SUPPLEMENTAL 

NUTRITION 

ASSISTANCE 

PROGRAM

Enhanced Detection 

Tools and Reporting 

Could Improve Efforts 

to Combat Recipient 

Fraud

Report to Ranking Member, Committee 

on the Budget, U.S. Senate

August 2014

GAO-14-641

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-641, a report to Ranking 

Member, Committee on the Budget, U.S.

Senate

August 2014

SUPPLEMENTAL NUTRITION ASSISTANCE 

PROGRAM

Enhanced Detection Tools and Reporting Could 

Improve Efforts to Combat Recipient Fraud

Why GAO Did This Study

In fiscal year 2013, SNAP, the nation’s 

largest nutrition support program,

provided about 47 million people with 

$76 billion in benefits. Fraud, including 

trafficking—the misuse of program 

benefits to obtain non-food items—has 

been a long-standing concern, and 

technology has provided additional 

opportunities to commit and combat 

such activities. State agencies are 

responsible for addressing SNAP 

recipient fraud under the guidance and 

monitoring of FNS. GAO was asked to 

review state and federal efforts to 

combat SNAP recipient fraud.

GAO reviewed: (1) how selected state 

agencies combat SNAP recipient 

fraud; (2) the effectiveness of certain 

state fraud detection tools; and (3) how 

FNS oversees state anti-fraud efforts. 

GAO reviewed relevant federal laws, 

regulations, guidance, and documents; 

interviewed officials in 11 states; 

interviewed federal officials; tested 

fraud detection tools using fiscal year 

2012 program data; and monitored 

websites for potential trafficking online.

Although results are not generalizable

to all states, the 11 states, selected 

based on various criteria including the 

size of their SNAP recipient household 

population and their payment error 

rates, served about a third of SNAP 

recipient households.

What GAO Recommends

GAO recommends, among other 

things, that FNS reassess current

financial incentives and detection tools

and issue guidance to help states

better detect fraud and report on their 

anti-fraud efforts. Agency officials 

agreed with our recommendations.

What GAO Found

The 11 states GAO reviewed employed a range of detection tools, but 

experienced mixed success investigating and pursuing cases to combat potential 

Supplemental Nutrition Assistance Program (SNAP) recipient fraud. States

reported using detection tools required or recommended by the Food and 

Nutrition Service (FNS), such as matching recipient data against prisoner and 

death files. However, most of selected states reported difficulties in conducting 

fraud investigations due to either reduced or maintained staff levels while SNAP 

recipient numbers greatly increased from fiscal year 2009 through 2013. Some 

state officials suggested changing the financial incentives structure to help 

support the costs of investigating potential SNAP fraud. For example, 

investigative agencies are not rewarded for cost-effective, anti-fraud efforts which 

prevent ineligible people from receiving benefits at all.

GAO found limitations to the effectiveness of recommended replacement card 

data and website monitoring tools for fraud detection. FNS requires states to 

monitor SNAP households that request at least four cards per year, but selected 

states reported limited success detecting fraud this way. GAO’s analysis found 

potential trafficking in 73 percent of households reviewed by focusing on SNAP 

households requesting cards in at least four monthly benefit periods. Benefits are 

allotted monthly, and a recipient selling their benefits and then requesting a new 

card would generally have one opportunity per month to do so. As a result, 

additional card requests in the same benefit period may not indicate increased 

risk of trafficking. Additionally, GAO found the FNS recommended e-commerce 

website monitoring tool to be less effective than manual searches in detecting 

posts indicative of SNAP trafficking. GAO found the recommended tool for 

monitoring social media to be impractical due to the volume of irrelevant data.

Figure 1: Using Replacement Cards to Target Trafficking in Michigan, Fiscal Year 2012

FNS has increased its oversight of state anti-fraud activity in recent years by 

issuing new regulations and guidance, conducting state audits, and 

commissioning studies on recipient fraud since fiscal year 2011. Despite these 

efforts, FNS does not have consistent and reliable data on states’ anti-fraud 

activities because its reporting guidance lacks specificity. For example, the 

guidance from FNS did not define the kinds of activities that should be counted 

as investigations, resulting in data that were not comparable across states.

Additional oversight efforts, such as providing guidance to states for reporting 

consistent data, could improve FNS’s ability to monitor states and obtain 

information about more efficient and effective ways to combat recipient fraud.

View GAO-14-641. For more information, 

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

brownke@gao.gov, or Seto J. Bagdoyan at 

(202) 512-6722 or bagdoyans@gao.gov.
Page i GAO-14-641 Supplemental Nutrition Assistance Program

Letter 1

Background 3

Selected States Employed a Range of Tools to Detect Fraud, but 

Conducted Investigations with Limited Staff and Pursued Cases 

with Mixed Success 8

FNS’s Guidance and Tools Can Be Used to Detect Potential 

SNAP Trafficking but Effectiveness is Limited 17

FNS Increased Its Oversight of State Anti-Fraud Activities but 

Lacks Reliable Data on These Efforts 31

Conclusions 36

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 38

Appendix I Objectives, Scope and Methodology 40

Appendix II Trafficking Flags in SNAP Households Receiving Excessive 

Replacement Cards 45

Appendix III Total E-commerce and Social Media Postings Detected During 

Testing Periods 47

Appendix IV Selected States’ Experiences Using FNS’s Recommended 

Automated Online Monitoring Tool and GAO Test Results 50

Appendix V List of Food and Nutrition Service-Commissioned Studies 52

Appendix VI GAO Contacts and Staff Acknowledgment 53

Related GAO Products 54

Contents
Page ii GAO-14-641 Supplemental Nutrition Assistance Program

Tables

Table 1: Tools Used to Detect Potential Supplemental Nutrition 

Assistance Program (SNAP) Eligibility Fraud 9

Table 2: Tools Used to Detect Potential Supplemental Nutrition 

Assistance Program (SNAP) Trafficking 11

Table 3: SNAP Households Receiving Replacement Cards in 

Fiscal Year 2012 19

Table 4: SNAP Households Receiving Excessive Replacement 

Cards and Making Transactions Potentially Indicative of 

Trafficking in Fiscal Year 2012 20

Table 5: Examples of Selected Suspicious Transactions Made by 

One Household Resulting in Trafficking Flags, Fiscal Year 

2012 21

Table 6: Key Food and Nutrition Service (FNS) Oversight 

Regulations, Guidance and Policies, Fiscal Years 2011 

through 2014 31

Table 7: Data Ranges for Percentages 41

Table 8: State Selection Criteria 42

Table 9: Geographic Locations Monitored in 11 Selected States 44

Table 10: Number of Trafficking Flags Associated with Fiscal Year 

2012 Transactions Made by Selected High Replacement 

Card Households in Three States 45

Table 11: Number of Michigan High Replacement Card 

Households Categorized by Count of Trafficking Flags 

and Replacement Card Benefit Periods , Fiscal Year 2012 45

Table 12: Number of Massachusetts High Replacement Card 

Households Categorized by Count of Trafficking Flags 

and Replacement Card Benefit Periods , Fiscal Year 2012 46

Table 13: Number of Nebraska High Replacement Card 

Households Categorized by Count of Trafficking Flags 

and Replacement Card Benefit Periods, Fiscal Year 2012 46

Table 14: E-commerce Postings Advertising Potential Sale of 

Food Stamp Benefits for Cash 47

Table 15: E-commerce Postings Advertising Potential Sale of 

Food Stamp Benefits for Services 48

Table 16: E-commerce Postings Advertising Potential Sale of 

Food Stamp Benefits for Goods 49

Table 17: Social Media Postings Soliciting Food Stamp Benefits 49
Page iii GAO-14-641 Supplemental Nutrition Assistance Program

Figures

Figure 1: Number of Supplemental Nutrition Assistance Program 

(SNAP) households per Investigator in Selected States, 

Fiscal Years 2009 and 2013 13

Figure 2: Targeting Potential Supplemental Nutrition Assistance 

Program (SNAP) Benefit Trafficking Using Replacement 

Card and Transaction Data to Identify Higher Risk 

Households in Michigan, Fiscal Year 2012 22

Figure 3: Analysis of Automated Tool Recommended for 

Monitoring E-commerce Websites 26

Figure 4: Results of 30-day Monitoring of One Popular ECommerce Website Using Automated and Manual Tools 

to Detect Posts Indicative of Food Stamp Trafficking and 

States' Experiences with Using Tools 27

Figure 5: FNS Recipient Integrity Review Components 33

Abbreviations

ALERT Anti-Fraud Locator Using Electronic Benefits Transfer

Retailer Transactions

ADH Administrative Disqualification Hearing

eDRS Electronic Disqualified Recipient System

EBT electronic benefit transfer

FNS Food and Nutrition Service

FY fiscal year

OMB Office of Management and Budget

PIN Personal Identification Number

SLEB state law enforcement bureau

SNAP Supplemental Nutrition Assistance Program

Recovery Act American Recovery and Reinvestment Act of 2009

USDA U.S. Department of Agriculture

USDA OIG U.S. Department of Agriculture Office of Inspector

General

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

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

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

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Page 1 GAO-14-641 Supplemental Nutrition Assistance Program

441 G St. N.W.

Washington, DC 20548

August 21, 2014

The Honorable Jeff Sessions

Ranking Member

Committee on the Budget

United States Senate

Dear Senator Sessions:

In fiscal year 2013, the federal government provided more than $76 billion 

in benefits to help about 48 million people purchase food through the 

Supplemental Nutrition Assistance Program (SNAP). On average, 

recipient households received about $275 a month in assistance in that 

year. Since fiscal year 2009, SNAP has experienced an over 50-percent 

increase in distributed benefits and an over 40-percent increase in 

recipients. Such rapid program growth can increase the potential for fraud 

unless appropriate agency controls are in place to help minimize these 

risks. The Office of Management and Budget has designated SNAP as a 

high-error program due to the estimated dollar amount in improper 

payments for fiscal year 2013.1

The state and federal governments share responsibility for addressing 

SNAP recipient fraud. State agencies are directly responsible for 

detecting, investigating, and prosecuting recipient fraud, and the U.S. 

Department of Agriculture’s Food and Nutrition Service (FNS) is 

responsible for guiding and monitoring this state activity. FNS has 

traditionally focused on pursuing retailer fraud. We reported on these 

efforts in fiscal year 2007 and found that FNS was making progress in 

Furthermore, program officials have had 

long-standing concerns that some recipients falsify information to 

improperly receive benefits, or misuse their benefits to solicit or obtain 

non-food goods, services and cash—a practice known as trafficking. 

Technology has provided new opportunities to commit as well as to 

combat such fraud. For example, e-commerce and social media websites 

have emerged as new venues for trafficking benefits. Conversely, 

monitoring recipient transaction data may provide clues to potential SNAP 

fraud.

 1 This dollar amount represents benefits distributed in error due to administrative as well 

as recipient errors, not all of which can be attributed to fraud.
Page 2 GAO-14-641 Supplemental Nutrition Assistance Program

using electronic data to investigate trafficking.2

This report examines: (1) how selected state agencies combat SNAP 

recipient fraud; (2) the effectiveness of certain fraud detection tools 

recommended to states, including benefit card replacement data and ecommerce and social media website monitoring; and (3) FNS’s oversight 

of state anti-fraud efforts.

To enhance these efforts, 

FNS implemented most of our recommendations by taking additional 

steps to target and provide early oversight of stores most likely to traffic; 

developing a strategy to increase penalties for trafficking; and promoting 

state efforts to pursue recipients suspected of trafficking. Since then, the 

agency has increased attention to the recipient side of trafficking. For 

example, in fiscal year 2012, FNS recommended that states use certain 

tools, such as analyzing transaction data for those requesting multiple 

benefit card replacements and monitoring websites where traffickers may 

be attempting to buy or sell SNAP benefits. In light of this increased 

emphasis, you asked us to review federal and state efforts to combat 

SNAP recipient fraud.

For all three reporting objectives, we focused on federal and state SNAP 

recipient anti-fraud work for fiscal years 2009 to 2014, a period after the 

program received additional funding through the American Recovery and 

Reinvestment Act of 2009 (Recovery Act).3

 2 Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better Targeting 

Stores Likely to Traffic and Increasing Penalties, 

We reviewed relevant federal 

laws, regulations, program guidance and reports, and we interviewed 

FNS officials in headquarters and all seven regional offices to obtain 

information for all three objectives. For the first objective, we selected 11 

states for our review—Florida, Maine, Massachusetts, Michigan, 

Nebraska, New Jersey, North Carolina, Utah, Tennessee, Texas, and 

Wyoming—to achieve variation in geographic location, and a mix of high, 

medium and low SNAP payment error rates, percent of the total number 

of SNAP households nationwide, and proportion of recipients whom state 

officials reported as disqualified from the program due to non-compliance.

For all 11 states, we interviewed knowledgeable state and local officials 

about their recipient anti-fraud work and obtained related documentation. 

For the second objective, we monitored a popular e-commerce website 

GAO-07-53 (Washington, D.C.: Oct. 13, 

2006).

3 Pub. L. No. 111-5, § 101, 123 Stat. 115, 120.
Page 3 GAO-14-641 Supplemental Nutrition Assistance Program

for 30 days and a popular social media website for 5 days, to determine 

how our selected states could use certain automated monitoring tools 

recommended by FNS to detect potential SNAP fraud.4

We conducted this performance audit from April 2013 through July 2014 

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 we obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

We also analyzed 

fiscal year 2012 replacement card and transaction data for households in 

three of the selected states—Michigan, Massachusetts, and Nebraska—

to assess the extent to which certain analyses could better uncover

patterns of potential fraud. We selected these three states to provide 

information on a mix of high, medium and low states in terms of their 

percentage of the total number of SNAP households nationwide.

Recipient households in the 11 states we reviewed represent about onethird of all SNAP program households; however, the information we report 

from these states is not generalizable to all states. For the third objective, 

we obtained and analyzed documents and reports relevant to FNS’s 

program oversight, including their fiscal year 2013 assessments of state 

anti-fraud work for all 50 states and the District of Columbia. All of the 

data included in this report were assessed and determined to be 

sufficiently reliable for our purposes.

The goal of SNAP, formerly known as the federal Food Stamp Program, 

is to help low-income individuals and households obtain a more nutritious 

diet. It does so by supplementing their income with benefits to purchase 

allowable food items. The federal government pays the full cost of the 

benefits and shares the responsibility and costs of administering the 

program with the states. Specifically, FNS is responsible for promulgating 

program regulations and ensuring that states comply with these 

 4 “E-commerce” websites allow users to advertise the sale of goods and services. “Social 

media” websites allow subscribers to exchange information and ideas with others who 

may or may not subscribe.

Background

Federal and State Roles 

for Addressing SNAP 

Fraud
Page 4 GAO-14-641 Supplemental Nutrition Assistance Program

regulations by issuing guidance and monitoring their activity. FNS officials 

at headquarters are assisted in this oversight work by officials in seven 

regional offices. FNS also determines which retailers are eligible to 

accept SNAP benefits in exchange for food and investigates and resolves 

cases of retailer fraud. State officials, on the other hand, are responsible 

for determining the eligibility of individuals and households, calculating 

the amount of their monthly benefits and issuing such benefits on an 

electronic benefit transfer (EBT) card in accordance with program rules.

States are also responsible for investigating possible violations by benefit 

recipients and pursuing and acting on those violations that are deemed 

intentional.5 Intentional program violations include acts of fraud, such as 

making false or misleading statements in order to obtain benefits and 

trafficking (i.e., using benefits in unallowable ways, such as by 

exchanging benefits for cash or non-food goods and services or 

attempting to do so). 6

Recipients can traffic benefits by:

• Selling benefits to retailers – recipients collaborate with retailers who 

exchange cash for SNAP benefits. For example, a retailer can allow a 

recipient to charge $100 on his or her EBT card and then pays the 

recipient $50 instead of providing food.

• Selling EBT cards to another person – recipient exchanges the EBT 

card and the corresponding Personal Identification Number (PIN) 7

All of these trafficking activities may result in recipients having to give 

their EBT card and PINs to another person who may not return the card. 

Recipients can report sold EBT cards as lost or stolen to state agencies 

or EBT management contractors and receive new cards which can be 

for 

cash or non-food goods or services (e.g., rent or transportation).

These sales can occur in person or by posting offers on social media 

and e-commerce sites.

 5 7 C.F.R. § 273.16.

6

7 U.S.C. § 2015(b), 7 C.F.R. § 273.16. Furthermore, under federal law, it is illegal for a 

person to knowingly use, transfer, acquire or possess SNAP benefits in any manner that is 

contrary to the laws and regulations that govern the SNAP program. 7 U.S.C. § 2024(b). 

The statute applies to program recipients and retailers as well as people not participating 

in the program.

7 Similar to a bank card, for security purposes, SNAP EBT cards require a PIN to access 

the benefits associated with the card.
Page 5 GAO-14-641 Supplemental Nutrition Assistance Program

used for future transactions, for example, when the benefits are 

replenished the next month.

According to a September 2012 U.S. Department of Agriculture Office of 

Inspector General (USDA OIG) report, the magnitude of program abuse 

due to recipient fraud is unknown because states do not have uniform 

ways of compiling the data that would provide such information.

Therefore, in the report, the USDA OIG recommended that FNS 

determine the feasibility of creating a uniform methodology for states to 

calculate their recipient fraud rate.8 As FNS seeks to address this 

recommendation, it is legally required to monitor its potential improper 

payments of SNAP benefits. The agency estimated an improper payment 

or error rate of the program at 3.4 percent, which represented an 

estimated $2.6 billion in wrongful payments, in fiscal year 2013.

9 The

percentage represents benefits distributed in error due to administrative 

as well as recipient errors, not all of which can be attributed to fraud. 

However, due to the large dollar amount involved in improper payments, 

the Office of Management and Budget (OMB) has placed SNAP on its list 

of high-error programs.10

 8 USDA OIG, Analysis of FNS’ Supplemental Nutrition Assistance Program Fraud 

Prevention and Detection Efforts. Audit Report 27002-0011-13, (Washington, D.C.: Sept. 

28, 2012).

Furthermore, after studying the cause of these 

errors, USDA officials stated that over 90 percent were due to verification 

errors. These types of errors occur when an agency fails to or is unable to 

verify recipient information—including earnings, income, assets, or work 

status—even though verifying information exists in third-party databases 

or other resources. Examples of verification errors include an agency not 

confirming a recipient’s reported earnings or work status through existing 

databases, or the recipient failing to provide an agency with information 

on earnings.

9 It also represents the over- and underpayment of benefits, although the vast majority of 

improperly paid SNAP benefits are overpaid.

10 OMB designates a program as “high-error” based on improper payment information in 

agencies’ annual Performance and Accountability Report and Agency Financial Report. 

Generally, a program is deemed susceptible to significant improper payments if the 

program has such payments greater than $10 million and over 2.5 percent of all payments 

made under that program, or if the program has more than $100 million in estimated 

improper payments. SNAP is ranked 7th based on the dollar amount estimated in improper 

payments among the 13 programs on the high error list.
Page 6 GAO-14-641 Supplemental Nutrition Assistance Program

Given FNS’s role of directly overseeing retailer eligibility and 

disqualification, federal officials have traditionally focused on retailer 

trafficking. In 1996, FNS was given legal authority to disqualify retailers by 

using EBT transaction data— which display suspicious patterns of benefit 

use—as its sole form of evidence.11 FNS maintains such transaction data 

within its Anti-Fraud Locator Using Electronic Benefits Transfer Retailer 

Transactions (ALERT) system. In our October 2006 report on potential 

retailer fraud, we found that federal officials had concerns about state 

efforts to address recipient trafficking, and recognized that retailer 

trafficking can only occur when willing recipients are involved.12 At the 

time of that report, federal officials told us that they were providing state 

officials with lists of recipients involved in their retailer trafficking cases, 

but many states were not acting on this information at the time because it 

was difficult and costly to prove individual trafficking cases. Furthermore, 

as we noted in our September 2010 report, the USDA OIG found that 

states were not analyzing their EBT data to detect misuse of benefits, 

largely because FNS did not require this.13 FNS has calculated a retailer 

trafficking rate, which was estimated to involve 1.3 percent of benefits 

issued from fiscal year 2009 to 2011—a total of $858 million.14

States must adhere to several requirements for detecting SNAP recipient 

fraud, conducting investigations and providing due process prior to 

disqualifying program violators. For example, states are required to have 

fraud detection units covering areas in which 5,000 or more households 

 11 Pub. L. No. 104-193, § 841, 110 Stat. 2105, 2331. Prior to this law, FNS usually sent its 

investigators into stores numerous times over a period of months to attempt to traffic 

benefits as a way to gather evidence against a retailer. The use of EBT transaction 

evidence can help to reduce the resources needed for investigations by eliminating the 

need for multiple store visits for some cases.

12 Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better Targeting 

Stores Likely to Traffic and Increasing Penalties, GAO-07-53 (Washington, D.C.: Oct. 13, 

2006).

13 USDA OIG, State Fraud Detection Efforts for the Supplement Nutrition Assistance 

Program – Use of EBT Management Reports, 27703-02-Hy(2) (Washington, D.C.: Sept. 

10, 2010).

14 The USDA OIG also recommended that FNS improve the calculation of its retailer 

trafficking rate because it was based on a judgmentally-selected sample. For more 

information, see USDA OIG, Analysis of FNS’ Supplemental Nutrition Assistance Program 

Fraud Prevention and Detection Efforts, Audit Report 27002-0011-13 (Washington, D.C.: 

Sept. 28, 2012).

State Anti-Fraud Activity 

Requirements
Page 7 GAO-14-641 Supplemental Nutrition Assistance Program

participate in the program; however, those working on fraud investigations 

need not be dedicated to this work full-time or exclusively to SNAP cases. 

States must also conduct data matches at the time of application and at 

other times to determine whether the information provided for a potential 

recipient is for someone who is incarcerated, deceased, or disqualified 

from the program. State SNAP agencies are responsible for pursuing 

judgments against those who intentionally violate SNAP rules. These 

judgments can be pursued within the state agency through an 

Administrative Disqualification Hearing (ADH) or through the judicial 

system in a court determined to have jurisdiction over the case. When a 

state decides to administratively pursue disqualification of a recipient for 

intentional program violations, the state is responsible for conducting a 

series of actions, such as providing timely notification to the recipient that 

there will be an ADH, and for states that have waiver procedures, that the 

recipients may waive their right to a hearing. If it is determined through 

the hearing or criminal prosecution that a person has intentionally violated 

program rules or the person has waived the hearing, only the person 

involved in the case is disqualified and not the entire household, but the 

entire household is responsible for repaying the specific ill-gotten or 

misused benefit amount. States are generally allowed to retain 35 percent 

of the fraud-related, overpaid benefits they collect, and the rest is 

returned to the federal government. In fiscal year 2012, states reported to 

FNS that they collected about $74 million in fraud-related claims. 15

To assist other states and FNS, states are also responsible for reporting 

on disqualifications and other fraud-related activities. Specifically, within 

30 days of disqualifying a benefit recipient, state officials are to report this 

information to FNS through a database known as the Electronic 

Disqualified Recipient System (eDRS).16

 15 Also, in fiscal year 2012, FNS reported that states established over $530 million in new 

claims against recipients and collected over $320 million. These claims represent those 

established due to intentional program violation (fraud), inadvertent household error, or 

agency error.

This information allows other 

states to learn who has been disqualified elsewhere and to impose 

16 eDRS is also a data matching tool to help prevent improper payments and FNS 

requires that states check this system prior to providing benefits to an applicant.
Page 8 GAO-14-641 Supplemental Nutrition Assistance Program

penalties, which vary based on the number and type of offense.17

Furthermore, states are required to report their fraud-related activity to 

FNS on their annual Program and Budget Summary Statements. This 

report, provided through the form FNS-366B, is to include the number of 

investigations and disqualifications, and the dollar amount of their fraud 

claims. 18

The 11 states we reviewed employed a range of detection tools, but 

experienced mixed success in combating SNAP fraud. Although some 

were able to leverage additional resources, officials in most states 

reported challenges with potential fraud because their staff remained 

limited while recipient numbers grew. Furthermore, pursuing cases 

through administrative hearings and the courts generally resulted in 

disqualifications but collecting overpayments was a challenge.

 17 According to program regulations, if a person is found to have trafficked $500 or more 

in benefits or used or received benefits in a transaction involving the sale of firearms, 

ammunition, or explosives, he or she will be disqualified permanently for the first offense. 

Also, a person who has fraudulently provided identification or residential information in 

order to gain duplicative benefits will be disqualified for 10 years for the first offense. Using 

or receiving benefits in transactions involving the sale of controlled substances will result 

in a 2 year penalty for the first violation and permanent disqualification for the second. 

Lesser offenses will result in 1 year disqualification for the first violation, 2 years for the 

second and permanent disqualification for the third.

18 These reports are submitted within 45 days of the end of the state’s fiscal year. 

According to FNS, this means the agency receives the reports on August 15th from most 

states.

Selected States 

Employed a Range of 

Tools to Detect Fraud, 

but Conducted 

Investigations with 

Limited Staff and 

Pursued Cases with 

Mixed Success
Page 9 GAO-14-641 Supplemental Nutrition Assistance Program

In the majority of states we reviewed, officials told us they were using 

well-known tools for detecting potential recipient eligibility fraud, such as 

data matching and referrals obtained through fraud reporting hotlines and 

websites. Specifically, all 11 states that we reviewed had fraud hotlines or 

websites, and all matched information about SNAP applicants and 

recipients against various data sources to detect those potentially 

improperly receiving benefits, as FNS recommended or required. (See 

table 1.)

Table 1: Tools Used to Detect Potential Supplemental Nutrition Assistance Program (SNAP) Eligibility Fraud

Detection tool

Federal or 

state initiative

# of 11 states 

that reported 

using tool Description

eDRS match FNS required 11 The Food and Nutrition Service (FNS) requires states to check for 

disqualified individuals in the Electronic Disqualified Recipient 

System (eDRS) when certifying or recertifying them for SNAP (all 11

states)

Prisoner match FNS required 11 States must routinely match applicants and recipients against a 

prisoner verification system to prevent receipt of SNAP benefits by 

incarcerated individuals (all 11 states)

Death match FNS required 11 States must check SSA's Death Master File to prevent receipt of 

benefits by deceased individualsa (all 11 states)

PARIS matchb FNS 

recommended

11 States provide lists of SNAP recipients for the quarterly PARIS 

matching, and receive lists of recipients who are also on the SNAP 

rolls of another state (all 11 states)

Wage matching State-initiated 9 9 states reported data matching to detect unreported and 

underreported wages (Florida, Maine, Massachusetts, Michigan, 

North Carolina, New Jersey, Tennessee, Texas, Wyoming)

Other data matching State-initiated 6 6 states verify information provided by applicants/recipients by 

matching with other data sources, such as local jails, schools, and 

lists of lottery winners (Florida, Maine, Michigan, North Carolina, 

Tennessee, Texas)

Online data search services State-initiated 2 2 states pay a private company for searches of numerous public and 

private databases including vital statistics, current wage and new hire 

data, child support, and residence information based on phone lines 

and motor vehicle registrations (Florida, Texas)

For Fraud Detection, 

Selected States Employed 

Tools Such As Data 

Matching, Referrals, 

Analysis of Transaction 

Data, and Website 

Monitoring
Page 10 GAO-14-641 Supplemental Nutrition Assistance Program

Detection tool

Federal or 

state initiative

# of 11 states 

that reported 

using tool Description

Identity verification software State-initiated 2 2 states use software that requires individuals to provide information 

confirming their identities when they set up or access an online 

SNAP account (Florida, Texas)

Error-prone profile State-initiated 1 State provides case workers with a profile for applications that lists 

items to watch for that may indicate applicant fraud (Florida)

Mapping software State-initiated 1 State uses locator software to identify individuals applying for SNAP 

from a computer in another state (Michigan)

Public referrals State-initiated 11 States provide fraud hot lines or online fraud referral (all 11 states)

Exchange of most recent 

available SNAP enrollment 

data

FNS pilot 1 5 states are participating in a pilot of the exchange of their most 

recent available SNAP enrollment data (Florida, Alabama, Georgia, 

Louisiana, Mississippi)

Source: GAO analysis of data from selected states. | GAO-14-641

a

Death Master File database contains the complete name of the deceased, the Social Security 

Number, birth and death dates, and whether the death report was verified.

b

PARIS is the Public Assistance Reporting Information System administered by the Department of 

Health and Human Services.

Beyond the required and recommended data matches, Florida, Texas, 

Michigan, and one county in North Carolina use specialized searches that 

check numerous public and private data sources, such as school 

enrollment, vehicle registration, vital statistics, and credit reports and 

other data on out-of-state program participation and benefit use to detect 

potential fraud prior to providing benefits to potential recipients. Florida 

officials told us that this focus on preventive efforts was key to helping 

them manage recent constraints on their investigative budgets. 

Specifically, Florida officials mentioned that when their investigative staff 

was reduced because of budget cuts in 2005, they shifted the majority of 

their anti-fraud resources from post-eligibility fraud investigations to 

preventing ineligible individuals from receiving SNAP benefits. This shift 

has allowed the state to more cost-effectively manage its efforts to 

combat potential fraud by developing detection tools against eligibility 

fraud and improper benefit receipt, such as identification verification 

software and profiles that case workers can use to identify error-prone 

applications.

To address trafficking, officials in the 11 states reported that they 

analyzed patterns of EBT transactions and monitored replacement card 

data and online postings, as recommended or required by FNS. (See 

table 2.) When reviewing EBT transactions, state officials attempt to 

uncover patterns that may indicate trafficking, much in line with what FNS 

has been doing for years to uncover retailer fraud. Officials in two states 
Page 11 GAO-14-641 Supplemental Nutrition Assistance Program

mentioned that, for some cases, this EBT data analysis is done only after 

receiving fraud referrals through the hotline and websites. For example, 

while Florida officials reported that they routinely review EBT transaction 

data for suspicious patterns, Texas officials reported that they only review 

transactions for individuals or households after they have been referred to 

them because of potential fraud.

Table 2: Tools Used to Detect Potential Supplemental Nutrition Assistance Program (SNAP) Trafficking

Detection tool

Federal or state 

initiative

# of 11 states that 

reported using tool Description

Monitoring of 

excessive 

replacement EBT 

cards

FNS required 11 The Food and Nutrition Service (FNS) requires states to track recipients 

who have requested 4 or more replacement electronic benefit transfer 

(EBT) cards in a 12-month period. States may send them letters 

explaining the proper use of EBT cards generally must warn them that 

their EBT transactions are being monitored. (all 11 states)

Monitoring of online 

postings

FNS recommended 8 8 states use either automated feeds or manual monitoring to detect 

postings on social media and e-commerce websites by individuals 

seeking to sell SNAP benefits (Florida, Maine, Michigan, New Jersey, 

Tennessee, Texas, Utah, Wyoming)

Analysis of EBT 

transactions data

FNS recommended 11 States analyze EBT transaction data for patterns that may indicate 

trafficking. The data analysis efforts vary from state to state.

Source: GAO analysis of data from selected states. | GAO-14-641

The size and organization of the investigative units differed among the 11 

states we reviewed, with wide variation in the number of staff available to 

investigate potential SNAP recipient fraud.19

 19 In most of the 11 states we reviewed, the fraud units are housed in the human services 

department or a state division responsible for program integrity, and investigators may be 

concentrated in the state capital or located around the state. Investigators typically have 

backgrounds either in investigation or as case workers or both, and five states noted that 

their typical investigator has a 4-year college degree in a related field. The federal 

government generally reimburses states for 50 percent of the cost of their fraud 

investigative work.

For example, in 2013, 

Most of the Selected 

States Reported Difficulty 

Conducting Fraud 

Investigations Due to 

Limited Staff and Growing 

Numbers of Recipients, 

but Some Leveraged 

Additional Resources
Page 12 GAO-14-641 Supplemental Nutrition Assistance Program

Massachusetts and New Jersey had 498,580 and 432,270 recipient 

households, respectively, but Massachusetts, where SNAP was 

administered at the state level, had just 37 investigators, while countyadministered New Jersey had nearly 300. Furthermore, the investigators 

in the 11 states we reviewed each had responsibilities unrelated to SNAP. 

Although officials in three states—Massachusetts, Tennessee, and 

Wyoming—reported that the majority of their investigations involved 

potential SNAP fraud, state investigators in all 11 states we reviewed 

were also responsible for pursuing fraud in other public assistance 

programs, such as Medicaid, Temporary Assistance for Needy Families, 

and child care and housing assistance programs. In North Carolina, fraud 

investigation was not the primary responsibility of some local officials who 

did this work; state officials reported that some counties opted to have 

caseworkers or program supervisors conduct fraud investigations. In 

general, state officials reported that limits on staffing levels are significant 

hindrances to their investigations of eligibility fraud and trafficking, with 8 

of the 11 states we reviewed reporting inadequate staffing due to attrition, 

turnover, or lack of funding. Of the 10 states that were able to provide the 

information,20

 20 Because counties in North Carolina vary in how they staff fraud investigations as 

mentioned earlier, officials were not able to provide the number of investigators working 

on SNAP. 

the number of SNAP households per investigator increased 

in 8 states between fiscal years 2009 and 2013 by as much as 155 

percent. In contrast, Maine and Michigan have increased their 

investigative staff, which decreased their household-to-investigator ratios 

in fiscal year 2013. (See fig. 1.)
Page 13 GAO-14-641 Supplemental Nutrition Assistance Program

Figure 1: Number of Supplemental Nutrition Assistance Program (SNAP) households per Investigator in Selected States, 

Fiscal Years 2009 and 2013 

Notes: New Jersey provided calendar year information for investigators. Florida lost 27 investigators 

in late 2009, dropping from 130 to 103. North Carolina was unable to provide the number of 

investigators because some local offices do not have designated fraud investigators. Furthermore, all 

investigators in the selected state were responsible for pursuing fraud in other public assistance 

programs, and therefore, could be responsible for monitoring a larger population than is mentioned in 

the figure.

In their effort to combat potential fraud, some states implemented a way 

to leverage their available investigative resources. Specifically, four of the 

states we reviewed—Florida, Massachusetts, Michigan and Nebraska—

had implemented and two states—Maine and North Carolina—were in the 
Page 14 GAO-14-641 Supplemental Nutrition Assistance Program

process of implementing state law enforcement bureau (SLEB) 

agreements. FNS has been supportive of states’ efforts to establish these

agreements between state SNAP agencies and federal, state, and local 

law enforcement agencies which enable state SNAP investigators to 

cooperate in various ways with local, state, and federal law enforcement 

agents, including those within the USDA OIG. For example, under these 

agreements, law enforcement agencies can notify the SNAP fraud unit 

when they arrest someone who possesses multiple EBT cards, and 

SNAP agencies can provide “dummy” EBT cards for state and local 

officers to use in undercover trafficking investigations. According to 

officials in one Florida county, this type of cooperation allowed local police 

officers to make 100 arrests in its first undercover operation of recipients 

who were allegedly trafficking SNAP benefits. Furthermore, some state 

and local officials in Michigan, Maine, and Florida told us that increasing 

awareness of SNAP trafficking among local law enforcement officials 

helps in resolving these matters when potential trafficking is uncovered in 

other police investigations. For example, while investigating drug-related 

crimes, officials in those states told us they have uncovered multiple EBT 

cards in the possession of one person.

In light of their increased SNAP caseload, some officials suggested 

changing the incentive structure to help states address the costs of 

investigating potential SNAP fraud. According to GAO’s Fraud Prevention 

Framework, investigations, although costly and resource-intensive, can 

help deter future fraud and ultimately save money.21 Officials in one state 

told us that it would help if FNS would provide additional financial 

incentives for states to prevent potential fraud at the time of application 

beyond what is currently provided for recovered funds.22

 21 GAO’s Fraud Prevention Framework, developed during previous program audits, 

emphasizes that comprehensive controls are necessary to minimize fraud, waste, and 

abuse within any federal program. For more information, see Individual Disaster 

Assistance Programs: Framework for Fraud, Prevention, Detection and Prosecution, 

When fraud by a 

recipient is discovered, the state may generally retain 35 percent of the 

GAO-06-954T (Washington, D.C.: July 12, 2006); Hurricanes Katrina and Rita Disaster 

Relief: Improper and Potentially Fraudulent Individual Assistance Payments Estimated to 

be between $600 Million and $1.4 Billion, GAO-06-844T (Washington, D.C.: June 14, 

2006); and Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s 

Control Weaknesses Exposed the Government to Significant Fraud and Abuse, 

GAO-06-403T (Washington, D.C.: Feb. 13, 2006).

22 According to the GAO Fraud Prevention Framework, prevention controls are the most 

efficient and effective ways to address fraud because payments can be difficult to recover.
Page 15 GAO-14-641 Supplemental Nutrition Assistance Program

recovered overpayment, but when a state detects potential fraud by an 

applicant and denies the application, there are no payments to recover. 

Officials in four of the states we reviewed said that their anti-fraud efforts 

could be enhanced if the percentage of recovered overpayments that 

states may retain was increased, and officials in three states said that 

FNS should direct that states apply the retention money to anti-fraud 

efforts. Overall, state anti-fraud incentives have the potential to produce 

federal cost savings by encouraging state officials to prevent the benefits 

from being issued to ineligible people as well as deter fraud by more 

actively investigating and recovering funds.23

Officials in most of the 11 states we reviewed said that they have mainly 

pursued cases of eligibility fraud, such as the misrepresentation of 

household income or composition. In addition to testimony from 

witnesses, state investigators are able to build cases based on public 

records and employment statements to prove the misrepresentation.

However, state officials reported that trafficking is more difficult to prove. 

Officials in North Carolina and a prosecutor in Michigan noted that 

trafficking cases involve two individuals breaking the law, and it can be 

difficult to get one to testify against the other. For example, the Michigan 

prosecutor told us about a case in which a landlord for a subsidized 

housing complex was receiving SNAP benefits in exchange for rent, and 

the tenants would not testify against this person because they thought 

she was doing them a favor by accepting the SNAP benefits as payment.

 23 For example, providing states with additional resources through increased retention 

rates may result in a net savings for SNAP if increased collections in payment recoveries 

outweigh the increased amount states receive in retentions. However, FNS officials noted 

the retention rate is set forth in federal law and that changing the retention rate would 

require legislative action. As early as December 2012, FNS officials reported encouraging 

states to use bonuses received from FNS for good performance and fraud claims 

collection retentions to support program integrity and anti-fraud efforts.

While Selected States 

Pursue Fraud through 

Administrative Hearings 

and the Courts, They 

Reported Difficulties with 

Prosecutions and 

Overpayment Recovery
Page 16 GAO-14-641 Supplemental Nutrition Assistance Program

State officials we interviewed also reported that the willingness of local 

prosecutors to pursue charges in court for SNAP fraud has varied across 

jurisdictions. Officials in eight states reported that a minimum dollar 

threshold of fraudulently-obtained benefits was required for prosecuting 

cases in court, ranging from $100 (in Tennessee) to $5,000 (in Texas). 

Prosecutors in some local jurisdictions were not willing to accept SNAP 

fraud cases at all. For example, prosecutors in one county in North 

Carolina told SNAP officials that they would not prosecute SNAP fraud 

cases because they need their resources for more serious criminal cases. 

Texas officials said that some local prosecutors in their state have also 

refused to prosecute SNAP cases due to workload concerns. Other 

prosecutors we interviewed said that to make efficient use of their limited 

resources, they have often sought plea deals that require the individual to 

repay the government rather than going to trial. Such plea deals may call 

for the individual to be arrested if the SNAP benefits are not repaid, and 

may also require that a person have a criminal record as a result of the 

plea. Furthermore, plea deals mitigate some of the unpredictability of 

trying a case before a jury. Prosecutors in Tennessee and Florida said 

that juries may be unwilling to convict individuals of SNAP fraud because 

they may be sympathetic to recipient claims that they do not understand 

government regulations or are compelled to commit fraud to support their 

families. SNAP officials in North Carolina said they were concerned about 

losing the deterrent effect of prosecutions due to the unwillingness of the 

judicial system to undertake SNAP recipient fraud cases.

Recovering overpayments from individuals found to have committed fraud 

in either an administrative or a court proceeding has been a challenge,

according to officials we interviewed in Florida and Michigan. Specifically, 

those officials reported that an individual who is disqualified may be 

required to repay an overpayment, but may not have enough income to 

do so. Furthermore, if the individual becomes eligible for SNAP benefits 

again after the period of disqualification is over, the state may garnish the 

future SNAP benefits to repay the recipient’s prior debt. However, when 

an individual is permanently disqualified from the program, garnishment is 

not possible. To encourage people to repay the benefits, one local 

Michigan prosecutor has established a program that offers to erase the 

individual’s criminal record if the individual makes full restitution through a 

repayment plan. The program helps collect restitution of fraud payments 

in all the county’s welfare programs and has had an 80 percent success 

rate in collecting repayments, according to the local prosecutor. States’

difficulty collecting overpayments compounds their concerns about having 

adequate resources for investigations because some states use 

recovered overpayments for this purpose.
Page 17 GAO-14-641 Supplemental Nutrition Assistance Program

Selected states reported difficulties using FNS recommended 

replacement card data as a fraud detection tool, and our data analysis 

found that a more targeted approach may better identify potential fraud. 

Our testing found the recommended e-commerce monitoring tool less 

effective than manual searches in detecting postings indicative of 

potential trafficking, and we found the tool for monitoring social media to 

be impractical for states due to the volume of irrelevant data.

Although FNS requires that states look at replacement card data as a 

potential indicator of trafficking, states reported difficulties using the data 

as a fraud detection tool. In 2012, FNS issued guidance to states based 

on a best practice used in North Carolina, encouraging states to review 

recipients who have requested four or more replacement EBT cards 

within 12 months because such behavior may indicate trafficking. In 2014, 

FNS finalized a rule that requires states to monitor replacement card data 

and send notices to those SNAP households requesting excessive 

replacement cards, defined as at least four cards in a 12-month period. 

All 11 states we reviewed reported tracking recipients who make 

excessive requests for replacement EBT cards and sending them warning 

letters, as required by FNS, but they have not had much success in 

detecting fraud through that method. At the time of our review, four states 

reported that they had not initiated any trafficking investigations as a 

result of this monitoring, and five states reported a low success rate for 

such investigations. One state had just started monitoring replacement 

card data. Only one of our selected states reported some success using 

the replacement card data to identify and pursue trafficking. Furthermore, 

although state officials recognized that some replacement card requests 

may be related to potential fraud, officials from 7 of the 11 states reported 

that the current detection approach specified by FNS often leads them to 

people who make legitimate requests for replacement cards for reasons 

such as unstable living situations or a misunderstanding of how to use the 

SNAP EBT card. North Carolina officials also mentioned that when they 

originally developed this approach currently required by FNS, it was not 

intended to detect trafficking. Rather, it was to help them manage the 

number of replacement card requests they received.24

 24 In addition to those in North Carolina, officials in Michigan and Massachusetts reported 

a reduction in replacement card requests after sending the notification letters.

FNS’s Guidance and 

Tools Can Be Used to 

Detect Potential 

SNAP Trafficking but 

Effectiveness is 

Limited

Selected States Report 

Limited Success Using 

Replacement Card Data 

as a Detection Tool
Page 18 GAO-14-641 Supplemental Nutrition Assistance Program

FNS is aware of states’ concerns about the effectiveness of this effort, but 

it continues to stress that monitoring these data is worthwhile. For 

example, FNS officials reported that they are also aware that many 

replacement card requests are legitimate but they feel that the monitoring 

of replacement card data has an important educational component, as it 

allows states to identify situations where a recipient requires education on 

how to use their SNAP EBT card. FNS officials also reported that states 

have seen a reduction in households continuing to request replacement 

cards related to these efforts. However, FNS’s Western Regional officials 

reported that, given states’ experiences with the current process, it may 

be better for states to be more selective in sending notices.

Our analysis found indicators of potential SNAP trafficking in households 

with excessive replacement cards, suggesting that states may be able to 

use replacement card data to help identify trafficking by taking a targeted 

approach to analyzing the data in conjunction with related transaction 

data. We identified 7,537 SNAP recipient households in three selected 

states—Michigan, Massachusetts and Nebraska—that both received 

replacement cards in four or more monthly benefit periods in fiscal year 

2012 and made transactions considered to be potential signs of 

trafficking. Furthermore, as discussed below, we developed an approach 

for analyzing replacement card data that may provide states with a more 

targeted way to identify potential trafficking activity and reduce the 

number of households for further review by up to 40 percent. Given that 

states reported having limited resources for conducting investigations, a 

more targeted approach may enhance their ability to pursue SNAP 

households at higher risk of trafficking.

Overall, our approach to analyzing replacement card data reduced the 

number of households for further review by 33 percent compared to the 

current FNS regulation. For the purposes of our analysis, we defined 

excessive replacement card households as those receiving replacement 

cards in four or more unique benefit periods in a year. Our approach took 

into account FNS’s rule that defines excessive replacement cards as at 

least four requested in a year. However, we further refined our analysis to 

consider the monthly benefit period of replacement card requests. SNAP 

benefits are allotted on a monthly basis, and a recipient who is selling the 

benefits on their EBT card and then requesting a replacement card would 

generally have only one opportunity per month to do so. If a SNAP 

recipient is requesting a replacement card because they have just sold 

their EBT card and its associated SNAP benefits, it is unlikely that there 

would be more benefits to sell until the next benefit period. As a result, 

Targeted Analysis of 

Excessive Replacement 

Cards Found Potential 

Recipient Trafficking
Page 19 GAO-14-641 Supplemental Nutrition Assistance Program

additional replacement card requests in the same benefit period may not 

indicate increased risk of trafficking. The current FNS regulation would 

include households for review that received at least four replacement 

cards at any time in the previous year, including households receiving 

four cards in the same monthly benefit period. Alternatively, the number 

of benefit periods with replacement cards may be a better indicator of 

trafficking risk than simply the number of requested replacement cards.

By taking into account the benefit period of replacement card requests, 

we significantly decreased the number of households in the three 

selected states that may warrant further review of potential trafficking 

compared to all households requesting four or more replacement cards at 

any time during fiscal year 2012. For example, as shown in table 3, while 

there were 8,190 recipient households in Michigan that received four or 

more replacement cards in fiscal year 2012, our approach identified 4,935 

households that received replacement cards in four or more benefit 

periods.

Table 3: SNAP Households Receiving Replacement Cards in Fiscal Year 2012

Number of households 

receiving

State

Total SNAP 

householdsa 4+ Cards

Cards in 4+ 

monthly benefit 

periods

Percent decrease in 

households using 

benefit periods

Michigan 924,643 8,190 4,935 39.74%

Massachusetts 479,830 6,380 4,786 24.98%

Nebraska 77,066 697 549 21.23%

Total 1,481,539 15,267 10,270 32.73%

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

a

Average monthly participating households in fiscal year 2012.

For the 10,266 high replacement card households we reviewed, we found 

that 73 percent were conducting other suspicious activities based on 

criteria used by FNS and state SNAP officials. 25

 25 We reviewed transaction data for 10,266 households receiving replacement cards in 

four or more benefit periods; we did not receive transaction data for 4 of the 10,270 total 

households we identified in our replacement card analysis.

We reviewed fiscal year 

2012 transaction data, analyzing transactions from the same benefit 

period when the household received a replacement card for indications of 
Page 20 GAO-14-641 Supplemental Nutrition Assistance Program

trafficking. Specifically, we analyzed the data for trafficking indicators 

based on suspicious transaction types already used by FNS and state 

SNAP officials, such as unusually large-dollar transactions or even-dollar 

transactions. We tested the transaction data for six different suspicious 

transaction types, resulting in 22,866 transactions flagged as potential 

trafficking indicators. 26

Table 4: SNAP Households Receiving Excessive Replacement Cards and Making 

Transactions Potentially Indicative of Trafficking in Fiscal Year 2012

As shown in table 4, we identified 7,537 

households out of those we reviewed that made at least one suspicious 

transaction in the same benefit period that the household received a 

replacement card in fiscal year 2012. These 7,537 households made over 

$26 million in purchases with SNAP benefits during fiscal year 2012.

SNAP households with

State 4+ Replacement cards

Replacement 

cards in 4+ 

benefit periods

Suspicious 

transactions and 

cards in 4+ benefit 

periods

Michigan 8,190 4,935 3,183

Massachusetts 6,380 4,786 4,008

Nebraska 697 549 346

Total 15,267 10,270 7,537

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

Overall, 84 percent of high replacement card households in 

Massachusetts, 65 percent in Michigan, and 63 percent in Nebraska 

made at least one suspicious transaction indicating potential trafficking. 

For more detailed information on the number of flagged transactions 

made by selected households in each of the three states, see appendix II.

Furthermore, we found that the likelihood of suspicious transactions 

generally increased with the number of benefit periods in which 

replacement cards were requested. For example, while 60 percent of 

Michigan households with replacement cards in four benefit periods made 

at least one suspicious transaction, 86 percent of households with 

 26 A transaction may appear under more than one trafficking flag. For example, a 

transaction for $500.00 that occurred prior to a replacement card would be flagged as both 

a large-dollar transaction and an even-dollar transaction. There were 2,484 transactions in 

our analysis that appeared under more than one trafficking flag. 
Page 21 GAO-14-641 Supplemental Nutrition Assistance Program

replacement cards in seven benefit periods had made suspicious 

transactions, and 100 percent of households with replacement cards in 10 

or 11 benefit periods had. In Nebraska, 100 percent of households with 

replacement cards in eight or more benefit periods also made suspicious 

transactions, indicating potential trafficking.

While 84 percent of households had five or fewer trafficking flags, there 

were 262 households, or 3 percent, with 10 or more trafficking flags. The 

highest number of flags for a single household was 41. This household’s 

flagged transactions showed suspicious large, even-dollar transactions, 

often at the same small grocery store. Table 5 provides examples of 

suspicious transactions made by this household in one benefit period.

Table 5: Examples of Selected Suspicious Transactions Made by One Household Resulting in Trafficking Flags, Fiscal Year 

2012

Transaction type Store Date Time Amount

Time from previous 

transaction

Benefits Issued - Jan. 14, 2012 - - -

Purchase 1 Store 1 – Supermarket Jan. 14, 2012 5:17:22 PM $130.07 -

Purchase 2 Store 2 – Small Grocery Jan. 14, 2012 8:43:12 PM $3.85 3 hours 26 minutes

Purchase 3 Store 2 – Small Grocery Jan. 14, 2012 8:44:13 PM $240.00 61 seconds

Purchase 4 Store 2 – Small Grocery Jan. 14, 2012 8:44:39 PM $100.00 26 seconds

Purchase 5 Store 2 – Small Grocery Jan. 14, 2012 8:45:06 PM $140.00 27 seconds

Replacement card issued - Jan. 18, 2012 10:05:52 AM - -

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

By comparing the number of benefit periods with replacement cards and 

the total number of transaction trafficking flags, we were able to better 

identify those households that may be at higher risk of trafficking. For 

example, as shown in figure 2, while there were 4,935 SNAP households 

in Michigan that received excessive replacement cards, we identified just 

39 households that received excessive replacement cards and made 

transactions resulting in 10 or more trafficking flags. While state SNAP 

officials may not want to limit their investigations to such a small number 

of households, this type of analysis may help provide a starting point for 

identifying higher priority households for further review.
Page 22 GAO-14-641 Supplemental Nutrition Assistance Program

Figure 2: Targeting Potential Supplemental Nutrition Assistance Program (SNAP) Benefit Trafficking Using Replacement Card 

and Transaction Data to Identify Higher Risk Households in Michigan, Fiscal Year 2012

Note: FY=fiscal year.

Recognizing the challenges with the current approach, FNS officials 

stated that they are working on how to better link excessive replacement 

card requests to potential trafficking. To inform these efforts, FNS has 

also commissioned a study focused on detecting indications of potential 

trafficking by those requesting excessive replacement cards. FNS officials 

feel it is too early provide additional guidance or draw conclusions about 

the effectiveness of current efforts, but officials intend to provide 

additional guidance to states once they have sufficient data to inform a 

trafficking detection methodology that can be used nationwide.
Page 23 GAO-14-641 Supplemental Nutrition Assistance Program

FNS provided states with guidance on installing free web-based software 

tools for monitoring certain e-commerce and social media websites for 

online sales of SNAP benefits, but some state officials from selected 

states reported problems with these detection tools. The tools employ 

Really Simple Syndication (RSS) technology, which is designed to keep 

track of frequently-updated content from multiple websites and 

automatically notify users of postings that contain key words. FNS stated 

that these tools could automate the searches that states would normally 

have to perform manually on these websites, but acknowledged that the 

tool for social media websites may not work well, given that these 

websites do not organize their posts geographically.27 Of the 11 states we 

reviewed, officials from only one selected state (Tennessee) reported that 

the tool worked well for identifying SNAP recipients attempting to sell their 

SNAP benefits online. Officials in three states—Michigan, Utah, and 

Florida—reported that they monitored social media websites manually 

because of the technical challenges they experienced with using the 

tools, including installation and operation.28

FNS officials acknowledge that there are limitations to the current 

monitoring tools, and stated that they provided these tools at the request 

of states to help with monitoring efforts as states had reported that 

manual monitoring was cumbersome and difficult given limited resources. 

FNS officials report that they are currently conducting a study of the 

effectiveness of the guidance to states and intend to make 

recommendations for improvements based on the results of the study. In 

addition to the guidance provided to states, FNS officials reported that 

they have contacted popular e-commerce and social media websites in 

the past regarding potential SNAP trafficking online, and continue to work 

Additionally, officials in one 

state noted that the automated tools have placed an excessive demand 

on staff because they had to sift through the many false-positive leads 

that were generated. Officials from three of the states we reviewed 

reported that although they do not routinely monitor websites to detect 

fraud, they have found these websites to be useful sources of information 

about recipients they are already investigating.

 27 FNS is currently assessing the prevalence of SNAP trafficking occurring online and the 

effectiveness of these automated tools.

28 For more information on how the 11 selected states monitored online postings, see 

Figure 4.

Officials from Selected 

States Reported 

Difficulties Using Social 

Media and E-commerce 

Website Monitoring Tools
Page 24 GAO-14-641 Supplemental Nutrition Assistance Program

with the websites on detecting and removing postings advertising the sale 

of SNAP benefits online.

We tested the automated detection tools recommended by FNS on 

selected geographical locations covering our selected states and found 

them to be of limited effectiveness for states’ fraud detection efforts. A 

crucial element to an effective fraud prevention framework requires 

resources and tools to continually monitor and detect potential fraud. 29

Although the recommended automated tool for monitoring e-commerce 

websites was intended to potentially replace the need for states to 

perform manual searches on these websites, our testing found that 

manual searches returned more postings indicative of potential SNAP 

trafficking than the automated tool, and that most of the postings detected 

through manual searches were not detected by the automated tool. We 

tested the recommended tool on one popular e-commerce website over 

30 days, and monitored 19 geographical locations covering the 11 

selected states.

Our testing of the recommended automated tool for monitoring ecommerce websites found it did not detect most of the postings found 

through manual website searches. Furthermore, we found the automated 

tool for monitoring social media websites to be impractical for states’

fraud detection efforts.

30 We spent an average time of about 30 minutes per day 

(10 hours total) monitoring for postings indicative of potential SNAP 

trafficking.31

 29 GAO: INDIVIDUAL DISASTER ASSISTANCE PROGRAMS: Framework for Fraud 

Prevention, Detection, and Prosecution, 

Through our manual and automated searches, we detected a 

total of 1,185 postings containing one of our two key words of “EBT” or 

“food stamps.” Out of these 1,185 postings, we detected 28 postings 

indicative of potential SNAP trafficking. They advertised the potential sale 

of food stamp benefits in exchange for cash, services, or goods (see fig. 

GAO-06-954T (Washington, D.C.: July 12, 2006).

30 We limited our searches to two key terms (i.e. “EBT” and “food stamps”). The use of 

other terms could have yielded additional or fewer posting results through our automated 

and manual searches.

31 We note that it could take additional or less time for states to conduct online monitoring 

based on the number of websites, geographical locations, and key terms that they actually 

decide to use.

Effectiveness of Current 

Automated Monitoring 

Tools for Recipient Fraud 

Detection by States is 

Limited

E-commerce Monitoring
Page 25 GAO-14-641 Supplemental Nutrition Assistance Program

4). 32

 32 See Appendix III for a summary of all e-commerce postings we detected on one popular 

e-commerce website.

We refer to these types of postings as true positives, and to those 

postings that did not indicate trafficking as false positives. (See fig. 3.)
Page 26 GAO-14-641 Supplemental Nutrition Assistance Program

Figure 3: Analysis of Automated Tool Recommended for Monitoring E-commerce Websites

a

States issue SNAP benefits through the use of Electronic Benefits Transfer (EBT) cards.
Page 27 GAO-14-641 Supplemental Nutrition Assistance Program

Figure 4: Results of 30-day Monitoring of One Popular E-Commerce Website Using Automated and Manual Tools to Detect 

Posts Indicative of Food Stamp Trafficking and States' Experiences with Using Tools

Geographical locations GAO monitored

Total posts detected

through manual

searches only

Total posts detected

by recommended 

automated tool only

4

0

0

0

0

0

Houston and San Antonio (TX)

Salt Lake City and Provo (UT)

Wyoming (WY)

Posts returned indicative of trafficking that GAO detected

Total

Total posts

GAO reviewed

75

5

0

1,180 21

Jacksonville and Southern Florida (FL) 123 13 8 2 a

Boston and Worcester (MA) 245 2 2 0

Maine (ME) 25 0 0 0

Detroit metro and Grand Rapids (MI) 89 0 0 0

Charlotte and Raleigh (NC) 153 5 3 0 b

Lincoln and Omaha (NE) 39 0 0 0

Total posts

detected

Northern New Jersey (NJ) 367 4 4 0

Memphis and Nashville (TN) 59 0 0 0

4d

0

0

28 2

Online monitoring efforts by selected states, and GAO monitoring results of 

e-commerce website for 30 days for posts indicative of food stamp trafficking, 

using manual tools and automated tools the Food and Nutrition Service 

(FNS) recommended

GAO Monitoring Results Instructions: Rollover the locations GAO monitored

to view selected states’ online monitoring efforts

Interactive Graphic

Print Version: Printable version of Figure 4 is 

available in Appendix IV

a

Three posts identified through the automated tool were also identified through manual searches. Eight 

postings from Southern Florida advertised an undisclosed amount of food stamps in exchange for services and 

appear to be a series of updates to the same posting. We counted these as unique postings in accordance with 

our methodology because the e-commerce website we monitored listed the postings under different dates. b

Two posts identified through the automated tool were also identified through manual searches. Three postings 

from Charlotte, NC advertised an undisclosed amount of food stamps in exchange for services and had 

duplicative language. Per our methodology, these were counted as unique postings because their posting 

dates, times, or subject lines were distinct.

c

North Carolina's SNAP program is county-administered.

d

Two postings from Houston, TX advertised an undisclosed amount of food stamps in exchange for goods and 

had duplicative language. Per our methodology, these were counted as unique postings because their posting 

dates, times, or subject lines were distinct.

Source: GAO analysis of e-commerce posts identified and related state efforts. | GAO-14-641
Page 28 GAO-14-641 Supplemental Nutrition Assistance Program

Overall, 21 of the 28 true positive postings were only detected through 

manual monitoring and did not appear in our RSS feeds during the 30-

day testing period, potentially due to limitations associated with the RSS 

technology. Specifically, 10 of these 21 postings were listed on the ecommerce website under their respective geographical locations as 

“local” results. The remaining 11 postings were listed under their 

geographical locations, but as “nearby” results, and six of these postings 

were located in states other than the 11 states we monitored.

33

The 21 postings detected manually were enumerated under the selected 

geographic locations for 5 of 11 selected states: Massachusetts, Texas, 

According 

to the company that designed the automated tool, the RSS feeds do not 

currently transmit the “nearby” postings that would normally be found in 

manual searches. This may limit the number of potentially relevant 

postings that would be detected by the recommended tool and 

transmitted to SNAP officials for review. Additionally, the 10 manually 

detected postings listed as “local” results were not detected by the 

automated tool due to potential technical limitations associated with RSS 

technology. The FNS-recommended RSS reader we used on one popular 

e-commerce website was set to poll the website at most once per hour. 

According to the company that designed the recommended RSS reader, 

websites strictly enforce these frequency limits to help manage the 

demand on their servers. Setting such time intervals may prevent 

postings from appearing as RSS feeds in the user’s RSS reader because 

such postings may be removed by the time the polling actually occurs. In 

addition, sometimes a website limits the amount of content transmitted 

through RSS feeds or the RSS capability can become inoperable or 

delayed, potentially causing the RSS reader to not detect a posting. 

Given these technical limitations and the results of our testing, we found 

that manual searches performed directly on the website were more 

effective at detecting postings indicative of SNAP trafficking. Accordingly, 

relying on the recommended automated tool may increase the risk of 

states missing opportunities to detect and deter individuals who are using 

the popular e-commerce website to facilitate SNAP trafficking.

 33 A posting would be included under “local” results if the individual placing the posting 

online chose to advertise to that specific geographic location. However, searches of the 

website we reviewed also included postings from “nearby” areas to the specific 

geographic location selected by the individual placing the posting online.

RSS technology uses RSS readers that 

aggregate content from a website based on 

key-word queries, transmitting the content 

through RSS feeds. An RSS reader can be 

supported by an email system, like the RSS 

reader FNS recommended to the states. RSS 

readers automatically check for updated 

content and display results automatically as 

RSS feeds. For example, once the RSS 

reader finds a relevant posting, it will 

automatically send an RSS feed along with a 

link to the posting. The RSS feed is similar in 

appearance to a new email message. 

However, RSS readers use algorithms to 

automatically poll websites for updated 

postings pursuant to a specified maximum 

polling frequency set by the websites being 

polled.

Source: GAO summary of literature review.
Page 29 GAO-14-641 Supplemental Nutrition Assistance Program

North Carolina, Florida, and New Jersey.

34

Below are three illustrative examples of the e-commerce postings that 

were detected through our manual searches of one popular e-commerce 

website. All three examples were identified solely through our manual 

searches. The automated tool did not detect these posts during our 30-

day testing period.

During our 30-day testing 

period, we did not detect any true positive postings for the selected 

geographic locations enumerated under the remaining six selected states: 

Michigan, Nebraska, Utah, Tennessee, Maine, or Wyoming. Although the 

automated tool for e-commerce websites delivered a total of seven 

postings indicative of potential SNAP trafficking during our 30-day testing 

period, the manual searches detected five of these seven postings.

• On December 3, 2013, we detected an e-commerce posting 

advertising the potential sale of $400 in food stamp benefits in 

exchange for $240 in cash. This posting included the seller’s 

telephone number.

• On December 13, 2013, we detected an e-commerce posting 

advertising the potential sale of food stamp benefits in exchange for a 

place to live. This posting stated that the seller was “a single mother 

needing a room and...a place to live.” The posting contained the 

seller’s name and telephone number.

• On December 18, 2013, we detected an e-commerce posting 

potentially advertising the sale of artwork valued up to $3,000 in 

exchange for food stamps. The posting read “Art for food. I am a local 

artist...looking to trade for ebt...my work ranges from $10 to $3000, 

so I’m open to a lot of offers.” The posting provided the seller’s 

contact information, including a website address to the artist’s 

website. 

We also monitored one popular social media website for potential SNAP 

trafficking using the automated tool recommended by FNS, but found the 

tool to be inefficient for states’ fraud detection efforts. For example, during 

our testing we found that the tool for monitoring social media websites 

 34 Search results can include postings from nearby geographic locations that were outside 

the target states. Also, eight of the postings from Florida appear to be a series of updates 

to the same posting, and three of the postings from North Carolina contain duplicative 

language. However, we counted these as unique postings in accordance with our 

methodology because they were listed on the e-commerce website under different dates 

or subject lines.

Social Media Monitoring
Page 30 GAO-14-641 Supplemental Nutrition Assistance Program

had changed since FNS issued its guidance and no longer allowed a user 

to tailor the automated results to a specific social media website. Instead, 

we found that the automated tool would poll from more than a dozen 

websites, including social media and news websites, returning thousands 

of automated results not necessarily indicative of potential SNAP 

trafficking.

We also found that the automated tool could not be tailored to a specific 

geographical location, potentially limiting a state’s ability to effectively 

determine whether the postings detected are relevant to the state’s 

jurisdiction. FNS officials are aware of this limitation, but still believe that 

the automated tool can help states detect social media postings indicative 

of SNAP trafficking. Further, we were unable to compare the automated 

tool to corresponding manual searches because, at the time of our 

testing, the popular social media website we chose to monitor did not 

support manual searches based on key words. Because of these 

technological limitations and the high volume of irrelevant postings 

delivered by the tool, we limited our testing of the automated tool to 5 

days.

Over 5 days using the automated tool to monitor one social media 

website, we reviewed a total of 3,367 social media postings; each posting 

contained one of our two key words (“EBT” and “food stamps”).35 We 

spent an average of 17 minutes per day (1 hour and 25 minutes total) 

reviewing the automated search results. However, we only detected four 

true positive postings that were potentially indicative of SNAP trafficking, 

and one of those four did not include potential location information.36

 35 While we limited our searches to these key terms, the use of other terms could have 

yielded additional or fewer posting results through our automated searches.

Although we were unable to compare the automated tool to manual 

approaches, we still found the automated tool for social media websites to 

be an impractical fraud detection tool for states, given the inability to limit 

monitoring to geographic areas within a state’s jurisdiction and the 

inability to exclude websites, such as news websites, likely irrelevant to 

fraud detection activities.

36 See Appendix III for a summary of all 4 social media postings potentially soliciting food 

stamp benefits. The 4 posts that we detected are not generalizable to the potential SNAP 

trafficking activity that may be occurring within or across all states or on the Internet.
Page 31 GAO-14-641 Supplemental Nutrition Assistance Program

FNS has recently issued regulations and guidance and conducted a 

national review of state anti-fraud activities as part of its increased 

oversight. Despite these efforts, FNS does not have consistent and 

reliable data on state anti-fraud activities, primarily because its guidance 

to the states on what data to report is unclear.

Since 2011, FNS increased its anti-fraud oversight activities, which 

included new regulations and guidance and a nationwide review of state 

agencies. Partially in response to public concerns, the Secretary for Food, 

Nutrition, and Consumer Services asked states to renew their efforts to 

combat SNAP recipient fraud, and since then FNS promulgated new 

regulations and provided additional guidance to direct states in these 

efforts.37

Table 6: Key Food and Nutrition Service (FNS) Oversight Regulations, Guidance 

and Policies, Fiscal Years 2011 through 2014

(See table 6 for details on key regulations, guidance and policy 

developments since 2011.)

2011 FNS issued guidance that encouraged states to use replacement card data.

FNS encouraged states to use the Anti-Fraud Locator Using Electronic Benefits 

Transfer Retailer Transactions (ALERT)a data developed during retailer 

investigations to pursue individuals who trafficked with those retailers.

2012 FNS promulgated a final rule that implemented the requirement that states 

conduct death match verifications.b

FNS issued guidance that encouraged states to use electronic benefit transfer 

(EBT) management reports.c

FNS emphasized the importance of having states work with their contractors that 

manage EBT transaction data to develop effective methods for fraud detection.

 37 Prior work by the USDA OIG found that FNS has not maintained strong internal controls 

for overseeing state fraud detection units. Specifically, in a 2010 report, the USDA OIG 

found that FNS had not conducted periodic reviews of state fraud detection activity to 

verify its effectiveness, and that FNS had not found such reviews necessary because the 

agency believed collecting data on states’ activities through the FNS-366B to be sufficient 

for its monitoring purposes. However, the USDA OIG found that FNS did not have a 

system for ensuring the accuracy of state-reported data and cited data problems in the 

two states included in the study. For more information, see USDA OIG, State Fraud 

Detection Efforts for Supplemental Nutrition Assistance Program, 27703-02-Hy 

(Washington, D.C.: July 12, 2010).

FNS Increased Its 

Oversight of State 

Anti-Fraud Activities 

but Lacks Reliable 

Data on These Efforts

FNS Issued Regulations 

and Guidance and 

Conducted a Nationwide 

Review as a Part of Its 

Increased Oversight
Page 32 GAO-14-641 Supplemental Nutrition Assistance Program

FNS issued guidance for detecting postings indicative of fraud on e-commerce 

sites.

2013 FNS issued guidance for detecting postings indicative of fraud on social media 

websites.

FNS promulgated a final rule that included a new trafficking definition. This new 

definition included the following activities: the purchase with Supplemental 

Nutrition Assistance Program (SNAP) benefits of a product that has a container 

requiring a return deposit with the purpose of discarding the product and 

returning the container for cash and subsequently doing so; the purchase of a 

product with SNAP benefits with the intent of obtaining cash or other non-eligible 

items by reselling the product, and subsequently doing so; intentionally 

purchasing products originally purchased with SNAP benefits in exchange for 

cash or other non-eligible items; stealing SNAP benefits.d

FNS promulgated an interim final rule that required states to monitor replacement 

card data.e

2014 FNS affirmed the interim final rule that required states to monitor replacement 

card data as a final rule.f

Source: GAO Analysis of Federal Register notices, FNS guidance and policies. | GAO-14-641

a

The ALERT system receives daily transaction records from EBT processors and conducts analysis 

of patterns in the data, which indicate potential fraudulent activity by stores.

b

77 Fed. Reg. 48,045 (Aug. 13, 2012).

c

The EBT reports provide each state with information on its EBT system, retailer transaction data, and 

the amount of SNAP benefits issued.

d

78 Fed. Reg. 11,967 (Feb. 21, 2013).

e

78 Fed. Reg. 51,649 (Aug. 21, 2013).

f

79 Fed. Reg. 22,766 (Apr. 24, 2014).

In fiscal year 2013, for the first time, FNS examined states’ compliance 

with federal requirements governing SNAP anti-fraud activities through 

Recipient Integrity Reviews. (See fig. 5 for an overview of the review 

components.) These assessments were conducted by FNS regional office 

staff and included interviews with state officials, observations of state 

hearing proceedings, and case file reviews in all 50 states and the District 

of Columbia. As part of these reviews, federal officials also analyzed 

information from program reports, including those from eDRS, which are 

used to track disqualified SNAP recipients, and the Program and Budget 

Summary (Form FNS-366B), which are used to report anti-fraud activities 

for all the states. Following these reviews, FNS regional officials issued 

state reports that included findings and, where appropriate, required 

corrective actions. FNS officials told us that timeframes for taking 

corrective actions varied by the problem, but they generally allow states a 

year to address them. FNS regional officials also acknowledged states’

noteworthy initiatives or best practices in the state reports – such as 

Michigan’s case management system which will improve the state’s ability 

to track the status and outcomes of investigations, Washington’s 
Page 33 GAO-14-641 Supplemental Nutrition Assistance Program

standardized training for investigators, and Indiana’s out-of-state usage 

report aimed at identifying potential trafficking by listing households that 

made 100 percent of their EBT transactions in another state for three 

months. FNS officials also reported that they provide their regional staff 

the opportunity to discuss such best practices during monthly 

teleconferences. Additionally, FNS officials present information on best 

practices to states during national conferences. FNS began conducting 

fiscal year 2014 Recipient Integrity Reviews in November 2013 and 

intends to complete them in September 2014.

Figure 5: FNS Recipient Integrity Review Components

In addition to its oversight efforts, FNS has 10 studies under way that are 

aimed at improving federal and state efforts to address potential recipient 

fraud. These studies represent a significant increase in its investment to 

learn more about recipient fraud; specifically, FNS designated about $3 

million38

 38 This dollar amount includes funding for studying some retailer anti-fraud efforts as well. 

Given the structure of the contracts for these studies, FNS could not provide a separate 

amount for only recipient fraud.

for this work in fiscal years 2013 and 2014, compared to none in 

prior years. Among other topics, these studies are to explore strategies 

for improving fraud detection. For example, the study titled Social Media 

Fraud Discovery is intended to assess the effectiveness of FNS’s current 

fraud detection approach and make recommendations for improvements. 

There is also a series of work, known as the SNAP Recipient & Retailer 

Fraud Data Mining Studies, aimed at improving FNS and the states’
Page 34 GAO-14-641 Supplemental Nutrition Assistance Program

ability to more effectively anticipate, discover and address fraudulent 

activity using predictive modeling. FNS expects to receive the results of 

these studies by September 2014. (Additional information on the 10 

studies is provided in App. V.)

Although states are required to regularly submit information on their antifraud activities to FNS, we found that these data are not reliable for 

ensuring program integrity and assessing states’ performance. 

Specifically, our review found that over half of the 2013 Recipient Integrity 

Review reports mentioned problems with the data states entered into 

eDRS, thereby affecting the information state officials used to ensure 

program integrity. Federal officials found that 30 states did not enter data 

within the federally-required timeframes, a problem that cut across each 

of the oversight regions.39 Federal officials also found that 15 states did 

not enter disqualification information for some cases at all. For 2 of these 

states, federal officials found that over 30 percent of the disqualifications 

mentioned in other federal reports were missing from their eDRS data. 

Furthermore, federal officials found that 10 states had entered data into 

the system inaccurately. Given the concerns with data quality, even 

though state officials are required to check eDRS to gather information on 

whether a program applicant has been disqualified in another state before 

issuing benefits, they are not allowed to deny an application based solely 

on the system’s data. Federal regulations require that states gather 

additional verifying information about a disqualification before denying a 

claim based solely on information from eDRS.40

FNS regional officials told us that state’s eDRS data problems stemmed 

from a variety of factors, including challenges with receiving timely 

information about administrative hearing and court decisions and 

transferring data to the system. To help address concerns with eDRS 

data quality, FNS officials are currently offering tools, guidance, and 

training to state and regional officials. Furthermore, states with related 

findings from the Recipient Integrity Reviews are expected to take 

corrective action, including improving communications with ADH and 

 39According to federal regulations, states must report disqualifications to FNS no later 

than 30 days after the disqualification takes effect. 7 C.F.R. § 273.16(i).

40 Poor eDRS data would also affect states’ ability to be aware of and impose penalties for 

repeat program violators.

FNS Lacks Reliable Data 

on State Anti-Fraud 

Activities
Page 35 GAO-14-641 Supplemental Nutrition Assistance Program

court officials to receive more timely information and enhance their 

procedures for validating data entered into the system.

Through our review of the 2013 Recipient Integrity Review reports, we 

also found that FNS has a nationwide problem with receiving inaccurate 

data on state anti-fraud activities through the Program and Budget 

Summary Statement (Form FNS-366B),41 thereby potentially limiting its 

ability to provide oversight. We found that FNS regional officials could not 

reconcile the FNS-366B data reported with supporting documentation for 

24 states, primarily due to data entry errors. Furthermore, some federal 

and state officials we interviewed recognized that there is not a consistent 

understanding of what should be reported on FNS-366B because the 

guidance from FNS is unclear. For example, on the form, FNS instructs 

states to report investigations for any case in which there is suspicion of 

an intentional program violation before and after eligibility determination. 

According to state and federal officials we interviewed, this information 

does not clearly establish a definition for what action constitutes an 

investigation and should then be reported on this form. Also, officials in 

three of the seven regional offices were not aware of FNS-sponsored 

training on what should be reported on this form.42

After reviewing states’ reports, we found examples of inconsistencies in 

what states reported as investigations on the FNS-366B. Specifically, in 

fiscal year 2009, one state had about 40,000 recipient households, but 

reported about 50,000 investigations. During the same year, another state 

that provided benefits to a significantly larger population (about 1 million 

recipient households) reported about 43,000 investigations. Officials from 

the state that serves a smaller population explained that they included 

activities such as manually reviewing paper files provided by the state’s 

However, officials from 

the remaining four offices mentioned that FNS provided them training 

such as webinars and teleconferences on this form. As a result, various 

types of state efforts can be counted in the total number of investigations.

 41 As mentioned earlier, states are required to report their fraud-related activity to FNS on 

their annual Program and Budget Summary Statements. This report, provided through the 

form FNS-366B, is to include the number of investigations and disqualifications, and the 

dollar amount of their fraud claims.

42 According to federal internal controls, it is important that sufficient guidance and training 

is provided to ensure accuracy and reduce misunderstandings. For more information see, 

GAO: Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999) and OMB Circular A-123 Revised.
Page 36 GAO-14-641 Supplemental Nutrition Assistance Program

Department of Labor for each SNAP recipient with reported wages in the 

state; therefore, even if fraud was not suspected, this review was counted 

as an investigation. Officials from the state that serves a larger population 

said that they counted the number of times a potential fraud case was 

actively reviewed by investigators, including interviews with witnesses 

and researching of related client information. Given these differences, 

state officials said that FNS and states are not able to compare program 

integrity performance, because each state is not counting the same 

activities. In addition, by fiscal year 2012, the new head official in the 

state that serves a smaller population decided to use an automated 

system to review the wage data. Therefore, the query results identified 

cases indicative of a benefit overpayment, either from potential fraud or 

unintentional errors, were counted among the cases that needed to be 

investigated. As a result, for fiscal 2012, the state that serves a smaller 

population only reported conducting about 8,000 investigations, making 

this count of investigations not comparable to others for that state over 

time. Furthermore, these data inconsistencies could limit in FNS’s ability 

to identify more effective and efficient practices for state anti-fraud efforts.

For example, the lack of consistent data on investigations does not allow 

for studying the matters, such as the cost-benefit of investigations versus 

fraud claims established and/or collected across states, which could be of 

interest to FNS and states given states’ concerns with managing 

investigative resources.

Given the ongoing fiscal pressures that face our nation, the 

unprecedented increase in SNAP participation and spending in recent 

years has focused attention on the importance of ensuring that these 

publicly-funded benefits are used appropriately, and that both the federal 

government and state agencies have strong controls for detecting and 

addressing fraud. Although investigations can ultimately deter fraud and 

save agency resources, states we reviewed have faced the challenge of 

limited staff to manage a growing program and raised questions about 

whether federal incentive structures could be designed to better support 

their work. For example, even though GAO has found preventative efforts 

to be the most efficient and effective means to address fraud and may 

stop ineligible people from receiving benefits that may not be fully 

recovered, state officials said the current fraud-related incentive is 

focused on collecting overpayments. While federal officials would need to 

be mindful of the costs and benefits that any changes to the incentive 

structure would have for the overall program, absent additional incentives, 

states may not be taking advantage of opportunities to aggressively 

pursue recipient fraud.

Conclusions
Page 37 GAO-14-641 Supplemental Nutrition Assistance Program

These investigative challenges have made efficient anti-fraud activities all 

the more critical. Although some states have questioned the efficacy of 

tools FNS requires or recommends for detecting SNAP benefit trafficking, 

some additions and refinements to the guidance for these tools could 

make them more effective. For example, a more targeted approach to 

reviewing requests for replacement benefit cards could substantially 

reduce the administrative burden by identifying recipients who are more 

likely to be misusing their benefits throughout the year. Furthermore, 

although FNS has tried to improve efficiency with monitoring online 

postings, the lack of relevant leads using the recommended tools cause 

others to question whether this monitoring could be done in a better way.

Meanwhile, FNS is working to learn more about states’ activities and 

better support anti-fraud work. For example, FNS has commissioned 10 

studies intended to help the agency gain knowledge on how states can 

better detect potential recipient fraud. However, absent additional actions 

from FNS, such as guidance and training to the states on how and what 

data to report on their fraud-related activities, these data are not likely to 

be as useful as they should. Specifically, without performance data that 

are consistent across states, FNS will not be able to determine whether 

certain state anti-fraud efforts may be more efficient and effective than 

others. FNS will need accurate and comprehensive information at the 

state level if it is to move forward in building a stronger national 

infrastructure for program integrity.

The Secretary of Agriculture should direct the Administrator of FNS to 

take the following four actions:

• Explore ways that federal financial incentives can better support costeffective state anti-fraud activities;

• Establish additional guidance to help states analyze SNAP transaction 

data to better identify SNAP recipient households receiving 

replacement cards that are potentially engaging in trafficking, and 

assess whether the use of replacement card benefit periods may 

better focus this analysis on high-risk households potentially engaged 

in trafficking;

• Reassess the effectiveness of the current guidance and tools 

recommended to states for monitoring e-commerce and social media 

websites, and use this information to enhance the effectiveness of the 

current guidance and tools; and

• Take steps, such as guidance and training, to enhance the 

consistency of what states report on their anti-fraud activities.

Recommendations for 

Executive Action
Page 38 GAO-14-641 Supplemental Nutrition Assistance Program

We requested comments on a draft of this product from USDA. On July 

28, 2014, the Director of the SNAP Program Accountability and 

Administration Division provided us with the following oral comments.

FNS agreed with our recommendations and reported that efforts were 

underway to address each of them. Specifically, FNS reported that, 

although the agency cannot change the state retention rate for 

overpayments without a change to federal laws, it plans to issue grants in 

this fiscal year to support state process improvements for detecting, 

investigating and prosecuting recipients engaged in trafficking.

Furthermore, in the next fiscal year, FNS reported that it will issue grants 

to support states in building information technology to strengthen recipient 

integrity efforts, as authorized by the Agricultural Act of 2014. FNS also 

reported that its commissioned studies will help inform its efforts to assist 

states in developing better recipient fraud detection tools, including 

potentially issuing new related guidance. As of May 2014, the agency had 

already begun to receive study results. Lastly, in May 2014, FNS also 

formed a working group, consisting of program integrity staff from each of 

the regional offices, to revamp the Form FNS-366B. Among other things, 

FNS reported that this group is tasked with exploring ways to clearly 

define the data elements on this form and adding elements that will help 

FNS glean better information on recipient trafficking as well as the value 

and impact of state anti-fraud efforts. FNS also provided technical 

comments, which were incorporated into the report as appropriate.

We are sending copies of this report to relevant congressional 

committees, the Secretary of Agriculture, the FNS Administrator and other 

relevant parties. This report will also be available at no charge on the 

GAO website at http://www.gao.gov .

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

us at (202) 512-7215 or brownke@gao.gov, or (202) 512-6722 or 

bagdoyans@gao.gov . Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Agency Comments 

and Our Evaluation
Page 39 GAO-14-641 Supplemental Nutrition Assistance Program

GAO staff who made key contributions to this report are listed in appendix 

VI.

Sincerely yours,

Kay E. Brown

Director

Education, Workforce

 and Income Security Issues

Seto J. Bagdoyan

Acting Director

Forensic Audits and Investigative Service
Appendix I: Objectives, Scope and 

Methodology

Page 40 GAO-14-641 Supplemental Nutrition Assistance Program

The objectives of this report were to review the following: (1) how 

selected state agencies combat SNAP recipient fraud; (2) the 

effectiveness of certain fraud detection tools recommended to states, 

including benefit card replacement data and e-commerce and social 

media website monitoring; and (3) FNS’s oversight of state anti-fraud 

efforts. To address these objectives, we focused on federal and state 

SNAP recipient anti-fraud work for fiscal years 2009 to 2014, a period 

after the program received additional funding through the American 

Recovery and Reinvestment Act of 2009 (Recovery Act).1

We conducted this performance audit from April 2013 through September 

2014 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 

We reviewed 

relevant federal laws, regulations, program guidance, and reports, and we 

interviewed FNS officials in headquarters and all seven regional offices to 

address all three objectives. Specifically, to determine how selected state 

agencies are pursuing SNAP recipient fraud, we reviewed 11 states, 

where we interviewed knowledgeable state and local officials about their 

recipient anti-fraud work and obtained related documentation. (See below 

for more information on the criteria we used to select states.) We also 

analyzed fiscal year 2012 replacement card and transaction data for 

households in three of the selected states to assess the extent to which 

certain analyses of replacement cards could better uncover patterns of 

potential fraud. (See below for more information about these tests and 

analyses.) Further, we tested automated tools and guidance that FNS 

recommended to states for monitoring popular e-commerce and social 

media websites for postings indicative of SNAP trafficking. Our test 

involved determining the extent to which our 11 selected states can use 

these tools for their fraud detection efforts. Lastly, to determine FNS’s 

oversight of state anti-fraud efforts, we analyzed documents and reports 

relevant to FNS’s program oversight, including their fiscal year 2013

assessments of state anti-fraud work—known as Recipient Integrity 

Review reports—for all 50 states and the District of Columbia. All the data 

included in this report were assessed and determined to be sufficiently 

reliable for our purposes.

 1 Pub. L. No. 111-5, § 101, 123 Stat. 115, 120.

Appendix I: Objectives, Scope and 

Methodology
Appendix I: Objectives, Scope and 

Methodology

Page 41 GAO-14-641 Supplemental Nutrition Assistance Program

that the evidence we obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

To determine how selected state agencies are pursuing SNAP recipient 

fraud, we selected 11 states for our review—Florida, Maine, 

Massachusetts, Michigan, Nebraska, New Jersey, North Carolina, Utah, 

Tennessee, Texas, and Wyoming—based on geographic dispersion, 

SNAP payment error rates, percent of the total number of SNAP 

households nationwide, and the percent of recipients they reported as 

disqualified from the program due to non-compliance. For three of these 

criteria—the percent of the total number of households, the percent of the 

total number of disqualifications, and the payment error rates- we 

assigned the states to high, medium, and low categories under each set 

of data based on natural breaks in the data when the states were ranked 

from the lowest to the highest percent. As a result, states were 

designated based on data ranges shown in table 7.

Table 7: Data Ranges for Percentages 

Percentage Low Medium High

Percent of the total SNAP 

households

less than .5% .5 to less than 3% 3% and higher

Percent of the total number 

of disqualifications

less than .5% .5 to less than 2.5% 2.5% and higher

Payment error rates less than 3.82% 3.82 to less than 5% 5% and higher

Source: GAO of analysis of FNS data. | GAO-14-641

We selected the states to review for variety within our criteria. Table 8

provides information on how the selected states align with our criteria.

State Selection 

Criteria
Appendix I: Objectives, Scope and 

Methodology

Page 42 GAO-14-641 Supplemental Nutrition Assistance Program

Table 8: State Selection Criteria 

State

Geographic 

region

Fiscal year 2011 SNAP 

payment error rates 

(in percent)a

Percent of SNAP 

households nationwide 

in fiscal year 2012b

Percent of recipients 

disqualified in 

fiscal year 2012c

Wyoming West 9.63% 0.07% 0.07%

Utah West 4.19% 0.51% 1.13%

Nebraska Midwest 4.5% 0.35% 0.19%

Michigan Midwest 3.12% 4.14% 5.28%

Maine Northeast 3.28% 0.59% 0.12%

Massachusetts Northeast 4.40% 2.15% 1.25%

New Jersey Northeast 4.33% 1.82% 2.05%

Tennessee South 5.46% 2.87% 3.29%

North Carolina South 2.65% 3.52% 3.98%

Florida South 0.87% 8.18% 11.59%

Texas South 3.48% 7.46% 12.98%

Source: GAO analysis of FNS and the United States Census Bureau data. | GAO-14-641

Note: The low range of percentages is indicated in blue, the medium is green, and the high is yellow.

a

For the payment error rates, ranges were: less than 3.82%=low, 3.82 to less than 5%=medium, and 

5% and higher=high. 

b

For the percent of the total SNAP households, ranges were: less than .5%=low, .5 to less than 

3%=medium, and 3% and higher=high.

c

For the percent of the total number of disqualifications, ranges were: less than .5%=low, .5 to less 

than 2.5%=medium, and 2.5% and higher=high.

We interviewed officials who oversee state activities in state fraud units in 

each of the 11 states. In some states, we also interviewed auditors and 

prosecutors who had knowledge of state activities. During each interview, 

we collected information on state policies and procedures for responding 

to and investigating fraud claims. We also gathered and reviewed 

information on how state authorities manage their investigations. We also 

discussed state anti-fraud efforts and common recipient fraud schemes 

that have been occurring in recent years. We conducted site visits in 

Michigan, North Carolina, and Florida and interviewed officials in the 

remaning eight states by telephone.

The information we gathered for our report represents the conditions 

present at the time of the review. We cannot comment on any changes 

that may have occurred after our fieldwork was completed. Although the 

11 states we reviewed administered SNAP for about one-third of the 

program’s recipient households, the information we report from these 

states is not generalizable.
Appendix I: Objectives, Scope and 

Methodology

Page 43 GAO-14-641 Supplemental Nutrition Assistance Program

To assess the effectiveness of replacement card data as a state fraud 

detection tool, we analyzed replacement card data for SNAP households 

in 3 of the 11 selected states—Michigan, Massachusetts, and Nebraska. 

We selected these states to include high, medium, and low percentage of 

the total number of SNAP households nationwide. We obtained 

replacement card data from the appropriate state agency overseeing 

SNAP in the three selected states, and analyzed fiscal year 2012 data to 

determine the number of households receiving four or more replacement 

cards in that year. We also analyzed the data to identify households 

receiving replacement cards in four or more monthly benefit periods, the 

approach we took to identifying households with excessive replacement 

cards. We then obtained fiscal year 2012 transaction data from FNS for 

those households that received excessive replacement cards. We 

analyzed the transaction data for suspicious transactions indicating 

potential trafficking that occurred during the same benefit period when a 

household received a replacement card. We tested the transaction data 

for six different suspicious transaction types that were reported to us as 

commonly used by FNS and state SNAP officials to identify potential 

trafficking. At the request of SNAP officials to maintain confidentiality over 

their fraud detection methods, we did not include descriptions of all six 

transaction tests in the report. We assessed the reliability of replacement 

card and transaction data used in analyses through review of related 

literature, interviews with knowledgeable officials, and electronic testing of 

the data, and found them to be sufficiently reliable for our purposes.

We installed and used the automated tools recommended by FNS 

pursuant to the guidance FNS released to the states for monitoring 

popular e-commerce and social media websites for postings indicative of 

SNAP trafficking. We tested the automated tools and guidance to 

determine the extent to which our 11 selected states can use these tools 

for their fraud detection efforts. We also used GAO’s Fraud Prevention

Framework2

Specifically, from November 22, 2013 to December 23, 2013, we spent 

30 days testing the automated tool for monitoring e-commerce websites 

on one popular e-commerce website, comparing our automated search 

to assess the automated tools and guidance.

 2 GAO, INDIVIDUAL DISASTER ASSISTANCE PROGRAMS: Framework for Fraud 

Prevention, Detection, and Prosecution, GAO-06-954T (Washington, D.C.: July 12, 2006).

Targeted Analysis of 

Excessive 

Replacement Card 

Data

Assessment of Tools 

Recommended by 

FNS for Monitoring 

Online SNAP 

Trafficking
Appendix I: Objectives, Scope and 

Methodology

Page 44 GAO-14-641 Supplemental Nutrition Assistance Program

results against our manual search results from the same e-commerce 

website. Our automated and manual search queries were set to detect 

postings containing one of the key words “EBT” or “food stamps.” Using 

both search approaches simultaneously, we monitored 19 selected 

geographic locations covering 11 selected states, and spent an average 

time of about 30 minutes a day monitoring for e-commerce postings 

indicative of potential SNAP trafficking. Then we compared our 

automated results with our manual results to determine the extent to 

which they were the same. We selected the 19 geographic locations to 

monitor (see table 9, below) to include the two highest population cities in 

each of the 11 states. For two states—Maine and Wyoming—the ecommerce website only allowed us to monitor postings statewide.

Table 9: Geographic Locations Monitored in 11 Selected States

11 selected states Geographic Areas Monitored 

Nebraska Lincoln/Omaha 

Tennessee Memphis/Nashville 

Texas Houston/San Antonio 

Utah Salt Lake City/Provo 

North Carolina Raleigh/Charlotte 

Massachusetts Boston/Worcester 

Michigan Detroit/Grand Rapids 

Florida Jacksonville/Southern Florida 

Maine Maine 

Wyoming Wyoming 

New Jersey Northern New Jersey 

Source: GAO analysis of United States Census Bureau data and e-commerce website geographic areas. | GAO-14-641

Additionally, from January 7, 2014 to January 13, 2014, we spent 5 days 

testing the automated tool and guidance that FNS recommended to 

states for monitoring social media websites on a popular social media 

using the same key words (“food stamps” and “EBT”). We spent an 

average time of about 17 minutes a day monitoring for social media 

postings indicative of potential SNAP trafficking. We were unable to 

compare the automated tool for social media websites to corresponding 

manual searches because, at the time of our testing, the popular social 

media website did not offer a capability to perform manual searches 

based key words, such as “EBT” and “food stamps.”
Appendix II: Trafficking Flags in SNAP 

Households Receiving Excessive Replacement 

Cards

Page 45 GAO-14-641 Supplemental Nutrition Assistance Program

As discussed above, we analyzed transaction data for households 

enrolled in the Supplemental Nutrition Assistance Program (SNAP) who 

received excessive replacement cards1

Table 10: Number of Trafficking Flags Associated with Fiscal Year 2012 

Transactions Made by Selected High Replacement Card Households in Three States 

in three selected states—

Michigan, Massachusetts and Nebraska—in fiscal year 2012. We tested 

the transaction data for six different suspicious transaction types, 

potentially indicative of trafficking. Tables 10 through 13, below, provide 

detailed information on the findings of these tests.

State Flag 1 Flag 2 Flag 3 Flag 4 Flag 5 Flag 6

Michigan 1,567 347 2,077 2,560 51 2,426

Massachusetts 2,397 1,530 3,007 3,002 153 5,261

Nebraska 209 37 269 177 6 274

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

Table 11: Number of Michigan High Replacement Card Households Categorized by Count of Trafficking Flags and 

Replacement Card Benefit Periods , Fiscal Year 2012

Total Trafficking Flags

Number of benefit periods with 

replacement cards 1-3 4-6 7-9 10-19 20+ Total 

% of Households with 1+ 

Trafficking Flag

4 1532 391 68 14 0 2005 60%

5 499 167 31 7 0 704 70%

6 183 68 28 6 2 287 79%

7 67 38 10 5 0 120 86%

8 24 10 9 4 0 47 90%

9 5 6 2 1 0 14 70%

10 3 0 1 0 0 4 100%

11 0 1 1 0 0 2 100%

Total 2313 681 150 37 2 3183

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

 1 For the purposes of our analysis, we defined excessive replacement cards as 

replacement cards in four or more monthly benefit periods.

Appendix II: Trafficking Flags in SNAP 

Households Receiving Excessive 

Replacement Cards
Appendix II: Trafficking Flags in SNAP 

Households Receiving Excessive Replacement 

Cards

Page 46 GAO-14-641 Supplemental Nutrition Assistance Program

Table 12: Number of Massachusetts High Replacement Card Households Categorized by Count of Trafficking Flags and 

Replacement Card Benefit Periods , Fiscal Year 2012

Total Trafficking Flags

Number of benefit periods 

with replacement cards 1-3 4-6 7-9 10-19 20+ Total 

% of Households with 1+ 

trafficking flags

4 1392 544 128 36 0 2100 78%

5 604 304 100 66 2 1076 89%

6 197 139 90 38 4 468 93%

7 86 71 38 32 2 229 95%

8 22 27 20 18 0 87 95%

9 5 13 6 8 1 33 97%

10 3 3 3 4 0 13 100%

11 0 0 0 2 0 2 100%

Total 2309 1101 385 204 9 4008

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641

Table 13: Number of Nebraska High Replacement Card Households Categorized by Count of Trafficking Flags and 

Replacement Card Benefit Periods, Fiscal Year 2012

Total Trafficking Flags

Number of benefit periods 

with replacement cards 1-3 4-6 7-9 10-19 20+ Total 

% of Households with 1+ 

trafficking flags

4 162 28 9 1 0 200 58%

5 57 22 2 0 0 81 66%

6 20 12 5 2 0 39 81%

7 6 4 3 0 0 13 65%

8 2 4 1 0 0 7 100%

9 0 0 1 0 0 1 100%

10 2 1 1 0 0 4 100%

12 0 0 1 0 0 1 100%

Total 249 71 23 3 0 346

Source: GAO analysis of Supplemental Nutrition Assistance Program (SNAP) transaction data. | GAO-14-641
Appendix III: Total E-commerce and Social 

Media Postings Detected During Testing 

Periods45F

Page 47 GAO-14-641 Supplemental Nutrition Assistance Program

As discussed above, during our 30-day testing period of the automated 

tool for e-commerce websites, we detected a total of 28 postings from 

one popular e-commerce website that advertised the potential sale of 

food stamp benefits in exchange for cash, services, and goods. During 

our 5 days of testing the automated tool for social media websites, we 

detected a total of 4 postings potentially soliciting food stamp benefits. 

The tables below summarize all the e-commerce and social media 

postings that we detected through the automated tools and manual 

searches.

Table 14: E-commerce Postings Advertising Potential Sale of Food Stamp Benefits 

for Cash

Manual or auto 

detection Date posted Summary of posting

Geographic 

location monitored

Manual 12/3/2013 $400 EBT for $240 in cash Boston, MAa

Manual 12/3/2013 $200 EBT for $100 in cash Northern New 

Jerseya

Manual 12/9/2013 $350 EBT for $200 in cash Northern New 

Jerseya

Manual 11/22/2013 $150 in food stamps for $75 

in cash

San Antonio, TX

Manual 12/15/2013 $400 EBT for $280 in cash Northern New 

Jerseya

Manual 12/15/2013 $105 in food stamps for $50 

in cash

San Antonio, TX

Auto 12/7/2013 $190 EBT want $160 in 

cash

Jacksonville, FL

Auto 12/14/2013 $228 in food stamps for 

$100 in cash

Jacksonville, FL

Auto and Manual 12/2/2013 $65 EBT for $30 in cash Jacksonville, FL

Auto and Manual 12/13/2013 $180 EBT for $100 in cash Southern Florida 

Source: GAO analysis of e-commerce website postings. | GAO-14-641

a

Posting from nearby geographic location outside the target state.

 1 We referred postings indicative of SNAP trafficking to the appropriate state and federal 

officials for further investigation. 

Appendix III: Total E-commerce and Social 

Media Postings Detected During Testing 

Periods1
Appendix III: Total E-commerce and Social 

Media Postings Detected During Testing 

Periods45F

Page 48 GAO-14-641 Supplemental Nutrition Assistance Program

Table 15: E-commerce Postings Advertising Potential Sale of Food Stamp Benefits 

for Services

Manual or auto 

detection

Date posted

or updated Summary of posting

Geographic 

location 

monitored

Manual 11/23/2013 Undisclosed amount of food 

stamps, for place to livea Southern Florida 

Manual 11/26/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 11/29/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/5/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/8/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/11/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/13/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/17/2013 Undisclosed amount of food 

stamps for place to livea Southern Florida

Manual 12/18/2013 $500 proposal-some cash to 

contribute as well as food 

stamps for place to sleep or 

for a van b

Charlotte, NC

Manual 12/18/2013 $300 proposal-some cash to 

contribute as well as food 

stamps for place to sleep or 

for a van b

Charlotte, NC

Manual 12/19/2013 $1 proposal-some cash to 

contribute as well as food 

stamps for place to sleep or 

for a van b

Charlotte, NC

Auto and Manual 12/17/2013 10 days of cooking and 

cleaning services in exchange 

for food stamps.

Raleigh, NC

Source: GAO analysis of e-commerce website postings. | GAO-14-641

a

Eight postings from Southern Florida advertised an undisclosed amount of food stamps in exchange 

for services and appear to be a series of updates to the same posting. We counted these as unique 

postings in accordance with our methodology because the e-commerce website we monitored listed 

the postings under different dates.

b

Three postings from Charlotte, NC advertised an undisclosed amount of food stamps in exchange 

for services and had duplicative language. Per our methodology, these were counted as unique 

postings because their posting dates, times, or subject lines were distinct.
Appendix III: Total E-commerce and Social 

Media Postings Detected During Testing 

Periods45F

Page 49 GAO-14-641 Supplemental Nutrition Assistance Program

Table 16: E-commerce Postings Advertising Potential Sale of Food Stamp Benefits 

for Goods

Manual or auto 

detection

Date posted or 

updated Summary of posting

Geographic 

location monitored

Manual 11/29/2013 Phone for EBT benefits Northern New 

Jerseya

Manual 12/18/2013 Art for EBT: $10-$3000 Worcester, MAa

Manual 12/19/2013 Catalytic converters for 

food stamps

Houston, TX b

Manual 12/23/2013 Catalytic converters for 

food stamps

Houston, TX b

Auto and Manual 11/26/2013 Phone for EBT benefits Southern Florida

Auto and Manual 12/12/2013 Food stamps for beer Charlotte, NC

Source: GAO analysis of e-commerce website postings. | GAO-14-641

a

Posting from nearby geographic location outside the target state.

b

Two postings from Houston, TX advertised an undisclosed amount of food stamps in exchange for 

goods and had duplicative language. Per our methodology, these were counted as unique postings 

because their posting dates, times, or subject lines were distinct.

Table 17: Social Media Postings Soliciting Food Stamp Benefits

Manual or auto 

detection Date posted Summary of posting

Potential location 

of posting

Auto 1/6/2014 “Who got food stamps” Rochester, NY

Auto 1/6/2014 “Who got food stamps” Minneapolis, MN

Auto 1/7/2014 “Who got food stamps for 

sale”

Pennsylvania

Auto 1/7/2014 “Who selling food stamps” Undisclosed

Source: GAO analysis of social media website postings. | GAO-14-641
Appendix IV: Selected States’ Experiences 

Using FNS’s Recommended Automated Online 

Monitoring Tool and GAO Test Results

Page 50 GAO-14-641 Supplemental Nutrition Assistance Program

Posts returned indicative of trafficking that 

GAO detected

Geographic 

locations 

GAO 

monitored

Total posts 

GAO 

reviewed

Total posts 

detected 

Total posts 

detected 

through 

manual 

searches only 

Total posts 

detected by 

recommended 

automated tool 

only 

FNSrecommended 

automated tool 

Manual 

searches

State experiences with 

using automated and 

manual tools

Jacksonville 

and 

Southern 

Florida (FL)

123 13a 8 2  Automated tools difficult to 

use, provides unreliable 

data

As a result, monitoring 

websites only

Boston and 

Worcester 

(MA)

245 2 2 0  Automated tools difficult to 

use, provides unreliable 

data, not using for social 

media websites.

Automated tools not 

compatible with state’s 

operating system

Using automated tools for 

ecommerce websites, but 

looking for other tools to 

use for monitoring. 

Maine (ME) 25 0 0 0  Has not implemented 

automated tools yet

Manual monitoring 

websites only

Detroit 

metro and 

Grand 

Rapids (MI)

89 0 0 0  Automated tools difficult to 

use, provides unreliable 

data

As a result, manual 

monitoring websites only

Charlotte 

and Raleigh 

(NC)

153 5b 3 0 Some counties have not 

implemented automated 

tools yet

Ad hoc monitoring of 

websites by some 

countiesc

Lincoln and 

Omaha 

(NE)

39 0 0 0 Is not using automated or 

manual search methods

Northern 

New Jersey 

(NJ)

367 4 4 0  Has not implemented 

automated tools yet

Manual monitoring 

websites only

Appendix IV: Selected States’ Experiences 

Using FNS’s Recommended Automated 

Online Monitoring Tool and GAO Test Results
Appendix IV: Selected States’ Experiences 

Using FNS’s Recommended Automated Online 

Monitoring Tool and GAO Test Results

Page 51 GAO-14-641 Supplemental Nutrition Assistance Program

Posts returned indicative of trafficking that 

GAO detected

Geographic 

locations 

GAO 

monitored

Total posts 

GAO 

reviewed

Total posts 

detected 

Total posts 

detected 

through 

manual 

searches only 

Total posts 

detected by 

recommended 

automated tool 

only 

FNSrecommended 

automated tool 

Manual 

searches

State experiences with 

using automated and 

manual tools

Memphis 

and 

Nashville 

(TN)

59 0 0 0  Automated tools are 

labor-intensive to use

However, still find 

automated tools to work 

well with some success

Houston 

and San 

Antonio 

(TX)

75 4d 4 0 Is not using automated or 

manual search 

approaches

Salt Lake 

City and 

Provo (UT)

5 0 0 0  Automated tools not 

compatible with state’s 

operating system

As a result, manual 

monitoring websites only 

Wyoming 

(WY)

0 0 0 0  Has not implemented 

automated tools yet

Manual monitoring 

websites only

Total 1,180 28 21 2

Source: GAO analysis of e-commerce website postings and data from selected states. | GAO-14-641

a

Three posts identified through the automated tool were also identified through manual searches.

Eight postings from Southern Florida advertised an undisclosed amount of food stamps in exchange 

for services and appear to be a series of updates to the same posting. We counted these as unique 

postings in accordance with our methodology because the e-commerce website we monitored listed 

the postings under different dates.

b

Two posts identified through the automated tool were also identified through manual searches. Three 

postings from Charlotte, NC advertised an undisclosed amount of food stamps in exchange for 

services and had duplicative language. Per our methodology, these were counted as unique postings 

because their posting dates, times, or subject lines were distinct.

c

North Carolina’s SNAP program is county-administered.

d

Two postings from Houston, TX advertised an undisclosed amount of food stamps in exchange for 

goods and had duplicative language. Per our methodology, these were counted as unique postings 

because their posting dates, times, or subject lines were distinct.
Appendix V: List of Food and Nutrition 

Service-Commissioned Studies

Page 52 GAO-14-641 Supplemental Nutrition Assistance Program

1. Indirect Trafficking Fraud Discovery: A study to identify a process 

to effectively detect indirect trafficking schemes. An example of an 

indirect trafficking scheme occurs when a SNAP recipient sells his or 

her EBT card to a third party, at a discount for cash, and the third 

party uses the EBT card to purchase eligible food.

2. Social Media Fraud Discovery: An evaluation on FNS’s current 

fraud detection approach using social media in order to identify a 

more effective process.

3. Recipient Integrity Outcomes Metrics: An analysis to identify 

metrics that FNS can use to better monitor State performance and 

outcomes.

4. Multiple EBT Card Replacement: A study aimed at improving FNS’s 

approach to using card replacement data to identify fraud.

5. Household Link Analysis: An analysis to further assess the 

relationship between client and retailers regarding trafficking 

schemes.

6. Household Demographic Fraud Discovery: An assessment of 

recipient benefit data to further refine models used to detect fraud.

7. Household Time and Distance (Geospatial Analysis): An analysis 

of recipient benefit data that focuses on geographical information; for 

example, recipients using their cards in Virginia and South Carolina 

within an hour.

8. Identify Clients Shopping in Geographic Areas Outside of their 

Normal Patterns (Geospatial Analysis): An analysis to identify an 

automated process to assess retailer and recipient EBT data.

9. Strengthen FNS Recipient Referrals from Disqualified Stores: A 

review of the existing recipient referral process and fraud detection 

models to develop a model for FNS to deploy that more effectively 

identifies suspicious recipients to states for investigation.

10. SNAP Recipient & Retailer Fraud Data Mining Studies: A series of 

recipient and retailer based analyses using predictive activity such as 

fraud discovery to increase FNS and states ability to detect fraudulent 

activity.

Appendix V: List of Food and Nutrition 

Service-Commissioned Studies
Appendix VI: GAO Contacts and Staff 

Acknowledgment

Page 53 GAO-14-641 Supplemental Nutrition Assistance Program

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

Seto J. Bagdoyan, 202-512-6722, bagdoyans@gao.gov.

In addition to those mentioned above, the following staff members may 

significant contributions to this report: Kathryn Larin and Philip Reiff, 

Assistant Directors; Celina Davidson and Danielle Giese, Analysts-inCharge; LaToya King, Flavio Martinez, Erik Shive and Jill Yost. 

Additionally, James Bennett, Holly Dye, Linda Miller, Maria McMullen and 

Almeta Spencer provided technical support; Shana Wallace provided 

methodological guidance; and Alexander Galuten and James Murphy 

provided legal counsel.

Appendix VI: GAO Contacts and Staff 

Acknowledgment

GAO Contacts

Key Contributors
Related GAO Products

Page 54 GAO-14-641 Supplemental Nutrition Assistance Program

Standards for Internal Control in the Federal Government: 2013 Exposure 

Draft. GAO-13-830SP. Washington, D.C.: September 3, 2013.

Supplemental Nutrition Assistance Program: Payment Errors and 

Trafficking Have Declines, but Challenges Remain. GAO-10-956T. 

Washington, D.C.: July 28, 2010.

Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better 

Targeting Stores Likely to Traffic and Increasing Penalties. GAO-07-53. 

Washington, D.C.: October 13, 2006.

Individual Disaster Assistance Programs: Framework for Fraud, 

Prevention, Detection and Prosecution. GAO-06-954T. Washington, D.C.: 

July 12, 2006.

Hurricanes Katrina and Rita Disaster Relief: Improper and Potentially 

Fraudulent Individual Assistance Payments Estimated to be between 

$600 Million and $1.4 Billion. GAO-06-844T. Washington, D.C.: June 14, 

2006.

Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s 

Control Weaknesses Exposed the Government to Significant Fraud and 

Abuse. GAO-06-403T. Washington, D.C.: February 13, 2006.

Standards for Internal Control in the Federal Government. 

GAO/AIMD-00-21.3.1 Washington, D.C.: November 1999.

Related GAO Products

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