As you may know, a Congressional conference committee has finally gotten around to producing a proposed compromise Farm Bill. The Title IV of Nutrition Title of the proposed Farm Bill covers the Supplemental Nutrition Assistance Program (SNAP) – formally known as the Food Stamp Program – and other nutrition programs. While reading the Center on Budget and Policy Priority’s (CBPP) summary of Title IV of the Agriculture Act of 2014 (http://www.cbpp.org/cms/index.cfm?fa=view&id=4082),
I found a few things very interesting:
1) For SNAP, not much actually changes.
The new requirements are mostly tweaks to existing policies.
2) Requiring states to use Health & Human Service’s National Directory of New Hires (NDNH) data match when determining eligibility.
On the surface this seems pretty straightforward and useful. However, the NDNH data isn’t that helpful. In the recent past, as Indiana’s Temporary Assistance for Needy Families (TANF) Policy Manager, I oversaw the implementation of a NDNH match of adult TANF recipients. The vast majority of matches were regarding known employment or employment that had no bearing upon eligibility. More annoying is that using the NDNH requires states to track and report the results of the NDNH matches. All of which equates to extra work with little return. There’s also an extra cost to SNAP agencies as they will be required to pay to HHS for the use of NDNH.
3) Prohibiting ex-felons convicted of violent crimes from receiving SNAP benefits unless they are in compliance with the terms of their parole agreement.
I’ve no problem with ex-felons receiving SNAP benefits but how will a state SNAP caseworker know whether or not an ex-felon is or isn’t in compliance with his parole agreement? This is similar to the existing issue with the fleeing felon prohibition.
4) CBPP’s insistence that SNAP is the most error free of the major welfare programs because SNAP Quality Control (QC) data shows that more than 98% of SNAP benefits were issued to eligible households.
Admittedly this is a pet peeve of mine. The trend over the last five years has been states figuring out how to use loop holes and procedural maneuvers to lower their SNAP QC requirements. For example, states have purposely suppressed data matches so that data wouldn’t be ‘known’ to the state. More frightening is states decreasing QC staff or instructing QC reviewers to very narrowly review cases. This criticism isn’t limited to SNAP. TANF programs use similar tactics to meet TANF work participation requirements whether it is moving families not meeting the work rate to a solely state funded, non-Maintenance of Effort (MOE) program so that the family isn’t included in the work participation rate (WPR) or claiming excess MOE to reduce the state’s WPR target.
The wonder of a QC program is that it gives an agency a chance to see its problems and address the root cause. Shuffling data may avoid fiscal sanctions but it does not fix underlying problems.
5) SNAP Employment and Training (E&T) Requirements
SNAP E&T has been a bit of touchy issue for the past few years. The SNAP E&T Provision in the Farm Bill offers a little bit of everything: tightening of federal oversight of the E&T programs, pilot programs for states desiring to implement more rigorous standards – even the option of implementing a program based upon the TANF work requirements – , and a few more federal dollars to cover some of the increased costs. However, the bottom line remains that the SNAP E&T program is a fifty/fifty cost share, so increased activities require increased state funds to run the program.