108.102 Alternate Address

A victim /survivor of domestic violence may use an alternate address for receipt of mail if:

The individual has applied for or received a good cause waiver based on domestic violence or,

The individual is at risk of further domestic violence.

NOTE: The CAO must ask any individual who discloses domestic violence whether it is safe to send mail to the home address or whether it would be safer to mail it to an alternate address.

55 Pa. Code §108.15(b)

The CAO should make this inquiry at application, renewal, and semi-annual reporting, any time the individual requests a waiver of a TANF requirement based upon domestic violence, and prior to imposing a sanction.

If the individual wants to use an alternate address, record the alternate address as the client mailing address in eCIS. The individual may use the CAO address as an alternate address. If the individual chooses to use an alternate address, the CAO must record the actual home address in the case record comments. Remind the individual that important mail will come from the CAO at the alternate address and to check for mail at that address regularly and frequently to avoid any problems.

The CAO will:

Generate system notices which will be sent to the alternate address;

Generate manual notices if the CAO is the alternate address.

108.1021 Address Confidentiality Program

The Address Confidentiality Program (ACP) is administered by Pennsylvania’s Office of Victim Advocate (OVA).

The ACP provides victims/survivors of domestic violence, sexual assault, human trafficking or stalking with an alternate mailing address to keep their actual home address out of public records where their perpetrator may find their location.

ACP is designed to be a part of an overall safety plan for victims/survivors who are planning to move or have recently moved to a location unknown to the perpetrator. ACP is not a witness protection program.

55 Pa. Code § 108.15(a)(3)

For more information about ACP enrollment, the CAO can provide an Individual the ACP Flyer located in Appendix A .

Program participants are:

Provided with a legal substitute mailing address which is used in place of their actual mailing address. First class, certified and registered mail is forwarded by OVA free of charge to the participants’ actual address.

Issued a program participation card with the substitute address on the card. The substitute address is used as the program participants’ legal residence, as well as work and/or school address. The address must be accepted as the participants’ legal address by all state and local government agencies.

The program participation card includes an ACP authorization code number which must be used on all correspondence with the participant.

Enrolled for three years, unless otherwise cancelled by the participant or ACP, before the expiration date.

Enrollment in the ACP may affect individuals who are applying for:

Temporary Assistance for Needy Families; Emergency Shelter Allowance; Supplemental Security Income/State Supplementary Payment; Supplemental Nutrition Assistance Program; Low-Income Home Energy Assistance Program (LIHEAP); Medical Assistance Programs, including waiver programs and dually-eligible Medicare/Medicaid programs; childcare payments; federal foster care and adoption cases.

Services at a county Mental Health and Intellectual Disabilities Program Office or base service unit.

Child support services at one of the 67 Domestic Relations Sections.

Although state or local government entities may not require individuals who are enrolled in the ACP to provide an address other than the Harrisburg P.O. Box substitute address, private providers are not subject to the provisions of this program . The CAO should explain the county of residence impacts some programs that are offered, such as, E&T program site location, health care provider assignment and location, DRS office location, LIHEAP, CHIP, MA, and home and community-based provider services.

The ACP address used for all participants is:

P.O. Box 2465

ACP Authorization Code

Harrisburg, PA. 17105-2465

NOTE: The ACP card will include a unique Authorization Number. The Authorization Code number should be included on the second address line so that the OVA knows who the mail should be forwarded to.

All ACP participants must have the DV indicator turned on in eCIS by answering Yes to Domestic Violence on the Non-Financial Questions Screen. Select Yes in the ACP Participation drop down box on the eCIS Domestic Violence Screen.

The ACP address should be entered in eCIS into the Mailing Address section as follows,

First line: P.O. Box 2465

Second line: ACP Authorization Code, example 1234

Third line: Harrisburg, PA 17105-2465

Do Not GIS Validate the ACP address.

Document in case record comments that the ACP address has been updated using the following script: “The ACP Program is a mail forwarding system maintained by the Office of Victim Advocate (OVA), participants enrolled in the program have a confidential mailing address due to supportive services. The client’s ACP address and ACP number are (enter the entire ACP address), and the ACP card has been scanned to case record imaging”.

Prior to releasing any case record information to a third-party, the CAO must contact the DHS Office of General Counsel and obtain specific authorization.

Applicants:

Applicants who participate in the ACP must present their ACP card to the CAO.

The CAO will:

Call 1-800-563-6399 to verify that the individual is certified in the program and the ACP authorization code. Scan a copy of the ACP card into the case record imaging. See Appendix A .

Inquire if the individual resides in the county in which they are applying. This may be volunteered but is not required. If the applicant chooses not to provide the county of residence, explain that the county of residence determines:

The amount of cash assistance that is authorized (Family Size Allowance).

Referral to the appropriate employment and training programs, including contracted programs.

Which local Domestic Relation section the applicant would be referred to for child support if a referral is appropriate.

The Medical Assistance health care delivery system and the proximity of the providers, including the primary care provider, from whom the applicant will receive health care. The health care delivery system would be based on the county of residence.

If the applicant refuses to confirm the county of residence, explain that the CAO must assume the applicant is residing in the county of application and will receive benefits accordingly. Inform the individual that by signing the application, the applicant agrees that the CAO may treat the individual as a resident of the county of application and will be considered for applicable county benefits.

Use the ACP mailing address as shown on the ACP card in place of the individual’s mailing address in eCIS. Do not GIS Validate the ACP address.

The CAO will select Yes in the Domestic Violence field on the Individual Non-Financial screen in eCIS. The Domestic Violence Screen will be prompted , and the CAO must answer Yes in the ACP Participation field, and also enter the ACP Number from the ACP card in the ACP Number field.

REMINDER: Include the individual’s authorization code that appears on the front of the ACP card on all correspondence in the second line of the mailing address.

NOTE: ACP mail is delayed 5-7days from the date it was sent by the CAO when it is processed through the ACP. It can be a longer period of time in rural areas of PA. This postal delay affects CAO notices for review and renewal dates and the IMCW must take this into consideration for ACP p articipants.

When verifying residence, household composition or shelter cost s , accept any document that lists the ACP address and verifies an eligibility factor. Allow the individual to provide any document that has a physical address concealed. If the applicant provides a document that lists the physical address:

Do not disclose or release the applicant, recipient or family members residential address, the name and address of the individual’s employer, education, training, or work program, the name and address of a child or children’s school, childcare or medical provider.

Do not disclose or release the individual, family member or household member is living in a domestic violence shelter and location of the shelter.

Do not disclose or release the amount of benefits received by the individual, family member or household member.

55 Pa. Code § 108.14

If the CAO receives judicial orders or a subpoena for client information from an entity outside of DHS, the CAO will request legal advice from the Office of General Counsel, see Supplemental Handbook 930.33, Subpoena of Client Information .

55 Pa. Code § 105.4 (b)(3)

The CAO will enter case comments indicating verification of residence and documents used to verify the residence.

Recipients:

If a recipient presents an ACP card, the CAO will:

Call the ACP at 1-800-563-6399 to verify the individual is certified in the program and the ACP authorization code.

Ask the recipient if they continue to reside in the county where benefits have been issued, and

Follow the steps listed under Applicants.

At renewal, re-verify the individual’s participation in ACP, if questionable.

If the applicant/recipient is not currently certified in the ACP and does not have an alternate address, the CAO will:

Ask the applicant/recipient if they prefer to use an alternate address. If yes, use that address.

If no, require the applicant/recipient to provide an actual physical address.

Verify the address according to procedures in Cash Assistance Handbook Chapter 178, Verification .

ALTERNATE ADDRESS ACP-ADDRESS CONFIDENTIALITY PROGRAM Client is Required to Provide Actual Home Address Yes No Enter Alternate or ACP Address in eCIS as Mailing Address Yes Yes Narrate Actual Home Address in Case Record Comments Yes No* *Actual address of client with ACP can be entered into case record comments if the client volunteers to provide the information.