Examples of Promising Practices for Integrating and Coordinating Eligibility, Enrollment and Retention: Human Services and Health Programs Under the Affordable Care Act. Description

07/21/2014

Low rates of SNAP participation among the elderly have posed a longstanding problem. In fiscal year 2010, SNAP served only 35 percent of eligible elderly persons—defined for SNAP purposes as people age 60 and older—compared with an overall participation rate of 75 percent among all SNAP-eligible consumers.29 Causes of non-participation identified in prior research include the perceived complexity of the application and enrollment process, transportation difficulties involved in reaching local SNAP offices, misunderstanding about available benefits, and stigma.30 To reach this population, FNS has long recognized the need for innovative enrollment and outreach strategies.

Since 1997, federal law has required SSA to give SSI applicants and recipients the opportunity to file a SNAP application while at the SSA office31. However, the process has not always worked seamlessly. For example, SSA case workers may not always obtain enough information to complete a SNAP application, due to differences in SNAP and SSI program requirements; or SSI might convey records to SNAP before verifying an applicant’s income. In either case, SNAP would need to follow-up with an elderly or disabled consumer to complete the application.

To improve this process, FNS (in collaboration with SSA) began authorizing state agency demonstrations for CAPs. By modestly “tweaking” the rules for determining SNAP benefits, these projects allow a significant simplification of the SNAP application process for SSI recipients who live alone or with a spouse who also receives SSI. These seniors and people with disabilities can qualify for SNAP based on the receipt of SSI by all household members, which establishes categorical eligibility. In such states, the SNAP application requires just one or two additional items of information. Benefit levels are standardized, often set at two or more values based on shelter expenses. FNS requires that, on average, participants applying through CAPs must receive benefits like those they would have received under the regular SNAP program, thus promoting both fairness and cost neutrality.

Standardizing benefits in this way allows a substantial simplification of application forms, since consumers are not required to provide the detailed information needed to establish precise benefit levels under standard SNAP rules. CAP participants are also exempt from the face-to-face interview usually required at SNAP offices. This exemption is helpful for SSI recipients, as the elderly and people with disabilities sometimes find it difficult to reach local social services offices. Recognizing that SSI recipients approved through CAP typically experience little income fluctuation,32 CAP households may have certification periods lasting 24, 36, or 48 months, reducing administrative and client burdens substantially compared to those experienced with SNAP’s normal 6- or 12-month certification periods.33 Operationally, SNAP programs can tap into information they already receive from SSA through an automated data exchange system, using that existing system for the additional purpose of identifying SSI recipients who have been approved for SNAP receipt and offering the CAP benefit to those not already approved. Such seniors and people with disabilities can begin receiving SNAP the month after they qualify for SSI if they applied with their SSI application. However, most CAP participants do not join SNAP through an application submitted at the SSA office, because the pool of people applying for SSI is small compared to the much larger pool already receiving SSI benefits.

As of 2013, 18 states were operating CAP demonstrations:34 Arizona, Florida, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Mississippi, New Jersey, New Mexico, New York, North Carolina, Pennsylvania, South Carolina, South Dakota, Texas, Virginia, and Washington. In most states, households receive a standard benefit, with the amount based on whether the state categorizes them as having “high” or “low” shelter expenses. In several states (including Florida, Massachusetts, New York, and Washington), the benefit calculation is a bit more complex. Households receive a SNAP benefit that is based on gross income, the standard deduction, a standard utility allowance (SUA), and standardized shelter expense. CAP participants receive no other SNAP income deductions.

Almost all states give CAP participants the opportunity to seek a fully individualized benefit determination, rather than a more standardized amount. In effect, someone making this choice opts out of CAP and into the regular SNAP program. A number of states give this option to all CAP recipients. Others limit this choice to consumers with shelter or medical expenses that exceed specified levels and thus are especially likely to receive larger SNAP benefits under regular procedures.

States take two basic approaches to CAPs. Through the “standard” model, all information needed by SNAP can be obtained during the SSA interview. For example, South Carolina, the first state to implement this model, asks SSI applicants to state whether average monthly shelter and utility expenses are in one of three specified ranges (less than $300, $301-$466, or more than $466). This information, which is not required for SSI purposes, determines which of several standardized SNAP benefit levels will apply. In addition, consumers must attest to living alone and receiving no earned income. SSA then transfers all data electronically to the SNAP program, which issues benefits without any further step required from the consumer or the state.

By contrast, the “modified” model does not feature SSA collecting CAP information. Instead, the State performs a data match to SSA data and captures the names and address information of SSI recipients who are not in the State’s SNAP records. SNAP then mails these consumers a highly simplified SNAP application form, encouraging them to enroll by completing and returning the form, free from the normal obligation to visit the SNAP office in person.

While beginning implementation of either model, states may convert existing SNAP beneficiaries to CAP if the CAP benefit is larger. They may also conduct outreach to households who already receive SSI but not SNAP. Such outreach consists of sending them either simplified SNAP/CAP application forms or electronic benefit transfer (EBT) cards pre-loaded with the smallest CAP benefit in their State. When the recipients use those cards, such use constitutes consent to enrollment into CAP.35 If the consumers respond to requests for information about shelter costs, their benefits can be increased to the appropriate CAP amounts.

Before using either model for a CAP waiver, states must obtain FNS approval. Standardized values that achieve cost neutrality are determined based on current SNAP-participating SSI-recipient households. Every 12 to 18 months, a CAP state must gather all the information necessary to perform a regular SNAP benefit calculation for a sample of CAP cases to determine if the CAP standardized values still meet cost neutrality requirements. If CAP benefits are not cost neutral, FNS and the State determine how to adjust CAP standardized benefits either up or down to establish cost neutrality. In addition, standardized CAP benefits must be changed to reflect cost-of-living (COLA) changes to SSI as well as SNAP COLAs, legislated changes, and any state changes to SNAP options.

SNAP benefits paid under a CAP waiver are subject to SNAP quality control reviews and potential inclusion in the state’s SNAP payment error rate. However, CAP cases are excluded if an erroneous CAP certification results from incorrect information from SSA regarding household composition or the beneficiary’s incorrect description of living arrangements on a simplified CAP application form. Although such cases do not count as a SNAP error, affected beneficiaries are removed from CAP and informed that they must file a standard SNAP application to continue receiving benefits.

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