Sanctions

Overview

The ministry promotes personal responsibility for all applicants and recipients.  Non-compliance with the requirements of the Employment and Assistance (EA) or Employment and Assistance for Persons with Disabilities (EAPWD) Acts and Regulations may result in sanctions which include rate reductions or ineligibility for assistance.

Policy

Effective: August 1, 2015

Periods of ineligibility or rate reductions may be applied for any of the following reasons:
 

  • failure to provide information or verification [see Policy – Table: Information or Verification Related Sanctions]
  • inaccurate or incomplete reporting – submitting the Monthly Report (HR0081) Form but providing inaccurate or incomplete information relating to income or assets or failing to report accurately a change in circumstance that affects the eligibility of the family unit and results in an overpayment of assistance.  [see Table: Sanctions for inaccurate or incomplete reporting]
  • failure to meet employment-related obligations or to comply with an Employment Plan [see Policy – Table: Employment Related Sanctions]
  • not accepting income or assets or disposing of assets [see Policy – Table: Income or Asset Related Sanction]

When applying sanctions, staff are to use discretion in situations where there are legitimate mitigating circumstances or the non-compliance is a one-time occurrence.

When determining whether a sanction for Employment Plan (EP) non-compliance can be applied, staff should be aware that the EP is a legal document and must be signed by the client and placed on the client case.  A sanction should not be applied in situations where the EP has not been signed.

Sanctions are not to be applied in situations where non-compliance is beyond the client’s control.  For example, sanctions would not be appropriate for a client with a severe mental health condition who is not able to complete an activity in the Employment Plan.

Inaccurate or Incomplete Reporting

As an incentive to encourage accurate and complete reporting of income, assets and changes in circumstances, a sanction may be imposed on those clients who do not report accurately, if an overpayment occurs as a result of the inaccurate reporting.  If, after calculating an overpayment and notifying the client of the overpayment, a determination is made that the overpayment is due to the client providing inaccurate or incomplete information on their Monthly Report (HR0081) the consequence will be a $25 reduction of assistance for a prescribed period of time (See Table below).

Case Example:

If a client has incurred a sanction for inaccurate or incomplete reporting and is serving a 3 month reduction, however, the case is closed after serving only 2 months, the sanction “clock” continues to run while the client is off assistance and will continue to count for the purpose of the sanction.  If the case re-opens in the future and the sanction duration is complete, the sanction is considered served.   

When assessing whether to apply a sanction for inaccurate or incomplete reporting, staff are to use discretion, based on the legislative criterion of whether the client took the necessary steps to ensure accuracy or completeness.  In exercising this discretion, the following should be considered:
 

  • Are there legitimate mitigating circumstances that resulted in the client not having accurate or complete information on the reporting date; e.g., delay in receiving bank statement?
  • Does the client’s mental health prevent accurate and complete reporting?
  • Are the circumstances such that imposing the sanction does not serve the intended purpose of encouraging accurate reporting in the future; for example, where the inaccurate or incomplete reporting occurred in the distant past and the client has, since then, provided accurate and complete reports?

There is no discretionary authority to alter either the duration or the amount of the sanction.

At all times, staff will ensure the principles of administrative fairness are followed when meeting the client to review both the overpayment and when explaining the consequence that will result if that overpayment was due to inaccurate or incomplete reporting.  Clients will receive letters in advance of the meeting: one with regard to the overpayment and the other with regard to the sanction. 

The client is provided the opportunity to review the overpayment during a meeting.  If during that meeting the overpayment amount is determined by the EAW, and the client receives notification of an overpayment, the staff may also advise the client of the sanction to be applied.  It is important to note that the client has the right to request the reconsideration of both the overpayment amount and the decision to impose a sanction based on inaccurate or incomplete reporting.  It is recommended that the client submit both reconsideration requests at the same time due to the fact the two issues are related.  It may be in the client’s better interest to do so, but the decision is ultimately up to the client.

Table: Information or Verification Related Sanctions

Types of Sanctions

Consequence

Period of Time

Failure to provide requested information

The Minister may impose ineligibility on the family unit

Until compliant

Failure to provide information, dependent youth

The Minister may impose a $100 per month reduction on the family unit

Until compliant

Failure to complete or submit monthly report (HR0081), or to report changes in circumstances

The family unit is ineligible

Until compliant

 

Failure to attend eligibility audit or complete HR0080R

The family unit is ineligible

Until compliant

Table: Sanctions for inaccurate or incomplete reporting

Types Sanctions

Consequence

Period of Time

Failure to accurately or completely report (on the Monthly Report HR0081) any income, assets or circumstances that affect the eligibility of the family unit that result in an overpayment.

The amount of assistance the family unit is eligible to receive is reduced by $25.

Note: The overpayment recovery amount is deducted from the reduced (sanctioned) amount.

1st occurrence – 3 months

2nd occurrence – 6 months

3rd occurrence – 12 months

Each subsequent occurrence – 12 months

Table: Employment Related Sanctions

Types Sanctions Consequence Period of Time

Failure to comply with an Employment Plan [for more information, see Related Links – Employment Plan]

The family unit is ineligible (when there are no mitigating circumstances for the non-compliance)

The family unit’s case is closed

If a person or family reapply for assistance at a later date, they must satisfy all application requirements including the work search.

Failure to accept suitable employment or

Voluntarily left employment without just cause  or

Dismissed for just cause

(See Just Cause)

Singles and couples are ineligible

Family units with dependent children are subject to a $100 per month rate reduction for each applicant or recipient that is subject to the sanction

Two calendar months from whichever is later: the date of application for assistance or the date the default occurred.

Failure to demonstrate reasonable work search

Singles and couples are ineligible

Family units with dependent children are subject to a $100 per month rate reduction for each applicant or recipient that is subject to the sanction

One calendar month from whichever is later: the date when the default occurred, or the date when the Minister becomes satisfied the recipient is demonstrating reasonable efforts to search for employment

Just Cause

Consequences are only related to failure to accept suitable employment, voluntarily leaving employment without just cause, or being dismissed for just cause.  In assessing whether there is just cause for persons who quit or refused employment or who were dismissed, the following factors can be considered in determining when there may be “just cause”:
 

  • having a physical or mental condition which precludes maintaining employment
  • sexual or other harassment
  • discrimination
  • dangerous working conditions
  • following a spouse to new employment
  • leaving an abusive or violent domestic situation
  • having to care for a child or other immediate family member who has a mental or physical condition which requires the person to care for them
  • reasonable assurance of another job

Table: Income or Asset Related Sanction

Types of Sanctions

Consequence

Period of Time

Failure to pursue or accept income or assets or other means of support that are still available

The minister may impose ineligibility

Until income, assets or other means of support are accepted or pursued

If income, assets or other means of support are no longer available

The minister may impose

  • ineligibility for singles or couples without dependent children
  • $100 per month rate reduction for one parent families
  • $200 per month rate reduction for two-parent families

One calendar month for each $2,000 of the value of the foregone income, asset or other means of support

[See Period of Time]

Disposal of property for inadequate consideration (less than the actual or market value)

The minister may impose

  • ineligibility for singles or couples without dependent children
  • $100 per month rate reduction for one parent families
  • $200 per month rate reduction for two-parent families

One calendar month for each $2,000 of the value of the foregone income, asset or other means of support [See Period of Time]

Disposal of property to reduce assets (intentionally disposed of to reduce assets)

The family unit is ineligible

Two calendar months for each $2,000 of the foregone asset, or other means of support [See Period of Time]

Period of Time

One calendar month for each $2,000 of the value of the foregone income, asset, or other means of support.  For example:
 

  • sanctions are not applied to amounts under $2,000
  • $2,000 to $3,999 has a one calendar month sanction
  • $4,000 to $5,999 has a two month sanction

Sanctions for Employment-Related Obligations:

Clients with employment-related obligations are required to fulfill both the requirements set out in Sections 9 (EP) and Section 13 (Employment-related obligations) of the EA Act (Section 9 and 12 of the EAPWD Act).

A client can be non-compliant due to their failure to meet employment-related obligations (e.g., fails to demonstrate reasonable work search) OR non-compliant due to their failure to comply with the conditions of their EP (e.g., must attend school in the evening).  In each case, the corresponding sanction would apply.

If the client does not comply with the conditions of the EP (e.g., must attend school in the evening) AND does not fulfill the employment-related obligations (e.g., fails to demonstrate reasonable work search), then the sanctions for both Sections 9 and 13 apply concurrently.

Note: There may be legitimate situations in which the conditions of the EP prevent the client from meeting the conditions of Section 13 of the EA Act (e.g., the client is attending an eligible course leaving very little time to search for employment).  The wording of Section 9 "subject to the conditions of an EP" means that Section 9 takes precedence when the two are in conflict.  Thus, if meeting the conditions of an EP causes non-compliance with Section 13, sanctions should not be applied.  Refer to EP Standards, Section D.1a and D.2a.

If the client is declared ineligible under both Section 9 and Section 13 and appeals the decision, two separate Request for Reconsideration forms (HR100's) are required.

[For more information on Employment Plan Sanctions, see Related Links – Employment Plan – Additional Resources – Employment Plan Standards.  For more information on differentiating between Employment Plan and Employment Obligations Sanctions, see Additional Resources – Guidelines for differentiating between Section 9 and Section 13].

Effective: September 3, 2009

Supervisory approval is required for all sanctions that could lead to ineligibility.  Before such sanctions may be applied, the Supervisor must review the ineligibility decision and indicate their support for the sanction decision on the case via an approval activity.  

Effective: August 1, 2015

Applicable sanctions that apply to the same period of time are deemed to have occurred concurrently. 

If assistance is subject to a reduction for more than one reason or on account of more than one person, the reduction of assistance is cumulative and must be reduced for each reason and for each person.

Note: In the case of sanctions for inaccurate or incomplete reporting, staff will exercise discretion when applying additional sanctions. 

Case Example 1: Two sanctions of ineligibility applicable to a couple without dependent children

If one person is ineligible for a two-month period due to voluntarily leaving work without just cause and the spouse is also ineligible for the same two-month period for the same or some other reason, the family unit is ineligible for those 2 months.

Case Example 2: Two reduction sanctions applicable for the same period

The recipient in a family unit has a $100 reduction applied for two months, and the recipient's spouse has two $100 reductions applied for the same two months.  The family unit's assistance is therefore reduced by $300/month for the two months ($100 + $200).

Case Example 3: Sanction of ineligibility and reduction

If a family unit is ineligible for assistance for a period of time and is also subject to rate reductions for the same time period, the ineligibility is imposed and the rate reduction is deemed to have occurred for that period.

The family unit has a six-month reduction for period of January to June and three-month ineligibility for period January to March is applied:

Month

Consequence

January

1st month of ineligibility

February

2nd month of ineligibility

March

3rd month of ineligibility

April

Rate reduction

May

Rate reduction

June

Rate reduction

July

Full Assistance (sanction period ends)

Procedures

Effective: September 30, 2006

Sanction amounts are not prorated within any month and are applied for an entire assistance month.

Case Example: A single parent with one child over the age of three fails to accept suitable employment on August 15.

The sanction start date is September 1 and will be applied for two consecutive assistance months (September and October) assuming the single parent received assistance for August.  Therefore, the September and October assistance cheques will each be reduced by $100.

Sanctions are based on the individual's situation at any given time and may change from ineligibility to a rate reduction, or vice versa, if the family unit composition changes.

Case Example: A single person ineligible for assistance for two months due to not accepting suitable employment, becomes part of a family unit consisting of two adults with dependent children.  A rate reduction of $100 per month is now applied to the family unit (one adult has been sanctioned and the other has no sanctions).

If the person with the sanction for failure to accept suitable employment leaves the family unit prior to the sanction end date, that person will continue to be ineligible for assistance and the remaining family unit will become eligible for full assistance.

Sanctions for inaccurate or incomplete reporting are based on whether the client provided inaccurate or incomplete information that resulted in an overpayment of assistance.  The amount of the reduction is $25 per month for 3 months on the first occurrence, 6 months on the second occurrence, and 12 months on the third and each additional occurrence.

There is discretionary authority to waive the sanction where there are legitimate mitigating  circumstances which demonstrate the client took the necessary steps to ensure the information they provided was accurate and complete.  There is no discretionary authority to alter either the term or the amount of the sanction.

Effective: September 3, 2009

Supervisory approval is required for all sanctions that could lead to ineligibility.  Before such sanctions may be applied, the Supervisor must review the ineligibility decision, and add an activity to indicate they have reviewed and support the ineligibility decision.  

Effective: September 4, 2008

Failure to Provide Requested Information or Attend Eligibility Audit

The recipient's cheque should be turned off until the recipient is compliant.  The recipient is not eligible for any assistance (including supplements) until compliant.

Failure to Submit a Monthly Report (HR0081)

If a recipient fails to submit the Monthly Report (HR0081) the cheque will automatically be set as "No Stub" and the recipient must complete the HR0081 before receiving further assistance.  (Recipients with the Persons with Disabilities designation are only required to submit a completed HR0081 if there is a change in income, assets, or circumstances.)

If a recipient with the Persons with Disabilities designation was issued an overpayment of assistance and they did not accurately or completely report the income, asset or circumstance that led to the overpayment, staff may impose a sanction for inaccurate or incomplete reporting.  However, staff must first review the case to ensure correct application of the earnings exemption.  [For more information on earnings exemptions and calculating overpayments, see Related Links – Recoveries – Overpayments – Additional Resources, Guidelines Applying Earnings Exemptions.]

Providing inaccurate or incomplete information, see below – Applying Sanctions for Inaccurate or Incomplete Reporting. 

Effective: October 9, 2008

For advising the client of a sanction for failure to meet work‑related requirements, send the Sanctions – Employment Related Obligations – Non-Compliance
Letter, HR3230 [see Forms and Letters].

Applying Sanctions

Sanctions are applied from the date non-compliance is determined and continue until the sanction time has elapsed. 

Example: If a client reapplies for assistance one week after they are determined ineligible under Section 13, they continue to be ineligible until the one month sanction period has elapsed.  However, if the client reapplied for assistance three months after they were determined ineligible, then the sanction for Section 13 would not apply as the one month sanction period had already elapsed.

Employment and Assistance Workers (EAWs) record sanctions and applicable start and end dates on the case.

EAWs cannot apply sanctions for fraud convictions, or court judgements.   

Note: EAWs may apply sanctions to clients who provide inaccurate or incomplete information on their stub (this includes recipients with the Persons with Disabilities designation who fail to report changes).

Notes describing the details surrounding the sanction are made on the case.

Sanctions and sanction resolutions can be removed or updated until the end of the business day on which they were entered.

Note: If a client or family unit is ineligible for assistance for a prescribed period of time due to a sanction, the case should be closed on the 1st of the applicable month using close reason “Sanction Disqualification” unless a reconsideration or appeal is pending. (Create an activity with a due date for after the appeal period).

Effective: September 4, 2008

Note: This includes recipients with the Persons with Disabilities (PWD) designation who fail to report changes.

If a recipient submits the Monthly Report (HR0081) and does not provide, accurately or completely, information regarding income, assets or changes and the inaccurate or incomplete reporting results in an overpayment, a sanction may be imposed as an incentive to encourage clients to report their income and assets.

Prior to imposing a sanction for inaccurate or incomplete reporting, staff will determine the amount of overpayment and contact the client.

[For policy and procedure on calculating an overpayment, see Related Links - Recoveries – Overpayments.]

Staff may exercise discretion when imposing a sanction and, if necessary, request Supervisor approval to waive a sanction via an activity on the case. 

[For decision-making guidelines on when it is appropriate to waive this sanction, see procedures, step 5 below.]

When determining whether a sanction for inaccurate or incomplete reporting of income or assets should be applied to a recipient of assistance, staff and clients should be aware that the Monthly Report (HR0081) for the calendar month in which the change occurred is a legal document and must be signed and completed by the client.

Staff must have a Monthly Report (HR0081) that corresponds to the overpayment as proof of inaccurate or incomplete reporting.

A sanction should not be applied in situations where the HR0081 is not available or has not been signed.  Clients with Persons with Disabilities designation are required to submit a completed HR0081 if there is a change in income, assets, or circumstances.  The sanction for inaccurate or incomplete reporting may be imposed if they have not reported accurately or completely (that is if they did not submit a Monthly Report HR0081).

Steps: Applying Sanctions for Inaccurate or Incomplete Reporting:
 

  1. Determine the amount of the overpayment and prepare the overpayment notification.
     
  2. Ensure the following:
    1. An overpayment has been calculated and is supported by evidence.
    2. A copy of the HR0081 is available and indicates inaccurate or incomplete information was provided.  (Example: the HR0081 shows $0.00 employment income under the income description column of the “stub” and a copy of the client’s pay-stub shows $450.00 of net income received.)  Or, in the case of a PWD client, there is no HR0081 but evidence supports the income, asset or change in circumstance.  (Remember to review the eligibility for earnings exemptions for PWD clients and whether they were required to report the changes.)
    3. Client has had an opportunity to review the overpayment and respond by providing information to challenge the existence of the overpayment (i.e., mitigating circumstances) or the amount.
    4. Client failed to take the necessary steps to ensure the accuracy and completeness of the HR0081.  (Example: they did not check their bank statement for a direct deposit of employment income and therefore failed to report.)  When meeting the client, provide an opportunity for the client to provide information if they did take steps to ensure the information was accurate and complete.  If the client demonstrates legitimate mitigating circumstances interfered with their ability to ensure accurate reporting, and they can demonstrate that they took steps to ensure accurate reporting, staff will waive the sanction in these cases.
  3. Determine whether the client has incurred an overpayment as a result of providing inaccurate or incomplete information.  Determine if this is the first, second or third (etc.) sanction.
     
  4. Meet the client to review the overpayment and provide them with the overpayment notification form.
     
  5. Staff may determine it is appropriate to waive a sanction in cases where there are legitimate mitigating circumstances which demonstrate the client took steps to ensure accurate reporting.  Such cases must be reviewed and approved by the supervisor and staff should note the reasons and complete the approval activity.

The following decision-making steps/questions may guide you in applying discretion.
 

  1. Discretionary authority is provided in the Act.
  2. Is the decision based on fact, i.e., not personal opinion or the rationalisation by the client? For example, is the sanction waived because the client’s situation (need for money) seems to warrant the act of non-reporting so the client could afford new things and get out of debt before closing their case?
  3. Is the person to be sanctioned present and capable of responding?
  4. Did the client fail to take necessary steps to ensure the accuracy and completeness of the information?
  5. Is the intent of the sanction being served by imposing it? (For example, is imposing the sanction going to provide incentive/reminder to accurately and completely report all income, assets and changes in circumstances in the future?)
  6. Is this decision consistent with the ministry’s values?

Example:  Waiving a sanction:  A mentally challenged client inaccurately reports their employment income because they misunderstood the correct reporting procedures.  They saved all their pay-stubs and reported all of it at one time (like filing income tax).  When the client and their community support worker meet with staff to review the overpayment, it becomes clear that the client, due to mental limitations, needs assistance in completing their stub regularly.  The decision may be to waive the sanction.  It also would not serve as an incentive for future reporting or prevent future overpayments.  The staff reviews correct reporting procedures and advises the client and their support worker that accurate reporting is important on a monthly basis to avoid future overpayments.

Example:  Applying a sanction:  A client inaccurately reports their employment income in 2004.  A review in 2006 indicates there was an overpayment of assistance for ten months.  The case was closed from January 2005 to November 2005.  When the client meets with staff to review the overpayment, the client explains the reason they did not report all their income was because they needed to buy extra clothing and to pay back loans to friends.  They currently have a broken leg and state a reduction of $25 right now would be really hard.  The staff advises the client that a sanction in the form of a $25 reduction in assistance for three months must be served and reviews correct reporting procedures.  The staff also advises the client that if in the future they provide inaccurate or incomplete information, the second occurrence will result in a $25 reduction for six months.

Example:  Applying a sanction:  A client states they don’t care about being sanctioned because it will not change their behaviour in the future.  They will continue non-reporting of income.  The staff advises the client that a sanction will be imposed and reviews correct reporting procedures and reminds the client of their reporting obligations.

Example:  Waiving a sanction:  A client incurs an overpayment because they submitted a monthly report that indicated only partial earnings when in fact their financial statements indicate two electronic funds transfers (paycheques) in the same month.  The client brings the bank statements to the meeting and explains that they received their bank statements after the 6th of the month and did not realise the pay had been deposited.  The staff may decide to waive this sanction because the client demonstrates legitimate mitigating circumstances that prevented them from knowing about the income prior to submitting the Monthly Report.
 

  1. Determine the appropriate sanction period.  Follow the principles of administrative fairness and advise the client of the sanction, the reasons, the duration, the amount of reduction in addition to the overpayment recapture amount, and when the sanction will begin.

Update the case accordingly.

Apply the sanction for non-reporting.  The sanction is in effect and the $25 reduction will begin on the next assistance cheque from the date the sanction is added.  The sanction is served for three consecutive months (the system will automatically monitor the duration).

Note: In cases where both adults in a family unit failed to report, a sanction may be imposed on both and the reduction will be $50.  The sanction is applied to each adult person who incurred the overpayment.  If the dependant adult leaves the case, their sanction will follow them because it is attached to the Contact.
 

  1. If the decision is to waive the sanction, supervisor approval must be noted on the case via an approval activity.
  2. Update the case by adding the sanction.  Then, resolve the sanction using resolve reason “New Information” and make notes on your decision to waive the sanction.

This will alert staff in future that a sanction has been waived and identify the date.  Staff will be able to review the notes and reasons for waiving the sanction by searching the case and activities.
 

  1. Make notes on the details of the sanction and ensure copies of all relevant documents pertaining to providing inaccurate or incomplete information are scanned and profiled.
     
  2. Advise the client of their right to request reconsideration.  It is recommended that if the client wishes to request reconsideration of both the overpayment and the sanction they be encouraged to submit both requests at the same time.  This will ensure the related information is reviewed and, if necessary, addressed in a timely manner.

Examples:
 

  1. The amount of the overpayment is overturned so a sanction is no longer valid.
  2. The overpayment amount is not overturned but information exists to support the client took action to report the income.  The information as to the client’s actions was not noted by the ministry, so the sanction is overturned.

Note: This is a unique situation because if the decision is to overturn the overpayment decision, the client will have already been serving the sanction.  Staff should remember to issue a reconsideration and/or appeal supplement to cover the sanction amount in these cases.  That way, if the sanction decision is overturned, the staff will resolve the sanction by updating the case using the applicable resolve reason (successful reconsideration or appeal) and advise the client accordingly.

Case Example: Case is closed prior to the end of the sanction period

If a client has incurred a sanction for inaccurate or incomplete reporting and is serving a 3 month reduction, however, the case is closed after serving only 2 months, the sanction “clock” continues to run while the client is off assistance and will continue to count for the purpose of the sanction.  If the case re-opens in the future and the sanction duration is complete, the sanction is considered served.

Removing or Updating Sanctions

EAWs can remove a sanction by entering the appropriate resolve reason on the case.

A sanction can be updated by changing the Sanction End Date (only if the end date is not system generated).  Exceptions:  a sanction for inaccurate or incomplete reporting is resolved only when the sanction duration period is completed, the client is successful at reconsideration or appeal, a decision to waive the sanction is made, new information presented reverses the determination that an overpayment was issued, or a recording error is made (e.g., staff update the wrong case by mistake).

A resolve reason is not required when the end date (set by either the system or the EAW) has been reached.

Case Example: An EAW sanctions a client for being dismissed with just cause on October 15.  The client has received October assistance.

The EAW enters the sanction and a start date of 2003 NOV.  The system will automatically set the end date for 2003 DEC and resolve the sanction when the two-month sanction has ended.

Effective: August 1, 2015

For details regarding the consequences of a conviction under the Criminal Code, the Employment and Assistance Act or the Employment and Assistance for Persons with Disabilities Act, please see related links – Recoveries.

Effective: August 5, 2008

Example: If a person has the 2-month sanction imposed for quitting or being fired and then subsequently obtains a full-time job, the two-month sanction is independent of whatever else takes place and it would stand regardless of whether or not the person has an open case, until the 2 months lapsed.  For example, if a person has a 2-month sanction imposed for quitting a job and then leaves income assistance for employment, the 2-month sanction would have lapsed if the person reapplies six months later.

Use of Section 13Example: A person who applies for income assistance 40 days after quitting or being fired, is found ineligible and a 2-month sanction is placed on the case.  The person re-applies after 20 more days have elapsed from the date they quit or got fired from their job.

The sanction would remain in effect for the 2-month period following an application for assistance.  Regulations stipulate the duration of the consequence begins from the later of the date of the event or date of application for assistance.

Authorities and Responsibilities

 

Responsibilities

Effective: August 1, 2015

EAWs who received training on administrative fairness and sanctions, Investigative Officers, and Ministry Investigators are responsible for:
 

  • Imposing sanctions for providing inaccurate or incomplete information resulting in an overpayment of assistance

Supervisors are authorized to waive discretionary sanctions that are levied for providing inaccurate or incomplete information resulting in an overpayment.

Supervisors are responsible for reviewing and approving all sanction decisions that could result in ineligibility.