration. Suspended sanctions would include non-compliance with child support services (i.e. appearing for interviews, hearings, and legal proceedings; supplying information or documentation; and submitting to genetic testing), substance use treatment, MRA/Outcome Plan terms and conditions. Applicants and recipients with active Work First sanctions for failure to cooperate with child support and/or failure to meet the work requirements will be eligible to receive Work First Cash Assistance if all other eligibility requirements are met.

As a result of COVID-19, the United States Department of Agriculture (USDA) approved a waiver giving North Carolina approval to temporarily suspend collection of active Food and Nutrition Services (FNS) recoupments of overpayments, delay collection action on newly established FNS overpayments, and not consider payments on established FNS overpayments delayed due to this suspension to be delinquent, DHHS extended the waiver to include Work First Cash Assistance in a collaborative effort with FNS to streamline the functionality of the NC FAST case management system. If households choose to continue to make payments, the payment can be accepted and applied to their claim. Counties should inform households there is no penalty for not making payments. Although collection may be temporarily suspended during the COVID-19 emergency declaration, households will remain liable for their outstanding FNS and WF debts and the collection activity and delinquency determination will resume at the end of the waiver period.

Upon the state’s decision to disregard unemployment insurance benefits (UIB), counties must not count UIB income received when eligibility for the UIB is directly related to unemployment, job loss or other qualifying status as a result of the COVID-19 emergency declaration; however, all other unemployment compensation payments received which are unrelated to the COVID-19 emergency declaration continue to be a countable source of income for TANF eligibility and benefit calculations.

In lieu of counting child support as unearned income for dependent child(ren) included in the Work First Cash Assistance budget unit, the state may opt to implement a temporary pass through of child support payments received to current TANF families. A temporary pass through will allow families to receive 100% or a portion of child support recouped by the state to offset TANF payments issued to the family.

The temporary suspensions furthermore allow for good cause exemption for not meeting eligibility requirements that are not available or attainable due to the onset of a natural disaster or other emergency situations. Case managers are encouraged to provide case management by phone or other virtual/electronic communication platform. Counties should utilize online approaches for participants to engage in work activities virtually, such as online trainings, job search and work readiness to keep them engaged without needing to go to a training site. In the event the disaster or emergency declaration does not allow for the implementation of such approaches, a good cause exemption may be applied to participants for work requirements. The state will automatically release Work First Cash Assistance payments to individuals/families currently in the pay after performance status when conditions require a statewide good cause exemption.