Food Stamp Program: Use of Alternative Methods to Apply for and  
Maintain Benefits Could Be Enhanced by Additional Evaluation and 
Information on Promising Practices (03-MAY-07, GAO-07-573).	 
                                                                 
One in 12 Americans participates in the federal Food Stamp	 
Program, administered by the Food and Nutrition Service (FNS).	 
States have begun offering individuals alternatives to visiting  
the local assistance office to apply for and maintain benefits,  
such as mail-in procedures, call centers, and on-line services.  
GAO was asked to examine: (1) what alternative methods states are
using to increase program access; (2) what is known about the	 
results of these methods, particularly on program access for	 
target groups, decision accuracy, and administrative costs; and  
(3) what actions states have taken to maintain program integrity 
while implementing alternative methods. GAO surveyed state food  
stamp administrators, reviewed five states in depth, analyzed FNS
data and reports, and interviewed program officials and 	 
stakeholders.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-573 					        
    ACCNO:   A69065						        
  TITLE:     Food Stamp Program: Use of Alternative Methods to Apply  
for and Maintain Benefits Could Be Enhanced by Additional	 
Evaluation and Information on Promising Practices		 
     DATE:   05/03/2007 
  SUBJECT:   Accessibility					 
	     Beneficiaries					 
	     Customer service					 
	     Data collection					 
	     Evaluation methods 				 
	     Food programs for children 			 
	     Food programs for the elderly			 
	     Food relief programs				 
	     Program evaluation 				 
	     Program management 				 
	     Food Stamp Program 				 

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GAO-07-573

   

     * [1]Results in Brief
     * [2]Background

          * [3]Program Participation
          * [4]Determination of Eligibility and Benefits
          * [5]The Process of Applying for and Maintaining Benefits
          * [6]Program Integrity

     * [7]All States Use Mail and About Half of States Use or Have Beg

          * [8]Almost All States Allow Households to Apply for Food Stamp B
          * [9]Almost Half of States Are Using or Developing Call Centers a
          * [10]States Report Taking Several Actions to Help Households Use

     * [11]Information on Results Is Limited, but States We Reviewed Ci

          * [12]Few Evaluations Have Been Conducted and Determining the Effe

               * [13]Federal Evaluation and Monitoring
               * [14]State Evaluation and Monitoring
               * [15]Evaluation Challenges

          * [16]Federal and State Officials Report Alternative Methods Help

               * [17]Advantages of Alternative Methods
               * [18]Challenges to Using Alternative Methods

     * [19]States Report Taking Actions to Maintain Food Stamp Program

          * [20]State Actions to Prevent Improper Food Stamp Payments and Fr

               * [21]State Actions to Limit Procedural Denials

     * [22]Conclusions
     * [23]Recommendations for Executive Action
     * [24]Agency Comments

          * [25]Survey of State Food Stamp Administrators
          * [26]State Site Visits and Structured Interviews
          * [27]Reviews of FNS Data and Relevant Studies

     * [28]GAO Contact
     * [29]Acknowledgments

Report to the Chairman, Committee on Agriculture, Nutrition, and Forestry,
U.S. Senate

United States Government Accountability Office

GAO

May 2007

FOOD STAMP PROGRAM

Use of Alternative Methods to Apply for and Maintain Benefits Could Be
Enhanced by Additional Evaluation and Information on Promising Practices

GAO-07-573

Contents

Letter 1

Results in Brief 3
Background 5
All States Use Mail and About Half of States Use or Have Begun Developing
On-line Services and Call Centers to Provide Access to the Food Stamp
Program 10
Information on Results Is Limited, but States We Reviewed Cite Advantages
and Challenges Using Alternative Access Methods 18
States Report Taking Actions to Maintain Food Stamp Program Integrity
While Using Alternative Methods 32
Conclusions 35
Recommendations for Executive Action 36
Agency Comments 36
Appendix I Objectives, Scope, and Methodology 38
Appendix II State-by-State Use of Alternative Methods and Waivers of the
Face-to-Face Interview 42
Appendix III GAO Contact and Acknowledgments 44
Related GAO Products 45

Tables

Table 1: Process to Apply for and Maintain Food Stamp Benefits 8
Table 2: Administrative Flexibility Available to States to Waive the
Face-to-Face Interview 14

Figures

Figure 1: Food Stamp Participation and Poverty Trends 6
Figure 2: Office-based Method Compared with Alternative Methods of
Applying for Food Stamp Benefits 9
Figure 3: Number and Percentage of States Making On-line Services
Available to Food Stamp Households 12
Figure 4: Number and Percentage of States Making Call Centers Available to
Food Stamp Households 13
Figure 5: Actions Used to Assist Households with On-line Services 16
Figure 6: Actions Used to Assist Households with Call Centers 17
Figure 7: FNS Monitoring of Indiana's Plan to Implement Alternative Access
Methods 21
Figure 8: States' Use of Measures to Monitor Performance of On-line
Services 23
Figure 9: States' Use of Measures to Monitor Performance of Call Centers
24
Figure 10: Use of Alternative Access Methods in Texas 30
Figure 11: Use of Alternative Access Methods in Florida 31

Abbreviations

EBT Electronic Benefits Transfer
ERS Economic Research Service
FNS Food and Nutrition Service
FSP Food Stamp Program
PRWORA Personal Responsibility and Work Opportunity Reconciliation Act of
1996
QC quality control
SSI Supplemental Security Income
TANF Temporary Assistance for Needy Families
USDA U.S. Department of Agriculture

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separately.

United States Government Accountability Office
Washington, DC 20548

May 3, 2007

The Honorable Tom Harkin Chairman Committee on Agriculture, Nutrition, and
Forestry United States Senate The Honorable Tom Harkin Chairman Committee
on Agriculture, Nutrition, and Forestry United States Senate

Dear Mr. Chairman:

Almost 1 in every 12 Americans participates in the federal Food Stamp
Program, which helps low-income individuals and families purchase
nutritious food, such as meat, dairy products, fruits, and vegetables. In
fiscal year 2005, the program, jointly administered by the U.S. Department
of Agriculture's (USDA) Food and Nutrition Service (FNS) and the states,
provided about $29 billion in benefits to nearly 26 million people, about
half of whom were children.^11Almost 1 in every 12 Americans participates
in the federal Food Stamp Program, which helps low-income individuals and
families purchase nutritious food, such as meat, dairy products, fruits,
and vegetables. In fiscal year 2005, the program, jointly administered by
the U.S. Department of Agriculture's (USDA) Food and Nutrition Service
(FNS) and the states, provided about $29 billion in benefits to nearly 26
million people, about half of whom were children.

Although participation in the program has increased substantially in
recent years, about 40 percent of people who were eligible for the program
did not participate in 2004, the most recent year data are available.
Elderly individuals, non-citizens that may have limited English
proficiency, and working families have consistently participated at lower
rates than the eligible population as a whole and FNS has targeted these
subgroups to increase participation. Even though there are many reasons
people may not participate in the program, some research has shown that
the administrative burden of applying for and maintaining eligibility for
benefits may be a factor, particularly for people who are elderly or who
work during the hours local public assistance offices are open.
Participation in the program generally requires individuals to submit an
application, participate in an interview at initial application and at
least annually, provide verification of certain information, report
certain changes in household circumstances while receiving benefits, and
reapply for benefits at the end of the certification period
(recertification). While completing the Food Stamp Program application and
recertification process has traditionally involved visiting the local
assistance office in person for interviews or to submit applications and
other documentation, Although participation in the program has increased
substantially in recent years, about 40 percent of people who were
eligible for the program did not participate in 2004, the most recent year
data are available. Elderly individuals, non-citizens that may have
limited English proficiency, and working families have consistently
participated at lower rates than the eligible population as a whole and
FNS has targeted these subgroups to increase participation. Even though
there are many reasons people may not participate in the program, some
research has shown that the administrative burden of applying for and
maintaining eligibility for benefits may be a factor, particularly for
people who are elderly or who work during the hours local public
assistance offices are open. Participation in the program generally
requires individuals to submit an application, participate in an interview
at initial application and at least annually, provide verification of
certain information, report certain changes in household circumstances
while receiving benefits, and reapply for benefits at the end of the
certification period (recertification). While completing the Food Stamp
Program application and recertification process has traditionally involved
visiting the local assistance office in person for interviews or to submit
applications and other documentation, states have begun offering
alternatives in the last several years, such as mail-in procedures, call
centers, and on-line services.

^1 Preliminary FNS data indicate that participation continued to grow to
nearly 27 million people receiving about $30 billion in food stamp
benefits in fiscal year 2006.

While FNS has allowed states to adopt these new ways of accessing the
program, it also has a quality control system in place to monitor program
integrity. Under this system, FNS monitors decision accuracy, including
how accurately states determine food stamp eligibility and calculate
benefits. In addition to monitoring the payment error rate, FNS estimates
the rate of cases denied, suspended, or terminated incorrectly, which is
called the negative error rate. FNS and USDA's Economic Research Service
(ERS) also fund Food Stamp Program research.

To understand what alternative approaches states are using to help
households apply for and maintain benefits and what is known about the
results of using these methods, we examined: (1) the alternative methods
to the traditional application and recertification process states are
using to increase program access; (2) what is known about the results of
these methods, particularly on program access for target groups, decision
accuracy, and administrative costs; and (3) what actions states have taken
to maintain program integrity while implementing alternative methods.

To answer these questions, we surveyed food stamp administrators in the 50
states and the District of Columbia^2 to collect information on what
alternative methods states are using or planning to use (mail, call
centers, on-line services), how performance of these methods is measured,
and what is known about the results of using these methods. To augment
information from our state survey, we conducted four site visits (Florida,
Texas, Utah, and Washington) and one set of semi-structured telephone
interviews (Pennsylvania). We selected states that have at least one
FNS-approved waiver of the face-to-face interview requirement and reflect
some variation in state participation rates. We also considered
recommendations from FNS officials, advocacy group representatives, and
researchers. For each of the five states we reviewed in depth, we
interviewed state officials administering and developing policy for the
Food Stamp Program, local officials in the assistance offices and call
centers where services are provided, and representatives from
community-based organizations that provide food assistance. We analyzed
data provided by FNS and the states we reviewed in depth to provide
background for our discussions with officials about state trends for
specific measures (participation, payment accuracy, administrative costs,
and reasons for denial). We also reviewed FNS reports and related studies.
We held discussions with program stakeholders, including officials at FNS
headquarters and regional offices, and representatives of advocacy
organizations. Appendix I explains our methodology in more detail. We
performed our work from September 2006 to March 2007 in accordance with
generally accepted government auditing standards.

^2 In this report, we refer to all 50 states and the District of Columbia
as states.

Results in Brief

All states use mail and about half of states use or have begun developing
on-line services and call centers to provide access to the Food Stamp
Program. Almost all states told us they allow households to submit
applications, report changes, and submit recertifications through the
mail, and 26 states have implemented or are developing systems to allow
households to submit applications, report changes, or submit
recertifications on-line. In addition, almost half of the states are using
or developing call centers and states are also using flexibility
authorized by FNS to increase use of the telephone as an alternative to
visiting the local assistance office. For example, FNS has approved
administrative waivers allowing 20 states to substitute a telephone
interview for the face-to-face interview for all households at
recertification without needing to document that coming into the office
would be a hardship for the household. States have taken a variety of
actions to help households use on-line services and call centers, such as
sending informational mailings, holding community meetings, and employing
call center staff who speak languages other than English. States are also
relying on community-based organizations, such as food banks, to help
households use alternative methods. For example, four of the five states
we interviewed provide grants to community-based organizations to inform
households about the program and help them complete the application
process.

Insufficient information is available to determine the results of using
alternative methods to provide access to the Food Stamp Program, but
federal and state officials reported that despite some challenges, they
believe these methods are making it easier for some households to access
program benefits. Few evaluations have been conducted to identify the
effect of alternative methods on program access, decision accuracy, or
administrative costs. FNS has two studies under way that will describe
implementation of alternative methods such as on-line services and call
centers, but it is unlikely that these studies will use research
approaches that would identify the effect of alternative methods. Further,
while states reported monitoring the performance of call centers and
on-line services, none of the states has conducted evaluations that would
identify the effect of the alternative methods on program access, decision
accuracy, or administrative costs. State officials reported implementing a
combination of methods over time, making it difficult to isolate the
effect of specific methods. Despite this, federal and state officials said
that they believe that giving households alternatives to visiting the food
stamp office can help improve access to benefits. For example, in the five
states we reviewed in depth, officials and community partners said that
allowing telephone interviews is especially beneficial for working
families and the elderly because they reduce barriers from transportation,
child care, or work responsibilities, as well as the stigma of visiting
the assistance office. However, officials and community partners also said
that certain types of households, such as those with limited English
proficiency, the elderly, and those with mental disabilities, may have
difficulty using on-line applications and navigating call center phone
systems. The advantages of alternative methods to households also may
depend on the technology and staff available. For example, on-line
applications without electronic signature capability have limited benefit
because households are required to also submit an actual signature through
mail, fax, or in person. Further, inadequate numbers of staff and
unskilled staff may limit the advantages of alternative methods because
households may not be able to receive the information and assistance
needed to successfully apply for or maintain benefits.

The five states we reviewed used a variety of strategies to maintain
program integrity while implementing alternative methods, some of which
were in place long before implementation of the alternative access
methods. All five states used software to help with verification of
household circumstances by, for example, matching state food stamp
caseloads against wage reporting systems and other databases to identify
unreported household income and assets. Nationwide, about half of the
states participate in quarterly matches with other states to detect
households receiving food stamp benefits in more than one state at a time.
In addition, all five states we reviewed developed special caseworker
training on topics such as how to detect misinformation provided by a
household over the telephone. State and local food stamp officials told us
they believed that using alternative methods had not increased the
frequency of fraud and abuse in the program because the verification
process is the same whether or not a worker sees an individual
face-to-face. There has been some concern that without face-to-face
contact with caseworkers, households may not know when or how to submit
paperwork or complete other tasks and would thus be denied benefits on
procedural grounds ("procedural denials"). However, our limited analysis
of FNS data found no considerable fluctuations in the rate of procedural
denials in the five states between fiscal years 2000 and 2005. To prevent
improper procedural denials, the five states we reviewed instituted such
approaches as reviewing case actions, correcting addresses for returned
mail, and changing automated systems to prevent caseworkers from
prematurely denying cases.

To improve USDA's ability to assess the effectiveness of its funded
efforts, we are recommending that the Secretary of Agriculture: direct FNS
and the Economic Research Service (ERS) to work together to enhance their
research agendas to include projects that would determine the effect of
alternative methods on program access, decision accuracy, and
administrative costs of the Food Stamp Program; and direct FNS to conduct
analyses of data received from states implementing waivers or
demonstration projects waiving the face-to-face interview and require
states implementing waivers or demonstration projects to collect and
report data that would facilitate such analyses. Further, to help states
implement alternative methods to provide access to the Food Stamp Program,
we are recommending that FNS disseminate and regularly update information
on states' implementation of alternative methods to the traditional
application and recertification process. FNS and ERS generally agreed with
our findings, conclusions, and recommendations and cited steps the agency
is taking to monitor and evaluate state implementation of alternative
access methods. FNS and ERS also provided technical comments, which were
incorporated into the report as appropriate.

Background

The federal Food Stamp Program is intended to help low-income individuals
and families obtain a more nutritious diet by supplementing their income
with benefits to purchase eligible foods at authorized food retailers,
such as meat, dairy products, fruits, and vegetables, but not items such
as soap, tobacco, or alcohol. FNS pays the full cost of food stamp
benefits and shares the states' administrative costs--with FNS usually
paying slightly less than 50 percent--and is responsible for promulgating
program regulations and ensuring that state officials administer the
program in compliance with program rules.^3 The states administer the
program by determining whether households meet the program's eligibility
requirements, calculating monthly benefits for qualified households, and
issuing benefits to participants through an electronic benefits transfer
system.

^3Reimbursements for food stamp administrative costs in 44 states are
adjusted each year to subtract certain food stamp administrative costs
that have already been factored into these states' Temporary Assistance
for Needy Families (TANF) grants. As a result, these states receive less
than 50 percent of their administrative costs. See GAO, Food Stamp
Program: States Face Reduced Federal Reimbursement for Administrative
Costs, [30]GAO/RCED/AIMD-99-231  (Washington D.C.: July 23, 1999).

Program Participation

In fiscal year 2005, the Food Stamp Program issued almost $28.6 billion in
benefits to about 25.7 million individuals per month, and the maximum
monthly food stamp benefit for a household of four living in the
continental United States in fiscal year 2007 was $518. As shown in figure
1, program participation decreased during the late 1990s, partly due to an
improved economy, but rose again from 2000 to 2005. The number of food
stamp recipients follows the trend in the number of people living at or
below the federal poverty level.

Figure 1: Food Stamp Participation and Poverty Trends

Notes: Poverty data are by calendar year and participation data are by
fiscal year.

Preliminary FNS data indicate that participation will continue to grow to
nearly 27 million people receiving about $30 billion in food stamp
benefits in fiscal year 2006.

In addition to the economic growth in the late 1990s, another factor
contributing to the decrease in number of participants from 1996 to 2001
was the passage of the Personal Responsibility and Work Opportunity
Reconciliation Act of 1996 (PRWORA), which added work requirements and
time limits to cash assistance and made certain groups ineligible to
receive food stamp benefits. In some cases, this caused participants to
believe they were no longer eligible for food stamps when TANF benefits
were ended.^4 Since 2000, that downward trend has reversed, and experts
believe that the downturn in the U.S. economy, coupled with changes in the
Food Stamp Program's rules and administration, has led to an increase in
the number of food stamp participants.

Determination of Eligibility and Benefits

Eligibility for participation in the Food Stamp Program is based primarily
on a household's income and assets. To determine a household's
eligibility, a caseworker must first determine the household's gross
income, which cannot exceed 130 percent of the poverty level for that year
as determined by the Department of Health and Human Services, and net
income, which cannot exceed 100 percent of the poverty level (or about
$1,799 per month for a family of three living in the continental United
States in fiscal year 2007). Net income is determined by deducting from
gross income a portion of expenses such as dependent care costs, medical
expenses for elderly individuals, utilities costs, and housing expenses.

The Process of Applying for and Maintaining Benefits

The application process for the Food Stamp Program requires households to
complete and submit an application to a local assistance office,
participate in an interview, and submit documentation to verify household
circumstances (see table 1). Applicants may need to make more than one
visit to the assistance office to complete the application process. After
eligibility is established, households are certified eligible for food
stamps for periods ranging from 1 to 24 months, depending on household
circumstances and state policy. While households are receiving benefits,
they must report changes in household circumstances that may affect
eligibility or benefit amounts. States may choose to require households to
report changes within 10 days of occurrence (incident reporting) or at
specified intervals (periodic reporting). States also have the option to
adopt a simplified system, which further reduces the burden of periodic
reporting by requiring households to report changes that happen during a
certification period only when their income rises above 130 percent of the
federal poverty level.^5 Once the certification period ends, households
must reapply for benefits, at which time eligibility and benefit levels
are redetermined. The recertification process is similar to the
application process. Households can be denied benefits or have their
benefits end at any point during the process if they are determined
ineligible under program rules or for procedural reasons, such as missing
a scheduled interview or failing to provide the required documentation.

^4As GAO and others have reported previously, following the passage of
PRWORA, there is evidence that food stamp participation dropped as
eligible recipients did not apply for food stamps because they incorrectly
assumed that if they were ineligible for TANF, they were also ineligible
for food stamps. See U.S. GAO, Food Stamp Program: Various Factors Have
Led to Declining Participation,  GAO/RCED-99-185 (Washington D.C.: July
1999) for more details.

Table 1: Process to Apply for and Maintain Food Stamp Benefits

Apply for benefits    While receiving benefits      Recertify for benefits 
      o Complete and        o Report changes in           o Complete and      
      submit application    household                     submit              
      to assistance         circumstances--such as        recertification     
      office                household composition,        application to      
      o Participate in      income, and expenses--that    assistance office   
      an interview          may affect eligibility or     o Participate in an 
      o Submit              benefit amounts               interview at least  
      documentation to                                    annually            
      verify information                                  o Submit            
      provided in the                                     documentation to    
      application and                                     verify information  
      interview                                           provided in the     
                                                          application and     
                                                          interview           

Source: GAO analysis of FNS information.

While applying for and maintaining food stamp benefits has traditionally
involved visiting a local assistance office, states have the flexibility
to give households alternatives to visiting the office, such as using the
mail, the telephone, and on-line services to complete the certification
and recertification process. Alternative methods may be used to support
other programs, such as Medicaid or TANF, since some food stamp
participants receive benefits from multiple programs. Figure 2 illustrates
a traditional office-based system and how states can use a number of
alternative methods to determine applicants' eligibility without requiring
them to visit an assistance office.

^5 The Farm Security and Rural Investment Act of 2002 (the 2002 Farm Bill)
included provisions intended to simplify program administration, such as
allowing states the option of using simplified/semiannual reporting
systems for most households, not just those with earned income. FNS
reported in October 2006 that 47 states have adopted some form of
simplified reporting, allowing most households to report changes only when
their income rises above 130 percent of the poverty level. A FNS study
suggested that simplified reporting policies have contributed to a
reduction in the food stamp payment error rate.

Figure 2: Office-based Method Compared with Alternative Methods of
Applying for Food Stamp Benefits

Program Integrity

FNS and the states share responsibility for implementing a quality control
system used to measure the accuracy of caseworker decisions concerning the
amount of food stamp benefits households are eligible to receive and
decisions to deny or end benefits. The food stamp payment error rate is
calculated by FNS for the entire program, as well as every state, by
adding overpayments (including payments higher than the amounts households
are eligible for or payments to those who are not eligible for any
benefit), and underpayments (payments lower than the amounts households
are eligible for). The national payment error rate has declined by about
40 percent between 1999 and 2005, from 9.86 percent to a record low of
5.84 percent. FSP payment errors are caused primarily by caseworkers,
usually when they fail to keep up with new information, and by
participants when they fail to report needed information. Another type of
error measured by FNS is the negative error rate, defined as the rate of
cases denied, suspended, or terminated incorrectly. An example of
incorrectly denying a case would be if a caseworker denied a household
participation in the program because of excess income, but there was a
calculation error and the household was actually eligible for benefits.
FNS also monitors individual fraud and retailer trafficking of food stamp
benefits.^6

All States Use Mail and About Half of States Use or Have Begun Developing
On-line Services and Call Centers to Provide Access to the Food Stamp Program

According to our survey, almost all states allow households to submit
applications, report changes, and submit recertifications through the
mail, and 26 states have implemented or are developing systems to allow
households to perform these tasks on-line. Almost half of the states are
using or developing call centers and states are also using flexibility
authorized by FNS to increase use of the telephone as an alternative to
visiting the local assistance office. States have taken a variety of
actions to help households use on-line services and call centers, such as
sending informational mailings, holding community meetings, and using
community partners to assist households.

^6 For more information on food stamp payment accuracy and trafficking,
see Food Stamp Program: States Have Made Progress Reducing Payment Errors,
and Further Challenges Remain, GAO-05-245. (Washington, D.C.: May 5, 2005)
and Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better
Targeting Stores Likely to Traffic and Increasing Penalties, GAO-07-53.
(Washington, D.C.: Oct. 13, 2006).

Almost All States Allow Households to Apply for Food Stamp Benefits and Maintain
Eligibility by Mail and about Half of the States Are Using or Developing On-line
Services

Many states are allowing households to apply for food stamp benefits,
report changes in household circumstances, and complete recertification
through the mail and on-line. ^7

           o Mail-In Procedures. Results of our survey show that households
           can submit applications through the mail in all states, report
           changes through the mail in all but 1 state, and submit
           recertifications through the mail in 46 states. For example,
           Washington state officials told us that the recertification
           process involves mailing a recertification application package to
           households that they can mail back without visiting a local
           assistance office.

           o On-line Services. All states we surveyed reported having a food
           stamp application available for households to download from a
           state website, as required by federal law, and 26 states (51
           percent) have implemented or are developing Web-based systems in
           which households can submit initial applications, report changes,
           or submit recertifications on line (see fig. 3). Most on-line
           applications were made available statewide and implemented within
           the last 3 years and states developing on-line services plan to
           implement these services within the next 2 years. All of the 14
           states that reported currently providing on-line services allow
           households to submit initial food stamp applications on-line, but
           only 6 states allow households to report changes and 5 states
           allow households to complete recertification on- line.^8 Of the 14
           states that reported using on-line applications, 2 reported they
           were only available in certain areas of the state. Only two states
           (Florida and Kansas) reported in our survey that the state closed
           program offices or reduced staff as a result of implementing
           on-line services.

^7 See appendix II for state-by-state information on use of alternative
methods.

^8 Utah began piloting an on-line application with electronic signature
capability in March 2007. Because this was after the time our survey was
conducted, Utah is not included in the 14 states that currently provide
on-line services. FNS reported in October 2006 that nine states nationwide
allow applicants to submit the application with an electronic signature.

Figure 3: Number and Percentage of States Making On-line Services
Available to Food Stamp Households

Almost Half of States Are Using or Developing Call Centers and Using Telephone
Interviews as an Alternative to Visiting the Local Assistance Office

Many states are using call centers, telephone interviews, or other
technologies to help households access food stamp benefits or information
without visiting a local assistance office.

           o Call Centers. Nineteen states (37 percent) have made call
           centers available to households and an additional 4 states (8
           percent) have begun development of call centers that will be
           available to households in 2007 (see fig. 4). Households have been
           able to use call centers in seven states for more than 3 years. Of
           the 19 states using call centers, 10 reported that call centers
           were only available in certain areas of the state. Only two states
           (Texas and Idaho) reported using private contractors to operate
           the call centers, but Texas announced in March 2007 that it was
           terminating its agreement with the private contractor (see fig. 10
           for more details). FNS officials told us that the Idaho private
           call center provides general food stamp program information to
           callers, while inquiries about specific cases are transferred to
           state caseworkers. Indiana reported in our survey that the state
           plans to pilot call centers in certain areas of the state in
           August 2007 using a private contractor and complete a statewide
           transition in March 2008. Only two states (Florida and Arizona)
           reported in our survey that the state closed offices or reduced
           staff as a result of implementing call centers.

Figure 4: Number and Percentage of States Making Call Centers Available to
Food Stamp Households

Most states with call centers reported that households can use them to
report changes in household circumstances, request a food stamp
application and receive assistance filling it out, receive information
about their case, or receive referrals to other programs. Only four states
reported using their call centers to conduct telephone interviews. For
example, local officials in Washington told us that households use their
call center primarily to request information, report changes in household
circumstances, and request an interview. Telephone interviews are
conducted by caseworkers in the local assistance office.

           o Telephone Interviews. Many states are using the flexibility
           provided by FNS to increase the use of the telephone as an
           alternative to households visiting the local assistance office.
           For example, FNS has approved administrative waivers for 20 states
           that allow states to substitute a telephone interview for the
           face-to-face interview for all households at recertification
           without documenting that visiting the assistance office would be a
           hardship for the household.^9 In addition to making it easier on
           households, this flexibility can reduce the administrative burden
           on the state to document hardship. FNS also allows certain states
           implementing demonstration projects to waive the interview
           requirement altogether for certain households. States we reviewed
           varied in terms of the proportion of interviews conducted over the
           phone. For example, Florida state and local officials estimated
           that about 90 percent of the interviews conducted in the state are
           completed over the telephone. Washington state officials estimated
           that 10 percent of application interviews and 30 percent of
           recertification interviews are conducted by phone. Table 2
           describes the types of flexibility available to states and how
           many are taking advantage of each.

^9 See appendix II for names of states with administrative waivers that
allow substitution of a telephone interview for the face-to-face
interview.

Table 2: Administrative Flexibility Available to States to Waive the
Face-to-Face Interview

                                                        Year                  
                                                available or                  
                                                       first                  
                                                 approved by Number of        
Description of flexibility     Availability           FNS states^d         
Hardship policy^a              All states            1978 All states       
                                                                              
Substitute telephone interview                                             
for face-to-face interview at                                              
application or recertification                                             
for all households                                                         
experiencing a hardship as                                                 
determined by the state.                                                   
Hardship must be documented in                                             
the case file.                                                             
Waiver at recertification      States   with         1992 20               
                                  waivers                                     
Substitute telephone interview                                             
for face-to-face interview for                                             
all households at                                                          
recertification without                                                    
documenting hardship.                                                      
Waiver       at        initial States   with         2005 3                
certification^b                waivers                                     
                                                                              
Substitute telephone interview                                             
for face-to-face interview for                                             
all households at initial                                                  
certification without                                                      
documenting hardship.                                                      
Combined           Application States with           1995    o 10 have     
Projects^c                     demonstration                 implemented   
                                  projects                      o 6 approved  
Households can apply for food                                or pending    
stamps at the same time they                                 approval but  
apply for or are recertified                                 have not      
for Supplemental Security                                    implemented   
Income (SSI) with the Social                                 o 5 more have 
Security Administration.                                     been invited  
Households are not required to                               to submit     
have a separate interview to                                 proposals     
apply for food stamps.                                                     
Elderly/Disabled Demonstration States with           2002 2                
Projects                       demonstration                               
                                  projects                                    
Simplify the application                                                   
process for elderly and/or                                                 
disabled households in part by                                             
waiving the interview                                                      
altogether.                                                                

Source: GAO analysis of FNS information.

aThese hardship conditions include, but are not limited to: illness,
transportation difficulties, care of a household member, hardships due to
residency in a rural area, prolonged severe weather conditions, or work or
training hours that prevent the household from participating in an
in-office interview. States must document hardship. The regulations also
allow states to opt to substitute telephone interviews for face-to-face
interviews for all households that have no earned income and in which all
members are elderly or disabled.

bLimited to no more than 50 percent of the statewide caseload.

cThe Food Stamp Act of 1977 included several access provisions, such as
addressing the use of mail, telephone, or home visits for certification
and joint food stamps and SSI application processing. Since 1986, federal
law has required that applicants for or recipients of SSI must be informed
of the opportunity to file a food stamp application at the SSA office when
applying for SSI.

dSee appendix II for specific state information.

           o Other Technologies. Some states reported implementing other
           technologies that support program access. Specifically, according
           to our survey, 11 states (21 percent) have implemented an
           Integrated Voice Response (IVR) system, a telephone system that
           provides automated information, such as case status or the benefit
           amount, to callers but does not direct the caller to a live
           person. In addition, 11 states (21 percent) are using document
           management/imaging systems that allow case records to be
           maintained electronically rather than in paper files.

All five of the states we reviewed have implemented in at least certain
areas of their state mail-in procedures, on-line services, call centers,
waiver of face-to-face interview at recertification, and document
management/imaging systems. Three of the five states (Florida, Texas, and
Washington) have implemented an integrated voice response system and two
(Florida and Utah) have implemented a waiver of the face-to-face interview
at initial application.

States Report Taking Several Actions to Help Households Use Alternative Methods

States have taken a variety of actions to help households use on-line
services and call centers, such as sending informational mailings, holding
community meetings, and employing call center staff who speak languages
other than English as shown in figures 5 and 6.

Figure 5: Actions Used to Assist Households with On-line Services

Figure 6: Actions Used to Assist Households with Call Centers

States are using community-based organizations, such as food banks, to
help households use alternative methods. All states implementing on-line
services (14)^10 and about half of states with call centers (10 of 19) use
community partners to provide direct assistance to households. Among the
states we reviewed, four provide grants to community-based organizations
to inform households about the program and help them complete the
application process. For example, Florida closed a third of its local
assistance offices and has developed a network of community partners
across the state to help households access food stamps. Florida state
officials said that 86 percent of the community partners offer at least
telephone and on-line access for completing and submitting food stamp
applications. Community partner representatives in Washington, Texas, and
Pennsylvania said that they sometimes call the call center with the
household or on their behalf to resolve issues. Pennsylvania provides
grants to community partners to help clients use the state's on-line
services. In addition to the assistance provided by community-based
organizations, H&R Block, a private tax preparation firm, is piloting a
project with the state of Kansas where tax preparers who see that a
household's financial situation may entitle them to food stamp benefits
can electronically submit an application for food stamps at no extra
charge to the household.

^10 Utah began piloting an on-line application with electronic signature
capability in March 2007. Because this was after the time our survey was
conducted, Utah is not included in the 14 states that currently provide
on-line services.

Information on Results Is Limited, but States We Reviewed Cite Advantages and
Challenges Using Alternative Access Methods

Insufficient information is available to determine the results of using
alternative methods to access the Food Stamp Program, but state and
federal officials report that alternative methods are helping some
households. Few evaluations have been conducted that identify the effect
of alternative methods on food stamp program access, decision accuracy, or
administrative costs. Although states monitor the implementation of
alternative methods, isolating the effects of specific methods is
difficult, in part because states typically have implemented a combination
of methods over time. Despite the limited information on the effectiveness
of alternative methods, federal and state officials believe that these
methods can help many households by making it easier for them to complete
the application or recertification process. However, technology and
staffing challenges can hinder the use of these methods.

Few Evaluations Have Been Conducted and Determining the Effectiveness of
Specific Methods Can Be Difficult

Few federal or state evaluations have been conducted to identify how using
alternative methods, such as on-line applications or call centers, affects
access to the Food Stamp Program, the accuracy of caseworker decisions
about eligibility and benefit amounts, or administrative costs. Few
evaluations have been conducted in part because evaluating the
effectiveness of alternative methods is challenging, given that limited
data are available, states are using a combination of methods, and studies
can be costly to conduct.

  Federal Evaluation and Monitoring

FNS and ERS have funded studies related to improving Food Stamp Program
access, but none of these previous studies provide a conclusive assessment
of the effectiveness of alternative methods and the factors that
contribute to their success (see app. I for a list of the studies we
selected and reviewed). Although these studies aimed to evaluate local
office practices, grants, and demonstration projects, the methodological
limitations of this research prevent assessments about the effectiveness
of these efforts. An evaluation of the Elderly Nutrition Demonstration
projects used a pre-post comparison group design to estimate the impact of
the projects and found that food stamp participation among the elderly can
be increased. ^11 Two of the projects evaluated focused on making the
application process easier by providing application assistance and
simplifying the process, in part by waiving the interview requirement.
However, one of the drawbacks of this study is that its findings are based
on a small number of demonstrations, which affects the generalizability of
the findings.

Two related FNS-funded evaluations are also under way, but it is unlikely
these studies will identify the effects of using alternative methods.^12

           o An implementation study of Florida's efforts to modernize its
           system using call centers and on-line services involves a
           descriptive case study to be published in late summer 2007,
           incorporating both qualitative and quantitative data. The
           objectives of the study are to: describe changes to food stamp
           policies and procedures that have been made in support of
           modernization; identify how technology is used to support the
           range of food stamp eligibility determination and case management
           functions; and describe the experiences of food stamp
           participants, eligible non-participants, state food stamp staff,
           vendors, and community partners. This study will describe
           Florida's Food Stamp Program performance over time in comparison
           to the nation, other states in the region, and other large states.
           Performance data that will be reviewed includes program
           participation in general and by subgroup, timeliness of
           application processing, payment error rates, and administrative
           costs. However, the study will not isolate the effect of the
           modernization efforts on program performance.

           o A national study of state efforts to enhance food stamp
           certification and modernize the food stamp program involves a
           state survey and case studies of 14 states and will result in a
           site visit report in late summer 2007, a comprehensive report in
           March 2009, and a public-use database systematically describing
           modernization efforts across all the states in May 2009. The
           national study will focus on four types of modernization efforts:
           policy changes to modernize FSP application, case management, and
           recertification procedures; reengineering of administrative
           functions; increased or enhanced use of technology; and partnering
           arrangements with businesses and nonprofit organizations. The
           goals of the study include documenting outcomes associated with
           food stamp modernization and examining the effect of these
           modernization efforts on four types of outcomes: program access,
           administrative cost, program integrity, and customer services.
           This study will compare performance data from the case study
           states with data from similar states and the nation as a whole,
           however, this analysis will not determine whether certain
           modernization efforts caused changes in performance.

^11 Evaluation of the USDA Elderly Nutrition Demonstrations, Scott Cody
and James Ohls, Mathematica Policy Research, Inc., May 2005.

^12 In addition to studies that are under way, the fiscal year 2008 Food
Nutrition and Consumer Services budget request, which includes FNS,
includes $2 million to support Food Stamp Modernization and Innovation
Projects to study the impact of new Food Stamp Program service delivery
models on program access, payment accuracy, and administrative costs.

USDA has also awarded $5 million in fiscal year 2006 to 5 grantees in
Virginia, California, Georgia and Alabama to help increase access to the
program, but there is currently no plan to publish an evaluation of the
outcomes of these projects. The participation grants focus on efforts to
simplify the application process and eligibility systems and each grantee
plans to implement strategies to improve customer service by allowing
Web-based applications and developing application sites outside the
traditional social services office. Grantees are required to submit
quarterly progress reports and final reports including a description of
project activities and implementation issues.

Although few evaluations have been conducted, FNS monitors state and local
offices and tracks state implementation of alternative methods to improve
program access. FNS also collects and monitors data from states, such as
the number of participants, amount of benefits issued, participation rates
overall and by subgroup, timeliness of application processing, payment
errors, negative errors, and administrative costs. FNS regional offices
conduct program access reviews of selected local offices in all states to
determine whether state and/or local policies and procedures served to
discourage households from applying for food stamps or whether local
offices had adopted practices to improve customer service. FNS also
monitors major changes to food stamp systems using a process where FNS
officials review and approve plans submitted by states related to system
development and implementation, including major upgrades. States like
Texas, Florida, and Indiana that have implemented major changes to their
food stamp system, such as moving from a local assistance office service
delivery model to call centers and on-line services, have worked with FNS
through this process. Figure 7 describes FNS's monitoring of Indiana's
plan to implement alternative access methods.

Figure 7: FNS Monitoring of Indiana's Plan to Implement Alternative Access
Methods

FNS has also encouraged states to share information about their efforts to
increase access among states, but states reported needing additional
opportunities to share information. FNS has funded national and regional
conferences, travel by state officials to visit other states to learn
about their practices, as well as provided states a guide to promising
practices for improving program access.^13 The guide contains information
about the goal of each practice, the number of places where the practice
is in use, and contact information for a person in these offices. However,
this guide has not been updated since 2002 and, for the most part, does
not include any evidence that these efforts were successful or any lessons
that were learned from these or other efforts.^14 In 2004, in response to
recommendations from our prior report,^15 FNS compiled and posted 19
practices aimed to improve access from 11 states. FNS also has a form
available on its website where states can submit promising practices to
improve access, but to date, practices from this effort have not been
published. In our survey, 13 states (about 25 percent) reported needing
additional conferences or meetings with other states to share information.

^13State Best Practices Improving Food Stamp Program Access, USDA, FNS,
(June 2002).

^14Advocacy groups such as the American Public Human Services Association
and the Food Research Action Center also make information available on
food stamp outreach and access in best practices guides, on their Web
sites, or through conferences.

^15 Food Stamp Program: Steps Have Been Taken to Increase Participation of
Working Families, but Better Tracking of Efforts Is Needed, GAO-04-346
(Washington, D.C.: March 5, 2004).

  State Evaluation and Monitoring

States also report monitoring use of alternative methods in the Food Stamp
Program, but have not conducted evaluations of their effectiveness. In our
survey, states reported monitoring several aspects of the performance of
on-line services. As shown in figure 8, states most commonly used the
number of applications submitted, the number of applications terminated
before completion, and customer satisfaction to monitor the performance of
on-line services. For example, Pennsylvania state officials monitor
performance of their on-line system and meet regularly with community
partners that help households submit applications for benefits to obtain
feedback on how they can improve the system. Florida state officials told
us they use responses to on-line feedback surveys submitted at the end of
the on-line application to assess customer satisfaction with the state's
on-line services.

Figure 8: States' Use of Measures to Monitor Performance of On-line
Services

States also reported in our survey monitoring several aspects of the
performance of their call centers. As shown in figure 9, most states with
call centers reported monitoring the volume of transactions and calls to
the center, customer satisfaction, the rate of abandoned calls, and the
length of time callers are on hold before speaking with a caseworker. For
example, Utah officials monitor several measures and added additional
staff to the call center after observing increased hold times when they
were implementing the call center to serve the Salt Lake City area. In
addition, Washington state officials told us that they monitor call
centers on an hourly basis, allowing call center managers to quickly
increase the number of staff answering phones as call volumes increase.

Figure 9: States' Use of Measures to Monitor Performance of Call Centers

Despite these monitoring efforts, no states reported conducting an
evaluation of the effectiveness of on-line services in our survey and only
one state reported conducting such an evaluation of its call centers. The
report Illinois provided on its call center described customer and worker
feedback on the performance of the call center, but did not provide a
conclusive assessment of its effectiveness. Seven states implementing
Combined Application Projects (CAP)^16 have submitted reports to FNS
including data on the number of participants in the CAP project compared
with when the project began, but do not use methods to isolate the effect
of the project or determine whether participation by SSI recipients would
have increased in the absence of the project. Two of the five states we
reviewed said they planned to conduct reviews of their system. For
example, Washington is conducting an internal quality improvement review
of its call centers. It will compare call center operations with industry
best practices and promising new technologies, and will identify the
costs, services offered, and best practices used by the call centers.

^16 Combined Application Projects (CAP) allow one-person SSI households to
file a shortened food stamp application form and waive the face-to-face
interview requirement.

  Evaluation Challenges

Few evaluations have been conducted, in part because evaluating the
effectiveness of alternative methods is challenging. For example, states
are limited in their ability to determine whether certain groups of
households are able to use alternative methods because few states collect
demographic information on households that use their on-line services and
call centers. Only six states reported in our survey that they collect
demographic information on the households that use on-line services and
four states reported collecting demographic information on the households
that use call centers. In addition, although FNS is requiring states with
waivers to the face-to-face interview to track the payment accuracy of
cases covered by these waivers, FNS has not yet assessed the effects of
these methods on decision accuracy because it has not collected enough
years of data to conduct reliable analyses of trends. Further, evaluations
that isolate the effect of specific methods can be challenging because
states implement methods at different times and are using a combination of
methods. For example, Washington state implemented call centers in 2000,
an on-line application and CAP in 2001, and document imaging and a waiver
of the face-to-face interview at recertification in 2003. Sophisticated
methodologies often are required to isolate the effects of certain
practices or technologies. These studies can be costly to conduct because
the data collection and analysis can take years to complete. For example,
the two studies that we reviewed that aimed to isolate the effects of
specific projects each cost over $1 million and were conducted over more
than 3 years. Although evaluating the effects of alternative methods is
challenging, FNS is collecting data from states through the waiver process
that could be analyzed and previous ERS-funded studies have used
methodologies that enable researchers to identify the effect of certain
projects or practices on program access.

Federal and State Officials Report Alternative Methods Help Some Households
Access Food Stamp Benefits, but Technology and Staffing Can Present Challenges

Despite the limited information on the effects of alternative methods,
federal and state officials report that alternative methods, such as the
availability of telephone interviews, can help many types of households by
making it easier for them to complete the food stamp application or
recertification process. Some state and local officials and community
partners noted, however, that certain types of households may have
difficulty using some methods. Moreover, some officials also described how
technology and staffing challenges can hinder the use of these methods.

  Advantages of Alternative Methods

According to federal and state officials we interviewed, alternative
methods can help households in several ways, such as increasing
flexibility, making it easier to receive case information or report
changes to household circumstances, or increasing efficiency of
application processing. In addition, community partner representatives
from some states we reviewed said that the availability of telephone
interviews helps reduce the stigma of applying for food stamp benefits
caused by visiting an assistance office.

           o Increased flexibility. Federal officials from the seven FNS
           regional offices said that alternative methods help households by
           reducing the number of visits a household makes to an assistance
           office or by providing additional ways to comply with program
           requirements. Moreover, all of the states in our survey that
           currently have on-line services and more than half of the states
           that currently operate call centers, reported that reducing the
           number of visits an individual must make to an office as a reason
           for implementing the alternative methods. For example, in Florida
           a household may submit an application or recertification through
           any one of the following access points -- on-line, mail, fax,
           community partner site, or in-person at the local assistance
           office. Additionally, in certain areas of Texas, it is possible
           for households to apply for food stamps without ever visiting a
           local assistance office because the state has made available phone
           interviews and on-line services. Reducing the number of required
           visits can be helpful for all households, according to state
           officials or community partner representatives in two of the
           states we reviewed.

           o Easier access to case information and ability to report changes.
           According to officials in the five states we reviewed, alternative
           methods, such as call centers, automated voice response systems,
           or electronic case records, make it easier for households to
           access information about their benefits and report changes to
           household circumstances. For example, in Washington, a household
           may call the automated voice response system 24 hours a day, 7
           days a week to immediately access case information, such as
           appointment times or whether their application has been received
           or is being processed. If the household has additional questions,
           they can call the call center where a call center agent can view
           their electronic case record and provide information on the status
           of their application, make decisions based on changes in household
           circumstances reported to them, inform them of what verification
           documents are needed or have been received, or perform other
           services.

           o Increased efficiency. State or local officials from four of the
           states we reviewed said that implementation of document
           management/imaging systems improves application processing times,
           while local officials in two of the states said that call centers
           help caseworkers complete tasks more quickly. Furthermore, about
           half of the states in our survey that have call centers reported
           that increasing timeliness of application processing and reducing
           administrative costs were reasons for implementing them. State
           officials in Florida said that the document management/imaging
           system allows a caseworker to retrieve an electronic case record
           in seconds compared to retrieving paper case files that previously
           took up to 24 hours, allowing caseworkers to make eligibility
           decisions more quickly on a case. Additionally, a call center
           agent can process a change in household circumstances instantly
           while on the phone. Caseworkers in Pennsylvania said that
           implementation of a change reporting call center has reduced the
           number of calls to caseworkers at the local assistance office,
           which allows them to focus on interviewing households and
           processing applications more quickly. Officials from four states
           we reviewed also said that use of a document management/imaging
           system has resulted in fewer lost documents, which can reduce the
           burden on households of having to resubmit information.

According to some of the state officials and community partners we
interviewed, the availability of alternative methods can be especially
beneficial for working families or the elderly because it reduces barriers
from transportation, child care or work responsibilities. For example,
state officials in Florida explained that a working individual can
complete a phone interview during their lunch break without taking time
off of work to wait in line at the assistance office. In addition, state
officials from three of the states we reviewed that have implemented CAP
projects told us that they had experienced an increase in participation
among SSI recipients and FNS and officials from two states said that
households benefited from the simplified application process. In addition,
state officials in Florida said that on-line services help elderly
households that have designated representatives to complete the
application on their behalf. For example, an elderly individual's adult
child who is the appointed designated representative but lives
out-of-state can apply and recertify for food stamp benefits for their
parent without traveling to Florida.

However, some state and local officials and community partners we
interviewed said certain types of households may have difficulty using
certain alternative methods. For example, community partner
representatives in two states that we reviewed said that those with
limited English proficiency, elderly, immigrants, or those with mental
disabilities may have difficulty using on-line applications. Local
officials from Philadelphia said that the elderly and households with very
low incomes may have trouble accessing computers to use on-line services
and may not have someone helping them. A community partner in Florida told
us that sometimes the elderly, illiterate, or those with limited English
proficiency need a staff person to help them complete the on-line
application. In addition, those with limited English proficiency, elderly,
or those with mental disabilities may have difficulty navigating the call
center phone system, according to officials from two states and community
partners from another state that we reviewed. A community partner
representative in Texas said that sometimes he calls the call center on
behalf of the applicant because a household may have experienced
difficulty or frustration in navigating the phone system.

  Challenges to Using Alternative Methods

Although officials told us that alternative methods are helpful to many
households, challenges from inadequate technology or staffing may limit
the advantages of alternative methods. For example, state officials from
Texas explained that on-line applications without electronic signature
capability have limited benefit because households are still required to
submit an actual signature through mail, fax, or in person after
completing the on-line application. Texas state officials and community
partner representatives told us that the lack of this capability limited
its use and benefit to households. By contrast, Florida's application has
electronic signature capability and Florida officials reported that, as of
December 2006, about 93 percent of their applications are submitted
on-line.

Call centers that do not have access to electronic records may not be as
effective at answering callers' questions. Officials from Washington state
and federal officials from an FNS regional office view the use of a
document management/imaging system as a vital part of the call center
system. Florida advocates said that households have received wrong
information from call center agents and attribute the complaints in part
to call center agents not having access to real-time electronic case
records. Florida recently expanded its document imaging system statewide,
which they believe will help address these concerns.

Further, while four of the five states we reviewed implemented alternative
methods in part to better manage increasing numbers of participants with
reduced numbers of staff, the staffing challenges certain states
experienced also limited the advantages of alternative methods. For
example, inadequate numbers of staff or unskilled call center staff may
reduce the level of service provided and limit the advantages to
households of having a call center available to them. Texas and Florida
have experienced significant staff reductions at a time of increased
participation, which has affected implementation of alternative methods
(see figs. 10 and 11).

Figure 10: Use of Alternative Access Methods in Texas

Figure 11: Use of Alternative Access Methods in Florida

While some states face challenges implementing alternative methods, Utah
state officials said that they have successful call centers because they
have implemented technology incrementally over time and because they use
state caseworkers experienced in program rules. Utah state officials also
reported having relatively low caseloads (180 per worker) compared with
Texas (815 per worker, in 2005).

States Report Taking Actions to Maintain Food Stamp Program Integrity While
Using Alternative Methods

To maintain program integrity while implementing alternative methods for
applying and recertifying for food stamps, officials from the states we
reviewed reported using a variety of strategies, some of which were in
place long before implementation of the alternative access methods. Some
states used finger imaging, electronic signatures, and special
verification techniques to validate the identity of households using call
centers or on-line services. In addition, states use databases to verify
information provided by households and to follow up on discrepancies
between information reported by the household and information obtained
from other sources. Officials in the five states we reviewed did not
believe that the use of alternative methods had increased fraud in the
program. Further, despite concern that a lack of face-to-face interaction
with caseworkers would lead to more households being denied benefits for
procedural reasons, such as missing a scheduled interview, our limited
analysis indicated no considerable fluctuations in the rate of procedural
denials and officials from the states we reviewed reported taking actions
to prevent them.

  State Actions to Prevent Improper Food Stamp Payments and Fraud

Some states have taken several actions to prevent improper food stamp
payments and fraud while implementing alternative methods. Nationally,
states have systems in place to protect program integrity and the states
we reviewed described how they prevent improper payments and fraud as they
implement alternative access methods.

           o Finger imaging. Nationwide, four states^17 currently use finger
           imaging of food stamp applicants to prevent households from
           applying more than once for benefits. FNS officials commented that
           the agency has not concluded that finger imaging enhances program
           integrity and that it may have a negative effect on program access
           by deterring certain households from applying.

           o Electronic signatures. FNS reported in October 2006 that nine
           states use electronic signatures to validate the identity of
           on-line users of their systems. For example, Florida's on-line
           application asks applicants to click a button signifying that they
           are signing the application. Of the states we reviewed,
           Pennsylvania, Florida, and Washington have on-line services with
           electronic signatures.^18 
           o In-depth interview for high-risk cases. In Florida, a case that
           is considered to have a greater potential for error or fraud is
           flagged as a "red track" case, and it receives an in-depth
           interview to more fully explore eligibility factors. FNS officials
           commented that Florida uses an abbreviated interview with most
           households and that their in-depth interview for red track cases
           may be equivalent to the standard interview process used in other
           states.

           o Special training for call center agents. Call center agents in
           the five states we reviewed are trained to verify callers'
           identities by asking for specific personal information available
           in the file or in the states' records. Pennsylvania has developed
           specialized interview training, including a video, for eligibility
           workers on conducting telephone interviews of households applying
           or recertifying for the Food Stamp Program. One element of the
           training is how to detect misinformation being provided by a
           household. For example, if records indicate that a household
           member is currently incarcerated and benefits are being claimed
           for that person, call center agents are trained to probe for
           additional information. Similarly, Utah trains telephone
           interviewers to request more information if needed to clarify
           discrepancies in the case, such as a household reporting rent
           payments too high to be covered by the household's reported
           income.

           o Data matching. States have used data matching systems for many
           years and all five states we reviewed used software either
           developed by the state or obtained through a third-party vendor to
           help with verification of household circumstances. For example,
           data matching software can match state food stamp caseloads
           against wage reporting systems and other databases to identify
           unreported household income and assets. Utah and Washington have
           developed software that automatically compares information
           provided by applicants and recipients with information contained
           in state databases, such as income and employment information.
           State officials told us that using this software greatly reduces
           the burden on caseworkers, who would otherwise have to search
           multiple databases one at a time. In addition to requiring case
           workers to access state and federal data sources to verify
           information, Texas contracts with a private data vendor to obtain
           financial and other background information on food stamp
           applicants and recipients. After a household has started receiving
           benefits, states conduct additional data matching, and their
           systems generate a notice to the caseworker if there is a conflict
           between what the household reported and information obtained from
           another source. The information in these notices is investigated
           to ensure that recipients receive the proper level of benefits.
           Finally, about half of all states participate in the voluntary
           quarterly matching of their food stamp rolls with those of other
           states to detect individuals receiving food stamp benefits in more
           than one state at a time.

^17 Texas, California, New York, and Arizona.

^18 Utah also began piloting an on-line application with electronic
signature capability in March 2007.

Food stamp officials in four of the states we reviewed said that they did
not believe the use of alternative methods has increased the frequency of
fraud and abuse in the program and officials in one state were unsure and
collecting data to help determine whether the frequency of fraud had
increased. Texas caseworkers, for example, told us they did not think
telephone interviews increased fraud because they believed the
verification conducted by caseworkers and the states' data matching system
was sufficient. However, we have previously reported on the risk of
improper payments and fraud in the food stamp program and since there is
always risk of fraud and improper payments, particularly given the high
volume of cases and the complexity of the program, it is important that
states include additional controls when changing their processes and that
states continually assess the adequacy of those controls for preventing
fraud.

  State Actions to Limit Procedural Denials

Some program experts have expressed concern that households would be
denied for procedural reasons more frequently if they had less
face-to-face interaction with caseworkers, although data have not borne
out these concerns and states are taking actions to limit procedural
denials. During our site visits, some officials reported examples of
procedural denials resulting from alternative methods. For example,
community group representatives in Florida said that some households were
denied benefits because they could not get through to a call center agent
to provide required verification in time. However, they also acknowledged
that procedural denials due to not providing verification were frequent
prior to the state implementing these methods. In addition, Texas
officials said that some households were denied benefits for missing
scheduled interviews when the private contractor was late in mailing
notices of the interview appointments.

Our limited analysis of FNS data for the five states we reviewed found no
considerable fluctuations in the rate of procedural denials between fiscal
years 2000 and 2005. However, a household's failure to provide
verification documents was the most common procedural reason for denial,
suspension, or termination of benefits in the five states we reviewed.
States we visited described their efforts to help households use
alternative methods and prevent procedural denials for households that are
not seen in person by case workers. Examples of actions the states we
reviewed took to prevent procedural denials include: reviewing actions
taken for cases that are denied, training caseworkers on preventing
improper denials, routinely correcting addresses from returned mail, and
developing automated system changes to prevent caseworkers from
prematurely denying a case. For example, Utah trains its caseworkers to
inform households of all deadlines, and their application tracking
software automatically generates a list of households that have not
scheduled an interview. This list is used by caseworkers to send notices
to the households. Washington uses its document imaging center staff to
process case actions associated with returned mail, including quickly
correcting addresses.

Conclusions

Over the last several years and for a variety of reasons, many states have
changed their food stamp certification and recertification processes to
enable households to make fewer visits to the local assistance office.
Given our findings, it is important for states to consider the needs of
all types of households when developing alternative ways of accessing food
stamp benefits. Despite making major changes in their systems, FNS and the
states have little information on the effects of the alternative methods
on the Food Stamp Program, including what factors contribute to successful
implementation, whether these methods are improving access to benefits for
target groups, and how best to ensure program integrity. Without
up-to-date information about what methods states are using and the factors
that contribute to successful implementation of alternative methods,
states and the federal government most likely will continue to invest in
large-scale changes to their certification and recertification processes
without knowing what works and in what contexts. Although FNS is beginning
to study state efforts in this regard, these studies are not designed to
systematically evaluate whether specific methods contributed to achieving
positive outcomes. In addition, FNS has not thoroughly analyzed the data
received from states implementing waivers of the face-to-face interview to
determine, for example, whether it should allow states to use telephone
interviews in lieu of face-to-face interviews for all types of households
without a waiver. Further, while FNS is using its Website to disseminate
information about promising practices, the information available is not
up-to-date, making it difficult to easily locate current information about
specific practices. Enhancing the research, collection and dissemination
of promising practices could be an important resource for states that want
to provide households effective alternatives to visiting local assistance
offices to receive food stamp benefits.

Recommendations for Executive Action

To improve USDA's ability to assess the effectiveness of its funded
efforts, we recommend that the Secretary of Agriculture take the following
actions:

           o direct FNS and the Economic Research Service to work together to
           enhance their research agendas to include projects that would
           complement ongoing research efforts and determine the effect of
           alternative methods on program access, decision accuracy, and
           administrative costs. Such projects would reliably identify the
           alternative methods that are effective and the factors that
           contribute to their success; and

           o direct FNS to conduct analyses of data received from states
           implementing waivers or demonstration projects waiving the
           face-to-face interview and require states implementing waivers or
           demonstration projects to collect and report data that would
           facilitate such analyses. Such analyses would identify the effect
           of the waivers on outcomes such as payment accuracy and could help
           determine whether the use of the waiver should be further expanded
           or inform whether regulations should be changed to allow telephone
           interviews for all households without documenting hardship.

In addition, we recommend that the Secretary of Agriculture help states
implement alternative methods to provide access to the Food Stamp Program
by directing FNS to disseminate and regularly update information on
practices states are using to implement alternative access methods to the
traditional application and recertification process. The information would
not be merely a listing of practices attempted, but would include details
on what factors or contexts seemed to make a particular practice
successful and what factors may have reduced its effectiveness.

Agency Comments

We provided a draft of this report to the U.S. Department of Agriculture
for review and comment. We met with FNS and ERS officials on April 16,
2007, to obtain their comments. In general, the officials agreed with our
findings, conclusions, and recommendations. They discussed the complexity
and variability of state modernization efforts and the related challenges
of researching the effects of these efforts. For example, policy changes,
organizational restructuring, and the engagement of community
organizations in the application process may occur simultaneously with
implementation of alternative methods and play a significant role in state
and client experiences. Having multiple interrelated factors creates
challenges for researching the effects of modernization efforts.
Nonetheless, the officials highlighted steps the agency is taking to
monitor and evaluate state implementation of alternative access methods.
First, the officials commented that as modernization evolves, FNS is using
its administrative reporting system to consistently and routinely track
changes in state program performance in the areas of application
timeliness, food stamp participation by subgroups, payment accuracy, and
administrative costs. Second, they stated that the two related FNS-funded
studies currently underway will be comparing performance data from the
case study states with data from similar states; however, this analysis
will not determine whether certain modernization efforts caused changes in
performance. Third, they stated that FNS plans to analyze data they are
collecting from states as part of the administrative waiver process to
determine the effect of telephone interviews on payment accuracy. Finally,
ERS officials noted that Food Stamp Program access is an area in which the
agency continues to solicit research from the private sector as well as
other government agencies and that ERS makes data available to support
these research efforts. FNS and ERS also provided us with technical
comments, which we incorporated where appropriate.

We are sending copies of this report to the Secretary of Agriculture,
appropriate congressional committees, and other interested parties. We
will also make copies available to others upon request. In addition, the
report will be available at no charge on GAO's Web site at
http://www.gao.gov .

If you or your staff have any questions about this report, please contact
me at (202) 512-7215 or [email protected] . Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in appendix III.

Sincerely,

Sigurd R. Nilsen, Director
Education, Workforce, and Income Security
Issues

Appendix I: Objectives, Scope, and Methodology

To understand what alternatives states are using to improve program access
and what is known about the results of using these methods, we examined:
(1) what alternative methods to the traditional application and
recertification process are states using to increase program access; (2)
what is known about the results of these methods, particularly on program
access for target groups, decision accuracy, and administrative costs; and
(3) what actions have states taken to maintain program integrity while
implementing alternative methods.

To address these issues, we surveyed food stamp administrators in the 50
states and the District of Columbia, conducted four state site visits
(Florida, Texas, Utah, and Washington) and one set of semi-structured
telephone interviews (Pennsylvania), analyzed data provided by the Food
and Nutrition Service (FNS) and the selected states, reviewed relevant
studies, and held discussions with program stakeholders, including
officials at FNS headquarters and regional offices, and representatives of
advocacy organizations. We performed our work from September 2006 to March
2007 in accordance with generally accepted government auditing standards.

Survey of State Food Stamp Administrators

To learn about state-level use of alternative methods to help households
access the Food Stamp Program, we conducted a Web-based survey of food
stamp administrators in the 50 states and the District of Columbia. The
survey was conducted between December 2006 and February 2007 with 100
percent of state food stamp administrators responding. The survey included
questions about the use of alternative methods to provide access to the
program, including mail-in procedures, call centers, on-line services, and
other technologies that support program access. In addition, we asked
about the reasons for implementing these methods, whether states had
conducted evaluations of the methods, what measures states used to
evaluate the performance of the methods, and additional assistance needed
from FNS.

Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any survey may introduce
nonsampling errors, such as variations in how respondents interpret
questions and their willingness to offer accurate responses. We took steps
to minimize nonsampling errors, including pre-testing draft instruments
and using a Web-based administration system. Specifically, during survey
development, we pre-tested draft instruments with officials in Washington,
Arizona, Utah, and Wisconsin in October and November 2006. In the
pre-tests, we were generally interested in the clarity of the questions
and the flow and layout of the survey. For example, we wanted to ensure
definitions used in the surveys were clear and known to the respondents,
categories provided in closed-ended questions were complete and exclusive,
and the ordering of survey sections and the questions within each section
was appropriate. We also used in-depth interviewing techniques to evaluate
the answers of pretest participants, and interviewers judged that all the
respondents' answers to the questions were based on reliable information.

On the basis of the pre-tests, the Web instrument underwent some slight
revisions. A second step we took to minimize nonsampling errors was using
a Web-based survey. By allowing respondents to enter their responses
directly into an electronic instrument, this method automatically created
a record for each respondent in a data file and eliminated the need for
and the errors (and costs) associated with a manual data entry process. To
further minimize errors, programs used to analyze the survey data were
independently verified to ensure the accuracy of this work.

After the survey was closed, we made comparisons between select items from
our survey data and other national-level data.^1 We found our survey data
were reasonably consistent with the other data set. On the basis of our
comparisons, we believe our survey data are sufficient for the purposes of
our work.

State Site Visits and Structured Interviews

We conducted four site visits (Florida, Texas, Utah, and Washington) and
one set of semi-structured telephone interviews (Pennsylvania). We
selected states that have at least one FNS-approved waiver of the
face-to-face interview requirement and reflect some variation in state
participation rates. We also considered recommendations from FNS
officials, advocacy group representatives, or researchers. We made
in-depth reviews for each state we selected. We interviewed state
officials administering and developing policy for the Food Stamp Program,
local officials in the assistance offices and call centers where services
are provided, and representatives from community-based organizations that
provide food assistance.

^1 We compared our Web-based survey data to data reported by FNS in the
2006 State Options Report.

Reviews of FNS Data and Relevant Studies

To supplement the information gathered through our site visits and
in-depth reviews, we analyzed data provided by FNS for the states we
reviewed. These analyses allowed us to include state trends for specific
measures (Program Access Index, monthly participation, payment accuracy,
administrative costs, and reasons for benefit denials) in our interviews
with officials. To review the reasons for benefit denials, we used FNS's
quality control (QC) system data of negative cases used in error rate
calculations. Specifically, we looked at the number and percentage of
cases denied, terminated, or suspended by the recorded reason for the
action in the five states we reviewed for fiscal years 2000 through 2005.
Though our data allowed us to examine patterns in these areas before and
after a method was implemented, we did not intend to make any statements
about the effectiveness of methods implemented in the states we visited
and reviewed. Instead, we were interested in gaining some insight through
our interviews on how alternative methods may have affected state trends.
Based on discussions with and documentation obtained from FNS officials,
and interviews with FNS staff during site visits, we determined that these
data are sufficiently reliable for our limited review of state trends.

In addition, we selected and reviewed several studies and reports that
relate to the use of alternative methods to increase food stamp program
access. These studies included food stamp participation outcome
evaluations that were funded by FNS and the Economic Research Service
(ERS) and focused on practices aimed to improve access to the Food Stamp
Program. To identify the selected studies, we conducted library and
Internet searches for research published on food stamp program access
since 1990, interviewed agency officials to identify completed and ongoing
studies on program access, and reviewed bibliographies that focused on
program access concerns. For each selected study, we determined whether
the study's findings were generally reliable. Two GAO social science
analysts evaluated the methodological soundness of the studies, and the
validity of the results and conclusions that were drawn.

The studies we selected and reviewed include:

           o U.S. Department of Agriculture, Economic Research Service, Food
           Stamp Program Access Study: Final Report, by Bartlett, S., N.
           Burstein, and W. Hamilton, Abt Associates Inc. (Washington, D.C.:
           November 2004).

           o U.S. Department of Agriculture, Economic Research Service,
           Evaluation of the USDA Elderly Nutrition Demonstrations, by Cody,
           S. and J. Ohls, Mathematica Policy Research, Inc. (Washington,
           D.C.: May 2005).

           o U.S. Department of Agriculture, Food and Nutrition Services,
           Office of Analysis, Nutrition and Evaluation, Evaluation of Food
           Stamp Research Grants to Improve Access Through New Technology and
           Partnerships, by Sheila Zedlewski, David Wittenburg, Carolyn
           O'Brien, Robin Koralek, Sandra Nelson, and Gretchen Rowe.
           (Alexandria, Va.: September 2005).

           o U.S. Department of Agriculture, Food and Consumer Service,
           Evaluation of SSI/FSP Joint Processing Alternatives Demonstration,
           by Carol Boussy, Russell H. Jackson, and Nancy Wemmerus.
           (Alexandria, Va: January 2000.

           o Combined Application Project Evaluations submitted to FNS by
           seven states: Florida, Massachusetts, Mississippi, North Carolina,
           South Carolina, Texas, and Washington.

Appendix II: State-by-State Use of Alternative Methods and Waivers of the
Face-to-Face Interview

Appendix III: GAO Contact and Acknowledgments

GAO Contact

Sigurd R. Nilsen (202) 512-7215 [email protected]

Acknowledgments

Heather McCallum Hahn, Assistant Director, Cathy Roark, Analyst-in-Charge,
Kevin Jackson, Alison Martin, Daniel Schwimer, Gretchen Snoey, Rachael
Valliere and Jill Yost made significant contributions to this report.

Related GAO Products 

Food Stamp Program: FNS Could Improve Guidance and Monitoring to Help
Ensure Appropriate Use of Noncash Categorical Eligibility. [34]GAO-07-465
. Washington, D.C.: March 28, 2007.

Food Stamp Program: Payment Errors and Trafficking Have Declined despite
Increased Program Participation. [35]GAO-07-422T . January 31, 2007.

Food Stamp Trafficking: FNS Could Enhance Program Integrity by Better
Targeting Stores Likely to Traffic and Increasing Penalties. [36]GAO-07-53
. Washington, D.C.: October 13, 2006.

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National Improper Payment Estimates on Federal Programs. [37]GAO-06-347 .
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Food Stamp Program: States Have Made Progress Reducing Payment Errors, and
Further Challenges Remain. [38]GAO-05-245 . Washington, D.C.: May 5, 2005.

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. Washington, D.C.: March 5, 2004.

Financial Management: Coordinated Approach Needed to Address the
Government's Improper Payments Problems. [41]GAO-02-749 . Washington,
D.C.: August 9, 2002.

Food Stamp Program: States' Use of Options and Waivers to Improve Program
Administration and Promote Access. [42]GAO-02-409 . Washington, D.C.:
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Executive Guide: Strategies to Manage Improper Payments: Learning from
Public and Private Sector Organizations. [43]GAO-02-69G . Washington,
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Food Stamp Program: States Seek to Reduce Payment Errors and Program
Complexity. [44]GAO-01-272 . Washington D.C.: January 19, 2001.

Food Stamp Program: Better Use of Electronic Data Could Result in
Disqualifying More Recipients Who Traffic Benefits. [45]GAO/RCED-00-61 .
Washington D.C.: March 7, 2000.

Food Assistance: Reducing the Trafficking of Food Stamp Benefits.
[46]GAO/T-RCED-00-250 . Washington D.C.: July 19, 2000.

Food Stamp Program: Information on Trafficking Food Stamp Benefits.
[47]GAO/RCED-98-77 . Washington D.C.: March 26, 1998.

(130601)

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www.gao.gov/cgi-bin/getrpt?GAO-07-573 .

To view the full product, including the scope
and methodology, click on the link above.

For more information, contact Sigurd Nilsen at (202) 512-7215 or
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Highlights of [55]GAO-07-573 , a report to the Chairman, Committee on
Agriculture, Nutrition, and Forestry, U.S. Senate

May 2007

FOOD STAMP PROGRAM

Use of Alternative Methods to Apply for and Maintain Benefits Could Be
Enhanced by Additional Evaluation and Information on Promising Practices

One in 12 Americans participates in the federal Food Stamp Program,
administered by the Food and Nutrition Service (FNS). States have begun
offering individuals alternatives to visiting the local assistance office
to apply for and maintain benefits, such as mail-in procedures, call
centers, and on-line services. GAO was asked to examine: (1) what
alternative methods states are using to increase program access; (2) what
is known about the results of these methods, particularly on program
access for target groups, decision accuracy, and administrative costs; and
(3) what actions states have taken to maintain program integrity while
implementing alternative methods. GAO surveyed state food stamp
administrators, reviewed five states in depth, analyzed FNS data and
reports, and interviewed program officials and stakeholders.

[56]What GAO Recommends

GAO recommends that the Secretary of Agriculture direct FNS to (1) work
with the Economic Research Service (ERS) to enhance their research agendas
to include projects that would determine the effects of alternative
methods; (2) conduct analyses of data received from states implementing
waivers or demonstration projects waiving the face-to-face interview; and

(3) disseminate and regularly update information on promising practices
states are using to implement alternative methods. FNS and ERS generally
agreed with GAO's findings, conclusions, and recommendations.

All states use mail and about half of states use or have begun developing
on-line services and call centers to provide access to the food stamp
program. Almost all states allow households to submit applications, report
changes, and submit recertifications through the mail, and 26 states have
implemented or are developing systems for households to perform these
tasks on-line. Almost half of the states are using or developing call
centers and states also are allowing households to participate in
telephone interviews instead of an in-office interview. States have taken
a variety of actions to help households use on-line services and call
centers, such as sending informational mailings, holding community
meetings, and using community partners.

Insufficient information is available to determine the results of using
alternative methods. Few evaluations have been conducted identifying the
effect of alternative methods on program access, decision accuracy, or
administrative costs. Evaluating the effectiveness of alternative methods
is challenging in part because limited data are available, states are
using a combination of methods, and studies can be costly to conduct.
Federal and state officials reported that while they believe alternative
methods can help households in several ways, such as increasing
flexibility and efficiency in the application process, certain types of
households may have difficulty using or accessing alternative methods. In
addition, technology and staffing challenges may hinder the use of
alternative methods.

To maintain program integrity while implementing alternative methods, the
states GAO reviewed used a variety of strategies, such as using software
to verify the information households submit, communicating with other
states to detect fraud, or using finger imaging. Although there has been
some concern that without frequent in-person interaction with caseworkers,
households may not submit required documents on time and thus be denied
benefits on procedural grounds ("procedural denials"), GAO's limited
analysis of FNS data found no considerable fluctuations in the rate of
procedural denials in the five states between fiscal years 2000 and 2005.
The states GAO reviewed have instituted several approaches to prevent
procedural denials.

Call Center Caseworker Answering Calls

References

Visible links
  30. http://www.gao.gov/cgi-bin/getrpt?GAO/RCED/AIMD-99-231
  34. http://www.gao.gov/cgi-bin/getrpt?GAO-07-465
  35. http://www.gao.gov/cgi-bin/getrpt?GAO-07-422T
  36. http://www.gao.gov/cgi-bin/getrpt?GAO-07-53
  37. http://www.gao.gov/cgi-bin/getrpt?GAO-06-347
  38. http://www.gao.gov/cgi-bin/getrpt?GAO-05-245
  39. http://www.gao.gov/cgi-bin/getrpt?GAO-04-916
  40. http://www.gao.gov/cgi-bin/getrpt?GAO-04-346
  41. http://www.gao.gov/cgi-bin/getrpt?GAO-02-749
  42. http://www.gao.gov/cgi-bin/getrpt?GAO-02-409
  43. http://www.gao.gov/cgi-bin/getrpt?GAO-02-69G
  44. http://www.gao.gov/cgi-bin/getrpt?GAO-01-272
  45. http://www.gao.gov/cgi-bin/getrpt?GAO/RCED-00-61
  46. http://www.gao.gov/cgi-bin/getrpt?GAO/T-RCED-00-250
  47. http://www.gao.gov/cgi-bin/getrpt?GAO/RCED-98-77
  55. http://www.gao.gov/cgi-bin/getrpt?GAO-07-573
*** End of document. ***