Supplemental Nutrition Assistance Program: Improved Oversight of State Eligibility Expansions Needed
Published: 2012-07-26T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.
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 higher income households without reporting requirements for several months.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: During fiscal year 2011, the U.S. Department of Agriculture’s (USDA)  Supplemental Nutrition Assistance Program (SNAP), previously known as  the Food Stamp Program, 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), state policy changes intended to improve  program access and simplify the administration of SNAP may also have  had an effect.
Under federal law, eligibility for SNAP is based primarily on whether a  household’s income and assets fall below certain thresholds. 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). 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 broad- based categorical eligibility (BBCE) policies. 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.
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?
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  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  and conclusions based on our audit objectives. See appendices I and II  for additional information on our objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: 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.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.
subsections: section_title: Participation and Costs
paragraphs: 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.
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 low- income 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,” 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.
section_title: Determination of Eligibility
paragraphs: Under federal law and regulations, eligibility for SNAP is based primarily  on a household’s income and assets. A household generally includes  everyone who lives together and purchases and prepares meals  together. To determine a household’s eligibility, a caseworker must first  determine the household’s gross income, which cannot exceed 130  percent of the federal poverty guidelines, 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).  Net income is determined by taking into account certain exclusions and  deductions, for example, expenses for dependent care, utilities, and  housing. 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. However,  certain assets are not counted for SNAP, such as a home, the  surrounding lot, and most retirement plans and educational savings  accounts. While there are also federal SNAP provisions that limit the  value of vehicles an applicant can own and still be eligible for the  program, 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.)
Federal law also allows certain households to be deemed categorically  eligible for SNAP. 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.)
In response to welfare reforms under the Personal Responsibility and  Work Opportunity Reconciliation Act of 1996, 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. 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. 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  receiving services that are less than 50 percent TANF-funded, with FNS  approval required in certain cases. 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.
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 non- cash 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.
Although FNS issued guidance in 1999 and regulations in 2000  explaining how states could adopt BBCE policies, 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).
According to FNS, as of May 1, 2012, 43 states—including Washington,  D.C., Guam, and the Virgin Islands—had BBCE policies. 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.
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. 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.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.
section_title: Certification and Reporting Requirements
paragraphs: 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,  but only households in which all members are elderly or disabled can be  certified for up to 24 months under federal regulations. Once the  certification period ends, households reapply for benefits, at which time  eligibility and benefit levels are redetermined.
Between certification periods, households generally must report changes  in their circumstances—such as household composition, income, and   Since  expenses—that may affect their eligibility or benefit amounts. 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.FNS, as of November 2010, all states except California and Wyoming use  this simplified reporting for some or all SNAP households.
section_title: Quality Control System
paragraphs: 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. 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  the national payment error rate and impose financial penalties or provide  financial incentives according to legal specifications.
section_title: While State Eligibility Changes Expanded Participation, the Economy Likely Played a Larger Role
subsections: section_title: More Became Eligible but Impact of Changes Likely Limited
paragraphs: For 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.
In 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. which is about 150 percent of the federal poverty guidelines,the federal income limit for SNAP is 130 percent of the guidelines.
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  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.
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, 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. 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. 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. For those with incomes below 100 percent of the  guidelines, the median amount was estimated to be zero.
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  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. 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. 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.
section_title: Economic Downturn a Major Cause of Recent Trends
paragraphs: 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  to 3 million. This relationship also existed during the most recent  economic recession of 2007-2009, 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.
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,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   which likely made participation in the  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. 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.  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.
section_title: State Eligibility Changes Increased Benefit Costs Somewhat, but Their Effect on Administrative Costs Is Unclear
subsections: section_title: Benefit Costs Increased Less Than 1 Percent
paragraphs: 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 percent of all SNAP benefits.  These benefits totaled an estimated $38.3 million a month, or  approximately $460 million annually. 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.
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.  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,  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.
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.
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  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.
section_title: Administrative Costs Affected by Many Factors
paragraphs: 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.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   During our site visits, staff in many of the  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. 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).
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. In our site visits to five states, officials frequently  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.
section_title: State Eligibility Changes May Negatively Affect Program Integrity
subsections: section_title: Payment Errors May Be Negatively Affected
paragraphs: 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  to 3.81 percent as the number of states with BBCE policies increased  from 0 to 39. 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.
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.
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. 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  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.
section_title: Limited Oversight May Contribute to Unintended Consequences
paragraphs: 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, 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 TANF- funded 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).caseworkers told us they did not consistently provide the guide to   However, in one state we visited, some local SNAP  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.
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. Many states rely on  data matches between their SNAP program and district-level school data  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. 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.
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. 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.
Letter 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.
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 guidelines— 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. In short, through their BBCE policies, some  states have effectively increased the income eligibility limits for two key  federal nutrition assistance programs.
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   households are required to report changes in income  nearly all states, 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. 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  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. Accordingly, a state TANF agency would not seek  information on these households’ income changes in order to share that  information with the SNAP agency.
section_title: Conclusions
paragraphs: 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  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.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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   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.
section_title: Appendix I: Objectives, Scope, and Methodology
subsections: section_title: U.S. Department of Agriculture (USDA) Data Analysis
subsections: section_title: Quality Control Data
paragraphs: 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. 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.
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, 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.
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.
FNS contracts with Mathematica Policy Research, Inc. to maintain the SNAP QC data.
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.
section_title: Other SNAP Data
paragraphs: 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  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.
section_title: Site Visits
paragraphs: 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 non- economic 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.
section_title: Appendix II: Quality Control Data Estimates and 95 Percent Confidence Intervals
section_title: Appendix III: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.
section_title: Related GAO Products
paragraphs: 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.
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.