Hotline 10/13: Mandatory Vendor Payments; Reasonable cause and temporary setback/emergency option

Q. 1. A family receiving TAFDC is renting an apartment and the household is behind in their rent. As I was
reviewing the BEACON pages concerning possible cash mismanagement of funds, the parents stated
that they never signed a lease with their landlord. Should mandatory vendor payments be established
in this case?
A. 1. No. Without a signed lease, there is an increased risk of eviction and homelessness. Also, the
likelihood of a landlord agreeing to an inspection is diminished, without a signed lease.

Q. 2. Since the mandatory vendor exception for the absence of a signed lease must be verified, how do I
document this type of situation?
A. 2. While primary documents are often the preferred method of verification, they are not always
obtainable. Remember that alternative forms of verification, such as a third party statement and/or
the client’s statement are also acceptable. For more information, refer to 106 CMR 702.311 and 106
CMR 702.340.
Reminder: Case managers must identify these alternative forms of documentation and
assist clients in obtaining required verifications. For more information, refer to
106 CMR 702.310.

Q. 3. In addition to the example in Q and A 2. above, are there other examples of when the verification of
an exception to mandatory vendor payments may be documented by a third party statement or the
client’s own statement?
A. 3. Yes. There are other situations such as clients who are “doubling up” with a host family, where
requiring an inspection or mandating vendor payments is not practical and could increase the risk of
eviction and homelessness. In situations where there are no other available forms of verification, a
client’s statement is acceptable. Additionally, remember that the client’s statement that domestic
violence is an issue is acceptable until a Domestic Violence/TAO Specialist can follow up to determine
and confirm any potential risk.

Q. 4. My client owes more than three months of utility payments, but when I spoke with her about the
particular circumstances leading up to the arrearage, she mentioned that the past due bills accrued
during her period of TAFDC closure and unemployment. Since she is currently receiving TAFDC and
working part time, does she still have reasonable cause for having a utility arrearage?
A. 4. Yes. The client does not need to have a current reasonable cause for case managers to use the
“temporary setback/emergency” option. As long as there was a temporary setback in the client’s past
that contributed to the arrearage, this reasonable cause option applies.