SUPPLEMENTAL

NUTRITION ASSISTANCE

PROGRAM

Observations on

Employment and Training 

Programs and Efforts to 

Address Program Integrity 

Issues

Statement of Kathryn Larin, Director,

Education, Workforce, and Income Security Issues 

Testimony Before the Subcommittees on 

Healthcare, Benefits and Administrative 

Rules and Intergovernmental Affairs, 

Committee on Oversight and Government 

Reform, House of Representatives

For Release on Delivery 

Expected at 10 a.m. ET

Wednesday, May 9, 2018

GAO-18-504T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-504T, a testimony 

before the Subcommittees on Healthcare, 

Benefits, and Administrative Rules and 

Intergovernmental Affairs, Committee on 

Oversight and Government Reform, House of 

Representatives

May 2018

SUPPLEMENTAL NUTRITION ASSISTANCE 

PROGRAM

Observations on Employment and Training Programs 

and Efforts to Address Program Integrity Issues

What GAO Found

Overseen by the U.S. Department of Agriculture (USDA) and administered by 

states, Supplemental Nutrition Assistance Program (SNAP) Employment and 

Training (E&T) programs served about 0.5 percent of the approximately 43.5 

million SNAP recipients in an average month of fiscal year 2016, according to the 

most recent USDA data available. These programs are generally designed to 

help SNAP recipients increase their ability to obtain regular employment through 

services such as job search and training. Some recipients may be required to 

participate. According to USDA, about 14 percent of SNAP recipients were 

subject to work requirements in an average month of fiscal year 2016, while 

others, such as children and the elderly, were generally exempt from these 

requirements. States have flexibility in how they design their E&T programs. 

Over the last several years, states have 1) increasingly moved away from 

programs that mandate participation, 2) focused on serving able-bodied adults 

without dependents whose benefits are generally time-limited unless they comply 

with work requirements, and 3) partnered with state and local organizations to 

deliver services. USDA has taken steps to increase support and oversight of 

SNAP E&T since 2014, including collecting new data on participant outcomes 

from states. GAO has ongoing work reviewing SNAP E&T programs, including 

USDA oversight. 

USDA and the states partner to address issues that affect program integrity, 

including improper payments and fraud, and USDA has taken some steps to 

address challenges in these areas, but issues remain.

• Improper Payments. In 2016, GAO reviewed SNAP improper payment rates 

and found that states’ adoption of program flexibilities and changes in federal 

SNAP policy in the previous decade, as well as improper payment rate 

calculation methods, likely affected these rates. Although USDA reported 

improper payment estimates for SNAP in previous years, USDA did not 

report an estimate for benefits paid in fiscal years 2015 or 2016 due to data 

quality issues in some states. USDA has since been working with the states 

to improve improper payment estimates for the fiscal year 2017 review.

• Recipient Fraud. In 2014, GAO made recommendations to USDA to 

address challenges states faced in combatting recipient fraud. For example, 

GAO found that USDA’s guidance on the use of transaction data to uncover 

potential trafficking lacked specificity and recommended USDA develop 

additional guidance. Since then, USDA has provided technical assistance to 

some states, including on the use of data analytics. GAO has ongoing work 

reviewing states’ use of data analytics to identify SNAP recipient fraud. 

• Retailer Trafficking. In 2006, GAO identified several ways in which SNAP 

was vulnerable to retailer trafficking—a practice involving the exchange of 

benefits for cash or non-food items. For example, USDA had not conducted 

analyses to identify high-risk retailers and target its resources. Since then, 

USDA has established risk levels for retailers based on various factors. GAO 

has ongoing work assessing how USDA prevents, detects, and responds to 

retailer trafficking and reviewing the usefulness of USDA’s estimates of the 

extent of SNAP retailer trafficking. 

View GAO-18-504Tor key components. For 

more information, contact Kathryn Larin at 

(202) 512-7215 or larink@gao.gov.

Why GAO Did This Study

SNAP is the largest federally funded 

nutrition assistance program. In fiscal 

year 2017, it provided about $63 billion 

in benefits. USDA and the states jointly 

administer SNAP and partner to 

address issues that affect program 

integrity, including improper payments 

and fraud. GAO has previously 

reported on various aspects of SNAP, 

including state SNAP E&T programs, 

improper payment rates, recipient 

fraud, and retailer trafficking.

This testimony discusses GAO’s prior

and ongoing work on (1) SNAP E&T 

programs, including program 

participants, design, and USDA

oversight, and (2) USDA’s efforts to 

address SNAP program integrity, 

including improper payments, as well 

as recipient and retailer fraud. As part 

of its ongoing work on SNAP E&T 

programs, GAO analyzed E&T 

expenditures and participation data 

from fiscal years 2007 through 2016,

the most recent data available; 

reviewed relevant research from 

USDA; and interviewed USDA and 

selected state and local officials. The 

prior work discussed in this testimony 

is based on four GAO products on E&T 

programs (GAO-03-388), improper 

payments (GAO-16-708T), recipient 

fraud (GAO-14-641), and retailer 

trafficking (GAO-07-53). Information on 

the scope and methodology of our prior 

work is available in each product. 

What GAO Recommends

GAO is not making new 

recommendations. USDA generally 

concurred with GAO’s prior 

recommendations.
Letter

Page 1 GAO-18-504T Supplemental Nutrition Assistance Program

Chairman Jordan, Chairman Palmer, Ranking Member Krishnamoorthi, 

Ranking Member Raskin, and Members of the Subcommittees:

Thank you for inviting me here today to discuss our work on the U.S. 

Department of Agriculture’s (USDA) Supplemental Nutrition Assistance 

Program (SNAP)—the largest federally-funded nutrition assistance 

program. Jointly administered by USDA’s Food and Nutrition Service 

(FNS) and the states, SNAP helps low-income households obtain a better 

diet by providing them with benefits to purchase food from authorized 

retailers. In fiscal year 2017, SNAP provided approximately $63 billion in 

benefits to about 42 million individuals in over 20 million households.

To receive SNAP benefits, individuals must apply in their state of 

residence and meet the program’s eligibility requirements, such as 

income limits. To be eligible for benefits, SNAP recipients must also 

generally comply with the program’s work requirements, such as 

registering for work and participating in certain work programs if required 

by the state agency.1 For example, SNAP recipients may be required by 

the state to participate in state-operated SNAP Employment and Training 

(E&T) programs. First federally required in the 1980s, SNAP E&T 

programs are intended to help individuals in SNAP households acquire 

skills, training, employment, or experience that will increase their ability to 

obtain regular employment.

The federal government pays the full cost of SNAP benefits and shares 

the costs and responsibility of administering the program and ensuring 

program integrity with the states. Most SNAP benefits are used for the 

intended purpose, according to FNS. However, improper payments—

payments to individuals that were made in an incorrect amount of should 

not have been made at all—may result from unintentional errors by SNAP 

recipients or staff administering the program or may result from intentional 

errors or misuse of benefits, practices which are considered fraud. For 

example, individuals may misrepresent their household’s circumstances 

to state agencies in order to obtain benefits. Further, some recipients sell 

their benefits for cash, often at a loss, to a retailer—a practice known as 

 1The general SNAP work requirements apply to people ages 16 through 59, except for 

those who are physically or mentally unfit, have responsibility for the care of a dependent 

child under age 6 or an incapacitated person, are already employed 30 hours or more per 

week or receive weekly earnings which equal the minimum hourly rate set under federal 

law multiplied by 30, or are a bona fide student enrolled half-time or more in any

recognized school training program, or institution of higher education, amongst other 

exceptions.

Letter
Page 2 GAO-18-504T Supplemental Nutrition Assistance Program

trafficking. FNS is responsible for authorizing and monitoring retailers 

from which recipients may purchase food, and states are responsible for 

determining applicant eligibility and investigating possible program 

violations by recipients. As we have reported in our prior work, both FNS 

and states face challenges in addressing recipient and retailer fraud.

In response to requests from the Chairman and other members of this 

Committee, we currently have work underway on SNAP E&T programs, 

as well as on SNAP recipient and retailer fraud. Today I will provide 

information from our ongoing and prior work, focusing on (1) SNAP E&T 

programs, including program participants, design, and FNS oversight, and 

(2) FNS’s efforts to address program integrity, including improper 

payments and SNAP recipient and retailer fraud.

To address the areas discussed in this testimony statement, we drew on 

our ongoing work on SNAP E&T programs, recipient fraud, retailer 

trafficking, as well as our prior work on improper payments. Specifically, 

for our discussion of SNAP E&T programs, we analyzed data on SNAP 

E&T expenditures and participation collected by FNS from the states for 

fiscal year 2007 through fiscal year 2016, the most recent data available. 

In addition, we analyzed published FNS Quality Control data on SNAP 

recipients and work registrants for fiscal year 2008 through fiscal year 

2016. To assess the reliability of the data included in this statement, we 

interviewed FNS and state officials knowledgeable about the data, and 

determined the data are sufficiently reliable for the purposes of this 

statement. We also reviewed relevant federal laws and regulations; 

reviewed guidance and research from FNS; interviewed FNS officials, as 

well as select state and local SNAP E&T staff from five states; and 

reviewed our prior work on SNAP E&T programs.2 For our discussion of 

FNS’s efforts to address improper payments and SNAP recipient and 

retailer fraud, we drew on our 2016 review of SNAP improper payment 

rates and reviewed relevant USDA reports.3 We also drew on our 2014 

 2In our ongoing work, we selected states based on several criteria, including varied SNAP 

E&T service delivery approaches and other program characteristics, as well as geographic 

dispersion. Our prior work on SNAP E&T is included in our 2003 report: GAO, Food 

Stamp Employment and Training Program: Better Data Needed to Understand Who Is 

Served and What the Program Achieves.GAO-03-388. (Washington, D.C.: March 12, 

2003).

3GAO, Supplemental Nutrition Assistance Program: Policy Changes and Calculation 

Methods Likely Affect Improper Payment Rates, and USDA Is Taking Steps to Help 

Address Recipient Fraud, GAO-16-708T (Washington, D.C.: July 6, 2016).
Page 3 GAO-18-504T Supplemental Nutrition Assistance Program

analysis of SNAP replacement card and transaction data, in which we 

conducted tests of FNS-recommended automated tools and interviewed 

program stakeholders, including federal and select state officials.4 We 

also obtained relevant documentation from FNS in April 2018 on steps 

the agency has taken to address our 2014 recommendations. We also 

drew on our 2006 work on retailer trafficking, in which we reviewed FNS 

reports on trafficking estimates; visited FNS field offices; analyzed FNS 

retailer data; and interviewed federal officials, among others.5 We also 

assessed FNS reports on trafficking estimates covering calendar years 

2006 through 2014 (the most recent data available), reviewed FNS 

policies and reports, and interviewed FNS officials.6 More complete 

information on the scope and methodology of our prior work is available in 

each published report. Our current work on SNAP E&T programs, 

recipient fraud, and retailer trafficking is still ongoing.

The work upon which this statement is based was conducted in 

accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

USDA’s Food and Nutrition Service (FNS) is responsible for promulgating 

SNAP program regulations, ensuring that state officials administer the 

program in compliance with program rules, and authorizing and 

monitoring retailers from which recipients may purchase food. States are 

responsible for determining applicant eligibility, calculating the amount of 

their benefits, issuing benefits on Electronic Benefit Transfer (EBT) 

cards—which can be used like debit cards to purchase food from 

 4GAO, Supplemental Nutrition Assistance Program: Enhanced Detection Tools and 

Reporting Could Improve Efforts to Combat Recipient Fraud, GAO-14-641. (Washington, 

D.C.: August 21, 2014).

5GAO, Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better Targeting 

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

2006). 

6FNS’s The Extent of Trafficking in the Supplemental Nutrition Assistance Program 

reports are published approximately two to three years after the time period covered in the 

report. For example, the most recent report—published in 2017—analyzes data from 2012 

to 2014.

Background
Page 4 GAO-18-504T Supplemental Nutrition Assistance Program

authorized retailers—and investigating possible program violations by 

recipients.

SNAP recipients are subject to various work requirements. Generally, all 

SNAP recipients ages 16 through 59, unless exempted by law or 

regulation, must comply with work requirements, including registering for 

work, reporting to an employer if referred by a state agency, accepting a 

bona fide offer of a suitable job, not voluntarily quitting a job or reducing 

work hours below 30 hours a week, and participating in a SNAP E&T 

program or a workfare program—in which recipients perform work on 

behalf of the state—if assigned by the state agency.7 SNAP recipients are 

generally exempt from complying with these work requirements if they are 

physically or mentally unfit, responsible for caring for a dependent child 

under age 6 or an incapacitated person, employed for 30 or more hours 

per week or receive weekly earnings which equal the minimum hourly 

rate set under federal law multiplied by 30, or are a bona fide student 

enrolled half-time or more in any recognized school training program, or 

institution of higher education, amongst other exemptions. SNAP 

recipients subject to the work requirements—known as work registrants—

may lose their eligibility for benefits if they fail to comply with these 

requirements without good cause.8

One segment of the work registrant population, SNAP recipients ages 18 

through 49 who are “able-bodied,” not responsible for a dependent child, 

and do not meet other exemptions—able-bodied adults without 

dependents (ABAWDs)—are generally subject to additional work 

requirements. In addition to meeting the general work requirements, 

ABAWDs must work or participate in a work program 20 hours or more 

per week, or participate in workfare, in which ABAWDs perform work to 

earn the value of their SNAP benefits. Participation in SNAP E&T, which 

is a type of work program, is one way for ABAWDs to meet the 20 hour 

per week ABAWD work requirement, but other work programs are 

acceptable as well. Unless ABAWDs meet these work requirements or 

 7Regarding work registration, SNAP recipients subject to work requirements are required 

to register for work or be registered by the state agency at the time of application and 

every 12 months after initial registration.

8Examples of good cause can include illness, household emergency, lack of 

transportation, and other circumstances. States must determine if a recipient has good 

cause for not complying with work requirements before disqualifying the recipient from 

benefits.

SNAP Work Requirements
Page 5 GAO-18-504T Supplemental Nutrition Assistance Program

are determined to be exempt, they are limited to 3 months of SNAP 

benefits in a 36-month period.9

At the request of states, FNS may waive the ABAWD time limit for 

ABAWDs located in certain areas of a state or an entire state under 

certain circumstances. A waiver may be granted if the area has an 

unemployment rate of over 10 percent or there are an insufficient number 

of jobs to provide employment for these individuals. If the time limit is 

waived, ABAWDs are not required to meet the ABAWD work requirement 

in order to receive SNAP for more than 3 months in a 36-month period yet 

they must still comply with the general work requirements.

Federal requirements for state SNAP E&T programs were first enacted in 

1985 and provide state SNAP agencies with flexibility in how they design 

their SNAP E&T programs, including who to serve and what services to 

offer. The state has the option to offer SNAP E&T services on a voluntary 

basis to some or all SNAP recipients, an approach commonly referred to 

as a voluntary program. Alternatively, the state can require some or all 

SNAP work registrants to participate in the SNAP E&T program as a 

condition of eligibility, an approach commonly referred to as a mandatory 

program. Further, states determine which service components to provide 

participants through their SNAP E&T programs, although they must 

provide at least one from a federally determined list. This list includes job 

search programs, job search training programs, workfare, programs 

designed to improve employability through work experience or training, 

education programs to improve basic skills and employability, job 

retention services, and programs to improve self-sufficiency through selfemployment. Total federal expenditures on SNAP E&T programs were

more than $337 million in fiscal year 2016. States are eligible to receive 

three types of federal funding available for state SNAP E&T programs: 

100 percent funds—formula grants for program administration,10 50 

 9According to FNS, reasons for ABAWD exemptions may include medically certified as 

physically or mentally unfit for employment, responsible for a child under 18, employed for 

30 or more hours per week, or pregnant. Further, state agencies have discretion to 

exempt, on a month-to-month basis, 15 percent of the ABAWDs who would otherwise be 

subject to the time limit. 

10Federal 100 percent funds are set at $90 million by statute. Federal 100 percent funds 

are allocated to states based on a formula, in which 90 percent of the state’s allocation is 

based on the number of work registrants in a state and 10 percent of the allocation is 

based on the number of ABAWDs in a state.

SNAP Employment and 

Training Programs
Page 6 GAO-18-504T Supplemental Nutrition Assistance Program

percent federal reimbursement funds, and ABAWD pledge funds—grants 

to states that pledge to serve all of their at-risk ABAWDs.11

The Office of Management and Budget has designated SNAP as a highpriority program due to the estimated dollar amount in improper 

payments—any payments that should not have been made or were made 

in an incorrect amount (including overpayments and underpayments) 

under statutory, contractual, administrative, or other legally applicable 

requirements. According to USDA’s fiscal year 2015 agency financial 

report, $2.6 billion, or 3.66 percent, of all SNAP benefits paid in fiscal year 

2014 were improper, the most recent year for which data are available. 

SNAP improper payments are caused by variances in any of the key 

factors involved in determining SNAP eligibility and benefit amounts, and, 

according to USDA, household income was the most common primary

cause of dollar errors.12 States review the accuracy of SNAP payments to 

recipients on an ongoing basis, and FNS assesses the accuracy of state 

reviews and determines a national improper payment rate annually.

FNS and states share responsibility for addressing SNAP fraud, which 

can occur through the eligibility process and when benefits are being 

used. Specifically, recipients may commit eligibility fraud when they 

misrepresent their household size, income, or expenses in order to 

fraudulently obtain SNAP benefits. Another type of fraud—trafficking—

occurs when recipients exchange benefits with authorized retailers or 

other individuals for cash or non-food items (e.g. rent or transportation). In 

 11ABAWD pledge funds are set at not more than $20 million by statute. States receiving 

ABAWD pledge funds from the federal government must make and comply with a 

commitment, or pledge, to use these funds to offer at-risk ABAWDs a position in an 

education, training or workforce component that fulfills the ABAWD work requirement. Atrisk ABAWDs are those in the last month of the three month time limit of SNAP eligibility 

and who meet other criteria. The ABAWD grants are allocated based on the number of 

ABAWDs in the states participating in the pledge. States may also use the other SNAP 

E&T funding streams to serve ABAWDs. 

12FNS developed its quality control process for SNAP in 1977 to track and measure errors 

in both eligibility and benefit determinations for the program. According to FNS officials, 

each month, a state’s SNAP quality control staff selects for review a representative 

sample of households thatreceived SNAP benefits. The statewide sample is designed to 

produce a valid statewide improper payment rate, which is the sum of the overpayments 

and underpayments divided by the value of all payments. A variance occurs when a 

quality control reviewer finds the incorrect application of policy, the basis of issuance is 

incorrect, or there is a difference between the information that was used and the 

information that should have been used to determine a household’s monthly SNAP benefit 

amount.

SNAP Program Integrity
Page 7 GAO-18-504T Supplemental Nutrition Assistance Program

a typical retailer trafficking situation, for example, a retailer may charge 

$100 to a recipient’s EBT card and give the recipient $50 in cash instead 

of $100 in food. The federal government reimburses the retailer $100, 

which results in a fraudulent $50 profit to the retailer.

State agencies are directly responsible for preventing, detecting, 

investigating, and prosecuting recipient fraud, including eligibility fraud 

and trafficking by SNAP recipients, under the oversight and guidance of 

FNS. States play a key role in preventing fraud when determining 

eligibility for SNAP. State agencies collect applicant information, such as 

household income and employment, and verify it through data matches 

with other information sources. After benefits are issued, the agencies 

may monitor EBT transaction data to identify spending patterns that may 

indicate trafficking. If an individual or household intentionally violates 

SNAP rules, such as by trafficking or making false or misleading 

statements in order to obtain benefits, states conduct administrative 

disqualification hearings or, in some cases, refer the case for criminal 

prosecution.

FNS is responsible for authorizing and overseeing retailers who 

participate in the program—totaling more than 263,000 in fiscal year 

2017—including investigating potential retailer trafficking. In order to 

participate in SNAP, a retailer applies to FNS and demonstrates that they 

meet program requirements, such as those on the amount and types of 

food that authorized stores must carry. FNS verifies a retailer’s 

compliance with these requirements and generally authorizes retailers for 

5 years. FNS then monitors retailers’ continued compliance with program 

requirements and administratively disqualifies, or assesses money 

penalties on, those who are found to have trafficked benefits. To this end, 

FNS officials collect and monitor EBT transaction data to detect irregular 

patterns of transactions that may indicate trafficking and also conduct 

undercover investigations. If found to be trafficking, retailers are generally 

permanently disqualified from SNAP or incur a monetary penalty in lieu of 

permanent disqualification.13

 13The retailer may appeal FNS’s decision, first within FNS and later to the appropriate 

federal district court. The USDA Office of Inspector General, U.S. Secret Service, and the 

Federal Bureau of Investigation also conduct investigations of SNAP retailers, which may 

lead to criminal prosecutions. 
Page 8 GAO-18-504T Supplemental Nutrition Assistance Program

According to FNS data, about 14 percent of SNAP recipients, or about 6.1 

million, were work registrants who were subject to work requirements,14

and about 0.5 percent of SNAP recipients, or about 200,000, participated 

in state SNAP E&T programs, in an average month of fiscal year 2016.15

(See fig. 1.) According to FNS, most SNAP recipients are exempt from 

work requirements. For example, according to FNS, almost two-thirds of 

SNAP recipients were children, elderly, or adults with a disability in an 

average month of fiscal year 2016—groups that are generally exempt. 

Further, adults who are already working at least 30 hours a week are also 

exempt from SNAP work requirements, and according to FNS data, more 

than 31 percent of non-elderly adult SNAP recipients were employed in 

an average month of fiscal year 2016.16 SNAP work registrants who are 

not participating in SNAP E&T programs may be participating in other 

 14Estimates for SNAP recipients overall and work registrants are FNS estimates derived

from a monthly sample of SNAP households. We have not yet assessed the statistical 

precision of these estimates or whether changes over time and among subgroups of 

recipients are statistically significant. We plan to further assess these estimates as part of 

our ongoing work.

15The average monthly SNAP recipients and work registrants in the fiscal year 2016 

SNAP Quality Control data are derived from an independent monthly sample of 

participating SNAP households selected from October 2015 through September 2016. To 

calculate the average monthly number of SNAP recipients participating in SNAP E&T 

programs, we calculated the total number of recipients participating in SNAP E&T 

components across all months in fiscal year 2016 and divided by 12. 

16This includes employed adults with a disability.

A Small Percentage 

of SNAP Recipients 

Participate in SNAP 

E&T Programs, 

Which Have 

Experienced 

Changes in 

Characteristics and 

FNS Oversight

A Small Percentage of 

SNAP Recipients

Participate in SNAP E&T
Page 9 GAO-18-504T Supplemental Nutrition Assistance Program

activities to meet work requirements or eligible for other exemptions.17

FNS officials told us that the state data reported to FNS on SNAP E&T 

participants are the best and most recent data available on this group, yet 

they also have limitations, which we will continue to explore in our 

ongoing work.18

Figure 1: Average Monthly State SNAP Employment and Training (E&T) Program 

Participants as a Percentage of Average Monthly SNAP Recipients, Fiscal Year 2016

Note: Data include the 50 states, District of Columbia, Guam, and the Virgin Islands. According to 

FNS officials, available data on SNAP E&T participants have certain limitations, given that the data

are state-reported and not subject to multiple verification processes. According to FNS officials, some 

SNAP recipients w ho are exempt from w ork registration requirements may participate in SNAP E&T 

programs, yet there are no data available w hich would allow us to calculate how many such recipients 

do so. Estimates for SNAP recipients overall and w ork registrants are FNS estimates derived from a 

monthly sample of SNAP households. We have not yet assessed the statistical precision of these 

estimates or w hether changes over time and among subgroups of recipients are statistically 

significant. We plan to further assess these estimates as part of our ongoing w ork.

 17There are other federal exemptions from SNAP work requirements, such as having 

responsibility for caring for a dependent child under six or an incapacitated person, or 

complying with work requirements for certain other programs, such as Temporary 

Assistance for Needy Families.

18According to FNS, state data on SNAP E&T participants have various limitations, in part 

because the data are state-reported and not subject to multiple verification processes. 

FNS officials noted that some of the common reporting errors made by states result in 

inconsistencies between quarterly and annual reports, incorrect reporting of ABAWDs, 

duplicate counts of SNAP E&T participants, and undercounts or duplicate counts of work 

registrants, among others. We are continuing to examine these data limitations as part of 

our ongoing work.
Page 10 GAO-18-504T Supplemental Nutrition Assistance Program

In recent years, the number and percentage of SNAP recipients and work 

registrants participating in SNAP E&T programs appears to have 

decreased, according to FNS data. From fiscal year 2008 through fiscal 

year 2016, the average monthly number of SNAP E&T participants 

decreased from about 256,000 to about 207,000, or by 19 percent, 

according to state data on SNAP E&T participants reported to FNS. (See 

fig. 2.) However, over the same time period, the average monthly number 

of SNAP recipients appears to have increased from about 27.8 million to 

about 43.5 million, and work registrants appears to have increased from 

about 3 million to about 6.1 million, according to FNS data. As a result, 

the percentage of total SNAP recipients participating in SNAP E&T 

programs decreased from about 0.9 to about 0.5 percent, and the 

percentage of SNAP work registrants participating in these programs 

decreased from approximately 8.1 percent to 3.4 percent, from fiscal year 

2008 through fiscal year 2016.19

 19According to FNS officials, some SNAP recipients who are exempt from work 

registration requirements may participate in SNAP E&T programs, yet there are no data 

available which would allow us to calculate how many such recipients do so. As a result, 

these percentages may overstate the percentage of work registrants participating in SNAP 

E&T programs.
Page 11 GAO-18-504T Supplemental Nutrition Assistance Program

Figure 2: Average Monthly Federal SNAP Employment and Training (E&T) 

Participants Compared with Average Monthly Work Registrants and SNAP 

Recipients, Fiscal Years 2008 to 2016

Note: Data include the 50 states, District of Columbia, Guam, and the Virgin Islands. According to 

FNS officials, available data on SNAP E&T participants have certain limitations, given that the data 

are state-reported and not subject to multiple verification processes. According to FNS officials, some 

SNAP recipients w ho are exempt from w ork registration requirements may participate in SNAP E&T 

programs, yet there are no data available w hich would allow us to calculate how many such recipients 

do so. As a result, these percentages may overstate the percentage of w ork registrants participating 

in SNAP E&T programs. Estimates for SNAP recipients overall and w ork registrants are FNS 

estimates derived from a monthly sample of SNAP households. We have not yet assessed the 

statistical precision of these estimates or w hether changes over time and among subgroups of 

recipients are statistically significant. We plan to further assess these estimates as part of our

ongoing w ork.

Available information suggests the characteristics of SNAP E&T 

participants are generally similar to those of SNAP work registrants who 

do not participate in these programs. A recent FNS study, which surveyed 

SNAP E&T participants and SNAP work registrants who had not 

participated in SNAP E&T, found that members of the two groups had 

similar demographic characteristics, including age and gender, and 

received similar monthly SNAP benefit amounts.20 Further, at the time 

 20Rowe, Gretchen, Elizabeth Brown, and Brian Estes. SNAP Employment and Training 

(E&T) Characteristics Study: Final Report. Prepared by Mathematica Policy Research for 

the U.S. Department of Agriculture, Food and Nutrition Service, Oct. 2017.
Page 12 GAO-18-504T Supplemental Nutrition Assistance Program

they were surveyed, about one third of each group were employed, and 

their average wage rates were similar, at about $10 per hour.21

State SNAP agencies have broad flexibility in how they design their 

SNAP E&T programs, and the characteristics of these programs have 

changed in several ways over the last decade. For example, states have 

increasingly moved from mandatory to voluntary programs, focused on 

serving ABAWDs, and partnered with state and local organizations to 

deliver services.

According to FNS data, states have increasingly moved from mandatory 

to voluntary SNAP E&T programs in recent years.22 In fiscal year 2010, 

17 states operated voluntary programs; however, by fiscal year 2017, 35 

states operated voluntary programs, according to FNS data. (See fig. 3.) 

FNS officials told us that they have been actively encouraging states to 

provide more robust employment and training services, such as 

vocational training or work experience, through voluntary programs. They 

said that they believe these types of robust services are more effective in 

moving participants toward self-sufficiency, but that funding may not be 

sufficient to provide these to the large numbers of participants served in 

mandatory programs. In addition, FNS officials told us that voluntary 

programs are less administratively burdensome than mandatory 

programs, as they allow states to focus on serving motivated participants 

rather than sanctioning non-compliant individuals.

 21The survey was conducted several months after respondents were identified as work 

registrants or SNAP E&T participants. Their circumstances could have changed during 

this period, including completing an SNAP E&T program and finding full-time employment. 

Although working more than 30 hours a week is an exemption from SNAP work 

requirements, study authors state that a number of the respondents might have been 

designated as work registrants many months prior to the survey. In addition, SNAP E&T 

participants included those who had participated in the program within the previous 24 

months and might have become employed after completion of the SNAP E&T program.

22FNS categorizes state SNAP E&T programs as either mandatory or voluntary. Some 

states operate mandatory SNAP E&T programs in certain localities rather than statewide. 

These states are denoted as having mandatory programs.

State SNAP E&T 

Programs Have Changed 

in Several Ways

States Have Increasingly 

Moved from Mandatory to 

Voluntary Programs
Page 13 GAO-18-504T Supplemental Nutrition Assistance Program

Figure 3: SNAP Employment and Training (E&T) Program Type, Fiscal Years 2010 and 2017

Note: Some states operate mandatory SNAP E&T programs in certain localities rather than statew ide. 

These states are denoted as having mandatory programs in the figure. Guam and the Virgin Islands 

are not included in the figure. In fiscal year 2010, Guam operated a voluntary program. In fiscal year 

2017, Guam, the District of Columbia, and the Virgin Islands operated voluntary programs.

According to FNS officials, when states move to a voluntary program, 

they generally experience a decline in SNAP E&T participation—a trend 

consistent with our analysis of FNS data—which may have contributed to 

the decline in overall SNAP E&T participation. Of the 22 states or 

territories that changed from a mandatory to a voluntary program from 

fiscal year 2010 through fiscal year 2016, according to FNS data, 13 

experienced a decrease in SNAP E&T participation—ranging from a 21 

percent decrease to a 93 percent decrease.23 Overall, voluntary programs 

are generally smaller than mandatory programs, according to our analysis 

 23Over the same period, 9 of the 13 states or territories that changed from a mandatory to 

a voluntary program and experienced a decrease in SNAP E&T participation experienced 

an increase in their total number of SNAP work registrants. In the 9 additional states or 

territories that changed from a mandatory to a voluntary programs and experienced an 

increase in SNAP E&T participation, this increase ranged from 3 percent to 954 percent. 

In the latter case, participation in one state increased from 13 participants in fiscal year 

2010 to 137 in fiscal year 2011.
Page 14 GAO-18-504T Supplemental Nutrition Assistance Program

of FNS data.24 In fiscal year 2016, for example, the 32 states or territories 

operating voluntary programs together served less than half of the total 

number of SNAP E&T participants served by the 21 states or territories 

operating mandatory programs, although these two groups of states had 

similar numbers of new work registrants.25 Furthermore, states operating 

voluntary programs served an average of nearly 7,000 SNAP E&T 

participants per state, while states operating mandatory programs served 

an average of 23,000 SNAP E&T participants per state.

Evidence suggests that states have increased their focus on serving 

ABAWDs—a sub-population of SNAP recipients subject to benefit time 

limits and additional work requirements—through SNAP E&T, as related 

waivers have expired in recent years, according to FNS data. During and 

after the 2007-2009 recession, the majority of states operated under 

statewide waivers of the ABAWD time limit due to economic conditions. 

However, as the economy recovered, most statewide waivers expired, 

and the ABAWD time limit was reinstated. For example, according to FNS 

data, in fiscal year 2011, 45 states or territories had a statewide waiver 

and 7 states had a partial waiver—one applying to certain localities. By 

fiscal year 2017, the number of states or territories with a statewide 

waiver had decreased to 9, while 27 states had partial waivers.26 FNS 

officials and state SNAP agency officials we spoke with in some states 

 24Program size may be affected by multiple factors. Although SNAP recipients choose 

whether or not to participate in voluntary programs, in mandatory programs, some work

registrants may fail to participate while others may be exempted from participation. For 

example, state SNAP agencies may elect to exempt from participation in mandatory E&T 

programs categories and individuals for whom participation is judged impractical or not 

cost effective. According to agency guidance, exemptions may be based on categories of 

individuals, such as those who live in certain areas; characteristics of individuals, such as 

those with low literacy; or significant access barriers, such as a lack of transportation, 

dependent care, or computer access.

25In fiscal year 2016, the 32 states operating voluntary programs had a combined 2.9 

million new work registrants and the 21 states operating mandatory programs had a 

combined 3.2 million new work registrants.

26The 9 states or territories with statewide waivers in fiscal year 2017 were Alaska, 

California, District of Columbia, Guam, Illinois, Louisiana, Nevada, New Mexico, and the 

Virgin Islands. 

Focus on ABAWDs Has 

Increased as Waivers Have 

Expired
Page 15 GAO-18-504T Supplemental Nutrition Assistance Program

told us that, as the waivers have ended, state SNAP E&T programs have 

become increasingly focused on serving ABAWDs.27

Although state data on SNAP E&T programs reported to FNS suggest a 

greater percentage of ABAWDs have been participating in these 

programs in recent years, according to FNS officials, these data have 

limited usefulness in assessing state trends in serving ABAWDs for 

several reasons. For example, in recent years, FNS officials learned that 

there was widespread confusion among states regarding the need to 

track ABAWDs when waivers were in place, and that as a result, some 

states had not been tracking ABAWDs or properly documenting SNAP 

recipients’ ABAWD status.28 This is consistent with what some of the 

selected states we spoke with reported. As part of our ongoing work, we 

are continuing to explore the availability and reliability of data on 

ABAWDs.

State SNAP agencies have increasingly partnered with other state and 

local organizations, such as workforce agencies, community-based social 

service providers, and community colleges, to provide services to SNAP 

E&T participants in recent years, according to FNS and states we 

selected for our review. In fiscal year 2018, nearly all states partnered 

with at least one other organization to deliver SNAP E&T services, with 

the majority partnering with more than one, according to an analysis by 

FNS.29

In recent years, FNS has urged states to make use of the broad network 

of American Job Centers. The American Job Centers, also known as one-

 27According to FNS data, as waivers have expired in recent years, some states have also 

made use of additional exemptions to extend SNAP eligibility beyond 3 months for 

ABAWDs subject to the time limit for up to 15 percent of a state’s ABAWDs subject to the 

time limits. Specifically, in fiscal year 2016, 33 states and territories made use of the 15 

percent exemptions.

28FNS officials told us that states should have continued to track ABAWDs even if the 

state was under a statewide ABAWD waiver. Furthermore, in a memorandum to regional 

directors, FNS noted the importance of accurately tracking ABAWDs following the 

expiration of the waivers and reinstatement of the time limit, writing that states that failed 

to do so risked potential overpayments and Quality Control errors. Specifically, an 

ABAWD who fails to comply with the SNAP work requirement within the time period is no 

longer eligible for SNAP; if the non-compliant ABAWD is not properly identified, this could 

lead to an overpayment.

29Kansas, New Hampshire, and New Mexico administer SNAP E&T programs that are 

solely operated by their state SNAP agencies.

States Increasingly Developed 

Partnerships to Deliver SNAP 

E&T Services
Page 16 GAO-18-504T Supplemental Nutrition Assistance Program

stop centers, are funded through the Department of Labor’s Employment 

and Training Administration and designed to provide a range of 

employment-related services, such as training referrals, career 

counseling, job listings, and similar employment-related services, to job 

seekers under one roof.30 Our prior work has highlighted the value of 

coordination between federally funded employment and training programs 

to ensure the efficient and effective use of resources.31 Despite 

encouraging such partnerships, FNS officials said that American Job 

Centers typically provide lighter touch services to SNAP E&T participants, 

such as job search and job search training, and they therefore may not be 

well suited for SNAP E&T participants who have multiple barriers to 

employment. In our 2003 work on SNAP E&T, we found that while 

workforce system programs offered some of the activities needed by 

SNAP E&T participants, officials from 12 of the 15 states we contacted 

said that most participants were not ready for these activities, in part, 

because they lacked basic skills, such as reading and computer literacy, 

that would allow them to successfully participate.32

An alternative service delivery strategy that FNS has promoted is the 

development of third party partnerships with community-based social 

service providers, community colleges, and other entities to help states 

enhance their SNAP E&T programs. According to FNS, in this model, 

third party organizations use non-federal funding to provide allowable 

SNAP E&T services and supports, which are then eligible for 50 percent 

 30The American Job Centers were established under the Workforce Investment Act of 

1998 and reauthorized in the Workforce Innovation and Opportunity Act. The Workforce 

Innovation and Opportunity Act aims, in part, to increase coordination among federal 

workforce development programs.

31GAO, Multiple Employment and Training Programs: Providing Information on Colocating 

Services and Consolidating Administrative Structures Could Promote Efficiencies, 

GAO-11-92 (Washington, D.C.: January 13, 2011).

32Officials from 5 of those states said that mental health problems often prevented SNAP 

E&T participants from participating in more intensive employment and training programs at 

one-stops. GAO-03-388. A 2017 FNS study that surveyed SNAP E&T participants about 

their barriers to obtaining or retaining employment found that while 20 percent of 

respondents reported no barriers, 28 percent reported one barrier, and 52 percent 

reported two or more barriers. The most frequently reported barriers were transportation 

issues, physical or mental health issues, lack of education, and having a criminal record. 

Rowe, Gretchen, Elizabeth Brown, and Brian Estes. SNAP Employment and Training 

(E&T) Characteristics Study: Final Report. Prepared by Mathematica Policy Research for 

the U.S. Department of Agriculture, Food and Nutrition Service, October 2017.
Page 17 GAO-18-504T Supplemental Nutrition Assistance Program

federal reimbursement funds through the state’s SNAP E&T program.33

According to FNS officials, third party partnerships enable states to 

leverage additional resources, grow their SNAP E&T programs, and 

reach more SNAP participants. In addition, FNS officials said that these 

partnerships allow states to improve their program outcomes by tapping 

into providers currently serving communities that include SNAP 

recipients. Federal 50 percent reimbursement funds expended increased 

from nearly $182 million to more than $223 million, or by 23 percent, from 

fiscal year 2007 to fiscal year 2016.34

FNS has taken steps to increase federal support of states’ SNAP E&T 

programs by increasing the number of federal staff responsible for SNAP 

E&T and providing additional technical assistance to states. Specifically, 

FNS officials said that in 2014, they created the Office of Employment 

and Training to provide support and oversight for the SNAP E&T program 

and expanded SNAP E&T staff in FNS headquarters from one to five 

fulltime employees. FNS has also taken steps to increase technical 

assistance to states. For example, they have developed tools, including 

the SNAP E&T Operations Handbook, intended to help states implement 

and grow their program, and by adding a dedicated SNAP E&T official in 

each of FNS’s seven regional offices. According to FNS, regional officials 

have targeted technical assistance to states on, for example, developing 

third-party partnerships, and they have emphasized evidence-based 

approaches to administering the program, such as providing skills-based 

training for in-demand occupations.

FNS officials rely on various information sources to oversee states’ SNAP 

E&T programs, including participant outcome data reported by states for 

the first time in January 2018. For example, FNS officials conduct 

management evaluation reviews of states, annually review states’ SNAP 

E&T plans for compliance, and collect data from states on program 

 33These funding sources can include state training funds for specific populations, county 

and city funds, foundation or corporate funds, and social enterprise funds, according to 

FNS. 

34States receive 50 percent reimbursement funds from the federal government for (1) 

administrative costs beyond the amount funded through 100 percent funds (described 

below), and (2) payments made by the states to participants for expenses reasonably 

related to participation in the program, like transportation and dependent care. According 

to FNS, states are required to reimburse participants for expenses that are necessary for 

participation in SNAP E&T.

FNS Has Taken Steps to 

Increase Support and 

Oversight of SNAP E&T
Page 18 GAO-18-504T Supplemental Nutrition Assistance Program

participation and expenditures. In addition, as of January 2018, FNS has 

begun receiving new data on SNAP E&T program participants and 

outcomes from states.35 These data include employment outcomes, such 

as the number of SNAP E&T participants in unsubsidized employment 

after participation in the program, and participant characteristics, such as 

the number of participants entering the program with a high school 

degree or equivalent. FNS officials said that although states generally 

submitted the new data on time, states experienced challenges that likely 

affected the accuracy of the data. For example, some states needed to 

manually collect data on participant characteristics due to the limited 

capacity of their data systems. Further, according to FNS officials, some 

states did not correctly interpret certain reporting definitions or time 

periods. To address these challenges, FNS officials have been providing 

technical assistance to states to help them refine their participant and 

outcome data reports. Officials told us that they expect the states to 

submit revised reports by May 2018; we will examine these data and 

related issues in our ongoing work.

 35The Agriculture Act of 2014 required that USDA, in consultation with the Department of 

Labor, develop reporting measures and that USDA require states to report outcome data

to USDA on an annual basis. ThatAct also specified that the measures be based on 

common measures of performance for federal workforce training programs. Pub. L. No. 

113-79, § 4022(a)(2), 128 Stat. 649, 805. FNS issued an interim rule implementing the 

reporting measures in March 2016. 81 Fed. Reg. 15,613 (Mar. 24, 2016).
Page 19 GAO-18-504T Supplemental Nutrition Assistance Program

FNS and the states partner to address issues that affect program 

integrity, including improper payments and fraud, and FNS has taken 

some steps to address challenges in these areas, but concerns remain. 

For example, regarding SNAP recipient and retailer fraud, FNS has taken 

some steps to address challenges identified in our 2006 and 2014 reports 

related to fraud committed by SNAP recipients and authorized retailers, 

but more remains to be done. We currently have ongoing work to assess 

the steps FNS and states have taken to address our recommendations 

related to recipient and retailer fraud and other program vulnerabilities.

In 2016, we reviewed SNAP improper payment rates and found that 

states’ adoption of program flexibilities and changes in federal SNAP 

policy in the previous decade, as well as improper payment rate 

calculation methods, likely affected these rates.36 For example, when 

states adopted available SNAP policy flexibilities that simplified or 

lessened participant reporting requirements, these changes reduced the 

opportunity for error and led to a decline in the improper payment rate, 

according to a USDA study. In addition, we found that the methodology 

SNAP used to calculate its improper payment rate was generally similar 

to the methodologies used for other large federal programs for lowincome individuals, including Medicaid, Earned Income Tax Credit, and 

Supplemental Security Income. However, we also found that some of the 

procedural and methodological differences in the rate calculation among 

these programs likely affected the resulting improper payment rates, such 

as how cases with insufficient information or certain kinds of errors were 

factored into the improper payment rate.37

In 2014, USDA identified SNAP improper payment data quality issues in 

some states and has since been working with the states to improve 

improper payment estimates. Although USDA reported national SNAP 

improper payment estimates for benefits paid through fiscal year 2014, 

USDA did not report a national SNAP improper payment estimate for 

 36GAO-16-708T. 

37For example, SNAP excludes certain errors from its improper payment calculation. 

Specifically, SNAP excludes errors below a specific dollar threshold from its improper 

payment rate calculation, and FNS’s data on payment errors suggests that the threshold 

has a direct effect on the SNAP improper payment rate. According to federal officials, the 

other federal programs for low-income individuals we reviewed did not exclude errors 

below a specific dollar threshold.

FNS Has Taken Steps 

to Address SNAP 

Program Integrity 

Issues, but Concerns 

Remain

SNAP Improper Payments
Page 20 GAO-18-504T Supplemental Nutrition Assistance Program

benefits paid in fiscal years 2015 or 2016.38 In response to a report from 

USDA’s Office of Inspector General that identified concerns in the 

application of SNAP’s quality control process, which is used to identify 

improper payments, USDA began a review of state quality control 

systems in all states in 2014.39 According to USDA, due to the data 

quality issues uncovered in 42 of 53 states during the reviews, the 

improper payment rates for those states could not be validated, and the 

department was unable to calculate a national improper payment rate for 

benefits paid in fiscal year 2015.40 To address the data quality concerns, 

USDA updated guidance, provided training to relevant state and federal 

staff, and worked with states to update their procedures to ensure 

consistency with federal guidelines. According to USDA, the department 

also required individual states to develop corrective action plans to 

address issues identified and monitored progress to ensure states took 

identified actions. On June 30, 2017, USDA notified the states that the 

department would not release a national SNAP improper payment rate for 

benefits paid in fiscal year 2016 and remained focused on conducting the 

fiscal year 2017 review.

FNS has increased its oversight of state anti-fraud activities in recent 

years by developing new guidance and providing training and technical 

assistance to states on detecting fraud by SNAP recipients and reporting 

 38USDA reports its estimate of SNAP benefits improperly paid in a specific fiscal year in 

the following year’s agency financial report. As such,USDA did not report SNAP improper 

payment estimates in its fiscal year 2016 and 2017 agency financial reports.

39The OIG found that states weakened the quality control process by using third-party 

consultants and error review committees to mitigate individual quality control-identified 

errors, rather than improve eligibility determinations; and that quality control staff also 

treated error cases non-uniformly. The OIG concluded that FNS’ quality control process 

may have understated SNAP’s improper payment rate. USDA, Office of Inspector 

General, FNS Quality Control Process for SNAP Error Rate, September, 2015. 

40USDA reviewed the quality control systems in the 50 states, District of Columbia, Guam, 

and the Virgin Islands.USDA released state error rates for the 11 states whose quality 

control data could be validated.

SNAP Recipient Fraud
Page 21 GAO-18-504T Supplemental Nutrition Assistance Program

on anti-fraud activities to FNS.41 In 2014, we reported on 11 selected 

states’ efforts to combat SNAP recipient fraud and made several 

recommendations to FNS to address the challenges states faced. 42 We 

found that FNS and states faced challenges in the following areas:

• Guidance on use of data tools to detect fraud: States faced 

challenges using FNS-recommended data tools to detect fraud, and 

FNS is in the process of developing improved guidance to address 

this concern. Specifically, FNS’s guidance on the use of EBT 

transaction data to uncover potential patterns of benefit trafficking 

lacked the specificity states needed to uncover such activity, and we 

recommended FNS develop additional guidance. Since then, FNS 

contracted with a private consulting firm to provide 10 states with 

technical assistance in recipient fraud prevention and detection, which 

included exploring the use of data analytics to analyze and interpret 

eligibility and transaction data to identify patterns or trends and create 

models that incorporate predictive analytics. FNS officials also 

recently told us that the agency is developing a SNAP Fraud 

Framework to provide guidance to states on improving fraud 

prevention and detection. FNS officials anticipated releasing the 

framework in mid- 2018.

• Tools for monitoring e-commerce websites: We also found FNSrecommended tools for automatically monitoring potential SNAP 

trafficking on e-commerce websites to be of limited use and less 

effective than manual searches, and FNS has developed but not 

finalized guidance on using such tools. We recommended that FNS 

reassess the effectiveness of its current guidance and tools for states 

to monitor e-commerce and social media websites. In August 2017, 

 41Little is known about the extent of recipient fraud in the SNAP program nationwide 

beyond data from investigations. According to a September 2012 USDA OIG report, the 

magnitude of program abuse due to recipient fraud is unknown because states do not 

have uniform ways of compiling, tracking, and reporting their recipient fraud rates. The 

USDA OIG recommended that FNS determine the feasibility of creating a uniform 

methodology for states to calculate their recipient fraud rate. U.S. Department of 

Agriculture, Office of Inspector General, Analysis of FNS’ Supplemental Nutrition 

Assistance Program Fraud Prevention and Detection Efforts, Audit Report 27002-001-13, 

September 2012, p. 2, https://www.usda.gov/oig/webdocs/27002-0011-13.pdf. In 2014, 

FNS responded to the OIG that it had determined that it would be infeasible to implement 

as it would require legislative authority mandating significant state investment of time and 

resources in investigating, prosecuting and reporting fraud beyond current requirements.

42GAO, Supplemental Nutrition Assistance Program: Enhanced Detection Tools and 

Reporting Could Improve Efforts to Combat Recipient Fraud, GAO-14-641 (Washington, 

D.C.: August 21, 2014). 
Page 22 GAO-18-504T Supplemental Nutrition Assistance Program

FNS officials told us that they had developed revised guidance for 

states on using social media in detection of SNAP trafficking. 

According to FNS, the guidance will be incorporated into the SNAP 

Fraud Framework.

• Staff levels:During the time of our 2014 work, most of our 11 

selected states reported difficulties conducting fraud investigations 

due to reduced or stagnant staff levels while numbers of SNAP 

recipients had greatly increased, but FNS decided not to make 

changes to address this issue. Specifically, 8 of the 11 states we 

reviewed reported inadequate staffing due to attrition, turnover, or lack 

of funding. Some states suggested changing the financial incentive 

structure to promote fraud investigations because agencies were not 

rewarded for cost-effective, anti-fraud efforts that could prevent 

ineligible people from receiving benefits. Specifically, when fraud by a 

SNAP recipient is discovered, a state may generally retain 35 percent 

of any recovered overpayments. However, there are no recovered 

funds when a state detects potential fraud by an applicant and denies 

the application. To help address states’ concerns about resources 

needed to conduct investigations, we recommended in our 2014 

report that FNS explore ways that federal financial incentives could be 

used to better support cost-effective anti-fraud strategies. FNS 

reported that it took some steps to explore alternative financial 

incentives, through a review of responses to a Request for Information 

in the Federal Register.43 However, FNS decided not to pursue bonus 

awards for anti-fraud and program integrity activities. Given that FNS 

has not made changes in this area, state SNAP fraud agencies may 

continue to report resource concerns in addressing fraud.

• Reporting guidance: We also found that FNS did not have 

consistent and reliable data on states’ activities because of unclear 

reporting guidance, and FNS has since revised its data collection form 

and provided training on the changes. To improve FNS’s ability to 

monitor states and obtain information about more efficient and 

effective ways to combat recipient fraud, we recommended in 2014 

that FNS take steps, such as providing guidance and training, to 

enhance the consistency of what states report on their anti-fraud 

activities. In response, FNS revised the form used to collect recipient 

integrity information and changed the reporting frequency from annual 

 43According to FNS officials, FNS considered changes to its bonus structure, such as 

including a new category for high or most improved performance in recipient integrity. FNS 

also encouraged states to use funds from existing performance bonuses to improve 

program administration, particularly in the area of program integrity.
Page 23 GAO-18-504T Supplemental Nutrition Assistance Program

to quarterly, effective fiscal year 2017. FNS officials also reported 

providing training to approximately 400 state agency and FNS 

regional office personnel on the updates to the form and related 

instructions.

In our ongoing work, we are further reviewing states’ use of data analytics 

to identify SNAP recipient fraud, including that which may be occurring 

during out-of-state transactions. Because transactions that may appear 

suspicious—such as those made out-of-state—may in fact be legitimate, 

states may use data analytic techniques to include additional factors that 

may help them better target their efforts to identify potential fraud. 

However, states may have different levels of capacity for using data 

analytics to detect fraud. We are examining how 7 selected states are 

using data analytics and identifying the advantages and challenges states 

have experienced in doing so. We are also assessing FNS’s efforts to 

assist states in implementing GAO’s leading practices for data analytics 

outlined in GAO’s Framework for Managing Fraud Risks in Federal 

Programs outlined in GAO’s Framework for Managing Fraud Risks in 

Federal Programs.44 In addition, we are conducting our own analysis of 

EBT out-of-state SNAP transaction data. We expect to report on our 

findings later this year.

FNS has taken some steps to prevent, detect, and respond to retailers 

who traffic SNAP benefits since our last report on the issue in 2006,45 but 

trafficking continues to be a problem. For example, in February 2018, a 

federal jury convicted a grocery store operator in Baltimore on charges of 

wire fraud in connection with a scheme to traffic more than $1.6 million in 

SNAP benefits for food sales that never occurred.46 The grocery store

operator paid cash for SNAP benefits, typically paying the recipient half 

the value of the benefits and keeping the other half for himself. In our 

2006 report, we found that SNAP was vulnerable to retailer trafficking in 

several areas, including:

 44GAO, A Framework for Managing Fraud Risks in Federal Programs,GAO-15-593SP 

(Washington, D.C.: July 2015).

45GAO, Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better 

Targeting Stores Likely to Traffic and Increasing Penalties. GAO-07-53. (Washington, 

D.C.: Oct. 13, 2006). 

46Department of Justice, “Catonsville Man Convicted for Food Stamp Fraud.” (Baltimore, 

MD: Feb. 20, 2018). 

SNAP Retailer Trafficking
Page 24 GAO-18-504T Supplemental Nutrition Assistance Program

• Requirements for food that retailers must stock to participate in 

SNAP: In 2006, we found that FNS had minimal requirements for the 

amounts of food that retailers must stock, which could allow retailers 

more likely to traffic into the program, although the agency has since 

taken steps to increase these requirements. In our 2006 report, FNS 

officials said that they authorized stores with limited food stock to 

provide access to food in low-income areas where large grocery 

stores were scarce. At that time, retailers were generally required to 

stock a minimum of 12 food items (at least 3 varieties of 4 staple food 

categories, such as fruits and vegetables), but FNS rules did not 

specify how many items of each variety would constitute sufficient 

stock.47 FNS officials told us that a retailer that only carries small 

quantities of food, such as a few cans of one kind of vegetable, may 

intend to traffic. In 2016, FNS promulgated a final rule increasing food 

stock requirements.48 FNS officials told us that these new rules are 

designed to encourage stores to provide more healthy food options for 

recipients and discourage trafficking. According to FNS, retailers are 

now generally required to stock at least 36 food items (a certain 

variety and quantity of staple foods in each of the 4 staple food 

categories).49

• Focus on high-risk retailers:We also found in 2006 that FNS had 

not conducted analyses to identify characteristics of retailers at high 

risk of trafficking and to target its resources—a shortcoming FNS has 

since taken some steps to address. For example, we reported that 

some stores may be at risk of trafficking because one or more 

previous owners had been found trafficking at the same location. 

However, FNS did not have a system in place to ensure that these 

retailers were quickly targeted for heightened attention. In addition, 

once a store was authorized to participate in the program, FNS staff 

typically would not inspect the store again until it applied for 

 47Alternatively, retailers could meet a second criterion for authorization, which required the 

store to have more than 50 percent of its sales in a staple food group, such as meat, 

poultry, or fish. 

4881 Fed. Reg. 90,675 (Dec. 15, 2016).

49Retailers can still meet the second criterion that more than 50 percent of its sales are in 

a staple food group. Stores that do not meet either criterion may still be considered for 

authorization if they are located in an area where SNAP recipients have significantly 

limited access to food.
Page 25 GAO-18-504T Supplemental Nutrition Assistance Program

reauthorization 5 years later.50 We recommended that FNS identify 

the stores most likely to traffic and provide earlier, more targeted 

oversight to those stores. In 2009, FNS began establishing risk levels 

for each authorized retailer, identifying high-risk stores as those with a 

prior permanent disqualification at that location or a nearby location.51

In 2013, FNS required all high-risk retailers to go through 

reauthorization and to provide additional documentation regarding 

store ownership.52 That same year, FNS also consolidated its retailer 

management functions, including those for authorizing stores and 

analyzing EBT transaction data, into a single national structure known 

as the Retailer Operations Division. FNS officials told us that this 

structure enables the agency to identify and deploy their investigative 

resources to the areas of highest risk nationally, rather than within a 

given region.

• Penalties to deter retailer trafficking: We also found in our 2006 

report that FNS’s penalties for retailer trafficking may be insufficient to 

deter traffickers, and since then, FNS has proposed—but not 

finalized—rules to increase them. FNS imposes administrative 

penalties for retailer trafficking—generally a permanent 

disqualification from the program or a monetary penalty.53 FNS relies 

on the USDA Office of Inspector General (OIG) and other law 

enforcement entities to conduct investigations that can lead to criminal 

prosecutions.54 In our 2006 report, we recommended that FNS 

 50After a retailer applies for authorization, an FNS contractor conducts an on-site 

inspection at the store to verify information from the application and take pictures of the 

store and its inventory, including the condition of its food stock.

51Medium-risk stores, for example, include those with temporary disqualifications or other 

program violations, according to FNS. 

52As part of our ongoing work, we will review FNS’s current authorization and 

reauthorization processes for stores. 

53In lieu of program disqualification, FNS can assess a civil monetary penalty if a store 

demonstrates that it had an effective policy and program in effect to prevent violations of 

relevant law and regulations. In addition, FNS imposes a “transfer of ownership” penalty if 

the disqualified owner sells his or her store before the expiration of the disqualification 

period (and in the case of permanent disqualification, the penalty is double that for a ten 

year disqualification period).

54Specifically, the USDA OIG, U.S. Secret Service, and Federal Bureau of Investigation 

conduct investigations that can lead to criminal prosecutions. However, in 2006, we found 

that these entities were conducting fewer of these resource-intensive investigations, 

instead focusing on high-impact investigations. According to the USDA OIG, it opened 

fewer trafficking investigations because it had fewer investigators and decided to focus its 

resources on high-impact cases, such as those with large-scale trafficking or involving 

other criminal activity. 
Page 26 GAO-18-504T Supplemental Nutrition Assistance Program

develop a strategy to increase penalties for trafficking. The Food, 

Conservation, and Energy Act of 2008 (known as the 2008 Farm Bill) 

gave USDA authority to impose higher monetary penalties, and the 

authority to impose both a monetary penalty and program 

disqualification on retailers found to have violated relevant law or 

regulations (which includes those found to have trafficked).55 In 2012, 

FNS proposed regulatory changes to implement these authorities. 

However, FNS has not finalized these rules, and as of fall 2017, the 

rules were considered “inactive.”56

In our ongoing work, we are continuing to assess FNS’s efforts to 

prevent, detect, and respond to retailer trafficking, as well as examining 

what is known about the extent of retailer trafficking nationwide. As part of 

this work, we are continuing to review FNS’s response to our prior 

recommendations, as well as related recommendations made by USDA’s 

OIG.57 We are also studying FNS’s periodic estimates of the rate of 

retailer trafficking, expressed as the dollar value and percentage of all 

SNAP benefits that were trafficked and the percentage of retailers 

involved. These data suggest an increase in the estimated rate of retailer 

trafficking since our 2006 report. However, we and others, including a 

group of experts convened by FNS, have identified some limitations with 

the retailer trafficking estimates.58 For example, the trafficking rate is 

calculated based on a sample of retailers that FNS considers most likely 

to traffic. Although FNS adjusts the data to better represent the broader 

population of authorized retailers, it is uncertain whether the resulting 

estimates accurately reflect the extent of trafficking nationwide. We are 

 55Specifically, the 2008 Farm Bill gave FNS the authority to increase penalties to up to 

$100,000 for each violation. Pub. L. No. 110-246, § 4132, 122 Stat. 1651, 1875.

56The Office of Information and Regulatory Affairs publishes the “Inactive List” of 

regulatory actions under agency review but not included on the “Unified Agenda” of rules 

planned to be implemented in the near or future term. Agencies designate actions as 

“inactive” when they choose to take additional time to review a regulatory or deregulatory 

action but wish to preserve the regulatory identification number and title for possible future 

use. 

57See, for example, USDA Office of Inspector General, FNS: Controls for Authorizing 

Supplemental Nutrition Assistance Program Retailers. Audit Report 27601-0001-31 

(Washington, D.C.: July 2013). 

58See USDA Office of Inspector General, Analysis of FNS’ Supplemental Nutrition 

Assistance Program Fraud Prevention and Detection Efforts. Audit Report 27002-0011-13 

(Washington, D.C.: September 2012). In addition, in 2013, FNS convened a technical 

working group of outside experts to assess its trafficking estimates methodology and 

propose alternatives. 
Page 27 GAO-18-504T Supplemental Nutrition Assistance Program

reviewing these limitations and FNS’s efforts to address them in our 

ongoing work.

Chairman Jordan, Chairman Palmer, Ranking Member Krishnamoorthi, 

Ranking Member Raskin, and Members of the Subcommittees, this 

completes my prepared statement. I would be pleased to respond to any 

questions that you may have at this time.

If you or your staff have any questions about this testimony, please 

contact Kathryn Larin, Director, Education, Workforce, and Income 

Security Issues at (202) 512-7215 or LarinK@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

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

to this testimony include Rachael Chamberlin, Celina Davidson, Swati 

Deo, Rachel Frisk, Alexander Galuten, Danielle Giese, Kristen Jones, 

Morgan Jones, Lara Laufer, Monica Savoy, and Kelly Snow.

GAO Contact and 

Staff 

Acknowledgments

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