oversight

Food Stamp Program: Households Collect Benefits for Persons Disqualified for Intentional Program Violations

Published by the Government Accountability Office on 1999-07-08.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to the Chairman, Subcommittee
                  on Department Operations, Oversight,
                  Nutrition, and Forestry, Committee on
                  Agriculture, House of Representatives

July 1999
                  FOOD STAMP
                  PROGRAM
                  Households Collect
                  Benefits for Persons
                  Disqualified for
                  Intentional Program
                  Violations




GAO/RCED-99-180
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-282612

      July 8, 1999

      The Honorable Bob Goodlatte
      Chairman, Subcommittee on
        Department Operations, Oversight,
        Nutrition and Forestry
      Committee on Agriculture
      House of Representatives

      Dear Mr. Chairman:

      During numerous hearings over the last several years, the Congress has
      expressed its strong desire to reduce the level of fraud, waste, and abuse
      in the Food Stamp Program, which is administered by the U.S. Department
      of Agriculture (USDA). In 1997 and 1998, we reported that millions of
      dollars in food stamp overpayments in four states were caused by
      counting thousands of inmates and deceased individuals as household
      members and by counting thousands of individuals as members of
      recipient households in more than one state during the same period.1 In
      these reports, we identified several actions, including the use of automated
      information, to reduce the level of ineligible participation. In response to
      your request, this report focuses on individuals who were disqualified
      from the program for intentionally violating the program’s rules but were
      included as household members during their disqualification period, a
      problem referred to as disqualified participation. Individuals are
      disqualified from participation in the program when it is determined that
      they have committed an intentional program violation.2

      Specifically, we (1) determined for calendar year 1997 how many
      individuals were included as members of food stamp households in four
      states while disqualified from the program and estimated the value of the
      benefits that were improperly issued to those households and
      (2) determined why these individuals were improperly included in

      1
       Food Stamps: Substantial Overpayments Result From Prisoners Counted as Household Members
      (GAO/RCED-97-54, Mar. 10, 1997), Food Stamp Overpayments: Thousands of Deceased Individuals Are
      Being Counted as Household Members (GAO/RCED-98-53, Feb. 11, 1998), and Food Stamp
      Overpayments: Households in Different States Collect Benefits for the Same Individuals
      (GAO/RCED-98-228, Aug. 6, 1998).
      2
       7 C.F.R. ch. II, part 273.16 (c) specifies that a determination of intentional program violation can be
      made when an individual is found to have intentionally (1) made a false or misleading statement or
      misrepresented, concealed, or withheld facts or (2) committed any act that constitutes a violation of
      the Food Stamp Act, the Food Stamp Program’s regulations, or any state statute relating to the use,
      presentation, transfer, acquisition, receipt, or possession of food stamp coupons or authorization to
      participate cards. The four procedures for determining intentional program violations are discussed in
      more detail in appendix II.



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                   households and what actions USDA and state agencies could take to detect
                   and prevent disqualified participation.

                   To identify disqualified participation, we conducted a computer match
                   comparing the calendar year 1997 food stamp rolls of four states
                   (California, Illinois, Louisiana, and Texas) with information on disqualified
                   individuals contained in USDA’s Disqualified Recipient Subsystem.3 These
                   four states accounted for about 28 percent of the nation’s participants in
                   the Food Stamp Program and were responsible for 19 percent of all active
                   disqualifications nationwide in 1997.4 (See app. I.) To ensure the accuracy
                   of our analyses, we used only those matches that (1) met the most reliable
                   and stringent criteria used by the Social Security Administration to verify
                   Social Security numbers and (2) identified individuals who were included
                   in households that were issued food stamp benefits for the same month(s)
                   that they were disqualified from participation.


                   Over 3,000 disqualified individuals in the four states we reviewed were
Results in Brief   improperly counted as members in households that received food stamp
                   benefits during calendar year 1997. While we cannot estimate the potential
                   amount of overpayments received nationwide for individuals who
                   participated while disqualified, the households in the four states we
                   reviewed improperly collected about $500,000 in food stamp benefits. The
                   $500,000 in overpayments, while small in relation to the $5.6 billion in food
                   stamps distributed to 6.4 million individuals in these four states,
                   undermine USDA’s accomplishments and ongoing efforts to ensure the
                   program’s integrity.

                   About 70 percent of the disqualified participation we identified was
                   attributable to weaknesses in state processes for the timely removal of
                   individuals from the food stamp rolls after they have been disqualified.
                   About 30 percent of the disqualified participation that we identified
                   occurred because the states did not check USDA’s national database of
                   disqualified individuals to determine if household members had been
                   disqualified by another state or because of delays in updating information
                   in the database. Furthermore, USDA’s database is incomplete and contains
                   errors; therefore, even if state agencies check the database, they may not


                   3
                    USDA’s Disqualified Recipient Subsystem compiles nationwide disqualification information collected
                   from the state agencies that administer the Food Stamp Program.
                   4
                    Because California does not maintain statewide participation information, we used state eligibility
                   information in our match. For California, we determined that eligibility for the program is
                   representative of actual participation, as described in appendix III.



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             receive full and accurate disqualification information. We could not
             estimate, however, the amount of additional disqualified participation
             attributable to this problem. USDA could help the states reduce disqualified
             participation by sharing best practices for imposing disqualifications
             promptly and requiring states to check its national database of
             disqualification information for applicants. This report includes a number
             of recommendations to the Secretary of Agriculture designed to reduce
             disqualified participation.


             The Food Stamp Program is designed to promote the general welfare and
Background   to safeguard the health and well-being of the nation’s population by raising
             the nutritional levels of low-income families. Recipients use their food
             stamp benefits to purchase allowable food products from authorized retail
             food merchants. USDA’s Food and Nutrition Service (FNS) manages the
             Food Stamp Program through agreements with state agencies. FNS
             approves the states’ plans to operate the program and ensures that states
             administer the program in accordance with regulations. The federal
             government pays all of the costs for benefits and one-half of the
             administrative costs for each state. In fiscal year 1997, USDA provided
             about 23 million participants with over $19.5 billion in benefits and paid
             the states, U.S. territories, and the District of Columbia about $1.7 billion
             to administer the program.

             Food stamps are issued to households, which can comprise an individual,
             a family, or any group that lives together and customarily purchases and
             prepares food in common. Households applying for benefits must provide
             information about each household member, including Social Security
             numbers. The value of the food stamp benefits for a household depends on
             the number of eligible household members and their income as adjusted
             for assets and such costs as those for shelter and utilities. Therefore, a
             household’s monthly food stamp allotment increases with each additional
             member, provided that income limits are not exceeded. The national
             average monthly food stamp benefit for individuals was $71.27 in 1997.

             Eligibility workers in service centers work directly with applicants or their
             representatives to certify households’ eligibility and determine the amount
             of benefits at the time of the application and at least annually thereafter.
             Generally, the service centers maintain the clients’ detailed case records,
             while the computerized eligibility and benefit issuance data are maintained
             at the state or local level. State agencies in Illinois, Louisiana, and Texas
             maintain both types of data, but in California, the state agency maintains



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                        the information on eligibility, while the counties maintain the information
                        on benefit issuance. Each state is required to establish a
                        performance-reporting system to monitor its food stamp program,
                        including a quality control review process to help ensure that benefits are
                        issued only to qualifying households and that the amounts of these
                        benefits are correct.

                        Each state is required to investigate any case of alleged intentional
                        program violation and ensure action if allegations are verified. Federal
                        regulations specify that individuals found to have committed an
                        intentional program violation shall be ineligible to participate in the
                        program for a specified period.5 States have several procedural options for
                        determining whether individuals have committed intentional program
                        violations, and the extent to which each procedure is used can vary widely
                        from state to state. (See app. II.) State agencies are responsible for
                        imposing penalties and for recovering any food stamp overpayments
                        associated with the intentional program violations. The disqualification of
                        an individual by one state is valid in all states.


                        In the four states we reviewed, over 3,000 disqualified individuals were
Disqualified            improperly included as members of food stamp households in calendar
Participation Weakens   year 1997. These households received about $500,000 in food stamp
the Program’s           overpayments during the year. Among these individuals were 40
                        disqualified participants who had been permanently disqualified from the
Integrity               program. While our review was limited to identifying disqualified
                        participation in four states, we believe it is likely that such participation
                        also occurs in other states. Table 1 summarizes the number of disqualified
                        participants that we identified in the four states we reviewed.




                        5
                         7 C.F.R. ch. II, part 273.16. In addition, the Personal Responsibility and Work Opportunity
                        Reconciliation Act of 1996 doubled the disqualification period for intentional program violations from
                        6 months to 1 year for the first violation, and from 1 year to 2 years for the second violation. The
                        penalty for the third violation remained the same—permanent disqualification. Disqualification
                        penalties can differ in specific cases, such as transactions involving food stamp benefits and drugs or
                        firearms, and may also be specified by the court for cases that are prosecuted.



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Table 1: Extent of Disqualified
Participation, Calendar Year 1997   Dollars in thousands
                                                                              Number of           Total months of
                                                                             disqualified             disqualified              Estimated
                                    States examined                          participants            participation          overpayments
                                    California                                        2,042                    4,839                     $340
                                    Illinois                                            505                    1,157                           88
                                    Louisiana                                           198                      504                           37
                                    Texas                                               421                      873                           63
                                    Total                                             3,166                    7,373                     $529
                                    Sources: For California, the California Department of Public Social Services; for Illinois, the Illinois
                                    Department of Human Services; for Louisiana, the Louisiana Office of Family Support, Department
                                    of Social Services; and for Texas, the Texas Department of Health Services.



                                    Overall, about 81 percent of the disqualified participants that we identified
                                    were members of food stamp households in the state that had imposed the
                                    disqualification, and about 19 percent had been disqualified by a different
                                    state. However, in some states and in one county, higher proportions of
                                    the disqualified participants had been disqualified by a different state. For
                                    example, in Texas, 209 out of 421, or 50 percent, of the disqualified
                                    participants we identified had been disqualified by some other state, yet
                                    they accounted for about 59 percent of the estimated overpayments
                                    because they had participated for a somewhat longer period of time. In
                                    Louisiana, about 34 percent of the disqualified participants had been
                                    disqualified by a different state, and in California, 38 percent of the
                                    disqualified participants in Los Angeles County had been disqualified by
                                    another state.

                                    While we focused our analysis on disqualified participation in the Food
                                    Stamp Program, such participation may be indicative of similar problems
                                    in other public assistance programs administered by the states. In our
                                    review of sample case files in three of the four states we visited, we found
                                    that some individuals who were disqualified from the Food Stamp
                                    Program were also disqualified at the same time, for the same offense,
                                    from the Temporary Assistance for Needy Families (TANF) program. While
                                    our match did not include other programs, we believe that if individuals
                                    were able to obtain food stamp benefits while disqualified, they may have
                                    obtained the other benefits as well.

                                    Although the total estimated dollar value of benefit overpayments
                                    associated with the disqualified participation for the four states we
                                    reviewed was not large compared with the total amount of food stamp



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                       benefits issued, such participation undermines the program’s integrity. The
                       importance of the program’s integrity was highlighted in the April 23, 1998,
                       testimony of USDA’s Food and Nutrition Service Administrator.6 The
                       Administrator stated that

                       “A crucial part of the President’s and Secretary’s commitment to delivering nutrition
                       assistance to needy Americans is ensuring that the integrity of the Food Stamp Program is
                       protected from those who would abuse the program. It is our nation’s most important
                       nutrition program, and we make protecting its integrity our highest priority.”


                       In her testimony, the Administrator cited the increase of 12 percent in
                       recipients’ disqualifications for fraud—from more than 94,000 in 1996 to
                       almost 106,000 in 1997. The positive impact of such efforts is undermined
                       when some of these same individuals who were disqualified for fraudulent
                       activities in the program are allowed to participate in the program during
                       their disqualification period.


                       Weaknesses in states’ processes for imposing disqualifications were
Improved State         responsible for about 70 percent of the disqualified participation that we
Processes and Use of   identified, which permitted disqualified individuals to continue receiving
Complete and           benefits during part or all of their disqualification period. Certain
                       practices, such as the centralization of responsibility for all aspects of
Accurate National      imposing a disqualification, including the removal of the individual from
Information Would      the food stamp rolls, can help reduce disqualified participation. States’
                       failure to check USDA’s national database to determine if household
Help Prevent           members had been disqualified by another state or delays in updating
Disqualified           disqualification information accounted for about 30 percent of the
Participation          disqualified participation that we identified. A routine check by states of
                       USDA’s database to determine the disqualification status of household
                       members, as well as quicker access to updated disqualification
                       information, would go further to detect and prevent disqualified
                       participation. In addition, USDA and the states do not effectively oversee
                       and control the submission of disqualification information to the database.
                       Although we identified and validated the participation of disqualified
                       individuals using information in the database, the database is incomplete
                       and contains errors; therefore, even if state agencies check the database,
                       they may not receive full and accurate disqualification information.




                       6
                       Testimony of Yvette S. Jackson, Administrator, Food and Nutrition Service, U.S. Department of
                       Agriculture, Before the Senate Committee on Agriculture, Nutrition and Forestry (Apr. 23, 1998).



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State Processes for          In the four states we reviewed, weaknesses in the different processes that
Imposing Disqualifications   they used to implement disqualifications and remove individuals from the
Allow Some Disqualified      food stamp rolls allowed some disqualified individuals to participate. We
                             found that certain state practices and procedures seem more effective
Participation to Occur       than others in detecting and preventing such ineligible participants and
                             that the states we visited have taken or are planning actions to address the
                             problems we identified.

                             Individuals are disqualified from participation in the program when it is
                             determined that they have committed an intentional program violation
                             (IPV). Federal regulations require that a disqualified individual be notified
                             of the disqualification and that the disqualification begin either at the
                             beginning of the month following written notification or, if the IPV was
                             determined by a court, on the date specified by the court or within 45 days
                             of the court decision if no date was specified.

                             State processes for removing disqualified individuals from the food stamp
                             rolls differed. Texas has a single Central Disqualification Unit for the
                             entire state that (1) receives notice that an individual has been determined
                             to have committed an IPV, (2) sends notification of disqualification to the
                             individual and the eligibility worker, and (3) imposes the disqualification
                             by removing the individual from the food stamp rolls. The unit also enters
                             the disqualification information into Texas’ statewide computerized
                             eligibility information system. During the disqualification period,
                             local-level eligibility workers cannot change the eligibility status of
                             disqualified individuals; only the central unit staff can make such changes.
                             If a local eligibility worker attempts to access the record of the disqualified
                             individual on the automated system, the disqualification information
                             appears on screen and the system rejects attempts to restore eligibility. On
                             the basis of our analysis, disqualified individuals are less likely to continue
                             participating under such a centralized system; Texas had a lower
                             percentage of in-state disqualified participants (i.e., participants
                             disqualified by Texas but continuing to participate) than the other states in
                             our review. According to state officials, participation by individuals
                             disqualified by Texas occurred primarily because the central unit received
                             late notification of an IPV from hearing officers, the courts, or out-of-state
                             decisions, resulting in the issuance of benefits in the first month of
                             disqualification. As a result of our findings, Texas has implemented a
                             policy giving priority to imposing disqualifications on individuals who are




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participating in active cases, thus preventing overpayments to the
household.7

Like Texas, Louisiana has a central unit that is responsible for imposing
disqualifications; however, the unit does not actually remove individuals
from the food stamp rolls. The unit sends electronic messages through
Louisiana’s statewide computerized eligibility information system to local
eligibility workers, notifying them that an individual has been disqualified
and that they must remove the individual from the food stamp rolls. The
central unit also enters the disqualification information into the system;
therefore, if a local worker attempts to access the record of the
disqualified individual, the information appears on screen. However, the
system does not ensure that the eligibility worker will act on the
disqualification information or prevent the worker from later restoring
eligibility for the disqualified individual. According to state officials, the
central unit does not actually remove disqualified individuals from the
rolls because the coincidental input of changes to a case record from two
different locations in a day, while unlikely, could cause a problem in the
case record. A state official stated that participation by individuals
disqualified by Louisiana primarily occurred because local eligibility
workers did not take prompt action, or never took action, on the
disqualification information that they were provided. Such delays and
oversights can occur for a variety of reasons, such as the worker’s
temporary absence for leave, training, or excessive workload. To address
these problems, Louisiana officials told us that they required staff in each
of the state’s parish offices to evaluate processes for imposing
disqualifications, and they plan to implement various practices, such as
increasing supervisory review of eligibility workers’ disqualification
actions.

In Illinois, a central unit is notified of IPV determinations and is responsible
for entering the information into a disqualification database on the
statewide computerized eligibility information system. The central unit
sends paper notices of IPV determinations to local eligibility workers, who
are responsible for notifying the individuals of their disqualification and
removing them from the food stamp rolls. The state conducts a monthly
match between its database of Illinois disqualifications and its food stamp
rolls to identify disqualifications that have not been imposed or
disqualified individuals who reapply. We found little disqualification
documentation in our review of case files, so it was generally not possible

7
 A federal appeals court recently decided that the imposition of food stamp disqualification penalties
cannot be postponed, for example, even if the individual is not currently participating in the program.
Garcia v. Concannon, 67F.3D 256 (1995).



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                             to ascertain if the responsible eligibility worker had received notice of the
                             disqualification or what action had been taken. However, in some case
                             files, we found notices reminding eligibility workers to disqualify
                             participants who had been identified in the monthly computer match of
                             disqualified individuals and participants. State officials said that
                             participation by individuals who had been disqualified by Illinois primarily
                             occurred because local eligibility workers did not take prompt action. To
                             address this problem, state officials said that they are considering the
                             complete centralization of their disqualification process by making a single
                             state-level unit responsible for all aspects of imposing disqualifications.

                             In California, responsibility for disqualifying individuals is delegated to
                             individual counties, and the state agency is notified of a disqualification
                             only after it is imposed, so that the information can be reported to USDA.
                             Like all California counties, Orange County and Los Angeles County,
                             operate independently of each other, with their own procedures and
                             separate computerized information systems, but they impose
                             disqualifications similarly. In each, the county fraud unit participates in
                             the IPV process and notifies the eligibility worker responsible for the active
                             case to send a disqualification notice and to remove the individual from
                             the food stamp rolls. In these counties, our review of case file records and
                             discussions with officials indicated that eligibility workers did not impose
                             disqualifications on time for a variety of reasons, such as getting
                             notification of a disqualification after the specified start date, and that
                             local workers sometimes reinstated the disqualified individual to eligibility
                             before the end of the disqualification period. According to an Orange
                             County official, the agency has taken action to address these issues by, for
                             example, altering its computerized eligibility system to inhibit workers
                             from restoring eligibility before the end of the disqualification period.


Disqualified Participation   About 30 percent of the disqualified participation we identified in four
Also Occurs Because          states was attributable to states’ not checking USDA’s Disqualified
States Do Not Check          Recipient Subsystem (DRS) to determine the disqualification status of
                             applicants or to delays in obtaining updated DRS disqualification data.
USDA’s Database              While states are not required to check the DRS to determine the
                             disqualification status of applicants, states are mandated to check the DRS
                             to determine the proper length of the disqualification penalty. However,
                             some states are not meeting this requirement.

                             The DRS is a national database of currently and previously disqualified food
                             stamp recipients. It contains identification information on disqualified



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individuals, including their name, Social Security number, and date of
birth, along with disqualification information, such as the decision and
start dates of disqualification, the length of penalty, previous
disqualifications, and the state that imposed the disqualification. States are
required to provide monthly updates of new disqualifications, changes to
prior data submitted, and deletions to the DRS. After the DRS is updated on
the 25th of each month, the updated information is made available to
states. States can either receive disqualification information files directly
from the USDA computer or obtain tapes through the mail. The
disqualification information files are available to states in three formats: a
file of the most recent update, a file of all currently active disqualifications,
or a file of the entire DRS database. States can use these files to update or
maintain a copy of the DRS on their own computerized information systems
or to match them against their food stamp rolls.

Most states do not routinely check the DRS database to determine the
disqualification status of applicants or household members, but they are
not required to do so. According to FNS’ records, of the 50 states and 2 U.S.
territories participating in the program, along with the District of
Columbia, 34 are provided with a file of DRS disqualification information
monthly. While FNS’ records do not indicate how the states use that
information, FNS regional office officials told us that just 22 states routinely
check the DRS disqualification data for new applicants.

Among the four states we visited, California was the only state that used
the DRS disqualification information to screen food stamp applicants in
1997. Our analysis indicates that California’s percentage of out-of-state
disqualified participants was lower than that of any of the other states in
our review. Instead of collecting statewide disqualification information
and making it available to eligibility workers through a computerized
system, as the other states we visited do, California maintains a copy of
the entire DRS database that is updated monthly. The DRS database is
compared with the applicant information submitted by counties for the
nightly computerized state income and eligibility verification process.
Disqualified applicants are reported to the responsible county eligibility
workers, who are then responsible for denying eligibility. According to
state officials, the use of the DRS helps prevent participation by individuals
disqualified in other states, but the lag in updating the DRS data can allow
some disqualified participants to apply and participate before the data are
available on California’s system. A state official estimated that it takes
between 30 and 60 days from the date when an IPV determination is made
by a county until the information is available on the state’s copy of the DRS



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database. This is reflected in our findings in Los Angeles County, where
43 percent of the disqualified participants that we identified had been
disqualified in a different county. Despite the applicant check process,
which uses the DRS data, disqualified participants were subsequently able
to participate in Los Angeles County during their disqualification period
for various reasons, including the delay in getting updated information into
the database.

The other three states in our review did not use the DRS database
information for various reasons. Texas officials said that their automated
system checks applicants against the state’s own disqualification database
and that it is not productive to also check the DRS. However, we found that
209 out of 421 matches, or 50 percent of the disqualified participants we
identified in Texas, were individuals who had been disqualified by
different states. Many of these ineligible individuals could have been
prevented from participating or could have been identified earlier if Texas
had checked the national DRS. Illinois officials told us they did not have the
technical capability to use the DRS when it was first made available and,
instead, used their own database of Illinois’ disqualified individuals for
applicant checks. However, the officials stated that they intend to begin
checking the DRS in the future. Louisiana officials stated that they did not
have the computer resources to use the DRS data until early 1998, when the
state began a monthly match of its food stamp rolls with the DRS file of
current disqualifications. In the 12 months between March 1998 and
February 1999, they identified and removed from their food stamp rolls
107 disqualified participants from other states.

FNS agreed to require states to check the DRS for applicants and recipients
more than 3 years ago in response to the USDA Inspector General’s
recommendations. The Inspector General, reporting on its review of the
implementation of the DRS, recommended that FNS develop procedures that
require all state agencies to compare their databases with the national
database and use the results to determine applicants’ eligibility or whether
current participants were disqualified elsewhere. Concurring, FNS stated
that a regulation to require applicant or case load matches was currently
being drafted. FNS estimated that the proposed rule would be published in
the Federal Register in November 1996. FNS officials stated that the
regulation has not been published because of other regulatory priorities
within the Food Stamp Program. FNS now plans to publish the proposed
rule by July 1, 2000.




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While not required to check the DRS for the disqualification status of
applicants or household members, states are required to use the DRS when
determining the length of disqualification penalty for an IPV. As noted
earlier in this report, the length of the penalty is based on the number of
prior violations. To assist the states in meeting the requirement, FNS
established telephonic access to the DRS through a Voice Response Unit.
The unit allows state workers to directly access the DRS database and, by
entering a Social Security number, determine if an individual has any prior
violations, thus determining the length of penalty for a new violation.
However, the Voice Response Unit is relatively slow, is not designed to
process a large amount of calls, and is not appropriate for application or
recertification checks.

Some state and county agencies are not complying with FNS’ regulation
that requires them to use the DRS to determine the length of the
disqualification penalty for an IPV. We found that in California, Los Angeles
and Orange counties do not use the Voice Response Unit, nor do they use
a microfiche of the DRS that the state provides them with quarterly, to
identify prior violations when determining disqualification penalty periods.
Instead, they check their own disqualification databases and determine the
penalty length on the basis of the number of prior disqualifications within
the county. Similarly, Illinois determines the length of penalty by
consulting its own database of state disqualifications rather than checking
the DRS. According to FNS officials, New Jersey, Rhode Island, and the
territory of Guam also do not check the DRS to determine the length of the
disqualification penalty. As a result, each of these state and county
agencies may not always be assigning the proper length of penalty for the
disqualifications that they impose.

To replace the aging and inefficient Voice Response Unit, FNS is developing
another method for states to query the DRS that is capable of
accommodating routine applicant checks by states. This new system,
known as the Online Query Subsystem, will allow eligibility workers to
directly access the DRS and perform multiple queries, including checking to
determine the disqualification status of applicants or recipients, through
the Internet. According to FNS officials, the on-line system will not require
any programming or maintenance by the states—only computers with
Internet access. The officials stated that the system will provide
information more quickly than the Voice Response Unit and allow access
to updated DRS records sooner than is available through a direct transfer of
files or a tape. FNS plans a phased implementation period, bringing several
states on-line at a time, starting in December 1999.



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                            FNS is also studying the feasibility of a national food stamp participation
                            database, which could provide another way for USDA to provide the states
                            with information on disqualified individuals. In 1998, we recommended
                            that FNS conduct a study to consider establishing a central system to help
                            insure that individuals participating in the Food Stamp Program are not
                            improperly included as a household member in more than one state
                            concurrently.8 FNS agreed with this recommendation, and the Congress
                            approved funding for a feasibility study. Public Law 105-379, dated
                            November 12, 1998, states that “the Secretary of Agriculture shall conduct
                            a study of options for the design, development, implementation, and
                            operation of a national database to track participation in Federal
                            means-tested public assistance programs.” The creation of such a database
                            provides the opportunity for FNS to match nationwide program
                            participation with disqualification information and provide the states with
                            the results for action. FNS has 1 year to complete the study and report the
                            results to the Congress.


The Integrity of the DRS    Although we were able to identify and validate the participation of
Data Can Be Improved to     disqualified individuals using the DRS information, the database is
Enhance Its Effectiveness   incomplete and contains errors, which could allow disqualified individuals
                            to participate or could result in states’ imposition of incorrect lengths for
                            disqualification penalties. For example, we found that the disqualification
                            data from three states—Michigan, Washington, and Arkansas—were not
                            entered into the DRS for a 6-month period between August 1, 1998, and
                            January 31, 1999. Michigan and Washington State officials attributed the
                            lack of reporting to computer problems that prevented them from
                            submitting information to the DRS, and an Arkansas official stated that the
                            state transmitted its data to the DRS monthly but did not know whether the
                            transmissions had been successful. An FNS official stated that the agency is
                            working with Arkansas State officials to resolve the problem.

                            Furthermore, during that same 6-month period, states sent in large
                            numbers of disqualification records that were rejected as “fatal errors” by
                            DRS data checks designed to keep faulty information from entering the
                            system. For example, of the 18,351 records sent by Oregon, 14,386, or
                            78 percent, were rejected, while South Dakota sent 3,408 records, but only
                            12 were accepted into the DRS. According to FNS officials, the number of
                            rejected records is large because the states resubmitted the same
                            erroneous records month after month without correction. FNS has no

                            8
                             Food Stamp Overpayments: Households in Different States Collect Benefits for the Same Individuals
                            (GAO/RCED-98-228, Aug. 6, 1998).



                            Page 13                                GAO/RCED-99-180 Disqualified Food Stamp Participants
B-282612




controls to ensure that the data are corrected and resubmitted; instead, it
relies completely on the states to correct and resubmit disqualification
data. If the states do not resubmit the data, the DRS disqualification
database is incomplete. Among the four states in our review, California,
Illinois, and Louisiana officials told us that they take action to review DRS’
error messages and resubmit corrections; Texas does not.

Finally, in many cases, state information is not reaching the DRS within the
required time frame. States are required to submit disqualification
information so that the FNS receives it no later than 30 days after the
disqualification takes effect. Yet, of the disqualifications that were active
during any part of 1997, 41 percent, or 49,826 out of 118,921, were received
more than 30 days after they took effect.

In addition to being incomplete, the DRS database also contains errors. For
example, in Texas, we compared the start dates on disqualification
documentation found in case files with the start dates in the DRS and
determined that the DRS start dates were 1 month earlier than the actual
disqualification start dates. In response to our request, officials in Texas
traced the problem to an error in the program it uses to create the
disqualification update file it sends to the DRS and plans to take corrective
action. Texas officials also found a Year 2000-related problem involving
the date-of-birth field. As a result of this problem, Texas did not report a
large number of disqualifications to the DRS from August 1998 to
January 1999. The officials told us that this problem has been corrected
and that they plan to submit the missing data.

The DRS’ data checks on information submitted by states do allow some
erroneous records to be accepted into the database with a “warning”
message sent back saying that the records contained an error or unusual
circumstance. Some examples of what triggers a warning message are
invalid gender codes and duplicate disqualification numbers (i.e., an
individual has more than one “first” disqualification). According to FNS
records, a large number of warning messages were sent to states from
August 1, 1998, to January 31, 1999. Of the 119,088 records accepted into
the DRS, 83,975, or 71 percent, were accepted with a warning message. An
FNS official attributed many of these 83,975 warning messages to certain
states that submit their entire database every month, which causes the
system to detect duplicates and generate warning messages. He stated that
the newly submitted duplicate records simply overwrite the existing
records.




Page 14                        GAO/RCED-99-180 Disqualified Food Stamp Participants
              B-282612




              While some of these errors would have little consequence to states using
              the information to identify disqualified participants, others, such as those
              involving the dates or numbers of disqualifications, could make the
              information difficult to use if not corrected. For example, our analysis of
              the disqualifications in the DRS database that were active during 1997
              found 5,960 individuals with two or more “first” disqualifications, 1,399
              individuals with two or more “second” disqualifications, and 123
              individuals with two or more “third” disqualifications. Since the length of
              a new disqualification is based on the number of prior disqualifications,
              such erroneous and conflicting information could make it difficult for
              states to properly determine disqualification penalties.

              FNS officials were unaware of many of the data problems that we identified
              during our review. FNS delegates to its regional offices responsibility for
              ensuring that states comply with the DRS requirements, but regional
              officials we spoke to were also generally unaware of the problems we
              identified. For example, regional officials were not aware that the three
              states previously mentioned had not input data to the DRS for 6 months. FNS
              ultimately holds the states responsible for ensuring that the data they
              submit to the DRS is complete, on time, and accurate.


              The inclusion of disqualified individuals in households receiving food
Conclusions   stamp benefits compromises the integrity of the Food Stamp Program and
              results in overpayments. The four states we reviewed have processes in
              place to help ensure that their own disqualifications are imposed;
              however, certain practices, such as centralizing disqualification
              responsibilities, are more effective in ensuring that disqualifications are
              implemented promptly so that overpayments do not occur. While some
              states currently use national disqualification information obtained from
              the DRS to ensure that individuals disqualified by other states do not
              participate in their programs, the current effort by FNS to offer
              disqualification information through an on-line query system will provide
              states with a quicker means to access more timely data. A match between
              a national food stamp participation database, currently under a feasibility
              study, and the DRS database, is another means by which FNS could notify
              states of disqualified participants. However, for the DRS data to be most
              useful to states, FNS must take actions to ensure that they are complete, up
              to date, and accurate.




              Page 15                       GAO/RCED-99-180 Disqualified Food Stamp Participants
                         B-282612




                         In order to ensure the integrity of the Food Stamp Program by preventing
Recommendations to       disqualified participation without imposing significant additional program
the Secretary of         costs to achieve this goal, we recommend that the Secretary of Agriculture
Agriculture              direct the Administrator of FNS to

                     •   collect, analyze, and disseminate state agencies’ “best practices” to help
                         ensure timely action on disqualifications;
                     •   require states to use the national database to determine the
                         disqualification status of applicants, using the method that each deems
                         most appropriate to its circumstances;
                     •   consider, as part of its study on the feasibility of creating a national
                         database to track participation in federal means-tested public assistance
                         programs, a process for periodically matching the disqualification
                         database and disseminating the resulting matches to the states; and
                     •   take actions to ensure that states provide the DRS with disqualification
                         information in a consistent and timely manner, that the data in the DRS are
                         accurate, and that sufficient controls are in place to ensure the accuracy of
                         data submitted to the database.


                         We provided USDA with a copy of this report for review and comment. FNS,
Agency Comments          in commenting on the draft report for USDA, stated that the Service
                         appreciated our work and substantially agreed with our findings.

                         In commenting on our recommendation to collect, analyze, and
                         disseminate state agencies’ “best practices,” FNS stated that resource
                         constraints prohibit a formal “best practices” survey but that the Service
                         will share, informally through regional offices, information about any
                         state’s DRS operations that FNS believes will be of benefit to other states.
                         Regarding the recommendation to require states to use the national
                         database to determine the disqualification status of applicants, FNS
                         reiterated its commitment to publishing a proposed regulation by July 1,
                         2000, requiring states to use the national disqualification database to
                         determine the disqualification status of applicants and/or recipients.

                         To address the recommendation to consider the periodic matching of
                         disqualification data in its study of the feasibility of a national
                         participation database, FNS stated that its study would address whether it
                         is feasible in a national database context for states to access and share
                         disqualification data. Finally, in response to the recommendation to take
                         actions to ensure that the DRS data are timely and accurate, FNS will more
                         closely monitor states’ data transmission reports and follow up with states



                         Page 16                       GAO/RCED-99-180 Disqualified Food Stamp Participants
B-282612




whenever data are not timely transmitted, when the number of records
transmitted appears low, or whenever a significant number of records are
rejected or accepted with warnings. FNS’ comments are provided in
appendix IV.

We also provided California, Illinois, Louisiana, and Texas State officials
with excerpts from the draft report for their review and comment. The
state officials substantially agreed with our findings and provided
technical and clarifying comments that we incorporated into the report as
appropriate.

We conducted our work from August 1998 through April 1999 in
accordance with generally accepted government auditing standards. Our
detailed methodology is presented in appendix III.


As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report for 30 days. At that
time, copies of this report will be sent to the Honorable Dan Glickman,
Secretary of Agriculture; the Honorable Jacob J. Lew, Director, Office of
Management and Budget; and other interested parties. We will make
copies available to others on request.

If you have any questions about this report, please contact me at
(202) 512-5138. Major contributors to this report are listed in appendix V.

Sincerely yours,




Robert E. Robertson
Associate Director, Food and
  Agriculture Issues




Page 17                        GAO/RCED-99-180 Disqualified Food Stamp Participants
Contents



Letter                                                                            1


Appendix I                                                                       20

Information on Food
Stamp Program
Participants and
Benefits in Four
States
Appendix II                                                                      21

Information on the
Procedures and
Criteria Used by
States to Determine
Intentional Program
Violations
Appendix III                                                                     24

Objectives, Scope,
and Methodology
Appendix IV                                                                      28

Comments From the
Food and Nutrition
Service, U.S.
Department of
Agriculture




                      Page 18   GAO/RCED-99-180 Disqualified Food Stamp Participants
                   Contents




Appendix V                                                                                       31

GAO Contacts and
Staff
Acknowledgments
Tables             Table 1: Extent of Disqualified Participation, Calendar Year 1997              5
                   Table I.1: The Food Stamp Program’s Participants, Benefits, and               20
                     Average Monthly Benefit per Participant by State, Fiscal Year
                     1997
                   Table I.2: Number and Percentage of Active Disqualifications by               20
                     State, Calendar Year 1997
                   Table II.1: Number of States Using Each Determination                         22
                     Procedure, Fiscal Year 1997
                   Table II.2: Percentage of Determinations by Procedure for Four                22
                     States, Fiscal Year 1997




                   Abbreviations

                   DRS        Disqualified Recipient Subsystem
                   FNS        Food and Nutrition Service
                   GAO        General Accounting Office
                   IPV        intentional program violation
                   TANF       Temporary Assistance for Needy Families
                   USDA       U.S. Department of Agriculture


                   Page 19                      GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix I

Information on Food Stamp Program
Participants and Benefits in Four States

                                      In fiscal year 1997, California, Illinois, Louisiana, and Texas accounted for
                                      about 28 percent of Food Stamp Program participants nationwide and
                                      29 percent of benefits issued, as shown in table I.1.

Table I.1: The Food Stamp Program’s
Participants, Benefits, and Average   Costs and participants in millions
Monthly Benefit per Participant by                                                                                    Average monthly
State, Fiscal Year 1997                                                                             Food stamp             benefit per
                                      State                           State participants               benefits            participant
                                      California                                       2.8                   $2,372             $70.21
                                      Illinois                                         1.0                     933               76.28
                                      Louisiana                                        0.6                     512               74.18
                                      Texas                                            2.0                    1,765              72.30
                                      Total                                            6.4                   $5,582
                                      Program total                                   22.9                $19,548               $71.27
                                      Source: U.S. Department of Agriculture’s Food and Nutrition Service.



                                      These four states accounted for approximately 19 percent of all the
                                      disqualifications that were in effect during any part of calendar year 1997,
                                      as shown in table I.2.

Table I.2: Number and Percentage of
Active Disqualifications by State,                                                  Number of active         Percentage of total active
Calendar Year 1997                    State                                         disqualifications                disqualifications
                                      California                                                  8,318                              7
                                      Illinois                                                    2,548                              2
                                      Louisiana                                                   3,295                              3
                                      Texas                                                       8,152                              7
                                      Total                                                     22,313                              19
                                      Program total                                            118,921                             100
                                      Source: U.S. Department of Agriculture’s Food and Nutrition Service.




                                      Page 20                                GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix II

Information on the Procedures and Criteria
Used by States to Determine Intentional
Program Violations
                  Food stamp regulations require that a state agency pursue administrative
                  disqualification or referral for prosecution when it has sufficient
                  documentary evidence to substantiate that a participant has intentionally
                  violated the program’s regulations. Intentional program violations include
                  (1) making a false or misleading statement or misrepresenting, concealing,
                  or withholding facts and (2) disobeying the Food Stamp Act, Program
                  Regulations, or any state statute relating to the use, presentation, transfer,
                  acquisistion, receipt, or possession of food stamp coupons or
                  authorization-to-participate cards.

                  Food stamp regulations specify four procedures that states may use to
                  determine intentional program violations.

              •   Administrative disqualification hearings, which provide individuals
                  suspected of an intentional program violation the opportunity to present
                  evidence to a hearing officer, who then renders a ruling as to whether an
                  intentional program violation was committed.
              •   Waived hearings, which allow individuals to waive their right to an
                  administrative disqualification hearing and accept the disqualification
                  penalty.
              •   Court referrals, which allow the state to refer appropriate cases for
                  prosecution by a federal or state court and impose a disqualification
                  penalty if the individual is found guilty of an intentional program
                  violation.1
              •   Deferred adjudication, through which, states can allow accused
                  individuals to sign disqualification consent agreements to avoid
                  prosecution and accept the disqualification penalty.

                  States are required to establish a system for conducting administrative
                  disqualification hearings. However, FNS may exempt a state from this
                  requirement if the state agency has already entered into an agreement with
                  the state’s attorney general’s office or county prosecutors for the
                  prosecution of intentional program violation cases. Waived hearings and
                  deferred adjudication procedures are optional for states.

                  During fiscal year 1997, at least 46 of the 53 participating states used
                  administrative disqualification hearings, waived hearings, and court

                  1
                   Food stamp regulations require states that are exempted from conducting administrative hearings to
                  refer cases for prosecution in accordance with an agreement with prosecutors or state law. The
                  agreement must include the understanding that prosecution will be pursued in cases where
                  appropriate. The agreement must include information on how and under what circumstances cases
                  will be accepted for possible prosecution and any other criteria set by the prosecutor for accepting
                  cases for prosecution, such as a minimum amount of overissuance that resulted from the intentional
                  program violation.



                  Page 21                                GAO/RCED-99-180 Disqualified Food Stamp Participants
                                       Appendix II
                                       Information on the Procedures and Criteria
                                       Used by States to Determine Intentional
                                       Program Violations




                                       referrals; just over half used deferred adjudication procedures.2 (See table
                                       II.1.) Most states used three or all four procedures to disqualify individuals
                                       from the program; a few use only one or two procedures, such as
                                       Delaware, which relied entirely on court referrals to disqualify individuals
                                       during fiscal year 1997.

Table II.1: Number of States Using
Each Determination Procedure, Fiscal   Procedure                                                    Number of states using procedure
Year 1997                              Administrative disqualification hearings                                                            47
                                       Waived hearings                                                                                     46
                                       Court referrals                                                                                     47
                                       Deferred adjudication                                                                               28
                                       Source: U.S. Department of Agriculture’s Food and Nutrition Service.



                                       The four states in our review—California, Illinois, Louisiana, and
                                       Texas—differed in the procedures each used to determine intentional
                                       program violations. (See table II.2.) Illinois, Louisiana, and Texas used
                                       administrative disqualification hearings or waived hearings for most of
                                       their disqualifications, while California primarily used court referrals or
                                       deferred adjudication.

Table II.2: Percentage of
Determinations by Procedure for Four                          Administrative
States, Fiscal Year 1997                                     disqualification              Waived                                  Deferred
                                       State                       hearings               hearings     Court referrals         adjudication
                                       California                             2                    0                  86                   12
                                       Illinois                              47                   47                    7                      0
                                       Louisiana                             54                   39                    5                      2
                                       Texas                                 42                   39                  11                       8
                                       Note: Rows may not add up to 100 percent because of rounding.

                                       Source: U.S. Department of Agriculture’s Food and Nutrition Service.



                                       Because federal regulations allow prosecutors to establish criteria for
                                       accepting cases for prosecution in their agreements with state agencies,
                                       we found that the criteria differed from state to state, and even from
                                       county to county within states. According to state agency officials,
                                       Louisiana prosecutors accept cases if the overissuance involved is greater
                                       than $1,000 or particularly flagrant, and Texas prosecutors accept cases
                                       involving overissuances in excess of $1,500. According to agency officials

                                       2
                                       For convenience, we used the term “states” to include the District of Columbia and the territories of
                                       Guam and the Virgin Islands.



                                       Page 22                                 GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix II
Information on the Procedures and Criteria
Used by States to Determine Intentional
Program Violations




in Illinois, the level of overpayment required to prosecute an intentional
program violation case varies from county to county—from a low of about
$3,500 to a high of $10,000 in the Cook County (Chicago) area. Similarly,
agency officials in California told us that the Los Angeles County
prosecution threshold is $2,000, while the threshold in neighboring Orange
County is $1,000 or lower if the intentional program violation is
particularly blatant or by a repeat offender.




Page 23                            GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix III

Objectives, Scope, and Methodology


                   To determine how many individuals were included as members of food
                   stamp households while disqualified from the Food Stamp Program and to
                   estimate the value of the benefits that were improperly issued to those
                   households, we matched the food stamp records of four selected states
                   against the U.S. Department of Agriculture’s (USDA) Disqualified Recipient
                   Subsystem (DRS) database of individuals disqualified from the Food Stamp
                   Program. California, Illinois, and Texas were among the top five states in
                   participation and benefit issuance in fiscal year 1997; Louisiana provides
                   balance as a smaller state that disqualifies individuals roughly in
                   proportion to its participation rate.

                   We obtained state and USDA data as follows:

               •   State welfare agencies in Illinois, Louisiana, and Texas provided us with
                   computer files containing information on all members of households and
                   the amount of food stamp benefits issued to those households during
                   calendar year 1997. The data provided personal identifiers, including
                   name, Social Security number, date of birth, gender, and the months in
                   which food stamp benefits had been issued to the household while each
                   individual was a member. The state agencies had verified the Social
                   Security numbers for the data on food stamp beneficiaries through Social
                   Security Administration’s Enumeration Verification System.
               •   In California, where issuance data are maintained at the county level, we
                   used the state’s eligibility information in lieu of the issuance data for our
                   match. The data provided the same personal identifiers as provided by the
                   other states and the months of eligibility for each individual. On the basis
                   of our analysis of two counties, we determined that eligibility was
                   predictive of participation.1
               •   USDA provided us with a copy of its DRS database, which contains
                   information on individuals disqualified by all states, districts, and
                   territories. The data provided the same personal identifiers as obtained for
                   food stamp beneficiaries and listed the start date and length of
                   disqualification in months for each individual.

                   We matched the verified Social Security numbers of members of food
                   stamp households in each state with those of individuals who were
                   disqualified for any period during calendar year 1997. For those


                   1
                    In a match between state eligibility information and the Los Angeles County and Orange County,
                   California, food stamp issuance information for calendar year 1996, we found that more than 89 and
                   75 percent of the eligible individuals participated, respectively. Using Orange County’s issuance
                   information for calendar year 1997, we found that more than 74 percent of the eligible individuals
                   participated. On the basis of the 1996 results and the similarity of Orange County’s 1996 and 1997
                   results, we believe that eligibility is predictive of issuance.



                   Page 24                                GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix III
Objectives, Scope, and Methodology




disqualified individuals identified as members of households, we
determined the months in which food stamp issuance occurred after the
date of disqualification and prior to the end of the disqualification period.

We estimated the dollar value of food stamps issued to households with
disqualified members by applying the state’s average monthly issuance per
individual recipient from 1997 to each period in which issuance occurred.
Food stamp benefits are calculated for households—not for individuals.
Thus, it is difficult to determine the exact value of benefits issued to an
individual included in a household, unless he or she is the only member of
a household. Even then, the amount will vary from individual to individual,
on the basis of such factors as income, assets, and the cost of shelter.
Therefore, we relied on the average monthly benefit issued per person in
the locations we reviewed, which ranged from a high of $76 in Illinois to a
low of $70 in California. We realize that the actual issuance may be higher
or lower than our estimates; for example, the maximum issuance to
single-member households who are included in our findings was $120 in
fiscal year 1997. Our estimates are intended to show the general magnitude
of the problem and cannot be used to estimate potential overpayments
nationwide because our methodology was not designed for that purpose.

We considered every month of issuance to households that included
disqualified members to be an overpayment, in keeping with food stamp
regulations (7 C.F.R. ch. II, part 273.16), which specify that
disqualifications be imposed beginning with the first month that follows
the date that the household member receives written notification of the
hearing decision. According to regulations (7 C.F.R. ch. II, part
273.13(b)(7)), there is no requirement to allow additional time for
notifying the household of an adverse action when a member is
disqualified for an intentional program violation.

Because of the quality control program operated by the Food and
Nutrition Service and the states’ ongoing quality assurance efforts, we
accepted their computerized food stamp data identifying participants as
reliable. To provide additional confidence in the data’s accuracy, we
reviewed a limited number of food stamp case files at social service
centers in five large metropolitan areas: Los Angeles County and Orange
County, California; Cook County, Illinois; Orleans Parish, Louisiana; and
Bexar County, Texas. We compared the name, Social Security number,
and date of birth of each individual in the computerized food stamp rolls
with information in the relevant case files and found no significant
differences. To further verify participation in the household, we reviewed



Page 25                              GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix III
Objectives, Scope, and Methodology




copies of available documents in the case files, such as birth certificates,
drivers’ licenses, and Social Security cards. We also verified the periods of
participation by reviewing approved applications, when available;
however, many case files did not contain complete information.

The Food and Nutrition Service has not conducted a comprehensive data
assessment of the DRS because the agency’s resources were committed to
implementing and maintaining the system. Therefore, to determine the
reliability of the disqualification data relevant to our review of four states,
we reviewed a limited number of case files at the five social service
centers mentioned previously to verify the disqualified individual’s name,
Social Security number, date of birth, disqualification start date, and
length of disqualification. To supplement the case file information, we also
obtained disqualification information from various other state agency
sources, including centralized disqualification or fraud units, and from
computerized state records. We found no significant differences, with the
exception of DRS start dates for Texas disqualifications, which were off by
1 month because of a computer programming error by the state agency.

To determine why disqualified individuals were improperly included in
households and identify actions that USDA and state agencies can take to
detect and prevent disqualified participation, we contacted state agency
officials in Sacramento, California; Springfield, Illinois; Baton Rouge,
Louisiana; and Austin, Texas, to discuss and review policy and procedures
for disqualifying individuals and removing them from the food stamp rolls.
We discussed the process for verifying applicants’ data, as well as methods
of fraud detection, computerized data-matching, and quality control and
assurance, with state officials. In the five large metropolitan areas that we
selected for review, we discussed local processes for ensuring that
disqualified individuals are removed from the food stamp rolls. We
discussed with state and local officials ways that their processes could be
changed and improved to better detect and prevent disqualified
participation.

To determine how USDA can help states detect and prevent disqualified
participation, we contacted USDA officials to determine what
disqualification information is available to states, how that information is
made available to states, and what states are receiving the information. To
address data integrity issues that we identified during our review, we
analyzed a computerized copy of the DRS database and other
documentation that USDA provided us with to determine the timeliness,
accuracy, and completeness of the data and discussed our findings with



Page 26                              GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix III
Objectives, Scope, and Methodology




USDA. We discussed with USDA officials the methods for ensuring that
reliable disqualification data are readily available to states and that
disqualified individuals do not participate in the program.




Page 27                              GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix IV

Comments From the Food and Nutrition
Service, U.S. Department of Agriculture




               Page 28    GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix IV
Comments From the Food and Nutrition
Service, U.S. Department of Agriculture




Page 29                            GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix IV
Comments From the Food and Nutrition
Service, U.S. Department of Agriculture




Page 30                            GAO/RCED-99-180 Disqualified Food Stamp Participants
Appendix V

GAO Contacts and Staff Acknowledgments


                  Robert Robertson (202) 512-5138

                  Keith Oleson (415) 904-2218


                  In addition to those named above, Brad Dobbins, Leo Acosta, Rod Moore,
Acknowledgments   Donald Ficklin, Jerry Hall, Jonathan Silverman, and Oliver Easterwood
                  made key contributions to this report.




(150082)          Page 31                       GAO/RCED-99-180 Disqualified Food Stamp Participants
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