Policy & Practice | Fall 2023

Policy & Practice | Fall 2023

The Magazine of the American Public Human Services Association Fall 2023

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Vol. 81, No. 3 Fall 2023





3 President’s Memo

Aspirations for the Future of Human Services Part Four: The Human Services Workforce

5 Legislative Update The New SNAP Landscape: What the Debt Ceiling Deal Means for SNAP Recipients this October 6 From Our Partners The Power of Insight: Extracting Data to Inform Decisions

8 From Our Partners

Piles of Stuff: Changing Our Thinking to Keep the Work Flowing

10 Federal Insights Moving Forward: One Step Closer to WIC Online Shopping

Revolutionizing Government IT Procurement

Realizing the Potential Gen AI in Human Services Delivery

12 Research Corner

Balancing Access and Security: The Digital Identity Landscape in Human Services

Innovative Alternatives to Current Practices for More Effective Delivery

14 APHSAViewpoint Data Sharing to Modernize Benefits Enrollment and Outreach: Insights from the CSNS Grant Program 34 Partnering for Impact Showing What’s Possible: How to Center Client Experience



36 Association News

Reimagining Customer Service: The Aligned Customer-Centered Ecosystem of Supports and Services (ACCESS) Initiative

38 Technology Speaks Innovative Solutions in Illinois: Natural Language Processing Platform to Save Significant Administrative Time

40 Technology Speaks Bits to Atoms: Tech Vision for Human Services

48 Staff Spotlight

Christine Johnson, Assistant Director, Policy

Driving Effective IT Innovation How to Power the Next Generation of Human Services

From Replacement to Reinvention Uncovering the Keys to People Centric, Technology-Enabled Medicaid Transformation in New Mexico

Kapria Lee, Project Associate, Child and Family Well-Being

49 Staff Spotlight

Marcus Robinson, Senior Project Associate, National Electronic Interstate Compact Enterprise (NEICE)

Sheila Poole, Vice President, External Relations

Cover image via Shutterstock


Fall 2023 Policy & Practice

Strategic Industry Partners

APHSA Executive Governing Board

Chair Dannette R. Smith, Former CEO, Nebraska Department of Health and Human Services Vice Chair Rodney Adams, Former Director, Mecklenburg County (NC) Department of Community Resources Immediate Past Chair David A. Hansell, Former Commissioner, New York City Administration for Children’s Services Treasurer Kathy Park, CEO, Evident Change Elected Director Derrik Anderson, Executive Director, Race Matters for Juvenile Justice Elected Director Vannessa L. Dorantes, Commissioner, Connecticut Department of Children and Families

Elected Director Grace B. Hou, Secretary, Illinois Department of Human Services Elected Director


Sherron Rogers, Vice President and CFO, Johns Hopkins All Children’s Hospital Elected Director Terry J. Stigdon , Agency Head/Executive Director, Indiana Department of Child Services Elected Director Jennifer Sullivan , Senior Vice President for Strategic Operations, Atrium Health Elected Director Eboni Washington , Assistant Director, Clark County (NV) Juvenile Justice Services Local Council Representative Dan Makelky , Director, Douglas County (CO) Department of Human Services




Policy & Practice Fall 2023

president’s memo By Tracy Wareing Evans

Aspirations for the Future of Human Services Part Four: The Human Services Workforce

This is the last of a four-part series exploring what leaders in human services aspire for the sector, drawn from the insights that emerged in multiple visioning sessions that APHSA sponsored last year. Those sessions led to our updated Strategic Playbook (see https://bit.ly/Playbook23) and, in particular, to this graphic depicting the critical gears and core components of getting to our desired future state. I n building a space for leaders to openly discuss their hopes for the future of human services, one thing rang true across the nation—the chal lenges in recruiting, training, and retaining a workforce in ways that attend to their sense of safety, well being, and belonging, remains one of the toughest challenges we face. Agency leaders are the first to acknowledge that it is the workforce that bears the direct weight of admin istering services through an outdated and misaligned system. And, too often, it is the workforce that carries the blame when the system does not meet expectations. This reality stands in stark contrast to the invaluable role we know people who work in human services play every day. And, as vital as our workforce is, many human services agencies are reporting vacancy rates of 30–50 percent or even higher, with no recruiting pipeline in sight. This shortage of personnel is particularly evident in positions like child welfare and eli gibility staff and has been further exacerbated by the ongoing “Great Resignation” phenomenon with which we are all too familiar.

Across the nation, we are hearing from agency leaders who are actively seeking to flip this current reality on its head. Leaders are starting by listening deeply to the experiences and recom mendations of the workforce to better understand where changes need to be made. They are advocating for long overdue pay increases, and investing in the modern tools that workers need. They are supporting ongoing learning in next-generation approaches such as human-centered design and commu nity power-building. Agency leaders are also working to make the critical role the workforce plays much more visible to policymakers and the public. Leaders recognize, however, that our aspirations to be community-led and to truly align our systems are heavily reliant on our sector’s ability to face, head-on, both long-standing and emerging obstacles to fully supporting the workforce. Put another way, if the

middle gear depicted in our graphic does not run smoothly, we’ll have a hard time advancing what we aspire for the future state of the sector, espe cially in ways that are led by people and communities. People who work on the front lines of human services are the heart and soul of the sector. They are often the first point of contact for people seeking assistance, and their expertise and empathy are essential in building trust and establishing meaningful relationships. Beyond the front line, agency staff at all levels plays a role in creating an infrastructure that supports the front-line work; provides for data collection and analysis; and continually assesses progress at individual, community, and popu lation levels. Senior leaders build relationships within and across the

See President’s Memo on page 42


Fall 2023 Policy & Practice

Vol. 81, No. 3


Policy & Practice™ (ISSN 1942-6828) is published four times a year by the American Public Human Services Association, 1300 N. 17th Street, Suite 340, Arlington, VA 22209. For subscription information, contact APHSA at (202) 682-0100 or visit the website at www.aphsa.org. Copyright © 2023. All rights reserved. This magazine may not be reproduced in whole or in part without written permission from the publisher. The viewpoints expressed in contributors’ materials are the authors’ own and do not necessarily reflect the policies or views of APHSA. Postmaster: Send address changes to Policy & Practice 1300 N. 17th Street, Suite 340, Arlington, VA 22209

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Policy & Practice Fall 2023

legislative update By Mary Alice Hunt

The New SNAP Landscape: What the Debt Ceiling Deal Means for SNAP Recipients this October

T his past May, just days before the federal government was expected to breach the debt ceiling, the U.S. House of Representatives passed a bill to avert default. The Fiscal Responsibility Act of 2023 (H.R. 3746), which was signed into law days later by the President, was the product of bipartisan negotiations that agreed to lift the debt ceiling in conjunction with spending cuts and the addition of new work requirements for participants of the Supplemental Nutrition Assistance Program (SNAP) who are considered able-bodied adults without depen dents (ABAWDs). The new SNAP work requirements are slated to begin going into effect as soon as this October. Work requirements under SNAP fall into two categories: general require ments and additional requirements expected of ABAWD recipients. General work requirements affect SNAP recipi ents aged 16–59 and require them to work a minimum of 30 hours per week and/or participate in employment and training (E&T) activities unless they meet exemption criteria. Exemption criteria include barriers to employ ment such as having physical or mental limitations; being a caretaker of a child younger than age 6 or an incapaci tated person; being treated for drug or alcohol disorders; or being enrolled as a student (at least half time). Should work requirements not be met, SNAP recipients face sanctions such as dis qualification from benefits. SNAP recipients categorized as ABAWDs and who are between the ages of 18–49 have additional work participation requirements such as

engaging in a minimum combined 80 hours per month of activities from paid employment, volunteer work, or other work programs. ABAWD recipients who have physical or mental limita tions or are pregnant are exempted from these additional requirements. Agencies and their workers provide a great deal of assistance to benefits recipients to help them meet their partic ipation requirements through more than just paid employment. This includes: n Providing assistance to achieve employability to those with tempo rary barriers to participation. This could include subsidized benefits such as child care for recipients with underage children or placing recipi ents with alcohol or substance abuse issues into treatment programs. n Providing access to work participa tion activities such as job training, counseling, and employment services

to recipients who need help finding (and keeping) a job. These activi ties count toward their participation goals and can count toward the recip ient’s work requirement criteria. n Placing recipients into work experi ences within government agencies or employment partners in the private sector—for example, a clerical position, or labor services in a Parks or Transportation department—to gain job experience and meet their participation needs. Agencies use a wide variety of tech nology tools and systems that provide features to support this processing. From websites and eligibility systems to case management and financial accounting tools, which are all configured to support SNAP and ABAWD requirements.

See New SNAP Landscape on page 46

Illustration by Chris Campbell


Fall 2023 Policy & Practice

from our partners

By Lauren Hirka

The Power of Insight: Extracting Data to Inform Decisions

I t’s a long-established challenge in human services that workers spend too much time collecting, entering, and verifying clients’ data, but not enough time using it to inform decisions and actions. The same goes for agency leaders who have a trove of valuable information buried in their systems that collect data for compliance. A few years ago, Brunswick County Department of Social Services (DSS) in North Carolina recognized an opportunity to turn their input into insight. Leveraging our software, Traverse®, they set out to identify creative ways to classify, organize, and extract important data to support program goals and outcomes, in addition to reporting to the state. Today, this work has inspired a full suite of reports that are built into the software for every customer to leverage. Now all agencies that use Traverse can unlock data that not only support compliance, but also allow them to identify trends, prioritize work, and allocate resources. Partnership with Brunswick County DSS Shortly after Brunswick County DSS began using Traverse, we started working together to better understand how we could evolve the software to support their reporting needs. Rich Ohmer, social work program administrator at Brunswick County DSS, previously had to maintain multiple spreadsheets, access data bases, and reports provided by the state to find and gather the informa tion he needed. Data often weren’t

agency to manage all their reporting needs with Traverse instead of having to open and log into other systems. Beyond the custom reports they created, there are more than 40 additional reports in the module that provide even more insight based on all the data in the system. “To be able to use everything we put into that system without having to duplicate it with all these other spreadsheets is fantastic,” Ohmer said. “It saves a lot of time and it’s more accurate.” Brunswick County DSS Social Services Director Cathy Lytch says the real-time availability of the data is most beneficial. “We have all this

available until a month later, which made it hard to accurately report on key statistics or use the information to inform decisions in real time. Now, Ohmer can quickly find the data he needs within Traverse. He initially worked with county IT to develop seven unique reports that pull from Traverse data, including data entered directly into forms, and then connected the county’s existing reporting tools to a replica database of Traverse to build them. Northwoods is currently working with Brunswick County DSS to move all seven reports into a recently launched reporting module of Traverse. This move will allow the

Illustration by Chris Campbell


Policy & Practice Fall 2023

demonstrate that they are good stewards of taxpayer money. Moving Forward Agencies like Brunswick County DSS, with a data-driven understanding of case and client information, can identify the most impactful ways to support the commu nity and advance the next generation of human services. Technology providers can help by listening to agencies’ needs and evolving our solu tions to address them. The possibilities are endless if every piece of data collected throughout the life cycle of every case can be turned into meaningful insight to inform ethical, equitable decisions and actions. Lauren Hirka is the Director of Product Marketing at Northwoods. Lauren works with partner agencies across the country to help them realize the impact of new products and functionality as changes roll out, plus understand their challenges to inform future features.

to target services accordingly. For example, an agency that regularly makes referrals to counselors or therapists may benefit from executing a public information campaign about additional mental health programs and resources that those community members could access. n Consent management. Creating reports that track the expiration dates on digital releases of informa tion or consent forms can empower workers to proactively work with clients to keep these forms current. This ensures no lapses in collabora tion or services based on outdated documentation. n Quality assurance. Going paper less doesn’t happen overnight, and reporting can help manage the process by tracking activity per case to identify what still needs to be scanned into the system. This way things that previously got lost in the shuffle of paper will no longer fall through the cracks. Agencies don’t have to scramble to prepare for audits, or sacrifice time spent with families, and can easily

great data in Traverse. The way we’re organizing it, we can pull it out in a meaningful way,” she said. “Rich used to spend hours trying to gather infor mation monthly for reports and now he can just hit a button and get what he needs.” Unlocking Meaningful Insights Brunswick County DSS is one of 41 Northwoods customers that use Traverse. Collectively, these agencies have completed more than 5 million forms and added more than 41 million content items. Here are a few ways the data previously hidden within these forms and documents can now be extracted to advance person-centered service delivery. n Targeting services. Referral forms are some of the most ubiquitous forms that caseworkers complete across all human services programs. Creating reports based on the zip codes listed on these forms can help agencies understand which areas or neighborhoods are sending the most referrals to different types of providers and use that information


Fall 2023 Policy & Practice

from our partners

By Bill Bott

Piles of Stuff: Changing Our Thinking to Keep the Work Flowing

T wenty years ago, a phone rang on someone else’s desk, in some other office, in some other building, with an angry customer on the other end demanding to know, “Where is my stuff?” And the deadline was born. After all, the customer had a point; they had been waiting two months for the stuff and it should have been done weeks ago. There needed to be a mechanism to make sure this never happened again. So it was decided that the stuff should never take more than 30 days to complete. Thirty days became the deadline for all the stuff. It was a safety net, set up to tell man agement that if the stuff goes past this point, clients are going to be upset. For a while, no one really worried about the deadline. A month to process the stuff seemed like plenty of time, and it would have been, if not for two laws no one can avoid forever. The first is Murphy’s Law: if anything can go wrong, it will go wrong. The second is the slightly more scientific Parkinson’s Law: work will expand to fill the time allotted. Think of all the Murphy’s Law–type things that happen to our stuff. Clients fail to provide us with what we need to process the stuff, the federal guide lines on stuff just changed to include all new stuff, so-in-so just quit and we learned they have been hiding the stuff in a closet for months and now we have to catch up on their stuff. If there is a problem that can occur with the stuff, we have seen it, had to fix it, and tried to do it within 30 days. While Murphy’s Law is an onslaught of outside influences making it harder to do the stuff, Parkinson’s Law is

counter-intuitive to our deadline as safety net thinking. What we hope for is a mark in time that work should not go past, but what we get is the finish line to the race, with workers natu rally expanding their efforts to that finish line. Parkinson’s Law presents a problem for deadlines, but it is only the start. When work extends to the deadline, and some work begins going over that date, thanks to Mr. Murphy, we begin to manage all work to the deadline. This means we begin to work the oldest stuff in order to have less “late” and new stuff has to wait until it gets closer to deadline. With more stuff waiting, more customers are calling asking where their stuff is, which robs us of our capacity to do the stuff… and so on, and so forth. Now all the stuff is finished around, or slightly after the deadline.

more of an internal ailment that slowly expands the work closer to the deadline and weakens our ability to fight off Murphy. For example, in college we are given a syllabus that clearly says we have a research paper due at the end of the term. We could just take the weekend and knock out the 20 or so hours it takes to do a great paper. Instead, we are likely to do a little research here and there, maybe outline a section or two a month out, and even a little writing, as the semester progresses. Then, three days before the paper is due, we buckle down. The work has expanded to the deadline. Then, Murphy hits you with a surprise left, the laptop gives you the blue screen of death, and you miss the deadline. The very idea that all work will naturally expand to the deadline is

Illustration by Chris Campbell


Policy & Practice Fall 2023

reach our standard of excellence. We move people from the front door to the back room in an effort to work the oldest part of the pile. Both of these steps end up adding to the pile: it’s like a perpetual work machine that creates more work than it is able to finish. We know that each pended determi nation adds an average of three touches, and nearly 45 minutes, to the total pro cessing time. Look no further than your pend rate to calculate how much time managing to deadline is costing you. Deadlines were never intended to drive work. They were intended to catch the few that were going on too long. However, in our effort to catch those, we unintentionally made every thing take longer and turned the safety net into the standard. So, can we just ditch the deadline? Unfortunately, we cannot—work cannot expand indefinitely. What we can change is the conversation we have about deadlines and return them to their original purpose. It begins with managing the work flow from the first interaction until the last. As leaders, we cannot afford just to look at the pile and manage the oldest item first. We must change our thinking to assure the work is always moving forward. There are three strategies to managing work this way. n First, know how long the work really takes! An eligibility decision does not take 240 hours to complete, and an assessment is not a 360-hour endeavor. That is just how many work hours we allot for them to be done. The difference between how As leaders, we cannot afford just to look at the pile and manage the oldest item first. We must change our thinking to assure the work is always moving forward.

long the work takes, versus the time we allot for it, is critical to the number one question leaders should be asking about work flow: How do 45 minutes become 30 days? How do 16 hours become a month and a half? The obstacles that keep us from doing the work in the expected time frame need to be removed. n Second, work the new work now! By working the new work as close to the beginning as possible, you assure that less work becomes old work. Yes, the pile needs to be worked, but if 50 applications come in the office a day, 50 should be going out, ideally the newest 50 possible. Change your management to address new work when it is new and fix the front door. n Third, get creative with your backlog! No one likes working overtime or giving up a Saturday to catch up. We particularly dislike it when we know we will just be behind again next month. However, willing to work with you to work the older work and get it off the books. When you fix the front door, you create hope that you can keep up, and with hope comes a renewed commitment to move the work along. Once you have caught up, never get behind again! You must constantly monitor performance so that on those days when you get 60 applica tions instead of 50 you can build in ways to knock them out while you are just 10 behind. Because 10 left unaddressed will kickstart the per petual work machine, and before you know it you’ll be right back to managing old work and thinking of the deadline as a standard. The true standard of excellence is that your work flows at the pace your clients and workers can support. It never sits waiting and it is not driven by a deadline. When work flows, deadlines are returned to their rightful place as a safety net, only there in case one slips and needs some extra attention. Bill Bott is the Director of Performance Improvement and the Child Welfare Practice Lead for Change & Innovation Agency (C!A®). if you get good at the second strategy, you will find workers

It is at this magic point where our once safety net becomes our new standard of excellence. If you get the stuff done by deadline you are doing great; if it goes past deadline, we need a coaching session and to set some new goals for your performance. Worse yet, since Murphy’s Law is completely out of our hands, you will now be held accountable to things completely out of your control. So how does this impact human services and what can we do about it? In child welfare there is often a 30–45 day deadline from the time a call comes in with an abuse or neglect allegation until we have a completed assessment of safety. Since it takes roughly 10–16 hours to conduct a quality assessment, 45 days should be the safety net that catches kids who have gone a month and a half without a decision. However, most agencies average right at, or slightly over their mandated deadline, which now has become the standard of excellence. Close before the deadline, you are a rock star; after the deadline, it will be reflected in your annual review. To make sure workers have every opportunity to be rock stars, we have used the following tools: 1. Rotate them out of getting new assessments so they can catch up on documentation; 2. Allow them to skip over some steps we would like to have done, but rec ognize there is no time for; 3. Build ticklers and notifications into our IT systems to remind them when they are getting behind; 4. Change the requirements to “close”; and 5. Extend the deadline and start the process from safety net to standard of excellence all over again. However, none of these things accomplish what we really want: doing the 10–16 hours of work in about 15 instead of 45 days. In benefits, there are so many eligi bility decisions nearing or at deadline that, in order to work with them, we are forced to make shortcuts to the work when it comes in. Over and over we “pend” new work so we have time to work on the older stuff and try to


Fall 2023 Policy & Practice

federal insights

Moving Forward: One Step Closer to WIC Online Shopping

The following is a Q&A with Rebecca Piazza , the Senior Advisor for Delivery at the U.S. Department of Agriculture’s Food and Nutrition Service. Q: The Food and Nutrition Service (FNS) is taking some major steps to modernize both the shopping experience for WIC (Special Supplemental Nutrition Program for Women, Infants, and Children) participants and also to continue some of the major changes that SNAP (Supplemental Nutrition Assistance Program) beneficiaries have seen. Tell us more about what the agency is doing. Rebecca Piazza: The way Americans shop and pay for food is changing, with options like online shopping, curbside pickup, and delivery becoming more popular. People like these options because they make food more accessible and ease the burden of busy family life. FNS believes WIC participants deserve an equitable and safe shopping experience equivalent to people shopping with other payment types. Online shopping is now available in all 50 states for SNAP ( https://www.fns.usda.gov/ news-item/fns-010.23) and eventu ally, WIC customers will have access to the same seamless experience of shopping from home. FNS has spon sored a pilot program to test online shopping for WIC and has proposed a rule—a necessary formal step to make improvements to the program—to remove barriers to online ordering, such as the requirement that partici pants complete WIC transactions in

SNAP can only be used to purchase eligible food items (not toiletries, for example, or hot, prepared foods), WIC works through a prescribed food package that may specify the brands and quantities of food items you can buy. So while there are differences between both SNAP and WIC, benefi ciaries of both programs have shared experiences and challenges when it comes to negotiating a shopping trip or deciding on their purchases. The proposed rule would encourage state agencies to issue electronic benefits remotely and mail Electronic Benefits Transfer (EBT) cards when possible, potentially reducing the number of required in-person visits to clinics by WIC participants. This is a con venience SNAP customers already have, as SNAP EBT cards are typically

the presence of a cashier. The rule also encourages state WIC agencies to allow for issuing benefits remotely, when possible, which saves participants the time of traveling to a clinic. Q: How would these changes benefit participants? RP: The current in-person WIC shopping requirements can be chal lenging for families, particularly those with limited access to trans portation, such as families who live in rural communities or who do not live near public transit. Even with transportation, shopping in person with infants or small children can be challenging and online shopping provides a convenient alternative for families. WIC also operates differently than other programs like SNAP. While

Illustration by Chris Campbell / Shutterstock


Policy & Practice Fall 2023

Q: Who is participating in the pilot and what does it entail? RP: FNS selected five states to participate in the pilot—Illinois, Louisiana, Massachusetts, Missouri, and Oklahoma—and applauds these state agencies for volunteering the time and energy to test a new way of serving SNAP participants. The participating states will receive assis tance with mobile-friendly software that streamlines SNAP EBT transac tions at the point of service, train and educate SNAP recipients on how to use the new technologies, and provide data to FNS so the pilots can be evaluated. Check out our press release at https://www.fns.usda.gov/ news-item/fns-006.23 Q: What does FNS hope to learn from the pilot? RP: Digital wallets are changing the way we pay in the checkout line. Many people now instinctively reach for their phones to “tap” for contact less payment instead of taking a card out of their wallet to swipe. The pilots will evaluate how quickly clients can start using their SNAP benefits (compared to having to wait for an EBT card to arrive in the mail) and how effectively mobile payments prevent fraud, such as EBT card skimming or card cloning. Feedback from all pilot participants, including SNAP households, will also be col lected. This information will help inform FNS of best practices for future guidance and policies related to these programs. That kind of information will also be shared with states and other administering agencies so they, too, can make use of the evidence based knowledge we gain. Q: How long until SNAP recipients in these five states can utilize the new technology? RP: These are complex pilots involving a broad network of parties carefully coordinating efforts; because of this, we estimate that this technology won’t be available to SNAP shoppers for 1.5 to 2 years. FNS will provide updates on our progress via our website and mailing lists, just as we routinely do with our numerous initiatives.

Q: Why is FNS revising the regulations to support online shopping for WIC? RP: FNS heard feedback from WIC participants and advocates loud and clear—and we agree: families who shop for food using WIC benefits should have the same convenient shopping options everyone else has. Q: What innovations are coming to SNAP? We know there have been some major gains made with SNAP Online Shopping. RP: That’s correct. All 50 states and the District of Columbia now offer SNAP Online purchasing. In January 2023, around 9.0 percent of SNAP redemptions occurred online. Around 190 retailer chains are now live with SNAP online purchasing, representing thousands of actual stores, and we’re onboarding more each month. To provide a comparison: In January 2023, more than 4.3 million SNAP households shopped online, which is a substantial increase in the reach of the program since March 2020, when about 35,000 SNAP households shopped online. FNS also recently awarded a $5 million grant (see https://www.fns.usda.gov/news-item/ fns-0016.22 ) to help smaller indepen dent stores offer online shopping. Q: So what are the new upcoming changes coming to SNAP? RP: With mobile payment tech nology continuing to grow in prevalence and capability, FNS is establishing a SNAP mobile payment pilot (MPP) to explore the technology’s potential for SNAP participants. SNAP benefits are currently issued electroni cally through EBT, which works like debit card technology. These pilots will help FNS test mobile payment technology in SNAP—allowing people to input their EBT card information onto a mobile device, like a cell phone, and make SNAP payments using their device. And while WIC is still testing its initial foray into electronic payments and shopping, it’s only a matter of time before both programs are offering the digital conveniences to our beneficiaries that they’ve grown accustomed to in their day-to-day shopping experiences.

mailed out and re-loaded with benefits each month electronically. Overall, the proposed changes would advance nutrition security by improving the WIC shopping experience, making it easier for WIC participants to access nutritious foods. Q: When will WIC participants be able to shop online? RP: While FNS believes families who shop for food using WIC benefits should have the same convenient shopping options everyone else has, this process will take time. We have gathered feedback to inform the final rule—an important step forward in that process. While FNS works on the final rulemaking, some state agencies and vendors will begin piloting online shopping for WIC using waivers through a partnership with the Gretchen Swanson Center for Nutrition and FNS. States or vendors that are interested in being early offerors of online shopping for WIC can reach out to the Gretchen Swanson Center for Nutrition for more information. Q: Are any of the temporary changes made during COVID proposed to be made permanent in this rule? RP: Yes. This rule would make per manent flexibilities that improved the experience of participants and simpli fied engagement with WIC—such as remote benefit issuance, transactions without the presence of a cashier, and virtual vendor monitoring. This proposed rule was informed by extensive engagement with the WIC community, including feedback on waivers of WIC regulatory require ments issued to WIC state agencies as part of USDA’s COVID-19 response. Nearly all WIC state agencies reported that certain COVID-19 waivers, including remote benefit issuance waivers, ultimately made WIC safer, more accessible, and more convenient for participants’ schedules. A list of WIC COVID waivers can be viewed at https://www.fns.usda.gov/disaster assistance/wic-covid-19-waivers. A broader list of FNS-wide COVID waivers can be viewed at https://www .fns.usda.gov/coronavirus-response


Fall 2023 Policy & Practice

research corner

By Elizabeth Bynum Sorrell and Ariel Kennan

Balancing Access and Security: The Digital Identity Landscape in Human Services

W hen people across the United States apply for human services programs or unemployment insur ance (UI) online, they may be asked to create a username and account, and in some cases, prove who they are by verifying their identity. The Digital Benefits Network (DBN), a project of the Beeck Center for Social Impact + Innovation at Georgetown University, has been conducting research on digital identity in public benefits since late 2022. 1 Specifically, we’ve examined how the processes of authentication and identity proofing show up during many people’s first touch point with a public benefits program: an initial application. 2 Agencies that administer public benefits applications online continually balance multiple potentially conflicting priorities around privacy, fraud pre vention, and accessibility to ensure equitable outcomes. While the overall data related to authentication and identity proofing obstacles are limited, it seems clear that how these processes are incorporated into applications and benefits management may shape access. Through our research and data, we seek to help you understand what’s happening across the sector and inform implementation in your state. Why Digital Identity Matters In public benefits applications, authentication processes can range from a quick signup with a username and password to more involved registra tion steps that require various pieces of information, including phone numbers, addresses, and other details. Some

and digital, remote access to benefits applications and information became more important than ever. 3 However, as human services and labor agencies worked hard to deliver essential benefits during a crisis, programs like UI were targeted by organized criminal groups and faced unprec edented levels of fraudulent claims. 4 The scale of fraud in UI programs indicated a clear need for program matic adjustments; however, efforts to curtail fraud and institute new safe guards and identity proofing checks also created accessibility and equity issues, and contributed to longer wait times and delays for applicants in systems that already faced backlogs. While the pandemic prompted new identity proofing requirements in state UI programs, we also know identity proofing had already been in place in some other programs.

systems also require further layers of security, including one-time pass words sent via SMS or email, security questions, or use of third-party authen ticator applications. Many applications check an individual’s self-asserted personal information with outside data bases. Applicants, however, may also be required to take active steps to verify their identities, for example through processes like knowledge-based verifi cation (KBV) that present users with a series of questions about their private information like credit history, or prompts to upload identity documen tation and selfies to be verified using facial recognition technologies. While the push to move applica tions and access online has been in progress for many years, participation in programs like the Supplemental Nutrition Assistance Program (SNAP) and UI rose during the pandemic,

Illustration by Chris Campbell


Policy & Practice Fall 2023

Landscape Research: Authentication and Identity Proofing The DBN recently produced a report and an open data set that catalogs digital authentication and identity verification practices in initial appli cations for SNAP, TANF, WIC, MAGI Medicaid, child care, and UI, across every state and territory, representing a total of 158 different applications. 2 A data-sharing partnership with Code for America facilitated the develop ment of these datasets, and supported work on their Benefits Enrollment Field Guide. 5 Through this work we learned a great deal about the land scape of online benefits applications, including the following highlights: Combined and standalone appli cations: In many states, SNAP, WIC, TANF, Medicaid, and child care are included on combined applications that allow users to apply for more than one benefit program at a time. Some states also have multiple appli cations for the same programs (e.g., SNAP/TANF in Mississippi or SNAP/ TANF/Medicaid in California), or offer simplified, stand-alone SNAP applications in addition to combined applications (e.g., kynect in Kentucky, or North Carolina’s ePASS). UI is not currently integrated with other program applications, but may share the same authentication services (e.g., UtahID, a state SSO which is used for the state’s unemployment insurance application and the state’s combined SNAP, TANF, Medicaid, and child care application). Authentication: A majority of applications (75%) across programs require applicants to log in or create an account to start an application. Of the 143 applications that require or allow account creation, either to start an application or later in the process, 93 of those account registra tion processes require users to include an email address. Requirements to include an email address during account registration are particularly important in some programs, like SNAP. Of the 39 SNAP applications that require accounts to start an application, 14 state application flows appear to require users to enter an email address, although some of these

Figure 1: Is an Email Address Required to Create an Account?

states have other online applications for SNAP that do not require users to create an account or provide an email address. The U.S. Department of Agriculture’s Food and Nutrition Service (FNS) has previously stated that applications for SNAP cannot require users to submit an email address, since doing so creates an additional condition of eligibility. 6 A total of 117 applications (81%) that have a log-in requirement or option also offer some kind of authentication security measures such as multifactor authentication or email validation links. These may help ensure accounts are secure, but depending on how such measures are deployed, they may also create additional steps or barriers for applicants and beneficia ries attempting to create or return to an account. Single sign-on: Currently 31 applications are using single sign-on options (SSOs) that enable applicants to use the same login for other gov ernment services in the state. SSOs are a growing service in many states, and some SSOs may be deployed with minimal program-specific consider ations and may also include identity verification. Identity verification in initial applications: Around a third of appli cations require or prompt some type of active identity proofing steps as part of an online application process. Identity proofing requirements are most common in UI online applica tions. Just over half of UI applications require some type of active identity

proofing steps to apply. Among other programs, identity proofing require ments or prompts were most common for applications that allow users to apply for MAGI Medicaid, with 46 percent of applications that include MAGI Medicaid requiring or prompting identity proofing steps. For UI, we found evidence that 22 labor agencies were using biometrics for identity proofing. We did not find evidence that biometrics are currently being used for identity proofing in any other safety net programs. When identity proofing prompts or requirements are included in online SNAP, TANF, WIC, MAGI Medicaid, or child care applications, they appear to use knowledge-based verification (KBV). The methods being used for identity proofing shape security and access. KBV questions—sometimes also referred to as remote identity proofing or RIDP—can create obstacles for people with limited credit history, as well as immigrant parents applying for services on behalf of their children. 7 Additionally, because of data breaches, answers to these types of ques tions, which include questions about cars owned, previous loans, or past addresses, may not actually be secret. The National Institute of Standards (NIST) has previously outlined limits on the use of KBV questions for identity proofing. In 2019, the U.S. Government Accountability Office also issued guidance recommending that several federal agencies discontinue

See Research Corner on page 44


Fall 2023 Policy & Practice

aphsa viewpoint

By Morgan McKinney and Jess Maneely

Data Sharing to Modernize Benefits Enrollment and Outreach: Insights from the CSNS Grant Program

I nnovative data sharing models are supporting state and local benefits access while paving the way for long term human services transformation. Projects funded under the Coordinating SNAP & Nutrition Supports (CSNS) grant program deployed three distinct data sharing models to drive better customer service, simplify access to the Supplemental Nutrition Assistance Program (SNAP) and connected benefits, and streamline program delivery workflows. These models were leveraged by CSNS teams to advance agency priorities ranging from customer-focused service delivery modernizations, to strengthened outcomes evaluation, to organizational culture enhancements. The imple mented models and lessons learned are detailed in the American Public Human Services Association’s (APHSA’s) new brief, Leveraging Cross-Program Data to Modernize Outreach and Enrollment in SNAP and Connected Benefits. 1 The issue brief presents user-friendly visual diagrams and narrative descrip tions of the three tested data sharing models and outlines considerations for agencies and partners embarking on data sharing initiatives. Here are top takeaways from this brief: Leveraging Data Sharing to Advance Priorities In their CSNS projects, human services agencies worked across systems and departments to analyze service gaps in the programs they

on the data fields collected by and exchanged between agencies, analyses can reveal trends related to participant characteristics and demographics such as age, race, location, languages spoken, and more. CSNS project teams in Michigan and Mecklenburg County, NC, demonstrated how these analyses can be deployed by agencies to develop and execute specific equity goals. For example, an analysis that reveals a wide participation gap among a population that primarily speaks a language other than English can be used to generate customer-focused improvements to program access for that specific population. Such was the case in Mecklenburg County where,

administer. CSNS sites then used those analyses to develop enrollment- and retention-focused interventions, like the Kansas team’s targeted client outreach to populations overrepre sented in enrollment gaps. Agencies also leveraged data sharing models to streamline referral and enrollment processes to eliminate steps customers need to take to apply for and receive needed services, exemplified by project teams in New Jersey and New Mexico deploying APIs, Decision Engines, and systems linkages to simplify WIC cer tification for families enrolled in SNAP and related programs. In administering the grant cohort, we at APHSA learned that depending

Image via Shutterstock


Policy & Practice Fall 2023

through the collected data fields, analyses revealed a large propor tion of Hispanic/Latino residents lacking access to nutrition assistance programs. Relatedly, the Hawai’i CSNS team demonstrated how agencies can use cross-program data analyses to more broadly understand trends across program areas and engage in multiagency ’Ohana Nui, 2 a multi generational approach to improving family well-being, by connecting families to nutrition supports and rep licating the data matching model to improve service delivery and customer experience. Overview of the Three CSNS Data Sharing Models 1. Match Cross-Program Data: This model involves sharing and matching data between agencies administering different programs to identify eligible participants who are not enrolled in all eligible services. It allows agencies to target outreach to these individuals, streamlining access to benefits. 2.Aggregate Cross-Agency Datasets in Data Lake: In this model, data from multiple systems are aggre gated in a centralized database or “data lake.” This allows agencies to perform more robust cross-program data analysis, providing deeper insights to inform strategic planning and evidence-based projects. 3.Automate Cross-Program Referrals: Data are shared auto matically between agencies when a customer interacts with one agency, triggering a referral to other eligible programs. While this model offers swift action for enrollment, it may not provide as comprehensive ana lytics as the previous two models.

n Analytics: Data analysts and sci entists uncover trends and gaps in program access to inform modern ization efforts. n Monitoring & Evaluation: Staff responsible for program monitoring and evaluation tracks key perfor mance indicators to assess impact. n Customer Service & Engagement: Specialized staff develops high-impact customer-facing interventions. n User Research: User researchers ensure program enhancements meet user needs and are user friendly. n Data Architecture: Data architects optimize data collection and storage for compatibility across agencies. n Data Visualization: Staff special izing in data visualization creates tool for advancing human services agencies’ priorities and achieving better outcomes for participants. By visualizing and describing the tested data sharing models, this new brief aims to demystify the process for non technical professionals and leaders. Emphasizing the core expertise areas and enabling factors, agencies can embark on successful data sharing initiatives to drive innovation and improve programmatic outcomes. To read the full brief and more, please visit APHSA’s Coordinating SNAP & Nutrition Supports webpage. 3 Reference Notes 1. https://bit.ly/3PavfrT 2. ’Ohana Nui is a proven approach that capitalizes on Hawai’i’s unique multigenerational family structure and provides a framework for human services delivery that positions whole families for a chance at greater well-being. See https://humanservices.hawaii.gov/blog/ ohana-nui-kicks-off/ 3. https://aphsa.org/APHSA/Policy_and_ Resources/csns.aspx clear and understandable data visuals to assess project impact. The CSNS grant program has shown that data sharing can be a powerful

Leveraging Cross-Program Data to Modernize Outreach and Enrollment in SNAP and Connected Benefits

Download this brief at https://bit.ly/3PavfrT

implementing technology-oriented tasks successfully. These collabora tions ensure that the right expertise is harnessed to efficiently execute data sharing initiatives. Equally important are clear use cases and specific plans for data analysis. Alongside setting data sharing goals, agencies must develop concrete strategies for ana lyzing the shared data effectively. By applying insights from the analyses, agencies can introduce innovations that improve their processes and prac tices, thereby enhancing the overall efficacy of their programs. To execute successful data sharing ini tiatives, agencies require expertise in: n Legal and Policy: Early engagement of policy staff and legal councils is essential for executing robust data sharing agreements. n Program Operations: Staff involved in program operations must be rep resented on project teams to ensure meaningful impact. n Data Systems: Data stewards play a crucial role in ensuring data compat ibility between agencies. Core Expertise Areas Required for Data Sharing Initiatives

Enabling Factors for Successful Data Sharing Initiatives

The success of data sharing ini tiatives hinges on several critical factors. First and foremost, strong leadership commitment to cross program coordination is essential. Additionally, forming robust relation ships with reliable vendors and subject matter experts plays a pivotal role in

Morgan McKinney is a Project Associate for Process Innovation at APHSA.

Jess Maneely is the Assistant Director of Process Innovation at APHSA.


Fall 2023 Policy & Practice

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