CEEWB: The Future of SNAP

Center for Employment and Economic Well-Being: The Future of SNAP – AModern and Responsive Program

MAY 2017

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Center for Employment and Economic Well-Being: The Future of SNAP – A Modern and Responsive Program

OVERVIEW AND GENERAL PRINCIPLES

APHSA’s Pathways initiative, our member-driven principles and proposals for a more effective and results-focused human services system, calls for sustainable and meaningful outcomes for individuals and families focused on achieving gainful employment and independence, stronger and healthier families, adults, and communities, and sustained well-being of children and youth. The strength and health of those who come to human services rest on a broad continuum of widely available conditions and resources as well as individual and family capacities and abilities. These include the means to access proper nutrition, and federal nutrition programs play multiple and important roles in supporting this result. As the largest and most widely available of these federal programs, the Supplemental Nutrition Assistance Program (SNAP) has served to significantly alleviate hunger for many decades and in turn greatly enhance individual, family and the nation’s well-being. SNAP is highly responsive to economic conditions. In times of economic distress, more people become eligible for the program and more people receive benefits—as evidenced by the substantial increase in enrollment and spending during the Great Recession. SNAP also helps poor communities during economic downturns by bringing additional federal dollars into the local economy. SNAP caseloads and spending also fluctuate with economic conditions as demonstrated by USDA-FNS data, having reached a high of 47.6 million individuals in 2013 with benefits of just over $76 million. As of 2016, recipients and costs declined to 44.2 million recipients at a cost of $66.6 billion and are expected to remain on a decline as the economy improves. This ebb and

flow of participants and costs based on economic circumstances is the key to SNAP’s effectiveness. SNAP also reaches over 80 percent of those who are eligible for benefits. 1 SNAP is also a highly effective work support program and its benefits lifted 10.3 million households including 4.9 million children out of poverty in 2012. 2 SNAP was reauthorized with the farm bill enacted in 2014 and will expire September 30, 2018. The reauthorization process is expected to begin in 2017 and culminate either as part of the farm bill reauthorization in 2018 or as separate legislation that might occur sooner. Reauthorization presents the opportunity to take stock of the program at a foundational level. Significant improvements can be considered that will enable the program to more fully realize its potential to reduce food insecurity and enhance economic independence by serving the nutrition needs of the low-income population. APHSA and its members have identified the following core principles for SNAP that must underpin the program’s modernization and its associated administrative and regulatory rules: • Nutrition is a key support that is typically separate in structure and administration, yet plays a direct and vital role in building health and capacity. SNAP can be far more effective if it is integrated into the larger framework of health and human service programs so that it supports and aligns with critically important health and wellness outcomes. • SNAP has contributed significantly to reducing need and to providing important bridge supports for those affected by job loss

1 USDA Food and Nutrition Service. (March 2017). SNAP Program Participation and Costs. Accessible at https://www.fns.usda.gov/sites/default/files/pd/ SNAPsummary.pdf. 2 Center on Budget and Policy Priorities. (October 2016). Snap Lifts Millions of Kids Out of Poverty. Accessible at http://www.cbpp.org/blog/snap-lifts- millions-of-kids-out-of-poverty.

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and other setbacks. It can respond quickly to recessions, food price inflation, and the changing needs of individuals and job markets. SNAP’s benefits flow through the existing retail food system and generate multiplier effects on the broader economy. SNAP’s benefit structure must continue to be able to provide this kind of immediate, effective, and sustained response. SNAP is also a key element in preventing “heavier-touch” and more costly problems down the road in health, nutrition, family stability, and independence. As the traditional foundation of nutritional and bridge supports across the nation, it has enhanced the effectiveness of other programs with varying benefits and standards, such as Temporary Assistance for Needy Families (TANF). • While SNAP must retain its current strengths, it can and should become a far more impactful and efficient program. First, SNAP must become more effectively aligned to the degree possible with other programs such as those in the area of health. SNAP also must take far greater advantage of new technology and electronic data exchanges that can speed the application process, avoid duplication of work for both participants and administrators, connect seamlessly with other programs, strengthen access, and further improve program integrity. SNAP can also substantially strengthen its ability to help participants find success in the

workforce through, for example, expansion and refinement of SNAP Employment and Training Programs, lessons learned from the work engagement pilots authorized in the 2014 farm bill and better coordination with both TANF and various programs under the Workforce Innovation and Opportunity Act (WIOA). • SNAP’s current entitlement structure should be retained. SNAP should retain its current benefit responsiveness as outlined above, including rapid adjustments for cost increases and caseload growth, a national floor for benefits, and alignment of state administrative match rates with other major human service programs. Any reductions in SNAP expenditures must be carefully assessed for their impacts on recipients and the states’ ability to meet their needs properly, as well as the retail food economy. SNAP benefit or administrative match reductions could have a number of undesirable consequences, including diminishing agencies’ ability to properly administer this very complex and labor-intensive program. • SNAP must allow and support the most up- to-date and effective business practices, making them a more seamless and efficient element of a person- and family-centered approach. A number of current SNAP laws, regulations, and administrative rulings prevent the program from taking full advantage of advances that would reduce administrative

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costs, improve customer service, and strengthen program impacts. Certain policies beyond SNAP also have similar impacts, such as those that keep SNAP and other programs from freely using important data bases that could improve administration and access. Similarly, states must have the option to implement horizontally integrated systems (particularly their information technology components) that streamline the eligibility and verification processes for SNAP, bringing them closer together where possible and without losing unique SNAP program aspects, with health, cash assistance, and other human services programs. Such integration will improve access, save administrative costs, improve program integrity, and maximize states’ ability to take advantage of extended enhanced federal funding. We believe that a combination of simpler program rules, rapid modernization of eligibility and verification methods, and a far more intentional system of training and communication are critically important next steps in SNAP’s progression as a fully realized nutrition and economic support program. We also call for a far broader and more outcome-focused way of assessing SNAP’s performance and impacts overall, including an independent analysis of what other metrics beyond QC are most important to consider and how they should be administered. These principles are reflected in the following suggestions for SNAP reauthorization. Program Simplification APHSA has for decades urged simplification of SNAP rules, and proper credit goes to Congress, several Administrations, and the program’s stakeholders for reducing complexity in many areas. However, the program still has far to go. SNAP remains one of the most challenging assistance programs for customers to understand and for agencies to administer, and remains tied to eligibility and verification procedures that are more difficult than those in most other major programs, that are often outdated in their application, and that take too little account of their interaction with

the rest of the health and human services system. Coordination and interoperability – While SNAP certainly has some points of focus and service that are different from other health and human services programs, on the whole it serves many of the same people with the same broad aim of improving and sustaining their well-being, independence, and capacity. By often functioning in isolation, SNAP misses many opportunities to interact with other programs and thus to enhance access and efficiency. One clear example is limitations on taking full advantage of the new information systems being implemented for health care, which can connect to SNAP in limited ways but cannot bridge SNAP’s differences in definitions of income and households and its approaches to interviewing and verification (see also Section II below). Another example concerns the current inability to effectively align SNAP and WIC, which could be significantly helped by a common benefit issuance process despite program income eligibility differences. Greater interoperability and alignment among these large systems would improve access by enhancing “single-portal” contact and reducing duplication in collecting and verifying case information. Many states have waivers in place to create greater interoperability, but there is little impact measurement of the success of waivers by FNS and where waivers currently demonstrate both their effectiveness and ability to be replicated in other states, they must continually be extended rather than simply made a permanent part of program delivery. Simplified benefit calculations – Simpler SNAP rules would reduce the opportunities for errors and reduce administrative burdens for states and confusion for customers. SNAP’s profusion of eligibility factors attempts to reflect precisely every type of change in both income and household expense factors – perhaps a desirable goal in theory, but these factors are now so numerous and so complex that it is questionable whether there is still a net benefit to this approach. Many SNAP households have frequent changes that strain our resources to constantly track and verify them and current client

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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.

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Administrative Modernization SNAP must be aggressively modernized in the way it collects, uses, and verifies eligibility information. The program is still far too paper-based, is too hampered by outmoded technology, makes insufficient use of existing electronic data, and focuses too little on the creation of new databases. The report on the SNAP hearing series findings of the 114 th Congress states that “technology plays an important role in implementing [existing] state options…the use of computers streamlines the application process and makes SNAP more accessible to low-income families. The use of technology can also ease administrative burdens and enhance program integrity.” 3 While true, the current technological infrastructure and barriers to the streamlined use of data present barriers to maximizing the benefits of modernization. Connectivity & Interoperability – In 2011, at the request of stakeholders, including the states, the Office of Management and Budget announced a time-limited “Exception” to the traditional way by which State expenses were to be cost-allocated under Circular A-87 by programs that shared common information technology (IT) services and business components. Expenses associated with eligibility and enrollment IT activities required by Medicaid, but also of use to other health and human service programs, would no longer need to be paid by those non-Medicaid programs or would be available at less cost. In many cases, state Medicaid programs would pay for these development costs, and receive a 90% Federal Financial Participation. Taken together, these opportunities have been and continue to be a critical component helping states achieve the ongoing efforts to modernize outdated technology across programs and meet the demand placed on them with the passing of the Affordable Care Act (ACA). While the intent of these funding mechanisms was meant to modernize state IT systems across like-programs, mandates placed on state Medicaid programs were significant and the full value of the Exception has not yet been realized. Understandably, many human service programs

allowed to benefit from these modernization efforts, and in many times to IT systems that are up to if not more than 20 years old, were unable to take advantage of the respective opportunities. Varying dynamics across states have created inconsistent use of the Exception, and efforts to streamline and support access to the unprecedented and innovative opportunity have not all been successful.  Clear language and direction about expectations of A-87 availability and access for all agencies will be integral to further advance the development of complex systems that both improve functionality and decrease program administrative costs across all programs. In addition, states continue to make significant progress with modernization efforts; however, as we get closer to the Exception expiration date of December 31, 2018, there will be increased reluctance to begin an integration project without assured funding through the end of the project deadline. An ongoing OMB A-87 Exception extension, with clearly stated expectations of system integration and interoperability across all programs, allows states to ensure less duplication of unnecessary services and enables them to leverage the information-sharing possibilities to improve outcomes and reduce fraud, waste and abuse. Without an ongoing Exception extension, states will continue to operate separate, free-standing, inefficient systems that compel them to duplicate efforts and create redundant processes for states and their clients accessing multiple health and human service programs. Use of Federal Data Hub and other data sources – SNAP and other human services programs need access to central data sources such as the Federal Data Services Hub and state data hubs, and the data within them must be considered already verified for SNAP use (assuming it meets reasonable standards for accuracy and currency). We are pleased that initial steps are already under way in this process and look forward to its full implementation as quickly as possible.

3 “Past, Present, & Future of SNAP. Hearing Series Findings: 114 th Congress.” p23. Available at http://agriculture.house.gov/uploadedfiles/snap_ report_2016.pdf

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Further, data from some other sources is available free for Medicaid, but states must pay for the same data again to access it for SNAP, an obviously unnecessary duplication of scarce funds. A comprehensive review of available data sources, undertaken by the Food and Nutrition Service (FNS) and other federal agencies would lead to rational decisions made on issues of data access, quality, and costs. Data content within the Federal Hub should be expanded to meet the needs of SNAP and other human services programs. Work Number – Work Number allows requesters, for a transactional fee, to receive immediate confirmation of an individual’s employment and salary for eligibility verification purposes. This real-time, electronic access to employment data is a critical tool to State SNAP agencies in their efforts to efficiently determine benefit eligibility while ensuring program integrity by reducing potential fraud from customer non-report. With the passage of the Affordable Care Act (ACA), the Federal Data Services Hub was created, allowing states to access data to aid in the determination of eligibility for enrollment in qualified health plans and insurance affordability programs. The Work Number is one of the many data elements available on the Hub. Several State SNAP agencies had existing individual state contracts with the Work Number, and sought access to the Federal Data Services Hub Work Number data, thus providing them with the ability

to eliminate the duplicative money being spent on individual state contracts with the Work Number. Unfortunately, Food and Nutrition Services (FNS) released a memo providing guidance to states, explaining that the state, “should not consider information from the Hub to be verified upon receipt for SNAP purposes.” The FNS memo goes on to explain that “FNS has worked with CMS diligently…to resolve this issue” and that CMS is “actively searching for ways to resolve this challenge.” The FNS memo was released to states in October 2013, and visible progress has yet to occur; resulting in the Work Number maintaining high-cost contracts to identical data at both a state and federal level. A single national Work Number contract, available for all eligibility programs, is a simple and necessary solution to eliminate this waste of dollars seen with multi-level contracts. Information sharing among states – Pilots such as the National Accuracy Clearinghouse, which is testing a multi-state recipient database, are promising and their successful elements should be quickly made available nationwide. Similar concepts should be incorporated into a variety of other contexts where information sharing could benefit the program. Potentially helpful innovations like these demand a much higher priority and much faster timetables than we have seen to date. In addition to contributing to the modernization of SNAP, progress on this front could reduce or eliminate many of the new integrity

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Supporting Work and Building Economic Capacity Stronger support and more sustainable opportunities for entering the workforce, and successfully retaining gainful employment once achieved, are key goals of APHSA’s membership and a critical activity that can help move more individuals and families toward greater capacity and self-sufficiency. SNAP E&T can play a forceful and positive role in moving towards this goal. SNAP E&T can be a doorway for families and individuals to access work supports as well as sector-based education and training and on-the-job training related specifically to available employment in local and regional labor markets. Through SNAP E&T, there is a significant opportunity to reach out to employers and community colleges in individual labor markets to understand their job skill needs and develop in partnership with community colleges and others work-based curricula that can match both employed and unemployed SNAP recipients to work opportunities. SNAP E&T can also serve as a bridge for families who have left TANF for employment but need additional training and skill development to advance economically. Update SNAP employment programs – SNAP’s role in supporting work efforts could be greatly strengthened if the rules and funding for the SNAP Employment & Training program meshed more seamlessly with other work support efforts (including new rules under the Workforce Innovation and Opportunity Act, or WIOA) and could more easily be made part of a comprehensive employment support effort. SNAP E&T’s strengths must be retained and expanded by the commitment of additional 100 percent funds and expanded flexibility in the use of 50/50 federal matching funds to encourage the ability of states, at their option, to draw down funds, leading to further state innovation and more work- eligible recipients able to be served. We appreciate that USDA/FNS is now expanding its own internal emphasis on SNAP E&T as an avenue towards gainful employment and economic advancement. The separate policy rules applicable to Able- Bodied Adults without Dependents (ABAWDs) can

concerns we currently face, that are often driven by the lack of commonly shared data and place states in the difficult position of having to maintain a high standard of program integrity without all the necessary tools to do so. Modern customer interfaces – Much of our population, at all income levels, has long since made the transition to engaging government and other sectors electronically, usually through personal devices, without the need for unreasonable paperwork and repetition of data already in the system. SNAP has begun making this transition, and indeed was a pioneer in changing to swipe card benefits nearly a decade and a half ago. But again, it has far to go in allowing simple electronic access, interoperability among related and human serving programs, alternatives to face-to-face interviews, and use of the vast amount of electronic data now residing in government systems. Reducing these barriers could enhance single-portal access and eligibility, cut the time and effort to submit verification information, and help the many SNAP participants who must work during normal business hours. Testing and implementing innovations – Modernizing SNAP must include accelerated development of innovative alternatives that improve the program’s impacts and administration, followed by rapid evaluation and prompt implementation of successful improvements. Applicable elements of the ten Employment & Training pilots now under way could be a model for numerous other potential pilots covering such major program aspects as; verification and program integrity; benefit adequacy, expanded earning deductions, broader use of summer EBT, improved nutrition and health through both purchase incentives and restrictions on sugar-sweetened beverages: modern methods of using benefits in retail settings; and new blended and braided funding models, including partnerships with other programs and sectors. Another example could be pilots that incorporate the use of Modified Adjusted Gross Income (MAGI) methodology and eligibility decisions from health programs to initiate and complete most of the SNAP eligibility process.

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interfere with states’ ability to conduct effective employment programs. In fact, we should be doing everything possible to create real work opportunities for ABAWDS, many of which are non-custodial fathers and/or post-incarcerated individuals, not only so they can find employment but also fulfill support obligations and not return to incarceration. Instead, ABAWD rules, because of the strict three in thirty-six-month time limit for failure to comply, ultimately diminish their ability to work and be economically productive. By quickly forcing these ABAWD recipients into activities, regardless of how superficial, simply to preserve their SNAP eligibility past the initial three months, rather than to incorporate them into a comprehensive program is counterproductive. Compounding this is the ongoing weakness in many labor markets where employment opportunities remain sparse, competition for jobs is strong and states and localities often cannot create sufficient eligible slots to meet the ABAWD compliance rules. When ABAWDS lose their benefits after three months, necessary food assistance has been severed and they are left outside the purview of the state’s efforts to skill them up and place them in stable jobs that are likely to be enduring or at least preparatory to other employment opportunities. Avenues to alleviate these problems and to maintain the strong and important work expectation message for ABAWDS would be to allow states that choose to do so, to expand the three in 36 month time limit for a longer period of time, perhaps nine months, align time limits for ABAWDS with their certification periods to make tracking easier for states, broaden allowable activities to meet work requirements including online learning and other provisions, provide new post-employment federal work support funding for transportation and other job related expenses to ensure job retention and guarantee that if no job or eligible activity is located that benefits will not be lost. Expand E&T pilots – The current E&T pilots, authorized by the 2014 farm bill, should shed important light on how SNAP can advance in this critical area, and clearly beneficial impacts from

these pilots should be implemented based on interim positive evaluation findings even before the pilots have concluded. Additional, similar pilots that can evaluate other strategies to build individual employment capacity should be promptly developed and tested. For those pilot states that demonstrate promising practices, bridge funding should be allocated to allow programs to continue pending final evaluation. The “cliff effect” – Among the most unfortunate results of multi-program disconnects is the so-called “cliff effect,” in which modest increases in income, and in turn program benefits, trigger significant reductions in other programs or even termination – a direct result of different approaches to eligibility rules and program philosophy. The cliff effect is often a significant disincentive to begin working or to increase hours and pay. While SNAP has gradual benefit phase-down provisions that make it less subject to a cliff effect than other programs, most notably child care, it could better accommodate rapidly changing household income situations by, for example, allowing states a period of one to three months in which federal SNAP benefits are held steady when employment is at a sufficiently high wage to end SNAP eligibility. Other work-related benefits such as transportation could also be extended for the same period of time in order to allow working families to adjust household budgeting post SNAP receipt. Accountability and Program Integrity APHSA and its members fully support the accountability of human services programs for results that are significant and sustainable, and that return proper value for the public’s investment. SNAP is without question one of the most highly regulated and strictly overseen programs when it comes to such metrics as benefits and timeliness, and reasonable requirements for these basic performance standards should remain in place. However, these and other equally important program results could be part of a broader and more balanced approach to assessing what SNAP accomplishes. Some ways to achieve this include the following.

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New measures of SNAP performance – A balanced and comprehensive assessment of SNAP’s performance and impacts is needed. It would measure not just the accuracy of individual state eligibility decisions but would tell policymakers and the larger public how SNAP has made the lives of individuals and families better. While grounded in consideration of accuracy and timeliness, the program accomplishes so much more: supporting gainful employment, stabilizing family budgets, and improving nutrition and other factors of economic well-being. The intense and nearly exclusive focus on current QC metrics leaves little staff time and capacity – either state or federal – to pay proper attention to these significant and broad impacts. SNAP plays important roles in preventing downstream, “heavy touch” and costlier problems and in strengthening families in multiple other ways, and these outcomes must be given their proper weight. Focusing so much attention on payment accuracy has basically cast these other positive impacts of SNAP into the shadows and undermines public opinion of the program. Of course, accurate benefits must remain important, but a properly balanced assessment approach would place far more emphasis on preventing errors rather than “chasing” them after the fact. Independent analysis – One way to develop and put in place a modernized measurement system would be to have an independent, outside party study SNAP’s QC and integrity procedures, such as was done to resolve QC concerns in the 1980s by the National Academy of Sciences. This analysis should examine which measures are most relevant and useful for evaluating SNAP’s success and how they should be administered. It should focus particularly on what SNAP could learn from how other government programs are measured, how SNAP’s broader impacts can be practically evaluated, and how improvements in administration can best be incentivized. Test alternative success outcomes – There are potentially several ways to evaluate the success of a broader approach within SNAP, such as further documenting progress toward less food insecurity,

toward greater engagement with the workforce, and toward greater overall economic capacity and independence. Demonstration projects testing SNAP as a strong factor in achieving such outcomes should be implemented, with some of the funding and procedures now devoted to output compliance repurposed for these broader and far more impactful goals. Performance incentives – Bonus funding awards to states were enacted with the 2002 farm bill. These modest amounts have proven successful in bringing state attention to important aspects of performance not limited to just payment accuracy, to the benefit of program quality and customer service. Incentive funding for high state performance should be reviewed to determine how past successes can be strengthened and targeted to modern approaches that deliver documented improvements. Healthier food choices – There is a great deal of interest in, and concern about, food choices that SNAP participants make. Many of our members have for years called for greater attention to the major role SNAP plays in the national problems of inadequate nutritional intake, obesity, early-onset diabetes, and other food-based concerns. Several innovative tests of food choice incentives have been held to assess whether wiser and healthier food choices result – including the USDA-funded Healthy Incentives Pilot in Massachusetts, market bucks to reward the purchase of fruits and vegetables, growing numbers of farmer’s market programs and several public-private efforts in Michigan and Minnesota. More such pilots should be carried out on a frequent basis, perhaps coupled with a rigorously evaluated state pilot in one or more areas to test restrictions on unhealthy food purchases such as sugar- sweetened beverages. With appropriate data support, the quality of SNAP recipients’ food choices could become part of a broader evaluation of successful program outcomes. Interim improvements to the existing QC system – As we examine new and better ways to evaluate SNAP, the current Quality Control system stands in serious need of significant improvement. For example, far too much confusion exists around what QC procedures are permissible and how a long list of

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Fraud – It is critical that initiatives designed to prevent fraud at application and before approval be explored and implemented in order to ensure truly eligible people are receiving benefits thereby preserving the integrity of the program.  Identity theft is a seriously increasing problem, especially within the federal and state benefits levels, and it is imperative this program implement safeguards appropriate to current day circumstances.  Trafficking, or the improper redemption of SNAP benefits for the acquisition of nonfood items, has also been and continues to be of great concern to policymakers, states, and the public since it represents unlawful activity as well as public funds not utilized for their intended purpose. Program integrity could be enhanced through additional resources to monitor and control trafficking. Some of those resources are already available in the states. States have historically been responsible for investigating and responding to fraudulent acts of recipients (in cases of benefit misuse, by filing claims and carrying out disqualifications) while FNS has taken responsibility for SNAP retailer activity. However, certain states have the ability and have shown the will to take direct action against retailers abusing the program and to take more decisive action against recipients misusing their benefits. States should be allowed to step up their efforts and should receive appropriately enhanced support from FNS for doing so. Identity theft has emerged as a rapidly growing concern that needs greater attention. The federal

technical issues should be interpreted and resolved. There are regional variations in guidance and training provided by FNS; a range of interpretations about the meaning of FNS manual material; different rulings by FNS on the same issue over time; and citation as violations of practices that have been frequently approved in the recent past. Better and more consistent training and communication; simpler and more straightforward procedural rules; fewer variations in interpretation; and simplified procedures for sampling, completion, and submittal of findings for reviewed cases are among the urgent improvements needed at once. Re-examine the QC error threshold – SNAP formerly had a very sensible tolerance level of $50 in budget changes before an error was cited, but the 2014 farm bill lowered that figure. Minor variations in circumstances should not be included in eligibility factors and their associated QC reviews. A fresh examination of a proper threshold amount, with a focus on the return on investment of “chasing” small errors, should be an immediate priority. Re-examine the QC requirement for a face-to- face interview – Although there are waivers available for telephone and video conferencing interviews for some cases, the face-to-face interview is still required for many others. A great deal of time and cost goes into meeting this requirement with limited benefit. Also, the face- to- face interview is not being conducted by FNS in their National Error Rate Review Project for FFY 2016, which is being used to determine the National SNAP-QC error rate.

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• Make the following permanent changes to the SNAP Program: 4. Expand the focus on work for work eligible SNAP households, but emphasize job development, job placement, job retention, sector focused education and skill training development, related to actual available jobs in local communities. As findings are released on the ten state Employment and Training pilots, permanently incorporate those that are effective into the E&T program. 5. Expand available E&T 100 percent funds and broaden the allowable uses of E&T 50/50 match funds to encourage additional state innovation and better coordinate E&T with TANF and other programs under the Workforce Innovation and Opportunity Act (WIOA). 6. Allow states at their option to change the current 3 in 36 month ABAWD Time Limit work rule to 9 in 36 months and coincide it with the individual’s certification period. Also, do not impose the time limit when no job or available work slot that meets ABAWD requirements can be provided to the individual. 7. Allow states greater flexibility to initiate innovative approaches and impose a time limit on USDA/FNS as to when they must approve or reject state waiver and demonstration requests such as 90-120 days, as current approval or rejection of such requests is often protracted and stifles state innovation. 8. Modernize systems in SNAP as well as system interfaces with other programs, more broadly share available data across programs and increase the emphasis and funding for research regarding what works best in SNAP. 9. Allowable Resources – Current levels are too low and have resulted in the use of Broad-Based Categorical Eligibility (Cat-El) by 42 states as a work around with the vast majority using it to eliminate any resource limit. 4 Raising the resource limit for all SNAP

government should provide states with the tools to both prevent this form of fraud and to detect and prosecute it when it occurs. Applicants and recipients need to have the assurance that the information they provide to state SNAP agencies is secure from exploitation by criminal elements. Specific Program Recommendations • Several pilot programs should be enacted and rigorously evaluated for potential future replication based on effectiveness and affordability: 1. Benefit Adequacy - Testing a pilot approach over several years in a single state or large locality by issuing benefits based on the Low-Cost Food Plan rather than TFP with rigorous evaluation as to impact on very low food security. 2. Earnings Disregard -Launch a rigorously evaluated pilot program in diverse geographic areas to test expanding the current Earnings Disregard for working individuals and families from 20 to 30 percent to assist more low- wage working families who are struggling to make ends meet. 3. Purchasing Restrictions -Test a pilot for interested states in geographically diverse areas (urban, rural, suburban) over a three to five-year period prohibiting SNAP dollars from being used to purchase a defined category of unhealthy sugar-sweetened beverages. These pilots would include an independent rigorous evaluation as to whether they lower the purchase of such items overall with resultant positive health outcomes or if families simply substitute non-SNAP funds to purchase the same items. If the pilots are successful, states, at their option could implement such a program without needing demonstration authority.

4 USDA Food and Nutrition Services. (August 2016). Accessible at https://www.fns.usda.gov/sites/default/files/snap/BBCE.pdf.

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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.

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Tracy Wareing Evans President and CEO American Public Human

Services Association twareing@aphsa.org 202-682-0100 x 231 Russell Sykes Director, CEEWB rsykes@aphsa.org 518-756-8149

1133 19th Street, NW, Suite 400 Washington, DC 20036

www.APHSA.org