One key to CAPs’ simplification of the enrollment process is the replacement of individualized with more standardized benefit determinations. Although states seek to set the latter as close to the former as possible, some imprecision is inevitable. The presumptions underlying CAP are that most participants would trade a few dollars in benefits for a significantly simplified enrollment process, recognizing that CAP focuses on consumers who (a) were not otherwise participating in SNAP and (b) belong to a significantly underserved population.
Among 13 CAP projects that FNS analyzed in detail over multiple years, standardized benefits ranged from an average of $54 below fully individualized levels per case per month to $20 above those levels, with most states falling within $10 of fully individualized levels for most years.
Shelter costs were responsible for most cases in which CAP benefits were more than 20 percent below individualized levels. Using four standardized benefit levels, based exclusively on variations in shelter costs, appeared to be an effective approach to preventing significant variation.
The states that mailed EBT cards to all individuals identified as eligible reported the largest variation, with average shortfalls of more than $50, compared to what individuals could have received had they gone through the full SNAP eligibility determination process. To some degree, this comparison is more theoretical than real in that these CAP recipients previously were receiving no SNAP benefits at all. Further, the largest difference results from loading EBT cards with the lowest standardized CAP benefit for recipients who could instead qualify for a larger CAP standardized value by providing information about their shelter costs.40
A related concern involves the option for CAP enrollees to obtain a fully individualized benefit determination by submitting a normal SNAP application. Although all enrollees receive notices explaining that option, surveys show that the vast majority do not know about it.41
Each CAP takes significant time for the review, approval, and initiation of new CAPs. Some delays result from the effort required to coordinate with SSA. Other delays involve the time required for the state to clarify its CAP goals and establish its cost neutrality calculations and for FNS to review and recommend cost neutrality solutions. Some observers propose changing the SNAP statute to simplify and streamline the approval process,42 but under current law, states must work closely with FNS before implementing a CAP.
States pursuing CAP waivers must choose between standard and modified models. We are aware of no rigorous research that analyzes the impact of this difference on participation levels. However, some observers suggest that, by eliminating the need for consumers to respond to a mailing, the standard model could increase participation more than the modified model, but CAP participation is delayed until the SSI application is approved.43 On the other hand, because of reduced need to build and test new data exchange mechanisms and develop other relationships between SSA and SNAP, and because SSI has been approved, the modified model may be easier to implement and may allow more rapid approval from FNS, compared to the standard model.44
According to FNS, states that sent pre-loaded EBT cards to their entire outreach population and that implemented the standard model for new SSI applicants achieved the highest participation gains. However, such states also incurred relatively high administrative costs, enrolled consumers with relatively low utilization of SNAP benefits, and had the highest average shortfall in benefit levels, compared to those that would have resulted from the SNAP program’s normal benefit determination process.