CEEWB: The Future of SNAP

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recipients to as high as $10K would make better sense and allow for families and individuals to accrue modest savings. 10. Expand the Summer EBT program option that increases SNAP benefits for households with children during the non-school year calendar in areas where geographic obstacles and lack of sponsors would not make a physically located summer food program for children practical. 11. Allow states at their option to add transitional benefits of one-three months when wages result in a full loss of benefits to avoid the cliff effect of rapidly losing all SNAP benefits. 12. Return state administrative costs for SNAP, which have eroded over the years to their original 50/50 percent split. 13. Allow states to establish longer certification periods for stable income non-error prone households part of law and regulations rather than subject to renewal through the waiver process. 14. Make Combined Application Procedures (CAP) a regular component of the program and eliminate the cost neutrality provision so that SSI recipients can automatically receive SNAP benefits. 15. Clear language and direction about expectations of A-87 availability and access for all agencies, particularly for the SNAP program, should be released by FNS, CMS & ACF, to further advance the development of complex systems that both improve functionality and decrease program administrative costs across all programs. 16. Provide written clarification in the guidance of how the major changes in program design at § 7 CFR 272.15 are intended to be operationalized, particularly around the 120-day requirement to notify the agency about any changes. Clarification is desired around the extent of notification on phases of system implementation versus initial indication of testing for system projects.

Additionally, we recommend FNS to develop a template capturing the performance measures demonstrating success being sought out by states. 17. States should be allowed at their option to hire non-government employees, under the supervision of the state, to perform program eligibility or any other administrative function under SNAP. States are experiencing increases in workloads, but unable to add permanent FTE's to meet the demands of these increases. 18. Simplify and align QC rules consistently across FNS regions, restore the previous $50 error threshold, simplify QC sampling requirements and allow states to substitute phone or online interviews for currently required QC face to face interviews. 19. Allow states, at their own option, to develop agreements with federally recognized tribal governments to allow those entities to complete eligibility determinations for SNAP where the tribe is also running a Tribal TANF program.  In these cases, states would maintain oversight, quality control and training functions for tribal government staff.