Food Stamp Program
Farm Bill Options Ease Administrative Burden, but Opportunities Exist to Streamline Participant Reporting Rules among Programs
Gao ID: GAO-04-916 September 16, 2004
Many individuals familiar with the Food Stamp Program view its rules as unnecessarily complex, creating an administrative burden for participants and caseworkers. In addition many participants receive benefits from other programs that have different program rules, adding to the complexity of accurately determining program benefits and eligibility. The 2002 Farm Bill introduced new options to help simplify the program. This report examines (1) which options states have chosen to implement and why, and (2) what changes local officials reported as a result of using these options. Selected results from GAO's web-based survey of food stamp administrators are provided in an e-supplement to this report, GAO-04-1058SP. Another e-supplement, GAO-04-1059SP, contains results from the local food stamp office surveys.
As of January 2004, states chose four of the eight Farm Bill options with greater frequency than the others. These options provided states with more flexibility in requiring participants to report changes and in determining eligibility. The most common reasons state officials gave for choosing the eight options were to simplify program rules for participants and caseworkers. Local food stamp officials reported mixed results from implementing the Farm Bill options. Although they reported some improvements for both caseworkers and participants from some options, no option received consistent positive reports in all the areas where state officials expected improvements. In fact, in many cases, officials were as likely to report that an option resulted in no change as they were to report improvements. Moreover, many local officials reported that three options introduced complications in program rules. One option that offered the most promise because it was selected by most states and affects a large number of participants resulted in food stamp participant reporting rules that differed from Medicaid and TANF. These differences resulted in confusion for food stamp participants and caseworkers, and some changes were made that undermined the intended advantages of the option. These problems reflect the challenge of trying to simplify rules for one program without making the rules of other related programs the same. Concerns about whether there are costs associated with aligning reporting rules may hinder a state's decision to pursue alignment; yet the extent to which program costs might increase as a result of making reporting rules the same is unclear.
Recommendations
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GAO-04-916, Food Stamp Program: Farm Bill Options Ease Administrative Burden, but Opportunities Exist to Streamline Participant Reporting Rules among Programs
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Report to the Committee on Agriculture, Nutrition, and Forestry, U.S.
Senate:
United States Government Accountability Office:
GAO:
September 2004:
FOOD STAMP PROGRAM:
Farm Bill Options Ease Administrative Burden, but Opportunities Exist
to Streamline Participant Reporting Rules among Programs:
GAO-04-916:
GAO Highlights:
Highlights of GAO-04-916, a report to Committee on Agriculture,
Nutrition, and Forestry, U.S. Senate:
Why GAO Did This Study:
Many individuals familiar with the Food Stamp Program view its rules
as unnecessarily complex, creating an administrative burden for
participants and caseworkers. In addition many participants receive
benefits from other programs that have different program rules, adding
to the complexity of accurately determining program benefits and
eligibility. The 2002 Farm Bill introduced new options to help simplify
the program. This report examines (1) which options states have chosen
to implement and why, and (2) what changes local officials reported as
a result of using these options. To view selected results from GAO‘s
Web-based survey of food stamp administrators, go to
www.gao.gov/cgi-bin/getrpt?GAO-04-1058SP. To view the results from the
local food stamp office surveys, go to
www.gao.gov/cgi-bin/getrpt?GAO-04-1059SP.
What GAO Found:
As of January 2004, states chose four of the eight Farm Bill options
with greater frequency than the others. These options provided states
with more flexibility in requiring participants to report changes and
in determining eligibility.
Number of States That Have Chosen, Implemented, or Not Chosen Farm
Bill Options as of January 2004:
[See PDF for image]
[End of section]
The most common reasons state officials gave for choosing the eight
options were to simplify program rules for participants and
caseworkers.
Local food stamp officials reported mixed results from implementing
the Farm Bill options. Although they reported some improvements for
both caseworkers and participants from some options, no option received
consistent positive reports in all the areas where state officials
expected improvements. In fact, in many cases, officials were as
likely to report that an option resulted in no change as they were to
report improvements.
Moreover, many local officials reported that three options introduced
complications in program rules. One option that offered the most
promise because it was selected by most states and affects a large
number of participants resulted in food stamp participant reporting
rules that differed from Medicaid and TANF. These differences resulted
in confusion for food stamp participants and caseworkers, and some
changes were made that undermined the intended advantages of the
option. These problems reflect the challenge of trying to simplify
rules for one program without making the rules of other related
programs the same. Concerns about whether there are costs associated
with aligning reporting rules may hinder a state‘s decision to pursue
alignment; yet the extent to which program costs might increase as a
result of making reporting rules the same is unclear.
What GAO Recommends:
GAO recommends that the Food and Nutrition Service (FNS) work with the
Department of Health and Human Services to (1) encourage states to
explore the advantages and disadvantages of better aligning
participant reporting rules, particularly for Medicaid and Temporary
Assistance for Needy Families (TANF) and (2) provide information to
states on the opportunities for better aligning reporting rules. In
comments on GAO‘s draft report, FNS officials agreed with our
recommendations and said they plan to explore ways to align participant
reporting rules.
www.gao.gov/cgi-bin/getrpt?GAO-04-916.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Sigurd Nilsen, (202)
512-7215 nilsens@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
States Chose Some Farm Bill Options More Frequently than Others to
Simplify Program Rules and Ease the Administrative Burden for
Participants and Caseworkers:
Local Food Stamp Officials Reported Mixed Results for Farm Bill
Options; These Results Ranged from Improvements to Complications:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Objective, Scope, and Methodology:
Appendix II: Farm Bill Options That States Have Implemented as of
January 2004:
Appendix III: Selected Responses to State Survey:
Appendix IV: Selected Responses to Local Surveys:
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Acknowledgments:
Related GAO Products:
Table:
Table 1: Disposition of Eight Farm Bill Option Samples:
Figures:
Figure 1: Description and Purpose of Farm Bill Options:
Figure 2: Number of States That Have Chosen, Implemented, or Not Chosen
Farm Bill Options, as of January 2004:
Figure 3: Important Reasons for Choosing Options:
Figure 4: Important Reasons for Not Choosing Options:
Figure 5: Results Reported by Local Officials on Administrative Burden
for Participants and Caseworkers:
Figure 6: Results Reported by Local Officials on Error Rate,
Participation, Benefit Amount, and Alignment:
Figure 7: Example of Possible Decisions and Actions under the Expanded
Simplified Reporting Option:
Figure 8: Farm Bill Options States Have Implemented as of January 2004:
Figure 9: Number of States That Gave Reasons for Choosing Options:
Figure 10: Number of States That Gave Reasons for Not Choosing Options:
Figure 11: Expanded Simplified Reporting:
Figure 12: Simplified Standard Utility Allowance:
Figure 13: Simplified Definition of Income:
Figure 14: Simplified Definition of Resources:
Figure 15: Transitional Benefits:
Figure 16: Child Support Expense Income Exclusion:
Figure 17: Simplified Determination of Deductions:
Abbreviations:
CMS: Centers for Medicare and Medicaid Services:
HHS: Department of Health and Human Services:
FNS: Food and Nutrition Service:
TANF: Temporary Assistance for Needy Families:
USDA: U.S. Department of Agriculture:
United States Government Accountability Office:
Washington, DC 20548:
September 16, 2004:
The Honorable Thad Cochran:
Chairman:
The Honorable Tom Harkin:
Ranking Minority Member:
Committee on Agriculture, Nutrition, and Forestry:
United States Senate:
In fiscal year 2003, the federal Food Stamp Program, administered by
the U.S. Department of Agriculture's (USDA) Food and Nutrition Service
(FNS), provided about $21.4 billion in food stamp benefits. In that
same year, the program helped a monthly average of 21 million low-
income individuals, many of whom were children. However, the program
faces a number of challenges. Many individuals familiar with the Food
Stamp Program view its rules as unnecessarily complex, creating an
administrative burden for both program participants and affected
government offices. In addition, many food stamp participants receive
benefits from other low-income assistance programs, such as Medicaid
and Temporary Assistance for Needy Families (TANF). These programs,
administered by the Department of Health and Human Services (HHS) have
different rules than those allowed under the Food Stamp Program.
Differences among these program rules add to the complexity of
accurately determining eligibility and program benefits. In 2003,
errors in overpayments and underpayments totaled $1.4 billion. These
errors occurred in part because of the complexity of program rules.
Further, FNS estimated that in September 2001, only 62 percent of
individuals who were eligible to receive food stamps participated in
the program. In the previous year, FNS established a goal to improve
the rate of food stamp participation among all eligible people to 68
percent by 2005.
For many years, states and advocacy groups have called for changes in
the program to help overcome these challenges. Some changes were made
to the program beginning in the late 1990s, and the Farm Security and
Rural Investment Act of 2002 (referred to in this report as the Farm
Bill) introduced new options, from which states could choose, to help
simplify the program, encourage greater participation among eligible
households, ease the administrative burden for participants and program
administrators, and help support low-income working families. For
example, one option reduces participant reporting requirements, while
another helps to ensure that families leaving TANF cash assistance
continue to receive their food stamp benefits without requiring the
family to reapply or submit additional paperwork. In addition, some of
these options permit states to more closely align food stamp
eligibility rules with the eligibility rules of other programs, an
improvement that could streamline administrative procedures for food
stamp workers, improve service for clients who participate in more than
one assistance program, and help reduce state payment error rates. In
order to understand whether the Farm Bill options have helped states
streamline their programs, you asked us to determine (1) which options
states have chosen to implement and why, and (2) what changes local
officials reported as a result of implementing these options.
To answer these questions, we surveyed food stamp administrators in the
50 states and the District of Columbia to collect information on which
Farm Bill options states have chosen and the reasons states chose
certain options. We also sent over 1,300 surveys to food stamp
supervisors in randomly selected local food stamp offices, where the
options are actually implemented during daily contacts with
participants. These survey results are generalizable to local offices
in states that implemented the options. We asked them how Farm Bill
options had affected several aspects of the Food Stamp Program, such as
administrative burden on participants and food stamp
caseworkers.[Footnote 1] We focused our surveys on eight of the nine
Farm Bill options, excluding one option that allows states on a pilot
basis to test issuing standardized benefits to residents of certain
group facilities. To view selected results from GAO's Web-based survey
of food stamp administrators, go to www.gao.gov/cgi-bin/getrpt?GAO-04-
1058SP. To view the results from the local food stamp office surveys,
go to www.gao.gov/cgi-bin/getrpt?GAO-04-1059SP.
To augment information from our state and local surveys, we conducted
three comprehensive site visits (Arizona, Maryland, and Michigan) and
two structured telephone interviews (Colorado and South Carolina). We
chose states for our site visits and telephone interviews to capture
the variation in the following criteria: (1) number of and type of
selected options, (2) numbers of food stamp participants and program
participation rate, (3) program error rates, and (4) entity (state or
county) administering the Food Stamp Program. During each visit we met
with state officials administering and developing policy for the Food
Stamp Program, local officials in the office where services are
provided, and officials responsible for other key assistance programs,
such as TANF and Medicaid.[Footnote 2] We also reviewed Farm Bill
legislation and related committee reports, and we reviewed FNS reports
and other program analysis. We held discussions with program
stakeholders, including officials at FNS headquarters and regional
offices, officials at HHS, representatives of advocacy organizations,
and other program experts. We performed our work from August 2003 to
June 2004 in accordance with generally accepted government auditing
standards.
Results in Brief:
States chose four of the eight options available in the Farm Bill more
frequently than the others and based their decisions largely on whether
they thought the options would help simplify Food Stamp Program rules
and ease the administrative burden for food stamp participants and
caseworkers. The four options that states chose most frequently
provided states more flexibility in how often participants must report
changes in their household circumstances (such as increases in income),
the way food stamp caseworkers in local offices calculate utility
costs, what household income is considered when determining food stamp
eligibility, and what household resources are considered when
determining eligibility. As of January 2004, each of these four options
had been implemented by at least 23 states, and other states told us
that they were planning to implement them. State officials gave many
reasons for choosing these options. Among the most common were to
decrease the workload for caseworkers, decrease the burden on
participants, and simplify rules for participants and caseworkers. For
example, at least 30 states cited these reasons in choosing the option
to reduce how often participants must report changes in household
circumstances. In addition, many states chose one or more of these
options because officials believed the option would decrease their
state's payment error rate, help align the Food Stamp Program with
other assistance programs, or increase overall participation in the
Food Stamp Program. States' decisions not to adopt the four other
options also hinged on what they believed the outcomes would be for
participants and caseworkers. These options allowed states to provide
transitional food stamps for up to 5 months to those families that
leave TANF without requiring the family to reapply for food stamps,
change how caseworkers treat child support payments for noncustodial
parents, disregard changes in certain deductions (such as child care
and medical expenses) during certification periods, and use a standard
deduction for homeless households that incur some shelter expenses.
Specifically, fewer states thought these other options would reduce the
administrative burden for participants and caseworkers. For example,
many states did not choose the option that provides transitional food
stamps for up to 5 months after a household leaves TANF cash assistance
because officials believed it would make program rules for participants
and caseworkers more complicated. Many states also thought these
options would have little or no advantage over current policy or would
create additional problems, including difficulties with programming
their computer systems. In fact, the majority of states that adopted
these four options reported that they faced some implementation
hurdles, such as difficulties related to caseworkers' adjustment to
program changes and reprogramming computer systems to accommodate
changes.
Local food stamp officials reported mixed results from implementing the
options; the results ranged from anticipated improvements to
complications in program rules. For example, some local officials
reported that the options they implemented had the anticipated effect
of easing the administrative burden for food stamp participants and
caseworkers by reducing the number of times participants are required
to submit paperwork and the amount of time caseworkers spend on
paperwork. On the other hand, many other local officials reported that
the administrative burden remained the same before and after
implementing the Farm Bill options. Similarly, for options implemented
in part to increase program participation, some local officials
reported that participation increased, while others told us that it
remained the same. Some options may have been associated with no
change, in part because they affected few food stamp participants.
Also, many options made minor changes to existing policy. Finally,
local officials reported that three options introduced complications in
program rules for both caseworkers and participants. Local officials
told us that the option to reduce reporting requirements for
participants--an option that local officials reported affected most
food stamp participants--introduced complications for food stamp
participants and caseworkers. Local officials on our site visits and in
telephone interviews explained that this change to reporting rules was
not consistent with how states structured the reporting rules of other
assistance programs, resulting in food stamp reporting rules that are
not aligned with Medicaid and, in all but one state we visited, are not
aligned with TANF. For example, in one state, the Food Stamp Program
requires a participant to report when his or her income rises above 130
percent of the federal poverty level, but that state's Medicaid program
requires the same participant to report all changes in household
circumstances, including any change in income. The variation among
these reporting rules often resulted in confusion on the part of
program participants and caseworkers, unnecessary work for the
caseworker, and the possible payment of improper benefits from the Food
Stamp Program and other assistance programs.
In order to take advantage of existing opportunities available to
states for streamlining participant reporting rules, we recommend that
the Secretary of Agriculture direct FNS to collaborate with HHS to take
the following two actions: (1) encourage state officials to explore the
advantages and disadvantages--in terms of both administrative and
benefit costs and savings--of better aligning participant reporting
rules in their states, particularly for Medicaid and TANF; and (2)
disseminate information and guidance to states on the opportunities
available for better aligning participant reporting rules among food
stamps, Medicaid, and TANF. In comments on GAO's draft report, FNS
officials agreed with our recommendations and said they plan to explore
ways to align participant reporting rules.
Background:
The federal Food Stamp Program is intended to help low-income
individuals and families obtain a better diet by supplementing their
income with benefits to purchase food. FNS pays the full cost of food
stamp benefits and shares the states' administrative cost--with FNS
paying about 50 percent of the administrative cost. FNS is responsible
for promulgating program regulations and ensuring that state officials
administer the program in compliance with program rules. The states
administer the program by determining whether households meet the
program's income and asset requirements, calculating monthly benefits
for qualified households, and issuing benefits to participants on an
electronic benefits transfer card.
Determination of Eligibility and Benefits:
Eligibility for participation in the Food Stamp Program is based on the
Department of Health and Human Services' poverty guideline for
households. In most states, a household's gross income cannot exceed
130 percent of the federal poverty level (or about $1,654 per month for
a family of three in 2003), and net income cannot exceed 100 percent of
the poverty guideline (or about $1,272 per month for a family of three
in 2003). Net income is determined by deducting from gross income
expenses such as dependent care costs, medical expenses, utilities
costs, and shelter expenses. In addition, most states place a limit of
$2,000 on household assets, and basic program rules limit the value of
vehicles an applicant can own and still be eligible for the
program.[Footnote 3] If the household owns a vehicle worth more than
$4,650, the excess value is included in calculating the household's
assets.[Footnote 4]
Recipients of TANF cash assistance are automatically eligible for food
stamps--a provision referred to as "categorical eligibility"--and do
not have to go through a separate food stamp eligibility determination
process, although the level of their benefits must still be determined.
Many needy families who are no longer receiving TANF cash assistance
may receive other TANF-funded services or benefits, such as child care
benefits. In 1999, to help ensure that these families are also eligible
for food stamp benefits, FNS offered states the option to extend
categorical eligibility to families receiving TANF-funded benefits or
services. Families who are automatically eligible for food stamps do
not have to meet the food stamp asset test in order to receive benefits
but would have to meet the state's TANF asset test.
States also have two ways in which they can allow households to own a
vehicle that is worth more than the amount allowed in current
regulations and still remain eligible for food stamp benefits. In
October 2000, in part to help support low-income working families, the
Congress enacted legislation that grants states the option to replace
the federal food stamp vehicle asset rule with the vehicle asset rule
from their TANF assistance program, which is set by the state and can
vary from state to state. States can also opt to use the categorical
eligibility option as a way to exclude all vehicles, as well as other
assets the family may have. This option affects the food stamp
eligibility only of food stamp families authorized to receive a TANF-
funded service or benefit. As of October 2003, the majority of states
had either replaced their federal food stamp vehicle asset rule with
the vehicle asset rule from their TANF assistance program or conferred
categorical eligibility as a way to exclude vehicles.
Certification and Reporting Requirements:
After eligibility is established, households are certified eligible for
food stamps for periods ranging from 1 to 24 months. The length of the
certification period depends on household circumstances, but only
households in which all members are elderly or disabled can be
certified for more than 12 months. Once the certification period ends,
households must reapply for benefits, at which time eligibility and
benefit levels are redetermined.[Footnote 5]
Between certification periods, households must report changes in their
circumstances--such as household composition, income, and expenses--
that may affect their eligibility or benefit amounts. States have the
option of requiring food stamp participants to report on their
financial circumstances at various intervals and in various ways.
States can institute a type of periodic reporting system or they can
rely on households to report changes in their household circumstances
within 10 days of occurrence.[Footnote 6] Under periodic reporting,
participants may report monthly, quarterly, or under a simplified
system. The simplified reporting system, available since early 2001,
provides for an alternative reporting option that requires households
with earned income to report changes only when their income rises above
130 percent of the poverty level.
FNS's Quality Control System:
FNS monitors how accurately states determine food stamp eligibility and
calculate benefits. Under FNS's quality control system, the states
calculate their payment errors by drawing a statistical sample to
determine whether participating households received the correct benefit
amount.[Footnote 7] Improper payments, which include overpayments of
food stamp benefits to participants, underpayments to participants, and
payments to those who are not eligible, may occur for a variety of
reasons. Overpayments can be caused by inadvertent or intentional
errors made by recipients and caseworkers. For example, caseworkers may
misapply complex food stamp rules when calculating benefits or
participants may inadvertently or deliberately provide inaccurate
information to food stamp offices. In the 1990s, the states' error rate
hovered around 10 percent, but it fell to 6.6 percent in fiscal year
2003, the lowest level in the program's history. The 2003 combined
error rate comprised $1 billion in overpayments to food stamp
participants and underpayments of more than $300 million. According to
USDA, about half of all payment errors are due to an incorrect
determination of household income.
The Farm Bill changed the Food Stamp Program's quality control system
by making only those states with persistently high error rates face
liabilities.[Footnote 8] The Farm Bill also provides for $48 million in
bonuses each year to be awarded to states with high or most improved
performance, including actions taken to correct errors, reduce error
rates, improve eligibility determinations, and other indicators of
effective administration as approved by the Secretary of
Agriculture.[Footnote 9]
Food Stamp Participants Receive Benefits from Other Assistance
Programs:
Many food stamp participants receive benefits from other federally
funded low-income assistance programs, including Medicaid and TANF. For
example, in 2002, about 85 percent of children who received food stamp
benefits were also on Medicaid, and about 20 percent of food stamp
households received assistance from TANF. Many food stamp participants
also receive child care assistance and Supplemental Security
Income.[Footnote 10] In most states, the Food Stamp Program is
administered out of a local assistance office that offers benefits from
these other assistance programs as well. Food stamp participants may
provide necessary information to only one caseworker who determines
eligibility and benefits for all of these programs, or they may work
with several caseworkers that administer benefits for different
programs.
Despite the overlap in the populations served by these various
assistance programs, program rules and requirements across these
programs vary significantly.[Footnote 11] Substantial variation exists
not only in program financial eligibility rules. The primary sources of
these variations are generally at the federal level, although for
several programs, such as TANF and Medicaid, states and localities have
some flexibility in setting financial eligibility rules. They also have
flexibility in the rules that govern how often participants are
required to report changes in their household circumstances. While the
Food Stamp Program allows states to choose either periodic or change
reporting, Medicaid provides states with even broader flexibility to
establish rules for when Medicaid participants must report changes in
their circumstances. Under Medicaid regulations, states must have
procedures designed to ensure that participants make timely and
accurate reports of any change in circumstances that may affect their
eligibility and that states act promptly to redetermine eligibility
based on the reported change in circumstances. However, the terms
"timely" and "promptly" are not defined and can be interpreted in
various ways by the states. TANF does not mandate a particular set of
participant reporting rules and generally allows states to develop
their own rules.[Footnote 12]
Options Made Available by the Farm Bill:
The Farm Bill makes available to states various new options that are
intended to simplify food stamp program rules, streamline food stamp
eligibility and benefit rules, and help ensure that food stamp
participants experience as smooth a transition from welfare to work as
possible. (See fig. 1.)
Figure 1: Description and Purpose of Farm Bill Options:
[See PDF for image]
[A] In addition to having these eight options, states also have the
option, on a pilot basis, to test issuing standardized benefits to
residents of certain group homes, such as facilities for the disabled
or that operate drug or alcohol treatment programs. The standardized
benefit would be in lieu of the regular food stamp benefit and would be
developed by the state, taking into account the food stamp benefits
typically received by residents of the covered group facilities.
[B] The Farm Bill refers to this option as Simplified Determination of
Housing Costs.
[End of figure]
States Chose Some Farm Bill Options More Frequently than Others to
Simplify Program Rules and Ease the Administrative Burden for
Participants and Caseworkers:
States chose four of the Farm Bill options with greater frequency than
the others. State officials gave reasons for choosing, or not choosing,
the options that focused primarily on how they thought the options
would affect food stamp participants and caseworkers. Other reasons
were also important in the choice of some options. For example, the
anticipated effect on the state's payment error rate was a key factor
in the selection of most options. During the period when states were
implementing the food stamp options, a number of them posed challenges
for the states, such as difficulties related to caseworkers' adjustment
to program changes and programming computer systems.
States Were Most Likely to Choose Four of the Options:
According to our survey of state food stamp administrators, 23 or more
states had implemented four of the options as of January 2004, while
less than one-quarter of the states had implemented the other four
options. (See fig. 2. Also see app. II for the options that individual
states have chosen and implemented.)
Figure 2: Number of States That Have Chosen, Implemented, or Not Chosen
Farm Bill Options, as of January 2004:
[See PDF for image]
Notes:
The Simplified Homeless Shelter Costs "chosen and implemented" category
only includes states that indicated they did not have a Standard
Homeless Shelter Allowance of $143 prior to the Farm Bill. The "not
chosen" category for this option includes 21 states that indicated they
already had a Standard Homeless Shelter Allowance of $143 prior to the
Farm Bill. One state did not respond to Simplified Homeless Shelter
Costs status item.
One state did not respond to the Expanded Simplified Reporting status
item.
[End of figure]
The Reasons States Gave for Choosing Options Were Largely Based on the
Anticipated Effects on Participants and Caseworkers:
The most common reasons state officials gave for choosing the eight
options were to simplify program rules for participants and
caseworkers, according to our survey. For example, state officials we
interviewed told us they thought program rules would be less confusing
for participants if the types of income considered in eligibility
determinations were more uniform across assistance programs, as is
allowed by the Simplified Definition of Income option. In addition,
officials in one state commented that they thought the Simplified
Standard Utility Allowance option would make the rules less complicated
for caseworkers because it would allow them to apply the standard
utility allowance--a fixed amount that can be used in place of actual
utility costs--to households sharing a residence, instead of having to
prorate the actual utility costs of the household. (See fig. 3 and app.
III for more detail on reasons states chose options.)
Figure 3: Important Reasons for Choosing Options:
[See PDF for image]
[A] Simplified Homeless Shelter Costs option only includes states that
indicated they did not have a Standard Homeless Shelter Allowance of
$143 prior to the Farm Bill.
[B] We only asked the child support item for the Child Support Expense
Income Exclusion option.
[End of figure]
In addition, two important reasons state officials gave for choosing
options were to decrease the burden on participants and decrease the
workload for caseworkers, as shown in figure 3. For example, several
state officials told us they thought options such as Simplified
Homeless Shelter Costs and Simplified Standard Utility Allowance that
allow states to use a standard allowance rather than actual costs in
determining eligibility would provide relief for participants and
caseworkers. When standard allowances are used, participants do not
have to furnish proof of all actual costs and, correspondingly,
caseworkers have less information to verify.[Footnote 13] In addition,
some state officials told us that they thought an option, such as
Transitional Benefits, that decreases the frequency with which
participants must report changes would reduce workload. Under the
Transitional Benefits option, households leaving TANF are automatically
allowed up to 5 months of food stamp benefits and are not required to
report changes in household circumstances during the transitional
period.
Other reasons were also important in the choice of some options.
Lowering their state's payment error rate was an important reason state
officials gave for choosing seven of the options, including the
Expanded Simplified Reporting option. States choosing this option are
held responsible only for errors that result from miscalculating
benefits at certification, or if income exceeds 130 percent of poverty
and the change is not reported during the reporting period. A state's
error rate is also not affected if the household experienced a change
in its circumstances that it did not report. In addition, officials in
one state told us they thought the Transitional Benefits option would
lower the state's payment error rate because it allows for certain
periods in which states are to be held harmless for unreported changes.
Otherwise, these unreported changes could be included in calculating
the error rate. Further, officials told us that the income option would
make the Food Stamp Program less error prone because it allows states
to use some of the same income definitions that are used when
determining eligibility for TANF cash assistance or Medicaid. This
alignment of income definitions may result in fewer errors because
following one set of program rules is easier for participants and
caseworkers than trying to adhere to many different sets of rules.
Increasing participation in the Food Stamp Program, including
participation of working families, was also an important reason for
choosing three of the options. For example, officials in one state told
us that they believed the Expanded Simplified Reporting option would
contribute to higher participation rates because cases would not be
closed as often under this option. In addition, state officials
reported that they thought the Child Support Expense Income Exclusion
option would help more households to receive food stamps by making it
easier for them to meet eligibility requirements. This option allows
states to exclude legally obligated child support payments from the
gross income of the noncustodial parent who is paying the child support
when determining food stamp eligibility. Without the option, these
child support payments are deducted from the noncustodial parent's
income after eligibility for food stamps is already
determined.[Footnote 14]
State officials we surveyed gave additional reasons for choosing some
options, including the desire to align food stamps with other
assistance programs, increase benefit amounts for participants, and
encourage payment of child support. Aligning the Food Stamp Program's
definition of income and resource rules with those used by TANF or
Medicaid--that is, conforming the definitions of income and resources
states use in the Food Stamp Program to the definitions they use in
their TANF or Medicaid program--was an important reason for choosing
the income and resources options. Increasing benefit amounts for
participants was an important reason for choosing some options,
including Transitional Benefits. Officials in one state told us they
thought this option would result in greater benefit amounts for
households leaving TANF because the new income that rendered them
ineligible for TANF is not included in the calculation of their benefit
amount for the transitional period. If this additional income were
taken into account, it would most likely result in a lower benefit
amount. Finally, among other reasons, state officials chose the Child
Support Expense Income Exclusion option because they thought it would
encourage payment of child support.
The Reasons States Gave for Not Choosing Options Were Primarily Related
to Anticipated Effects on Participants and Caseworkers and Other
Aspects of the Program:
State officials gave a number of reasons for not choosing options.
Among the most common was their belief that the option would complicate
rules for participants and complicate rules for caseworkers in their
state. Because of the variability among states in the design of Food
Stamp Programs and other assistance programs, an option that simplified
processes in one state may have a different effect in other states. For
example, officials in two states commented that they thought the
Simplified Determination of Deductions option might confuse
participants and caseworkers because it would create additional, and
sometimes conflicting, participant reporting rules in their state. As
one state official noted, this option, which allows states to disregard
reported changes in certain deductions during the certification period,
could be confusing for caseworkers because of its inconsistency with
her stateís policy to act on all reported changes. (See fig. 4. Also
see app. III for more detail on reasons states did not choose
options.)
Figure 4: Important Reasons for Not Choosing Options:
[See PDF for image]
Note: Data for Simplified Homeless Shelter Costs option are not
available.
[End of figure]
State officials gave additional reasons for not choosing some of the
options. An important reason for not choosing two of the options was
that officials believed the options would result in little or no
increase in the amount of food stamp benefits for participants in their
state. For example, officials in several states noted that according to
their calculations, implementing the child support option would not
increase food stamp benefit amounts for participants in their state who
pay child support. In addition, some state officials commented that
they did not choose the deductions option, which allows states to
disregard reported changes in certain deductions during the
certification period, because they believed the option could prevent
participants from receiving additional benefits if their expenses
increased during this period.
State officials also reported an important reason they did not choose
three of the options was because of their belief that the options would
affect very few participants in their state. For example, some state
officials reported that the number of households that would be helped
by the Transitional Benefits option in their state would be relatively
small because their state had implemented simplified reporting systems
that provided similar advantages, such as allowing households to forgo
reporting most changes between scheduled reporting periods. Similarly,
officials in one state commented that they thought the child support
option would not increase the number of eligible households in their
state because many of the affected households would already be
categorically eligible for food stamps.
In addition, an important reason state officials gave for not choosing
five of the options was that they thought the options would have little
or no advantage over current policy in their state. For example,
officials in some states commented that the income and resources
options would not allow them much additional flexibility in their Food
Stamp Program definitions because FNS placed restrictions on the types
of incomes and resources that could be excluded under these options,
while one other state official noted that before these options became
available, they had already largely aligned TANF and Medicaid
definitions of resources with those used by the Food Stamp Program. In
addition, other state officials told us the deductions option would be
duplicative in their state because they had already implemented
simplified reporting options that exempt participating households from
reporting changes in the deductions covered by this option during the
certification period.
Other reasons were important for not choosing some options, including a
possible increase in the state's payment error rate or the difficulty
in programming the state's computer system to implement the change.
Officials in some states said they thought the Expanded Simplified
Reporting option might increase the payment error rate in their state.
Simplified reporting systems reduce the frequency with which households
must report changes, which may make the reporting rules of food stamps
different from those of other assistance programs in the state that
require households to report changes on a more regular basis. These
differences in reporting rules could lead to errors by participants and
caseworkers, who often determine eligibility for more than one
assistance program. In addition, some state officials reported that
they did not choose the Transitional Benefits option because the
required changes would be too difficult to program into their state's
computer systems. Food stamp computer systems in many states are
integrated with other assistance programs, such as TANF and Medicaid.
Implementation Challenges for States Choosing Certain Options:
In states that did choose specific options, a number of these options
posed challenges for the states during initial implementation. Reported
challenges included difficulties related to caseworkers' adjustment to
program changes, lack of alignment with other assistance programs, and
programming state computer systems. For example, officials in one state
told us caseworkers had trouble adjusting to the new reporting system
under Simplified Determination of Deductions because many were
accustomed to the former system in which participants reported, and
caseworkers acted on, changes in some household deductions within 10
days of the change. In addition, state officials told us some options,
such as Expanded Simplified Reporting, lessened the degree to which
Food Stamp Program rules aligned with those of other assistance
programs, which also presented challenges. Food stamp officials in one
state told us they selected the Expanded Simplified Reporting option
even though they knew it was going to result in food stamp reporting
rules that were different from those of another assistance program
because they thought the option would have many benefits for
participants. Finally, difficulties with programming computers were
commonly mentioned challenges to implementation. We heard from
officials in two states that had implemented the Transitional Benefits
option that this integration posed difficulties for them. These
officials reported that they had to delink the connection with other
programs so that the food stamp benefit remained frozen during the 5-
month transitional period, regardless of the information recorded in
the computer system for the other assistance programs. Officials from
seven states provided cost estimates for implementing the options. The
cost estimates ranged from $14,880 to $3.7 million, almost all of
which, in six of the states, represented the costs of changing the
state's computer system. These estimates included costs for such
expenses as programming and testing the computer systems. Other states
did not provide estimates for the costs of implementing the options.
Local Food Stamp Officials Reported Mixed Results for Farm Bill
Options; These Results Ranged from Improvements to Complications:
Local food stamp officials, who often have day-to-day contact with
frontline caseworkers and food stamp participants, reported mixed
results from implementing the Farm Bill options; the results ranged
from improvements to complications. They reported that most of the
options achieved at least some of the improvements anticipated by state
officials. However, in a number of cases, local officials reported that
the options did not result in expected improvements, or their opinions
differed on whether the option achieved the anticipated result.
Finally, local officials reported that three options introduced
complications in program rules for both caseworkers and participants.
Local Food Stamp Officials Reported the Options Achieved Some, but Not
All, Anticipated Improvements:
Local food stamp officials reported on our survey that the options
resulted in some, but not all, of the improvements anticipated by state
officials. The officials' views were mixed on whether the
administrative burden was reduced for program participants and
caseworkers. For example, many local officials reported that the
options reduced paperwork for participants. However, officials were
less likely to report that the options reduced the actual time
participants spent applying for food stamps or reporting changes in
household circumstances. In addition, some local officials reported
that participation increased as a result of implementing options
intended to increase participation, while others told us that those
options had no effect on participation. Similarly, for the two options
expected to increase alignment of program definitions with TANF and
Medicaid, most officials agreed that these options made the definitions
of income and resources the same as in TANF, but officials' opinions
differed on whether the options helped increase alignment with
Medicaid.[Footnote 15]
Administrative Burden on Participants:
Local food stamp supervisors reported mixed results on whether the
options eased the administrative burden on participants--a primary
reason that states chose most of these options--as measured by both the
amount of paperwork required and the time spent applying for food
stamps and reporting changes.[Footnote 16] These local officials
reported on our survey that the Expanded Simplified Reporting option
eased the administrative burden on participants, particularly those who
do not receive benefits from other assistance programs, by decreasing
the time needed to prepare paperwork and report changes in their
household circumstances.[Footnote 17] (See fig. 5.) For five other
options, local officials differed in their views; some reported that
the administrative burden on participants decreased while others
reported no change. These five options are Simplified Standard Utility
Allowance, Simplified Definition of Income, Simplified Definition of
Resources, Transitional Benefits, and Simplified Determination of
Deductions. For example, about the same number of local officials
reported that the Transitional Benefits option decreased the
administrative burden on participants as reported that it remained the
same. Further, most local officials from states that adopted the
deductions option reported that the administrative burden under this
option remained the same for participants. This may be because three of
the four states that implemented this option also implemented Expanded
Simplified Reporting, which already decreased the administrative burden
for participants in a similar way.
Figure 5: Results Reported by Local Officials on Administrative Burden
for Participants and Caseworkers:
[See PDF for image]
[End of figure]
Administrative Burden on Caseworkers:
Although five of the Farm Bill options--Expanded Simplified Reporting,
Simplified Standard Utility Allowance, Simplified Definition of Income,
Simplified Definition of Resources, and Simplified Determination of
Deductions--were chosen by state officials to ease the administrative
burden on caseworkers, local officials reported that most of these
options had little effect on reducing the administrative burden on the
caseworkers. (See fig. 5.) Overall, local officials reported no effect
on the number of contacts with participants and time spent with
participants during those contacts. However, local officials reported
some reduction in the time spent on paperwork. For example, local
officials told us that the utility option reduced the amount of time
caseworkers spent on paperwork because they no longer had to conduct an
additional complicated procedure to determine the correct benefit
amount for certain participants. (See app. IV for additional details
from our surveys regarding how Farm Bill options affected participants
and caseworkers.)
Payment Error Rate, Program Participation, Benefit Amount, and Program
Alignment:
Similarly, for options implemented in part to achieve other goals--to
decrease payment error rate, increase program participation, and
increase benefit amount--some local officials reported improvements,
while others told us that the options had no effect. (See fig. 6.)
Although about one-quarter of local officials reported that they did
not know how most Farm Bill options affected their payment error rates,
some others attributed improvements in error rates to two
options.[Footnote 18] About half of the local officials that responded
said that Expanded Simplified Reporting and the utility option
decreased the error rate, and the other half reported that the error
rate remained the same. For options that state officials thought would
increase program participation, local food stamp officials reported
that the options had little effect on participation. For example,
although state officials thought that the Child Support Expense Income
Exclusion option would increase participation, local officials reported
that it did not. There was no consensus on whether the other two
options chosen to increase participation--Expanded Simplified
Reporting and Transitional Benefits--resulted in increased
participation. For options that state officials thought would increase
food stamp benefit amounts, some locals reported improvements, while
others reported no change. Specifically, local officials reported that
the utility option increased benefit amounts for participants, while
about half reported that the income option increased benefits and about
half reported it did not.
Figure 6: Results Reported by Local Officials on Error Rate,
Participation, Benefit Amount, and Alignment:
[See PDF for image]
[A] We did not measure this item at the local level.
[End of figure]
Most local officials reported increased alignment of the definitions of
income and resources between food stamps and TANF from the income and
resources options. States selected these two options in part to
increase alignment by making these definitions the same in their Food
Stamp Program and TANF. For example, local food stamp officials from
one state we visited told us that aligning the definition of income
under the income option eliminated a food stamp form that was not
required for TANF or Medicaid. This form was used to verify loans from
educational institutions, such as community colleges, regarding the
amount and duration of the loan. They told us that obtaining this
information from educational institutions could take a month and
possibly require several follow-up contacts with the institution. This
decrease in paperwork for both participants and some caseworkers
demonstrates one benefit from increased alignment. However, on our
survey, officials' opinions differed on whether the income and
resources options helped increase alignment of definitions between food
stamps and Medicaid.
Local officials may have reported little or no change from certain
options because they affected relatively few food stamp participants or
they did not affect caseworkers' responsibilities. For example, most
local officials reported that four options--income, resources,
transitional benefits, and child support--affected less than 20 percent
of their caseload. In addition, most options made only slight changes
to caseworkers' administrative processes, and others may not have
affected their processes at all because some changes were automatically
incorporated into state computer systems.[Footnote 19] For example,
local officials reported that the child support option was
automatically incorporated into state computer systems, so caseworkers'
responsibilities were not affected by this change.
Several of the Farm Bill options made only slight changes to existing
food stamp policy, such as the utility, child support, and Simplified
Homeless Shelter Costs options. For example, the utility option
expanded the existing standard utility allowance policy to cover two
additional types of households that were previously excluded:
households sharing a living space and public housing residents who were
charged for only excess utility costs. Also, of the local officials we
surveyed on the homeless option, the majority indicated that they
implemented a similar policy prior to its availability under the Farm
Bill.
Many Local Food Stamp Officials Reported That Certain Options
Introduced Complications in Program Rules for Participants and
Caseworkers:
Many local officials reported on our surveys that three options--
Expanded Simplified Reporting, Transitional Benefits, and Simplified
Determination of Deductions--introduced complications in program rules
for participants and caseworkers. Of these options, the Expanded
Simplified Reporting option--an option that local officials told us
affected most of their caseloads--introduced the most serious
complications because of how it interacts with participant reporting
rules for other assistance programs. Officials told us that adopting
the Expanded Simplified Reporting option resulted in Food Stamp Program
reporting rules that differed in important ways from the reporting
rules of other assistance programs, such as Medicaid and TANF,
depending on how their states have structured these programs. About
one-third of local officials we surveyed reported that this option
decreased alignment between Food Stamp Program reporting rules and
those of Medicaid; about one-half reported a decrease in alignment with
TANF.
Local officials told us that these differences in reporting rules often
resulted in confusion on the part of food stamp participants,
particularly because most participate in other assistance programs.
They explained that although the caseworkers provided information to
help participants determine which changes they were required to report
(i.e., changes that increased their income to over 130 percent of the
federal poverty level), some participants still reported changes that
were not required. According to a recent case study, some participants
may believe they need to report these changes to maintain their food
benefits.[Footnote 20] On the other hand, local officials told us that
some participants think that the new reduced reporting requirements
apply to other assistance programs in addition to the Food Stamp
Program. Consequently, some participants do not report changes they are
required to report for these other assistance programs, and in some
cases, participants might face interruptions in benefits or penalties
for not reporting changes for other programs.
In addition to reporting complications for participants, local food
stamp officials on our site visits and in telephone interviews told us
that different participant reporting rules for assistance programs are
confusing for caseworkers because they are uncertain whether to act on
a change for the Food Stamp Program when reported for another
assistance program. Moreover, trying to determine whether to act on a
change for the Food Stamp Program can cause them to perform additional
work. When a participant reports a change that is required for Medicaid
or TANF,[Footnote 21] but not for food stamps, caseworkers must decide
whether to act on that change for the Food Stamp Program.[Footnote 22]
Caseworkers, who often determine benefits for more than one assistance
program, first must decide if a change will increase the participant's
food stamp benefit. To make this decision, caseworkers typically enter
the information into the computer system as if they were going to act
on the change in order to determine if the change will result in an
increase in the participant's food stamp benefit. If the caseworker
determines that the change reported by the participant will increase
the participant's benefit, caseworkers are required to act on the
change. On the other hand, if the caseworker determines that the change
reported by the participant will decrease the benefit, the caseworker
must then determine whether or not to act on this change. (See fig. 7
for one example of how this process would work.) FNS regulations
mandate that states not act on changes that would result in a decrease
in benefits for participants unless one of three exceptions is met: (1)
the household voluntarily requests that the case be closed, (2) the
participant's TANF (or, in some areas, General Assistance) grant is
changed, or (3) the information about the change is considered
"verified upon receipt."[Footnote 23] A reported change is considered
verified upon receipt when the information is not questionable and the
provider is its primary source, such as information about earnings
provided by the participant's employer.[Footnote 24] Many local
officials suggested that aligning food stamp reporting rules with
Medicaid and TANF, by making them the same across these programs, would
help to simplify this process.
Figure 7: Example of Possible Decisions and Actions under the Expanded
Simplified Reporting Option:
[See PDF for image]
[A] This example assumes the caseworker is the same for food stamps,
TANF, and Medicaid.
[End of figure]
State officials generally believed that the Expanded Simplified
Reporting option would help states reduce their food stamp payment
error rates. However, local officials told us that caseworkers'
confusion about the reporting rules for different assistance programs
could result in improper food stamp and other assistance program
benefits. A recent case study found that caseworkers were concerned
that they might make errors in benefits because of the complexity of
the decision-making process involved in determining when to act or not
to act on a change.[Footnote 25] Moreover, supervisors told us that
payment error rates of other assistance programs might increase if
participants do not report required changes to these assistance
programs because they believe the Expanded Simplified Reporting rules
apply to these other programs.
In an attempt to address these issues, many states have modified this
option in a way that may undermine some of its benefits. Officials in
17 of the 33 states that implemented this option told us that rather
than having caseworkers decide whether or not to act on a change, they
have a waiver from FNS that requires caseworkers to act on all changes
reported by participants, including those that would decrease benefits.
Some states choosing this waiver did so because acting on some but not
all changes would require significant reprogramming of their computer
systems and may be difficult for their caseworkers to understand.
However, acting on all changes counteracts the potential reduction in
workload for caseworkers. Further, when the participant reports a
change during the reporting period, having the waiver does not reduce
exposure to errors in the way that the option does for states without
the waiver. In short, the more changes caseworkers make, the more
opportunity there is for a change to be processed incorrectly. In
addition, in certain circumstances, a change might result in lower
benefits for participants in states with this waiver as opposed to
states without this waiver.[Footnote 26]
In April 2004, USDA proposed some revisions to simplified reporting
regulations in order to help alleviate some of these complications with
this waiver.[Footnote 27] USDA proposed that state agencies that have
this waiver not be required to act on changes a household reports for
another public assistance program when the change does not trigger
action in that other program. For example, if a household receiving
food stamps and Medicaid reports an increase in income to its Medicaid
caseworker that is not required to be reported for food stamp purposes,
the state agency would not have to reduce the household's food stamp
benefit if the income change does not affect its Medicaid eligibility
or benefits. This proposed change would simplify the procedure for
caseworkers and, in some cases, eliminate the possibility that benefits
would be reduced in states with this waiver. However, while this
proposal addresses issues for caseworkers and participants in states
with this waiver, we found that local officials in states without the
waiver were more likely to report that this option introduced
complications for caseworkers than local officials in states with the
waiver.
States have flexibility to align the reporting rules for Medicaid and
TANF with their food stamp reporting rules available under the Expanded
Simplified Reporting option, but many have not done so. Although one of
the three states we visited achieved some alignment of reporting rules
between TANF and food stamps, none of the three states, despite
preliminary discussions between Medicaid and food stamp officials, had
been successful in aligning Medicaid and food stamp reporting
rules.[Footnote 28] Food stamp officials in these states told us the
discussions had not resulted in alignment of reporting rules largely
because Medicaid officials believed that Medicaid benefit costs could
increase. For example, if a participant experienced a household change
that would not affect the participant's food stamp benefit but would
affect Medicaid eligibility, the participant might receive Medicaid
benefits for longer periods than he or she would have under a state's
current reporting rules. Thus Medicaid benefit costs could increase. A
recent study of four states found that states are often reluctant to
make changes in policies that may increase TANF or Medicaid benefit
costs or caseloads, particularly when states experience budget
shortfalls.[Footnote 29] For example, because states contribute a
nationwide average of 43 percent to Medicaid benefit costs (while food
stamp benefits are 100 percent federally funded), increases in Medicaid
caseloads or costs would place demands on state budgets that increases
in food stamp caseloads would not. In addition, another report noted
that changes to rules and procedures typically require that a state
reprogram its computer to apply the new policies, and these changes may
result in increased cost to the state.[Footnote 30] However, the extent
to which program costs might increase as a result of alignment is
unclear, and in two of the three states we visited, state officials had
little or no information on possible costs associated with implementing
such changes.[Footnote 31]
A case study also noted that in some states, staff responsible for
these various benefit programs work in different agencies with varied
priorities, and there is no incentive to coordinate policy across these
programs.[Footnote 32] Finally, an official from HHS's Centers for
Medicare and Medicaid Services (CMS) noted that there are numerous
groups of eligible Medicaid participants, and many groups, depending on
state eligibility rules, may receive continuous eligibility for 12
months.[Footnote 33] For these participants, reporting on a 6-month
schedule for Medicaid would not be appropriate.
Two additional options introduced complications in program rules,
though to a lesser extent. Some local officials reported that the
Transitional Benefits option introduced complications for the
caseworkers, again because of interactions between this option and
other assistance programs. For example, transitional benefits from
Medicaid are for persons transitioning to work and are provided for up
to 1 year. On the other hand, transitional food stamp benefits are for
persons leaving TANF and are granted for a maximum of 5 months. In
addition, program experts told us that reporting rules for the two
types of transitional benefits are not aligned, and this creates an
additional administrative burden for caseworkers. Medicaid requires
persons receiving transitional benefits to report household financial
circumstances at the 4th, 7th, and 10th month of transitional benefits,
whereas persons receiving food stamp transitional benefits must reapply
at the end of the 5th month. About a third of local officials reported
that they would like transitional food stamp benefits to be available
for 6 months or to be aligned with transitional benefits from Medicaid.
Finally, some local officials reported that the Simplified
Determination of Deductions option introduced complications for the
participants and the caseworkers. For example, local officials told us
that this option complicates decisions about whether to act on changes
reported by participants. Local officials told us that when
participants report a change that is not required under the deductions
option, caseworkers must first determine if the household is subject to
reporting rules under Expanded Simplified Reporting or not. If the
household falls under Expanded Simplified Reporting, the caseworkers
must follow the decision-making process for Expanded Simplified
Reporting depicted in figure 7 above. If the household does not fall
under Expanded Simplified Reporting and the change is to a deduction
from household income, the caseworkers must not act on the change.
Conclusions:
Since the late 1990s, and most recently in the Farm Bill, the Congress
and FNS have offered states a number of options to simplify and
streamline the administration of the Food Stamp Program. These options
presented states with additional opportunities to tailor their Food
Stamp Programs to the social and economic needs of their own states.
Moreover, these changes coincided with actions taken by the Congress to
grant states considerable flexibility in the design and administration
of other key assistance programs, such as TANF and Medicaid, and the
growing realization that the Food Stamp Program provides crucial
support to low-income working families.
Local officials, who have day-to-day contact with frontline caseworkers
and food stamp participants, reported mixed results from implementing
the options. Although they reported some improvements for both
caseworkers and participants from some options, no option received
consistently positive reports in all the areas where state officials
expected improvements when they selected the option. In fact, in many
cases, officials were as likely to report that an option resulted in no
change as they were to report improvements. This may be due in part to
the fact that the Farm Bill options made only slight changes to policy
and, as reported, affected relatively few program participants.
Of all the options, the Expanded Simplified Reporting option offered
the most promise because it was selected by the most states, affects a
large number of participants, and has the potential to significantly
streamline the participant reporting process. The fact that local
officials reported that adopting this option actually complicated
program rules in many states reflects the challenge of trying to
simplify requirements for one program without efforts by states to
adjust the rules of other related assistance programs. This is
particularly relevant because most food stamp recipients also
participate in other assistance programs. The reported complications
resulted in problems, such as confusion for the caseworker and a
possible increase in payment errors. In response, many states adopted a
waiver that negated many of the potential benefits of Expanded
Simplified Reporting for caseworkers and participants. Although USDA
proposed a change to this waiver, the change will not address the
complications reported by local officials in states without the waiver.
Moreover, neither the waiver to act on all changes nor USDA's proposed
change to the waiver will address overall alignment issues related to
reporting rules among various assistance programs.
Although federal law and program rules allow states to align
participant reporting rules among assistance programs, state officials
in most states have not made the broad changes that would result in
greater consistency among programs. Concerns regarding whether there
are costs associated with aligning participant reporting requirements
may hinder a state's decision to make program changes that increase
alignment. These concerns may include the cost of programming changes
into state computers and the concern that benefit costs may increase in
those programs that require a higher proportion of state funds, such as
the Medicaid program. On the other hand, savings could result from
reducing the administrative burden on caseworkers. Yet it is unclear
whether costs would rise or savings would be realized. In addition,
aligning Medicaid reporting rules with food stamp rules may work for
some groups of Medicaid participants, but not others. Although
alignment of state program rules may not be advantageous in every
circumstance, many government officials told us that they were
interested in improved alignment. In general, increased alignment
remains important to simplification and ease of service delivery.
Recommendations for Executive Action:
In order to take advantage of existing opportunities available to
states for streamlining participant reporting rules, we recommend that
the Secretary of Agriculture direct FNS to collaborate with HHS to take
the following two actions:
1. Encourage state officials to explore the advantages and
disadvantages--in terms of both administrative and benefit costs and
savings--of better aligning participant reporting rules in their
states, particularly for Medicaid and TANF, and:
2. Disseminate information and guidance to states on the opportunities
available for better aligning participant reporting requirements among
food stamps, Medicaid, and TANF.
Agency Comments:
We provided a draft of this report to the U.S. Department of
Agriculture for review and comment and on August 20, 2004, we met with
FNS officials to get their comments. The officials said they agreed
with our findings, conclusions, and recommendations. They stated that
they are interested in helping states better align their participant
reporting requirements and that they plan to contact HHS to initiate
discussions on ways to help states align these reporting requirements.
They also said they plan to provide best practices information to
states regarding the administration of the Food Stamp Program and that
they would explore disseminating information on any progress states
have made in streamlining their participant reporting rules. FNS
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. Please contact me at (202) 512-7215 if you or your staffs
have any questions about this report. Major contributors to this report
are listed in appendix V.
Signed by:
Sigurd R. Nilsen:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Objective, Scope, and Methodology:
To accomplish our research objectives, we surveyed state food stamp
administrators and local food stamp supervisors on the implementation
of the Farm Bill food stamp options. To augment information from our
state and local surveys, we conducted three comprehensive site visits
(Arizona, Maryland, and Michigan) and two semi-structured telephone
interviews (Colorado and South Carolina). We chose states for our site
visits and telephone interviews to capture variation in the following
criteria: (a) number of and type of selected options, (b) number of
food stamp participants and program participation rate, (c) program
error rate, and (d) entity (state or county) administering the Food
Stamp Program. During each visit we met with state officials
administering and developing policy for the Food Stamp Program, local
officials in the office where services are provided, and officials
responsible for other key assistance programs, such as Temporary
Assistance for Needy Families (TANF) and Medicaid. We also reviewed
Farm Bill legislation and related committee reports, and we reviewed
Food and Nutrition Service (FNS) reports and other program analysis. We
held discussions with program stakeholders, including officials at FNS
headquarters and regional offices, representatives of advocacy
organizations, and other program experts. We performed our work from
August 2003 to June 2004 in accordance with generally accepted
government auditing standards.
Survey of State Food Stamp Administrators:
To learn about state-level use of the food stamp options made available
under the Farm Bill, we conducted a Web-based survey of food stamp
administrators in the 50 states and the District of Columbia. For each
of the eight Farm Bill options, we asked state officials to provide
information on whether or not their state had chosen and implemented
the option, reasons for choosing (or not choosing) the option, program
challenges in implementing the option, changes because of the options,
and potential improvements to the option. In addition, we asked for
other information, including cost estimates for implementing the
options, estimates of time and cost savings as a result of implementing
the options, efforts to align the Food Stamp Program with TANF and
Medicaid, and other food stamp options states had implemented prior to
the Farm Bill. We administered the survey between December 9, 2003, and
January 30, 2004. We also contacted some respondents via phone or e-
mail to clarify their responses after the Web survey was completed.
Food stamp administrators in all 50 states and the District of Columbia
participated in the survey, for a response rate of 100 percent. To view
selected results of GAO's Web-based survey of food stamp adminstrators,
go to www.gao.gov/cgi-bin/getrpt?GAO-04-1058SP.
We believe the state survey data are sufficiently reliable to be used
for the applicable questions of our work. We pretested the survey with
several state Food Stamp administrators and modified the survey to take
their comments into account. We also compared our survey responses on
which of the states had implemented the options with information
published by FNS and found our data had a reasonable level of
consistency with the agency's data, with the exception of data for the
Simplified Homeless Shelter Costs option. Our analysis indicated fewer
states had implemented this option than are listed in the FNS report.
The cause of the discrepancy is that many states were already using a
homeless shelter allowance of $143 prior to the Farm Bill, and many of
these states are included in the information published by FNS as having
implemented the Farm Bill option. However, for the purposes of our
study, we decided to limit our analysis to only those states that
implemented the homeless shelter allowance of $143 after the Farm Bill
became effective.
Survey of Local Food Stamp Supervisors:
To learn about local-level use of the Farm Bill options, we
administered 1,328 mailed surveys to supervisors in local food stamp
offices in the states that had implemented the options. These survey
results are generalizable to local offices in states that implemented
the options. We conducted a separate survey for each of the eight
options and used a separate sample for each of the surveys. On all
eight surveys, we asked supervisors in local offices for their opinions
about the extent to which the Farm Bill option had affected change in
several areas of the Food Stamp Program, including administrative
burden on participants and caseworkers, the error rate, program
participation, and alignment with other assistance programs. In
addition, we asked the supervisors for their opinions about the
proportion of the local office's food stamp caseload that was affected
by the option and changes the local office officials would like to see
to the option. To view the results from the local food stamp office
surveys, go to www.gao.gov/cgi-bin/getrpt?GAO-04-1059SP.
We chose to survey food stamp supervisors because we believed they
would be aware of the changes for participants and caseworkers
resulting from the Farm Bill options. We collected the opinion of these
supervisors because we did not find existing data on the information we
needed to complete the objectives of this study, including the number
of food stamp recipients affected by each option and the time costs or
savings for food stamp participants and caseworkers because of the
implementation of the options. We conducted the surveys between
December 2003 and April 2004. We also contacted some respondents via
phone or e-mail to clarify their responses after the mailed survey was
completed.
Local Survey Sample Design:
For each Farm Bill option, the population of interest was the set of
all local food stamp offices located in states that adopted the option.
Because we could not survey the entire population of local offices, we
selected a sample of local offices to be representative of this
population of interest. In each sample, the sampling unit is the local
food stamp office. To determine the eight samples, we contacted state
and county food stamp officials to compile a complete mailing list of
food stamp offices in the 50 states and the District of Columbia. We
compiled our own list because we were unaware of any other such
comprehensive list. From these lists of local offices, we selected a
simple random sample of local offices located in states that, according
to information provided by FNS, had already implemented the
option.[Footnote 34] For example, if the FNS report indicated 12 states
had implemented an option, we drew the sample for that option from the
combined list of the local offices in those 12 states.
Since many states had chosen multiple options, we capped the number of
surveys a local office could receive at three in order to minimize
response burden. Only one local office was randomly selected to receive
more than three surveys. To make sure this office did not receive more
than three surveys, we randomly selected two of the five options for
which we had drawn this office. We then randomly selected two
replacement offices to receive the surveys. To select the replacement
offices, we used the remaining offices on the list.
Sampling and Nonsampling Errors:
Because we surveyed a random sample of local food stamp offices, our
results are estimates of the responses we would have received had we
surveyed the entire population of interest, and are thus subject to
sampling errors. We are 95 percent confident that each of the
confidence intervals in the local survey results will contain the true
values of the population of interest. All percentage estimates from the
local survey have sampling errors of plus or minus 10 percentage
points. We calculated confidence intervals for our local survey results
using methods that are appropriate for probability samples of this
type.
In addition to sampling errors, the practical difficulties in
conducting surveys of this type may introduce other types of errors,
commonly referred to as nonsampling errors. For example, questions may
be misinterpreted, the respondents' answers may differ from those in
local offices that did not respond, or errors could be made in keying
completed questionnaires or in the preparation of data files for
analysis. We took steps in the development, collection, and analysis of
the local surveys to minimize these errors. For example, we pretested
each of the eight local surveys with at least one local food stamp
official prior to mailing the surveys.
Response Rates:
The response rates for the eight surveys ranged from 74.0 percent to
86.1 percent (see table 1 below). Some respondents returned the survey
to us but indicated that their local office had not implemented the
option we asked them about or that they implemented the option prior to
the date the Farm Bill became effective. We refer to these surveys as
"out of scope." There are several reasons surveys could be out of
scope, including the time lag between the FNS report we used to
determine our sample and the launch of our survey and possible delays
in state-level policy decisions being implemented on the local level.
Given how quickly the status of the Farm Bill options can change in
states, the number of out of scopes is not surprising. In this report
we did not use out-of-scope surveys in the estimates derived from local
survey data.
We did not use the data we collected from the local survey on the
Simplified Homeless Shelter Costs option because we had used the FNS
list of states that had implemented the option to draw our sample, but
later we learned of the discrepancy between our definition of the
option and the data provided by FNS that had implemented this option.
We concluded our sample for this option was flawed and the results
should not be used in the local survey analysis.
Table 1: Disposition of Eight Farm Bill Option Samples:
Farm Bill option: Expanded simplified reporting;
Sample: Sample: 192;
Sample: Received: 157;
Sample: Out of scopes: 3;
Sample: Response rate[A]: 81.5%.
Farm Bill option: Transitional benefits;
Sample: Sample: 165;
Sample: Received: 134;
Sample: Out of scopes: 10;
Sample: Response rate[A]: 80.0%.
Farm Bill option: Simplified definition of income;
Sample: Sample: 181;
Sample: Received: 152;
Sample: Out of scopes: 37;
Sample: Response rate[A]: 79.9%.
Farm Bill option: Simplified definition of resources;
Sample: Sample: 170;
Sample: Received: 141;
Sample: Out of scopes: 48;
Sample: Response rate[A]: 76.2%.
Farm Bill option: Simplified homeless shelter costs;
Sample: Sample: 176.
Farm Bill option: Simplified standard utility costs;
Sample: Sample: 179;
Sample: Received: 155;
Sample: Out of scopes: 6;
Sample: Response rate[A]: 86.1%.
Farm Bill option: Simplified determination of deductions;
Sample: Sample: 126;
Sample: Received: 100;
Sample: Out of scopes: 8;
Sample: Response rate[A]: 78.0%.
Farm Bill option: Child support expense income exclusion;
Sample: Sample: 139;
Sample: Received: 112;
Sample: Out of scopes: 35;
Sample: Response rate[A]: 74.0%.
[A] The response rates shown in table 1 are calculated using the
following formula:
(Total number of responses - Number of out of scopes)/(Total sample
size - Number of out scopes) = Response rate.
[End of table]
[End of section]
Appendix II: Farm Bill Options That States Have Implemented as of
January 2004:
Figure 8: Farm Bill Options States Have Implemented as of January 2004:
[See PDF for image]
[A] Simplified Homeless Shelter Costs option only includes states that
indicated they did not have a Standard Homeless Shelter Allowance of
$143 prior to the Farm Bill.
[End of figure]
[End of section]
Appendix III: Selected Responses to State Survey:
Figure 9: Number of States That Gave Reasons for Choosing Options:
[See PDF for image]
[A] Simplified Homeless Shelter Costs option only includes states that
indicated they did not have a Standard Homeless Shelter Allowance of
$143 prior to the Farm Bill.
[B] We only asked child support item for Child Support Expense Income
Exclusion option.
[End of figure]
Figure 10: Number of States That Gave Reasons for Not Choosing Options:
[See PDF for image]
Notes: Data for Simplified Homeless Shelter Costs option are not
available.
[A] We only asked child support item for Child Support Expense Income
Exclusion option.
[End of figure]
[End of section]
Appendix IV: Selected Responses to Local Surveys:
Figure 11: Expanded Simplified Reporting:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 12: Simplified Standard Utility Allowance:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 13: Simplified Definition of Income:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 14: Simplified Definition of Resources:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 15: Transitional Benefits:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 16: Child Support Expense Income Exclusion:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
Figure 17: Simplified Determination of Deductions:
[See PDF for image]
Note: These estimates are accurate to within plus or minus 10
percentage points at the 95 percent level of confidence. Rows may not
sum to 100 percent because of rounding errors.
[End of figure]
[End of section]
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Kay Brown, (202) 512-3674, brownke@gao.gov
Elizabeth Morrison, (202) 512-9641, morrisone@gao.gov:
Acknowledgments:
Katharine Leavitt and Anne Welch also made significant contributions to
this report. In addition, Carl Barden, Kevin Jackson, MacDonald
Phillips, and Jay Smale were responsible for sampling, survey design,
and data analysis,and Corinna Nicolaou assisted in the report
development.
[End of section]
Related GAO Products:
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.
Food Stamp Employment and Training Program: Better Data Needed to
Understand Who Is Served and What the Program Achieves. GAO-03-388.
Washington, D.C.: March 12, 2003:
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.
Food Stamp Program: States Seek to Reduce Payment Errors and Program
Complexity. GAO-01-272. Washington, D.C.: January 19, 2001.
Means-Tested Programs: Determining Financial Eligibility Is Cumbersome
and Can Be Simplified. GAO-02-58. Washington, D.C.: November 2, 2001.
Food Stamp Program: Various Factors Have Led to Declining
Participation: GAO/RCED-99-185. Washington, D.C.: July 2, 1999.
FOOTNOTES
[1] See appendix I for a detailed explanation of the methodology we
used for the state and local surveys.
[2] The Personal Responsibility and Work Opportunity Reconciliation Act
of 1996 reformed Aid to Families with Dependent Children and
established the $16.5 billion Temporary Assistance for Needy Families
block grant, which provides to the states federal funds to support low-
income families and help these families reduce their dependence on
welfare. Medicaid, established in 1965, is a joint federal-state
entitlement program that finances health care coverage for certain low-
income families, children, pregnant women, and individuals who are aged
or disabled. Federal income limits for children and pregnant women
range from 100 percent to 185 percent of the federal poverty level,
depending on age. Income limits for adults and individuals who are aged
or disabled vary by state.
[3] Households with disabled or elderly members are exempt from the
gross income limit. In addition, households with elderly members may
have assets valued at $3,000.
[4] If a household has no other assets, its vehicle can be worth
$6,650.
[5] Prior to welfare reform, federal regulations required households to
have a face-to-face interview with an agency worker at each
recertification. Current regulations give states the option to require
only one face-to-face interview a year regardless of the length of
certification.
[6] States can choose from a variety of change-reporting methods. They
can require households to report only when a member changes jobs,
receives a different rate of pay, or has a change in his or her work
status, i.e., from full-time to part-time or vice versa. States can
also require households to report only when there is a change in
earnings of $100 or more per month.
[7] The food stamp error rate is calculated for the entire program, as
well as every state, by adding overpayments to those who are eligible
for smaller benefits, overpayments to those who are not eligible for
any benefit, and underpayments to those who do not get as much as they
should. The program also calculates a negative action error rate,
defined as the rate of improper denials or terminations of benefits.
[8] Before the Farm Bill, states were penalized if their combined
payment error rate was higher than the national average. As a result,
about half of states were subject to financial sanctions each year.
States are required to either pay the sanction or provide additional
state funds--beyond their normal share of administrative costs--to be
reinvested in error-reduction efforts, such as additional training in
calculating benefits for certain households. Under the Farm Bill, a
state will be subject to fiscal sanction if there is a 95 percent
statistical probability that the state's payment error rate exceeds 105
percent of the national average for 2 consecutive years.
[9] The Farm Bill requires the Secretary to issue regulations for
fiscal year 2005 and thereafter that will establish criteria related to
these improved performances and be used to award performance bonus
payments.
[10] Supplemental Security Income is a federal income supplement
program that assists people who are age 65 or older, blind, or
disabled, and who have limited income and resources. The program
provides monthly cash payments to help those who are qualified meet
basic needs for food, clothing, and shelter.
[11] See GAO, Means-Tested Programs: Determining Financial Eligibility
Is Cumbersome and Can Be Simplified, GAO-02-58 (Washington, D.C. Nov.
2001) for a comprehensive discussion of the overlap and complexities in
financial eligibility rules for 11 federal assistance programs, and the
cumbersome effect for both caseworkers and participants.
[12] TANF regulations require that states report information such as
the type and amount of assistance received, work participation
activities, and earned and unearned income. The regulations do not
specify how the states collect such information. (45 CFR 265.) States
set their own income limits for eligibility purposes.
[13] Homeless households may have shelter costs for a variety of
reasons, for example, if they pay to board with a family member or at a
homeless shelter.
[14] Deductions are subtracted from the household's gross income to
determine net income. Deductions include household expenses such as
those for shelter, utilities, and medical care. Absent the option, the
amount paid for child support would be deducted as a household expense.
[15] States provided a reason for selecting the Child Support Expense
Income Exclusion (encourage payment of child support) option that we
did not measure at the local level.
[16] This section excludes a discussion of the effects of the
Simplified Homeless Shelter Costs option because the majority of local
officials we surveyed indicated that they were already using a food
stamp policy that allowed them the same homeless shelter cost deduction
as this Farm Bill option.
[17] It is likely that many local officials reported improvements that
pertain to all households covered by the Expanded Simplified Reporting
option, that is, earned-income and most other food stamp households,
including unearned-income households.
[18] Although some factors, such as the time spent on paperwork, may
affect the administrative burden on participants and caseworkers, local
officials may not have been able to relate changes in error rates to
specific options because local officials are not immediately aware of
whether an error has occurred (when determining eligibility and
benefits). Moreover, according to an official at FNS, 4 months elapse
between collecting the information for the payment error rate analysis
and when FNS reports the payment error rate to the states, thus making
it even harder for local officials to tie changes in error rates to
specific options.
[19] We generally found no differences between the responses of local
officials in states that implemented an option in the first 6 months
after it became available and those in states that implemented the
option later.
[20] Carole Trippe, Liz Schott, Nancy Wemmerus, and Andrew Burwick,
Simplified Reporting and Transitional Benefits in the Food Stamp
Program--Case Studies of State Implementation. Final Report.
Mathematica Policy Research, Inc. E-FAN-04-003 May 2004 (Economic
Research Service).
[21] In some cases, a change reported by a participant may not result
in a change in Medicaid or TANF benefits. For example, a person may
have a change in income but the change does not affect that person's
Medicaid eligibility.
[22] Caseworkers can also learn of some changes through an automated
process that matches participants' information with other databases,
such as a new hire database, that could indicate a change in household
circumstances that might merit a change in the food stamp benefit.
[23] These exceptions are noted in current USDA regulations related to
Simplified Reporting: 7 CFR 273.12 (a)(1)(vii)(A). Proposed regulations
for Expanded Simplified Reporting maintain these same exceptions. 69
Fed. Reg. 20762.
[24] Information is considered verified upon receipt when the source
is, but is not limited to, specific data from the Social Security
Administration, data from the U.S. Citizenship and Immigration
Services, and Unemployment Compensation data from a state agency.
[25] See Economic Research Service: E-FAN-04-003 May 2004.
[26] Specifically, if a participant reports a change that would
decrease the benefit but does not meet any of the three exceptions as
explained on page 28, the change would not be made in states without
the waiver but would be made in states with the waiver.
[27] 69 Fed. Reg. 20724-64.
[28] A recent informal study that gathered information from 12 states
that are using the simplified or expanded simplified reporting option
showed that 3 states have aligned TANF and food stamp rules. Upon
further clarification, no state has aligned Medicaid and food stamp
rules. See www.NAPIPM.org (www.napipm.org/simp%20reporting.htm 5/10/
04).
[29] See Economic Research Service: E-FAN-04-003 May 2004.
[30] Liz Schott, Stacey Dean, Jocelyn Guyer, Coordinating Medicaid and
Food Stamps: How New Food Stamp Policies Can Reduce Barriers to Health
Care Cover for Low-Income Working Families. Center on Budget and Policy
Priorities, September 2001.
[31] One state provided preliminary analysis of estimated costs for
aligning reporting rules for TANF and child care programs to 6-month
reporting for earned-income households only.
[32] See Economic Research Service: E-FAN-04-003 May 2004.
[33] Federal Medicaid statute identifies over 25 different eligibility
categories of persons who may be covered under a state Medicaid plan.
According to a CMS official, a state could have as many as 50 groups of
eligible Medicaid participants.
[34] We used draft information provided by FNS, which we later
supplemented with information from its October 2003 report, released in
November 2003: United States Department of Agriculture, Food and
Nutrition Service, Food Stamp Program: State Options Report, Third
Edition, October 2003. The FNS State Options Report was the only source
of which we were aware at that time that listed which states had
implemented the option. We could not use our state survey data to
develop the list of states that had implemented the option because we
had not completed the state survey at the time we needed to draw the
sample for the local survey.
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