Do the IEVS requirements at section 1137 apply to food bank programs where the portion of the eligible population is estimated using a reasonable methodology?
A3: ACF has previously stated that the IEVS requirements apply to any applicant or recipient of a TANF-funded benefit, whether assistance or non-assistance, where income or citizenship and alienage is a condition of eligibility (please see Q&A’s at http://www.acf.hhs.gov/programs/ofa/polquest/ievsys.htm). As described in Answer 1, eligibility is not determined on an individual, case-by-case basis; therefore, verification of an individual’s income is not necessary for receipt of TANF-funded food bank benefits, i.e., while the program has an income standard, it is not applied individually. As described in Answer 2, States do not need to verify the qualified alien status of any recipient of food bank benefits since these benefits fall under the exception created by Attorney General Order No. 2049, 61 FR 45985 (1996). Therefore, the IEVS requirements do not apply to TANF-funded food bank programs that use a reasonable estimation methodology to determine the portion of recipients who meet i