Inadvertent Household Error (IHE)

Definition [63-801.21]

An IHE overissuance is one which was caused by a misunderstanding or error on the part of the household or the sponsor of a noncitizen household.

Categorical Eligibility (CE) Households

An IHE claim must not be filed against a CE household unless the overissuance is due to a change in net income (based on income or deductions) or household size.

CE household status cannot be rescinded, even if a household is later determined to have been ineligible for federal PA.

Failure to Provide Correct/Complete Information

An overissuance due to a household's or sponsor's failure to provide correct or complete information must be considered an IHE overissuance.

ExampleExample

Failure to Report Changes

An overissuance which results from a household's failure to report changes in household composition, income, property (for NA households, only), or the circumstances of a sponsor is considered an IHE overissuance.

Note: The overissuance begins in the first month that the benefits would have been affected, if the client had reported timely. For a SAR household, this is usually the first month of the upcoming SAR Payment Period.

Income

When determining whether a household missed a required report of income over the Income Reporting Threshold (IRT) for their household size, the EW must use actual gross monthly income received as this is the income the household should have used to determine whether they were required to report. The EW must not apply the conversion factor. The conversion factor must only be used for budgeting purposes when converting weekly or bi-weekly income into an anticipated monthly income amount.

If a household misses a required report of gross monthly income received over the IRT and…	Then...
They remain eligible for CalFresh benefits under MCE,	Recalculate the household’s monthly allotment for the months in which their income exceeded the IRT.  Establish an IHE OI for the total amount of benefits the household received but was not entitled to for the months since they failed to make the required report. The first month impacted by the household’s failure to report is the first month included in the OI calculation.
They are ineligible for CalFresh,	Determine whether the household should have been discontinued (i.e., income over the IRT continued for more than one month).  If the household should have been discontinued, any benefits subsequently received after the month in which the household should have been discontinued must be included when determining the value of the OI.

IEVS Matches

Compare information found in IEVS matches to the household’s case information and determine whether it affects the household’s eligibility or benefit level. The determination is based on the household’s IRT and any other mandatory reporting requirements.

Important: If there is a potential discrepancy in income, refer to the Third-Party Payroll Sources topic in DEBS BP Handbook Chapter 9 Income Verification System (IEVS) for more information.

If the household...	Then...
Should have been discontinued based on the income verified after an IEVS match,	Any benefits subsequently received by the household for the remainder of the relevant SAR payment period after what would have been the month of discontinuance must be included when determining the value of the OI.
Should not have been discontinued, but received benefits that it was not entitled to based on the income information verified after an IEVS match,	Establish an IHE OI for the total amount of CalFresh benefits that the household received and was not entitled to.

Reminder: MCE households certified between 131 percent and 200 percent FPL are not required to make reports of income received during the SAR payment period. These households have already reported income over 130 percent and met their IRT reporting requirement at the time that eligibility was determined.

 

ExampleExample Application Date 01/01/2023, HH of 1 approved with income under 130% IRT for SAR payment period 01/2023-06/2023. The client was determined to be over IRT 03/2023 and total ineligibility. If the client had reported timely, discontinuance would have been effective 05/01/23. However, the client did not report a change in IRT timely, so an OI must be established from 05/2023 onward.

ExampleExample Application Date 01/01/2023 HH of 1 approved with $0 income for SAR payment period 01/2023-06/2023. Income went unreported since application until discovered by the IFD IEVS match. Clients’ income was determined to cause total ineligibility. The client failed to report earned income at application and received benefits they were not entitled to. The OI will be established for the total amount of benefits that the household received and was not entitled to.

Late SAR 7 Eligibility/Status Report

An IHE overissuance MUST be established when a recipient submits a late SAR 7 (after the 11th of the SAR submit month) which results in the household receiving more benefits than to which it is entitled because of the county’s inability to decrease benefits due to the 10-day notice requirement.

Reminder: If the SAR 7 was received timely (by the 11th of the Submit Month) but was not processed or was processed incorrectly by the county, then an administrative error overissuance must be established if the household received more benefits than to which it was entitled for the SAR Payment Period.

IHE and Loss of the Earned Income Deduction [63-801.312]

When determining an overissuance due to the failure of the household to report earned income in a timely manner (by the extended filing date), disallow the 20% earned income deduction on the unreported portion of the earned income.

Exception: When good cause exists for late SAR 7 reporting, the 20% earned income disregard is allowed.

Aid Paid Pending

An overissuance which results when a household received more benefits than it was entitled to through aid paid pending a fair hearing, which it subsequently lost, is considered an IHE overissuance.

ExampleExample

Related Topics

Supplemental Payments and Claims Definitions