Minnesota Minnesota

Combined Manual

Combined Manual


SANCTIONS FOR FAILURE TO COMPLY - CASH

ISSUE DATE: 03/2026

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 drug felony sanctions, see 0011.27.03 (Drug Felons). For information on post 60-month sanctions, see 0028.30.04 (Post 60-Month Empl. Services 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 impose a sanction when the participant comes into compliance BEFORE the effective date of the sanction for failure to:

Attend financial orientation.

 

OR

Comply with child support requirements. See 0012.24 (Child Support 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 job 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 job 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 job 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 provided the grant reduction has been in effect for a minimum of 1 month. The job counselor will send you a Status Update Form to tell you to remove the sanction. If the grant was vendor paid as a result of the sanction, continue vendor payment for 6 months after the month in which the participant returns to compliance.


Do not impose a sanction when a participant complies with MFIP-ES requirements ON OR BEFORE 10 days prior to the effective date of the sanction.

Participants may cure an MFIP-ES sanction by complying with the MFIP-ES requirements as outlined below:

FOR THE 1ST OCCURRENCE OF NON-COMPLIANCE
The sanction can be cured ON OR BEFORE 10 days prior to the EFFECTIVE date of the sanction. When a sanction has been imposed, it must be in effect for a minimum of 1 month and you may remove it in the month after the month the participant comes into compliance.

FOR THE 2ND OCCURRENCE OF NON-COMPLIANCE
The sanction can be cured ON OR BEFORE 10 days prior to the effective date of the sanction. When the participant comes into compliance AFTER the 10-day cure time period has passed, remove the sanction the month after the month the participant comes into compliance.

3RD THROUGH 6TH OCCURRENCES OF NON-COMPLIANCE
When the 30% sanction has been imposed for 1 month, ALL subsequent consecutive months in which a 10-day notice is not required may be cured up to the day prior to the effective date of the sanction. When subsequent months are not consecutive, a notice of adverse action is sent out and the sanction must be cured ON OR BEFORE 10 days prior to the EFFECTIVE date of the sanction.

7TH OCCURRENCE OF NON-COMPLIANCE (100% SANCTION - MONTH OF CLOSURE)
The sanction can be cured ON OR BEFORE 10 days 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).


When a case has been closed, and you then reinstate or reopen it, apply the following procedures:

CLOSED FOR LESS THAN A CALENDAR MONTH
If the sanction was already in effect prior to closing, the sanction remains in place.

If the notice of adverse action was sent to the client prior to the case closing, impose the sanction immediately.

If the notice was not sent prior to closing, send the notice when the case opens. Impose the sanction for the 1st of the month for which you are able to give 10 days notice.

CLOSED FOR MORE THAN A CALENDAR MONTH DUE TO NON COMPLIANCE WITH EMPLOYMENT SERVICES WITH A NEW APPLICATION AND PROSPECTIVE BUDGETING
The client must demonstrate compliance with ES requirements for up to 1 month or be granted good cause before reopening the case. Reopen the case from the date of compliance or begin date of good cause. If you approve a new application and the client again fails to cooperate, send the appropriate notices.

CLOSED FOR MORE THAN A CALENDAR MONTH FOR REASONS OTHER THAN NON COOPERATION WITH EMPLOYMENT SERVICES WITH A NEW APPLICATION AND PROSPECTIVE BUDGETING
The client has a new opportunity to comply with Employment Services. Do not reduce benefits based on previous ES sanctions. If you approve the new application and the client again fails to cooperate, send the appropriate notices.

For information on type and length of MFIP sanctions depending on case circumstances, 1st or subsequent occurrence of non compliance, and dual sanctions, see 0028.30.03 (Pre 60-Month Type/Length of ES Sanctions).


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.imageimageimage

PREVIOUS REVISIONS

DateNotes
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.

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