An Audit Report on the Supplemental Nutrition Assistance Program at the Health and Human Services Commission

March 2010

Report Number 10-026

Overall Conclusion

The Health and Human Services Commission (Commission) should eliminate process inefficiencies, more fully utilize technology, better manage its workforce, and develop detailed management information to improve the timeliness and accuracy of its Supplemental Nutrition Assistance Program (SNAP, formerly Food Stamps) eligibility determinations. The Commission currently falls significantly short of federal requirements for both timeliness and accuracy. Many local eligibility offices continue to use inefficient, outdated processes and have been unable to respond effectively to an increased number of SNAP applications. To improve the timeliness and accuracy of SNAP eligibility determinations, the Commission must modernize its eligibility determination processes and continue to improve its management of the SNAP program and workforce.

The percent of SNAP applications that the Commission processed in a timely manner fell from almost 92 percent in fiscal year 2006 to less than 70 percent in fiscal year 2010. At the same time, the number of SNAP eligibility determinations that the Commission completed increased from an average of 191,041 per month in fiscal year 2006 to an average of 279,336 per month in the first five months of fiscal year 2010, a 46 percent increase.

In fiscal year 2010, the Commission had hired more than 800 additional staff in its Office of Eligibility Services as of February 2010 to improve the timeliness of its SNAP eligibility determinations. The addition of significantly more inexperienced eligibility workers makes it more important that the Commission work to streamline its SNAP processes and improve the way it manages its workforce.

SNAP Error Rates

One result of having a less tenured staff has been a significant increase in the error rate for SNAP eligibility determinations. Since fiscal year 2004, the Commission's self-determined error rates for both inappropriate denial of benefits (negative errors) and inaccurate benefit issuances (positive errors) increased sharply. (See Appendix 3 for more information about SNAP error rates.) Additionally, the State of Texas Federal Portion of the Statewide Single Audit Report for the Fiscal Year Ended August 31, 2009 (State Auditor's Office Report No. 10-339, March 2010), contained findings related to errors and control weaknesses in SNAP eligibility determinations. Having a streamlined determination process and an experienced, well-trained, and supervised staff should help the Commission reduce error rates and increase timeliness. Many recommendations in this report are intended to address these issues.

Communication with Applicants and Clerical Support

The Commission should take immediate steps to better inform SNAP applicants about the information they are required to submit during the eligibility determination process. Better communication should reduce the number of trips that clients make to local offices, reduce the waiting times in local office lobbies, and reduce the number of cases the Commission pends following the required SNAP interviews. Local eligibility offices do not consistently post clear guidance on program requirements, and clients often must wait in long lines just to ask basic questions. Clients often cannot get answers over the telephone because local eligibility office staff are unavailable to answer questions over the telephone and because of phone system problems that local eligibility offices have experienced. In addition, the Commission does not utilize e-mail or the Internet to more effectively communicate with clients, including allowing clients to use this technology to check on the status of their applications.

Local office clerks could better support the eligibility determination process by contacting clients to remind them to bring all required documentation to the clients' scheduled interviews. Also, clerks should be trained to thoroughly review application documents prior to the interviews to avoid inappropriately expediting clients who are not eligible for emergency benefits, and to avoid errors in automated systems that delay eligibility determinations (see page 8 in the Detailed Results section of this report for further information).

Technology

The Commission also needs to better utilize technology to minimize delays in eligibility determinations. The Commission should consider using readily available, inexpensive scanning equipment to create electronic case files for the approximately 80 percent of SNAP cases that are still maintained as paper files, which are labor-intensive to maintain and store, and are prone to errors and loss. The Commission also should consider utilizing risk scoring programs that automatically rank SNAP cases based on their complexity. Risk scoring programs could streamline the eligibility determination process, reduce errors, and strengthen fraud detection by identifying:

- Low-risk recertification cases for which eligibility determination may be fast-tracked.

- Difficult cases that should be worked by more experienced staff.

- Cases with fraud characteristics that should be given additional scrutiny.

Workforce Management

Eligibility workers with less than two years of experience currently make up about 41 percent of the Commission's frontline eligibility workforce, compared to fiscal year 2005 when these less tenured workers made up about 4 percent of the eligibility workforce. Additionally, the number of Texas Works Advisor IVs, who act as assistant supervisors, declined from 733 in fiscal year 2005 to 441 in fiscal year 2010, a decrease of approximately 40 percent.

The Commission's limits on supervisors' compensatory time resulted in eligibility workers working a significant amount of overtime without a supervisor on duty. The Commission reported that, in calendar year 2009, eligibility workers worked more than 1 million hours of combined overtime and compensatory time.

The Commission should improve the way it manages the eligibility workforce to minimize the effects of having inexperienced eligibility determination staff. To do this, the Commission should:

- Establish clear performance expectations for eligibility workers to serve as the basis for assessing performance and planning for staffing needs.

- Revise its policies on case reading, overtime, and compensatory time.

- Reassess the effectiveness of its training for new eligibility workers.

- Reassess and consider increasing the salaries of eligibility workers to help recruit qualified workers and retain experienced staff (see page 20 in the Detailed Results section of this report for information about the average salaries of eligibility workers).

Management Information

The Commission also lacks sufficiently detailed management information that it could use to analyze opportunities to re-engineer and streamline its eligibility determination process, speed up its application process, and accommodate the increased demand for services. Although the Commission generates numerous management reports on eligibility determination, there is a lack of consensus among state, regional, and local eligibility offices regarding which key performance indicators should be tracked for more effective management of SNAP.

The Commission has not maintained the programming, distribution, and use of management reports generated by the System for Application, Verification, Eligibility, Referral, and Reporting (SAVERR). It also lacks timely, automated reports on the accurate amount of the SNAP application backlog or the current workload needing to be processed.

In addition, the Office of Eligibility Services did not receive key management reports on received, pended, and delinquent applications and current caseloads from fiscal year 2005 to November 2009.

Supplemental Federal Funding

The federal government has recently made available to the Commission more than $27 million in supplemental funding for the administration of SNAP. The Commission should consider using these funds to address the recommendations in this report related to salaries, training, and technology.

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