Improving Program Access to Working Families
16 April 2002
Subject: Improving Program Access to Working Families
To: Regional Administrators / All Regions
As you know, Under Secretary Bost has announced a major initiative to
improve access to food stamp benefits. In connection with this initiative,
we are asking you, as you meet and correspond with your State counterparts,
to encourage those State agencies that have not already done so to consider
seriously adopting provisions currently available to simplify operations
and improve program access for households with earnings. Adopting
any of these provisions will help improve program access for the working
poor, significantly reduce workload burden on local staffs, and improve
payment accuracy. In this regard, the option for Semi-Annual Reporting
(SAR), the provision for waiving the face-to-face interview for households
with earnings, and the option for adopting State cash assistance vehicle
rules have a great deal of potential.
As you are aware, the Noncitizen Eligibility and Certification Provisions
rule, published November 20, 2000, established SAR as new reporting option.
Since publication of that rule, almost 20 State agencies have recognized
the positive potential of SAR.
Some have adopted SAR as provided for in the regulations. Others
have obtained a waiver of 7 CFR 273.12(a) to enable them to establish
an SAR that is more compatible with their other programs or computer systems.
Your staff has been instrumental in working with these State agencies
to implement SAR. However, the State agencies that have not adopted
some form of SAR should be made aware of its advantages.
For working food stamp recipients, SAR provides a relatively steady food
stamp benefit amount for up to 6 months. The reporting burden on
households is significantly reduced, primarily to only income changes
that exceed the 130 percent threshold. Generally, benefits are only
affected by changes known to the State agency (such as changes to a Temporary
Assistance for Needy Families (TANF) grant or a cost-of-living mass change),
income increases that make the household ineligible, and any additional
changes the household chooses to report.
For State agencies, this reporting system has the potential to reduce
error rates significantly and to reduce the eligibility worker’s workload
through longer certification periods and a significant reduction in the
number of changes required to be processed. State agencies can move
to SAR quickly, thereby obtaining an immediate impact on workloads and
payment accuracy. This can be achieved either through adoption of
the regulatory procedure or through a waiver. We will move quickly
to approve waiver requests.
The November 21, 2000, final rule reinforced the obligation of State
agencies to offer to waive the face-to-face interview when a household
would face a hardship in attending an in-office interview. The State
agency has the discretion to define the hardship conditions that would
warrant such a waiver. Use of this provision is one means of insuring
program access to wage earners who would otherwise lose income by taking
off work to attend an interview. State agencies may also offer expanded
work hours to make it more convenient for the working poor to apply for
Public Law 106-387, effective July 1, 2001, provides an option to State
agencies allowing them to substitute the TANF vehicle policy for the food
stamp policy, if the TANF policy is more beneficial to the applicant food
stamp household. Several States have not yet taken advantage of
this option. The option is clearly beneficial to low-income workers
who need a modest, but reliable, vehicle to accept and maintain employment.
The State agency also can benefit from a less complex vehicle evaluation
policy and an attendant increase in payment accuracy.
We see full use of these procedures and options as a win-win situation
for everyone, having a very positive effect on Program operations.
Offering encouragement to State agencies to consider and adopt these procedures
and options is a critical step you can take at this time to improve the
Food Stamp Program operations in your States.
/s/ Bonny O’Neil for
George A. Braley