The goal of SNAP is to help low-income individuals and households obtain a more nutritious diet by supplementing their income with benefits to purchase allowable food items. The overarching rules governing SNAP are set at the federal level. Accordingly, FNS is responsible for promulgating program regulations and ensuring that state officials administer the program in compliance with program rules. The states, or in some cases counties, administer the program by determining whether households meet the program’s eligibility requirements, calculating monthly benefits for qualified households, and issuing benefits to participants on an electronic benefits transfer card. States are also allowed flexibility in establishing some state-specific policy modifications, such as through state options. One financial criterion for SNAP eligibility and benefit amount involves household income, which can come from various sources, including earned income, such as wages and salaries, and unearned income, such as payments from other government programs (see table 1). Generally, under federal law, a household’s gross income cannot exceed 130 percent of the federal poverty level ($2,628 per month for a family of four for most states in fiscal year 2016). The household’s net income, which is determined by deducting certain expenses from gross income, such as certain dependent care and shelter costs, cannot exceed 100 percent of the federal poverty level ($2,021 per month for a family of four for most states in fiscal year 2016). Net income is used in determining the household’s benefit amount, subject to maximum benefit limits. Generally, eligibility is based on various household circumstances, including income. After eligibility is established, households are certified to receive SNAP for periods ranging from 1 to 24 months depending upon household circumstances and state-selected policy options. Households are required to report certain changes during the certification period which can affect their eligibility and benefit amounts. Once the certification period ends, there is a recertification process whereby households reapply for benefits and eligibility and benefit levels are redetermined. SNAP agencies use data matching to obtain information about households’ income, verify information that households provide when they initially apply or recertify for benefits, or identify potential discrepancies. For households that already receive SNAP benefits, data matching can provide information about changes in income that affect households’ eligibility or benefit levels (see fig. 1). In certain cases, data matching can take the place of traditional forms of verifying information provided by applicants, such as requiring households to submit documentation (e.g. pay stubs or a child support agreement) or making collateral contacts, such as a phone call to an employer. Certain federal policies that help protect individuals from inappropriately losing benefits affect whether SNAP agencies need to take additional steps to verify information from a data match. Federal law generally requires that government agencies administering benefits using matching programs verify information from matches before reducing or terminating benefits unless specified government entities have determined that there is a high degree of confidence that the information is accurate. For SNAP, FNS defines some data matches as “verified upon receipt,” if the match is with a primary or original source of the data (such as information on a government benefit provided by the administering agency) and is not questionable. An example is a match with SSA that provides information on the amount of Old-Age, Survivors, and Disability Insurance (OASDI) benefits a household receives. Eligibility workers can use this information for eligibility determinations without taking additional steps to verify that the data are accurate, according to FNS guidance. In contrast, data from a secondary source (not verified upon receipt) require additional verification before they can be used in eligibility determinations. For instance, state quarterly wage data are considered a secondary source because they are a compilation of earnings data submitted by employers to the state workforce agency. Accordingly, the SNAP caseworker must take additional steps, such as contacting an employer or requesting paystubs from the client, to verify that information from that match is accurate before using it to change a household’s eligibility status or benefit amount. Failing to verify information from secondary sources can cause eligible households to lose benefits if caseworkers act on inaccurate information. Alternatively, if caseworkers do not follow up to verify information from secondary sources, they may miss opportunities to reduce or prevent improper payments. Regardless of whether the data are from primary or secondary sources, SNAP agencies are required to notify the household of the actions they intend to take and provide the household with an opportunity to request a fair hearing prior to any adverse action. Federal law and regulations require states to conduct certain data matches for SNAP eligibility, including three matches that provide non- income related information on people who may be incarcerated, deceased, or otherwise disqualified from receiving SNAP benefits (see table 2). Most recently, the Agricultural Act of 2014 required SNAP agencies to conduct a match with the National Directory of New Hires (NDNH) to verify employment data. In response to our survey, all states reported conducting multiple data matches for income information that they use to determine SNAP eligibility. These matches gather information from federal, state, and commercial data sources on earned income from employment or self- employment, or unearned income from other government benefit programs (see table 3). As of September 2016, 39 state SNAP agencies conduct the federally- required match with the NDNH New Hire data (see sidebar), according to our survey and information from HHS/ACF’s Office of Child Support Enforcement (OCSE) on states’ progress in implementing the match. FNS required states to implement this match for SNAP eligibility purposes by September 21, 2014; however, some states have experienced implementation delays, and FNS officials said that each of the 12 remaining states is working towards implementing the match. States that experienced implementation delays had not yet developed the capacity to conduct the NDNH New Hire match or faced competing priorities for resources, according to FNS, OCSE, and state officials. For example, two of the remaining states said they will implement the match in coordination with efforts to upgrade or replace SNAP eligibility systems. Two other states said in their survey responses that a lack of resources has delayed their implementation of the match. FNS monitors states’ progress in implementing the required NDNH New Hire match and promotes states’ compliance by reviewing monthly reports on states’ matching activities and following up with states as needed, according to FNS officials. Specifically, FNS officials reported that the national office in Washington, D.C., reviews monthly reports from OCSE on states matching activities and forwards information to FNS regional offices for follow up as needed. Data matches with primary sources, those that allow for real-time access to data, and those that provide up-to-date information are useful because they enable efficient and accurate SNAP eligibility determinations, and matches that combine these characteristics are particularly useful, according to our analysis of state survey responses. Officials from SNAP agencies we interviewed explained that these data matching characteristics streamlined the eligibility determination process for caseworkers and households. Data matches with primary data sources are more useful because caseworkers can use the information without having to conduct additional verification, according to officials from each of the six state SNAP agencies we interviewed. Matches that can be accessed in real-time, or immediately upon request, can help caseworkers make determinations more quickly or eliminate the need to revisit eligibility or benefit determinations multiple times, according to officials we interviewed in five of the six states. Real-time access allows caseworkers to verify information provided by applicants and discuss apparent discrepancies during interviews rather than contact households again later. It can be difficult for caseworkers to contact households, according to officials we spoke with in four of the six states, and the need to do so can create delays in processing applications, a key FNS performance measure for SNAP. FNS regulations generally require recent information on income for SNAP eligibility and benefit determinations. Generally, FNS directs states to use income received in the last 30 days as the basis for determining SNAP benefit amounts. Accordingly, matches that provide current information can be used to accurately calculate or adjust benefits whereas older data may introduce errors if not updated. Officials from each of the six states we interviewed emphasized the importance of up-to-date information. Four data matches for unearned income have each of the useful characteristics described above, while the data matches for earned income lack one or more of these characteristics. The four data matches most states reported using and finding very or extremely useful are with primary sources including state or federal agencies that administer benefit programs that provide households’ unearned income (see fig. 2). Matches with SSA can provide real-time access to current SSI and OASDI program benefits that a household may receive. Matches with state-level unemployment insurance and child support enforcement agencies can provide up-to-date and real-time access to information on households’ receipt of benefits or support payments, depending on states’ matching capabilities. The data source for earned income that the most states reported as very or extremely useful was the commercial verification service The Work Number®, which is owned by Equifax Inc. and stores employment and earnings information gathered from participating employers’ payroll systems. Equifax representatives told us they estimate that The Work Number covers about 35-40 percent of the working population at any given time. Additionally, FNS officials told us that while The Work Number is a secondary source of information for SNAP eligibility purposes, SNAP agencies can use it to verify earned income reported by households or to identify potential earnings that were not reported. Similar to our findings in a recent report on the use of commercial data services to help identify fraud and improper payments, officials from five of the six states where we interviewed SNAP agency officials said The Work Number can improve program integrity or program efficiency by providing real-time access to accurate and up-to-date information.