SUPPLEMENTAL 

NUTRITION 

ASSISTANCE 

PROGRAM

More Information on 

Promising Practices 

Could Enhance 

States’ Use of Data 

Matching for Eligibility 

Report to the Chairman, Committee on 

Agriculture, House of Representatives

October 2016

GAO-17-111

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-111, a report to the 

Chairman, Committee on Agriculture, House 

of Representatives

October 2016

SUPPLEMENTAL NUTRITION ASSISTANCE 

PROGRAM

More Information on Promising Practices 

Could Enhance States' Use of Data Matching 

for Eligibility 

What GAO Found

In administering the Supplemental Nutrition Assistance Program (SNAP), all 

state SNAP agencies verify household income by conducting multiple data 

matches, which they find useful for detecting potential discrepancies related to 

SNAP eligibility (see figure below), according to GAO’s survey of all state SNAP 

directors. Most states reported that particularly useful data matches provided 

current information, can be accessed in real-time (i.e., immediately), and are 

from original sources. Some data sources for unearned income, including from 

the Social Security Administration, have all these characteristics. Data matches 

for earned income lacked one or more of these useful characteristics, but can be 

used as leads to follow up on with households or employers. 

Examples of Data Matching for Supplemental Nutrition Assistance Program (SNAP) Eligibility

States identified challenges with following up on data matches and with the costs 

of data matching. The issue states cited most often in GAO’s survey as very or 

extremely challenging was the need to conduct follow-up for data that are not 

sufficiently recent, accurate, or complete, which can be cumbersome and timeconsuming. Officials GAO interviewed in several states were implementing ways 

to manage follow-up. Over one-third of states also reported that costs associated 

with accessing certain commercial data to verify earnings were very or extremely 

challenging, with some states limiting their use of these data due to costs. 

The Department of Agriculture’s (USDA) Food and Nutrition Service (FNS), 

which oversees the SNAP program, has efforts underway to promote data 

matching to improve program administration, but may be missing some 

opportunities. For example, FNS has initiated pilot or demonstration projects to 

improve program integrity or service to households. However, FNS has not 

actively collected or disseminated information on promising data matching 

practices, consistent with federal internal controls. Further, 32 states reported in 

GAO’s survey that more information from FNS on promising data matching 

practices would be extremely or very useful. With more information, states will 

have increased awareness of other potentially useful or cost-effective practices. 

In addition, FNS has begun to explore ways to help states reduce the cost of

using commercial data, but has not systematically analyzed spending and SNAP 

needs for these data to consider how to best leverage government buying power 

through strategic sourcing practices. Without this analysis, FNS may not be able 

to identify the best ways to lower data matching costs.

View GAO-17-111. For more information, 

contact Kay E. Brown at (202) 512-7215 or 

brownke@gao.gov

Why GAO Did This Study

During fiscal year 2015, state SNAP 

agencies provided about 46 million 

low-income individuals approximately 

$70 billion in federally funded benefits, 

and an additional $7.6 billion in federal 

and state funds was spent in 

administering the program in fiscal 

year 2014, according to the most 

recent data. SNAP agencies use data 

matching to verify eligibility information

about applicant or recipient 

households, including their incomes, 

as well as to help detect improper 

payments. GAO was asked to review 

issues related to data matching in 

administering SNAP. 

This report examines (1) the extent to 

which states use data matching to 

obtain income information and find 

these matches useful for SNAP 

eligibility, (2) challenges states 

experience using data matching, and 

(3) actions FNS has taken to promote 

data matching for SNAP. GAO

surveyed all state SNAP directors for a 

100 percent response rate and 

interviewed state officials in six states 

that varied in caseload size, 

geography, and other criteria, and 

visited local offices in three of these 

states. GAO also reviewed relevant 

federal laws, regulations, and agency 

documents and interviewed agency 

officials. 

What GAO Recommends

GAO recommends that FNS

disseminate information on promising 

practices to state SNAP agencies, and 

analyze spending and data needs as it 

explores ways to reduce costs of using 

commercial data. FNS agreed with 

these recommendations
Page i GAO-17-111 Supplemental Nutrition Assistance Program

Letter 1

Background 4

States Reported Conducting Numerous Data Matches for SNAP 

and the Matches They Find Most Useful Provide Real-Time 

Access to Recent Data 10

States Reported Challenges with Following Up on Data Matches, 

Using Data Matches for Multiple Programs, and Costs 17

FNS Has Efforts Underway to Promote the Use of Data Matching 

to Improve SNAP, but May Be Missing Some Opportunities 28

Conclusions 38

Recommendations for Executive Action 39

Agency Comments and Our Evaluation 39

Appendix I GAO Contact and Staff Acknowledgements 41

Tables

Table 1: Common Sources of Countable Income for Households 

Receiving Supplemental Nutrition Assistance Program 

(SNAP) Benefits in Fiscal Year 2014 6

Table 2: Federally Required Data Matches for Determining 

Supplemental Nutrition Assistance Program (SNAP) 

Eligibility 9

Table 3: Number of State Supplemental Nutrition Assistance 

Program (SNAP) Agencies That Reported Using Data 

Matches for Income Information for SNAP Eligibility 10

Table 4: Characteristics of Selected Data Sources of Earnings 

Information Used for the Supplemental Nutrition 

Assistance Program (SNAP) 20

Table 5: Food and Nutrition Service (FNS) Demonstration Projects 

and Pilots That Use Data Matching to Improve 

Supplemental Nutrition Assistance Program (SNAP) 

Program Efficiencies 29

Contents
Page ii GAO-17-111 Supplemental Nutrition Assistance Program

Figures

Figure 1: Examples of the Use of Data Matching to Determine 

Eligibility and Benefit Amounts for the Supplemental 

Nutrition Assistance Program (SNAP) 7

Figure 2: Reported Usefulness of Common Income Data Matches 

That States Conduct to Determine Eligibility for the 

Supplemental Nutrition Assistance Program (SNAP) 16

Figure 3: Data Challenges States Reported with Data Matching 

Conducted to Determine Eligibility for the Supplemental 

Nutrition Assistance Program (SNAP) 19

Figure 4: Illustration of Verification Processes for a Household that 

Applies for or Receives Both Supplemental Nutrition 

Assistance Program (SNAP) and Medicaid Benefits 

When the Department of Health and Human Services’ 

Federal Data Services Hub Is Used for Medicaid 

Verification 25

Figure 5: Cost-Related Challenges States Reported with Data 

Matching that They Conduct to Determine Eligibility for 

the Supplemental Nutrition Assistance Program (SNAP) 27
Page iii GAO-17-111 Supplemental Nutrition Assistance Program

Abbreviations

ACF Administration for Children and Families

BEER Beneficiaries Earnings Exchange Record

CMS Centers for Medicare & Medicaid Services

FNS Food and Nutrition Service

HHS Department of Health and Human Services

NAC National Accuracy Clearinghouse 

NDNH National Directory of New Hires

OASDI Old-Age, Survivors, and Disability Insurance

OCSE Office of Child Support Enforcement

PARIS Public Assistance Reporting Information System

PPACA Patient Protection and Affordable Care Act

SNAP Supplemental Nutrition Assistance Program

SSA Social Security Administration

SSI Supplemental Security Income

TANF Temporary Assistance for Needy Families

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-111 Supplemental Nutrition Assistance Program

441 G St. N.W.

Washington, DC 20548

October 19, 2016

The Honorable K. Michael Conaway

Chairman

Committee on Agriculture

House of Representatives

Dear Mr. Chairman:

During fiscal year 2015, the Supplemental Nutrition Assistance Program 

(SNAP), previously known as the Food Stamp Program, provided nutrition 

assistance to almost 46 million low-income individuals each month for a 

total of approximately $70 billion in federally-funded benefits for the year. 

The Food and Nutrition Service (FNS) in the U.S. Department of 

Agriculture (USDA) administers SNAP at the federal-level, in partnership 

with states. According to the most recent data in fiscal year 2014, an 

additional $7.6 billion—divided between federal and state funds—was 

spent on administering the program that year, a large portion of which 

was spent on certification procedures, such as collecting and verifying 

information to determine whether households were eligible and, if so, for 

what benefit amount. Federal laws and regulations require state SNAP 

agencies to verify various aspects of SNAP eligibility; however, income 

information can be particularly difficult to obtain and verify as correct. For 

example, based on the most recent available data from fiscal year 2013 

on improper payments made in the SNAP program, errors related to 

household income were, by far, the largest cause of improper payments 

over other causes of error, such as those related to household resources, 

deductions, or non-financial information.1 To help avoid improper 

payments and improve other aspects of program administration, SNAP 

agencies use data matching— the process of matching information about 

applicants and recipients against various data sources—as part of their 

routine eligibility processes. In recent work, we have also reported that 

 1

USDA measures sources of error in its quality control system. See USDA, Supplemental 

Nutrition Assistance Program Quality Control Annual Report Fiscal Year 2013, (March 

2015). We recently testified on the methods used to calculate SNAP improper payment 

rates. GAO, Supplemental Nutrition Assistance Program: Policy Changes and Calculation 

Methods Likely Affect Improper Payment Rates, and USDA Is Taking Steps to Help 

Address Recipient Fraud, GAO-16-708T, (Washington, D.C.: July 6, 2016).

Letter
Page 2 GAO-17-111 Supplemental Nutrition Assistance Program

SNAP agencies use data matching as one of various tools to detect 

potential SNAP cases involving fraud.2

You asked GAO to examine the use of data matching or sharing to 

administer the SNAP program. In this review, we answered the following 

questions:

1. To what extent do states use data matching to obtain income 

information for SNAP eligibility purposes and how useful do they find 

these matches?

2. What challenges, if any, do states experience with their use of data 

matching?

3. What actions has FNS taken to promote data matching and what 

additional actions, if any, are needed?

To address these questions, we collected and analyzed information using 

several methods. We administered a survey by e-mail to state SNAP 

directors of all 50 states and the District of Columbia from February to 

May 2016 to obtain information on all three research questions.3 We 

obtained a 100 percent response rate. While we generally did not validate 

specific information administrators reported through our survey, we 

reviewed their responses and conducted follow-up, as necessary, to 

determine that their responses were complete, reasonable, and 

sufficiently reliable for the purposes of this report. As part of our survey 

development, we pretested the questionnaire with four states, had 

internal and external experts review it, and incorporated comments as 

appropriate. Once we received the survey responses, they were 

subjected to data entry, processing, and analysis. We verified the 

accuracy at each step in the process with independent reviews. To ask 

for elaborations on survey responses and other related questions, we 

conducted semi-structured phone interviews with state SNAP officials 

 2

GAO, Supplemental Nutrition Assistance Program: Enhanced Detection Tools and 

Reporting Could Improve Efforts to Combat Recipient Fraud, GAO-14-641, (Washington, 

D.C.: Aug. 21, 2014). Data matching is also a practice, among others, mentioned in more 

recent GAO work on managing fraud in government programs. See GAO, A Framework 

for Managing Fraud in Federal Programs, GAO-15-593SP, (Washington, D.C.: July 2015).

3

We used a form-fillable document that respondents could return electronically after 

marking checkboxes or entering responses into open answer boxes. In this report, District 

of Columbia is referred to as a state. 
Page 3 GAO-17-111 Supplemental Nutrition Assistance Program

from six states that represented 31 percent of the national SNAP 

caseload in fiscal year 2014 (California, Florida, Massachusetts, Texas, 

Virginia, and Washington). Criteria for states we selected included 

caseload size, geographic location, whether SNAP is state or countyadministered, and participation in relevant demonstrations or pilots. We 

also visited two to three local offices in three of these states (California, 

Virginia, and Washington) to obtain perspectives from local program 

managers and eligibility staff and to observe eligibility processes and 

systems. Our selection criteria for localities within each state included 

variation in population density and geographic location. The information 

gathered from interviews with officials from selected states and localities 

is not generalizable to all states and localities and is meant to provide 

illustrative examples. To obtain pertinent federal-level information, we 

reviewed relevant federal laws, regulations, guidance, and other 

information and interviewed federal agency officials. Specifically, we 

interviewed officials from FNS about pertinent initiatives, as well as 

oversight, technical assistance, and guidance related to data matches. 

We spoke with officials in FNS’ national office as well as a 

nongeneralizable sample of three of its seven regional offices.4 To assess 

FNS’ efforts, we reviewed prior GAO work on collaboration and strategic 

sourcing and federal internal control standards. We also interviewed 

officials and reviewed information from the Department of Health and 

Human Services (HHS)’ Administration for Children and Families (ACF) 

and Centers for Medicare & Medicaid Services (CMS), as well as the 

Social Security Administration (SSA) to obtain information on relevant 

data matches and other data matching or data sharing initiatives. 

Additionally, we interviewed representatives with expertise on SNAP from 

relevant national trade associations, private service providers, and 

research or client advocacy organizations.

We conducted this performance audit from August 2015 to October 2016 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

 4

The three regional offices were the Northeast, Southeast, and Western regions, which we 

selected because they covered four of our six selected states.
Page 4 GAO-17-111 Supplemental Nutrition Assistance Program

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The goal of SNAP is to help low-income individuals and households 

obtain a more nutritious diet by supplementing their income with benefits 

to purchase allowable food items. The overarching rules governing SNAP 

are set at the federal level. Accordingly, FNS is responsible for 

promulgating program regulations and ensuring that state officials 

administer the program in compliance with program rules. The states, or 

in some cases counties, administer the program by determining whether 

households meet the program’s eligibility requirements, calculating 

monthly benefits for qualified households, and issuing benefits to 

participants on an electronic benefits transfer card. States are also 

allowed flexibility in establishing some state-specific policy modifications, 

such as through state options.5

One financial criterion for SNAP eligibility and benefit amount involves 

household income, which can come from various sources, including 

earned income, such as wages and salaries, and unearned income, such 

as payments from other government programs (see table 1).6 Generally,

under federal law, a household’s gross income cannot exceed 130 

percent of the federal poverty level ($2,628 per month for a family of four 

for most states in fiscal year 2016).7 The household’s net income, which 

is determined by deducting certain expenses from gross income, such as 

certain dependent care and shelter costs, cannot exceed 100 percent of 

the federal poverty level ($2,021 per month for a family of four for most 

 5

State policy options are flexibilities set forth in federal law or regulation that permit states 

to use alternative procedures when administering their SNAP program. 

6

In this report, we focused on earned income and unearned income from government 

programs. We did not look at other types of unearned income, such as from alimony or 

interest and dividend payments.

7

SNAP’s income eligibility criteria are largely laid out in federal laws and regulations, 

although some variation at the option of individual states is allowed. 

Background

Determining SNAP 

Eligibility and Benefits
Page 5 GAO-17-111 Supplemental Nutrition Assistance Program

states in fiscal year 2016).8 Net income is used in determining the 

household’s benefit amount, subject to maximum benefit limits. Generally, 

eligibility is based on various household circumstances, including income. 

After eligibility is established, households are certified to receive SNAP 

for periods ranging from 1 to 24 months depending upon household 

circumstances and state-selected policy options. Households are required 

to report certain changes during the certification period which can affect 

their eligibility and benefit amounts. Once the certification period ends, 

there is a recertification process whereby households reapply for benefits 

and eligibility and benefit levels are redetermined.

8

According to information from FNS, many state SNAP agencies have implemented a 

state option known as broad-based categorical eligibility, which allows states to make 

households that receive non-cash services funded by Temporary Assistance for Needy 

Families (TANF), such as a toll-free number to obtain program information or an 

informational brochure, automatically eligible for SNAP. Through this option, the TANF 

non-cash service requirements for income and assets become those relevant for SNAP, 

and we previously reported that this resulted in some states effectively removing or 

increasing SNAP asset limits, raising the SNAP gross income limit, and removing the 

SNAP net income limit. For more information, see GAO, Supplemental Nutrition 

Assistance Program: Improved Oversight of State Eligibility Expansions Needed, 

GAO-12-670 (Washington, D.C.: July 26, 2012). 
Page 6 GAO-17-111 Supplemental Nutrition Assistance Program

Table 1: Common Sources of Countable Income for Households Receiving 

Supplemental Nutrition Assistance Program (SNAP) Benefits in Fiscal Year 2014 

Income Source

Percentage of 

SNAP Households 

with Income Source

Unearned Income

Old-Age, Survivors, and Disability Insurance (“Social Security”) 25 

Supplemental Security Income 20

Child support enforcement payments 8

Temporary Assistance for Needy Families (cash assistance) 6

General assistance 3

Unemployment insurance 2

Earned Income

Wages and salaries 28

Self-employment 4

No Income 22

Source: Mathematica Policy Research, Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2014, 

Report No. SNAP-15-CHAR, prepared at the request of U.S. Department of Agriculture’s Food and Nutrition Service, December 2015. | 

GAO-17-111. 

Note: These numbers are based on a sample of SNAP households from program quality control data. 

This is not a complete list of income sources. Also, households may receive income from more than 

one source. For example, of the 25 percent of households that received Old-Age, Survivors, and 

Disability Insurance, 8 percent also received Supplemental Security Income, according to this report. 

The sources of income are explained in part by the characteristics of household members. According 

to this report, in fiscal year 2014: about 44 percent of SNAP households included children, 19 percent 

included at least one elderly individual, and about 20 percent included at least one non-elderly 

individual with disabilities. Households may have more than one characteristic.

SNAP agencies use data matching to obtain information about 

households’ income, verify information that households provide when 

they initially apply or recertify for benefits, or identify potential 

discrepancies. For households that already receive SNAP benefits, data 

matching can provide information about changes in income that affect 

households’ eligibility or benefit levels (see fig. 1). In certain cases, data 

matching can take the place of traditional forms of verifying information 

provided by applicants, such as requiring households to submit 

documentation (e.g. pay stubs or a child support agreement) or making 

collateral contacts, such as a phone call to an employer.

Use of Data Matching for 

Eligibility
Page 7 GAO-17-111 Supplemental Nutrition Assistance Program

Figure 1: Examples of the Use of Data Matching to Determine Eligibility and Benefit Amounts for the Supplemental Nutrition 

Assistance Program (SNAP)

Certain federal policies that help protect individuals from inappropriately 

losing benefits affect whether SNAP agencies need to take additional 

steps to verify information from a data match. Federal law generally 

requires that government agencies administering benefits using matching 

programs verify information from matches before reducing or terminating 

benefits unless specified government entities have determined that there 

is a high degree of confidence that the information is accurate.9 For 

SNAP, FNS defines some data matches as “verified upon receipt,” if the 

match is with a primary or original source of the data (such as information 

9

5 U.S.C. § 552a(p). Federal agencies with computer matching programs are required to 

have a data integrity board which oversees computer matching activities. For additional 

information on these and other requirements, see GAO, Computer Matching Act: OMB 

and Selected Agencies Need to Ensure Consistent Implementation, GAO-14-44, 

(Washington, D.C.: Jan. 13, 2014). Also, for other examples of federal privacy and 

confidentiality requirements for human services programs, see GAO, Human Services: 

Sustained and Coordinated Efforts Could Facilitate Data Sharing While Protecting Privacy,

GAO-13-106, (Washington, D.C.: Feb. 8, 2013), table 2.
Page 8 GAO-17-111 Supplemental Nutrition Assistance Program

on a government benefit provided by the administering agency) and is not 

questionable. An example is a match with SSA that provides information 

on the amount of Old-Age, Survivors, and Disability Insurance (OASDI) 

benefits a household receives. Eligibility workers can use this information 

for eligibility determinations without taking additional steps to verify that 

the data are accurate, according to FNS guidance. In contrast, data from 

a secondary source (not verified upon receipt) require additional 

verification before they can be used in eligibility determinations. For 

instance, state quarterly wage data are considered a secondary source 

because they are a compilation of earnings data submitted by employers 

to the state workforce agency. Accordingly, the SNAP caseworker must 

take additional steps, such as contacting an employer or requesting 

paystubs from the client, to verify that information from that match is 

accurate before using it to change a household’s eligibility status or 

benefit amount. Failing to verify information from secondary sources can 

cause eligible households to lose benefits if caseworkers act on 

inaccurate information. Alternatively, if caseworkers do not follow up to 

verify information from secondary sources, they may miss opportunities to 

reduce or prevent improper payments. Regardless of whether the data 

are from primary or secondary sources, SNAP agencies are required to 

notify the household of the actions they intend to take and provide the 

household with an opportunity to request a fair hearing prior to any 

adverse action.10

Federal law and regulations require states to conduct certain data 

matches for SNAP eligibility, including three matches that provide nonincome related information on people who may be incarcerated, 

deceased, or otherwise disqualified from receiving SNAP benefits (see 

table 2).11 Most recently, the Agricultural Act of 2014 required SNAP 

10 7 C.F.R. § 273.13.

11We looked at the use of these matches in selected states in GAO-14-641 on SNAP 

recipient fraud. The USDA Inspector General also looked at several of these matches in a 

2012 report. See USDA, Office of the Inspector General, Analysis of the FNS’ 

Supplemental Nutrition Assistance Program Fraud Prevention and Detection Efforts, Audit 

Report 27002-0011-13 (Washington, D.C: September 2012). 
Page 9 GAO-17-111 Supplemental Nutrition Assistance Program

agencies to conduct a match with the National Directory of New Hires 

(NDNH) to verify employment data.12

Table 2: Federally Required Data Matches for Determining Supplemental Nutrition Assistance Program (SNAP) Eligibility

Laws and 

Regulations

Name and description of match 

Income-related

7 U.S.C. § 

2020(e)(24) and 7 

C.F.R. § 272.16a

HHS’ National Directory of New Hires: SNAP agencies must compare employment information from the 

national file on new hires at certification (when the household applies) and recertification to determine eligibility 

status and correct benefit amount for SNAP applicants and participants. 

Other

7 U.S.C. § 

2020(e)(18) and 7 

C.F.R. § 272.13

SSA’s Prisoner Verification System: To ensure that individuals incarcerated in a federal, state, or local 

facility for more than 30 days do not receive benefits, SNAP agencies must conduct this match at certification 

and recertification.

7 U.S.C. § 2020(r) 

and 7 C.F.R. § 

272.14

SSA’s Death Master File: To ensure that deceased individuals do not receive benefits, SNAP agencies must 

conduct this match at the time of certification and recertification, and no less than every 12 months.

7 C.F.R. § 

273.16(i)(4)(i)

FNS’ Electronic Disqualified Recipient System: To ensure that certain people who were previously 

disqualified from receiving SNAP benefits do not receive benefits, SNAP agencies must screen all program 

applicants prior to certification.

Source: GAO review of relevant laws and regulations as well as information from U.S. Department of Agriculture’s Food and Nutrition Service (FNS). | GAO-17-111

Note: HHS is the Department of Health and Human Services; SSA is the Social Security 

Administration.

a

FNS issued an interim final rule on this requirement in January 2016. However, state agencies were 

directed to implement this match in 2014, based on section 4013 of the Agricultural Act of 2014. 

12Pub. L. No. 113-79, § 4013, 128 Stat. 649, 793. The Agricultural Act of 2014 also 

included separate requirements for states to use an immigration status verification system, 

as well as an income and eligibility verification system. FNS officials told us that the 

department has not yet proposed implementing regulations or guidance for these 

requirements, and we do not discuss these further in the report. 
Page 10 GAO-17-111 Supplemental Nutrition Assistance Program

In response to our survey, all states reported conducting multiple data 

matches for income information that they use to determine SNAP 

eligibility. These matches gather information from federal, state, and 

commercial data sources on earned income from employment or selfemployment, or unearned income from other government benefit 

programs (see table 3).

Table 3: Number of State Supplemental Nutrition Assistance Program (SNAP) Agencies That Reported Using Data Matches for 

Income Information for SNAP Eligibility

Description of match or information provided

Federally 

required 

matcha Commercial 

data source

Earned 

income 

data 

Unearned 

income 

data 

Number 

of 

states 

using

National data sources

Old Age, Survivors, and Disability Insurance (OASDI) income 

information can be obtained from multiple data matches with the Social 

Security Administration (SSA).b - - - ✔

51

Supplemental Security Income (SSI) information comes from several 

direct data matches with SSA.c - - - ✔ 51

The Work Number® is a commercial verification service operated by 

Equifax Inc. that provides payroll information from participating 

employers for a fee. 

- ✔ ✔ - 

45

Public Assistance Reporting Information System (PARIS) Interstate 

file from the Department of Health and Human Services (HHS) provides 

information on individuals’ benefit receipt in other states.

- - - ✔

40

States Reported 

Conducting 

Numerous Data 

Matches for SNAP 

and the Matches 

They Find Most 

Useful Provide RealTime Access to 

Recent Data

All States Conduct a 

Range of Data Matches 

for SNAP, and Most States 

Have Implemented the 

Recently Required New 

Hire Data Match
Page 11 GAO-17-111 Supplemental Nutrition Assistance Program

Description of match or information provided

Federally 

required 

matcha Commercial data source

Earned 

income 

data 

Unearned 

income 

data 

Number 

of 

states 

using

National Directory of New Hires (NDNH) New Hire file is a national 

database of employer reports of newly hired employees collected from 

state directories of new hires and from federal agencies by HHS.

✔ - ✔ - 

39d

PARIS federal and Veterans Affairs files include data from 

Department of Defense and the Office of Personnel Management on 

earnings or retirement income and benefits received from the 

Department of Veterans Affairs. 

- - ✔ ✔

31

Beneficiary Earnings Exchange Record (BEER) from SSA provides 

information on individuals’ earned income based on the Internal 

Revenue Service’s earnings and tax data, including earnings from selfemployment and employment in other states.

- - ✔ - 

24

NDNH Unemployment Insurance file provides information on 

individuals who received or applied for unemployment benefits. HHS 

collects this data from state workforce agencies.

- - - ✔

9

NDNH Quarterly Wage file include employees’ wage amounts collected 

by HHS from state workforce agencies or federal agencies. - - ✔ - 4

State-level data sources

Unemployment insurance information from direct data matches with 

state workforce agencies provides benefit information. - - - ✔ 49

Child support payment information from direct data matches with state 

enforcement programs provide information on child support payments 

made or received. 

- - - ✔

47

State quarterly wage data provides information from employers 

covered by state unemployment insurance programs. - - ✔ - 45

Income information verified by other programs, such as Temporary 

Assistance for Needy Families (TANF) programs, for their own eligibility 

or benefit determinations.

- - ✔ ✔

42

State directories of new hires are databases of employer reports of 

newly hired employees collected by states. - - ✔ - 36
Page 12 GAO-17-111 Supplemental Nutrition Assistance Program

Description of match or information provided

Federally 

required 

matcha Commercial data source

Earned 

income 

data 

Unearned 

income 

data 

Number 

of 

states 

using

Day care license databases provide information on day care workers’ 

earnings. - - ✔ - 11

State tax filings provide information on individuals’ earned income and 

unearned income. - - ✔ ✔ 7

Legend: ✔ = yes, - = no

Source: Counts of states using data matches based on survey responses from state SNAP agencies and information from HHS’s Office of Child Support Enforcement (OCSE). Data match characteristics 

based on GAO analysis of information from HHS, SSA, U.S. Department of Agriculture’s Food and Nutrition Service, and Equifax. | GAO-17-111

a

State SNAP agencies are required to match against the NDNH. Not all states had implemented the 

match at the time of our review. FNS officials said that each of the states that have not yet 

implemented the match are working towards implementation and FNS is monitoring states’ progress. 

Also, other federally required matches for SNAP, according to FNS, are for non-income related 

information, which are not represented in this table.

b

OASDI matches include the State On-Line Query, State Verification and Exchange System, and 

Beneficiary and Earnings Data Exchange. 

c

SSI matches include State On-Line Query, State Verification and Exchange System, and State Data 

Exchange.

d

This number is based on survey responses as well as the most recent available information from 

OCSE that includes states that requested the NDNH New Hire data in August 2016.
Page 13 GAO-17-111 Supplemental Nutrition Assistance Program

As of September 2016, 39 state SNAP agencies conduct the federallyrequired match with the NDNH New Hire data (see sidebar), according to 

our survey and information from HHS/ACF’s Office of Child Support 

Enforcement (OCSE) on states’ progress in implementing the match.13 

FNS required states to implement this match for SNAP eligibility purposes 

by September 21, 2014; however, some states have experienced 

implementation delays, and FNS officials said that each of the 12 

remaining states is working towards implementing the match. States that 

experienced implementation delays had not yet developed the capacity to 

conduct the NDNH New Hire match or faced competing priorities for 

resources, according to FNS, OCSE, and state officials. For example, two 

of the remaining states said they will implement the match in coordination 

with efforts to upgrade or replace SNAP eligibility systems. Two other 

states said in their survey responses that a lack of resources has delayed 

their implementation of the match. FNS monitors states’ progress in 

implementing the required NDNH New Hire match and promotes states’

compliance by reviewing monthly reports on states’ matching activities 

and following up with states as needed, according to FNS officials. 

Specifically, FNS officials reported that the national office in Washington, 

D.C., reviews monthly reports from OCSE on states matching activities 

and forwards information to FNS regional offices for follow up as 

needed.14

 13We reviewed state survey responses and information from OCSE to determine the 

number of states that have implemented this match. Subsequent to our survey, we 

updated the count of states who have implemented the NDNH New Hire match to include 

all states that submitted records for the match in August 2016 based on the most recent 

available information from OCSE. 

14In addition, FNS officials said that they monitor states’ NDNH matching activities as part 

of management evaluation case reviews and require states to develop corrective action 

plans if FNS finds that required matching activities were not carried out.

National Directory of New Hires (NDNH)

The Department of Health and Human 

Services’ Office of Child Support 

Enforcement compiles information from 

state and federal agencies into three 

separate files that comprise the NDNH. 

The New Hire file contains information on 

newly hired employees nationwide as 

reported by employers to each state 

directory of new hires and as reported by 

federal agencies directly to the NDNH.

The Quarterly Wage file contains quarterly 

earnings amounts for individual employees 

nationwide collected from state workforce 

agency and federal agency records.

The Unemployment Insurance file contains 

information on individuals who received or 

applied for unemployment benefits 

nationwide, as reported by state workforce 

agencies

Source: GAO analysis of Department of Health and Human

Services Guide to the National Directory of New Hires. | 

GAO-17-111
Page 14 GAO-17-111 Supplemental Nutrition Assistance Program

Data matches with primary sources, those that allow for real-time access 

to data, and those that provide up-to-date information are useful because 

they enable efficient and accurate SNAP eligibility determinations, and 

matches that combine these characteristics are particularly useful, 

according to our analysis of state survey responses. Officials from SNAP 

agencies we interviewed explained that these data matching 

characteristics streamlined the eligibility determination process for 

caseworkers and households.

• Data matches with primary data sources are more useful because 

caseworkers can use the information without having to conduct 

additional verification, according to officials from each of the six state 

SNAP agencies we interviewed.

• Matches that can be accessed in real-time, or immediately upon 

request, can help caseworkers make determinations more quickly or 

eliminate the need to revisit eligibility or benefit determinations 

multiple times, according to officials we interviewed in five of the six 

states. Real-time access allows caseworkers to verify information 

provided by applicants and discuss apparent discrepancies during 

interviews rather than contact households again later. It can be 

difficult for caseworkers to contact households, according to officials 

we spoke with in four of the six states, and the need to do so can 

create delays in processing applications, a key FNS performance 

measure for SNAP.

• FNS regulations generally require recent information on income for 

SNAP eligibility and benefit determinations. Generally, FNS directs 

states to use income received in the last 30 days as the basis for 

determining SNAP benefit amounts.15 Accordingly, matches that 

provide current information can be used to accurately calculate or 

adjust benefits whereas older data may introduce errors if not 

updated. Officials from each of the six states we interviewed 

emphasized the importance of up-to-date information.

Four data matches for unearned income have each of the useful 

characteristics described above, while the data matches for earned 

income lack one or more of these characteristics. The four data matches 

most states reported using and finding very or extremely useful are with 

 157 C.F.R. § 273.10(c).

Matches States Reported 

Finding Most Useful 

Provide Real-Time Access 

to Recent Data, and Other 

Matches May Detect 

Unreported Sources of 

Income
Page 15 GAO-17-111 Supplemental Nutrition Assistance Program

primary sources including state or federal agencies that administer benefit 

programs that provide households’ unearned income (see fig. 2). Matches 

with SSA can provide real-time access to current SSI and OASDI 

program benefits that a household may receive. Matches with state-level 

unemployment insurance and child support enforcement agencies can 

provide up-to-date and real-time access to information on households’

receipt of benefits or support payments, depending on states’ matching 

capabilities. The data source for earned income that the most states 

reported as very or extremely useful was the commercial verification 

service The Work Number®, which is owned by Equifax Inc. and stores 

employment and earnings information gathered from participating 

employers’ payroll systems.16 Equifax representatives told us they 

estimate that The Work Number covers about 35-40 percent of the 

working population at any given time. Additionally, FNS officials told us 

that while The Work Number is a secondary source of information for 

SNAP eligibility purposes, SNAP agencies can use it to verify earned 

income reported by households or to identify potential earnings that were 

not reported. Similar to our findings in a recent report on the use of 

commercial data services to help identify fraud and improper payments, 

officials from five of the six states where we interviewed SNAP agency 

officials said The Work Number can improve program integrity or program 

efficiency by providing real-time access to accurate and up-to-date 

information.17 Also, use of The Work Number can reduce the reporting 

burden on households and employers because caseworkers can use it in 

lieu of collecting pay stubs from households or contacting employers to 

confirm reported earnings, according to state or local officials in these five 

states and Equifax representatives we interviewed.18

 16Equifax Inc. is a publicly held company that provides data services that include 

consumer and commercial information as well as workforce information. The Work 

Number includes information from approximately 65 million active employees, according 

to Equifax. 

17GAO, Program Integrity: Views on the Use of Commercial Data Services to Help Identify 

Fraud and Improper Payments, GAO-16-624, (Washington, D.C.: June 30, 2016).

18SNAP agencies must generally verify households’ income prior to certification using 

documentary evidence such as a pay stub. When such evidence cannot be obtained or is 

insufficient to make a determination, collateral contacts, such as a phone call with an 

employer, or a home visit, may be used. 7 C.F.R. § 273.2(f).
Page 16 GAO-17-111 Supplemental Nutrition Assistance Program

Figure 2: Reported Usefulness of Common Income Data Matches That States Conduct to Determine Eligibility for the 

Supplemental Nutrition Assistance Program (SNAP)

Note: Responses do not always add to 51 because not all states use these matches for SNAP 

eligibility and some states that use these matches did not know how to rate their usefulness or did not 

provide this information in the survey.

a

Although it does not come from a primary data source, information reported for TANF that affects 

SNAP benefits is considered by Food and Nutrition Service to be verified for SNAP purposes.

b

Real-time access may depend on state agencies’ information technology capabilities.
Page 17 GAO-17-111 Supplemental Nutrition Assistance Program

Data matches that do not have the characteristics that states found 

particularly useful can be used as leads to detect income that households 

may not have reported. For example, although state new hire directories 

and the NDNH New Hire data do not include information on the amount of 

employee earnings, caseworkers can use them to identify new 

employment that may not be reflected in households’ case files and follow 

up with households or employers to verify earnings. Eligibility workers at 

one county office we visited said that although not all data matches they 

used had complete or up-to-date information, they were still useful 

because they prompted action and helped prevent potential improper 

payments.

In our survey, we asked states about overall challenges for the incomerelated data matches they use, and the issue the most states found very 

or extremely challenging was following up to verify information provided 

by those matches. Other issues related to the data, such as the recency

of information, were also noted as challenges (see fig. 3). SNAP agency 

officials we interviewed in each of the six states said that following up on 

data matches to ensure information is accurate and up-to-date can be 

time intensive and difficult to achieve. As discussed earlier, the need to 

follow up on data matches stems from limitations in using the data for 

SNAP eligibility purposes. According to FNS guidance, before taking 

certain actions that affect households’ benefits, SNAP agencies should 

confirm income information that is not considered verified. FNS does not 

consider information that is questionable or that comes from a secondary 

States Reported 

Challenges with 

Following Up on Data 

Matches, Using Data 

Matches for Multiple 

Programs, and Costs

Necessary Follow-Up on 

Data Matches Is 

Challenging, Especially 

Related to Earnings and 

Out-of-State Benefits
Page 18 GAO-17-111 Supplemental Nutrition Assistance Program

rather than a primary source of information to be verified.19 These 

secondary data sources are often collected for multiple purposes and 

thus may not be sufficiently recent, accurate, or complete for SNAP 

eligibility determinations. NDNH files, for example, contain data used for 

many purposes. They are used to help state child support agencies locate 

parents and enforce child support orders. They also assist with the 

administration of SNAP, TANF, and child and family services programs, 

among others.20 However, some information, such as NDNH’s Quarterly 

Wage file, may not be sufficiently recent to serve as the basis for SNAP 

eligibility determinations without potentially leading to improper payments. 

It can take months to compile this information from employers at state 

and national levels—states have four months after the end of a calendar 

quarter to transmit quarterly wage data to NDNH.21 Thus, it may be 

difficult to accurately calculate SNAP benefits from quarterly earnings if 

employees experienced changes in employment, hours worked, or wage 

rates.22 In addition, officials we spoke with from four of the six states said 

that a new hire match may not indicate that someone actually earned 

wages, such as when someone signs up with a temporary employment 

agency but has not actually been placed in a job.

 19Food and Nutrition Service, “Questions and Answers on the Noncitizen Eligibility and 

Certification Provisions Final Rule,” (Nov. 21, 2000) and “Supplemental Nutrition 

Assistance Program (SNAP) Questions and Answers on Simplified Reporting,” (Aug. 13, 

2013). 

2042 U.S.C. § 653(i), (j). OCSE has authority to provide NDNH data to the SSA, 

Department of Education, Department of Housing and Urban Development, and the 

Department of Treasury, among other entities. States may also use NDNH data for 

various purposes. For example, we recently reported that federal agencies overseeing 

certain employment and training programs use quarterly wage data to track outcomes. We 

reported these efforts in GAO, Workforce Innovation and Opportunity Act: Performance 

Reporting and Related Challenges, GAO-15-764R (Washington, D.C.: Sept. 23, 2015).

21According to ACF officials, some states report wage data more frequently to NDNH, 

such as on a monthly or weekly basis.

22Generally, SNAP agencies must use income received in the past 30 days as an 

indicator of the household’s income when determining eligibility. However, depending on 

the circumstances, they may use older information, according to SNAP regulations at 7 

C.F.R. § 273.10(c). In such cases, however, there is the potential for errors to be identified 

later through the SNAP quality control process.
Page 19 GAO-17-111 Supplemental Nutrition Assistance Program

Figure 3: Data Challenges States Reported with Data Matching Conducted to 

Determine Eligibility for the Supplemental Nutrition Assistance Program (SNAP)

Working families make up a growing share of SNAP households; yet 

earned income information can be particularly difficult to obtain through 

data matches.23 Data matches that provide earned income information do 

not come from primary sources and have unique advantages and 

disadvantages in how recent or comprehensive their data are for 

determining SNAP eligibility (see table 4). Unlike several data matches for 

unearned income, all data matches for earned income lack one or more 

characteristics that are useful for determining SNAP eligibility. Earned 

income data sources such as the PARIS federal file, The Work Number, 

and various state sources do not include all employers, whereas more 

comprehensive sources such as NDNH or Internal Revenue Service 

earnings and tax data are more than 30 days old, lack relevant details, 

and are not available in real-time. In addition, states reported that the 

security and privacy safeguards needed to use tax data can be 

 23Over the past 20 years, the share of SNAP households with earned income rose by 50 

percent, according to an analysis of USDA data by the Council of Economic Advisers.
Page 20 GAO-17-111 Supplemental Nutrition Assistance Program

particularly challenging.24 Accordingly, SNAP agencies reported that they 

rely on multiple data matches for earned income information, which they 

should confirm is correct and relevant for SNAP eligibility before using the 

information for eligibility or benefit determinations.

Table 4: Characteristics of Selected Data Sources of Earnings Information Used for the Supplemental Nutrition Assistance 

Program (SNAP)

Source of earnings 

information Advantages for determining SNAP eligibility Disadvantages for determining SNAP eligibility 

Earnings and tax data

from the Beneficiary 

Earnings Exchange

Record or state 

records

• Matches include taxed income, including 

self-employment earnings, which is not 

available in other national data sources.

• Information may not become available until a year or 

more after the calendar year it represents.

• Tax records may not provide detail on changes in 

employment, hours worked, or wage rates during the 

year, which may affect SNAP benefits.

National Directory of 

New Hires (NDNH) 

New Hire file or state 

directories of new 

hires

• NDNH includes federal agency and multistate employer hires, which state 

directories may lack.

• New hires appear in state directories within 

20 days, and may be accessed from state 

directories in real-time.

• NDNH and state directories provide employment 

information, but do not provide income amounts.

• SNAP agencies request NDNH matches once per 

month, and the matches they receive do not include 

new hires within the last 30 days.

NDNH or state 

Quarterly Wage files

• NDNH includes federal agency and multistate employer wages, which state files

may lack.

• States make their files available before the 

national file, and may provide real-time 

access.

• NDNH and state files may not be available until 

months after the quarter has ended.

• NDNH and state files may not provide detail on 

changes in employment, hours worked, or wage rates 

during the quarter, which may affect SNAP benefits.

Public Assistance 

Reporting Information 

System (PARIS) 

federal file

• Matches include pay for active and retired 

federal civilian and military employees. 

• Only federal and military pay is included.

• Some payments are reported on an annual or year-todate basis, which may not provide sufficient detail for 

SNAP eligibility determination.

The Work Number® • Matches provide information from the last 

pay period and can be accessed in realtime.

• Data are available from participating employers only.

Source: GAO analysis of information from the Department of Health and Human Services’ Administration for Children and Families, Social Security Administration, the U.S. Department of Agriculture’s 

Food and Nutrition Service, and Equifax Inc., which owns and operates The Work Number.| GAO-17-111

 24Twenty-one states reported that designing and implementing data security and privacy 

safeguards are very or extremely challenging for income-related data matches in general. 

Additionally, when we asked about challenges associated with national data sources, 

about 38 percent (9 of 24) of states conducting the BEER match for Internal Revenue 

Service earnings and tax data said that security and privacy safeguards were very or 

extremely challenging, a larger percentage than any other national data source we asked 

about in our survey. 
Page 21 GAO-17-111 Supplemental Nutrition Assistance Program

Similarly, several data matches provide information on whether 

households received unearned income in the form of benefits from 

programs in other states or receive benefits from the same program in 

multiple states at the same time, but following up to confirm matches 

across states can be difficult. Data matches on benefits in other states 

can help SNAP agencies identify when a household or household 

member moves from one state to another but has not reported the move, 

as well as detect possible instances of intentional fraud. Data matches 

such as the PARIS Interstate file and NDNH Unemployment Insurance 

file aggregate income information across states and can provide useful 

leads for follow up by states. However, 13 states reported in our survey 

that lack of access to income information from other states was very or 

extremely challenging.25 In addition, officials we interviewed in four of six 

states said that it is time consuming to conduct follow up verifications with 

other states in terms of obtaining verification from other states or in terms 

of providing verifications to other states upon request. For example, an 

official from one state noted that the state receives approximately 500 

inquiries a month from other states following up on matches from the 

PARIS Interstate file, and the state must respond to each one in writing. 

Officials from another state said that out-of-state-benefits were the most 

cumbersome form of income to verify because the process varies by state 

or even by county, and other agencies may be slow to provide 

information, place verification requesters on hold for extended periods of 

time, or frequently change their points of contact.

States reported efforts to target and streamline data matching activities in 

order to reduce some of the manual work associated with data matching, 

including those associated with worker follow-up. SNAP agency officials 

we interviewed in three of the six states reported initiatives underway to 

improve data matching efficiency by better prioritizing which matches 

need follow up. For instance, in response to earlier challenges it 

encountered with data matching processes, Massachusetts has gone 

through a yearlong effort to better distinguish patterns of information from 

their quarterly wage and new hire matches that indicate whether follow up 

is worthwhile, according to state officials. By developing more 

sophisticated data matching algorithms, they hope to be able to filter out 

 25In addition, 12 states reported this was moderately challenging and 16 states reported it 

was somewhat or not at all challenging.
Page 22 GAO-17-111 Supplemental Nutrition Assistance Program

new hire matches that are not likely to affect SNAP benefits such as for 

one-day employment as an election worker or college students’ income 

from federal work-study programs that are not counted when determining 

SNAP eligibility and benefits. Massachusetts officials said that efforts 

such as these to use data matches more strategically can improve 

program integrity and service to households, as well as administrative 

efficiencies. Also, among states we interviewed, Texas, Virginia, and 

Washington have implemented information systems that enable 

caseworkers to look up available client information from multiple state and 

federal data systems with one search rather than conducting each data 

match individually. In addition, five states responded to our survey that 

they have systems to automatically import information from most or all 

matches into their eligibility systems without additional manual data entry.

Similarly, SNAP agency officials in two of the six states we interviewed 

(Massachusetts and Washington) said they were involved in stateinitiated efforts to address the need for faster, more complete cross-state 

data. For example, Massachusetts officials described a direct match that 

their state does with New York to provide one another data on 

households receiving benefits. Massachusetts officials said they can take 

action on exact matches showing household members receiving benefits 

from both states, and follow up on leads as appropriate if matches are not 

exact. Washington state officials told us that they provide neighboring 

states with certain read-only access to an online benefits verification 

system to allow those states to more easily confirm whether applicants 

already receive benefits in Washington. Washington officials told us this 

online system is easier than faxing or phoning the information to other 

states, and that they are pursuing access to other states’ information 

through similar online systems.

States reported ways they have integrated SNAP eligibility processes with 

other programs, particularly TANF and Medicaid, but also reported that 

limitations on using the same data matches for multiple programs were 

challenging. States sometimes integrate aspects of the SNAP eligibility 

process with those of other programs, such as through combined 

applications, common eligibility workers, or integrated or linked eligibility 

systems. According to our survey, SNAP eligibility processes were most 

commonly integrated with state TANF cash assistance programs, as well 

States Reported Barriers 

to Using Data Matches for 

Multiple Programs and the 

Cost of Conducting 

Matches as Challenges
Page 23 GAO-17-111 Supplemental Nutrition Assistance Program

as with state Medicaid programs, although to a somewhat lesser 

degree.26 However, 21 states reported that they found it very or extremely

challenging that Medicaid and other programs use income information 

from matches differently than SNAP because, for example, processes for 

verifying income information or definitions of household income differ 

across programs.27

One way state Medicaid programs verify income information differently 

than SNAP is by accessing data sources through CMS’s federal data 

services hub (the Hub). As we have previously reported, CMS created the 

Hub to implement provisions of the Patient Protection and Affordable 

Care Act (PPACA).28 The Hub provides a single access point for state 

agencies to gather information from various data sources used to verify 

eligibility determinations for Medicaid and related insurance affordability 

 26According to our survey, 44 states reported having integrated or linked eligibility 

systems, common eligibility workers, and combined applications between their SNAP and 

TANF cash assistance programs. Somewhat fewer states reported sharing these 

components of eligibility between their SNAP and Medicaid programs (31 states had an 

integrated or linked eligibility system and common eligibility workers, 24 had combined 

applications). Many fewer states shared these eligibility components with other programs, 

such as child care assistance, the Low-Income Home Energy Assistance Program, and 

child support enforcement. Also, according to other research, many states delinked their 

Medicaid application and eligibility processes from those used for human services 

programs, such as SNAP and TANF, in response the Patient Protection and Affordable 

Care Act; however, a number of states plan to reintegrate their health and human services 

eligibility systems over time. See Kaiser Family Foundation, Medicaid and CHIP Eligibility, 

Enrollment, Renewal, and Cost-Sharing Policies as of January 2016: Findings from a 50-

State Survey, (Washington, D.C.: The Kaiser Commission on Medicaid and the 

Uninsured, January 2016).

27In addition, 9 states reported this was moderately challenging and 16 states reported it 

was somewhat or not at all challenging.

28GAO, Patient Protection and Affordable Care Act: CMS Should Act to Strengthen 

Enrollment Controls and Manage Fraud Risk, GAO-16-29 (Washington, D.C.: Feb. 23, 

2016). States use the Hub to access information to support eligibility determinations for 

Medicaid and other health insurance affordability programs, including the Children’s 

Health Insurance Program and the Basic Health Program, and financial assistance such 

as advanced premium tax credits, and cost-sharing subsidies for coverage obtained 

through health insurance marketplaces, although use of the Hub varies by state according 

to CMS officials. Although the Hub plays a pivotal role in supporting the eligibility and 

enrollment processes for qualified health plans or health care affordability programs, we 

recently reported areas of vulnerability to fraud, and recommended that CMS take several 

actions to enhance program integrity and management and better assess potential fraud 

risk. HHS agreed with our recommendations. 
Page 24 GAO-17-111 Supplemental Nutrition Assistance Program

programs. More specifically, the Hub provides access to OASDI data from 

SSA and earnings data from Equifax’s Work Number, among other data, 

according to our prior work and additional information from CMS, SSA, 

and Equifax.29 Although these data are also used for SNAP, if state 

agencies access this information from the Hub, they cannot use it for 

SNAP eligibility determinations, even for a household that applies for or 

receives both Medicaid and SNAP benefits, according to FNS guidance.30

This is because data use agreements between CMS and federal 

agencies and the contract between CMS and Equifax do not authorize 

states to also use data accessed through the Hub for SNAP, according to 

officials from CMS and SSA.31 Due to these restrictions, when a state 

uses the Hub for Medicaid eligibility and a caseworker would like to use 

information on OASDI benefits or earnings available from The Work 

Number to determine SNAP eligibility, the caseworker would need to 

access this information independently, in effect conducting duplicative 

data matches to verify some of the same information for the same 

household. (See fig. 4).

 29The data provided through the Hub may differ from the data SNAP agencies access 

from the same sources outside the Hub. For example, SSA provides information to SNAP 

agencies on SSI for SNAP verification, but does not provide this information through the 

Hub.

30FNS, “Supplemental Nutrition Assistance Program (SNAP) and Data Sharing Under the 

Affordable Care Act (ACA),” (Oct. 25, 2013).

31Equifax representatives also said that state agencies were not able to use data from The 

Work Number for both Medicaid and SNAP verifications due to the Fair Credit Reporting 

Act, which representatives said restricts a single data transaction from being used for 

multiple decisions. 
Page 25 GAO-17-111 Supplemental Nutrition Assistance Program

Figure 4: Illustration of Verification Processes for a Household that Applies for or 

Receives Both Supplemental Nutrition Assistance Program (SNAP) and Medicaid 

Benefits When the Department of Health and Human Services’ Federal Data 

Services Hub Is Used for Medicaid Verification

a

Information that the Social Security Administration provides to both the federal data services hub and 

SNAP agencies include verification of Social Security numbers, incarceration status, Old-Age, 

Survivors, and Disability Insurance (OASDI) benefits, and quarters of coverage under OASDI.

b The Work Number is a commercial service owned by Equifax Inc. that verifies employment and 

earnings information.

c

Other federal data matches conducted both by the federal data services hub and SNAP agencies 

include, for example, immigration status information from the Department of Homeland Security.

Officials we interviewed in four of the six states and officials in six 

additional states in their responses to open-ended survey questions 

reported they would like to use the Hub for SNAP determinations or that it 
Page 26 GAO-17-111 Supplemental Nutrition Assistance Program

was challenging they were not able to do so. During interviews, officials 

from two of these states noted that this was challenging given that 

households that participate in SNAP are often also enrolled in Medicaid.32

For instance, an official from one state we interviewed expressed 

frustration with the duplicative work caused by not being able to use data 

accessed through the Hub for Medicaid eligibility verifications, to also 

verify SNAP or TANF eligibility, when applicable. An official from another 

state told us that having different processes to verify income for SNAP 

and Medicaid posed challenges to integrating program operations. 

Specifically, the official said that it was difficult to train eligibility workers to 

verify income in different ways for Medicaid and SNAP, and that it is also 

more difficult to integrate eligibility systems and combine households’

records across these programs when income information from data 

matches can be used for Medicaid but not for SNAP. Concerns regarding 

program inefficiencies, duplicative work, or additional costs were echoed 

by representatives we interviewed among five of seven stakeholder 

groups.

Costs may also be a factor in states’ ability to access data. About onethird of states reported in our survey that upfront and ongoing costs 

associated with conducting data matches were very or extremely 

challenging overall (see fig. 5), and states reported costs as particularly 

challenging with respect to use of The Work Number. Upfront costs are 

those associated with establishing a new data match, such as developing 

data sharing agreements, updating information systems or adapting 

business processes to use the match. Ongoing costs include those 

charged by the source agency or the commercial provider for ongoing use 

of the match, such as a per match charge. Additionally, there are costs 

associated with maintaining data sharing agreements. More states 

reported that costs associated with The Work Number were very or 

extremely challenging than they did for other national data sources. Of 

the 45 states that used The Work Number match, upfront costs were a 

 32Other research has shown that households which receive SNAP often also receive 

Medicaid. For example, R. Moffitt, “Multiple Program Participation and the SNAP 

Program,” Russell Sage Foundation Working Paper (February 2014) found that 79 percent 

of families that receive SNAP also receive Medicaid based on analysis of 2008 data from 

the Census’ Survey of Income and Program Participation, the most recent available. 

Economic and policy changes since that time may have affected the share of households 

that apply for or receive both SNAP and Medicaid.
Page 27 GAO-17-111 Supplemental Nutrition Assistance Program

challenge for 17 states, and ongoing costs were a challenge for 19.33

Some states limit their use of The Work Number or do not use it at all due 

to costs, according to interviews with state and FNS officials and 

comments from states in response to our survey. For instance, officials 

from one state we interviewed said they would like to be able to use The 

Work Number for every application and that applicants ask them to verify 

earnings through The Work Number, but because of the cost of these 

matches, caseworkers are asked to only conduct these matches as a last 

resort when other forms of verification are not available. Even with these 

limitations, the state contracts for a limited number of matches per month 

and frequently loses access to The Work Number when that limit is met 

before the end of the month, according to officials in this state and 

Equifax representatives. Such challenges can create inefficiencies for 

eligibility workers and increase the burden for households.

Figure 5: Cost-Related Challenges States Reported with Data Matching that They 

Conduct to Determine Eligibility for the Supplemental Nutrition Assistance Program 

(SNAP)

 33Fifteen states said that both upfront and ongoing costs of The Work Number were either 

very or extremely challenging, and 21 states identified at least one of the two types of 

costs as very or extremely challenging.
Page 28 GAO-17-111 Supplemental Nutrition Assistance Program

FNS has initiated several demonstration projects or pilots aimed at using 

data matching to improve client access, program integrity, or program 

efficiencies for SNAP (see table 5). Two of these initiatives, the Combined 

Application Project and the Elderly Simplified Application Project, are 

designed to help vulnerable populations, particularly the elderly, obtain 

benefits more easily.34 Currently, states are able to participate in these 

projects by requesting waivers from FNS.35 However, based on the 

success of these demonstrations in increasing elderly participation in 

SNAP, FNS recently proposed creating a state option (instead of the use 

of waivers) that would allow states to adopt a set of policies to streamline 

and simplify SNAP application, reporting requirements, and recertification 

 34According to FNS, low-income seniors are among the most at-risk of food insecurity 

because they often live alone, have health problems, and are less mobile.

35Waivers for the Combined Application and the Elderly Simplified Application Projects 

include those related to interview requirements, verification requirements, and the length 

of the certification period, among others.

FNS Has Efforts 

Underway to Promote 

the Use of Data 

Matching to Improve 

SNAP, but May Be 

Missing Some 

Opportunities

FNS Efforts Include 

Initiating Demonstration 

Projects and Pilots, 

Promoting Program 

Integration, and Working 

with CMS to Reduce 

Duplicative Processes

SNAP Demonstration Projects 

and Pilots
Page 29 GAO-17-111 Supplemental Nutrition Assistance Program

for low-income elderly individuals.36 In contrast, based on the results of 

another demonstration that explored the use of quarterly wage data 

matches, FNS recently concluded that it could not recommend the use of 

these data, as it affected the accuracy of benefit amounts.37

Table 5: Food and Nutrition Service (FNS) Demonstration Projects and Pilots That Use Data Matching to Improve 

Supplemental Nutrition Assistance Program (SNAP) Program Efficiencies

Name and Purpose of 

Demonstration or Pilot Description Current Status

Combined Application Project 

(CAP)

Purpose: To improve access to 

SNAP benefits for elderly and/or 

individuals with disabilities 

receiving Supplemental Security 

Income (SSI).

The standard version of this project involves a 

simplified joint application that includes both SNAP 

and SSI that is processed by SSA when individuals 

apply or are recertified for SSI. The interview for SSI 

application or recertification substitutes for a regular 

SNAP interview. State agencies match the SSA data 

from these applications in order to calculate a 

standardized benefit.a CAP households are certified for 

24, 36, or 48 months.

Began in 1995. As of 2016, 17 states 

participated in this project. States can 

participate in this project by submitting 

waivers to FNS, among other 

requirements.

Elderly Simplified Application 

Project

Purpose: To improve access to 

SNAP benefits for low income 

households with elderly and/or 

disabled individuals with no 

earned income.

This project has several components, specifically it: (1) 

waives certain verification requirements to allow states 

to make greater use of data matching when 

determining SNAP eligibility, although states must still 

verify information from data matches when 

questionable; (2) waives the recertification interview; 

and (3) extends the certification period to 36 months.

Began in 2003. As of 2016, 7 states 

participated in this project (Alabama, 

Florida, Georgia, Mississippi, 

Pennsylvania, South Carolina, and 

Washington) with an additional 2 states 

approved, but which have not yet 

implemented the project (Maryland and 

Massachusetts). States can participate in 

this project by submitting waivers to FNS, 

among other requirements.

 36 USDA proposed creating a state option in lieu of waivers in its fiscal year 2016 budget 

proposal. See United States Department of Agriculture, Fiscal Year 2016 Budget 

Summary and Annual Performance Plan, (Washington, D.C.: 2016). Creation of this state 

option would require changes to the Food and Nutrition Act of 2008, as amended 

according to FNS officials. 

37In a June 2016 letter summarizing the results of the demonstration, FNS reported that 

the use of quarterly wage data resulted in monthly benefits that in Texas, for example, 

were larger for 49 percent of households in the demonstrations than the benefits they 

would have received using income from the month of application and smaller benefit 

amounts for 42 percent of households.
Page 30 GAO-17-111 Supplemental Nutrition Assistance Program

Name and Purpose of 

Demonstration or Pilot Description Current Status

Quarterly Wage Report

Purpose: To simplify program 

administration, improve the 

timeliness of application 

processing, and help states better 

align certain SNAP and Medicaid 

processes. 

The demonstration project used the quarterly wage 

data match to verify earnings for households with 

stable income. In order to use the quarterly wage data, 

the applicant households must (a) have worked for the 

same employer over the three months of the prior 

quarter (b) have the same job at the time of application 

and no new sources of income and (c) maintained the 

same full-time/part-time status and wage/salary.

Occurred from 2014-2015 in portions of 2 

states (Texas and Utah). After analyzing 

the results, FNS concluded that using the 

quarterly wage data was not a practical 

option for verifying income as it was less 

accurate than current verification 

practices.

National Accuracy 

Clearinghouse (NAC)

Purpose: To reduce or prevent 

duplicate receipt of SNAP benefits 

(i.e. receipt of benefits in more 

than one state)

The NAC was a new data sharing system that was 

developed to enable state agencies to share 

information in real-time about the receipt of SNAP. 

State agencies match data on individual beneficiaries 

against this central data sharing system to identify 

individuals who are receiving SNAP benefits in another 

state and, if so, can terminate the benefits in the state 

in which the dual beneficiary no longer resides.

Began in June 2013. The grant funding 

the NAC will end December 2016 with 

any further participation after that date 

requiring states to match 50 percent of 

the funding. Five states (Alabama, 

Florida, Georgia, Louisiana, and 

Mississippi) have been part of the pilot. 

FNS is currently developing an action 

plan for further rollout.

Source: GAO analysis of information from FNS publications and interviews with FNS officials. | GAO-17-111

a

State SNAP agencies have the option to use a modified version of the CAP project, in which they 

use SSI data to identify and send simplified SNAP application forms to eligible households.

A fourth FNS-sponsored project, the National Accuracy Clearinghouse 

(NAC) pilot, created a new data sharing system in 2013 that enabled five 

pilot states affected by Hurricane Katrina (Alabama, Florida, Georgia, 

Louisiana, and Mississippi) to share information across states about the 

receipt of SNAP.38 The 2015 evaluation of the NAC reported that the five 

participating states were able to identify or prevent duplicate receipt of 

SNAP benefits among these states.39 Unlike the PARIS data match, 

which identifies potential duplicate receipt a number of months after it has 

occurred, the NAC’s real-time data could help states prevent duplicate 

 38The NAC pilot project was funded by the Office of Management and Budget’s 

Partnership Fund for Program Integrity Innovation. This fund supported pilot projects and 

evaluations aimed at improving program administration, through greater program integrity, 

improved program efficiencies, and better client service.

39Public Consulting Group, National Accuracy Clearinghouse (NAC) Evaluation: Final 

Report, prepared at the request of the Mississippi Department of Human Services,

October 2015. Mississippi was awarded funding by FNS to lead the project on behalf of 

the participating states. GAO did not assess the findings of the pilot’s evaluation.
Page 31 GAO-17-111 Supplemental Nutrition Assistance Program

receipt of benefits.40 These sentiments were echoed by Florida officials 

we interviewed, who told us that the NAC is more useful than PARIS 

because it is updated daily rather than quarterly. The evaluation also 

found that net cost savings were achieved in each of the five participating 

states, although to varying degrees.41

Along with several SNAP-focused demonstration projects and pilots, FNS 

has also worked with HHS on initiatives that affect SNAP and its 

integration and interoperability (the ability to exchange information across 

systems) with other health and human services programs.42 These efforts 

have largely been spurred by time-limited funding opportunities aimed at 

promoting more streamlined and efficient enrollment and eligibility 

systems across state health and human services programs, according to 

information from HHS and FNS. Specifically, to help states meet 

requirements under the PPACA, CMS increased the level of federal 

funding for information technology (IT) modernization for health systems 

improvements. Human services programs can benefit from these 

improvements at little or no additional costs, under a time-limited waiver 

to normal cost allocation rules (see sidebar). FNS has worked with CMS 

and ACF to promote states’ awareness and use of this funding. For 

example, these three agencies sent a joint letter to states in 2011 that 

announced the cost allocation waiver and another in 2015 that 

announced an extension of the waiver through 2018. According to FNS, 

38 states had availed themselves of the cost allocation waiver to fund 

 40This pilot also addressed a finding from the USDA Inspector General report on efforts to 

prevent SNAP recipient fraud, including when recipients apply for and receive benefits in 

multiple states. The IG recommended that FNS continue its development of the NAC, 

report on the findings of the pilot, and provide a determination on implementing a 

permanent, nationwide system. Department of Agriculture, Office of the Inspector General, 

Analysis of FNS’ Supplemental Nutrition Assistance Program Fraud Prevention and 

Detection Efforts, Audit Report 27002-0011-13 (Washington, D.C.: September 2012). 

41The report’s authors attributed the variation to differences in the state business 

processes, such as whether the data match was integrated with the eligibility system or

automatic emails were sent when a match was found. 

42HHS’ Administration for Children and Families (ACF) has initiated several efforts at 

promoting greater interoperability across human services programs, such as establishing 

a human services work group to apply principles from the National Information Exchange 

Model. This model aims to streamline information sharing among organizations in 

emergency and day-to-day operations. ACF notes that standardized data and information 

exchanges help fulfill human services goals: improved service delivery for clients, reduced 

errors and improved program integrity, and improved administrative efficiency.

Program Integration Efforts

Funding Available for Health and Human 

Services Integration

The federal government funds 90 percent of 

the qualifying costs of information technology 

(IT) improvements for investments in the 

design and development of state eligibilitydetermination and enrollment systems for 

Medicaid and the Children’s Health Insurance 

Program. Under normal cost allocation rules, 

human services programs that benefit from 

these systems improvements would be 

required to pay their share of associated 

costs. However, under a waiver of these rules 

through 2018, state human services agencies 

do not need to pay their share of costs for 

certain systems improvements that benefit 

both health and human services programs.

Source: Information from HHS and USDA. | GAO-17-111
Page 32 GAO-17-111 Supplemental Nutrition Assistance Program

health systems improvements that also include improvements to SNAP 

eligibility systems, at the time of this review, and according to our survey, 

almost three-fourths of states (29 of 40) that rated the usefulness of this 

funding said that it was very or extremely helpful.

Since 2013, FNS also has been involved in CMS-led interagency efforts 

to address duplication and program integration challenges, previously 

discussed, related to restrictions of data accessed through the Hub for 

joint Medicaid cases that include SNAP or TANF. Officials from FNS, 

CMS, and ACF (the federal agency that oversees TANF) as well as SSA, 

told us that they have been working for several years to develop policy 

options and modified data sharing agreements to allow for SSA data 

accessed through the Hub for Medicaid verifications to also be used for 

SNAP and TANF in joint cases. Officials told us that progress in 

addressing these issues has been slow, due to complex issues related to 

various legal requirements, including those under the Privacy Act of 

1974.43 However, CMS officials told us that they have the support of 

multiple agencies, including SSA and the Office of Management and 

Budget (the federal agency that provides guidance on the Privacy Act), to 

allow TANF and SNAP agencies’ use of Hub data and they hope to 

resolve these issues by the end of the calendar year. In our prior work on 

data sharing across state and local human services programs, we noted 

that strong leadership support across agencies is a key factor for success 

in facilitating data sharing.44

These interagency efforts to improve efficiencies across programs for 

Hub-accessed data are in line with several efforts aimed at better 

coordination across government. In our extensive work on duplication, 

fragmentation, and overlap in the federal government, we defined 

duplication as occurring when two or more agencies or programs are 

engaged in the same activities or providing the same service to the same 

beneficiaries. We have reported that federal agencies should identify 

 43In our report on data sharing across state and local human services programs, we noted 

that there are various challenges associated with data sharing across programs and 

balancing privacy issues, including: confusion and misinterpretation around what agencies 

were allowed to share, a tendency to be risk averse and overly cautious in interpreting 

federal privacy requirements, or potential inconsistencies in federal privacy requirements 

that applied to data sharing across multiple programs. See GAO-13-106.

44GAO-13-106. 
Page 33 GAO-17-111 Supplemental Nutrition Assistance Program

opportunities to reduce duplication, which could enable better 

management of program administration or result in potential cost 

savings.45 In the case of the Hub, because some duplicative data 

matching processes related to eligibility determinations occur due to the 

current Hub restrictions, reducing these duplicative processes may result 

in improved administrative efficiencies. Additionally, the interagency 

efforts related to the Hub are also in line with HHS recommendations, 

developed in response to requirements under the PPACA, which called 

on federal agencies to promote greater interoperability across health and 

human services programs to streamline program administration, including 

the use of data for eligibility determinations among several programs 

when possible. Similarly, officials from CMS, FNS, and ACF indicated that 

their current efforts in facilitating use of data from the Hub across 

Medicaid, SNAP, and TANF were part of a larger vision to promote health 

and human services interoperability and integration overall, and were 

related to current funding opportunities for such integration, discussed 

earlier in the report. In a tri-agency letter to states, these agencies stated 

that they were “committed to a strong partnership with states and our 

federal stakeholders as we work together to implement our shared vision 

of interoperable, integrated and consumer-focused health and human 

services systems.”46

FNS also has begun to explore ways to help states address some of the 

cost challenges associated with use of The Work Number discussed 

earlier in the report. Equifax representatives told us that each state SNAP 

agency that conducts data matches with The Work Number contracts 

independently with Equifax, and states pay different prices to use the 

service due to various factors including the volume of matches that each 

state purchases. In contrast, CMS has negotiated a single contract with 

Equifax that allows states to access information from The Work Number 

through the Hub to determine eligibility for Medicaid and related insurance 

 45More information about GAO’s work identifying overlap and duplication in the federal 

government can be found at http://www.gao.gov/duplication/overview.

46The tri-agency letter from ACF, CMS, and FNS addressed to “Medicaid, Children’s 

Health Insurance Program, and Health and Human Services Directors, and State 

Marketplace CEOs” provided additional guidance on the exception to the cost allocation 

requirements set forth in Office of Management and Budget’s Circular A-87 (July 20, 

2015).

Use of The Work Number
Page 34 GAO-17-111 Supplemental Nutrition Assistance Program

affordability programs.47 Due to volume-pricing, Equifax representatives 

told us that a single contract to cover all state SNAP agencies use of The 

Work Number would likely lead to lower costs per match than what most 

state SNAP agencies pay now through individual contracts. It would also 

help states by eliminating the need for each state to negotiate separate 

contracts. FNS and CMS officials told us that they have discussed 

opportunities to expand use of The Work Number through the Hub for 

SNAP verifications when CMS’ current contract with Equifax expires in 

2018 and the service is reprocured. In addition, FNS officials told us that 

FNS could also consider negotiating a separate, single contract for The 

Work Number that would allow all state SNAP agencies to access the 

match, but would first explore possibilities that involved access through 

the Hub.48 Various options have the potential to result in cost savings 

such as through volume pricing discounts or enabling the use of the 

match across programs.

Despite FNS’ current efforts, 32 states reported that more information 

from FNS on promising data matching practices, such as on the use of 

different data matches or on ways to filter data to streamline worker 

follow-up, would be extremely or very useful, according to our survey. 

However, information on such practices available on FNS websites is 

limited, based on our review. FNS uses both its public website and its 

PartnerWeb site (a web portal available to state agencies and others) to 

publish guidance, share information on state practices, and communicate 

other information to SNAP agencies. Officials at one FNS regional office 

said that, while states may engage in more informal communication with 

other states in their region, the PartnerWeb site serves as a broader 

source of information that can facilitate additional communication across 

states about relevant practices. Through these websites, FNS has 

provided detailed information on what states are doing to modernize their 

 47According to Equifax officials, another example in which multiple states access The 

Work Number through a national contract is a pilot project sponsored by the Department 

of Labor focused on identifying improper payments to unemployment insurance recipients 

with disqualifying income from work. In this project, three participating states are 

accessing The Work Number through a single contract. We described some of the 

Department of Labor’s efforts in our report on commercial data, GAO-16-624. 

48FNS has a contract with Equifax that enables FNS reviewers to use The Work Number 

for SNAP quality control reviews, according to FNS officials.

FNS Has Not Widely 

Disseminated Promising 

Practices for Data 

Matching or Assessed 

Options to Reduce 

Commercial Data Costs
Page 35 GAO-17-111 Supplemental Nutrition Assistance Program

SNAP eligibility systems and processes in areas such as states’ use of 

call centers, document imaging, or alternative methods for managing 

SNAP caseloads.49 However, based on our review of FNS’ websites, we 

found few documents with specific information on data matching 

strategies, such as data brokering (allowing access to various data 

sources in a centralized portal), data filtering (using data analytics and 

information on program rules to better identify discrepancies and prioritize 

follow-up), or automatically populating the eligibility determination system 

(information obtained from reliable matches are automatically added to a 

client’s SNAP case file). For example, an FNS document on one of the 

websites listed states that used data brokering, but did not include 

information that described the practice in detail or its implementation. 

Additionally, although FNS has been engaged in recent efforts to test new 

data matching practices described earlier, such as the NAC, it has not yet 

widely disseminated findings from the NAC evaluation to states. FNS 

officials told us that they submitted these findings to Congress and 

relevant stakeholders in May 2016 and intend to more broadly 

disseminate the information once a determination has been made 

regarding the pilot’s future expansion. In our survey, 28 states said that 

information from FNS on cross-state data matching or sharing would be 

extremely or very useful. Accordingly, timely dissemination of findings 

from the NAC evaluation would be useful for states, even while decisions 

regarding its expansion are pending. 

Regarding other state practices, FNS officials told us that they would 

typically consider disseminating information on data matching practices 

considered effective based on evidence, and not necessarily on state 

practices that have not been evaluated. While supporting and sharing 

information on practices that have been proven effective is vital, 

information on various implementation and program administration issues 

 49As technology use has expanded, many aspects of SNAP program administration in the 

states have changed. For example, applicants can apply or recertify online or by phone, 

through the use of document imaging or phone-interviews. See, for example, a 2013 

report sponsored by FNS titled The Evolution of SNAP Modernization Initiatives in Five 

States that describes some of these practices, as well as Timeliness of the SNAP 

Application Process (2013) that includes description of states’ efforts to modernize their 

office business practices.
Page 36 GAO-17-111 Supplemental Nutrition Assistance Program

are also useful for agencies operating programs.50 Likewise, officials we 

interviewed from three of the six states said that it would be useful for 

FNS to facilitate additional information sharing on state practices, such as 

implementation issues, so they could be aware of how other states were 

implementing data matches:

• Officials from one state said FNS could provide information about 

whether other states were effectively using data matches that they 

found challenging to implement in their state.

• An official from a second state said that FNS could serve as a 

clearinghouse for state practices on data matching. While this official 

acknowledged that FNS’ guidance on data matches needed to be 

relatively high level, this official said that more specific information on 

what other states were doing to implement data matches would be 

useful and that FNS could play a more active role in facilitating this 

type of information sharing.

• An official from a third state said it would be helpful to get additional 

information about state practices so states would not have to “reinvent 

the wheel” each time and could learn from each other.

Our prior work on collaboration practices has shown that agencies can 

enhance and sustain collaborative efforts and identify and address needs 

by leveraging resources, such as through information sharing.51 In other 

work on human services integration, we have found that federal agencies 

can help states improve their information systems by acting as a facilitator 

to help states work together and share their models with other states.52

Additionally, federal standards for internal controls call for agencies to 

 50In prior work, we have observed that learning from evaluation allowed for continuous 

improvements in operations and programs, and the advancement of a knowledge base. 

See GAO, Program Evaluation: An Evaluation Culture and Collaborative Partnerships 

Help Build Agency Capacity, GAO-03-454, (Washington, D.C.: May 2, 2003). We have 

also found that evaluation studies, while important, may take a long time before results are 

finalized. GAO, Program Evaluation: Strategies to Facilitate Agencies’ Use of Evaluation 

in Program Management and Policy Making, GAO-13-570, (Washington, D.C.: June 26, 

2013). 

51GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15, (Washington D.C.: Oct. 21, 2005). 

52GAO, Human Services Integration: Results of a GAO Cosponsored Conference on 

Modernizing Information Systems, GAO-02-121, (Washington, D.C.: Jan. 31, 2002). 
Page 37 GAO-17-111 Supplemental Nutrition Assistance Program

communicate necessary quality information to external parties in order to 

achieve the agency’s objectives.53 If FNS took additional steps to facilitate 

information sharing on promising practices, state SNAP agencies would 

be better positioned to improve program integrity, experience greater 

administrative efficiencies, and place fewer burdens on SNAP applicants 

and recipients. States would also be better able to leverage existing 

knowledge and resources and avoid duplicative efforts.

Further, although FNS is beginning to explore ways to reduce the costs of 

The Work Number for state SNAP agencies by working with CMS to 

expand its use through the Hub, it has not yet systematically analyzed 

spending and SNAP data needs for this service and more thoroughly 

considered how various factors would affect costs. For example:

• Not all states currently access The Work Number for Medicaid 

eligibility through the Hub, according to CMS officials. Although there 

is potential for expanding Hub use among states, it is unclear how 

much cost savings would result if some states do not use the Hub to 

access The Work Number, and FNS officials indicated that they had 

not yet gathered information from states to assess this.

• CMS and FNS officials told us they are currently considering 

expanded use of The Work Number through the Hub for joint cases 

involving both Medicaid and SNAP benefits. Thus, states may still 

need to maintain individual contracts for The Work Number for SNAP 

cases that do not include Medicaid or related health programs, and it 

is unclear what subsequent cost implications there might be for these 

state-level contracts. FNS officials indicated that they had not yet 

obtained information on the extent that states would need to maintain 

individual contracts for SNAP-only cases and analyzed how state 

spending for the service would be affected.

• CMS and FNS officials told us that there was the potential for cost 

savings in facilitating use of the match across programs (i.e., a state 

agency would not need to run a query twice for a case that includes 

both SNAP and Medicaid). However, CMS officials did indicate that 

the price CMS pays Equifax to allow states access to The Work 

Number through the Hub would likely increase if they were to expand 

 53GAO, Standards for Internal Control in the Federal Government, GAO-14-704G,

(Washington, D.C.: Sept. 2014), 62.
Page 38 GAO-17-111 Supplemental Nutrition Assistance Program

its use to other programs and said they needed to work through cost 

implications of possible scenarios.

Both GAO and the Office of Management and Budget have emphasized 

opportunities for agencies to lower prices, reduce duplication, and reduce 

administrative costs by leveraging the government’s buying power 

through practices such as strategic sourcing and category management.54

For instance, in 2013, we found that leading commercial companies 

achieve savings by pooling purchases by using various practices, 

including analyzing spending of purchased services across entities, 

understanding the needs or requirements of services across various 

users, and promoting transparency about acquisitions within the 

organization to help identify inefficiencies.55 It is possible that the options 

FNS is exploring with CMS could help lower the cost of The Work 

Number across multiple government users by leveraging the 

government’s buying power. However, FNS will not be able to identify 

informed ways to best do this without conducting a more thorough 

analysis of SNAP data needs and spending across state and federal-level 

contracts and in relation to other programs.

Data matching is a tool that has the potential to help SNAP agencies 

increase program integrity, improve administrative efficiency, and reduce 

household burden. The extent to which these benefits occur, however, 

may sometimes depend on the characteristics of the match or the use of 

promising data matching practices. Although FNS has efforts under way 

to promote the use of data matching to improve SNAP, it has not yet 

 54Strategic sourcing is a process that moves an organization away from numerous 

individual procurements to a broader aggregate approach. A related buying strategy is 

category management, which is an approach based on leading practices that aims to 

manage entire categories of spending across government for commonly purchased goods 

and services. Recent GAO work on this includes GAO, Strategic Sourcing: Opportunities 

Exist to Better Manage Information Technology Services Spending, GAO-15-549, 

(Washington, D.C.: Sept. 22, 2015). Recent guidance from the Office of Management and 

Budget includes OMB, Memorandum for Chief Acquisition Officers and Senior 

Procurement Executives: Transforming the Marketplace: Simplifying Federal Procurement 

to Improve Performance, Drive Innovation, and Increase Savings (Washington D.C.: Dec. 

4, 2014).

55GAO, Strategic Sourcing: Leading Commercial Practices Can Help Federal Agencies 

Increase Savings When Acquiring Services, GAO-13-417, (Washington, D.C.: April 15, 

2013).

Conclusions
Page 39 GAO-17-111 Supplemental Nutrition Assistance Program

widely disseminated information on the results of all of these efforts or 

taken steps to more broadly facilitate information sharing about other 

promising data matching practices that states employ. With wider, timely 

dissemination of promising practices, state SNAP agencies will be better 

positioned to be aware of potentially useful ways to help them address 

implementation issues and improve the effectiveness of their data 

matching processes. Additionally, we applaud the interagency work done 

by CMS, FNS, and other agencies to try and reduce duplicative work 

across programs and promote the use of technology advances to 

facilitate program integration overall. These efforts are important, as is 

sustained attention to make further progress toward effective solutions. 

FNS has also taken initial steps to explore ways to reduce costs related to 

the use of commercial data services, such as through cross-program 

efficiencies. However, FNS, working with CMS as appropriate, has not yet 

systematically analyzed spending and taken steps to understand data 

needs for these services. Without such an approach, FNS will not be able 

to identify the best ways to leverage the government’s buying power 

through strategic sourcing practices and potentially reduce costs and 

improve performance.

We recommend that the Secretary of Agriculture:

1. Take additional steps to collect and disseminate information on 

promising practices that could help improve data matching processes 

among state SNAP agencies, including broad and timely 

dissemination of information on results of recent relevant pilots or 

demonstrations.

2. Work with HHS (as appropriate) to analyze spending and understand 

data needs for SNAP across federal and state contracts and in 

relation to other programs as FNS explores ways to potentially reduce 

the costs of using commercial data services.

We provided a draft of our report to USDA, HHS, and SSA for review and 

comment. On September 21, 2016, FNS officials from SNAP’s Program 

Development Division and SNAP’s Program Accountability and 

Administration Division provided us with the agency’s oral comments. 

FNS officials told us that they agreed with the recommendations in the 

report. They noted that they have been moving in the general direction of 

these recommendations and would build on current efforts to address 

them. FNS and SSA also provided technical comments, which were 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 40 GAO-17-111 Supplemental Nutrition Assistance Program

incorporated into the report as appropriate. HHS did not have any 

comments on the report.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate

congressional committees, Secretaries of Agriculture and Health and 

Human Services, the Commissioner of the Social Security Administration, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or brownke@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

Appendix I.

Sincerely yours,

Kay E. Brown

Director, Education, Workforce,

and Income Security Issues
Appendix I: GAO Contact and Staff 

Acknowledgements

Page 41 GAO-17-111 Supplemental Nutrition Assistance Program

Kay E. Brown, 202-512-7215, brownke@gao.gov.

In addition to the contact above, Gale Harris (Assistant Director), Theresa 

Lo (Analyst-in-Charge), David Reed, and Russell Voth made key 

contributions to this report. Also contributing to this report were Holly Dye, 

Alexander Galuten, David Lin, Jean McSween, Mimi Nguyen, and Jerome 

Sandau.

Appendix I: GAO Contact and Staff 

Acknowledgements

GAO Contact

Staff 

Acknowledgements

(100276)
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