Food Stamp Program: Various Factors Have Led to Declining Participation
(Letter Report, 07/02/1999, GAO/RCED-99-185).
Participation in the Food Stamp Program has dropped by 27 percent during
the past 3-1/2 years. Welfare reform changed welfare from an entitlement
program to one designed to end needy parents' dependence on government
aid by promoting employment. The Food Stamp Program was retained as an
entitlement but eligibility standards were tightened; adults without
dependents had to meet work requirements and most permanent resident
aliens were disqualified from participating. This report examines the
reasons for the recent drop in food stamp participation and any problems
that households with eligible children have experienced in obtaining
food stamps. GAO found that the strong U.S. economy, tighter food stamp
eligibility requirements, and welfare reform initiatives are the primary
reasons for the decline in food stamp participation. But, some
households, including those with children, have had problems obtaining
food stamps because some state and local governments have gone farther
than the law permits in limiting benefits.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-99-185
TITLE: Food Stamp Program: Various Factors Have Led to Declining
Participation
DATE: 07/02/1999
SUBJECT: Program graduation
Disadvantaged persons
Children
Food relief programs
Eligibility criteria
State-administered programs
IDENTIFIER: Food Stamp Program
Aid to Families with Dependent Children Program
HHS Temporary Assistance for Needy Families Program
AFDC
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United States General Accounting Office GAO Report
to Congressional Requesters July 1999 FOOD STAMP PROGRAM
Various Factors Have Led to Declining Participation GAO/RCED-99-
185 GAO United States General Accounting Office Washington,
D.C. 20548 Resources, Community, and Economic Development Division
B-282728 July 2, 1999 The Honorable William J. Coyne Ranking
Minority Member Subcommittee on Oversight Committee on Ways and
Means House of Representatives The Honorable Sander M. Levin
Ranking Minority Member Subcommittee on Trade Committee on Ways
and Means House of Representatives Participation in the Food Stamp
Program, the nation's largest food assistance program, has dropped
by 27 percent during the past 3-1/2 years. The monthly average
number of low-income participants declined from 25.5 million in
fiscal year 1996 to about 18.5 million in the first half of fiscal
year 1999. The U.S. Department of Agriculture (USDA) estimates
that participation has declined at about the same rate for
children, who represent about half of the food stamp rolls. The
Personal Responsibility and Work Opportunity Reconciliation Act of
1996, commonly known as the Welfare Reform Act, changed welfare
from an entitlement program to one designed to end needy parents'
dependence on government aid by promoting employment. Accordingly,
the act gave the states flexibility, for example, to require
applicants to look for work as a condition of eligibility for
welfare benefits. The act retained the Food Stamp Program as an
entitlement program for qualifying participants, but it tightened
the program's eligibility standards by establishing work
requirements for able-bodied adults without dependents and by
disqualifying most permanent resident aliens from participating in
the program. Because of concerns that states' efforts to reduce
their welfare caseloads may have diminished eligible children's
participation in the Food Stamp Program, you asked us to examine
(1) the reasons for the recent drop in food stamp participation
and (2) any problems that households with eligible children have
experienced in obtaining food stamps. To assess these concerns, we
analyzed the responses to a questionnaire we sent the 50 states
and the District of Columbia; obtained data and reports on food
stamp participation from the Food and Nutrition Service within
USDA; and surveyed each of the Food and Nutrition Service's seven
regional offices, Page 1
GAO/RCED-99-185 Food Stamp Participation B-282728 which oversee
state and local governments' implementation of the program.
Results in Brief The strong U.S. economy, tighter food stamp
eligibility requirements, and welfare reform initiatives are the
primary reasons for the decline in food stamp participation.
According to the states, participation has dropped mainly because
fewer people are eligible to receive food stamps-a result of the
strong economy and changes in food stamp eligibility. However,
most states also believe that welfare reform initiatives designed
to reduce the welfare rolls have helped to lower food stamp
participation. Children accounted for about 48 percent of the
total decline in participation in fiscal year 1997, the most
recent year for which detailed data are available. Moreover,
children's participation in the Food Stamp Program has dropped
more sharply than the number of children living in poverty,
indicating a growing gap between need and assistance. Some
households, including those with eligible children, have had
problems obtaining food stamps because some state and local
governments have gone farther than the law permits in limiting
benefits. Believing that welfare families need to become self-
reliant and break their dependence on government assistance, these
state and local governments have taken steps that USDA has
subsequently found to be excessive. For example, New York City
emphasized job searches during applicants' first visits without
permitting households to apply for food stamps-a procedure that
USDA determined was a violation of food stamp law and a federal
court, in effect, barred by granting a preliminary injunction in
an ongoing court case. Similarly, Michigan denied food stamp
benefits to whole households rather than to individual members of
households when these members had violated welfare requirements-a
procedure that a federal court ruled was illegal. In addition,
many former welfare recipients do not receive food stamp benefits
because several state and local governments have not publicized
differences in the eligibility requirements for welfare and food
stamps. The states' actions occurred, in part, because USDA has
not promulgated regulations for implementing revisions to the Food
Stamp Program enacted almost 3 years ago. Furthermore, USDA's Food
and Nutrition Service has not reviewed potential participants'
access to food stamp benefits in 10 states since the beginning of
fiscal year 1997. We offer recommendations to USDA to correct
these inequities in the program. Page 2
GAO/RCED-99-185 Food Stamp Participation B-282728 Background
The Food Stamp Program helps low-income individuals and families
obtain a more nutritious diet by supplementing their income with
food stamp benefits. USDA's Food and Nutrition Service (FNS) and
the states jointly implement the Food Stamp Program. FNS
promulgates regulations for implementing the Food Stamp Program,
reviews states' operating plans to ensure compliance with the
regulations, and pays the full cost of the food stamp benefits and
about half of the states' administrative costs. The states
administer the program by determining whether households meet the
program's income and asset requirements, calculating monthly
benefits for qualified households, and issuing benefits to
participants. Almost all of the states use a single application
for the Food Stamp and welfare programs to reduce administrative
costs, even though the eligibility rules for these two programs
are different. In fiscal year 1998, the Food Stamp Program
provided about $16.9 billion in benefits, or an average of $170
per participating household per month.1 A household's monthly food
stamp benefit depends on the household's income, assets, and
number of qualified members. Eligibility for food stamps is based
on the Department of Health and Human Services' poverty guideline:
A household's gross income cannot exceed 130 percent of the
guideline (about $1,800 per month for a family of four living in
the contiguous United States), and its net income cannot exceed
100 percent of the guideline (about $1,400 per month for a family
of four living in the contiguous United States). In addition, a
household is limited to $2,000 in countable resources, plus a
vehicle worth no more than $4,650. (Eligibility requirements are
less stringent for households with elderly or disabled members.)
The states generally require food stamp households to have their
eligibility recertified every 3 to 12 months. The Welfare Reform
Act (P.L. 104-193, Aug. 22, 1996) reformed the nation's welfare
program and modified aspects of the Food Stamp Program. To reform
welfare, the act replaced the Aid to Families with Dependent
Children (AFDC) program with the Temporary Assistance for Needy
Families (TANF) program and gave the states responsibility for
administering TANF with block grant funding. The act set a
lifetime limit of 5 years on the receipt of TANF benefits and
established financial penalties for states that fail to ensure
that a specified minimum percentage of their welfare households
work or participate in work-related activities each year. In
implementing welfare reform, the states have used the act's
flexibility to (1) require that applicants look for jobs before
their TANF 1A household consists of individuals who live together
and customarily purchase and prepare food in common. Page 3
GAO/RCED-99-185 Food Stamp Participation B-282728 applications are
processed; (2) require that TANF recipients attend training
sessions and search for work as a basis for continuing to receive
benefits; (3) offer onetime, lump-sum payments (known as diversion
payments) to potential applicants rather than enroll them in the
TANF program; and (4) disqualify individuals from participation in
the Food Stamp Program for TANF violations, thereby reducing the
household's total food stamp benefit.2 The act also tightened food
stamp eligibility requirements and eased administrative
requirements. It disqualified able-bodied adults without
dependents who, during the preceding 36-month period, received
food stamp benefits for at least 3 months but worked less than 20
hours per week.3 Similarly, the act required that the states, by
August 1997, remove from their rolls most permanent resident
aliens who were previously eligible to receive food stamps.4 In
addition, the act replaced several specific administrative
requirements with more general standards that give the states more
flexibility in operating their food stamp programs. Historically,
participation in the Food Stamp Program has tracked U.S. business
cycles: Food stamp participation has grown as the economy has
slowed and declined as the economy has expanded. However,
particularly since 1996, food stamp participation has dropped
faster than related economic indicators would predict. Figure 1
shows that food stamp participation, unemployment, and the number
of people living in poverty rose during the recession in the late
1980s and early 1990s. Since then, food stamp participation and
unemployment have dropped to their 1990 and 1989 levels,
respectively, as the U.S. economy has expanded. (See table I.1 in
app. I for data on food stamp participation by state.) However,
the number of people living in poverty, which peaked at 39.3
million in 1993, declined more gradually and leveled off after
1995-about 4 million more people were living in poverty in 1997
than in 1989. 2See Welfare Reform: States Are Restructuring
Programs to Reduce Welfare Dependence (GAO/HEHS-98-109). 3States
may ask to waive the work requirement for groups of individuals
who live in an area where the unemployment rate is over 10 percent
or there are not enough jobs to provide employment. 4As of Nov. 1,
1998, the Agricultural Research, Extension, and Education Reform
Act of 1998 (P.L. 105-185) restored eligibility for the Food Stamp
Program to permanent resident aliens who (1) were living in the
United States when the Welfare Reform Act was enacted in Aug. 1996
and were over 65 or disabled or (2) are under age 18. Page 4
GAO/RCED-99-185 Food Stamp Participation B-282728 Figure 1: Number
of Food Stamp Participants Compared With Numbers People in
millions of Unemployed People and People Living in Poverty, 1989-
98 Note: The number of people living in poverty is unavailable for
1998. Sources: FNS; the Bureau of Labor Statistics, Department of
Labor; and the Bureau of the Census, Department of Commerce. The
number of people who received food stamp benefits has declined
each year since fiscal year 1994, with most of the decline
occurring after fiscal year 1996. Between fiscal year 1996 and
fiscal year 1998, the food stamp rolls decreased by 5.8 million
participants, accounting for 75 percent of the total decrease
since fiscal year 1994. Food stamp participation dropped in each
state, declining by an average of 23 percent and ranging from
about 32 percent in Wisconsin to 6 percent in Hawaii. (See table
I.2 in app. I for the states with the greatest decline in
participation.) Page 5
GAO/RCED-99-185 Food Stamp Participation B-282728 Various Factors
Have The primary factors contributing to the decline in food
stamp participation Caused the Decline in have been the strong
U.S. economy, provisions of the Welfare Reform Act that tightened
the Food Stamp Program's eligibility requirements, and Food Stamp
state and local government initiatives designed to reduce TANF
rolls, Participation according to the 50 respondents to
our survey5 and FNS' most recent report.6 Few states cited any
other factor as a major or moderate reason for the recent decline
in food stamp participation. Overall, 27 states attributed the
decline in food stamp participation in their state primarily to a
drop in the number of people eligible to receive food stamps,
while the decline in the number of eligible people who participate
in the program was less important. FNS' data similarly show that
the number of people eligible for food stamps declined by 18
percent from August 1996 to September 1997, reflecting the strong
economy and tighter eligibility requirements. In contrast, seven
states attributed the decline in food stamp participation in their
state primarily to a drop in the number of eligible people who
participate in the program. In recent years, the number of
children living in poverty who receive food stamp benefits has
dropped, indicating a growing gap between need and assistance.
USDA also reported that the number of children receiving free
lunches through its school lunch program increased by 6.4 percent
from fiscal year 1994 through fiscal year 1997. Forty-two states
cited their improved state economy as either a major or a moderate
reason for the decline in food stamp participation since 1996.
(See table 1.) The strong U.S. economy has reduced the number of
eligible people because more people are employed and earning more
money, reducing the number of people who meet the Food Stamp
Program's income eligibility standard. The strong economy has also
reduced the length of time some people spend on the food stamp
rolls because they can find a new job faster. Finally, the strong
economy may indirectly lower the percentage of eligible people
participating in the program because, as households' income levels
rise and food stamp benefits fall proportionally, households may
decide not to apply or seek recertification for these benefits,
especially when they approach the $10-per-month minimum level.
5These respondents, referred to as "states" in the remainder of
this report, include 49 states and the District of Columbia. Rhode
Island did not respond to our questionnaire. 6Characteristics of
Food Stamp Households for fiscal year 1997 (Feb. 1999) cited these
factors but could not determine the relative importance of each
factor in causing the drop in food stamp participation. Page 6
GAO/RCED-99-185 Food Stamp Participation B-282728 Table 1:
Distribution of Reasons Cited by States for the Decline in Food
Stamp Participation Minor No basis to Major Moderate
reason/not judge/does Reason cited for the decline
reason reason a reason not apply Improved state
economy/more people with jobs
28 14 4 3 Changes in federal
law that tightened food stamp requirements for able-bodied adults
without dependents
7 20 21 2 Changes in federal
law that tightened food stamp eligibility requirements for legal
immigrants
5 15 29 1 Federal, state, or
local welfare reform initiatives designed to reduce the TANF
caseload that also affected food stamp participation
5 14 27 4 Fewer months spent
by participants on the food stamp rolls
2 12 15 21 Perceived stigma
associated with receiving food stamps
0 4 36 10 Small monthly food
stamp benefits/not worth the time and effort to apply or be
recertified for food stamps
0 3 39 8 Change in attitudes
of potential food stamp applicants to rely primarily on themselves
and their families rather than on food stamps
0 3 27 18
Automation/technology improvements that reduced fraud and waste
0 4 35 11 Net movement of
eligible individuals and households out of the state
0 0 32 18 Implementation of
electronic benefit transfer (EBT) card that discouraged use by
participants lacking experience with electronic cards
0 0 32 18 Source: State-
reported survey data. Many states believe that the tighter
eligibility restrictions on able-bodied adults without dependents
and on permanent resident aliens are important reasons for the
drop in food stamp participation. Specifically, 27 states cited
the new work requirements for able-bodied adults without
dependents as a major or moderate reason for the decline in food
stamp participation. Similarly, 20 states cited the new
restrictions on permanent resident aliens as a major or moderate
reason for the decline in food stamp participation. California,
Florida, and Texas, which have large permanent resident alien
populations, cited the new restrictions on permanent resident
aliens as a major reason for the decline in their food stamp
rolls; New York, which also has a large permanent resident alien
population, cited these restrictions as a moderate reason for the
decline in its food stamp rolls. During fiscal year 1997,
participation in the Food Stamp Program by able-bodied adults
without dependents and by permanent resident aliens fell by about
714,000 people, accounting for about 25 percent of the decline in
food stamp participation. (See tables II.1 and II.2 in app. II for
information about categories of participants.) Page 7
GAO/RCED-99-185 Food Stamp Participation B-282728 Federal, state,
or local initiatives designed to reduce the TANF caseload were
cited by 19 states as a major or moderate reason and by 19
additional states as a minor reason for the decline in their food
stamp rolls. As shown in figure 2, participation in both welfare
and the Food Stamp Program peaked in 1994 and has dropped sharply
since then. The number of welfare recipients dropped by about 43
percent, from about 14.2 million in 1994 to about 8.1 million in
August 1998. About two-thirds of this decline occurred after
August 1996, when the Welfare Reform Act was enacted and there
were about 12.2 million welfare recipients. The number of TANF
recipients leaving the Food Stamp Program during fiscal year 1997
was almost twice as great as the number of non-TANF recipients.
(See tables II.3 and II.4 in app. II.) Figure 2: Number of Food
Stamp Participants Compared With Number Participants in
millions of AFDC/TANF Recipients, 1989 Through 1998 Source: FNS
and the Administration for Children and Families. Page 8
GAO/RCED-99-185 Food Stamp Participation B-282728 Studies
conducted by various states suggest that many former TANF
recipients do not receive food stamp benefits, even though they
are eligible.7 For example, a Wisconsin study found that former
welfare recipients had a median wage of $7.00 per hour, which
would meet the food stamp income eligibility standard for a
household of three; however, 51 percent of these former recipients
did not receive food stamps, and 34 percent of the former
recipients were unaware that they might still qualify for food
stamps.8 The Wisconsin study also found that 32 percent of the
state's former welfare recipients had no way to buy food for some
period of time after they left welfare and 13 percent relied on
food pantries for assistance. Similarly, a South Carolina study
found that former welfare recipients had an average wage of $6.45
per hour, which was below the food stamp income eligibility
requirement for a household of three; however, 40 percent of these
former recipients did not receive food stamps, and 22 percent were
unaware that they might qualify for food stamps.9 The South
Carolina study also found that 13 percent of the state's former
welfare recipients had no way to buy food for some period of time
after they left welfare and 17 percent received assistance from a
shelter or food pantry. Studies conducted by Massachusetts and
Texas found similar trends.10 The food stamp directors of four FNS
regional offices told us that the implementation of TANF has been
an important factor in the decline in food stamp participation in
their regions. In particular, the directors cited confusion about
the eligibility rules for both TANF and food stamps as a deterrent
to potential applicants. According to these directors, many people
do not apply for food stamps because they assume that if they are
ineligible for TANF, they are also ineligible for food stamps. One
director noted that one of the most common problems identified by
the regional office's state operations reviews is confusion over
eligibility requirements-on the part of both the eligibility
workers and the food stamp applicants. 7Although these studies did
not specifically examine food stamp participation among eligible
former TANF recipients, they provide data on former recipients'
earnings and receipt of food stamps. 8Survey of Those Leaving AFDC
or W-2 January to March 1998 Preliminary Report, State of
Wisconsin, Department of Workforce Development (Jan. 13, 1999).
9Survey of Former Family Independence Program Clients: Cases
Closed during July through September 1997, South Carolina
Department of Social Services, Division of Program Quality
Assurance (Oct. 9, 1998). 10How Are They Doing? A Longitudinal
Study of Households Leaving Welfare Under Massachusetts Reform,
Massachusetts Department of Transitional Assistance (Apr. 1999)
and Texas Families in Transition: The Impacts of Welfare Reform
Changes in Texas, Early Findings, Texas Department of Human
Services (Dec. 1998). Page 9
GAO/RCED-99-185 Food Stamp Participation B-282728 The Percentage
of Children As shown in table 2, there is a growing
gap between the number of Living in Poverty Who
children living in poverty-an important indicator of children's
need for Received Food Stamp food assistance-
and the number of children receiving food stamp Benefits Dropped
in 1997 assistance. In particular, during fiscal
year 1997, the number of children living in poverty dropped by
350,000 (or 3 percent) while the number of children participating
in the Food Stamp Program dropped by 1.3 million (or 10 percent).
As a result, the percentage of children living in poverty who
received food stamps declined from 91.4 percent to 84.1 percent.
Table 2: Comparison of the Number of Children Receiving Food
Stamps With Children in thousands the Number of Children
Living in
Percentage of Poverty, 1989-97
children living in Children who
poverty who received food Children living received food
Year stampsa in
povertyb stamps 1989
9,442 12,590 75.0 1990
10,139 13,431 75.5 1991
11,960 14,341 83.4 1992
13,364 15,294 87.4 1993
14,211 15,727 90.4 1994
14,407 15,289 94.2 1995
13,879 14,665 94.6 1996
13,212 14,463 91.4 1997
11,868 14,113 84.1 aTotals are
estimates by fiscal year. bTotals are estimates by calendar year.
Sources: FNS for food stamp data and the U.S. Bureau of the
Census, within the U.S. Department of Commerce, for poverty data.
Figure 3 shows that children's participation in the Food Stamp
Program has declined at the same rate as adults' participation.11
Children consistently accounted for about half of all Food Stamp
Program participants from fiscal year 1989 through fiscal year
1997. From fiscal year 1994 through fiscal year 1997, the number
of children receiving food stamps declined by an estimated 2.5
million. (See tables II.5 and II.6 in app. II for information on
the distribution of food stamp participants by age.) Most of this
drop occurred during fiscal year 1997, when an estimated 1.3
million children left the Food Stamp Program. This drop in
children's 11The Food Stamp Program defines children as being less
than 18 years old. Page 10
GAO/RCED-99-185 Food Stamp Participation B-282728 participation
accounted for 48 percent of the total decline in participation
during fiscal year 1997. Figure 3: Children as a Proportion of All
Participants in the Food Stamp Participants in
millions Program, Fiscal Years 1989-97 30 27 24 21 18 15 12 9 6 3
0 1989 1990 1991 1992 1993 1994 1995
1996 1997 Fiscal year Other participants (18+ years) Children
participants (0-17 years) Source: FNS. Page 11
GAO/RCED-99-185 Food Stamp Participation B-282728 Demand for Food
Data from USDA and several nonprofit organizations show that the
demand Assistance Has Increased for food assistance by low-
income families has increased in recent years, While Food Stamp
indicating that the drop in food stamp participation is not solely
the result Participation Has Declined of a strong U.S. economy.
According to these data, the need for food assistance has not
diminished; rather, needy individuals are relying on sources of
assistance other than food stamps. For example, the number of
children served free lunches in USDA's National School Lunch
Program increased by 6 percent from fiscal year 1994 through
fiscal year 1997, while the number of school-age children
participating in the Food Stamp Program declined by 18 percent-
about 5 million more children obtained free lunches than food
stamps in fiscal year 1997.12 (See table II.7 in app. II.)
Catholic Charities reported that during 1998, the demand for
emergency food assistance rose, on average, by 38 percent among 73
percent of the local parishes that responded to its survey.
Similarly, from November 1997 through October 1998, requests for
emergency food assistance by needy individuals increased by an
average of 14 percent in 21 of the 30 major cities surveyed by the
U.S. Conference of Mayors. Some Eligible While
many states have treated food stamps as an important safety net
Families With that helps the working poor move
from public assistance to the workforce, several state and local
governments have implemented more stringent Children Have Had
policies that have restricted the access to food stamp benefits of
an Problems Obtaining undeterminable number of eligible
families with children. In particular, FNS regional offices have
investigated practices in New York City; Portland, Food Stamps
Oregon; and Milwaukee, Wisconsin, and found barriers to food stamp
participation. Similarly, at least seven states have policies that
improperly remove eligible households with children from the food
stamp rolls as a sanction for a TANF violation. This has occurred,
in part, because FNS has not promulgated regulations that
implement the Welfare Reform Act's revisions to the Food Stamp
Program. Without regulations, state and local governments believe
they have the flexibility to implement more stringent requirements
associated with the TANF program than FNS believes is appropriate.
In addition, FNS regional offices have not reviewed participants'
access to food stamp benefits in 10 states since the Welfare
Reform Act was enacted in August 1996. These reviews have not
occurred, in part, because some regional offices have not annually
reviewed Food Stamp Program operations in each state within their
jurisdiction, as required. 12To be eligible for a free lunch, a
child must come from a household whose income is at or below 130
percent of the federal poverty guideline. Page 12
GAO/RCED-99-185 Food Stamp Participation B-282728 Three Regional
FNS During the past year, FNS regional offices have
reviewed access to the Reviews Reveal Barriers to Food Stamp
Program in New York, Oregon, and Wisconsin in response to
Participation complaints from advocacy groups
and a Member of Congress. As described more fully in appendix III,
each of these reviews has identified barriers that have made the
Food Stamp Program less accessible for eligible people. * FNS
found that New York City violated federal law and regulations
because caseworkers at the two job centers it reviewed (1) did not
permit households to apply for food stamps during their first
visit; (2) did not inform applicants about the availability of
food stamps if the applicants either were denied TANF benefits or
accepted a onetime, lump-sum payment (known as a diversion
payment) instead of applying for TANF benefits; and (3) frequently
denied food stamp benefits to applicants who did not participate
in eligibility verification for food stamps and employment-related
activities primarily for TANF. In addition, FNS' food stamp
director for the Northeast Region told us that job center staff
were informing applicants that expedited food stamps were no
longer available, refusing to accept food stamp applications
because it was "too late" in the day, and encouraging applicants
to withdraw their food stamp applications. While New York City
officials initially disagreed with FNS' report, citing the
agency's reliance on regulations that the officials believed were
inconsistent with the Welfare Reform Act, New York City
implemented New York State's corrective action plan that addressed
FNS' concerns in April 1999. In addition, in January 1999, a
federal district court granted a preliminary injunction, in effect
barring New York City from using certain procedures. The court
found that the plaintiffs and other applicants for food stamp
benefits, Medicaid, and cash assistance would suffer irreparable
harm if relief were not provided through a preliminary injunction.
As a result, the court directed New York City, among other things,
to (1) allow all persons applying for food stamps, Medicaid, and
cash assistance to apply for such benefits on the first day that
they visit a job center and (2) process all applications for
expedited food stamps at job centers within the time frames
required by law. * FNS found that certain area offices in
Portland, Oregon, had procedures that created possible barriers to
participation. Food stamp applicants who arrived after 8:30 a.m.
were told to return to the office on another day to file their
applications. Furthermore, the offices' "first-come, first-served"
procedures created situations where clients who arrived before
8:30 a.m. Page 13 GAO/RCED-99-185
Food Stamp Participation B-282728 had waited all day without being
seen by an eligibility worker, only to be told at the close of
business to return on another day and start over again. Although
Oregon officials questioned some of FNS' findings and
recommendations, they submitted a corrective action plan that
addressed FNS' concerns. FNS officials noted that procedures that
require food stamp applicants to return for a second day create
barriers to participation, especially for the working poor,
because most food stamp offices are open only during business
hours.13 Furthermore, many participants are required to return to
the food stamp office four times a year to be recertified for food
stamps. A 3-month recertification period has become more common
because the states are seeking to reduce errors, such as
overpayments resulting from changes in a household's income or
composition. Households with earned income typically are
recertified more often than households on fixed incomes because
their incomes are more likely to change. * FNS found that several
practices violated federal regulations in its review of two
welfare centers in Milwaukee, Wisconsin. However, FNS believed
that these centers were not intentionally trying to divert
potential applicants from food stamp benefits. For example, staff
at the centers did not (1) inform applicants of their right to
file a food stamp application on the day of their first contact
with the office and (2) provide food stamp applications upon
request.14 In addition, FNS found that the centers hindered
participation because posters that outline food stamp applicants'
rights were not displayed and clients' work schedules were not
taken into account when recertification interviews were scheduled.
Although Wisconsin officials questioned some of FNS' findings,
they submitted a corrective action plan that FNS currently is
reviewing. Some States Have Some states have used
what is called the comparable disqualification Disqualified Whole
provision of the Welfare Reform Act to disqualify an entire
household from Households From the Food participation in the
Food Stamp Program because one member has Stamp Program for TANF
violated a TANF requirement. The comparable disqualification
provision Violations by Individual gives the states the
option to (1) disqualify a food stamp participant who has been
disqualified under another means-tested program and (2) apply
Members 13Five states cited the inconvenience of being recertified
during business hours as a moderate reason why eligible households
with children do not participate in the Food Stamp Program, while
20 states characterized it as a minor reason. 14Failing to inform
applicants of their right to file a food stamp application on the
day of their first contact with the office also violates the Food
Stamp Act. Page 14
GAO/RCED-99-185 Food Stamp Participation B-282728 the
disqualification for benefits under the other means-tested program
to food stamp benefits. As a result, the states can disqualify a
food stamp participant for not complying with TANF's work
requirements, even if the participant is exempt from work
requirements under the Food Stamp Program's rules. Initially, FNS'
guidance allowed the states to decide whether to disqualify the
entire household or just the noncomplying individual. However, FNS
reversed its position in November 1997 and directed the states to
disqualify only the noncomplying individual. Despite the revision
in FNS' guidance, 7 states said they disqualify an entire
household for food stamp benefits because of a member's TANF
violations, 13 states said they determine whom to sanction for a
TANF violation on a case-by-case basis, and 2 states said they had
previously suspended the food stamp benefits of an entire
household for a member's TANF violations. In March 1998, a federal
district court (in an unreported decision) directed Michigan to
stop disqualifying an entire household for food stamps because of
a member's TANF violation (not cooperating in obtaining child
support). An FNS regional official told us that FNS cannot force
states to change their policies until FNS publishes regulations
for implementing the comparable disqualification provision. FNS
Has Not Promulgated The Welfare Reform Act revised the Food
Stamp Program's administrative Regulations for
requirements by replacing several specific requirements with more
general Implementing the Welfare performance standards.
Specifically, the act allows each state to establish Reform Act's
Revisions procedures for operating its food stamp offices
that the state determines best serve its households provided, in
part, that the state (1) provides timely, accurate, and fair
service to applicants for, and participants in, the Food Stamp
Program and (2) permits households to apply to participate in the
program on the same day that they first contact a food stamp
office in person during office hours. It is unclear whether, as a
result of this revision, FNS will continue to require, for
example, that the states prominently display signs in all food
stamp certification offices explaining eligibility standards and
inform each applicant for assistance of the right to apply for
food stamps on the day of initial contact. Although the Welfare
Reform Act was enacted almost 3 years ago, FNS has not promulgated
regulations implementing the act's food stamp revisions because of
delays in USDA's clearance process. FNS could not provide a reason
for the delay in promulgating regulations. In May 1999, FNS
published the first of several Notices of Proposed Rulemaking in
the Page 15 GAO/RCED-99-185 Food
Stamp Participation B-282728 Federal Register (this notice
addressed an unrelated revision). FNS plans to promulgate final
rules for all of the Welfare Reform Act's revisions by December
2000. FNS has also provided guidance to the states on specific
issues, such as diversion payments and comparable
disqualifications, through policy memorandums and questions and
answers posted on its Web site. However, unlike federal
regulations, this guidance is not binding. Because FNS has not
promulgated implementing regulations, some state and local
governments have implemented more stringent requirements
associated with the TANF program than FNS believes is appropriate.
The Midwest regional office has told its states that they are
allowed to interpret the Welfare Reform Act's revisions for
themselves until regulations are published. New York City
officials have petitioned USDA to promulgate new regulations
repealing food stamp regulations that, in New York City's opinion,
are inconsistent with the Welfare Reform Act and to clarify the
ability of states and localities to implement the act's goals in
their local food stamp offices. FNS Has Not Examined FNS'
regulations require that FNS regional offices annually review the
Program Access Issues in operations of each state in their
jurisdiction to ensure that the states are Many States
complying with federal regulations implementing the Food Stamp
Program. These reviews have previously identified obstacles to
gaining access to benefits and have directed the states to correct
their procedures. For example, the regional offices have found
untimely application processing, a lack of bilingual staff,
confusion over rules and regulations affecting eligibility, and
failure to inform applicants who have been denied TANF benefits
about the availability of food stamps. Each of these problems, if
uncorrected, creates a barrier to participation for eligible
households. However, we found that only three of the seven
regional offices regularly conduct an annual review of each state
in their jurisdiction. The other offices said they did not have
sufficient staff resources to annually examine each state's
operations. Even when the regional offices review the states'
operations, they often do not evaluate the access of potential
participants to food stamp benefits. As of June 21, 1999, FNS
regional offices had not examined program access issues in 10
states since the beginning of fiscal year 1997. (See app. IV.)
Conclusions While the strong U.S. economy and
legislation revising eligibility requirements for the Food Stamp
Program are important reasons why participation in the program is
declining, several state and local Page 16
GAO/RCED-99-185 Food Stamp Participation B-282728 governments have
implemented stringent policies designed to reduce their TANF
caseloads that have restricted low-income families' access to food
stamp benefits. Because FNS found that some of these policies
violate food stamp law, it has worked with the states to make
appropriate changes. FNS also determined that some states'
implementation of the Welfare Reform Act's comparable
disqualification provision is not supported by law. However, FNS
has not ordered the states to change their policies, and FNS has
not promulgated regulations implementing the Welfare Reform Act's
revisions to the Food Stamp Act. As long as the policies remain in
effect, some qualifying households, including those with children,
may not be receiving food stamp benefits to which they are legally
entitled. This is important because the number of children living
in poverty who receive food stamps has declined in recent years,
indicating a growing gap between need and assistance. In addition,
states' studies of TANF reform indicate that many former TANF
recipients may not receive food stamp benefits because they are
unaware that they may qualify for food stamps. Further
exacerbating this problem, FNS regional offices inconsistently
enforce food stamp requirements and some do not annually review
each state's operations, as required. Finally, when FNS performs
such reviews, it does not always examine people's access to food
stamp benefits. Recommendations To ensure that eligible
people receive food stamp benefits, we recommend that the
Secretary of Agriculture direct the Administrator, Food and
Nutrition Service, to take the following actions: * Promulgate
regulations implementing the Welfare Reform Act's revisions to the
Food Stamp Act. These regulations should, at a minimum, require
that the states (1) inform each applicant for assistance of the
right to apply for food stamps during the first meeting,
regardless of whether the applicant applies for other assistance,
and (2) sanction the food stamp benefits only of the individual
who does not comply with requirements of the Temporary Assistance
for Needy Families program. * Publicize eligibility requirements
for the Food Stamp Program and distinguish them from the
eligibility requirements for the Temporary Assistance for Needy
Families program. * Give higher priority to aggressively targeting
issues related to participants' access to food stamp benefits in
reviewing states' food stamp operations. Agency Comments
We provided the U.S. Department of Agriculture with a draft of
this report and Our Evaluation for review and comment. We met
with Agriculture officials, including the Page 17
GAO/RCED-99-185 Food Stamp Participation B-282728 Associate Deputy
Administrator for the Food Stamp Program within the Food and
Nutrition Service. The Department agreed with the thrust of the
report and with our recommendations for promulgating regulations
implementing the Welfare Reform Act's revisions and publicizing
eligibility requirements for the Food Stamp Program. In response
to our proposed recommendation that Agriculture develop a strategy
for ensuring an annual review of each state's food stamp
operations, the Department said that on-site reviews would be
difficult to conduct at each state annually, given resource
constraints, but agreed on the importance of targeting participant
access issues. We revised our proposed recommendation, eliminating
the reference to conducting annual reviews of each state's
operations while continuing to emphasize the importance of
targeting issues associated with participants' access to food
stamp benefits. In addition, the Department provided comments to
improve the report's technical accuracy, which we incorporated as
appropriate. We also made portions of the draft report available
to the states of New York, Oregon, and Wisconsin. New York
officials pointed out that the decline in food stamp participation
in their state either has mirrored or is below the national trend
for various periods between 1994 and 1999. While we agree with New
York State's point, we did not modify the report because it does
not discuss individual states' food stamp participation rates.
(See app. V. for New York's written comments and our responses.)
In addition, Oregon and Wisconsin provided comments to improve the
report's technical accuracy, which we incorporated as appropriate.
(See app. VI for Wisconsin's written comments.) Scope and To
assess the reasons individual states cite for the recent drop in
food Methodology stamp participation, we surveyed the food
stamp directors of the 50 states and the District of Columbia
about their (1) perceptions as to why, for example, their state's
food stamp rolls have declined and eligible households with
children may decide not to apply for food stamps and (2) state's
food stamp participation data, to the extent that these data were
readily available. We received responses to our questionnaire from
49 states and the District of Columbia (Rhode Island did not
return the questionnaire). However, most of the states could not
readily provide data on food stamp participation by categories of
participants, recertifications, applications, or sanctions. We
also obtained FNS' official participation data (known as
"keydata") and FNS' quality control data. The keydata reflect the
monthly number of food stamp participants in each state. The
quality control data, which are derived from a national
probability sample of Page 18
GAO/RCED-99-185 Food Stamp Participation B-282728 participating
food stamp households, provide participation information for
children, the elderly, and other categories of food stamp
participants. Fiscal year 1997 data are the most current quality
control data available. We used both data sources to provide
aggregate level trends from fiscal year 1989 through fiscal year
1998 and children's participation trends from fiscal year 1989
through fiscal year 1997. We interviewed cognizant FNS officials
and representatives of Mathematica Policy Research, Inc., which
for several years has had a contract with FNS to analyze food
stamp participation trends. In addition, we examined several
states' studies of former TANF recipients that provided data on
former recipients' earnings and receipt of food stamps. To
identify the problems eligible households with children may be
having in obtaining food stamps, we surveyed states about their
policies and procedures for implementing the Food Stamp Program,
including their procedures for sanctioning TANF violations. We
also examined program access reviews that FNS regional offices
have conducted in New York, Oregon, and Wisconsin. Each of these
reviews identified barriers that reduced eligible people's access
to the Food Stamp Program. We interviewed cognizant officials at
FNS headquarters about its plans to promulgate regulations and at
each of its seven regional offices about their annual reviews of
states' operations. We performed our work from August 1998 through
June 1999 in accordance with generally accepted government
auditing standards. We did not independently verify the accuracy
of participation data from FNS' quality control sample. The
quality control sample data are the best data available for
examining participation by categories of food stamp participants.
As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter. At that time, we will
send copies of the report to the congressional committees and
subcommittees responsible for the Food Stamp Program; the
Honorable Dan Glickman, Secretary of Agriculture; the Honorable
Jacob Lew, Director, Office of Management and Budget; and other
interested parties. We will also make copies available upon
request. Page 19 GAO/RCED-99-185
Food Stamp Participation B-282728 Please contact me at (202) 512-
5138 if you or your staff have any questions about this report.
Key contributors to this report are listed in appendix VII.
Lawrence J. Dyckman Director, Food and Agriculture Issues Page 20
GAO/RCED-99-185 Food Stamp Participation Page 21 GAO/RCED-99-
185 Food Stamp Participation Contents Letter
1 Appendix I
26 Food Stamp Participation Trends Appendix II
29 Changes in Participation Among Selected Food Stamp Populations
Appendix III
35 FNS' Program Access New York City
35 Portland, Oregon 36
Reviews Reveal Milwaukee, Wisconsin
37 Barriers to Participation Appendix IV
38 States Reviewed by FNS Concerning Participants' Access to Food
Stamp Benefits, Fiscal Years 1997-99 Appendix V
40 Comments From New York State Page 22 GAO/RCED-
99-185 Food Stamp Participation Contents Appendix VI
44 Comments From Wisconsin Appendix VII
46 GAO Contacts and Staff Acknowledgments Tables
Table 1: Distribution of Reasons Cited by States for the Decline
7 in Food Stamp Participation Table 2: Comparison of the Number of
Children Receiving Food 10 Stamps With the Number
of Children Living in Poverty, 1989-97 Table I.1: Average Monthly
Number of Food Stamp Participants, 26 by State,
Fiscal Years 1990-98 Table I.2: States With the Greatest
Percentage Decline in Food 28 Stamp Participation
Since the Enactment of the Welfare Reform Act, Fiscal Years 1996-
98 Table II.1: Selected Demographic Characteristics of Food Stamp
29 Participants, Fiscal Years 1996-97 Table II.2: Permanent
Resident Aliens Who Received Food 30 Stamps,
Fiscal Years 1994-97 Table II.3: Change in AFDC/TANF and Food
Stamp Participation 30 Since the Enactment of the
Welfare Reform Act, August 1996 to August 1998 Table II.4: Food
Stamp Participation by TANF Participants and 32
Non-TANF Participants, Fiscal Years 1996-97 Table II.5: Age
Distribution of Food Stamp Participants, Fiscal 32
Years 1989-97 Table II.6: Number of Children Who Received Food
Stamps, by 33 State, Fiscal Years 1995-97 Table
II.7: Number of School-Age Children Receiving Food
34 Stamps Compared With the Number of Children Receiving Free
Lunches in School, Fiscal Years 1994-97 Figures Figure
1: Number of Food Stamp Participants Compared With
5 Numbers of Unemployed People and People Living in Poverty, 1989-
98 Page 23 GAO/RCED-99-185 Food
Stamp Participation Contents Figure 2: Number of Food Stamp
Participants Compared With 8 Number of
AFDC/TANF Recipients, 1989 through 1998 Figure 3: Children as a
Proportion of All Participants in the Food 11 Stamp
Program, Fiscal Years 1989-97 Abbreviations AFDC Aid to
Families with Dependent Children FNS Food and Nutrition
Service GAO General Accounting Office TANF
Temporary Assistance for Needy Families USDA U.S.
Department of Agriculture Page 24
GAO/RCED-99-185 Food Stamp Participation Page 25 GAO/RCED-99-
185 Food Stamp Participation Appendix I Food Stamp Participation
Trends The data in this appendix are the actual number of
participants reported monthly by each state to the U.S. Department
of Agriculture's (USDA) National Data Bank. Table I.1: Average
Monthly Number of Food Stamp Participants, by State, Fiscal Years
1990-98 Participants in thousands Change in Fiscal year
Fiscal year Fiscal year Fiscal year Fiscal year
number of State 1990
1992 1994 1996 1998
participants Alabama 453.5
549.7 547.7 509.2 426.8
82.4 Alaska 25.1
37.7 45.9 46.2 42.5 3.7
Arizona 317.1 457.1
511.7 427.5 295.7 131.8 Arkansas
234.9 276.8 282.5 273.9
255.7 18.2 California 1,954.8
2,557.9 3,154.6 3,143.4 2,259.1
884.3 Colorado 221.3
259.7 268.3 243.7 191.0
52.7 Connecticut 133.3
202.3 222.6 222.8 195.9
26.9 Delaware 33.3
50.6 59.2 57.8 45.6 12.2
Florida 781.5 1,403.9
1,474.4 1,371.4 990.6 380.8 Georgia
535.6 754.1 830.4 792.5
631.7 160.8 Hawaii 77.0
94.3 114.6 130.3 122.0 8.3
Idaho 58.6 71.9
81.5 79.9 62.4 17.5 Illinois
1,013.1 1,156.4 1,188.8 1,105.2
922.9 182.3 Indiana 310.9
447.7 517.9 389.5 313.1
76.4 Iowa 170.5
192.3 195.7 177.3 141.1
36.2 Kansas 142.3
174.5 191.7 171.8 119.2
52.6 Kentucky 458.2
528.8 522.3 485.6 412.0
73.6 Louisiana 727.3
779.3 756.4 670.0 536.8
133.2 Maine 93.8
132.5 135.8 130.9 115.1
15.8 Maryland 254.7
342.2 390.2 374.5 322.7
51.8 Massachusetts 347.3
428.8 441.8 373.6 293.0
80.6 Michigan 916.6
994.2 1,030.7 935.4 771.6
163.8 Minnesota 262.9
308.9 313.5 294.8 219.7
75.1 Mississippi 499.2
535.9 510.5 457.1 329.1
128.0 Missouri 431.4
549.5 593.1 553.9 411.0
142.9 Montana 56.7
66.3 71.4 70.8 62.3 8.5
Nebraska 94.5 107.3
110.8 101.6 94.9 6.7 Nevada
49.8 79.7 96.7 96.7
71.5 25.2 New Hampshire 30.6
57.7 61.6 52.8 39.6 13.2
New Jersey 381.6 494.1
545.3 540.5 424.7 115.8 New Mexico
157.3 221.3 244.3 235.1
174.7 60.4 (continued) Page 26
GAO/RCED-99-185 Food Stamp Participation Appendix I Food Stamp
Participation Trends Participants in thousands Change in Fiscal
year Fiscal year Fiscal year Fiscal year
Fiscal year number of State
1990 1992 1994 1996
1998 participants New York 1,548.3
1,885.1 2,153.6 2,098.6 1,627.2
471.4 North Carolina 419.0
596.7 629.9 631.1 527.8
103.3 North Dakota 39.1
45.9 45.4 39.8 33.8
6.0 Ohio 1,089.5
1,250.6 1,245.2 1,045.1 733.6
311.5 Oklahoma 266.6
346.0 376.0 353.8 287.8
66.0 Oregon 216.4
264.9 286.3 287.6 238.4
49.2 Pennsylvania 952.0
1,137.4 1,208.3 1,123.5 906.7
216.8 Rhode Island 64.1
87.4 93.8 90.9 72.8
18.1 South Carolina 299.2
368.8 385.4 358.3 333.0
25.3 South Dakota 50.4
54.7 53.3 48.8 45.2
3.6 Tennessee 526.6
701.6 734.6 637.8 538.5
99.3 Texas 1,879.9
2,454.0 2,725.8 2,372.0 1,636.2
735.8 Utah 99.5
123.2 127.8 110.0 91.8
18.2 Vermont 38.4
53.5 64.6 56.5 45.7
10.8 Virginia 345.9
495.5 547.1 537.5 396.6
140.9 Washington 340.3
431.5 467.6 476.4 362.2
114.2 West Virginia 261.8
309.6 321.4 299.7 269.1
30.6 Wisconsin 285.8
334.0 329.8 283.3 192.9
90.4 Wyoming 28.3
33.4 34.0 33.0 25.5
7.5 District of Columbia 62.1
82.3 90.7 92.8 85.4
7.4 Guam 11.7
19.8 15.2 17.6 25.2
7.6 Virgin Islands 17.6
16.5 20.0 30.7 17.3
13.4 Total 20,066.8
25,405.6 27,467.8 25,540.3 19,786.7
5,753.6 Note: Puerto Rico is excluded because it receives block
grant funding. Columns may not add because of rounding. Source:
Food and Nutrition Service (FNS), USDA. Page 27
GAO/RCED-99-185 Food Stamp Participation Appendix I Food Stamp
Participation Trends Table I.2: States With the Greatest
Percentage Decline in Food Stamp Participants in thousands
Participation Since the Enactment of
Fiscal year Fiscal year Fiscal year Percent change the
Welfare Reform Act, Fiscal Years State
1996 1997 1998 (FY 1996-98) 1996-98
Wisconsin 283.3 232.1
192.9 31.9 Texas 2,372.0
2,033.8 1,636.2 31.0 Arizona
427.5 363.8 295.7 30.8 Kansas
171.8 148.7 119.2 30.6 Ohio
1,045.1 873.6 733.6 29.8 California
3,143.4 2,814.8 2,259.1 28.1 Mississippi
457.1 399.1 329.1 28.0 Florida
1,371.4 1,191.7 990.6 27.8 Virginia
537.5 476.1 396.6 26.2 Nevada
96.7 82.4 71.5 26.1 Source: FNS,
USDA. Page 28 GAO/RCED-99-185
Food Stamp Participation Appendix II Changes in Participation
Among Selected Food Stamp Populations Many of the data provided in
this appendix are derived from reports entitled Characteristics of
Food Stamp Households, prepared by Mathematica Policy Research,
Inc., for FNS. These reports are based on FNS' Integrated Quality
Control System, which uses a national probability sample of
participating food stamp households, denials of applications, and
terminations to monitor the accuracy of the Food Stamp Program's
operations. Table II.1: Selected Demographic Characteristics of
Food Stamp Participants in thousands Participants, Fiscal
Years 1996-97
Change in Characteristic of Fiscal year Fiscal
year number of Percent participants
1996 1997 participants change
Childrena 13,212 11,868
1,344 10.2 Preschool age 4,815
4,046 769 16.0 School age
8,399 7,825 574 6.8
Adults with dependents 7,582
6,549 1,033 13.6 Able-bodied adults without
dependents 1,107 833
274 24.8 Permanent resident aliens
1,463 1,023 440 30.1
Elderlyb 1,895 1,834
61 3.2 Disabled c
2,278 c c aChildren are
defined as individuals who are 0-17 years old. Preschool-age
children are under the age of 5 and school-age children are 5-17
years old. bElderly people are defined as individuals who are 60
years old and over. cData unavailable for fiscal year 1996.
Source: FNS, Characteristics of Food Stamp Households, for fiscal
years 1996-97. Page 29
GAO/RCED-99-185 Food Stamp Participation Appendix II Changes in
Participation Among Selected Food Stamp Populations Table II.2:
Permanent Resident Aliens Who Received Food Stamps, Fiscal Years
1994-97 Participants in thousands Percent Fiscal year 1994
Fiscal year 1995 Fiscal year 1996 Fiscal
year 1997 change State
Total Percenta Total Percenta Total
Percenta Total Percenta (FY 1996-97) California
463 13.2 431 13.2 445
13.5 302 10.4 32.1 Florida
132 8.8 127 8.9 157
10.9 103 8.4 34.4 New York
245 10.8 273 12.8 265
12.4 196 10.0 26.0 Texas
297 10.9 247 9.5 246
10.0 165 7.8 32.9 All other
316 1.8 373 2.1 350
2.1 256 1.7 26.9 Total
1,453 5.2 1,451 5.4 1,463
5.6 1,023 4.4 30.1 aPercentage of
each state's total food stamp participants. Source: FNS,
Characteristics of Food Stamp Households, for fiscal year 1997.
Table II.3: Change in AFDC/TANF and Food Stamp Participation Since
the Enactment of the Welfare Reform Act, August 1996 to August
1998 Participants in thousands AFDC/TANF participantsa
Food stamp participants State August 1996
August 1998 Percent change August 1996 August
1998 Percent change Alabama 100.7
53.1 47.3 505.1 415.6
17.7 Alaska 35.5
28.6 19.4 47.8 42.9
10.3 Arizona 169.4
101.0 40.4 424.9 276.0
35.0 Arkansas 56.3
31.7 43.7 274.6 253.3
7.8 California 2,581.9
1,952.2 24.4 3,076.1
2,131.2 30.7 Colorado
95.8 49.0 48.9
237.8 182.3 23.3 Connecticut
159.2 122.1 23.3
224.0 188.3 15.9 Delaware
23.7 15.0 36.7
59.4 43.3 27.1 Florida
533.8 247.8 53.6
1,356.1 952.1 29.8 Georgia
330.3 175.8 46.8
776.8 606.2 22.0 Hawaii
66.5 46.4 30.2
130.4 121.4 6.9 Idaho
21.8 3.5 83.9
76.2 56.3 26.1 Illinois
642.6 460.7 28.3
1,091.3 877.7 19.6 Indiana
142.6 116.5 18.3
372.6 302.0 18.9 Iowa
86.1 65.2 24.3
174.6 134.4 23.0 Kansas
63.8 34.1 46.6
167.5 116.3 30.6 Kentucky
172.2 115.8 32.8
472.6 398.9 15.6 Louisiana
228.1 122.6 46.3
644.1 526.3 18.3 Maine
53.9 38.4 28.8
129.6 110.2 15.0 (continued) Page
30 GAO/RCED-99-185
Food Stamp Participation Appendix II Changes in Participation
Among Selected Food Stamp Populations Participants in thousands
AFDC/TANF participantsa Food
stamp participants State August 1996
August 1998 Percent change August 1996 August 1998
Percent change Maryland 194.1
111.6 42.5 364.6 307.4
15.7 Massachusetts 226.0
165.6 26.7 367.8 275.4
25.1 Michigan 502.4
315.9 37.1 906.3 743.6
18.0 Minnesota 169.7
145.1 14.5 287.5 217.9
24.2 Mississippi 123.8
47.7 61.5 447.7 312.4
30.2 Missouri 222.8
141.3 36.6 539.7 403.1
25.3 Montana 29.1
20.1 30.9 69.2 60.8
12.1 Nebraska 38.6
35.9 7.0 101.0 96.1
4.9 Nevada 34.3
24.7 28.0 93.8 66.2
29.4 New Hampshire 22.9
14.5 36.7 50.2 35.3
29.7 New Jersey 275.6
186.1 32.5 530.3 403.0
24.0 New Mexico 99.7
77.5 22.3 231.4 178.0
23.1 New York 1,144.0
872.1 23.8 2,060.5 1,604.8
22.1 North Carolina 267.3
166.1 37.9 605.2 506.4
16.3 North Dakota 13.1
8.5 35.1 38.4 33.7
12.2 Ohio 549.3
323.3 41.1 988.0 684.9
30.7 Oklahoma 96.2
59.0 38.7 337.8 283.7
16.0 Oregon 78.4
44.6 43.1 279.8 223.4
20.2 Pennsylvania 531.1
352.3 33.7 1,088.3 877.1
19.4 Rhode Island 56.6
54.2 4.2 93.5 55.9
40.2 South Carolina 114.3
54.7 52.1 359.8 324.3
9.9 South Dakota 15.9
9.4 40.9 49.3 45.1
8.5 Tennessee 254.8
148.5 41.7 627.5 527.3
16.0 Texas 649.0
349.6 46.1 2,260.1 1,510.2
33.2 Utah 39.1
28.0 28.4 107.2 89.0
17.0 Vermont 24.3
19.2 21.0 54.1 28.1
48.1 Virginia 152.8
95.6 37.4 525.9 374.5
28.8 Washington 268.9
194.9 27.5 487.3 339.0
30.4 West Virginia 89.0
37.8 57.5 293.1 257.2
12.2 Wisconsin 148.9
35.5 76.2 262.0 174.0
33.6 Wyoming 11.4
1.9 83.3 31.6 23.9
24.4 District of Columbia 69.3
54.4 21.5 90.1 81.7
9.3 Guam 8.3
7.0 15.7 18.2 17.2
5.5 Puerto Rico 151.0
119.2 21.1 b b
b Virgin Islands 4.9
4.4 10.2 23.1 16.5
28.6 Total 12,241.5
8,105.8 33.8 24,911.8 18,911.7
24.1 (Table notes on next page) Page 31
GAO/RCED-99-185 Food Stamp Participation Appendix II Changes in
Participation Among Selected Food Stamp Populations Note: Columns
may not add because of rounding. aThe 1996 Welfare Reform Act
replaced the Aid to Families with Dependent Children (AFDC)
program with the Temporary Assistance for Needy Families (TANF)
block grant. bData unavailable because Puerto Rico receives block
grant funding. Source: FNS and the Administration for Children and
Families, Department of Health and Human Services. Table II.4:
Food Stamp Participation by TANF Participants and Non-TANF
Participants in thousands Participants, Fiscal Years 1996-97
Characteristic of Fiscal year
Fiscal year participants 1996
1997 Difference TANF recipients
12,459 10,649 1,810 Non-TANF
recipients 13,466
12,468 998 Source: FNS, Characteristics of Food
Stamp Households, for fiscal years 1996-97. Table II.5: Age
Distribution of Food Stamp Participants, Fiscal Years
Participants in thousands 1989-97
Age distribution 0 to 17 18 to 59 60 years
Fiscal year years
years and older 1989
9,442 7,621 1,561 1990
10,139 8,244 1,574 1991
11,960 9,396 1,623 1992
13,364 10,698 1,704 1993
14,211 11,498 1,870 1994
14,407 11,615 1,955 1995
13,879 11,117 1,923 1996
13,212 10,782 1,895 1997
11,868 9,384 1,834 Note:
Children are defined as individuals who are 0-17 years old.
Source: FNS, Characteristics of Food Stamp Households, for fiscal
year 1997. Page 32
GAO/RCED-99-185 Food Stamp Participation Appendix II Changes in
Participation Among Selected Food Stamp Populations Table II.6:
Number of Children Who Received Food Stamps, by State,
Participants in thousands Fiscal Years 1995-97
Fiscal year Fiscal year Fiscal year Percent change State
1995 1996 1997 (FY 1995-97) Alabama
281 273 240 14.6 Alaska
24 27 25 4.2 Arizona
284 233 219 22.9 Arkansas
133 136 125 6.0 California
2,035 2,042 1,808 11.2 Colorado
126 125 112 11.1 Connecticut
128 107 107 16.4 Delaware
28 30 28 0.0 Florida
720 715 600 16.7 Georgia
421 422 368 12.6 Hawaii
61 53 62 1.6 Idaho
41 40 36 12.2 Illinois
581 545 528 9.1 Indiana
219 188 161 26.5 Iowa
93 84 79 15.1 Kansas
99 88 76 23.2 Kentucky
224 212 203 9.4 Louisiana
385 362 298 22.6 Maine
53 51 51 3.8 Maryland
206 200 186 9.7 Massachusetts
232 190 181 22.0 Michigan
490 460 426 13.1 Minnesota
163 152 121 25.8 Mississippi
250 220 188 24.8 Missouri
292 276 241 17.5 Montana
34 37 32 5.9 Nebraska
53 52 51 3.8 Nevada
56 52 44 21.4 New Hampshire
28 27 22 21.4 New Jersey
284 282 250 12.0 New Mexico
126 125 110 12.7 New York
951 964 892 6.2 North
Carolina 300 304 276
8.0 North Dakota 19 17
19 0.0 Ohio 575
488 404 29.7 Oklahoma
187 164 157 16.0 (continued)
Page 33 GAO/RCED-99-185
Food Stamp Participation Appendix II Changes in Participation
Among Selected Food Stamp Populations Participants in thousands
Fiscal year Fiscal year Fiscal year Percent
change State 1995
1996 1997 (FY 1995-97) Oregon
139 131 112 19.4
Pennsylvania 536 513
470 12.3 Rhode Island 50
48 45 10.0 South Carolina
199 191 182 8.5
South Dakota 28 24
25 10.7 Tennessee 315
284 272 13.7 Texas
1,406 1,320 1,192 15.2
Utah 65 58
55 15.4 Vermont 30
27 22 26.7 Virginia
276 261 232 15.9
Washington 249 247
206 17.3 West Virginia 124
124 114 8.1 Wisconsin
186 159 130 30.1
Wyoming 19 17
15 21.1 District of Columbia
52 48 50 3.8
Guam 10 10
12 20.0 Virgin Islands 15
15 12 20.0 Total
13,882 13,214 11,871
14.5 Note: Columns may not add because of rounding. Source: FNS,
Characteristics of Food Stamp Households, for fiscal years 1995-
97. Table II.7: Number of School-Age Children Receiving Food
Stamps Children in thousands Compared With the Number of
Type of Fiscal year Fiscal year Fiscal
year Fiscal year Percent Children Receiving Free
Lunches in assistance 1994
1995 1996 1997 change School,
Fiscal Years 1994-97 School-age children receiving food
stamps 9,558 8,784
8,399 7,825 18.1 Children receiving free
lunches at school 12,191 12,492
12,657 12,973 6.4 Note: School-age
children are defined as 5-17 years old. Source: FNS, Office of
Analysis and Evaluation, and Characteristics of Food Stamp
Households, for fiscal years 1994-97. Page 34
GAO/RCED-99-185 Food Stamp Participation Appendix III FNS' Program
Access Reviews Reveal Barriers to Participation During the past
year, FNS regional offices have reviewed access to the Food Stamp
Program in New York, Oregon, and Wisconsin in response to
complaints from advocacy groups and a Member of Congress. Each of
these reviews identified barriers that have made the program less
accessible to eligible people. New York City In March 1998, New
York City began converting welfare offices to job centers. The job
centers were designed to reduce dependency on government services
by diverting potential applicants from government programs by
requiring them to find employment or other, private sources of
assistance. For example, to be eligible for TANF and food stamps,
applicants first had to search extensively for a job and explore
alternative resources, such as private food pantries, family, or
friends. In November 1998, FNS launched a review of access to New
York City's Food Stamp Program after receiving complaints from
advocacy groups that needy individuals were not being given the
opportunity to apply for food stamps during their first visit to a
job center. FNS' review of two New York City job centers found
many barriers to access, including impediments to the timely
processing of applications, the imposition of eligibility
standards not authorized under the Food Stamp Act, and a lack of
effective oversight of local districts' operations by the state
agency. In particular, FNS found that New York City violated
federal law because caseworkers (1) did not permit households to
apply for food stamps during their first visit, (2) did not inform
applicants about the availability of food stamps if the applicants
either were denied TANF benefits or accepted a diversion payment,1
and (3) frequently denied food stamp benefits to applicants for
failure to participate in a job center's employment-related
activities or Eligibility Verification Reviews. In addition, the
food stamp director of FNS' Northeast regional office told us that
job center staff were informing applicants that expedited food
stamps were no longer available, refusing to accept food stamp
applications because it was "too late" in the day, and encouraging
applicants to withdraw their food stamp applications. Because
these policies violate the Food Stamp Act, FNS ordered New York to
submit a corrective action plan to resolve the identified
problems. In response, New York State and New York City officials
have stated that some job center practices help end government
dependency, prevent fraud, and protect applicants' rights.
According to FNS, New York City officials believe they have the
right to 1New York City's job centers included a brochure
explaining food stamp eligibility in their application packages,
which were made available only after applicants returned for a
second visit. In contrast, Alaska has mailed food stamp notices to
many households. Page 35
GAO/RCED-99-185 Food Stamp Participation Appendix III FNS' Program
Access Reviews Reveal Barriers to Participation interpret the
Welfare Reform Act for themselves and develop policies and
procedures on the basis of their interpretations because FNS has
not issued regulations that implement the Welfare Reform Act's
revisions. Nevertheless, New York State submitted a corrective
action plan that FNS concluded was generally responsive to its
findings; however, FNS notified New York State officials that if
the corrective action plan was not implemented by May 1999, it
would institute a fine of $5 million every 3 months. In April
1999, New York City officials implemented New York State's
corrective action plan, addressing FNS' concerns. To reduce their
welfare rolls, 22 states, including New York, are currently using
diversion payments, or onetime, lump-sum cash payments, which are
designed to keep people off welfare by eliminating their need for
assistance. While accepting a diversion payment disqualifies an
applicant from the TANF program for a specified time, it does not
affect the applicant's food stamp eligibility, and the states have
a legal obligation to inform applicants that they can still apply
for food stamps. All 22 states reported that they have procedures
in place for ensuring that qualified applicants are told of their
right to apply for food stamps. However, FNS found that applicants
in New York City's job centers were not being told of the
availability of food stamps if they accepted a diversion payment.
Portland, Oregon In December 1998, FNS reviewed clients' access
to the Food Stamp Program at three Portland-area offices after an
advocacy group complained that food stamp applicants' rights were
being violated. FNS found that the offices' procedures could
hinder participation by forcing food stamp applicants to return on
a second day before meeting with an eligibility worker. During its
on-site review, FNS found that food stamp applicants and current
participants could make an appointment to meet with a food stamp
eligibility worker to apply or seek recertification for food
stamps only between 7:30 a.m. and 8:30 a.m. (The office would give
an application to an applicant arriving after 8:30 a.m. but would
ask the applicant to return on another day for an appointment.)
FNS observed that more applicants were showing up during this 1-
hour period than could possibly be served in a single day. Hence,
an applicant could wait all day, only to be told at the close of
business to return on another day. FNS ordered Oregon to submit a
corrective action plan that outlined how this situation and other
identified problems would be resolved. Although Oregon officials
questioned some of FNS' findings and recommendations, they
submitted a corrective action plan that addressed FNS' concerns.
Page 36 GAO/RCED-99-185 Food
Stamp Participation Appendix III FNS' Program Access Reviews
Reveal Barriers to Participation Milwaukee, Wisconsin Wisconsin
has privatized 13 welfare centers, including 6 centers in
Milwaukee that serve Wisconsin's TANF and Food Stamp programs. In
the privatized centers, various nonprofit and for-profit
organizations administer the TANF program while county employees
administer the Food Stamp Program. In March 1999, FNS reviewed
participants' access to the privatized welfare centers after
receiving a letter from a Member of the Congress, who expressed
concern that the efforts to divert TANF applicants may also limit
clients' access to the Food Stamp Program. Although FNS found that
some practices violated federal regulations, it did not find that
applicants were being intentionally diverted from applying for
food stamps in the two centers reviewed. However, FNS observed
that diversion might be occurring unintentionally because staff at
the centers were not (1) informing clients of their right to file
a food stamp application on the day of their first contact with
the office and (2) providing a food stamp application to those who
asked for one. In addition, clients' work schedules were not taken
into account when recertification interviews were scheduled, and
one center did not accept food stamp applications after 4 p.m.
Furthermore, the centers did not make informational brochures on
the Food Stamp Program readily available and did not display
posters outlining food stamp applicants' rights. According to FNS
officials, when these signs are posted in welfare centers,
applicants have an opportunity to read about their rights as food
stamp applicants and obtain telephone numbers to use if they
believe they are being treated unfairly. Five of seven food stamp
directors in FNS' regional offices believe the signs are helpful
for ensuring that food stamp applicants know and understand their
rights. FNS officials stated that while FNS cannot require that
welfare centers post signs to inform applicants of their rights,
FNS has the authority to require that welfare centers find
alternative means of providing information to applicants about
their rights if posters are not used.2 In a February 5, 1999,
letter, FNS told New York State that it must "post signs or make
available other advisory materials explaining an applicant's right
to file and the application processing procedures. . . ." USDA's
Office of General Counsel concurred with this statement. 2In Apr.
1999, FNS implemented a toll-free 800 number that customers can
call to receive information about the Food Stamp Program. Page 37
GAO/RCED-99-185 Food Stamp Participation Appendix IV States
Reviewed by FNS Concerning Participants' Access to Food Stamp
Benefits, Fiscal Years 1997-99 State Fiscal year 1997
Fiscal year 1998 Fiscal year 1999 Alabama
X b Alaska X
a Arizona
b Arkansas X X
b California X X
b Colorado X X
X Connecticut X
X Delaware
b Florida X
X Georgia X
b Hawaii X Idaho
X b Illinois Indiana Iowa
X X b Kansas
X X X Kentucky
X Louisiana X X
X Maine X Maryland
X Massachusetts X Michigan
Minnesota Mississippi X
Missouri X X
b Montana X X
X Nebraska X X
X Nevada
X New Hampshire X New Jersey
X b New Mexico
X X b New York
X North Carolina X
b North Dakota X X
b Ohio Oklahoma X X
b Oregon X
Xc Pennsylvania X
b (continued) Page 38 GAO/RCED-99-185 Food
Stamp Participation Appendix IV States Reviewed by FNS Concerning
Participants' Access to Food Stamp Benefits, Fiscal Years 1997-99
State Fiscal year 1997 Fiscal
year 1998 Fiscal year 1999 Rhode Island
X South Carolina
X South Dakota X
X b Tennessee
X Texas X
X b Utah
X X X Vermont
Virginia
b Washington
X X West Virginia
X X b Wisconsin
Xc Wyoming X
X b District of Columbia
b Total 22
32 14 aThe FNS regional office has yet to
determine what functional areas will be included in reviews of the
states' operations. bFNS regional offices plan to review program
access in these states. cFNS conducted program access reviews in
Oregon and Wisconsin in response to complaints during fiscal year
1999. Source: FNS regional offices. Page 39
GAO/RCED-99-185 Food Stamp Participation Appendix V Comments From
New York State Note: GAO comments supplementing those in the
report text appear at the end of this appendix. See comment 1. See
comment 2. Page 40 GAO/RCED-99-185 Food Stamp Participation
Appendix V Comments From New York State See comment 3. See comment
4. Page 41 GAO/RCED-99-185 Food Stamp
Participation Appendix V Comments From New York State See comment
5. See comment 6. Page 42 GAO/RCED-99-185
Food Stamp Participation Appendix V Comments From New York State
GAO's Comments The following are GAO's comments on New York
State's letter dated June 16, 1999. 1. This report does not
discuss participation in individual states. 2. This point is
clarified on page 12 of the report. 3. This point is clarified on
page 13 of the report. 4. This point is clarified on page 13 of
the report. 5. This report does not discuss individual states'
perceptions of the role of the Food Stamp Program. 6. We disagree.
The three USDA reviews discussed in this report identified
barriers that have made the Food Stamp Program less accessible for
eligible people. Page 43
GAO/RCED-99-185 Food Stamp Participation Appendix VI Comments From
Wisconsin Page 44 GAO/RCED-99-185 Food Stamp Participation
Appendix VI Comments From Wisconsin Page 45
GAO/RCED-99-185 Food Stamp Participation Appendix VII GAO Contacts
and Staff Acknowledgments GAO Contacts Lawrence J. Dyckman
(202) 512-5138 Richard Cheston (202) 512-5138 Acknowledgments
In addition to those named above, Carl Christian, Nikki Clowers,
Donald Ficklin, and Luann Moy made key contributions to this
report. (150079) Page 46
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