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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