CEEWB: The Future of SNAP

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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opportunities have been and continue to be a critical component helping states achieve the ongoing efforts to modernize outdated technology across programs and meet the demand placed on them with the passing of the Affordable Care Act (ACA).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