Report to the Committee on 

Agriculture, Nutrition, and Forestry, 

U.S. Senate 

United States Government Accountability Office

GAO

September 2004 FOOD STAMP 

PROGRAM 

Farm Bill Options 

Ease Administrative 

Burden, but 

Opportunities Exist to 

Streamline Participant 

Reporting Rules 

among Programs 

GAO-04-916 
www.gao.gov/cgi-bin/getrpt?GAO-04-916. 

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Sigurd Nilsen, 

(202) 512-7215 nilsens@gao.gov. 

Highlights of GAO-04-916, a report to 

Committee on Agriculture, Nutrition, and 

Forestry, U.S. Senate 

September 2004

FOOD STAMP PROGRAM 

Farm Bill Options Ease Administrative 

Burden, but Opportunities Exist to 

Streamline Participant Reporting Rules 

among Programs 

As of January 2004, states chose four of the eight Farm Bill options with 

greater frequency than the others. These options provided states with more 

flexibility in requiring participants to report changes and in determining 

eligibility. 

Number of States That Have Chosen, Implemented, or Not Chosen Farm Bill Options as of 

January 2004 

0

10

20

30

40

50

Not chosen Chosen, not yet implemented Chosen and implemented

 Simplified

homeless

shelter

costs

Simplified

determination

of deductions

Child

support

expense

income

exclusion

Transitional

benefits

Simplified

definition

of resources

Simplified

definition

of income

Simplified

standard

utility

allowance

Expanded

simplified

reporting

Source: GAO analysis of survey data.

33

24

30

23

12 7 4 4

9 7 12 12

27

35

44 45

8 9 20 16

12

9 3

1

Number of states

Simplified homeless

shelter costs

Simplified

determ

of deductions

ination

Child support expense

income exclusion

Transitional

benefits

Simplified definition

of resources

Simplified definition

of income

Simplified standard

utility allowance

Expanded

reporting

simplified

The most common reasons state officials gave for choosing the eight options 

were to simplify program rules for participants and caseworkers. 

 

Local food stamp officials reported mixed results from implementing the 

Farm Bill options. Although they reported some improvements for both 

caseworkers and participants from some options, no option received 

consistent positive reports in all the areas where state officials expected 

improvements. In fact, in many cases, officials were as likely to report that 

an option resulted in no change as they were to report improvements. 

Moreover, many local officials reported that three options introduced 

complications in program rules. One option that offered the most promise 

because it was selected by most states and affects a large number of 

participants resulted in food stamp participant reporting rules that differed 

from Medicaid and TANF. These differences resulted in confusion for food 

stamp participants and caseworkers, and some changes were made that 

undermined the intended advantages of the option. These problems reflect 

the challenge of trying to simplify rules for one program without making the 

rules of other related programs the same. Concerns about whether there are 

costs associated with aligning reporting rules may hinder a state’s decision 

to pursue alignment; yet the extent to which program costs might increase as 

a result of making reporting rules the same is unclear. 

Many individuals familiar with the 

Food Stamp Program view its rules 

as unnecessarily complex, creating 

an administrative burden for 

participants and caseworkers. In 

addition many participants receive 

benefits from other programs that 

have different program rules, 

adding to the complexity of 

accurately determining program 

benefits and eligibility. The 2002 

Farm Bill introduced new options 

to help simplify the program. This 

report examines (1) which options 

states have chosen to implement 

and why, and (2) what changes 

local officials reported as a result 

of using these options. To view 

selected results from GAO’s Webbased survey of food stamp 

administrators, go to 

www.gao.gov/cgi-bin/getrpt?GAO-04-

1058SP. To view the results from 

the local food stamp office surveys, 

go to www.gao.gov/cgi-bin/getrpt?GAO04-1059SP. 

GAO recommends that the Food 

and Nutrition Service (FNS) work 

with the Department of Health and 

Human Services to (1) encourage 

states to explore the advantages 

and disadvantages of better 

aligning participant reporting rules, 

particularly for Medicaid and 

Temporary Assistance for Needy 

Families (TANF) and (2) provide 

information to states on the 

opportunities for better aligning 

reporting rules. In comments on 

GAO’s draft report, FNS officials 

agreed with our recommendations 

and said they plan to explore ways 

to align participant reporting rules. 
Page i GAO-04-916 Food Stamp Program 

Letter 1

Results in Brief 3 

Background 5 

States Chose Some Farm Bill Options More Frequently than Others 

to Simplify Program Rules and Ease the Administrative Burden 

for Participants and Caseworkers 11 

Local Food Stamp Officials Reported Mixed Results for Farm Bill 

Options; These Results Ranged from Improvements to 

Complications 20 

Conclusions 32 

Recommendations for Executive Action 33 

Agency Comments 34 

Appendix I Objective, Scope, and Methodology 35 

Appendix II Farm Bill Options That States Have Implemented as 

of January 2004 40 

Appendix III Selected Responses to State Survey 41 

Appendix IV Selected Responses to Local Surveys 43 

Appendix V GAO Contacts and Staff Acknowledgments 50 

GAO Contacts 50 

Acknowledgments 50 

Related GAO Products 51 

Table 

Table 1: Disposition of Eight Farm Bill Option Samples 39 

Contents 
Page ii GAO-04-916 Food Stamp Program 

Figures 

Figure 1: Description and Purpose of Farm Bill Options 10 

Figure 2: Number of States That Have Chosen, Implemented, or 

Not Chosen Farm Bill Options, as of January 2004 12 

Figure 3: Important Reasons for Choosing Options 14 

Figure 4: Important Reasons for Not Choosing Options 17 

Figure 5: Results Reported by Local Officials on Administrative 

Burden for Participants and Caseworkers 22 

Figure 6: Results Reported by Local Officials on Error Rate, 

Participation, Benefit Amount, and Alignment 24 

Figure 7: Example of Possible Decisions and Actions under the 

Expanded Simplified Reporting Option 28 

Figure 8: Farm Bill Options States Have Implemented as of January 

2004 40 

Figure 9: Number of States That Gave Reasons for Choosing 

Options 41 

Figure 10: Number of States That Gave Reasons for Not Choosing 

Options 42 

Figure 11: Expanded Simplified Reporting 43 

Figure 12: Simplified Standard Utility Allowance 44 

Figure 13: Simplified Definition of Income 45 

Figure 14: Simplified Definition of Resources 46 

Figure 15: Transitional Benefits 47 

Figure 16: Child Support Expense Income Exclusion 48 

Figure 17: Simplified Determination of Deductions 49 

Abbreviations 

CMS Centers for Medicare and Medicaid Services 

HHS Department of Health and Human Services 

FNS Food and Nutrition Service 

TANF Temporary Assistance for Needy Families 

USDA U.S. Department of Agriculture 
Page iii GAO-04-916 Food Stamp Program 

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Page 1 GAO-04-916 Food Stamp Program 

September 16, 2004 

The Honorable Thad Cochran 

Chairman 

The Honorable Tom Harkin 

Ranking Minority Member 

Committee on Agriculture, Nutrition, 

 and Forestry 

United States Senate 

In fiscal year 2003, the federal Food Stamp Program, administered by the 

U.S. Department of Agriculture’s (USDA) Food and Nutrition Service 

(FNS), provided about $21.4 billion in food stamp benefits. In that same 

year, the program helped a monthly average of 21 million low-income 

individuals, many of whom were children. However, the program faces a 

number of challenges. Many individuals familiar with the Food Stamp 

Program view its rules as unnecessarily complex, creating an 

administrative burden for both program participants and affected 

government offices. In addition, many food stamp participants receive 

benefits from other low-income assistance programs, such as Medicaid 

and Temporary Assistance for Needy Families (TANF). These programs, 

administered by the Department of Health and Human Services (HHS) 

have different rules than those allowed under the Food Stamp Program. 

Differences among these program rules add to the complexity of 

accurately determining eligibility and program benefits. In 2003, errors in 

overpayments and underpayments totaled $1.4 billion. These errors 

occurred in part because of the complexity of program rules. Further, FNS 

estimated that in September 2001, only 62 percent of individuals who were 

eligible to receive food stamps participated in the program. In the 

previous year, FNS established a goal to improve the rate of food stamp 

participation among all eligible people to 68 percent by 2005. 

For many years, states and advocacy groups have called for changes in the 

program to help overcome these challenges. Some changes were made to 

the program beginning in the late 1990s, and the Farm Security and Rural 

Investment Act of 2002 (referred to in this report as the Farm Bill) 

introduced new options, from which states could choose, to help simplify 

the program, encourage greater participation among eligible households, 

ease the administrative burden for participants and program 

administrators, and help support low-income working families. For 

example, one option reduces participant reporting requirements, while 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-04-916 Food Stamp Program 

another helps to ensure that families leaving TANF cash assistance 

continue to receive their food stamp benefits without requiring the family 

to reapply or submit additional paperwork. In addition, some of these 

options permit states to more closely align food stamp eligibility rules with 

the eligibility rules of other programs, an improvement that could 

streamline administrative procedures for food stamp workers, improve 

service for clients who participate in more than one assistance program, 

and help reduce state payment error rates. In order to understand whether 

the Farm Bill options have helped states streamline their programs, you 

asked us to determine (1) which options states have chosen to implement 

and why, and (2) what changes local officials reported as a result of 

implementing these options. 

To answer these questions, we surveyed food stamp administrators in the 

50 states and the District of Columbia to collect information on which 

Farm Bill options states have chosen and the reasons states chose certain 

options. We also sent over 1,300 surveys to food stamp supervisors in 

randomly selected local food stamp offices, where the options are actually 

implemented during daily contacts with participants. These survey results 

are generalizable to local offices in states that implemented the options. 

We asked them how Farm Bill options had affected several aspects of the 

Food Stamp Program, such as administrative burden on participants and 

food stamp caseworkers.1

 We focused our surveys on eight of the nine 

Farm Bill options, excluding one option that allows states on a pilot basis 

to test issuing standardized benefits to residents of certain group facilities. 

To view selected results from GAO’s Web-based survey of food stamp 

administrators, go to www.gao.gov/cgi-bin/getrpt?GAO-04-1058SP. To view 

the results from the local food stamp office surveys, go to 

www.gao.gov/cgi-bin/getrpt?GAO-04-1059SP. 

To augment information from our state and local surveys, we conducted 

three comprehensive site visits (Arizona, Maryland, and Michigan) and two 

structured telephone interviews (Colorado and South Carolina). We chose 

states for our site visits and telephone interviews to capture the variation 

in the following criteria: (1) number of and type of selected options, 

(2) numbers of food stamp participants and program participation rate, 

(3) program error rates, and (4) entity (state or county) administering the 

Food Stamp Program. During each visit we met with state officials 

administering and developing policy for the Food Stamp Program, local 

 1

See appendix I for a detailed explanation of the methodology we used for the state and 

local surveys. 
Page 3 GAO-04-916 Food Stamp Program 

officials in the office where services are provided, and officials responsible 

for other key assistance programs, such as TANF and Medicaid. 2 We also 

reviewed Farm Bill legislation and related committee reports, and we 

reviewed FNS reports and other program analysis. We held discussions 

with program stakeholders, including officials at FNS headquarters and 

regional offices, officials at HHS, representatives of advocacy 

organizations, and other program experts. We performed our work from 

August 2003 to June 2004 in accordance with generally accepted 

government auditing standards. 

States chose four of the eight options available in the Farm Bill more 

frequently than the others and based their decisions largely on whether 

they thought the options would help simplify Food Stamp Program rules 

and ease the administrative burden for food stamp participants and 

caseworkers. The four options that states chose most frequently provided 

states more flexibility in how often participants must report changes in 

their household circumstances (such as increases in income), the way 

food stamp caseworkers in local offices calculate utility costs, what 

household income is considered when determining food stamp eligibility, 

and what household resources are considered when determining 

eligibility. As of January 2004, each of these four options had been 

implemented by at least 23 states, and other states told us that they were 

planning to implement them. State officials gave many reasons for 

choosing these options. Among the most common were to decrease the 

workload for caseworkers, decrease the burden on participants, and 

simplify rules for participants and caseworkers. For example, at least 

30 states cited these reasons in choosing the option to reduce how often 

participants must report changes in household circumstances. In addition, 

many states chose one or more of these options because officials believed 

the option would decrease their state’s payment error rate, help align the 

Food Stamp Program with other assistance programs, or increase overall 

participation in the Food Stamp Program. States’ decisions not to adopt 

 2

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 reformed 

Aid to Families with Dependent Children and established the $16.5 billion Temporary 

Assistance for Needy Families block grant, which provides to the states federal funds to 

support low-income families and help these families reduce their dependence on welfare. 

Medicaid, established in 1965, is a joint federal-state entitlement program that finances 

health care coverage for certain low-income families, children, pregnant women, and 

individuals who are aged or disabled. Federal income limits for children and pregnant 

women range from 100 percent to 185 percent of the federal poverty level, depending on 

age. Income limits for adults and individuals who are aged or disabled vary by state. 

Results in Brief 
Page 4 GAO-04-916 Food Stamp Program 

the four other options also hinged on what they believed the outcomes 

would be for participants and caseworkers. These options allowed states 

to provide transitional food stamps for up to 5 months to those families 

that leave TANF without requiring the family to reapply for food stamps, 

change how caseworkers treat child support payments for noncustodial 

parents, disregard changes in certain deductions (such as child care and 

medical expenses) during certification periods, and use a standard 

deduction for homeless households that incur some shelter expenses. 

Specifically, fewer states thought these other options would reduce the 

administrative burden for participants and caseworkers. For example, 

many states did not choose the option that provides transitional food 

stamps for up to 5 months after a household leaves TANF cash assistance 

because officials believed it would make program rules for participants 

and caseworkers more complicated. Many states also thought these 

options would have little or no advantage over current policy or would 

create additional problems, including difficulties with programming their 

computer systems. In fact, the majority of states that adopted these four 

options reported that they faced some implementation hurdles, such as 

difficulties related to caseworkers’ adjustment to program changes and 

reprogramming computer systems to accommodate changes. 

Local food stamp officials reported mixed results from implementing the 

options; the results ranged from anticipated improvements to 

complications in program rules. For example, some local officials reported 

that the options they implemented had the anticipated effect of easing the 

administrative burden for food stamp participants and caseworkers by 

reducing the number of times participants are required to submit 

paperwork and the amount of time caseworkers spend on paperwork. On 

the other hand, many other local officials reported that the administrative 

burden remained the same before and after implementing the Farm Bill 

options. Similarly, for options implemented in part to increase program 

participation, some local officials reported that participation increased, 

while others told us that it remained the same. Some options may have 

been associated with no change, in part because they affected few food 

stamp participants. Also, many options made minor changes to existing 

policy. Finally, local officials reported that three options introduced 

complications in program rules for both caseworkers and participants. 

Local officials told us that the option to reduce reporting requirements for 

participants—an option that local officials reported affected most food 

stamp participants—introduced complications for food stamp participants 

and caseworkers. Local officials on our site visits and in telephone 

interviews explained that this change to reporting rules was not consistent 

with how states structured the reporting rules of other assistance 
Page 5 GAO-04-916 Food Stamp Program 

programs, resulting in food stamp reporting rules that are not aligned with 

Medicaid and, in all but one state we visited, are not aligned with TANF. 

For example, in one state, the Food Stamp Program requires a participant 

to report when his or her income rises above 130 percent of the federal 

poverty level, but that state’s Medicaid program requires the same 

participant to report all changes in household circumstances, including 

any change in income. The variation among these reporting rules often 

resulted in confusion on the part of program participants and 

caseworkers, unnecessary work for the caseworker, and the possible 

payment of improper benefits from the Food Stamp Program and other 

assistance programs. 

In order to take advantage of existing opportunities available to states for 

streamlining participant reporting rules, we recommend that the Secretary 

of Agriculture direct FNS to collaborate with HHS to take the following 

two actions: (1) encourage state officials to explore the advantages and 

disadvantages—in terms of both administrative and benefit costs and 

savings—of better aligning participant reporting rules in their states, 

particularly for Medicaid and TANF; and (2) disseminate information and 

guidance to states on the opportunities available for better aligning 

participant reporting rules among food stamps, Medicaid, and TANF. In 

comments on GAO’s draft report, FNS officials agreed with our 

recommendations and said they plan to explore ways to align participant 

reporting rules. 

The federal Food Stamp Program is intended to help low-income 

individuals and families obtain a better diet by supplementing their income 

with benefits to purchase food. FNS pays the full cost of food stamp 

benefits and shares the states’ administrative cost—with FNS paying about 

50 percent of the administrative cost. FNS is responsible for promulgating 

program regulations and ensuring that state officials administer the 

program in compliance with program rules. The states administer the 

program by determining whether households meet the program’s income 

and asset requirements, calculating monthly benefits for qualified 

households, and issuing benefits to participants on an electronic benefits 

transfer card. 

Eligibility for participation in the Food Stamp Program is based on the 

Department of Health and Human Services’ poverty guideline for 

households. In most states, a household’s gross income cannot exceed 

130 percent of the federal poverty level (or about $1,654 per month for a 

Background 

Determination of 

Eligibility and Benefits 
Page 6 GAO-04-916 Food Stamp Program 

family of three in 2003), and net income cannot exceed 100 percent of the 

poverty guideline (or about $1,272 per month for a family of three in 

2003). Net income is determined by deducting from gross income 

expenses such as dependent care costs, medical expenses, utilities costs, 

and shelter expenses. In addition, most states place a limit of $2,000 on 

household assets, and basic program rules limit the value of vehicles an 

applicant can own and still be eligible for the program.3

 If the household 

owns a vehicle worth more than $4,650, the excess value is included in 

calculating the household’s assets.4

Recipients of TANF cash assistance are automatically eligible for food 

stamps—a provision referred to as “categorical eligibility”—and do not 

have to go through a separate food stamp eligibility determination process, 

although the level of their benefits must still be determined. Many needy 

families who are no longer receiving TANF cash assistance may receive 

other TANF-funded services or benefits, such as child care benefits. In 

1999, to help ensure that these families are also eligible for food stamp 

benefits, FNS offered states the option to extend categorical eligibility to 

families receiving TANF-funded benefits or services. Families who are 

automatically eligible for food stamps do not have to meet the food stamp 

asset test in order to receive benefits but would have to meet the state’s 

TANF asset test. 

States also have two ways in which they can allow households to own a 

vehicle that is worth more than the amount allowed in current regulations 

and still remain eligible for food stamp benefits. In October 2000, in part to 

help support low-income working families, the Congress enacted 

legislation that grants states the option to replace the federal food stamp 

vehicle asset rule with the vehicle asset rule from their TANF assistance 

program, which is set by the state and can vary from state to state. States 

can also opt to use the categorical eligibility option as a way to exclude all 

vehicles, as well as other assets the family may have. This option affects 

the food stamp eligibility only of food stamp families authorized to receive 

a TANF-funded service or benefit. As of October 2003, the majority of 

states had either replaced their federal food stamp vehicle asset rule with 

the vehicle asset rule from their TANF assistance program or conferred 

categorical eligibility as a way to exclude vehicles. 

 3

Households with disabled or elderly members are exempt from the gross income limit. In 

addition, households with elderly members may have assets valued at $3,000. 

4

If a household has no other assets, its vehicle can be worth $6,650. 
Page 7 GAO-04-916 Food Stamp Program 

After eligibility is established, households are certified eligible for food 

stamps for periods ranging from 1 to 24 months. The length of the 

certification period depends on household circumstances, but only 

households in which all members are elderly or disabled can be certified 

for more than 12 months. Once the certification period ends, households 

must reapply for benefits, at which time eligibility and benefit levels are 

redetermined.5

Between certification periods, households must report changes in their 

circumstances—such as household composition, income, and expenses—

that may affect their eligibility or benefit amounts. States have the option 

of requiring food stamp participants to report on their financial 

circumstances at various intervals and in various ways. States can institute 

a type of periodic reporting system or they can rely on households to 

report changes in their household circumstances within 10 days of 

occurrence.6

 Under periodic reporting, participants may report monthly, 

quarterly, or under a simplified system. The simplified reporting system, 

available since early 2001, provides for an alternative reporting option that 

requires households with earned income to report changes only when 

their income rises above 130 percent of the poverty level. 

FNS monitors how accurately states determine food stamp eligibility and 

calculate benefits. Under FNS’s quality control system, the states calculate 

their payment errors by drawing a statistical sample to determine whether 

participating households received the correct benefit amount.7

 Improper 

payments, which include overpayments of food stamp benefits to 

participants, underpayments to participants, and payments to those who 

 5

Prior to welfare reform, federal regulations required households to have a face-to-face 

interview with an agency worker at each recertification. Current regulations give states the 

option to require only one face-to-face interview a year regardless of the length of 

certification. 

6

States can choose from a variety of change-reporting methods. They can require 

households to report only when a member changes jobs, receives a different rate of pay, or 

has a change in his or her work status, i.e., from full-time to part-time or vice versa. States 

can also require households to report only when there is a change in earnings of $100 or 

more per month. 

7

The food stamp error rate is calculated for the entire program, as well as every state, by 

adding overpayments to those who are eligible for smaller benefits, overpayments to those 

who are not eligible for any benefit, and underpayments to those who do not get as much 

as they should. The program also calculates a negative action error rate, defined as the rate 

of improper denials or terminations of benefits. 

Certification and 

Reporting Requirements 

FNS’s Quality Control 

System 
Page 8 GAO-04-916 Food Stamp Program 

are not eligible, may occur for a variety of reasons. Overpayments can be 

caused by inadvertent or intentional errors made by recipients and 

caseworkers. For example, caseworkers may misapply complex food 

stamp rules when calculating benefits or participants may inadvertently or 

deliberately provide inaccurate information to food stamp offices. In the 

1990s, the states’ error rate hovered around 10 percent, but it fell to 

6.6 percent in fiscal year 2003, the lowest level in the program’s history. 

The 2003 combined error rate comprised $1 billion in overpayments to 

food stamp participants and underpayments of more than $300 million. 

According to USDA, about half of all payment errors are due to an 

incorrect determination of household income. 

The Farm Bill changed the Food Stamp Program’s quality control system 

by making only those states with persistently high error rates face 

liabilities.8

 The Farm Bill also provides for $48 million in bonuses each 

year to be awarded to states with high or most improved performance, 

including actions taken to correct errors, reduce error rates, improve 

eligibility determinations, and other indicators of effective administration 

as approved by the Secretary of Agriculture.9

 

Many food stamp participants receive benefits from other federally funded 

low-income assistance programs, including Medicaid and TANF. For 

example, in 2002, about 85 percent of children who received food stamp 

benefits were also on Medicaid, and about 20 percent of food stamp 

households received assistance from TANF. Many food stamp participants 

also receive child care assistance and Supplemental Security Income.10 In 

 8

Before the Farm Bill, states were penalized if their combined payment error rate was 

higher than the national average. As a result, about half of states were subject to financial 

sanctions each year. States are required to either pay the sanction or provide additional 

state funds—beyond their normal share of administrative costs—to be reinvested in errorreduction efforts, such as additional training in calculating benefits for certain households. 

Under the Farm Bill, a state will be subject to fiscal sanction if there is a 95 percent 

statistical probability that the state’s payment error rate exceeds 105 percent of the 

national average for 2 consecutive years. 

9

The Farm Bill requires the Secretary to issue regulations for fiscal year 2005 and thereafter 

that will establish criteria related to these improved performances and be used to award 

performance bonus payments. 

10Supplemental Security Income is a federal income supplement program that assists 

people who are age 65 or older, blind, or disabled, and who have limited income and 

resources. The program provides monthly cash payments to help those who are qualified 

meet basic needs for food, clothing, and shelter. 

Food Stamp Participants 

Receive Benefits from 

Other Assistance Programs 
Page 9 GAO-04-916 Food Stamp Program 

most states, the Food Stamp Program is administered out of a local 

assistance office that offers benefits from these other assistance programs 

as well. Food stamp participants may provide necessary information to 

only one caseworker who determines eligibility and benefits for all of 

these programs, or they may work with several caseworkers that 

administer benefits for different programs. 

Despite the overlap in the populations served by these various assistance 

programs, program rules and requirements across these programs vary 

significantly.11 Substantial variation exists not only in program financial 

eligibility rules. The primary sources of these variations are generally at 

the federal level, although for several programs, such as TANF and 

Medicaid, states and localities have some flexibility in setting financial 

eligibility rules. They also have flexibility in the rules that govern how 

often participants are required to report changes in their household 

circumstances. While the Food Stamp Program allows states to choose 

either periodic or change reporting, Medicaid provides states with even 

broader flexibility to establish rules for when Medicaid participants must 

report changes in their circumstances. Under Medicaid regulations, states 

must have procedures designed to ensure that participants make timely 

and accurate reports of any change in circumstances that may affect their 

eligibility and that states act promptly to redetermine eligibility based on 

the reported change in circumstances. However, the terms “timely” and 

“promptly” are not defined and can be interpreted in various ways by the 

states. TANF does not mandate a particular set of participant reporting 

rules and generally allows states to develop their own rules.12

The Farm Bill makes available to states various new options that are 

intended to simplify food stamp program rules, streamline food stamp 

eligibility and benefit rules, and help ensure that food stamp participants 

experience as smooth a transition from welfare to work as possible. (See 

fig. 1.) 

 11See GAO, Means-Tested Programs: Determining Financial Eligibility Is Cumbersome 

and Can Be Simplified, GAO-02-58 (Washington, D.C. Nov. 2001) for a comprehensive 

discussion of the overlap and complexities in financial eligibility rules for 11 federal 

assistance programs, and the cumbersome effect for both caseworkers and participants. 

12TANF regulations require that states report information such as the type and amount of 

assistance received, work participation activities, and earned and unearned income. The 

regulations do not specify how the states collect such information. (45 CFR 265.) States set 

their own income limits for eligibility purposes. 

Options Made Available by 

the Farm Bill 
Page 10 GAO-04-916 Food Stamp Program 

Figure 1: Description and Purpose of Farm Bill Options 

a

In addition to having these eight options, states also have the option, on a pilot basis, to test issuing 

standardized benefits to residents of certain group homes, such as facilities for the disabled or that 

operate drug or alcohol treatment programs. The standardized benefit would be in lieu of the regular 

food stamp benefit and would be developed by the state, taking into account the food stamp benefits 

typically received by residents of the covered group facilities. 

b

The Farm Bill refers to this option as Simplified Determination of Housing Costs. 

Farm Bill optionsa Description and purpose of Farm Bill option What the Farm Bill option changed

Sources: Food and Nutrition Service, Pub. L. No. 107-171; Senate Rpt. No. 107-117 (2001); Art Explosion and Copyright  Corel Corp.

All rights reserved (images).

Expanded

simplified

reporting

Allows states to expand to most food stamp households, 

including unearned income households, the option that sets 

reporting intervals at 4, 5, or 6 months. Participants do not 

have to report any household changes (such as changes in 

income) as long as their income does not exceed 130 

percent of the federal poverty level. 

Simplified reporting was available only for earned income 

households and the reporting interval was set at 6 months.

Simplified standard 

utility allowance

Modifies the standard utility allowance (SUA) option already 

available to states. This new option eliminates the 

requirement to prorate the SUA among households that 

share living space, and allows public housing residents with 

shared meters who are charged for only excess utility costs 

to have the benefit of the SUA as a deduction from income.

Not all households were eligible for the SUA. The exceptions 

included households sharing a living space and not eligible 

for the full value of the SUA, and public housing residents 

who were charged for only excess utility costs.

Simplified definition

of income

Allows states to exclude additional types of income by using 

the same definitions of income as they do in their TANF or 

Medicaid programs.

States had less flexibility to exclude certain types of income 

when determining eligibility in the food stamp program. 

Compared with those in other programs, such as TANF, food 

stamp participants generally had to provide information on 

more types of income.

Simplified

definition

of resources

Allows states to exclude additional types of resources by 

using the same definitions of resources as they do in their 

TANF or Medicaid programs.

States had less flexibility to exclude certain types of 

resources in determining eligibility in the food stamp 

program. Compared with those in other programs, such as 

TANF, food stamp participants generally had to provide 

information on more types of resources.

Transitional food 

stamp benefits

for families

leaving welfare

Allows states to provide up to 5 months of food stamp 

benefits to families that leave welfare without requiring the 

family to reapply or submit additional paperwork. Benefit 

levels are frozen for the transitional period at the level equal 

to the amount received by the household prior to TANF 

termination, with adjustments for the loss of TANF income.

This option expanded a previous option that allowed families 

leaving TANF to receive food stamps for 3 months.

Child support

expense income 

exclusion

Legally obligated child support payments from noncustodial 

parents are counted as an income exclusion when 

determining food stamp eligibility.

Legally obligated child support payments made to

nonhousehold members were counted as a deduction from 

income when the caseworker determines the benefit level 

but after eligibility for food stamps has already been 

determined.

Simplified

homeless shelter 

costsb

Allows states to use a flat standard deduction from income 

of $143 per month for homeless households with some 

shelter expenses.

States could use a standard deduction up to $143 per 

month.

Simplified

determination

of deductions

Allows states to disregard changes in certain deduction 

amounts, such as child care and medical expenses, during 

certification periods.

This option allows a state to wait to address changes in 

household deductions at the time it undertakes full eligibility 

reviews.
Page 11 GAO-04-916 Food Stamp Program 

States chose four of the Farm Bill options with greater frequency than the 

others. State officials gave reasons for choosing, or not choosing, the 

options that focused primarily on how they thought the options would 

affect food stamp participants and caseworkers. Other reasons were also 

important in the choice of some options. For example, the anticipated 

effect on the state’s payment error rate was a key factor in the selection of 

most options. During the period when states were implementing the food 

stamp options, a number of them posed challenges for the states, such as 

difficulties related to caseworkers’ adjustment to program changes and 

programming computer systems. 

According to our survey of state food stamp administrators, 23 or more 

states had implemented four of the options as of January 2004, while less 

than one-quarter of the states had implemented the other four options. 

(See fig. 2. Also see app. II for the options that individual states have 

chosen and implemented.) 

States Chose Some 

Farm Bill Options 

More Frequently than 

Others to Simplify 

Program Rules and 

Ease the 

Administrative 

Burden for 

Participants and 

Caseworkers 

States Were Most Likely to 

Choose Four of the 

Options 
Page 12 GAO-04-916 Food Stamp Program 

Figure 2: Number of States That Have Chosen, Implemented, or Not Chosen Farm 

Bill Options, as of January 2004 

Notes: 

The Simplified Homeless Shelter Costs “chosen and implemented” category only includes states that 

indicated they did not have a Standard Homeless Shelter Allowance of $143 prior to the Farm Bill. 

The “not chosen” category for this option includes 21 states that indicated they already had a 

Standard Homeless Shelter Allowance of $143 prior to the Farm Bill. One state did not respond to 

Simplified Homeless Shelter Costs status item. 

One state did not respond to the Expanded Simplified Reporting status item. 

0

10

20

30

40

50

Not chosen

Chosen, not yet implemented

Chosen and implemented

Source: GAO analysis of survey data.

Number of states

Options

33

24

30

23

12

7

4 4

9

7

12 12

27

35

44 45

8

9 20

16

12

9

3 1

Simplified homeless

shelter costs

Simplified

determination

of deductions

Child support expense

income exclusion

Transitional

benefits

Simplified definition

of resources

Simplified definition

of income

Simplified standard

utility allowance

Expanded

simplified

reporting
Page 13 GAO-04-916 Food Stamp Program 

The most common reasons state officials gave for choosing the eight 

options were to simplify program rules for participants and caseworkers, 

according to our survey. For example, state officials we interviewed told 

us they thought program rules would be less confusing for participants if 

the types of income considered in eligibility determinations were more 

uniform across assistance programs, as is allowed by the Simplified 

Definition of Income option. In addition, officials in one state commented 

that they thought the Simplified Standard Utility Allowance option would 

make the rules less complicated for caseworkers because it would allow 

them to apply the standard utility allowance—a fixed amount that can be 

used in place of actual utility costs—to households sharing a residence, 

instead of having to prorate the actual utility costs of the household. (See 

fig. 3 and app. III for more detail on reasons states chose options.) 

The Reasons States Gave 

for Choosing Options Were 

Largely Based on the 

Anticipated Effects on 

Participants and 

Caseworkers 
Page 14 GAO-04-916 Food Stamp Program 

Figure 3: Important Reasons for Choosing Options 

a

Simplified Homeless Shelter Costs option only includes states that indicated they did not have a 

Standard Homeless Shelter Allowance of $143 prior to the Farm Bill. 

b

We only asked the child support item for the Child Support Expense Income Exclusion option. 

In addition, two important reasons state officials gave for choosing 

options were to decrease the burden on participants and decrease the 

workload for caseworkers, as shown in figure 3. For example, several state 

officials told us they thought options such as Simplified Homeless Shelter 

Costs and Simplified Standard Utility Allowance that allow states to use a 

Simplify rules for 

caseworkers

Simplify rules for 

participants

Decrease 

workload for 

caseworkers

Decrease burden 

on participants

Increase benefit 

amounts for 

participants

Options

(Number of states chosen and implemented option)









































 









 











Expanded

simplified

reporting

Simplified

standard utility

allowance

Simplified

definition of

income

Simplified

definition of

resources

Transitional

benefits

Simplified

determination

of deductions

Simplified

homeless

shelter costsa

Child support

expense income

exclusion

(N = 33) (N = 30) (N = 24) (N = 23) (N = 12) (N = 4) (N = 4) (N = 7)

Decrease

error rate

Increase overall 

participation

Increase 

participation

of working families

Ease alignment of 

Food Stamp 

Program with TANF 

and/or Medicaid

Encourage 

payment of child 

supportb

= Important reason states chose this option

Sources: GAO analysis of survey data; Art Explosion and Copyright  Corel Corp. All rights reserved (images).



























Participant and caseworker reasons

Other reasons
Page 15 GAO-04-916 Food Stamp Program 

standard allowance rather than actual costs in determining eligibility 

would provide relief for participants and caseworkers. When standard 

allowances are used, participants do not have to furnish proof of all actual 

costs and, correspondingly, caseworkers have less information to verify.13

In addition, some state officials told us that they thought an option, such 

as Transitional Benefits, that decreases the frequency with which 

participants must report changes would reduce workload. Under the 

Transitional Benefits option, households leaving TANF are automatically 

allowed up to 5 months of food stamp benefits and are not required to 

report changes in household circumstances during the transitional period. 

Other reasons were also important in the choice of some options. 

Lowering their state’s payment error rate was an important reason state 

officials gave for choosing seven of the options, including the Expanded 

Simplified Reporting option. States choosing this option are held 

responsible only for errors that result from miscalculating benefits at 

certification, or if income exceeds 130 percent of poverty and the change 

is not reported during the reporting period. A state’s error rate is also not 

affected if the household experienced a change in its circumstances that it 

did not report. In addition, officials in one state told us they thought the 

Transitional Benefits option would lower the state’s payment error rate 

because it allows for certain periods in which states are to be held 

harmless for unreported changes. Otherwise, these unreported changes 

could be included in calculating the error rate. Further, officials told us 

that the income option would make the Food Stamp Program less error 

prone because it allows states to use some of the same income definitions 

that are used when determining eligibility for TANF cash assistance or 

Medicaid. This alignment of income definitions may result in fewer errors 

because following one set of program rules is easier for participants and 

caseworkers than trying to adhere to many different sets of rules. 

Increasing participation in the Food Stamp Program, including 

participation of working families, was also an important reason for 

choosing three of the options. For example, officials in one state told us 

that they believed the Expanded Simplified Reporting option would 

contribute to higher participation rates because cases would not be closed 

as often under this option. In addition, state officials reported that they 

thought the Child Support Expense Income Exclusion option would help 

 13Homeless households may have shelter costs for a variety of reasons, for example, if they 

pay to board with a family member or at a homeless shelter. 
Page 16 GAO-04-916 Food Stamp Program 

more households to receive food stamps by making it easier for them to 

meet eligibility requirements. This option allows states to exclude legally 

obligated child support payments from the gross income of the 

noncustodial parent who is paying the child support when determining 

food stamp eligibility. Without the option, these child support payments 

are deducted from the noncustodial parent’s income after eligibility for 

food stamps is already determined.14

State officials we surveyed gave additional reasons for choosing some 

options, including the desire to align food stamps with other assistance 

programs, increase benefit amounts for participants, and encourage 

payment of child support. Aligning the Food Stamp Program’s definition of 

income and resource rules with those used by TANF or Medicaid—that is, 

conforming the definitions of income and resources states use in the Food 

Stamp Program to the definitions they use in their TANF or Medicaid 

program—was an important reason for choosing the income and 

resources options. Increasing benefit amounts for participants was an 

important reason for choosing some options, including Transitional 

Benefits. Officials in one state told us they thought this option would 

result in greater benefit amounts for households leaving TANF because the 

new income that rendered them ineligible for TANF is not included in the 

calculation of their benefit amount for the transitional period. If this 

additional income were taken into account, it would most likely result in a 

lower benefit amount. Finally, among other reasons, state officials chose 

the Child Support Expense Income Exclusion option because they thought 

it would encourage payment of child support. 

State officials gave a number of reasons for not choosing options. Among 

the most common was their belief that the option would complicate rules 

for participants and complicate rules for caseworkers in their state. 

Because of the variability among states in the design of Food Stamp 

Programs and other assistance programs, an option that simplified 

processes in one state may have a different effect in other states. For 

example, officials in two states commented that they thought the 

Simplified Determination of Deductions option might confuse participants 

and caseworkers because it would create additional, and sometimes 

 14Deductions are subtracted from the household’s gross income to determine net income. 

Deductions include household expenses such as those for shelter, utilities, and medical 

care. Absent the option, the amount paid for child support would be deducted as a 

household expense. 

The Reasons States Gave 

for Not Choosing Options 

Were Primarily Related to 

Anticipated Effects on 

Participants and 

Caseworkers and Other 

Aspects of the Program 
Page 17 GAO-04-916 Food Stamp Program 

conflicting, participant reporting rules in their state. As one state official 

noted, this option, which allows states to disregard reported changes in 

certain deductions during the certification period, could be confusing for 

caseworkers because of its inconsistency with her state’s policy to act on 

all reported changes. (See fig. 4. Also see app. III for more detail on 

reasons states did not choose options.) 

Figure 4: Important Reasons for Not Choosing Options 

Note: Data for Simplified Homeless Shelter Costs option are not available. 

State officials gave additional reasons for not choosing some of the 

options. An important reason for not choosing two of the options was that 

officials believed the options would result in little or no increase in the 

amount of food stamp benefits for participants in their state. For example, 

officials in several states noted that according to their calculations, 

implementing the child support option would not increase food stamp 

Options

(Number of states that did not choose option)

Expanded

simplified

reporting

Simplified

standard utility

allowance

Simplified

definition of

income

Simplified

definition of

resources

Transitional

benefits

Simplified

determination

of deductions

 = Important reason states did not choose this option

Sources: GAO analysis of survey data; Art Explosion and Copyright  Corel Corp. All rights reserved (images).

Child support

expense income

exclusion

(N = 9) (N = 12) (N = 7) (N = 12) (N = 27) (N = 44) (N = 35)

Complicate rules 

for caseworkers

Complicate rules 

for participants

Little or no increase 

in benefit amounts

Very few 

participants 

affected









 







 

Participant and caseworker reasons

Other reasons

Little or no 

advantage over 

current policy

Increase

error rate

Too difficult to 

program computer










Page 18 GAO-04-916 Food Stamp Program 

benefit amounts for participants in their state who pay child support. In 

addition, some state officials commented that they did not choose the 

deductions option, which allows states to disregard reported changes in 

certain deductions during the certification period, because they believed 

the option could prevent participants from receiving additional benefits if 

their expenses increased during this period. 

State officials also reported an important reason they did not choose three 

of the options was because of their belief that the options would affect 

very few participants in their state. For example, some state officials 

reported that the number of households that would be helped by the 

Transitional Benefits option in their state would be relatively small 

because their state had implemented simplified reporting systems that 

provided similar advantages, such as allowing households to forgo 

reporting most changes between scheduled reporting periods. Similarly, 

officials in one state commented that they thought the child support 

option would not increase the number of eligible households in their state 

because many of the affected households would already be categorically 

eligible for food stamps. 

In addition, an important reason state officials gave for not choosing five 

of the options was that they thought the options would have little or no 

advantage over current policy in their state. For example, officials in some 

states commented that the income and resources options would not allow 

them much additional flexibility in their Food Stamp Program definitions 

because FNS placed restrictions on the types of incomes and resources 

that could be excluded under these options, while one other state official 

noted that before these options became available, they had already largely 

aligned TANF and Medicaid definitions of resources with those used by 

the Food Stamp Program. In addition, other state officials told us the 

deductions option would be duplicative in their state because they had 

already implemented simplified reporting options that exempt 

participating households from reporting changes in the deductions 

covered by this option during the certification period. 

Other reasons were important for not choosing some options, including a 

possible increase in the state’s payment error rate or the difficulty in 

programming the state’s computer system to implement the change. 

Officials in some states said they thought the Expanded Simplified 

Reporting option might increase the payment error rate in their state. 

Simplified reporting systems reduce the frequency with which households 

must report changes, which may make the reporting rules of food stamps 

different from those of other assistance programs in the state that require 
Page 19 GAO-04-916 Food Stamp Program 

households to report changes on a more regular basis. These differences 

in reporting rules could lead to errors by participants and caseworkers, 

who often determine eligibility for more than one assistance program. In 

addition, some state officials reported that they did not choose the 

Transitional Benefits option because the required changes would be too 

difficult to program into their state’s computer systems. Food stamp 

computer systems in many states are integrated with other assistance 

programs, such as TANF and Medicaid. 

In states that did choose specific options, a number of these options posed 

challenges for the states during initial implementation. Reported 

challenges included difficulties related to caseworkers’ adjustment to 

program changes, lack of alignment with other assistance programs, and 

programming state computer systems. For example, officials in one state 

told us caseworkers had trouble adjusting to the new reporting system 

under Simplified Determination of Deductions because many were 

accustomed to the former system in which participants reported, and 

caseworkers acted on, changes in some household deductions within 

10 days of the change. In addition, state officials told us some options, 

such as Expanded Simplified Reporting, lessened the degree to which 

Food Stamp Program rules aligned with those of other assistance 

programs, which also presented challenges. Food stamp officials in one 

state told us they selected the Expanded Simplified Reporting option even 

though they knew it was going to result in food stamp reporting rules that 

were different from those of another assistance program because they 

thought the option would have many benefits for participants. Finally, 

difficulties with programming computers were commonly mentioned 

challenges to implementation. We heard from officials in two states that 

had implemented the Transitional Benefits option that this integration 

posed difficulties for them. These officials reported that they had to delink 

the connection with other programs so that the food stamp benefit 

remained frozen during the 5-month transitional period, regardless of the 

information recorded in the computer system for the other assistance 

programs. Officials from seven states provided cost estimates for 

implementing the options. The cost estimates ranged from $14,880 to 

$3.7 million, almost all of which, in six of the states, represented the costs 

of changing the state’s computer system. These estimates included costs 

for such expenses as programming and testing the computer systems. 

Other states did not provide estimates for the costs of implementing the 

options. 

Implementation 

Challenges for States 

Choosing Certain Options 
Page 20 GAO-04-916 Food Stamp Program 

Local food stamp officials, who often have day-to-day contact with 

frontline caseworkers and food stamp participants, reported mixed results 

from implementing the Farm Bill options; the results ranged from 

improvements to complications. They reported that most of the options 

achieved at least some of the improvements anticipated by state officials. 

However, in a number of cases, local officials reported that the options did 

not result in expected improvements, or their opinions differed on 

whether the option achieved the anticipated result. Finally, local officials 

reported that three options introduced complications in program rules for 

both caseworkers and participants. 

Local food stamp officials reported on our survey that the options resulted 

in some, but not all, of the improvements anticipated by state officials. The 

officials’ views were mixed on whether the administrative burden was 

reduced for program participants and caseworkers. For example, many 

local officials reported that the options reduced paperwork for 

participants. However, officials were less likely to report that the options 

reduced the actual time participants spent applying for food stamps or 

reporting changes in household circumstances. In addition, some local 

officials reported that participation increased as a result of implementing 

options intended to increase participation, while others told us that those 

options had no effect on participation. Similarly, for the two options 

expected to increase alignment of program definitions with TANF and 

Medicaid, most officials agreed that these options made the definitions of 

income and resources the same as in TANF, but officials’ opinions differed 

on whether the options helped increase alignment with Medicaid.15

Local food stamp supervisors reported mixed results on whether the 

options eased the administrative burden on participants—a primary 

reason that states chose most of these options—as measured by both the 

amount of paperwork required and the time spent applying for food 

stamps and reporting changes.16 These local officials reported on our 

survey that the Expanded Simplified Reporting option eased the 

 15States provided a reason for selecting the Child Support Expense Income Exclusion 

(encourage payment of child support) option that we did not measure at the local level. 

16This section excludes a discussion of the effects of the Simplified Homeless Shelter Costs 

option because the majority of local officials we surveyed indicated that they were already 

using a food stamp policy that allowed them the same homeless shelter cost deduction as 

this Farm Bill option. 

Local Food Stamp 

Officials Reported 

Mixed Results for 

Farm Bill Options; 

These Results Ranged 

from Improvements 

to Complications 

Local Food Stamp Officials 

Reported the Options 

Achieved Some, but Not 

All, Anticipated 

Improvements 

Administrative Burden on 

Participants 
Page 21 GAO-04-916 Food Stamp Program 

administrative burden on participants, particularly those who do not 

receive benefits from other assistance programs, by decreasing the time 

needed to prepare paperwork and report changes in their household 

circumstances.17 (See fig. 5.) For five other options, local officials differed 

in their views; some reported that the administrative burden on 

participants decreased while others reported no change. These five 

options are Simplified Standard Utility Allowance, Simplified Definition of 

Income, Simplified Definition of Resources, Transitional Benefits, and 

Simplified Determination of Deductions. For example, about the same 

number of local officials reported that the Transitional Benefits option 

decreased the administrative burden on participants as reported that it 

remained the same. Further, most local officials from states that adopted 

the deductions option reported that the administrative burden under this 

option remained the same for participants. This may be because three of 

the four states that implemented this option also implemented Expanded 

Simplified Reporting, which already decreased the administrative burden 

for participants in a similar way. 

 17It is likely that many local officials reported improvements that pertain to all households 

covered by the Expanded Simplified Reporting option, that is, earned-income and most 

other food stamp households, including unearned-income households. 
Page 22 GAO-04-916 Food Stamp Program 

Figure 5: Results Reported by Local Officials on Administrative Burden for Participants and Caseworkers 

Although five of the Farm Bill options—Expanded Simplified Reporting, 

Simplified Standard Utility Allowance, Simplified Definition of Income, 

Simplified Definition of Resources, and Simplified Determination of 

Deductions—were chosen by state officials to ease the administrative 

burden on caseworkers, local officials reported that most of these options 

had little effect on reducing the administrative burden on the caseworkers. 

(See fig. 5.) Overall, local officials reported no effect on the number of 

contacts with participants and time spent with participants during those 

contacts. However, local officials reported some reduction in the time 

spent on paperwork. For example, local officials told us that the utility 

option reduced the amount of time caseworkers spent on paperwork 

Administrative Burden on 

Caseworkers 

Indicates an improvement reported by most officials, i.e., decreased administrative burden

Indicates no change reported by most officials

Indicates about the same number of officials reported an improvement as reported no change

Indicates that this was not an important reason states chose this option

Sources: GAO analysis of survey responses from local food stamp officials; Art Explosion and Copyright  Corel Corp.

All rights reserved (images).

—

Participants

Amount of 

paperwork 

required

Time spent 

applying for 

or reporting 

changes for 

food stamps

Caseworkers

Time spent 

on paperwork

Number of 

contacts with 

participants

Time spent 

with 

participants 

during 

contacts

Administrative

burden

Expanded

simplified

reporting

Simplified

standard utility

allowance

Simplified

definition of

income

Simplified

definition of

resources

Transitional

benefits

Simplified

determination

of deductions

Child support

expense income

exclusion

—

—

—

—

—
Page 23 GAO-04-916 Food Stamp Program 

because they no longer had to conduct an additional complicated 

procedure to determine the correct benefit amount for certain 

participants. (See app. IV for additional details from our surveys regarding 

how Farm Bill options affected participants and caseworkers.) 

Similarly, for options implemented in part to achieve other goals—to 

decrease payment error rate, increase program participation, and increase 

benefit amount—some local officials reported improvements, while others 

told us that the options had no effect. (See fig. 6.) Although about onequarter of local officials reported that they did not know how most Farm 

Bill options affected their payment error rates, some others attributed 

improvements in error rates to two options.18 About half of the local 

officials that responded said that Expanded Simplified Reporting and the 

utility option decreased the error rate, and the other half reported that the 

error rate remained the same. For options that state officials thought 

would increase program participation, local food stamp officials reported 

that the options had little effect on participation. For example, although 

state officials thought that the Child Support Expense Income Exclusion 

option would increase participation, local officials reported that it did not. 

There was no consensus on whether the other two options chosen to 

increase participation—Expanded Simplified Reporting and Transitional 

Benefits—resulted in increased participation. For options that state 

officials thought would increase food stamp benefit amounts, some locals 

reported improvements, while others reported no change. Specifically, 

local officials reported that the utility option increased benefit amounts 

for participants, while about half reported that the income option 

increased benefits and about half reported it did not. 

 18Although some factors, such as the time spent on paperwork, may affect the 

administrative burden on participants and caseworkers, local officials may not have been 

able to relate changes in error rates to specific options because local officials are not 

immediately aware of whether an error has occurred (when determining eligibility and 

benefits). Moreover, according to an official at FNS, 4 months elapse between collecting 

the information for the payment error rate analysis and when FNS reports the payment 

error rate to the states, thus making it even harder for local officials to tie changes in error 

rates to specific options. 

Payment Error Rate, Program 

Participation, Benefit Amount, 

and Program Alignment 
Page 24 GAO-04-916 Food Stamp Program 

Figure 6: Results Reported by Local Officials on Error Rate, Participation, Benefit Amount, and Alignment 

a

We did not measure this item at the local level. 

Most local officials reported increased alignment of the definitions of 

income and resources between food stamps and TANF from the income 

and resources options. States selected these two options in part to 

increase alignment by making these definitions the same in their Food 

Stamp Program and TANF. For example, local food stamp officials from 

one state we visited told us that aligning the definition of income under the 

income option eliminated a food stamp form that was not required for 

TANF or Medicaid. This form was used to verify loans from educational 

institutions, such as community colleges, regarding the amount and 

duration of the loan. They told us that obtaining this information from 

educational institutions could take a month and possibly require several 

Program

administration

Expanded

simplified

reporting

Simplified

standard utility

allowance

Simplified

definition of

income

Simplified

definition of

resources

Transitional

benefits

Simplified

determination

of deductions

Indicates an improvement reported by most officials, i.e., decreased error rate, increased participation, 

increased alignment

Indicates no change reported by most officials

Indicates about the same number of officials reported an improvement as reported no change

Indicates that this was not an important reason states chose this option

Sources: GAO analysis of survey responses from local food stamp officials; Art Explosion and Copyright  Corel Corp.

All rights reserved (images).

Child support

expense income

exclusion

—

—

a

a

—

—

—

—

—

—

—

—

Error rate

Error rate

Participation

Overall

For working

families

Benefit amount

Benefit amount

Alignment

With TANF

With Medicaid

—

—

—

—

—

—

—

—

—

—

— — a — —
Page 25 GAO-04-916 Food Stamp Program 

follow-up contacts with the institution. This decrease in paperwork for 

both participants and some caseworkers demonstrates one benefit from 

increased alignment. However, on our survey, officials’ opinions differed 

on whether the income and resources options helped increase alignment 

of definitions between food stamps and Medicaid. 

Local officials may have reported little or no change from certain options 

because they affected relatively few food stamp participants or they did 

not affect caseworkers’ responsibilities. For example, most local officials 

reported that four options—income, resources, transitional benefits, and 

child support—affected less than 20 percent of their caseload. In addition, 

most options made only slight changes to caseworkers’ administrative 

processes, and others may not have affected their processes at all because 

some changes were automatically incorporated into state computer 

systems.19 For example, local officials reported that the child support 

option was automatically incorporated into state computer systems, so 

caseworkers’ responsibilities were not affected by this change. 

Several of the Farm Bill options made only slight changes to existing food 

stamp policy, such as the utility, child support, and Simplified Homeless 

Shelter Costs options. For example, the utility option expanded the 

existing standard utility allowance policy to cover two additional types of 

households that were previously excluded: households sharing a living 

space and public housing residents who were charged for only excess 

utility costs. Also, of the local officials we surveyed on the homeless 

option, the majority indicated that they implemented a similar policy prior 

to its availability under the Farm Bill. 

Many local officials reported on our surveys that three options—Expanded 

Simplified Reporting, Transitional Benefits, and Simplified Determination 

of Deductions—introduced complications in program rules for 

participants and caseworkers. Of these options, the Expanded Simplified 

Reporting option—an option that local officials told us affected most of 

their caseloads—introduced the most serious complications because of 

how it interacts with participant reporting rules for other assistance 

programs. Officials told us that adopting the Expanded Simplified 

Reporting option resulted in Food Stamp Program reporting rules that 

 19We generally found no differences between the responses of local officials in states that 

implemented an option in the first 6 months after it became available and those in states 

that implemented the option later. 

Many Local Food Stamp 

Officials Reported That 

Certain Options 

Introduced Complications 

in Program Rules for 

Participants and 

Caseworkers 
Page 26 GAO-04-916 Food Stamp Program 

differed in important ways from the reporting rules of other assistance 

programs, such as Medicaid and TANF, depending on how their states 

have structured these programs. About one-third of local officials we 

surveyed reported that this option decreased alignment between Food 

Stamp Program reporting rules and those of Medicaid; about one-half 

reported a decrease in alignment with TANF. 

Local officials told us that these differences in reporting rules often 

resulted in confusion on the part of food stamp participants, particularly 

because most participate in other assistance programs. They explained 

that although the caseworkers provided information to help participants 

determine which changes they were required to report (i.e., changes that 

increased their income to over 130 percent of the federal poverty level), 

some participants still reported changes that were not required. According 

to a recent case study, some participants may believe they need to report 

these changes to maintain their food benefits.20 On the other hand, local 

officials told us that some participants think that the new reduced 

reporting requirements apply to other assistance programs in addition to 

the Food Stamp Program. Consequently, some participants do not report 

changes they are required to report for these other assistance programs, 

and in some cases, participants might face interruptions in benefits or 

penalties for not reporting changes for other programs. 

In addition to reporting complications for participants, local food stamp 

officials on our site visits and in telephone interviews told us that different 

participant reporting rules for assistance programs are confusing for 

caseworkers because they are uncertain whether to act on a change for 

the Food Stamp Program when reported for another assistance program. 

Moreover, trying to determine whether to act on a change for the Food 

Stamp Program can cause them to perform additional work. When a 

participant reports a change that is required for Medicaid or TANF,21 but 

not for food stamps, caseworkers must decide whether to act on that 

 20Carole Trippe, Liz Schott, Nancy Wemmerus, and Andrew Burwick, Simplified Reporting 

and Transitional Benefits in the Food Stamp Program—Case Studies of State 

Implementation. Final Report. Mathematica Policy Research, Inc. E-FAN-04-003 May 2004 

(Economic Research Service). 

21In some cases, a change reported by a participant may not result in a change in Medicaid 

or TANF benefits. For example, a person may have a change in income but the change does 

not affect that person’s Medicaid eligibility. 
Page 27 GAO-04-916 Food Stamp Program 

change for the Food Stamp Program.22 Caseworkers, who often determine 

benefits for more than one assistance program, first must decide if a 

change will increase the participant’s food stamp benefit. To make this 

decision, caseworkers typically enter the information into the computer 

system as if they were going to act on the change in order to determine if 

the change will result in an increase in the participant’s food stamp 

benefit. If the caseworker determines that the change reported by the 

participant will increase the participant’s benefit, caseworkers are 

required to act on the change. On the other hand, if the caseworker 

determines that the change reported by the participant will decrease the 

benefit, the caseworker must then determine whether or not to act on this 

change. (See fig. 7 for one example of how this process would work.) FNS 

regulations mandate that states not act on changes that would result in a 

decrease in benefits for participants unless one of three exceptions is met: 

(1) the household voluntarily requests that the case be closed, (2) the 

participant’s TANF (or, in some areas, General Assistance) grant is 

changed, or (3) the information about the change is considered “verified 

upon receipt.”23 A reported change is considered verified upon receipt 

when the information is not questionable and the provider is its primary 

source, such as information about earnings provided by the participant’s 

employer.24 Many local officials suggested that aligning food stamp 

reporting rules with Medicaid and TANF, by making them the same across 

these programs, would help to simplify this process. 

 22Caseworkers can also learn of some changes through an automated process that matches 

participants’ information with other databases, such as a new hire database, that could 

indicate a change in household circumstances that might merit a change in the food stamp 

benefit. 

23These exceptions are noted in current USDA regulations related to Simplified Reporting: 

7 CFR 273.12 (a)(1)(vii)(A). Proposed regulations for Expanded Simplified Reporting 

maintain these same exceptions. 69 Fed. Reg. 20762. 

24Information is considered verified upon receipt when the source is, but is not limited to, 

specific data from the Social Security Administration, data from the U.S. Citizenship and 

Immigration Services, and Unemployment Compensation data from a state agency. 
Page 28 GAO-04-916 Food Stamp Program 

Figure 7: Example of Possible Decisions and Actions under the Expanded Simplified Reporting Option 

a

This example assumes the caseworker is the same for food stamps, TANF, and Medicaid. 

Sources: GAO analysis; Art Explosion and Copyright  Corel Corp. All rights reserved (images).

Participant 

experiences a 

change that is 

required to be 

reported for 

Medicaid or 

TANF but not for 

food stamps.

Participant 

reports change to 

caseworker.a

Caseworker 

reviews change 

for Medicaid or 

TANF.

Caseworker 

determines that 

Medicaid or TANF 

benefit does not 

change.

Caseworker 

calculates 

hypothetical new 

benefit to determine 

if change will 

increase or 

decrease food 

stamp benefit.

Food stamp 

benefit 

increases.

Caseworker acts 

on the change.

Food stamp 

benefit 

decreases.

Caseworker must 

determine if one of 

three exceptions

is met.

Exception 

is not met.

Caseworker does not 

act on the change.

Exception 

is met.

Caseworker acts on 

the change; benefit 

decreases even 

though the change 

was not required to

be reported to the 

Food Stamp Program.

Verified upon receipt

Change affects TANF grant

Participant asks to close 

food stamp case
Page 29 GAO-04-916 Food Stamp Program 

State officials generally believed that the Expanded Simplified Reporting 

option would help states reduce their food stamp payment error rates. 

However, local officials told us that caseworkers’ confusion about the 

reporting rules for different assistance programs could result in improper 

food stamp and other assistance program benefits. A recent case study 

found that caseworkers were concerned that they might make errors in 

benefits because of the complexity of the decision-making process 

involved in determining when to act or not to act on a change.25 Moreover, 

supervisors told us that payment error rates of other assistance programs 

might increase if participants do not report required changes to these 

assistance programs because they believe the Expanded Simplified 

Reporting rules apply to these other programs. 

In an attempt to address these issues, many states have modified this 

option in a way that may undermine some of its benefits. Officials in 17 of 

the 33 states that implemented this option told us that rather than having 

caseworkers decide whether or not to act on a change, they have a waiver 

from FNS that requires caseworkers to act on all changes reported by 

participants, including those that would decrease benefits. Some states 

choosing this waiver did so because acting on some but not all changes 

would require significant reprogramming of their computer systems and 

may be difficult for their caseworkers to understand. However, acting on 

all changes counteracts the potential reduction in workload for 

caseworkers. Further, when the participant reports a change during the 

reporting period, having the waiver does not reduce exposure to errors in 

the way that the option does for states without the waiver. In short, the 

more changes caseworkers make, the more opportunity there is for a 

change to be processed incorrectly. In addition, in certain circumstances, 

a change might result in lower benefits for participants in states with this 

waiver as opposed to states without this waiver.26

In April 2004, USDA proposed some revisions to simplified reporting 

regulations in order to help alleviate some of these complications with this 

waiver.27 USDA proposed that state agencies that have this waiver not be 

required to act on changes a household reports for another public 

 25See Economic Research Service: E-FAN-04-003 May 2004. 

26Specifically, if a participant reports a change that would decrease the benefit but does not 

meet any of the three exceptions as explained on page 28, the change would not be made in 

states without the waiver but would be made in states with the waiver. 

2769 Fed. Reg. 20724-64. 
Page 30 GAO-04-916 Food Stamp Program 

assistance program when the change does not trigger action in that other 

program. For example, if a household receiving food stamps and Medicaid 

reports an increase in income to its Medicaid caseworker that is not 

required to be reported for food stamp purposes, the state agency would 

not have to reduce the household’s food stamp benefit if the income 

change does not affect its Medicaid eligibility or benefits. This proposed 

change would simplify the procedure for caseworkers and, in some cases, 

eliminate the possibility that benefits would be reduced in states with this 

waiver. However, while this proposal addresses issues for caseworkers 

and participants in states with this waiver, we found that local officials in 

states without the waiver were more likely to report that this option 

introduced complications for caseworkers than local officials in states 

with the waiver. 

States have flexibility to align the reporting rules for Medicaid and TANF 

with their food stamp reporting rules available under the Expanded 

Simplified Reporting option, but many have not done so. Although one of 

the three states we visited achieved some alignment of reporting rules 

between TANF and food stamps, none of the three states, despite 

preliminary discussions between Medicaid and food stamp officials, had 

been successful in aligning Medicaid and food stamp reporting rules.28

Food stamp officials in these states told us the discussions had not 

resulted in alignment of reporting rules largely because Medicaid officials 

believed that Medicaid benefit costs could increase. For example, if a 

participant experienced a household change that would not affect the 

participant’s food stamp benefit but would affect Medicaid eligibility, the 

participant might receive Medicaid benefits for longer periods than he or 

she would have under a state’s current reporting rules. Thus Medicaid 

benefit costs could increase. A recent study of four states found that states 

are often reluctant to make changes in policies that may increase TANF or 

Medicaid benefit costs or caseloads, particularly when states experience 

budget shortfalls.29 For example, because states contribute a nationwide 

average of 43 percent to Medicaid benefit costs (while food stamp benefits 

are 100 percent federally funded), increases in Medicaid caseloads or costs 

would place demands on state budgets that increases in food stamp 

 28A recent informal study that gathered information from 12 states that are using the 

simplified or expanded simplified reporting option showed that 3 states have aligned TANF 

and food stamp rules. Upon further clarification, no state has aligned Medicaid and food 

stamp rules. See www.NAPIPM.org (www.napipm.org/simp%20reporting.htm 5/10/04). 

29See Economic Research Service: E-FAN-04-003 May 2004. 
Page 31 GAO-04-916 Food Stamp Program 

caseloads would not. In addition, another report noted that changes to 

rules and procedures typically require that a state reprogram its computer 

to apply the new policies, and these changes may result in increased cost 

to the state.30 However, the extent to which program costs might increase 

as a result of alignment is unclear, and in two of the three states we 

visited, state officials had little or no information on possible costs 

associated with implementing such changes.31

A case study also noted that in some states, staff responsible for these 

various benefit programs work in different agencies with varied priorities, 

and there is no incentive to coordinate policy across these programs.32

Finally, an official from HHS’s Centers for Medicare and Medicaid Services 

(CMS) noted that there are numerous groups of eligible Medicaid 

participants, and many groups, depending on state eligibility rules, may 

receive continuous eligibility for 12 months.33 For these participants, 

reporting on a 6-month schedule for Medicaid would not be appropriate. 

Two additional options introduced complications in program rules, though 

to a lesser extent. Some local officials reported that the Transitional 

Benefits option introduced complications for the caseworkers, again 

because of interactions between this option and other assistance 

programs. For example, transitional benefits from Medicaid are for 

persons transitioning to work and are provided for up to 1 year. On the 

other hand, transitional food stamp benefits are for persons leaving TANF 

and are granted for a maximum of 5 months. In addition, program experts 

told us that reporting rules for the two types of transitional benefits are 

not aligned, and this creates an additional administrative burden for 

caseworkers. Medicaid requires persons receiving transitional benefits to 

report household financial circumstances at the 4th, 7th, and 10th month 

of transitional benefits, whereas persons receiving food stamp transitional 

benefits must reapply at the end of the 5th month. About a third of local 

 30Liz Schott, Stacey Dean, Jocelyn Guyer, Coordinating Medicaid and Food Stamps: How 

New Food Stamp Policies Can Reduce Barriers to Health Care Cover for Low-Income 

Working Families. Center on Budget and Policy Priorities, September 2001. 

31One state provided preliminary analysis of estimated costs for aligning reporting rules for 

TANF and child care programs to 6-month reporting for earned-income households only. 

32See Economic Research Service: E-FAN-04-003 May 2004. 

33Federal Medicaid statute identifies over 25 different eligibility categories of persons who 

may be covered under a state Medicaid plan. According to a CMS official, a state could 

have as many as 50 groups of eligible Medicaid participants. 
Page 32 GAO-04-916 Food Stamp Program 

officials reported that they would like transitional food stamp benefits to 

be available for 6 months or to be aligned with transitional benefits from 

Medicaid. 

Finally, some local officials reported that the Simplified Determination of 

Deductions option introduced complications for the participants and the 

caseworkers. For example, local officials told us that this option 

complicates decisions about whether to act on changes reported by 

participants. Local officials told us that when participants report a change 

that is not required under the deductions option, caseworkers must first 

determine if the household is subject to reporting rules under Expanded 

Simplified Reporting or not. If the household falls under Expanded 

Simplified Reporting, the caseworkers must follow the decision-making 

process for Expanded Simplified Reporting depicted in figure 7 above. If 

the household does not fall under Expanded Simplified Reporting and the 

change is to a deduction from household income, the caseworkers must 

not act on the change. 

Since the late 1990s, and most recently in the Farm Bill, the Congress and 

FNS have offered states a number of options to simplify and streamline the 

administration of the Food Stamp Program. These options presented 

states with additional opportunities to tailor their Food Stamp Programs 

to the social and economic needs of their own states. Moreover, these 

changes coincided with actions taken by the Congress to grant states 

considerable flexibility in the design and administration of other key 

assistance programs, such as TANF and Medicaid, and the growing 

realization that the Food Stamp Program provides crucial support to lowincome working families. 

Local officials, who have day-to-day contact with frontline caseworkers 

and food stamp participants, reported mixed results from implementing 

the options. Although they reported some improvements for both 

caseworkers and participants from some options, no option received 

consistently positive reports in all the areas where state officials expected 

improvements when they selected the option. In fact, in many cases, 

officials were as likely to report that an option resulted in no change as 

they were to report improvements. This may be due in part to the fact that 

the Farm Bill options made only slight changes to policy and, as reported, 

affected relatively few program participants. 

Of all the options, the Expanded Simplified Reporting option offered the 

most promise because it was selected by the most states, affects a large 

Conclusions 
Page 33 GAO-04-916 Food Stamp Program 

number of participants, and has the potential to significantly streamline 

the participant reporting process. The fact that local officials reported that 

adopting this option actually complicated program rules in many states 

reflects the challenge of trying to simplify requirements for one program 

without efforts by states to adjust the rules of other related assistance 

programs. This is particularly relevant because most food stamp recipients 

also participate in other assistance programs. The reported complications 

resulted in problems, such as confusion for the caseworker and a possible 

increase in payment errors. In response, many states adopted a waiver that 

negated many of the potential benefits of Expanded Simplified Reporting 

for caseworkers and participants. Although USDA proposed a change to 

this waiver, the change will not address the complications reported by 

local officials in states without the waiver. Moreover, neither the waiver to 

act on all changes nor USDA’s proposed change to the waiver will address 

overall alignment issues related to reporting rules among various 

assistance programs. 

Although federal law and program rules allow states to align participant 

reporting rules among assistance programs, state officials in most states 

have not made the broad changes that would result in greater consistency 

among programs. Concerns regarding whether there are costs associated 

with aligning participant reporting requirements may hinder a state’s 

decision to make program changes that increase alignment. These 

concerns may include the cost of programming changes into state 

computers and the concern that benefit costs may increase in those 

programs that require a higher proportion of state funds, such as the 

Medicaid program. On the other hand, savings could result from reducing 

the administrative burden on caseworkers. Yet it is unclear whether costs 

would rise or savings would be realized. In addition, aligning Medicaid 

reporting rules with food stamp rules may work for some groups of 

Medicaid participants, but not others. Although alignment of state program 

rules may not be advantageous in every circumstance, many government 

officials told us that they were interested in improved alignment. In 

general, increased alignment remains important to simplification and ease 

of service delivery. 

In order to take advantage of existing opportunities available to states for 

streamlining participant reporting rules, we recommend that the Secretary 

of Agriculture direct FNS to collaborate with HHS to take the following 

two actions: 

Recommendations for 

Executive Action 
Page 34 GAO-04-916 Food Stamp Program 

1. Encourage state officials to explore the advantages and 

disadvantages—in terms of both administrative and benefit costs and 

savings—of better aligning participant reporting rules in their states, 

particularly for Medicaid and TANF, and 

2. Disseminate information and guidance to states on the opportunities 

available for better aligning participant reporting requirements among 

food stamps, Medicaid, and TANF. 

We provided a draft of this report to the U.S. Department of Agriculture 

for review and comment and on August 20, 2004, we met with FNS 

officials to get their comments. The officials said they agreed with our 

findings, conclusions, and recommendations. They stated that they are 

interested in helping states better align their participant reporting 

requirements and that they plan to contact HHS to initiate discussions on 

ways to help states align these reporting requirements. They also said they 

plan to provide best practices information to states regarding the 

administration of the Food Stamp Program and that they would explore 

disseminating information on any progress states have made in 

streamlining their participant reporting rules. FNS provided us with 

technical comments, which we incorporated where appropriate. 

We are sending copies of this report to the Secretary of Agriculture, 

appropriate congressional committees, and other interested parties. We 

will also make copies available to others upon request. In addition, the 

report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. Please contact me at (202) 512-7215 if you or your 

staffs have any questions about this report. Major contributors to this 

report are listed in appendix V. 

Sigurd R. Nilsen 

Director, Education, Workforce, and 

 Income Security Issues 

Agency Comments 
Appendix I: Objective, Scope, and 

Methodology 

Page 35 GAO-04-916 Food Stamp Program 

To accomplish our research objectives, we surveyed state food stamp 

administrators and local food stamp supervisors on the implementation of 

the Farm Bill food stamp options. To augment information from our state 

and local surveys, we conducted three comprehensive site visits (Arizona, 

Maryland, and Michigan) and two semi-structured telephone interviews 

(Colorado and South Carolina). We chose states for our site visits and 

telephone interviews to capture variation in the following criteria: (a) 

number of and type of selected options, (b) number of food stamp 

participants and program participation rate, (c) program error rate, and 

(d) entity (state or county) administering the Food Stamp Program. During 

each visit we met with state officials administering and developing policy 

for the Food Stamp Program, local officials in the office where services 

are provided, and officials responsible for other key assistance programs, 

such as Temporary Assistance for Needy Families (TANF) and Medicaid. 

We also reviewed Farm Bill legislation and related committee reports, and 

we reviewed Food and Nutrition Service (FNS) reports and other program 

analysis. We held discussions with program stakeholders, including 

officials at FNS headquarters and regional offices, representatives of 

advocacy organizations, and other program experts. We performed our 

work from August 2003 to June 2004 in accordance with generally 

accepted government auditing standards. 

To learn about state-level use of the food stamp options made available 

under the Farm Bill, we conducted a Web-based survey of food stamp 

administrators in the 50 states and the District of Columbia. For each of 

the eight Farm Bill options, we asked state officials to provide information 

on whether or not their state had chosen and implemented the option, 

reasons for choosing (or not choosing) the option, program challenges in 

implementing the option, changes because of the options, and potential 

improvements to the option. In addition, we asked for other information, 

including cost estimates for implementing the options, estimates of time 

and cost savings as a result of implementing the options, efforts to align 

the Food Stamp Program with TANF and Medicaid, and other food stamp 

options states had implemented prior to the Farm Bill. We administered 

the survey between December 9, 2003, and January 30, 2004. We also 

contacted some respondents via phone or e-mail to clarify their responses 

after the Web survey was completed. Food stamp administrators in all 

50 states and the District of Columbia participated in the survey, for a 

response rate of 100 percent. To view selected results of GAO’s Web-based 

survey of food stamp adminstrators, go to 

www.gao.gov/cgi-bin/getrpt?GAO-04-1058SP. 

Appendix I: Objective, Scope, and 

Methodology 

Survey of State Food 

Stamp Administrators 
Appendix I: Objective, Scope, and 

Methodology 

Page 36 GAO-04-916 Food Stamp Program 

We believe the state survey data are sufficiently reliable to be used for the 

applicable questions of our work. We pretested the survey with several 

state Food Stamp administrators and modified the survey to take their 

comments into account. We also compared our survey responses on which 

of the states had implemented the options with information published by 

FNS and found our data had a reasonable level of consistency with the 

agency’s data, with the exception of data for the Simplified Homeless 

Shelter Costs option. Our analysis indicated fewer states had implemented 

this option than are listed in the FNS report. The cause of the discrepancy 

is that many states were already using a homeless shelter allowance of 

$143 prior to the Farm Bill, and many of these states are included in the 

information published by FNS as having implemented the Farm Bill 

option. However, for the purposes of our study, we decided to limit our 

analysis to only those states that implemented the homeless shelter 

allowance of $143 after the Farm Bill became effective. 

To learn about local-level use of the Farm Bill options, we administered 

1,328 mailed surveys to supervisors in local food stamp offices in the 

states that had implemented the options. These survey results are 

generalizable to local offices in states that implemented the options. We 

conducted a separate survey for each of the eight options and used a 

separate sample for each of the surveys. On all eight surveys, we asked 

supervisors in local offices for their opinions about the extent to which the 

Farm Bill option had affected change in several areas of the Food Stamp 

Program, including administrative burden on participants and 

caseworkers, the error rate, program participation, and alignment with 

other assistance programs. In addition, we asked the supervisors for their 

opinions about the proportion of the local office’s food stamp caseload 

that was affected by the option and changes the local office officials would 

like to see to the option. To view the results from the local food stamp 

office surveys, go to www.gao.gov/cgi-bin/getrpt?GAO-04-1059SP. 

We chose to survey food stamp supervisors because we believed they 

would be aware of the changes for participants and caseworkers resulting 

from the Farm Bill options. We collected the opinion of these supervisors 

because we did not find existing data on the information we needed to 

complete the objectives of this study, including the number of food stamp 

recipients affected by each option and the time costs or savings for food 

stamp participants and caseworkers because of the implementation of the 

options. We conducted the surveys between December 2003 and April 

2004. We also contacted some respondents via phone or e-mail to clarify 

their responses after the mailed survey was completed. 

Survey of Local Food 

Stamp Supervisors 
Appendix I: Objective, Scope, and 

Methodology 

Page 37 GAO-04-916 Food Stamp Program 

For each Farm Bill option, the population of interest was the set of all 

local food stamp offices located in states that adopted the option. Because 

we could not survey the entire population of local offices, we selected a 

sample of local offices to be representative of this population of interest. 

In each sample, the sampling unit is the local food stamp office. To 

determine the eight samples, we contacted state and county food stamp 

officials to compile a complete mailing list of food stamp offices in the 

50 states and the District of Columbia. We compiled our own list because 

we were unaware of any other such comprehensive list. From these lists of 

local offices, we selected a simple random sample of local offices located 

in states that, according to information provided by FNS, had already 

implemented the option.1

 For example, if the FNS report indicated 

12 states had implemented an option, we drew the sample for that option 

from the combined list of the local offices in those 12 states. 

Since many states had chosen multiple options, we capped the number of 

surveys a local office could receive at three in order to minimize response 

burden. Only one local office was randomly selected to receive more than 

three surveys. To make sure this office did not receive more than three 

surveys, we randomly selected two of the five options for which we had 

drawn this office. We then randomly selected two replacement offices to 

receive the surveys. To select the replacement offices, we used the 

remaining offices on the list. 

Because we surveyed a random sample of local food stamp offices, our 

results are estimates of the responses we would have received had we 

surveyed the entire population of interest, and are thus subject to 

sampling errors. We are 95 percent confident that each of the confidence 

intervals in the local survey results will contain the true values of the 

population of interest. All percentage estimates from the local survey have 

sampling errors of plus or minus 10 percentage points. We calculated 

confidence intervals for our local survey results using methods that are 

appropriate for probability samples of this type. 

 1

We used draft information provided by FNS, which we later supplemented with 

information from its October 2003 report, released in November 2003: United States 

Department of Agriculture, Food and Nutrition Service, Food Stamp Program: State 

Options Report, Third Edition, October 2003. The FNS State Options Report was the only 

source of which we were aware at that time that listed which states had implemented the 

option. We could not use our state survey data to develop the list of states that had 

implemented the option because we had not completed the state survey at the time we 

needed to draw the sample for the local survey. 

Local Survey Sample Design 

Sampling and Nonsampling 

Errors 
Appendix I: Objective, Scope, and 

Methodology 

Page 38 GAO-04-916 Food Stamp Program 

In addition to sampling errors, the practical difficulties in conducting 

surveys of this type may introduce other types of errors, commonly 

referred to as nonsampling errors. For example, questions may be 

misinterpreted, the respondents’ answers may differ from those in local 

offices that did not respond, or errors could be made in keying completed 

questionnaires or in the preparation of data files for analysis. We took 

steps in the development, collection, and analysis of the local surveys to 

minimize these errors. For example, we pretested each of the eight local 

surveys with at least one local food stamp official prior to mailing the 

surveys. 

The response rates for the eight surveys ranged from 74.0 percent to 

86.1 percent (see table 1 below). Some respondents returned the survey to 

us but indicated that their local office had not implemented the option we 

asked them about or that they implemented the option prior to the date 

the Farm Bill became effective. We refer to these surveys as “out of 

scope.” There are several reasons surveys could be out of scope, including 

the time lag between the FNS report we used to determine our sample and 

the launch of our survey and possible delays in state-level policy decisions 

being implemented on the local level. Given how quickly the status of the 

Farm Bill options can change in states, the number of out of scopes is not 

surprising. In this report we did not use out-of-scope surveys in the 

estimates derived from local survey data. 

We did not use the data we collected from the local survey on the 

Simplified Homeless Shelter Costs option because we had used the FNS 

list of states that had implemented the option to draw our sample, but later 

we learned of the discrepancy between our definition of the option and the 

data provided by FNS that had implemented this option. We concluded our 

sample for this option was flawed and the results should not be used in the 

local survey analysis. 

Response Rates 
Appendix I: Objective, Scope, and 

Methodology 

Page 39 GAO-04-916 Food Stamp Program 

Table 1: Disposition of Eight Farm Bill Option Samples 

Sample 

Farm Bill option Sample Received Out of scopes Response ratea

Expanded simplified reporting 192 157 3 81.5%

Transitional benefits 165 134 10 80.0%

Simplified definition of income 181 152 37 79.9%

Simplified definition of resources 170 141 48 76.2%

Simplified homeless shelter costs 176 

Simplified standard utility costs 179 155 6 86.1%

Simplified determination of deductions 126 100 8 78.0%

Child support expense income exclusion 139 112 35 74.0%

a

The response rates shown in table 1 are calculated using the following formula: 

= Response rate (Total number of responses – Number of out of scopes)

(Total sample size – Number of out of scopes)
Appendix II: Farm Bill Options That States 

Have Implemented as of January 2004 

Page 40 GAO-04-916 Food Stamp Program 

Figure 8: Farm Bill Options States Have Implemented as of January 2004 

a

Simplified Homeless Shelter Costs option only includes states that indicated they did not have a 

Standard Homeless Shelter Allowance of $143 prior to the Farm Bill.

Appendix II: Farm Bill Options That States 

Have Implemented as of January 2004 
Appendix III: Selected Responses to State 

Survey 

Page 41 GAO-04-916 Food Stamp Program 

Figure 9: Number of States That Gave Reasons for Choosing Options 

a

Simplified Homeless Shelter Costs option only includes states that indicated they did not have a 

Standard Homeless Shelter Allowance of $143 prior to the Farm Bill. 

b

We only asked child support item for Child Support Expense Income Exclusion option. 

Appendix III: Selected Responses to State 

Survey 
Appendix III: Selected Responses to State 

Survey 

Page 42 GAO-04-916 Food Stamp Program 

Figure 10: Number of States That Gave Reasons for Not Choosing Options 

Notes: Data for Simplified Homeless Shelter Costs option are not available. 

a

We only asked child support item for Child Support Expense Income Exclusion option. 

Source: GAO survey.

Options

(Number of states chosen and implemented option)

Reasons

Expanded

simplified

reporting

Simplified

standard utility

allowance

Simplified

definition of

income

Simplified

definition of

resources

Transitional

benefits

Simplified

determination

of deductions

Child support

expense income

exclusion

(N = 9) (N = 12) (N = 7) (N = 12) (N = 27) (N = 44) (N = 35)

Computers

Too difficult to program computer system 4 2 1 0 22 17 14

Participants and caseworkers

Would increase workload for

caseworkers 3 2 2 1 13 7 10

Would complicate rules for caseworkers 5 2 3 1 18 19 28

Would complicate rules for participants 5 2 1 2 11 9 26

Little or no increase in benefit amounts

for participants 1 4 4 5 9 20 15

Very few participants would be affected

by change 1 2 5 7 7 18 8

Would increase burden on participants 2 0 0 2 1 0 5

Would not encourage participants to

transition from welfare to work 0 0 1 0 2 2 1

Participation

Would decrease overall participation in

program 0 0 0 0 0 1 0

Would decrease participation of working

families 0 0 0 0 0 1 1

Would decrease participation of elderly

and/or disabled 0 1 0 0 0 0 0

Alignment

Would make it more difficult to align Food

Stamp Program with TANF 2 0 0 0 5 6 9

Would make it more difficult to align Food

Stamp Program with Medicaid 3 0 0 0 3 5 4

Relative advantage

Would have little or no advantage over

policy rules already in place 5 6 5 6 11 23 20

Error rate

Would increase error rate 5 2 0 0 7 12 12

Other reasons

Would decrease application process

timeliness 0 0 0 0 0 1 1

Would not work well with other Farm Bill

options state chose to implement 1 0 0 0 6 2 15

Would raise administrative costs 2 1 0 0 5 3 2

Would not encourage payment of

child support a a a a a 4 a

Other 1 7 1 4 4 3 12
Appendix IV: Selected Responses to Local 

Surveys 

Page 43 GAO-04-916 Food Stamp Program 

Figure 11: Expanded Simplified Reporting 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Appendix IV: Selected Responses to Local 

Surveys 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

reporting changes 13% 48% 32% 5% 3%

Amount of

paperwork required 19% 42% 27% 10% 2%

Participant

simplification

measures

1% 8% 9% 18% 39% 22% 4%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

changes 17% 30% 8% 33% 12%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 9% 48% 33% 9% 2%

Time spent with

participants

during contacts 2% 18% 61% 16% 4%

Time spent on

paperwork

(including

verification) 6% 36% 37% 12% 9%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

16% 47% 29% 7% 1%

Decisions on

whether to apply

changes reported

by participants 4% 18% 31% 27% 20%

Frequency of

benefit calculation
Appendix IV: Selected Responses to Local 

Surveys 

Page 44 GAO-04-916 Food Stamp Program 

Figure 12: Simplified Standard Utility Allowance 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for food

stamps or

reporting changes 1% 25% 71% 3% 0%

Amount of

paperwork required 5% 46% 48% 1% 0%

Participant

simplification

measures

1% 19% 10% 3% 12% 46% 8%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

utility expenses 18% 42% 36% 4% 0%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 3% 20% 73% 4% 0%

Time spent with

participants

during contacts 5% 25% 67% 3% 0%

Time spent on

paperwork

(including

verification) 10% 43% 44% 3% 0%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Decisions on

whether to apply

changes in utility

costs reported by

participants 26% 43% 24% 6% 1%

Calculation of food

stamp benefits 16% 40% 37% 7% 0%
Appendix IV: Selected Responses to Local 

Surveys 

Page 45 GAO-04-916 Food Stamp Program 

Figure 13: Simplified Definition of Income 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for food

stamps or

reporting changes 3% 39% 56% 2% 0%

Amount of

paperwork required 3% 56% 38% 3% 0%

Participant

simplification

measures

0% 62% 16% 5% 9% 6% 2%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

income 8% 56% 27% 7% 2%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 1% 28% 67% 4% 0%

Time spent with

participants

during contacts 1% 30% 62% 7% 0%

Time spent on

paperwork

(including

verification) 7% 47% 41% 4% 1%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Determination

or redetermination

of eligibility 3% 47% 43% 5% 2%

Calculation of food

stamp benefits 6% 46% 42% 5% 2%
Appendix IV: Selected Responses to Local 

Surveys 

Page 46 GAO-04-916 Food Stamp Program 

Figure 14: Simplified Definition of Resources 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for food

stamps or

reporting changes 4% 33% 60% 2% 0%

Amount of

paperwork required 6% 46% 46% 1% 0%

Participant

simplification

measures

0% 55% 18% 6% 12% 9% 1%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

income 10% 46% 39% 4% 1%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 3% 22% 69% 6% 0%

Time spent with

participants

during contacts 2% 28% 62% 8% 0%

Time spent on

paperwork

(including

verification) 9% 44% 44% 3% 0%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Determination

or redetermination

of eligibility 4% 42% 51% 2% 1%

Calculation of food

stamp benefits 3% 33% 62% 1% 1%
Appendix IV: Selected Responses to Local 

Surveys 

Page 47 GAO-04-916 Food Stamp Program 

Figure 15: Transitional Benefits 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for food

stamps or

reporting changes 12% 40% 41% 7% 0%

Amount of

paperwork required 15% 34% 41% 9% 0%

Participant

simplification

measures

5% 77% 14% 2% 2% 0% 1%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

income 16% 35% 30% 15% 4%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 2% 32% 53% 13% 0%

Time spent with

participants

during contacts 3% 20% 68% 9% 0%

Time spent on

paperwork

(including

verification) 14% 19% 41% 21% 4%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Decisions on

whether to apply

changes reported

by participants 15% 22% 26% 29% 7%

Calculation of food

stamp benefits 15% 27% 31% 26% 1%
Appendix IV: Selected Responses to Local 

Surveys 

Page 48 GAO-04-916 Food Stamp Program 

Figure 16: Child Support Expense Income Exclusion 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for

food stamps

0% 0% 84% 16% 0%

Amount of

paperwork required 0% 1% 76% 23% 0%

0% 77% 19% 3% 2% 0% 0%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 0% 3% 83% 15% 0%

Time spent with

participants

during contacts 0% 1% 84% 15% 0%

Time spent on

paperwork

(including

verification) 0% 1% 76% 23% 0%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Determination

or redetermination

of eligibility 0% 5% 81% 14% 0%

Calculation of food

stamp benefits 0% 5% 79% 16% 0%
Appendix IV: Selected Responses to Local 

Surveys 

Page 49 GAO-04-916 Food Stamp Program 

Figure 17: Simplified Determination of Deductions 

Note: These estimates are accurate to within plus or minus 10 percentage points at the 95 percent 

level of confidence. Rows may not sum to 100 percent because of rounding errors. 

Source: GAO survey.

Percentage of food stamp caseload affected 

None

(0%)

Few

(1-19%)

Some

(20-39%)

About half

(40-59%)

Most

(60-79%)

Almost all

(80-99%)

All

(100%)

Changes for food stamp participants 

Participant

administrative

burden measures

Changes for

the participants

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Time spent

applying for food

stamps or

reporting changes 3% 26% 65% 5% 2%

Amount of

paperwork required 4% 35% 57% 3% 2%

Participant

simplification

measures

0% 24% 35% 14% 13% 13% 2%

Changes for

the participants

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Rules related to

reporting or

documenting

deductions 2% 41% 23% 24% 10%

Changes for food stamp caseworkers 

Caseworker

administrative

burden measures

Changes for

the caseworker

Greatly

decreased

Somewhat

decreased

Remained

the same

Somewhat

increased

Greatly

increased

Number of contacts

with participants 1% 29% 55% 13% 3%

Time spent with

participants

during contacts 2% 24% 60% 13% 2%

Time spent on

paperwork

(including

verification) 7% 40% 43% 9% 2%

Caseworker

simplification

measures

Changes for

the caseworker

Greatly

simplified

Somewhat

simplified

Remained

the same

Somewhat

complicated

Greatly

complicated

Decisions on

whether to apply

changes reported

by participants 7% 29% 23% 35% 6%

Frequency of

benefit calculation 9% 39% 39% 11% 2%
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 50 GAO-04-916 Food Stamp Program 

Kay Brown, (202) 512-3674, brownke@gao.gov 

Elizabeth Morrison, (202) 512-9641, morrisone@gao.gov 

Katharine Leavitt and Anne Welch also made significant contributions to 

this report. In addition, Carl Barden, Kevin Jackson, MacDonald Phillips, 

and Jay Smale were responsible for sampling, survey design, and data 

analysis,and Corinna Nicolaou assisted in the report development. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Acknowledgments 
Related GAO Products 

Page 51 GAO-04-916 Food Stamp Program 

Food Stamp Program: Steps Have Been Taken to Increase Participation 

of Working Families, but Better Tracking of Efforts Is Needed. 

GAO-04-346. Washington, D.C.: March 5, 2004. 

Food Stamp Employment and Training Program: Better Data Needed to 

Understand Who Is Served and What the Program Achieves. GAO-03-388. 

Washington, D.C.: March 12, 2003 

Food Stamp Program: States’ Use of Options and Waivers to Improve 

Program Administration and Promote Access. GAO-02-409. Washington, 

D.C.: February 22, 2002. 

Food Stamp Program: States Seek to Reduce Payment Errors and 

Program Complexity. GAO-01-272. Washington, D.C.: January 19, 2001. 

Means-Tested Programs: Determining Financial Eligibility Is 

Cumbersome and Can Be Simplified. GAO-02-58. Washington, D.C.: 

November 2, 2001. 

Food Stamp Program: Various Factors Have Led to Declining 

Participation: GAO/RCED-99-185. Washington, D.C.: July 2, 1999. 

Related GAO Products 

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