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Report to the Chairman, Committee on Agriculture, Nutrition, and
Forestry, U.S. Senate:
United States Government Accountability Office:
GAO:
May 2007:
Food Stamp Program:
Use of Alternative Methods to Apply for and Maintain Benefits Could Be
Enhanced by Additional Evaluation and Information on Promising
Practices:
GAO-07-573:
GAO Highlights:
Highlights of GAO-07-573, a report to the Chairman, Committee on
Agriculture, Nutrition, and Forestry, U.S. Senate
Why GAO Did This Study:
One in 12 Americans participates in the federal Food Stamp Program,
administered by the Food and Nutrition Service (FNS). States have begun
offering individuals alternatives to visiting the local assistance
office to apply for and maintain benefits, such as mail-in procedures,
call centers, and on-line services. GAO was asked to examine: (1) what
alternative methods states are using to increase program access; (2)
what is known about the results of these methods, particularly on
program access for target groups, decision accuracy, and administrative
costs; and (3) what actions states have taken to maintain program
integrity while implementing alternative methods. GAO surveyed state
food stamp administrators, reviewed five states in depth, analyzed FNS
data and reports, and interviewed program officials and stakeholders.
What GAO Found:
All states use mail and about half of states use or have begun
developing on-line services and call centers to provide access to the
food stamp program. Almost all states allow households to submit
applications, report changes, and submit recertifications through the
mail, and 26 states have implemented or are developing systems for
households to perform these tasks on-line. Almost half of the states
are using or developing call centers and states also are allowing
households to participate in telephone interviews instead of an in-
office interview. States have taken a variety of actions to help
households use on-line services and call centers, such as sending
informational mailings, holding community meetings, and using community
partners.
Insufficient information is available to determine the results of using
alternative methods. Few evaluations have been conducted identifying
the effect of alternative methods on program access, decision accuracy,
or administrative costs. Evaluating the effectiveness of alternative
methods is challenging in part because limited data are available,
states are using a combination of methods, and studies can be costly to
conduct. Federal and state officials reported that while they believe
alternative methods can help households in several ways, such as
increasing flexibility and efficiency in the application process,
certain types of households may have difficulty using or accessing
alternative methods. In addition, technology and staffing challenges
may hinder the use of alternative methods.
To maintain program integrity while implementing alternative methods,
the states GAO reviewed used a variety of strategies, such as using
software to verify the information households submit, communicating
with other states to detect fraud, or using finger imaging. Although
there has been some concern that without frequent in-person interaction
with caseworkers, households may not submit required documents on time
and thus be denied benefits on procedural grounds (“procedural
denials”), GAO’s limited analysis of FNS data found no considerable
fluctuations in the rate of procedural denials in the five states
between fiscal years 2000 and 2005. The states GAO reviewed have
instituted several approaches to prevent procedural denials.
Figure: Call Center Caseworker Answering Calls:
[See PDF for Image]
Source: GAO.
[End of figure]
What GAO Recommends:
GAO recommends that the Secretary of Agriculture direct FNS to (1) work
with the Economic Research Service (ERS) to enhance their research
agendas to include projects that would determine the effects of
alternative methods; (2) conduct analyses of data received from states
implementing waivers or demonstration projects waiving the face-to-face
interview; and (3) disseminate and regularly update information on
promising practices states are using to implement alternative methods.
FNS and ERS generally agreed with GAO’s findings, conclusions, and
recommendations.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-573].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Sigurd Nilsen at (202)
512-7215 or nilsens@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
All States Use Mail and About Half of States Use or Have Begun
Developing On-line Services and Call Centers to Provide Access to the
Food Stamp Program:
Information on Results Is Limited, but States We Reviewed Cite
Advantages and Challenges Using Alternative Access Methods:
States Report Taking Actions to Maintain Food Stamp Program Integrity
While Using Alternative Methods:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: State-by-State Use of Alternative Methods and Waivers of
the Face-to-Face Interview:
Appendix III: GAO Contact and Acknowledgments:
Related GAO Products:
Tables:
Table 1: Process to Apply for and Maintain Food Stamp Benefits:
Table 2: Administrative Flexibility Available to States to Waive the
Face-to-Face Interview:
Figures:
Figure 1: Food Stamp Participation and Poverty Trends:
Figure 2: Office-based Method Compared with Alternative Methods of
Applying for Food Stamp Benefits:
Figure 3: Number and Percentage of States Making On-line Services
Available to Food Stamp Households:
Figure 4: Number and Percentage of States Making Call Centers Available
to Food Stamp Households:
Figure 5: Actions Used to Assist Households with On-line Services:
Figure 6: Actions Used to Assist Households with Call Centers:
Figure 7: FNS Monitoring of Indiana's Plan to Implement Alternative
Access Methods:
Figure 8: States' Use of Measures to Monitor Performance of On-line
Services:
Figure 9: States' Use of Measures to Monitor Performance of Call
Centers:
Figure 10: Use of Alternative Access Methods in Texas:
Figure 11: Use of Alternative Access Methods in Florida:
Abbreviations:
EBT: Electronic Benefits Transfer:
ERS: Economic Research Service:
FNS: Food and Nutrition Service:
FSP: Food Stamp Program:
PRWORA: Personal Responsibility and Work Opportunity Reconciliation Act
of 1996:
QC: quality control:
SSI: Supplemental Security Income:
TANF: Temporary Assistance for Needy Families:
USDA: U.S. Department of Agriculture:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
May 3, 2007:
The Honorable Tom Harkin:
Chairman:
Committee on Agriculture, Nutrition, and Forestry:
United States Senate:
Dear Mr. Chairman:
Almost 1 in every 12 Americans participates in the federal Food Stamp
Program, which helps low-income individuals and families purchase
nutritious food, such as meat, dairy products, fruits, and vegetables.
In fiscal year 2005, the program, jointly administered by the U.S.
Department of Agriculture's (USDA) Food and Nutrition Service (FNS) and
the states, provided about $29 billion in benefits to nearly 26 million
people, about half of whom were children.[Footnote 1]
Although participation in the program has increased substantially in
recent years, about 40 percent of people who were eligible for the
program did not participate in 2004, the most recent year data are
available. Elderly individuals, non-citizens that may have limited
English proficiency, and working families have consistently
participated at lower rates than the eligible population as a whole and
FNS has targeted these subgroups to increase participation. Even though
there are many reasons people may not participate in the program, some
research has shown that the administrative burden of applying for and
maintaining eligibility for benefits may be a factor, particularly for
people who are elderly or who work during the hours local public
assistance offices are open. Participation in the program generally
requires individuals to submit an application, participate in an
interview at initial application and at least annually, provide
verification of certain information, report certain changes in
household circumstances while receiving benefits, and reapply for
benefits at the end of the certification period (recertification).
While completing the Food Stamp Program application and recertification
process has traditionally involved visiting the local assistance office
in person for interviews or to submit applications and other
documentation, states have begun offering alternatives in the last
several years, such as mail-in procedures, call centers, and on-line
services.
While FNS has allowed states to adopt these new ways of accessing the
program, it also has a quality control system in place to monitor
program integrity. Under this system, FNS monitors decision accuracy,
including how accurately states determine food stamp eligibility and
calculate benefits. In addition to monitoring the payment error rate,
FNS estimates the rate of cases denied, suspended, or terminated
incorrectly, which is called the negative error rate. FNS and USDA's
Economic Research Service (ERS) also fund Food Stamp Program research.
To understand what alternative approaches states are using to help
households apply for and maintain benefits and what is known about the
results of using these methods, we examined: (1) the alternative
methods to the traditional application and recertification process
states are using to increase program access; (2) what is known about
the results of these methods, particularly on program access for target
groups, decision accuracy, and administrative costs; and (3) what
actions states have taken to maintain program integrity while
implementing alternative methods.
To answer these questions, we surveyed food stamp administrators in the
50 states and the District of Columbia[Footnote 2] to collect
information on what alternative methods states are using or planning to
use (mail, call centers, on-line services), how performance of these
methods is measured, and what is known about the results of using these
methods. To augment information from our state survey, we conducted
four site visits (Florida, Texas, Utah, and Washington) and one set of
semi-structured telephone interviews (Pennsylvania). We selected states
that have at least one FNS-approved waiver of the face-to-face
interview requirement and reflect some variation in state participation
rates. We also considered recommendations from FNS officials, advocacy
group representatives, and researchers. For each of the five states we
reviewed in depth, we interviewed state officials administering and
developing policy for the Food Stamp Program, local officials in the
assistance offices and call centers where services are provided, and
representatives from community-based organizations that provide food
assistance. We analyzed data provided by FNS and the states we reviewed
in depth to provide background for our discussions with officials about
state trends for specific measures (participation, payment accuracy,
administrative costs, and reasons for denial). We also reviewed FNS
reports and related studies. We held discussions with program
stakeholders, including officials at FNS headquarters and regional
offices, and representatives of advocacy organizations. Appendix I
explains our methodology in more detail. We performed our work from
September 2006 to March 2007 in accordance with generally accepted
government auditing standards.
Results in Brief:
All states use mail and about half of states use or have begun
developing on-line services and call centers to provide access to the
Food Stamp Program. Almost all states told us they allow households to
submit applications, report changes, and submit recertifications
through the mail, and 26 states have implemented or are developing
systems to allow households to submit applications, report changes, or
submit recertifications on-line. In addition, almost half of the states
are using or developing call centers and states are also using
flexibility authorized by FNS to increase use of the telephone as an
alternative to visiting the local assistance office. For example, FNS
has approved administrative waivers allowing 20 states to substitute a
telephone interview for the face-to-face interview for all households
at recertification without needing to document that coming into the
office would be a hardship for the household. States have taken a
variety of actions to help households use on-line services and call
centers, such as sending informational mailings, holding community
meetings, and employing call center staff who speak languages other
than English. States are also relying on community-based organizations,
such as food banks, to help households use alternative methods. For
example, four of the five states we interviewed provide grants to
community-based organizations to inform households about the program
and help them complete the application process.
Insufficient information is available to determine the results of using
alternative methods to provide access to the Food Stamp Program, but
federal and state officials reported that despite some challenges, they
believe these methods are making it easier for some households to
access program benefits. Few evaluations have been conducted to
identify the effect of alternative methods on program access, decision
accuracy, or administrative costs. FNS has two studies under way that
will describe implementation of alternative methods such as on-line
services and call centers, but it is unlikely that these studies will
use research approaches that would identify the effect of alternative
methods. Further, while states reported monitoring the performance of
call centers and on-line services, none of the states has conducted
evaluations that would identify the effect of the alternative methods
on program access, decision accuracy, or administrative costs. State
officials reported implementing a combination of methods over time,
making it difficult to isolate the effect of specific methods. Despite
this, federal and state officials said that they believe that giving
households alternatives to visiting the food stamp office can help
improve access to benefits. For example, in the five states we reviewed
in depth, officials and community partners said that allowing telephone
interviews is especially beneficial for working families and the
elderly because they reduce barriers from transportation, child care,
or work responsibilities, as well as the stigma of visiting the
assistance office. However, officials and community partners also said
that certain types of households, such as those with limited English
proficiency, the elderly, and those with mental disabilities, may have
difficulty using on-line applications and navigating call center phone
systems. The advantages of alternative methods to households also may
depend on the technology and staff available. For example, on-line
applications without electronic signature capability have limited
benefit because households are required to also submit an actual
signature through mail, fax, or in person. Further, inadequate numbers
of staff and unskilled staff may limit the advantages of alternative
methods because households may not be able to receive the information
and assistance needed to successfully apply for or maintain benefits.
The five states we reviewed used a variety of strategies to maintain
program integrity while implementing alternative methods, some of which
were in place long before implementation of the alternative access
methods. All five states used software to help with verification of
household circumstances by, for example, matching state food stamp
caseloads against wage reporting systems and other databases to
identify unreported household income and assets. Nationwide, about half
of the states participate in quarterly matches with other states to
detect households receiving food stamp benefits in more than one state
at a time. In addition, all five states we reviewed developed special
caseworker training on topics such as how to detect misinformation
provided by a household over the telephone. State and local food stamp
officials told us they believed that using alternative methods had not
increased the frequency of fraud and abuse in the program because the
verification process is the same whether or not a worker sees an
individual face-to-face. There has been some concern that without face-
to-face contact with caseworkers, households may not know when or how
to submit paperwork or complete other tasks and would thus be denied
benefits on procedural grounds ("procedural denials"). However, our
limited analysis of FNS data found no considerable fluctuations in the
rate of procedural denials in the five states between fiscal years 2000
and 2005. To prevent improper procedural denials, the five states we
reviewed instituted such approaches as reviewing case actions,
correcting addresses for returned mail, and changing automated systems
to prevent caseworkers from prematurely denying cases.
To improve USDA's ability to assess the effectiveness of its funded
efforts, we are recommending that the Secretary of Agriculture: direct
FNS and the Economic Research Service (ERS) to work together to enhance
their research agendas to include projects that would determine the
effect of alternative methods on program access, decision accuracy, and
administrative costs of the Food Stamp Program; and direct FNS to
conduct analyses of data received from states implementing waivers or
demonstration projects waiving the face-to-face interview and require
states implementing waivers or demonstration projects to collect and
report data that would facilitate such analyses. Further, to help
states implement alternative methods to provide access to the Food
Stamp Program, we are recommending that FNS disseminate and regularly
update information on states' implementation of alternative methods to
the traditional application and recertification process. FNS and ERS
generally agreed with our findings, conclusions, and recommendations
and cited steps the agency is taking to monitor and evaluate state
implementation of alternative access methods. FNS and ERS also provided
technical comments, which were incorporated into the report as
appropriate.
Background:
The federal Food Stamp Program is intended to help low-income
individuals and families obtain a more nutritious diet by supplementing
their income with benefits to purchase eligible foods at authorized
food retailers, such as meat, dairy products, fruits, and vegetables,
but not items such as soap, tobacco, or alcohol. FNS pays the full cost
of food stamp benefits and shares the states' administrative costs--
with FNS usually paying slightly less than 50 percent--and is
responsible for promulgating program regulations and ensuring that
state officials administer the program in compliance with program
rules.[Footnote 3] The states administer the program by determining
whether households meet the program's eligibility requirements,
calculating monthly benefits for qualified households, and issuing
benefits to participants through an electronic benefits transfer
system.
Program Participation:
In fiscal year 2005, the Food Stamp Program issued almost $28.6 billion
in benefits to about 25.7 million individuals per month, and the
maximum monthly food stamp benefit for a household of four living in
the continental United States in fiscal year 2007 was $518. As shown in
figure 1, program participation decreased during the late 1990s, partly
due to an improved economy, but rose again from 2000 to 2005. The
number of food stamp recipients follows the trend in the number of
people living at or below the federal poverty level.
Figure 1: Food Stamp Participation and Poverty Trends:
[See PDF for image]
Source: GAO analysis of FNS and U.S. Census data.
Notes: Poverty data are by calendar year and participation data are by
fiscal year.
Preliminary FNS data indicate that participation will continue to grow
to nearly 27 million people receiving about $30 billion in food stamp
benefits in fiscal year 2006.
[End of figure]
In addition to the economic growth in the late 1990s, another factor
contributing to the decrease in number of participants from 1996 to
2001 was the passage of the Personal Responsibility and Work
Opportunity Reconciliation Act of 1996 (PRWORA), which added work
requirements and time limits to cash assistance and made certain groups
ineligible to receive food stamp benefits. In some cases, this caused
participants to believe they were no longer eligible for food stamps
when TANF benefits were ended.[Footnote 4] Since 2000, that downward
trend has reversed, and experts believe that the downturn in the U.S.
economy, coupled with changes in the Food Stamp Program's rules and
administration, has led to an increase in the number of food stamp
participants.
Determination of Eligibility and Benefits:
Eligibility for participation in the Food Stamp Program is based
primarily on a household's income and assets. To determine a
household's eligibility, a caseworker must first determine the
household's gross income, which cannot exceed 130 percent of the
poverty level for that year as determined by the Department of Health
and Human Services, and net income, which cannot exceed 100 percent of
the poverty level (or about $1,799 per month for a family of three
living in the continental United States in fiscal year 2007). Net
income is determined by deducting from gross income a portion of
expenses such as dependent care costs, medical expenses for elderly
individuals, utilities costs, and housing expenses.
The Process of Applying for and Maintaining Benefits:
The application process for the Food Stamp Program requires households
to complete and submit an application to a local assistance office,
participate in an interview, and submit documentation to verify
household circumstances (see table 1). Applicants may need to make more
than one visit to the assistance office to complete the application
process. After eligibility is established, households are certified
eligible for food stamps for periods ranging from 1 to 24 months,
depending on household circumstances and state policy. While households
are receiving benefits, they must report changes in household
circumstances that may affect eligibility or benefit amounts. States
may choose to require households to report changes within 10 days of
occurrence (incident reporting) or at specified intervals (periodic
reporting). States also have the option to adopt a simplified system,
which further reduces the burden of periodic reporting by requiring
households to report changes that happen during a certification period
only when their income rises above 130 percent of the federal poverty
level.[Footnote 5] Once the certification period ends, households must
reapply for benefits, at which time eligibility and benefit levels are
redetermined. The recertification process is similar to the application
process. Households can be denied benefits or have their benefits end
at any point during the process if they are determined ineligible under
program rules or for procedural reasons, such as missing a scheduled
interview or failing to provide the required documentation.
Table 1: Process to Apply for and Maintain Food Stamp Benefits:
Apply for benefits:
* Complete and submit application to assistance office;
* Participate in an interview;
* Submit documentation to verify information provided in the
application and interview;
While receiving benefits:
* Report changes in household circumstances--such as household
composition, income, and expenses--that may affect eligibility or
benefit amounts;
Recertify for benefits:
* Complete and submit recertification application to assistance office;
* Participate in an interview at least annually;
* Submit documentation to verify information provided in the
application and interview.
Source: GAO analysis of FNS information.
[End of table]
While applying for and maintaining food stamp benefits has
traditionally involved visiting a local assistance office, states have
the flexibility to give households alternatives to visiting the office,
such as using the mail, the telephone, and on-line services to complete
the certification and recertification process. Alternative methods may
be used to support other programs, such as Medicaid or TANF, since some
food stamp participants receive benefits from multiple programs. Figure
2 illustrates a traditional office-based system and how states can use
a number of alternative methods to determine applicants' eligibility
without requiring them to visit an assistance office.
Figure 2: Office-based Method Compared with Alternative Methods of
Applying for Food Stamp Benefits:
[See PDF for image]
Source: GAO analysis.
[End of figure]
Program Integrity:
FNS and the states share responsibility for implementing a quality
control system used to measure the accuracy of caseworker decisions
concerning the amount of food stamp benefits households are eligible to
receive and decisions to deny or end benefits. The food stamp payment
error rate is calculated by FNS for the entire program, as well as
every state, by adding overpayments (including payments higher than the
amounts households are eligible for or payments to those who are not
eligible for any benefit), and underpayments (payments lower than the
amounts households are eligible for). The national payment error rate
has declined by about 40 percent between 1999 and 2005, from 9.86
percent to a record low of 5.84 percent. FSP payment errors are caused
primarily by caseworkers, usually when they fail to keep up with new
information, and by participants when they fail to report needed
information. Another type of error measured by FNS is the negative
error rate, defined as the rate of cases denied, suspended, or
terminated incorrectly. An example of incorrectly denying a case would
be if a caseworker denied a household participation in the program
because of excess income, but there was a calculation error and the
household was actually eligible for benefits. FNS also monitors
individual fraud and retailer trafficking of food stamp
benefits.[Footnote 6]
All States Use Mail and About Half of States Use or Have Begun
Developing On-line Services and Call Centers to Provide Access to the
Food Stamp Program:
According to our survey, almost all states allow households to submit
applications, report changes, and submit recertifications through the
mail, and 26 states have implemented or are developing systems to allow
households to perform these tasks on-line. Almost half of the states
are using or developing call centers and states are also using
flexibility authorized by FNS to increase use of the telephone as an
alternative to visiting the local assistance office. States have taken
a variety of actions to help households use on-line services and call
centers, such as sending informational mailings, holding community
meetings, and using community partners to assist households.
Almost All States Allow Households to Apply for Food Stamp Benefits and
Maintain Eligibility by Mail and about Half of the States Are Using or
Developing On-line Services:
Many states are allowing households to apply for food stamp benefits,
report changes in household circumstances, and complete recertification
through the mail and on-line. [Footnote 7]
* Mail-In Procedures. Results of our survey show that households can
submit applications through the mail in all states, report changes
through the mail in all but 1 state, and submit recertifications
through the mail in 46 states. For example, Washington state officials
told us that the recertification process involves mailing a
recertification application package to households that they can mail
back without visiting a local assistance office.
* On-line Services. All states we surveyed reported having a food stamp
application available for households to download from a state website,
as required by federal law, and 26 states (51 percent) have implemented
or are developing Web-based systems in which households can submit
initial applications, report changes, or submit recertifications on
line (see fig. 3). Most on-line applications were made available
statewide and implemented within the last 3 years and states developing
on-line services plan to implement these services within the next 2
years. All of the 14 states that reported currently providing on-line
services allow households to submit initial food stamp applications on-
line, but only 6 states allow households to report changes and 5 states
allow households to complete recertification on-line.[Footnote 8] Of
the 14 states that reported using on-line applications, 2 reported they
were only available in certain areas of the state. Only two states
(Florida and Kansas) reported in our survey that the state closed
program offices or reduced staff as a result of implementing on-line
services.
Figure 3: Number and Percentage of States Making On-line Services
Available to Food Stamp Households:
[See PDF for image]
Source: GAO survey.
[End of figure]
Almost Half of States Are Using or Developing Call Centers and Using
Telephone Interviews as an Alternative to Visiting the Local Assistance
Office:
Many states are using call centers, telephone interviews, or other
technologies to help households access food stamp benefits or
information without visiting a local assistance office.
* Call Centers. Nineteen states (37 percent) have made call centers
available to households and an additional 4 states (8 percent) have
begun development of call centers that will be available to households
in 2007 (see fig. 4). Households have been able to use call centers in
seven states for more than 3 years. Of the 19 states using call
centers, 10 reported that call centers were only available in certain
areas of the state. Only two states (Texas and Idaho) reported using
private contractors to operate the call centers, but Texas announced in
March 2007 that it was terminating its agreement with the private
contractor (see fig. 10 for more details). FNS officials told us that
the Idaho private call center provides general food stamp program
information to callers, while inquiries about specific cases are
transferred to state caseworkers. Indiana reported in our survey that
the state plans to pilot call centers in certain areas of the state in
August 2007 using a private contractor and complete a statewide
transition in March 2008. Only two states (Florida and Arizona)
reported in our survey that the state closed offices or reduced staff
as a result of implementing call centers.
Figure 4: Number and Percentage of States Making Call Centers Available
to Food Stamp Households:
[See PDF for image]
Source: GAO survey.
[End of figure]
Most states with call centers reported that households can use them to
report changes in household circumstances, request a food stamp
application and receive assistance filling it out, receive information
about their case, or receive referrals to other programs. Only four
states reported using their call centers to conduct telephone
interviews. For example, local officials in Washington told us that
households use their call center primarily to request information,
report changes in household circumstances, and request an interview.
Telephone interviews are conducted by caseworkers in the local
assistance office.
* Telephone Interviews. Many states are using the flexibility provided
by FNS to increase the use of the telephone as an alternative to
households visiting the local assistance office. For example, FNS has
approved administrative waivers for 20 states that allow states to
substitute a telephone interview for the face-to-face interview for all
households at recertification without documenting that visiting the
assistance office would be a hardship for the household.[Footnote 9] In
addition to making it easier on households, this flexibility can reduce
the administrative burden on the state to document hardship. FNS also
allows certain states implementing demonstration projects to waive the
interview requirement altogether for certain households. States we
reviewed varied in terms of the proportion of interviews conducted over
the phone. For example, Florida state and local officials estimated
that about 90 percent of the interviews conducted in the state are
completed over the telephone. Washington state officials estimated that
10 percent of application interviews and 30 percent of recertification
interviews are conducted by phone. Table 2 describes the types of
flexibility available to states and how many are taking advantage of
each.
Table 2: Administrative Flexibility Available to States to Waive the
Face-to-Face Interview:
Description of flexibility: Hardship policy[A]; Substitute telephone
interview for face-to-face interview at application or recertification
for all households experiencing a hardship as determined by the state.
Hardship must be documented in the case file;
Availability: All states;
Year available or first approved by FNS: 1978;
Number of states[D]: All states.
Description of flexibility: Waiver at recertification; Substitute
telephone interview for face-to-face interview for all households at
recertification without documenting hardship;
Availability: States with waivers;
Year available or first approved by FNS: 1992;
Number of states[D]: 20.
Description of flexibility: Waiver at initial certification[B];
Substitute telephone interview for face-to-face interview for all
households at initial certification without documenting hardship;
Availability: States with waivers;
Year available or first approved by FNS: 2005;
Number of states[D]: 3.
Description of flexibility: Combined Application Projects[C];
Households can apply for food stamps at the same time they apply for or
are recertified for Supplemental Security Income (SSI) with the Social
Security Administration. Households are not required to have a separate
interview to apply for food stamps;
Availability: States with demonstration projects;
Year available or first approved by FNS: 1995;
Number of states[D]:
* 10 have implemented;
* 6 approved or pending approval but have not implemented;
* 5 more have been invited to submit proposals.
Description of flexibility: Elderly/Disabled Demonstration Projects;
Simplify the application process for elderly and/or disabled households
in part by waiving the interview altogether;
Availability: States with demonstration projects;
Year available or first approved by FNS: 2002;
Number of states[D]: 2.
Source: GAO analysis of FNS information.
[A] These hardship conditions include, but are not limited to: illness,
transportation difficulties, care of a household member, hardships due
to residency in a rural area, prolonged severe weather conditions, or
work or training hours that prevent the household from participating in
an in-office interview. States must document hardship. The regulations
also allow states to opt to substitute telephone interviews for face-
to-face interviews for all households that have no earned income and in
which all members are elderly or disabled.
[B] Limited to no more than 50 percent of the statewide caseload.
[C] The Food Stamp Act of 1977 included several access provisions, such
as addressing the use of mail, telephone, or home visits for
certification and joint food stamps and SSI application processing.
Since 1986, federal law has required that applicants for or recipients
of SSI must be informed of the opportunity to file a food stamp
application at the SSA office when applying for SSI.
[D] See appendix II for specific state information.
[End of table]
* Other Technologies. Some states reported implementing other
technologies that support program access. Specifically, according to
our survey, 11 states (21 percent) have implemented an Integrated Voice
Response (IVR) system, a telephone system that provides automated
information, such as case status or the benefit amount, to callers but
does not direct the caller to a live person. In addition, 11 states (21
percent) are using document management/imaging systems that allow case
records to be maintained electronically rather than in paper files.
All five of the states we reviewed have implemented in at least certain
areas of their state mail-in procedures, on-line services, call
centers, waiver of face-to-face interview at recertification, and
document management/imaging systems. Three of the five states (Florida,
Texas, and Washington) have implemented an integrated voice response
system and two (Florida and Utah) have implemented a waiver of the face-
to-face interview at initial application.
States Report Taking Several Actions to Help Households Use Alternative
Methods:
States have taken a variety of actions to help households use on-line
services and call centers, such as sending informational mailings,
holding community meetings, and employing call center staff who speak
languages other than English as shown in figures 5 and 6.
Figure 5: Actions Used to Assist Households with On-line Services:
[See PDF for image]
Source: GAO survey.
[End of figure]
Figure 6: Actions Used to Assist Households with Call Centers:
[See PDF for image]
Source: GAO survey.
[End of figure]
States are using community-based organizations, such as food banks, to
help households use alternative methods. All states implementing on-
line services (14)[Footnote 10] and about half of states with call
centers (10 of 19) use community partners to provide direct assistance
to households. Among the states we reviewed, four provide grants to
community-based organizations to inform households about the program
and help them complete the application process. For example, Florida
closed a third of its local assistance offices and has developed a
network of community partners across the state to help households
access food stamps. Florida state officials said that 86 percent of the
community partners offer at least telephone and on-line access for
completing and submitting food stamp applications. Community partner
representatives in Washington, Texas, and Pennsylvania said that they
sometimes call the call center with the household or on their behalf to
resolve issues. Pennsylvania provides grants to community partners to
help clients use the state's on-line services. In addition to the
assistance provided by community-based organizations, H&R Block, a
private tax preparation firm, is piloting a project with the state of
Kansas where tax preparers who see that a household's financial
situation may entitle them to food stamp benefits can electronically
submit an application for food stamps at no extra charge to the
household.
Information on Results Is Limited, but States We Reviewed Cite
Advantages and Challenges Using Alternative Access Methods:
Insufficient information is available to determine the results of using
alternative methods to access the Food Stamp Program, but state and
federal officials report that alternative methods are helping some
households. Few evaluations have been conducted that identify the
effect of alternative methods on food stamp program access, decision
accuracy, or administrative costs. Although states monitor the
implementation of alternative methods, isolating the effects of
specific methods is difficult, in part because states typically have
implemented a combination of methods over time. Despite the limited
information on the effectiveness of alternative methods, federal and
state officials believe that these methods can help many households by
making it easier for them to complete the application or
recertification process. However, technology and staffing challenges
can hinder the use of these methods.
Few Evaluations Have Been Conducted and Determining the Effectiveness
of Specific Methods Can Be Difficult:
Few federal or state evaluations have been conducted to identify how
using alternative methods, such as on-line applications or call
centers, affects access to the Food Stamp Program, the accuracy of
caseworker decisions about eligibility and benefit amounts, or
administrative costs. Few evaluations have been conducted in part
because evaluating the effectiveness of alternative methods is
challenging, given that limited data are available, states are using a
combination of methods, and studies can be costly to conduct.
Federal Evaluation and Monitoring:
FNS and ERS have funded studies related to improving Food Stamp Program
access, but none of these previous studies provide a conclusive
assessment of the effectiveness of alternative methods and the factors
that contribute to their success (see app. I for a list of the studies
we selected and reviewed). Although these studies aimed to evaluate
local office practices, grants, and demonstration projects, the
methodological limitations of this research prevent assessments about
the effectiveness of these efforts. An evaluation of the Elderly
Nutrition Demonstration projects used a pre-post comparison group
design to estimate the impact of the projects and found that food stamp
participation among the elderly can be increased. [Footnote 11] Two of
the projects evaluated focused on making the application process easier
by providing application assistance and simplifying the process, in
part by waiving the interview requirement. However, one of the
drawbacks of this study is that its findings are based on a small
number of demonstrations, which affects the generalizability of the
findings.
Two related FNS-funded evaluations are also under way, but it is
unlikely these studies will identify the effects of using alternative
methods.[Footnote 12]
* An implementation study of Florida's efforts to modernize its system
using call centers and on-line services involves a descriptive case
study to be published in late summer 2007, incorporating both
qualitative and quantitative data. The objectives of the study are to:
describe changes to food stamp policies and procedures that have been
made in support of modernization; identify how technology is used to
support the range of food stamp eligibility determination and case
management functions; and describe the experiences of food stamp
participants, eligible non-participants, state food stamp staff,
vendors, and community partners. This study will describe Florida's
Food Stamp Program performance over time in comparison to the nation,
other states in the region, and other large states. Performance data
that will be reviewed includes program participation in general and by
subgroup, timeliness of application processing, payment error rates,
and administrative costs. However, the study will not isolate the
effect of the modernization efforts on program performance.
* A national study of state efforts to enhance food stamp certification
and modernize the food stamp program involves a state survey and case
studies of 14 states and will result in a site visit report in late
summer 2007, a comprehensive report in March 2009, and a public-use
database systematically describing modernization efforts across all the
states in May 2009. The national study will focus on four types of
modernization efforts: policy changes to modernize FSP application,
case management, and recertification procedures; reengineering of
administrative functions; increased or enhanced use of technology; and
partnering arrangements with businesses and nonprofit organizations.
The goals of the study include documenting outcomes associated with
food stamp modernization and examining the effect of these
modernization efforts on four types of outcomes: program access,
administrative cost, program integrity, and customer services. This
study will compare performance data from the case study states with
data from similar states and the nation as a whole, however, this
analysis will not determine whether certain modernization efforts
caused changes in performance.
USDA has also awarded $5 million in fiscal year 2006 to 5 grantees in
Virginia, California, Georgia and Alabama to help increase access to
the program, but there is currently no plan to publish an evaluation of
the outcomes of these projects. The participation grants focus on
efforts to simplify the application process and eligibility systems and
each grantee plans to implement strategies to improve customer service
by allowing Web-based applications and developing application sites
outside the traditional social services office. Grantees are required
to submit quarterly progress reports and final reports including a
description of project activities and implementation issues.
Although few evaluations have been conducted, FNS monitors state and
local offices and tracks state implementation of alternative methods to
improve program access. FNS also collects and monitors data from
states, such as the number of participants, amount of benefits issued,
participation rates overall and by subgroup, timeliness of application
processing, payment errors, negative errors, and administrative costs.
FNS regional offices conduct program access reviews of selected local
offices in all states to determine whether state and/or local policies
and procedures served to discourage households from applying for food
stamps or whether local offices had adopted practices to improve
customer service. FNS also monitors major changes to food stamp systems
using a process where FNS officials review and approve plans submitted
by states related to system development and implementation, including
major upgrades. States like Texas, Florida, and Indiana that have
implemented major changes to their food stamp system, such as moving
from a local assistance office service delivery model to call centers
and on-line services, have worked with FNS through this process. Figure
7 describes FNS's monitoring of Indiana's plan to implement alternative
access methods.
Figure 7: FNS Monitoring of Indiana's Plan to Implement Alternative
Access Methods:
[See PDF for image]
Source: GAO analysis.
[End of figure]
FNS has also encouraged states to share information about their efforts
to increase access among states, but states reported needing additional
opportunities to share information. FNS has funded national and
regional conferences, travel by state officials to visit other states
to learn about their practices, as well as provided states a guide to
promising practices for improving program access.[Footnote 13] The
guide contains information about the goal of each practice, the number
of places where the practice is in use, and contact information for a
person in these offices. However, this guide has not been updated since
2002 and, for the most part, does not include any evidence that these
efforts were successful or any lessons that were learned from these or
other efforts.[Footnote 14] In 2004, in response to recommendations
from our prior report,[Footnote 15] FNS compiled and posted 19
practices aimed to improve access from 11 states. FNS also has a form
available on its website where states can submit promising practices to
improve access, but to date, practices from this effort have not been
published. In our survey, 13 states (about 25 percent) reported needing
additional conferences or meetings with other states to share
information.
State Evaluation and Monitoring:
States also report monitoring use of alternative methods in the Food
Stamp Program, but have not conducted evaluations of their
effectiveness. In our survey, states reported monitoring several
aspects of the performance of on-line services. As shown in figure 8,
states most commonly used the number of applications submitted, the
number of applications terminated before completion, and customer
satisfaction to monitor the performance of on-line services. For
example, Pennsylvania state officials monitor performance of their on-
line system and meet regularly with community partners that help
households submit applications for benefits to obtain feedback on how
they can improve the system. Florida state officials told us they use
responses to on-line feedback surveys submitted at the end of the on-
line application to assess customer satisfaction with the state's on-
line services.
Figure 8: States' Use of Measures to Monitor Performance of On-line
Services:
[See PDF for image]
Source: GAO survey.
[End of figure]
States also reported in our survey monitoring several aspects of the
performance of their call centers. As shown in figure 9, most states
with call centers reported monitoring the volume of transactions and
calls to the center, customer satisfaction, the rate of abandoned
calls, and the length of time callers are on hold before speaking with
a caseworker. For example, Utah officials monitor several measures and
added additional staff to the call center after observing increased
hold times when they were implementing the call center to serve the
Salt Lake City area. In addition, Washington state officials told us
that they monitor call centers on an hourly basis, allowing call center
managers to quickly increase the number of staff answering phones as
call volumes increase.
Figure 9: States' Use of Measures to Monitor Performance of Call
Centers:
[See PDF for image]
Source: GAO survey.
[End of figure]
Despite these monitoring efforts, no states reported conducting an
evaluation of the effectiveness of on-line services in our survey and
only one state reported conducting such an evaluation of its call
centers. The report Illinois provided on its call center described
customer and worker feedback on the performance of the call center, but
did not provide a conclusive assessment of its effectiveness. Seven
states implementing Combined Application Projects (CAP)[Footnote 16]
have submitted reports to FNS including data on the number of
participants in the CAP project compared with when the project began,
but do not use methods to isolate the effect of the project or
determine whether participation by SSI recipients would have increased
in the absence of the project. Two of the five states we reviewed said
they planned to conduct reviews of their system. For example,
Washington is conducting an internal quality improvement review of its
call centers. It will compare call center operations with industry best
practices and promising new technologies, and will identify the costs,
services offered, and best practices used by the call centers.
Evaluation Challenges:
Few evaluations have been conducted, in part because evaluating the
effectiveness of alternative methods is challenging. For example,
states are limited in their ability to determine whether certain groups
of households are able to use alternative methods because few states
collect demographic information on households that use their on-line
services and call centers. Only six states reported in our survey that
they collect demographic information on the households that use on-line
services and four states reported collecting demographic information on
the households that use call centers. In addition, although FNS is
requiring states with waivers to the face-to-face interview to track
the payment accuracy of cases covered by these waivers, FNS has not yet
assessed the effects of these methods on decision accuracy because it
has not collected enough years of data to conduct reliable analyses of
trends. Further, evaluations that isolate the effect of specific
methods can be challenging because states implement methods at
different times and are using a combination of methods. For example,
Washington state implemented call centers in 2000, an on-line
application and CAP in 2001, and document imaging and a waiver of the
face-to-face interview at recertification in 2003. Sophisticated
methodologies often are required to isolate the effects of certain
practices or technologies. These studies can be costly to conduct
because the data collection and analysis can take years to complete.
For example, the two studies that we reviewed that aimed to isolate the
effects of specific projects each cost over $1 million and were
conducted over more than 3 years. Although evaluating the effects of
alternative methods is challenging, FNS is collecting data from states
through the waiver process that could be analyzed and previous ERS-
funded studies have used methodologies that enable researchers to
identify the effect of certain projects or practices on program access.
Federal and State Officials Report Alternative Methods Help Some
Households Access Food Stamp Benefits, but Technology and Staffing Can
Present Challenges:
Despite the limited information on the effects of alternative methods,
federal and state officials report that alternative methods, such as
the availability of telephone interviews, can help many types of
households by making it easier for them to complete the food stamp
application or recertification process. Some state and local officials
and community partners noted, however, that certain types of households
may have difficulty using some methods. Moreover, some officials also
described how technology and staffing challenges can hinder the use of
these methods.
Advantages of Alternative Methods:
According to federal and state officials we interviewed, alternative
methods can help households in several ways, such as increasing
flexibility, making it easier to receive case information or report
changes to household circumstances, or increasing efficiency of
application processing. In addition, community partner representatives
from some states we reviewed said that the availability of telephone
interviews helps reduce the stigma of applying for food stamp benefits
caused by visiting an assistance office.
* Increased flexibility. Federal officials from the seven FNS regional
offices said that alternative methods help households by reducing the
number of visits a household makes to an assistance office or by
providing additional ways to comply with program requirements.
Moreover, all of the states in our survey that currently have on-line
services and more than half of the states that currently operate call
centers, reported that reducing the number of visits an individual must
make to an office as a reason for implementing the alternative methods.
For example, in Florida a household may submit an application or
recertification through any one of the following access points --on-
line, mail, fax, community partner site, or in-person at the local
assistance office. Additionally, in certain areas of Texas, it is
possible for households to apply for food stamps without ever visiting
a local assistance office because the state has made available phone
interviews and on-line services. Reducing the number of required visits
can be helpful for all households, according to state officials or
community partner representatives in two of the states we reviewed.
* Easier access to case information and ability to report changes.
According to officials in the five states we reviewed, alternative
methods, such as call centers, automated voice response systems, or
electronic case records, make it easier for households to access
information about their benefits and report changes to household
circumstances. For example, in Washington, a household may call the
automated voice response system 24 hours a day, 7 days a week to
immediately access case information, such as appointment times or
whether their application has been received or is being processed. If
the household has additional questions, they can call the call center
where a call center agent can view their electronic case record and
provide information on the status of their application, make decisions
based on changes in household circumstances reported to them, inform
them of what verification documents are needed or have been received,
or perform other services.
* Increased efficiency. State or local officials from four of the
states we reviewed said that implementation of document management/
imaging systems improves application processing times, while local
officials in two of the states said that call centers help caseworkers
complete tasks more quickly. Furthermore, about half of the states in
our survey that have call centers reported that increasing timeliness
of application processing and reducing administrative costs were
reasons for implementing them. State officials in Florida said that the
document management/imaging system allows a caseworker to retrieve an
electronic case record in seconds compared to retrieving paper case
files that previously took up to 24 hours, allowing caseworkers to make
eligibility decisions more quickly on a case. Additionally, a call
center agent can process a change in household circumstances instantly
while on the phone. Caseworkers in Pennsylvania said that
implementation of a change reporting call center has reduced the number
of calls to caseworkers at the local assistance office, which allows
them to focus on interviewing households and processing applications
more quickly. Officials from four states we reviewed also said that use
of a document management/imaging system has resulted in fewer lost
documents, which can reduce the burden on households of having to
resubmit information.
According to some of the state officials and community partners we
interviewed, the availability of alternative methods can be especially
beneficial for working families or the elderly because it reduces
barriers from transportation, child care or work responsibilities. For
example, state officials in Florida explained that a working individual
can complete a phone interview during their lunch break without taking
time off of work to wait in line at the assistance office. In addition,
state officials from three of the states we reviewed that have
implemented CAP projects told us that they had experienced an increase
in participation among SSI recipients and FNS and officials from two
states said that households benefited from the simplified application
process. In addition, state officials in Florida said that on-line
services help elderly households that have designated representatives
to complete the application on their behalf. For example, an elderly
individual's adult child who is the appointed designated representative
but lives out-of-state can apply and recertify for food stamp benefits
for their parent without traveling to Florida.
However, some state and local officials and community partners we
interviewed said certain types of households may have difficulty using
certain alternative methods. For example, community partner
representatives in two states that we reviewed said that those with
limited English proficiency, elderly, immigrants, or those with mental
disabilities may have difficulty using on-line applications. Local
officials from Philadelphia said that the elderly and households with
very low incomes may have trouble accessing computers to use on-line
services and may not have someone helping them. A community partner in
Florida told us that sometimes the elderly, illiterate, or those with
limited English proficiency need a staff person to help them complete
the on-line application. In addition, those with limited English
proficiency, elderly, or those with mental disabilities may have
difficulty navigating the call center phone system, according to
officials from two states and community partners from another state
that we reviewed. A community partner representative in Texas said that
sometimes he calls the call center on behalf of the applicant because a
household may have experienced difficulty or frustration in navigating
the phone system.
Challenges to Using Alternative Methods:
Although officials told us that alternative methods are helpful to many
households, challenges from inadequate technology or staffing may limit
the advantages of alternative methods. For example, state officials
from Texas explained that on-line applications without electronic
signature capability have limited benefit because households are still
required to submit an actual signature through mail, fax, or in person
after completing the on-line application. Texas state officials and
community partner representatives told us that the lack of this
capability limited its use and benefit to households. By contrast,
Florida's application has electronic signature capability and Florida
officials reported that, as of December 2006, about 93 percent of their
applications are submitted on-line.
Call centers that do not have access to electronic records may not be
as effective at answering callers' questions. Officials from Washington
state and federal officials from an FNS regional office view the use of
a document management/imaging system as a vital part of the call center
system. Florida advocates said that households have received wrong
information from call center agents and attribute the complaints in
part to call center agents not having access to real-time electronic
case records. Florida recently expanded its document imaging system
statewide, which they believe will help address these concerns.
Further, while four of the five states we reviewed implemented
alternative methods in part to better manage increasing numbers of
participants with reduced numbers of staff, the staffing challenges
certain states experienced also limited the advantages of alternative
methods. For example, inadequate numbers of staff or unskilled call
center staff may reduce the level of service provided and limit the
advantages to households of having a call center available to them.
Texas and Florida have experienced significant staff reductions at a
time of increased participation, which has affected implementation of
alternative methods (see figs. 10 and 11).
Figure 10: Use of Alternative Access Methods in Texas:
[See PDF for image]
Source: GAO analysis.
[End of figure]
Figure 11: Use of Alternative Access Methods in Florida:
[See PDF for image]
Source: GAO analysis.
[End of figure]
While some states face challenges implementing alternative methods,
Utah state officials said that they have successful call centers
because they have implemented technology incrementally over time and
because they use state caseworkers experienced in program rules. Utah
state officials also reported having relatively low caseloads (180 per
worker) compared with Texas (815 per worker, in 2005).
States Report Taking Actions to Maintain Food Stamp Program Integrity
While Using Alternative Methods:
To maintain program integrity while implementing alternative methods
for applying and recertifying for food stamps, officials from the
states we reviewed reported using a variety of strategies, some of
which were in place long before implementation of the alternative
access methods. Some states used finger imaging, electronic signatures,
and special verification techniques to validate the identity of
households using call centers or on-line services. In addition, states
use databases to verify information provided by households and to
follow up on discrepancies between information reported by the
household and information obtained from other sources. Officials in the
five states we reviewed did not believe that the use of alternative
methods had increased fraud in the program. Further, despite concern
that a lack of face-to-face interaction with caseworkers would lead to
more households being denied benefits for procedural reasons, such as
missing a scheduled interview, our limited analysis indicated no
considerable fluctuations in the rate of procedural denials and
officials from the states we reviewed reported taking actions to
prevent them.
State Actions to Prevent Improper Food Stamp Payments and Fraud:
Some states have taken several actions to prevent improper food stamp
payments and fraud while implementing alternative methods. Nationally,
states have systems in place to protect program integrity and the
states we reviewed described how they prevent improper payments and
fraud as they implement alternative access methods.
* Finger imaging. Nationwide, four states[Footnote 17] currently use
finger imaging of food stamp applicants to prevent households from
applying more than once for benefits. FNS officials commented that the
agency has not concluded that finger imaging enhances program integrity
and that it may have a negative effect on program access by deterring
certain households from applying.
* Electronic signatures. FNS reported in October 2006 that nine states
use electronic signatures to validate the identity of on-line users of
their systems. For example, Florida's on-line application asks
applicants to click a button signifying that they are signing the
application. Of the states we reviewed, Pennsylvania, Florida, and
Washington have on-line services with electronic signatures.[Footnote
18]
* In-depth interview for high-risk cases. In Florida, a case that is
considered to have a greater potential for error or fraud is flagged as
a "red track" case, and it receives an in-depth interview to more fully
explore eligibility factors. FNS officials commented that Florida uses
an abbreviated interview with most households and that their in-depth
interview for red track cases may be equivalent to the standard
interview process used in other states.
* Special training for call center agents. Call center agents in the
five states we reviewed are trained to verify callers' identities by
asking for specific personal information available in the file or in
the states' records. Pennsylvania has developed specialized interview
training, including a video, for eligibility workers on conducting
telephone interviews of households applying or recertifying for the
Food Stamp Program. One element of the training is how to detect
misinformation being provided by a household. For example, if records
indicate that a household member is currently incarcerated and benefits
are being claimed for that person, call center agents are trained to
probe for additional information. Similarly, Utah trains telephone
interviewers to request more information if needed to clarify
discrepancies in the case, such as a household reporting rent payments
too high to be covered by the household's reported income.
* Data matching. States have used data matching systems for many years
and all five states we reviewed used software either developed by the
state or obtained through a third-party vendor to help with
verification of household circumstances. For example, data matching
software can match state food stamp caseloads against wage reporting
systems and other databases to identify unreported household income and
assets. Utah and Washington have developed software that automatically
compares information provided by applicants and recipients with
information contained in state databases, such as income and employment
information. State officials told us that using this software greatly
reduces the burden on caseworkers, who would otherwise have to search
multiple databases one at a time. In addition to requiring case workers
to access state and federal data sources to verify information, Texas
contracts with a private data vendor to obtain financial and other
background information on food stamp applicants and recipients. After a
household has started receiving benefits, states conduct additional
data matching, and their systems generate a notice to the caseworker if
there is a conflict between what the household reported and information
obtained from another source. The information in these notices is
investigated to ensure that recipients receive the proper level of
benefits. Finally, about half of all states participate in the
voluntary quarterly matching of their food stamp rolls with those of
other states to detect individuals receiving food stamp benefits in
more than one state at a time.
Food stamp officials in four of the states we reviewed said that they
did not believe the use of alternative methods has increased the
frequency of fraud and abuse in the program and officials in one state
were unsure and collecting data to help determine whether the frequency
of fraud had increased. Texas caseworkers, for example, told us they
did not think telephone interviews increased fraud because they
believed the verification conducted by caseworkers and the states' data
matching system was sufficient. However, we have previously reported on
the risk of improper payments and fraud in the food stamp program and
since there is always risk of fraud and improper payments, particularly
given the high volume of cases and the complexity of the program, it is
important that states include additional controls when changing their
processes and that states continually assess the adequacy of those
controls for preventing fraud.
State Actions to Limit Procedural Denials:
Some program experts have expressed concern that households would be
denied for procedural reasons more frequently if they had less face-to-
face interaction with caseworkers, although data have not borne out
these concerns and states are taking actions to limit procedural
denials. During our site visits, some officials reported examples of
procedural denials resulting from alternative methods. For example,
community group representatives in Florida said that some households
were denied benefits because they could not get through to a call
center agent to provide required verification in time. However, they
also acknowledged that procedural denials due to not providing
verification were frequent prior to the state implementing these
methods. In addition, Texas officials said that some households were
denied benefits for missing scheduled interviews when the private
contractor was late in mailing notices of the interview appointments.
Our limited analysis of FNS data for the five states we reviewed found
no considerable fluctuations in the rate of procedural denials between
fiscal years 2000 and 2005. However, a household's failure to provide
verification documents was the most common procedural reason for
denial, suspension, or termination of benefits in the five states we
reviewed. States we visited described their efforts to help households
use alternative methods and prevent procedural denials for households
that are not seen in person by case workers. Examples of actions the
states we reviewed took to prevent procedural denials include:
reviewing actions taken for cases that are denied, training caseworkers
on preventing improper denials, routinely correcting addresses from
returned mail, and developing automated system changes to prevent
caseworkers from prematurely denying a case. For example, Utah trains
its caseworkers to inform households of all deadlines, and their
application tracking software automatically generates a list of
households that have not scheduled an interview. This list is used by
caseworkers to send notices to the households. Washington uses its
document imaging center staff to process case actions associated with
returned mail, including quickly correcting addresses.
Conclusions:
Over the last several years and for a variety of reasons, many states
have changed their food stamp certification and recertification
processes to enable households to make fewer visits to the local
assistance office. Given our findings, it is important for states to
consider the needs of all types of households when developing
alternative ways of accessing food stamp benefits. Despite making major
changes in their systems, FNS and the states have little information on
the effects of the alternative methods on the Food Stamp Program,
including what factors contribute to successful implementation, whether
these methods are improving access to benefits for target groups, and
how best to ensure program integrity. Without up-to-date information
about what methods states are using and the factors that contribute to
successful implementation of alternative methods, states and the
federal government most likely will continue to invest in large-scale
changes to their certification and recertification processes without
knowing what works and in what contexts. Although FNS is beginning to
study state efforts in this regard, these studies are not designed to
systematically evaluate whether specific methods contributed to
achieving positive outcomes. In addition, FNS has not thoroughly
analyzed the data received from states implementing waivers of the face-
to-face interview to determine, for example, whether it should allow
states to use telephone interviews in lieu of face-to-face interviews
for all types of households without a waiver. Further, while FNS is
using its Website to disseminate information about promising practices,
the information available is not up-to-date, making it difficult to
easily locate current information about specific practices. Enhancing
the research, collection and dissemination of promising practices could
be an important resource for states that want to provide households
effective alternatives to visiting local assistance offices to receive
food stamp benefits.
Recommendations for Executive Action:
To improve USDA's ability to assess the effectiveness of its funded
efforts, we recommend that the Secretary of Agriculture take the
following actions:
* direct FNS and the Economic Research Service to work together to
enhance their research agendas to include projects that would
complement ongoing research efforts and determine the effect of
alternative methods on program access, decision accuracy, and
administrative costs. Such projects would reliably identify the
alternative methods that are effective and the factors that contribute
to their success; and:
* direct FNS to conduct analyses of data received from states
implementing waivers or demonstration projects waiving the face-to-face
interview and require states implementing waivers or demonstration
projects to collect and report data that would facilitate such
analyses. Such analyses would identify the effect of the waivers on
outcomes such as payment accuracy and could help determine whether the
use of the waiver should be further expanded or inform whether
regulations should be changed to allow telephone interviews for all
households without documenting hardship.
In addition, we recommend that the Secretary of Agriculture help states
implement alternative methods to provide access to the Food Stamp
Program by directing FNS to disseminate and regularly update
information on practices states are using to implement alternative
access methods to the traditional application and recertification
process. The information would not be merely a listing of practices
attempted, but would include details on what factors or contexts seemed
to make a particular practice successful and what factors may have
reduced its effectiveness.
Agency Comments:
We provided a draft of this report to the U.S. Department of
Agriculture for review and comment. We met with FNS and ERS officials
on April 16, 2007, to obtain their comments. In general, the officials
agreed with our findings, conclusions, and recommendations. They
discussed the complexity and variability of state modernization efforts
and the related challenges of researching the effects of these efforts.
For example, policy changes, organizational restructuring, and the
engagement of community organizations in the application process may
occur simultaneously with implementation of alternative methods and
play a significant role in state and client experiences. Having
multiple interrelated factors creates challenges for researching the
effects of modernization efforts. Nonetheless, the officials
highlighted steps the agency is taking to monitor and evaluate state
implementation of alternative access methods. First, the officials
commented that as modernization evolves, FNS is using its
administrative reporting system to consistently and routinely track
changes in state program performance in the areas of application
timeliness, food stamp participation by subgroups, payment accuracy,
and administrative costs. Second, they stated that the two related FNS-
funded studies currently underway will be comparing performance data
from the case study states with data from similar states; however, this
analysis will not determine whether certain modernization efforts
caused changes in performance. Third, they stated that FNS plans to
analyze data they are collecting from states as part of the
administrative waiver process to determine the effect of telephone
interviews on payment accuracy. Finally, ERS officials noted that Food
Stamp Program access is an area in which the agency continues to
solicit research from the private sector as well as other government
agencies and that ERS makes data available to support these research
efforts. FNS and ERS also provided us with technical comments, which we
incorporated where appropriate.
We are sending copies of this report to the Secretary of Agriculture,
appropriate congressional committees, and other interested parties. We
will also make copies available to others upon request. In addition,
the report will be available at no charge on GAO's Web site at
http://www.gao.gov.
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or nilsens@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 major contributions to
this report are listed in appendix III.
Sincerely,
Signed by:
Sigurd R. Nilsen, Director:
Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
To understand what alternatives states are using to improve program
access and what is known about the results of using these methods, we
examined: (1) what alternative methods to the traditional application
and recertification process are states using to increase program
access; (2) what is known about the results of these methods,
particularly on program access for target groups, decision accuracy,
and administrative costs; and (3) what actions have states taken to
maintain program integrity while implementing alternative methods.
To address these issues, we surveyed food stamp administrators in the
50 states and the District of Columbia, conducted four state site
visits (Florida, Texas, Utah, and Washington) and one set of semi-
structured telephone interviews (Pennsylvania), analyzed data provided
by the Food and Nutrition Service (FNS) and the selected states,
reviewed relevant studies, and held discussions with program
stakeholders, including officials at FNS headquarters and regional
offices, and representatives of advocacy organizations. We performed
our work from September 2006 to March 2007 in accordance with generally
accepted government auditing standards.
Survey of State Food Stamp Administrators:
To learn about state-level use of alternative methods to help
households access the Food Stamp Program, we conducted a Web-based
survey of food stamp administrators in the 50 states and the District
of Columbia. The survey was conducted between December 2006 and
February 2007 with 100 percent of state food stamp administrators
responding. The survey included questions about the use of alternative
methods to provide access to the program, including mail-in procedures,
call centers, on-line services, and other technologies that support
program access. In addition, we asked about the reasons for
implementing these methods, whether states had conducted evaluations of
the methods, what measures states used to evaluate the performance of
the methods, and additional assistance needed from FNS.
Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any survey may
introduce nonsampling errors, such as variations in how respondents
interpret questions and their willingness to offer accurate responses.
We took steps to minimize nonsampling errors, including pre-testing
draft instruments and using a Web-based administration system.
Specifically, during survey development, we pre-tested draft
instruments with officials in Washington, Arizona, Utah, and Wisconsin
in October and November 2006. In the pre-tests, we were generally
interested in the clarity of the questions and the flow and layout of
the survey. For example, we wanted to ensure definitions used in the
surveys were clear and known to the respondents, categories provided in
closed-ended questions were complete and exclusive, and the ordering of
survey sections and the questions within each section was appropriate.
We also used in-depth interviewing techniques to evaluate the answers
of pretest participants, and interviewers judged that all the
respondents' answers to the questions were based on reliable
information.
On the basis of the pre-tests, the Web instrument underwent some slight
revisions. A second step we took to minimize nonsampling errors was
using a Web-based survey. By allowing respondents to enter their
responses directly into an electronic instrument, this method
automatically created a record for each respondent in a data file and
eliminated the need for and the errors (and costs) associated with a
manual data entry process. To further minimize errors, programs used to
analyze the survey data were independently verified to ensure the
accuracy of this work.
After the survey was closed, we made comparisons between select items
from our survey data and other national-level data.[Footnote 19] We
found our survey data were reasonably consistent with the other data
set. On the basis of our comparisons, we believe our survey data are
sufficient for the purposes of our work.
State Site Visits and Structured Interviews:
We conducted four site visits (Florida, Texas, Utah, and Washington)
and one set of semi-structured telephone interviews (Pennsylvania). We
selected states that have at least one FNS-approved waiver of the face-
to-face interview requirement and reflect some variation in state
participation rates. We also considered recommendations from FNS
officials, advocacy group representatives, or researchers. We made in-
depth reviews for each state we selected. We interviewed state
officials administering and developing policy for the Food Stamp
Program, local officials in the assistance offices and call centers
where services are provided, and representatives from community-based
organizations that provide food assistance.
Reviews of FNS Data and Relevant Studies:
To supplement the information gathered through our site visits and in-
depth reviews, we analyzed data provided by FNS for the states we
reviewed. These analyses allowed us to include state trends for
specific measures (Program Access Index, monthly participation, payment
accuracy, administrative costs, and reasons for benefit denials) in our
interviews with officials. To review the reasons for benefit denials,
we used FNS's quality control (QC) system data of negative cases used
in error rate calculations. Specifically, we looked at the number and
percentage of cases denied, terminated, or suspended by the recorded
reason for the action in the five states we reviewed for fiscal years
2000 through 2005. Though our data allowed us to examine patterns in
these areas before and after a method was implemented, we did not
intend to make any statements about the effectiveness of methods
implemented in the states we visited and reviewed. Instead, we were
interested in gaining some insight through our interviews on how
alternative methods may have affected state trends. Based on
discussions with and documentation obtained from FNS officials, and
interviews with FNS staff during site visits, we determined that these
data are sufficiently reliable for our limited review of state trends.
In addition, we selected and reviewed several studies and reports that
relate to the use of alternative methods to increase food stamp program
access. These studies included food stamp participation outcome
evaluations that were funded by FNS and the Economic Research Service
(ERS) and focused on practices aimed to improve access to the Food
Stamp Program. To identify the selected studies, we conducted library
and Internet searches for research published on food stamp program
access since 1990, interviewed agency officials to identify completed
and ongoing studies on program access, and reviewed bibliographies that
focused on program access concerns. For each selected study, we
determined whether the study's findings were generally reliable. Two
GAO social science analysts evaluated the methodological soundness of
the studies, and the validity of the results and conclusions that were
drawn.
The studies we selected and reviewed include:
* U.S. Department of Agriculture, Economic Research Service, Food Stamp
Program Access Study: Final Report, by Bartlett, S., N. Burstein, and
W. Hamilton, Abt Associates Inc. (Washington, D.C.: November 2004).
* U.S. Department of Agriculture, Economic Research Service, Evaluation
of the USDA Elderly Nutrition Demonstrations, by Cody, S. and J. Ohls,
Mathematica Policy Research, Inc. (Washington, D.C.: May 2005).
* U.S. Department of Agriculture, Food and Nutrition Services, Office
of Analysis, Nutrition and Evaluation, Evaluation of Food Stamp
Research Grants to Improve Access Through New Technology and
Partnerships, by Sheila Zedlewski, David Wittenburg, Carolyn O'Brien,
Robin Koralek, Sandra Nelson, and Gretchen Rowe. (Alexandria, Va.:
September 2005).
* U.S. Department of Agriculture, Food and Consumer Service, Evaluation
of SSI/FSP Joint Processing Alternatives Demonstration, by Carol
Boussy, Russell H. Jackson, and Nancy Wemmerus. (Alexandria, Va:
January 2000.
* Combined Application Project Evaluations submitted to FNS by seven
states: Florida, Massachusetts, Mississippi, North Carolina, South
Carolina, Texas, and Washington.
[End of section]
Appendix II: State-by-State Use of Alternative Methods and Waivers of
the Face-to-Face Interview:
[See PDF for Image]
Source: GAO survey and FNS.
[End of section]
Appendix III: GAO Contact and Acknowledgments:
GAO Contact:
Sigurd R. Nilsen (202) 512-7215 nilsens@gao.gov:
Acknowledgments:
Heather McCallum Hahn, Assistant Director, Cathy Roark, Analyst-in-
Charge, Kevin Jackson, Alison Martin, Daniel Schwimer, Gretchen Snoey,
Rachael Valliere and Jill Yost made significant contributions to this
report.
[End of section]
Related GAO Products:
Food Stamp Program: FNS Could Improve Guidance and Monitoring to Help
Ensure Appropriate Use of Noncash Categorical Eligibility. GAO-07-465.
Washington, D.C.: March 28, 2007.
Food Stamp Program: Payment Errors and Trafficking Have Declined
despite Increased Program Participation. GAO-07-422T. January 31, 2007.
Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better
Targeting Stores Likely to Traffic and Increasing Penalties. GAO-07-53.
Washington, D.C.: October 13, 2006.
Improper Payments: Federal and State Coordination Needed to Report
National Improper Payment Estimates on Federal Programs. GAO-06-347.
Washington, D.C.: April 14, 2006.
Food Stamp Program: States Have Made Progress Reducing Payment Errors,
and Further Challenges Remain. GAO-05-245. Washington, D.C.: May 5,
2005.
Food Stamp Program: Farm Bill Options Ease Administrative Burden, but
Opportunities Exist to Streamline Participant Reporting Rules among
Programs. GAO-04-916. Washington, D.C.: September 16, 2004.
Food Stamp Program: Steps Have Been Taken to Increase Participation of
Working Families, but Better Tracking of Efforts Is Needed. GAO-04-346.
Washington, D.C.: March 5, 2004.
Financial Management: Coordinated Approach Needed to Address the
Government's Improper Payments Problems. GAO-02-749. Washington, D.C.:
August 9, 2002.
Food Stamp Program: States' Use of Options and Waivers to Improve
Program Administration and Promote Access. GAO-02-409. Washington,
D.C.: February 22, 2002.
Executive Guide: Strategies to Manage Improper Payments: Learning from
Public and Private Sector Organizations. GAO-02-69G. Washington, D.C.:
October 2001.
Food Stamp Program: States Seek to Reduce Payment Errors and Program
Complexity. GAO-01-272. Washington D.C.: January 19, 2001.
Food Stamp Program: Better Use of Electronic Data Could Result in
Disqualifying More Recipients Who Traffic Benefits. GAO/RCED-00-61.
Washington D.C.: March 7, 2000.
Food Assistance: Reducing the Trafficking of Food Stamp Benefits. GAO/
T-RCED-00-250. Washington D.C.: July 19, 2000.
Food Stamp Program: Information on Trafficking Food Stamp Benefits.
GAO/RCED-98-77. Washington D.C.: March 26, 1998.
FOOTNOTES
[1] Preliminary FNS data indicate that participation continued to grow
to nearly 27 million people receiving about $30 billion in food stamp
benefits in fiscal year 2006.
[2] In this report, we refer to all 50 states and the District of
Columbia as states.
[3] Reimbursements for food stamp administrative costs in 44 states are
adjusted each year to subtract certain food stamp administrative costs
that have already been factored into these states' Temporary Assistance
for Needy Families (TANF) grants. As a result, these states receive
less than 50 percent of their administrative costs. See GAO, Food Stamp
Program: States Face Reduced Federal Reimbursement for Administrative
Costs, GAO/RCED/AIMD-99-231 (Washington D.C.: July 23, 1999).
[4] As GAO and others have reported previously, following the passage
of PRWORA, there is evidence that food stamp participation dropped as
eligible recipients did not apply for food stamps because they
incorrectly assumed that if they were ineligible for TANF, they were
also ineligible for food stamps. See U.S. GAO, Food Stamp Program:
Various Factors Have Led to Declining Participation, GAO/RCED-99-185
(Washington D.C.: July 1999) for more details.
[5] The Farm Security and Rural Investment Act of 2002 (the 2002 Farm
Bill) included provisions intended to simplify program administration,
such as allowing states the option of using simplified/semiannual
reporting systems for most households, not just those with earned
income. FNS reported in October 2006 that 47 states have adopted some
form of simplified reporting, allowing most households to report
changes only when their income rises above 130 percent of the poverty
level. A FNS study suggested that simplified reporting policies have
contributed to a reduction in the food stamp payment error rate.
[6] For more information on food stamp payment accuracy and
trafficking, see Food Stamp Program: States Have Made Progress Reducing
Payment Errors, and Further Challenges Remain, GAO-05-245. (Washington,
D.C.: May 5, 2005) and Food Stamp Trafficking: FNS Could Enhance
Program Integrity by Better Targeting Stores Likely to Traffic and
Increasing Penalties, GAO-07-53. (Washington, D.C.: Oct. 13, 2006).
[7] See appendix II for state-by-state information on use of
alternative methods.
[8] Utah began piloting an on-line application with electronic
signature capability in March 2007. Because this was after the time our
survey was conducted, Utah is not included in the 14 states that
currently provide on-line services. FNS reported in October 2006 that
nine states nationwide allow applicants to submit the application with
an electronic signature.
[9] See appendix II for names of states with administrative waivers
that allow substitution of a telephone interview for the face-to-face
interview.
[10] Utah began piloting an on-line application with electronic
signature capability in March 2007. Because this was after the time our
survey was conducted, Utah is not included in the 14 states that
currently provide on-line services.
[11] Evaluation of the USDA Elderly Nutrition Demonstrations, Scott
Cody and James Ohls, Mathematica Policy Research, Inc., May 2005.
[12] In addition to studies that are under way, the fiscal year 2008
Food Nutrition and Consumer Services budget request, which includes
FNS, includes $2 million to support Food Stamp Modernization and
Innovation Projects to study the impact of new Food Stamp Program
service delivery models on program access, payment accuracy, and
administrative costs.
[13] State Best Practices Improving Food Stamp Program Access, USDA,
FNS, (June 2002).
[14] Advocacy groups such as the American Public Human Services
Association and the Food Research Action Center also make information
available on food stamp outreach and access in best practices guides,
on their Web sites, or through conferences.
[15] Food Stamp Program: Steps Have Been Taken to Increase
Participation of Working Families, but Better Tracking of Efforts Is
Needed, GAO-04-346 (Washington, D.C.: March 5, 2004).
[16] Combined Application Projects (CAP) allow one-person SSI
households to file a shortened food stamp application form and waive
the face-to-face interview requirement.
[17] Texas, California, New York, and Arizona.
[18] Utah also began piloting an on-line application with electronic
signature capability in March 2007.
[19] We compared our Web-based survey data to data reported by FNS in
the 2006 State Options Report.
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