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Supplemental Nutrition Assistance Program: Improved Oversight of State Eligibility Expansions Needed

GAO-12-670 Published: Jul 26, 2012. Publicly Released: Jul 30, 2012.
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What GAO Found

In fiscal year 2010, GAO estimates that 2.6 percent (473,000) of households that received Supplemental Nutrition Assistance Program (SNAP) benefits would not have been eligible for the program without broad-based categorical eligibility (BBCE) because their incomes were over the federal SNAP eligibility limits. The characteristics of these households were generally similar to other SNAP households, although they were more likely to work or receive unemployment benefits. BBCE removes asset limits in most states, and while reliable data on participants’ assets are not available, other data suggest few likely had assets over these limits. Although BBCE contributed to recent increases in SNAP participation, other factors, notably the recent recession, had a greater effect.

GAO estimates that BBCE increased SNAP benefit costs, which are borne by the federal government, by less than 1 percent in fiscal year 2010. In that year, total SNAP benefits provided to households that, without BBCE, would not have been eligible for the program because their incomes were over the federal SNAP eligibility limits were an estimated $38 million monthly or about $460 million for the year. These households received an estimated average monthly SNAP benefit of $81 compared to $293 for other households. BBCE’s effect on SNAP administrative costs, which are shared by the federal and state governments, is unclear, in part because of other recent changes that affect this spending, such as state budget and staffing reductions in the recent recession.

BBCE has potentially had a negative effect on SNAP program integrity. In recent years, the SNAP payment error rate declined to an historic low, but evidence suggests the decline is primarily due to changes other than BBCE. While BBCE may improve administrative efficiency, both national data and discussions with local staff suggest BBCE may also be associated with more errors. In addition, BBCE has led to unintended consequences for SNAP and related programs. For example, in implementing BBCE, some states are designating SNAP applicants as categorically eligible without providing them with the service required to make this determination. Further, likely because they are unaware of recent USDA guidance, some states certify children for free school meals when their households are determined eligible for SNAP, even though they do not receive SNAP benefits—a result more common in states with BBCE. Finally, because of federal guidance on BBCE, rules for reporting changes in household circumstances now differ by household income level and may leave higher income households without reporting requirements for several months.

Why GAO Did This Study

Over the last 10 years, participation in the U.S. Department of Agriculture’s (USDA) SNAP, previously known as the Food Stamp Program, has more than doubled, and costs have quadrupled. Since 1999, USDA has allowed states to expand SNAP eligibility by adopting BBCE policies, which make households that receive services funded by Temporary Assistance for Needy Families, such as a toll-free number or brochure, categorically eligible for SNAP. Under BBCE policies, states are able to increase federal SNAP limits on household income and remove limits on assets. Although USDA has encouraged states to adopt BBCE to improve SNAP access and administration, little is known about the effects of these policies. GAO was asked to assess: (1) To what extent are households that would otherwise be ineligible for SNAP deemed eligible for the program under BBCE? (2) What effect has BBCE had on program costs? (3) What are the program integrity implications of BBCE? GAO analyzed data from USDA, selected states, and other national sources; conducted site visits to 5 states; and interviewed federal, state, and local officials, as well as others with knowledge of SNAP.

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GAO recommends that USDA review state procedures for implementing BBCE, disseminate guidance to states on certifying SNAP households as eligible for school meals, and revisit its guidance on SNAP reporting requirements to ensure they address all households. USDA generally agreed with GAO’s recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Agriculture To improve SNAP program integrity and oversight, the Secretary of Agriculture should require FNS to review state procedures for implementing BBCE, specifically those in place for providing the relevant Temporary Assistance for Needy Families (TANF)-funded service to all SNAP applicants deemed eligible under BBCE, as well as ensuring the relevant service is funded with TANF dollars.
Closed – Implemented
USDA's Food and Nutrition Service (FNS) reported that it developed a detailed policy memorandum to states on procedures for implementing broad-based categorical eligibility (BBCE), including the requirements outlined in SNAP regulations at 7 CFR 273.2. These requirements include that BBCE can only be conferred to SNAP applications that receive or are authorized to receive service from a TANF program that meets regulatory requirements; and states must note in the case file which cases have been approved under BBCE. In July 2016, FNS reported that this memo will be issued soon. FNS further said it continues to provide guidance and technical assistance as needed to ensure the proper application of BBCE policy.
Department of Agriculture To improve SNAP program integrity and oversight, the Secretary of Agriculture should require FNS to disseminate the agency's October 2011 guidance clarifying that children in households certified as eligible for $0 in SNAP benefits should not be directly certified to receive free school meals directly to state agencies administering SNAP.
Closed – Implemented
In August 2012, FNS updated the "Eligibility Manual for School Meals" and included clarification that children in households certified as eligible for $0 in SNAP benefits should not be directly certified to receive free school meals. Additionally, in August 2013, FNS issued guidance to state agencies administering SNAP and those administering school meals in which USDA reiterated its policy regarding children in households certified as eligible for $0 in SNAP benefits. USDA also invited both groups of state agencies to participate in a webinar that discussed this issue, which was held in that month.
Department of Agriculture To improve SNAP program integrity and oversight, the Secretary of Agriculture should require FNS to revisit agency guidance on change reporting requirements to ensure that all households, including those deemed eligible under BBCE with incomes above the federal gross income limit, are treated equitably.
Closed – Not Implemented
Following GAO's report, in September 2015, the USDA Inspector General similarly reported this issue in its findings on the SNAP quality control system and implementation of the BBCE policy. On July 18, 2016, FNS indicated that it is committed to integrity and equity in SNAP and continues to work to ensure that all SNAP households are treated equitably. However, FNS has not made any changes to the reporting requirements.

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