MILITARY 

PERSONNEL

DOD Needs More 

Complete Data on 

Active-Duty 

Servicemembers’ Use 

of Food Assistance 

Programs

Report to Congressional Committees

July 2016

GAO-16-561

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-561, a report to 

congressional committees

July 2016

MILITARY PERSONNEL

DOD Needs More Complete Data on Active-Duty 

Servicemembers’ Use of Food Assistance Programs

Why GAO Did This Study

According to the Defense Commissary 

Agency, servicemembers on active 

duty spent over $21 million in SNAP 

benefits at commissaries from 

September 2014 through August 2015. 

This suggests that people serving our 

country may be having difficulty 

making ends meet. House Report 114-

102 includes a provision that GAO 

review food assistance programs 

available to servicemembers. This 

report assesses, among other things, 

the extent to which (1) active-duty 

servicemembers and their families 

have access to food assistance 

programs and any variations in 

eligibility for these programs, and (2) 

DOD has identified the 

servicemembers’ use of these 

programs. GAO reviewed information 

on government and charitable food 

assistance programs and policies. 

GAO also interviewed DOD and 

service officials at four installations that 

were selected based on size, cost of 

living, and presence of food assistance

programs.

What GAO Recommends

GAO recommends that DOD (1) revise 

surveys of servicemembers to collect 

and analyze more complete data and, 

if warranted, implement actions such 

as assigning department-level 

responsibilities for monitoring food 

assistance; and (2) coordinate with 

USDA to access its usage information. 

DOD concurred with the first 

recommendation and partially 

concurred with the second, stating that 

it has tried to coordinate with USDA. 

GAO continues to believe the 

recommendation is valid, as discussed 

in this report.

What GAO Found

Active-duty servicemembers and their families have access to food assistance 

through various government and charitable programs, but use of these programs 

varies, in part, on their ability to meet specific eligibility criteria. In an April 2010 

report, GAO identified 18 government programs that provide food assistance to 

low-income households. Servicemembers may apply for and, if they qualify, 

receive benefits from any of these programs. However, servicemembers’

eligibility for these programs can vary by program and location. For example, 

GAO found that it might be easier for servicemembers to qualify for Special 

Supplemental Nutrition Program for Women, Infants, and Children (WIC) than 

Supplemental Nutrition Assistance Program (SNAP) because WIC allows state 

agencies to exclude portions of a servicemember’s pay when determining 

eligibility and SNAP does not. Also, charitable organizations, such as food 

pantries, are available to servicemembers in need of food assistance. 

The Department of Defense (DOD) has some data on servicemembers’ use of

food assistance programs it administers, but it does not know the extent that

servicemembers use such programs because (1) it is not fully collecting or 

analyzing such information within the department, and (2) it has not coordinated 

with organizations such as U.S. Department of Agriculture (USDA) to access 

their data on servicemembers’ use of their programs. Standards for Internal 

Control in the Federal Government state that management should use quality 

information to achieve its objectives. DOD has data on the number of 

servicemembers’ children receiving free and reduced-price school meals at DOD 

Education Activity (DODEA) schools in the United States. For example, DODEA 

data for September 2015 showed that 24 percent of children in DODEA schools 

in the continental U.S. were eligible for free meals and 21 percent were eligible 

for reduced-price meals. A DOD survey also provides some information on

servicemembers’ use of food assistance programs such as SNAP. However, this 

survey is of limited usefulness in part because it does not inquire about other 

food assistance programs used by servicemembers such as National School 

Lunch Program; also no office within DOD is monitoring food assistance needs 

such as through survey data. Without more complete survey data, DOD will not 

understand the prevalence of need among servicemembers to effectively target 

its support and determine if it should assign department-level responsibility for 

monitoring food assistance needs.

Standards for Internal Control in the Federal Government also state that 

management should communicate with external parties to obtain needed 

information. USDA has access to data on servicemembers’ use of food 

assistance programs, but none of the DOD officials with whom GAO spoke were 

aware of efforts by the department to coordinate with USDA to access these 

data. For example, USDA administers SNAP benefits that, according to a 2013 

U.S. Census Bureau survey, were used by about 23,000 active-duty 

servicemembers in the previous 12 months. The National Defense Authorization 

Act for Fiscal Year 2016 included a provision to address the sharing of SNAP 

data between USDA and DOD; however, DOD does not have a coordination 

effort underway to access such data. Without such coordination, DOD will miss 

the opportunity to collect data on the needs of its servicemembers. 

View GAO-16-561. For more information, 

contact Brenda S. Farrell at (202) 512-3604 or

farrellb@gao.gov.
Page i GAO-16-561 DOD Food Assistance 

Letter 1

Background 4

Active-Duty Servicemembers Have Access to Various 

Government and Charitable Food Assistance Programs, but 

Their Eligibility for Some Government Programs Can Vary 7

DOD Does Not Know the Extent to Which Servicemembers Use 

Food Assistance Programs 13

Military Officials at Selected Installations Cited Challenges 

Affecting Servicemembers Who Seek Food Assistance Benefits 21

Conclusions 23

Recommendations for Executive Action 24

Agency Comments and Our Evaluation 24

Appendix I Scope and Methodology 28

Appendix II Listing of Selected Federal Food and Nutrition Assistance Programs 34

Appendix III Eligibility Requirements for Food Assistance Programs Commonly

Used by Active-Duty Servicemembers and Their Families 39

Appendix IV Comments from the Department of Defense 46

Appendix V GAO Contact and Staff Acknowledgments 48

Tables

Table 1: Examples of Agencies and Organizations That Provide 

Food Assistance to Active-Duty Servicemembers and 

Their Families 9

Table 2: Organizations, Offices, and Military Installations Visited or 

Contacted 32

Table 3: Selected Federal Food and Nutrition Assistance 

Programs, by Agency 35

Contents
Page ii GAO-16-561 DOD Food Assistance 

Figure

Figure 1: Minimum Household Size Required for a 

Servicemember in the Paygrade of E-4 to Qualify for 

Commonly Used Government Food Assistance 

Programs 11

Abbreviations

BAH Basic Allowance for Housing

BAS Basic Allowance for Subsistence

DOD Department of Defense

DODEA DOD Education Activity

FSSA Family Subsistence Supplemental Allowance

NDAA National Defense Authorization Act

NSLP National School Lunch Program

School Breakfast Program

Summer Food Service Program

Supplemental Nutrition Assistance Program

SBP 

SFSP 

SNAP 

TANF Temporary Assistance for Needy Families

USD (P&R) Under Secretary of Defense for Personnel and

Readiness

USDA United States Department of Agriculture

WIC Special Supplemental Nutrition Program for 

Women, Infants, and Children

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Page 1 GAO-16-561 DOD Food Assistance 

441 G St. N.W.

Washington, DC 20548

July 15, 2016

Congressional Committees

According to the Defense Commissary Agency, servicemembers on 

active duty spent over $21 million in food stamp benefits at military 

commissaries from September 2014 through August 2015. This suggests 

that some people serving our country may be having difficulty making 

ends meet. Military families facing financial hardship have federal, state 

and private-sector options for food assistance. One option provided by 

the Department of Defense (DOD) to active-duty servicemembers is the 

Family Subsistence Supplemental Allowance (FSSA). In 2000, Congress 

created FSSA as an alternative to the United States Department of 

Agriculture’s (USDA) Supplemental Nutrition Assistance Program 

(SNAP)—formerly called the Food Stamp Program. However, in 2015, the 

Military Compensation and Retirement Modernization Commission 

reported that few active-duty servicemembers took advantage of FSSA 

and recommended that Congress end the FSSA program for 

servicemembers located in the United States and its territories, and refer 

servicemembers to apply for benefits under the USDA’s SNAP program.1

 

The National Defense Authorization Act (NDAA) for Fiscal Year 2016 

implemented the commission’s recommendation with the effect that after 

September 30, 2016, FSSA will be available only to active-duty 

servicemembers serving outside the United States and its territories. 

However, a 2015 House Armed Services committee report stated a 

concern that active-duty servicemembers and their families may have a 

continuing need for nutrition assistance. 

House Report 114-102, which accompanied a bill for the NDAA for fiscal 

year 2016, includes a provision that we review the food assistance 

programs available to active-duty servicemembers and their families. 

Subsequently, the Senate Agriculture, Nutrition, and Forestry committee 

1

The Military Compensation and Retirement Modernization Commission was established 

by the National Defense Authorization Act (NDAA) for Fiscal Year 2013, Pub. L. No. 112-

239, §§ 671-80 (2013), to provide the President of the United States and the Congress 

specific recommendations to modernize the military compensation and retirement 

systems. 

Letter
Page 2 GAO-16-561 DOD Food Assistance 

became co-requesters of our work in response to this House report 

provision. This report assesses (1) the extent to which active-duty 

servicemembers and their families have access to government and 

charitable food assistance programs and any variations in eligibility 

requirements for these programs, (2) the extent to which DOD has 

identified active-duty servicemembers’ use of food assistance programs, 

and (3) any challenges that active-duty servicemembers encounter when 

seeking food assistance.2

For our first objective, we reviewed our prior related reports and a 

Congressional Research Service report on domestic food assistance 

programs, and we interviewed officials from DOD and USDA to identify 

food assistance programs available to active-duty servicemembers and 

their families. We interviewed officials who administer these programs at 

the federal, state, and local levels to obtain additional background 

information and to confirm the availability and our understanding of the 

food assistance programs we identified. We also met with representatives 

of various charitable organizations that provide food assistance to activeduty servicemembers and their families. To determine if there were any 

variations in eligibility requirements in government food assistance 

programs, we reviewed the laws that established selected food 

assistance programs and analyzed eligibility criteria for these programs 

and used those eligibility criteria to develop scenarios to illustrate 

situations in which a servicemember would or would not qualify for these 

food assistance programs.

For our second objective, we interviewed officials from multiple offices 

within the Under Secretary of Defense for Personnel and Readiness 

(USD (P&R)) to determine which office(s) had department-level 

responsibilities related to active-duty servicemembers’ use of food 

assistance programs and to obtain any relevant data on servicemembers’

use of these programs. We reviewed DOD documents on the 

organization and the assigned responsibilities of USD (P&R). We 

 2

The House Report 114-102 originally requested that we examine servicemembers’

access to and use of nutrition assistance programs. However, early in our review, we 

determined that agency officials interpreted “nutrition assistance” as relating to a 

servicemember’s diet as opposed to our intended focus on their access to food. As 

discussed with congressional staff, we replaced “nutrition assistance” with “food 

assistance” to clarify our intent and to mitigate further confusion about the focus of our 

review. 
Page 3 GAO-16-561 DOD Food Assistance 

obtained and reviewed DOD’s Status of Forces Survey of Active Duty 

Members for calendar years 2010, 2012, and 2013, the U.S. Census 

Bureau’s 2013 American Community Survey, FSSA data from the 

Defense Joint Military Pay System, and data on the number of students in 

DOD Education Activity (DODEA) schools who were eligible to receive 

free and/or reduced-price meals. We found this information to be 

sufficiently reliable for the purpose of reporting on DOD’s awareness of 

military participants receiving these benefits. Also, we compared the data 

collection and communications processes for DOD with Standards for 

Internal Control in the Federal Government, which state that management 

should obtain quality information to achieve its objectives and that it 

should communicate with external parties regarding the information that is 

needed to achieve its objectives.3 To obtain information on other food 

assistance programs available to servicemembers and their families, we 

visited four selected military installations in the United States and 

interviewed officials who administer these programs, officials who assist 

servicemembers in need, and visited food pantries, if any, on the 

installation. We selected sites to represent each of the military services 

and to include locations with a large population of servicemembers and 

dependents, a range of cost-of-living areas—using the Basic Allowance 

for Housing (BAH)4 rates—and a food pantry and/or a Special 

Supplemental Nutrition Program for Women, Infants, and Children (WIC)5

program office on the military installation. Based on these criteria, we 

visited Fort Hood, Texas; Naval Base San Diego, California; Marine 

Corps Base Camp Pendleton, California; and Altus Air Force Base, 

Oklahoma. During our site visits, we met with military officials who assist 

 3

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

21.3.1 (Washington, D.C.: November 1999). These standards were in effect prior to fiscal 

year 2016 and cover the time period of government agencies’ data. The standards were 

subsequently updated. The updated standards went into effect on October 1, 2015. See 

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

(Washington, D.C.: Sept. 10, 2014).

4

BAH is an allowance paid to cover housing expenses of servicemembers not residing in 

military housing. Approximately two-thirds of servicemembers receive BAH. BAH rates 

vary by geographic region to accommodate the wide variations in housing costs across 

the country. The amount paid is based on geographic duty location, pay grade, and family 

status.

5

WIC provides supplemental, nutrient-rich foods; nutrition education, including breastfeeding promotion and support, to low-income infants, children and women who are 

pregnant, postpartum, and breastfeeding.
Page 4 GAO-16-561 DOD Food Assistance 

servicemembers and their families in financial difficulty— which may 

include a need for food assistance—as well as state and local officials 

who oversee non-military food assistance programs that servicemembers 

may use. We also met with representatives from military and non-military 

charitable organizations to learn what food assistance they provide to 

active-duty servicemembers and their families.

For our third objective, we conducted site visits to four selected military 

installations and interviewed military service officials who work with 

servicemembers in need to gain their perspectives on any challenges that 

may be faced by servicemembers attempting to obtain food assistance. 

Specifically, we interviewed military Chaplains, First Sergeants and 

Command Master Chiefs, financial specialists, and officials from 

charitable military organizations, including Army Emergency Relief, the 

Navy-Marine Corps Relief Society, and the Air Force Aid Society.6 We 

also interviewed private and local government officials who assist civilians 

and some servicemembers with food assistance, such as SNAP, WIC, 

summer meals programs, and food pantries. Further, we interviewed 

representatives from advocacy groups who support active-duty families or 

try to reduce hunger in America. We provide further details on our scope 

and methodology in Appendix I.

We conducted this performance audit from July 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 6

We interviewed officials from these charitable military organizations because they are the 

ones most likely to assist servicemembers when they experience financial difficulty, such 

as the need for food assistance.

Background
Page 5 GAO-16-561 DOD Food Assistance 

The Under Secretary for Personnel and Readiness (USD (P&R)) is the 

principal staff assistant and advisor to the Secretary of Defense for Total 

Force Management as it relates to readiness, health affairs, training, 

personnel requirements, and quality-of-life matters.7 USD (P&R) is the 

Secretary’s senior policy advisor on recruitment, career development, and 

pay and benefits for military personnel and DOD civilians. The USD 

(P&R) oversees the Defense Health Program, Defense Commissary 

Agency, the Defense Education Activity, Defense Manpower Data Center, 

Military Community and Family Policy, and others. USD (P&R) 

responsibilities include, but are not limited to, developing policies, plans, 

and programs for compensation of military personnel and quality of life for 

military personnel and their families.

Although included in the military compensation system as a non-cash 

benefit, DOD commissaries can be considered a food assistance program 

in that the commissaries provide servicemembers an opportunity to 

purchase food at reduced cost. Active-duty servicemembers receive a 

compensation package that includes cash compensation, non-cash 

compensation, and deferred compensation. Non-cash compensation 

includes various types of benefits such as health care, child-care centers, 

educational benefits, and access to subsidized commissaries (i.e., 

grocery stores). DOD operates a worldwide chain of commissaries that 

sell food and related household items to active-duty, reserve and guard 

members of the military services, retirees of these military services, their 

families, and other authorized patrons. According to the Defense 

Commissary Agency’s Annual Financial Report Fiscal Year 2015, DOD’s 

240 commissaries sold $5.5 billion of items to approximately 5.3 million 

households in fiscal year 2015. Commissaries sell food and related 

household items to authorized patrons at cost plus a 5-percent surcharge, 

which DOD estimates saves patrons an average of more than 30 percent 

on their purchases compared to commercial prices. The Defense 

Commissary Agency wrote in its report that it received $1.3 billion in 

appropriation transfers during fiscal year 2015.

 7

The total force is the organizations, units, and individuals that comprise the DOD 

resources for implementing the National Security Strategy. It includes DOD active and 

reserve component military personnel, military retired members, DOD civilian personnel 

(including foreign-national direct and indirect hires, as well as nonappropriated fund 

employees), contractors, and host-nation support personnel.

Under Secretary for 

Personnel and Readiness 

Is Responsible for Areas 

That Affect Personnel 

Health and Welfare

Defense Commissaries 

Sell Servicemembers 

Food at Reduced Cost
Page 6 GAO-16-561 DOD Food Assistance 

The USDA’s Food and Nutrition Service has responsibility for 

administering most of the federal domestic food and nutrition programs, 

including the five largest programs. As the federal government’s primary 

domestic food assistance agency, USDA aims to help households 

achieve food security—that is, to have consistent, dependable access to 

enough food for an active, healthy life—and monitors the extent and 

severity of food insecurity. The Department of Health and Human 

Services and the Department of Homeland Security also fund programs 

that provide food and nutrition assistance.

In May 2015, we testified before Congress that, in fiscal year 2014, the 

federal government spent more than $100 billion on 18 domestic food

assistance programs.8 Specifically, we identified that program spending 

ranged from approximately $5 million on the Community Food Projects 

Competitive Grants Program to more than $74 billion on SNAP. Our 

testimony also stated that in fiscal year 2014, the five largest food 

assistance programs—SNAP, National School Lunch Program (NSLP), 

WIC, School Breakfast Program (SBP), and the Child and Adult Care 

Food Program—accounted for 96 percent of total spending on the 18 

programs. SNAP, the largest program, accounted for more than 70 

percent of the overall spending total. SNAP, NSLP, SBP, and the Child 

and Adult Care Food Program are entitlement programs, meaning that 

federal law requires benefits to be provided to all applicants who meet 

eligibility requirements.

 8

GAO, Domestic Food Assistance: Multiple Programs Benefit Millions of Americans, but 

Additional Action Is Needed to Address Potential Overlap and Inefficiencies, 

GAO-15-606T (Washington, D.C.: May 20, 2015).

Department of Agriculture 

Administers Most of the 

Federal Domestic Food 

Assistance Programs
Page 7 GAO-16-561 DOD Food Assistance 

Active-duty servicemembers and their families have access to food 

assistance through various government and charitable programs, but their 

eligibility for some government food assistance programs can vary based 

on the programs’ income criteria and servicemembers’ location.

Active-duty servicemembers and their families have access to food 

assistance through a variety of government and charitable sources. For 

example, in a testimony before Congress on May 2015, we identified 18 

selected federal government programs that focus primarily on providing 

food and nutrition assistance, such as SNAP and WIC, to low-income 

individuals and households.9 Active-duty servicemembers and their 

families may apply to any of these programs, and can receive benefits if 

they meet the eligibility requirements. Appendix II provides a general 

description of these 18 programs as well as the target population. 

Additionally, DOD provides active-duty servicemembers with FSSA. By 

design, the FSSA program increases a servicemember’s income by an 

amount to preclude them from applying for benefits under the SNAP 

program. However, the NDAA for fiscal year 2016 restricted the 

availability of FSSA to only servicemembers stationed outside the United 

States and its territories starting October 1, 2016. Servicemembers 

stationed in the United States and its territories and in need of food 

 9

GAO-15-606T. The testimony documented in GAO-15-606T was largely based on a 

report we issued in April 2010 that examined domestic food assistance programs—GAO, 

Domestic Food Assistance: Complex System Benefits Millions, but Additional Efforts 

Could Address Potential Inefficiency and Overlap among Smaller Programs, GAO-10-346 

(Washington, D.C.: Apr. 15, 2010). In the report, we describe how the 18 programs were 

selected. 

Active-Duty 

Servicemembers 

Have Access to 

Various Government 

and Charitable Food 

Assistance Programs, 

but Their Eligibility for 

Some Government 

Programs Can Vary

Active-Duty 

Servicemembers Have 

Access to Various 

Government and 

Charitable Food 

Assistance Programs
Page 8 GAO-16-561 DOD Food Assistance 

assistance previously provided by FSSA are expected to apply to the 

SNAP program.

In addition to the government food assistance programs, active-duty 

servicemembers and their families can seek assistance from a variety of 

charitable organizations. For example, each military service has a 

charitable organization such as the Army Emergency Relief that, 

depending on the type of assistance needed, is able to provide 

servicemembers with grants or interest-free loans that can be used to 

purchase food and to help meet any other immediate needs they may 

have in an emergency situation. During our visits to four selected military 

installations, we also found that additional assistance may be available to 

active-duty servicemembers and their families through locally-developed 

initiatives, such as food pantries, that are typically organized by 

volunteers to address food assistance needs at a particular military 

installation. Many of the food pantries we examined were local operations 

intended to meet emergency needs; however, at one of the military 

installations we visited there were four food pantries operating on the 

installation that provided food routinely once a month. Table 1 provides 

further details about some of the different types of food assistance 

available to active-duty servicemembers and their families.
Page 9 GAO-16-561 DOD Food Assistance 

Table 1: Examples of Agencies and Organizations That Provide Food Assistance to Active-Duty Servicemembers and Their 

Families

Category of food 

assistance Organization/program Description

Government programs

DOD’s Family Subsistence Supplemental 

Allowance (FSSA)

FSSA is a monetary supplement that increases a 

servicemember’s household income to 130 percent of 

federal poverty guidelines.

USDA’s Supplemental Nutrition Assistance 

Program (SNAP)

SNAP provides nutrition assistance benefits via 

Electronic Benefit Transfer (EBT) cards to low-income 

individuals in order to purchase food at authorized 

stores.

USDA’s Special Supplemental Nutrition Program 

for Women, Infants, and Children (WIC)

WIC provides supplemental, nutrient-rich foods; 

nutrition education, including breast-feeding 

promotion and support, to low-income infants, 

children and women who are pregnant, postpartum, 

and breastfeeding.

USDA’s National School Lunch Program (NSLP) 

and School Breakfast Program (SBP)

NSLP and SBP programs provide low-income 

students with nutritionally balanced low-cost or free 

lunches and breakfasts at school. 

USDA’s Summer Food Service Program (SFSP) SFSP provides federal cash assistance and some 

commodity foods to local public and private nonprofit 

service institutions running summer youth programs, 

camps, or other recreation sites that serve lowincome children during their summer break or during 

lengthy school-year breaks. Any child, 18 or younger, 

or certain individuals with disabilities over the age of 

18, can receive a meal at a SFSP site.

Charitable organizations

Military

Navy-Marine Corps 

Relief Society 

(NMCRS)

NMCRS provides financial, educational, and other 

need-based assistance to active-duty and retired 

sailors and marines, their eligible family members, 

and survivors.

Air Force Aid Society 

(AFAS)

AFAS provides emergency assistance to airmen and 

their eligible family members to meet immediate 

needs in an emergency situation.

Army Emergency Relief 

(AER)

AER provides emergency financial assistance to 

soldiers (active and retired) and their families in time 

of distress.

Community-based Food pantries/banks

Local, independent, and volunteer organizations that 

provide food to people in need.

Source: GAO review of agency documents. | GAO-16-561
Page 10 GAO-16-561 DOD Food Assistance 

An applicant’s income must be below a given level in order to qualify for 

benefits from the government food assistance programs. To develop an 

understanding of how active-duty servicemembers could meet the 

financial criteria, we compared the base income for servicemembers in a 

specific paygrade with the income eligibility requirements for five 

government food assistance programs that are commonly used by activeduty servicemembers and their families. Specifically, these five programs 

include DOD’s FSSA—the only food assistance program offered through 

DOD—and four USDA programs, including SNAP, WIC, NSLP, and 

SBP.10 These programs’ statutory authorities define the financial criteria 

as a maximum income limit by household or family size.11 Our 

comparison enabled us to develop an understanding of the size of 

household or family a servicemember in a specific paygrade would need 

in order to qualify for a program.12 Although other factors beyond 

household or family size and base income affect servicemembers’

eligibility for these food assistance programs, our analysis is generally 

limited to these factors in order to isolate the effect of income on 

eligibility.13 Further, we recognize that to receive benefits the 

servicemember would also have to meet the program’s non-financial 

eligibility requirements, which are detailed in appendix III. Given that, we 

compared the basic pay and allowances of a servicemember in the E-4 

paygrade with maximum income eligibility criteria for the five government 

food assistance programs commonly used by active-duty 

servicemembers and their families and determined the minimum 

 10The four programs USDA provides are ones that it promotes to military families and that 

DOD officials confirmed active-duty servicemembers used.

11In determining eligibility for SNAP, FSSA, WIC, NSLP, and SBP, household or family is 

not limited to just the servicemember and his or her dependents. For SNAP and FSSA, 

the household may include any group of individuals who live together and customarily 

purchase food and prepare meals together for home consumption. For WIC, NSLP, and 

SBP, a household or family may include a group of related or nonrelated individuals who 

are not residents of an institution, boarding house, or homeless shelter, but who are living 

together as one economic unit.

12According to DOD’s 2014 Demographics: Profile of the Military Community, active-duty 

servicemembers with dependents have an average of 2.4 dependents.

13When conducting our analysis, we made certain assumptions about the characteristics 

of servicemembers’ households or families so as to remove the influence of these factors 

on a servicemember’s eligibility and allow us to see the impact of income on the 

servicemember’s eligibility. For example, for SNAP we assumed that servicemembers did 

not have any dependent care or child-support deductions.

Servicemembers’ Eligibility 

for Government Food 

Assistance Programs Can 

Vary Based on the 

Program’s Criteria and the 

Servicemember’s Location
Page 11 GAO-16-561 DOD Food Assistance 

household or family size the servicemember needed in order to qualify for 

each program. We selected the paygrade of E-4 in part because it 

includes junior enlisted personnel who are compensated at the lower end 

of the pay scale for active-duty servicemembers. Further, DOD’s data on 

FSSA recipients showed that servicemembers in the paygrade of E-4 

were the most frequent recipients of this allowance, thus suggesting that 

there may be food assistance needs more commonly experienced by 

personnel at this paygrade. The results of our analysis are presented in 

Figure 1 and show that a servicemember’s income eligibility will likely 

vary based on where he or she lives and the program through which one 

applies for food assistance.

Figure 1: Minimum Household Size Required for a Servicemember in the Paygrade of E-4 to Qualify for Commonly Used 

Government Food Assistance Programs

a

These locations were selected to represent: each of the military services and to include locations 

with a large population of servicemembers and dependents, a range of cost-of-living areas (using the 

Basic Allowance for Housing (BAH) rates), and the presence of a food pantry and/or a WIC program 

office on the installation.

b

In calculating the E-4 salary, we included only three types of pay: Basic Pay, Basic Allowance for 

Subsistence (BAS), and BAH with dependent rate. We included these elements of military pay 

because active-duty servicemembers who are entitled to basic pay are also entitled to BAS and BAH. 

We did not include other military pay and allowances because active-duty servicemembers are not all 
Page 12 GAO-16-561 DOD Food Assistance 

eligible for the other pay and allowances. Our analysis is based on the assumption that the only 

source of income for the household is the servicemembers’ military pay.

c

In calculating the minimum household size to qualify for SNAP benefits, we assumed that the 

household does not include any elderly or disabled persons, there were no dependent care, medical 

expenses, or child-support deductions, the monthly rent or mortgage payment equaled the 

servicemember’s BAH, and the standard utility allowance was appropriate to use in the calculations.

d

The NSLP and SBP provide free or reduced-priced school meals. The minimum household size 

presented here is only for reduced-price meals.

e

Eligibility for free and reduced-price school meals under the NSLP and SBP is addressed separately 

in this table for servicemembers who live in privatized military housing and those residing in the local 

community because of how the servicemember’s BAH is treated. For servicemembers residing in 

privatized military housing, BAH is not included in income when determining eligibility for free and 

reduced-price school meals. However, for servicemembers receiving BAH and who do not reside in 

privatized government housing, BAH is included in income.

We found that each of the government food assistance programs 

included in our review requires that an applicant’s household or family 

income falls below a specified amount to qualify for benefits and that this 

income limit varies by program and sometimes by state. Further, including 

BAH benefits in a determination of an applicant’s income eligibility also 

plays a role in the food assistance programs used by active-duty 

servicemembers and their families. Specifically, we found that it might be 

easier for servicemembers to qualify for WIC than SNAP or FSSA 

because WIC allows state agencies to choose to exclude BAH from 

income. For example, based on our analysis a servicemember at Naval 

Base San Diego, California, would need a minimum household size of 3 

to qualify for WIC benefits, but would require a minimum household size 

of 7 to qualify for SNAP benefits and a minimum household size of 9 to 

qualify for FSSA. We also found that servicemembers may be more likely 

to qualify for free or reduced- price meals from NSLP and SBP if they

reside in privatized housing than if they live in the local community 

because the eligibility criteria for those programs do not count BAH as 

income for servicemembers living in privatized military housing.14 For 

example, based on our analysis a servicemember residing in privatized 

military housing on Camp Pendleton in California would require a 

minimum household size of 3 to qualify for reduced-price school meals 

compared to a servicemember residing in the local community who would 

need a minimum household size of 6 to qualify.

 1442 U.S.C. § 1758(b)(13); id. at § 1773(e)(1)(A) (citing to the eligibility standards in 42 

U.S.C. § 1758).
Page 13 GAO-16-561 DOD Food Assistance 

Based on our analysis, we found that it might be easier for 

servicemembers to qualify for SNAP than FSSA because SNAP’s 

statutory authority15 gives the states, in certain instances, the option to 

increase the gross-income limit for SNAP to as much as 200 percent of 

the federal poverty guidelines16 but fixes the income limit for FSSA at 130 

percent of the federal poverty guidelines regardless of the state the 

servicemember lives in. For example, our analysis suggests that a 

servicemember at Camp Pendleton, California, would need a minimum 

household size of 6 to qualify for SNAP benefits but would require a 

minimum household size of 9 to qualify for FSSA, and a servicemember 

at Fort Hood, Texas, would need a minimum household size of 6 to 

qualify for SNAP benefits but would require a minimum household size of 

7 to qualify for FSSA benefits. In this example, a smaller household size 

is required to qualify for SNAP than for FSSA primarily because California 

and Texas raised the gross-income test for SNAP to 200 percent and 165 

percent of federal poverty guidelines, respectively. Appendix III details 

both the income and non-income eligibility criteria for the government 

food assistance programs commonly used by active-duty 

servicemembers and their families.

DOD has some data on servicemembers’ use of food assistance 

programs that it administers, but DOD does not know the extent to which 

servicemembers use food assistance programs because (1) its officials 

are not fully collecting or analyzing such information within the 

department, and (2) DOD officials we spoke with were not aware of 

efforts to coordinate with USDA to access data on servicemembers’ use 

of the respective programs. We contacted multiple offices within DOD to 

obtain data on the use of food assistance programs and found that none 

of the offices had efforts to monitor servicemembers’ food assistance 

 157 U.S.C. § 2014(a).

16Under expanded eligibility rules, called “broad-based categorical eligibility,” states can 

allow households receiving noncash services funded by Temporary Assistance for Needy 

Families (such as a toll-free number or brochure) to be automatically eligible for SNAP. 

States that adopt a broad-based categorical eligibility policy may increase limits on 

household gross income up to 200 percent of federal poverty guidelines. However, 

categorically eligible households have their SNAP benefits determined under the same 

rules as other households, and while the household may be categorically eligible, its 

income may be too high to actually receive a SNAP benefit.

DOD Does Not Know 

the Extent to Which 

Servicemembers Use 

Food Assistance 

Programs
Page 14 GAO-16-561 DOD Food Assistance 

needs. Further, DOD has not assigned responsibility for monitoring 

servicemembers’ use of food assistance programs.

We found that some data exist within and outside of DOD on the use of 

the food assistance programs by active-duty servicemembers and their 

families. However, DOD does not know the extent to which these 

programs are used. Standards for Internal Control in the Federal 

Government states that management should use quality information to 

achieve the entity’s objectives, and defines quality information as 

complete, accurate and current.17

As the administrator of FSSA, DOD has data on servicemembers who 

receive the FSSA benefit. Specifically, based on Defense Joint Military 

Pay System records, 188 active-duty servicemembers received FSSA 

benefits in calendar year 2015, 224 received benefits in calendar year 

2014, and 285 received benefits in calendar year 2013. However, these 

data are of limited usefulness because DOD does not collect and analyze 

relevant data that are available from other sources within the department 

and that would facilitate a more comprehensive understanding of 

servicemembers’ use of food assistance programs. Further, FSSA data 

alone will provide fewer insights into servicemembers’ use of food 

assistance programs in the future because, as previously noted, the 

benefit will no longer be available to servicemembers who are stationed 

within the continental U.S. after September 30, 2016.

Through the DOD Education Activity (DODEA), which operates 52 

schools on military installations within the continental United States, DOD 

has access to data on the number of children who attend these schools 

and are eligible to receive free and reduced-price lunches and 

breakfast.18 For example, we obtained data from DODEA officials for the 

2014-2015 school year that showed, on average, of the 19,001 children 

enrolled in DODEA schools in the continental United States, 26 percent 

 17GA0-14-704G. The standards were updated and went into effect on October 1, 2015. 

The current standards describe the need for quality information similar to the prior 

standards described in GAO/AIMD-00-21.3.1 which were in effect prior to fiscal year 2016 

and cover the time period of government agencies’ data.

18DODEA schools within the United States serve dependent children of DOD military 

members on active duty and civilian federal employees assigned permanent living 

quarters on a military installation, as well as other eligible dependents if space is available.

DOD Does Not Collect 

and Analyze Relevant 

Data on Servicemembers’

Use of Food Assistance 

Programs

Some Data Are Available 

within DOD on 

Servicemembers’ Use of Food 

Assistance
Page 15 GAO-16-561 DOD Food Assistance 

(5,010) were eligible for free meals and 25 percent (4,675) were eligible 

for reduced-price meals. In addition, DODEA officials provided data for 

September 2015—the start of the 2015-2016 school year—that showed 

that 24 percent of the 18,228 (4,427) children enrolled in DODEA schools 

in the continental United States were eligible for free meals and 21 

percent (3,909) were eligible for reduced-price meals. These data do not 

fully capture the use of food assistance by servicemembers and their 

families, but they may be an indicator of a need that exists for a specific 

population within the military services. However, a DODEA official stated 

that prior to our request she was not aware of any efforts by DOD to 

collect and analyze such data to better understand the extent to which 

servicemembers use food assistance.

DOD also periodically conducts Status of Forces surveys that seek to 

understand attitudes and views on a wide range of personnel issues and 

the results of which are used to help DOD decision makers evaluate 

existing programs and policies, establish baselines before implementing 

new programs and policies, and monitor the progress of programs and 

policies and their effects on the total force.19 However, DOD has not 

utilized this survey as a tool to collect and analyze data on the use of food 

assistance programs by active-duty servicemembers and their families. 

DOD Instruction 1342.22 directs DOD’s family readiness services, which 

include a variety of support programs for servicemembers and their 

families that range from financial assistance to child care, be designed, 

funded, and managed using results obtained from a performance 

management strategy that includes assessment of needs.20 DOD’s Status 

of Forces surveys include a survey of active-duty servicemembers that, in 

recent years, has included questions about the use of food assistance 

programs. Based on the 2013 survey—the most recent results 

 19Status of Forces surveys are administered to a variety of DOD personnel, but we limit 

our reference to the active-duty survey because our report is focused on active-duty 

servicemembers. Other Status of Forces surveys include a survey of reserve component 

personnel, called the Status of Forces Survey Reserve Component Members; and a 

survey of civilian employees, called the Status of Forces Survey of DOD Civilian 

Employees. These surveys include outcome—”leading indicator”—measures for these 

individuals, such as overall satisfaction, retention intention, and perceived readiness, as 

well as demographic items needed to classify individuals into various subpopulations.

20Department of Defense Instruction 1342.22, Military Family Readiness (July 3, 2012).
Page 16 GAO-16-561 DOD Food Assistance 

available—DOD estimated that 2 percent (about 20,000)21 of active-duty 

servicemembers or their spouses had received income or financial 

support from SNAP22 in the previous 12 months and 9 percent received 

income from either WIC and/or Temporary Assistance For Needy 

Families (TANF).23 However, the WIC and TANF data are of limited 

usefulness in determining the extent to which servicemembers use food 

assistance, in part, because it combines data on WIC—a food assistance 

program—with TANF data—a non-food assistance program. The survey 

also does not specifically address other sources of food assistance that 

may be used by active-duty servicemembers and their families such as 

NSLP, SBP, SFSP, or food pantries. Further, in July 2010,24 we reported 

that the low response rates to the Status of Forces Survey could 

potentially bias the survey results and recommended that the Defense 

Manpower Data Center develop and implement guidance to conduct a 

nonresponse analysis. DOD agreed with the recommendation, but it has 

not fully implemented our recommendation because, according to DOD 

officials, funding is not currently available to carry out the full intent of the 

recommendation. Without more complete data, DOD will not be able to 

identify the prevalence of need and the use of food assistance programs 

by active-duty servicemembers. Furthermore, DOD will be unable to 

effectively target its support so that it is producing maximum benefit for 

those in need.

 21The survey estimate has a margin of error of plus or minus 2 percent, which means the 

actual number of servicemembers receiving SNAP could range from 0 to about 40,000.

22In technical comments on this report, USDA officials stated that the question asked by 

DOD in its Status of Forces survey was incorrect in that SNAP is not a financial or cash 

benefit. Instead, the question should have asked servicemembers if they had received any 

SNAP benefits. 

23TANF is a program designed to help needy families achieve self-sufficiency and is not 

applicable to this review. However, we reference TANF data from DOD’s 2013 Status of 

Forces Survey because it is combined with and cannot be broken out from data reported 

on WIC, which is addressed in this review.

24GAO, Human Capital: Quality of DOD Status of Forces Surveys Could Be Improved by 

Performing Nonresponse Analysis of the Results, GAO-10-751R (Washington, D.C.: July 

12, 2010).
Page 17 GAO-16-561 DOD Food Assistance 

We also identified other agencies and organizations outside of DOD that 

have access to, or are in a position to collect, data on food assistance 

used by active-duty servicemembers and their families. Standards for 

Internal Control in the Federal Government state that management 

should communicate with external parties regarding quality information 

needed to achieve objectives.25 In addition, DOD Instruction 1342.22 

specifies that family readiness services shall be provided through a 

system that maximizes the network of agencies, programs, services, and 

individuals in a collaborative manner to promote military family 

readiness.26 The instruction further states that family readiness services 

shall promote interagency collaboration and service coordination within 

and among federal and non-federal entities to identify and achieve 

common family readiness goals and improve communication among 

service providers and with servicemembers and their families.

While DOD could benefit from more complete information on 

servicemembers’ use of food assistance, none of the DOD officials we 

met were aware of any efforts by the department to coordinate with 

agencies, such as the USDA, to collect and share relevant data on food 

assistance. Specifically, we contacted multiple offices within USD (P&R) 

to obtain data on the use of food assistance programs, including the 

offices for Military Compensation, Military Community & Family Policy, 

Defense Commissary Agency, Defense Manpower Data Center, and the 

Defense Health Agency. We found that none of these offices had efforts 

to monitor or collect data on servicemembers’ food assistance needs, 

including coordinating with USDA regarding collecting and sharing data or 

other relevant information. The USDA works through various state and 

local agencies to administer four of the five food assistance programs 

commonly used by active-duty servicemembers and their families, 

including: (1) SNAP, (2) WIC, (3) NSLP, and (4) SBP. A provision in the 

NDAA for fiscal year 2016 addressed DOD’s access to information on 

SNAP usage by servicemembers. The NDAA for fiscal year 2016 calls 

for the USDA to ensure that any safeguards that prevent the use or 

 25GAO-14-704G. The standards were updated and went into effect on October 1, 2015. 

The current standards describe the need for quality information similar to the prior 

standards described in GAO/AIMD-00-21.3.1, which were in effect prior to fiscal year 2016 

and cover the time period of government agencies’ data.

26DOD Instruction 1342.22.

Some Data Are Available 

Outside of DOD on 

Servicemembers’ Use of Food

Assistance
Page 18 GAO-16-561 DOD Food Assistance 

disclosure of information collected from SNAP recipients will not prevent 

the USDA from disclosing that information to DOD, or DOD using that 

information, for the purposes of determining the number of SNAP 

applicant households that contain one or more military servicemembers.27

DOD provided us an email exchange that occurred in February to March 

2016 discussing how to use the new authority provided in section 605 of 

the 2016 NDAA to obtain SNAP data. However, officials were not aware 

of further attempts to collect such information. According to results from 

the 2013 U.S. Census Bureau’s annual American Community Survey 

(ACS), about 23,000 active-duty servicemembers28 received SNAP 

benefits in the previous 12 months.29 While it is known that 

servicemembers use food assistance programs and that information on 

recipients can be obtained, specific data on servicemembers’ use of 

these programs are not available because there is no requirement or 

need that has been established for agencies such as the USDA to collect 

such information. For example, during visits to four selected military 

installations,30 we met with local administrators of USDA food assistance 

 27National Defense Authorization Act for Fiscal Year 2016, Pub. L. No. 114-92, § 605 

(2015).

28The estimate is based on responses to the question, “In the past 12 months, did you or 

any member of this household receive benefits from the Food Stamp Program or SNAP?”

The survey did not count members of the military serving overseas. Further, if a member 

of the military was serving overseas and his or her family was living stateside, the member 

of the military would not be listed in the household and therefore would not count in the 

family for this survey. There are some additional limitations to this estimate such as if a 

servicemember was living off base with a roommate who received SNAP benefits, the 

survey would count that servicemember as living in a household receiving SNAP benefits 

even though the member really did not receive SNAP benefits himself or herself. Also, the 

estimate did not differentiate between servicemembers who received SNAP benefits while 

in the military from those who received SNAP benefits prior to joining the military. Activeduty military members living in housing units who received SNAP benefits in the past 12 

months or those living in group quarters who personally received SNAP benefits in the 

past 12 months as measured in the ACS: 23,205 (margin of error is +/- 3,347). Total 

active-duty military members measured in the ACS: 963,220 (margin of error is +/-

16,171).

29According to the USDA, in an average month during fiscal year 2013, SNAP provided 

benefits to 47.6 million people living in nearly 23.1 million households across the United 

States. See U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy 

Support, Characteristics of Supplemental Nutrition Assistance Program Households: 

Fiscal Year 2013, Report No. SNAP-14-CHAR (Alexandria, Va; December 2014).

30We visited Fort Hood, Texas; Altus Air Force Base, Oklahoma; Naval Base San Diego, 

California; and Camp Pendleton, California.
Page 19 GAO-16-561 DOD Food Assistance 

programs who told us that they are able to identify servicemembers 

through required documentation such as a Leave and Earnings 

Statement that will identify if an individual is a member of the U.S. 

military. However, officials said that they do not ask about or routinely 

document an applicant’s military status since it does not have a bearing 

on their eligibility for assistance.

We also spoke with representatives from charitable organizations located 

on the installations that we visited who have information that DOD could 

use to gain insights into the needs of its servicemembers. For example, 

we spoke with representatives from Army Emergency Relief, the NavyMarine Corps Relief Society, and the Air Force Aid Society—each of 

which offers various types of support, including financial support to 

purchase food for servicemembers in need. Army Emergency Relief and 

the Air Force Aid Society track the amount provided for food assistance. 

Specifically, an official with Army Emergency Relief told us that the 

organization provided $2.3 million in food assistance to active-duty 

servicemembers in calendar year 2015, $2.7 million in calendar year 

2014, and $1.8 million in calendar year 2013. According to an official with 

the Air Force Aid Society, the organization provided $300,000 in food 

assistance in fiscal year 2015, and $600,000 in each of the previous two 

years.

During our site visits, we also visited volunteer-run food pantries and food 

distribution operations of varying sizes that were started to address a 

locally-identified need. For example, during our site visit to Altus Air Force 

Base, Oklahoma, we visited a pantry that provides free food to anyone in 

need, but it does not track the number of individuals served. We also 

visited a food pantry on Fort Hood in Texas that Army officials told us 

responded to 508 separate requests for food from active-duty 

servicemembers, retirees, and their family members in fiscal year 2015. 

Of the four military installations, Marine Corps Base Camp Pendleton in 

California had the largest and most organized of the food distribution 

operations that we visited. Specifically, during our visit to the base in 

December 2015, we identified four food pantries that distribute food on 

specific days of the month around Camp Pendleton. The manager of one 

pantry told us that its operation alone provides food assistance each 

month to an average of 400 to 500 military families on Camp Pendleton. 

Without coordination with USDA, and considering outreach to other 

organizations that have data on servicemembers’ use of food assistance, 

DOD will miss the opportunity to collect more complete data and 

information on the needs of its servicemembers.
Page 20 GAO-16-561 DOD Food Assistance 

DOD has not assigned department-level responsibilities, such as a 

collateral duty within the Office of the USD (P&R), for monitoring the use 

of food assistance programs by active-duty servicemembers and their 

families. Standards for Internal Control in the Federal Government state 

that management should establish an organizational structure, assign 

responsibility, and delegate authority to achieve the entity’s objectives.31

We contacted multiple offices within USD (P&R) to obtain data on the use 

of food assistance programs, including Military Compensation, Military 

Community & Family Policy, Defense Commissary Agency, Defense 

Manpower Data Center, and Defense Health Agency. None of these 

offices was responsible for monitoring servicemembers’ use of food 

assistance programs with the exception of FSSA and the meals provided 

under NSLP and SBP at DODEA schools. Further, to better understand 

the purpose of DOD’s survey questions on food assistance and how any 

resulting data are used, we spoke with the Defense Manpower Data 

Center official involved in developing DOD’s Status of Forces Survey who 

told us that different offices within USD P&R are responsible for 

developing questions that relate to their particular mission. The official 

referred us to the Military Community and Family Policy office within USD 

(P&R) for the survey questions related to servicemembers’ use of food 

assistance programs. However, officials were not able to identify any 

official or office that had responsibility for or knowledge about why or how 

these questions are used, omitted, or changed from survey year to survey 

year. In general, DOD officials could not identify an office with 

responsibility for reviewing and updating the questions on food assistance 

asked in the Status of Forces Survey.

Without collecting more data and determining whether DOD should 

assign department-level responsibility for monitoring servicemembers’

use of food assistance programs, DOD will not have a good 

understanding of the prevalence of need among servicemembers. 

Moreover, assigning department-level responsibility for monitoring food 

assistance needs could provide DOD with the ability to coordinate the 

military services’ collection and analysis of relevant data and determine 

 31GAO/AIMD-00-21.3.1. These standards were in effect prior to fiscal year 2016 and 

cover the time period of government agencies’ data. The standards were subsequently 

updated and similarly require management to establish the same organization elements. 

The updated standards went into effect on October 1, 2015; see GAO-14-704G.

DOD Has Not Assigned 

Department-Level 

Responsibilities for 

Monitoring the Use of 

Food Assistance 

Programs
Page 21 GAO-16-561 DOD Food Assistance 

what actions may be needed to address the needs of the 

servicemembers and their families.

Military service officials at all four of the military installations that we 

visited described challenges that servicemembers may experience when 

seeking food assistance benefits, and stated they have been addressing 

the challenges by continuing to refer interested servicemembers to 

potential assistance from government food assistance programs and 

charitable organizations. Some of the challenges mentioned during our 

group interviews at each of the four military installations that we visited 

were: (1) limited awareness of some food assistance programs (2) stigma 

associated with receiving food assistance; and (3) misconceptions about 

military compensation and the ability of a servicemember to qualify for 

food assistance.

Military service officials who assist servicemembers and their families at 

all four of the installations we visited generally had knowledge of some 

food assistance programs administered by USDA, such as SNAP and 

WIC. However, we found that some of the military officials at three of the 

four installations we visited were not aware of the FSSA food assistance 

program even though it is administered by DOD. Those who were aware 

of FSSA said that they had not referred many servicemembers to the 

program because it is more difficult to qualify for than SNAP. For 

example, at one military installation, the officials told us that no applicant 

has been able to qualify for FSSA. In addition, the military officials told us 

that they assisted servicemembers who were also not aware of some 

food assistance programs, such as foodbanks, SNAP, and particularly 

FSSA.

Military service officials at three of the four selected installations we 

visited stated that they believe a societal stigma exists generally for those 

who use food assistance. Officials at one installation added that the selfsufficient culture of the military can make these stigmas even more 

pronounced for servicemembers who receive food assistance from, for 

example, SNAP, and to a lesser degree from charitable organizations and 

food pantries. In contrast, these officials said that there seems to be no 

stigma with regard to receiving WIC benefits, which suggest that WIC is 

seen as more of a health and nutrition benefit rather than a program for 

those with financial and food assistance needs. Officials added that WIC 

is advertised more than other food assistance programs; in some cases 

Military Officials at 

Selected Installations 

Cited Challenges 

Affecting 

Servicemembers 

Who Seek Food 

Assistance Benefits

Limited Awareness of 

Food Assistance 

Programs

Stigma for Those 

Receiving Food 

Assistance
Page 22 GAO-16-561 DOD Food Assistance 

there have been proactive efforts to promote the program by including 

WIC representatives at military briefings to inform and encourage 

servicemembers to apply if they are expecting or have small children.

Military officials at all four of the installations we visited cited 

misconceptions about military compensation relative to income eligibility 

requirements for food assistance programs as another challenge that may 

deter servicemembers in need from seeking such assistance. For 

example, some military officials at one installation who are in a position to 

refer servicemembers to food assistance programs sometimes do not 

because they mistakenly assume that a potential recipient’s income 

exceeds eligibility requirements for such programs.

The BAH benefit also plays a role in a servicemember’s eligibility for food 

assistance and may contribute to misconceptions about eligibility and a 

servicemember’s decision to apply for such programs. For example, a 

program such as SNAP counts the amount a servicemember receives in 

BAH as part of one’s income when determining eligibility for benefits, 

while other programs, such as WIC, do not count BAH as income. Also, 

the amount of a servicemember’s BAH benefit is affected by location, 

meaning that the same servicemember may qualify for food assistance at 

one location but not be eligible at another location with a higher housing 

benefit. For example, a servicemember stationed at Altus Air Force Base, 

Oklahoma, would have a BAH rate of $789, that, when combined with 

one’s basic pay, may result in a level of income that is low enough to 

qualify for food assistance.32 However, if that same servicemember 

transferred to San Diego, California, which has a BAH rate of $2,178, the 

servicemember may no longer have income low enough to qualify for 

food assistance programs for which he or she was previously eligible.33

Military service officials we interviewed at all four of the installations we 

visited suggested that BAH makes it difficult to qualify when determining 

eligibility for SNAP in part because a servicemember’s ability to qualify for 

SNAP can be affected by the inclusion of BAH. Currently, U.S. code 

requires all income, regardless of the source, to be considered when 

 32Altus, Oklahoma BAH rate (with dependents) is as of 2015.

33San Diego, California BAH rate (with dependents) is as of 2015.

Misconceptions About 

Military Compensation and 

Income Eligibility 

Requirements for Food 

Assistance
Page 23 GAO-16-561 DOD Food Assistance 

determining eligibility for SNAP unless specifically excluded by law, and 

BAH is not excluded by law. Further, the U.S. Code defines regular 

military compensation to include BAH and DOD’s description of military 

pay and compensation includes BAH.

34 On January 12, 2016, the Chief 

Executive Officer for MAZON,35 a national nonprofit organization working 

to end hunger, testified to the House Committee on Agriculture, 

Subcommittee on Nutrition, that many lower ranking servicemembers are 

made ineligible for SNAP because their housing allowance is counted as 

income.36 MAZON contended that since BAH is excluded as income for 

the purposes of calculating income taxes and eligibility for some federal 

programs, such as Head Start, that BAH should be excluded as income 

for the purposes of determining eligibility for all food assistance 

programs.37 MAZON maintains that treating the BAH benefit as income 

for determining eligibility for SNAP puts some military families at an unfair 

disadvantage and disqualifies them from receiving food assistance.

Military families facing financial hardship have access to government and 

charitable food assistance programs. As the administrator of FSSA and 

through the Status of Forces Survey that it periodically conducts, DOD 

has some data on the use of food assistance programs by active-duty 

servicemembers and their families. However, the survey is of limited 

usefulness because it does not address all the food assistance programs 

that servicemembers use. In addition, based on our interviews with DOD 

officials, DOD has not coordinated with and leveraged the information and 

access that other agencies, such as the USDA, have on servicemembers’

use of food assistance. USDA’s role as one of the primary administrators 

of food assistance programs in the U.S. is one source of information that 

 3437 U.S.C. § 101(25).

35MAZON: A Jewish Response to Hunger is a national nonprofit organization working to 

end hunger among people of all faiths and backgrounds in the United States and Israel.

36Past, Present, and Future of SNAP: Addressing Special Populations: Hearing Before the 

Subcomm. on Nutrition of the H. Comm. on Agriculture, 114th Cong. (2016) (statement of 

Abby J. Leibman, President and CEO, MAZON).

37The Head Start program, overseen by the Department of Health and Human Services’ 

Administration for Children and Families and administered by the Office of Head Start 

(OHS), is one of the largest federal early childhood programs. Head Start promotes the 

school readiness of young children from low-income families through agencies in their 

local community.

Conclusions
Page 24 GAO-16-561 DOD Food Assistance 

DOD could use to better understand the extent to which such programs 

are used by active-duty servicemembers and their families. Without more 

complete data and determining whether it needs to assign specific 

department-level responsibility within DOD for monitoring food assistance 

use, DOD will continue to have a limited understanding of 

servicemembers’ food assistance needs and whether further actions are 

needed to help ensure that the basic needs of servicemembers and their 

families are met and that any existing gaps are not related to their service 

in the military.

To more fully understand the food assistance needs that exist for activeduty servicemembers and their families, and to help ensure that DOD 

effectively targets its support to those in need of assistance, we 

recommend that the Secretary of Defense direct the Office of the Under 

Secretary of Defense for Personnel and Readiness to take the following 

two actions:

• Revise, as appropriate, any existing data-collection mechanisms, 

such as periodic surveys, to collect and analyze more complete 

data on the use of food assistance programs by servicemembers 

and their families and use the data to determine if any further 

actions are needed, such as assigning responsibilities at the 

department-level for monitoring the use of food assistance 

programs by active-duty servicemembers; and,

• Coordinate with USDA to leverage its access to data on activeduty servicemembers and their families who use its programs and 

services and consider outreaching to other organizations that 

have data on servicemembers’ use of food assistance.

We provided a draft of this report to DOD for review and comment. In its 

written comments, reproduced in appendix IV, DOD concurred with our 

first recommendation and partially concurred with our second 

recommendation.

Specifically, DOD concurred with our first recommendation to revise, as 

appropriate, any existing data-collection mechanisms, such as periodic 

surveys, to collect and analyze more complete data on the use of food 

assistance programs by servicemembers and their families, and use the 

data to determine if any further actions are needed, such as assigning 

responsibilities at the department-level for monitoring the use of food 

assistance programs by active-duty servicemembers. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 25 GAO-16-561 DOD Food Assistance 

DOD partially concurred with our second recommendation, to coordinate 

with USDA to leverage its access to data on active-duty servicemembers 

and their families who use its programs and services and consider 

outreaching to other organizations that have data on servicemembers’ 

use of food assistance. DOD noted in its comments that it concurred with 

most of the findings regarding visibility on servicemembers receiving food 

assistance programs but non-concurred with our statement that DOD has 

not coordinated with USDA to access its data on servicemember use of 

programs it administers. DOD stated that it has tried, for several years, to 

obtain SNAP data from USDA and that although the National Defense 

Authorization Act for Fiscal Year 2016 clarified that existing safeguards 

on SNAP recipient data do not prevent the disclosure of such information 

to DOD, it also did not mandate that USDA provide the data. Further, 

DOD stated that the Defense Manpower Data Center has been in contact 

with USDA to set up data exchange agreements, but that it has been 

unable to identify one source within USDA from which to obtain these

data. 

We are encouraged by DOD’s recent efforts to work with USDA to obtain 

data that would provide the department with greater insight into the needs 

of its servicemembers. However, during the course of this review we 

spoke with DOD officials—on multiple occasions—in the Office of the 

Deputy Assistant Secretary of Defense for Military Community and Family 

Policy, the Office of the Under Secretary of Defense for Personnel and 

Readiness’ Military Compensation office, and at the Defense Manpower 

Data Center, among others, to discuss the department’s efforts to monitor 

servicemembers’ food assistance needs. We consistently found officials 

to be unaware of any previous such efforts by DOD until after passage of 

the National Defense Authorization Act for Fiscal Year 2016 when we 

were provided, as noted in our report, an email exchange that occurred in 

February to March 2016 discussing how to use the new authority to 

obtain SNAP data. Importantly, no DOD official with whom we met 

believed that their office was responsible for such coordination with

USDA. 

Furthermore, following the receipt of DOD’s comments on our draft report, 

we contacted the Office of Assistant Secretary of Defense, Manpower 

and Reserve Affairs to further inquire about the efforts it noted had 

previously been taken to obtain data from USDA. Specifically, we spoke 

with an official in that office who stated that three or four years earlier 

DOD tried to obtain data from USDA on servicemembers’ use of SNAP, 

but were unsuccessful. We requested, but DOD did not provide us with, 

any additional documentation to confirm this or other efforts to coordinate 
Page 26 GAO-16-561 DOD Food Assistance 

with USDA to access its data. We also recognize the inherent complexity 

of interagency coordination and believe DOD should continue its dialogue 

with USDA about ways in which it can leverage their access to data that 

would provide valuable insights into servicemembers’ needs.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense; the Secretary of Agriculture; the 

Secretaries of the Army, the Navy, and the Air Force; the Commandant of 

the Marine Corps; and the Under Secretary of Defense for Personnel and 

Readiness. In addition, the report is available at no charge on the GAO 

website at http://www.gao.gov.

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

at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff members who made key contributions to this 

report are listed in appendix V.

Brenda S. Farrell

Director, Defense Capabilities and Management
Page 27 GAO-16-561 DOD Food Assistance 

List of Committees

The Honorable Pat Roberts

Chairman

The Honorable Debbie Stabenow

Ranking Member

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives
Appendix I: Scope and Methodology

Page 28 GAO-16-561 DOD Food Assistance 

Our review focused on the food assistance programs available to activeduty servicemembers from the four military services—Army, Navy, Marine 

Corps, and Air Force—and their families. To assess the extent to which 

active-duty servicemembers and their families have access to 

government and charitable food assistance programs, we reviewed 

various reports and documents to identify federal government programs 

that focus primarily on providing food and nutrition assistance to lowincome individuals and households. The reports and documents included: 

our related report, Domestic Food Assistance: Complex System Benefits 

Millions, but Additional Efforts Could Address Potential Inefficiency and 

Overlap among Smaller Programs; our related testimony, Domestic Food 

Assistance: Multiple Programs Benefit Millions of Americans, but 

Additional Action Is Needed to Address Potential Overlap and 

Inefficiencies,

1 and a Congressional Research Service report on domestic 

food assistance programs, Domestic Food Assistance: Summary of 

Programs.

2 For the purpose of this engagement, we focused on 

government and charitable food assistance programs available to activeduty servicemembers and their families who are assigned to installations 

within the continental United States. We interviewed officials from United 

States Department of Agriculture (USDA) and Department of Defense 

(DOD) to identify food assistance programs available to active-duty 

servicemembers and their families. Further, we interviewed officials who 

administer these programs at the federal, state, and local levels to obtain 

additional background information and confirm the availability and 

completeness of the food assistance programs we identified. To find 

charitable organizations that provide food assistance to active-duty 

servicemembers and their families, we interviewed officials from each of 

the military services who identified the following charities that support 

servicemembers and families: Army Emergency Relief, Air Force Aid 

Society, and Navy-Marine Corps Relief Society. Further, we conducted 

internet searches to identify charitable food pantries operating on military 

 1

See GAO, Domestic Food Assistance: Multiple Programs Benefit Millions of Americans, 

but Additional Action Is Needed to Address Potential Overlap and Inefficiencies, 

GAO-15-606T (Washington, D.C.: May 20, 2015) and Domestic Food Assistance: 

Complex System Benefits Millions, but Additional Efforts Could Address Potential 

Inefficiency and Overlap among Smaller Programs, GAO-10-346 (Washington, D.C.: Apr. 

15, 2010).

2

Congressional Research Service, Domestic Food Assistance: Summary of Programs

(Feb. 4, 2015).

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 29 GAO-16-561 DOD Food Assistance 

installations, and when one was located, we contacted local military 

service officials to confirm its existence.

To assess the extent to which there was any variation in eligibility 

requirements for government food assistance programs, we reviewed the 

laws that established selected food assistance programs and analyzed 

eligibility criteria for these programs and used those eligibility criteria to 

develop scenarios to illustrate situations in which a servicemember would 

or would not qualify for these food assistance programs.3 Specifically, we 

conducted an analysis to show what a servicemember in the paygrade of 

E-4 needs to meet the income eligibility requirements for Family 

Subsistence Supplemental Allowance (FSSA), Supplemental Nutrition 

Assistance Program (SNAP), Special Supplemental Nutrition Program for 

Women, Infants, and Children (WIC), National School Lunch Program 

(NSLP), and School Breakfast Program (SBP) at the four military 

installations we visited. We selected the paygrade of E-4 because these 

servicemembers are junior enlisted personnel and as such are at the 

lower end of the pay scale for active-duty servicemembers. Also, FSSA 

program data for calendar year 2014 showed that the E-4 paygrade was 

the most frequent paygrade to receive this allowance, suggesting that 

personnel at this paygrade have a need for assistance. In calculating the 

servicemember’s income, we included only three types of military pay: 

Basic Pay, Basic Allowance for Subsistence (BAS), and Basic Allowance 

for Housing (BAH) with dependent rate. We included these elements of 

military pay because active-duty servicemembers who are entitled to 

basic pay are also entitled to BAS and BAH. We did not include other 

military pay and allowances because active-duty servicemembers are not 

necessarily eligible for the other pay and allowances. Further, our 

analysis is based on the assumption that the only source of income for 

the household is the servicemembers’ military pay. Next, we reviewed 

relevant federal statutes to determine the income criteria for each of the 

programs and what types of military pay and allowances are included in 

active-duty servicemembers’ income when applying to one of these food 

assistance programs. Since federal law provides states some discretion 

in setting the income criteria for some of the food assistance programs 

and deciding what portion of military pay is included in income, we 

 3

The statutes we reviewed were 7 U.S.C. § 2014 (SNAP), 37 U.S.C. § 402a (FSSA), and 

42 U.S.C. §§ 1758 (NSLP), 1773 (SBP), and 1786 (WIC).
Appendix I: Scope and Methodology

Page 30 GAO-16-561 DOD Food Assistance 

interviewed state officials to determine how they calculated the income of 

active-duty servicemembers and what specific income criteria they 

employ. The state’s income criteria are on a graduated scale that as the 

household size increases, the income level to qualify for benefits also 

increases. We compared the income of a servicemember in the paygrade 

of E-4 to the income criteria used by the state and determined how large 

a household the servicemember needed in order to qualify given his/her 

income.

To determine the household size required to qualify for SNAP benefits, 

we made additional calculations with several assumptions. Applicants for 

SNAP must pass a two-income test, a gross-income test and a netincome test. Most households must meet gross- and net-income tests, 

but a household with an elderly person or a person who is receiving 

certain types of disability payments has to meet only the net-income test. 

We based our analysis on the assumption that the servicemembers had 

to pass both the gross- and net-income tests. To calculate net income, 

SNAP allows taking a number of deductions from the household income.

In conducting our analysis, we assumed that the household does not 

include any elderly or disabled persons, there were no dependent care, 

medical expenses, or child-support deductions, the monthly rent or 

mortgage payment equaled the servicemember’s BAH, and the standard 

utility allowance was appropriate to use in the calculations. We had state 

or local officials responsible for the SNAP program in their area review 

our calculations to ensure they were correct.

To assess the extent to which DOD has identified that active-duty 

servicemembers and their families use food assistance programs, we 

interviewed officials from multiple offices within Under Secretary of 

Defense for Personnel and Readiness (USD (P&R)) to determine which 

office(s) had department-level responsibilities related to active-duty 

servicemembers’ use of food assistance programs and to obtain any 

relevant data on servicemembers’ use of these programs. We reviewed 

DOD documents on the organization and assigned responsibilities of 

USD (P&R). We obtained and reviewed the results of recent surveys 

completed by active-duty servicemembers that include questions about 

the use of food assistance programs. Specifically, we obtained and 

reviewed DOD’s Status of Forces Survey of Active Duty Members for 

calendar year 2010, 2012, and 2013, the U.S. Census Bureau’s 2013 

American Community Survey, FSSA data from the Defense Joint Military 

Pay System, and data on the number of students in DOD Education 

Activity (DODEA) schools who were eligible to receive free and/or 

reduced-price meals. We assessed the reliability of this information by 
Appendix I: Scope and Methodology

Page 31 GAO-16-561 DOD Food Assistance 

interviewing responsible officials and, in the case of the Status of Forces 

Survey, reviewing documentation of the survey’s methodology. We found 

this information to be sufficiently reliable for the purpose of reporting 

DOD’s awareness of military participants receiving these benefits. Also, 

we compared the data collection and communications processes for DOD 

with Standards for Internal Control in the Federal Government, which 

state that management should obtain quality information to achieve its 

objectives and that it should communicate with external parties regarding 

the information that is needed to achieve its objectives.4 To obtain 

information on other food assistance programs available to 

servicemembers and their families for which data were not available, we 

visited four military installations in the United States and interviewed 

officials who administer these programs, officials who assist 

servicemembers in need, and visited food pantries, if any, on the 

installation. We selected sites to represent each of the military services. 

We then refined our site selections to include: locations with a large 

population of servicemembers and dependents, a range of cost-of-living 

areas (using the BAH rates), and the presence of a food pantry and/or a 

WIC program office on the military installation. Specifically, we visited Fort 

Hood, Texas; Altus Air Force Base, Oklahoma; Naval Base San Diego, 

California; and Camp Pendleton, California. In addition, we visited and 

interviewed state and local officials who oversee non-military food 

assistance programs at these four geographic locations. Finally, we 

interviewed officials from the Navy-Marine Corps Relief Society, Army 

Emergency Relief, and the Air Force Aid Society to learn what food 

assistance they provide to active-duty servicemembers and their families.

To identify any challenges that active-duty servicemembers encounter 

when seeking food assistance, we interviewed military service officials 

who assist servicemembers in need of financial assistance, including food 

assistance, to gain their perspectives on any challenges that may be 

faced by servicemembers attempting to obtain such assistance. 

Specifically, we interviewed military Chaplains, First Sergeants and 

 4

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

21.3.1 (Washington, D.C.: November 1999). These standards were in effect prior to fiscal 

year 2016 and cover the time period of government agencies’ data. The standards were 

subsequently updated. The updated standards went into effect on October 1, 2015. See 

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

(Washington, D.C.: Sept. 10, 2014).
Appendix I: Scope and Methodology

Page 32 GAO-16-561 DOD Food Assistance 

Command Master Chiefs, financial specialists, and officials from 

charitable military organizations, including the Navy-Marine Corps Relief 

Society, the Air Force Aid Society, and Army Emergency Relief. We also 

interviewed private and local government officials who assist 

servicemembers with food assistance, such as SNAP, WIC, summermeals programs, and food pantries. Further, we interviewed 

representatives from advocacy groups who support active-duty families or 

try to reduce hunger in America.

Table 2 contains a list of organizations, offices, and military installations 

we visited or contacted during our review.

Table 2: Organizations, Offices, and Military Installations Visited or Contacted

Department of Defense • Military Compensation, Military Personnel Policy, Office of the Under Secretary for 

Personnel and Readiness, Washington, D.C.

• Office of the Deputy Assistant Secretary of Defense for Military Community and 

Family Policy, Washington, D.C.

• DOD Education Activity, Alexandria, Virginia

• Deputy Assistant Secretary of Defense (Force Readiness), Washington, D.C.

• Defense Research, Surveys, and Statistics Center, Defense Manpower Data 

Center, Alexandria, Virginia

• Defense Commissary Agency, Washington, D.C.

Army • Fort Hood, Texas

• Office of the Assistant Secretary of the Army, Manpower and Reserve Affairs, 

Washington, D.C.

Air Force • Altus Air Force Base, Oklahoma

• U.S. Air Force Headquarters, Airman & Family Care Division, Air Force Services 

Directorate, Washington, D.C.

• U.S. Air Force Headquarters, Services Operations Division, Sustainment Branch, 

Washington, D.C.

Navy • Naval Base San Diego, California

• Fleet and Family Support Programs, Commander, Navy Installations Command, 

Washington, D.C.

Marine Corps • Marine Corps Base Camp Pendleton, California

• Marine and Family Programs Division, Headquarters Marine Corps, Quantico, 

Virginia

Department of Commerce • American Community Survey Office, U.S. Census Bureau, Suitland, Maryland

Department of Agriculture • Food and Nutrition Service, Alexandria, Virginia

State agencies • California Department of Social Services, Sacramento, California

• Oklahoma Department of Human Services, Oklahoma City, Oklahoma

• Texas Department of State Health Services, Austin, Texas

• Texas Health and Human Services Commission, Austin, Texas
Appendix I: Scope and Methodology

Page 33 GAO-16-561 DOD Food Assistance 

Local government agencies • CalFresh Eligibility Operations, Health & Human Services Agency, San Diego 

County, San Diego, California

• American Red Cross, Women, Infants, & Children Program, San Diego, California

• Jackson County Health Department, Altus, Oklahoma

• Region 2, District 3 (Greer, Harmon, Jackson, Kiowa, and Tillman Counties), 

Oklahoma Department of Human Services, Altus, Oklahoma

• Bell County Public Health District, WIC Program, Fort Hood, Texas

• Office of Eligibility Services, Texas Health and Human Services Commission, 

Killeen, Texas

Charitable organizations • Army Emergency Relief, Alexandria, Virginia

• Bay Area Food Bank, Theodore, Alabama

• Feeding America, Chicago, Illinois

• Feeding South Dakota, Sioux Falls, South Dakota

• Foodbank of Southeastern Virginia, Norfolk, Virginia

• Jewish Family Service of San Diego, San Diego, California

• National Military Family Association, Alexandria, Virginia

• Navy-Marine Corps Relief Society, San Diego, California

• Regional Food Bank of Oklahoma, Oklahoma City, Oklahoma

• Second Harvest Food Bank of Southeast North Carolina, Fayetteville, North 

Carolina

Other • Military Compensation and Retirement Modernization Commission, Arlington, 

Virginia

Source: GAO. I GAO-16-561

We conducted this performance audit from July 2015 to July 2016 in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs

Page 34 GAO-16-561 DOD Food Assistance 

In our April 2010 report, we identified 18 programs that focus primarily on 

providing food and nutrition assistance to low-income individuals and 

households (see table 3).1 Federal food assistance programs provide 

different types of food benefits to address a variety of needs through a 

decentralized service delivery structure of federal, state, and local 

agencies and nonprofit organizations. In May 2015, we testified before 

Congress that in fiscal year 2014 the four largest food assistance 

programs—Supplemental Nutrition Assistance Program (SNAP), the 

National School Lunch Program, the Special Supplemental Nutrition 

Program for Women, Infants, and Children, and the School Breakfast 

Program—accounted for 93 percent of total spending on the 18 

programs.2 We further testified that SNAP, the largest program, 

accounted for more than 70 percent of the overall spending total. Fifteen 

of the programs are administered by the U.S. Department of Agriculture, 

one program is administered by the Department of Homeland Security’s 

Federal Emergency Management Agency, and two programs are 

administered by the Health and Human Services’ Administration on 

Aging.

 1

GAO, Domestic Food Assistance: Complex System Benefits Millions, but Additional 

Efforts Could Address Potential Inefficiency and Overlap among Smaller Programs, 

GAO-10-346 (Washington, D.C.: Apr. 15, 2010).

2

GAO, Domestic Food Assistance: Multiple Programs Benefit Millions of Americans, but 

Additional Action is Needed to Address Potential Overlap and Inefficiencies, 

GAO-15-606T (Washington, D.C.: May 20, 2015).

Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs
Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs

Page 35 GAO-16-561 DOD Food Assistance 

Table 3: Selected Federal Food and Nutrition Assistance Programs, by Agency

Program Target population Benefit type Participation (approx.)a

U.S. Department of Agriculture

Child and Adult Care Food 

Program

Children in certain 

nonresidential child care 

centers, family, or group day 

care; children in after-school 

programs in low-income areas, 

or residing in emergency 

shelters; and chronically 

impaired disabled adults and 

persons 60 years or older in 

adult day care centers.

Reimburse local providers 

(child-care centers, adult daycare centers, etc.) for meals and 

snacks served.

An average of 3.6 million 

children and adults was served

daily in fiscal year 2014.

Commodity Supplemental Food 

Program

Low-income persons 60 years 

or older. Low-income pregnant, 

postpartum, and breastfeeding 

women, infants, and children up 

to age 6 who were receiving 

benefits as of February 6, 

2014—can continue to receive 

assistance until they are no 

longer eligible.

Supplemental foods, in the form 

of USDA commodities, are 

provided in food packages to 

individuals.

An average of 573,703 people 

was served monthly in fiscal 

year 2014, including 9,996 

women, infants, and children, 

and 563,707 elderly 

participants.

Community Food Projects 

Competitive Grant Program

Low-income individuals in 

participating communities.

Matching grants made to 

organizations to plan and 

implement projects to improve 

access of low-income 

community members to 

food/nutrition, increase the selfreliance of communities in 

providing for their own needs, 

and promote comprehensive 

responses to local food, farm, 

and nutrition issues.

26 projects were funded in fiscal 

year 2013.

Food Distribution Program on 

Indian Reservations

American Indian and non-Indian 

households that reside on a 

reservation and Indian 

households living in an 

otherwise designated area, and 

recognized as having 

inadequate income and 

resources.

Food is provided to qualifying 

households.

An average of 85,400 

participants was served monthly 

in fiscal year 2014.

Fresh Fruit and Vegetable 

Program

Elementary school children in 

designated schools with a high 

percentage of students eligible 

for free or reduced-price meals.

Reimburse local providers 

(elementary schools) for fresh 

fruit and vegetable snacks 

served free to students outside 

of breakfast or lunch periods.

Students in more than 7,100 

schools during the 2011-2012 

school year.
Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs

Page 36 GAO-16-561 DOD Food Assistance 

National School Lunch Program Students from families with 

incomes below 130 percent of 

the federal poverty level (or from 

families receiving SNAP) qualify 

for free meals, and students from 

families with incomes below 185 

percent of the federal poverty 

level qualify for reduced-price 

meals.

Cash grants and food donations 

are provided to reimburse local 

providers (schools) for meals 

and snacks served. Schools 

must agree to serve free and 

reduced-price meals to eligible 

children.

An average of 30.3 million 

students was served daily in 

fiscal year 2014.

Nutrition Assistance for Puerto 

Rico

Needy persons living in the 

Commonwealth of Puerto Rico.

Nutrition assistance benefits 

provided via Electronic Benefit 

Transfer (EBT) cards to needy 

persons for the purchase of food 

at authorized retailers.

An average of 1.35 million 

individuals was served 

monthly in fiscal year 2014.

School Breakfast Program Eligible children in schools and 

residential child-care institutions. 

Children whose families meet 

income eligibility guidelines 

qualify for free or reduced- price 

breakfasts.

Reimburse local providers 

(schools and residential childcare institutions) for breakfasts 

served.

An average of 13.5 million 

students was served daily in 

fiscal year 2014.

Senior Farmers’ Market 

Nutrition Program

Low-income seniors Benefits can be used to 

purchase fresh fruits, 

vegetables, and herbs at 

authorized farmers’ markets, 

roadside stands, and community 

supported agriculture programs.

787,139 low-income seniors 

were served in fiscal year 

2014.

Special Milk Program Children in schools, of high 

school grade or under, child-care 

institutions, and similar nonprofit 

institutions that do not participate 

in other federal meal service 

programs, including the National 

School Lunch or School 

Breakfast Programs.

Formula grant, reimbursing cost 

of milk for children in schools, 

camps, and other programs that 

do not participate in other child 

nutrition programs.

3,868 schools, non-residential 

child-care institutions, and 

summer camps participated, 

and 49.9 million half-pints 

were served in fiscal year 

2014.

Summer Food Service Program Children from needy areas 

during summer break or school 

vacations.

Reimburse local providers 

(schools, government agencies, 

and nonprofit organizations) for 

meals and snacks served in 

programs during breaks in 

school year.

During July 2014, 2.63 million 

children participated on an 

average day.

Supplemental Nutrition 

Assistance Program (SNAP)

Low-income individuals and 

households with gross income at 

or below 130 percent of federal 

poverty level or net income at or 

below 100 percent of the poverty 

level and with limited resources.

Benefits provided to households 

through electronic debit card for 

food purchase in participating 

retail stores.

An average of 46.3 million 

people was served monthly in 

fiscal year 2014.
Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs

Page 37 GAO-16-561 DOD Food Assistance 

The Emergency Food 

Assistance Program

Needy individuals, such as those 

who may be homeless or 

participate in welfare programs.

Commodity foods are distributed 

through state agencies to food 

banks and other agencies, which 

provide food to local 

organizations, such as soup 

kitchens and food pantries, or 

directly provide the foods to 

needy households.

USDA entitlement and bonus 

commodity foods valued at 

over $566 million delivered to 

states for distribution in fiscal 

year 2014.

Special Supplemental Nutrition 

Program for Women, Infants, 

and Children (WIC)

Low-income infants, children to 

age 5, and women who are 

pregnant, postpartum, and 

breastfeeding and who are 

determined to be at nutritional 

risk.

Check, voucher, or electronic 

benefit transfer benefits provided 

to recipients to pay for 

supplemental foods, and provide 

nutrition education and health 

care referrals for participants. 

Some state agencies distribute 

WIC foods directly to recipients 

through warehouses or home 

delivery.

An average of 8.3 million 

women, infants, and children 

was served monthly in fiscal 

year 2014.

WIC Farmers’ Market Nutrition 

Program

WIC participants and those on a 

waiting list to receive WIC 

benefits (Low-income infants, 

children to age 5, and women 

who are pregnant, postpartum, 

and breastfeeding and who are 

determined to be at nutritional 

risk).

Coupons provided for purchase 

of fresh fruits and vegetables at 

certified farmers’ markets.

Over 1.6 million women, 

infants, and children were 

served in fiscal year 2014.

Department of Homeland Security’s Federal Emergency Management Agency

Emergency Food and Shelter 

Program

Homeless individuals. Funds provided to private and 

independent nonprofit or public 

organizations (such as 

community action agencies, food 

banks, and food pantries) to 

provide emergency food and 

shelter to families and individuals 

in need of assistance.

More than 52 million meals 

were provided in fiscal year 

2014

Health and Human Services’ Administration on Aging

Elderly Nutrition Program: 

Home-Delivered and 

Congregate Nutrition Services

Individuals 60 years of age and 

older and their spouses, 

especially those with the greatest 

social or economic need, and in 

certain cases, under age 60 if the 

individual is disabled and 

accompanies an older individual 

to meals. Special focus is given 

to those with greatest economic 

or social need, including lowincome minorities and those 

residing in rural areas.

Supports the provision of 

nutritious meals (with education 

and other services) served in a 

congregate setting or delivered 

to the home, if individual is 

homebound.

More than 830,000 individuals 

received home-delivered 

meals and 1.6 million seniors 

received congregate meals in 

fiscal year 2013.
Appendix II: Listing of Selected Federal Food 

and Nutrition Assistance Programs

Page 38 GAO-16-561 DOD Food Assistance 

Grants to American Indian, 

Alaska Native, and Native 

Hawaiian organizations for 

nutrition and supportive 

services

American Indians, Alaska 

Natives, and Native Hawaiians 

who are at least 60 years old and 

their spouses (or those 

designated as older Indian by 

tribal authorities).

Grants are provided to tribal 

organizations to fund services 

including nutrition and supportive 

services, similar to those in the 

Elderly Nutrition Program: 

Home-Delivered and Congregate 

Nutrition Services.

25,192 American Indian elders 

received home-delivered 

meals and 52,137 received 

congregate meals in fiscal 

year 2013.

Source: GAO. | GAO-16-561

a

Participation information varies by program because some programs provide benefits to individuals 

while others provide a service or meal.
Appendix III: Eligibility Requirements for Food 

Assistance Programs Commonly Used by 

Active-Duty Servicemembers and Their 

Families

Page 39 GAO-16-561 DOD Food Assistance 

We obtained copies of eligibility requirements for government food 

assistance programs that applicants—whether military or civilian—must 

meet to receive benefits, and this appendix summarizes requirements for 

the five programs commonly used by servicemembers and families. In 

this report, we describe income requirements and how income affects 

active-duty servicemembers’ eligibility for government food assistance 

programs. In addition to the income requirements, each of these 

programs has other requirements that must be met before one may 

receive benefits or, in some cases, provisions for specific groups to 

receive benefits without regard to the other eligibility requirements. The 

requirements for the five programs we found that servicemembers and 

families use are described below.

Title 37, section 402a of the U.S. Code and DOD Instruction 1341.11 

require members of the military services serving on active duty to meet 

the following requirements to receive FSSA: income, Basic Allowance for 

Subsistence (BAS), pay status, dependents, and application.1

a. Income: The income of the servicemember, together with the 

income of the rest of the household (if any) of that servicemember, 

must be within 130 percent of the federal poverty guidelines.2

b. BAS: Servicemembers must be receiving full or partial BAS.

c. Pay status: Servicemembers must be in a pay status. When a 

servicemember is in a non-pay status for any reason, the 

servicemember is not eligible for FSSA during that non-pay 

period.

d. Dependent: At least one person in the household of a 

servicemember must be a military dependent for that 

servicemember.3

 1

Department of Defense Instruction 1341.11, Family Subsistence Supplemental 

Allowance (FSSA) Program (March 4, 2008).

2

Household is defined as an individual who lives alone or who, while living with others, 

customarily purchases food and prepares meals for home consumption separate and 

apart from the others; or a group of individuals who live together and customarily purchase 

food and prepare meals together for home consumption.

Appendix III: Eligibility Requirements for 

Food Assistance Programs Commonly Used 

by Active-Duty Servicemembers and Their 

Families

Family Subsistence 

Supplemental Allowance 

(FSSA)
Appendix III: Eligibility Requirements for Food 

Assistance Programs Commonly Used by 

Active-Duty Servicemembers and Their 

Families

Page 40 GAO-16-561 DOD Food Assistance 

e. Application: Servicemembers must apply and be certified to 

receive the FSSA payment.

The National Defense Authorization Act for Fiscal Year 2016 limited 

FSSA eligibility to only those servicemembers serving outside the United 

States, the Commonwealth of Puerto Rico, the United States Virgin 

Islands, or Guam starting October 1, 2016.

Eligibility requirements for SNAP benefits, as laid out in 7 U.S.C. §§ 2014 

and 2015 and 7 C.F.R. Part 273, include criteria for financial resources, 

income, and employment.

a. Resources: To be eligible for SNAP, households cannot have 

more than $2,250 in countable resources, such as a bank 

account, or $3,250 in countable resources if at least one person in 

the household is age 60 or older, or is disabled.4 However, certain 

resources are not counted, such as a home and lot, the resources 

of household members who receive Supplemental Security 

Income (SSI), the resources of household members who receive 

Temporary Assistance for Needy Families (TANF), and most 

retirement (pension) plans. States may determine whether to 

include the value of a vehicle in countable resources, if the state 

vehicle allowance standards would result in a household incurring 

a lower attribution of resources.

b. Income: Most households must meet gross- and net-income tests, 

but a household with an elderly person or a person who is 

receiving certain types of disability payments has to meet only the 

 3

Dependents are a servicemember’s spouse; children who are unmarried and under age 

21, or under age 23, if she or he is enrolled full-time in an institution of higher education 

and is in fact dependent on the member for more than one-half of his or her support, or 

who, regardless of age, are physically or mentally incapable of self-support, and is in fact 

dependent on the member for more than one-half of his or her support; dependent 

parents, including step and legally adoptive parents of the employee’s spouse; and 

unmarried persons placed in the servicemember’s legal custody, and has not reached age 

21, or 23 if he or she is enrolled full time at an institution of higher learning, or is physically 

or mentally incapable of self-support.

4

In the U.S. Code, section 2014(g)(1)(A)-(B) of Title 7 sets the maximum amount of a 

household’s financial resources at $2,000 (or at $3,000 for a household with an elderly or 

disabled member), which is adjusted annually to the nearest $250 increment to reflect 

changes in inflation.

Supplemental Nutrition 

Assistance Program 

(SNAP)
Appendix III: Eligibility Requirements for Food 

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Active-Duty Servicemembers and Their 

Families

Page 41 GAO-16-561 DOD Food Assistance 

net-income test. A household’s gross income cannot exceed 130 

percent of the federal poverty guidelines to receive SNAP 

benefits. Gross income means a household’s total, non-excluded 

income, before any deductions have been made. A household’s 

net income cannot exceed 100 percent of the federal poverty 

guidelines. According to the USDA, net income is gross income 

minus allowable deductions. Deductions allowed are:

• 20 percent of earned income;

• a standard deduction of $155 for household sizes of 1 to 3 

people, and $168 for a household size of 4 (higher for some

larger households);

• dependent-care expenses when needed for work, training, or 

education;

• medical expenses for elderly or disabled members that are 

more than $35 for the month if they are not paid by insurance 

or someone else;

• legally owed child-support payments, if a state agency 

chooses not to exclude child-support payments from income;

• and excess shelter costs that are more than half of the 

household’s income after the other deductions. Allowable 

shelter costs include the cost of fuel to heat and cook with, 

cooling, electricity, water, service fees for one telephone, rent 

or mortgage payments and property taxes. The amount of the 

shelter deduction cannot be more than $504 unless one 

person in the household is elderly or disabled. The limit is 

higher in Alaska, Hawaii and Guam. Some states allow 

homeless households to deduct a set amount ($143) for 

shelter costs.

c. Employment requirement: In general, people must meet work 

requirements to be eligible for SNAP. An applicant is ineligible for 

SNAP if the individual refuses to register for work, accept an offer 

of employment, or participate in an employment and training 

program required by a state agency, or the individual voluntarily, 

and without good cause, quits a job or reduces hours. In addition, 

able-bodied adults without dependents are required to work or 

participate in a work program for at least 20 hours per week to 

receive SNAP benefits for more than 3 months in a 36-month 

period. Some special groups—including children, seniors, 

pregnant women, and people who are exempt for physical or 
Appendix III: Eligibility Requirements for Food 

Assistance Programs Commonly Used by 

Active-Duty Servicemembers and Their 

Families

Page 42 GAO-16-561 DOD Food Assistance 

mental health reasons—may not be subject to these 

requirements.

The federal law regarding SNAP provides an additional pathway for 

financial eligibility to SNAP. This federal law makes households in which 

all members are either eligible for or receive cash benefits from TANF, 

SSI, or state-financed General Assistance (GA) programs automatically 

eligible for SNAP.5 These households, which have already gone through 

eligibility determination for those programs, bypass the income and 

resource tests described above and are deemed financially eligible. 

Further, under expanded eligibility rules, called “broad-based categorical 

eligibility,” states can allow households receiving noncash services 

funded by TANF to be automatically eligible for SNAP. States that adopt a 

broad-based categorical eligibility policy may increase limits on household 

gross income up to 200 percent of federal poverty guidelines. However, 

categorically eligible households have their SNAP benefits determined 

under the same rules as other households, and while the household may 

be categorically eligible, its income may be too high to actually receive a 

SNAP benefit.

For WIC eligibility, as laid out in title 42, Section 1786 of the U.S. Code 

and 7 C.F.R. § 246.7, applicants must meet categorical, residential, 

income, and nutrition-risk requirements.

a. Categorical requirement: The WIC program is designed to serve

certain categories of individuals. Therefore, only the following

categories of individuals are eligible for WIC:

• Women:

o Pregnant (women determined to have one or more fetuses

in utero)

o Postpartum (up to six months after the termination of

pregnancy)

o Breastfeeding (up to the infant’s first birthday)

• Infants (up to the infant’s first birthday)

5

7 U.S.C. § 2014(a).

Special Supplemental 

Nutrition Program for 

Women, Infants, and 

Children (WIC)
Appendix III: Eligibility Requirements for Food 

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Families

Page 43 GAO-16-561 DOD Food Assistance 

Children (between ages 1 and 5)

b. Residential requirement: Applicants must live in the state in which

they apply. At state agency option, applicants may be required to

live in a local service area and apply at a WIC clinic that serves

that area. Applicants are not required to live in the state or local

service area for a certain amount of time in order to meet the WIC

residency requirement.

c. Income requirement: To be eligible for WIC, applicants must have

income at or below an income level or standard set by the state

agency or be determined automatically income-eligible based on

participation in certain programs.

• Income standard: The state agency’s income standard must

be between 100 percent and 185 percent of the federal

poverty guidelines. According to U.S. Department of

Agriculture (USDA) officials, all states have elected to raise the

income standard to 185 percent of federal poverty guidelines.

• Automatic Income eligible: Some applicants can be

determined income eligible for WIC based on their

participation in certain programs. These include:

o individuals who are eligible to receive SNAP benefits,

Medicaid, or TANF,

o individuals who have certain family members eligible to

receive Medicaid or TANF,

o At state agency option, individuals who are eligible to

participate in certain other state-administered programs.

d. Nutrition-Risk Requirement: To be certified as eligible for WIC,

applicants must be determined to be at nutritional risk.6 A

competent professional authority, such as a physician, registered

6

“Nutritional risk” means (A) detrimental or abnormal nutritional conditions detectable by 

biochemical or anthropometric measurements, (B) other documented nutritionally related 

medical conditions, (C) dietary deficiencies that impair or endanger health, (D) conditions 

that directly affect the nutritional health of a person, such as alcoholism or drug abuse, or 

(E) conditions that predispose persons to inadequate nutritional patterns or nutritionally 

related medical conditions, including, but not limited to, homelessness and migrancy. 42 

U.S.C. § 1786(b)(8).

•
Appendix III: Eligibility Requirements for Food 

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Families

Page 44 GAO-16-561 DOD Food Assistance 

nurse, or nutritionist, makes that determination through a medical 

and/or nutritional assessment. Examples of medical-based 

conditions include anemia (low blood levels), underweight, or 

history of poor-pregnancy outcome. A dietary-based condition 

includes, for example, a poor diet.

Sections 1758 and 1773 of Title 42 in the U.S. Code require that 

applicants must meet income requirements to receive free or reducedprice lunches or breakfasts at schools or be a member of a certain group. 

The NSLP and the SBP are two different programs but they have the 

same eligibility requirements.

a. Household income requirement: Children are eligible to receive a 

free meal if their household income is at or below 130 percent of 

the federal poverty guidelines or a reduced-price meal if their 

household income is between 130 and at or below 185 percent of 

the federal poverty guidelines.

b. Categorical (or automatic) eligibility requirement: Children are 

eligible to receive a free meal based on household participation in 

certain other need-tested programs or children’s specified 

vulnerabilities (e.g., foster children). A child shall be considered 

automatically eligible for a free lunch and breakfast without further 

application or eligibility determination if the child is:

• in a household receiving benefits through SNAP or Food 

Distribution Program on Indian Reservations benefits or TANF 

cash assistance. Food Distribution Program on Indian 

Reservations is a program that operates in lieu of or 

concurrently with SNAP on some Indian reservations;

• enrolled in Head Start;

• in foster care;

• a migrant;

• a runaway, or

• homeless.

c. Community Eligibility Provision: A child can receive free meals if 

he or she attends a school that has decided to provide free meals 

to all its students under the Community Eligibility Provision. 

Community Eligibility Provision is an option in NSLP and SBP law 

that allows eligible schools and school districts to offer free meals 

to all enrolled students based on the percentage of their students 

National School Lunch 

Program (NSLP) and 

School Breakfast Program 

(SBP)
Appendix III: Eligibility Requirements for Food 

Assistance Programs Commonly Used by 

Active-Duty Servicemembers and Their 

Families

Page 45 GAO-16-561 DOD Food Assistance 

who are identified as automatically eligible from non-household 

application sources, primarily direct certification through other 

programs. For a school (or school district, or group of schools 

within a district) to provide free meals to all children, the following 

must occur:

• the school(s) must be eligible for Community Eligibility 

Provision, based on the share (40 percent or greater) of its 

enrolled children that can be identified as categorically (or 

automatically) eligible for free meals, and

• the school must opt in to Community Eligibility Provision.
Appendix IV: Comments from the Department 

of Defense

Page 46 GAO-16-561 DOD Food Assistance 

Appendix IV: Comments from the 

Department of Defense
Appendix IV: Comments from the Department 

of Defense

Page 47 GAO-16-561 DOD Food Assistance 
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 48 GAO-16-561 DOD Food Assistance 

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov

In addition to the contact named above, Kay Brown, Rachel Frisk, Dawn 

Godfrey, Kevin Keith, Amie Lesser, Felicia Lopez, Tamiya Lunsford, 

Grant Mallie, Kimberly Mayo (Assistant Director), Shahrzad Nikoo, Sara 

Pelton, Richard Powelson, Monica Savoy, and John Van Schaik made 

key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff Acknowledgments

(100199)
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