Although the details have not yet been announced, the Department of Children and Families (DCF) is pulling back some of the important safety net measures it put in place in March – measures that have ensured families who lost jobs during the pandemic can make ends meet.
DCF says that — effective July 2020 — it is reinstating work requirements for Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) participants, as well as SNAP, TANF and Medicaid recertifications. just as Floridians scramble to feed their family, pay rent, and get medical care until they get back on their feet.
Nothing about reviving work requirements or recertifications during the height of the pandemic makes sense. The reason that Florida suspended work requirements and extended recertifications in the first place was to ensure that families have the support and resources they need during the pandemic until the Sunshine State flattens the COVID-19 curve and can safely reopen.
Coronavirus has only gotten worse since the date that Florida put these special measures into place. The number of people infected with COVID-19 in Florida has grown from 563 to over 432,000, more than the population of the city of Tampa. Hospitalizations for COVID-19 have increased by over a hundredfold. Unemployment is at an all-time high and claims for Reemployment Assistance are on the rise. Deaths are climbing. Food insecurity among families with low income, particularly people of color and households with young children, is expected to increase in every county in the state. One-fifth of Floridians are behind on rent. Applications for SNAP, TANF, and Medicaid have risen by 54 percent due largely to COVID-19.
Although everyone may be tired of hunkering down, now is not the time for Florida leaders to reverse course. Continuing to extend recertification and suspend work requirements are effective strategies to mitigate against coronavirus infection and support families whose lives are particularly at risk from the disruption caused by COVID-19.
Ordinarily, SNAP and TANF participants must work, or participate in a work or training program, to qualify for assistance unless they are exempt for reasons such as having a disability. If the head of household fails to comply without “good cause,” the family’s entire assistance is terminated as a work sanction.
Many — but not all — TANF and SNAP participants are subject to work requirements. For those who are required to work, the mandates are significant. In the TANF program, work requirements demand that parents either work or participate anywhere from 20 up to 55 hours a week depending on their household composition. For SNAP, participants must work or participate in a “work activity” for at least 80 hours each month.
Reinstating work requirements puts SNAP and TANF participants, and their families, in the bull’s eye for contracting and spreading COVID-19 infection. This is because, in many cases, people who are required to work as a condition of receiving SNAP or TANF must interact with a variety of strangers in order to comply. Because they cannot control the behavior of potential employers and others who refuse to adhere to Centers for Disease Control and Prevention (CDC) guidelines, some are even forced to break social distancing rules just to maintain eligibility for SNAP or TANF.
Even if DCF decides to permit online activities to fulfill work requirements, one-third of families with very low income in Florida do not have internet access and will be unable to work or participate in this manner. Subjecting those Floridians to work requirements means that they will be forced to engage face to face with potential employers and others in the community to apply for jobs, be interviewed, and eventually, go back to work if they find employment. For families relying on TANF, it forces parents who cannot work or participate from home to send young children back to brick-and mortar schools instead of having them engage in distance learning — or risk loss of benefits for noncooperation, even if they have a family member whose age or health puts them at risk of becoming critically ill from exposure to an asymptomatic child.
Just complying with work requirements is an uphill battle that participants often lose due to red tape under the best of circumstances. A 2018 study by the Florida Legislature’s Office of Program Policy Analysis & Government Accountability suggests that many families in Florida are terminated from SNAP and TANF assistance when significant barriers, such as transportation problems that should confer good cause, keep them from being able to follow through with work requirements. These barriers are only exacerbated by the pandemic, where, for example, occupancy on public transportation in many communities is limited in order to adhere to social distancing guidelines.
Work requirements also perpetuate a harmful myth about the work ethic of families with low income.
The truth is that most Floridians receiving SNAP have strong work histories. Even though they may have challenges finding a job, most adults without disabilities who received SNAP in Florida before COVID-19 already worked, or would work in the near future, regardless of work requirements. For them, SNAP has always been a critical support — one that helps about 1.27 million Floridians with low income who already work get by each month.
Sadly, though, it is unlikely that enough jobs exist for the SNAP and TANF participants who will be up against a work requirement during the COVID-19 recession.
Even when jobs were more plentiful, SNAP and TANF participants who were required to participate in work faced a more difficult time finding full-time jobs than other Floridians. While some are ready and able to work and possess the skills that potential employers are looking for to fill job openings, many SNAP and TANF participants have education levels that make it difficult for them to find work, even in the best of times. For example, only about 7 percent of adult TANF recipients in Florida have more than a high school education, and 32 percent did not finish the 10th grade. Although both SNAP and TANF’s Employment and Training (E&T) programs have education and training components, few participants in either TANF or SNAP are provided skills training or education activities that lead to real jobs.
With rampant unemployment, many safety net participants are even less likely to find jobs now. Most of the jobs that SNAP participants in Florida hold, such as food service and grounds maintenance, are in the service industry, which is one of the industries losing the most jobs in the state and having one of the highest claims for Reemployment Assistance during the pandemic. Work requirements particularly disadvantage Floridians of color, who already have an unemployment rate roughly 53 percent higher than the state average.
Recertification is a process in which SNAP, TANF, and Medicaid participants periodically renew their eligibility to continue to receive benefits. Ordinarily, families in the SNAP and TANF programs must be recertified every 6 or 12 months while Medicaid participants must be recertified every 12 months. Recertification requires families to be vigilant for notices arriving in the mail so they can quickly respond with requested paperwork and other documentation.
When recertifications are not completed on time, benefits are terminated and otherwise-eligible families face food insecurity, inability to pay their rent or mortgage, and periods of uninsurance and delays in getting needed medical care.
For most of the pandemic, DCF has extended recertifications by 6 months. This means, for example, that if a family was due to recertify in June 2020, DCF pushed back their recertification to December 2020, which ensured that the family continued to get needed help without bureaucratic red tape or interruption in assistance. Extending recertification periods during COVID-19 does not mean that families who become ineligible are able to keep getting assistance anyway. Although they may not have to recertify right away, participants in safety net programs still have a duty to report certain changes, like an increase in income or change in their household composition, depending on the program.
Reinstating recertification is especially risky for Floridians who are unable to submit their recertification applications online because they do not have internet service at home or are not technologically savvy, particularly those who cannot get outside help from a library or community partner because their age or health condition requires them to stay at home during the pandemic. While DCF’s call center may be able to help some participants recertify by phone in limited cases, call centers are not equipped to handle mass recertifications by phone, even for families that have the minutes on their phones to spare.
Not only will reinstating recertification harm families, it will also cause significantly more work for the state, which has to process each recertification application. The state is already struggling with an insufficient number of staff and the challenges of broader implementation of remote work. Adding recertifications to DCF’s to-do list defies logic.
Reinstatement of recertification requirements for Medicaid is particularly puzzling considering the “continuous coverage” requirements under the Families First Coronavirus Response Act. Those requirements prohibit terminations of Medicaid coverage during the federal public health emergency to prevent unnecessary health insurance disruptions. The only exceptions are for individuals who voluntarily terminate their coverage and those who no longer reside in the state or die. Especially with widespread job and income loss due to the recession, most of those protected by these provisions are likely to be eligible for coverage. Continuous coverage keeps those families from losing eligibility because of outdated data or difficulty obtaining and producing documentation during the public health crisis.
As businesses continue to shut down or scale back and families exhaust savings on everyday necessities, safety net programs are more in demand than ever in Florida. Instead of diverting staff time to processing recertifications or forcing families into a dangerous hunt for non-existent jobs, Florida officials should be doing everything possible to enhance the state’s capacity to support the growing number of SNAP, TANF, and Medicaid applications and enrollment.
Anything less is unsound and unsafe.
American Rescue Plan Act Changes. The American Rescue Plan Act of 2021 extended PEUC and PUA benefits through the week ending September 6, 2021. It also increased the maximum duration of PEUC benefits ($300 a week) to 53 weeks and the maximum duration of PUA to 79 weeks. Although PEUC and PUA did not end until September 6, 2021, Florida withdrew from the Federal Pandemic Unemployment Compensation Program (FPUC) effective June 26, 2021. FPUC provided persons who were out of work due to COVID-19 with an additional $300 a week in unemployment insurance.
Reemployment Assistance weeks reverted to 12 effective January 1, 2022. DEO determines the maximum number of weeks available to RA claimants based on a statutory formula that looks at the average unemployment rate for the most recent third calendar year quarter (i.e., July, August, and September). Based on the downturn in unemployment, the maximum number of weeks for RA reverted to 12 effective January 1, 2022.
RA work-search and work registration requirements reinstated on May 30, 2021. Persons filing an application for RA benefits beginning March 15, 2020, are not required to complete work registration in Employ Florida through May 29, 2021. In addition, work search requirements for individuals requesting benefits for the weeks beginning March 15, 2020, were also reinstated on May 30, 2021.
Mobile app deployed. DEO has deployed a mobile app for RA applications.
DEO announces extended benefits. DEO announced implementation of Extended Benefits (EB).
Resources and guidance. For a list of resources and guidance from the United States Department of Labor on unemployment insurance and COVID-19, go here.
For DEO’s “Reemployment Assistance Frequently Asked Questions and Additional Resources,” updated 12/30/2020, go here.
For DEO’s latest claims data, go here.
DCF opens offices. DCF has reopened its brick-and-mortar storefronts, which were previously closed due to coronavirus.
DCF adds call center numbers. DCF has added a call center number for Monday through Friday, from 7 a.m. to 6 p.m. Call center numbers now include 850-300-4323, 866-762-2237, or TTY 1-800-955-8771.
Certification periods extended by 6 months only through August 2020. Certification periods for cash, food and medical assistance were extended by 6 months for individuals and families scheduled to recertify in April through August 2020. FNS’ approval of the SNAP extension for August is here. However, effective September 1, 2020, SNAP, TANF and Medicaid recertifications have been reinstated, although DCF says that no one will lose Medicaid due to recertification.
DCF allows phone interviews. Phone interviews are now being used for TANF cash and SNAP food assistance.
Mandatory work requirements suspended only through May 2021. Under a directive from Governor DeSantis to waive work requirements for safety net programs, DCF waived work requirements for individuals participating in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) through May 2021. To do this, DCF explains that it partnered with the Department of Economic Opportunity to apply “good cause” statewide for TANF and SNAP recipients who would otherwise be subject to participation in mandatory work requirements as a condition of receiving those benefits. Through May 2021, persons who were sanctioned in the past due to work requirements will be able to reapply and participate in SNAP or TANF again.
Work requirements were reinstated effective June 1, 2021.
Emergency allotments (EA) ended. DCF automatically supplemented SNAP allotments of current recipients up to the maximum for a household’s size for July 2021. However, EA was discontinued beginning August 1, 2021.
The SNAP benefits increase by 15 percent ended in October 2021. Floridians who participate in SNAP to put food on the table will receive a temporary 15 percent supplement to SNAP under COVID relief passed by Congress and extended by the American Rescue Plan Act through September 2021.
FNS permanently increases SNAP through revamp of the Thrifty Food Plan. Effective October 2021, FNS has mandated a permanent increase to SNAP through a revamp of the Thrifty Food Plan. DCF says that the increase amounts to about 6% for Floridians.
Time limits suspended. SNAP time limits are suspended during the COVID-19 public health emergency. No one in Florida should be barred from SNAP due to time limits, even if they exhausted their time limit in the past.
Florida granted waiver to allow families to purchase groceries online. DCF has been granted a federal waiver to permit the State of Florida to launch a pilot project statewide effective April 21, 2020, that allows families to purchase groceries online with their Electronic Benefit Transfer (EBT) card instead of going into stores.
No Medicaid terminations from March 2020 through the end of the federal public health emergency. The national public health emergency has existed since January 27, 2020 and has been renewed by the Secretary of the U.S. Department of Health & Human Services in 90-day increments since that time. The most recent renewal is effective January 16, 2022.
Redetermination/recertification times are reinstated. As of October 1, 2020 AHCA's website is alerting recipients that the Department of Children and Families is now mailing letters for case reviews to check if a household is still eligible for Medicaid and/or Medically Needy. AHCA is urging people receiving these letters to take steps now to re-apply. But note, Medicaid coverage will not end during the COVID-19 Public Health Emergency. In January 2021 DCF conducted one-year “automated renewals” for people whose sole income is social security and SSI and are enrolled in an SSI-related Medicaid program (e.g., MEDS/AD, Medically Needy and Medicare Savings Programs). People getting VA income were not included in the automated renewal.
Extended application time. Effective with applications filed in February 2020, the time for submitting documentation required to process an application is extended for 120 days from the date of the application and eligibility will still be effective the first day of the month the application was received. Effective July 1, 2021, this policy has been rescinded. Medicaid applications submitted on or after July 1, 2021 may be denied on the 30th day after application or the day after verification information is due. Applications filed prior to July 1, will be allowed 120 days to provide requested verification to establish Medicaid eligibility.
Exclusion of additional unemployment payments in determining eligibility. The $600/week of additional unemployment insurance payments under the CARES Act will not be counted as income in determining Medicaid eligibility. (However, these payments will be counted as income in determining marketplace subsidy calculations.)
Coverage of Medicaid services during the state of emergency
COVID-19 Vaccines for Medicaid Enrollees. In an executive order published March 16, 2021 Governor DeSantis revised the vaccine distribution plan, which applies to the general public including Medicaid enrollees, to lower the age requirement to 40 effective March 29, 2021 and then effective April 5, 2021 all Floridians are eligible to receive any COVID-19 vaccination approved by the Food and Drug Administration.
Medicaid enrollees eligible to receive the vaccine may visit myvaccine.fl.gov to find a location distributing the vaccine and to schedule an appointment.
On March 12, 2021, AHCA published instructions for Medicaid enrollees on how to obtain Medicaid transportation once they have scheduled an appointment for a vaccine. AHCA states: "Florida Medicaid will take you to get the COVID-19 vaccine at no cost. All you need to do is set up a time to get your vaccine. Next, let your Medicaid plan know you need a ride and they will take care of the rest. If you are not enrolled in a plan, call the Medicaid Helpline at 1-877-254-1055 to find out the name and phone number for a transportation service."
The state has also recently launched a new email system to help bring COVID-19 vaccines to homebound seniors. Seniors will be able to sign up to have the vaccine come to them by emailing a request to HomeboundVaccine@em.myflorida.com.
AHCA has posted Medicaid Alerts and FAQs providing more detail on Medicaid service changes in response to COVID-19. They address a wide range of topics including, but not limited to: telemedicine guidance for medical, behavioral health, and early intervention services providers; long-term care provider network flexibilities allowing more types of providers to deliver specified long term care services; and continuity of care for adult day care center enrollees during the time these centers are closed.
AHCA is loosening coverage restrictions for behavioral health services. Effective May 5, 2020, all prior authorization requirements for mental health or substance use disorder treatment are waived and service limitations (frequency and duration) are lifted. For behavioral analysis services, current authorizations will be extended through an "administrative approval process" which does not require providers to reassess beneficiaries currently getting services. Effective July 1, 2021 service limits will be reinstated for behavioral health services and effective July 15, 2021 Medicaid prior authorization requirements will be reinstated for behavioral health services.
Per a May 29, 2020 provider alert, during the state of emergency AHCA will be reimbursing providers for telemedicine well-child visits provided to children older than 24 months through age 20. Providers are directed to actively work to schedule follow-up in-person visits to administer immunizations and other physical components of the exam which cannot be accomplished through telemedicine.
Coverage of home and community-based waiver services (HCBS) - In response to the public emergency, Florida obtained approval from the federal government to make changes in HCBS waiver programs, including the Long Term Care and Developmental Disabilities programs. The changes are effective retroactively from January 27, 2020 to January 26, 2021. Details can be found here. They include, but are not limited to:
Note on COVID-19 testing, treatment, and vaccines for the uninsured. Florida has not opted to receive 100 percent federal Medicaid funding for COVID-19 testing of people without health insurance. Under the 2021 American Rescue Plan Act this option has been expanded to cover COVID-19 treatment and vaccines for the uninsured as well. Since the state has not taken up this option Floridians must look to an uneven patchwork of free testing, treatment, and vaccine resources scattered around the state. AHCA advises that uninsured people may receive free testing from their county health department or a federally qualified health center and that “many communities provide testing for free for individuals who do not have insurance. Please [click here] to find a test site in your area. Uninsured individuals should ask before the test whether testing is free of charge." There are no state agency instructions on where uninsured people can receive free treatment. However, more information on possible sources for free treatment is available here.
Residency proof no longer required at some vaccine sites, “paving the way for migrants.” - On April 29, 2021 Surgeon General Rivkees issued a new public health advisory specifying that COVID-19 vaccines are available to “a Florida resident” or someone “who is present in Florida for the purpose of providing goods or services for the benefits of residents and visitors of the State of Florida.” This new policy applies to all state-run and federally supported vaccination sites. It rescinds an advisory issued in January that had restricted vaccinations to people who could show proof of Florida residency
2021 unemployment compensation claimants can access free or reduced cost health insurance through the ACA marketplace. The Affordable Care Act (ACA) Marketplace was re-opened in February 2021 to give people who need health insurance a new “special enrollment" opportunity to get covered. The 2021 American Rescue Plan eliminated or vastly reduced premiums for many people with low or moderate incomes.
Starting July 1, 2021, people who received or have been approved for unemployment compensation for any week beginning in 2021 can access free or reduced cost comprehensive health insurance plans through the ACA marketplace. This benefit is available regardless of someone's current income. To get this benefit, people must enroll in the marketplace no later than August 15, 2021. For help with enrollment, contact Covering Florida at 877-813-9115.
School children in distance learning still eligible for free or reduced cost meals. Students in distance learning for 2020-21 can still receive school meals through the National School Lunch Program if they are eligible. The student or parent/guardian may pick up meals at the school but should contact their school for more information.
For a list of current child nutrition program waivers for Florida from USDA, go here.
Congress allows increased fruit and vegetable benefits. At present, WIC provides $9 for children and $11 for women monthly for fruits and vegetables. The American Rescue Plan Act makes funding available for a four-month increase in the benefit of up to $35 monthly, if a state chooses to do so.
DOH attains waiver allowing remote issuance: Department of Health (DOH) obtained a waiver of the requirement that participants pick up their EBT cards in person at recertification or during nutritional education appointments.
WIC participants allowed to substitute certain food. Under a waiver from USDA, WIC participants in Florida are allowed to substitute milk of any available fat content and whole wheat or whole grain bread in package sizes up to 24 oz. when 16 oz. packages are unavailable.
USDA waived physical presence requirements: Although the scope and logistics are unclear at this time, USDA has given DOH permission to waive the requirement that persons be physically present at each certification or recertification determination in order to determine eligibility under the program through May 31, 2020.
USDA extends certification periods through May 31, 2020, for some participants.
For a list of current WIC waivers for Florida from USDA, go here.
HHS provides guidance. HHS has issued guidance on the flexibilities in TANF to respond to COVID-19.