Military Personnel: DOD Needs More Complete Data on Active-Duty Servicemembers' Use of Food Assistance Programs
Published: 2016-07-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: According to the Defense Commissary Agency, servicemembers on active duty spent over $21 million in SNAP benefits at commissaries from September 2014 through August 2015. This suggests that people serving our country may be having difficulty making ends meet. House Report 114-102 includes a provision that GAO review food assistance programs available to servicemembers. This report assesses, among other things, the extent to which (1) active-duty servicemembers and their families have access to food assistance programs and any variations in eligibility for these programs, and (2) DOD has identified the servicemembers' use of these programs. GAO reviewed information on government and charitable food assistance programs and policies. GAO also interviewed DOD and service officials at four installations that were selected based on size, cost of living, and presence of food assistance programs.
section_title: What GAO Found
paragraphs: Active-duty servicemembers and their families have access to food assistance through various government and charitable programs, but use of these programs varies, in part, on their ability to meet specific eligibility criteria. In an April 2010 report, GAO identified 18 government programs that provide food assistance to low-income households. Servicemembers may apply for and, if they qualify, receive benefits from any of these programs. However, servicemembers' eligibility for these programs can vary by program and location. For example, GAO found that it might be easier for servicemembers to qualify for Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) than Supplemental Nutrition Assistance Program (SNAP) because WIC allows state agencies to exclude portions of a servicemember's pay when determining eligibility and SNAP does not. Also, charitable organizations, such as food pantries, are available to servicemembers in need of food assistance.
The Department of Defense (DOD) has some data on servicemembers' use of food assistance programs it administers, but it does not know the extent that servicemembers use such programs because (1) it is not fully collecting or analyzing such information within the department, and (2) it has not coordinated with organizations such as U.S. Department of Agriculture (USDA) to access their data on servicemembers' use of their programs. Standards for Internal Control in the Federal Government state that management should use quality information to achieve its objectives. DOD has data on the number of servicemembers' children receiving free and reduced-price school meals at DOD Education Activity (DODEA) schools in the United States. For example, DODEA data for September 2015 showed that 24 percent of children in DODEA schools in the continental U.S. were eligible for free meals and 21 percent were eligible for reduced-price meals. A DOD survey also provides some information on servicemembers' use of food assistance programs such as SNAP. However, this survey is of limited usefulness in part because it does not inquire about other food assistance programs used by servicemembers such as National School Lunch Program; also no office within DOD is monitoring food assistance needs such as through survey data. Without more complete survey data, DOD will not understand the prevalence of need among servicemembers to effectively target its support and determine if it should assign department-level responsibility for monitoring food assistance needs.
Standards for Internal Control in the Federal Government also state that management should communicate with external parties to obtain needed information. USDA has access to data on servicemembers' use of food assistance programs, but none of the DOD officials with whom GAO spoke were aware of efforts by the department to coordinate with USDA to access these data. For example, USDA administers SNAP benefits that, according to a 2013 U.S. Census Bureau survey, were used by about 23,000 active-duty servicemembers in the previous 12 months. The National Defense Authorization Act for Fiscal Year 2016 included a provision to address the sharing of SNAP data between USDA and DOD; however, DOD does not have a coordination effort underway to access such data. Without such coordination, DOD will miss the opportunity to collect data on the needs of its servicemembers.
section_title: What GAO Recommends
paragraphs: GAO recommends that DOD (1) revise surveys of servicemembers to collect and analyze more complete data and, if warranted, implement actions such as assigning department-level responsibilities for monitoring food assistance; and (2) coordinate with USDA to access its usage information. DOD concurred with the first recommendation and partially concurred with the second, stating that it has tried to coordinate with USDA. GAO continues to believe the recommendation is valid, as discussed in this report.

section_title: Letter
paragraphs: According to the Defense Commissary Agency, servicemembers on  active duty spent over $21 million in food stamp benefits at military  commissaries from September 2014 through August 2015. This suggests  that some people serving our country may be having difficulty making  ends meet. Military families facing financial hardship have federal, state  and private-sector options for food assistance. One option provided by  the Department of Defense (DOD) to active-duty servicemembers is the  Family Subsistence Supplemental Allowance (FSSA). In 2000, Congress  created FSSA as an alternative to the United States Department of  Agriculture’s (USDA) Supplemental Nutrition Assistance Program  (SNAP)—formerly called the Food Stamp Program. However, in 2015, the  Military Compensation and Retirement Modernization Commission  reported that few active-duty servicemembers took advantage of FSSA  and recommended that Congress end the FSSA program for  servicemembers located in the United States and its territories, and refer  servicemembers to apply for benefits under the USDA’s SNAP program.   The National Defense Authorization Act (NDAA) for Fiscal Year 2016  implemented the commission’s recommendation with the effect that after  September 30, 2016, FSSA will be available only to active-duty  servicemembers serving outside the United States and its territories.  However, a 2015 House Armed Services committee report stated a  concern that active-duty servicemembers and their families may have a  continuing need for nutrition assistance.
House Report 114-102, which accompanied a bill for the NDAA for fiscal  year 2016, includes a provision that we review the food assistance  programs available to active-duty servicemembers and their families.  Subsequently, the Senate Agriculture, Nutrition, and Forestry committee  became co-requesters of our work in response to this House report  provision. This report assesses (1) the extent to which active-duty  servicemembers and their families have access to government and  charitable food assistance programs and any variations in eligibility  requirements for these programs, (2) the extent to which DOD has  identified active-duty servicemembers’ use of food assistance programs,  and (3) any challenges that active-duty servicemembers encounter when  seeking food assistance.
For our first objective, we reviewed our prior related reports and a  Congressional Research Service report on domestic food assistance  programs, and we interviewed officials from DOD and USDA to identify  food assistance programs available to active-duty servicemembers and  their families. We interviewed officials who administer these programs at  the federal, state, and local levels to obtain additional background  information and to confirm the availability and our understanding of the  food assistance programs we identified. We also met with representatives  of various charitable organizations that provide food assistance to active- duty servicemembers and their families. To determine if there were any  variations in eligibility requirements in government food assistance  programs, we reviewed the laws that established selected food  assistance programs and analyzed eligibility criteria for these programs  and used those eligibility criteria to develop scenarios to illustrate  situations in which a servicemember would or would not qualify for these  food assistance programs.
For our second objective, we interviewed officials from multiple offices  within the Under Secretary of Defense for Personnel and Readiness  (USD (P&R)) to determine which office(s) had department-level  responsibilities related to active-duty servicemembers’ use of food  assistance programs and to obtain any relevant data on servicemembers’  use of these programs. We reviewed DOD documents on the  organization and the assigned responsibilities of USD (P&R). We  obtained and reviewed DOD’s Status of Forces Survey of Active Duty  Members for calendar years 2010, 2012, and 2013, the U.S. Census  Bureau’s 2013 American Community Survey, FSSA data from the  Defense Joint Military Pay System, and data on the number of students in  DOD Education Activity (DODEA) schools who were eligible to receive  free and/or reduced-price meals. We found this information to be  sufficiently reliable for the purpose of reporting on DOD’s awareness of  military participants receiving these benefits. Also, we compared the data  collection and communications processes for DOD with Standards for  Internal Control in the Federal Government, which state that management  should obtain quality information to achieve its objectives and that it  should communicate with external parties regarding the information that is  needed to achieve its objectives. To obtain information on other food  assistance programs available to servicemembers and their families, we  visited four selected military installations in the United States and  interviewed officials who administer these programs, officials who assist  servicemembers in need, and visited food pantries, if any, on the  installation. We selected sites to represent each of the military services  and to include locations with a large population of servicemembers and  dependents, a range of cost-of-living areas—using the Basic Allowance  for Housing (BAH) rates—and a food pantry and/or a Special  Supplemental Nutrition Program for Women, Infants, and Children (WIC)  program office on the military installation. Based on these criteria, we  visited Fort Hood, Texas; Naval Base San Diego, California; Marine  Corps Base Camp Pendleton, California; and Altus Air Force Base,  Oklahoma. During our site visits, we met with military officials who assist  servicemembers and their families in financial difficulty— which may  include a need for food assistance—as well as state and local officials  who oversee non-military food assistance programs that servicemembers  may use. We also met with representatives from military and non-military  charitable organizations to learn what food assistance they provide to  active-duty servicemembers and their families.
For our third objective, we conducted site visits to four selected military  installations and interviewed military service officials who work with  servicemembers in need to gain their perspectives on any challenges that  may be faced by servicemembers attempting to obtain food assistance.  Specifically, we interviewed military Chaplains, First Sergeants and  Command Master Chiefs, financial specialists, and officials from  charitable military organizations, including Army Emergency Relief, the  Navy-Marine Corps Relief Society, and the Air Force Aid Society. We  also interviewed private and local government officials who assist civilians  and some servicemembers with food assistance, such as SNAP, WIC,  summer meals programs, and food pantries. Further, we interviewed  representatives from advocacy groups who support active-duty families or  try to reduce hunger in America. We provide further details on our scope  and methodology in Appendix I.
We conducted this performance audit from July 2015 to July 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Under Secretary for Personnel and Readiness Is Responsible for Areas That Affect Personnel Health and Welfare
paragraphs: The Under Secretary for Personnel and Readiness (USD (P&R)) is the  principal staff assistant and advisor to the Secretary of Defense for Total  Force Management as it relates to readiness, health affairs, training,  personnel requirements, and quality-of-life matters. USD (P&R) is the  Secretary’s senior policy advisor on recruitment, career development, and  pay and benefits for military personnel and DOD civilians. The USD  (P&R) oversees the Defense Health Program, Defense Commissary  Agency, the Defense Education Activity, Defense Manpower Data Center,  Military Community and Family Policy, and others. USD (P&R)  responsibilities include, but are not limited to, developing policies, plans,  and programs for compensation of military personnel and quality of life for  military personnel and their families.
section_title: Defense Commissaries Sell Servicemembers Food at Reduced Cost
paragraphs: Although included in the military compensation system as a non-cash  benefit, DOD commissaries can be considered a food assistance program  in that the commissaries provide servicemembers an opportunity to  purchase food at reduced cost. Active-duty servicemembers receive a  compensation package that includes cash compensation, non-cash  compensation, and deferred compensation. Non-cash compensation  includes various types of benefits such as health care, child-care centers,  educational benefits, and access to subsidized commissaries (i.e.,  grocery stores). DOD operates a worldwide chain of commissaries that  sell food and related household items to active-duty, reserve and guard  members of the military services, retirees of these military services, their  families, and other authorized patrons. According to the Defense  Commissary Agency’s Annual Financial Report Fiscal Year 2015, DOD’s  240 commissaries sold $5.5 billion of items to approximately 5.3 million  households in fiscal year 2015. Commissaries sell food and related  household items to authorized patrons at cost plus a 5-percent surcharge,  which DOD estimates saves patrons an average of more than 30 percent  on their purchases compared to commercial prices. The Defense  Commissary Agency wrote in its report that it received $1.3 billion in  appropriation transfers during fiscal year 2015.
section_title: Department of Agriculture Administers Most of the Federal Domestic Food Assistance Programs
paragraphs: The USDA’s Food and Nutrition Service has responsibility for  administering most of the federal domestic food and nutrition programs,  including the five largest programs. As the federal government’s primary  domestic food assistance agency, USDA aims to help households  achieve food security—that is, to have consistent, dependable access to  enough food for an active, healthy life—and monitors the extent and  severity of food insecurity. The Department of Health and Human  Services and the Department of Homeland Security also fund programs  that provide food and nutrition assistance.
In May 2015, we testified before Congress that, in fiscal year 2014, the  federal government spent more than $100 billion on 18 domestic food  assistance programs. Specifically, we identified that program spending  ranged from approximately $5 million on the Community Food Projects  Competitive Grants Program to more than $74 billion on SNAP. Our  testimony also stated that in fiscal year 2014, the five largest food  assistance programs—SNAP, National School Lunch Program (NSLP),  WIC, School Breakfast Program (SBP), and the Child and Adult Care  Food Program—accounted for 96 percent of total spending on the 18  programs. SNAP, the largest program, accounted for more than 70  percent of the overall spending total. SNAP, NSLP, SBP, and the Child  and Adult Care Food Program are entitlement programs, meaning that  federal law requires benefits to be provided to all applicants who meet  eligibility requirements.
section_title: Active-Duty Servicemembers Have Access to Various Government and Charitable Food Assistance Programs, but Their Eligibility for Some Government Programs Can Vary
paragraphs: Active-duty servicemembers and their families have access to food  assistance through various government and charitable programs, but their  eligibility for some government food assistance programs can vary based  on the programs’ income criteria and servicemembers’ location.
subsections: section_title: Active-Duty Servicemembers Have Access to Various Government and Charitable Food Assistance Programs
paragraphs: Active-duty servicemembers and their families have access to food  assistance through a variety of government and charitable sources. For  example, in a testimony before Congress on May 2015, we identified 18  selected federal government programs that focus primarily on providing  food and nutrition assistance, such as SNAP and WIC, to low-income  individuals and households. Active-duty servicemembers and their  families may apply to any of these programs, and can receive benefits if  they meet the eligibility requirements. Appendix II provides a general  description of these 18 programs as well as the target population.  Additionally, DOD provides active-duty servicemembers with FSSA. By  design, the FSSA program increases a servicemember’s income by an  amount to preclude them from applying for benefits under the SNAP  program. However, the NDAA for fiscal year 2016 restricted the  availability of FSSA to only servicemembers stationed outside the United  States and its territories starting October 1, 2016. Servicemembers  stationed in the United States and its territories and in need of food  assistance previously provided by FSSA are expected to apply to the  SNAP program.
In addition to the government food assistance programs, active-duty  servicemembers and their families can seek assistance from a variety of  charitable organizations. For example, each military service has a  charitable organization such as the Army Emergency Relief that,  depending on the type of assistance needed, is able to provide  servicemembers with grants or interest-free loans that can be used to  purchase food and to help meet any other immediate needs they may  have in an emergency situation. During our visits to four selected military  installations, we also found that additional assistance may be available to  active-duty servicemembers and their families through locally-developed  initiatives, such as food pantries, that are typically organized by  volunteers to address food assistance needs at a particular military  installation. Many of the food pantries we examined were local operations  intended to meet emergency needs; however, at one of the military  installations we visited there were four food pantries operating on the  installation that provided food routinely once a month. Table 1 provides  further details about some of the different types of food assistance  available to active-duty servicemembers and their families.
section_title: Servicemembers’ Eligibility for Government Food Assistance Programs Can Vary Based on the Program’s Criteria and the Servicemember’s Location
paragraphs: An applicant’s income must be below a given level in order to qualify for  benefits from the government food assistance programs. To develop an  understanding of how active-duty servicemembers could meet the  financial criteria, we compared the base income for servicemembers in a  specific paygrade with the income eligibility requirements for five  government food assistance programs that are commonly used by active- duty servicemembers and their families. Specifically, these five programs  include DOD’s FSSA—the only food assistance program offered through  DOD—and four USDA programs, including SNAP, WIC, NSLP, and  SBP. These programs’ statutory authorities define the financial criteria  as a maximum income limit by household or family size. Our  comparison enabled us to develop an understanding of the size of  household or family a servicemember in a specific paygrade would need  in order to qualify for a program. Although other factors beyond  household or family size and base income affect servicemembers’  eligibility for these food assistance programs, our analysis is generally  limited to these factors in order to isolate the effect of income on  eligibility. Further, we recognize that to receive benefits the  servicemember would also have to meet the program’s non-financial  eligibility requirements, which are detailed in appendix III. Given that, we  compared the basic pay and allowances of a servicemember in the E-4  paygrade with maximum income eligibility criteria for the five government  food assistance programs commonly used by active-duty  servicemembers and their families and determined the minimum  household or family size the servicemember needed in order to qualify for  each program. We selected the paygrade of E-4 in part because it  includes junior enlisted personnel who are compensated at the lower end  of the pay scale for active-duty servicemembers. Further, DOD’s data on  FSSA recipients showed that servicemembers in the paygrade of E-4  were the most frequent recipients of this allowance, thus suggesting that  there may be food assistance needs more commonly experienced by  personnel at this paygrade. The results of our analysis are presented in  Figure 1 and show that a servicemember’s income eligibility will likely  vary based on where he or she lives and the program through which one  applies for food assistance.
We found that each of the government food assistance programs  included in our review requires that an applicant’s household or family  income falls below a specified amount to qualify for benefits and that this  income limit varies by program and sometimes by state. Further, including  BAH benefits in a determination of an applicant’s income eligibility also  plays a role in the food assistance programs used by active-duty  servicemembers and their families. Specifically, we found that it might be  easier for servicemembers to qualify for WIC than SNAP or FSSA  because WIC allows state agencies to choose to exclude BAH from  income. For example, based on our analysis a servicemember at Naval  Base San Diego, California, would need a minimum household size of 3  to qualify for WIC benefits, but would require a minimum household size  of 7 to qualify for SNAP benefits and a minimum household size of 9 to  qualify for FSSA. We also found that servicemembers may be more likely  to qualify for free or reduced- price meals from NSLP and SBP if they  reside in privatized housing than if they live in the local community  because the eligibility criteria for those programs do not count BAH as  income for servicemembers living in privatized military housing. For  example, based on our analysis a servicemember residing in privatized  military housing on Camp Pendleton in California would require a  minimum household size of 3 to qualify for reduced-price school meals  compared to a servicemember residing in the local community who would  need a minimum household size of 6 to qualify.
Based on our analysis, we found that it might be easier for  servicemembers to qualify for SNAP than FSSA because SNAP’s  statutory authority gives the states, in certain instances, the option to  increase the gross-income limit for SNAP to as much as 200 percent of  the federal poverty guidelines but fixes the income limit for FSSA at 130  percent of the federal poverty guidelines regardless of the state the  servicemember lives in. For example, our analysis suggests that a  servicemember at Camp Pendleton, California, would need a minimum  household size of 6 to qualify for SNAP benefits but would require a  minimum household size of 9 to qualify for FSSA, and a servicemember  at Fort Hood, Texas, would need a minimum household size of 6 to  qualify for SNAP benefits but would require a minimum household size of  7 to qualify for FSSA benefits. In this example, a smaller household size  is required to qualify for SNAP than for FSSA primarily because California  and Texas raised the gross-income test for SNAP to 200 percent and 165  percent of federal poverty guidelines, respectively. Appendix III details  both the income and non-income eligibility criteria for the government  food assistance programs commonly used by active-duty  servicemembers and their families.
section_title: DOD Does Not Know the Extent to Which Servicemembers Use Food Assistance Programs
paragraphs: DOD has some data on servicemembers’ use of food assistance  programs that it administers, but DOD does not know the extent to which  servicemembers use food assistance programs because (1) its officials  are not fully collecting or analyzing such information within the  department, and (2) DOD officials we spoke with were not aware of  efforts to coordinate with USDA to access data on servicemembers’ use  of the respective programs. We contacted multiple offices within DOD to  obtain data on the use of food assistance programs and found that none  of the offices had efforts to monitor servicemembers’ food assistance  needs.  Further, DOD has not assigned responsibility for monitoring  servicemembers’ use of food assistance programs.
subsections: section_title: DOD Does Not Collect and Analyze Relevant Data on Servicemembers’ Use of Food Assistance Programs
paragraphs: We found that some data exist within and outside of DOD on the use of  the food assistance programs by active-duty servicemembers and their  families. However, DOD does not know the extent to which these  programs are used. Standards for Internal Control in the Federal  Government states that management should use quality information to  achieve the entity’s objectives, and defines quality information as  complete, accurate and current.
subsections: section_title: Some Data Are Available within DOD on Servicemembers’ Use of Food Assistance
paragraphs: As the administrator of FSSA, DOD has data on servicemembers who  receive the FSSA benefit. Specifically, based on Defense Joint Military  Pay System records, 188 active-duty servicemembers received FSSA  benefits in calendar year 2015, 224 received benefits in calendar year  2014, and 285 received benefits in calendar year 2013. However, these  data are of limited usefulness because DOD does not collect and analyze  relevant data that are available from other sources within the department  and that would facilitate a more comprehensive understanding of  servicemembers’ use of food assistance programs. Further, FSSA data  alone will provide fewer insights into servicemembers’ use of food  assistance programs in the future because, as previously noted, the  benefit will no longer be available to servicemembers who are stationed  within the continental U.S. after September 30, 2016.
Through the DOD Education Activity (DODEA), which operates 52  schools on military installations within the continental United States, DOD  has access to data on the number of children who attend these schools  and are eligible to receive free and reduced-price lunches and  breakfast. For example, we obtained data from DODEA officials for the  2014-2015 school year that showed, on average, of the 19,001 children  enrolled in DODEA schools in the continental United States, 26 percent  (5,010) were eligible for free meals and 25 percent (4,675) were eligible  for reduced-price meals. In addition, DODEA officials provided data for  September 2015—the start of the 2015-2016 school year—that showed  that 24 percent of the 18,228 (4,427) children enrolled in DODEA schools  in the continental United States were eligible for free meals and 21  percent (3,909) were eligible for reduced-price meals. These data do not  fully capture the use of food assistance by servicemembers and their  families, but they may be an indicator of a need that exists for a specific  population within the military services. However, a DODEA official stated  that prior to our request she was not aware of any efforts by DOD to  collect and analyze such data to better understand the extent to which  servicemembers use food assistance.
DOD also periodically conducts Status of Forces surveys that seek to  understand attitudes and views on a wide range of personnel issues and  the results of which are used to help DOD decision makers evaluate  existing programs and policies, establish baselines before implementing  new programs and policies, and monitor the progress of programs and  policies and their effects on the total force. However, DOD has not  utilized this survey as a tool to collect and analyze data on the use of food  assistance programs by active-duty servicemembers and their families.  DOD Instruction 1342.22 directs DOD’s family readiness services, which  include a variety of support programs for servicemembers and their  families that range from financial assistance to child care, be designed,  funded, and managed using results obtained from a performance  management strategy that includes assessment of needs. DOD’s Status  of Forces surveys include a survey of active-duty servicemembers that, in  recent years, has included questions about the use of food assistance  programs. Based on the 2013 survey—the most recent results  available—DOD estimated that 2 percent (about 20,000) of active-duty  servicemembers or their spouses had received income or financial  support from SNAP in the previous 12 months and 9 percent received  income from either WIC and/or Temporary Assistance For Needy  Families (TANF). However, the WIC and TANF data are of limited  usefulness in determining the extent to which servicemembers use food  assistance, in part, because it combines data on WIC—a food assistance  program—with TANF data—a non-food assistance program. The survey  also does not specifically address other sources of food assistance that  may be used by active-duty servicemembers and their families such as  NSLP, SBP, SFSP, or food pantries. Further, in July 2010, we reported  that the low response rates to the Status of Forces Survey could  potentially bias the survey results and recommended that the Defense  Manpower Data Center develop and implement guidance to conduct a  nonresponse analysis. DOD agreed with the recommendation, but it has  not fully implemented our recommendation because, according to DOD  officials, funding is not currently available to carry out the full intent of the  recommendation. Without more complete data, DOD will not be able to  identify the prevalence of need and the use of food assistance programs  by active-duty servicemembers. Furthermore, DOD will be unable to  effectively target its support so that it is producing maximum benefit for  those in need.
section_title: Some Data Are Available Outside of DOD on Servicemembers’ Use of Food Assistance
paragraphs: We also identified other agencies and organizations outside of DOD that  have access to, or are in a position to collect, data on food assistance  used by active-duty servicemembers and their families. Standards for  Internal Control in the Federal Government state that management  should communicate with external parties regarding quality information  needed to achieve objectives. In addition, DOD Instruction 1342.22  specifies that family readiness services shall be provided through a  system that maximizes the network of agencies, programs, services, and  individuals in a collaborative manner to promote military family  readiness. The instruction further states that family readiness services  shall promote interagency collaboration and service coordination within  and among federal and non-federal entities to identify and achieve  common family readiness goals and improve communication among  service providers and with servicemembers and their families.
While DOD could benefit from more complete information on  servicemembers’ use of food assistance, none of the DOD officials we  met were aware of any efforts by the department to coordinate with  agencies, such as the USDA, to collect and share relevant data on food  assistance. Specifically, we contacted multiple offices within USD (P&R)  to obtain data on the use of food assistance programs, including the  offices for Military Compensation, Military Community & Family Policy,  Defense Commissary Agency, Defense Manpower Data Center, and the  Defense Health Agency. We found that none of these offices had efforts  to monitor or collect data on servicemembers’ food assistance needs,  including coordinating with USDA regarding collecting and sharing data or  other relevant information. The USDA works through various state and  local agencies to administer four of the five food assistance programs  commonly used by active-duty servicemembers and their families,  including: (1) SNAP, (2) WIC, (3) NSLP, and (4) SBP. A provision in the  NDAA for fiscal year 2016 addressed DOD’s access to information on  SNAP usage by servicemembers.  The NDAA for fiscal year 2016 calls  for the USDA to ensure that any safeguards that prevent the use or  disclosure of information collected from SNAP recipients will not prevent  the USDA from disclosing that information to DOD, or DOD using that  information, for the purposes of determining the number of SNAP  applicant households that contain one or more military servicemembers.  DOD provided us an email exchange that occurred in February to March  2016 discussing how to use the new authority provided in section 605 of  the 2016 NDAA to obtain SNAP data. However, officials were not aware  of further attempts to collect such information. According to results from  the 2013 U.S. Census Bureau’s annual American Community Survey  (ACS), about 23,000 active-duty servicemembers received SNAP  benefits in the previous 12 months. While it is known that  servicemembers use food assistance programs and that information on  recipients can be obtained, specific data on servicemembers’ use of  these programs are not available because there is no requirement or  need that has been established for agencies such as the USDA to collect  such information. For example, during visits to four selected military  installations, we met with local administrators of USDA food assistance  programs who told us that they are able to identify servicemembers  through required documentation such as a Leave and Earnings  Statement that will identify if an individual is a member of the U.S.  military. However, officials said that they do not ask about or routinely  document an applicant’s military status since it does not have a bearing  on their eligibility for assistance.
We also spoke with representatives from charitable organizations located  on the installations that we visited who have information that DOD could  use to gain insights into the needs of its servicemembers. For example,  we spoke with representatives from Army Emergency Relief, the Navy- Marine Corps Relief Society, and the Air Force Aid Society—each of  which offers various types of support, including financial support to  purchase food for servicemembers in need. Army Emergency Relief and  the Air Force Aid Society track the amount provided for food assistance.  Specifically, an official with Army Emergency Relief told us that the  organization provided $2.3 million in food assistance to active-duty  servicemembers in calendar year 2015, $2.7 million in calendar year  2014, and $1.8 million in calendar year 2013. According to an official with  the Air Force Aid Society, the organization provided $300,000 in food  assistance in fiscal year 2015, and $600,000 in each of the previous two  years.
During our site visits, we also visited volunteer-run food pantries and food  distribution operations of varying sizes that were started to address a  locally-identified need. For example, during our site visit to Altus Air Force  Base, Oklahoma, we visited a pantry that provides free food to anyone in  need, but it does not track the number of individuals served. We also  visited a food pantry on Fort Hood in Texas that Army officials told us  responded to 508 separate requests for food from active-duty  servicemembers, retirees, and their family members in fiscal year 2015.  Of the four military installations, Marine Corps Base Camp Pendleton in  California had the largest and most organized of the food distribution  operations that we visited. Specifically, during our visit to the base in  December 2015, we identified four food pantries that distribute food on  specific days of the month around Camp Pendleton. The manager of one  pantry told us that its operation alone provides food assistance each  month to an average of 400 to 500 military families on Camp Pendleton.  Without coordination with USDA, and considering outreach to other  organizations that have data on servicemembers’ use of food assistance,  DOD will miss the opportunity to collect more complete data and  information on the needs of its servicemembers.
section_title: DOD Has Not Assigned Department-Level Responsibilities for Monitoring the Use of Food Assistance Programs
paragraphs: DOD has not assigned department-level responsibilities, such as a  collateral duty within the Office of the USD (P&R), for monitoring the use  of food assistance programs by active-duty servicemembers and their  families. Standards for Internal Control in the Federal Government state  that management should establish an organizational structure, assign  responsibility, and delegate authority to achieve the entity’s objectives.  We contacted multiple offices within USD (P&R) to obtain data on the use  of food assistance programs, including Military Compensation, Military  Community & Family Policy, Defense Commissary Agency, Defense  Manpower Data Center, and Defense Health Agency. None of these  offices was responsible for monitoring servicemembers’ use of food  assistance programs with the exception of FSSA and the meals provided  under NSLP and SBP at DODEA schools. Further, to better understand  the purpose of DOD’s survey questions on food assistance and how any  resulting data are used, we spoke with the Defense Manpower Data  Center official involved in developing DOD’s Status of Forces Survey who  told us that different offices within USD P&R are responsible for  developing questions that relate to their particular mission. The official  referred us to the Military Community and Family Policy office within USD  (P&R) for the survey questions related to servicemembers’ use of food  assistance programs. However, officials were not able to identify any  official or office that had responsibility for or knowledge about why or how  these questions are used, omitted, or changed from survey year to survey  year. In general, DOD officials could not identify an office with  responsibility for reviewing and updating the questions on food assistance  asked in the Status of Forces Survey.
Without collecting more data and determining whether DOD should  assign department-level responsibility for monitoring servicemembers’  use of food assistance programs, DOD will not have a good  understanding of the prevalence of need among servicemembers.  Moreover, assigning department-level responsibility for monitoring food  assistance needs could provide DOD with the ability to coordinate the  military services’ collection and analysis of relevant data and determine  what actions may be needed to address the needs of the  servicemembers and their families.
section_title: Military Officials at Selected Installations Cited Challenges Affecting Servicemembers Who Seek Food Assistance Benefits
paragraphs: Military service officials at all four of the military installations that we  visited described challenges that servicemembers may experience when  seeking food assistance benefits, and stated they have been addressing  the challenges by continuing to refer interested servicemembers to  potential assistance from government food assistance programs and  charitable organizations. Some of the challenges mentioned during our  group interviews at each of the four military installations that we visited  were: (1) limited awareness of some food assistance programs (2) stigma  associated with receiving food assistance; and (3) misconceptions about  military compensation and the ability of a servicemember to qualify for  food assistance.
subsections: section_title: Limited Awareness of Food Assistance Programs
paragraphs: Military service officials who assist servicemembers and their families at  all four of the installations we visited generally had knowledge of some  food assistance programs administered by USDA, such as SNAP and  WIC. However, we found that some of the military officials at three of the  four installations we visited were not aware of the FSSA food assistance  program even though it is administered by DOD. Those who were aware  of FSSA said that they had not referred many servicemembers to the  program because it is more difficult to qualify for than SNAP. For  example, at one military installation, the officials told us that no applicant  has been able to qualify for FSSA. In addition, the military officials told us  that they assisted servicemembers who were also not aware of some  food assistance programs, such as foodbanks, SNAP, and particularly  FSSA.
section_title: Stigma for Those Receiving Food Assistance
paragraphs: Military service officials at three of the four selected installations we  visited stated that they believe a societal stigma exists generally for those  who use food assistance. Officials at one installation added that the self- sufficient culture of the military can make these stigmas even more  pronounced for servicemembers who receive food assistance from, for  example, SNAP, and to a lesser degree from charitable organizations and  food pantries. In contrast, these officials said that there seems to be no  stigma with regard to receiving WIC benefits, which suggest that WIC is  seen as more of a health and nutrition benefit rather than a program for  those with financial and food assistance needs. Officials added that WIC  is advertised more than other food assistance programs; in some cases  there have been proactive efforts to promote the program by including  WIC representatives at military briefings to inform and encourage  servicemembers to apply if they are expecting or have small children.
section_title: Misconceptions About Military Compensation and Income Eligibility Requirements for Food Assistance
paragraphs: Military officials at all four of the installations we visited cited  misconceptions about military compensation relative to income eligibility  requirements for food assistance programs as another challenge that may  deter servicemembers in need from seeking such assistance. For  example, some military officials at one installation who are in a position to  refer servicemembers to food assistance programs sometimes do not  because they mistakenly assume that a potential recipient’s income  exceeds eligibility requirements for such programs.
The BAH benefit also plays a role in a servicemember’s eligibility for food  assistance and may contribute to misconceptions about eligibility and a  servicemember’s decision to apply for such programs. For example, a  program such as SNAP counts the amount a servicemember receives in  BAH as part of one’s income when determining eligibility for benefits,  while other programs, such as WIC, do not count BAH as income. Also,  the amount of a servicemember’s BAH benefit is affected by location,  meaning that the same servicemember may qualify for food assistance at  one location but not be eligible at another location with a higher housing  benefit. For example, a servicemember stationed at Altus Air Force Base,  Oklahoma, would have a BAH rate of $789, that, when combined with  one’s basic pay, may result in a level of income that is low enough to  qualify for food assistance. However, if that same servicemember  transferred to San Diego, California, which has a BAH rate of $2,178, the  servicemember may no longer have income low enough to qualify for  food assistance programs for which he or she was previously eligible.
Military service officials we interviewed at all four of the installations we  visited suggested that BAH makes it difficult to qualify when determining  eligibility for SNAP in part because a servicemember’s ability to qualify for  SNAP can be affected by the inclusion of BAH. Currently, U.S. code  requires all income, regardless of the source, to be considered when  determining eligibility for SNAP unless specifically excluded by law, and  BAH is not excluded by law. Further, the U.S. Code defines regular  military compensation to include BAH and DOD’s description of military  pay and compensation includes BAH. On January 12, 2016, the Chief  Executive Officer for MAZON, a national nonprofit organization working  to end hunger, testified to the House Committee on Agriculture,  Subcommittee on Nutrition, that many lower ranking servicemembers are  made ineligible for SNAP because their housing allowance is counted as  income. MAZON contended that since BAH is excluded as income for  the purposes of calculating income taxes and eligibility for some federal  programs, such as Head Start, that BAH should be excluded as income  for the purposes of determining eligibility for all food assistance  programs. MAZON maintains that treating the BAH benefit as income  for determining eligibility for SNAP puts some military families at an unfair  disadvantage and disqualifies them from receiving food assistance.
section_title: Conclusions
paragraphs: Military families facing financial hardship have access to government and  charitable food assistance programs. As the administrator of FSSA and  through the Status of Forces Survey that it periodically conducts, DOD  has some data on the use of food assistance programs by active-duty  servicemembers and their families. However, the survey is of limited  usefulness because it does not address all the food assistance programs  that servicemembers use. In addition, based on our interviews with DOD  officials, DOD has not coordinated with and leveraged the information and  access that other agencies, such as the USDA, have on servicemembers’  use of food assistance. USDA’s role as one of the primary administrators  of food assistance programs in the U.S. is one source of information that  DOD could use to better understand the extent to which such programs  are used by active-duty servicemembers and their families. Without more  complete data and determining whether it needs to assign specific  department-level responsibility within DOD for monitoring food assistance  use, DOD will continue to have a limited understanding of  servicemembers’ food assistance needs and whether further actions are  needed to help ensure that the basic needs of servicemembers and their  families are met and that any existing gaps are not related to their service  in the military.
section_title: Recommendations for Executive Action
paragraphs: To more fully understand the food assistance needs that exist for active- duty servicemembers and their families, and to help ensure that DOD  effectively targets its support to those in need of assistance, we  recommend that the Secretary of Defense direct the Office of the Under  Secretary of Defense for Personnel and Readiness to take the following  two actions:
Revise, as appropriate, any existing data-collection mechanisms,  such as periodic surveys, to collect and analyze more complete  data on the use of food assistance programs by servicemembers  and their families and use the data to determine if any further  actions are needed, such as assigning responsibilities at the  department-level for monitoring the use of food assistance  programs by active-duty servicemembers; and,
Coordinate with USDA to leverage its access to data on active- duty servicemembers and their families who use its programs and  services and consider outreaching to other organizations that  have data on servicemembers’ use of food assistance.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD for review and comment. In its  written comments, reproduced in appendix IV, DOD concurred with our  first recommendation and partially concurred with our second  recommendation.
Specifically, DOD concurred with our first recommendation to revise, as  appropriate, any existing data-collection mechanisms, such as periodic  surveys, to collect and analyze more complete data on the use of food  assistance programs by servicemembers and their families, and use the  data to determine if any further actions are needed, such as assigning  responsibilities at the department-level for monitoring the use of food  assistance programs by active-duty servicemembers.
DOD partially concurred with our second recommendation, to coordinate  with USDA to leverage its access to data on active-duty servicemembers  and their families who use its programs and services and consider  outreaching to other organizations that have data on servicemembers’  use of food assistance. DOD noted in its comments that it concurred with  most of the findings regarding visibility on servicemembers receiving food  assistance programs but non-concurred with our statement that DOD has  not coordinated with USDA to access its data on servicemember use of  programs it administers. DOD stated that it has tried, for several years, to  obtain SNAP data from USDA and that although the National Defense  Authorization Act for Fiscal Year 2016 clarified that existing safeguards  on SNAP recipient data do not prevent the disclosure of such information  to DOD, it also did not mandate that USDA provide the data. Further,  DOD stated that the Defense Manpower Data Center has been in contact  with USDA to set up data exchange agreements, but that it has been  unable to identify one source within USDA from which to obtain these  data.
We are encouraged by DOD’s recent efforts to work with USDA to obtain  data that would provide the department with greater insight into the needs  of its servicemembers. However, during the course of this review we  spoke with DOD officials—on multiple occasions—in the Office of the  Deputy Assistant Secretary of Defense for Military Community and Family  Policy, the Office of the Under Secretary of Defense for Personnel and  Readiness’ Military Compensation office, and at the Defense Manpower  Data Center, among others, to discuss the department’s efforts to monitor  servicemembers’ food assistance needs. We consistently found officials  to be unaware of any previous such efforts by DOD until after passage of  the National Defense Authorization Act for Fiscal Year 2016 when we  were provided, as noted in our report, an email exchange that occurred in  February to March 2016 discussing how to use the new authority to  obtain SNAP data. Importantly, no DOD official with whom we met  believed that their office was responsible for such coordination with  USDA.
Furthermore, following the receipt of DOD’s comments on our draft report,  we contacted the Office of Assistant Secretary of Defense, Manpower  and Reserve Affairs to further inquire about the efforts it noted had  previously been taken to obtain data from USDA. Specifically, we spoke  with an official in that office who stated that three or four years earlier  DOD tried to obtain data from USDA on servicemembers’ use of SNAP,  but were unsuccessful. We requested, but DOD did not provide us with,  any additional documentation to confirm this or other efforts to coordinate  with USDA to access its data. We also recognize the inherent complexity  of interagency coordination and believe DOD should continue its dialogue  with USDA about ways in which it can leverage their access to data that  would provide valuable insights into servicemembers’ needs.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense; the Secretary of Agriculture; the  Secretaries of the Army, the Navy, and the Air Force; the Commandant of  the Marine Corps; and the Under Secretary of Defense for Personnel and  Readiness. In addition, the report is available at no charge on the GAO  website at http://www.gao.gov.
If you or your staff has any questions about this report, please contact me  at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff members who made key contributions to this  report are listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: Our review focused on the food assistance programs available to active- duty servicemembers from the four military services—Army, Navy, Marine  Corps, and Air Force—and their families. To assess the extent to which  active-duty servicemembers and their families have access to  government and charitable food assistance programs, we reviewed  various reports and documents to identify federal government programs  that focus primarily on providing food and nutrition assistance to low- income individuals and households. The reports and documents included:  our related report, Domestic Food Assistance: Complex System Benefits  Millions, but Additional Efforts Could Address Potential Inefficiency and  Overlap among Smaller Programs; our related testimony, Domestic Food  Assistance: Multiple Programs Benefit Millions of Americans, but  Additional Action Is Needed to Address Potential Overlap and  Inefficiencies, and a Congressional Research Service report on domestic  food assistance programs, Domestic Food Assistance: Summary of  Programs. For the purpose of this engagement, we focused on  government and charitable food assistance programs available to active- duty servicemembers and their families who are assigned to installations  within the continental United States. We interviewed officials from United  States Department of Agriculture (USDA) and Department of Defense  (DOD) to identify food assistance programs available to active-duty  servicemembers and their families. Further, we interviewed officials who  administer these programs at the federal, state, and local levels to obtain  additional background information and confirm the availability and  completeness of the food assistance programs we identified. To find  charitable organizations that provide food assistance to active-duty  servicemembers and their families, we interviewed officials from each of  the military services who identified the following charities that support  servicemembers and families: Army Emergency Relief, Air Force Aid  Society, and Navy-Marine Corps Relief Society. Further, we conducted  internet searches to identify charitable food pantries operating on military  installations, and when one was located, we contacted local military  service officials to confirm its existence.
To assess the extent to which there was any variation in eligibility  requirements for government food assistance programs, we reviewed the  laws that established selected food assistance programs and analyzed  eligibility criteria for these programs and used those eligibility criteria to  develop scenarios to illustrate situations in which a servicemember would  or would not qualify for these food assistance programs. Specifically, we  conducted an analysis to show what a servicemember in the paygrade of  E-4 needs to meet the income eligibility requirements for Family  Subsistence Supplemental Allowance (FSSA), Supplemental Nutrition  Assistance Program (SNAP), Special Supplemental Nutrition Program for  Women, Infants, and Children (WIC), National School Lunch Program  (NSLP), and School Breakfast Program (SBP) at the four military  installations we visited. We selected the paygrade of E-4 because these  servicemembers are junior enlisted personnel and as such are at the  lower end of the pay scale for active-duty servicemembers. Also, FSSA  program data for calendar year 2014 showed that the E-4 paygrade was  the most frequent paygrade to receive this allowance, suggesting that  personnel at this paygrade have a need for assistance. In calculating the  servicemember’s income, we included only three types of military pay:  Basic Pay, Basic Allowance for Subsistence (BAS), and Basic Allowance  for Housing (BAH) with dependent rate. We included these elements of  military pay because active-duty servicemembers who are entitled to  basic pay are also entitled to BAS and BAH. We did not include other  military pay and allowances because active-duty servicemembers are not  necessarily eligible for the other pay and allowances. Further, our  analysis is based on the assumption that the only source of income for  the household is the servicemembers’ military pay. Next, we reviewed  relevant federal statutes to determine the income criteria for each of the  programs and what types of military pay and allowances are included in  active-duty servicemembers’ income when applying to one of these food  assistance programs. Since federal law provides states some discretion  in setting the income criteria for some of the food assistance programs  and deciding what portion of military pay is included in income, we  interviewed state officials to determine how they calculated the income of  active-duty servicemembers and what specific income criteria they  employ. The state’s income criteria are on a graduated scale that as the  household size increases, the income level to qualify for benefits also  increases. We compared the income of a servicemember in the paygrade  of E-4 to the income criteria used by the state and determined how large  a household the servicemember needed in order to qualify given his/her  income.
To determine the household size required to qualify for SNAP benefits,  we made additional calculations with several assumptions. Applicants for  SNAP must pass a two-income test, a gross-income test and a net- income test. Most households must meet gross- and net-income tests,  but a household with an elderly person or a person who is receiving  certain types of disability payments has to meet only the net-income test.  We based our analysis on the assumption that the servicemembers had  to pass both the gross- and net-income tests. To calculate net income,  SNAP allows taking a number of deductions from the household income.  In conducting our analysis, we assumed that the household does not  include any elderly or disabled persons, there were no dependent care,  medical expenses, or child-support deductions, the monthly rent or  mortgage payment equaled the servicemember’s BAH, and the standard  utility allowance was appropriate to use in the calculations. We had state  or local officials responsible for the SNAP program in their area review  our calculations to ensure they were correct.
To assess the extent to which DOD has identified that active-duty  servicemembers and their families use food assistance programs, we  interviewed officials from multiple offices within Under Secretary of  Defense for Personnel and Readiness (USD (P&R)) to determine which  office(s) had department-level responsibilities related to active-duty  servicemembers’ use of food assistance programs and to obtain any  relevant data on servicemembers’ use of these programs. We reviewed  DOD documents on the organization and assigned responsibilities of  USD (P&R). We obtained and reviewed the results of recent surveys  completed by active-duty servicemembers that include questions about  the use of food assistance programs. Specifically, we obtained and  reviewed DOD’s Status of Forces Survey of Active Duty Members for  calendar year 2010, 2012, and 2013, the U.S. Census Bureau’s 2013  American Community Survey, FSSA data from the Defense Joint Military  Pay System, and data on the number of students in DOD Education  Activity (DODEA) schools who were eligible to receive free and/or  reduced-price meals. We assessed the reliability of this information by  interviewing responsible officials and, in the case of the Status of Forces  Survey, reviewing documentation of the survey’s methodology. We found  this information to be sufficiently reliable for the purpose of reporting  DOD’s awareness of military participants receiving these benefits. Also,  we compared the data collection and communications processes for DOD  with Standards for Internal Control in the Federal Government, which  state that management should obtain quality information to achieve its  objectives and that it should communicate with external parties regarding  the information that is needed to achieve its objectives. To obtain  information on other food assistance programs available to  servicemembers and their families for which data were not available, we  visited four military installations in the United States and interviewed  officials who administer these programs, officials who assist  servicemembers in need, and visited food pantries, if any, on the  installation. We selected sites to represent each of the military services.  We then refined our site selections to include: locations with a large  population of servicemembers and dependents, a range of cost-of-living  areas (using the BAH rates), and the presence of a food pantry and/or a  WIC program office on the military installation. Specifically, we visited Fort  Hood, Texas; Altus Air Force Base, Oklahoma; Naval Base San Diego,  California; and Camp Pendleton, California. In addition, we visited and  interviewed state and local officials who oversee non-military food  assistance programs at these four geographic locations. Finally, we  interviewed officials from the Navy-Marine Corps Relief Society, Army  Emergency Relief, and the Air Force Aid Society to learn what food  assistance they provide to active-duty servicemembers and their families.
To identify any challenges that active-duty servicemembers encounter  when seeking food assistance, we interviewed military service officials  who assist servicemembers in need of financial assistance, including food  assistance, to gain their perspectives on any challenges that may be  faced by servicemembers attempting to obtain such assistance.  Specifically, we interviewed military Chaplains, First Sergeants and  Command Master Chiefs, financial specialists, and officials from  charitable military organizations, including the Navy-Marine Corps Relief  Society, the Air Force Aid Society, and Army Emergency Relief. We also  interviewed private and local government officials who assist  servicemembers with food assistance, such as SNAP, WIC, summer- meals programs, and food pantries. Further, we interviewed  representatives from advocacy groups who support active-duty families or  try to reduce hunger in America.
Table 2 contains a list of organizations, offices, and military installations  we visited or contacted during our review.
We conducted this performance audit from July 2015 to July 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Listing of Selected Federal Food and Nutrition Assistance Programs
paragraphs: In our April 2010 report, we identified 18 programs that focus primarily on  providing food and nutrition assistance to low-income individuals and  households (see table 3). Federal food assistance programs provide  different types of food benefits to address a variety of needs through a  decentralized service delivery structure of federal, state, and local  agencies and nonprofit organizations. In May 2015, we testified before  Congress that in fiscal year 2014 the four largest food assistance  programs—Supplemental Nutrition Assistance Program (SNAP), the  National School Lunch Program, the Special Supplemental Nutrition  Program for Women, Infants, and Children, and the School Breakfast  Program—accounted for 93 percent of total spending on the 18  programs. We further testified that SNAP, the largest program,  accounted for more than 70 percent of the overall spending total. Fifteen  of the programs are administered by the U.S. Department of Agriculture,  one program is administered by the Department of Homeland Security’s  Federal Emergency Management Agency, and two programs are  administered by the Health and Human Services’ Administration on  Aging.
section_title: Appendix III: Eligibility Requirements for Food Assistance Programs Commonly Used by Active-Duty Servicemembers and Their Families
paragraphs: We obtained copies of eligibility requirements for government food  assistance programs that applicants—whether military or civilian—must  meet to receive benefits, and this appendix summarizes requirements for  the five programs commonly used by servicemembers and families. In  this report, we describe income requirements and how income affects  active-duty servicemembers’ eligibility for government food assistance  programs. In addition to the income requirements, each of these  programs has other requirements that must be met before one may  receive benefits or, in some cases, provisions for specific groups to  receive benefits without regard to the other eligibility requirements. The  requirements for the five programs we found that servicemembers and  families use are described below.
subsections: section_title: Family Subsistence Supplemental Allowance (FSSA)
paragraphs: Title 37, section 402a of the U.S. Code and DOD Instruction 1341.11  require members of the military services serving on active duty to meet  the following requirements to receive FSSA: income, Basic Allowance for  Subsistence (BAS), pay status, dependents, and application.  a.  Income: The income of the servicemember, together with the  income of the rest of the household (if any) of that servicemember,  must be within 130 percent of the federal poverty guidelines.  b.  BAS: Servicemembers must be receiving full or partial BAS.  c.  Pay status: Servicemembers must be in a pay status. When a  servicemember is in a non-pay status for any reason, the  servicemember is not eligible for FSSA during that non-pay  period.  d.  Dependent: At least one person in the household of a  servicemember must be a military dependent for that  servicemember.  e.  Application: Servicemembers must apply and be certified to  receive the FSSA payment.
The National Defense Authorization Act for Fiscal Year 2016 limited  FSSA eligibility to only those servicemembers serving outside the United  States, the Commonwealth of Puerto Rico, the United States Virgin  Islands, or Guam starting October 1, 2016.
section_title: Supplemental Nutrition Assistance Program (SNAP)
paragraphs: Eligibility requirements for SNAP benefits, as laid out in 7 U.S.C. §§ 2014  and 2015 and 7 C.F.R. Part 273, include criteria for financial resources,  income, and employment.  a.  Resources: To be eligible for SNAP, households cannot have  more than $2,250 in countable resources, such as a bank  account, or $3,250 in countable resources if at least one person in  the household is age 60 or older, or is disabled. However, certain  resources are not counted, such as a home and lot, the resources  of household members who receive Supplemental Security  Income (SSI), the resources of household members who receive  Temporary Assistance for Needy Families (TANF), and most  retirement (pension) plans. States may determine whether to  include the value of a vehicle in countable resources, if the state  vehicle allowance standards would result in a household incurring  a lower attribution of resources.  b.  Income: Most households must meet gross- and net-income tests,  but a household with an elderly person or a person who is  receiving certain types of disability payments has to meet only the  net-income test. A household’s gross income cannot exceed 130  percent of the federal poverty guidelines to receive SNAP  benefits. Gross income means a household’s total, non-excluded  income, before any deductions have been made. A household’s  net income cannot exceed 100 percent of the federal poverty  guidelines. According to the USDA, net income is gross income  minus allowable deductions. Deductions allowed are:
20 percent of earned income; a standard deduction of $155 for household sizes of 1 to 3  people, and $168 for a household size of 4 (higher for some  larger households); dependent-care expenses when needed for work, training, or medical expenses for elderly or disabled members that are  more than $35 for the month if they are not paid by insurance  or someone else;  legally owed child-support payments, if a state agency  chooses not to exclude child-support payments from income; and excess shelter costs that are more than half of the  household’s income after the other deductions. Allowable  shelter costs include the cost of fuel to heat and cook with,  cooling, electricity, water, service fees for one telephone, rent  or mortgage payments and property taxes. The amount of the  shelter deduction cannot be more than $504 unless one  person in the household is elderly or disabled. The limit is  higher in Alaska, Hawaii and Guam. Some states allow  homeless households to deduct a set amount ($143) for  shelter costs.  c.  Employment requirement: In general, people must meet work  requirements to be eligible for SNAP. An applicant is ineligible for  SNAP if the individual refuses to register for work, accept an offer  of employment, or participate in an employment and training  program required by a state agency, or the individual voluntarily,  and without good cause, quits a job or reduces hours. In addition,  able-bodied adults without dependents are required to work or  participate in a work program for at least 20 hours per week to  receive SNAP benefits for more than 3 months in a 36-month  period. Some special groups—including children, seniors,  pregnant women, and people who are exempt for physical or  mental health reasons—may not be subject to these  requirements.
The federal law regarding SNAP provides an additional pathway for  financial eligibility to SNAP. This federal law makes households in which  all members are either eligible for or receive cash benefits from TANF,  SSI, or state-financed General Assistance (GA) programs automatically  eligible for SNAP. These households, which have already gone through  eligibility determination for those programs, bypass the income and  resource tests described above and are deemed financially eligible.  Further, under expanded eligibility rules, called “broad-based categorical  eligibility,” states can allow households receiving noncash services  funded by TANF to be automatically eligible for SNAP. States that adopt a  broad-based categorical eligibility policy may increase limits on household  gross income up to 200 percent of federal poverty guidelines. However,  categorically eligible households have their SNAP benefits determined  under the same rules as other households, and while the household may  be categorically eligible, its income may be too high to actually receive a  SNAP benefit.
section_title: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
paragraphs: For WIC eligibility, as laid out in title 42, Section 1786 of the U.S. Code  and 7 C.F.R. § 246.7, applicants must meet categorical, residential,  income, and nutrition-risk requirements.  a. Categorical requirement: The WIC program is designed to serve certain categories of individuals. Therefore, only the following categories of individuals are eligible for WIC: o Pregnant (women determined to have one or more fetuses in utero) o Postpartum (up to six months after the termination of pregnancy) o Breastfeeding (up to the infant’s first birthday)
Infants (up to the infant’s first birthday)
Children (between ages 1 and 5) b. Residential requirement: Applicants must live in the state in which they apply. At state agency option, applicants may be required to live in a local service area and apply at a WIC clinic that serves that area. Applicants are not required to live in the state or local service area for a certain amount of time in order to meet the WIC residency requirement. c.
Income requirement: To be eligible for WIC, applicants must have income at or below an income level or standard set by the state agency or be determined automatically income-eligible based on participation in certain programs.
Income standard: The state agency’s income standard must be between 100 percent and 185 percent of the federal poverty guidelines. According to U.S. Department of Agriculture (USDA) officials, all states have elected to raise the income standard to 185 percent of federal poverty guidelines.
Automatic Income eligible: Some applicants can be determined income eligible for WIC based on their participation in certain programs. These include: individuals who are eligible to receive SNAP benefits, Medicaid, or TANF, individuals who have certain family members eligible to receive Medicaid or TANF, o At state agency option, individuals who are eligible to participate in certain other state-administered programs. d. Nutrition-Risk Requirement: To be certified as eligible for WIC, applicants must be determined to be at nutritional risk. A competent professional authority, such as a physician, registered nurse, or nutritionist, makes that determination through a medical  and/or nutritional assessment. Examples of medical-based  conditions include anemia (low blood levels), underweight, or  history of poor-pregnancy outcome. A dietary-based condition  includes, for example, a poor diet.
section_title: National School Lunch Program (NSLP) and School Breakfast Program (SBP)
paragraphs: Sections 1758 and 1773 of Title 42 in the U.S. Code require that  applicants must meet income requirements to receive free or reduced- price lunches or breakfasts at schools or be a member of a certain group.  The NSLP and the SBP are two different programs but they have the  same eligibility requirements.  a.  Household income requirement: Children are eligible to receive a  free meal if their household income is at or below 130 percent of  the federal poverty guidelines or a reduced-price meal if their  household income is between 130 and at or below 185 percent of  the federal poverty guidelines.  b.  Categorical (or automatic) eligibility requirement: Children are  eligible to receive a free meal based on household participation in  certain other need-tested programs or children’s specified  vulnerabilities (e.g., foster children). A child shall be considered  automatically eligible for a free lunch and breakfast without further  application or eligibility determination if the child is:  in a household receiving benefits through SNAP or Food  Distribution Program on Indian Reservations benefits or TANF  cash assistance. Food Distribution Program on Indian  Reservations is a program that operates in lieu of or  concurrently with SNAP on some Indian reservations; enrolled in Head Start; a runaway, or homeless.  c.  Community Eligibility Provision: A child can receive free meals if  he or she attends a school that has decided to provide free meals  to all its students under the Community Eligibility Provision.  Community Eligibility Provision is an option in NSLP and SBP law  that allows eligible schools and school districts to offer free meals  to all enrolled students based on the percentage of their students  who are identified as automatically eligible from non-household  application sources, primarily direct certification through other  programs. For a school (or school district, or group of schools  within a district) to provide free meals to all children, the following  must occur:  the school(s) must be eligible for Community Eligibility  Provision, based on the share (40 percent or greater) of its  enrolled children that can be identified as categorically (or  automatically) eligible for free meals, and  the school must opt in to Community Eligibility Provision.
section_title: Appendix IV: Comments from the Department of Defense
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Kay Brown, Rachel Frisk, Dawn  Godfrey, Kevin Keith, Amie Lesser, Felicia Lopez, Tamiya Lunsford,  Grant Mallie, Kimberly Mayo (Assistant Director), Shahrzad Nikoo, Sara  Pelton, Richard Powelson, Monica Savoy, and John Van Schaik made  key contributions to this report.