Food Stamp Program: Farm Bill Options Ease Administrative Burden,
but Opportunities Exist to Streamline Participant Reporting Rules
among Programs (16-SEP-04, GAO-04-916).
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 review the results
from the local food stamp office surveys, go to
www.gao.gov/cgi-bin/getrpt?GAO-04- 1059SP.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-916
ACCNO: A12412
TITLE: Food Stamp Program: Farm Bill Options Ease Administrative
Burden, but Opportunities Exist to Streamline Participant
Reporting Rules among Programs
DATE: 09/16/2004
SUBJECT: Eligibility criteria
Eligibility determinations
Federal aid programs
Food relief programs
Locally administered programs
Program management
State-administered programs
State/local relations
Food Stamp Program
HHS Temporary Assistance for Needy
Families Program
Medicaid Program
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GAO-04-916
United States Government Accountability Office
GAO
Report to the Committee on
Agriculture, Nutrition, and Forestry, U.S. Senate
September 2004
FOOD STAMP PROGRAM
Farm Bill Options Ease Administrative Burden, but Opportunities Exist to
Streamline Participant Reporting Rules among Programs
GAO-04-916
September 2004
FOOD STAMP PROGRAM
Farm Bill Options Ease Administrative Burden, but Opportunities Exist to
Streamline Participant Reporting Rules among Programs
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
Number of states 50
40
30
20
10
1
0 Expanded Simplified Simplified Simplified Transitional Child Simplified
Simplified simplified standard definition definition benefits support
determinationhomeless reporting utility of incomeof resources expenseof
deductions shelter
allowance income costs
exclusion
Not chosen Chosen, not yet implemented Chosen and implemented
Source: GAO analysis of survey data.
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.
Highlights of GAO-04-916, a report to Committee on Agriculture, Nutrition,
and Forestry, U.S. Senate
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 Webbased survey of food stamp
administrators, go to
www.gao.gov/cgi-bin/getrpt?GAO-041058SP. To view the results from the
local food stamp office surveys, go to
www.gao.gov/cgi-bin/getrpt?GAO04-1059SP.
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 [email protected].
simplifiedExpandedreporting
dancew
utility allo
e ces
Simplified definitionof incom of resour
Simplified definition
nsitionalbenefits t ee e
incomChild suppor
xpensexc
lusionSimplified
of deductions shelter costsdetermination Simplified homeless
aTr
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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
1
3 5
11
20 32 33 34
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 50
GAO Contacts 50 Acknowledgments 50
Related GAO Products 51
Table
Table 1: Disposition of Eight Farm Bill Option Samples 39
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
10
12 14 17
22
24
28
40
41
42 43 44 45 46 47 48 49
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
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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separately.
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.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
1See appendix I for a detailed explanation of the methodology we used for
the state and local surveys.
Results in Brief
officials in the office where services are provided, and officials
responsible for other key assistance programs, such as TANF and Medicaid.
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.
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
2The 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.
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 for participation in the Food Stamp Program
is based on the
Eligibility and Benefits 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.3 If the household
owns a vehicle worth more than $4,650, the excess value is included in
calculating the household's assets.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.
3Households 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.
4If a household has no other assets, its vehicle can be worth $6,650.
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.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.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.7 Improper payments, which include overpayments of food stamp
benefits to participants, underpayments to participants, and payments to
those who
5Prior 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.
6States 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.
7The 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.
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.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.9
Food Stamp Participants Many food stamp participants receive benefits from
other federally funded Receive Benefits from low-income assistance
programs, including Medicaid and TANF. For Other Assistance Programs
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.10 In
8Before 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 errorreduction 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.
9The 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.
10Supplemental 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.
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.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.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.)
11See 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.
12TANF 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.
Figure 1: Description and Purpose of Farm Bill Options
Sources: Food and Nutrition Service, Pub. L. No. 107-171; Senate Rpt. No.
107-117 (2001); Art Explosion and Copyright Corel Corp. All
rights reserved (images).
aIn 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.
bThe Farm Bill refers to this option as Simplified Determination of
Housing Costs.
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 According to our survey of state food stamp
administrators, 23 or more Choose Four of the states had implemented four
of the options as of January 2004, while less Options 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
Number of states
1
reportingsimplified d
utility allowanceSimplified standar
ces
Simplified definitionof income of resour
Simplified definitionansitionalbenefits t e
income e
Child suppor
xpensex
usionlc
determinationSimplified homelessshelter costs
rTOptions
Not chosen
Chosen, not yet implemented
Chosen and implemented
Source: GAO analysis of survey data.
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.
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
�= Important reason states chose this option
Sources: GAO analysis of survey data; Art Explosion and Copyright
Corel Corp. All rights reserved (images).
aSimplified 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.
bWe only asked the child support item for the Child Support Expense Income
Exclusion option.
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.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
13Homeless 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.
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.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
14Deductions 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.
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 state's
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
� = Important reason states did not choose this option
Sources: GAO analysis of survey data; Art Explosion and Copyright
Corel Corp. All rights reserved (images).
Note: Data for Simplified Homeless Shelter Costs option are not available.
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
Administrative Burden on Participants
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.15
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.16 These local officials reported on our survey that the
Expanded Simplified Reporting option eased the
15States 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.
16This 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.
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.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.
17It 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.
Figure 5: Results Reported by Local Officials on Administrative Burden for
Participants and Caseworkers
Administrative Burden on Caseworkers
Indicates an improvement reported by most officials, i.e., decreased
administrative burden
Indicates no change reported by most officials
Indicates about the same number of officials reported an improvement as
reported no change
- Indicates that this was not an important reason states chose this option
Sources: GAO analysis of survey responses from local food stamp officials;
Art Explosion and Copyright Corel Corp. All rights reserved
(images).
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
Payment Error Rate, Program Participation, Benefit Amount, and Program
Alignment
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.)
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
onequarter 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.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.
18Although 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.
Figure 6: Results Reported by Local Officials on Error Rate, Participation,
Benefit Amount, and Alignment
Indicates an improvement reported by most officials, i.e., decreased error
rate, increased participation, increased alignment Indicates no change
reported by most officials Indicates about the same number of officials
reported an improvement as reported no change - Indicates that this was
not an important reason states chose this option
Sources: GAO analysis of survey responses from local food stamp officials;
Art Explosion and Copyright Corel Corp. All rights reserved
(images).
aWe did not measure this item at the local level.
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.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
19We 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.
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.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,21 but
not for food stamps, caseworkers must decide whether to act on that
20Carole 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).
21In 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.
change for the Food Stamp Program.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."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.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.
22Caseworkers 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.
23These 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.
24Information 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.
Figure 7: Example of Possible Decisions and Actions under the Expanded
Simplified Reporting Option
Sources: GAO analysis; Art Explosion and Copyright Corel Corp.
All rights reserved (images).
aThis example assumes the caseworker is the same for food stamps, TANF,
and Medicaid.
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.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.26
In April 2004, USDA proposed some revisions to simplified reporting
regulations in order to help alleviate some of these complications with
this waiver.27 USDA proposed that state agencies that have this waiver not
be required to act on changes a household reports for another public
25See Economic Research Service: E-FAN-04-003 May 2004.
26Specifically, 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.
2769 Fed. Reg. 20724-64.
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.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.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
28A 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).
29See Economic Research Service: E-FAN-04-003 May 2004.
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.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.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.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.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
30Liz 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.
31One 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.
32See Economic Research Service: E-FAN-04-003 May 2004.
33Federal 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.
Conclusions
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.
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 lowincome 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 In order to take advantage of existing opportunities
available to states for streamlining participant reporting rules, we
recommend that the SecretaryExecutive Action of Agriculture direct FNS to
collaborate with HHS to take the following two actions:
Agency Comments
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.
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.
Sigurd R. Nilsen Director, Education, Workforce, and Income Security
Issues
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.
Appendix I: Objective, Scope, and Methodology
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.
Appendix I: Objective, Scope, and Methodology
Local Survey Sample Design
Sampling and Nonsampling Errors
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.1 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.
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.
1We 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.
Appendix I: Objective, Scope, and Methodology
Response Rates
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.
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.
Appendix I: Objective, Scope, and Methodology
Table 1: Disposition of Eight Farm Bill Option Samples Sample
Farm Bill option Sample Received Out of scopes Response ratea
Expanded simplified reporting 192 157 3 81.5%
Transitional benefits 165 134 10 80.0%
Simplified definition of 181 152 37 79.9%
income
Simplified definition of 170 141 48 76.2%
resources
Simplified homeless shelter 176
costs
Simplified standard utility 179 155 6 86.1%
costs
Simplified determination of 126 100 8 78.0%
deductions
Child support expense income 139 112 35 74.0%
exclusion
aThe response rates shown in table 1 are calculated using the following
formula:
(Total number of responses - Number of out of scopes) = Response
rate(Total sample size - Number of out of scopes)
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
aSimplified 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.
Appendix III: Selected Responses to State Survey
Figure 9: Number of States That Gave Reasons for Choosing Options
aSimplified 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.
bWe only asked child support item for Child Support Expense Income
Exclusion option.
Appendix III: Selected Responses to State Survey
Figure 10: Number of States That Gave Reasons for Not Choosing Options
Relative
advantage
Would have
Computers little or
Too Would not no
difficult to encourage Would advantage
program participants make it over policy
Options computer Little or no to transition Would Would more rules
(Number of system increase in from welfare decrease decrease difficult already in Would raise
states Participants 5 2 3 1 18 19 28 5 2 1 2 11 9 26 benefit 2 0 0 2 1 0 5 to work participation participation to align place Error administrative 2 1 0 0 5 3 2 a a a a a a Other 1 7 1 4 4 3 12
chosen and and amounts for Participation of working of elderly Food rate Would costs
implemented caseworkers participants Would families and/or Stamp increase Would not
option) Would decrease disabled Program error rate work well
increase overall Alignment with Other with
Child workload for participation Would make it Medicaid reasons other
Simplified Simplified support caseworkers Very few in program more Would Farm Bill Would not
Expanded standard Simplified definition expense Simplified Would Would participants Would difficult to decrease options encourage
simplified utility definition of Transitional income determination complicate complicate would be increase align Food application 5 6 5 6 11 23 20 state payment
reporting allowance of income resources benefits (N exclusion of deductions 4 2 1 0 22 17 14 rules for rules for affected by burden on 0 0 1 0 2 2 1 Stamp Program 0 1 0 0 0 0 0 process 5 2 0 0 7 12 12 chose to of child
Reasons (N = 9) (N = 12) (N = 7) (N = 12) = 27) (N = 35) (N = 44) 3 2 2 1 13 7 10 caseworkers participants 1 4 4 5 9 20 15 change 1 2 5 7 7 18 8 participants 0 0 0 0 0 1 0 0 0 0 0 0 1 1 with TANF 2 0 0 0 5 6 9 3 0 0 0 3 5 4 timeliness 0 0 0 0 0 1 1 implement 1 0 0 0 6 2 15 support 4
Source: GAO survey.
Notes: Data for Simplified Homeless Shelter Costs option are not
available. aWe only asked child support item for Child Support Expense
Income Exclusion option.
Appendix IV: Selected Responses to Local Surveys
Figure 11: Expanded Simplified Reporting
Changes for Changes for
food stamp the
participants participants
Participant Time spent
administrative reporting Changes for
burden changes the
measures Amount of caseworker
Percentage Participant paperwork Time spent Decisions on
of food simplification required Number of with Time spent on whether to
stamp 1% 8% 9% 18% 39% 22% 4% measures Changes for contacts participants paperwork apply
caseload Changes for the with during (including changes
affected food stamp participants participants contacts verification) reported by
None (0%) caseworkers Rules Greatly Somewhat Remained Somewhat participants
Caseworker related to decreased decreased the same increased Greatly Frequency of
administrative reporting or 13% 19% 48% 42% 32% 27% 5% 10% increased benefit
burden documenting Greatly Somewhat Remained Somewhat 3% 2% calculation
measures changes simplified simplified the same complicated Greatly
About Almost Caseworker Changes for 17% 30% 8% 33% complicated Greatly Somewhat Remained Somewhat Greatly
Few Some half Most all All simplification the Greatly Somewhat Remained Somewhat 12% Greatly simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) measures caseworker decreased decreased the same increased increased 9% 48% 33% 9% 2% 2% 18% 61% 16% 4% 6% 36% 37% 12% 9% 16% 4% 47% 18% 29% 31% 7% 27% 1% 20%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 12: Simplified Standard Utility Allowance
Changes for
the
participants
Time spent
applying for
food stamps
Changes for or reporting
food stamp changes
participants Amount of
Participant paperwork
administrative required
burden Changes for Time spent on
measures the paperwork Decisions on
Percentage Participant participants (including whether to
of food simplification Rules verification) apply
stamp 1% 19% 10% 3% 12% 46% 8% measures related to Changes for changes in
caseload Changes for reporting or the utility
affected food stamp documenting caseworker costs
None (0%) caseworkers utility Calculation reported by
Caseworker expenses of food stamp participants
administrative Changes for benefits
burden the
measures caseworker
Caseworker Number of Greatly Somewhat Remained
simplification contacts decreased decreased the same Somewhat Greatly
measures with 1% 5% 25% 46% 71% 48% increased increased
participants Greatly Somewhat Remained 3% 1% 0% 0%
Time spent simplified simplified the same Somewhat Greatly
with 18% 42% 36% complicated complicated 10% 43% 44%
About Almost participants Greatly Somewhat Remained 4% Somewhat 0% Greatly Greatly Somewhat Remained 3% Somewhat 0% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 3% 5% 20% 25% 73% 67% 4% 3% 0% 0% 16% 40% 37% 7% 0% 26% 43% 24% 6% 1%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 13: Simplified Definition of Income
Changes for
the
participants
Time spent
applying for
Changes for food stamps
food stamp or reporting
participants changes
Participant Amount of
administrative paperwork
burden required Time spent on
measures Changes for paperwork
Percentage Participant the (including
of food simplification participants verification) Determination
stamp measures Rules Changes for or
caseload 0% 62% 16% 5% 9% 6% 2% Changes for related to the redetermination
affected food stamp reporting or caseworker of eligibility
None (0%) caseworkers documenting Calculation
Caseworker income of food stamp
administrative Changes for benefits
burden the
measures caseworker
Caseworker Number of Somewhat Remained
simplification contacts Greatly decreased the same Somewhat Greatly
measures with decreased 39% 56% 56% 38% increased increased
participants 3% 3% Somewhat Remained 2% 3% 0% 0%
Time spent Greatly simplified the same Somewhat Greatly
with simplified 56% 27% complicated complicated 47% 41%
About Almost participants 8% Greatly Somewhat Remained 7% Somewhat 2% Greatly 7% Greatly Somewhat Remained 4% Somewhat 1% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 1% 1% 28% 30% 67% 62% 4% 7% 0% 0% 6% 46% 42% 5% 2% 3% 47% 43% 5% 2%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 14: Simplified Definition of Resources
Changes for
the
participants
Time spent
applying for
Changes for food stamps
food stamp or reporting
participants changes
Participant Amount of
administrative paperwork
burden required Time spent on
measures Changes for paperwork
Percentage Participant the (including
of food simplification participants verification) Determination
stamp measures Rules Changes for or
caseload 0% 55% 18% 6% 12% 9% 1% Changes for related to the redetermination
affected food stamp reporting or caseworker of eligibility
None (0%) caseworkers documenting Calculation
Caseworker income of food stamp
administrative Changes for benefits
burden the
measures caseworker
Caseworker Number of Greatly Somewhat Remained
simplification contacts decreased decreased the same Somewhat Greatly
measures with 4% 6% 33% 46% 60% 46% increased increased
participants Greatly Somewhat Remained 2% 1% 0% 0%
Time spent simplified simplified the same Somewhat Greatly
with 10% 46% 39% complicated complicated 44% 44%
About Almost participants Greatly Somewhat Remained 4% Somewhat 1% Greatly 9% Greatly Somewhat Remained 3% Somewhat 0% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 3% 2% 22% 28% 69% 62% 6% 8% 0% 0% 3% 33% 62% 1% 1% 4% 42% 51% 2% 1%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 15: Transitional Benefits
Changes for
the
participants
Time spent
applying for
Changes for food stamps
food stamp or reporting
participants changes
Participant Amount of
administrative paperwork
burden required Time spent on
measures Changes for paperwork
Percentage Participant the (including Decisions on
of food simplification participants verification) whether to
stamp measures Rules Changes for apply
caseload 5% 77% 14% 2% 2% 0% 1% Changes for related to the changes
affected food stamp reporting or caseworker reported by
None (0%) caseworkers documenting Calculation participants
Caseworker income of food stamp
administrative Changes for benefits
burden the
measures caseworker
Caseworker Number of Greatly Somewhat Remained Somewhat
simplification contacts decreased decreased the same increased Greatly
measures with 12% 15% 40% 34% 41% 41% 7% 9% increased
participants Greatly Somewhat Remained Somewhat 0% 0%
Time spent simplified simplified the same complicated Greatly
with 16% 35% 30% 15% complicated 14% 19% 41% 21%
About Almost participants Greatly Somewhat Remained Somewhat 4% Greatly Greatly Somewhat Remained Somewhat 4% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 2% 3% 32% 20% 53% 68% 13% 9% 0% 0% 15% 27% 31% 26% 1% 15% 22% 26% 29% 7%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 16: Child Support Expense Income Exclusion
Changes for
the
Changes for participants
food stamp Time spent
participants applying for
Participant food stamps Time spent on
administrative Amount of paperwork
Percentage burden paperwork (including
of food measures required verification) Determination
stamp Changes for Changes for Changes for or
caseload 0% 77% 19% 3% 2% 0% 0% food stamp the the redetermination
affected caseworkers caseworker caseworker of eligibility
None (0%) Caseworker Number of Calculation
administrative contacts of food stamp
burden with benefits
measures participants Greatly Somewhat Remained Somewhat Greatly
Caseworker Time spent decreased decreased the same increased increased
simplification with 0% 0% 0% 1% 84% 76% 16% 23% 0% 0% 1% 76% 23%
About Almost measures participants Greatly Somewhat Remained Somewhat Greatly 0% Greatly Somewhat Remained Somewhat 0% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 0% 0% 3% 1% 83% 84% 15% 15% 0% 0% 0% 5% 79% 16% 0% 0% 5% 81% 14% 0%
Source: GAO survey.
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.
Appendix IV: Selected Responses to Local Surveys
Figure 17: Simplified Determination of Deductions
Changes for
the
participants
Time spent
applying for
Changes for food stamps
food stamp or reporting
participants changes
Participant Amount of
administrative paperwork
burden required Time spent on
measures Changes for paperwork
Percentage Participant the (including Decisions on
of food simplification participants verification) whether to
stamp measures Rules Changes for apply
caseload 0% 24% 35% 14% 13% 13% 2% Changes for related to the changes
affected food stamp reporting or caseworker reported by
None (0%) caseworkers documenting Frequency of participants
Caseworker deductions benefit
administrative Changes for calculation
burden the
measures caseworker
Caseworker Number of Somewhat Remained Somewhat
simplification contacts Greatly decreased the same increased Greatly
measures with decreased 26% 35% 65% 57% 5% 3% increased
participants 3% 4% Somewhat Remained Somewhat 2% 2%
Time spent Greatly simplified the same complicated Greatly
with simplified 41% 23% 24% complicated 40% 43%
About Almost participants 2% Greatly Somewhat Remained Somewhat 10% Greatly 7% Greatly Somewhat Remained 9% Somewhat 2% Greatly
Few Some half Most all All during decreased decreased the same increased increased simplified simplified the same complicated complicated
(1-19%) (20-39%) (40-59%) (60-79%) (80-99%) (100%) contacts 1% 2% 29% 24% 55% 60% 13% 13% 3% 2% 9% 39% 39% 11% 2% 7% 29% 23% 35% 6%
Source: GAO survey.
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.
Appendix V: GAO Contacts and Staff Acknowledgments
GAO Contacts Kay Brown, (202) 512-3674, [email protected] Elizabeth
Morrison, (202) 512-9641, [email protected]
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.
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.
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