Food Stamp Program: Households Collect Benefits for Persons Disqualified
for Intentional Program Violations (Letter Report, 07/08/1999,
GAO/RCED-99-180).
Congress has expressed a strong desire in recent years to reduce fraud,
waste, and abuse in the Food Stamp Program. Earlier GAO reports found
that millions of dollars in food stamp overpayments in four states were
caused by counting thousands of inmates and deceased individuals as
household members and thousands of individuals as members of recipient
households in more than one state during the same period. (See
GAO/RCED-97-54, Mar. 1997, GAO/RCED-98-53, Feb. 1998, and
GAO/RCED-98-228, Aug. 1998.) This report discusses individuals who were
disqualified from the program for intentionally violating the program's
rules but were included as household members during their
disqualification period. GAO found that more than 3,000 disqualified
individuals in the four states it reviewed were improperly counted as
members in households that received food stamp benefits during 1997.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-180
TITLE: Food Stamp Program: Households Collect Benefits for
Persons Disqualified for Intentional Program Violations
DATE: 07/08/1999
SUBJECT: Fraud
Federal/state relations
Program abuses
Food relief programs
State-administered programs
Internal controls
Overpayments
Data bases
Data integrity
IDENTIFIER: Food Stamp Program
HHS Temporary Assistance for Needy Families Program
FNS Disqualified Recipient Subsystem
FNS Voice Response System
FNS Online Query Subsystem
California
Illinois
Louisiana
Texas
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United States General Accounting Office GAO Report
to the Chairman, Subcommittee on Department Operations, Oversight,
Nutrition, and Forestry, Committee on Agriculture, House of
Representatives July 1999 FOOD STAMP PROGRAM Households
Collect Benefits for Persons Disqualified for Intentional Program
Violations GAO/RCED-99-180 GAO United States General Accounting
Office Washington, D.C. 20548 Resources, Community, and Economic
Development Division B-282612 July 8, 1999 The Honorable Bob
Goodlatte Chairman, Subcommittee on Department Operations,
Oversight, Nutrition and Forestry Committee on Agriculture House
of Representatives Dear Mr. Chairman: During numerous hearings
over the last several years, the Congress has expressed its strong
desire to reduce the level of fraud, waste, and abuse in the Food
Stamp Program, which is administered by the U.S. Department of
Agriculture (USDA). In 1997 and 1998, we reported that millions of
dollars in food stamp overpayments in four states were caused by
counting thousands of inmates and deceased individuals as
household members and by counting thousands of individuals as
members of recipient households in more than one state during the
same period.1 In these reports, we identified several actions,
including the use of automated information, to reduce the level of
ineligible participation. In response to your request, this report
focuses on individuals who were disqualified from the program for
intentionally violating the program's rules but were included as
household members during their disqualification period, a problem
referred to as disqualified participation. Individuals are
disqualified from participation in the program when it is
determined that they have committed an intentional program
violation.2 Specifically, we (1) determined for calendar year 1997
how many individuals were included as members of food stamp
households in four states while disqualified from the program and
estimated the value of the benefits that were improperly issued to
those households and (2) determined why these individuals were
improperly included in 1Food Stamps: Substantial Overpayments
Result From Prisoners Counted as Household Members (GAO/RCED-97-
54, Mar. 10, 1997), Food Stamp Overpayments: Thousands of Deceased
Individuals Are Being Counted as Household Members (GAO/RCED-98-
53, Feb. 11, 1998), and Food Stamp Overpayments: Households in
Different States Collect Benefits for the Same Individuals
(GAO/RCED-98-228, Aug. 6, 1998). 27 C.F.R. ch. II, part 273.16 (c)
specifies that a determination of intentional program violation
can be made when an individual is found to have intentionally (1)
made a false or misleading statement or misrepresented, concealed,
or withheld facts or (2) committed any act that constitutes a
violation of the Food Stamp Act, the Food Stamp Program's
regulations, or any state statute relating to the use,
presentation, transfer, acquisition, receipt, or possession of
food stamp coupons or authorization to participate cards. The four
procedures for determining intentional program violations are
discussed in more detail in appendix II. Page 1
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612
households and what actions USDA and state agencies could take to
detect and prevent disqualified participation. To identify
disqualified participation, we conducted a computer match
comparing the calendar year 1997 food stamp rolls of four states
(California, Illinois, Louisiana, and Texas) with information on
disqualified individuals contained in USDA's Disqualified
Recipient Subsystem.3 These four states accounted for about 28
percent of the nation's participants in the Food Stamp Program and
were responsible for 19 percent of all active disqualifications
nationwide in 1997.4 (See app. I.) To ensure the accuracy of our
analyses, we used only those matches that (1) met the most
reliable and stringent criteria used by the Social Security
Administration to verify Social Security numbers and (2)
identified individuals who were included in households that were
issued food stamp benefits for the same month(s) that they were
disqualified from participation. Results in Brief Over 3,000
disqualified individuals in the four states we reviewed were
improperly counted as members in households that received food
stamp benefits during calendar year 1997. While we cannot estimate
the potential amount of overpayments received nationwide for
individuals who participated while disqualified, the households in
the four states we reviewed improperly collected about $500,000 in
food stamp benefits. The $500,000 in overpayments, while small in
relation to the $5.6 billion in food stamps distributed to 6.4
million individuals in these four states, undermine USDA's
accomplishments and ongoing efforts to ensure the program's
integrity. About 70 percent of the disqualified participation we
identified was attributable to weaknesses in state processes for
the timely removal of individuals from the food stamp rolls after
they have been disqualified. About 30 percent of the disqualified
participation that we identified occurred because the states did
not check USDA's national database of disqualified individuals to
determine if household members had been disqualified by another
state or because of delays in updating information in the
database. Furthermore, USDA's database is incomplete and contains
errors; therefore, even if state agencies check the database, they
may not 3USDA's Disqualified Recipient Subsystem compiles
nationwide disqualification information collected from the state
agencies that administer the Food Stamp Program. 4Because
California does not maintain statewide participation information,
we used state eligibility information in our match. For
California, we determined that eligibility for the program is
representative of actual participation, as described in appendix
III. Page 2 GAO/RCED-99-180
Disqualified Food Stamp Participants B-282612 receive full and
accurate disqualification information. We could not estimate,
however, the amount of additional disqualified participation
attributable to this problem. USDA could help the states reduce
disqualified participation by sharing best practices for imposing
disqualifications promptly and requiring states to check its
national database of disqualification information for applicants.
This report includes a number of recommendations to the Secretary
of Agriculture designed to reduce disqualified participation.
Background The Food Stamp Program is designed to promote the
general welfare and to safeguard the health and well-being of the
nation's population by raising the nutritional levels of low-
income families. Recipients use their food stamp benefits to
purchase allowable food products from authorized retail food
merchants. USDA's Food and Nutrition Service (FNS) manages the
Food Stamp Program through agreements with state agencies. FNS
approves the states' plans to operate the program and ensures that
states administer the program in accordance with regulations. The
federal government pays all of the costs for benefits and one-half
of the administrative costs for each state. In fiscal year 1997,
USDA provided about 23 million participants with over $19.5
billion in benefits and paid the states, U.S. territories, and the
District of Columbia about $1.7 billion to administer the program.
Food stamps are issued to households, which can comprise an
individual, a family, or any group that lives together and
customarily purchases and prepares food in common. Households
applying for benefits must provide information about each
household member, including Social Security numbers. The value of
the food stamp benefits for a household depends on the number of
eligible household members and their income as adjusted for assets
and such costs as those for shelter and utilities. Therefore, a
household's monthly food stamp allotment increases with each
additional member, provided that income limits are not exceeded.
The national average monthly food stamp benefit for individuals
was $71.27 in 1997. Eligibility workers in service centers work
directly with applicants or their representatives to certify
households' eligibility and determine the amount of benefits at
the time of the application and at least annually thereafter.
Generally, the service centers maintain the clients' detailed case
records, while the computerized eligibility and benefit issuance
data are maintained at the state or local level. State agencies in
Illinois, Louisiana, and Texas maintain both types of data, but in
California, the state agency maintains Page 3
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612 the
information on eligibility, while the counties maintain the
information on benefit issuance. Each state is required to
establish a performance-reporting system to monitor its food stamp
program, including a quality control review process to help ensure
that benefits are issued only to qualifying households and that
the amounts of these benefits are correct. Each state is required
to investigate any case of alleged intentional program violation
and ensure action if allegations are verified. Federal regulations
specify that individuals found to have committed an intentional
program violation shall be ineligible to participate in the
program for a specified period.5 States have several procedural
options for determining whether individuals have committed
intentional program violations, and the extent to which each
procedure is used can vary widely from state to state. (See app.
II.) State agencies are responsible for imposing penalties and for
recovering any food stamp overpayments associated with the
intentional program violations. The disqualification of an
individual by one state is valid in all states. Disqualified
In the four states we reviewed, over 3,000 disqualified
individuals were Participation Weakens improperly included as
members of food stamp households in calendar year 1997. These
households received about $500,000 in food stamp the Program's
overpayments during the year. Among these individuals were 40
Integrity disqualified participants who had
been permanently disqualified from the program. While our review
was limited to identifying disqualified participation in four
states, we believe it is likely that such participation also
occurs in other states. Table 1 summarizes the number of
disqualified participants that we identified in the four states we
reviewed. 57 C.F.R. ch. II, part 273.16. In addition, the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996
doubled the disqualification period for intentional program
violations from 6 months to 1 year for the first violation, and
from 1 year to 2 years for the second violation. The penalty for
the third violation remained the same-permanent disqualification.
Disqualification penalties can differ in specific cases, such as
transactions involving food stamp benefits and drugs or firearms,
and may also be specified by the court for cases that are
prosecuted. Page 4 GAO/RCED-99-
180 Disqualified Food Stamp Participants B-282612 Table 1: Extent
of Disqualified Participation, Calendar Year 1997 Dollars in
thousands Number of Total months of disqualified
disqualified Estimated States examined
participants participation overpayments
California 2,042
4,839 $340 Illinois
505 1,157 88
Louisiana 198
504 37 Texas
421 873 63 Total
3,166 7,373 $529 Sources:
For California, the California Department of Public Social
Services; for Illinois, the Illinois Department of Human Services;
for Louisiana, the Louisiana Office of Family Support, Department
of Social Services; and for Texas, the Texas Department of Health
Services. Overall, about 81 percent of the disqualified
participants that we identified were members of food stamp
households in the state that had imposed the disqualification, and
about 19 percent had been disqualified by a different state.
However, in some states and in one county, higher proportions of
the disqualified participants had been disqualified by a different
state. For example, in Texas, 209 out of 421, or 50 percent, of
the disqualified participants we identified had been disqualified
by some other state, yet they accounted for about 59 percent of
the estimated overpayments because they had participated for a
somewhat longer period of time. In Louisiana, about 34 percent of
the disqualified participants had been disqualified by a different
state, and in California, 38 percent of the disqualified
participants in Los Angeles County had been disqualified by
another state. While we focused our analysis on disqualified
participation in the Food Stamp Program, such participation may be
indicative of similar problems in other public assistance programs
administered by the states. In our review of sample case files in
three of the four states we visited, we found that some
individuals who were disqualified from the Food Stamp Program were
also disqualified at the same time, for the same offense, from the
Temporary Assistance for Needy Families (TANF) program. While our
match did not include other programs, we believe that if
individuals were able to obtain food stamp benefits while
disqualified, they may have obtained the other benefits as well.
Although the total estimated dollar value of benefit overpayments
associated with the disqualified participation for the four states
we reviewed was not large compared with the total amount of food
stamp Page 5 GAO/RCED-99-180
Disqualified Food Stamp Participants B-282612 benefits issued,
such participation undermines the program's integrity. The
importance of the program's integrity was highlighted in the April
23, 1998, testimony of USDA's Food and Nutrition Service
Administrator.6 The Administrator stated that "A crucial part of
the President's and Secretary's commitment to delivering nutrition
assistance to needy Americans is ensuring that the integrity of
the Food Stamp Program is protected from those who would abuse the
program. It is our nation's most important nutrition program, and
we make protecting its integrity our highest priority." In her
testimony, the Administrator cited the increase of 12 percent in
recipients' disqualifications for fraud-from more than 94,000 in
1996 to almost 106,000 in 1997. The positive impact of such
efforts is undermined when some of these same individuals who were
disqualified for fraudulent activities in the program are allowed
to participate in the program during their disqualification
period. Improved State Weaknesses in states' processes
for imposing disqualifications were Processes and Use of
responsible for about 70 percent of the disqualified participation
that we identified, which permitted disqualified individuals to
continue receiving Complete and benefits during part or
all of their disqualification period. Certain Accurate National
practices, such as the centralization of responsibility for all
aspects of imposing a disqualification, including the removal of
the individual from Information Would the food stamp rolls,
can help reduce disqualified participation. States' Help Prevent
failure to check USDA's national database to determine if
household Disqualified members had been disqualified by
another state or delays in updating disqualification information
accounted for about 30 percent of the Participation
disqualified participation that we identified. A routine check by
states of USDA's database to determine the disqualification status
of household members, as well as quicker access to updated
disqualification information, would go further to detect and
prevent disqualified participation. In addition, USDA and the
states do not effectively oversee and control the submission of
disqualification information to the database. Although we
identified and validated the participation of disqualified
individuals using information in the database, the database is
incomplete and contains errors; therefore, even if state agencies
check the database, they may not receive full and accurate
disqualification information. 6Testimony of Yvette S. Jackson,
Administrator, Food and Nutrition Service, U.S. Department of
Agriculture, Before the Senate Committee on Agriculture, Nutrition
and Forestry (Apr. 23, 1998). Page 6
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612
State Processes for In the four states we reviewed,
weaknesses in the different processes that Imposing
Disqualifications they used to implement disqualifications and
remove individuals from the Allow Some Disqualified food
stamp rolls allowed some disqualified individuals to participate.
We Participation to Occur found that certain state
practices and procedures seem more effective than others in
detecting and preventing such ineligible participants and that the
states we visited have taken or are planning actions to address
the problems we identified. Individuals are disqualified from
participation in the program when it is determined that they have
committed an intentional program violation (IPV). Federal
regulations require that a disqualified individual be notified of
the disqualification and that the disqualification begin either at
the beginning of the month following written notification or, if
the IPV was determined by a court, on the date specified by the
court or within 45 days of the court decision if no date was
specified. State processes for removing disqualified individuals
from the food stamp rolls differed. Texas has a single Central
Disqualification Unit for the entire state that (1) receives
notice that an individual has been determined to have committed an
IPV, (2) sends notification of disqualification to the individual
and the eligibility worker, and (3) imposes the disqualification
by removing the individual from the food stamp rolls. The unit
also enters the disqualification information into Texas' statewide
computerized eligibility information system. During the
disqualification period, local-level eligibility workers cannot
change the eligibility status of disqualified individuals; only
the central unit staff can make such changes. If a local
eligibility worker attempts to access the record of the
disqualified individual on the automated system, the
disqualification information appears on screen and the system
rejects attempts to restore eligibility. On the basis of our
analysis, disqualified individuals are less likely to continue
participating under such a centralized system; Texas had a lower
percentage of in-state disqualified participants (i.e.,
participants disqualified by Texas but continuing to participate)
than the other states in our review. According to state officials,
participation by individuals disqualified by Texas occurred
primarily because the central unit received late notification of
an IPV from hearing officers, the courts, or out-of-state
decisions, resulting in the issuance of benefits in the first
month of disqualification. As a result of our findings, Texas has
implemented a policy giving priority to imposing disqualifications
on individuals who are Page 7 GAO/RCED-99-
180 Disqualified Food Stamp Participants B-282612 participating in
active cases, thus preventing overpayments to the household.7 Like
Texas, Louisiana has a central unit that is responsible for
imposing disqualifications; however, the unit does not actually
remove individuals from the food stamp rolls. The unit sends
electronic messages through Louisiana's statewide computerized
eligibility information system to local eligibility workers,
notifying them that an individual has been disqualified and that
they must remove the individual from the food stamp rolls. The
central unit also enters the disqualification information into the
system; therefore, if a local worker attempts to access the record
of the disqualified individual, the information appears on screen.
However, the system does not ensure that the eligibility worker
will act on the disqualification information or prevent the worker
from later restoring eligibility for the disqualified individual.
According to state officials, the central unit does not actually
remove disqualified individuals from the rolls because the
coincidental input of changes to a case record from two different
locations in a day, while unlikely, could cause a problem in the
case record. A state official stated that participation by
individuals disqualified by Louisiana primarily occurred because
local eligibility workers did not take prompt action, or never
took action, on the disqualification information that they were
provided. Such delays and oversights can occur for a variety of
reasons, such as the worker's temporary absence for leave,
training, or excessive workload. To address these problems,
Louisiana officials told us that they required staff in each of
the state's parish offices to evaluate processes for imposing
disqualifications, and they plan to implement various practices,
such as increasing supervisory review of eligibility workers'
disqualification actions. In Illinois, a central unit is notified
of IPV determinations and is responsible for entering the
information into a disqualification database on the statewide
computerized eligibility information system. The central unit
sends paper notices of IPV determinations to local eligibility
workers, who are responsible for notifying the individuals of
their disqualification and removing them from the food stamp
rolls. The state conducts a monthly match between its database of
Illinois disqualifications and its food stamp rolls to identify
disqualifications that have not been imposed or disqualified
individuals who reapply. We found little disqualification
documentation in our review of case files, so it was generally not
possible 7A federal appeals court recently decided that the
imposition of food stamp disqualification penalties cannot be
postponed, for example, even if the individual is not currently
participating in the program. Garcia v. Concannon, 67F.3D 256
(1995). Page 8 GAO/RCED-99-180
Disqualified Food Stamp Participants B-282612 to ascertain if the
responsible eligibility worker had received notice of the
disqualification or what action had been taken. However, in some
case files, we found notices reminding eligibility workers to
disqualify participants who had been identified in the monthly
computer match of disqualified individuals and participants. State
officials said that participation by individuals who had been
disqualified by Illinois primarily occurred because local
eligibility workers did not take prompt action. To address this
problem, state officials said that they are considering the
complete centralization of their disqualification process by
making a single state-level unit responsible for all aspects of
imposing disqualifications. In California, responsibility for
disqualifying individuals is delegated to individual counties, and
the state agency is notified of a disqualification only after it
is imposed, so that the information can be reported to USDA. Like
all California counties, Orange County and Los Angeles County,
operate independently of each other, with their own procedures and
separate computerized information systems, but they impose
disqualifications similarly. In each, the county fraud unit
participates in the IPV process and notifies the eligibility
worker responsible for the active case to send a disqualification
notice and to remove the individual from the food stamp rolls. In
these counties, our review of case file records and discussions
with officials indicated that eligibility workers did not impose
disqualifications on time for a variety of reasons, such as
getting notification of a disqualification after the specified
start date, and that local workers sometimes reinstated the
disqualified individual to eligibility before the end of the
disqualification period. According to an Orange County official,
the agency has taken action to address these issues by, for
example, altering its computerized eligibility system to inhibit
workers from restoring eligibility before the end of the
disqualification period. Disqualified Participation About 30
percent of the disqualified participation we identified in four
Also Occurs Because states was attributable to states'
not checking USDA's Disqualified States Do Not Check
Recipient Subsystem (DRS) to determine the disqualification status
of USDA's Database applicants or to delays in
obtaining updated DRS disqualification data. While states are not
required to check the DRS to determine the disqualification status
of applicants, states are mandated to check the DRS to determine
the proper length of the disqualification penalty. However, some
states are not meeting this requirement. The DRS is a national
database of currently and previously disqualified food stamp
recipients. It contains identification information on disqualified
Page 9 GAO/RCED-99-180 Disqualified Food
Stamp Participants B-282612 individuals, including their name,
Social Security number, and date of birth, along with
disqualification information, such as the decision and start dates
of disqualification, the length of penalty, previous
disqualifications, and the state that imposed the
disqualification. States are required to provide monthly updates
of new disqualifications, changes to prior data submitted, and
deletions to the DRS. After the DRS is updated on the 25th of each
month, the updated information is made available to states. States
can either receive disqualification information files directly
from the USDA computer or obtain tapes through the mail. The
disqualification information files are available to states in
three formats: a file of the most recent update, a file of all
currently active disqualifications, or a file of the entire DRS
database. States can use these files to update or maintain a copy
of the DRS on their own computerized information systems or to
match them against their food stamp rolls. Most states do not
routinely check the DRS database to determine the disqualification
status of applicants or household members, but they are not
required to do so. According to FNS' records, of the 50 states and
2 U.S. territories participating in the program, along with the
District of Columbia, 34 are provided with a file of DRS
disqualification information monthly. While FNS' records do not
indicate how the states use that information, FNS regional office
officials told us that just 22 states routinely check the DRS
disqualification data for new applicants. Among the four states we
visited, California was the only state that used the DRS
disqualification information to screen food stamp applicants in
1997. Our analysis indicates that California's percentage of out-
of-state disqualified participants was lower than that of any of
the other states in our review. Instead of collecting statewide
disqualification information and making it available to
eligibility workers through a computerized system, as the other
states we visited do, California maintains a copy of the entire
DRS database that is updated monthly. The DRS database is compared
with the applicant information submitted by counties for the
nightly computerized state income and eligibility verification
process. Disqualified applicants are reported to the responsible
county eligibility workers, who are then responsible for denying
eligibility. According to state officials, the use of the DRS
helps prevent participation by individuals disqualified in other
states, but the lag in updating the DRS data can allow some
disqualified participants to apply and participate before the data
are available on California's system. A state official estimated
that it takes between 30 and 60 days from the date when an IPV
determination is made by a county until the information is
available on the state's copy of the DRS Page 10
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612
database. This is reflected in our findings in Los Angeles County,
where 43 percent of the disqualified participants that we
identified had been disqualified in a different county. Despite
the applicant check process, which uses the DRS data, disqualified
participants were subsequently able to participate in Los Angeles
County during their disqualification period for various reasons,
including the delay in getting updated information into the
database. The other three states in our review did not use the DRS
database information for various reasons. Texas officials said
that their automated system checks applicants against the state's
own disqualification database and that it is not productive to
also check the DRS. However, we found that 209 out of 421 matches,
or 50 percent of the disqualified participants we identified in
Texas, were individuals who had been disqualified by different
states. Many of these ineligible individuals could have been
prevented from participating or could have been identified earlier
if Texas had checked the national DRS. Illinois officials told us
they did not have the technical capability to use the DRS when it
was first made available and, instead, used their own database of
Illinois' disqualified individuals for applicant checks. However,
the officials stated that they intend to begin checking the DRS in
the future. Louisiana officials stated that they did not have the
computer resources to use the DRS data until early 1998, when the
state began a monthly match of its food stamp rolls with the DRS
file of current disqualifications. In the 12 months between March
1998 and February 1999, they identified and removed from their
food stamp rolls 107 disqualified participants from other states.
FNS agreed to require states to check the DRS for applicants and
recipients more than 3 years ago in response to the USDA Inspector
General's recommendations. The Inspector General, reporting on its
review of the implementation of the DRS, recommended that FNS
develop procedures that require all state agencies to compare
their databases with the national database and use the results to
determine applicants' eligibility or whether current participants
were disqualified elsewhere. Concurring, FNS stated that a
regulation to require applicant or case load matches was currently
being drafted. FNS estimated that the proposed rule would be
published in the Federal Register in November 1996. FNS officials
stated that the regulation has not been published because of other
regulatory priorities within the Food Stamp Program. FNS now plans
to publish the proposed rule by July 1, 2000. Page 11
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612
While not required to check the DRS for the disqualification
status of applicants or household members, states are required to
use the DRS when determining the length of disqualification
penalty for an IPV. As noted earlier in this report, the length of
the penalty is based on the number of prior violations. To assist
the states in meeting the requirement, FNS established telephonic
access to the DRS through a Voice Response Unit. The unit allows
state workers to directly access the DRS database and, by entering
a Social Security number, determine if an individual has any prior
violations, thus determining the length of penalty for a new
violation. However, the Voice Response Unit is relatively slow, is
not designed to process a large amount of calls, and is not
appropriate for application or recertification checks. Some state
and county agencies are not complying with FNS' regulation that
requires them to use the DRS to determine the length of the
disqualification penalty for an IPV. We found that in California,
Los Angeles and Orange counties do not use the Voice Response
Unit, nor do they use a microfiche of the DRS that the state
provides them with quarterly, to identify prior violations when
determining disqualification penalty periods. Instead, they check
their own disqualification databases and determine the penalty
length on the basis of the number of prior disqualifications
within the county. Similarly, Illinois determines the length of
penalty by consulting its own database of state disqualifications
rather than checking the DRS. According to FNS officials, New
Jersey, Rhode Island, and the territory of Guam also do not check
the DRS to determine the length of the disqualification penalty.
As a result, each of these state and county agencies may not
always be assigning the proper length of penalty for the
disqualifications that they impose. To replace the aging and
inefficient Voice Response Unit, FNS is developing another method
for states to query the DRS that is capable of accommodating
routine applicant checks by states. This new system, known as the
Online Query Subsystem, will allow eligibility workers to directly
access the DRS and perform multiple queries, including checking to
determine the disqualification status of applicants or recipients,
through the Internet. According to FNS officials, the on-line
system will not require any programming or maintenance by the
states-only computers with Internet access. The officials stated
that the system will provide information more quickly than the
Voice Response Unit and allow access to updated DRS records sooner
than is available through a direct transfer of files or a tape.
FNS plans a phased implementation period, bringing several states
on-line at a time, starting in December 1999. Page 12
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612 FNS
is also studying the feasibility of a national food stamp
participation database, which could provide another way for USDA
to provide the states with information on disqualified
individuals. In 1998, we recommended that FNS conduct a study to
consider establishing a central system to help insure that
individuals participating in the Food Stamp Program are not
improperly included as a household member in more than one state
concurrently.8 FNS agreed with this recommendation, and the
Congress approved funding for a feasibility study. Public Law 105-
379, dated November 12, 1998, states that "the Secretary of
Agriculture shall conduct a study of options for the design,
development, implementation, and operation of a national database
to track participation in Federal means-tested public assistance
programs." The creation of such a database provides the
opportunity for FNS to match nationwide program participation with
disqualification information and provide the states with the
results for action. FNS has 1 year to complete the study and
report the results to the Congress. The Integrity of the DRS
Although we were able to identify and validate the participation
of Data Can Be Improved to disqualified individuals using the
DRS information, the database is Enhance Its Effectiveness
incomplete and contains errors, which could allow disqualified
individuals to participate or could result in states' imposition
of incorrect lengths for disqualification penalties. For example,
we found that the disqualification data from three states-
Michigan, Washington, and Arkansas-were not entered into the DRS
for a 6-month period between August 1, 1998, and January 31, 1999.
Michigan and Washington State officials attributed the lack of
reporting to computer problems that prevented them from submitting
information to the DRS, and an Arkansas official stated that the
state transmitted its data to the DRS monthly but did not know
whether the transmissions had been successful. An FNS official
stated that the agency is working with Arkansas State officials to
resolve the problem. Furthermore, during that same 6-month period,
states sent in large numbers of disqualification records that were
rejected as "fatal errors" by DRS data checks designed to keep
faulty information from entering the system. For example, of the
18,351 records sent by Oregon, 14,386, or 78 percent, were
rejected, while South Dakota sent 3,408 records, but only 12 were
accepted into the DRS. According to FNS officials, the number of
rejected records is large because the states resubmitted the same
erroneous records month after month without correction. FNS has no
8Food Stamp Overpayments: Households in Different States Collect
Benefits for the Same Individuals (GAO/RCED-98-228, Aug. 6, 1998).
Page 13 GAO/RCED-99-180
Disqualified Food Stamp Participants B-282612 controls to ensure
that the data are corrected and resubmitted; instead, it relies
completely on the states to correct and resubmit disqualification
data. If the states do not resubmit the data, the DRS
disqualification database is incomplete. Among the four states in
our review, California, Illinois, and Louisiana officials told us
that they take action to review DRS' error messages and resubmit
corrections; Texas does not. Finally, in many cases, state
information is not reaching the DRS within the required time
frame. States are required to submit disqualification information
so that the FNS receives it no later than 30 days after the
disqualification takes effect. Yet, of the disqualifications that
were active during any part of 1997, 41 percent, or 49,826 out of
118,921, were received more than 30 days after they took effect.
In addition to being incomplete, the DRS database also contains
errors. For example, in Texas, we compared the start dates on
disqualification documentation found in case files with the start
dates in the DRS and determined that the DRS start dates were 1
month earlier than the actual disqualification start dates. In
response to our request, officials in Texas traced the problem to
an error in the program it uses to create the disqualification
update file it sends to the DRS and plans to take corrective
action. Texas officials also found a Year 2000-related problem
involving the date-of-birth field. As a result of this problem,
Texas did not report a large number of disqualifications to the
DRS from August 1998 to January 1999. The officials told us that
this problem has been corrected and that they plan to submit the
missing data. The DRS' data checks on information submitted by
states do allow some erroneous records to be accepted into the
database with a "warning" message sent back saying that the
records contained an error or unusual circumstance. Some examples
of what triggers a warning message are invalid gender codes and
duplicate disqualification numbers (i.e., an individual has more
than one "first" disqualification). According to FNS records, a
large number of warning messages were sent to states from August
1, 1998, to January 31, 1999. Of the 119,088 records accepted into
the DRS, 83,975, or 71 percent, were accepted with a warning
message. An FNS official attributed many of these 83,975 warning
messages to certain states that submit their entire database every
month, which causes the system to detect duplicates and generate
warning messages. He stated that the newly submitted duplicate
records simply overwrite the existing records. Page 14
GAO/RCED-99-180 Disqualified Food Stamp Participants B-282612
While some of these errors would have little consequence to states
using the information to identify disqualified participants,
others, such as those involving the dates or numbers of
disqualifications, could make the information difficult to use if
not corrected. For example, our analysis of the disqualifications
in the DRS database that were active during 1997 found 5,960
individuals with two or more "first" disqualifications, 1,399
individuals with two or more "second" disqualifications, and 123
individuals with two or more "third" disqualifications. Since the
length of a new disqualification is based on the number of prior
disqualifications, such erroneous and conflicting information
could make it difficult for states to properly determine
disqualification penalties. FNS officials were unaware of many of
the data problems that we identified during our review. FNS
delegates to its regional offices responsibility for ensuring that
states comply with the DRS requirements, but regional officials we
spoke to were also generally unaware of the problems we
identified. For example, regional officials were not aware that
the three states previously mentioned had not input data to the
DRS for 6 months. FNS ultimately holds the states responsible for
ensuring that the data they submit to the DRS is complete, on
time, and accurate. Conclusions The inclusion of disqualified
individuals in households receiving food stamp benefits
compromises the integrity of the Food Stamp Program and results in
overpayments. The four states we reviewed have processes in place
to help ensure that their own disqualifications are imposed;
however, certain practices, such as centralizing disqualification
responsibilities, are more effective in ensuring that
disqualifications are implemented promptly so that overpayments do
not occur. While some states currently use national
disqualification information obtained from the DRS to ensure that
individuals disqualified by other states do not participate in
their programs, the current effort by FNS to offer
disqualification information through an on-line query system will
provide states with a quicker means to access more timely data. A
match between a national food stamp participation database,
currently under a feasibility study, and the DRS database, is
another means by which FNS could notify states of disqualified
participants. However, for the DRS data to be most useful to
states, FNS must take actions to ensure that they are complete, up
to date, and accurate. Page 15 GAO/RCED-99-
180 Disqualified Food Stamp Participants B-282612 Recommendations
to In order to ensure the integrity of the Food Stamp Program
by preventing the Secretary of disqualified participation
without imposing significant additional program costs to achieve
this goal, we recommend that the Secretary of Agriculture
Agriculture direct the Administrator of FNS to *
collect, analyze, and disseminate state agencies' "best practices"
to help ensure timely action on disqualifications; * require
states to use the national database to determine the
disqualification status of applicants, using the method that each
deems most appropriate to its circumstances; * consider, as part
of its study on the feasibility of creating a national database to
track participation in federal means-tested public assistance
programs, a process for periodically matching the disqualification
database and disseminating the resulting matches to the states;
and * take actions to ensure that states provide the DRS with
disqualification information in a consistent and timely manner,
that the data in the DRS are accurate, and that sufficient
controls are in place to ensure the accuracy of data submitted to
the database. Agency Comments We provided USDA with a copy
of this report for review and comment. FNS, in commenting on the
draft report for USDA, stated that the Service appreciated our
work and substantially agreed with our findings. In commenting on
our recommendation to collect, analyze, and disseminate state
agencies' "best practices," FNS stated that resource constraints
prohibit a formal "best practices" survey but that the Service
will share, informally through regional offices, information about
any state's DRS operations that FNS believes will be of benefit to
other states. Regarding the recommendation to require states to
use the national database to determine the disqualification status
of applicants, FNS reiterated its commitment to publishing a
proposed regulation by July 1, 2000, requiring states to use the
national disqualification database to determine the
disqualification status of applicants and/or recipients. To
address the recommendation to consider the periodic matching of
disqualification data in its study of the feasibility of a
national participation database, FNS stated that its study would
address whether it is feasible in a national database context for
states to access and share disqualification data. Finally, in
response to the recommendation to take actions to ensure that the
DRS data are timely and accurate, FNS will more closely monitor
states' data transmission reports and follow up with states Page
16 GAO/RCED-99-180 Disqualified Food Stamp
Participants B-282612 whenever data are not timely transmitted,
when the number of records transmitted appears low, or whenever a
significant number of records are rejected or accepted with
warnings. FNS' comments are provided in appendix IV. We also
provided California, Illinois, Louisiana, and Texas State
officials with excerpts from the draft report for their review and
comment. The state officials substantially agreed with our
findings and provided technical and clarifying comments that we
incorporated into the report as appropriate. We conducted our work
from August 1998 through April 1999 in accordance with generally
accepted government auditing standards. Our detailed methodology
is presented in appendix III. As agreed with your office, unless
you publicly announce its contents earlier, we plan no further
distribution of this report for 30 days. At that time, copies of
this report will be sent to the Honorable Dan Glickman, Secretary
of Agriculture; the Honorable Jacob J. Lew, Director, Office of
Management and Budget; and other interested parties. We will make
copies available to others on request. If you have any questions
about this report, please contact me at (202) 512-5138. Major
contributors to this report are listed in appendix V. Sincerely
yours, Robert E. Robertson Associate Director, Food and
Agriculture Issues Page 17 GAO/RCED-99-180
Disqualified Food Stamp Participants Contents Letter
1 Appendix I
20 Information on Food Stamp Program Participants and Benefits in
Four States Appendix II
21 Information on the Procedures and Criteria Used by States to
Determine Intentional Program Violations Appendix III
24 Objectives, Scope, and Methodology Appendix IV
28 Comments From the Food and Nutrition Service, U.S. Department
of Agriculture Page 18 GAO/RCED-99-180 Disqualified Food
Stamp Participants Contents Appendix V
31 GAO Contacts and Staff Acknowledgments Tables
Table 1: Extent of Disqualified Participation, Calendar Year 1997
5 Table I.1: The Food Stamp Program's Participants, Benefits, and
20 Average Monthly Benefit per Participant by State, Fiscal Year
1997 Table I.2: Number and Percentage of Active Disqualifications
by 20 State, Calendar Year 1997 Table II.1:
Number of States Using Each Determination
22 Procedure, Fiscal Year 1997 Table II.2: Percentage of
Determinations by Procedure for Four 22 States,
Fiscal Year 1997 Abbreviations DRS Disqualified Recipient
Subsystem FNS Food and Nutrition Service GAO
General Accounting Office IPV intentional program
violation TANF Temporary Assistance for Needy Families
USDA U.S. Department of Agriculture Page 19
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix I
Information on Food Stamp Program Participants and Benefits in
Four States In fiscal year 1997, California, Illinois, Louisiana,
and Texas accounted for about 28 percent of Food Stamp Program
participants nationwide and 29 percent of benefits issued, as
shown in table I.1. Table I.1: The Food Stamp Program's
Participants, Benefits, and Average Costs and participants in
millions Monthly Benefit per Participant by
Average monthly State, Fiscal Year 1997
Food stamp benefit per State
State participants benefits participant
California 2.8
$2,372 $70.21 Illinois
1.0 933 76.28 Louisiana
0.6 512 74.18 Texas
2.0 1,765 72.30 Total
6.4 $5,582 Program total
22.9 $19,548 $71.27 Source: U.S.
Department of Agriculture's Food and Nutrition Service. These four
states accounted for approximately 19 percent of all the
disqualifications that were in effect during any part of calendar
year 1997, as shown in table I.2. Table I.2: Number and Percentage
of Active Disqualifications by State,
Number of active Percentage of total active Calendar Year 1997
State disqualifications
disqualifications California
8,318 7 Illinois
2,548 2 Louisiana
3,295 3 Texas
8,152 7 Total
22,313 19 Program total
118,921 100 Source: U.S. Department
of Agriculture's Food and Nutrition Service. Page 20
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix II
Information on the Procedures and Criteria Used by States to
Determine Intentional Program Violations Food stamp regulations
require that a state agency pursue administrative disqualification
or referral for prosecution when it has sufficient documentary
evidence to substantiate that a participant has intentionally
violated the program's regulations. Intentional program violations
include (1) making a false or misleading statement or
misrepresenting, concealing, or withholding facts and (2)
disobeying the Food Stamp Act, Program Regulations, or any state
statute relating to the use, presentation, transfer, acquisistion,
receipt, or possession of food stamp coupons or authorization-to-
participate cards. Food stamp regulations specify four procedures
that states may use to determine intentional program violations. *
Administrative disqualification hearings, which provide
individuals suspected of an intentional program violation the
opportunity to present evidence to a hearing officer, who then
renders a ruling as to whether an intentional program violation
was committed. * Waived hearings, which allow individuals to waive
their right to an administrative disqualification hearing and
accept the disqualification penalty. * Court referrals, which
allow the state to refer appropriate cases for prosecution by a
federal or state court and impose a disqualification penalty if
the individual is found guilty of an intentional program
violation.1 * Deferred adjudication, through which, states can
allow accused individuals to sign disqualification consent
agreements to avoid prosecution and accept the disqualification
penalty. States are required to establish a system for conducting
administrative disqualification hearings. However, FNS may exempt
a state from this requirement if the state agency has already
entered into an agreement with the state's attorney general's
office or county prosecutors for the prosecution of intentional
program violation cases. Waived hearings and deferred adjudication
procedures are optional for states. During fiscal year 1997, at
least 46 of the 53 participating states used administrative
disqualification hearings, waived hearings, and court 1Food stamp
regulations require states that are exempted from conducting
administrative hearings to refer cases for prosecution in
accordance with an agreement with prosecutors or state law. The
agreement must include the understanding that prosecution will be
pursued in cases where appropriate. The agreement must include
information on how and under what circumstances cases will be
accepted for possible prosecution and any other criteria set by
the prosecutor for accepting cases for prosecution, such as a
minimum amount of overissuance that resulted from the intentional
program violation. Page 21
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix II
Information on the Procedures and Criteria Used by States to
Determine Intentional Program Violations referrals; just over half
used deferred adjudication procedures.2 (See table II.1.) Most
states used three or all four procedures to disqualify individuals
from the program; a few use only one or two procedures, such as
Delaware, which relied entirely on court referrals to disqualify
individuals during fiscal year 1997. Table II.1: Number of States
Using Each Determination Procedure, Fiscal Procedure
Number of states using procedure Year 1997
Administrative disqualification hearings
47 Waived hearings
46 Court referrals
47 Deferred adjudication
28 Source: U.S. Department of Agriculture's Food and Nutrition
Service. The four states in our review-California, Illinois,
Louisiana, and Texas-differed in the procedures each used to
determine intentional program violations. (See table II.2.)
Illinois, Louisiana, and Texas used administrative
disqualification hearings or waived hearings for most of their
disqualifications, while California primarily used court referrals
or deferred adjudication. Table II.2: Percentage of Determinations
by Procedure for Four Administrative
States, Fiscal Year 1997
disqualification Waived
Deferred State hearings
hearings Court referrals adjudication California
2 0 86 12
Illinois 47 47
7 0 Louisiana 54
39 5 2 Texas
42 39 11
8 Note: Rows may not add up to 100 percent because of rounding.
Source: U.S. Department of Agriculture's Food and Nutrition
Service. Because federal regulations allow prosecutors to
establish criteria for accepting cases for prosecution in their
agreements with state agencies, we found that the criteria
differed from state to state, and even from county to county
within states. According to state agency officials, Louisiana
prosecutors accept cases if the overissuance involved is greater
than $1,000 or particularly flagrant, and Texas prosecutors accept
cases involving overissuances in excess of $1,500. According to
agency officials 2For convenience, we used the term "states" to
include the District of Columbia and the territories of Guam and
the Virgin Islands. Page 22
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix II
Information on the Procedures and Criteria Used by States to
Determine Intentional Program Violations in Illinois, the level of
overpayment required to prosecute an intentional program violation
case varies from county to county-from a low of about $3,500 to a
high of $10,000 in the Cook County (Chicago) area. Similarly,
agency officials in California told us that the Los Angeles County
prosecution threshold is $2,000, while the threshold in
neighboring Orange County is $1,000 or lower if the intentional
program violation is particularly blatant or by a repeat offender.
Page 23 GAO/RCED-99-180 Disqualified
Food Stamp Participants Appendix III Objectives, Scope, and
Methodology To determine how many individuals were included as
members of food stamp households while disqualified from the Food
Stamp Program and to estimate the value of the benefits that were
improperly issued to those households, we matched the food stamp
records of four selected states against the U.S. Department of
Agriculture's (USDA) Disqualified Recipient Subsystem (DRS)
database of individuals disqualified from the Food Stamp Program.
California, Illinois, and Texas were among the top five states in
participation and benefit issuance in fiscal year 1997; Louisiana
provides balance as a smaller state that disqualifies individuals
roughly in proportion to its participation rate. We obtained state
and USDA data as follows: * State welfare agencies in Illinois,
Louisiana, and Texas provided us with computer files containing
information on all members of households and the amount of food
stamp benefits issued to those households during calendar year
1997. The data provided personal identifiers, including name,
Social Security number, date of birth, gender, and the months in
which food stamp benefits had been issued to the household while
each individual was a member. The state agencies had verified the
Social Security numbers for the data on food stamp beneficiaries
through Social Security Administration's Enumeration Verification
System. * In California, where issuance data are maintained at the
county level, we used the state's eligibility information in lieu
of the issuance data for our match. The data provided the same
personal identifiers as provided by the other states and the
months of eligibility for each individual. On the basis of our
analysis of two counties, we determined that eligibility was
predictive of participation.1 * USDA provided us with a copy of
its DRS database, which contains information on individuals
disqualified by all states, districts, and territories. The data
provided the same personal identifiers as obtained for food stamp
beneficiaries and listed the start date and length of
disqualification in months for each individual. We matched the
verified Social Security numbers of members of food stamp
households in each state with those of individuals who were
disqualified for any period during calendar year 1997. For those
1In a match between state eligibility information and the Los
Angeles County and Orange County, California, food stamp issuance
information for calendar year 1996, we found that more than 89 and
75 percent of the eligible individuals participated, respectively.
Using Orange County's issuance information for calendar year 1997,
we found that more than 74 percent of the eligible individuals
participated. On the basis of the 1996 results and the similarity
of Orange County's 1996 and 1997 results, we believe that
eligibility is predictive of issuance. Page 24
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix III
Objectives, Scope, and Methodology disqualified individuals
identified as members of households, we determined the months in
which food stamp issuance occurred after the date of
disqualification and prior to the end of the disqualification
period. We estimated the dollar value of food stamps issued to
households with disqualified members by applying the state's
average monthly issuance per individual recipient from 1997 to
each period in which issuance occurred. Food stamp benefits are
calculated for households-not for individuals. Thus, it is
difficult to determine the exact value of benefits issued to an
individual included in a household, unless he or she is the only
member of a household. Even then, the amount will vary from
individual to individual, on the basis of such factors as income,
assets, and the cost of shelter. Therefore, we relied on the
average monthly benefit issued per person in the locations we
reviewed, which ranged from a high of $76 in Illinois to a low of
$70 in California. We realize that the actual issuance may be
higher or lower than our estimates; for example, the maximum
issuance to single-member households who are included in our
findings was $120 in fiscal year 1997. Our estimates are intended
to show the general magnitude of the problem and cannot be used to
estimate potential overpayments nationwide because our methodology
was not designed for that purpose. We considered every month of
issuance to households that included disqualified members to be an
overpayment, in keeping with food stamp regulations (7 C.F.R. ch.
II, part 273.16), which specify that disqualifications be imposed
beginning with the first month that follows the date that the
household member receives written notification of the hearing
decision. According to regulations (7 C.F.R. ch. II, part
273.13(b)(7)), there is no requirement to allow additional time
for notifying the household of an adverse action when a member is
disqualified for an intentional program violation. Because of the
quality control program operated by the Food and Nutrition Service
and the states' ongoing quality assurance efforts, we accepted
their computerized food stamp data identifying participants as
reliable. To provide additional confidence in the data's accuracy,
we reviewed a limited number of food stamp case files at social
service centers in five large metropolitan areas: Los Angeles
County and Orange County, California; Cook County, Illinois;
Orleans Parish, Louisiana; and Bexar County, Texas. We compared
the name, Social Security number, and date of birth of each
individual in the computerized food stamp rolls with information
in the relevant case files and found no significant differences.
To further verify participation in the household, we reviewed Page
25 GAO/RCED-99-180 Disqualified Food
Stamp Participants Appendix III Objectives, Scope, and Methodology
copies of available documents in the case files, such as birth
certificates, drivers' licenses, and Social Security cards. We
also verified the periods of participation by reviewing approved
applications, when available; however, many case files did not
contain complete information. The Food and Nutrition Service has
not conducted a comprehensive data assessment of the DRS because
the agency's resources were committed to implementing and
maintaining the system. Therefore, to determine the reliability of
the disqualification data relevant to our review of four states,
we reviewed a limited number of case files at the five social
service centers mentioned previously to verify the disqualified
individual's name, Social Security number, date of birth,
disqualification start date, and length of disqualification. To
supplement the case file information, we also obtained
disqualification information from various other state agency
sources, including centralized disqualification or fraud units,
and from computerized state records. We found no significant
differences, with the exception of DRS start dates for Texas
disqualifications, which were off by 1 month because of a computer
programming error by the state agency. To determine why
disqualified individuals were improperly included in households
and identify actions that USDA and state agencies can take to
detect and prevent disqualified participation, we contacted state
agency officials in Sacramento, California; Springfield, Illinois;
Baton Rouge, Louisiana; and Austin, Texas, to discuss and review
policy and procedures for disqualifying individuals and removing
them from the food stamp rolls. We discussed the process for
verifying applicants' data, as well as methods of fraud detection,
computerized data-matching, and quality control and assurance,
with state officials. In the five large metropolitan areas that we
selected for review, we discussed local processes for ensuring
that disqualified individuals are removed from the food stamp
rolls. We discussed with state and local officials ways that their
processes could be changed and improved to better detect and
prevent disqualified participation. To determine how USDA can help
states detect and prevent disqualified participation, we contacted
USDA officials to determine what disqualification information is
available to states, how that information is made available to
states, and what states are receiving the information. To address
data integrity issues that we identified during our review, we
analyzed a computerized copy of the DRS database and other
documentation that USDA provided us with to determine the
timeliness, accuracy, and completeness of the data and discussed
our findings with Page 26 GAO/RCED-
99-180 Disqualified Food Stamp Participants Appendix III
Objectives, Scope, and Methodology USDA. We discussed with USDA
officials the methods for ensuring that reliable disqualification
data are readily available to states and that disqualified
individuals do not participate in the program. Page 27
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix IV
Comments From the Food and Nutrition Service, U.S. Department of
Agriculture Page 28 GAO/RCED-99-180 Disqualified Food Stamp
Participants Appendix IV Comments From the Food and Nutrition
Service, U.S. Department of Agriculture Page 29
GAO/RCED-99-180 Disqualified Food Stamp Participants Appendix IV
Comments From the Food and Nutrition Service, U.S. Department of
Agriculture Page 30 GAO/RCED-99-180
Disqualified Food Stamp Participants Appendix V GAO Contacts and
Staff Acknowledgments Robert Robertson (202) 512-5138 Keith Oleson
(415) 904-2218 Acknowledgments In addition to those named
above, Brad Dobbins, Leo Acosta, Rod Moore, Donald Ficklin, Jerry
Hall, Jonathan Silverman, and Oliver Easterwood made key
contributions to this report. (150082) Page 31
GAO/RCED-99-180 Disqualified Food Stamp Participants Ordering
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