Policy Recommendations for Strengthening Florida’s Safety Net In Response to COVID-19

Policy Recommendations for Strengthening Florida’s Safety Net In Response to COVID-19

The needs of families with low income must be a priority as the state decides what steps it will take to lessen the effects of COVID-19. On March 24th, 44 organizations signed on to a letter authored by Florida Policy Institute to Governor DeSantis urging him to adopt the below 47 policy changes to bolster the state's safety net. Download the letter at the bottom of this page.

Florida should adopt proactive COVID-19 policies to protect families who rely on safety net programs to avoid hunger, stay well, and make ends meet, such as the Supplemental Nutrition Assistance Program (SNAP), Medicaid, Temporary Assistance for Needy Families (TANF), Reemployment Assistance (RA), and the Special Nutrition Program for Women, Infants, and Children (WIC).

DCF-Administered Safety Net Programs

  • Develop a plan to serve Floridians confined to their homes who are unable to use a computer. DCF announced on March 18, 2020, that it was closing public access to brick-and-mortar storefronts due to coronavirus. Because 10 percent of people apply for safety net benefits in person, DCF recommends that those Floridians use drop-boxes at the Department’s storefront locations to turn in their applications. However, all seniors and persons with significant medical conditions, many of whom do not have internet access or a computer, have been advised to stay home. While DCF may be allowing phone interviews, we are unaware that people can apply by phone. If phone interviews are an option, the public should be advised on how to apply by phone.  If not, we encourage DCF to begin to employ telephone applications or develop a focused plan to serve seniors and persons with disabilities who do not have access to computers or the internet during the pandemic.

Supplemental Nutrition Assistance Program 

Florida’s Supplemental Nutrition Assistance Program (SNAP) provides families with low income with assistance to put food on the table.

  • Use phone interviews. Federal law gives DCF flexibility to substitute phone interviews for face-to-face interviews for all SNAP applicants. We encourage DCF, who already uses telephone interviews for many applicants, to substitute phone interviews across the board for households able and willing to be interviewed by phone. We also suggest that interviews be temporarily waived for families without adequate cell phone data.
  • Extend certification periods to the maximum extent possible and ease or delay verification of eligibility factors not required by law to be verified. Many families in Florida who are eligible for SNAP lose their benefits due to red tape, particularly at recertification, even though they cannot make ends meet. Because it is more important than ever that struggling families be able to establish eligibility and continue to receive assistance for as long as they are in need, we suggest that DCF not only extend certification periods but also ease or delay verification requirements during the pandemic.  
  • Suspend work requirements. Currently, Florida operates a mandatory work program for SNAP recipients who are considered to be Able Bodied Adults Without Dependents (ABAWDs). Under that program, SNAP recipients who are not exempt must participate in work activities or lose their assistance as a sanction. Further, ABAWDs who voluntarily quit employment or reduce hours of employment without good cause also face reduction or termination of their assistance. Until social distancing guidelines are relaxed and employers are able to stay open for normal business hours, we encourage DCF to take steps to suspend SNAP work and voluntary quit requirements  so that families can continue to participate in SNAP uninterrupted and without risk to the health of themselves, members of their households, or those in their communities. No sanctions for failure to meet SNAP E&T or work requirements should be imposed during the pandemic.
  • Place a moratorium on time limits. Florida currently imposes SNAP time limits state-wide for all ABAWDs. Under these time limits, ABAWDs cannot receive SNAP for more than three months in a 36-month period unless they work or are in a work activity for an average of 80 hours per month. We ask that DCF institute a moratorium on time limits during the pandemic.  ABAWDs, many of whom face enormous barriers to employment in normal circumstances, will encounter even greater barriers during the COVID-19 emergency due to social distancing and the inevitable economic downturn from this public health crisis.
  • Consider ways to ensure that college students can establish eligibility during the pandemic. Ordinarily, students who are enrolled in college or other institutions of higher education at least half time are not eligible for SNAP. Because college closures impact the ability of many students to access food, DCF should think about ways to extend eligibility to students who have been unable to qualify in the past.
  • Reinforce good cause exemptions. For individuals unable to meet SNAP work or voluntary quit requirements due to COVID-19,  we urge the State of Florida to reinforce its good cause policies for coronavirus circumstances beyond the participant’s control, and provide a directive to staff about the importance of screening for good cause. 
  • Implement pilot programs for ordering groceries online. USDA allows states, including Alabama,  to operate a pilot program for SNAP recipients to purchase groceries online using their EBT card. To minimize social interaction during the pandemic, we urge the State of Florida to develop such a program.
  • Expand good cause for COVID-19-related noncooperation with child support. The SNAP program requires that applicants cooperate with Florida’s child support enforcement unit (CSEU) as a condition of receiving food assistance unless good cause exists. The State of Florida should expand the definition of good cause to specify that noncooperation due to the impact of coronavirus constitutes good cause. If cooperation would require personal interaction, we urge the state to explore a moratorium on such activities in order to comply with federal social distancing guidelines as well as to protect families, staff, and the communities in which they live from spreading coronavirus.
  • Automatically supplement the SNAP allotments of participating families. To respond to the profound economic impact of COVID-19 on low-income families, we urge DCF to automatically supplement SNAP allotments up to the maximum for families of the household’s size. We request ask that this supplement be in addition to the allotment that the household already receives.
  • Broaden expedited service eligibility. Families impacted by COVID-19, especially those losing jobs or experiencing significant cut in work hours, may not necessarily meet current expedited service criteria but still be in desperate need of help putting food on the table. We urge DCF to broaden expedited service criteria during the pandemic to meet the emergency food needs of affected families.
  • Determine financial eligibility based on expected income.  Because so many Floridians have been informed that they will lose jobs or have their hours at work reduced, we urge DCF to determine eligibility based on their expected income.
  • Implement a Disaster SNAP (D-SNAP) program as soon as permissible under federal law. Although we urge DCF to institute a D-SNAP program when possible, we encourage the Department to ensure that families are screened for regular SNAP.
  • Issue SNAP for school-aged children who would otherwise receive free or reduced-price school meals. Given the urgent need of families losing income during the pandemic, we urge the state to set benefits for each child at a level that is more than the value of meals at the free rate, assume that all school-age children in households receiving SNAP benefits also receive free school meals, and provide this issuance in addition to any other supplement that current recipients receive.
  • Temporarily allow purchases of hot foods. After disasters, USDA often waives the prohibition on using SNAP benefits to purchase prepared hot foods. In light of  food shortages on grocery store shelves in Florida, we ask that DCF obtain such a waiver from USDA for this pandemic.


Temporary Assistance for Needy Families (TANF)

The Temporary Assistance for Needy Families (TANF) program provides temporary cash assistance to families with very low income, many of whom are facing an unexpected crisis such as loss of a job, divorce, death of a breadwinner, or health crisis.

  • Increase TANF benefit levels. Even before having to buy additional disinfectants, medical supplies, and non-perishable goods, many families participating in TANF struggle each month to meet all of their basic needs. The Florida Legislature should revisit TANF benefit levels through the lens of disaster recovery. Until lawmakers raise TANF benefits, thousands of Floridians will be unable to take adequate precautions against the spread of coronavirus, or in the wake of any other disaster.
  • Create special coronavirus programs. The State of Florida should create COVID-19-specific programs for relief.  Florida has about $16 million in unspent TANF funds as of 2019. With bars and restaurants shutting or cutting hours, rank-and-file hospitality workers need innovative relief based on their unique circumstances. In newly created programs, Florida has the flexibility to waive asset tests and impose broad income guidelines, such as serving families with income under 200 percent of the federal poverty line.
  • Suspend mandatory work requirements. The TANF program requires that most able-bodied recipients participate in work activities or face sanction (loss of benefits). As with our recommendations for suspension of SNAP E&T, we suggest that DCF suspend mandatory TANF work requirements, at least until social distancing guidelines are relaxed and employers are able to stay open during normal business hours. This will allow families to continue to participate in TANF without interruption and without risking the health of their families or others in their communities.
  • Use phone interviews. We encourage DCF, who already uses telephone interviews for many TANF applicants, to substitute phone interviews across the board for households able and willing to be interviewed by phone. We also suggest that interviews be temporarily waived for families without adequate cell phone data.
  • Suspend all requirements that require in-person interaction. The TANF program imposes many requirements that may entail in-person interaction with staff of state agencies (e.g., child support cooperation).  Until Florida develops the capacity to offer telephone or video certification appointments, we urge the state to impose a moratorium on such activities in order to comply with federal social distancing guidelines as well as to protect families, staff, and the communities in which they live from spreading coronavirus.
  • Expand good cause for COVID-19-related noncooperation with child support. The TANF program requires that caregivers cooperate with child support enforcement as a condition of receiving assistance unless good cause exists.  The State of Florida should expand the definition of good cause to specify that noncooperation due to the impact of coronavirus constitutes good cause.
  • Impose a moratorium on Learnfare. In Florida, parents must attend a school conference each semester in order to continue to get assistance. In light of school closures, the state should issue guidance explicitly halting Learnfare requirements during the pandemic.
  • Harness the existing transitional assistance program for the pandemic. Florida’s TANF program provides one-time, short-term assistance for applicants in specified situations who do not need ongoing assistance but have an unexpected emergency that requires immediate assistance. DCF should issue guidance explaining ways in which its existing transitional assistance programs can be used in coronavirus-related circumstances to assist families in need.
  • Place a moratorium on work sanctions. No sanctions for failure to meet TANF work requirements should be imposed during the pandemic under a blanket good cause exemption.
  • Determine financial eligibility based on expected income.  Because so many Floridians have been informed that they will lose jobs or have their hours at work reduced, we urge DCF to determine eligibility based on their expected income.
  • Increase time limits. Ordinarily, adults in Florida can receive TANF assistance for no more than 48 cumulative months, unless they meet the criteria for an exemption due to barriers and limited employment prospects. This is more stringent than federal law, which allows up to 60 months of assistance. We ask that lawmakers increase the number of months that participants impacted by COVID-19 can receive assistance and urge DCF to redefine criteria to consider COVID-19 barriers.
  • Extend review periods and ease or delay verification of eligibility factors not required by law to be verified.  Currently, DCF requires that families receiving TANF be reviewed at frequent intervals in order to continue to receive assistance. Many families in Florida who are eligible for TANF lose their benefits during these reviews due to red tape even though they are no better off. Because it is more important than ever that struggling families be able to establish eligibility and continue to receive assistance for as long as they are in need, we suggest that DCF extend review periods and also ease or delay verification requirements during the pandemic. 

Reemployment Assistance

Reemployment Assistance (RA) (also referred to as Unemployment Compensation) provides temporary benefits to Floridians who lose their job through no fault of their own.  As businesses shut down or reduce hours, RA will be an important part of the safety net to help workers, families, and communities respond to job loss due to COVID-19. 

  • Address Florida’s low RA recipiency rate. Florida’s RA recipiency rate (percentage of total unemployed receiving benefits) is consistently one of the worst in the country. This signals a system that, in the best of times, is inadequate to take care of workers who lose jobs through no fault of their own. We believe that one of the state’s most important priorities should be to immediately explore ways to make RA accessible to out-of-work Floridians so that, as the pandemic plays out, systems will be in place to accommodate an influx of workers out of jobs.
  • Waive work-search requirements. Florida requires out-of-work applicants for RA to document that they have conducted five work search contacts per week. We urge Florida to waive work search requirements, especially considering the impact of the pandemic on businesses and their ability to operate at capacity. Further, while many qualifying work searches can take place online, not every claimant has access to technology to complete work search remotely. As a result, many claimants will be unable to conduct work search without violating federal guidelines limiting social interaction and putting themselves, their families, and their communities at risk.
  • Waive the waiting period.  In Florida, claimants for RA have a one-week wait period that they must serve out before getting benefits. This requirement should be waived during the COVID-19 pandemic so that assistance for Floridians who have lost jobs due to the pandemic get the immediate assistance they need to keep their families afloat.
  • Expand the definition of “good cause” to include quitting. In Florida’s RA program, persons who quit jobs without good cause are ineligible to collect RA. However, the pandemic will impact the ability of Floridians to work for a variety of reasons that may not strictly be considered good cause. We applaud DEO’s COVID-19 policy defining good cause to include being quarantined by a medical professional or a government agency as well as caring for an immediate family member who is diagnosed with COVID-19. However, the State of Florida should expand the definition of good cause to include those self-quarantined under federal guidelines, quitting work that violates health and safety standards, and quitting work to care for a quarantined family member.

Special Nutrition Program for Women, Infants, and Children (WIC)

WIC is a federally funded program that provides healthy food and one-on-one nutrition counseling not only to pregnant, breastfeeding, and non-breastfeeding postpartum mothers with low income, but also to infants and children under the age of five at nutritional risk.

  • Maximize ability to waive physical presence requirements. Under federal rules, WIC applicants must physically report to the WIC office when they are first certified and at each certification. To accommodate families, states have discretion to adopt certain exemptions, such as for some children of working parents. While Florida has opted to adopt most of the permissible exemptions, it does not exempt children of working parents. During the pandemic, Florida should exercise its discretion to limit physical presence requirements to the maximum extent allowed by law.
  • Maximize flexibility in food choice and minimum stocking requirements. Florida’s WIC program should allow shoppers in stores with reduced stock to make substitutions for missing items.
  • Obtain waiver to allow WIC participants to spend their next month’s benefits early. Allowing participants early access to benefits is a safeguard against the real possibility of grocery stores running out of food or a WIC participant being unexpectedly quarantined
  • Seek a waiver to extend certification periods. Until WIC develops the capacity to offer telephone or video certification appointments, we urge Florida to keep issuing benefits under extended certification periods. 

Medicaid/KidCare

Medicaid and KidCare provide vital health care coverage to more than 4 million Floridians. We appreciate the steps the state has already taken through its section 1135 waiver to give providers more flexibility to meet the COVID-19 testing and treatment needs of their patients. However, there are numerous additional flexibilities provided under federal law that are essential for extending coverage to more people, making it easier for people to enroll and stay enrolled and get the care they need. Moreover, since Florida's 1135 waiver was granted, Congress has passed the Families First Coronavirus Response Act, which will require immediate state policy changes, such as the cessation of Medicaid terminations. 

  • Ensure access to COVID-19 evaluation, testing and treatment for all. This should be provided at no cost, regardless of insurance or immigration status. This is key to protecting the overall public health of our state and country.
  • Expand Medicaid coverage for adults with income up to 138% of poverty. More than 800,000 low income uninsured Floridians are currently excluded from Medicaid coverage. In addition, thousands of Floridians with low income are losing jobs and employer-sponsored health coverage at the very moment when access to health care is critical for themselves and their families.
  • Immediately enroll applicants who are eligible based on the information they provide on their applications.  Needed verification can be obtained after enrollment.  
  • Maximize the use of presumptive eligibility by allowing additional "qualified entities" such as social services agencies to temporarily enroll clients when they seek assistance.
  • Verify income through electronic data sources whenever possible. If electronic data aren't reasonably compatible with the information the applicant provides, accept a reasonable explanation (e.g., the employer closed due to the public health emergency).
  • For income that cannot be verified electronically, accept an applicant's information on a case-by-case basis.  Obtaining or submitting documents will be difficult for applicants due to employer and other office closures.
  • Suspend Medicaid/KidCare eligibility terminations and renewals for all beneficiaries until the threat of the epidemic has passed. During this time, the State of Florida should minimize the burden on beneficiaries and keep people covered.
  • Suspend periodic eligibility checks. This should include quarterly wage checks. The state should also avoid acting on mid-year checks, to reduce extra paperwork for beneficiaries and state workers and prevent potential termination of coverage for people who remain eligible. Many people who had jobs may no longer have them or may be working reduced hours.
  • Restore retroactive Medicaid eligibility for seniors, persons with disabilities and non-pregnant adults. Without this coverage people suddenly becoming gravely ill due to COVID-19 face enormous medical debt and possible bankruptcy. The increased federal match under the federal disaster package will more than cover the cost.  
  • Temporarily increase provider payments for Medicaid patients in long-term care. For patients in nursing facilities and other institutional settings or for those receiving home and community- based care increased payments can help to provide enhanced care, including additional nursing assistance to deal with intensive patient needs.
  • Ensure that if/when a vaccine becomes available, coverage is required for all eligible children under Medicaid’s early and periodic screening, diagnosis, and treatment benefit, as well as for all Medicaid-enrolled adults.

The following organizations support the recommendations listed above:

Florida Policy Institute

Alianza for Progress

Allegany Franciscan Ministries

Alliance for Public Schools

Broward for Progress

Catalyst Miami

Catholic Charities of Central Florida

Central Florida Jobs with Justice

Community Justice Project

Dream Defenders

Faith in Public Life

Farmworker's Self-Help

Florida Center for Fiscal and Economic Policy

Florida Children's Council

Florida Health Justice Project

Florida Impact to End Hunger

Florida Institute for Health Innovation

Florida Parent Teacher Association (PTA)

Florida Voices for Health

Florida’s Children First

Hubbell Farms

Huddle in the Harbor, Inc.

Ju’Coby Pittman-White Harvest Farm at Clara White

League of Women Voters of Florida

LULAC Florida

Lupus and Allied Diseases Association, Inc.

Miami Workers Center

Miami-Dade County Commissioner, District 8

Miami Freedom Project

National Association of Social Workers - Florida

National Lawyers Guild, South Florida Chapter

New Florida Majority

North Florida Educational Development Corporation

Opportunity For All Floridians

Organize Florida

ParentsTogether

Pinellas Juvenile Welfare Board

Progress Florida Education Institute

QLatinx

Second Harvest Food Bank of Central Florida

Slow Food First Coast

SPLC Action Fund

The Common Ground Project

Treasure Coast Food Bank

United Way of Broward County

USF Florida Covering Kids and Families



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