SNAP Applications and the Affordable Care Act
As States implement application and process changes for the Patient Protection and Affordable Care Act (ACA), States look to the Food and Nutrition Service (FNS) for technical assistance on the Supplemental Nutrition Assistance Program (SNAP) application issues and policy compatibility. This memorandum provides Regional Offices with guidance as they work with States to ensure that online and paper SNAP applications meet Federal requirements and are user-friendly, understandable and effective.
As part of the October 1, 2013, roll out of open enrollment under ACA, State agencies across the country are reviewing and updating applications to conform to ACA's Medicaid-related provisions. Many States have multi-benefit applications for both SNAP benefits and other health and human services programs like Medicaid. They are now facing the challenging task of implementing changes required by ACA while complying with existing SNAP requirements.
New ACA requirements are significant, but they do not affect existing laws and regulations governing SNAP and do not change SNAP application policies. Since updates to applications can have unintended impacts on SNAP content and functionality, strict adherence to SNAP regulations and guidance is imperative.
FNS encourages the use of multi-benefit applications as they provide inherent administrative, workload, and access advantages to State agencies and SNAP clients. At the same time, faced with limited resources and time constraints, some States are temporarily de-coupling integrated systems and applications in order to stand up new applications in time for the October 1, 2013, deadline. Federal-State collaboration will be a key tool to support continued integration.
While FNS does not approve State applications, all applications should be reviewed for compliance with SNAP requirements when modifications are made; this is particularly important as States implement wide-ranging changes associated with the ACA requirements for Medicaid. The timing of these reviews is up to each Regional Office working with their States, but all State applications should be examined by the end of Fiscal Year 2014. These reviews can be part of State-level Management Evaluation review or can be conducted independently.
States must notify FNS whenever existing applications are modified and new online application systems are launched so that FNS can help quickly address any areas that do not comply with SNAP policy. If States do not adhere to SNAP rules and guidelines, action must be taken to correct instances of non-compliance.
To ensure that all FNS offices are measuring compliance using standardized methods, FNS has developed an Online Application Checklist that is enclosed with this memorandum and included in the Program Access Review Guide released in January 2013.
In preparing to review States' paper applications, staff may find it useful to review the guidance and technical assistance materials available at SNAP's Program Improvement page at: http://www. fns. usda. gov I snap/ government/program-improvement.htm. In addition, it may be helpful to consider the recent guidance provided to States regarding ACA and their Medicaid applications.