No intentional program violation but recoupment for over-issuance permitted.

Respondent did not disclose certain financial information in her food stamp recertification.  The Office of Inspector General (OIG) sought to disqualify her from Food Stamp Program participation on the basis of an intentional program violation.  Because there was insufficient evidence to establish her lapses were intentional under a clear and convincing standard, Judge Langston reversed the disqualification.  OIG was permitted to recoup the overpayment of $9,434.00.