Date: 1993-02-03
Speaker: JAMES FOWLER (republican)
Chamber: S

General Accounting Office. Washington. DC. DEAR MR. FOWLER: This letter Is offered for your consideration when preparing General Accounting Offices (GAO) report back to Congress regarding two Indian reservation provisions mandated in the. Mickey Leland Domestic Hunger Relief Act. Reservation provisions of great concern to the South Dakota Department of Social Services and to many nf our reservation recipients include a thirty day staggered Issuance rule and the prohibition of monthly reporting retrospective budgeting on Indian reservations. South Dakota has nine Indian Reservations. The Oglala Sioux Reservation was included in the initial GAO report on food assistance programs on Indian Reservations. Staggered Issuance--Section 1728 of Public Law 101824 requires staggered issuance throughout the entire month on Indian reservations. Please reference the attached letter to FNS from Secretary James W. Ellenbecker regarding proposed rules published May 20. 1991. which reflects reservation recipiants fears about staggered issuance. Their concerns were gathered in a South Dakota survey conducted in June. 1991 in which fortyfour percent of active food stamp reservation households responded (see attachment one). Survey results voice the same transportation difficulties described in your report. A thirty day staggered issuance will spread issuances over the entire month and make carpooling impossible. Currently. common practice on South Dakota reservations is for those with vehicles to charge $20 to $50 for a ride to purchase groceries when the transporter must make a special trip. Staggered Issuances will greatly increase these "special tripe" and cause great financial hardship for approximately half of the reservation food stamp families without transportation. Staggered issuance was also mandated due to general comments to the GAO that grocery prices are higher during regular issuance schedules. GAO did not prove whether these statements were in fact valid. FNS staff from the Bismarck. North Dakota. office did visit several grocery stores to determine if grocery prices fluctuate according to food stamp issuance dates. Three reservations stores and six nearreservations stores were visited (see attachment two). Four of the six small towns visited are located in three different counties which border the North Dakota reservation selected for the GAO report. Two visits were made to the stores. one on issuance day (September 25. 1990) and the second between two issuance periods (December 11. 1990). Grocery prices reflected a decline in milk prices and showed slight variations according to normal factors such as grocery volume purchased and transportation expenses. Prices did not vary due to food stamp issuance cycles. The South Dakota FNS office. located in Pierre. surveyed seventeen various items at ten authorized retailers on the Pine Ridge Oglala Sioux Reservation. The visits were made on September 1718. 1990 (between issuance cycles). and again on December 1112. 1990 (regular issuance pay date). Both surveys included the same stores and products. It was found that there was no appreciable difference in the pricing of the selected items for the end of the issuance period to the beginning of the issuance period (see attachment three). Therefore. thirty day staggered issuance is not a necessary nor a beneficial change for reservation recipients but conversely would be an impairment to those households. Monthly Reporting Retrospective BudgetaryMandatory exemption of additional households from monthly reporting requirements is a barrier to effective state administration. The option currently exists for states to exempt additional households should they so choose. Monthly reporting is client responsive as it allows for twelve monthly certifications periods which is responsive to transportation difficulties found on reservations. Without monthly reporting. South Dakota would assign much shorter certifications periods as reservation households frequently change income and the Native American extended family culture results in fluid household composition. Other reasons to preserve the portion of monthly reporting on reservations includes the following: (1) Joint AFDCFood Stamp households will still monthly report for AFDC which will cause client and agency confusion. The same household would be prospectively budgeted for food stamps but retrospectively budgeted for AFDC. Mandatory exemption of reservation households from monthly reporting provides further inconsistencies between AFDC and Food Stamps. (2) Monthly reporting provides for changes to be reported Just once a month. Eliminating this monthly change report structure would cause household to report changes as they occur. which in our opinion. would increase a reservation households reporting responsibilities as food stamp case circumstances frequently change throughout the month. (3) Many reservation households do not have telephones nor access to them which will make it difficult to report. necessary changes. (4) The GAO report does not hint at elimination of monthly reporting on reservations but instead remarks that states who do not reinstate benefits after an incomplete or late monthly report is filed should be required to do so. We agree with that recommendation. (5) Agency workloads will Increase as reservation households will be assigned shorter certification periods because caseworkers must check on circumstances without the benefit of monthly reports. (6) Prospecting fluctuating Income levels and household composition will be difficult. However. Indian lease income and other stable income sources can be anticipated based on historical data. In the future. Congress should move to exempt all Indian lease income from food stamp consideration. I appreciate the opportunity comment on these provisions. Sincerely.