CEEWB: The Future of SNAP

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reporting requirements of every minutia can create a churning effect to the detriment of clients living on the economic margins as well as increased state administrative workloads. Change reporting remains important for program accuracy and integrity but allowing some further flexibility would benefit both clients and administrators. The plethora of deductions for expense items should be reduced; certification policy would thereby be simplified and better aligned with other programs, and the current complex and error-prone reporting, processing, and deadline requirements would be simplified. We note again that SNAP does currently benefit from several important options that help simplify the program to a degree, chief among them is simplified reporting, and this and similar current options must be retained and enhanced. Interviews and certification procedures – The SNAP statute does not address the subject of interviews, but regulations written in a different era continue to require them – and generally for states to conduct them face-to-face with agency personnel. This stands in contrast to other large programs like Medicaid, whose requirements are far more flexible and make far greater use of electronic or phone contacts. With respect to both program alignment and to SNAP alone, states should be allowed the option to utilize face to face interviews for SNAP only as necessary to make accurate determinations, maintain program integrity, and assess broader customer concerns and needs. When deemed necessary, interviews should be allowed to take various forms, again dictated by state concerns for accuracy, integrity, or customer needs. Face-to-face interviews may best meet those needs if capacity and budgets allow, but contacts for certifying applicant households can also be accomplished effectively by telephone or by electronic communication such as web- based interviews. Findings from the “No Interview Demonstration Pilots” conducted by both Utah and Oregon are worth reviewing as they were successful and did not seemingly result in inaccurate verification or higher error rates. States should be given broad

and general latitude, without the need for waivers, to define their interview process in varying ways according to household situations. Extended certification periods – Certification periods should be lengthened at state option and made a permanent part of SNAP without the need for ongoing waivers. Certification periods, where states choose to extend them for households whose circumstances are not likely to change, could be as long as several years for certain stable categories such as those consisting entirely of elderly or disabled members receiving Supplemental Security Income (SSI) or Medicare Savings Program benefits. States would benefit from fewer required certification actions, while these groups of households would benefit from longer periods of uninterrupted access. Longer certification periods for these stable income families would be focused only on the least error- prone households as outlined above and would create more program efficiency. Households with fluctuating incomes that are not predictable or stable would continue to have reasonable certification periods that allow for adjusting benefits up or down accordingly with income changes. Reduced barriers for SSI recipients and other stable groups – The current Combined Application Project (CAP) option allows greatly streamlined SNAP eligibility and participation by SSI recipients. Linkages between the Social Security Administration and state IT systems establish the eligible base of SSI recipients. Currently, the individual benefit levels are established according to a table of standardized values. Administration is greatly simplified and access is improved for this population – that is, in states where it does exist since each state must be individually evaluated for CAP participation. The option has been in place since the late 1990s, yet still, only 15 states have adopted it so far largely due to the cost-neutrality provision. CAP should be a regular program option without its current requirement for a separate determination of cost neutrality and should be promptly expanded to other groups whose household composition and income are likely to be stable.