SANCTIONS FOR FAILURE TO COMPLY - CASH
ISSUE DATE: 07/2026
MFIP:
For information on child support sanctions when the participant is not also sanctioned for another reason, see 0012.24 (Child Support Sanctions). For information on MFIP sanctions for refusing or terminating suitable employment, see 0028.30.09 (Refusing or Terminating Employment). Also see 0028.18 (Good Cause for Non-Compliance--MFIP), 0028.30.12 (Sanction Notice for Minor Caregiver).
UNLESS THERE IS GOOD CAUSE, consider a participant out of compliance with the requirements of MFIP Employment Services if they fail to:
● | Attend a financial orientation. |
OR | |
● | Attend the overview. |
OR | |
● | Conduct the required job search. |
OR | |
● | Cooperate in the development of an Employment Plan. |
OR | |
● | Comply with or make satisfactory progress in the activities specified in the Employment Plan. The Employment Plan must clearly specify the criteria for satisfactory progress. |
OR | |
● | Accept or terminates suitable employment. |
OR | |
● | Meet school attendance requirements. |
Do not sanction a Family Stabilization Services (FSS) participant unless all FSS pre-sanction provisions have been met. See 0011.34 (Family Stabilization Services), MFIP Employment Services Manual 17.61 (Sanctions).
Do NOT continue a sanction that was imposed in a previous state. Sanctions do not follow from state to state.
In addition, apply the process below for any EMPLOYMENT-RELATED sanction:
1. | The employment counselor must send participants the MFIP Notice of Intent to Sanction (DHS-3175) (PDF) and tell them they may request a conciliation conference. Your agency’s Employment Services Provider (ESP) must conduct the conference within 5 days of the request. Participants may request a fair hearing when they get a Notice of Intent to Sanction without exercising the option of a conciliation conference. |
2. | If a participant does not request a conciliation conference within 10 calendar days of the mailing of the Notice of Intent to Sanction, the employment counselor will send a MFIP Status Update Form (DHS-3165) (PDF). When you get the Status Update Form, send the caregiver a Notice of Adverse Action (NOAA). |
3. | Apply the sanction to the grant for the 1st possible month after the determination of non-compliance, following 10-day notice requirements. Notify the employment counselor of the effective date of sanction. |
4. | The caregiver may request a fair hearing upon getting the NOAA. See 0027 (Appeals). If the caregiver files an appeal within 10 days after the date of the NOAA, follow the provisions of 0027.15 (Continuation of Benefits). |
5. | Lift the sanction in the month after the month the caregiver complies with the MFIP-ES requirement, unless the participant comes into compliance on or before the 15th of the sanctioned month. If the participant comes into compliance on or before the 15th of the month, the benefit amount must be restored and the sanction lifted. The employment counselor will send you a Status Update Form to tell you to remove the sanction. |
Do not impose a sanction when a participant complies with MFIP-ES requirements prior to the effective date of the sanction.
The sanction count restarts if MFIP closes for a minimum of one full month for a reason other than 100% sanction and is not reinstated. Upon a new application, the sanction count resets to 0 and the participant has a new opportunity to comply with MFIP program requirements.
Participants may cure an MFIP-ES sanction by complying with the MFIP-ES requirements as outlined below:
FOR THE 1ST – 6th OCCURRENCE OF NON-COMPLIANCE
When a sanction has been imposed, it must be in effect for a minimum of 1 month, unless the participant comes into compliance on or before the 15th of the sanctioned month. If the participant comes into compliance on or before the 15th of the sanction month, the grant amount must be restored retroactively for that month.
NOTE: When the participant comes into compliance the sanction count resets to zero.
7TH OCCURRENCE OF NON-COMPLIANCE (100% SANCTION - MONTH OF CLOSURE)
The sanction can be cured prior to the EFFECTIVE date of the sanction (case closure) unless good cause is granted or pre-employment activities are found to exist.
For a relative caregiver case, in which the eligible relative caregiver has opted to be included in the MFIP grant, and the caregiver has reached the 7th occurrence sanction limit, MFIP should remain open for the relative care child. For MAXIS instructions, see POLI/TEMP TE17.13 (7th Occurrence Sanction - Relative Caregiver).
Also, see TE20.07 (Reapply After 7th Occur. Sanction Examples) for a list of case examples with information on regaining eligibility after a 7th occurrence of non-compliance (100% sanction case closure).
Before the case is closed, the county agency must review the participant's case to determine if the employment plan is still appropriate and attempt to meet with the participant face-to-face. The participant may bring an advocate to the face-to-face meeting.
During the face-to-face meeting, the county agency must:
● | Review the employment plan to determine if the work activities are appropriate or if preemployment activity is required |
● | Review the case to determine if the participant qualifies for a good cause |
● | Review the case to determine if the participant qualifies for the family violence waiver |
● | Review the participant's sanction status and explain the consequences of continuing noncompliance |
● | Provide other resources that may be available to the participant to meet the needs of the family; and |
● | Inform the participant of the right to appeal (link to Appeal section of CM) |
If a face-to-face meeting is not conducted, the county agency must send the participant a written notice that includes the above information.
When a case has been closed, and you then reinstate or reopen it, apply the following procedures:
● | CLOSED FOR LESS THAN A CALENDAR MONTH |
● | CLOSED FOR MORE THAN A CALENDAR MONTH DUE TO NON COMPLIANCE WITH EMPLOYMENT SERVICES WITH A NEW APPLICATION AND PROSPECTIVE BUDGETING |
FOR TWO PARENT HOUSEHOLDS:
● | A 2-parent household gets a total of 6 occurrences before closure. For example: if Mom has 3 occurrences and Dad has 3, the next (7th) occurrence results in case closure. However, if both parents in a 2-parent household are out of compliance during the same month, it counts as 1 occurrence. |
● | The household remains in sanction until BOTH caregivers have come back into compliance. |
FOR DUAL SANCTIONS:
Impose sanctions as follows for participants who refuse to comply with child support requirements AND have a concurrent sanction for failure to attend orientation or to develop or to comply with their Employment Plan:
● | If the child support non-compliance and other program non-compliance occur in the SAME month, reduce the cash portion of the grant by 25%. |
● | The household remains subject to 25% sanction until BOTH issues of non-compliance have been resolved. |
SNAP:
For information on work rules for SNAP, see 0011.24 (Time-limited SNAP Recipients), 0028.07 (General Work Rules for SNAP). For information on sanctions for not meeting work rules for SNAP, see 0028.21 (Good Cause Non-Compliance-SNAP/MSA/GA/HSP), 0028.30.06 (Sanctions for Not Meeting SNAP Work Rules).
MSA, GA, HSP:
No provisions.![]()
![]()
![]()
PREVIOUS REVISIONS
| Date | Notes |
|---|---|
| 03/2026 | Manuals Moratorium - removes DWP language for the DWP repeal, reviews DHS language, updates language of GRH to HSP, reinserts bold. |
| 02/2023 | in SNAP updates title for 11.24 to Time-limited SNAP Recipients |
| 04/2022 | in MFIP adds and deletes cross-references. |
| 12/2021 | in SNAP updates language and cross-references. |
| 01/2021 | in MFIP updates cross-references. |
| 08/2020 | in MFIP under sub-heading CLOSED FOR MORE THAN A CALENDAR MONTH DUE TO NON COMPLIANCE WITH EMPLOYMENT SERVICES WITH A NEW APPLICATION AND PROSPECTIVE BUDGETING adds being granted good cause as a reason to open the case after closing. |
| 12/2018 | in MFIP under "CLOSED FOR MORE THAN A CALENDAR MONTH FOR REASONS OTHER..." deletes "Do not impose the previous ES sanction" & adds "Do not reduce benefits based on previous ES sanctions". In SNAP deletes cross-reference 0028.20 due to section deletion. |
| 04/2015 | Removed WB. This program was suspended 12/1/14. |
| 03/2014 | update cross-references to 0028.20 (Failure to Comply - SNAP E&T), 0028.30.06 (Type/Length of SNAP E&T Sanctions). No policy was changed. |
Report this page