|DATE:||April 16, 2002|
|SUBJECT:||Improving Program Access to Working Families|
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 Nov. 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 Nov. 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 benefits.
PL 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.
George A. Braley
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.