Food Stamp Program: How States Are Using Federal Waivers of the Work
Requirement (Letter Report, 10/20/1999, GAO/RCED-00-5).

Pursuant to a congressional request, GAO provided information on the
Food Stamp Program, focusing on: (1) the measures used by the Department
of Agriculture (USDA) to assess states' requests for waivers to the work
requirement for able-bodied adults without dependents; (2) how states
have used the waiver provision; and (3) whether USDA and states
considered the availability of employment in adjacent areas when
deciding which areas to include in a waiver.

GAO noted that: (1) USDA uses federal and state data to assess
employment conditions when reviewing states' requests to waive the
requirement that able-bodied adults without dependents work in order to
remain eligible for food stamps; (2) consistent with welfare reform law,
states must show that the areas where the individuals live have
unemployment rates above 10 percent or do not have sufficient numbers of
jobs to provide employment for these individuals; (3) USDA has generally
granted waivers if the states' requests were supported by data from the
Department of Labor showing that areas either had unemployment rates
above 10 percent or were designated as labor surplus areas, meaning that
the numbers of jobs there were not sufficient; (4) USDA has provided
states with guidance for other measures of employment conditions and has
accepted data from states showing, among other things, worsening
employment-to-population ratios or meager job growth to demonstrate that
areas do not have sufficient numbers of jobs; (5) as of June 1999, 38
states and the District of Columbia had USDA waivers in place, whereas
12 states had chosen not to seek them; (6) the 13 states GAO reviewed in
detail differed in their waiver policies as well; (7) of the 10 states
reviewed that implemented waivers, 8 had sought waivers for all eligible
areas, while 2 had sought waivers for only some eligible areas; (8)
California determined that in most areas that might qualify for waivers,
enough options existed for food stamp recipients to meet the work
requirement; (9) hence, the state sought a waiver only for two
agricultural areas that had suffered economically disastrous freezes;
(10) the three remaining states GAO reviewed had decided not to seek
waivers; (11) officials in those states said that all able-bodied adults
without dependents should meet the work requirement and that if they
fail to do so, their food stamp benefits should be terminated; (12) USDA
does not consider the availability of employment in adjacent areas when
assessing states' waiver requests because the law does not require it to
do so; (13) of the 10 states GAO reviewed that have implemented waivers,
9 did not consider employment options in adjoining areas; (14) the
exception was California, where local officials decided not to seek
waivers for Indian reservations with severe unemployment if jobs were
available in nearby towns; and (15) California officials said that
employment in adjacent areas would generally not be a viable option,
mainly because of transportation difficulties.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-5
     TITLE:  Food Stamp Program: How States Are Using Federal Waivers
	     of the Work Requirement
      DATE:  10/20/1999
   SUBJECT:  Food relief programs
	     Disadvantaged persons
	     Eligibility determinations
	     Eligibility criteria
	     Labor surplus areas
	     Waivers
	     State-administered programs
	     Federal/state relations
	     Workfare
	     Unemployment rates
IDENTIFIER:  Food Stamp Program

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Cover
================================================================ COVER

Report to the Chairman, Committee on the Budget, House of
Representatives

October 1999

FOOD STAMP PROGRAM - HOW STATES
ARE USING FEDERAL WAIVERS OF THE
WORK REQUIREMENT

GAO/RCED-00-5

Work Requirement Waivers

(150128)

Abbreviations
=============================================================== ABBREV

  USDA - U.S.  Department of Agriculture

Letter
=============================================================== LETTER

B-283514

October 20, 1999

The Honorable John R.  Kasich
Chairman, Committee on the Budget
House of Representatives

Dear Mr.  Chairman: 

The Welfare Reform Act limits able-bodied adults between the ages of
18 and 50 who have no dependents to 3 months' participation in the
Food Stamp Program in a 3-year period, unless they meet a work
requirement or are exempted from that requirement.  States may
directly exempt up to 15 percent of their able-bodied adults without
dependents from the work requirement.  In addition, states may
request waivers from the Department of Agriculture (USDA) for
able-bodied adults without dependents who live in areas with
insufficient jobs.  In September 1998, we surveyed state food stamp
officials to determine, among other things, the number of able-bodied
adults without dependents who were receiving food stamp benefits, the
number required to meet the work requirement, and the number who were
exempted from the requirement.  Together, in the 42 states that
responded to our survey, 514,000 able-bodied adults without
dependents were receiving food stamps.  As we reported to you in
December 1998, about 58 percent of those able-bodied adults were
required to work, about 2 percent were covered by state exemptions,
and about 40 percent were covered by USDA waivers.\1

As you requested, this report provides information on (1) the
measures used by USDA to assess states' requests for waivers to the
work requirement for able-bodied adults without dependents, (2) how
states have used the waiver provision, and (3) whether USDA and
states considered the availability of employment in adjacent areas
when deciding which areas to include in a waiver.  In addition to
analyzing USDA data covering all 50 states for this study, we also
reviewed 13 states in more detail--10 that have implemented waivers
and 3 that have notto better understand states' decisions about
seeking waivers.\2

--------------------
\1 Food Stamp Program:  Information on Employment and Training
Activities (GAO/RCED-99-40, Dec.  14, 1998). 

\2 The 13 states we reviewed, which together had about 65 percent of
able-bodied adults without dependents who were on food stamps,
included 10 states--California, Florida, Georgia, Illinois, Kentucky,
Louisiana, New York, Pennsylvania, Texas, and West Virginia--that
have implemented waivers and 3 states--Michigan, Ohio, and
Wisconsin--that have not implemented waivers. 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

USDA uses federal and state data to assess employment conditions when
reviewing states' requests to waive the requirement that able-bodied
adults without dependents work in order to remain eligible for food
stamps.  Consistent with welfare reform law, states must show that
the areas where the individuals live (1) have unemployment rates
above 10 percent or (2) do not have sufficient numbers of jobs to
provide employment for these individuals.  USDA has generally granted
waivers if the states' requests were supported by data from the
Department of Labor showing that areas either had unemployment rates
above 10 percent or were designated as labor surplus areas, meaning
that the numbers of jobs there were not sufficient.  USDA has
provided states with guidance for other measures of employment
conditions and has accepted data from states showing, among other
things, worsening employment-to-population ratios or meager job
growth to demonstrate that areas do not have sufficient numbers of
jobs. 

States vary in their use of USDA waivers.  As of June 1999, 38 states
and the District of Columbia had USDA waivers in place, whereas 12
states had chosen not to seek them.  The 13 states we reviewed in
detail differed in their waiver policies as well.  For instance, of
the 10 states we reviewed that have implemented waivers, 8 had sought
waivers for all eligible areas, while 2 had sought waivers for only
some eligible areas.  California, for example, determined that in
most areas that might qualify for waivers, enough options existed for
food stamp recipients to meet the work requirement.  Hence, the state
sought a waiver only for two agricultural areas that had suffered
economically disastrous freezes.  The three remaining states we
reviewed had decided not to seek waivers.  Officials in those states
said that all able-bodied adults without dependents should meet the
work requirement and that if they fail to do so, their food stamp
benefits should be terminated. 

USDA does not consider the availability of employment in adjacent
areas when assessing states' waiver requests because the law does not
require it to do so.  Moreover, of the 10 states we reviewed that
have implemented waivers, 9 did not consider employment options in
adjoining areas.  The exception was California, where local officials
decided not to seek waivers for Indian reservations with severe
unemployment if jobs were available in nearby towns.  But California
officials, like those in USDA and the other states, said that
employment in adjacent areas would generally not be a viable option,
mainly because of transportation difficulties.  These officials
questioned how far individuals should have to travel to seek
employment and how individuals who typically work for low wages could
afford transportation to distant jobs. 

   BACKGROUND
------------------------------------------------------------ Letter :2

The Food Stamp Program is an entitlement program that helps
low-income individuals and families obtain a more nutritious diet by
supplementing their income with food stamp benefits.  The Personal
Responsibility and Work Opportunity Reconciliation Act of 1996,
commonly referred to as the Welfare Reform Act, retained the Food
Stamp Program as an entitlement program for participants who meet
household income and asset qualifications.  However, it tightened
eligibility standards for food stamps by establishing the work
requirement for able-bodied adults without dependents and by
disqualifying most permanent resident aliens from participation. 
USDA's Food and Nutrition Service and the states jointly implement
the Food Stamp Program; the states administer the program. 

The Welfare Reform Act requires able-bodied adults between the ages
of 18 and 50 who have no dependents to meet a work requirement, or
have an exemption from that requirement, if they are to continue to
be eligible for food stamps for more than 3 months in a 3-year
period.\3 To meet the work requirement, these individuals must (1)
work a minimum of 80 hours a month, (2) participate in a qualifying
state employment and training program for 20 hours a week, or (3) do
public service through a state Workfare program, which is a program
that provides work in a public service capacity in exchange for
public benefits, such as food stamps.  Two kinds of exemptions may be
granted for this requirement.  Under welfare reform, at the request
of a state agency, USDA may waive the work requirement after making a
determination that the area in which the individuals reside has an
unemployment rate above 10 percent or does not have a sufficient
number of jobs to provide employment for the individuals.  In
addition, under the Balanced Budget Act of 1997, the states may
exempt up to 15 percent of their able-bodied adults without
dependents from the work requirement, using state-determined
criteria. 

--------------------
\3 The provisions of this legislation apply to the 50 states, the
District of Columbia, Guam, and the Virgin Islands. 

   USDA USES FEDERAL AND STATE
   DATA TO ASSESS WAIVER REQUESTS
------------------------------------------------------------ Letter :3

USDA's Food and Nutrition Service has developed fairly
straightforward guidance to the states for requesting waivers of the
work requirement.  While the guidance does not specifically define
the geographic areas that may be considered for waivers, it directs
the states to consider areas within, or combinations of, counties,
cities, or towns as well as rural areas and Indian reservations
that best reflect the labor market prospects of program participants
and State administrative needs. Waivers may be granted for a maximum
of 1 year and may be renewed annually for areas where the employment
conditions continue to qualify. 

      INFORMATION USED TO EVALUATE
      WAIVERS BASED ON
      UNEMPLOYMENT ABOVE 10
      PERCENT
---------------------------------------------------------- Letter :3.1

Under the Food and Nutrition Service's guidance, waivers will be
granted for any requested area in which the average unemployment rate
in the preceding 12 months was greater than 10 percent, using the
Bureau of Labor Statistics' standard data or methods.  The Bureau
releases unemployment estimates monthly for all counties, cities of
25,000 or more, all cities and towns in New England, and all
metropolitan and small labor market areas.  These data, which are
produced by state employment security agencies using Bureau-developed
concepts, definitions, and technical specifications, are also used to
determine eligibility for benefits in other federal programs,
including job training under the Job Training Partnership Act and
assistance under the Emergency Food and Shelter Program.  The Bureau
screens and tests these data for consistency.  The data released by
the Bureau for June 1999 included 35 states that had areas with
unemployment estimates above 10 percent. 

For areas for which unemployment estimates are not routinely
developed, the Food and Nutrition Service's guidance allows states to
generate estimated unemployment rates using the Bureau of Labor
Statistics' standard methods and formulas.  State-generated data on
employment trends and unemployment covering a short period may also
be used to support waiver requests for areas where rising
unemployment is expected to exceed 10 percent and where predictable
seasonal unemployment has historically risen above 10 percent. 
Alaska, for example, has requested and received seasonal waivers
using data that show seasonal unemployment rates above 10 percent. 

      INFORMATION USED TO EVALUATE
      WAIVERS BASED ON AN
      INSUFFICIENT NUMBER OF JOBS
---------------------------------------------------------- Letter :3.2

According to the Food and Nutrition Service's guidance, the law
provides for waivers based on an insufficient number of jobs because
the Congress recognized that the unemployment rate alone is an
imperfect measure of the employment prospects of individuals with
little work history and diminished opportunities. Noting that no
standard data or methods exist to determine the sufficiency of jobs
in an area, the guidance offers examples of the types and sources of
data that the states may useand that the Food and Nutrition Service
will consider--to demonstrate that an area has an insufficient number
of jobs. 

The following are some of the types and sources of data cited in the
guidance as potentially useful for identifying areas for which states
may seek waivers based on an insufficient number of jobs: 

  -- Designation as a "labor surplus area"--The Department of Labor
     classifies an area as a labor surplus area if its average
     unemployment rate was at least 20 percent higher than the
     average unemployment rate for all states during the previous 2
     years.\4 For instance, the national average unemployment rate
     for the 2-year period from January 1996 through December 1997
     was 5.3 percent.  Thus, to qualify as a labor surplus area for
     fiscal year 1999, an area needed an unemployment rate of at
     least 6.4 percent.  All but two states, Delaware and New
     Hampshire, had areas that qualified as labor surplus areas for
     fiscal 1999.  USDA has approved all waivers requested for
     designated labor surplus areas. 

  -- Areas in states that qualify for extended unemployment insurance
     benefits--The Department of Labor determines whether a state can
     qualify for extended unemployment insurance benefits for its
     residents.  The Food and Nutrition Service's guidance recognizes
     this as a potentially useful indicator of insufficient jobs. 
     However, only Alaska currently meets Labor's criteria for
     extending unemployment insurance benefits, and Alaska has not
     used this measure to support a waiver request.  According to
     Food and Nutrition Service officials, the fact that only one
     state qualifies for extended benefits is a reflection of the
     strong condition of the economy; however, more states would
     qualify for extended unemployment insurance benefits in an
     economic downturn. 

  -- Areas with lagging job growth--The Food and Nutrition Service's
     guidance recognizes that job seekers may have a harder time
     finding work in an area where job growth lags behind population
     growth.  The ratio for lagging job growth is computed using
     employment and population estimates for an area.  However, the
     guidance points out that the Census estimates for the
     populations of counties and cities are released only
     periodically and may not be current.  According to the Food and
     Nutrition Service, a few states have used this indicator in
     conjunction with other data to show that an area has
     insufficient jobs. 

  -- Areas with declining occupations or industries--The Food and
     Nutrition Service's guidance recognizes that where employment
     markets are dominated by declining industries, large numbers of
     people may have skills that are no longer in demand.  According
     to the guidance, the impact could be particularly significant in
     smaller rural areas where the loss of a single employer could
     have an immediate effect on job prospects and unemployment
     rates.  The guidance cites several options for measuring this
     decline, such as the Bureau of Labor Statistics' monthly data on
     state and local employment by major industry, state welfare and
     employment security agencies' data on occupation and employment
     changes, and increased filings for unemployment insurance. 
     According to the Food and Nutrition Service, a few states have
     used this indicator with other data to show insufficient jobs;
     it has also been used alone for a few rural areas that lost
     major employers. 

Noting that decisions to approve waivers because of insufficient jobs
will be made on a case-by-case basis, the guidance alerts the states
to provide sufficient data to support an assertion that an area lacks
jobs.  It further states that the thoroughness of the data that a
state presents will have a bearing on whether a waiver request is
approved. 

--------------------
\4 The average unemployment rate for all states includes data for the
District of Columbia and Puerto Rico, but not Guam and the Virgin
Islands. 

   WAIVER POLICY DIFFERS AMONG
   STATES
------------------------------------------------------------ Letter :4

States vary in the extent to which they have sought and used USDA
waivers.  As of June 1999, 38 states and the District of Columbia had
USDA-granted waivers in place.  All these jurisdictions had received
waivers for one or more areas on the basis of insufficient jobs; 21
states also had sought and received waivers for one or more areas on
the basis of unemployment rates above 10 percent.  The Food and
Nutrition Service estimates that just over 206,000 able-bodied adults
without dependents live in these waived areas and receive food
stamps.  At the same time, however, 12 states, together with Guam and
the Virgin Islands, have chosen not to seek USDA waivers of the work
requirements for their able-bodied adults without dependents. 
According to the Food and Nutrition Service, the states that have
chosen not to seek waivers would likely qualify to receive them. 
Indeed, 10 of the 12 states have areas with unemployment rates above
10 percent or have designated labor surplus areas--circumstances for
which USDA has routinely approved waiver requests from other
statesand the other 2 have areas for which other data may
demonstrate that sufficient numbers of jobs do not exist. 

Appendix I provides information on states' use of USDA waivers as of
June 1999.  For states that sought and received waivers, the appendix
includes the basis on which USDA granted the waivers (whether
unemployment above 10 percent or insufficient numbers of jobs) and
the number and types of areas covered by the waivers. 

To obtain a better understanding of states' decisions about seeking
USDA waivers, we contacted 13 states.  As shown in table 1, 10 of
these states have implemented waivers and 3 states have not. 

                                Table 1
                
                   States We Reviewed Regarding Their
                     Decisions to Seek USDA Waivers

State (rank among all states in number
of able-bodied adults)\a                  Use waivers
----------------------------------------  ----------------------------
California (1)                            Yes-some eligible areas

Florida (7)                               Yes-all eligible areas

Georgia (11)                              Yes-all eligible areas

Illinois (3)                              Yes-all eligible areas

Kentucky (5)                              Yes-all eligible areas

Louisiana (8)                             Yes-all eligible areas

Michigan (9)                              No

New York (2)                              Yes-all eligible areas

Ohio (22)                                 No

Pennsylvania (4)                          Yes-all eligible areas

Texas (6)                                 Yes-some eligible areas

West Virginia (10)                        Yes-all eligible areas

Wisconsin (17)                            No
----------------------------------------------------------------------
\a Rank is based on data for a 3-month periodApril, May, and June
1998reported to GAO by 42 states.  See Food Stamp Program: 
Information on Employment and Training Activities (GAO/RCED-99-40,
Dec.  14, 1998). 

Source:  GAO's analysis. 

Officials from eight of these states (Florida, Georgia, Illinois,
Kentucky, Louisiana, New York, Pennsylvania, and West Virginia)
sought waivers for all areas that had unemployment rates above 10
percent and all areas that they could demonstrate did not have
sufficient numbers of jobs.  Most also told us that they would
continue to seek waivers for all areas that might qualify because,
among other things, it would not be equitable to waive the work
requirement for able-bodied adults without dependents in one area but
not for such individuals in another area that had the same employment
characteristics.  Some states told us they sought waivers from the
work requirement because their states' agencies did not have the
resources to offer job training or Workfare to individuals who were
geographically scattered. 

Eight states (Florida, Georgia, Illinois, Kentucky, Louisiana, New
York, Pennsylvania, and Texas) also raised concerns about the
administrative burdens on their agencies for such tasks as overseeing
compliance with the work requirements, tracking individuals' job
status, and operating work support programs, such as Workfare. 
Officials in Illinois, Louisiana, and New York, for example, pointed
out that they are spending an inordinate amount of time on paperwork
for the relatively small numbers of able-bodied adults without
dependents who participate in their food stamp programs.  In
addition, officials in Louisiana and Pennsylvania voiced concern that
many individuals regarded as able-bodied had medical problems that
limited their ability to meet the work requirement.  However, under
the Welfare Reform Act, individuals certified as physically or
mentally unfit for employment are not considered able-bodied.  The
Food and Nutrition Service is planning to propose regulations in
December 1999 for determining what constitutes physically or
mentally unfit. Until then, the states will have no consistent basis
for making that determination. 

Two of the states we reviewedCalifornia and Texastold us they
sought waivers only for a few of the areas in their jurisdictions
that could qualify.  California sought a 6-month waiverwhich expired
July 31, 1999--for two primarily agricultural counties that had
suffered massive unemployment following economically disastrous
freezes.  Officials in California told us that sufficient employment
training and Workfare programs existed in areas that might qualify
for waivers for able-bodied adults without dependents there to
fulfill the work requirement.  California currently has no areas
covered by waivers. 

Texas officials told us that the state's policy is to seek waivers
only for those counties with unemployment rates above 10 percent. 
Texas has 254 counties, of which 19 are covered by waivers.  The
unemployment rate in 1 of the 19 counties dropped below 10 percent
after Texas applied for its most recent waiver.  The Food and
Nutrition Service granted a waiver for that county based on its
designation as a labor surplus area; Texas decided to implement the
waiver because the county's unemployment rate was still very high and
it had been covered by a waiver during each of the previous 2 years. 
Texas officials told us they believe that Workfare and employment and
training programs are disincentives to looking for jobs.  According
to the officials, these programs allow able-bodied adults without
dependents to receive benefits instead of securing jobs. 

Finally, officials in Michigan, Ohio, and Wisconsin--states that have
chosen not to seek USDA waivers of the work requirementtold us that
all able-bodied adults without dependents should be able to meet the
work requirement and that if they fail to do so, their food stamp
benefits should be terminated.  Michigan has a number of mechanisms
in place to help able-bodied adults find work; for example, if the
state cannot place an individual in a job within 3 months, it
guarantees him or her a position with a public service or community
service organization, which will fulfill the work requirement.  Ohio
had initially sought a waiver, and in early 1997 was granted a waiver
for 20 counties and 12 cities; however, the state decided not to
implement the waiver.  According to an Ohio official, the state
requires low-income individuals with dependents who participate in
another assistance program to work in order to receive benefits from
that program, so it would not be fair to waive the work requirement
for able-bodied adults without dependents who participate in the Food
Stamp Program.  In Wisconsin, officials believe a waiver may be a
good option in areas with high unemployment but that it is not needed
at this point.  Only 27 able-bodied adults without dependents reside
in the state's labor surplus areas (seven counties and one city);
none reside in the one county with an unemployment rate above 10
percent.  According to Wisconsin officials, the state has an
extensive, well-funded program operating in every county that
provides numerous and widely available opportunities to fulfill the
work participation requirement. 

   USDA AND MOST STATES CONTACTED
   DID NOT CONSIDER THE
   AVAILABILITY OF EMPLOYMENT IN
   ADJOINING AREAS
------------------------------------------------------------ Letter :5

USDA officials said that they did not consider the availability of
employment in adjoining counties or jurisdictionsor require states
to do sowhen reviewing waiver requests, primarily because the law
does not require them to do so.  Of the 10 states we reviewed that
have USDA waivers, only California had considered the availability of
employment in surrounding areas in deciding whether to seek a waiver. 
California officials told us that local officials had considered
seeking a waiver for Indian reservations that had severe
unemployment.  However, when the local officials considered the
availability of employment in nearby towns, they decided that a
waiver would not be needed for the reservations.  The California
officials agreed with USDA and other state officials who expressed
the view that employment in adjacent areas would not be a viable
option in most instances.  The concerns they raised focused on the
transportation difficulties this would pose for the individuals
required to work and on the administrative burden that it would place
on state agencies. 

With regard to transportation difficulties, USDA and state officials
questioned how far individuals should have to travel to seek
employment and how individuals who typically work for low wages would
be able to afford transportation to distant jobs.  In rural areas,
able-bodied adults without dependents who rely on food stamps do not
usually have access to public transportation or even have relatives
who could provide transportation to jobs.  In both Kentucky and West
Virginia, for example, most of the counties covered by waivers are in
rural areas where mass transit is unavailable.  In some locations,
the expense of getting to a job would not be covered by the paycheck
the individual would receive.  In many instances, state officials
told us that areas with high unemployment are adjacent to other areas
with high unemployment.  In Louisiana, for example, so many parishes
have high unemployment that finding jobs in adjoining areas is not
likely; individuals would have to travel across several parishes to
get to an area where jobs may be available.  This is true as well in
Kentucky, Texas, and West Virginia, where the counties covered by
waivers are concentrated in a particular section of each state. 

Even in urban areas, where public transportation is available, there
may be limitations that could make it difficult to hold a job in a
distant location.  As we reported to you in May 1998, the majority of
the entry-level jobs that the poor would be likely to fill are
located in suburbs that have limited or no accessibility through
existing public transportation systems.\5

In Pennsylvania, for example, many low-paying, low-skilled jobs are
in retail or fast food businesses, which often require employees to
work late at night.  According to Pennsylvania officials, workers
would have to provide their own transportation for these jobs because
reliable public transportation often ends earlier in the evening.  In
addition, they said that job growth tends to be in the suburbs and
that, in many places, there is no transportation to the suburbs from
the inner city.  A recent report by the Department of Housing and
Urban Development observed that public transit is frequently not
designed to carry city residents to suburban jobs.\6 The report cited
a study on entry-level job openings that found that, in Boston, a
1-hour transit commute would reach only 14 percent of jobs in the
region's fast-growth areas and, in the Atlanta area, less than half
the entry-level jobs were within a quarter mile of a public transit
route. 

Some states are providing transportation so that able-bodied adults
without dependents can travel to distant jobs.  Three adjacent
Florida counties, for example, have established a transportation
system that uses county-owned vans to pick up individuals at
designated stops and drop them off at places of employment anywhere
within the tri-county area.  Pennsylvania encourages individuals to
seek employment wherever necessary and will pay relocation expenses
to help with these efforts.  In addition, the District of Columbia,
which has a waiver for all its able-bodied adults without dependents,
provides free farecards for public transportation to individuals who
live in the District but are able to secure employment in Virginia or
Maryland.  The District also helps these individuals find jobs in the
adjacent areas. 

State officials also said that state agencies would face
administrative problems if the states had to consider the
availability of employment in adjacent areas when deciding whether to
seek waivers.  USDA's guidance acknowledges that, because the county
is the usual administrative unit for states' food stamp programs, it
may not be feasible for states to assess recipients' employment
prospects in geographical areas that cross county or state lines. 
Officials said that determining whether an applicant has fulfilled a
requirement to seek work in another jurisdiction could be a
nightmare; state agencies may have no administrative structure with
which to monitor efforts to seek or hold jobs across county or state
lines.  Finally, officials in several states told us they believe
they are already spending a disproportionate amount of administrative
effort on assisting and overseeing the relatively small portion of
the food stamp population that is made up of able-bodied adults
without dependents. 

--------------------
\5 Welfare Reform:  Transportation's Role in Moving From Welfare to
Work (GAO/RCED-98-161, May 29, 1998). 

\6 The State of the Cities 1999, U.S.  Department of Housing and
Urban Development, June 1999. 

   AGENCY COMMENTS
------------------------------------------------------------ Letter :6

We provided USDA and the Department of Labor with a draft of this
report for their review and comment.  USDA responded that the report
gave an accurate and evenhanded picture of the process USDA uses to
waive the work requirement for able-bodied adults without dependents. 
USDA also suggested several technical clarifications that we
incorporated as appropriate.  The Department of Labor had no
comments.  We also provided officials in the District of Columbia and
the states we reviewed with excerpts that were attributed to them and
incorporated their clarifications as appropriate. 

   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

To obtain information on the measures USDA uses to determine whether
to approve states' requests for waivers to the work requirement, we
reviewed the appropriate statutes and USDA's guidance, spoke with
officials from USDA's Food and Nutrition Service, and reviewed 43
waiver applications.  We reviewed documents from the Bureau of Labor
Statistics and the Employment and Training Administration to
determine their methodology for gathering, compiling, and reporting
the unemployment data used by USDA. 

To determine how states have used the waiver provision, we assessed
USDA's data on participation in the waiver program and summary
information on waiver requests; we discussed the data with USDA's
Food and Nutrition Service officials.  Information in this report on
the basis for states' decisions about whether and to what extent to
use waivers is based in part on our analysis of the waiver practices
and experiences in 13 states.  We selected the 10 states--California,
Florida, Georgia, Illinois, Kentucky, Louisiana, New York,
Pennsylvania, Texas, and West Virginiawith the largest populations
of able-bodied adults without dependents that had USDA waivers, as
identified in our December 14, 1998, report, Food Stamp Program: 
Information on Employment and Training Activities (GAO/RCED-99-40). 
We also selected three states--Michigan, Ohio, and Wisconsin--that
had substantial populations of food stamp recipients who are
able-bodied individuals but that had not implemented waivers.  The
December report analyzed data from our survey of states covering
April, May, and June 1998.  The 13 states together have about 65
percent of the able-bodied adults without dependents that the Food
and Nutrition Service estimates currently participate in the Food
Stamp Program. 

To determine whether USDA and the states have considered the
availability of employment in adjacent jurisdictions, we reviewed
USDA's Food and Nutrition Service's guidance and discussed the
guidance and waiver review procedures with Food and Nutrition Service
officials.  We also questioned officials in the 10 states we
consulted that had requested and implemented waivers. 

We performed our work in accordance with generally accepted
government auditing standards from February 1999 through September
1999. 

---------------------------------------------------------- Letter :7.1

Copies of this report will be sent to the Honorable Richard Lugar,
Chairman, and the Honorable Tom Harkin, Ranking Minority Member,
Senate Committee on Agriculture, Nutrition, and Forestry; the
Honorable Larry Combest, Chairman, and the Honorable Charles
Stenholm, Ranking Minority Member, House Committee on Agriculture;
other appropriate congressional committees; the Honorable Dan
Glickman, Secretary of Agriculture; the Honorable Alexis M.  Herman,
Secretary of Labor; the Honorable Jacob Lew, Director, Office of
Management and Budget; and other interested parties.  We will also
make copies available to others upon request. 

If you or your staff have any questions about the information in this
report, please contact me or Erin Lansburgh at (202) 512-5138.  Key
contributors to this report were Abiud Amaro, Natalie Herzog, and
Stuart Ryba. 

Sincerely yours,

Lawrence J.  Dyckman
Director, Food and Agriculture Issues

INFORMATION ON STATES' USE OF USDA
WAIVERS OF WORK REQUIREMENT FOR
ABLE-BODIED ADULTS WITHOUT
DEPENDENTS, AS OF JUNE 1999
=========================================================== Appendix I

                                     Basis for waiver
                               ----------------------------
                                                   Insuffic
                     Waiver    Unemployment over   ient
States               status    10 percent          jobs      Areas included in waiver
-------------------  --------  ------------------  --------  ----------------------------
Alabama              Yes       x                   x         25 counties

Alaska               Yes       x                   x         21 census tracts (14
                                                             seasonal)

Arizona              Yes       x                   x         10 counties, 1 partial
                                                             county, 3 Indian
                                                             reservations

Arkansas             Yes                           x         33 counties, 1 city

California           Yes       x                             2 counties

Colorado             Yes                           x         7 counties, 2 Indian
                                                             reservations

Connecticut          Yes                           x         21 cities and towns

Delaware             No

District of          Yes       x                   x         Entire District
Columbia

Florida              Yes       x                   x         21 counties, 1 city

Georgia              Yes                           x         53 counties, 5 cities

Guam                 No

Hawaii               Yes       x                   x         3 islands

Idaho                Yes       x                   x         5 Indian reservations

Illinois             Yes                           x         36 counties, 21 cities, 227
                                                             small municipalities

Indiana              Yes                           x         3 counties, 2 cities

Iowa                 No

Kansas               No

Kentucky             Yes                           x         64 counties, 2 cities, 1
                                                             partial county

Louisiana            Yes                           x         41 parishes, 5 cities

Maine                Yes                           x         6 counties, 1 local
                                                             metropolitan area, 1 Indian
                                                             reservation, 9 cities

Maryland             Yes       x                   x         8 counties, 2 cities

Massachusetts        No

Michigan             No

Minnesota            Yes       x                   x         20 counties, 9 Indian
                                                             reservations

Mississippi          No

Missouri             Yes                           x         28 counties, 1 city

Montana              Yes       x                   x         13 counties, 7 Indian
                                                             reservations

Nebraska             Yes                           x         3 Indian reservations

Nevada               Yes       x                   x         6 counties, 2 cities, 16
                                                             Indian reservations/
                                                             colonies

New Hampshire        No

New Jersey           Yes       x                   x         1 county, 2 partial
                                                             counties, 35 municipalities

New Mexico           Yes       x                   x         15 counties, 1 city, 22
                                                             Indian reservations

New York             Yes       x                   x         23 counties, 1 partial
                                                             county, 12 cities

North Carolina       No

North Dakota         Yes                           x         3 counties

Ohio                 No

Oklahoma             No

Oregon               No

Pennsylvania         Yes                           x         33 counties, 6 cities

Rhode Island         Yes                           x         4 cities and towns

South Carolina       Yes       x                   x         22 counties, 2 cities

South Dakota         Yes       x                   x         7 counties, 7 Indian
                                                             reservations

Tennessee            Yes       x                   x         54 counties

Texas                Yes       x                   x         19 counties

Utah                 Yes                           x         5 counties

Vermont              Yes                           x         2 counties

Virginia             Yes                           x         19 counties, 3 cities

Virgin Islands       No

Washington           Yes       x                   x         27 counties, 3 cities, 26
                                                             Indian reservations

West Virginia        Yes       x                   x         38 counties

Wisconsin            No

Wyoming              Yes                           x         1 Indian reservation
-----------------------------------------------------------------------------------------
Source:  GAO's analysis of the Food and Nutrition Service's data. 

*** End of document. ***