Using Behavioral Economics to Inform the Integration of Human Services and Health Programs under the Affordable Care Act . Implications for facilitating SNAP enrollment


The above analysis suggests that the process of enrolling into subsidized Marketplace coverage is likely to deplete the cognitive resources of many who go through the process. Asking such consumers to then begin the process of enrolling into SNAP, an entirely new benefit program, could prove challenging.

In designing strategies to overcome this challenge, it is important to take into account two constraints. The first is legal. CMS has issued guidance for states that use multi-benefit applications as alternatives to the single, streamlined application for insurance affordability programs. According to that guidance, multi-benefit applications, which could include questions related to SNAP, are acceptable “if the application collects sufficient information to determine … eligibility for all insurance affordability programs” and the “state clearly indicates the additional questions are optional, or not required for submission, and therefore do not serve as a barrier to the … determination” of eligibility for health coverage. In addition, states “may not deny or delay eligibility for an insurance affordability program due to missing or unverified information pertaining only to a non-health program.”74

The second constraint involves state health agency resources. For the foreseeable future, ACA implementation is likely to continue making many demands on state health officials. Human services programs thus may find it more feasible to implement integration initiatives if they can keep to a minimum the time and other resources needed from state health agencies.

Taking into account these constraints as well as the cognitive burdens of enrolling into health coverage, the following sections sketch out approaches through which consumers applying for health coverage could be given opportunities to seek SNAP benefits at various points in their interactions with the Marketplace. The relative effectiveness of these strategies with consumers in general and with specific subpopulations could be tested empirically, perhaps through randomized, controlled experiments accompanied by strong ethical safeguards.75 The three approaches described below could be implemented separately or in combination.

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