SUPPLEMENTAL 

NUTRITION 

ASSISTANCE 

PROGRAM

Improved Oversight of 

State Eligibility 

Expansions Needed

Report to Congressional Requesters

July 2012

GAO-12-670

United States Government Accountability Office

GAO

This report was reissued on August 2, 2012 to add 

an additional addressee.
United States Government Accountability Office

Highlights of GAO-12-670, a report to 

congressional requesters

July 2012

SUPPLEMENTAL NUTRITION ASSISTANCE 

PROGRAM

Improved Oversight of State Eligibility Expansions 

Needed 

Why GAO Did This Study

Over the last 10 years, participation in 

the U.S. Department of Agriculture’s 

(USDA) SNAP, previously known as 

the Food Stamp Program, has more 

than doubled, and costs have 

quadrupled. Since 1999, USDA has 

allowed states to expand SNAP 

eligibility by adopting BBCE policies, 

which make households that receive

services funded by Temporary 

Assistance for Needy Families, such 

as a toll-free number or brochure, 

categorically eligible for SNAP. Under 

BBCE policies, states are able to 

increase federal SNAP limits on 

household income and remove limits 

on assets. Although USDA has 

encouraged states to adopt BBCE to 

improve SNAP access and 

administration, little is known about the 

effects of these policies. GAO was

asked to assess: (1) To what extent 

are households that would otherwise 

be ineligible for SNAP deemed eligible 

for the program under BBCE? (2) What 

effect has BBCE had on program 

costs? (3) What are the program 

integrity implications of BBCE? GAO 

analyzed data from USDA, selected 

states, and other national sources;

conducted site visits to 5 states; and 

interviewed federal, state, and local 

officials, as well as others with 

knowledge of SNAP. 

What GAO Recommends

GAO recommends that USDA review 

state procedures for implementing

BBCE, disseminate guidance to states 

on certifying SNAP households as 

eligible for school meals, and revisit its 

guidance on SNAP reporting 

requirements to ensure they address

all households. USDA generally 

agreed with GAO’s recommendations.

What GAO Found

In fiscal year 2010, GAO estimates that 2.6 percent (473,000) of households that 

received Supplemental Nutrition Assistance Program (SNAP) benefits would not 

have been eligible for the program without broad-based categorical eligibility 

(BBCE) because their incomes were over the federal SNAP eligibility limits. The 

characteristics of these households were generally similar to other SNAP 

households, although they were more likely to work or receive unemployment

benefits. BBCE removes asset limits in most states, and while reliable data on 

participants’ assets are not available, other data suggest few likely had assets 

over these limits. Although BBCE contributed to recent increases in SNAP 

participation, other factors, notably the recent recession, had a greater effect. 

Estimated Sub-groups of SNAP Households, Fiscal Year 2010

GAO estimates that BBCE increased SNAP benefit costs, which are borne by the 

federal government, by less than 1 percent in fiscal year 2010. In that year, total 

SNAP benefits provided to households that, without BBCE, would not have been 

eligible for the program because their incomes were over the federal SNAP 

eligibility limits were an estimated $38 million monthly or about $460 million for 

the year. These households received an estimated average monthly SNAP 

benefit of $81 compared to $293 for other households. BBCE’s effect on SNAP 

administrative costs, which are shared by the federal and state governments, is 

unclear, in part because of other recent changes that affect this spending, such 

as state budget and staffing reductions in the recent recession. 

BBCE has potentially had a negative effect on SNAP program integrity. In recent 

years, the SNAP payment error rate declined to an historic low, but evidence 

suggests the decline is primarily due to changes other than BBCE. While BBCE 

may improve administrative efficiency, both national data and discussions with 

local staff suggest BBCE may also be associated with more errors. In addition, 

BBCE has led to unintended consequences for SNAP and related programs. For 

example, in implementing BBCE, some states are designating SNAP applicants 

as categorically eligible without providing them with the service required to make 

this determination. Further, likely because they are unaware of recent USDA 

guidance, some states certify children for free school meals when their 

households are determined eligible for SNAP, even though they do not receive 

SNAP benefits—a result more common in states with BBCE. Finally, because of 

federal guidance on BBCE, rules for reporting changes in household 

circumstances now differ by household income level and may leave higherincome households without reporting requirements for several months. 

View GAO-12-670. For more information, 

contact Kay Brown at (202) 512-7215 or 

brownke@gao.gov. 
Page i GAO-12-670 Supplemental Nutrition Assistance Program

Letter 1 

Background 4

While State Eligibility Changes Expanded Participation, the 

Economy Likely Played a Larger Role 15

State Eligibility Changes Increased Benefit Costs Somewhat, but 

Their Effect on Administrative Costs Is Unclear 24

State Eligibility Changes May Negatively Affect Program Integrity 32

Conclusions 39

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 41

Appendix I Objectives, Scope, and Methodology 43

Appendix II 2010 Quality Control Data Estimates and 95 Percent Confidence 

Intervals 46

Appendix III GAO Contacts and Staff Acknowledgments 51

Related GAO Products 52

Tables

Table 1: Number of States with Various Income and Asset Limits 

for Programs Used to Confer BBCE, as of May 1, 2012 13

Table 2: Characteristics of Specified Groups of SNAP Households, 

in Fiscal Year 2010 17

Table 3: Estimated Percent of Specified Groups of SNAP 

Households Receiving Deductions and the Estimated 

Average Amount of the Deduction, in Fiscal Year 2010 26

Table 4: SNAP Households That Would Not Have Been Eligible for 

the Program without BBCE because Their Incomes Were

over Federal Limits in Fiscal Year 2010 46

Table 5: Characteristics of Specified Groups of SNAP Households 

in Fiscal Year 2010 46

Contents
Page ii GAO-12-670 Supplemental Nutrition Assistance Program

Table 6: Benefits Provided to SNAP Households That Would Not 

Have Been Eligible for the Program without BBCE 

because Their Incomes were over Federal Limits in Fiscal 

Year 2010 48

Table 7: Benefits Received by Specified Groups of SNAP 

Households in Fiscal Year 2010 48

Table 8: Estimated Percent of Specified Groups of SNAP 

Households Receiving Deductions and the Estimated 

Average Amount of the Deduction in Fiscal Year 2010 49

Figures

Figure 1: Average Monthly Number of SNAP Participants per Fiscal 

Year, in Millions 5

Figure 2: Total Federal SNAP Costs per Fiscal Year, in Billions 5

Figure 3: How an Applicant’s Eligibility Is Determined under 

Federal SNAP Guidance 8

Figure 4: How an Applicant’s Eligibility Is Determined under 

Traditional Cash Assistance-Related Categorical Eligibility 9

Figure 5: How an Applicant’s Eligibility May Be Determined under 

BBCE 11

Figure 6: Timeline of State BBCE Policy Implementation, Fiscal 

Years 2001-2012 12

Figure 7: SNAP Households That Would Not Have Been Eligible for 

the Program without BBCE because Their Incomes Were 

over Federal Limits in Fiscal Year 2010 16

Figure 8: Trends in SNAP Participation, Unemployment, and 

Poverty, 1990-2011 21

Figure 9: Benefits Provided to SNAP Households That Would Not 

Have Been Eligible for the Program without BBCE 

because Their Incomes Were over Federal Limits, Fiscal 

Year 2010 25

Figure 10: Selected Information on SNAP Benefits and Potentially 

Related Factors, Fiscal Years 2001-2011 27

Figure 11: SNAP Administrative Costs, Fiscal Years 2001-2010 30

Figure 12: Administrative Costs per SNAP Household, Fiscal Years 

2001-2010 31

Figure 13: Examples of How States Confer BBCE for SNAP 35
Page iii GAO-12-670 Supplemental Nutrition Assistance Program

Abbreviations

BBCE broad-based categorical eligibility

FNS Food and Nutrition Service

SNAP Supplemental Nutrition Assistance Program

TANF Temporary Assistance for Needy Families 

USDA U.S. Department of Agriculture

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

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

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Page 1 GAO-12-670 Supplemental Nutrition Assistance Program

United States Government Accountability Office 

Washington, DC 20548

July 26, 2012

The Honorable Frank D. Lucas

Chairman

The Honorable Collin C. Peterson

Ranking Member

Committee on Agriculture

House of Representatives

The Honorable Jeff Sessions

Ranking Member

Committee on the Budget

United States Senate

The Honorable Pat Roberts

Ranking Member

Committee on Agriculture, Nutrition and Forestry

United States Senate

During fiscal year 2011, the U.S. Department of Agriculture’s (USDA) 

Supplemental Nutrition Assistance Program (SNAP), previously known as 

the Food Stamp Program,1 provided food and nutrition assistance to 

almost 45 million individuals each month for a total of $71.8 billion in 

benefits for the year. SNAP is intended to help low-income individuals 

and families obtain a better diet by supplementing their incomes with 

benefits to purchase food. Over the last 10 years, SNAP participation has 

more than doubled and costs have quadrupled. While some of the recent 

increases in SNAP participation and costs are due to the recession and 

benefit increases included in the American Recovery and Reinvestment 

Act of 2009 (Recovery Act),2

 

1

SNAP was given its present name in 2008. Food, Conservation, and Energy Act of 2008, 

Pub. L. No. 110-346, § 4002(a), 122 Stat. 1651, 1853.

state policy changes intended to improve 

program access and simplify the administration of SNAP may also have 

had an effect.

2

Pub. L. No. 111-5, § 101(a) and (e), 123 Stat. 115, 120.

 
 

Page 2 GAO-12-670 Supplemental Nutrition Assistance Program

Under federal law, eligibility for SNAP is based primarily on whether a 

household’s income and assets fall below certain thresholds.3 In addition, 

low-income households are categorically eligible for SNAP if they receive 

benefits from certain other federal programs, such as Temporary 

Assistance for Needy Families (TANF).4 Originally, categorical eligibility 

was designed as a method by which households receiving cash 

assistance benefits were deemed SNAP-eligible. However, since 1999, 

USDA has allowed states to expand categorical eligibility to households 

authorized to receive TANF-funded non-cash services by adopting broadbased categorical eligibility (BBCE) policies.5

Although USDA has encouraged states to adopt BBCE to improve SNAP 

access and simplify administration, little is known about the impact of 

BBCE on SNAP. As a result, we were asked to assess: (1) To what 

extent are households that would otherwise be ineligible for SNAP 

deemed eligible for the program under BBCE? (2) What effect has BBCE 

had on program costs? (3) What are the program integrity implications, if 

any, of BBCE?

Under BBCE policies, states 

align the SNAP household income and asset limits in federal law with the 

income and asset limits for the relevant TANF-funded non-cash service. 

While SNAP eligibility limits therefore differ among states that have 

adopted BBCE policies, the amount of assistance eligible households 

receive is determined using the same process for all SNAP applicants. 

From fiscal year 2006 through fiscal year 2012, the number of states with 

BBCE policies increased from 7 to 43.

As criteria for our review, we examined federal laws affecting SNAP, as 

well as USDA regulations and guidance related to SNAP and specifically 

to BBCE. To answer our research questions, we collected and analyzed 

information through several methods. At the federal level, we reviewed 

USDA’s information on states’ BBCE policies and interviewed department 

officials. We also reviewed USDA’s data on SNAP households, program 

 

3

7 U.S.C. § 2014(a).

4

In addition, households in which all members receive Supplemental Security Income 

(SSI) or benefits from state or local general assistance programs are categorically eligible 

for SNAP. 7 U.S.C. § 2014(a). 

5

Letter to Regional Administrators–All Regions, “FSP–Categorical Eligibility,” signed by 

the Deputy Administrator of the Food Stamp Program, Food and Nutrition Service, USDA. 

July 14, 1999.
 

Page 3 GAO-12-670 Supplemental Nutrition Assistance Program

costs, and error rates for the 50 states; Washington, D.C.; Guam; and the 

Virgin Islands. We determined that these data were sufficiently reliable for 

the purposes of this report. Because USDA’s data lack information on the 

assets of SNAP households deemed eligible under BBCE, which is key to 

understanding the effects of BBCE on participation and benefit costs, we 

also reviewed additional national data sources that provide information on 

household assets, such as the Survey of Consumer Finances, and 

determined that these data were sufficiently reliable for the purposes of 

this report. While these data sources provide estimates of the average 

amount of assets owned by households of different income levels, which 

can therefore be used to approximate the level of assets owned by SNAP 

households, they do not directly provide estimates of SNAP households’ 

assets. To gather additional background information on the effects of 

various factors on SNAP participation and costs, we identified and 

reviewed additional studies on SNAP conducted by USDA and several 

research organizations that assess programs for low-income populations.

To gather information from state and local SNAP administrators on the 

effects of BBCE policies, as well as other simultaneous changes to the 

program, we conducted site visits to 5 states (Arizona, Illinois, North 

Carolina, South Carolina, and Wisconsin) and 18 local SNAP offices 

located in both urban and rural areas in those states. We selected these 

states because they varied in their BBCE adoption dates, characteristics 

of their BBCE policies, and geographic locations. States selected also 

had relatively large SNAP caseloads and generally high proportions of 

their SNAP households deemed eligible under BBCE policies. Within 

each state, we interviewed state SNAP administrators, as well as local 

SNAP administrators from three to four local offices. We cannot 

generalize our findings from the site visits beyond the states and localities 

we visited. In addition to our site visits, we also interviewed state SNAP 

administrators in Idaho and Michigan to gather information on the impacts 

of the asset limits that these states added to their BBCE policies in 2011. 

To gather other perspectives about the effects of BBCE on SNAP, we 

also interviewed officials knowledgeable about SNAP from research and 

advocacy organizations that focus on nutrition assistance policy.

We conducted this performance audit from August 2011 through July 

2012 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 
 

Page 4 GAO-12-670 Supplemental Nutrition Assistance Program

and conclusions based on our audit objectives. See appendices I and II 

for additional information on our objectives, scope, and methodology.

SNAP is the largest of the 15 domestic food and nutrition assistance 

programs overseen by USDA’s Food and Nutrition Service (FNS). FNS 

jointly administers SNAP with the states. FNS pays the full cost of SNAP 

benefits and pays approximately half of states’ administrative costs.6

 FNS 

is also responsible for promulgating program regulations and ensuring 

that state officials administer the program in compliance with program 

rules. States administer the program by determining whether households 

meet the program’s eligibility requirements, calculating monthly benefits 

for qualified households, and issuing benefits to participants. 

As shown in figures 1 and 2, SNAP participation and costs generally 

increased between fiscal years 2001 and 2011, though the most 

significant increases began in fiscal year 2008.

 

6

Generally, FNS reimburses states for 50 percent of most types of SNAP administrative 

costs. However, some types of administrative costs are reimbursed at higher rates, such 

as some costs related to employment and training services and computer system 

development. Further, in response to SNAP participation increases during the recent 

economic downturn, the American Recovery and Reinvestment Act of 2009 and the 

Department of Defense Appropriations Act, 2010 made $290.5 million and $400 million, 

respectively, available to states for SNAP administrative costs in fiscal years 2009-2011. 

Pub. L. No. 111-5, § 101(c), 123 Stat. 115, 120 and Pub. L. No. 111-118, § 1002(a), 123 

Stat. 3409, 3468-69.

Background

Participation and Costs
 

Page 5 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 1: Average Monthly Number of SNAP Participants per Fiscal Year, in Millions

Figure 2: Total Federal SNAP Costs per Fiscal Year, in Billions
 

Page 6 GAO-12-670 Supplemental Nutrition Assistance Program

Note: “Other Costs” include the federal share of SNAP administrative costs and employment and 

training programs, as well as other federal costs (e.g., benefit and retailer redemption and monitoring, 

payment accuracy, electronic benefit transfer systems, program evaluation and modernization, 

program access, health and nutrition pilot projects). 

According to FNS, the growth in SNAP participation in recent years is 

likely attributable to the economic recession, outreach efforts, and 

modifications to program policy. Because households must be lowincome to receive SNAP benefits, participation and costs typically 

increase during economic downturns as more people become eligible and 

apply. Although the recent recession officially lasted from December 2007 

through June 2009, since then, unemployment has remained above 

average levels and SNAP participation has continued to grow. Further, 

because federal law identifies SNAP’s main purpose as “raising levels of 

nutrition among low-income households,”7 one of the key performance 

measures for the program is the rate of participation among eligible 

households. As a result, for years, FNS has encouraged states to 

undertake outreach efforts and adopt various modifications to program 

policy to increase participation among the eligible population and increase 

program efficiency. Although the participation rate varies by state, ranging 

from an estimated 53 percent in California to 100 percent in Maine in 

fiscal year 2009, the national rate has been about 70 percent in recent 

years.8

Under federal law and regulations, eligibility for SNAP is based primarily 

on a household’s income and assets.9 A household generally includes 

everyone who lives together and purchases and prepares meals 

together.10

 

7

7 U.S.C. § 2011.

To determine a household’s eligibility, a caseworker must first 

8

To estimate the program’s participation rate, the number of SNAP participants in each 

state, according to administrative data, is divided by the estimated number of eligible 

persons. To estimate the number eligible, USDA applies SNAP federal eligibility rules to 

household data in the U.S. Census Bureau’s Current Population Survey. This approach 

does not take into account households potentially eligible for SNAP in states with BBCE 

policies that modify the federal eligibility rules. If these households were included, many 

states’ participation rate estimates would likely be lower. 

9

7 U.S.C. § 2014.

107 U.S.C. § 2012(n). There are specific exceptions to the definition of a household. For 

example, husbands, wives, and most children under age 22 that live together are included 

in the same household, even if they purchase and prepare meals separately. 

Determination of 

Eligibility
 

Page 7 GAO-12-670 Supplemental Nutrition Assistance Program

determine the household’s gross income, which cannot exceed 130 

percent of the federal poverty guidelines,11 and its net income, which 

cannot exceed 100 percent of the guidelines (or $18,530 annually for a 

family of three living in the continental United States in fiscal year 2012).12

Net income is determined by taking into account certain exclusions and 

deductions, for example, expenses for dependent care, utilities, and 

housing.13 In addition, a caseworker must determine a household’s assets 

under various requirements. For example, a household’s liquid assets, 

such as those in a bank account, currently cannot exceed $2,000 or, for 

households with an elderly or disabled member, $3,250.14 However, 

certain assets are not counted for SNAP, such as a home, the 

surrounding lot, and most retirement plans and educational savings 

accounts.15 While there are also federal SNAP provisions that limit the 

value of vehicles an applicant can own and still be eligible for the 

program,16

 

117 U.S.C. § 2014(c)(2). The federal poverty guidelines are updated periodically in the 

Federal Register by the Secretary of Health and Human Services. 42 U.S.C. § 9902(2) 

and (4). 

all states have opted to modify those rules, and most exclude 

the value of all household vehicles. (See figure 3 for a general depiction 

of the eligibility determination process under federal SNAP rules.)

127 U.S.C. § 2014(c)(1). Households that include an elderly or disabled member do not 

have to meet the gross income limit but must meet the net income limit. SNAP defines 

elderly members of a household as those aged 60 and older. 7 U.S.C. § 2012(j)(1).

137 U.S.C. § 2014(d) and (e). Exclusions include, for example, educational loans, 

veteran’s educational benefits, and income earned by minor children.

147 U.S.C. § 2014(g)(1).

157 U.S.C. § 2014(g)(2)–(7).

167 U.S.C. § 2014(g)(2)(C). 
 

Page 8 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 3: How an Applicant’s Eligibility Is Determined under Federal SNAP 

Guidance

Federal law also allows certain households to be deemed categorically

eligible for SNAP.17

 

177 U.S.C. § 2014(a).

Under statute, households receiving monthly cash 

assistance from certain programs—including TANF, SSI, and state or 

local general assistance programs—are categorically eligible for SNAP. 

According to USDA, categorical eligibility can increase program access 

and reduce administrative burden, as states assess a household’s 

eligibility once for the cash assistance program rather than twice for both 

the cash assistance program and SNAP. (See figure 4 for a general 

depiction of the eligibility determination process under traditional cash

assistance-related categorical eligibility.)
 

Page 9 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 4: How an Applicant’s Eligibility Is Determined under Traditional Cash 

Assistance-Related Categorical Eligibility

In response to welfare reforms under the Personal Responsibility and 

Work Opportunity Reconciliation Act of 1996,18 USDA advised states that 

households authorized to receive non-cash services—such as case 

management services, transportation subsidies, or child care subsidies—

from a program funded with TANF dollars could also be deemed 

categorically eligible.19 In order for a state to fund a non-cash service with 

TANF dollars, the service generally must further one of TANF’s purposes, 

which include the promotion of job preparation, work, and marriage, and 

the reduction of out-of-wedlock births.20

 

18Pub. L. No.104-193, 110 Stat. 2105.

As set out in SNAP regulations, 

households in which members are authorized to receive non-cash 

services primarily funded with TANF are categorically eligible, and states 

also have the option of extending categorical eligibility to households 

19This includes federal TANF dollars and state dollars counted as maintenance-of-effort 

for TANF. 7 C.F.R. § 273.2(j)(2)(ii) (2012). 

2042 U.S.C. § 601(a) and 604. 
 

Page 10 GAO-12-670 Supplemental Nutrition Assistance Program

receiving services that are less than 50 percent TANF-funded, with FNS 

approval required in certain cases.21

As a result of this expansion of categorical eligibility, states have adopted 

a variety of policies to deem households that receive non-cash services 

from TANF-funded programs eligible for SNAP. FNS separates these 

types of policies into two groups—broad-based and narrow. According to 

FNS, BBCE policies make most, if not all, households that apply for 

SNAP categorically eligible because they receive a TANF-funded noncash service, such as an informational brochure or toll-free number. (See 

figure 5 for a general depiction of the eligibility determination process 

under BBCE.) In contrast, narrow categorical eligibility policies require 

households to be enrolled in certain TANF-funded programs, such as 

employment assistance, or receiving child care or transportation 

assistance, in order to be categorically eligible for SNAP.

SNAP regulations also direct that the 

TANF-funded non-cash services used to confer categorical eligibility be 

available only to households with incomes equal to or below 200 percent 

of the federal poverty guidelines.

 

217 C.F.R. § 273.2(j)(2)(i)-(iii) (2012).
 

Page 11 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 5: How an Applicant’s Eligibility May Be Determined under BBCE

Note: This figure depicts the general process for determining a household’s SNAP eligibility in a state 

with a BBCE policy that removes the federal SNAP asset limit and does not include a net income 

limit. Not all states have such a policy. 

Although FNS issued guidance in 1999 and regulations in 2000 

explaining how states could adopt BBCE policies,22

 

2265 Fed. Reg. 70,134, 70,160 and 70,198 (Nov. 21, 2000). Although promulgated in 

2000, none of its provisions became effective prior to January 20, 2001.

relatively few states 

implemented them early on. Between fiscal years 2001 and 2006, 7 

states adopted these policies. However, when the recent economic 

downturn began, and households applying for SNAP began to increase 

greatly, FNS encouraged states to adopt these policies to streamline 

eligibility processes and ease workload (see fig. 6).
 

Page 12 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 6: Timeline of State BBCE Policy Implementation, Fiscal Years 2001-2012

According to FNS, as of May 1, 2012, 43 states—including Washington, 

D.C., Guam, and the Virgin Islands—had BBCE policies.23 These policies 

differ in terms of the income and asset limits used to determine eligibility, 

as shown in table 1. For example, 24 states’ BBCE policies increase the 

federal gross income limit for SNAP and remove the asset limit while 2 

states’ BBCE policies retain the federal gross income limit and increase 

the federal asset limit.

 

23For this report, we reviewed information on SNAP in the 50 states; Washington, D.C.; 

Guam; and the Virgin Islands. We use “states” throughout the report to refer to this group.
 

Page 13 GAO-12-670 Supplemental Nutrition Assistance Program

Table 1: Number of States with Various Income and Asset Limits for Programs Used 

to Confer BBCE, as of May 1, 2012

Higher asset limit than 

federal SNAP limits 

No asset

limit

Federal SNAP gross income limit equal to 

130 percent of the federal poverty guidelines

2 14a

Higher gross income limit (160-200 percent of 

the federal poverty guidelines)

3 24

Source: GAO analysis of USDA data on states’ BBCE policies.

a

Nine of these states increased the federal gross income limit to 200 percent of the federal poverty 

guidelines, but only for households with elderly or disabled members. 

After eligibility is established, benefits are determined based on each 

household’s monthly net income, with greater benefits provided to those 

with less income. SNAP expects each eligible household to spend 30 

percent of its own resources on food, and therefore, each household’s 

monthly SNAP benefit is determined by subtracting 30 percent of its 

monthly net income from the maximum SNAP benefit for the relevant 

household size.24 All eligible one- and two-person households are 

guaranteed a minimum benefit, which is $16 for households in the 

continental United States in fiscal year 2012.25 However, households with 

three or more members do not receive a minimum benefit. Under federal 

income eligibility limits, a household with three or more members will 

typically be determined eligible for a SNAP benefit greater than $0. 

However, because some states’ BBCE policies raise the SNAP income 

limits, under these policies, such households are more likely to be 

deemed eligible for $0 in benefits.

SNAP households are certified eligible for SNAP for periods ranging from 

1 to 24 months, which vary based on state policy choices. Generally, the 

length of the certification period depends on household circumstances, 

 

247 U.S.C. § 2017(a) If a household has zero net income (that is, its deductable expenses 

equal or exceed its gross income), it receives the maximum SNAP benefit based on 

household size. Maximum benefits are based on USDA’s Thrifty Food Plan, which is an 

estimate of how much it costs to buy food to prepare nutritious, low-cost meals for a 

household. The Thrifty Food Plan estimate is changed every year to keep pace with food 

prices. 

257 U.S.C. § 2017(a). The minimum benefit for eligible one- and two-person households in 

Alaska, Hawaii, Guam, and the Virgin Islands ranges from $19-$30 in fiscal year 2012. 

Determination of Benefits

Certification and 

Reporting Requirements
 

Page 14 GAO-12-670 Supplemental Nutrition Assistance Program

but only households in which all members are elderly or disabled can be 

certified for up to 24 months under federal regulations.26

Between certification periods, households generally must report changes 

in their circumstances—such as household composition, income, and 

expenses—that may affect their eligibility or benefit amounts.

Once the 

certification period ends, households reapply for benefits, at which time 

eligibility and benefit levels are redetermined.

27 Since 

early 2001, states have had the option of requiring households to report 

changes only when their incomes rise above 130 percent of the federal 

poverty guidelines, rather than reporting changes at regular intervals or 

within 10 days of occurrence, as was required in the past.28 According to 

FNS, as of November 2010, all states except California and Wyoming use 

this simplified reporting for some or all SNAP households.

FNS and the states share responsibility for implementing an extensive 

quality control system used to measure the accuracy of SNAP eligibility 

and benefits and from which state and national error rates are 

determined.29

 

267 C.F.R. § 273.2(f)(1) (2012). The state must have at least one contact with these 

households every 12 months.

Under FNS’s quality control system, the states calculate 

their payment errors annually by drawing a statistical sample to determine 

whether participating households are eligible and received the correct 

benefit amount. Because SNAP considers many factors in determining 

each household’s benefit amount, any of these factors can result in a 

payment error. For example, incorrect calculations of earned income or 

unearned income and inaccurate accounting of the number of household 

members may cause payment errors. The state’s payment error rate is 

based on the sample and determined by dividing the dollars paid in error 

by the total SNAP benefits issued. Once the payment error rates are 

determined, FNS is required to compare each state’s performance with 

277 C.F.R. § 273.12(a) (2012).

287 C.F.R. § 273.12(a)(1)(vii) (2012) and 65 Fed. Reg. 70,134, 70,143 and 70,208 (Nov. 

21, 2000) (effective Jan. 20, 2001).

29The SNAP error rate is calculated for the entire program, as well as every state, and is a 

combination of overpayments to those who are eligible for smaller benefits, overpayments 

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

as much as they should.

Quality Control System
 

Page 15 GAO-12-670 Supplemental Nutrition Assistance Program

the national payment error rate and impose financial penalties or provide 

financial incentives according to legal specifications.

In fiscal year 2010, an estimated 2.6 percent30 (approximately 473,000) of 

all households receiving SNAP benefits nationwide would not have been 

eligible for the program without BBCE because their incomes were 

greater than the income limits defined in federal law.31 32

 

30The 95 percent confidence interval for the 2.6 percent estimate is (2.4, 2.8). For the 95 

percent confidence intervals for all estimates in this paragraph, see appendix II, table 4.

However, over 

half of the states did not have BBCE policies that increased SNAP 

income limits above the federal limits in fiscal year 2010. In the 24 states 

whose BBCE policies raised household income limits above the federal 

limits in that year, around 4.8 percent of SNAP households had incomes 

over those limits (see fig. 7). Those households eligible solely because of 

BBCE generally had incomes that were modestly higher than the federal 

limits. On average, their total monthly income was an estimated $1,965, 

31For more information about our analysis, see appendix I. As previously noted, 

household eligibility is determined by local staff administering SNAP, and the accuracy of 

those determinations is assessed by state and federal reviewers. We did not 

independently determine households’ eligibility. 

32In April 2012, the Congressional Budget Office (CBO) released a report on SNAP that 

estimates a 4.3 percent annual reduction in SNAP participants over the 2013-2022 period 

if federal SNAP income and asset limits were applied to all categorically eligible 

households. However, CBO’s methodology for producing its estimates differs from our 

methodology in several ways. For example, although CBO indicates its estimates reflect 

changes to BBCE, the Office’s estimates include both participants deemed eligible under 

BBCE policies, as well as those deemed eligible under narrow non-cash categorical 

eligibility policies. In addition, CBO estimates include assumptions about the share of 

these households that exceed federal asset limits.

While State Eligibility 

Changes Expanded 

Participation, the 

Economy Likely 

Played a Larger Role

More Became Eligible but 

Impact of Changes Likely 

Limited
 

Page 16 GAO-12-670 Supplemental Nutrition Assistance Program

which is about 150 percent of the federal poverty guidelines,33

Figure 7: SNAP Households That Would Not Have Been Eligible for the Program 

without BBCE because Their Incomes Were over Federal Limits, in Fiscal Year 2010

whereas 

the federal income limit for SNAP is 130 percent of the guidelines.

Note: For the 95 percent confidence intervals for these estimates, see appendix II, table 4. 

Households eligible under BBCE with incomes over the federal limits had 

characteristics that were generally similar to all other SNAP households; 

however, they were more likely to be working or receiving unemployment 

benefits (see table 2). About half of these households included a child, as 

was the case for all other SNAP households, and a similar proportion of 

each group of households included a single female head of household. 

While a generally similar proportion of both groups of households were 

elderly recipients of Social Security benefits, the average monthly amount 

of Social Security benefits received by households that would have failed 

 

33In fiscal year 2010, 150 percent of the federal poverty guidelines equaled $1,821 

monthly for a 2-person household and $2,289 monthly for a 3-person household. We 

estimate that households with incomes over the federal limits in fiscal year 2010 had, on 

average, 2.2 members. 
 

Page 17 GAO-12-670 Supplemental Nutrition Assistance Program

the federal income tests was substantially higher. In two of the local 

offices we visited, staff noted that BBCE may have increased the number 

of elderly applicants since the policy change enabled some who were 

previously ineligible because of their Social Security earnings to become 

eligible for SNAP. Also, although both groups had the same proportion of 

households with unearned income, a higher percentage of households 

with incomes above the federal limits had members who worked or who 

received Unemployment Insurance benefits. Further, the average monthly 

amount they received in Unemployment Insurance was considerably 

higher than that received by all other SNAP households.

Table 2: Characteristics of Specified Groups of SNAP Households, in Fiscal Year 

2010 

SNAP households 

with incomes 

over federal 

income limits

All other SNAP 

households

Total number of SNAP households 473,381 17,895,847

Percentage of households with at least one 

child

56.3 48.5

Percentage of households with a single female 

as the head

30.7 25.8

Percentage of households with at least one 

member receiving Social Security benefits

27.8 21.2

Average amount of Social Security benefits 

received

$340 $155

Percentage of households with at least one 

member with unearned income

60.0 60.3

Percentage of households with at least one 

member with earned income

65.9 29.0

Percentage of households with at least one 

member receiving Unemployment Insurance 

benefits

18.6 6.4

Average amount of Unemployment Insurance 

benefits received

$223 $55

Source: GAO analysis of USDA’s SNAP quality control data.

Note: The average amount of Social Security and Unemployment Insurance benefits received was 

calculated for all households in each group, rather than only for households that received these 

benefits. For the 95 percent confidence intervals for these estimates, see appendix II, table 5. 
 

Page 18 GAO-12-670 Supplemental Nutrition Assistance Program

Available data suggest few households that qualified for SNAP under 

BBCE likely had assets that would have exceeded federal asset limits. In 

fiscal year 2010, 37 states had removed the federal asset limit, which was 

$2,000 for most households,34 as part of their BBCE policies. Because 

asset information was therefore not collected from SNAP applicants in 

these states, USDA’s data on SNAP households cannot be used to 

estimate the number or share of participating households with assets over 

the federal limits. However, other national data sources suggest the 

number is relatively small. For example, a national survey that gathered 

information on families’ assets in 2010 found that an estimated 24 percent 

of families in the bottom income quintile did not have a checking, savings, 

or other financial transaction account.35 Among the estimated 76 percent 

of this group that had such an account, the median balance was an 

estimated $700. This survey also found that while a greater proportion of 

families in the second lowest income quintile had such an account in 

2010 (91 percent), their median account balance was an estimated 

$1,500. For the most part, SNAP households deemed eligible under 

BBCE—households with incomes under 200 percent of the federal 

poverty guidelines—fall within the two lowest income quintiles.36 A 2007 

survey of families with children found that those with incomes between 

100 and 199 percent of the federal poverty guidelines held median liquid 

assets of around $300.37

Available state-level data, as well as information shared by state and local 

officials during our site visits, also suggest the value of assets held by 

For those with incomes below 100 percent of the 

guidelines, the median amount was estimated to be zero.

 

34As previously noted, federal SNAP asset limits are $2,000 for most households and 

$3,250 for households with an elderly or disabled member.

35Federal Reserve Board, 2010 Survey of Consumer Finances. Transaction accounts 

include checking, savings, and money market deposit accounts; money market mutual 

funds, and call or cash accounts at brokerages. 

36According to U.S. Census Current Population Survey data, as of March 2010, families 

with incomes of an estimated $27,379 or less were in the bottom income quintile, and 

those with estimated incomes from $27,380 to $48,705 were in the second lowest income 

quintile, in 2010 dollars.

37University of Michigan, Institute for Social Research, 2007 Panel Study of Income 

Dynamics. In this survey, liquid assets are defined as immediately available assets that 

can be easily converted to cash. These include, for example, the value of checking and 

savings accounts, as well as stocks, bonds, and cash-value of life insurance. Further, note 

that families with no liquid assets are included in this analysis.
 

Page 19 GAO-12-670 Supplemental Nutrition Assistance Program

SNAP households is low. For example, according to state officials in 

Idaho and Michigan, both states initially removed the federal asset limits 

as part of their BBCE policies but reinstated an asset limit of $5,000 

during 2011. Officials indicated that the new limits had a very small 

impact on overall caseloads. For example, during the 9 months following 

Idaho’s reinstatement, approximately 850 new applicants and existing 

recipients seeking recertification were denied benefits because their 

assets exceeded the asset limit. This represented less than a 1 percent 

reduction in the total number of SNAP households in that state during that 

period.38 Similarly, during the month following Michigan’s reinstatement of 

the asset limit, about 1 percent of the state’s existing SNAP cases were 

closed due to assets.39 Further, during our site visits, caseworkers in all of 

the offices we visited said they believe the value of assets held by SNAP 

households is usually very low or $0. Several caseworkers said that while 

they may have served SNAP applicants that held assets greater than the 

federal limits, they believe such instances are rare. Many caseworkers 

noted it is common to hear from applicants that they have exhausted a 

significant portion of their available assets before applying for SNAP.

While implementation of BBCE by many states has enabled more 

households to receive SNAP, the nation’s recent economic downturn has 

likely played a larger role in the increases in participation during the past 

decade. As shown in figure 8, increases and decreases in SNAP 

participation often coincide with similar changes in unemployment and 

poverty. A 2002 USDA study found that during past economic recessions, 

a 1 percentage-point increase in the national unemployment rate has 

been associated with an increase in the number of SNAP participants of 1 

 

38For the 9 full months after reinstatement, the average monthly SNAP caseload in Idaho 

was approximately 101,000 households.

39However, according to Michigan officials, this figure includes both cases closed because 

they had assets over the $5,000 limit, as well as those closed because they had vehicles 

worth more than the $15,000 limit that the state simultaneously established. Also, since 

both Idaho and Michigan’s new $5,000 asset limits are higher than the federal SNAP 

asset limits, it is likely that these estimates are lower than they would be if the states had 

reinstated the federal asset limits. 

Economic Downturn a 

Major Cause of Recent 

Trends
 

Page 20 GAO-12-670 Supplemental Nutrition Assistance Program

to 3 million.40 This relationship also existed during the most recent 

economic recession of 2007-2009,41

 

40Kenneth Hanson and Craig Gunderson, How Unemployment Affects the Food Stamp 

Program, USDA Economic Research Service, FANRR-26-7 (Washington, D.C.:

September 2002). GAO and others have also noted the relationship between 

unemployment and SNAP. See GAO, Domestic Food Assistance: Complex System 

Benefits Millions, but Additional Efforts Could Address Potential Inefficiency and Overlap 

among Smaller Programs, 

which was marked by a steep rise in 

the nation’s unemployment rate and an increase in the proportion of 

families living in poverty. Between fiscal years 2007 and 2010, the 

number of SNAP participants rose by around 14 million (or approximately 

54 percent), while the unemployment rate increased by 5 percentage 

points. This relationship was also noted by staff administering SNAP in all 

18 local offices we visited who cited the economic downturn, and related 

unemployment, as the primary cause of the increases in SNAP 

participation in their localities.

GAO-10-346 (Washington, D.C.: April 15, 2010); and James 

Mabli and Carolina Ferrerosa, Supplemental Nutrition Assistance Program Caseload 

Trends and Changes in Measures of Unemployment, Labor Underutilization, and Program 

Policy from 2000 to 2008 (Cambridge, MA: Mathematica Policy Research, Inc., October 

18, 2010).

41According to the National Bureau of Economic Research, the U.S. economy was in 

recession from December 2007 to June 2009. 
 

Page 21 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 8: Trends in SNAP Participation, Unemployment, and Poverty, 1990-2011

Note: Numbers of people in poverty are based on data for March of the following year (except the 

2010 figure is based on June 2010 data). Numbers of SNAP participants are based on the average 

monthly value for the fiscal year. Unemployed people are based on data as of June of that year. 

Federal changes to SNAP, as well as those initiated by individual states, 

and a shift in public perception of the program, have also likely 

contributed to increases in participation during the past decade. For 

example, the Recovery Act implemented a 13.6 percent increase in 

maximum monthly SNAP benefits,42

 

42§ 101(a), 123 Stat. 120.

which likely made participation in the 

program more attractive to eligible households. In addition, the simplified 

reporting option, which most states have implemented since it became 

available in 2001, has been linked to increased participation, likely 

because it reduces the administrative burden for SNAP households and 

lengthens certification periods. Further, USDA expenditures targeted to 
 

Page 22 GAO-12-670 Supplemental Nutrition Assistance Program

state and community outreach efforts, as well as relaxed limits on vehicle 

ownership, have been linked to increased SNAP participation. During our 

site visits, officials noted that the Recovery Act’s suspension of the 3-

month time limit for able-bodied adults without dependents also caused a 

noticeable increase in SNAP participants.43 In addition, individual states 

have implemented program changes that may have increased 

participation, such as taking steps to make it easier to apply for SNAP. 

For example, staff in most of the states we visited cited implementation of 

online applications and phone interviews, instead of in-person interviews, 

as improving access to SNAP and shifting the public’s perception of the 

program. Some local caseworkers noted that being able to apply without 

going to a public assistance office lowers the stigma associated with 

receipt of government assistance. These changes may also be 

encouraging participation among specific age groups, as local 

caseworkers across several states we visited described an increasing 

trend of single people aged 22 applying as their own SNAP households.44

Several studies have examined the impact of various changes on SNAP 

participation, though it is difficult to measure the precise impact of any 

single change.45

Other studies, our own analysis of USDA data, and information we 

obtained during our site visits indicate the impact of BBCE on SNAP 

participation is likely small, and the extent to which the policy directly 

encouraged eligible households to participate is uncertain. While several 

studies have concluded that BBCE policies have contributed to increases 

 

43§ 101(e), 123 Stat. 121. The Recovery Act eliminated the SNAP time limit for these 

adults without dependents during the period April 1, 2009, through September 30, 2010, 

but most states have since received waivers to continue the time limit suspension through 

fiscal year 2013.

44At age 22, a SNAP applicant can be declared a separate household, even if living with 

friends or family. 7 C.F.R. § 273.1(b)(ii). Caseworkers noted that they have seen some 

people apply for SNAP on their 22nd birthdays, and they believe that online information 

about program rules, as well as online applications, may be affecting this trend. 

45Caroline Ratcliffe, Signe-Mary McKernan, and Kenneth Finegold, The Effect of State 

Food Stamp and TANF Policies on Food Stamp Program Participation (Washington, D.C.: 

The Urban Institute, March 2007); James Mabli, Emily Sama Martin, and Laura Castner, 

Effects of Economic Conditions and Program Policy on State Food Stamp Program 

Caseloads, 2000 to 2006 (Washington, D.C.: Mathematica Policy Research, Inc., August 

2009); and Jacob Alex Klerman and Caroline Danielson, Determinants of the Food Stamp 

Program Caseload (Washington, D.C.: RAND, January 2009).
 

Page 23 GAO-12-670 Supplemental Nutrition Assistance Program

in SNAP participation,46 they yield inconclusive results concerning the 

magnitude of the impact. Our own analysis of changes in SNAP 

participation in the 17 states that adopted BBCE policies during fiscal 

year 2009 revealed those states had a slightly larger increase in 

participation between fiscal years 2008 and 2010 than states without 

BBCE. However, because of the many other factors influencing SNAP 

participation during these years, we cannot attribute this increase entirely 

to BBCE. State officials and local caseworkers in the five states we visited 

were also uncertain of BBCE’s effect on SNAP participation. According to 

those we spoke to, BBCE had a noticeable, but relatively small, effect on 

SNAP participation, and local staff in all 18 of the offices we visited said 

BBCE’s impact on SNAP participation was considerably less than that 

caused by the economic downturn. Those in one office said they had 

been alerted by their state office to prepare for a significant spike in 

applications once the BBCE policy went into effect, but the subsequent 

increase was considerably less than expected. Others noted that the 

participation increases they noticed after BBCE implementation may also 

have been due to some other simultaneous cause, such as seasonal 

increases.

 

46Jacob Alex Klerman and Caroline Danielson, “The Transformation of the Supplemental 

Nutrition Assistance Program,” Journal of Policy Analysis and Management, vol. 30, no. 4, 

(2011); Janna Johnson, The Dynamics of SNAP Participation and the Increase in SNAP 

Caseloads during the Recovery of 2003-2007 (Madison, WI: Institute for Research on 

Poverty, November 30, 2011); Mabli, Martin, and Castner, Effects of Economic Conditions 

and Program Policy on State Food Stamp Caseloads, 2000 to 2006; and Ratcliffe, 

McKernan, and Finegold, The Effect of State Food Stamp and TANF Policies on Food 

Stamp Program Participation. 
 

Page 24 GAO-12-670 Supplemental Nutrition Assistance Program

Although SNAP households that had incomes over the federal limits 

made up an estimated 2.6 percent of the SNAP caseload in fiscal year 

2010, this group received an estimated 0.7 percent47 of all SNAP benefits. 

These benefits totaled an estimated $38.3 million a month, or 

approximately $460 million annually.48 In the group of states that 

increased the federal SNAP gross income limit with their BBCE policies, 

benefits provided to households that had incomes over the federal limits 

were an estimated 1.5 percent of all SNAP benefits (see fig. 9). Due to 

data limitations, these estimates represent minimums, as they do not 

include benefits provided to SNAP households deemed eligible under 

BBCE with assets over the federal SNAP asset limits.49

 

47The 95 percent confidence interval for the 0.7 percent estimate is (0.6, 0.8). For the 95 

percent confidence intervals for all estimates in this paragraph, see appendix II, tables 4 

and 6. For more information about our analysis, see appendix I.

48In April 2012, CBO released a report on SNAP that estimates $1.2 billion as the average 

annual savings in spending over the 2013-2022 period if federal SNAP income and asset 

limits were applied to all categorically eligible households. CBO considers this estimate to 

be equivalent to a 1.6 percent annual savings for SNAP. However, CBO’s methodology for 

producing its estimates differs from our methodology in several ways. For example, 

although CBO indicates its estimates reflect changes to BBCE, the Office’s estimates 

include both benefits provided to households deemed eligible under BBCE policies, as 

well as benefits provided to households deemed eligible under narrow non-cash 

categorical eligibility policies. In addition, CBO estimates include assumptions about the 

share of these households that exceed federal asset limits and the benefits they receive. 

49The national SNAP household data that we used for our analysis does not include 

reliable information on assets owned by households deemed eligible under BBCE. As a 

result, our estimates represent minimums that do not include benefits provided to 

households who had assets over the federal SNAP asset limits. 

State Eligibility 

Changes Increased 

Benefit Costs 

Somewhat, but Their 

Effect on 

Administrative Costs 

Is Unclear

Benefit Costs Increased 

Less Than 1 Percent
 

Page 25 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 9: Benefits Provided to SNAP Households That Would Not Have Been 

Eligible for the Program without BBCE because Their Incomes Were over Federal 

Limits, per Month in Fiscal Year 2010

Note: For the 95 percent confidence intervals for these estimates, see appendix II, table 6. 

Because SNAP benefits are calculated based on income and expenses, 

and provide greater benefits to those with fewer means, those with 

incomes over the federal limits tend to be eligible for fewer benefits. On 

average, these households received an estimated $81 average monthly 

SNAP benefit in fiscal year 2010 compared to an estimated $293 average 

monthly benefit received by all other SNAP households in that year.50

 

50For the 95 percent confidence intervals for all estimates in this paragraph, see appendix 

II, tables 7 and 8.

These households also disproportionately received the minimum benefit 

of $16. An estimated 44 percent of these households received the 

minimum benefit compared to 3 percent of all other households. 

Households eligible solely because of BBCE had higher average 

deductions in certain categories—including dependent care and child 

support expenses—than other households in fiscal year 2010 (see table 

3), and deductions increase monthly SNAP benefits. However, in general, 
 

Page 26 GAO-12-670 Supplemental Nutrition Assistance Program

the higher incomes of households eligible solely because of BBCE seem 

to have had a greater impact on their SNAP benefits than their 

deductions, given the relatively low average benefits they received.

Table 3: Estimated Percent of Specified Groups of SNAP Households Receiving 

Deductions and the Estimated Average Amount of the Deduction, in Fiscal Year 

2010

Deduction

Percentage of SNAP 

households with incomes over 

the federal limits receiving 

deduction (average amount)

Percentage of all other 

SNAP households 

receiving deduction 

(average amount)

Child support expenses 6.7 ($20) 1.9 ($4)

Dependent care 14.3 ($50) 3.5 ($8)

Earned income 65.9 ($243) 28.9 ($57)

Medical 13.0 ($19) 3.5 ($5) 

Excess shelter 72.2 ($220) 70.5 ($265)

Source: GAO analysis of USDA’s SNAP quality control data.

Note: The average amount of the deduction was calculated for all households in each group, rather 

than only for households that received the deduction. All percentage and numerical estimates in this 

table are significantly different at the 95 percent confidence level except for the estimated percentage 

of each group receiving the excess shelter deduction. See appendix II, table 8 for the 95 percent 

confidence intervals for these estimates. 

Both the cost of total SNAP benefits and the average benefit per 

household increased over the last decade while many states were 

implementing BBCE; however, other factors likely had a greater effect on 

benefit costs (see fig. 10). The annual adjustment made to the Thrifty 

Food Plan—which is the basis for the maximum SNAP benefit amounts, 

as well as changes in the economy, demographics, and policies affecting 

deductions, outreach, and eligibility can all affect total spending on SNAP 

benefits. In recent years, the recession drove increased benefit costs, 

both by changing household circumstances and by increasing the benefit 

cost per household. For example, because household benefits are 

primarily determined based on each household’s monthly income, 

increases in the poverty and unemployment rates likely correlate with 

increases in the average benefit provided to households. In addition, as 

previously noted, the Recovery Act implemented a 13.6 percent increase 

in the maximum monthly SNAP benefit per household. During our site 

visits, some officials cited these changes as key factors that impacted 

household benefits in recent years. Officials we spoke to also noted that 

the slow economic recovery has led to SNAP households remaining on 

the program for longer time periods than before the recession, which can 

lead to increases in total benefit costs.
 

Page 27 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 10: Selected Information on SNAP Benefits and Potentially Related Factors, 2001-2011

Because many factors impact SNAP benefit costs, the full extent of 

BBCE’s impact is unclear, though evidence suggests other factors played 

a more important role in recent years. Although BBCE may impact SNAP 

benefit costs because the policy both expands who is eligible for the 

program and streamlines the process for receiving benefits, state and 

local officials we met with consistently indicated that they did not think 
 

Page 28 GAO-12-670 Supplemental Nutrition Assistance Program

BBCE had a significant impact on benefits. Further, our analysis of SNAP 

household data suggests factors beyond BBCE typically have a greater 

impact on benefits. For example, in our review of SNAP benefits in the 

group of 17 states that implemented BBCE during fiscal year 2009, we 

found that the average monthly benefit per household significantly 

increased in all of these states between fiscal years 2008 and 2010. 

However, for most of these states, the increases were likely primarily 

related to the increase in maximum benefits implemented under the 

Recovery Act, as we found no significant differences in the two factors 

used to determine benefit amounts—net income and household size—for 

those years.51

Many factors affect SNAP administrative costs, and state BBCE policies 

are one factor that may help reduce such costs. Studies have shown that 

factors ranging from a state’s economy and demographic characteristics 

to its SNAP policies, administrative processes, staff salaries, and the use 

of technology all impact state administrative spending to varying degrees. 

As we previously reported, because categorical eligibility policies simplify 

the eligibility determination process by creating consistency in income 

and resource limits across programs, these policies can save resources, 

improve productivity, and help staff focus more time on performing 

essential program activities.52

 

51We found no differences in these two factors in 13 states. However, when comparing 

SNAP household characteristics for fiscal years 2008 and 2010, we found significant 

increases in SNAP households’ average net income in 3 states that implemented BBCE in 

fiscal year 2009. In these states, average net income increases appear to be related to 

higher net incomes in households deemed eligible under BBCE. One state also had a 

significant decrease in household size. 

During our site visits, staff in many of the 

local offices we visited stated that, before BBCE was implemented, 

verifying assets often took a considerable amount of time, and state 

officials added that it could be costly, as banks sometimes charge SNAP 

offices a fee to provide account documentation. As a result, staff in almost 

all of the local offices we visited said BBCE’s removal of the SNAP asset 

limit helped streamline case processing, and some noted that 

streamlining occurred both because SNAP households did not have to 

52See GAO, Human Service Programs: Demonstration Projects Could Identify Ways to 

Simplify Policies and Facilitate Technology Enhancements to Reduce Administrative 

Costs, GAO-06-942 (Washington, D.C.: Sept. 19, 2006).

Administrative Costs 

Affected by Many Factors
 

Page 29 GAO-12-670 Supplemental Nutrition Assistance Program

provide documentation of assets and caseworkers did not need to verify 

asset information.

Consistent with annual increases in SNAP participation and benefit costs 

between fiscal years 2001 and 2010, SNAP administrative costs generally 

increased annually during this period, though at a lower rate. Certification 

costs—a sub-set of SNAP administrative costs that include the cost of 

staff determination of household eligibility for benefits—also generally 

increased over this period (see fig. 11). Cost increases in recent years 

are likely directly related to the $690.5 million in extra federal funding for 

SNAP administrative costs provided to states through the Recovery Act 

and the Department of Defense Appropriations Act, 2010, in response to 

the national economic recession.53

 

53Although the federal government generally funds half of states’ administrative costs for 

SNAP, this additional funding was provided to the states without a requirement that they 

match it with their own funds.

However, despite this additional 

federal funding, because administrative costs increased at a lower rate 

than SNAP participation, administrative costs per SNAP household 

declined during this period (see fig. 12).
 

Page 30 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 11: SNAP Administrative Costs, Fiscal Years 2001-2010

Note: These data include administrative costs paid by both federal and state governments. 
 

Page 31 GAO-12-670 Supplemental Nutrition Assistance Program

Figure 12: Administrative Costs per SNAP Household, Fiscal Years 2001-2010

Note: These data include administrative costs paid by both federal and state governments. 

While many states implemented BBCE during this period, the largest 

decreases in these costs occurred in recent years when the economic 

recession was also a factor. Specifically, during the recent recession, 

states faced budgetary constraints to funding SNAP administrative 

expenditures. Because states pay for approximately half of these 

expenditures, when state tax revenues decrease during recessions, state 

balanced budget requirements and other constraints affect state and local 

governments’ ability to provide services at the same time that demand for 

services increases.54

 

54Although the most recent national recession affected states to different degrees, in part 

depending on their tax structures and economic characteristics, state and local 

governments generally experienced more severe and long-lasting declines in revenue 

during this recession when compared to past recessions. For more information on the 

effect of recessions on state and local governments, see GAO, State and Local 

Governments: Knowledge of Past Recessions Can Inform Future Federal Fiscal 

Assistance, 

In our site visits to five states, officials frequently 

GAO-11-401 (Washington, D.C.: Mar. 31, 2011). 
 

Page 32 GAO-12-670 Supplemental Nutrition Assistance Program

noted how overwhelmed local SNAP caseworkers have been with the 

increased workload during the recent recession. They noted that 

workload increases have been driven by increases in SNAP participation 

and the amount of time households remain on the program, as well as 

budget constraints that hinder their offices’ ability to hire additional staff. 

Across the seven local offices we visited in states that adopted BBCE 

during the recent recession, staff noted that while BBCE helped 

streamline the processing of individual cases, these improvements were 

offset by the increased workload. However, some staff indicated they 

believe reinstating the federal SNAP asset test that was removed under 

BBCE would make their workload unmanageable.

In addition to the recession, other changes that states have made to 

simplify and ease program administration during the last decade make it 

difficult to determine BBCE’s full impact on administrative costs. For 

example, state and local officials frequently cited the implementation of 

reduced reporting requirements under the simplified reporting option, the 

conversion of case files from paper to electronic formats, the 

implementation of online SNAP applications, and increased use of phone 

interviews as changes that also helped to ease staff workloads. Officials 

in one state we visited noted that while these changes may have helped 

to reduce administrative expenditures over time, some, like BBCE, may 

have resulted in increased spending in the short-term due to the need for 

training and modifications to computer systems. Further, while most state 

SNAP officials we met with during our site visits felt that BBCE likely 

decreased administrative expenditures to some extent, they did not know 

the policy’s actual impact because of other changes.

In recent years, the SNAP payment error rate declined to an historic low 

while multiple program changes occurred, including BBCE, but evidence 

suggests that factors other than BBCE may have played a larger role in 

the decline. Between fiscal years 2000 and 2010, USDA reported that the 

national payment error rate—the percentage of SNAP benefits paid in 

error, including underpayments and overpayments—fell from 8.91 percent 

State Eligibility 

Changes May 

Negatively Affect 

Program Integrity

Payment Errors May Be 

Negatively Affected
 

Page 33 GAO-12-670 Supplemental Nutrition Assistance Program

to 3.81 percent as the number of states with BBCE policies increased 

from 0 to 39.55 Because most states’ BBCE policies eliminated the need 

to confirm that SNAP household assets fall below certain limits, BBCE 

effectively removed the potential for asset-related errors in these states. 

However, USDA data indicate that most errors have been caused by 

factors other than assets in recent years. In fact, fewer than 4 percent of 

all error cases nationally have been caused by asset errors since 2000.56

Further, both our analysis of USDA data and our discussions with SNAP 

staff suggest that BBCE may, in fact, contribute to more payment errors. 

Although BBCE has been promoted by USDA as a possible means to 

reduce errors, we found that a greater percentage of SNAP households 

eligible under BBCE that had incomes over the federal limits had payment 

errors than other households (17.2 percent compared to 6.7 percent) in 

fiscal year 2010.

Therefore, it is likely that other factors had a greater impact on error rates 

during this time. For example, the number of states adopting the 

simplified reporting option for at least some SNAP households increased 

during this period. Because this option eliminates substantial paperwork 

requirements for participants and states, and reduces the number of 

times income is verified, states experience fewer related errors. In 

addition, states we visited reported that they had also made other

changes during this period to help lower their error rates, such as 

incorporating the use of technology with new case management models 

or digital files.

57

 

55The 95 percent confidence interval for the 8.91 percent estimate is (8.56, 9.26) and the 

95 percent confidence interval for the 3.81percent estimate is (3.61, 4.01).

This may be related to the fact that these households 

were significantly more likely to have earned income, and income is a 

frequent cause of SNAP payment errors. In addition, while most states’ 

BBCE policies removed a potential source of error by eliminating asset 

limits, SNAP caseworkers we spoke with told us that a reduction in the 

level of verification they perform may actually increase the potential for 

errors as well as fraud. For example, staff in two states reported that 

56Income-related errors have consistently been the largest contributor to payment errors, 

representing 49 to 55 percent of all errors since 2000.

57The 95 percent confidence interval for the 17.2 percent estimate is (14.3, 20.2), and the 

95 percent confidence interval for the 6.7 percent estimate is (6.4, 7.0). These estimates 

differ from the SNAP payment error rate, as the error rate measures benefit dollars 

provided in error rather than the percentage of SNAP households with errors.
 

Page 34 GAO-12-670 Supplemental Nutrition Assistance Program

removing asset verification under BBCE has reduced their ability to 

investigate other applicant information for possible inconsistencies. 

Specifically, while asset verification often took considerable time to 

perform, they noted that previously reviewing bank accounts gave them 

the ability to identify regular deposits that may be income to ensure those 

were reported by the applicant. Beyond changes due to BBCE, 

caseworkers in several states we visited suggested there has been a 

cultural shift towards an overall reduction in the level of verification and 

investigation they perform, in part because of the increased participation 

and workload related to the recent recession. They expressed concern 

about maintaining a balance between providing assistance to those who 

need it and ensuring program integrity, noting they worry about losing 

access to information to help ensure integrity.

While federal rules provide states with considerable flexibility in designing 

their BBCE policies, gaps in federal oversight may contribute to some 

unintended consequences for SNAP and related programs’ integrity. We 

found unintended consequences relating to three key areas:

• provision of a TANF-funded service,58

• direct certification for free school meals, and

• requirements for categorically eligible households to report changes 

(in household circumstances).

Our visits to states suggest that SNAP applicants are not consistently 

receiving the TANF-funded information required to confer categorical 

eligibility and that the extent to which this information is TANF-funded is 

unclear. According to USDA, BBCE policies make most households that 

apply for SNAP categorically eligible because they receive a TANFfunded service, such as an informational brochure or toll-free number, as 

long as the household’s income is within the state’s specified income limit 

(see fig. 13).59

 

58For this report, we use “TANF-funded service” to refer to a TANF-funded non-cash 

benefit or service that can be used by states to confer BBCE, per USDA guidance. Per 

federal regulations, states may grant categorical eligibility to any household authorized to 

receive a TANF-funded benefit or service. 7 C.F.R. § 273.2(j)(2)(ii) and (iii) (2012). 

However, in one state we visited, some local SNAP 

caseworkers told us they did not consistently provide the guide to 

59Applicants may be granted categorical eligibility solely through receipt of such a 

document, regardless of whether or not they access or receive additional services. 

Limited Oversight May 

Contribute to Unintended 

Consequences

TANF-Funded Service Not 

Consistently Provided
 

Page 35 GAO-12-670 Supplemental Nutrition Assistance Program

services brochure to all applicants. In another, staff said that at the 

applicant’s request, and/or if caseworkers think there is a need, they will 

provide referrals to services. In a third state we visited, applicants were 

directed on the SNAP application to call a toll-free number to receive an 

informational brochure on services; however, we were unsuccessful in 

obtaining this brochure after repeated (5) attempts to call the number 

listed. Further, according to USDA, states must use TANF funds to pay 

for either the document households receive or the services mentioned in 

the document. If states use TANF funds to cover at least 50 percent of 

the cost, they do not need to obtain USDA approval of their BBCE 

policies. While SNAP officials in three of the states we visited confirmed 

that the documents used to confer categorical eligibility are partially 

TANF-funded, they did not know the exact percentage of TANF dollars 

used to fund them.

Figure 13: Examples of How States Confer BBCE for SNAP

Massachusetts 

A Non-Public Assistance food stamp household which consists of adults between the 

ages of 19 and 59 is subject to the food stamp gross and net income tests and is no 

longer subject to an asset test. Receipt of the Help for Those in Need: A Resources 

Brochure confers a TANF Program service.

Nevada 

All SNAP applicant households receiving the revised “This is Your Copy” page from the 

back of the application are categorically eligible for benefits. There will be no resource 

or gross/net income tests applied to these households. This page was revised to 

contain the following information about services available from the Nevada Public 

Health Foundation (NPHF): 

Utilizing TANF funds, DWSS through the Nevada Public Health Foundation (NPHF), 

has developed a class to target pregnant and parenting teens... 

Washington 

Basic Food Assistance Units with countable income up to 200% of the federal poverty 

guidelines are eligible to use the department’s Online CSO website. This website 

provides information about our programs as well as referrals to resources in the 

community. This web-based information and referral service is partly funded with TANF 

and TANF Maintenance Of Effort funds. Because of this funding, we use this service to 

make Assistance Units categorically eligible for Basic Food if they have countable 

income at or under 200%. Clients are notified and authorized to receive this service 

through a text block on their approval letter for Basic Food.

Source: Commonwealth of Massachusetts, Executive Office of Health and Human Services, Department of Transitional Assistance, 

Field Operations Memo 2008-27, “Maximized Categorical Eligibility for NPA Food Stamp Households,” (May 30, 2008); State of 

Nevada, Department of Human Resources, Welfare Division, Policy Transmittal, “SNAP Categorical Eligibility – Receipt of TANF 

Benefit” (March 9, 2009); and Washington State Department of Social and Health Services, Eligibility A-Z Manual, “Categorical 

Eligibility for Basic Food,” (revised February 28, 2012).

Note: We did not conduct site visits to these 3 states, and we did not conduct an independent legal 

analysis to verify this information. 
 

Page 36 GAO-12-670 Supplemental Nutrition Assistance Program

Gaps in USDA’s oversight of states’ procedures for implementing BBCE 

may contribute to the inconsistencies we found in providing qualified 

applicants with the TANF-funded information or service that confers 

BBCE. While USDA has issued guidance over the past 3 years in 

response to various state questions about BBCE, the agency’s 

documentation requirements for states that adopt it are limited. According 

to agency guidance, while states must document that a household was 

determined categorically eligible, USDA does not require states to 

document that the TANF-funded service was received by applicants. As a 

result, in a state where a document, such as a brochure, is used to confer 

eligibility, the state does not have to verify that it has provided the 

document to applicants as part of the eligibility determination process. In 

addition, headquarters and regional USDA officials told us the agency 

does not request documentation from states on the extent of TANF 

funding used, even though that information is necessary to determine 

whether a BBCE policy would require agency approval. Agency officials 

added that the burden is on the states to let USDA know if approval is 

needed. Agency officials also told us that while they provide technical 

assistance to states, as needed, on the development of their BBCE 

policies and collect summary information on states’ BBCE provisions, 

they do not approve state BBCE policies.

Because states have flexibility to decide how to treat SNAP households 

deemed eligible for $0 in benefits—an outcome more likely under 

BBCE—some children have been inappropriately certified for free school 

meals, including in two states we visited. Under SNAP, states have been 

allowed to decide whether to deny eligibility to households who qualify for 

$0 in benefits or whether to certify these households SNAP-eligible 

without benefits. For school meals programs, statute indicates states 

must certify children in households that receive SNAP benefits eligible for 

free school meals—a process called direct certification that is designed to 

ease administrative burden when certifying children for multiple 

assistance programs with similar eligibility criteria.60

 

6042 U.S.C. § 1758(b)(4). School districts have been required to directly certify SNAP 

recipients since school year 2008-2009. According to USDA, once a child is directly 

certified for free school meals, eligibility lasts the entire school year regardless of a 

change in family circumstances. Households may voluntarily report a change in family 

circumstances; however, because of the year-long duration of eligibility, households are 

not required to report changes in their categorical eligibility status.

Many states rely on 

data matches between their SNAP program and district-level school data 

Inappropriate Certification for 

Free School Meals 
 

Page 37 GAO-12-670 Supplemental Nutrition Assistance Program

to identify children eligible for direct certification, and beginning in school 

year 2012-2013, all states are expected to do so. However, because a 

state can certify families receiving $0 in SNAP benefits as eligible in its 

SNAP data system, it can directly certify children in such families for free 

school meals, even though they do not receive SNAP benefits.61

In recognition of this practice, in 2011, USDA issued guidance for states 

through its regional offices reiterating that children in households 

receiving $0 in benefits are not categorically eligible for free school meals 

and therefore should not be directly certified; however, officials in the 

states we visited were unaware of this guidance. In its October 2011 

memorandum, USDA further suggested that state SNAP agencies work 

with their school meal agency counterparts to ensure that children from 

$0 benefit SNAP households are excluded from direct certification as 

soon as possible. According to USDA, school meal agencies were to be 

in compliance with this guidance by July 1, 2012.

This 

practice occurred in two states we visited. SNAP officials in one state told 

us the state adopted BBCE, in part, to potentially enable more children to 

become eligible for free school meals. Local caseworkers in that state 

similarly said that they believe parents apply for SNAP specifically 

because they know their child(ren) are eligible for free school lunch even 

if they are deemed eligible for $0 in SNAP benefits.

62

 

61This may also impact other programs. For example, some school districts that receive 

federal funds under Title I, Part A of the Elementary and Secondary Education Act of 1965

(20 U.S.C. § 6301-6339) use the number of children eligible for free and reduced-price 

meals in each of their schools as a proxy measure of school poverty in order to 

appropriately distribute those funds to their schools. 

Agency officials in 

USDA’s regional offices representing the states we visited told us they 

routinely transmit guidance and policy changes to states from the national 

office. This guidance was also made available on USDA’s Web site. 

However, in June 2012, we followed up with the two states we visited that 

had been directly certifying children from $0 benefit SNAP households, 

and state officials indicated the practice was still occurring, as they were 

not aware of this guidance from USDA.

62Letter to Program Directors-All Regions, “National School Lunch Program and Direct 

Certification with SNAP,” signed by the Director of the Program Development Division, 

FNS, USDA. October 25, 2011. The practical result is that direct certification of students 

from families eligible for SNAP but entitled to $0 benefit should not continue in the 2012-

13 school year.
 

Page 38 GAO-12-670 Supplemental Nutrition Assistance Program

Direct certification of children in categorically eligible SNAP households 

creates another unintended consequence—one of effectively increasing 

the income eligibility limit for free school meals for some children. While 

the federal gross income-eligibility limit for SNAP aligns with that of the 

school meals programs—providing free meal benefits to children in 

households at or below 130 percent of the federal poverty guidelines63—

the programs no longer align in states with BBCE policies that have 

raised the SNAP gross income limit. In the 27 states with BBCE gross 

income limits between 160 and 200 percent of the federal poverty 

guidelines, children in categorically eligible households may receive free 

school meals when, under traditional federal rules, they would not qualify 

for free meal assistance.64

In states that have adopted BBCE, requirements for reporting changes in 

household income or household size can vary, resulting in unequal 

treatment of households. Under simplified reporting rules adopted by 

nearly all states,

In short, through their BBCE policies, some 

states have effectively increased the income eligibility limits for two key 

federal nutrition assistance programs.

65 households are required to report changes in income 

between scheduled reporting periods only if income exceeds the federal 

SNAP gross income limit—130 percent of the federal poverty guidelines. 

Because of BBCE, however, 27 states have, in effect, changed their 

SNAP gross income limit to levels greater than 130 percent. USDA issued 

SNAP guidance on change reporting requirements clarifying that, in 

states with simplified reporting, categorically eligible households with 

gross incomes over 130 percent of the federal poverty guidelines at the 

time of certification have no federal SNAP reporting requirements until 

they recertify or file a periodic report.66

 

6342 U.S.C. § 1758(b)(1)(A). 

While guidance further indicates 

that states may choose to require these households to report when their 

gross income exceeds the income limit of the TANF program that confers 

64Under school meals rules, children in families with gross household incomes between 

130 and 185 percent of the federal poverty guidelines, while not eligible for free meals, are 

eligible to receive reduced price meals. 42 U.S.C. § 1758(b)(1)(A). 

65As of November 2010, all states, except California and Wyoming, used simplified 

reporting for at least some SNAP households.

66One of the recent documents that provides this guidance is the Memo to Regional 

Directors, “Categorical Eligibility Questions and Answers,” signed by the Director of the 

Program Development Division, FNS, USDA. January 26, 2010. 

Inequities in Reporting 

Requirements 
 

Page 39 GAO-12-670 Supplemental Nutrition Assistance Program

categorical eligibility, they are not required to do so. Two states we visited 

do not require households with incomes above 130 percent of the poverty 

guidelines to report changes in income between reporting periods. This 

results in lower-income SNAP households having a greater reporting 

burden than higher income SNAP households in order to retain their 

benefits.

While USDA has issued guidance to states in this area, its guidance 

relies on TANF reporting requirements that do not exist. USDA officials 

told us that TANF rules require categorically eligible SNAP households to 

report to TANF when their incomes exceed the income limit of the TANF 

service used to confer BBCE. However, because BBCE households are 

often authorized to receive a TANF-funded service through a brochure or 

toll-free telephone number given to them by a SNAP office, they may not 

be aware of any related TANF reporting requirements. Further, as we 

have previously reported, state TANF agencies are not required to collect 

data on many recipients of TANF-funded services, which include BBCE 

households.67 Accordingly, a state TANF agency would not seek 

information on these households’ income changes in order to share that 

information with the SNAP agency.

In response to the recent economic downturn and prolonged recovery, 

the Supplemental Nutrition Assistance Program has grown to provide 

unprecedented numbers of low-income households with benefits for food 

assistance. While the substantial increases in SNAP participation led to 

concerns that the large number of states adopting BBCE policies in 

recent years may have been a driver of those increases, these policies 

have had only a modest impact on program participation. Further, SNAP 

generally continues to serve households with the same types of 

characteristics it always has, and is intended to.

As federal and state governments face mounting fiscal pressures and 

confront limited resources, ensuring the integrity of SNAP and other 

programs spending public dollars is critical. While USDA touted BBCE as 

a way to improve program integrity and administrative efficiency, state 

adoption of BBCE has created unintended consequences that may 

 

67GAO, Temporary Assistance for Needy Families: Implications of Caseload and Program 

Changes for Families and Program Monitoring, GAO-10-815T (Washington, D.C.: Sept. 

21, 2010).

Conclusions
 

Page 40 GAO-12-670 Supplemental Nutrition Assistance Program

weaken both SNAP and related programs’ integrity and introduce 

inequities. First, because gaps exist in USDA’s review of states’ 

procedures for implementing BBCE, some states are deeming 

households eligible under BBCE without following the required steps to 

do so. In addition, it is not known whether states are following the funding 

requirements associated with these policies. Second, because USDA’s 

guidance clarifying children’s eligibility for free school meals when their 

families receive $0 in SNAP benefits—an outcome likely more common 

because of BBCE—has not reached all states, school meal programs are 

vulnerable to overpayments and abuse. Finally, USDA’s guidance on

SNAP reporting requirements has resulted in lower-income households 

eligible under federal SNAP rules having to do more to retain their 

benefits than higher-income SNAP households eligible solely because of 

states’ BBCE policies.

While these unintended consequences of BBCE on SNAP program 

integrity are potentially significant, they may also be easily addressed by 

those overseeing and administering the program. At a time when the 

economy has left more in need of assistance, SNAP continues to help 

low-income households obtain adequate nutrition. As a result, any 

changes to BBCE should carefully weigh the potential benefits and costs, 

which at this time include the increased burden on state and local staff 

who are already stretched thin as a result of decreased budgets and staff 

resources.

To improve SNAP program integrity and oversight, we are recommending 

that the Secretary of Agriculture require FNS to take several actions:

• Review state procedures for implementing BBCE, specifically those in 

place for providing the relevant TANF-funded service to all SNAP 

applicants deemed eligible under BBCE, as well as ensuring the 

relevant service is funded with TANF dollars.

• Disseminate the agency’s October 2011 guidance clarifying that 

children in households certified as eligible for $0 in SNAP benefits 

should not be directly certified to receive free school meals directly to 

state agencies administering SNAP.

• Revisit agency guidance on change reporting requirements to ensure 

that all households, including those deemed eligible under BBCE with 

incomes above the federal gross income limit, are treated equitably.

Recommendations for 

Executive Action
 

Page 41 GAO-12-670 Supplemental Nutrition Assistance Program

We provided a draft of this report to USDA for review and comment. On 

July 16, 2012, the Associate Administrator for SNAP and other FNS 

officials provided us with the agency’s oral comments. Officials stated that 

they were in general agreement with the findings and recommendations 

presented in the report and offered technical comments that we have 

incorporated as appropriate. Officials also discussed the positive impacts 

BBCE has had on SNAP, including state administrative relief and cost 

savings, and emphasized our finding that BBCE policies have generally 

not changed the characteristics of SNAP households. As a result, the 

program continues to serve those it is intended to. Officials also noted 

their agreement with our conclusion that BBCE’s benefits should be 

considered when assessing changes to these policies. Concerning our 

finding on the percentage of SNAP households with incomes over the 

federal limits that had payment errors, officials noted that these 

households may be more likely to have benefit errors than other SNAP 

households because they have greater earned income and deductions—

factors that have been found to increase the likelihood of errors. We 

agree, and our findings on the characteristics of this sub-group of 

households support that conclusion. Further, officials suggested that the 

total amount of benefit dollars provided in error to this sub-group of 

households is likely relatively small because the average monthly benefit 

provided to these households is much smaller than the average benefit 

provided to all other SNAP households. Because of this, officials believe 

that errors in these households impact the overall SNAP payment error 

rate to a small extent, which is supported by the fact that the program’s 

error rate has been relatively constant in recent years while the number of 

states with BBCE has increased. While we agree that it is likely that the 

total amount of benefit dollars provided in error to this sub-group of 

households is relatively small, we did not develop such an estimate 

during our analysis of the SNAP quality control data.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Agriculture, and 

other interested parties. In addition, this report will be available at no 

charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 

Agency Comments 

and Our Evaluation
 

Page 42 GAO-12-670 Supplemental Nutrition Assistance Program

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix III.

Kay E. Brown

Director, Education, Workforce, and Income Security Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-12-670 Supplemental Nutrition Assistance Program

To determine the prevalence and characteristics of households deemed 

eligible under states’ broad-based categorical eligibility (BBCE) policies 

that had incomes over the federal Supplemental Nutrition Assistance 

Program (SNAP) eligibility limits in fiscal years 2008 and 2010, we 

analyzed the Food and Nutrition Service’s (FNS) quality control (QC) 

system data of active SNAP cases.1

To identify which households were deemed eligible under BBCE, and the 

sub-set of BBCE households that had incomes over the federal SNAP 

eligibility limits, we took several steps. First, we identified which states 

had BBCE policies in place in fiscal years 2008 and 2010 using an FNS 

compilation of BBCE policy implementation dates. Based on our 

discussions with FNS officials, Mathematica Policy Research, Inc. staff,

Per federal SNAP requirements, 

state officials draw monthly random samples of SNAP cases and review 

them to determine the extent to which households received benefits to 

which they were entitled. FNS officials in its regional offices and 

headquarters perform a secondary review of a sub-set of each state’s 

sample of cases. The weighted analyses of the QC data produce 

nationally representative results.

2

We obtained the QC data directly from the QC database, which is made 

available to the public via Mathematica Policy Research, Inc.’s Web site. 

and state and local staff we spoke to during our five site visits, we 

assumed that once BBCE was enacted by a state, it was used as the 

default SNAP eligibility policy. Therefore, in states with BBCE policies in 

the fiscal year analyzed, we considered BBCE households to be those 

denoted in the QC data as categorically eligible in which all members did 

not receive cash assistance from another means-tested program. From 

this group, we determined the sub-set of BBCE households that had 

incomes over the federal SNAP eligibility limits.

 

1

We reviewed information on SNAP in the 50 states; Washington, D.C.; Guam; and the 

Virgin Islands. We use “states” throughout the report to refer to this group.

2

FNS contracts with Mathematica Policy Research, Inc. to maintain the SNAP QC data. 

Appendix I: Objectives, Scope, and 

Methodology 

U.S. Department of 

Agriculture (USDA) 

Data Analysis

Quality Control Data
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-12-670 Supplemental Nutrition Assistance Program

To analyze the data, we reviewed the technical user’s manual for both the 

2008 and 2010 QC public release data sets and evaluated the sampling 

methodology used to produce the data. We also reviewed the 

documentation for the internal review and coding process that FNS 

follows to prepare the QC data. Further, we checked the variables used in 

our analysis for out-of-range values or outliers. To produce weighted 

frequencies, weighted percents, and weighted dollar estimates for QC 

variables at the state and national level, we used the household weight 

variable provided in the public release QC data set. Because the records 

in the SNAP QC data are from a random sample, data analysis results 

are weighted estimates for a population of eligible households and thus 

are subject to sampling errors associated with samples of this size and 

type. The QC sample is only one of a large number of samples that states 

might have drawn. As each sample could have provided different 

estimates, we expressed our confidence in the precision of our QC data 

estimates as a 95 percent confidence interval (e.g., plus or minus 10 

percentage points). To produce 95 percent confidence intervals around 

our weighted estimates, we used a statistical software package and an 

appropriate variance estimation method suitable for the sample design of 

the QC data. (Appendix II provides the estimates and 95 percent 

confidence intervals for the data we present in the body of this report.)

Through our analysis of the QC data, a review of the technical 

documentation, and interviews with FNS officials and Mathematica 

statisticians, we determined that the QC public release data were 

sufficiently reliable for the purposes of our audit.

In addition to conducting our own analysis of the QC data, we reviewed 

national-level data on SNAP payment error rates—the percentage of 

SNAP benefits paid in error—available from FNS for fiscal years 2000 to 

2010. We also reviewed the primary sources of payment errors from 

2000-2010 to help identify the extent to which payment errors were 

attributable to assets or another source.

In addition to the QC data, we reviewed other data on SNAP participation 

and costs from USDA. Specifically, we analyzed data on average monthly 

SNAP participation in recent years obtained from USDA reports. In 

addition, we obtained data on total benefit costs and the average monthly 

SNAP benefits per household from USDA’s Web site and the annual 

SNAP State Activity Reports for fiscal years 2001-2011, as well as data 

on the proportion of households receiving the maximum SNAP benefit 

from the annual Characteristics of SNAP Households reports for fiscal 

Other SNAP Data
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-12-670 Supplemental Nutrition Assistance Program

years 2001-2010. To assess administrative costs, we obtained data on 

federal and state outlays and obligations for fiscal years 2001-2010 from 

USDA’s National Data Bank. These data are annually reported by states 

on the Standard Form 269 in specific cost categories designated by 

USDA. In addition, we obtained data on state expenditures of the federal 

Recovery Act funds provided for state administrative expenses in fiscal 

years 2009 and 2010, as well as the related funds provided through the 

Department of Defense Appropriations Act, 2010.

To better understand the effects of state BBCE policies on SNAP, as well 

as other factors impacting SNAP, we conducted site visits to 5 states and 

18 local offices responsible for administering SNAP in those states, 

during January and February 2012. The states and localities we visited 

were Arizona—Maricopa, Pima, and Pinal counties; Illinois—Cook and 

Lake counties; North Carolina—Cabarrus, Gaston, Lincoln, and 

Mecklenburg counties; South Carolina—Greenville, Laurens, and Pickens 

counties; and Wisconsin—Kenosha, Milwaukee, and Racine counties. We 

selected these states because they varied in their BBCE adoption dates, 

in the characteristics of their BBCE policies, and in their geographic 

locations. States selected also had relatively large SNAP caseloads and 

generally high proportions of their SNAP households deemed eligible 

under BBCE policies.

In each state, we interviewed state officials responsible for administering 

SNAP, as well as local SNAP administrators and caseworkers at three or 

four local offices. The local offices we visited ranged from urban to rural 

areas. During the interviews we collected information about the state’s 

BBCE policy and its application. In addition, we collected information 

about recent trends in SNAP participation, benefit amounts, 

administrative workload, and program errors, as well as BBCE’s impact 

on each. We also collected information on other economic and noneconomic factors that have impacted SNAP. Also, at each local office we 

observed the office’s general process for serving SNAP applicants, 

including the forms, documents, and technological systems used, and we 

gathered information on how BBCE was applied during the process. 

Lastly, we conducted interviews with federal officials at the USDA 

regional office associated with each state in order to discuss their role in 

the oversight of SNAP. We cannot generalize our findings beyond the 

states and localities we visited.

Site Visits
Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals 

Page 46 GAO-12-670 Supplemental Nutrition Assistance Program

Table 4: SNAP Households That Would Not Have Been Eligible for the Program 

without BBCE because Their Incomes Were over Federal Limits, in Fiscal Year 2010

Estimate 

95 percent 

confidence 

interval

SNAP households deemed eligible under BBCE with 

incomes over federal limits as a percentage of all SNAP 

households

2.6% 2.4% - 2.8%

SNAP households deemed eligible under BBCE with 

incomes over federal limits

473,381 438,088 - 

508,675 

All SNAP households 18,369,228 18,332,348 - 

18,406,108

SNAP households deemed eligible under BBCE with 

incomes over federal limits as a percentage of SNAP 

households in states with BBCE policies that increased 

the gross income limit

4.8% 4.4% - 5.2%

SNAP households deemed eligible under BBCE with 

incomes over federal limits in states with BBCE policies 

that increased the gross income limit

405,927 374,464 - 

437,390

All SNAP households in states with BBCE policies that 

increased the gross income limit

8,423,615 8,398,837 - 

8,448,393

Average total income of SNAP households deemed 

eligible under BBCE with incomes over federal limits

$1,965 $1,919 - 

$2,010

Average total income of SNAP households deemed 

eligible under BBCE with incomes over federal limits as a 

percentage of the federal poverty guidelines

151% 149% - 153%

Source: GAO analysis of USDA’s SNAP quality control data.

Table 5: Characteristics of Specified Groups of SNAP Households, in Fiscal Year 

2010

Estimate 

95 percent 

confidence 

interval 

SNAP households with at least one child as a percentage 

of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

56.3%

48.5%

52.5% - 60.1%

47.9% - 49.1%

SNAP households with a single female as the head as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

30.7%

25.8%

27.2% - 34.2%

25.3% - 26.3%

Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals
Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals 

Page 47 GAO-12-670 Supplemental Nutrition Assistance Program

Estimate 

95 percent 

confidence 

interval 

SNAP households with at least one member receiving 

Social Security benefits as a percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

27.8%

21.2%

24.3% - 31.4%

20.8% - 21.7%

Average amount of Social Security benefits received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$340

$155

$293 - $388

$151 - $159

SNAP households with at least one member with unearned 

income as a percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

60.0%

60.3%

56.3% - 63.7%

59.7% - 60.9%

SNAP households with at least one member with earned 

income as a percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

65.9%

29.0%

62.2% - 69.5%

28.4% - 29.5%

SNAP households with at least one member receiving 

Unemployment Insurance benefits as a percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

18.6%

6.4%

15.6% - 21.6%

6.1% - 6.7%

Average amount of Unemployment Insurance benefits 

received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$223

$55

$185 - $262

$52 - $58

Source: GAO analysis of USDA’s SNAP quality control data.
Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals 

Page 48 GAO-12-670 Supplemental Nutrition Assistance Program

Table 6: Benefits Provided to SNAP Households That Would Not Have Been Eligible 

for the Program without BBCE because Their Incomes were over Federal Limits, per 

Month in Fiscal Year 2010

Estimate 

95 percent 

confidence 

interval 

SNAP benefits provided to households 

deemed eligible under BBCE with incomes 

over federal limits as a percentage of all 

SNAP benefits 

0.7% 0.6% - 0.8%

SNAP benefits provided to households 

deemed eligible under BBCE with incomes 

over federal limits

$38,333,145 33,972,894 – 

42,693,395

Total amount of benefits provided to all SNAP 

households

$5,273,937,192 5,227,633,694 – 

5,320,240,691

SNAP benefits provided to households 

deemed eligible under BBCE with incomes 

over federal limits as a percentage of all 

SNAP benefits in states with BBCE policies 

that increased the gross income limit

1.5% 1.3% - 1.6%

SNAP benefits provided to households 

deemed eligible under BBCE with incomes 

over federal limits in states with BBCE 

policies that increased the gross income limit

$33,987,767 $30,127,143 - 

$37,848,392

Total amount of benefits provided to all SNAP 

households in states with BBCE policies that 

increased the gross income limit

$2,308,594,258 $2,277,254,048 - 

$2,339,934,469

Source: GAO analysis of USDA’s SNAP quality control data.

Table 7: Benefits Received by Specified Groups of SNAP Households, in Fiscal 

Year 2010

Estimate 

95 Percent 

Confidence 

Interval 

Average monthly SNAP benefit received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$81

$293

$74 - $88

$290 - 295

SNAP households receiving the minimum benefit as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

44.3%

2.7%

40.3% - 48.1%

2.5% - 2.9%

Source: GAO analysis of USDA’s SNAP quality control data.
Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals 

Page 49 GAO-12-670 Supplemental Nutrition Assistance Program

Table 8: Estimated Percent of Specified Groups of SNAP Households Receiving 

Deductions and the Estimated Average Amount of the Deduction in Fiscal Year 

2010

Estimate 

95 Percent 

Confidence 

Interval 

SNAP households receiving child support deduction as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

6.7%

1.9%

4.6% - 8.9%

1.7% - 2.0%

Average amount of child support deduction received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$20

$4

$13 - $27

$4 - $5

SNAP households receiving dependent care deduction as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

14.3%

3.5%

11.6% - 17.0%

3.3% - 3.7%

Average amount of dependent care deduction received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$50

$8

$37 - $62

$7 - $8

SNAP households receiving earned income deduction as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

65.9%

28.9%

62.2% - 69.5%

28.4% - 29.5%

Average amount of earned income deduction received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$243

$57

$227 - $260

$56 - $59

SNAP households receiving medical deduction as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

13.0%

3.5%

10.3% - 15.8%

3.3% - 3.8%

Average amount of medical deduction received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$19

$5

$14 - $25

$5 - $6
Appendix II: Quality Control Data Estimates 

and 95 Percent Confidence Intervals 

Page 50 GAO-12-670 Supplemental Nutrition Assistance Program

Estimate 

95 Percent 

Confidence 

Interval 

SNAP households receiving excess shelter deduction as a 

percentage of:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

72.2%

70.5%

68.7% - 75.6%

70.0% - 71.1%

Average amount of excess shelter deduction received by:

• SNAP households deemed eligible under BBCE with 

incomes over federal limits

• all other SNAP households

$220

$265

$205 - $235

$263 - $268

Source: GAO analysis of USDA’s SNAP quality control data.
Appendix III: GAO Contacts and Staff 

Acknowledgments

Page 51 GAO-12-670 Supplemental Nutrition Assistance Program

Kay E. Brown, (202) 512-7215 or brownke@gao.gov

Kathy Larin (Assistant Director), Rachel Frisk (Analyst-in-Charge), Avani 

Locke, and David Perkins made significant contributions to all aspects of 

this report. Also contributing to this report were Carl Barden, Marquita 

Campbell, Susannah Compton, Heather Dunahoo, Greg Kutz, Jean 

McSween, Mimi Nguyen, Susan Offutt, Rhiannon Patterson, Kathy 

Peyman, Almeta Spencer, Craig Winslow, and Jill Yost.

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 52 GAO-12-670 Supplemental Nutrition Assistance Program

State and Local Governments: Knowledge of Past Recessions Can 

Inform Future Federal Fiscal Assistance. GAO-11-401. Washington, D.C.: 

March 31, 2011.

Temporary Assistance for Needy Families: Implications of Caseload and 

Program Changes for Families and Program Monitoring. GAO-10-815T. 

Washington, D.C.: September 21, 2010.

Supplemental Nutrition Assistance Program: Payment Errors and 

Trafficking Have Declined, but Challenges Remain. GAO-10-956T. 

Washington, D.C.: July 28, 2010.

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.: April 15, 

2010.

Food Stamp Program: FNS Could Improve Guidance and Monitoring to 

Help Ensure Appropriate Use of Noncash Categorical Eligibility. 

GAO-07-465. Washington, D.C.: March 28, 2007.

Human Service Programs: Demonstration Projects Could Identify Ways to 

Simplify Policies and Facilitate Technology Enhancements to Reduce 

Administrative Costs. GAO-06-942. Washington, D.C.: September 19, 

2006.

Food Stamp Program: States Have Made Progress Reducing Payment 

Errors, and Further Challenges Remain. GAO-05-245. Washington, D.C.: 

May 5, 2005.

Food Stamp Program: Farm Bill Options Ease Administrative Burden, but 

Opportunities Exist to Streamline Participant Reporting Rules among 

Programs. GAO-04-916. Washington, D.C.: September 16, 2004.

Food Stamp Program: Steps Have Been Taken to Increase Participation 

of Working Families, but Better Tracking of Efforts Is Needed. 

GAO-04-346. Washington, D.C.: March 5, 2004.

Food Stamp Program: States’ Use of Options and Waivers to Improve 

Program Administration and Promote Access. GAO-02-409. Washington, 

D.C.: February 22, 2002.

Related GAO Products
Related GAO Products

Page 53 GAO-12-670 Supplemental Nutrition Assistance Program

Means-Tested Programs: Determining Financial Eligibility Is 

Cumbersome and Can Be Simplified. GAO-02-58. Washington, D.C.: 

November 2, 2001.

Food Stamp Program: States Seek to Reduce Payment Errors and 

Program Complexity. GAO-01-272. Washington, D.C.: January 19, 2001.

(131118)
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