[Federal Register Volume 59, Number 46 (Wednesday, March 9, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-5376]


[[Page Unknown]]

[Federal Register: March 9, 1994]


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DEPARTMENT OF AGRICULTURE
Food and Nutrition Service

 

Food Stamp Program; Recommendations for Improvements to Food 
Stamp/SSI Joint Processing

ACTION: Notice.

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SUMMARY: The purpose of this notice is to solicit public 
recommendations for consideration by the Food and Nutrition Service 
(FNS) of the U.S. Department of Agriculture (USDA) and the Social 
Security Administration (SSA) of the Department of Health and Human 
Services (HHS) to improve the Supplemental Security Income (SSI)/Food 
Stamp Program joint processing system. Joint processing requirements 
are set forth in sections 11 of the Food Stamp Act of 1977, as amended 
(the Act) (7 U.S.C. 2011 et seq.). Sections 11 (i) and (j) require SSA 
to inform applicants for, and recipients of, SSI payments of the 
benefits under the Food Stamp Program, that food stamp applications are 
available in SSA offices, and that ``pure'' SSI household food stamp 
applicants can simultaneously apply for both SSI and food stamps at SSA 
offices if they choose to do so. 7 U.S.C. 2020 (i), (j).
    State food stamp agencies, upon receipt of an SSA-completed food 
stamp application, are required to certify food stamp households 
eligible for food stamps utilizing information contained in SSA records 
where practical and (with some few exceptions) may not require 
households to have another face-to-face interview for determining food 
stamp eligibility. The purpose of this process is to provide ``one-stop 
shopping'' to clients of both programs.
    Based on recommendations received, we will consider publishing 
criteria and requesting proposals for specific demonstration projects.

DATES: Recommendations will be accepted if postmarked no later than 
June 7, 1994.

ADDRESSES: Send recommendations to Dwight Moritz, Chief, Program Design 
Branch, Food and Nutrition Service, 3101 Park Center, room 720, 
Alexandria, Virginia 22302.

FOR FURTHER INFORMATION CONTACT: Dan Woodhead, Supervisor, 
Certification Policy Interpretation Section, Food and Nutrition 
Service, 3101 Park Center Drive, Alexandria, Virginia 22302, telephone 
(703) 305-2497, FAX (703) 305-2454 or Garth Dence, Chief, State 
Supplementation and Related Programs Branch, Division of Payment 
Policy, Office of Supplemental Security Income, 6401 Security 
Boulevard, Woodlawn, Maryland 21235, telephone (410) 965-9872.

SUPPLEMENTARY INFORMATION: Under joint processing, SSA staff conducting 
SSI interviews are required to screen potential SSI food stamp 
applicants to determine if they currently receive or recently applied 
for food stamps. SSA staff then determine whether applicants who do not 
receive food stamps want to complete a food stamp application with SSA 
(either in the field office or by telephone). SSA staff can provide 
joint processing service only to ``pure'' SSI households. A ``pure'' 
SSI/Food Stamp household is one in which all members are applicants for 
or recipients of SSI payments. SSA offices are required to forward 
completed food stamp applications to local food stamp offices within 
one work day of receipt of a signed food stamp application.
    Local food stamp office staff, upon receipt of an SSA-completed 
food stamp application, are required to process the application and 
certify food stamp eligibility within 30 days. Applicants who are 
entitled to expedited service must be processed within 5 days from the 
date the application is received at the correct State agency office. 
Food stamp workers generally may not require SSI/food stamp household 
applicants to have another face-to-face interview. They may, however, 
recontact applicants by telephone, written correspondence, and/or home 
visits to obtain information needed to complete an application and 
certify food stamp eligibility if such data are missing from the 
application, are not contained in SSA records, or are questionable.

Review of the Current Process

    Over the years, problems have been identified with the joint 
processing of food stamp applications in SSA offices. Some of the 
problems, such as poor communication between agencies of two different 
departments and misunderstanding of each other's policies have been 
addressed through training and management action. However, more 
fundamental problems are the result of caseload and processing factors 
that cannot be changed. These factors have caused SSA and FNS to look 
at alternatives to the current system of joint processing as a means of 
providing better service to our mutual program clients.
    There have been two recent reports addressing concerns with joint 
processing. In August 1992, the SSI Modernization Project published its 
``Final Report of the Experts.'' A majority of experts supported two 
approaches for improving the ``linkage'' between the Food Stamp and SSI 
Programs. One option is to have SSA offices complete a short-form food 
stamp application for all interested SSI/Food Stamp clients. The other 
option is to eliminate automatic (categorical) eligibility for food 
stamps when the SSI Federal benefit rate reaches the poverty line. In 
September 1992, the General Accounting Office (GAO) issued a report 
entitled ``Social Security: Need for Better Coordination of Food Stamp 
Services for Social Security Clients,'' which documented that joint 
processing has not worked well in improving the coordination of food 
stamp services for SSI clients as contemplated by section 11 of the 
Act.

Problems With Joint Processing

    1. Few Food Stamp Applications
    There is a perception that SSA offices process fewer food stamp 
applications than they should. By law, SSA is only required to process 
food stamp applications for SSI clients who are members of a ``pure'' 
SSI household and who choose to file for food stamp benefits at an SSA 
office. Other SSI clients in mixed households who want to apply for 
food stamps are referred to local food stamp offices to file for food 
stamp benefits.
    The client populations served by the two programs are similar to 
one another, e.g., they have limited resources and income. However, the 
large volume of SSI household applicants envisioned at the outset of 
the program who would simultaneously apply for SSI and food stamps at 
SSA offices has never materialized. Anecdotal data indicate that one 
reason for this may be that States often refer clients who already 
receive food stamps directly to SSA to file for SSI. Another reason is 
that a relatively small percentage of applicants residing in pure SSI 
households want to file for food stamps at SSA. Data recently obtained 
by SSA in a national 1-day study of all individuals contacting SSA 
offices about SSI showed that only one-fourth of SSI applicants and 
recipients lived in pure SSI households. Most of them already 
participated in the Food Stamp Program, had a food stamp application 
pending, or preferred filing at the local food stamp office because 
they wanted expedited service or for other reasons. About 14 percent of 
pure SSI household members did not want to participate in the Food 
Stamp Program. Fewer than 3 percent of pure SSI household members 
wanted to file an application at an SSA office.

2. SSA's Telephone Application Process

    Another problem in joint processing is that more and more SSI 
applicants are utilizing SSA's telephone service option, where an SSI 
and food stamp application are completed over the telephone rather than 
requiring individuals to have a face-to-face interview in the SSA 
office. The completed SSI and food stamp applications are sent to the 
individual for signature. The applicants are given the option of 
returning the signed food stamp application to the local food stamp 
office (for faster service) or returning it to SSA along with the SSI 
application. There are concerns that applicants may not follow through 
and send applications to local food stamp offices; the applicants may 
not send necessary documentation to determine food stamp eligibility; 
and/or food stamp offices may require these individuals to have another 
(face-to-face) interview. On the other hand, returning applications to 
SSA further delays the food stamp application process.

3. Incomplete Food Stamp Applications

    SSA can only rarely provide all the food stamp data and 
documentation local food stamp offices need to certify food stamp 
eligibility without having to recontact individuals. When joint 
processing legislation was passed, it was envisioned that, after SSA 
offices forwarded food stamp applications to local food stamp offices, 
States would utilize SSA's State data exchange (SDX) files in most 
situations to determine food stamp eligibility rather than recontact 
individuals. However, that process never worked well for States and has 
therefore not fulfilled expectations in the joint application process.
    SSA does not gather and verify any medical expense data in the SSI 
process and therefore this information does not appear on the SDX. 
Neither does it gather shelter expense information for the bulk of 
those persons in pure SSI households (most pure SSI households consist 
of one person). All such data are unique to the Food Stamp Program. If 
the food stamp applicant does not have this information and supporting 
documentation with him/her at the time SSA completes an application, 
food stamp offices have to recontact the individual.
    Local food stamp offices often must recontact individuals to obtain 
and verify resource and income data (which is also needed for SSI 
purposes) because it has not been supported on the food stamp 
application or on SSA's SDX tape within the timeframe in which States 
must certify households as food stamp eligible. To understand the 
problem, it is important to understand how the SSI application process 
has evolved and currently works.
    When joint processing was implemented, development of information 
on income, resources, living arrangements and other nondisability 
eligibility factors was done in a single fashion for the entire SSI 
claims workload. For both aged and disabled applicants, SSA field 
offices obtained complete eligibility information and documentation 
regarding these factors at the initial application interview and during 
the following weeks. For disability claims, development of the 
disability portion of the claim, which involves a State's determining 
whether the claimant is disabled, occurred simultaneously with the SSA 
nondisability claim development. If the State's action took over 90 
days to complete, for those claims where disability was found, the SSA 
office had to update the nondisability information it had previously 
obtained.
    For aged claims this process made sense; there was no reason to 
delay development of eligibility information. However, for disability 
claims, simultaneous development of disability and nondisability 
information resulted in wasted SSA effort--developing nondisability 
information for claimants found not to be disabled, and for claims 
where the disability decision took a long time, revisiting and updating 
nondisability information previously obtained.
    To more effectively manage its field office resources, SSA changed 
its processing of SSI disability claims, which now comprise the 
majority of SSI claims. Since the preponderance of SSI applications are 
for the disabled (90 percent) and of those the majority are deferred 
(74 percent), processing of most SSI claims involves the deferral of 
the nondisability development until after the State makes a disability 
determination. For claimants found to be disabled, nondisability 
information is obtained only once. For SSA, this is cost-effective 
management of its SSI disability process.
    The problem for joint processing is that at the initial SSI 
disability application interview, SSA does not obtain the complete 
nondisability information that is needed for the food stamp eligibility 
determination. SSA's process calls for obtaining only allegations and 
the documentation in the applicant's possession at the time of the 
initial interview. SSA does not do complete nondisability development, 
if at all, for several months. The information pertinent to determining 
food stamp eligibility is therefore not available when it is needed, 
and must be obtained by the food stamp office.
    A requirement that compounds the problem for food stamp 
applications taken in SSA offices is that the FNS regulations require 
SSA offices to transmit any food stamp applications and supporting 
documentation to the food stamp office within one working day of the 
application interview. This requirement virtually guarantees the 
incompleteness of food stamp applications and documentation obtained by 
SSA offices.

4. New Food Stamp Requirements

    Compounding these structural problems are additional requirements 
being implemented by food stamp agencies which were not anticipated 
when joint processing was created. For example, some States are 
requiring photo-ID cards to enhance security, others are issuing 
personal identification numbers (PINs) for automated delivery of 
Authorization to Participate (ATP) cards, and yet others are 
implementing electronic benefit transfer (EBT) systems, which require 
issuance of PINs, and also require training sessions for recipients. 
These initiatives, by design, add a face-to-face meeting requirement--
one that arguably is prohibited by section 11(i) of the Act.
    Another barrier is that more and more States are moving to an on-
line automated application process. Food stamp offices are inclined to 
ask pure SSI food stamp household applicants to reapply for food stamps 
at local food stamp offices to accommodate their automated systems 
rather than transfer information from a paper application completed by 
the SSA.

Conclusion

    SSA and FNS agree with the aforementioned GAO report that the 
coordination of food stamp services for SSI clients that Congress 
intended via the joint processing legislation has not worked well. We 
are working to improve our performance. However, we also agree with the 
GAO's conclusion that, even if all our responsibilities under the 
current process were adequately carried out, systemic barriers which 
minimize our prospects for significant service improvement exist under 
the current system and are increasing. We are, therefore, exploring 
alternatives to the current process that have the potential to provide 
better service to SSI/food stamp household applicants while maintaining 
the cost effectiveness of both programs. SSA and FNS are soliciting 
recommendations on alternative ways to improve service and 
recommendations for possible projects to demonstrate their feasibility. 
Responders are invited to indicate their interest in participating in 
such demonstration projects as well.

Instructions for Making Suggestions

    There are no specific formats for submitting recommendations; 
however, submissions should include:

--A reference to this notice;
--A clear description of how the recommended change should work;
--A description of how the recommended change would solve particular 
problems with the current joint processing system;
--A reference to any prior relevant research or other efforts that 
support the recommendations; and
--Possible options for conducting demonstration projects including 
duration, cost estimates, and location.

    Recommendations should be brief. Five pages or less are preferred 
since it is not necessary to provide extensive background on the 
individual or organization making the recommendation. Please submit 
original and one copy of the document.

    Dated: February 26, 1994.
William E. Ludwig,
Administrator, Food and Nutrition Service.
[FR Doc. 94-5376 Filed 3-8-94; 8:45 am]
BILLING CODE 3410-30-U