Across the sites, we found most eligibility workers are relatively well versed with general non-citizen eligibility rules. For instance, they are readily able to point out that citizen children in mixed status families are eligible for benefits; undocumented immigrants are ineligible; and legal immigrants are eligible except for those affected by the five-year bars and food stamp work requirements. Workers navigate the complexity of the immigrant eligibility rules primarily by relying on immigration documents in conjunction with charts that crosswalk program eligibility with these documents.
In most cases, workers can easily determine if a person is eligible — all else equal — by the type of document they provide on their current immigrant status. All sites except Seattle then verify applicants' immigration documents by submitting key information to INS through the Systematic Alien Verification Entitlement (SAVE) system electronically or via telephone.1 Workers reported that SAVE generally responds to inquiries within a day or two and delays are rare.2
The advantage of the document-driven approach is that it is relatively simple and straightforward for workers to implement and works well for the majority of cases where non-citizens do in fact have common types of immigration documents. To be effective, however, it is also critical that agencies update immigrant eligibility/documentation charts to keep them accurate and that non-citizens present their most current documents so that they are not denied benefits incorrectly. Non-citizen eligibility rules continue to be most challenging and error-prone on the margins, in cases where the non-citizen applicant has a less common immigration status (for instance, an asylee), or where the applicant presents an uncommon document (e.g., a letter from INS stating she or he is an applicant for permanent residency).
Some agencies also rely on more experienced workers or specialized units to handle non-citizen eligibility (e.g., the immigrant and refugee offices in New York City and the refugee unit in Dallas) or have offices located in areas with large immigrant communities (e.g., the Seattle/Kent and Seattle/Rainier offices). Workers in these settings typically have more experience and familiarity with non-citizen eligibility rules and immigration documents. In contrast, dealing with immigrant eligibility rules may be more challenging for workers in areas of the country, such as Raleigh and Sedalia, where immigration is on the rise but non-citizen applications are still infrequent.
Welfare agency staff also noted that they have minimal to no interaction with INS on how to address applicants' questions and concerns about the potential impact of receiving TANF, FSP, Medicaid and SCHIP benefits on their immigration status and citizenship. Although these observations were made in all six study sites, such concerns appear to be more pronounced in the smaller study sites — Raleigh and Sedalia — where immigrant communities are newer, and agencies have less experience working with these issues.
Welfare agencies are increasingly turning to computer software to help guide workers and applicants through eligibility determination interviews. Such automation provides a means to further standardize the eligibility determination process, making it possible for all workers to systematically gather all the information needed to correctly apply eligibility rules, including the complex rules pertaining to non-citizen eligibility. For example, the computer programs used by welfare agencies in Seattle and Dallas prompt workers to enter on screen almost all of the information needed to determination eligibility and benefit levels accurately. Arlington also has such an automated system, although at the time of our visit it was used only for benefit issuance — not in the "interactive mode" for eligibility interviews for which it was designed — due to technical problems. New York City was nearing the point of phasing in a similar system, and Missouri had one in the relatively early stages of development.
Although using automated programs to guide the eligibility determination interview process offers many advantages, it is not a panacea. In order to be effective, the software must be well-designed with correctly sequenced questions that capture all the information needed, and welfare agency staff must enter the information correctly — both challenging demands in their own right. Even with the assistance of automated eligibility interview packages, eligibility staff must still recognize which immigration documents are acceptable. Optimally, strategies to address the implementation complexities presented by the non-citizen eligibility rules — and all eligibility determination rules for that matter — involve the use of highly trained and specialized workers in conjunction with automated systems that prompt for all the information that is required.