FEDERAL LOWINCOME 

PROGRAMS

Eligibility and Benefits 

Differ for Selected 

Programs Due to 

Complex and Varied 

Rules

Report to the Chairman, Committee on 

the Budget, U.S. Senate

June 2017

GAO-17-558

United States Government Accountability Office
United States Government Accountability Office

 

Highlights of GAO-17-558, a report to the 

Chairman, Committee on the Budget, U.S.

Senate

June 2017

FEDERAL LOW-INCOME PROGRAMS

Eligibility and Benefits Differ for Selected 

Programs Due to Complex and Varied Rules

What GAO Found

Six key federally funded programs for low-income people vary significantly with 

regard to who is eligible, how income is counted and the maximum income 

applicants may have to be eligible, and the benefits provided. In fiscal year 2015, 

the most current data available, the federal government spent nearly $540 billion 

on benefits for these six programs—the Earned Income Tax Credit (EITC), 

Medicaid, the Housing Choice Voucher program, Supplemental Nutrition 

Assistance Program (SNAP), Supplemental Security Income (SSI), and

Temporary Assistance for Needy Families (TANF). The target population for 

each of these programs differs, for example, people who are elderly or disabled 

or who have dependent children. Further, some programs have conditions for 

continued eligibility, such as participation in work activities under TANF. The six 

programs also vary in what income is and is not counted when determining an 

applicant’s eligibility. For example, certain programs, such as SNAP, disregard a 

portion of earned income, while others do not. The maximum amount of income

an applicant may have and still be eligible for benefits, which is determined for 

some programs at the federal level and for others at the state or local level, also 

differs significantly. As of December 2016, this amount ranged from $5,359 per 

month for one state’s Medicaid program to $0 per month in one state for TANF

cash assistance, for a single parent with two children. Benefit levels also differed

across the six selected programs, with average monthly benefits for these 

programs ranging in fiscal year 2015 from $258 for SNAP to $626 for Housing 

Choice Vouchers, and four of the six programs adjust benefits annually.

Legal, administrative, and financial constraints pose challenges to efforts to 

streamline varying eligibility rules for federal low-income programs, according to 

GAO’s current and previous work. A key challenge is that the programs are 

authorized by different federal statutes enacted at different times in response to 

differing circumstances. Other laws, such as appropriations laws, can also have 

an impact on federal programs and their rules. As a result, streamlining eligibility 

rules would require changing many laws and coordination among a broad set of 

lawmakers and congressional committees. A further challenge is that a different 

federal agency or office administers each program GAO reviewed. For some of 

these programs, such as TANF, state governments also establish some program 

rules, making it more difficult to streamline rules at the federal level within or 

across these programs. Finally, financial constraints may also affect efforts to 

streamline program rules. For example, if rule changes raise the income 

eligibility limit in a program, more people may become eligible and that program’s

costs may increase. Despite these challenges, Congress, federal agencies, and 

states have taken some steps to streamline program administration and rules, 

such as by making greater use of data-sharing where permitted by federal law

and aligning programs’ applications and eligibility determination processes. For 

example, SSI recipients in most states are automatically eligible for Medicaid, 

and GAO previously reported that some states have integrated the SNAP 

eligibility process with other low-income programs, such as through combined 

View GAO applications and common eligibility workers. -17-558. For more information, 

contact Kathryn Larin at (202) 512-7215 or 

larink@gao.gov.

Why GAO Did This Study

Various federal programs provide cash

assistance, food, housing, and health 

care to millions of individuals, families, 

and households whose income falls 

below defined levels and who meet 

other eligibility requirements. As GAO 

previously reported, the numerous 

financial and nonfinancial rules for 

determining eligibility for such lowincome programs can confuse 

applicants and increase program 

administration challenges. GAO was 

asked to examine eligibility rules for 

low-income programs.

This report examines (1) the ways in 

which eligibility rules and benefits for 

selected federal low-income programs 

vary across the programs; and (2) what 

is known about challenges associated 

with efforts to streamline these rules. 

GAO reviewed relevant agency 

guidance and other information 

provided by agencies and analyzed 

financial eligibility rules and benefits 

across six low-income programs. GAO

confirmed all information on program 

rules with the respective administering 

agencies. GAO selected these 

programs because they are among the 

largest of the federally funded 

programs addressing low-income 

people’s basic needs and they

illustrate variations in eligibility rules 

among low-income programs. GAO 

also reviewed previous GAO reports 

and selected reports from the 

Congressional Research Service and 

other knowledgeable research and 

policy organizations.

What GAO Recommends

GAO is not making recommendations 

in this report. 
Page i GAO-17-558 Federal Low-Income Programs

Letter 1

Background 3

Selected Federal Low-Income Programs Vary with Regard to 

Target Populations, Rules for Counting Income and Assets, and 

Benefits 11

Legal, Administrative, and Financial Constraints Challenge Efforts 

to Streamline Rules for Low-Income Programs 31

Agency Comments and Our Evaluation 40

Appendix I Estimated Number of People Eligible for Selected Low-Income 

Programs Compared with Program Recipients 41

Appendix II Selected Deductions for Calculating Income for Determining 

Program Eligibility 45

Appendix III Maximum Monthly Income an Applicant May Have and 

Still Be Eligible for Six Selected Low-Income Programs 47

Appendix IV GAO Contact and Staff Acknowledgements 50

Tables

Table 1: Program Purposes, Type of Benefit, and Numbers 

Served for Six Selected Federal Low-Income Programs 4

Table 2: Federal Departments and Agencies Responsible for Six 

Low-Income Programs 7

Table 3: Target Populations among Selected Low-Income 

Programs (as of December 31, 2016) 11

Table 4: Work Requirements for Eligible Adults among Selected 

Low-Income Programs (as of December 31, 2016) 13

Table 5: Applicant Unit and Whose Income Is Counted in 

Determining Eligibility among Selected Low-Income 

Programs (as of December 31, 2016) 15

Table 6: Types and Amounts of Earned Income Disregarded in 

Determining Initial Financial Eligibility, by Selected LowIncome Program (as of December 31, 2016) 16

Contents
Page ii GAO-17-558 Federal Low-Income Programs

Table 7: Benefits from Selected Federally-Funded Low-Income 

Programs That Are Either Included or Excluded when 

Counting Income for Financial Eligibility (as of December 

31, 2016) 18

Table 8: Deductions for Child Care Expenses in Calculating 

Income for the Purpose of Determining Eligibility for 

Selected Low-Income Programs (as of December 31, 

2016) 19

Table 9: Standards and Methods Used to Set Income Limits for 

Program Eligibility (as of December 31, 2016) 21

Table 10: Average Benefit and Annual Adjustment of Benefits 

Across Six Selected Low-Income Programs 28

Table 11: Deductions for Utilities Expenses in Calculating Income 

for the Purpose of Determining Eligibility for Selected 

Low-Income Programs (as of December 2016) 45

Table 12: Deductions for Selected Other Expenses in Calculating 

Income for the Purpose of Determining Eligibility for 

Selected Low-Income Programs (as of December 2016) 45

Figures

Figure 1: Federal Expenditures on Benefits for Six Low-Income 

Programs, in Billions, FY 2015 6

Figure 2: Program Recipients as a Percent of Total U.S. 

Population in 2015 9

Figure 3: Conceptual Overview of Key Features of the Eligibility 

Determination Process for Selected Low-Income 

Programs 10

Figure 4: Illustration of Maximum Monthly Amounts of Income an 

Applicant May Have and Still Be Eligible for Three 

Selected Low-Income Programs with Nationally-Set 

Maximum Income Limits 23

Figure 5: Illustration of Range of Maximum Monthly Amounts of 

Income an Applicant May Have and Still Be Eligible for 

Four Selected Low-Income Programs with State 

Variations in Income Limits 24

Figure 6: Asset Limits for Determining Initial SNAP and TANF 

Program Eligibility, Range by Number of States (as of 

August 2016) 26

Figure 7: Congressional Committees, Federal Agencies, and State 

and Local Governments Involved in the Six Programs 33
Page iii GAO-17-558 Federal Low-Income Programs

Figure 8: Estimated Number of People Eligible for Benefits 

Compared to Those Receiving Benefits, 2012, for Four 

Low-Income Programs 42

Figure 9: Illustration of Maximum Monthly Amounts of Income an 

Applicant May Have and Still Be Eligible for Six Selected 

Low-Income Programs 47

Abbreviations

ACF Administration for Children and Families

AGI Adjusted Gross Income

AMI Area Median Income

BBCE broad-based categorical eligibility

CCDF Child Care and Development Fund

CMS Centers for Medicare & Medicaid Services

CPI Consumer Price Index

CRS Congressional Research Service

EITC Earned Income Tax Credit 

FNS Food and Nutrition Service

FPG federal poverty guidelines 

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development 

IRS Internal Revenue Service 

MAGI Modified Adjusted Gross Income 

MOE maintenance of effort 

PHA Public Housing Agency

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 

TRIM3 Transfer Income Model, version 3

USDA Department of Agriculture 

WIC Special Supplemental Nutrition Program for Women,

Infants, and Children 

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Page 1 GAO-17-558 Federal Low-Income Programs

441 G St. N.W.

Washington, DC 20548

June 29, 2017

The Honorable Michael B. Enzi

Chairman

Committee on the Budget

United States Senate

Dear Mr. Chairman:

Various federal programs provide cash or noncash assistance to millions 

of individuals, families, or households whose incomes fall below defined 

levels and who meet other eligibility requirements. Many of these 

programs provide supports to address a range of basic needs for lowincome people, including cash assistance, food, housing, and health care. 

According to the most recent agency data available, in fiscal year 2015, 

the federal government expended nearly $540 billion in benefits for six 

programs for low-income people: the Earned Income Tax Credit (EITC), 

Medicaid, the Housing Choice Voucher program, Supplemental Nutrition 

Assistance Program (SNAP), Supplemental Security Income (SSI), and 

Temporary Assistance for Needy Families (TANF).

As we have reported in the past, the numerous financial and nonfinancial 

eligibility rules for federal low-income programs can confuse applicants 

and increase program administration challenges.1, 2 For applicants, these 

rules have sometimes made it difficult and burdensome to navigate the 

application process for some programs. For program staff, separate rules 

for each program mean that staff have to keep track of and apply different 

rules when determining eligibility, even though they may collect and 

document much of the same personal and financial information from 

applicants. In light of these issues, the Senate Committee on the Budget 

asked us to examine eligibility rules and benefits for low-income 

programs.

 1 In this report, we use the term “rules” to refer generally to the programs’ requirements, 

regardless of the source of those requirements, which may be found in federal or state 

statutes or regulations, depending on the program. 

2 GAO, Means-Tested Programs: Determining Financial Eligibility is Cumbersome and 

Can Be Simplified, GAO-02-58 (Washington, D.C.: Nov. 2, 2001); Human Services 

Programs: Opportunities to Reduce Inefficiencies, GAO-11-531T (Washington, D.C.: Apr.

5, 2011); and Welfare: Issues to Consider in Assessing Proposals for Reform,

GAO/HRD-87-51BR (Washington, D.C.: Feb. 19, 1987).

Letter
Page 2 GAO-17-558 Federal Low-Income Programs

This report examines (1) in what ways eligibility rules and benefits for 

selected federal low-income programs vary across these programs; and 

(2) what is known about challenges associated with efforts to streamline 

varying eligibility rules for federal low-income programs.

To address the first question, we analyzed and compared the target 

populations and rules for determining eligibility and benefits—including 

financial and other eligibility rules—across six federally-funded lowincome programs: (1) EITC,3 (2) Medicaid,4 (3) Housing Choice 

Vouchers, (4) SNAP, (5) SSI, and (6) TANF.5 We selected these six 

programs because they are among the largest of the federally-funded 

low-income programs addressing basic needs, and they illustrate 

similarities and variations in how financial eligibility is determined among 

such federally-funded low-income programs.6 The programs we selected 

were intended to illustrate this variability rather than serve as a 

comprehensive inventory of all of the eligibility requirements or an 

exhaustive description of differences among programs. We obtained 

 3 The EITC is a tax credit, which reduces tax liability dollar-for-dollar. The EITC can result 

in a cash refund for the taxpayer, if the credit exceeds the taxpayer’s tax liability. In other 

cases, the EITC may reduce a taxpayer’s tax liability but does not result in a refund. In this 

report, we focus on people who self-certify for and receive an EITC refund and the benefit 

they receive. We consider the refunded portion of the EITC to be a low-income program 

for the purposes of this report because it subsidizes the wages of low-income workers and 

provides a direct cash benefit to the taxpayer. The refunded portion of the EITC was 

among the four largest federal spending programs for people with low-incomes in fiscal 

year 2013, according to our prior work. GAO, Federal Low-Income Programs: Multiple 

Programs Target Diverse Populations and Needs, GAO-15-516 (Washington, D.C.: July 

15, 2015). 

4 In this report, we focus on individuals eligible for Medicaid under Modified Adjusted 

Gross Income (MAGI) rules (referred to in this report as “MAGI-eligible”). As of January 1, 

2014, MAGI rules are to be used in determining eligibility for most of Medicaid’s nonelderly, non-disabled populations. A different eligibility process, not discussed in this 

report, is used for other groups of people, including the elderly and disabled individuals 

who qualify for Medicaid on the basis of being blind or disabled without regard to whether 

the individual is eligible for SSI.

5 TANF is a block grant to states that emphasizes work and time-limited cash assistance 

and gives states wide discretion on how to use TANF funds, including for various noncash 

services. In this report, we focus on TANF cash assistance, which is defined as 

“assistance” under the U.S. Department of Health and Human Services’ regulations.

6 We previously reported that Medicaid (the largest program in terms of federal spending 

and program recipients), SNAP, SSI, and the refunded portion of the EITC comprised 

almost two-thirds of fiscal year 2013 federal obligations among the 80 plus federal 

programs we examined that provide aid to people with low incomes. See GAO-15-516. By 

financial eligibility rules, we mean rules regarding income and asset limits, as opposed to 

nonfinancial eligibility rules, such as those related to having a disability.
Page 3 GAO-17-558 Federal Low-Income Programs

information for these comparative analyses, including the program target 

populations and eligibility and benefit rules, using a two-step process. 

First, we reviewed relevant federal agency reports, documents, and 

agency guidance, as well as GAO and Congressional Research Service 

(CRS) reports describing program eligibility rules and benefits. In some 

cases, we also reviewed relevant federal laws and regulations, although 

we did not conduct a comprehensive legal review. Second, to ensure the 

accuracy of this information and our analysis, we obtained confirmation of 

the applicable program information and rules as of December 2016 from 

the specific agency that administers each program, such as the U.S. 

Department of Agriculture, Food and Nutrition Service (FNS) for SNAP.

To address the second question, we relied primarily on findings and 

analyses from previous GAO reports on the six selected programs. To 

supplement our prior work, we also reviewed CRS and other 

governmental reports on low-income programs, as well as selected 

reports and testimony by research and policy organizations with expertise 

in this area.7

We conducted this performance audit from May 2016 through June 2017 

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 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The six selected federal programs have varying purposes and are 

designed to target different segments of the low-income population, 

according to information confirmed by the administering agencies (see 

table 1). For example, EITC targets working families, whereas SSI targets 

the elderly, blind, and disabled. Because potential participants must 

generally meet a test of financial need in order to be eligible for benefits, 

 7 In selecting policy reports and testimony from research and policy organizations, we 

considered those that discussed eligibility or benefit issues, looked across low-income 

programs rather than at a single program, and offered a range of perspectives on these 

programs. Reports and testimony we reviewed were from the American Enterprise 

Institute, the American Public Human Services Association, the Center for Law and Social 

Policy jointly with the Urban Institute, and the Heritage Foundation. 

Background
Page 4 GAO-17-558 Federal Low-Income Programs

these programs are commonly referred to as “means-tested programs.”8

Three of the programs—EITC, SSI, and TANF—provide direct cash 

assistance to recipients, while the other programs provide an in-kind 

benefit, meaning that the recipient receives a good or service rather than 

cash.9 The six programs serve millions of low-income people, ranging

from nearly 69 million individuals a month for Medicaid to about 4 million 

individuals a month for TANF in fiscal year 2015, according to our 

analysis of agency data, as confirmed by the agencies.

Table 1: Program Purposes, Type of Benefit, and Numbers Served for Six Selected Federal Low-Income Programs

Program Purpose/population Type of benefit Number of individuals served 

in an average month in FY 

2015 (unless otherwise noted)

Earned Income Tax Credit 

(EITC) (refunded portion)a To offset the burden of taxes, including Social Security taxes; provide an incentive to 

work; and provide income support to lowincome families with earnings.

Cash assistance 23.7 million tax returns 

(rounded)b

Housing Choice Vouchers To enable very low-income families, the 

elderly, and the disabled to afford decent, 

safe, and sanitary housing in the private 

market.

In-kind benefit in the 

form of a rent subsidy

5.32 millionc

Medicaid To finance the delivery of health care 

services to eligible low-income adults, 

children, pregnant women, elderly adults and 

people with disabilities 

In-kind benefit in the 

form of health care 

services

68.9 million (projected)d

Supplemental Nutrition 

Assistance Program 

(SNAP)

To alleviate hunger and malnutrition and 

permit low-income households to obtain a 

more nutritious diet by increasing their food 

purchasing power.

In-kind benefit in the 

form of electronic 

benefits for food

45.8 million 

Supplemental Security 

Income (SSI)

To provide a minimum income for aged, blind 

or disabled individuals who have very limited 

income and assets.

Cash assistance 8.2 millione

 8 In this report, we may use the terms “participants,” “recipients,” or “beneficiaries” 

interchangeably to refer to individuals, families, or other entities that are receiving benefits 

from one of our selected low-income programs.

9 SNAP benefits are generally considered in-kind assistance, though these benefits are 

provided to SNAP recipients through Electronic Benefit Transfer cards. These cards work 

generally like a debit card at approved SNAP retailers, where recipients swipe their card 

and enter their personal identification number to pay for eligible food items. Similarly, 

Housing Choice Vouchers are also considered in-kind assistance in the form of a voucher 

that can be used to pay for rent. As mentioned previously, states may use their TANF 

block grant funds to provide both cash assistance and noncash services to eligible 

participants; however, in this report we focus on TANF cash assistance.
Page 5 GAO-17-558 Federal Low-Income Programs

Program Purpose/population Type of benefit Number of individuals served 

in an average month in FY 

2015 (unless otherwise noted)

Temporary Assistance for 

Needy Families (TANF) 

cash assistance

To provide assistance to needy families so 

that children may be cared for in their own 

homes or in the homes of relatives, among 

other purposes.f

Cash assistance 4.18 million

Source: GAO analysis of prior GAO work and agency data, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Individuals may receive benefits from more 

than one program. The data in this table cannot be used to determine the total number of individuals 

served through all six programs.

a

The EITC is a tax credit that reduces tax liability dollar-for-dollar. The EITC can result in a refund for 

the taxpayer, if the credit exceeds the taxpayer’s tax liability. In other cases, the EITC may reduce a 

taxpayer’s tax liability but does not result in a refund. In this report, we focus on people who claim and 

receive an EITC refund and the benefit they receive.

b

This figure represents the number of 2015 tax returns that contained a claim for and resulted in a 

refund from the EITC and does not represent the number of individuals served in an average month.

These returns were filed in 2016. In addition to the 23.7 million tax returns that resulted in a refund, 

3.6 million tax returns contained a claim for the EITC that resulted in an offset of taxes owed but not a 

refund. The number of individuals served, which may include both spouses and children in the 

household, would be higher than the number of tax returns. According to a Treasury official, an 

internal analysis estimated that 70.8 million individuals received an EITC in calendar year 2015, either 

as a tax filer or one of the qualifying children on the return. This estimate includes all individuals who 

received an EITC, not just those who received a refund.

c

This figure represents the number of persons served by a Housing Choice Voucher in December 

2015 (single point-in-time).

d

This figure represents the total projected average monthly enrollment for Medicaid.

e

This figure represents the number of individuals who received at least one SSI payment during 

calendar year 2015. For SSI, a state can choose to supplement federal payments with state funds to 

whatever extent it finds appropriate with respect to the needs of its citizens and the resources of the 

state. States may administer their own program or they may enter into an agreement whereby the 

federal government administers the state program in exchange for a fee. This figure does not include 

those served by the SSI State Supplementary Programs.

f

The other purposes of TANF are to end the dependence of needy parents on government benefits by 

promoting job preparation, work, and marriage; prevent and reduce the incidence of out-of-wedlock 

pregnancies and establish annual numerical goals for preventing and reducing the incidence of these 

pregnancies; and encourage the formation and maintenance of two-parent families. We do not report 

spending on or numbers served by noncash assistance services related to these purposes.

Medicaid is the largest program in terms of expenditures on benefits 

among the six selected programs, according to information provided by 

the administering agencies, totaling $329.73 billion in federal spending for 
Page 6 GAO-17-558 Federal Low-Income Programs

the entire Medicaid population in fiscal year 2015 (see fig.1).10 Federal 

spending on benefits for the five other programs ranged from $4.16 billion 

for TANF cash assistance to $66.60 billion for SNAP in that year. In TANF 

and Medicaid, states and the federal government generally share in the 

cost of benefits, whereas benefits are entirely federally funded for EITC, 

SNAP, SSI, and Housing Choice Vouchers.11

Figure 1: Federal Expenditures on Benefits for Six Low-Income Programs, in Billions, Fiscal Year 2015

 10 Figure 1 represents expenditures on the total Medicaid population, not just those whose 

financial eligibility is determined based on Modified Adjusted Gross Income rules. 

Medicaid differs from the other programs we selected in that the costs of benefits or 

services received are generally driven by individual health care needs and the rising costs 

of the health care market generally, as well as recent expansions to the eligible 

population. According to CRS, spending on Long Term Services and Supports (LTSS) 

makes up a sizeable portion of Medicaid expenditures (federal and state), accounting for 

about 26 percent of all Medicaid spending, despite LTSS recipients representing a 

relatively small share of the total Medicaid population, at 6.4 percent. LTSS benefits 

include nursing facility services and home health services. Other types of LTSS include 

case management services, personal care services, and private duty nursing. 

11 The federal government and states share in the financing of the Medicaid program, with 

the federal government matching most state expenditures for Medicaid services based on 

a statutory formula. As a condition of receiving federal TANF block grant funds, states are 

required to spend a certain amount of their own funds on TANF-allowable categories—

called state maintenance of effort (MOE) spending. In fiscal year 2015, state spending on 

cash assistance benefits totaled $3.64 billion, according to our analysis of agency data, as 

confirmed by the agency. 
Page 7 GAO-17-558 Federal Low-Income Programs

Note: The numbers in this figure represent federal expenditures for program benefits in the 50 states 

and the District of Columbia unless noted otherwise.

a

Represents expenditures on the total Medicaid population, not just those whose financial eligibility is 

determined based on Modified Adjusted Gross income rules. In fiscal year 2015, states paid an 

additional $194.53 billion in Medicaid benefits, not shown in the figure.

b

Includes SNAP expenditures made on behalf of recipients in Guam and the U.S. Virgin Islands.

c

Includes EITC expenditures for the refunded portion only. In fiscal year 2015, an additional $2.12 

billion was expended on offsets for taxes owed, not shown in the figure.

d

Includes SSI expenditures made on behalf of recipients in the Northern Mariana Islands.

e

Includes Housing Choice Voucher expenditures made on behalf of recipients in Guam, the Northern 

Mariana Islands, Puerto Rico and the U.S. Virgin Islands. Because of how the Department of Housing 

and Urban Development reports its data, this figure includes administrative costs as well as costs for 

benefits.

f

States spent an additional $3.64 billion of their state maintenance of effort (MOE) funds for cash 

assistance benefits in fiscal year 2015, not shown in this figure.

Several federal departments and agencies or offices administer and 

oversee the six selected low-income programs (see table 2).

Table 2: Federal Departments and Agencies Responsible for Six Low-Income 

Programs

Program Federal department Federal agency or office

Earned Income Tax Credit U.S. Department of the 

Treasury

Internal Revenue Service

Medicaid U.S. Department of Health 

and Human Services

Centers for Medicare & 

Medicaid Services

Housing Choice Vouchers U.S. Department of Housing 

and Urban Development

Office of Public and Indian 

Housing

Supplemental Nutrition 

Assistance Program

U.S. Department of 

Agriculture

Food and Nutrition Service

Supplemental Security 

Income

N/A Social Security 

Administration

Temporary Assistance for 

Needy Families

U.S. Department of Health 

and Human Services

Administration for Children 

and Families

Source: Agency documentation. | GAO-17-558

The funding structure of these low-income programs differs, which to 

some extent may affect the number of program recipients. SNAP, EITC, 

SSI, and Medicaid are open-ended entitlement programs, which means 

that the government is legally required to make payments to individuals or 

families who meet the requirements established by law. As a result, all 

individuals or families who apply for these programs and are eligible are 

entitled to benefits. In contrast, the Housing Choice Voucher and TANF 

cash assistance programs are not entitlement programs, and the number 

of recipients may be limited, in part, by these programs’ funding 
Page 8 GAO-17-558 Federal Low-Income Programs

amounts.12 Programs also differ in their source of funding: some 

programs are entirely federally-funded, while in other programs, the 

states and the federal government each contribute some funding for 

benefits, program administration, or both.

Partly because the programs have different purposes and to some extent 

target different populations, the six low-income programs vary in the 

extent of their reach. Figure 2 shows the number of program recipients, 

according to agency data, as a percentage of the total U.S. population.13

As a general comparison, in 2015, Medicaid served 22 percent of the 

population, or more than 1 in 5 people,14 while TANF served 1 percent of 

the total U.S. population in that year.15

 12 CRS, Need-Tested Benefits: Estimated Eligibility and Benefit Receipt by Families and 

Individuals, R44327 (Washington, D.C.: Dec. 30, 2015). 

13 The percentages are not strictly comparable due to differences in the agency data. See 

figure note for further detail.

14 In this instance, we are referring to the total Medicaid population, not just those who are 

MAGI-eligible.

15 See appendix I for information on participation rates for subsidized housing (which 

includes the Section 8 Housing Choice Voucher program, as well as the project-based 

rental assistance program and the public housing program), SNAP, SSI, and TANF. The 

participation rates show the numbers served for each program as a percentage of the 

eligible population.
Page 9 GAO-17-558 Federal Low-Income Programs

Figure 2: Program Recipients as a Percent of Total U.S. Population in 2015

Note: We calculated these percentages by comparing the number of individuals, and for EITC, tax 

returns, that receive benefits from each program to the total U.S. population for 2015 (estimated as of 

March 2016). The percentages are not strictly comparable because the underlying time unit for 

numbers served varies (i.e. SNAP, TANF, and Medicaid report numbers served as monthly averages 

for fiscal year 2015, while Housing Choice Vouchers report numbers served in December 2015 

(single point-in-time), SSI reports numbers served at any one time during calendar year 2015, and 

EITC reports the total number of tax returns receiving refunds n calendar year 2015.)

a

Represents the total number of Medicaid recipients, not just the subset whose financial eligibility is 

determined based on Modified Adjusted Gross Income rules.

b

This reflects the number of tax returns that self-certified for the EITC and received a refund from it. 

Because tax returns may be for one or more individuals, this percentage should be considered a 

minimum. According to a Treasury official, an internal analysis estimated that 70.8 million individuals, 

or about 22 percent of the U.S. population, received an EITC in calendar year 2015, either as a tax 

filer or one of the qualifying children on the return. This estimate includes all individuals who received 

an EITC, not just those who received a refund.

Common basic elements exist in how the six low-income programs 

determine program eligibility.16 Figure 3 provides a conceptual overview 

of the types of elements typically considered when determining eligibility 

for these low-income programs. Generally, several factors are taken into 

consideration to assess applicant eligibility.17 For determining financial 

 16 While there are common elements in how these six programs determine eligibility, the 

specific requirements vary by program. 

17 In this report, we use the term “applicant” to refer to a potential program recipient. 

Depending on the program, the applicant unit may be an individual, married couple, 

family, or household. However, there is no application process for the EITC. Taxpayers 

self-certify their eligibility and claim the credit on their tax returns. 

Process for Determining 

Eligibility
Page 10 GAO-17-558 Federal Low-Income Programs

eligibility, the factors commonly considered include how much income the 

applicant has (both earned, such as wages, and unearned, such as 

income from other public benefit programs), as well as, for some 

programs, the applicant’s assets. Further, certain nonfinancial factors 

may be taken into consideration to assess applicant eligibility, such as 

whether the applicant has a dependent child or a disability or is working. If 

an applicant is found to be eligible for a program, the benefit amount they 

are eligible for is then determined using the benefit rules for that particular 

program.18

Figure 3: Conceptual Overview of Key Features of the Eligibility Determination 

Process for Selected Low-Income Programs

Note: This figure provides a general overview of common steps taken in determining eligibility for our 

six selected programs; the specific requirements vary by program. This figure does not include rules 

used to determine benefit amounts.

a

In this figure, we use the term “applicant” to refer to a potential program recipient. Depending on the 

program, the applicant may be an individual, married couple, family, or household. However, there is 

no application process for the EITC. Taxpayers self-certify their eligibility and claim the credit on their 

tax returns. 

 18 Benefits for Medicaid are provided in the form of health care services to beneficiaries. 

As opposed to a benefit that is calculated by a formula, the level of health care services 

provided is determined by the beneficiaries’ health care needs and the benefit design in 

the state. States make decisions regarding what health services to cover beyond the 

minimum coverage and benefits standards required by federal law, and they establish the 

amount, duration, and scope of services within broad federal guidelines. 
Page 11 GAO-17-558 Federal Low-Income Programs

In addition to having different program purposes, the six programs we 

reviewed target a range of low-income populations, including people with 

some earnings, people who are elderly or disabled, or families with 

dependent children, according to our analysis of agency documents, as 

confirmed by the agencies (see table 3). The programs’ nonfinancial 

eligibility rules establish the specific characteristics an individual or 

household must have, if any, in order to be eligible for the program.

19 For 

example, to qualify for TANF, families generally must have a dependent 

child, while for SSI, the applicant must be 65 years old or older, blind, or 

have a disability that meets certain requirements.

Table 3: Target Populations among Selected Low-Income Programs (as of 

December 31, 2016)

Program Target population

Earned Income Tax Credit 

(EITC)

Low-income working families with children age 18 or 

younger, disabled children, students under 23, and 

childless adults with earned income below set limits.

Housing Choice Vouchers Low and very low-income families, individuals age 65 or 

older, and the disabled (which may include single 

individuals).

Medicaid Low-income families with dependent children; pregnant 

women; individuals age 65 or older, or blind or disabled 

individuals; nonelderly, nondisabled low-income individuals 

in certain states.

 19 Unless otherwise indicated, in this report we focus on the rules for each program that 

are set at the federal level, although some program rules may vary by state.

Selected Federal 

Low-Income 

Programs Vary with 

Regard to Target 

Populations, Rules for 

Counting Income and 

Assets, and Benefits

Selected Programs Target 

a Range of Low-Income 

Populations, Including 

People Who Are Elderly or 

Disabled or Those with 

Dependent Children, and 

Some Require Work
Page 12 GAO-17-558 Federal Low-Income Programs

Program Target population

Supplemental Nutrition 

Assistance Program 

(SNAP)

Low-income households.

Supplemental Security 

Income (SSI)

Low-income individuals age 65 or older or blind or disabled 

children or adults.

Temporary Assistance for 

Needy Families (TANF)

Needy families with children.a

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies.

a

For TANF, this includes eligible families with a pregnant woman and families with a dependent child.

Federal low-income programs sometimes have overlapping target 

populations, and program rules for some programs allow those who 

qualify for one program to be automatically eligible for another—also 

known as categorical eligibility—which, as we have previously reported, 

can both ease access to these programs as well as reduce administrative 

costs.20 For example, according to SSA, in most states SSI recipients are 

automatically eligible for Medicaid, and we have previously reported that 

some TANF recipients are automatically eligible for SNAP. Specifically, 

TANF cash assistance recipients are categorically eligible for SNAP, and 

some states have opted to extend categorical eligibility to households 

authorized to receive certain TANF or state maintenance of effort (MOE)-

funded noncash services under broad-based categorical eligibility (BBCE) 

policies.21

Nonfinancial eligibility rules for some of the programs we reviewed also 

include requirements that participants must comply with as a condition of 

eligibility for benefits or services, such as participation in work or workrelated activities in three of the programs (see table 4). For example, 

federal TANF rules require states to engage a certain percentage of 

families receiving cash assistance in specified work-related activities, 

such as job search and job readiness assistance, if there is an individual 

in the family who is generally required to work. EITC is unique in that its 

target population is working low-income people, and therefore, EITC rules 

 20 GAO, Supplemental Nutrition Assistance Program: Improved Oversight of State 

Eligibility Expansions Needed, GAO-12-670 (Washington, D.C.: July 26, 2012).

21 As of August 2016, 39 states and the District of Columbia had expanded SNAP 

eligibility through BBCE, according to USDA. For more information on BBCE, see 

GAO-12-670. 
Page 13 GAO-17-558 Federal Low-Income Programs

require work for initial eligibility. Since EITC is administered through the 

tax system, it generally requires tax filers who claim the credit to have 

earned income—as its name suggests—unlike the other programs we 

reviewed.

Table 4: Work Requirements for Eligible Adults among Selected Low-Income Programs (as of December 31, 2016)

Program Federal work requirement Who is required to work, if applicable

Earned Income Tax 

Credit (EITC)

Yes - In order to receive the EITC benefit, eligible 

taxpayers must have earned income, such as from 

wages from working or self-employment earnings.

Taxpayers applying for EITC, or at least one 

taxpayer in the case of joint returns.

Housing Choice 

Vouchers

None N/A

Medicaid None N/A

Supplemental Nutrition 

Assistance Program 

(SNAP)

Yes - SNAP requires participants to work, register for 

work, and/or participate in an employment and training 

program if assigned by the state SNAP agency, unless 

otherwise exempt.

SNAP recipients ages 16 through 59 who are 

mentally and physically able to work and who are 

not otherwise exempt.

In addition to the general work requirements, 

able-bodied adults between 18 and 49 without 

dependents must work and/or participate in a 

qualifying work program at least 80 hours per 

month, or comply with a workfare program, to 

receive SNAP for more than 3 months in 3 years.

Supplemental Security 

Income (SSI)

Nonea N/A

Temporary Assistance 

for Needy Families 

(TANF)

Yes - For those receiving TANF cash assistance, federal 

law requires each state to engage

• at least 50 percent of all TANF families with a workeligible individual and

• at least 90 percent of two-parent TANF families with 

two work-eligible individuals

in specified work or work-related activities or face 

potential financial penalties. However, these 

percentages are subject to adjustments based on 

caseload reduction and state spending. The specified 

work activities include job search and job readiness 

assistance, among other activities.b

Work-eligible individuals in families receiving 

TANF cash assistance.

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies.

a

In order to be eligible for SSI benefits based on a disability, an adult must have a medically 

determinable physical or mental impairment that (1) prevents the individual from engaging in any 

substantial gainful activity, and (2) has lasted or is expected to last at least 1 year or result in death. 

While disabled adult SSI recipients have generally been determined by the Social Security 

Administration to be unable to work, taking into account age, education, and work experiences, 

program rules allow disabled SSI recipients to work and still receive monthly benefits, provided their 

earnings do not exceed certain limits and other conditions are met.

b

TANF family participation in 12 specified work activities counts toward the state performance 

measure: unsubsidized employment, subsidized private sector employment, subsidized public sector 
Page 14 GAO-17-558 Federal Low-Income Programs

employment, on-the-job training, job search and readiness, work experience, community service, 

vocational educational training, job skills training, education directly related to employment, 

completion of secondary school, and providing child care to a community service participant. Our 

review of eligibility rules included only those for TANF cash assistance and not those related to other 

noncash TANF services.

The six low-income programs we reviewed use different rules to 

determine the financial eligibility of program applicants, according to our 

analysis of agency documents, as confirmed by the agencies. These 

variations affect whose income is counted, what income is and is not 

counted, whether expenses are deducted from income, and how much 

income applicants may have and still be eligible.

The six programs we reviewed differ not only in their definitions of who 

the benefit is provided to once eligibility is determined—which we refer to 

as the “applicant unit”—but also in how they count the income of different 

people when determining applicant eligibility.22 For some programs, such 

as SSI, the applicant unit is the individual, while for others, such as 

SNAP, the unit is the household (see table 5).23 Further, while programs 

may use similar terminology, there is no single definition of “family” or 

“household” used across these low-income programs—the same term 

may mean different things depending on the program. For purposes of 

counting income, for example, both TANF and the Housing Choice 

Voucher program count the income of individuals in a “family.” However, 

in the case of the Housing Choice Voucher program, for example, a 

single person living alone or a group of persons living together is 

considered a “family,” while for TANF cash assistance, states determine 

what constitutes a “family” and the family must generally include a 

dependent child. In addition, in some programs, the applicant unit differs 

from whose income is counted when determining financial eligibility. For 

example, in SSI, while the applicant is typically an individual, the income 

of the applicant’s parent or spouse may be considered when determining 

eligibility, if that person is living in the applicant’s household.

 22 Unlike for the other selected programs, taxpayers self-certify their eligibility for EITC 

and claim the credit on their tax returns.

23 As we previously reported, most low-income programs target specific sub-populations 

and do not serve low-income people generally. See GAO, Federal Low-Income Programs: 

Multiple Programs Target Diverse Populations and Needs, GAO-15-516 (Washington, 

D.C.: July 30, 2015).

Selected Programs Differ 

Greatly in How Income Is 

Counted and How Much 

Income Applicants May 

Have to Be Eligible

Whose Income Is Counted
Page 15 GAO-17-558 Federal Low-Income Programs

Table 5: Applicant Unit and Whose Income Is Counted in Determining Eligibility among Selected Low-Income Programs (as of 

December 31, 2016)

Program Applicant unit Whose income is counted

Earned Income Tax 

Credit (EITC)

Individual taxpayers or married 

couples (if filing a joint return)

Individual taxpayers or married couples (if filing a joint return). All income and 

earnings amounts are calculated at the tax return level.

Housing Choice 

Vouchers

Household Family, meaning a single person or a group of persons living together.

Medicaid Individual Household, based on Modified Adjusted Gross Income (MAGI).a With certain 

exceptions, Medicaid defines total household income as the sum of the 

MAGI-based income of every individual included in the household.b

Supplemental 

Nutrition 

Assistance 

Program (SNAP)

Householdc Household, including all eligible and ineligible household members (such as 

those with an intentional program violation). Earned income of children under 

18 who are elementary or secondary school students is exempted from 

countable household income. 

Supplemental 

Security Income 

(SSI)

Individual or married couple Individual or married couple applying for benefits, as well as others in the 

household. For example, if applicant has a spouse living in the same 

household who is not eligible for benefits, that individual’s income is 

considered. If applicant is under 18 and living in the parent(s) household, 

parent(s) income is considered.

Temporary 

Assistance for 

Needy Families 

(TANF)

Family Family, which is determined by the state and includes dependent children, 

their siblings, and their parents or other caretaker relatives living together.

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies.

a

In this report, we focus on individuals eligible for Medicaid under Modified Adjusted Gross Income 

(MAGI) rules. MAGI-based Medicaid rules take into account the application of MAGI to individuals 

who do not file taxes (usually due to no filing requirement), as well as exceptions for certain tax 

dependents who are treated as non-filers. As of January 1, 2014, MAGI rules are used in determining 

eligibility for most of Medicaid’s non-elderly, non-disabled populations. A different eligibility process, 

not discussed in this report, is used for other groups of people, including the elderly and disabled 

individuals who qualify for Medicaid on the basis of being blind or disabled without regard to whether 

the individual is eligible for SSI.

b

These exceptions include: the income of a child who is included in the household of his or her natural 

parent, adopted parent, or step-parent and is not expected to file a tax return is not included in the 

Medicaid household income; the income of a tax dependent who is not expected to file a tax return is 

not included in the Medicaid household income of the taxpayer, regardless of whether the tax 

dependent files a tax return; and Medicaid household income may, at state option, include cash 

support above nominal amounts provided by another tax payer expected to claim a member of the 

household (other than a spouse, a natural child, adopted child, or step-child) as a tax dependent.

c

In general, SNAP defines a household as persons living together who purchase food and prepare 

meals together for home consumption. Some people (such as spouses and children 21 and under) 

who live together are included in the same household even if they purchase and prepare meals 

separately.

The programs we reviewed also differ in how they treat an applicant’s 

earned income—or income earned from working—for the purposes of 

eligibility determination, according to our analysis of agency 

What Income Is and Is Not 

Counted
Page 16 GAO-17-558 Federal Low-Income Programs

documentation, as confirmed by the agencies, with some programs 

structuring their earned income rules to incentivize work, as we have 

previously reported (see table 6).24 For example, when determining 

income eligibility for SNAP, federal rules disregard 20 percent of the 

applicant household’s earned income. In other words, if an applicant has 

$1,000 in monthly earned income, only $800 is considered when 

calculating the household’s income eligibility for SNAP.25 For TANF, 

states determine earned income rules, and according to HHS, almost all 

states disregard some earned income, either as a percentage of 

earnings, a set dollar amount, or both, although the percentage or amount 

differs by state.

Table 6: Types and Amounts of Earned Income Disregarded in Determining Initial Financial Eligibility, by Selected LowIncome Program (as of December 31, 2016)

Program Earned income disregarded, for initial eligibility

Earned Income Tax Credit 

(EITC)

Federally-set rules: Adjusted Gross Income (AGI), which partially determines the credit amount 

from EITC, includes additional sources of income besides earned income and permits certain 

allowable deductions. However, there are no specific earned income types that are always 

disregarded in determining eligibility.a

Housing Choice Vouchers Federally-set rules: After total annual income has been calculated (including both earned and 

unearned income), there is a mandatory deduction of $480 for each dependent and $400 for any 

elderly family or disabled family members. In addition, the Housing Choice Voucher excludes 

earned income of minors, among others, when calculating annual income. 

Medicaid Federally-set rules: Specific earned income disregards are not permitted for Medicaid eligibility 

under MAGI-based rules.b

Supplemental Nutrition 

Assistance Program (SNAP)

Federally-set rules: The federal earned income deduction provides for a 20% deduction of earned 

income.

c

Supplemental Security Income 

(SSI)

Federally-set rules: After total monthly income has been calculated, there is a mandatory deduction 

of $20 per month of income and $65 per month of earnings for recipients plus one-half of 

remaining earnings.

Temporary Assistance for Needy 

Families (TANF)

State-determined rules: As of July 2015, examples of earned income disregards for initial income 

eligibility included set amounts (e.g., $90) and proportions of earned income (e.g. 20% of earned 

income).

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

 24 See GAO-02-58.

25 The SNAP income eligibility process has both gross and net income tests. The 20 

percent earned income disregard occurs when assessing whether the applicant meets the 

net income test. Under MAGI-based Medicaid rules, an applicant with $1,000 in monthly 

earned income would have 5 percent of the federal poverty guidelines for their family size 

deducted from their counted income. For example, if the applicant is part of a three-person 

family, $84 would be deducted from earned income, and therefore $916 would be 

considered for determining Medicaid eligibility, as of December 2016.
Page 17 GAO-17-558 Federal Low-Income Programs

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other noncash TANF services.

a

Taxpayers who receive combat pay, which is generally exempt from tax, have the option to include it 

in earned income if this results in a larger EITC. Additionally, certain adjustments to income are 

permitted under tax rules to calculate Adjusted Gross Income. These adjustments include, for 

example: student loan interest deduction, tuition and fees, alimony paid, educator expenses, and 

moving expenses.

b

As of January 1, 2014, the MAGI-based rules have required a state to subtract an amount equal to 5 

percentage points of the federal poverty guidelines for the applicable family size from an individual’s 

total income in determining Medicaid eligibility.

c

In addition, the standard deduction is available to all SNAP applicants, regardless of whether they 

have earned income or unearned income, and is meant to cover other household costs not otherwise 

covered by the other deductions. For fiscal year 2016, the federal standard deduction provided a 

deduction $155 for households of 1 to 3 people and $168 for a household of 4 (higher for some larger 

households).

The programs we reviewed also differ greatly in how they treat an 

applicant’s unearned income—which may include benefits received from 

other federally-funded programs for low-income people—for the purposes 

of eligibility determination (see table 7). A low-income family is likely to be 

eligible for and may participate in more than one low-income program. 

However, not all of those eligible received a benefit. We have previously 

reported that families receiving TANF cash assistance generally also 

receive Medicaid and SNAP.26 However, because of differences in these 

programs’ eligibility rules related to unearned income, TANF benefits are 

counted as income when determining SNAP eligibility but not counted as 

income when determining Medicaid eligibility, according to our analysis of 

agency documents, as confirmed by the agency. In contrast, the cash 

benefit received from the refunded portion of EITC is not counted as 

income when determining eligibility for any of the other selected 

programs. According to a 2015 CRS analysis, of those who received a 

benefit from one of nine major federally funded low-income programs, an 

estimated 41 percent received benefits from one program and an 

estimated 27 percent received benefits from two programs.27 The 

remaining families received benefits from three or more programs. 

According to CRS, 18 percent of families received benefits from three 

programs, 9 percent received benefits from four programs, and less than 

5 percent received benefits from five or more programs. The nine low-

 26 GAO-02-58.

27 Congressional Research Service, Need-Tested Benefits: Estimated Eligibility and 

Benefit Receipt by Families and Individuals (Washington, D.C.: Dec. 30, 2015). For more 

information on program participation by those eligible, see app. I. 
Page 18 GAO-17-558 Federal Low-Income Programs

income programs in CRS’s analysis included five of the six we reviewed 

for this report.28

Table 7: Benefits from Selected Federally-Funded Low-Income Programs That Are Either Included or Excluded when Counting 

Income for Financial Eligibility (as of December 31, 2016)

Program Benefits included Benefits excluded

Earned Income Tax 

Credit (EITC)

Benefits that are included in income can affect EITC to the 

extent that these benefits affect Adjusted Gross Income 

(AGI).

(Generally, however, benefits from low-income programs 

are not taxable, and therefore are not included in AGI.)

TANF, SSI, SNAP

(Generally, however, benefits from low-income 

programs are not taxable, and therefore are not 

included in AGI.)

Housing Choice 

Vouchers

TANF EITC, SNAP, SSI (for certain purposes) 

Medicaid None EITC, SNAP, TANF, SSI 

Supplemental Nutrition 

Assistance Program 

(SNAP)

SSI and TANF EITC 

Supplemental Security 

Income (SSI)

TANF EITC, Housing Choice Vouchers, SNAP 

Temporary Assistance 

for Needy Families 

(TANF)

At state discretion EITC, others at state discretion

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other noncash TANF services. The list of 

programs presented in this table as included or excluded from counted income includes only the six 

programs we reviewed and is therefore not exhaustive. For example, there are other programs’ 

benefits that are excluded or included, such as Unemployment Insurance, which is included for 

Medicaid and Housing Choice Vouchers, and the Low-Income Home Energy Assistance Program, 

which is explicitly excluded for Housing Choice Vouchers and SSI.

In calculating applicants’ income levels to determine eligibility, some of 

the low-income programs we reviewed deduct certain types of expenses 

from income, such as those for child care, utilities, and shelter, according 

to our analysis of agency documentation and information provided by 

agencies, as confirmed by the agencies. Programs may allow the 

 28 The CRS report reviewed nine programs: SNAP; TANF; EITC; SSI; Housing 

Assistance, including the Housing Choice Voucher program, among others; the Additional 

Child Tax Credit; the Special Supplemental Nutrition Program for Women, Infants, and 

Children; the Child Care and Development Fund; and the Low-Income Home Energy 

Assistance Program. Due to data limitations and methodological factors, Medicaid was not 

included in the central analysis of the CRS report and was instead discussed separately in 

an appendix.

Expenses Deducted from 

Counted Income
Page 19 GAO-17-558 Federal Low-Income Programs

deduction of certain types of expenses when determining applicant 

eligibility to ensure that the applicants’ financial circumstances and ability 

to meet certain basic needs are more fully captured. For example, 

Housing Choice Voucher and SNAP both deduct child care expenses 

when determining program eligibility, while EITC and Medicaid take these 

expenses into account in other ways (see table 8).29 (For additional 

deductions for selected other expenses, see appendix II.)

Table 8: Deductions for Child Care Expenses in Calculating Income for the Purpose of Determining Eligibility for Selected 

Low-Income Programs (as of December 31, 2016)

Program Deductions for child care expenses

Earned Income Tax Credit 

(EITC)

For some taxpayers, a portion of child care expenses can be excluded and are not counted as part 

of Adjusted Gross Income (AGI). Taxpayers may also be eligible for a child and dependent care tax 

credit, which has no effect on AGI or earnings for purposes of the EITC, but may affect the portion 

of the EITC that exceeds tax liability. 

Housing Choice Vouchers Reasonable child care expenses deducted for children under age 13a

Medicaid Child care expenses are generally not disregarded or deducted from income for determining 

Medicaid eligibility.b

Supplemental Nutrition 

Assistance Program (SNAP)

A household can deduct the actual cost of payments necessary for the care of a dependent if the 

care enables a household member to accept or continue employment, or training or education that 

is preparatory for employment.

Supplemental Security Income 

(SSI)

None.

Temporary Assistance for 

Needy Families (TANF)

Varies by state. Some states do not deduct any child care expenses while others deduct child care 

expenses in the same way as Medicaid.

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other noncash TANF services.

a

For the Housing Choice Voucher program, each local Public Housing Agency (PHA) administering 

the program can adopt policies on how it will determine what constitutes a reasonable childcare 

expense.

b

However, to the extent child care expenses are excluded from adjusted gross income (AGI) on a tax 

return, then these exclusions factor into applicants’ Modified Adjusted Gross Income (MAGI).

A fundamental difference among the six programs we reviewed is the 

variation in the income limits used for determining applicants’ program 

eligibility, according to our analysis of agency data and documentation, as 

confirmed by agencies. These programs differed in the ways they 

 29 For the Housing Choice Voucher program, each local Public Housing Agency (PHA) 

administering the program can adopt policies on how it will determine reasonable 

childcare expenses.

How Much Income Applicants 

May Have to Be Eligible
Page 20 GAO-17-558 Federal Low-Income Programs

measure applicants’ income, the standards and methods used to 

determine the maximum amount of income an applicant may have and 

still be eligible for the program, whether this amount is set nationwide or 

varies by state or locality, and the amount of the income limit itself. The 

various standards and methods used to set income limits by the selected 

programs include a fixed dollar amount, a percentage of the federal 

poverty guidelines (FPG) or Area Median Income (AMI), or Modified 

Adjusted Gross Income (MAGI)(see table 9).30 For two of the programs—

EITC and SSI—the maximum amount of income an applicant may have 

to be eligible is a federally-set dollar amount that applies nationwide; 

however, that amount differs by program.31 For the other four low-income 

programs we reviewed, the rules for determining the maximum amounts 

of income an applicant may have and still be eligible, the amounts 

themselves, and whether they are set nationwide or vary by state or 

locality, vary significantly, according to our analysis of agency data as 

confirmed by agencies.32 For Medicaid, TANF, and in states that have 

implemented SNAP BBCE policies, states or localities determine financial 

eligibility rules for applicants, generally within certain federal guidelines. 

For example, under SNAP BBCE policies, states have the flexibility to 

adopt policies that allow certain applicants with incomes up to 200 

percent FPG to be eligible, whereas federal rules generally allow 

applicants with incomes up to 130 percent FPG to be eligible.33 In the 

 30 The FPG are a simplified version of the poverty thresholds that the Census Bureau 

uses to prepare its estimates of the number of individuals and families in poverty, and are 

updated annually by the Department of Health and Human Services based on the 

Consumer Price Index for All Urban Consumers. AMI is determined annually by the 

Department of Housing and Urban Development based on specified percentages of 

median family incomes for states and metropolitan and nonmetropolitan areas within 

states.

31 Even for programs with nationwide income limits, these limits will vary depending on the 

number of people in the applicant household. For example, SSI has different income limits 

depending on whether the applicant is an individual or a married couple. In the case of 

EITC, income limits are based on the number of children that are part of the tax unit 

claiming the credit. 

32 In the case of Housing Choice Vouchers, federal rules require that eligibility be based 

on AMI; however, AMI varies throughout the country by state and locality—not surprising 

given the different costs of living in urban and rural areas across the nation.

33 Under BBCE, states can allow households authorized to receive certain TANF noncash 

services to be categorically eligible for SNAP. States that adopt a BBCE policy may 

increase limits on household gross income to up to 200 percent of FPG. However, 

categorically eligible households are subject to the same nonfinancial rules as other 

households, and while the household may be categorically eligible, its income after 

allowable deductions may be too high to actually receive a SNAP benefit. For the 

purposes of this report, we refer to the non-BBCE SNAP eligibility rules as “federal rules.”
Page 21 GAO-17-558 Federal Low-Income Programs

case of TANF, states have flexibility in how they establish eligibility, 

including choosing both the type of measure and income level they use. 

For Medicaid and the Housing Choice Voucher program, there are also 

different income limits for different populations within the program.34

Table 9: Standards and Methods Used to Set Income Limits for Program Eligibility (as of December 31, 2016)

Program Standards and Methods used to set income limits for eligibility

Earned Income Tax 

Credit (EITC)

Federally-set, specific dollar amounts.

The two main income measures used for calculating program eligibility are (individual or joint) earnings and 

Adjusted Gross Income (AGI). As of December 2016, the maximum income per month for a single mother 

with two children was $3,721.a

Housing Choice 

Vouchers

Federally-set, percentage of Area Median Income (AMI).

HUD uses a relative measure of income, AMI, for determining benefits and eligibility for the Housing Choice 

Voucher program. AMI is based on specified percentages of median family incomes for metropolitan and 

nonmetropolitan areas within states. For example, families generally must have incomes no higher than 50 

percent of the AMI to be eligible, and 75 percent of newly available vouchers each year must go to families 

whose incomes do not exceed the higher of (1) the applicable HHS poverty guidelines or (2) 30 percent of 

AMI.

Medicaid Federally-set, Modified Adjusted Gross Income (MAGI) based on federal poverty guidelines (FPG), with 

option for state variation within federal parameters. 

A federal requirement, MAGI is used to determine Medicaid income eligibility for most nonelderly and 

nondisabled individuals, including individuals under the age of 21, pregnant women, and adults under the 

age of 65. The income limits for MAGI-based Medicaid eligibility groups is expressed as a percentage of the 

official federal poverty guidelines, as updated annually by the Department of Health and Human Services. 

Specific MAGI percentages vary by state and eligible population.b MAGI was created under the Patient 

Protection and Affordable Care Act to create a standard definition of household income.

Supplemental Nutrition 

Assistance Program 

(SNAP)

Federally-set, federal poverty guidelines (FPG) with option for state variation within federal parameters.

The official federal poverty thresholds—the income levels by which households are considered to be in 

poverty depending on their size ($1,680 for a family of 3 as of December 2016)—are updated annually by the 

Census Bureau to reflect current prices. HHS then uses these thresholds to establish federal poverty 

guidelines, under which households without elderly or disabled individuals generally must have monthly 

gross income at or below 130 percent of FPG and monthly net income after allowable deductions at or below 

100 percent of FPG to qualify for SNAP. Households with elderly (defined as age 60 or older) or disabled 

individuals only have to meet the net income test of 100 percent of poverty.c

Supplemental Security 

Income (SSI)

Federally-set, specific dollar amounts. 

SSI has an income break-even point, above which a person no longer qualifies for an SSI benefit. As of 

December 2016, the Earned Income break-even point for an Individual applicant was $1,551, and for 

Unearned Income was $753.

 34 For the Housing Choice Voucher program, families generally must have incomes no 

higher than 50 percent of the AMI—considered “Very Low-Income”—to be eligible. 

However, 75 percent of newly available vouchers each year must go to families whose 

incomes do not exceed the higher of (1) the applicable HHS poverty guidelines or (2) 30 

percent of AMI—considered “Extremely Low-Income.”
Page 22 GAO-17-558 Federal Low-Income Programs

Program Standards and Methods used to set income limits for eligibility

Temporary Assistance 

for Needy Families 

(TANF)

State-determined: varies by states. 

Some states use federal poverty guidelines, which are annually adjusted, while others have a defined 

maximum limit set in state law that is not adjusted.

Source: GAO analysis of agency documentation and data, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other TANF noncash services.

a

We used the annual amount of $44,648, and divided by 12, to calculate an illustrative average 

maximum monthly dollar amount a filing individual can have with two children and still qualify for 

EITC. In fact the EITC is not available on a monthly basis. Taxpayers whose income varies over the 

year may have earned more or less than this average maximum amount in any given month. In 

addition, income from investments must be $3,400 or less per year.

b

Under the Patient Protection and Affordable Care Act (PPACA), certain groups are exempt from the 

MAGI income-counting rule. Pre-PPACA income determination rules under Medicaid will continue to 

apply to the following MAGI-exempted groups: Individuals who are eligible for Medicaid through 

another federal or state assistance program (e.g., foster care children and individuals receiving SSI; 

the elderly (defined as aged 65 and older); certain disabled individuals who qualify for Medicaid on 

the basis of being blind or disabled, without regard to the individual’s eligibility for SSI; the medically 

needy (defined as individuals who are members of one of the broad categories of Medicaid-covered 

groups, but who do not meet the applicable income requirements); and enrollees in a Medicare 

Savings Program (e.g., qualified Medicare beneficiaries for whom Medicaid pays the Medicare 

premiums or coinsurance and deductibles).

c

In states that have adopted broad-based categorical eligibility (BBCE) for SNAP, certain households 

who receive a noncash TANF or maintenance of effort (MOE)-funded benefit are categorically eligible 

for SNAP, meaning the income limit for the TANF/MOE program can be deemed for SNAP purposes. 

Gross income limits for categorically eligible households differ by state and range from 130 percent to 

200 percent of federal poverty guidelines.

To illustrate the different income limits used for these programs, we 

analyzed maximum allowable income using a common metric—dollars 

per month—for programs that have nationally set income limits (see 

figure 4) and for programs with a range of maximum allowable income 

due to state variation (see figure 5). For the purposes of illustrating 

maximum allowable income across these programs, we use a family of 

three—a single mother with two children—living in their own household, 

because we have previously found this to be a common recipient unit in 

federal low-income programs, such as TANF.35 Although these are the 

maximum allowable amounts of income such families may have to be 

eligible for each program, these amounts are not fully comparable 

because the calculation of this amount differs for each program by the 

factors discussed earlier in this report, such as whose income is counted. 

Also as already discussed, for an applicant, having income below the 

relevant threshold is one of the multiple factors that may be assessed 

 35 Due to different poverty guidelines for Alaska and Hawaii, we analyzed data for the 48 

contiguous U.S. states and the District of Columbia.
Page 23 GAO-17-558 Federal Low-Income Programs

when determining eligibility for each program. (For a comparison of 

maximum monthly income for all six programs, see app. III.)

Figure 4: Illustration of Maximum Monthly Amounts of Income an Applicant May 

Have and Still Be Eligible for Three Selected Low-Income Programs with NationallySet Maximum Income Limits

Allowable monthly income amounts for a family of 3, with single parent and 2 children, in 

the 48 contiguous states and Washington, D.C., as of December 31, 2016.

Note: Applicants with the amounts of income presented in the figure would not necessarily qualify for 

a benefit above $0. For example, an applicant for SSI with a monthly income of $1,551 would qualify 

for $0 in SSI benefits. While GAO did not independently verify the legal accuracy of the information in 

this figure, we confirmed the information with the cognizant agencies.

a

We used the annual amount of $44,648, and divided by 12, to calculate an illustrative average 

maximum monthly dollar amount a filing individual can have with two children and still qualify for 

EITC. In fact the EITC is not available on a monthly basis. Taxpayers whose income varies over the 

year may have earned more or less than this average maximum amount in any given month. In 

addition, income from investments must be $3,400 or less per year.

b

For SSI, this is the amount of earned income at which a disabled individual with no unearned income 

no longer qualifies for a federal SSI payment. The amount is higher for a married couple. However, in 

addition to meeting the financial requirements for SSI eligibility, a person must also be unable to 

engage in substantial gainful activity to qualify for SSI. In 2016, substantial gainful activity for a nonblind, disabled individual was defined as having earnings of more than $1,130 per month. For the 

purpose of illustrating SSI eligibility here, we are assuming that the single parent in the 3-person 

household is the applicant and has a disability that makes her eligible for SSI.

c

We use the term “federal” to refer to the SNAP eligibility rules used by states that have not adopted 

BBCE policies. The federal SNAP income amount represents 130 percent of the federal poverty 

guidelines, an amount set at the federal level. To be eligible for SNAP, most households must meet 
Page 24 GAO-17-558 Federal Low-Income Programs

gross and net income tests. Households cannot have gross monthly income (total, non-excluded 

income before any deductions) higher than 130 percent of federal poverty guidelines. They also 

cannot have net monthly income (gross income minus deductions) higher than 100 percent of federal 

poverty guidelines, or $1,680 per month for a household of three under standard program eligibility 

rules). .

Figure 5: Illustration of Range of Maximum Monthly Amounts of Income an Applicant May Have and Still Be Eligible for Four 

Selected Low-Income Programs with State Variations in Income Limits

Range of allowable monthly income amounts for a family of 3, with single parent and 2 children, in the 48 contiguous states and

Washington, D.C., as of December 31, 2016

Note: While GAO did not independently verify the legal accuracy of the information in this figure, we 

confirmed the information with the cognizant agencies.

a

The Housing Choice Vouchers program uses specified percentages of the Area Median Income 

(AMI) to determine eligibility. For example, families generally must have incomes no higher than 50 

percent of the AMI, to be eligible, and 75 percent of newly available vouchers each year must go to 

families whose incomes do not exceed the higher of (1) the applicable HHS poverty guidelines or (2) 

30 percent of AMI. The lowest state amount for 30 percent AMI, $1,613 per month, does not appear 

in the figure due to space limitations.

b

The amounts presented for Medicaid represent allowable amounts under Modified Adjusted Gross 

Income (MAGI) rules. As of January 1, 2014, MAGI rules are used in determining eligibility for most of 

Medicaid’s non-elderly non-disabled populations. For these eligibility groups, an individual’s income, 

computed using MAGI-based income rules, is compared to the income standards in the state in which 

the applicant lives to determine if they are income eligible for Medicaid. The MAGI-based rules 

generally include adjusting an individual’s income by subtracting an amount equivalent to 5 percent of

the official federal poverty guidelines (FPG). We present two columns for Medicaid because income 

limits under MAGI-based rules are different for parents and children. Since state Medicaid programs’

income eligibility limits may vary based on the age of a child (i.e. 0-1 year, 1-5 years, or 6-18), for the 

child analysis the income limit used is the lowest MAGI level in the state for the three age categories 
Page 25 GAO-17-558 Federal Low-Income Programs

for children. The lowest percentage was used so the maximum allowable household income 

represented would allow all children in that household to qualify for Medicaid. In addition, states have 

significant flexibility in setting income eligibility levels for children in Medicaid and Children’s Health 

Insurance Program (CHIP). States may operate CHIP as a separate program, include CHIP-eligible 

children in their Medicaid programs (referred to as CHIP Medicaid expansion), or use a combination 

of the two approaches. Our analysis for children includes income eligibility levels for CHIP Medicaid 

expansion programs, but not separate CHIP programs. A different process, not discussed in this 

report, is used for determining eligibility for non-MAGI groups, which include, among others: (1) 

individuals who are eligible for Medicaid through another federal or state assistance program (e.g., 

foster care children and individuals receiving Supplemental Security Income [SSI]), (2) the elderly, 

and (3) certain individuals who qualify for Medicaid on the basis of being blind or disabled without 

regard to whether the individual is eligible for SSI.

c

The range of maximum monthly income allowed presented in the figure for SNAP represents SNAP’s 

broad-based categorical eligibility (BBCE) state option, in which households may become 

categorically eligible for SNAP because they qualify for a noncash Temporary Assistance for Needy 

Families (TANF) or state maintenance of effort (MOE)-funded benefit. Under BBCE, states use the 

maximum allowable income amount a household may have for their TANF/MOE programs, so this 

amount varies by state, unlike with standard SNAP eligibility rules. As of August 2016, 39 states and 

the District of Columbia have adopted SNAP BBCE policies. Of these, 28 states and the District use 

an income amount to assess recipient eligibility higher than the federally-defined SNAP gross income 

limit of 130 percent of federal poverty guidelines. Under federal income eligibility limits, a household 

with three or more members will typically be determined eligible for a SNAP benefit greater than $0. 

However, because BBCE policies can make households with incomes higher than the federal limits 

eligible for SNAP, it is likely that more of these BBCE households will have net incomes too high to 

qualify for a benefit than under federal rules.

d

Data on income eligibility limits for TANF are as of July 2015, the most recent data available at the 

time of our review. Income limits for TANF are determined by states. Some states use federal poverty 

guidelines, which are annually adjusted, while others have a defined maximum limit set in state law 

that is not adjusted. Our review of eligibility rules included only those for TANF cash assistance and 

not those related to other noncash TANF services.

In addition to having income tests, some programs set certain limits on 

the assets that an individual or family may hold in order to be eligible for 

the program, while others do not, according to our analysis of agency 

data and documentation, as confirmed by the agencies. Assets—referred 

to as “resources” by some programs—generally include financial 

resources—such as cash held in checking and savings accounts, 

individual retirement accounts, 401(k)s, and other accounts that can be 

readily transferred into cash—and nonfinancial resources, such as a 

home or car. Similar to income limits, three of the six selected 

programs—SSI, TANF, and SNAP under federal rules—have federally set 

limits on the amount or type of financial assets that an individual or family 

may have in order to be determined eligible for benefits. For example, to 

qualify for SSI, the limit for countable assets is $2,000 for an individual 

and $3,000 for a married couple. However, certain nonfinancial assets, 

such one vehicle, do not count toward this limit. For SNAP, under federal 

rules, there is a limit of $2,250 in countable resources or $3,250 in 

countable resources if at least one person is age 60 or older or is 

disabled, and since 2008, these limits have been adjusted annually and 

rounded to the nearest $250 based on changes to the Consumer Price 

Index (CPI).

Some Programs Define 

Limits on Assets an 

Applicant May Have to Be 

Eligible
Page 26 GAO-17-558 Federal Low-Income Programs

In recent years, some states have moved away from having asset limits 

for certain low-income programs. For example, as of August 2016, 34

states and the District of Columbia have adopted SNAP BBCE policies 

that removed asset limits from their financial eligibility determinations for 

those deemed eligible using BBCE. In TANF, asset limits are determined 

by the state, and as of August 2016, 8 states did not have asset limits, 

while 43 states had set varying limits on assets (see figure 6). Other lowincome programs we reviewed—EITC, Housing Choice Vouchers, and 

Medicaid for non-elderly, non-disabled (MAGI) populations—have no 

restrictions on assets.36 However, financial assets that produce unearned 

income can be taken into account when determining applicant eligibility. 

For example, for EITC, applicants’ income from any investments must be 

$3,400 or less per year.

Figure 6: Asset Limits for Determining Initial SNAP and TANF Program Eligibility, Range by Number of States (as of August 

2016)

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other noncash TANF services. Data on 

asset limits for SNAP and TANF are as of August 2016, the most recent data available at the time of 

our review.

 36 We use the term “assets” here to refer to what are referred in Medicaid program 

guidance as “resources,” which are anything owned, such as bank accounts or property, 

that can be converted to cash. Medicaid does have asset limits—or resource limits—for 

non-MAGI populations, such as the elderly. This report focuses on those eligible for 

Medicaid under MAGI rules; the processes for non-MAGI groups are not discussed in this 

report. 
Page 27 GAO-17-558 Federal Low-Income Programs

Asset tests are further complicated because of the differences in how the 

equity in vehicles is treated when determining assets. Vehicle asset rules 

exist in certain programs, and these rules vary, not only across programs, 

but across states as well. In one program, a vehicle used to access work 

may be disregarded; in another program, a certain portion of the value of 

the vehicle may be disregarded. In TANF, treatment of vehicles is at the 

state’s discretion and most states disregard $4,650 or more of the value 

of one vehicle.37 For SNAP, certain vehicles are excluded in their entirety, 

or states may opt to substitute their TANF vehicle rules, according to 

USDA.38

Average benefits vary across the six selected programs due in part to 

differing benefit purposes and other factors, according to our analysis of 

agency documentation and information, as confirmed by the agencies. 

For the four programs that provide monthly benefits—Housing Choice 

Vouchers, SNAP, SSI, and TANF—average benefit levels ranged from 

$258 monthly for SNAP to $626 monthly for Housing Choice Vouchers in 

fiscal year 2015. These average benefit amounts—for Housing Choice 

Vouchers, SNAP, and TANF—are per household, while the SSI average

benefit is per individual.39 The EITC provided a one-time annual benefit of 

more than $2,455 on average in 2016, based on tax returns filed for 2015, 

which, for comparison, converts to $205 per month. (See table 10). There 

is no average benefit amount for Medicaid since its benefits are provided 

 37 Center for Law and Social Policy, Eliminating Asset Limits: Creating Savings for 

Families and State Governments (Washington, D.C.: Oct. 2016). The analysis in this 

report is based on data from the Welfare Rules Database, which is a database of TANF 

rules in effect in the 50 states and the District of Columbia. HHS/ACF, in conjunction with 

the Department of Health and Human Services, Assistant Secretary for Planning and 

Evaluation (HHS/ASPE), funds the collection of data and maintenance of the Welfare 

Rules Database.

38 If not excluded, all but $4,650 of the fair market value of one licensed vehicle for each 

adult is counted toward the asset limit and additional vehicles are counted at the higher of 

their equity or their excess fair market value over $4,650. 

39 For information about average SSI benefits received by multiple recipient households, 

see GAO, Supplemental Security Income: SSA Provides Benefits to Multiple Recipient 

Households but Needs System Changes to Improve Claims Management, GAO-16-674, 

(Washington, D.C.: Aug. 17, 2016).

Average Monthly Benefits 

for Selected Programs 

Range from $258 to $626, 

and Vary by Annual 

Adjustment
Page 28 GAO-17-558 Federal Low-Income Programs

in the form of health care services to individuals.40 These variations in 

average benefit amounts are due in part to differing program and benefit 

purposes and other factors, according to our analysis of agency 

documentation and other governmental reports. For example, the SNAP 

benefit amount is structured to make up the difference between the cost 

of purchasing a nutritionally adequate low-cost diet and 30 percent of net 

household income, because a household is expected to spend about 30 

percent of its net income on food, according to FNS.41 Alternatively, the 

SSI benefit is meant to provide a basic level of income for those who are 

elderly, blind, and disabled.

Table 10: Average Benefit and Annual Adjustment of Benefits Across Six Selected Low-Income Programs

Earned Income 

Tax Credit 

(EITC)

Medicaid Housing Choice 

Vouchers

Supplemental 

Security Income 

(SSI)

Supplemental 

Nutrition Assistance 

Program (SNAP)

Temporary 

Assistance 

for Needy 

Families 

(TANF)

Average 

benefit amount 

paid and timing

$2455 per return 

one-time annual 

benefit in tax 

year 2015, 

received in early 

2016; which 

converts to $205 

monthlya

n/ab $626 per household 

average monthly 

benefit in FY 2015

$551 per recipient 

average monthly 

benefit in FY 2015

$127/person; 

$258/household 

average monthly 

benefit in FY 2015

Varies by 

state;

$398 per family 

monthly 

average 

benefit in FY 

2015c

 40 Average expenditures for Medicaid beneficiaries vary by the type of beneficiary served. 

According to the 2015 Medicaid Actuarial report, the average annual per person 

expenditure (including the federal and state share) of $7,724 in fiscal year 2014 ranged 

from $3,141 for children to $18,789 for persons with disabilities. Average expenditures per 

person also vary by state.

41 The cost of a nutritionally adequate low-cost diet is measured by the USDA-created 

and-calculated Thrifty Food Plan. The Thrifty Food Plan is the cheapest of four diet plans 

meeting minimal nutrition requirements devised by USDA.
Page 29 GAO-17-558 Federal Low-Income Programs

Earned Income 

Tax Credit 

(EITC)

Medicaid Housing Choice 

Vouchers

Supplemental 

Security Income 

(SSI)

Supplemental 

Nutrition Assistance 

Program (SNAP)

Temporary 

Assistance 

for Needy 

Families 

(TANF)

Annual 

adjustment to 

benefits

Yes.

The Internal 

Revenue Service 

annually adjusts 

benefits for 

inflation through 

several 

adjustments it 

makes to the 

parameters it 

uses to calculate 

households’ 

EITC benefits.

d 

n/ae Yes.

The subsidy amount 

is adjusted when the 

rental agreement is 

renewed, based on 

the U.S. Department 

of Housing and 

Urban 

Development’s 

annual adjustment of 

Fair Market Rents 

for inflation.

Yes.

The Social Security 

Administration 

annually adjusts 

SSI benefits if there 

is an increase in 

inflation as 

measured by the 

Consumer Price 

Index for Urban 

Wage Earners and 

Clerical Workers.f

Yes.

The U.S. Department 

of Agriculture annually 

adjusts benefits based 

on any changes in the 

price of food in the 

Thrifty Food Plan.

g

At state 

discretion.

States may 

adjust TANF 

cash benefits 

amounts. 

(However, the 

TANF block 

grant amount 

is not adjusted 

for inflation.)

Source: GAO analysis of agency documents, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. 

a

For purposes of this table, the EITC “benefit amount” which is based on available agency data, 

includes both the refunded portion of the EITC and the offset portion of taxes owed. The average 

EITC benefit is based on 2015 tax returns, which are filed in 2016.

b

There is no average benefit amount for Medicaid since its benefits are provided in the form of health 

care services to individuals. Average expenditures for Medicaid beneficiaries vary by type of 

beneficiary served. According to the 2015 Medicaid Actuarial report, the average annual per person 

expenditure of $7,724 in fiscal year 2014 ranged from $3,141 for children to $18,789 for persons with 

disabilities. Average expenditures per person also vary by state.

c

The monthly average TANF family benefit ranged from $139 (Mississippi) to $612 (Alaska) in fiscal 

year 2015.

d

The EITC benefit amount rises with earned income until reaching a maximum level, plateaus, and 

then phases out. IRS computes annual inflation adjustments that affect a) the maximum EITC; b) the 

income level at which the maximum credit is reached; c) the beginnings of the phase-out range; and 

d) the completed phase-out threshold based on filing status and number of children claimed.

e

For Medicaid, the amount of benefits provided to a beneficiary is not a dollar amount but a service; 

thus, whether the benefit is adjusted for inflation is not applicable. While annual benefits to recipients 

in the form of health care services are not a dollar amount, the payment rates states pay providers 

and managed care organizations for services can change over time

f

The Consumer Price Index for Urban Wage Earners and Clerical Workers represents changes in 

prices of all goods and services purchased for consumption by urban households that have hourly 

wage earnings or clerical jobs.

g

The Thrifty Food Plan serves as a national standard for a nutritious diet at a minimal cost and is used 

as the basis for maximum food stamp allotments.

Four of the five programs that provide benefit amounts to recipients 

directly or indirectly adjust benefits for inflation, while one program varies 
Page 30 GAO-17-558 Federal Low-Income Programs

by state.42 Whether or not benefits are adjusted for inflation affects the 

value of the benefit over time. EITC, SSI, and SNAP explicitly adjust 

benefits for inflation, while the amount of a Housing Choice Voucher is 

adjusted in response to changes in area rental costs. According to CRS, 

TANF benefits for families are not automatically adjusted for inflation by 

the states and have lost considerable value in terms of their purchasing 

power over time.43 We have previously estimated that annual aggregate 

cash benefits under 2005 TANF rules were 17 percent lower than they 

were under 1995 rules.44 More recently, CRS has found that between 

1981 and 2013, the inflation-adjusted value of the maximum TANF cash 

assistance benefit for needy families in the median state declined by 45 

percent.45

 42 While annual Medicaid benefits to recipients in the form of health care services are not 

a dollar amount that is or is not adjusted annually, the payment rates states pay providers 

and managed care organizations for services can change over time.

43 See CRS, Temporary Assistance for Needy Families: Eligibility and Benefit Amounts in 

State TANF Cash Assistance Programs, R43634 (Washington, D.C.: Dec. 30, 2014). CRS 

also notes that, distinct from the cash benefit to families, the amount of the basic TANF 

block grant paid to states and the District of Columbia—$16,489 million—has not been 

adjusted for inflation since its creation in 1996. 

44 GAO, Temporary Assistance for Needy Families: Fewer Eligible Families Have 

Received Cash Assistance Since the 1990s, and the Recession’s Impact on Caseloads 

Varies by State, GAO-10-164 (Washington, D.C.: Feb. 23, 2010). 

45 According to CRS, a large share of the decline occurred under the Aid to Families with 

Dependent Children program, TANF’s predecessor, before enactment of the law that 

created TANF. From 1981 to 1996, CRS found that the maximum Aid to Families with 

Dependent Children cash benefit in the median state declined from $778 per month to 

$561 in 2013 dollars—a 28 percent reduction. See CRS, Temporary Assistance for Needy 

Families: Eligibility and Benefit Amounts in State TANF Cash Assistance Programs,

R43634 (Washington, D.C.: Dec. 30, 2014).
Page 31 GAO-17-558 Federal Low-Income Programs

Legal, administrative, and financial constraints pose challenges to 

streamlining or better aligning varying eligibility rules for low-income 

programs, according to our previous work. The issue of streamlining, and 

its feasibility, has been a concern for decades.46 As we noted in our 

earlier work, the complexity and variability in programs’ financial eligibility 

rules have had negative consequences for both program administration 

and family access to assistance, according to policy experts and 

researchers.47 For example, in 2002 we found that staff administering 

each program collected much of the same personal and financial 

information from applicants to determine program eligibility, leading to 

time-consuming and inefficient administrative processes that can 

contribute to overall costs. Further, people seeking aid from more than 

one low-income program often must visit multiple offices and provide the 

same information numerous times, according to our prior work.48

However, just as the advantages of simplifying financial eligibility rules 

 46 GAO-02-58 and GAO-11-531T. 

47 GAO-02-58. 

48 For example, while applicants may be able to access TANF, SNAP, and Medicaid 

through one local office, they may need to contact other offices to apply for housing 

assistance and SSI; and for EITC, they must file a tax return with the IRS. See 

GAO-11-531T and GAO-02-58. For those programs that are collocated, application 

processes are sometimes linked, although we reported in 2016 that, 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 to the 

Patient Protection and Affordable Care Act. See GAO, Supplemental Nutrition Assistance 

Program: More Information on Promising Practices Could Enhance States’ Use of Data 

Matching for Eligibility, GAO-17-111 (Washington, D.C.: Oct. 19, 2016).

Legal, Administrative, 

and Financial 

Constraints 

Challenge Efforts to 

Streamline Rules for 

Low-Income 

Programs

Several Challenges Hinder 

Efforts to Streamline 

Program Rules
Page 32 GAO-17-558 Federal Low-Income Programs

have been acknowledged, there has also been a general recognition that 

achieving substantial improvements in this area is difficult.49

A key challenge to streamlining eligibility rules for these low-income 

programs is that the programs are authorized by different federal statutes, 

which establish many of the program rules. These different statutes were 

enacted—and amended—at different times in response to differing 

circumstances.50 The statutes originate with numerous congressional 

authorizing committees. For example, the House Energy and Commerce 

Committee and the Senate Finance Committee are the authorizing 

committees for Medicaid, while the House Financial Services Committee 

and Senate Banking, Housing, and Urban Affairs Committee are the

authorizing committees for the Housing Choice Voucher program (see fig. 

7). Other laws, such appropriations acts, can also have an impact on 

federal programs and their rules. Modifying eligibility rules to bring them 

more in line with each other would require changing many laws and 

coordination among a broad set of lawmakers, including multiple 

congressional committees.

 49 GAO-02-58.

50 For example, in response to the Great Depression, early public housing and welfare 

cash assistance programs were established in the 1930s as part of the New Deal; 

similarly, Medicaid and the modern Food Stamp Program—now called SNAP—were 

initially established in the 1960s as part of the War on Poverty. The law that created TANF 

in 1996 included work-related activities as one of its program requirements and also 

established or amended other programs to meet emerging needs, such as the child care 

subsidy block grant to support working parents.
Page 33 GAO-17-558 Federal Low-Income Programs

Figure 7: Congressional Committees, Federal Agencies, and State and Local Governments Involved in the Six Programs

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. This figure is not meant to be exhaustive: 

other entities may also be involved in the creation or administration of these programs.

a

For SNAP and TANF, both state and local governments may be involved in eligibility and benefit 

determination. In EITC, recipient eligibility and benefits are not determined in the same way as in the 

other selected programs. Tax credit recipients self-certify their eligibility and claim without the 

involvement of agency staff. In the other programs, administrative agency staff assess eligibility and 

determine benefits.

b

Benefits for Medicaid are provided as health care services provided to beneficiaries. As opposed to a 

benefit that is calculated by a formula, the amount of health care services provided is determined by 

the beneficiaries’ health care needs as well as by federal and state rules. States make decisions 
Page 34 GAO-17-558 Federal Low-Income Programs

regarding what health services to cover beyond the minimum coverage and benefits standards 

required by federal law, and they establish within broad federal guidelines the amount, duration, and 

scope of services.

c

The SSA field offices process applications for benefits, verify financial eligibility, and compute benefit 

amounts. Following SSA’s initial review, state disability determination services offices assess 

applicants’ medical eligibility for SSI.

Another challenge to streamlining stems from the multiple government 

entities involved in administering and funding each program and the 

varied administrative relationships between the federal and state levels of 

government by program. To start with, a different federal agency or office 

administers each program we reviewed. For example, FNS administers 

SNAP, CMS administers Medicaid, and the Office of Public and Indian 

Housing within HUD administers the Housing Choice Voucher. These 

different federal agencies generally develop regulations separately for 

each program, which may affect program rules. Furthermore, as 

discussed earlier, state governments are also involved in administering 

and funding some of these programs. Specifically, for programs that allow 

state flexibility, state governments also establish some program rules, 

making it more difficult to streamline or align program rules within or 

across these programs at the federal level. For example, for TANF cash 

assistance, the development of eligibility and benefit rules is primarily 

delegated to state agencies administering the program, while for SNAP, 

state agencies have some flexibility in determining eligibility rules within 

federally-established parameters.51 Regarding program funding, while 

states may partially fund TANF cash assistance benefits, the federal 

government funds the full cost of SNAP benefits. As a result of these 

different roles, streamlining eligibility rules and benefits across multiple 

programs would entail, in part, modifying and realigning complex 

administrative relationships among a range of federal and state 

government entities.

Finally, financial or program cost implications pose a major challenge to 

streamlining financial eligibility and benefit rules for low-income programs, 

 51 In addition to setting eligibility rules, different entities may be involved in applying those 

rules. In the case of SSI, financial and nonfinancial eligibility determination responsibilities 

are split between federal and state offices: the SSA field offices process applications for 

SSI benefits, verify financial eligibility, and compute benefit amounts. However, state 

disability determination services offices assess applicants’ medical eligibility for the 

program. Eligibility for a housing voucher is determined by Public Housing Agencies 

(PHA). PHAs may be states, counties, municipalities, or other governmental entities 

authorized to administer the program, and PHAs may contract aspects of program 

administration (including eligibility determinations) to private or public non-profit 

contractors. 
Page 35 GAO-17-558 Federal Low-Income Programs

according to our previous work.52 Modifying financial eligibility rules for 

purposes of simplifying them or making them more consistent across 

programs will likely result in changes to the number of people who are 

eligible for assistance, and may also affect the benefit amounts they 

receive, as well as overall program costs.53 Depending on the 

modification, and the current rules of each program affected, changes 

made to streamline rules will affect each program’s recipients and costs 

differently. On the one hand, if such rule changes have the effect of 

raising a program’s income eligibility limits, more people will be eligible for 

assistance and that program’s costs may increase, particularly for 

entitlement programs. For example, according to our earlier work, SNAP 

program participation more than doubled and costs quadrupled over a 10-

year period, largely due to the 2008 recession; however, a factor that 

contributed to both increases was that some states aligned their SNAP 

income eligibility limits with the higher limits used in other low-income 

programs under the BBCE policy option.54 On the other hand, if such rule 

changes have the effect of lowering a program’s income eligibility level, 

 52 GAO-02-58.

53 Under entitlement programs, such as Medicaid and SNAP, the government is legally 

required to make payments to individuals or families that meet the requirements 

established by law. For non-entitlement programs, such as the Housing Choice Voucher 

and TANF cash assistance, funding amounts may limit the number of people served. 

Moreover, some of the programs require state matching money (e.g., Medicaid), while 

others are entirely federally funded (e.g., SSI, EITC), contributing further to the complexity 

of these funding structures within and across programs.

54 As we reported in 2012, states that implement SNAP BBCE policies are essentially 

aligning their SNAP eligibility limit with the eligibility limit for TANF-funded programs that 

provide benefits other than cash assistance. In GAO-12-670, we reviewed information on 

the 24 states whose BBCE policies raised household income limits above the federal 

SNAP income limit in fiscal year 2010, and found that an estimated 4.8 percent of SNAP 

households had incomes over the federal limit. However, we also found that while 

implementation of BBCE by these states enabled more households to receive SNAP, the 

2008 economic downturn likely played a larger role in the increases in participation from 

2001-2010. Furthermore, total SNAP benefit costs increased by less than 1 percent in 

fiscal year 2010 because of benefits provided to households that, without BBCE, would 

not have been eligible for the program because their incomes were over the federal SNAP 

eligibility limit. 
Page 36 GAO-17-558 Federal Low-Income Programs

some people will no longer be eligible for assistance from that program, 

thereby potentially lowering program costs.55

Despite these challenges, Congress, federal agencies, and states have 

taken some steps to streamline eligibility rules, according to our prior 

work. These include establishing automatic or categorical eligibility 

among programs, making greater use of technology and data-sharing 

among low-income programs, and aligning application and eligibility 

determination processes for multiple programs.

Automatic or categorical eligibility: These policies—where allowed under 

federal law—can simplify the eligibility determination process for both 

applicants and caseworkers by increasing consistency in income and 

resource limits across programs. For example, in addition to SNAP BBCE 

policies already discussed (which make households that receive noncash 

services funded by TANF categorically eligible for SNAP in some states), 

SSI recipients in most states are automatically eligible for Medicaid health 

insurance,56 and if they live alone or in households in which all members 

receive SSI benefits, they are automatically eligible for SNAP.57 In 

another example, recipients of Medicaid, TANF, or SNAP are 

automatically deemed income-eligible for the Special Supplemental 

Nutrition Program for Women, Infants, and Children (WIC)—a WIC policy 

known as adjunctive eligibility that is similar to categorical eligibility.58

Finally, under the federal school meals programs’ direct certification 

 55 A related challenge to program streamlining efforts may be the relative lack of 

information on the costs and effects of these efforts, as we noted in our earlier work. For 

example, we found in 2011 that no definitive information existed to demonstrate the type 

and extent of changes that might result in reduced administrative costs or to demonstrate 

how strategies might work differently in different communities. GAO-11-531T.

56 In some states, SSI recipients are not automatically eligible for Medicaid because those 

states have opted to use more restrictive Medicaid eligibility standards than SSI’s 

standards. See GAO-16-674 and GAO-14-473.

57 With the exception of California, which converts the value of SNAP benefits to cash 

payments that are included in additional state-provided benefits for SSI recipients, SSI 

recipients may be eligible to receive SNAP. If all household members receive SSI, the 

household is categorically eligible for SNAP and does not need to meet SNAP’s financial 

eligibility standards. However, if SSI recipients live in households with others who do not 

receive SSI benefits, the household must meet the SNAP financial eligibility standards to 

qualify for SNAP benefits. See GAO-16-674.

58 The Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) 

provides food, nutrition education, and health and social service program referrals to lowincome pregnant and postpartum women, infants, and young children. GAO-13-290.

Agencies and States Have 

Made Efforts to Streamline 

Rules within Program 

Constraints
Page 37 GAO-17-558 Federal Low-Income Programs

policy, students who receive SNAP benefits are automatically certified as 

eligible for free school meals. According to our prior work, this policy not 

only eased access for eligible students but also improved program 

integrity, because of SNAP’s more detailed certification process 

compared to the school meals programs.59 Overall, we found in our prior 

work that such policies can ease the administrative burden for 

participants as well as save resources, improve productivity, and allow 

staff to focus more time on performing essential program activities.60

Technology and data sharing: Computer systems can be used as a tool to 

carry out joint eligibility determination processes that streamline program 

administration for staff. Data-sharing arrangements, where permitted by 

federal law, allow programs to share client information that they otherwise 

would each collect and verify separately, thus reducing duplicative effort, 

saving money, and improving integrity, according to our earlier work.61

More specifically, with data sharing, staff may use existing data sources 

to prepopulate forms, thereby reducing the need for clients to provide the 

same information and documentation to multiple agencies. Staff may also 

use existing reliable data sources to automate the verification of 

information instead of conducting manual checks.62 For example, state 

agencies administering SNAP were able to determine SSI recipients’ 

eligibility for SNAP benefits by receiving verified electronic data from 

SSA, without having to separately collect and verify applicant information, 

an arrangement that officials said saved administrative dollars and 

reduces duplicative effort across programs, according to our prior work.63

 59 GAO, School Meals: USDA Could Improve Verification Process for Program Access, 

GAO-15-634T (Washington, D.C.: May 19, 2015). 

60 GAO-11-531T and GAO-12-670.

61 GAO-11-531T. Such data sharing arrangements may be subject to various laws and 

regulations, including those that have been established to protect individuals’ privacy, an 

important consideration. In our prior work, we found that there was confusion or 

misperceptions around what state and local agencies were allowed to share, as well as a 

tendency to be risk averse and overly cautious in agencies’ interpretation of federal 

privacy requirements. In part to address these matters, HHS posted information for state 

and local agencies, including an Interoperability Toolkit and data security guidance, as 

part of a larger Interoperability initiative to develop standards for information technology 

systems that will enable information exchange across federal, state, local, and private 

human services systems. GAO, Human Services: Sustained and Coordinated Efforts 

Could Facilitate Data Sharing While Protecting Privacy, GAO-13-106 (Washington, D.C.: 

Feb. 8, 2013). 

62 For other potential uses of data sharing, including program oversight, see GAO-13-106. 

63 GAO-11-531T. 
Page 38 GAO-17-558 Federal Low-Income Programs

In contrast, we recently found that states are experiencing barriers to 

using data matches for certain other low-income programs. For example, 

in a 2016 report we found that state staff who administer both SNAP and 

Medicaid were not allowed to use benefits or earnings information from a 

federal data services hub created for Medicaid to determine SNAP 

eligibility; as a result, staff would need to conduct duplicative data 

matches to verify some of the same information for the same 

household.64

Flexibility to align application and eligibility determination processes: In 

addition to helping streamline the application process by making greater 

use of call centers and online applications in some programs,65 some 

states have also taken other steps to align application and eligibility 

determination processes, according to our prior work. Exercising such 

flexibilities, when available to states, can help ease access and 

streamline the process for both recipients and administrators. For 

example, some states reported that they integrated aspects of the SNAP 

eligibility process with those of other programs, such as through 

combined applications, common eligibility workers, or integrated or linked 

 64 More specifically, as we reported in October 2016, state Medicaid programs verify 

income information by accessing data sources through CMS’s federal data services hub 

(the Hub), which was created to implement provisions of the Patient Protection and 

Affordable Care Act (PPACA). 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 programs established under the PPACA. 

However, we found that data accessed through the Hub can only be used to determine 

eligibility for Medicaid and related insurance affordability programs. According to officials, 

CMS’s contract and data use agreements with the organization and federal agencies that 

provide the data do not authorize states to use the data for SNAP. As such, state staff 

cannot use benefits or earnings information from the Hub to determine SNAP eligibility, 

and instead would need to access this information independently, which in effect results in 

staff conducting duplicative data matches to verify some of the same information for the 

same household. See GAO-17-111. In December 2016, SSA and CMS entered into a 

data-sharing agreement to permit eligible state Medicaid agencies to use SSA data that 

they obtain via the CMS Hub to also determine eligibility for SNAP and TANF applicants 

when making Medicaid eligibility determinations. This arrangement is currently being 

piloted in three states.

65 For example, in an earlier report, we reported that staff in most of the states we visited 

cited implementation of online applications and phone interviews, instead of in-person 

interviews, as improving access to SNAP. See GAO-12-670.
Page 39 GAO-17-558 Federal Low-Income Programs

eligibility systems, according to our 2017 report.66 Overall, according to 

our state survey in this report, we found that SNAP eligibility processes 

were most commonly integrated with state TANF cash assistance 

programs (44 states), as well as with state Medicaid programs, although 

to a somewhat lesser degree.67 In another example, known as the 

Express Lane Eligibility option, states can choose to evaluate children’s 

eligibility for Medicaid or CHIP by using findings—such as determinations 

regarding a family’s income—made by other agencies, such as those 

administering SNAP or TANF.68 Further, while states administer the 

Medicaid program, SSI recipients’ eligibility for Medicaid is sometimes 

determined by the Social Security Administration (SSA). We previously 

reported that as of May 2016, 33 states and the District of Columbia had 

agreements with SSA to determine SSI recipients’ eligibility for Medicaid, 

according to SSA.69 In these states, the SSI application is also the 

Medicaid application.

 66 GAO-17-111. For example, we reported that under an FNS initiative called the 

Combined Application Project, states can seek waivers from FNS to adopt a set of policies 

to improve access to SNAP benefits for elderly and/or disabled individuals who are 

receiving SSI. As of 2016, according to FNS information, 17 states participated in this 

project under which a simplified joint application that includes both SNAP and SSI is 

processed by SSA when individuals apply or are recertified for SSI. Other examples of 

service-oriented integration that is client and case management focused are the colocation of different program offices and cross-training of caseworkers. 

67 However, we also reported that Medicaid and other programs use income information 

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

income information or definitions of household income differ across programs: in 

responding to our survey, 21 states reported that they found these differences very or 

extremely challenging.

68 In a 2012 report, we noted that available information suggested that the Express Lane 

Eligibility option could save time and reduce administrative costs and could have 

beneficial effects on enrollment; it was unclear whether Express Lane Eligibility may have 

resulted in erroneous excess payments for children enrolled through this eligibility option. 

GAO, Medicaid and CHIP: Considerations for Express Lane Eligibility, GAO-13-178R

(Washington, D.C.: Dec. 5, 2012). In October 2016, the HHS Office of Inspector General 

found that the states that used this option reported benefits, including reduced 

administrative burden and cost savings. HHS, State Use of Express Lane Eligibility for 

Medicaid and CHIP Enrollment, OEI-06-15-00410 (Washington, D.C.: Oct. 2016).

69 GAO-16-674. As we also reported, according to SSA’s Program Operations Manual 

System, in the 17 additional states, individuals determined to be eligible for SSI need to 

separately apply for Medicaid through their state’s Medicaid application. Seven of those 

states use SSI eligibility criteria for Medicaid, and the remaining 10 states use at least one 

eligibility criterion more restrictive than SSI to determine whether an SSI recipient is 

eligible for the program. 
Page 40 GAO-17-558 Federal Low-Income Programs

We provided a draft of this report to the Departments of Agriculture 

(USDA), Health and Human Services (HHS), Housing and Urban 

Development (HUD), and the Treasury; and the Social Security 

Administration (SSA). With the exception of HUD, which provided no 

comments, the agencies provided technical comments, which we 

incorporated as appropriate. 

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

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

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

appropriate congressional committees; the Secretaries of the Department 

of Agriculture, HHS, HUD, and the Treasury; the Acting Commissioner of 

the SSA; and other interested parties. In addition, this report will be 

available at no charge on GAO’s website at http://www.gao.gov.

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

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

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix IV.

Sincerely yours,

Kathryn A. Larin

Director, Education, Workforce, and Income Security Issues

Agency Comments 

and Our Evaluation
Appendix I: Estimated Number of People 

Eligible for Selected Low-Income Programs 

Compared with Program Recipients

Page 41 GAO-17-558 Federal Low-Income Programs

One measure of a program’s reach is the program participation rate, or 

the percentage of those eligible who receive benefits from a program. 

According to a December 2015 Congressional Research Service (CRS) 

analysis of the latest data available for subsidized housing, Supplemental 

Security Income (SSI), the Supplemental Nutrition Assistance Program 

(SNAP) and Temporary Assistance for Needy Families (TANF), the 

estimated proportion of those eligible who received benefits in 2012 

varied substantially, and not all of those eligible actually received 

benefits.1 (See fig. 8.) For the entitlement programs—those legally 

required to provide benefits to all those who apply and qualify (SNAP, 

EITC, and SSI)—the estimated proportion of eligible people who were 

enrolled ranged from 66.6 percent to 80 percent.2 In contrast, for the nonentitlement programs, the estimated proportion of eligible people who 

were enrolled was 18.2 percent for subsidized housing and 28.4 percent 

for TANF.3

 1 CRS developed these estimates using data from the Census Bureau’s 2013 Annual 

Social and Economic Supplement (ASEC) to the Current Population Survey, 

supplemented with estimates of program eligibility, receipt, and benefits from the TRIM3 

microsimulation model. TRIM3 is a microsimulation model for government benefit receipt 

that is primarily funded by the U.S. Department of Health and Human Services (HHS) and 

maintained at the Urban Institute. According to CRS, the analysis does not include 

Medicaid estimates because (1) TRIM3 does not provide information on enrollment in 

Medicaid, only eligibility; and (2) data from 2012 would miss the major expansion of 

Medicaid eligibility under the Patient Protection and Affordable Care Act. CRS, NeedTested Benefits: Estimated Eligibility and Benefit Receipt by Families and Individuals,

R44327 (Washington, D.C.: Dec. 30, 2015).

For additional discussion of these programs and program recipients, see GAO, Federal 

Low-Income Programs: Multiple Programs Target Diverse Populations and Needs,

GAO-15-516 (Washington, D.C.: July 30, 2015), which describes federal programs 

targeted to people with low incomes; identifies the number and characteristics of people in 

poverty; identifies the number, poverty status, and household characteristics of selected 

programs’ recipients; and examines research on how selected programs may affect 

incentives to work. Our report also relied, in part, on TRIM3. 

2 For EITC, we use IRS’s 2012 tax year estimate here. IRS develops its estimate in 

cooperation with the U.S. Census Bureau, and it calculates both national and state-level 

participation rates. The EITC participation rate we present here is for all EITC participants, 

not just those who receive the refunded credit.

3 Subsidized housing in the CRS analysis includes the Section 8 Housing Choice 

Voucher, as well as the project-based rental assistance programs and the public housing 

program.

Appendix I: Estimated Number of People 

Eligible for Selected Low-Income Programs 

Compared with Program Recipients
Appendix I: Estimated Number of People 

Eligible for Selected Low-Income Programs 

Compared with Program Recipients

Page 42 GAO-17-558 Federal Low-Income Programs

Figure 8: Estimated Number of People Eligible for Benefits Compared to Those Receiving Benefits, 2012, for Four LowIncome Programs

Notes: Estimates reported in this figure represent people eligible for benefits or receiving benefits at 

any time during the year. CRS developed the estimates for subsidized housing, SNAP, SSI, and 

TANF using data from the Census Bureau’s 2013 Annual Social and Economic Supplement (ASEC) 

to the Current Population Survey, supplemented with estimates of program eligibility, receipt, and 

benefits from the TRIM3 microsimulation model. TRIM3 is a microsimulation model for government 

benefit receipt that is primarily funded by the U.S. Department of Health and Human Services (HHS) 

and maintained at the Urban Institute. According to CRS, the analysis does not include Medicaid 

estimates because (1) TRIM3 does not provide information on enrollment in Medicaid, only eligibility; 

and (2) data from 2012 would miss the major expansion of Medicaid eligibility under the Patient 

Protection and Affordable Care Act. CRS, Need-Tested Benefits: Estimated Eligibility and Benefit 

Receipt by Families and Individuals, R44327 (Washington, D.C.: Dec. 30, 2015).

The term “subsidized housing” refers to multiple programs and not just Housing Choice Vouchers. 

See figure note b for further information.

a

In its estimates for subsidized housing, CRS includes the Section 8 Housing Choice Voucher, as well 

as the project-based rental assistance program and the public housing program. The estimate does 

not correct for under-reporting of federal housing assistance or the over-reporting of other housing 

assistance, known issues with Current Population Survey (CPS) data that may bias results in ways 

that are not fully understood. Fair market rents and income eligibility thresholds are based on 

(weighted) statewide averages rather than local area data.

b

Estimates for SNAP can be sensitive to assumptions of how “SNAP households” are formed within 

Census households. The definition of a household for the purpose of determining SNAP eligibility 

may be distinct from the Census household.

c

The SSI-eligible disabled population is estimated based on income and receipt of disability benefits 

(including SSI itself) or self-reported work limitations.

d

Families estimated as eligible for TANF might include those who were made ineligible by states for 

failure to comply with program rules (such as work requirements).

The gap between those eligible for these programs and those receiving 

benefits may be explained by several factors, including program funding 
Appendix I: Estimated Number of People 

Eligible for Selected Low-Income Programs 

Compared with Program Recipients

Page 43 GAO-17-558 Federal Low-Income Programs

structure, the type of benefits provided, ease of access to the programs, 

and applicants’ lack of awareness and misperceptions about the 

programs, among other things.4

• The program’s funding structure may contribute to a gap between the 

number of eligible people and the number of recipients. For example, 

for non-entitlement programs, such as TANF and Housing Choice 

Vouchers, funding amounts may limit the number of people served. 

Because of this, states and localities sometimes ration aid, using 

mechanisms such as waiting lists for housing.5

• The type and amount of benefits can also affect program participation. 

In our earlier work, we reported that participation rates tended to be 

higher among subgroups of people eligible for larger benefits and 

among programs that provide cash benefits rather than direct 

services. Specifically, in our previous work, one of the reasons we

found for the decline in TANF participation was a decline in the annual 

aggregate cash benefit amounts, which were 17 percent lower under 

2005 program rules than they were under 1995 program rules.6

• Factors that influence the ease with which potential participants can 

access a program—including office location and hours as well as the 

ease with which program participants can use their benefits—can also 

affect the participation rate. For example, a 2012 Congressional 

Budget Office report found that the increase in the rate at which 

eligible people received SNAP benefits between 2007 and 2011 was 

likely due in part to changes in the program’s administration that made 

it easier for people to apply for and continue receiving benefits—such 

as greater use of online applications, mail-in renewals, and phone 

interviews—as well as to the poor economy, which reduced people’s 

income and caused longer periods of need, prompting more people 

 4 GAO, Means Tested Programs: Information on Program Access Can Be an Important 

Management Tool, GAO-05-221 (Washington, D.C.: Mar. 11, 2005).

5 HUD tracks the extent of households with worst case housing needs in its report on 

households with worst case housing needs, defined as households with very low-income 

renters who do not receive government housing assistance and who paid more than onehalf of their income for rent, lived in severely inadequate conditions, or both. U.S. 

Department of Housing and Urban Development, Office of Policy Development and 

Research, Worst Case Housing Needs: 2015 Report to Congress (Washington, D.C.: April 

2015).

6 GAO, Temporary Assistance for Needy Families: Fewer Eligible Families Have Received 

Cash Assistance Since the 1990’s, and the Recession’s Impact on Caseloads Varies by 

State, GAO-10-164 (Washington, D.C.: Feb. 23, 2010).
Appendix I: Estimated Number of People 

Eligible for Selected Low-Income Programs 

Compared with Program Recipients

Page 44 GAO-17-558 Federal Low-Income Programs

who were already eligible for the program to apply.7 In contrast, we 

found in our 2005 report that it was difficult for some participants to 

use Housing Choice Vouchers and Medicaid, as some service 

providers, such as landlords or health care providers, would not 

exchange their services for program benefits.8

• Lack of awareness about program benefits on the part of the eligible 

population or misconceptions about eligibility can affect the overall 

number and characteristics of people who participate. In our 2005 

work, we reported that several EITC, Medicaid, Food Stamp, and SSI 

studies indicated that one of the primary barriers to participation was 

that individuals did not know that they were eligible for these benefits.9

We further reported that for some individuals—like the elderly and 

non-English speakers—this unfamiliarity with program benefits was 

even more widespread, creating a larger barrier to participation and 

an under-representation of these individuals in the caseload.

• Finally, eligible families also choose whether to participate in a 

program in response to their personal feelings about government 

assistance programs and their individual circumstances. For example, 

according to our previous work, changes made to allow households to 

apply for SNAP online or by phone lowered the stigma associated 

with going to a public assistance office and may have contributed to 

an increase in SNAP participation.10 Also as we previously reported, 

the sharp declines in eligible families’ participation in TANF cash 

assistance from 1995 to 2005 resulted from, among other things, the 

dynamics of family decision-making in response to TANF policies, 

such as mandatory participation in work activities. Specifically, we 

found that families eligible for TANF cash assistance often had 

characteristics that make employment difficult, such as poor health, 

low educational attainment, or limited English proficiency, which may 

affect their decisions to apply for TANF.11

 7 Congressional Budget Office, The Supplemental Nutrition Assistance Program 

(Washington, D.C.: April 2012).

8 GAO-05-221.

9 GAO-05-221. SNAP was previously known as the Food Stamp Program; it was given its 

present name in 2008. 

10 GAO-12-670.

11 GAO-10-164.
Appendix II: Selected Deductions for 

Calculating Income for Determining Program 

Eligibility

Page 45 GAO-17-558 Federal Low-Income Programs

Table 11: Deductions for Utilities Expenses in Calculating Income for the Purpose of Determining Eligibility for Selected LowIncome Programs (as of December 2016)

Program Deductions for utilities expenses

Earned Income Tax Credit 

(EITC)

Nonea

Housing Choice Vouchers None

Medicaid Utilities expenses are generally not disregarded or deducted from income for determining Medicaid 

eligibility.

Supplemental Nutrition 

Assistance Program (SNAP)

Utility costs, including the cost of fuel to heat and cook with, electricity, water, and the basic fee for one 

telephone, as well as rent or mortgage payments and related taxes, are included in the excess shelter 

cost deduction. Excess shelter costs that are more than half of the household’s income after the other 

allowable deductions are deducted from a household’s income up to a maximum amount, unless the 

household includes an elderly or disabled individual, in which case there is no limit. For utilities, the 

vast majority of states establish standardized amounts to use in place of actual household costs.

Supplemental Security 

Income (SSI)

Noneb

Temporary Assistance for 

Needy Families (TANF)

State option. Varies by state. Some states do not deduct any utilities expenses while others do.

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other TANF noncash services.

a

Generally, in private taxpayer (i.e. non-business) cases, utility expenses are not deducted in 

calculating the income used for the purpose of determining eligibility.

b

While SSI does not deduct utilities from income, if an SSI recipient receives assistance to help pay 

for utilities in the form of cash or by direct payment to the vendor (not in the form of a loan), SSI 

payments are paid at a reduced rate.

Table 12: Deductions for Selected Other Expenses in Calculating Income for the Purpose of Determining Eligibility for 

Selected Low-Income Programs (as of December 2016)

Program Deductions for selected other expenses

Earned Income Tax Credit 

(EITC)

Certain expenses may be able to be deducted in calculating an individual’s adjusted gross income 

(AGI), which partially determines when the credit amount from EITC phases out.a

Housing Choice Vouchers Selected other deductions from counted income (according to 24 CFR 5.609(c)), among others:

payments received for the care of foster children or foster adults (usually persons with disabilities, 

unrelated to the tenant family, who are unable to live alone);

deferred periodic amounts from supplemental security income and Social Security benefits that are 

received in a lump sum amount or in prospective monthly amounts, or any deferred Department of 

Veterans Affairs disability benefits that are received in a lump sum amount or in prospective monthly 

amounts.

Medicaid Under Modified Adjusted Gross Income (MAGI)-based rules, certain expenses may be able to be 

deducted or adjusted in calculating an individual’s adjusted gross income (AGI). Once a person’s AGI 

is calculated, there are no further income deductions (other than Medicaid-specific rules, such as the 

standard 5% income disregard).

Appendix II: Selected Deductions for 

Calculating Income for Determining Program 

Eligibility
Appendix II: Selected Deductions for 

Calculating Income for Determining Program 

Eligibility

Page 46 GAO-17-558 Federal Low-Income Programs

Program Deductions for selected other expenses

Supplemental Nutrition 

Assistance Program (SNAP)

Legally owed child support payments. Medical expenses for elderly or disabled household members 

that are more than $35 for the month if they are not paid by insurance or someone else.

Supplemental Security 

Income (SSI)

A variety of expenses may be deducted when calculating income for SSI eligibility. For example, 

certain types of medical-related assistance are not counted as income.

Temporary Assistance for 

Needy Families (TANF)

State option. Varies by state. Some states do not deduct any other expenses while others do.

Source: GAO analysis of agency documentation, as confirmed by the agencies. | GAO-17-558

Note: While GAO did not independently verify the legal accuracy of the information in this table, we 

confirmed the information with the cognizant agencies. Our review of eligibility rules included only 

those for TANF cash assistance and not those related to other TANF noncash services.

a

Additionally, certain adjustments to income are permitted under tax rules to calculate Adjusted Gross 

Income. These adjustments include, for example: student loan interest deduction, tuition and fees, 

alimony paid, educator expenses, and moving expenses.
Appendix III: Maximum Monthly Income an 

Applicant May Have and Still Be Eligible for Six 

Selected Low-Income Programs

Page 47 GAO-17-558 Federal Low-Income Programs

There is no single maximum income amount an applicant may have to be 

eligible for the six federal low-income programs we reviewed, and the 

amount of allowable income varies significantly among the programs, 

according to data confirmed by the administering agencies. Figure 9 

shows this variation by presenting the maximum income limits for EITC, 

SSI, and SNAP under federal rules, as well as the median amount (50th 

percentile) of the range of maximum income limits for the 48 contiguous 

states and Washington D.C. for the programs with varying income limits—

Housing Choice Vouchers, Medicaid, SNAP under state BBCE policies, 

and TANF. EITC has the highest maximum income allowed, and TANF, 

at well under the federal poverty guideline, has the lowest median 

maximum income allowed.

Figure 9: Illustration of Maximum Monthly Amounts of Income an Applicant May Have and Still Be Eligible for Six Selected 

Low-Income Programs

Allowable monthly income amounts for a family of 3, with single parent and 2 children, in the 48 contiguous states and Washington 

D.C., as of December 31, 2016, shown as the median for programs with state variation in income limits.

Note: Applicants with the amounts of income presented in the figure would not necessarily qualify for 

a benefit above $0. For example, an applicant for SSI with a monthly income of $1,551 would qualify 

for $0 in SSI benefits. While GAO did not independently verify the legal accuracy of the information in 

this figure, we confirmed the information with the cognizant agencies.

a

For EITC, we used the annual amount of $44,648, and divided by 12, to calculate an illustrative 

average maximum monthly dollar amount a filing individual can have with two children and still qualify 

for EITC. In fact the EITC is not available on a monthly basis. Taxpayers whose income varies over 

Appendix III: Maximum Monthly Income an 

Applicant May Have and Still Be Eligible for 

Six Selected Low-Income Programs
Appendix III: Maximum Monthly Income an 

Applicant May Have and Still Be Eligible for Six 

Selected Low-Income Programs

Page 48 GAO-17-558 Federal Low-Income Programs

the year may have earned more or less than this average maximum amount in any given month. In 

addition, income from investments must be $3,400 or less per year.

b

For SSI, this is the amount of earned income at which a disabled individual with no unearned income 

no longer qualifies for a federal SSI payment. The amount is higher for a married couple. However, in 

addition to meeting the financial requirements for SSI eligibility, a person must also be unable to 

engage in substantial gainful activity to qualify for SSI. In 2016, substantial gainful activity for a nonblind, disabled individual was defined as having earnings of more than $1,130 per month. For the 

purpose of illustrating SSI eligibility here, we are assuming that the single parent in the 3-person 

household is the applicant and has a disability that makes her eligible for SSI. 

c

The Housing Choice Vouchers program uses specified percentages of the Area Median Income 

(AMI) to determine eligibility. For example, families generally must have incomes no higher than 50 

percent of the AMI, to be eligible, and 75 percent of newly available vouchers each year must go to 

families whose incomes do not exceed the higher of (1) the applicable HHS poverty guidelines or (2) 

30 percent of AMI.

d

The amounts presented for Medicaid represent allowable amounts under Modified Adjusted Gross 

Income (MAGI) rules. As of January 1, 2014, MAGI rules are used in determining eligibility for most of 

Medicaid’s non-elderly non-disabled populations. For these eligibility groups, an individual’s income, 

computed using MAGI-based income rules described in 42 CFR 435.603, is compared to the income 

standards in the state in which the applicant lives to determine if they are income eligible for 

Medicaid. The MAGI-based rules generally include adjusting an individual’s income by subtracting an 

amount equivalent to 5 percent of the official federal poverty guidelines (FPG). We present two 

columns for Medicaid because income limits under MAGI-based rules are different for parents and 

children. Since state Medicaid programs’ income eligibility limits may vary based on the age of a child 

(i.e. 0-1 year, 1-5 years, or 6-18), for the child analysis the income limit used is the lowest MAGI level 

in the state for the three age categories for children. The lowest percentage was used so the 

maximum allowable household income represented would allow all children in that household to 

qualify for Medicaid. In addition, states have significant flexibility in setting income eligibility levels for 

children in Medicaid and Children’s Health Insurance Program (CHIP). States may operate CHIP as a 

separate program, include CHIP-eligible children in their Medicaid programs (referred to as CHIP 

Medicaid expansion), or use a combination of the two approaches. Our analysis for children includes 

income eligibility levels for CHIP Medicaid expansion programs, but not separate CHIP programs. A 

different process, not discussed in this report, is used for determining eligibility for non-MAGI groups, 

which include, among others: (1) individuals who are eligible for Medicaid through another federal or 

state assistance program (e.g., foster care children and individuals receiving Supplemental Security 

Income [SSI]), (2) the elderly, and (3) certain individuals who qualify for Medicaid on the basis of 

being blind or disabled without regard to whether the individual is eligible for SSI.

e

The federal SNAP income amount represents 130 percent of the federal poverty guidelines, an 

amount set at the federal level. To be eligible for SNAP, most households must meet gross and net 

income tests. Households cannot have gross monthly income (total, non-excluded income before any 

deductions) higher than 130 percent of federal poverty guidelines. They also cannot have net monthly 

income (gross income minus deductions) higher than 100 percent of federal poverty guidelines, or 

$1,680 per month for a household of three under standard program eligibility rules). 

f

The median maximum monthly income allowed presented in the figure for SNAP represents SNAP’s 

broad-based categorical eligibility (BBCE) state option, in which households may become 

categorically eligible for SNAP because they qualify for a noncash Temporary Assistance for Needy 

Families (TANF) or state maintenance of effort (MOE)-funded benefit. Under BBCE, states use the 

maximum allowable income amount a household may have for their TANF/MOE programs, so this 

amount varies by state, unlike with standard SNAP eligibility rules. As of August 2016, 39 states and 

the District of Columbia have adopted SNAP BBCE policies. Of these, 28 states and the District use

an income amount to assess recipient eligibility higher than the federally-defined SNAP gross income 

limit of 130 percent of federal poverty guidelines. Under federal income eligibility limits, a household 

with three or more members will typically be determined eligible for a SNAP benefit greater than $0. 

However, because BBCE policies can make households with incomes higher than the federal limits 

eligible for SNAP, it is likely that more of these BBCE households will have net incomes too high to 

qualify for a benefit than under standard federal rules.

g

Data on income eligibility limits for TANF are as of July 2015, the most recent data available at the 

time of our review. Income limits for TANF are determined by states. Some states use federal poverty 

guidelines, which are annually adjusted, while others have a defined maximum limit set in state law 
Appendix III: Maximum Monthly Income an 

Applicant May Have and Still Be Eligible for Six 

Selected Low-Income Programs

Page 49 GAO-17-558 Federal Low-Income Programs

that is not adjusted. Our review of eligibility rules included only those for TANF cash assistance and 

not those related to other TANF noncash services.
Appendix IV: GAO Contact and Staff 

Acknowledgements

Page 50 GAO-17-558 Federal Low-Income Programs

Kathryn A. Larin (202) 512-7215 or Larink@gao.gov

In addition to the contact named above, Rachel Frisk (Assistant Director), 

Deborah A. Signer (Analyst-in-Charge), Kay E. Brown, Gale C. Harris, 

Kelly Snow, and Srinidhi Vijaykumar made key contributions to this report. 

Also contributing to this report were James Bennett, Sarah Cornetto, 

Kirsten Lauber, David Lin, Theresa Lo, Sheila McCoy, Jessica Orr, Jason 

Palmer, Gloria Proa, David Reed, Almeta Spencer, Rebecca Kuhlmann 

Taylor, and Max Sawicky.

Appendix IV: GAO Contact and Staff 

Acknowledgements

GAO Contact

Staff 

Acknowledgements

(100867)
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