SNAP is a Federal nutrition assistance program that is State administered. Given this relationship with the States, FNS has established reporting and monitoring tools to oversee ongoing State agency program operations for SNAP and ensure the integrity of the SNAP benefits issued. These efforts include a quality control process which samples and reviews the eligibility determination and benefit amount of SNAP cases (referred to as payment accuracy reviews); monthly financial and program activity level reporting; management evaluations; and program access reviews.
ARRA SNAP funds are mandatory, meaning that separate financial accounting of the funds is required but the recipient-level reporting required by Section 1512 of the Recovery Act does not apply. FNS will continue to use these existing monitoring activities to obtain information on the implementation of ARRA funding in the States.
In addition to obtaining the obligations and outlays of SNAP benefits through required ARRA financial reports, FNS will use its existing payment accuracy review process to draw a statistically valid sample of cases for review to determine the appropriateness of the determination for eligibility and the accuracy of the benefit amount. Each year States review about 48,000 active cases and 33,000 closed cases to determine the validity of payment levels and denials. Federal staff validates a sample of the State reviews. This system will provide a continuing stream of management information about payment accuracy levels before and after ARRA implementation.
SNAP administrative funds used to stabilize State governments and avoid a reduction in critical safety net services make up approximately 5% of current State Administrative Expenses (SAE) in the SNAP program. We are requiring States to report on how they are spending ARRA SNAP SAE funding by providing a separate ARRA SNAP specific SF-269 form, which will collect obligations and outlays of the ARRA funding specifically. This SNAP specific SF-269 form collects State-level obligations and outlays across 20 categories, well beyond the standard financial reporting required for all federal grant programs, including such functions as certification, issuance, and nutrition education.
To help ensure the appropriateness of expenditures, FNS requires States to submit a State plan of operations for approval, which includes a series of additional plans including: an Employment and Training Plan, an Outreach Plan, a Nutrition Education Plan, and an Advanced Planning Document (APD) for IT expenditures. If ARRA funds are used to support additional activities in any of these areas, a State would need to submit a plan amendment for approval. Otherwise, ARRA funds will be spent on approved activities.
In addition to reviewing planned and actual expenditures, FNS will conduct on-site financial and programmatic monitoring of SNAP administrative expenditures; these on-site efforts will now include a specific module on the review of ARRA activities.
As we do in the course of our normal oversight responsibilities, FNS will also draw on any audit finding associated with specific ARRA audits conducted by GAO and OIG, using these findings as a source of additional data to identify and resolve any issues related to implementation.
In addition to monitoring the use of funds, the implementation of ARRA presents a unique opportunity to measure the impact of increased benefits on food insecurity. For decades, policy makers, advocates, and those implementing the program have hypothesized that increasing benefit amounts would reduce food insecurity and, perhaps, draw more individuals into the program that may have been reticent to apply. The natural experiment offered by the ARRA’s benefit increase will be used to measure its impact of food insecurity by surveying new program entrants at the time of certification and in a follow-up survey months after being on the program.