One possible approach would delay questions about SNAP until after the health application process is complete. This would ensure that SNAP questions pose no barrier to enrollment into health coverage, thereby meeting the requirements of the CMS guidance described earlier. It would also avoid burdening state health programs with the need to modify questions and procedures that involve health coverage, since those questions would be answered and procedures completed before any SNAP issues are raised.
However, raising SNAP at this late stage in the application process would subject consumers to the full weight of cognitive overload, as described above. It would therefore be important to recognize that many consumers could enter the SNAP interaction in an exhausted frame of mind. They might not be willing or able to make additional choices about whether to apply for SNAP or learn new facts related to human services programs. At the same time, consumers vary, and many will value choice, information, and flexibility, even if they are exhausted.
One possible approach to minimize these burdens would begin by offering consumers a cognitively undemanding route to SNAP participation. After someone completes the application and plan selection processes for health coverage, the Marketplace interface (or application assister working with the consumer) would inform the consumer that he or she might qualify for help paying for food, based on the information that the consumer already provided. The consumer could then be asked, “Would you like your state’s food agency to contact you to see if you qualify for help paying for food?” If so, the consumer would be asked for his or her preferred contact method (e.g., by text message, email, cell phone call, mail, etc.) and contact information.76 The SNAP office would follow up by contacting the consumer, with a timing that fits the local office’s workflow, to obtain the additional information needed to determine SNAP eligibility.
Whether or not the consumer agrees to be contacted by the state food agency, the consumer could next be asked if he or she wants information about SNAP or an opportunity to apply, without waiting to be contacted by the state’s food agency. If so, the consumer could be given simple information describing SNAP benefits and be connected to the online SNAP application. If technically feasible, that application would be pre-populated with information that the consumer already provided for health coverage. Despite such pre-population, the consumer would need to provide additional information to qualify for SNAP, as explained earlier.
A related approach, inspired by the behavioral economics research discussed in the first part of this paper, would have the consumer’s contact information forwarded to the SNAP agency unless the consumer opts out. Under this variant, more consumers would have their information sent to SNAP. However, consumers might not have indicated their preferred method of contact. It is not obvious that furnishing more names to SNAP, without any information about the contact method that works best for each consumer, would generate increased SNAP enrollment. A hybrid approach might work better, in which consumers are: (a) informed that they will be contacted by the state food agency unless they indicate a contrary preference; (b) asked for their desired method of being contacted; then (c) given a chance to opt out of being contacted.
Proponents of any opt-out approach, whether or not in a hybrid form, would need to answer several questions, in this context. First, is the Marketplace legally authorized to share the applicant’s contact information, without the applicant’s affirmative consent?77 Second, would consumers be taken aback or worry that they are being targeted by “scam artists” if someone claiming to be from the SNAP agency reaches out to them, in the absence of an affirmative request? If so, how could that outreach be designed to forestall such concerns? For example, perhaps quick turnaround from the SNAP agency might minimize this risk by increasing the odds that consumers will remember reading about SNAP when they applied for health coverage.
Regardless of how these questions are answered or which of these specific approaches is preferred, the period after completing the health coverage application and enrollment process deserves consideration as an appropriate point to connect consumers to SNAP, so long as the connection process is carefully designed to account for the cognitive depletion that many consumers are likely to experience at that time.