When the county agency or Tribal Nation finds a payment was incorrect, reconstruct each budget month and corresponding payment month using the policies and procedures that were in effect for the payment month. The overpayment or underpayment is the difference between the benefit amount the program participant actually received, and the benefit amount the program participant should have received.

Overpayments once computed must be entered on MAXIS through the CCOL/CLAM queue. See TEMP Manual TE02.09.01 (Entering Claims) and 0025.21.07 (JOL - Establishing Claims). For overpayment notice requirements, see 0026.39 (Notice of Overpayment and Recoupment). Enter claims the county agency or Tribal Nation suspect are fraud claims as client error initially and adjust them later to fraud if appropriate. Once entered on MAXIS, initiate recovery on collectible claims. See 0025.12.06 (Repaying Overpayments - Participants), 0025.12.09 (Repaying Overpayments - Non-Participants), 0025.24.03 (Recovering Fraudulently Obtained Assistance).

To determine if a program participant was overpaid, refer to other sections of this manual. For example, see 0022.21 (Income Overpayment Relating to Budget Cycle) to determine if an increase in income results in an overpayment. See 0008 (Changes in Circumstances) for information on other changes that may cause an overpayment or underpayment.

When computing overpayments, allow earned income disregards and work expense deductions only for earned income reported timely. Timeliness varies between programs, see program provisions. Do not allow the earned income disregard on income reported through other means such as IEVS, a “New Hire Message”, or a person other than the client, the authorized representative, or guardian. If a client reports only part of his/her earned income, do not allow earned income disregards on the income not reported timely. (For example, a client has 2 jobs but fails to report the 2nd job. When computing the overpayments, allow all the disregards on the earnings from the 1st job but not the 2nd job.) Also see 0018.06 (Work Expense Deductions), 0018.18 (Earned Income Disregards).

When processing a restored benefit on a case that has a claim for the same period, ALWAYS enter the claim first. MAXIS will apply the restored benefit amount to the claim when appropriate. See TEMP Manual TE02.08.025 (Restored Benefits Applied to a Claim).

Determine Discovery and Established Dates as part of the process for calculating a claim. See DISCOVERY DATE in 0002.15 (Glossary: Deed...), ESTABLISHED DATE in 0002.21 (Glossary: Employment...), TE02.09.01 (Entering Claims). Documents needed to calculate a claim could be wage stubs, W-2s, bank statements, employer verification, etc.

Do not include any amounts in the overpayment calculation that occurred more than 6 years prior to the Discovery Date for overpayments due to client error or fraud. Do not include amounts that occurred more than 1 year prior to the Discovery Date for overpayments due to agency error.

If the Discovery Date is not correctly identified it can result in monthly overpayments erroneously being included or excluded in a claim. See 0025.12.12 (Action On Overpayments - Time Limits).


MFIP:
DO NOT establish an overpayment or underpayment for units for any month for which assistance was issued on the best information available at the time, if the correct policy was applied, and there was no client error.

DO NOT establish an overpayment when a 100% sanction has not been imposed due to the agency’s failure to act. See 0028.30.03 (Pre 60-Month Type/Length of ES Sanctions).

For purposes of allowing the earned income disregard, a report is timely when the client or authorized representative reports income within 2 calendar months following the end of the month in which the income was received.

Reporting procedures and client notice requirements used when clients report timely do not apply when changes in household composition are not reported timely.

●

When a mandatory unit member enters the household and the unit fails to report the change timely, calculate the overpayment starting with the month the mandatory unit member arrives.

●

When a mandatory unit member leaves the household and the unit fails to report the change timely, if the agency could have reduced or terminated assistance for 1 or more payment months had a delay in reporting the change not occurred, determine whether timely notice could have been issued on the day that the change occurred. Determine the correct benefit amount beginning with the 1st month in which the county agency or Tribal Nation could have given timely notice.

Subtract the benefit the unit should have received for the payment month from the actual MFIP issued.

Subtract the full benefit amount the unit should have received (disregard any recoupment previously deducted) from the full benefit amount the unit actually received (disregard any recoupment previously deducted) for each month in the overpayment period. The difference is the overpayment amount.

NOTE: The housing subsidy deduction reduces only the cash portion of the MFIP grant. See 0017.15.99 (Housing Subsidy). When determining the correct overpayment amount, do NOT use the housing subsidy to reduce the food portion of the benefit amount.

If the client refuses to provide information to establish the amount of the overpayment and if no information is available to estimate a claim amount, assign an overpayment for the full amount of MFIP issued for the period in question.

Notify the client of the right to provide proof to establish a smaller overpayment. Close the case if it is not possible to establish current eligibility.


DWP:
Follow general provisions. In addition, do not establish an overpayment or underpayment if the determination of the DWP grant amount is based on the best information available at the time of approval, even when there is additional income to the family unit. See 0022.12 (How to Calc. Benefit Level – MFIP/ GA).


SNAP:
Assess for overpayments on changes that were required to be reported during the certification but were not reported timely. See 0007.03.02 (Six-Month Reporting) and 0007.03.05 (Change Reporting). Do not establish an overpayment or underpayment because of changes that were not required to be reported by the unit during the certification period.

Assess for overpayments of changes that were known to the agency during the certification period when the change:

●	Required immediate actions
	AND
●	The agency did not act timely. See 0008.06.01 (Implementing Changes – Program Provisions).

For expedited SNAP overpayments, see 0004.04 (Expedited SNAP).

When calculating overpayments or underpayments for SNAP, use the amount of cash assistance actually received in the payment month even if the cash assistance was later determined to be an overpayment.

CALCULATING AN OVERPAYMENT

When calculating an overpayment for all SNAP units consider the following:

●	Total overpayments cannot be determined when you do not have sufficient income verifications for the overpayment period. Income verification is required to reconstruct the budget and determine if or how much a unit was overpaid. Use available resources to obtain income verification.
●	Do not use actual income. Anticipate the income and use the anticipated income to calculate the over or under payment. To adjust the anticipated income, apply the existing policies and procedures that were in effect such as, adjust the anticipated income when the unit would have completed a review, recertification, or when the unit was required to report a change according to their reporting requirements.
●	When there is totally ineligibility one month during the overpayment period, continue to assess each overpayment month and do not assume a total overpayment for each month.

When calculating overpayments for non-categorically eligible SNAP units, or when the unit should have been approved as non-categorically eligible (see 0013.06 (SNAP Categorical Eligibility/Ineligibility) to determine SNAP categorical eligibility/ineligibility):

●	Use the Verification Request Form (DHS-2919) (PDF) to request income and asset verification for the potential overpayment period. Do not request income verification if the county or Tribal Nation already has the required income verification.
●	Use the verifications provided to determine if the unit would have met the non-categorical eligibility income and asset limits during any month of the overpayment period.
●	The overpayment period ends the first month the unit would have met the non-categorical eligibility income and asset limits. Do not continue overpayment calculations. This may result in no overpayments or a shorter overpayment period.
●	In these situations, only, assess total overpayments for the overpayment period if income and/or asset verifications are not submitted. If verifications are submitted later or during an appeal, the overpayment amount may be adjusted.

MSA:
Follow general provisions.

In addition, if the client receives SSI and SSA does not establish an overpayment or charge a partial overpayment, do not establish an MSA overpayment. For any month in which there is a total SSI overpayment, establish an MSA overpayment. If the total SSI overpayment is due to excess assets, the entire MSA benefit is an overpayment. If the total SSI overpayment is due to excess income, evaluate income to determine the amount of the MSA overpayment.

Do not allow the work expense deduction on income not reported timely. See 0018.06 (Work Expense Deductions).

For self-employment income overpayments that occurred after February 1, 2016, use the gross self-employment income calculation method for self-employment income not reported timely. See 0017.15.33.03 (Self-Employment, Convert Inc. To Monthly Amt).
When there is 1 month or more of total ineligibility and then 1 month or more of eligibility, presume that the unit reapplied on the 1st day they were eligible. Calculate the amount the unit should have received based on the 1st day of the month they were eligible.


GA:
Follow general provisions.

For self-employment income overpayments that occurred after February 1, 2016, use the gross self-employment income calculation method for self-employment income not reported timely. See 0017.15.33.03 (Self-Employment, Convert Inc. To Monthly Amt).
When there is 1 month or more of total ineligibility and then 1 month or more of eligibility, presume that the unit reapplied on the 1st day they were eligible. Calculate the amount the unit should have received based on the 1st day they were eligible. Prorate if necessary; see 0022.12.03 (Proration).


HSP:
No provisions.