Food Stamp Disaster Manual FSDM

III. DISASTER RESPONSE

PART III: DISASTER RESPONSE

Change #1-2009

October 1, 2009

III. DISASTER RESPONSE

State and county agencies should act as quickly as possible when responding to a disaster. The State depends on information provided by affected counties. Much of this information is received from county emergency management officials through their contact with state personnel. The Division of Social Services works closely with the State Emergency Response Team (SERT) to coordinate disaster activities throughout the state.

A. Sequence of Events

1. State Division of Social Services

• An Emergency Command Center (ECC) is established and manned by Division management and designated personnel. ECC staff answers questions from affected counties, secures and arranges for supplies, and assists counties as needed.

• Information regarding the ECC and who is in charge is provided to everyone involved at the State and county level. All directives are issued from this individual or their office.

• All staff report to the regular duty stations where they are briefed on special assignments due to the disaster.

• Reorganization and/or special training are conducted as required.

• Each section chief prepares and forwards a roster of personnel available to work regular and overtime hours to the ECC.

• State staff assigned to affected counties contact the local DSS contact person(s) regarding regular and disaster business.

2. Affected County Department of Social Services

• Contacts Emergency Management for information on damage assessment.

• Provides the State with damage assessment information which includes:

• The number of households potentially eligible for Disaster Food and Nutrition Services benefits considering the income of the residents in the affected area;

• The number of households in the affected area already receiving Food and Nutrition Services; and

• The type and degree of damage in the affected area.

The county director of social services/designee is involved in the decision making process as it relates to the method of handling the disaster, including the procedure selected for potential and ongoing Food and Nutrition Services recipients.

The scope of devastation in the disaster area and the estimated length of time it will take to return to normal activities determine the selection. Choices for handling the disaster include:

• Regular Food and Nutrition Services Program;

• Modified Food and Nutrition Services Program (MF NS);

• Disaster Food and Nutrition Services Program (DF NS); and

• Commodities.

Once a decision has been made regarding which disaster feeding program is appropriate for the disaster, the affected county also:

• Coordinates disaster response in his county. This includes assigning county staff to:

• Assist with the Food and Nutrition Services application process and/or issuance;

• Work in shelter operations, if applicable; and

• Work with other relief programs the agency is assigned to administer.

NOTE: Consideration should be given to DSS employees who are affected by the disaster. Designate members of management to take employee applications. County employee applications will be investigated as needed.

• Determines site(s) for disaster relief activities.

• Coordinates all activities with ECC.

3. State Division of Social Services Economic and Family Services Section

Once a disaster assessment has been made and a decision regarding which Food and Nutrition Services program is appropriate to operate, the Economic and Family Services Section takes the following actions:

• Provides the format for and collects data through local support staff pertaining to damage assessment. The section will obtain as much information as possible from the State Emergency Response Team (SERT);

• Forwards data and request for a Modified or Disaster Food and Nutrition Services Program to the U.S. Department of Agriculture, Food and Nutrition Service (USDA/FNS);

• Expands the current Help Desk to answer questions from county staff, clients, and the general public;

• Provides training on application process;

• Maintains daily contact with USDA/FNS;

• Provides daily reports to USDA/FNS;

• Secures and arranges for supplies;

• Uses the Food Stamp Information System (FSIS) to provide data to USDA;

• Maintains constant contact with affected counties; and

• Provides training to local agencies regarding the Food and Nutrition Services option chosen in response to the disaster.

B. Application for Operation of a Disaster Food and Nutrition Services Program

If all or part of the county suffers a disaster that meets the necessary requirements for applying for a Modified or Disaster Food and Nutrition Services Program, the Division of Social Services, in consultation with the affected counties, will submit an application to USDA/FNS.

Immediately following and no later than 24 hours after occurrence of a disaster, the designated State staff contacts the affected county’s contact person to assess damages and determine the county's interest in pursuing an application for the Disaster Food and Nutrition Services Program.

The designated State staff member immediately notifies the State Office of the county's intention to request a Disaster Food and Nutrition Services Program and assists in completing the required assessment.

Counties are responsible for providing information necessary to operate a Modified or Disaster Food and Nutrition Services Program. Counties must submit the information described in Part C. in order for the Division of Social Services to request a Disaster Food and Nutrition Services Program. The information must be provided as soon as possible and should be faxed to the Economic and Family Services Section at 919-334-1266 or 919-334-1265.

C. Required Application Information

Include the following items in the county request for a Disaster Food and Nutrition Services Program application:

Requirement	Specify
Dates	The date the disaster began
Area	Provide a detailed description of the geographic area or part of the county in need of assistance. Attach a detailed area map defining the affected area. Pinpoint areas where homes/businesses were damaged/destroyed in the disaster. Describe: • Total number of homes destroyed; • Total number of homes with major damage; and • Total number of homes with minor damage NOTE: The Economic and Family Services Section will secure as much of this information as possible from SERT.
Need	A determination, with substantiation, indicating households in the affected area are in need of disaster assistance because the ongoing Food and Nutrition Services Program cannot meet the food needs of these households. Counties will need to provide data concerning the demographics of the affected area. Include a description of the increased demand on the existing emergency food sources or the necessity of feeding sites. Provide estimates for: • How long households are expected to be adversely affected by lack of power, water, and heat; • How long families will be out of work due to the disaster; and • Time needed to repair homes to enable families to live in them.

Requirement	Specify
	NOTE: The Economic and Family Services Section will secure as much of this information as possible from SERT.
Substantiation	Provide supporting facts such as a statement from the Federal Emergency Management Agency (FEMA) representative, SERT, Red Cross, etc.
Commercial Food Distribution Outlets	The following is normally done by the USDA Regional Office staff: Provide a statement with substantiation that commercial channels of food distribution have been disrupted and restored. Disruption: • Severely hampered transportation to retail and wholesale outlets; • Closing of retail and wholesale food outlets; • Significantly hampered delivery of food products to food outlets; • Significantly shortened hours of operation for food outlets, restricting opportunities to purchase food; • Unusually heavy demand on food outlets so that normal opportunities to purchase food are significantly hampered; • Power failure that restricts operation of food outlets. Restoration: • Conditions or operations have improved to the extent that households have reasonable access to food outlets. NOTE: If the President has declared the area a major disaster, only provide substantiation that commercial channels of food distribution are available.
Estimate of Eligible Households	Provide an estimate of the number of potentially eligible households. Total this figure by on-going and new applicants.
Application Sites	Provide an assessment of available application/card issuance sites. Include proposed agreements with other agencies or locations to handle certification and issuance functions, if applicable.
Authorization Period	Provide a recommendation of how long it will take to accept and process applications from disaster victims. This request should be from three to ten calendar days.

Requirement	Specify
Benefit Period	Provide a recommendation of how long the benefit period should be, from one-half to one full month. Base this recommendation on the severity of the disaster, estimated time for affected households to resume work, estimated time to return to their homes, etc.
Current Food and Nutrition Services Recipients and Disaster Benefits	Currently participating households may also be eligible for Disaster Food and Nutrition Services (DFNS) benefits. Since Food and Nutrition Services benefits may be replaced for these households, DFNS allotments may be reduced by the regular monthly allotment. Indicate whether replacement Food and Nutrition Services benefits will be sufficient or if households need to be given additional benefits to bring the allotment up to the maximum benefit level. Determine if automatic replacements are needed or if replacements can be issued on a case-by-case basis. NOTE: The State will consider requesting automatic benefit replacement for ongoing Food and Nutrition Services households if the scope of the disaster warrants such.
Security Resources	Provide a description of resources available to: • Protect EBT cards; • Protect staff; and • Provide crowd control.
Fraud Control Measures	Provide information for: • Conducting checks for duplicate participation, • Preventing fraudulent applications; and • Dealing with suspected fraud.

D. FNS Response to an Application for Operation of a Disaster Food and Nutrition Services Program

1. Approval

If the county department's application and the State’s request for a Disaster Food and Nutrition Services Program is approved, FNS authorizes the use of disaster certification and issuance procedures. The approval specifies the geographic boundaries and

time frames covered for the Modified/Disaster Food and Nutrition Services Program. It also provides for specific policy to be used in taking and processing applications. Notice of approval may be made in person or by telephone, followed by written confirmation to the State Division of Social Services. Counties will be notified of the approval as soon as possible. Upon approval, Economic and Family Services finalizes an administrative letter to provide counties with the policy specific to the disaster.

2. Denial

If the application for a Disaster Food and Nutrition Services Program is denied, FNS notifies the State Division of Social Services. The Division may request that FNS review its decision if additional information is available to further substantiate the application.

Within 24 hours of receipt of the denial, the Economic and Family Services Section will verbally notify the county. Written confirmation follows the verbal notification.

E. Application and Issuance Sites

Refer to Section II., K., L., and M. for checklists and recommendations on application and issuance sites. The objective is to reduce wait, ensure safety of crowd/staff, and reduce the potential for fraud and theft.

F. Taking and Processing Disaster Food and Nutrition Services Applications

1. Filing an Application

The household must submit a completed application to a certification site in person or through a disaster representative. A disaster representative is an individual authorized to apply for and receive benefits on behalf of a household. A signed statement from the head of household or spouse is acceptable documentation when allowing a disaster representative to apply/receive benefits. Do not require the household to complete an authorized representative form.

NOTE: Use DSS-1432, Disaster Food and Nutrition Services application unless notified by the State Office to use another form. Counties will be notified via an administrative letter as to what form to use for applications.

The household must file the application during the period authorized by USDA to accept applications for Disaster Food and Nutrition Services.

The applicant must be interviewed and advised of his/her rights and responsibilities and of the length of the certification period for Disaster Food and Nutrition Services. Advise the household of the civil and criminal penalties for violations of the Food and Nutrition Services Program. This information is contained on the Disaster Food and Nutrition Services application.

Distribute the “Important Disaster Food and Nutrition Services Program” handout to provide applicants with general program facts. See DSS-8600. This may be modified to meet the needs of a particular disaster.

The interview is an official discussion of the household’s circumstances and should allow the interviewer to quickly assess a household’s situation. To ensure applicants are treated consistently, staff (including volunteers) should be trained on policies appropriate to their job. Interviews may be conducted by:

• Eligibility workers or other agency personnel;

• Volunteers; and

• Disaster relief agency personnel.

The interviewer may interview any of the following:

• Head of household;

• Spouse;

• Responsible household member; or

• Authorized disaster representative (DR)

The interviewer’s responsibilities include:

• Reviewing the application form;

• Answering all questions and ensuring the information is understood by all parties;

• Ensuring the application is signed and dated by the responsible member or DR and the interviewer;

• Informing the applicant of his rights and responsibilities, including his right to a fair hearing civil and criminal penalties, post-disaster review information and proper use of benefits; and

• Referring the applicant to other disaster-related programs as appropriate.

NOTE: Obtain verification of eligibility factors (e.g., identity, etc.) by examining and documenting any forms, cards, ID’s, etc. the applicant may have in his/her possession during the interview. It is recommended that copies of verification documents be made when possible.

Interviewing applicants and processing applications may be done by one individual or the duties may be separated. Keep in mind that only DSS employees are allowed to process applications.

Once the applicant has applied for Disaster Food and Nutrition Services benefits provide the applicant with the following:

• A disaster EBT card;

• A PIN mailer;

• EBT training materials;

• An explanation that disaster benefits are expunged from the EBT account after 12 months; and

• An explanation of what an individual can purchase with Food and Nutrition Services benefits. If the program allows for the purchase of prepared foods from grocery stores, inform the applicant. (This is decided at each disaster and will be addressed in the administrative letter.)

The Economic and Family Services Section recommends that your agency establish an EBT Card issuance site within your agency. Security should be present at this location, but the location should be easily accessible for applicants. Two or three DSS employees should staff the EBT Card issuance site. Their duties will include:

• EBT card issuance;

• PIN mailer issuance;

• Attaching the SUI and PAN number tear-off to the Disaster application;

• Obtaining client signatures on the EBT card manifest;

• Signing the manifest when issuing an EBT card to verify issuance; and

• Providing EBT training materials and information.

NOTE: The purpose of the new and improved EBT card delivery method is to expedite card delivery and receipt of benefits. This means that no applicant should be required to return to DSS to receive an EBT card. ALL applicants should receive an EBT Card on the day he/she applies for benefits.

2. Eligibility Requirements

Requirement	The Household…
Household Composition	• Consists of persons who are living and purchasing food together during the disaster period. Persons with whom the applicants are temporarily staying during the disaster period are considered a separate household.
Residency	• Must have been living in the disaster area at the time of the disaster; • May be eligible if temporarily living outside the disaster area but within the disaster area at the time of the disaster.
Purchase Food	Must plan on purchasing food during the benefit period
Adverse Affect	Must have experienced at least one of the following adverse affects: • Lost food or Food and Nutrition Services benefits; • Damage to or destruction of the household’s residence or self-employment business; • Disaster-related expenses not expected to be reimbursed during the benefit period (e.g., home or business repairs, temporary shelter expenses, evacuation expenses, home/business protection, disaster-related personal injury including funeral expenses); • Lost or inaccessible income, including reduction or termination of income or a delay in receipt of income for at least half of the benefit period; • Inaccessible liquid resources (e.g., the bank is closed due to the disaster)
Resource Test	Liquid resources (cash readily available and all funds in checking and savings accounts) must be less than $2000 ($3000 or less if someone in the household is age 60 or older). NOTE: The resource test may vary from one disaster to another.

Requirement	The Household…
Income Test	The total income received (or expected to be received) during the benefit period minus a deduction for disaster-related expenses shall not exceed the allowable income limit. NOTE: The income test may vary from one disaster to another.

In past disasters, questions have arisen on the following special cases:

• Shelter Residents – An applicant who is staying in a shelter, but not expected to remain there for the entire benefit period is eligible for benefits.

• Pending Applications – If an applicant has an application pending for the regular program, he is not an ongoing recipient for the purposes of determining eligibility or amount of disaster benefits.

The following are definitions and terms related to the income and resource test:

Term	Definition
Accessible Liquid Resources	Includes cash on hand and funds in checking and savings accounts. Do not include IRA accounts, 401K accounts, disaster insurance, or disaster assistance received or expected to be received during the benefit period or payments from federal, State or local government agencies, or disaster assistance organizations. NOTE: This can change with each disaster. The policy will be addressed in the administrative letter.
Deductible Disaster-Related Expenses	Expenses the household has paid or expects to pay during the disaster benefit period. If the household receives or anticipates receiving a reimbursement for these expenses during the disaster period, only the net expense is deductible.
Disaster Benefit Period	The period for which disaster benefits are issued (usually one month)
Term	Definition
Income	The combined gross earned and unearned income of household members
Maximum Disaster Benefit	An allotment equal to the maximum monthly allotment established for the regular Food and Nutrition Services Program for the appropriate household size.

3. Verification and Documentation

Verification rules are usually eased during a disaster to reduce administrative burdens and reflect the reality that households and eligibility workers will not have access to usual verification sources.

Some things must be verified, some things should be verified where possible, and others can be verified if questionable.

The following table outlines possible verification requirements. Keep in mind that policy is issued via an administrative letter and this chart may not be accurate in every disaster situation.

Applicant Info	Status	Verification Methods
Identity	Mandatory	• Photo ID • Two documents that verify ID and residency • A signed affidavit from a collateral contact attesting to the ID of the applicant
Residency	Where Possible	• Utility bills, tax bills, insurance policies or bills
Household Composition	If Questionable	• Collateral • After taking the application, the eligibility worker may ask applicant to orally list the names, ages, and birthdays of all household members
Income	Where Possible	• Check stubs • Client’s written and signed statement • Telephone call to employer
Loss or Inaccessibility of Liquid Resources	Where Possible	• Obtain a list of banks closed due to the disaster and compare with damage maps

Applicant Info	Status	Verification Methods
Food Loss	If Questionable	• Ensure residence is within the most seriously damaged areas • Check with the power company

4. Disposition of Pending Regular Food and Nutrition Services Applications

The decision concerning the disposition of regular Food and Nutrition Services applications pending when a disaster occurs will be made post-disaster. The policy instructions will be based on the size of the disaster and the timing of the disaster. Instructions will be issued via an administrative letter prior to implementation of a Disaster Food and Nutrition Services Program.

G. Determining Eligibility

The following may be considered in determining eligibility for Disaster Food and Nutrition Services benefits. The determination is not made until USDA approves a Disaster Food and Nutrition Services Program.

1. Student status;

2. Striker;

3. Work program participant;

4. Citizen or Alien; or

5. Someone disqualified under the regular Food Stamp Program.

H. Application Processing

Process all applications promptly to provide benefits the same day or the day following the date the application is filed. Benefits must be available no later than three days after the application is filed. It is important to key both approvals and denials as timely as possible.

NOTE: Eligibility/ineligibility must be documented on the Disaster Application form.

I. Benefit Amount

If the benefit period is a full month, issue eligible households the full benefit allotment for the household size. If the benefit period is one-half month, issue one-half the full benefit allotment for the household size, rounded up to the nearest dollar. The no-prorate indicator is automatically populated with an “N” for every disaster case; therefore, FSIS will not prorate disaster benefits.

J. Procedures for Preventing Duplicate Participation

A system to detect and prevent duplicate applications for the Disaster Food and Nutrition Services Program must be followed. The State will issue a daily cumulative report that identifies Food and Nutrition Services case dispositions. A receptionist may be assigned the responsibility of tracking this report and for maintaining a daily disaster application log.

Since every Disaster application will be assigned a new FSIS case number, it is important to search individuals thoroughly to ensure that duplicate participation will not occur.

K. Reporting Requirements

Disaster Food and Nutrition Services certification activities must be reported to FNS daily during the disaster authorization period. To accomplish this requirement, the county director of social services/designee must be available to provide information on the number of applications taken and the number of pending applications. The Division of Social Services consolidates the daily reports of each county department of social services and submits one report to FNS.

L. Economic and Family Services Help Desk

The Economic and Family Services Help Desk staff will be available to answer policy and procedure questions throughout the Disaster application period and during the recovery process. Contact the Help Desk with policy and procedure questions at (919) 334-1100.