Nutrition Assistance Program Report Series 

The Office of Analysis, Nutrition and Evaluation 

Food Stamp Program Report No. FSP-03-TRAF 

The Extent of Trafficking in The Food 

Stamp Program: 

1999—2002 

United States Food and 

Department of Nutrition 

Agriculture Service 

July 2003
This page left blank for two-sided printing 
The Extent of Trafficking in The Food 

Stamp Program: 

1999—2002 

Author: 

Theodore F. Macaluso, Ph.D. 

This report is available on the Food and Nutrition Service web site: http://www.fns.usda.gov/oane

Suggested Citation:

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and Evaluation, The Extent of 

Trafficking in The Food Stamp Program: 1999—2002, FSP-03-TRAF, by Theodore F. Macaluso, Ph.D. 

United States Food and 

Department of Nutrition 

Agriculture Service 

July 2003

Food Stamp Program

Report No. FSP-03-TRAF
ii

Non-Discrimination Statement: 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, 

sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) 

Persons with disabilities who require alternative means for communication of program information 

(Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 

(voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil 

Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, S.W., Washington, DC 

20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an equal opportunity provider and 

employer. 
iii

Acknowledgments

The author wishes to express his appreciation to the many individuals who contributed to this report. 

Richard Mantovani, Ph.D, at ORC Macro International successfully compiled and merged the data 

summarized here, faithfully reproduced the original methodology, made thoughtful suggestions, and 

responded promptly to the author’s numerous requests for additional information and analyses. 

Steven Carlson, Director of the Family Programs Staff in the Office of Analysis, Nutrition and 

Evaluation (OANE), Food and Nutrition Service, provided guidance and commented thoughtfully on 

drafts of the text. Sharron Cristofar, also of OANE, managed the contractual support for the project, 

performed considerable legwork in tracking down data, and also commented thoughtfully on drafts. 

Finally, the staff of the Benefit Redemption Division of the Food Stamp Program provided many 

comments and corrections and helped to make this a comprehensive – and better – report. 
iv
v

TABLE OF CONTENTS 

Executive Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 

Findings 

 The Level of Trafficking in 1999—2002 . . . . . . . . . . . . . . . . . . . . . . . . . 5 

 Reasons for the Decline in the Level of Trafficking . . . . . . . . . . . . . . . . . 11 

 Trafficking and Store Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 

Conclusion and Implications for Program Integrity. . . . . . . . . . . . . . . . . . . . . . . . 19 

Technical Discussion 

 Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 

 Estimation Error . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 

Appendices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 
vi
vii

THE EXTENT OF TRAFFICKING IN THE FOOD STAMP PROGRAM: 

1999 – 2002 

EXECUTIVE SUMMARY

Food stamps are intended for food. When individuals sell their benefits for cash it violates the spirit 

and intent of the Food Stamp Program as well as the law. This practice, known as trafficking, diverts 

food stamp benefits away from their purpose. It reduces intended nutritional assistance and 

undermines public perceptions of the integrity and utility of the program. 

To combat trafficking, the Food and Nutrition Service conducts undercover investigations of 

authorized food stores. In addition, the agency has developed powerful new EBT-based administrative 

tools to identify and sanction traffickers. 

A crucial question is the extent to which trafficking exists. Over the last ten years, USDA developed a 

method to estimate the extent of food stamp trafficking and released two prevalence estimates, first for 

1993 and an update for calendar years 1996-1998. This report updates the two earlier analyses for the 

1999 – 2002 calendar year period. We have improved the estimate to take advantage of the new 

EBT-based tools. The findings are based on 14,642 undercover investigations of food retailers and 

1,537 EBT-based administrative case actions against retailers suspected of trafficking. 

KEY FINDINGS 

Program integrity has improved substantially. About $395 million per year was diverted from 

food stamp benefits by trafficking between 1999 and 2002. This is less than two-thirds of the $660 

million per year diverted between 1996 and 1998 and less than half of the $815 million diverted in 

1993. 

Trafficking now amounts to two-and-a-half cents of every benefit dollar issued, a 29 percent 

decline in the rate of trafficking between 1996 – 1998 and 1999 – 2002. 

The stores which redeem the majority of food stamp benefits continue to be stores with the 

lowest trafficking rates. Almost a quarter of the redemptions flowing through small groceries are 

trafficked. However, the impact is limited by the fact that small grocery stores account for less than 5 

percent of total food stamp redemptions. Supermarkets redeemed nearly 83 percent of all benefit 

dollars but few of those dollars are trafficked. 
This page left blank for two-sided printing 
1

The Extent of Trafficking in the Food Stamp Program: 

1999 – 2002

United States Department of Agriculture 

Food and Nutrition Service 

Office of Analysis, Nutrition and Evaluation 

July 2003 

INTRODUCTION 

Food stamps are intended for food. When individuals sell their benefits for cash it violates the 

spirit and intent of the Food Stamp Program as well as the law. This practice, known as 

trafficking, diverts food stamp benefits away from their purpose. It reduces intended nutritional 

assistance and undermines public perceptions of the integrity and utility of the program. A crucial 

question is the extent to which trafficking exists. 

Over the last ten years, USDA developed a method to estimate the extent of food stamp trafficking 

and released two prevalence estimates, first for 1993 and an update for calendar years 1996-1998.1 

This report updates the two earlier analyses with data from the 1999 – 2002 calendar year period. 

As in the past, we focus on authorized food retailers because all trafficking must eventually flow 

through a food retailer authorized to participate in the Food Stamp Program.2 Both paper and 

electronic food stamp benefits can be sold for cash at a discount on the street. However, 

authorized food retailers are the only ones who can redeem food benefits for cash from the 

government. Without access to an authorized store, the last person in the trafficking chain will lose 

 

1

 Theodore F. Macaluso, The Extent of Trafficking in the Food Stamp Program (Alexandria, VA: 

Food and Nutrition Service, USDA; 1995) and Theodore F. Macaluso, The Extent of Trafficking 

in the Food Stamp Program: An Update (Alexandria, VA: Food and Nutrition Service, USDA; 

2000). 

2

 While food retailers constitute the overwhelming majority of authorized redeemers of food 

stamp benefits, the Food Stamp Program has also authorized a few meal services to accept food 

stamp benefits. For simplicity, we refer to all authorized entities as retailers. 
2

money. Trafficking is more visible if several people are involved in the chain of buying and 

selling, but the dollars diverted from food assistance are the same regardless of the number of 

individuals involved. Therefore knowing the amount of trafficking among retailers tells us the 

maximum value of dollars diverted from food stamp benefits by trafficking for cash. 3 

As in the past, we calculate three basic measures of trafficking: 

• the amount of trafficking (i.e., the total sum of dollars trafficked, which depends partly upon 

the total sum of benefits issued and partly upon the next measure, the rate of trafficking); 

• the rate of trafficking (the proportion of total benefits issued which were trafficked); and 

• the store violation rate (the proportion of all authorized stores that engaged in trafficking). 

While all three measures are important for different purposes, the second measure – the rate of 

trafficking – is the one that provides an approximation of FNS’ relative success in combating 

trafficking because it is independent of total benefits issued. 

EBT-based Administrative Actions Against Trafficking 

Our approach to calculating the current estimate is consistent with past practice, with a significant 

improvement. With the growth of electronic benefit transfer (EBT), FNS has successfully 

developed a new EBT-based technique for fighting trafficking (referred to as “administrative 

cases”). Administrative cases do not involve an undercover investigation. These actions start 

with lists of stores that exceed thresholds on EBT transaction patterns that suggest the store may 

be engaging in trafficking. Staff then screen out stores that have an obvious explanation for their 

otherwise suspicious EBT transaction pattern. Stores that pass the various screens are sorted into 

those for which an investigation is warranted and those which can be handled administratively. 

The latter are sent a Charge Letter and given an opportunity to explain the observed pattern. 

Stores that fail to provide a satisfactory explanation are sanctioned for trafficking. 

Prior to 2001, the number of administrative cases per year was too small to have a significant effect 

on estimates of the extent of trafficking. Starting in 2001, however, administrative cases have 

increased substantially. While still small in total number, these EBT-based cases have 

progressively become an important source of findings of trafficking (Figure 1). 

 

3

 Trafficked food stamp benefits are not always redeemed for cash from the government. Owners 

of small authorized or unauthorized stores, restaurants, and the like can buy food stamp benefits for 

cash, pretend to be recipients and illegally use food stamp benefits to buy food at supermarkets for 

resale in their stores. We label this "evasion trafficking" (since it is a form of tax evasion) and 

discuss its impact on our estimate in the Technical Discussion section of this report. It is important 

to note, however, that under EBT this transfer of benefits outside a store is much more difficult and 

more rare than it was under coupon benefits. 
3

Figure 1 

Findings Of Trafficking -- Constant 

Number, Changing Source

0

100

200

300

400

500

600

700

800

98 99 00 01 02

Year

Number of Stores Found 

Trafficking

Investigations Administrative Cases

Source: Food and Nutrition Service, Benefit Redemption Division 

____________________ 

Therefore, unlike the prior reports, this report presents two estimates of trafficking. 

• In order to ensure consistent comparisons with the past, the first estimate uses precisely the 

same methodology and data sources as the two earlier reports. It is based on evidence from 

14,642 new undercover investigations of authorized food retailers. As in the past, the 

calculation of trafficking consists of investigations that find trafficking divided by all 

investigations. (This percent is weighted by the national distribution of stores and 

redemptions as described in the Technical Discussion section.). We refer to this estimate as 

the “original method.” 

• In the second estimate, the calculation of trafficking combines the outcomes of 1,537 EBTbased administrative case actions against retailers suspected of trafficking with the outcomes 

of the 14,642 investigations used in the first estimate. The calculation of trafficking consists 

of (a) investigations that find trafficking plus administrative case actions that find trafficking 

divided by (b) all investigations and all administrative case actions. Except for this one 

change, all statistical and weighting procedures are identical with the first estimate. We refer 

to this estimate as the “EBT method.” 
4

 

It is important to recognize the limitations and strengths of these estimates. Both start with 

detected trafficking. Both investigations and EBT-based administrative actions may 

underestimate the extent of trafficking because investigators and EBT-based administrative 

procedures are unable to detect all trafficking. This source of underestimation, however, is 

counterbalanced by the fact that authorized retailers are not selected randomly for either 

investigations or administrative action. Investigations significantly overestimate trafficking 

because investigators rarely visit stores they believe are honest. Likewise administrative actions 

are only started for stores with suspicious EBT transaction patterns. The Technical Discussion 

section presents all the sources of over- and underestimation inherent in our approach. However, 

the non-random selection of stores is the most significant and gives us confidence that both 

estimates err on the side of overestimating trafficking. 

 
5

FINDINGS 

THE LEVEL OF TRAFFICKING IN 1999 – 2002 

About $395 million per year was diverted from food benefits by trafficking between 1999 and 

2002 (Table 1). As in prior years, this estimate is more likely to overestimate the dollars diverted 

from food benefits by direct trafficking in 1999-2002 than to underestimate it. 

The amount of trafficking has decreased by more than half since 1993 (Figure 2). Trafficking 

declined 19 percent between 1993 and 1996 – 1998, from about $815 million to $660 million. 

Trafficking declined another 40 percent between 1996 - 1998 and 1999 - 2002, falling from $660 

million to under $395 million (EBT method). When we calculate trafficking exactly as we did in 

the past, trafficking has fallen 65 percent since 1993, to about $285 million (original method). 

Trafficking now amounts to about two-and-a-half cents of every benefit dollar issued 

(Figure 3). The trafficking rate is the single best measure of effectiveness in combating 

trafficking. It declined from just under 4 percent of benefits issued in 1993 to 3.5 percent in 1996 

– 1998 and to 2.5 percent of benefits issued in 1999 – 2002 (1.8 percent of benefits issued when 

calculated exactly as done in the past). 

The stores that redeem the majority of food stamp benefits continue to be stores with the 

lowest trafficking rates (Table 2). 

• Supermarkets redeemed nearly 83 percent of all benefit dollars but few of those dollars are 

trafficked. The trafficking rate in supermarkets is less than 1 percent. In comparison to 

supermarkets, trafficking rates among small stores are 5 to 20 times higher. 

• Small groceries continue to have a high trafficking rate. In each of the two previous estimates, 

about 1 out of every 6 food stamp dollars flowing through small groceries was trafficked. 

While the original methodology shows that this level is unchanged, the EBT method suggests 

that the level may actually be closer to 1 of every 4 food stamp dollars. The impact of the 

continued high rate of trafficking among small groceries is limited by the fact that less than 5 

percent of all food stamp redemptions occur in small groceries (Table 3). Redemptions in 

small groceries have declined 20 percent over time, falling from 5.4 percent in 1993 to 5.2 

percent in 1996 – 1998 and to 4.4 percent in 1999 – 2002. 

• There have been improvements in the trafficking rates among some categories of smaller 

stores: trafficking rates at specialty, gas/grocery, and “other” stores all fell. 

 
6

Table 1 – Dollar Amount of Trafficking 

1999 – 2002 

Type of Store 

1993 

Original 

Method 

(000) 

1996 – 1998 

Original 

Method 

(000)

Original 

Method 

(000)

EBT 

Method 

(000)

Supermarkets a $282,058 $279,163 $99,746 $117,180

Large Groceries b 46,632 35,255 16,073 21,981

Subtotal 328,690 314,418 115,819 139,161

Small Groceries c 177,809 154,109 111,747 159,114

Convenience d

 78,090 66,809 23,676 40,617

Specialty e

 117,004 55,782 16,608 22,904

Gas/Grocery f 27,528 21,784 6,193 10,315

Other Types g 82,605 43,892 13,377 20,684

Subtotal 483,036 342,376 171,601 253,634

All Stores $811,726 $656,794 $287,420 $392,795

 Note: The data have been annualized. 

a

 Any store identifying itself to FNS as a supermarket or grocery with gross sales over 

$2,000,000. 

b

 Any store identifying itself as a supermarket or grocery with gross sales between 

$500,000 and $2,000,000. c

 Any store identifying itself as a supermarket or grocery with gross sales under $500,000. 

d

 Any store identifying itself by this title, regardless of gross sales. 

e

 Any store identifying itself by this title, regardless of gross sales (these are almost always 

single product line stores such as meat markets, fish markets, dairy stores, etc.). 

f

 Any store identifying itself by this title, regardless of gross sales. 

g

 Any store identifying itself by a different title, regardless of gross sales (such as produce 

stands, general stores, grocery/bars, health/natural food stores, milk or bread routes). 

____________________ 
7

Figure 2 

0

300

600

900

Millions of $

1993 1996-1998 1999-2002

The Dollar Amount of Trafficking Declined

Original method EBT method

____________________ 

Figure 3 

0

1

2

3

4

Percent

1993 1996-1998 1999-2002

The Percent Of Benefits Issued That 

Were Trafficked Declined

Original method EBT method

____________________

29% decline 

40% decline 
8

Table 2 – Rate Of Food Stamp Trafficking By Type of Store 

1999 – 2002 

Type of Store 

1993 

Original 

Method 

1996 – 1998 

Original 

Method 

Original 

Method 

EBT 

Method 

Supermarkets 1.7 1.9 0.8% 0.9% 

Large Groceries 3.7 3.2 2.2 3.0 

Subtotal 1.9 2.0 0.8 1.0 

Small Groceries 15.7 15.8 16.3 23.3 

Convenience 9.6 10.8 6.5 11.2 

Specialty 14.2 8.1 3.5 4.8 

Gas/Grocery 10.4 9.7 4.5 7.4 

Other Types 12.4 9.4 4.3 6.7 

Subtotal 13.0 11.5 8.7 12.9 

All Stores 3.8 3.5 1.8 2.5 

Notes: The data have been annualized. 

 The trafficking rate is the percent of trafficked redemptions in investigated stores, 

weighted by the national distribution of redemptions. The rate figures tell us the 

percent of all benefits issued that were trafficked. Because the dollar value of 

trafficking is a function of both rate and total redemptions, trafficking rates in small 

groceries and convenience stores rose, even though their dollar value of trafficking 

(in Table 1) declined. 

____________________ 
9

 Table 3 - Distribution and Market Shares of Authorized Food Stamp Retailers. 

1996 – 1998 1999 – 2002 

 Percent of All Percent of All 

Type of Store Stores Redemptions Stores Redemptions 

 

Supermarkets 14.9% 78.3% 18.8% 82.7% 

Large Groceries 7.0 5.8 6.9 4.7 

 Subtotal 21.9 84.1 25.7 87.4 

Small Groceries 20.0 5.2 19.2 4.4 

Convenience 26.8 3.3 24.7 2.3 

Specialty 9.0 3.7 8.4 3.0 

Gas/Grocery 11.9 1.2 11.0 0.9 

Other Types 10.4 2.5 11.1 2.0 

 Subtotal 78.1 15.9 74.3 12.6 

All Stores 100.0 a 100.0 b 100.0 c 100.0 d

Notes: 

a Based on 237,824 unique food retailers redeeming at any point during the 1996-1998 

period (see Appendix I for breakdown by year). 

 b Based on a total of $56.16 billion over the three years (see Appendix I for breakdown). 

c Based on 200,480 unique food retailers redeeming at any point during the 1999-2002 

period (see Appendix I for breakdown). 

d Based on a total of $60.3 billion over the four years (see Appendix I for breakdown).

____________________
10

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11

REASONS FOR THE DECLINE IN THE LEVEL OF TRAFFICKING

The preceding findings demonstrate that the integrity of the Food Stamp Program has improved. 

Their implications for future action, however, depend upon the reasons why trafficking declined. 

We explore two factors: the overall size of the program and the proportion of redemptions 

flowing through large and small food retailers. 

Size of the Food Stamp Program 

Perhaps the most obvious potential explanation for the decline in the value of trafficking is the 

concurrent decline in the size of the Food Stamp Program. In the 1990s, food stamp caseloads fell 

over 28 percent in response to both welfare reform and a growing economy, and total redemptions 

fell from $21 billion in 1993 to an average of $15 billion per year between 1999 – 2002. 4 All else 

equal, the total value of trafficked benefits would fall simply because fewer benefits were issued. 

To assess the degree to which the total level of food stamp redemptions influence the dollar 

amount of trafficking we calculated what would have happened if the rate of trafficking had 

remained at 1993 levels while total redemptions fell (Figure 4). If trafficking had remained at the 

1993 rate (3.8 percent of redemptions), then the value of trafficking would have been $573 million 

in 1999 – 2002, when in fact it was $393 million. The actual amount of trafficking is 31 percent 

lower than it would be if the decline in total food stamp redemptions was the only influence. 

When we calculate trafficking exactly as we did in the past, the amount – $287 million – is half of 

what it would have been if the decline in total redemptions was the only factor. The size of the 

Food Stamp Program influences the level of trafficking – but other factors play an important role. 

Characteristics of Authorized Food Retailers 

A second possible reason for the decline in trafficking stems from the fact that the number of food 

retailers authorized to accept food stamp benefits fell over the last decade, from about 208,000 

retailers in September 1993 to just under 152,000 in September 2001. More importantly, the 

decline occurred among small stores (which have higher trafficking rates). The number of 

supermarkets (which have very low trafficking rates) stayed constant (31,000 in 1993, 32,000 in 

2001). As a result of the shift in store mix, redemptions in supermarkets declined by 24 percent 

while redemptions in small stores declined by 53 percent. All else equal, we would expect the 

total value of trafficked benefits to fall since redemptions in stores in categories with higher 

trafficking rates fell. 

 

4

 Redemption data corresponds to the estimate period: i.e., the figures used in generating the 

estimates are summed by calendar year and then annualized. 
12

Figure 4 

0

300

600

900

Millions of $

1993 1996-1998 1999-2002

Trafficking Fell More Than The Change In 

Total Redemptions Can Explain

If only total redemptions changed 

Actual dollars (original method)

Actual dollars (EBT method)

Note: this chart compares the actual trafficking amount with the amount that would have 

occurred as total redemptions declined if the rate of trafficking had not changed from 

1993 levels (i.e., for the striped bars the 1999-2002 figure is the actual 1999-2002 

redemption amount times the 1993 trafficking rate). The differences between the striped 

and dotted bars measure the degree to which trafficking is affected by factors other than 

the level of total redemptions. 

____________________ 

We follow a similar approach to assess how the proportion of large and small retailers influences 

the level of trafficking. Figure 5 compares actual trafficking amounts with what they would have 

been if the trafficking rate by store type had remained at 1993 levels while the share of 

redemptions in large and small stores changed. 

If trafficking by store type had remained at the 1993 rates (1.7 percent of redemptions in 

supermarkets, 3.7 percent of redemptions in large groceries, 15.7 percent of redemptions in small 

groceries, etc.), while the proportion of redemptions within each store type changed then the value 

of trafficking would have been $491 million in 1999 – 2002, when in fact it was $393 million. The 

31% less 
13

actual amount of trafficking is 20 percent lower than it would be if the changing mix of large and 

small food retailers was the only influence. When we calculate trafficking exactly as we did in the 

past, the amount of trafficking – $287 million – is over 40 percent lower. Changes in the 

proportion of redemptions by type of store appear to account for much of the change in the level of 

trafficking – but other factors still must play an important role.

Figure 5 

0

300

600

900

Millions of $

1993 1996-1998 1999-2002

Trafficking Fell More Than Changes 

Among Food Retailers Can Explain

If only the share of redemptions by type of food store changed

Actual dollars (original method)

Actual dollars (EBT method)

Note: this chart compares the actual trafficking amount with the amount that would have 

occurred as (a) the proportion of redemptions by each type of store changed if (b) the rate 

of trafficking by store type had not changed from 1993 levels (i.e., for the striped bars the 

1999-2002 figure is the total 1999-2002 redemptions times the 1993 trafficking rates 

weighted by the 1999 – 2002 proportion of redemptions in each type of store). The 

differences between the striped and dotted bars measure the degree to which trafficking is 

affected by factors other than the influence of changes in the authorized food retailer 

population and total redemptions. 

____________________ 

20% less 
14

Importance of Factors 

The total change in trafficking between 1993 and 1999 – 2002 was a decrease of $422 million 

($815 million minus $393 million). Table 4 breaks this down among the factors discussed 

above. 

Table 4 – Reasons Why Trafficking Declined 

(EBT method) 

Factor Amount 

Percent of 

Total 

Change 

Trafficking in 1993 $815 million 

Minus trafficking in 1999-2002 if only program size changed $573 million 

Change due to program size $242 million 57% 

Trafficking in 1999-2002 if only program size changed $573 million 

Minus trafficking in 1999-2002 if the proportion of 

redemptions in each type of retailer changed $491 million 

Change due to retailers’ share of redemptions $82 million 20% 

Trafficking in 1999-2002 if the proportion of redemptions in 

each type of retailer changed $491 million 

Actual trafficking in 1999-2002 (EBT method) $393 million 

Change due to other factors $ 98 million 23% 

Total change in trafficking $422 million 100% 

____________________ 
15

Electronic Benefit Transfer 

While the decline in total food stamp redemptions and the shifting proportion of redemptions by 

store types may account for 60 to 80 percent of the decline in trafficking, the two factors do not 

explain all of the decline. A possible additional reason for the decline is FNS action to replace 

paper food coupons with electronic benefit transfer (EBT). Under EBT certain forms of trafficking 

are harder to conduct and large-scale trafficking is easier to detect. Therefore, we would expect its 

expansion to reduce both the level and rate of trafficking. 

Existing data do not lend themselves to a direct test of this expectation. However, in 1993 virtually 

all food stamp benefits were in the form of paper coupons; in 1996 – 1998 an average of 69 percent 

of all benefits were in paper form; and by 1999 – 2002, an average of 20 percent of benefits were 

paper. 

TRAFFICKING AND STORE CHARACTERISTICS 

As in the two previous reports, stores located in the poorest neighborhoods continue to be more 

likely to engage in trafficking than stores located elsewhere (Table 5). Few recipients are likely to 

sell food stamp benefits for less than they can buy in food, unless the need for cash is 

overwhelming. It is no surprise, therefore, to find that the rate of trafficking (i.e., proportion of 

benefits trafficked) continues to vary widely by the economic status of neighborhoods. 

We found only a mild relationship between the trafficking rate and urbanicity. The Bureau of the 

Census classifies zip codes by the urban/rural percentage of residents in the zip code. The 

urban/rural percentage in the zip code in which a store is located does not show a clear relationship 

with trafficking rates (Table 6). 
16

Table 5 -Trafficking Rates By Poverty Rate.

Trafficking Rates: 

Distribution Of Stores And 

Redemptions 

Store 

Violation 

Rate 

Trafficking 

Rate 

Percent of all 

Stores 

Percent of all 

Redemptions 

Percent of Households 

in Poverty in Zip Code

Where Store is 

Located: 1996- 

1998 

1999- 

2002 

1996- 

1998 

1999- 

2002 

1996- 

1998 

1999- 

2002 

1996-

1998 

1999- 

2002 

 0 to 10% 9.5 4.7 2.0 0.9 26.5 28.3 23.2 21.6 

 11 to 20% 10.7 8.8 3.1 1.7 40.5 41.7 40.1 43.1 

 21 to 30% 13.2 13.0 3.3 4.0 20.5 19.9 21.6 23.0 

 Over 30% 16.8 17.3 7.1 5.3 12.4 10.2 15.1 12.2 

All Stores 11.7 9.3 3.5 2.5 100.0 100.0 100.0 100.0 

Notes: The data have been annualized. 

 Figures for 1996 – 1998 use the original methodology (investigations only). The 1999 – 

2002 figures use the EBT methodology (the figures using the original methodology in both 

time periods are provided in Appendix II). 

 Trafficking violation rates are calculated separately for stores and redemptions. The store 

violation rate is the percent of investigated stores caught trafficking weighted by the 

national distribution of stores. The trafficking rate is the percent of trafficked redemptions 

in investigated stores, weighted by the national distribution of redemptions. 

____________________ 
17

Table 6 - Trafficking Rate By Percent Urban. 

Stores Located in Store Violation Rate Trafficking Rate 

Zip Codes Where 

Percent Urban is: 1996-1998 1999-2002 1996-1998 1999-2002 

0 to 10% 12.9 10.3 2.4 2.7 

11 to 50% 11.6 8.8 2.5 1.4 

51 to 90% 10.9 6.7 3.0 1.0 

90 to 100% 11.6 10.2 3.9 3.2 

All Stores 11.7 9.3 3.5 2.5 

Notes: The data have been annualized. 

 Figures for 1996 – 1998 use the original methodology (investigations only). The 1999 – 

2002 figures use the EBT methodology (figures using the original methodology in both 

time periods are provided in Appendix II). 

 Trafficking violation rates are calculated separately for stores and redemptions. The store 

violation rate is the percent of investigated stores caught trafficking weighted by the 

national distribution of stores. The trafficking rate is the percent of trafficked redemptions 

in investigated stores, weighted by the national distribution of redemptions. 

____________________ 

The two previous reports also explored the relationship between trafficking and the public or 

private ownership status of stores. The trafficking rate continues to be considerably lower 

among publicly-owned stores than among their privately-owned counterparts (Table 7). 

Publicly-owned stores have a trafficking rate of one-tenth-of-one-percent and account for a third 

of all redemptions (Table 8). 

We suggest some caution with these figures, however, because it is unlikely that ownership 

status per se is the actual influence. The variable probably is a proxy for aspects of store 

management that cannot be measured directly. 
18

Table 7 – Trafficking By Store Ownership 

Trafficking When the 

Store is Publicly Owned 

Trafficking When the 

Store is Privately Owned Type of Store Store Violation 

Rate 

Trafficking 

Rate 

Store Violation 

Rate 

Trafficking 

Rate 

Supermarkets 0.0% 0.0% 2.8% 1.5% 

Large Groceries 0.0% 0.0% 7.3% 3.1% 

Other Types 1.4% 1.4% 13.5% 14.7% 

All Stores 1.0% 0.1% 11.1% 3.8% 

Notes: The data have been annualized. Calculations are based on the EBT method. 

____________________

Table 8 – Distribution of Stores by Ownership 

Category of Store 

Trafficking 

Rates 

Percent of 

All Stores 

Percent of 

All Redemptions 

Publicly Owned Stores 0.1% 17.9% 33.9% 

Large Private Stores 1.6% 20.9% 55.3% 

Private Other Stores 14.7% 61.2% 10.8% 

All Stores 2.5% 100.0% 100.0% 

Notes: The data have been annualized. Calculations are based on the EBT method. 

____________________
19

CONCLUSION AND IMPLICATIONS FOR PROGRAM INTEGRITY 

Over the last ten years, USDA developed a method to estimate the extent of food stamp trafficking 

and released two prevalence estimates, first for 1993 and an update for calendar years 1996-1998. 

This report updates the two earlier analyses with 14,642 new undercover investigations of 

trafficking completed during the 1999 – 2002 calendar year period. For the first time, we also 

include 1,537 EBT-based administrative actions against trafficking. The new prevalence 

estimates indicate that: 

Program integrity has improved substantially: 

• About $395 million per year in food stamp benefits was diverted by trafficking between 1999 

and 2002. As in prior years, this estimate is more likely to overestimate the dollars diverted 

from food benefits by direct trafficking in 1999-2002 than to underestimate it. 

• Trafficking is less than two-thirds of the $660 million per year diverted between 1996 and 

1998 and half of the $815 million diverted in 1993. When we calculate trafficking exactly as 

we did in the past, trafficking has fallen 65 percent since 1993, to $287 million. 

Trafficking now amounts to two-and-a-half cents of every benefit dollar issued, a 29 percent 

decline in the rate of trafficking between 1996 – 1998 and 1999 – 2002. The trafficking rate is the 

single best measure of effectiveness in controlling trafficking. It declined from just under 4 

percent of benefits issued in 1993 to 3.5 percent in 1996 – 1998 and to 2.5 percent of benefits 

issued in 1999 – 2002 (1.8 percent of benefits issued when calculated exactly as done in the past). 

The decline in total food stamp redemptions and the changing mix of large and small food 

retailers account for much of the decline in the value of trafficked benefits, but not all. 

Trafficking is about 20 percent lower than it would be if these were the only two influences. It is 

possible that FNS actions to replace paper food coupons with EBT also played a meaningful role 

in reducing trafficking. 

The stores which redeem the majority of food stamp benefits continue to be stores with the 

lowest trafficking rates. 

• Almost a quarter of the redemptions flowing through small groceries are trafficked. The 

impact of the continued high rate of trafficking among small groceries is limited by the fact 

that less than 5 percent of all food stamp redemptions occur in small groceries. 

• Supermarkets redeemed nearly 83 percent of all benefit dollars but few of those dollars are 

trafficked. The trafficking rate in supermarkets is less than 1 percent. 

 
20

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21

TECHNICAL DISCUSSION 

APPROACH 

This report presents two estimates of trafficking. Both estimates focus on authorized food retailers. 

Knowing the prevalence of trafficking among retailers tells us the maximum amount of dollars 

diverted from food benefits by trafficking for cash. 

Estimate 1 – Consistent Methods and Data 

In order to ensure consistent comparisons with the past, the first estimate uses precisely the same 

methodology and data sources as the two earlier reports. It is based on evidence from 14,642 

new undercover investigations of authorized food retailers. In the text we refer to this as the 

original-method estimate. 

The Food and Nutrition Service (FNS) maintains a staff of investigators who work undercover to 

determine whether authorized food stores sell ineligible items or engage in trafficking. Stores 

caught violating are fined or removed from the program and in some instances prosecuted.

We obtained all investigations provided by the four FNS compliance branch offices from their 

Automated Investigation and Monitoring System (AIMS) databases. In total, 50,781 

investigative reports were contained in those files, of which 1,133 were of unauthorized 

retailers. There is no information on store characteristics for unauthorized retailers; thus they 

were eliminated from the analysis. Of the 49,738 investigations of authorized retailers, there 

were 7,930 instances in which a retailer was investigated more than once. If in scanning any 

of multiple case records, a retailer was found to be in violation after 1998, we determined that 

the retailer was a violator (even if the retailer had a subsequent case in which they were not 

found to be in violation). The resulting database contained information about whether the 

retailer had violated since 1998. This resulted in a database of 41,808 unique stores. To 

conform to the time period of the study, we eliminated 27,119 stores in which the investigative 

reports were distributed before 1999 (or had missing distribution dates). Of the 14,689 

remaining investigative reports, we were unable to match 47 stores to Census data or retailer 

characteristics data (42 of these were in Guam). The remaining 14,642 investigative reports are 

the ones used in the analysis. 
22

For the 1999 – 2002 original-method estimate, we followed the same approach used in both earlier 

reports:5

• First, we sorted the 14,642 completed investigations across five specific dimensions that 

categorize store types and store locations. The five dimensions we employ consist of three that 

categorize stores (type of store, ownership, and level of food stamp redemptions) and two that 

categorize the zip code in which each store was located (degree of urbanization, percent of 

households in poverty). Specific definitions employed are provided in Table 9. 

• Second, for each specific category of store and location we compiled national data from 

January 1999 through October 2002 on the total number of stores and the total food stamp 

redemptions in that category. 

• Third, we analyzed the investigation outcomes and calculated the weighted trafficking and 

store violation rates within each category. The numbers of investigations in each store 

category are large enough to give high confidence in the estimates, ranging from a low of 484 

investigations of supermarkets to a high of 4839 investigations of small groceries. 

• Fourth, we weighted the investigation data to accurately represent the national figures.6 We 

calculated two of our three measures: the trafficking rate (which is a redemption-based rate to 

reflect dollar diversions) and the store violation rate (which is a store-based rate to identify the 

kinds of stores that contain the most violators). 

 

5

 There is one trivial difference in the approaches: the 1993 estimate involved data on 

investigations started by January 1, 1991 and completed by March 1994 which were combined 

with the twelve months of redemption data from 1993 and presented as a single result for calendar 

1993; the 1996 – 1998 estimate and this current one involve data on investigations completed 

between January of the start year (1996, 1999) through the end points (December 1998, October 

2002) combined with redemptions from the same respective periods, which we annualize and 

present as a single result for the estimate period. The different lengths of time involved in each 

estimate (1.5 years, 3 years and 4 years) do not affect the results since all information is 

annualized. 

6

 Statistically, the FNS investigation database encompasses a sufficient number of cases to be used 

as a post-stratified sample of the national "population" of retailers. By categorizing the 

investigated stores on the five dimensions described above and weighting the stores, by category, 

to reflect the national population of retailers, by category, we are able to draw valid conclusions 

about the national situation. 
23

Table 9 – Dimensions Used To Categorize Store Types And Locations 

Dimension Description 

1. Type of 

Store 

Based on each retailer’s identification of its store type on the FNS 

application form, store types were collapsed into the following seven 

categories (to ensure an adequate number of cases of each type): 

Supermarket any store identifying itself as a supermarket or 

grocery with gross sales over $2,000,000. 

Large grocery any store identifying itself as a supermarket or 

grocery with gross sales between $500,000 and 

$2,000,000. 

Small grocery any store identifying itself as a supermarket or 

grocery with gross sales under $500,000. 

Convenience any store identifying itself by this title, regardless of 

gross sales. 

Specialty any store identifying itself by this title, regardless of 

gross sales. They are almost always single product 

line stores such as meat markets, fish markets, dairy 

stores, etc. 

Gas/Grocery any store identifying itself by this title, regardless of 

gross sales. 

Other Types any store identifying itself by a title different than 

any of the preceding, regardless of gross sales. 

Examples include produce stands, general stores, 

combination grocery/bars, health/natural food stores, 

milk and/or bread routes. 

2. Ownership Ownership types on the FNS application form were collapsed to the 

following two categories (to ensure an adequate number of cases of 

each type). 

Public any store identifying itself to FNS as a public corporation 

(i.e., a retailer whose stock trades publicly). 
24

Table 9 – Dimensions Used To Categorize Store Types And Locations 

Dimension Description 

Private any store identifying itself to FNS as other than publiclyowned. This includes private (i.e., closely-held) 

corporations as well as partnerships, sole proprietorships, coops, etc. 

("Franchise" is a separate category on the FNS application, not an 

ownership type: both public and private ownership categories include 

stores that report themselves as franchises.) 

3. Amount of 

Food Stamp 

Business 

Stores were categorized into deciles on the basis of food stamp 

redemptions. The purpose was statistical, rather than analytical, to 

ensure that large disparities in redemptions by stores do not distort 

results. 

4. Urbanization Based on census data for the zip code in which the store is located. 

Four categories were employed: 0 to 10 percent urban population, 11 

to 50 percent, 51 to 90 percent, and over 90 percent. 

5. Poverty Based on census data for the zip code in which the store is located. 

Four categories were employed: 0 to 10 percent of residential 

population below poverty, 11 to 20 percent, 21 to 30 percent, and over 

30 percent. 

____________________

• Finally, we multiplied the redemption-based trafficking rate against the total food stamp 

redemptions in each category and summed across all categories to obtain the first of our three 

measures: the amount of trafficking, which provides an estimate of dollars diverted from food 

benefits by trafficking in the Food Stamp Program. The specific calculation was a two-stage 

one: 

− The first stage combines the data on the trafficking rates by type of store and store location 

with national redemption data to yield an estimate of the gross redemptions by authorized 

food stores found trafficking. 
25

− The second stage accounts for the fact that some of the gross redemptions are legitimate 

food sales. To maintain consistency with the earlier estimate, we continue to use the 

assumption that legitimate food sales account for 60 percent of the gross redemptions 

among supermarkets and large grocery stores caught trafficking and treat 40 percent of 

their gross redemptions as trafficked. Among all other types of food stores, we assume that 

only 10 percent of the gross redemptions are legitimate food sales and treat 90 percent of 

their gross redemptions as trafficked. 

Estimate 2 – Consistent Methods, Expanded Data 

The second estimate uses the same statistical methodology described under estimate 1 and all 

14,642 investigations included in estimate 1. However, it adds data that were unavailable before 

1999: the results of 1,537 EBT-based actions against food retailers suspected of trafficking 

(“administrative cases”). The trafficking rate within each category was calculated as follows: 

Investigations that found trafficking + Administrative cases that found trafficking 

All investigations + All administrative cases 

All other steps in calculating estimate 2 are identical to those described above. In the text we refer 

to estimate 2 as the EBT method. 

Data Considerations

Because the outcomes of in-person undercover investigations are central to both of the USDA 

estimates of trafficking, change in the quantity or quality of these investigations between reporting 

periods has the potential to distort any comparisons over time. 

There has been no meaningful change in the quantity of FNS investigations. The numbers per 

year remain within their historic range of 4,100 to 5,300 investigations (Figure 6) while the 

number of investigations per authorized store has increased (Figure 7). 
26

Figure 6 

FNS Investigations: 1991 - 2002

0

2000

4000

6000

91 93 95 97 99 01

Year

Number

Trafficking Positive Total Investigations

Source: Food and Nutrition Service, Benefit Redemption Division Annual Reports 

___________________

Figure 7 

Percentage of Authorized Stores 

Investigated, 1991 - 2002

0

0.5

1

1.5

2

2.5

3

3.5

91 93 95 97 99 01

Year

Percent

Source: Food and Nutrition Service, Benefit Redemption Division Annual Reports 

____________________ 
27

At the same time, the number of investigations where trafficking is detected has been declining, 

from a high of 21 percent in 1994 to 7 percent in 2002 (Figure 8). A crucial question is whether 

this decline reflects less trafficking or changes in the ability of traffickers to avoid detection. 

To some degree, FNS Compliance Branch (CB) investigations have a deterrent effect, reducing 

trafficking among other stores. After a quality positive investigation, appropriate action is taken 

against storeowners. The storeowners tell their employees and other storeowners about actions 

taken against them due to food stamp violations. FNS Regional and Field Offices also issue press 

releases so that the general public, including food stamp recipients, are made aware of FNS’ 

compliance monitoring efforts. These actions increase voluntary compliance, which reduces 

trafficking within the program. Some of the decline in the percentage of investigations that find 

trafficking may reflect the cumulative effect of CB actions. 

Another possibility is that traffickers have gotten smarter and are better able to elude investigators. 

The quality of investigations is hard to measure; however, continuing experience, routine sharing 

of information about investigative techniques among investigators, and greater use of EBT data to 

select stores for investigation make it likely that the quality of investigations has improved – and 

that would tend to compensate for any changes in the behavior of traffickers. 

Figure 8 

The Percent Of Investigations That Find 

Trafficking Varies, But Has Declined In 

Recent Years

0

5

10

15

20

25

91 93 95 97 99 01

Year

Percent 

Source: Food and Nutrition Service, Benefit Redemption Division Annual Reports 

____________________ 
28

A final possibility is that investigative techniques that worked for trafficking with paper food 

stamp coupons do not work as well under EBT. While the degree to which this occurs is unknown, 

the addition of administrative cases to the estimate compensates for any difficulty in conducting 

investigations under EBT. 

ESTIMATION ERROR 

When we look at additional considerations that bear on trafficking, we find two factors that would 

tend to increase our estimate and three others that would tend to decrease it. It is important to 

discuss each of these additional considerations explicitly. 

Sources Of Underestimation 

1. Our procedure underestimates two aspects of the trafficking problem. The first aspect leading 

to underestimation is evasion trafficking: 

• Among small retailers that are family-owned or where ownership is closely held, some 

violators did not redeem coupons for cash from the government (direct trafficking) but 

bought food stock for resale from large stores with trafficked coupons (a form of tax 

evasion we label "evasion trafficking"). This practice appears to be continuing under EBT 

although the frequency is not known. Evasion trafficking is a gray area, since the practice 

does not necessarily involve discounting: a small firm makes an illicit profit at the least 

risk of detection if it accepts food stamp benefits at full value for food from legitimate 

recipients, but illegally uses them to buy food at supermarkets for resale in their own store. 

• In our estimate we are most concerned about evasion trafficking when it is linked to 

discounting (i.e., the firm buys food stamp benefits at a discount). We have no data to 

estimate the extent of evasion trafficking by unauthorized food stores or restaurants. 

However, evasion trafficking by authorized retailers is captured by our estimating 

procedure, when the trafficking involves discounting. The data we use to estimate direct 

trafficking adequately capture the rate at which all authorized stores engage in discounting. 

If redemptions from unauthorized businesses could be measured, then the evasion 

trafficking factor would increase the national estimate of dollars diverted from food 

benefits by trafficking but would not change the store-based violation rates useful for 

targeting future action. 

2. The second potential cause of underestimation is network trafficking: 

• Some violating stores will traffic with strangers while others restrict their illegal activities 

to people they know (which we label "network trafficking"). Investigators can and do 

catch this type of trafficking, but it involves a more complicated investigation. 
29

• As a result, some network trafficking is included in our original-method estimate (because 

our investigations include some cases where the network was penetrated and trafficking 

was caught). But other instances of network trafficking are not included in our originalmethod estimate (because investigators were unable to penetrate the network and make the 

case). If investigators could catch all instances of trafficking, the national investigationbased estimate of trafficking diversions would increase.7

 

• Administrative cases, which depend only upon observed EBT transaction patterns, can 

have much greater success at catching network trafficking. The addition of administrative 

cases in the new EBT-method estimate substantially decreases concern about this source of 

underestimation, but does not entirely eliminate it (since administrative actions do not 

detect all instances of network trafficking). 

Sources Of Overestimation 

1. At the same time, our procedure overestimates other aspects of the trafficking problem. A first 

source of overestimation is the procedure used to determine legitimate food sales. 

• With extremely rare exceptions, stores that engage in trafficking also sell food and we must 

allocate some proportion of their total redemptions to legitimate food sales and the balance 

to trafficking. We used very low figures to estimate the percentage of legitimate food sales 

by violating stores: when a supermarket or large grocery is caught trafficking we assume 

that 40 percent of all the store’s redemptions are trafficked (even if the trafficking only 

involved a single clerk away from the register area); among small stores caught trafficking 

we assume that 90 percent of the store’s redemptions are trafficked. While these figures 

are unrealistically high, we choose them purposefully because it serves our goal of assuring 

an estimate of the maximum benefits diverted by trafficking. 

• To be consistent with the 1993 and 1996 – 1998 figures, we keep our allocation figures the 

same in this report – but our estimates of trafficking diversion would be lower to the extent 

that our method to estimate legitimate food sales was more precise. This factor affects both 

the original- and EBT-method estimates. 

 

7

 An additional potential consideration is the quality of the investigation. Even when retailers are 

willing to traffic with strangers, investigators with greater experience are likely to catch more 

trafficking than investigators with lesser experience. We believe the overall quality of 

investigations in our sample is high for two reasons. First, FNS investigative procedures provide 

adequate time and resources to establish a case. Second, in the earlier report we only used cases 

from 1991 and later, to ensure that investigators either had at least two years of experience in 

establishing trafficking cases (or were hired with the understanding that trafficking cases were 

highest priority). In the second estimate and this third one, most investigators have at least six 

years of experience in establishing trafficking cases, which strengthens our confidence in these 

estimates. 
30

2. Another source of overestimation stems from the fact that the data on administrative cases are 

incomplete. The development of an administrative case starts with lists of stores that exceed 

thresholds on suspicious EBT transaction patterns. The process of building an administrative 

case involves screening out stores that have an obvious explanation for their otherwise 

suspicious EBT transaction pattern. Stores that pass the various screens are sorted into those 

for which an investigation is warranted and those which can be handled administratively. 

The latter are sent a letter containing charges of program violations (“Charge Letter”) and 

given an opportunity to explain the observed pattern. To properly compute a trafficking rate 

with administrative cases we need to know the number of stores that exceeded thresholds but 

were screened out. The proper computation is: 

All Charge Letters that find trafficking 

All Charge Letter stores + All stores screened out 

Data has not been kept on screened out stores, however, so the administrative case 

component of our estimate is based on: 

All Charge Letters that find trafficking 

All Charge Letter stores 

This causes the EBT method approach to overestimate the amount of trafficking. FNS is 

exploring ways to maintain appropriate data to address this problem before the next 

trafficking update is computed. 

3. A final – and major – source of overestimation is that investigations are a non-random sample 

of stores. 

• Our original estimating procedure relies on investigations targeted to find fraud: our 

estimate would decrease substantially if investigators had randomly selected from all 

stores, rather than selected suspicious stores on purpose. Likewise our estimate would 

decrease substantially if the Charge Letters that underlie administrative cases were sent 

randomly to all stores, rather to stores that are suspicious because they exceed thresholds 

on EBT transaction scans. 

• Of our five technical considerations, this is arguably the one with the largest impact on our 

estimate. It applies to both the original- and EBT-method estimates and supports our goal 

of ensuring that we can estimate the maximum amount of dollars diverted by trafficking. 
31

APPENDIX I 

We processed all stores received from FNS redemption files but used only the ones with a match 

to zip code data in the analysis (since two of the five dimensions underlying the estimates are 

based on information linked to zip code). Stores that had no redemptions were dropped from the 

analysis (unless they had been investigated, in which case they were retained). For each specific 

year the total number of authorized retailers received and total number in our analysis file are as 

follows: 

 Received Analysis File Percent Matchable

 1996: 205,318 202,850 98.8 

 1997: 196,408 193,510 98.5 

1998: 184,055 180,857 98.3 

1999: 156,594 156,169 99.7 

2000: 157,587 157,116 99.7 

2001: 154,802 154,356 99.7 

2002: 147,034* 146,585 99.7 

* Includes only the first 10 months of 2002. 

For each specific year the sum of redemptions (total dollars) was: 

 Received Analysis File Percent Matchable

1996: $21,713,774,005 $21,580,132,008 99.4 

1997: $18,463,396,131 $18,322,710,580 99.2 

1998: $16,433,240,311 $16,260,221,191 99.0 

1999: $15,144,649,239 $15,090,992,653 99.6 

2000: $14,661,266,860 $14,605,272,650 99.6 

2001: $16,056,825,785 $16,002,812,646 99.7 

2002: $14,438,703,946* $14,385,848,187 99.6 

* Includes only the first 10 months of 2002. 
32

APPENDIX II 

Tables Based On The Original-Method Estimate 

Table 10 – Trafficking By Percent In Poverty: Original Methodology 

Trafficking Rates: Distribution Of Stores And 

Redemptions 

Percent of Households 

in Poverty in Zip Code 

Store 

Violation 

Rate 

Trafficking 

Rate 

Percent of all 

Stores 

Percent of all 

Redemptions 

Where Store is 

Located: 

1996- 

1998 

1999- 

2002 

1996- 

1998 

1999- 

2002 

1996- 

1998 

1999- 

2002 

1996-

1998 

1999- 

2002 

 0 to 10% 9.5 3.4 2.0 0.5 26.5 28.3 23.2 21.6 

 11 to 20% 10.7 5.5 3.1 1.3 40.5 41.7 40.1 43.1 

 21 to 30% 13.2 8.7 3.3 3.0 20.5 19.9 21.6 23.0 

 Over 30% 16.8 11.7 7.1 3.7 12.4 10.2 15.1 12.2 

All Stores 11.7 6.2 3.5 1.8 100.0 100.0 100.0 100.0 

Note: The data have been annualized. 

Table 11 – Trafficking By Percent Urban, Original Methodology 

Stores Located in Store Violation Rate Trafficking Rate 

Zip Codes Where 

Percent Urban is: 1996-1998 1999-2002 1996-1998 1999-2002 

0 to 10% 12.9% 5.6% 2.4% 1.4% 

11 to 50% 11.6 4.9 2.5 1.0 

51 to 90% 10.9 4.4 3.0 0.7 

90 to 100% 11.6 7.2 3.9 2.4 

All Stores 11.7 6.2 3.5 1.8 

Note: The data have been annualized.