e. Verifying Compliance Using a Combination of Activities

In accordance with section 1902(xx)(2)(E) of the Act, implemented at § 435.552(a)(5), an applicable individual may demonstrate compliance by completing a combination of work, community service, participation in a work program, or participation in an educational program. To verify compliance using a combination of activities, States must verify hours for each activity separately, as described in sections II.C.1. through II.C.3. and II.C.6. of this IFC, and then add the number of hours for each of the four activities to calculate the total number of qualifying community engagement hours for the month.

As noted in section II.C.6. of this IFC, States may have to calculate the number of hours an applicable individual who is enrolled less than half-time participated in an educational program by multiplying each credit hour by three to get the weekly total and then multiplying the weekly total by 4.33 for the monthly total. In addition, as discussed in section II.C.8. and II.I.6.a. of this IFC, when the monthly income is less than the applicable Federal minimum wage multiplied by 80 hours and the State does not have information regarding the number of hours worked. States may divide the verified monthly income by the Federal minimum wage to determine the number of work hours. For example, if the State verifies an individual has $380 in monthly income, the State may divide the monthly income by the current Federal minimum wage of $7.25 and credit the individual with having worked 52 hours for the month ($380 divided by $7.25). We also remind States that some individuals who meet the definition of a family caregiver will not qualify as a specified excluded individual under the family caregiver component of section 1902(xx)(9)(A)(ii)(III) of the Act, because they are not related to and do not live with the individual for whom they provide assistance, and they provide such assistance for fewer than 80 hours per month. States must ensure any hours of assistance provided by these applicable individuals are accounted for in the individual's monthly work hour total prior to combining those hours with all hours of other qualifying activities. See section II.I.6.a. of this IFC for more information about calculating work hours for family caregivers who do not qualify as specified excluded individuals.

After determining the number of hours an individual spent engaging in work, community service, a work program, and/or an educational program in a given month, the State must have procedures in place to aggregate those hours and must not request that the applicable individual provide documentation or other information when the sum of the hours of qualifying activities as reflected in reliable information available to the State is sufficient to verify the individual demonstrated community engagement for the relevant month. The State must also make sure that, when additional information is required for one or more categories of qualifying activity hours, the State considers the total number of hours across these activities, as reflected in the reliable information available to the State combined with the hours verified by documentation or other information provided by the applicable individual.

For example, an individual reports on their application that they worked and volunteered for 40 hours each in the prior month, for a total of 80 qualifying hours. The State verifies the individual worked for 40 hours in prior month using reliable information available to the State but needs more information to verify the community service hours. The State sends a request for information seeking documentation regarding the individual's participation in community service. In response, the individual submits documents that demonstrate the individual completed 42 hours of community service in the prior month. The State must combine the 40 hours of work that was verified using the reliable information available to the State with the 42 hours of community service reflected in the documentation for a total of 82 qualifying hours and determine the individual demonstrated community engagement in that month.