Measuring the Timeliness of Supplemental Nutrition Assistance Program (SNAP) Applications for Recertification

Section II(e)(4) of the Food and Nutrition Act of2008 (the Act) entitles Supplemental Nutrition Assistance Program (SNAP) recipients to a timely recertification and creates a finite period of eligibility. Specifically, the Act requires the State agency to notify the household that its certification period is ending prior to the last month of the certification period. The Act also requires the State agency to provide eligible households with benefits no later than one month after the last allotment was received, provided that the household files a timely re-application and is "found to be still eligible."

We have become increasingly aware of problems and complaints concerning untimely recertification actions. For a household that depends on its SNAP issuance cycle to make ends meet, an untimely recertification can affect its food budget as strongly as an untimely action on an initial application. Recertification timeliness has become a larger issue as States struggle to provide households with timely benefits. Many households have waited for long periods to receive benefits and some have chosen to apply for benefits as a new applicant instead of waiting for their recertifications to be processed in order to receive benefits quicker.

While the Food and Nutrition Service (FNS) has monitored the timeliness of initial applications for many years, we have lacked an ability to monitor the timeliness of recertifications systematically. Without the ability to measure the timeliness of recertifications, FNS has no real way to monitor how well or poorly States are providing households with benefits timely.

We examined whether issuances could be authorized while the recertification process was pending. The Act couples the entitlement to timely recertification with a requirement of a finding of continuing eligibility. SNAP regulations at 7 CFR 273.14 state that households may not receive benefits beyond the end of their certification period without a fresh determination of eligibility for a new period. Based on law and regulation, we cannot support this approach.

We also considered to what extent we could rely on the Management Evaluation (ME) process to improve our oversight of the process. MEs are invaluable because they can identify how practices and procedures are affecting outcomes. However, they are not designed to gather representative data about State performance.

Accordingly, we believe that we must start to measure recertification timeliness more systematically. We recognize that FNS and States will be implementing a more rigorous review of negative actions beginning on October 1, 2012. In order to allow maintained focus on this critical initiative, we are requiring that State agencies begin to review the timeliness of recertification actions with the October 2012, Quality Control (QC) sample. During the corning fiscal year, we hope to work with several States to test our procedures for measuring timeliness.

We are attaching a flow chart, a process narrative, and a set of questions and answers that describe specific review procedures. We soon will be revising the 310 Handbook along these lines. Some of the key points are:

• Only recertification actions that occur during the same fiscal year as the QC reviews are subject to review. This parallels the review of initial certifications for timeliness. We recognize that it will yield a smaller sample, but want to be sensitive to resource constraints and focus on obtaining more current performance information.
• Review procedures will identify instances where client-caused delays contribute to untimely recertification and drop these cases. Specifically, cases will be dropped if issuance is not timely but the participant failed to timely reapply, missed an interview, or did not timely turn in verifications. This procedure differs from the measure of the timeliness of initial certifications, which was developed as a basis for performance bonuses. We wanted a measure that focuses on compliance with law and regulations.
• Regional offices will be expected to re-review State recertification timeliness findings for cases in the federal subsample.

We believe that these reviews will provide empirical information that will enable FNS to fulfill its oversight responsibilities and allow States to make informed assessments about the effectiveness of their procedures and systems.

We recognize that this is not an easy time for anyone to take on increased responsibilities, but improving our oversight of such an important component of food access is apriority. We will be working closely with the regions over the coming months to assist in a smooth implementation.

Jessica Shahin
Associate Administrator
Supplemental Nutrition Assistance Program

Attachment

• How to Code Recertification Timeliness for Active Cases
• Steps to Measure Recertification Timeliness/or Active Cases
• Questions and Answers on Coding Recertification Timeliness