Federal Low-Income Programs: Eligibility and Benefits Differ for Selected Programs Due to Complex and Varied Rules
Published: 2017-06-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Various federal programs provide cash assistance, food, housing, and health care to millions of individuals, families, and households whose income falls below defined levels and who meet other eligibility requirements. As GAO previously reported, the numerous financial and nonfinancial rules for determining eligibility for such low-income programs can confuse applicants and increase program administration challenges. GAO was asked to examine eligibility rules for low-income programs.
This report examines (1) the ways in which eligibility rules and benefits for selected federal low-income programs vary across the programs; and (2) what is known about challenges associated with efforts to streamline these rules. GAO reviewed relevant agency guidance and other information provided by agencies and analyzed financial eligibility rules and benefits across six low-income programs. GAO confirmed all information on program rules with the respective administering agencies. GAO selected these programs because they are among the largest of the federally funded programs addressing low-income people's basic needs and they illustrate variations in eligibility rules among low-income programs. GAO also reviewed previous GAO reports and selected reports from the Congressional Research Service and other knowledgeable research and policy organizations.
section_title: What GAO Found
paragraphs: Six key federally funded programs for low-income people vary significantly with regard to who is eligible, how income is counted and the maximum income applicants may have to be eligible, and the benefits provided. In fiscal year 2015, the most current data available, the federal government spent nearly $540 billion on benefits for these six programs—the Earned Income Tax Credit (EITC), Medicaid, the Housing Choice Voucher program, Supplemental Nutrition Assistance Program (SNAP), Supplemental Security Income (SSI), and Temporary Assistance for Needy Families (TANF). The target population for each of these programs differs, for example, people who are elderly or disabled or who have dependent children. Further, some programs have conditions for continued eligibility, such as participation in work activities under TANF. The six programs also vary in what income is and is not counted when determining an applicant's eligibility. For example, certain programs, such as SNAP, disregard a portion of earned income, while others do not. The maximum amount of income an applicant may have and still be eligible for benefits, which is determined for some programs at the federal level and for others at the state or local level, also differs significantly. As of December 2016, this amount ranged from $5,359 per month for one state's Medicaid program to $0 per month in one state for TANF cash assistance, for a single parent with two children. Benefit levels also differed across the six selected programs, with average monthly benefits for these programs ranging in fiscal year 2015 from $258 for SNAP to $626 for Housing Choice Vouchers, and four of the six programs adjust benefits annually.
Legal, administrative, and financial constraints pose challenges to efforts to streamline varying eligibility rules for federal low-income programs, according to GAO's current and previous work. A key challenge is that the programs are authorized by different federal statutes enacted at different times in response to differing circumstances. Other laws, such as appropriations laws, can also have an impact on federal programs and their rules. As a result, streamlining eligibility rules would require changing many laws and coordination among a broad set of lawmakers and congressional committees. A further challenge is that a different federal agency or office administers each program GAO reviewed. For some of these programs, such as TANF, state governments also establish some program rules, making it more difficult to streamline rules at the federal level within or across these programs. Finally, financial constraints may also affect efforts to streamline program rules. For example, if rule changes raise the income eligibility limit in a program, more people may become eligible and that program's costs may increase. Despite these challenges, Congress, federal agencies, and states have taken some steps to streamline program administration and rules, such as by making greater use of data-sharing where permitted by federal law and aligning programs' applications and eligibility determination processes. For example, SSI recipients in most states are automatically eligible for Medicaid, and GAO previously reported that some states have integrated the SNAP eligibility process with other low-income programs, such as through combined applications and common eligibility workers.
section_title: What GAO Recommends
paragraphs: GAO is not making recommendations in this report.

section_title: Letter
paragraphs: Various federal programs provide cash or noncash assistance to millions  of individuals, families, or households whose incomes fall below defined  levels and who meet other eligibility requirements. Many of these  programs provide supports to address a range of basic needs for low- income people, including cash assistance, food, housing, and health care.  According to the most recent agency data available, in fiscal year 2015,  the federal government expended nearly $540 billion in benefits for six  programs for low-income people: the Earned Income Tax Credit (EITC),  Medicaid, the Housing Choice Voucher program, Supplemental Nutrition  Assistance Program (SNAP), Supplemental Security Income (SSI), and  Temporary Assistance for Needy Families (TANF).
As we have reported in the past, the numerous financial and nonfinancial  eligibility rules for federal low-income programs can confuse applicants  and increase program administration challenges.1,  For applicants, these  rules have sometimes made it difficult and burdensome to navigate the  application process for some programs. For program staff, separate rules  for each program mean that staff have to keep track of and apply different  rules when determining eligibility, even though they may collect and  document much of the same personal and financial information from  applicants. In light of these issues, the Senate Committee on the Budget  asked us to examine eligibility rules and benefits for low-income  programs.
In this report, we use the term “rules” to refer generally to the programs’ requirements,  regardless of the source of those requirements, which may be found in federal or state  statutes or regulations, depending on the program.
This report examines (1) in what ways eligibility rules and benefits for  selected federal low-income programs vary across these programs; and  (2) what is known about challenges associated with efforts to streamline  varying eligibility rules for federal low-income programs.
To address the first question, we analyzed and compared the target  populations and rules for determining eligibility and benefits—including  financial and other eligibility rules—across six federally-funded low- income programs: (1) EITC, (2) Medicaid, (3) Housing Choice  Vouchers, (4) SNAP, (5) SSI, and (6) TANF. We selected these six  programs because they are among the largest of the federally-funded  low-income programs addressing basic needs, and they illustrate  similarities and variations in how financial eligibility is determined among  such federally-funded low-income programs. The programs we selected  were intended to illustrate this variability rather than serve as a  comprehensive inventory of all of the eligibility requirements or an  exhaustive description of differences among programs. We obtained information for these comparative analyses, including the program target  populations and eligibility and benefit rules, using a two-step process.  First, we reviewed relevant federal agency reports, documents, and  agency guidance, as well as GAO and Congressional Research Service  (CRS) reports describing program eligibility rules and benefits. In some  cases, we also reviewed relevant federal laws and regulations, although  we did not conduct a comprehensive legal review. Second, to ensure the  accuracy of this information and our analysis, we obtained confirmation of  the applicable program information and rules as of December 2016 from  the specific agency that administers each program, such as the U.S.  Department of Agriculture, Food and Nutrition Service (FNS) for SNAP.
To address the second question, we relied primarily on findings and  analyses from previous GAO reports on the six selected programs. To  supplement our prior work, we also reviewed CRS and other  governmental reports on low-income programs, as well as selected  reports and testimony by research and policy organizations with expertise  in this area.
We conducted this performance audit from May 2016 through June 2017  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
paragraphs: The six selected federal programs have varying purposes and are  designed to target different segments of the low-income population,  according to information confirmed by the administering agencies (see  table 1). For example, EITC targets working families, whereas SSI targets  the elderly, blind, and disabled. Because potential participants must  generally meet a test of financial need in order to be eligible for benefits,  these programs are commonly referred to as “means-tested programs.”  Three of the programs—EITC, SSI, and TANF—provide direct cash  assistance to recipients, while the other programs provide an in-kind  benefit, meaning that the recipient receives a good or service rather than  cash. The six programs serve millions of low-income people, ranging  from nearly 69 million individuals a month for Medicaid to about 4 million  individuals a month for TANF in fiscal year 2015, according to our  analysis of agency data, as confirmed by the agencies.
Medicaid is the largest program in terms of expenditures on benefits  among the six selected programs, according to information provided by  the administering agencies, totaling $329.73 billion in federal spending for  the entire Medicaid population in fiscal year 2015 (see fig.1). Federal  spending on benefits for the five other programs ranged from $4.16 billion  for TANF cash assistance to $66.60 billion for SNAP in that year. In TANF  and Medicaid, states and the federal government generally share in the  cost of benefits, whereas benefits are entirely federally funded for EITC,  SNAP, SSI, and Housing Choice Vouchers.
Several federal departments and agencies or offices administer and  oversee the six selected low-income programs (see table 2).
The funding structure of these low-income programs differs, which to  some extent may affect the number of program recipients. SNAP, EITC,  SSI, and Medicaid are open-ended entitlement programs, which means  that the government is legally required to make payments to individuals or  families who meet the requirements established by law. As a result, all  individuals or families who apply for these programs and are eligible are  entitled to benefits. In contrast, the Housing Choice Voucher and TANF  cash assistance programs are not entitlement programs, and the number  of recipients may be limited, in part, by these programs’ funding  amounts. Programs also differ in their source of funding: some  programs are entirely federally-funded, while in other programs, the  states and the federal government each contribute some funding for  benefits, program administration, or both.
Partly because the programs have different purposes and to some extent  target different populations, the six low-income programs vary in the  extent of their reach. Figure 2 shows the number of program recipients,  according to agency data, as a percentage of the total U.S. population.  As a general comparison, in 2015, Medicaid served 22 percent of the  population, or more than 1 in 5 people, while TANF served 1 percent of  the total U.S. population in that year.
subsections: section_title: Process for Determining Eligibility
paragraphs: Common basic elements exist in how the six low-income programs  determine program eligibility. Figure 3 provides a conceptual overview  of the types of elements typically considered when determining eligibility  for these low-income programs. Generally, several factors are taken into  consideration to assess applicant eligibility. For determining financial  eligibility, the factors commonly considered include how much income the  applicant has (both earned, such as wages, and unearned, such as  income from other public benefit programs), as well as, for some  programs, the applicant’s assets. Further, certain nonfinancial factors  may be taken into consideration to assess applicant eligibility, such as  whether the applicant has a dependent child or a disability or is working. If  an applicant is found to be eligible for a program, the benefit amount they  are eligible for is then determined using the benefit rules for that particular  program.
section_title: Selected Federal Low-Income Programs Vary with Regard to Target Populations, Rules for Counting Income and Assets, and Benefits Selected Programs Target a Range of Low-Income Populations, Including People Who Are Elderly or Disabled or Those with Dependent Children, and Some Require Work
paragraphs: In addition to having different program purposes, the six programs we  reviewed target a range of low-income populations, including people with  some earnings, people who are elderly or disabled, or families with  dependent children, according to our analysis of agency documents, as  confirmed by the agencies (see table 3). The programs’ nonfinancial  eligibility rules establish the specific characteristics an individual or  household must have, if any, in order to be eligible for the program. For  example, to qualify for TANF, families generally must have a dependent  child, while for SSI, the applicant must be 65 years old or older, blind, or  have a disability that meets certain requirements.
Federal low-income programs sometimes have overlapping target  populations, and program rules for some programs allow those who  qualify for one program to be automatically eligible for another—also  known as categorical eligibility—which, as we have previously reported,  can both ease access to these programs as well as reduce administrative  costs. For example, according to SSA, in most states SSI recipients are  automatically eligible for Medicaid, and we have previously reported that  some TANF recipients are automatically eligible for SNAP. Specifically,  TANF cash assistance recipients are categorically eligible for SNAP, and  some states have opted to extend categorical eligibility to households  authorized to receive certain TANF or state maintenance of effort (MOE)- funded noncash services under broad-based categorical eligibility (BBCE)  policies.
Nonfinancial eligibility rules for some of the programs we reviewed also  include requirements that participants must comply with as a condition of  eligibility for benefits or services, such as participation in work or work- related activities in three of the programs (see table 4). For example,  federal TANF rules require states to engage a certain percentage of  families receiving cash assistance in specified work-related activities,  such as job search and job readiness assistance, if there is an individual  in the family who is generally required to work. EITC is unique in that its  target population is working low-income people, and therefore, EITC rules  require work for initial eligibility. Since EITC is administered through the  tax system, it generally requires tax filers who claim the credit to have  earned income—as its name suggests—unlike the other programs we  reviewed.
section_title: Selected Programs Differ Greatly in How Income Is Counted and How Much Income Applicants May Have to Be Eligible
paragraphs: The six low-income programs we reviewed use different rules to  determine the financial eligibility of program applicants, according to our  analysis of agency documents, as confirmed by the agencies. These  variations affect whose income is counted, what income is and is not  counted, whether expenses are deducted from income, and how much  income applicants may have and still be eligible.
subsections: section_title: Whose Income Is Counted
paragraphs: The six programs we reviewed differ not only in their definitions of who  the benefit is provided to once eligibility is determined—which we refer to  as the “applicant unit”—but also in how they count the income of different  people when determining applicant eligibility. For some programs, such  as SSI, the applicant unit is the individual, while for others, such as  SNAP, the unit is the household (see table 5). Further, while programs  may use similar terminology, there is no single definition of “family” or  “household” used across these low-income programs—the same term  may mean different things depending on the program. For purposes of  counting income, for example, both TANF and the Housing Choice  Voucher program count the income of individuals in a “family.” However,  in the case of the Housing Choice Voucher program, for example, a  single person living alone or a group of persons living together is  considered a “family,” while for TANF cash assistance, states determine  what constitutes a “family” and the family must generally include a  dependent child. In addition, in some programs, the applicant unit differs  from whose income is counted when determining financial eligibility. For  example, in SSI, while the applicant is typically an individual, the income  of the applicant’s parent or spouse may be considered when determining  eligibility, if that person is living in the applicant’s household.
The programs we reviewed also differ in how they treat an applicant’s  earned income—or income earned from working—for the purposes of  eligibility determination, according to our analysis of agency  documentation, as confirmed by the agencies, with some programs  structuring their earned income rules to incentivize work, as we have  previously reported (see table 6). For example, when determining  income eligibility for SNAP, federal rules disregard 20 percent of the  applicant household’s earned income. In other words, if an applicant has  $1,000 in monthly earned income, only $800 is considered when  calculating the household’s income eligibility for SNAP. For TANF,  states determine earned income rules, and according to HHS, almost all  states disregard some earned income, either as a percentage of  earnings, a set dollar amount, or both, although the percentage or amount  differs by state.
The programs we reviewed also differ greatly in how they treat an  applicant’s unearned income—which may include benefits received from  other federally-funded programs for low-income people—for the purposes  of eligibility determination (see table 7). A low-income family is likely to be  eligible for and may participate in more than one low-income program.  However, not all of those eligible received a benefit. We have previously  reported that families receiving TANF cash assistance generally also  receive Medicaid and SNAP. However, because of differences in these  programs’ eligibility rules related to unearned income, TANF benefits are  counted as income when determining SNAP eligibility but not counted as  income when determining Medicaid eligibility, according to our analysis of  agency documents, as confirmed by the agency. In contrast, the cash  benefit received from the refunded portion of EITC is not counted as  income when determining eligibility for any of the other selected  programs. According to a 2015 CRS analysis, of those who received a  benefit from one of nine major federally funded low-income programs, an  estimated 41 percent received benefits from one program and an  estimated 27 percent received benefits from two programs. The  remaining families received benefits from three or more programs.  According to CRS, 18 percent of families received benefits from three  programs, 9 percent received benefits from four programs, and less than  5 percent received benefits from five or more programs. The nine low- income programs in CRS’s analysis included five of the six we reviewed  for this report.
In calculating applicants’ income levels to determine eligibility, some of  the low-income programs we reviewed deduct certain types of expenses  from income, such as those for child care, utilities, and shelter, according  to our analysis of agency documentation and information provided by  agencies, as confirmed by the agencies. Programs may allow the  deduction of certain types of expenses when determining applicant  eligibility to ensure that the applicants’ financial circumstances and ability  to meet certain basic needs are more fully captured. For example,  Housing Choice Voucher and SNAP both deduct child care expenses  when determining program eligibility, while EITC and Medicaid take these  expenses into account in other ways (see table 8). (For additional  deductions for selected other expenses, see appendix II.)
A fundamental difference among the six programs we reviewed is the  variation in the income limits used for determining applicants’ program  eligibility, according to our analysis of agency data and documentation, as  confirmed by agencies. These programs differed in the ways they  measure applicants’ income, the standards and methods used to  determine the maximum amount of income an applicant may have and  still be eligible for the program, whether this amount is set nationwide or  varies by state or locality, and the amount of the income limit itself. The  various standards and methods used to set income limits by the selected  programs include a fixed dollar amount, a percentage of the federal  poverty guidelines (FPG) or Area Median Income (AMI), or Modified  Adjusted Gross Income (MAGI)(see table 9). For two of the programs— EITC and SSI—the maximum amount of income an applicant may have  to be eligible is a federally-set dollar amount that applies nationwide;  however, that amount differs by program. For the other four low-income  programs we reviewed, the rules for determining the maximum amounts  of income an applicant may have and still be eligible, the amounts  themselves, and whether they are set nationwide or vary by state or  locality, vary significantly, according to our analysis of agency data as  confirmed by agencies. For Medicaid, TANF, and in states that have  implemented SNAP BBCE policies, states or localities determine financial  eligibility rules for applicants, generally within certain federal guidelines.  For example, under SNAP BBCE policies, states have the flexibility to  adopt policies that allow certain applicants with incomes up to 200  percent FPG to be eligible, whereas federal rules generally allow  applicants with incomes up to 130 percent FPG to be eligible. In the  case of TANF, states have flexibility in how they establish eligibility,  including choosing both the type of measure and income level they use.  For Medicaid and the Housing Choice Voucher program, there are also  different income limits for different populations within the program.
To illustrate the different income limits used for these programs, we  analyzed maximum allowable income using a common metric—dollars  per month—for programs that have nationally set income limits (see  figure 4) and for programs with a range of maximum allowable income  due to state variation (see figure 5). For the purposes of illustrating  maximum allowable income across these programs, we use a family of  three—a single mother with two children—living in their own household,  because we have previously found this to be a common recipient unit in  federal low-income programs, such as TANF. Although these are the  maximum allowable amounts of income such families may have to be  eligible for each program, these amounts are not fully comparable  because the calculation of this amount differs for each program by the  factors discussed earlier in this report, such as whose income is counted.  Also as already discussed, for an applicant, having income below the  relevant threshold is one of the multiple factors that may be assessed  when determining eligibility for each program. (For a comparison of  maximum monthly income for all six programs, see app. III.)
section_title: Some Programs Define Limits on Assets an Applicant May Have to Be Eligible
paragraphs: In addition to having income tests, some programs set certain limits on  the assets that an individual or family may hold in order to be eligible for  the program, while others do not, according to our analysis of agency  data and documentation, as confirmed by the agencies. Assets—referred  to as “resources” by some programs—generally include financial  resources—such as cash held in checking and savings accounts,  individual retirement accounts, 401(k)s, and other accounts that can be  readily transferred into cash—and nonfinancial resources, such as a  home or car. Similar to income limits, three of the six selected  programs—SSI, TANF, and SNAP under federal rules—have federally set  limits on the amount or type of financial assets that an individual or family  may have in order to be determined eligible for benefits. For example, to  qualify for SSI, the limit for countable assets is $2,000 for an individual  and $3,000 for a married couple. However, certain nonfinancial assets,  such one vehicle, do not count toward this limit. For SNAP, under federal  rules, there is a limit of $2,250 in countable resources or $3,250 in  countable resources if at least one person is age 60 or older or is  disabled, and since 2008, these limits have been adjusted annually and  rounded to the nearest $250 based on changes to the Consumer Price  Index (CPI).
In recent years, some states have moved away from having asset limits  for certain low-income programs. For example, as of August 2016, 34  states and the District of Columbia have adopted SNAP BBCE policies  that removed asset limits from their financial eligibility determinations for  those deemed eligible using BBCE. In TANF, asset limits are determined  by the state, and as of August 2016, 8 states did not have asset limits,  while 43 states had set varying limits on assets (see figure 6). Other low- income programs we reviewed—EITC, Housing Choice Vouchers, and  Medicaid for non-elderly, non-disabled (MAGI) populations—have no  restrictions on assets. However, financial assets that produce unearned  income can be taken into account when determining applicant eligibility.  For example, for EITC, applicants’ income from any investments must be  $3,400 or less per year.
Asset tests are further complicated because of the differences in how the  equity in vehicles is treated when determining assets. Vehicle asset rules  exist in certain programs, and these rules vary, not only across programs,  but across states as well. In one program, a vehicle used to access work  may be disregarded; in another program, a certain portion of the value of  the vehicle may be disregarded. In TANF, treatment of vehicles is at the  state’s discretion and most states disregard $4,650 or more of the value  of one vehicle. For SNAP, certain vehicles are excluded in their entirety,  or states may opt to substitute their TANF vehicle rules, according to  USDA.
section_title: Average Monthly Benefits for Selected Programs Range from $258 to $626, and Vary by Annual Adjustment
paragraphs: Average benefits vary across the six selected programs due in part to  differing benefit purposes and other factors, according to our analysis of  agency documentation and information, as confirmed by the agencies.  For the four programs that provide monthly benefits—Housing Choice  Vouchers, SNAP, SSI, and TANF—average benefit levels ranged from  $258 monthly for SNAP to $626 monthly for Housing Choice Vouchers in  fiscal year 2015. These average benefit amounts—for Housing Choice  Vouchers, SNAP, and TANF—are per household, while the SSI average  benefit is per individual. The EITC provided a one-time annual benefit of  more than $2,455 on average in 2016, based on tax returns filed for 2015,  which, for comparison, converts to $205 per month. (See table 10). There  is no average benefit amount for Medicaid since its benefits are provided  in the form of health care services to individuals. These variations in  average benefit amounts are due in part to differing program and benefit  purposes and other factors, according to our analysis of agency  documentation and other governmental reports. For example, the SNAP  benefit amount is structured to make up the difference between the cost  of purchasing a nutritionally adequate low-cost diet and 30 percent of net  household income, because a household is expected to spend about 30  percent of its net income on food, according to FNS. Alternatively, the  SSI benefit is meant to provide a basic level of income for those who are  elderly, blind, and disabled.
Four of the five programs that provide benefit amounts to recipients  directly or indirectly adjust benefits for inflation, while one program varies  by state. Whether or not benefits are adjusted for inflation affects the  value of the benefit over time. EITC, SSI, and SNAP explicitly adjust  benefits for inflation, while the amount of a Housing Choice Voucher is  adjusted in response to changes in area rental costs. According to CRS,  TANF benefits for families are not automatically adjusted for inflation by  the states and have lost considerable value in terms of their purchasing  power over time. We have previously estimated that annual aggregate  cash benefits under 2005 TANF rules were 17 percent lower than they  were under 1995 rules. More recently, CRS has found that between  1981 and 2013, the inflation-adjusted value of the maximum TANF cash  assistance benefit for needy families in the median state declined by 45  percent.
section_title: Legal, Administrative, and Financial Constraints Challenge Efforts to Streamline Rules for Low-Income Programs Several Challenges Hinder Efforts to Streamline Program Rules
paragraphs: Legal, administrative, and financial constraints pose challenges to  streamlining or better aligning varying eligibility rules for low-income  programs, according to our previous work. The issue of streamlining, and  its feasibility, has been a concern for decades. As we noted in our  earlier work, the complexity and variability in programs’ financial eligibility  rules have had negative consequences for both program administration  and family access to assistance, according to policy experts and  researchers. For example, in 2002 we found that staff administering  each program collected much of the same personal and financial  information from applicants to determine program eligibility, leading to  time-consuming and inefficient administrative processes that can  contribute to overall costs. Further, people seeking aid from more than  one low-income program often must visit multiple offices and provide the  same information numerous times, according to our prior work.  However, just as the advantages of simplifying financial eligibility rules  have been acknowledged, there has also been a general recognition that  achieving substantial improvements in this area is difficult.
A key challenge to streamlining eligibility rules for these low-income  programs is that the programs are authorized by different federal statutes,  which establish many of the program rules. These different statutes were  enacted—and amended—at different times in response to differing  circumstances. The statutes originate with numerous congressional  authorizing committees. For example, the House Energy and Commerce  Committee and the Senate Finance Committee are the authorizing  committees for Medicaid, while the House Financial Services Committee  and Senate Banking, Housing, and Urban Affairs Committee are the  authorizing committees for the Housing Choice Voucher program (see fig.  7). Other laws, such appropriations acts, can also have an impact on  federal programs and their rules. Modifying eligibility rules to bring them  more in line with each other would require changing many laws and  coordination among a broad set of lawmakers, including multiple  congressional committees.
Another challenge to streamlining stems from the multiple government  entities involved in administering and funding each program and the  varied administrative relationships between the federal and state levels of  government by program. To start with, a different federal agency or office  administers each program we reviewed. For example, FNS administers  SNAP, CMS administers Medicaid, and the Office of Public and Indian  Housing within HUD administers the Housing Choice Voucher. These  different federal agencies generally develop regulations separately for  each program, which may affect program rules. Furthermore, as  discussed earlier, state governments are also involved in administering  and funding some of these programs. Specifically, for programs that allow  state flexibility, state governments also establish some program rules,  making it more difficult to streamline or align program rules within or  across these programs at the federal level. For example, for TANF cash  assistance, the development of eligibility and benefit rules is primarily  delegated to state agencies administering the program, while for SNAP,  state agencies have some flexibility in determining eligibility rules within  federally-established parameters. Regarding program funding, while  states may partially fund TANF cash assistance benefits, the federal  government funds the full cost of SNAP benefits. As a result of these  different roles, streamlining eligibility rules and benefits across multiple  programs would entail, in part, modifying and realigning complex  administrative relationships among a range of federal and state  government entities.
Finally, financial or program cost implications pose a major challenge to  streamlining financial eligibility and benefit rules for low-income programs, according to our previous work. Modifying financial eligibility rules for  purposes of simplifying them or making them more consistent across  programs will likely result in changes to the number of people who are  eligible for assistance, and may also affect the benefit amounts they  receive, as well as overall program costs. Depending on the  modification, and the current rules of each program affected, changes  made to streamline rules will affect each program’s recipients and costs  differently. On the one hand, if such rule changes have the effect of  raising a program’s income eligibility limits, more people will be eligible for  assistance and that program’s costs may increase, particularly for  entitlement programs. For example, according to our earlier work, SNAP  program participation more than doubled and costs quadrupled over a 10- year period, largely due to the 2008 recession; however, a factor that  contributed to both increases was that some states aligned their SNAP  income eligibility limits with the higher limits used in other low-income  programs under the BBCE policy option. On the other hand, if such rule  changes have the effect of lowering a program’s income eligibility level,  some people will no longer be eligible for assistance from that program,  thereby potentially lowering program costs.
subsections: section_title: Agencies and States Have Made Efforts to Streamline Rules within Program Constraints
paragraphs: Despite these challenges, Congress, federal agencies, and states have  taken some steps to streamline eligibility rules, according to our prior  work. These include establishing automatic or categorical eligibility  among programs, making greater use of technology and data-sharing  among low-income programs, and aligning application and eligibility  determination processes for multiple programs.
Automatic or categorical eligibility: These policies—where allowed under  federal law—can simplify the eligibility determination process for both  applicants and caseworkers by increasing consistency in income and  resource limits across programs. For example, in addition to SNAP BBCE  policies already discussed (which make households that receive noncash  services funded by TANF categorically eligible for SNAP in some states),  SSI recipients in most states are automatically eligible for Medicaid health  insurance, and if they live alone or in households in which all members  receive SSI benefits, they are automatically eligible for SNAP. In  another example, recipients of Medicaid, TANF, or SNAP are  automatically deemed income-eligible for the Special Supplemental  Nutrition Program for Women, Infants, and Children (WIC)—a WIC policy  known as adjunctive eligibility that is similar to categorical eligibility.  Finally, under the federal school meals programs’ direct certification policy, students who receive SNAP benefits are automatically certified as  eligible for free school meals. According to our prior work, this policy not  only eased access for eligible students but also improved program  integrity, because of SNAP’s more detailed certification process  compared to the school meals programs. Overall, we found in our prior  work that such policies can ease the administrative burden for  participants as well as save resources, improve productivity, and allow  staff to focus more time on performing essential program activities.
Technology and data sharing: Computer systems can be used as a tool to  carry out joint eligibility determination processes that streamline program  administration for staff. Data-sharing arrangements, where permitted by  federal law, allow programs to share client information that they otherwise  would each collect and verify separately, thus reducing duplicative effort,  saving money, and improving integrity, according to our earlier work.  More specifically, with data sharing, staff may use existing data sources  to prepopulate forms, thereby reducing the need for clients to provide the  same information and documentation to multiple agencies. Staff may also  use existing reliable data sources to automate the verification of  information instead of conducting manual checks. For example, state  agencies administering SNAP were able to determine SSI recipients’  eligibility for SNAP benefits by receiving verified electronic data from  SSA, without having to separately collect and verify applicant information,  an arrangement that officials said saved administrative dollars and  reduces duplicative effort across programs, according to our prior work.
In contrast, we recently found that states are experiencing barriers to  using data matches for certain other low-income programs. For example,  in a 2016 report we found that state staff who administer both SNAP and  Medicaid were not allowed to use benefits or earnings information from a  federal data services hub created for Medicaid to determine SNAP  eligibility; as a result, staff would need to conduct duplicative data  matches to verify some of the same information for the same  household.
Flexibility to align application and eligibility determination processes: In  addition to helping streamline the application process by making greater  use of call centers and online applications in some programs, some  states have also taken other steps to align application and eligibility  determination processes, according to our prior work. Exercising such  flexibilities, when available to states, can help ease access and  streamline the process for both recipients and administrators. For  example, some states reported that they integrated aspects of the SNAP  eligibility process with those of other programs, such as through  combined applications, common eligibility workers, or integrated or linked  eligibility systems, according to our 2017 report. Overall, according to  our state survey in this report, we found that SNAP eligibility processes  were most commonly integrated with state TANF cash assistance  programs (44 states), as well as with state Medicaid programs, although  to a somewhat lesser degree. In another example, known as the  Express Lane Eligibility option, states can choose to evaluate children’s  eligibility for Medicaid or CHIP by using findings—such as determinations  regarding a family’s income—made by other agencies, such as those  administering SNAP or TANF. Further, while states administer the  Medicaid program, SSI recipients’ eligibility for Medicaid is sometimes  determined by the Social Security Administration (SSA). We previously  reported that as of May 2016, 33 states and the District of Columbia had  agreements with SSA to determine SSI recipients’ eligibility for Medicaid,  according to SSA. In these states, the SSI application is also the  Medicaid application.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Departments of Agriculture  (USDA), Health and Human Services (HHS), Housing and Urban  Development (HUD), and the Treasury; and the Social Security  Administration (SSA). With the exception of HUD, which provided no  comments, the agencies provided technical comments, which we  incorporated as appropriate.
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 Secretaries of the Department  of Agriculture, HHS, HUD, and the Treasury; the Acting Commissioner of  the SSA; 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 larink@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 IV.
section_title: Appendix I: Estimated Number of People Eligible for Selected Low-Income Programs Compared with Program Recipients
paragraphs: One measure of a program’s reach is the program participation rate, or  the percentage of those eligible who receive benefits from a program.  According to a December 2015 Congressional Research Service (CRS)  analysis of the latest data available for subsidized housing, Supplemental  Security Income (SSI), the Supplemental Nutrition Assistance Program  (SNAP) and Temporary Assistance for Needy Families (TANF), the  estimated proportion of those eligible who received benefits in 2012  varied substantially, and not all of those eligible actually received  benefits. (See fig. 8.) For the entitlement programs—those legally  required to provide benefits to all those who apply and qualify (SNAP,  EITC, and SSI)—the estimated proportion of eligible people who were  enrolled ranged from 66.6 percent to 80 percent. In contrast, for the non- entitlement programs, the estimated proportion of eligible people who  were enrolled was 18.2 percent for subsidized housing and 28.4 percent  for TANF.
The gap between those eligible for these programs and those receiving  benefits may be explained by several factors, including program funding  structure, the type of benefits provided, ease of access to the programs,  and applicants’ lack of awareness and misperceptions about the  programs, among other things.
The program’s funding structure may contribute to a gap between the  number of eligible people and the number of recipients. For example,  for non-entitlement programs, such as TANF and Housing Choice  Vouchers, funding amounts may limit the number of people served.  Because of this, states and localities sometimes ration aid, using  mechanisms such as waiting lists for housing.
The type and amount of benefits can also affect program participation.
In our earlier work, we reported that participation rates tended to be  higher among subgroups of people eligible for larger benefits and  among programs that provide cash benefits rather than direct  services. Specifically, in our previous work, one of the reasons we  found for the decline in TANF participation was a decline in the annual  aggregate cash benefit amounts, which were 17 percent lower under  2005 program rules than they were under 1995 program rules.
Factors that influence the ease with which potential participants can  access a program—including office location and hours as well as the  ease with which program participants can use their benefits—can also  affect the participation rate. For example, a 2012 Congressional  Budget Office report found that the increase in the rate at which  eligible people received SNAP benefits between 2007 and 2011 was  likely due in part to changes in the program’s administration that made  it easier for people to apply for and continue receiving benefits—such  as greater use of online applications, mail-in renewals, and phone  interviews—as well as to the poor economy, which reduced people’s  income and caused longer periods of need, prompting more people  who were already eligible for the program to apply. In contrast, we  found in our 2005 report that it was difficult for some participants to  use Housing Choice Vouchers and Medicaid, as some service  providers, such as landlords or health care providers, would not  exchange their services for program benefits.
Lack of awareness about program benefits on the part of the eligible  population or misconceptions about eligibility can affect the overall  number and characteristics of people who participate. In our 2005  work, we reported that several EITC, Medicaid, Food Stamp, and SSI  studies indicated that one of the primary barriers to participation was  that individuals did not know that they were eligible for these benefits.  We further reported that for some individuals—like the elderly and  non-English speakers—this unfamiliarity with program benefits was  even more widespread, creating a larger barrier to participation and  an under-representation of these individuals in the caseload.
Finally, eligible families also choose whether to participate in a  program in response to their personal feelings about government  assistance programs and their individual circumstances. For example,  according to our previous work, changes made to allow households to  apply for SNAP online or by phone lowered the stigma associated  with going to a public assistance office and may have contributed to  an increase in SNAP participation. Also as we previously reported,  the sharp declines in eligible families’ participation in TANF cash  assistance from 1995 to 2005 resulted from, among other things, the  dynamics of family decision-making in response to TANF policies,  such as mandatory participation in work activities. Specifically, we  found that families eligible for TANF cash assistance often had  characteristics that make employment difficult, such as poor health,  low educational attainment, or limited English proficiency, which may  affect their decisions to apply for TANF.
section_title: Appendix II: Selected Deductions for Calculating Income for Determining Program Eligibility
section_title: Appendix III: Maximum Monthly Income an Applicant May Have and Still Be Eligible for Six Selected Low-Income Programs
paragraphs: There is no single maximum income amount an applicant may have to be  eligible for the six federal low-income programs we reviewed, and the  amount of allowable income varies significantly among the programs,  according to data confirmed by the administering agencies. Figure 9  shows this variation by presenting the maximum income limits for EITC,  SSI, and SNAP under federal rules, as well as the median amount (50th  percentile) of the range of maximum income limits for the 48 contiguous  states and Washington D.C. for the programs with varying income limits— Housing Choice Vouchers, Medicaid, SNAP under state BBCE policies,  and TANF. EITC has the highest maximum income allowed, and TANF,  at well under the federal poverty guideline, has the lowest median  maximum income allowed.
section_title: Appendix IV: GAO Contact and Staff Acknowledgements
subsections: section_title: GAO Contact
section_title: Staff Acknowledgements
paragraphs: In addition to the contact named above, Rachel Frisk (Assistant Director),  Deborah A. Signer (Analyst-in-Charge), Kay E. Brown, Gale C. Harris,  Kelly Snow, and Srinidhi Vijaykumar made key contributions to this report.  Also contributing to this report were James Bennett, Sarah Cornetto,  Kirsten Lauber, David Lin, Theresa Lo, Sheila McCoy, Jessica Orr, Jason  Palmer, Gloria Proa, David Reed, Almeta Spencer, Rebecca Kuhlmann  Taylor, and Max Sawicky.