On October 10, NGA hosted a call on the SNAP Quality Control Continuum as part of its SNAP 101 series to build awareness of SNAP operations and protocol, given the new requirements instituted in H.R.1. The briefing featured a presentation from Chloe Green, the Assistant Director of Policy at APHSA, to shed light on the quality control process’s impact on state administration and program integrity efforts.
Interested state staff can reach out to Jess Kirchner (jkirchner@nga.org) to receive a copy of the presentation.
Critical State Considerations
- Federally enforced siloes: USDA limits the ability of state quality control teams to work with state SNAP policy teams, which impacts a state’s ability to react to issues driving SNAP error rates in real-time.
- Small sample sizes impact representations: To determine error rate, states sample an average of 1,000 cases per year, and USDA re-evaluates only a portion of these cases from states. Given the small sample size that feeds the national numbers, states have raised flags about the disproportionate effect of errors and have questioned whether these sample sizes are representative of a state’s full SNAP population.
- States may not know their status until it’s too late: The USDA team conducts federal assessments after states have completed their own efforts to assess their payment error rate. However, states are given no advance warnings about any discrepancy with their estimated error rate and find out their federal error rate when the numbers are posted publicly in June. Following the signing into law of H.R.1, a 1% difference between these two numbers could represent millions of dollars in new cost-share penalties for states.
- State eligibility workers are penalized for not being fortune tellers: USDA’s reviews are performed within a specific sample month, which does not aptly consider the information available to an eligibility worker on the day that a consumer came into a program.
- In other words, if a consumer experiences a life change that renders them ineligible between the time of original determination and the sample month, a states’ error rate is negatively impacted despite an eligibility worker making the correct decision at the time of assessment.
Understanding the SNAP Quality Control Process
The purpose of the SNAP QC process is to assess if SNAP payments are being issued correctly and at the right amount to households.
- FNS’s 310 Handbook dictates the parameters for the QC process
- The handbook is 400 pages and is updated about every two years
The QC process assesses several factors, including:
- Timeliness
- Case and Procedural Error Rates
- Payment Error Rates
The SNAP Quality Control Continuum
What Can Cause Payment Errors?
- Outdated state eligibility systems require expensive and complicated technological investments to update systems to perform necessary operations.
- Longstanding workforce challenges in state agencies, including high rates of retirements, low retention rates that have led to empty seats, heavy workloads and inexperienced staff.
- States have been penalized during QC process for taking advantage of permitted and promoted flexibilities, like relaxed consumer shelter requirements for homeless applicants.
- Rapidly changing federal policy guidelines have given state staff whiplash, especially in the years post-pandemic–staff training and outdated tech eligibility systems can’t keep up
