A Governor's Guide to State Opportunities to
Boost Food Stamp Enrollment

The Food Stamp Program is a federal program administered by the states, with 100 percent federal funding of the benefits. (Administrative costs are shared equally by the states and the federal government.) Because funding of benefits is 100 percent federal, broadening use of the program can help strengthen state and local economies even when state budgets are tight.

To be eligible, families must have income below 130 percent of the federal poverty line and assets worth no more than $2,000 (or, in some cases $3,000). The amount of food stamps a household receives depends on its income, its household size, and to some extent its monthly expenses for certain items like shelter. The maximum monthly benefit for a family of four is currently $465.

Benefits average 79 cents per person per meal. Four-fifths (79.6 percent) of all benefits go to households with children.

Food stamps provide valuable income and nutrition support for low-income families, but according to the most recent available data (from 2000), only 59 percent of eligible people receive them. This represents a decline from 75 percent in 1994. (The participation rate among eligible low-income working families is even lower, only 51 percent in 2000.) Researchers, state administrators, and advocates agree that a major reason for the decline was that the program had become too complicated, both for needy families to access and for states to administer.

In 2000-2002, however, a broad consensus was reached on ways to streamline and simplify the administration of the program and transform it into a more effective support for low-income working families.¹

Federal policymakers listened. The U.S. Department of Agriculture announced through rules and guidance a number of new state options to simplify administration of the Food Stamp Program and reach more needy families. And in reauthorizing the Food Stamp Program as part of the 2002 Farm Bill, Congress created yet more options to streamline administration in ways that will benefit both low-income households and state agencies. Congress also significantly reformed the federal Quality Control system so that only a few states with consistently high error rates will be subject to any fiscal sanctions. With the threat of expensive Quality Control sanctions greatly reduced, states now may more readily consider proactive strategies that reach higher proportions of eligible families with food stamps.

Thus, there is now a real opportunity to simplify state administration of the Food Stamp Program, to help more needy families in the current economic downturn, and to bring federal food stamp dollars into the states to help jump-start struggling economies.

One set of options described below streamlines the application process, making the program more inviting to new households (while easing state employees' workloads). Another set of options makes it easier for a family to keep receiving food stamps through reducing paperwork, also easing the states' job. Finally, we list steps states can take to welcome legal immigrants into the program when they again become eligible. Almost all legal immigrants lost food stamp eligibility as a result of the 1996 welfare law, but the 2002 Farm Bill restored eligibility to many of them. The restoration is being phased in over time; the largest part will occur starting April 1, 2003. With careful planning and targeted outreach (for which the federal government will pay half the costs), states can enroll thousands of new households into the Food Stamp Program this spring.

I. STREAMLINING ELIGIBILITY RULES AND THE APPLICATION PROCESS

To apply for food stamps, a family must submit an application that a state can make long or short, submit verification that a state can make complicated or simple, and have an interview at a time which a caseworker can make inconvenient or convenient for a working family.

Recent changes in federal rules and statutes let states streamline the eligibility standards and application processes considerably. These new options allow the state to eliminate paperwork at various points in the process, and in some cases will make more families eligible than are now. Under these new options, states may:

• Simplify income and asset rules. States can align their rules about what counts as income and assets in the Food Stamp Program with the parallel rules in their TANF (cash welfare) and Medicaid programs, with some exceptions. No longer do caseworkers have to apply complicated, different rules in similar programs. Aligning program rules simplifies application processing by reducing the kinds of income and resources households must list and verify, reducing questions that caseworkers pursue, and reducing the number of different rules agency staff must know and administer. States could eliminate all but the most essential asset questions from their food stamp applications and interviews. Such a change would also expand the pool of eligible families with low incomes, as some poor families now ineligible because of obscure types of income or assets would become eligible.
  
  
• Broaden Use of the Standard Utility Allowance. The computation of the amount of food stamp benefits a family gets allows a deduction for very high shelter expenses, a significant portion of which are utility costs. Families applying for food stamps generally must submit recent gas, electric, oil, water, and phone bills to the food stamp office. All states now have created Standard Utility Allowances (SUAs) - presumptive amounts for all or some utilities - which they may use instead of a family's actual utility expenses, if use of the SUA would benefit the family. The new law provides further support for this option.
  
  A number of states, however, have not adjusted their SUAs to keep up with rising utility costs. Any increase in the SUA would increase food stamp benefits for roughly one third of the state's food stamp caseload - at federal expense.
  
  
• Make application procedures more family-friendly: Many families do not apply for food stamps because their state's application procedures are too cumbersome. America's Second Harvest, the association of food banks, found in 2000 that the average state food stamp application was 12 pages long; 12 states' were over 18 pages².³ Most applications were longer than for mortgage loans, firearms permits or school bus drivers' licenses. A 1999 study showed that the average family spends a total of five hours and over $10 (primarily on carfare) applying for benefits. There are a number of steps to make procedures easier for families: shortening and simplifying application forms; extending office hours; distributing and accepting food stamp applications at new locations, including over the internet; and making sure that efforts to deter or postpone cash assistance applications do not spill over into the Food Stamp Program.

II. HELPING FAMILIES CONTINUE TO RECEIVE FOOD STAMPS

Once families overcome the initial hurdles to applying, they must meet certain rules, like reporting changes in income, in order to continue to receive food stamps. States now can make these rules much simpler - easier for families and easier for state personnel. For example, many families lose food stamps at the time they leave the welfare rolls for work, very often at low pay, unaware that they can continue to receive food stamps although they no longer receive cash assistance. Thirty percent of the former welfare families who left food stamps and who had income below the poverty level in 1999 left food stamps because of administrative problems.⁴

Fortunately, states now have a number of new options to ensure that families retain food stamps over time - options that also should reduce state administrative costs once implemented.

• Simplify reporting rules. Existing Food Stamp Program rules requiring households to report changes in their income and other circumstances to the food stamp office, often on a monthly basis, can overburden households. Many working families are unable to keep up with these reporting demands and paperwork flow, and consequently lose or forego needed food stamps for which they are eligible. States may now choose to collect information from households only every six months. Food stamp benefits are frozen during that period, and households only have to report if their income goes over the eligibility limit. This option reduces burdens on households and state caseworkers, and will result in fewer Quality Control errors.
  
  
• Provide transitional food stamps to families leaving welfare. A national study showed that, in 1999, only 43 percent of former welfare families with children still received food stamps, despite remaining eligible. Of former welfare families with income below 50 percent of the poverty level, only half still received food stamps.⁵ This alarming drop-off is largely due to two reasons: bureaucratic processes in the welfare office make it tricky to remain on food stamps, and many former welfare recipients do not know they can still receive food stamps. To address these problems, Congress now allows states to provide five months of transitional food stamps to almost any family leaving cash assistance for almost any reason. This option likewise reduces burdens on both families and state workers. For more information, see Get Ready for Food Stamp Reauthorization Changes in Your State:
  http://www.frac.org/pdf/implementation081402.PDF
  
  
• Extend the time between reapplications. In an effort to gather more information and reduce overpayments that led to federal "Quality Control" sanctions, in the 1990s many states started requiring working families to reapply for food stamps every three months. This change to shorter "certification periods" unintentionally caused a dramatic decline in food stamp participation, as families were unable or unwilling to reapply so often. The Quality Control reform in last year's reauthorization has alleviated the state fear driving the requirement of frequent reapplications. Extending certification periods to six months or a year will ease burdens on both families and state staff.
  
  
• Conduct interviews over the phone rather than in person. Many low-income working families do not apply or reapply for food stamps because they are unwilling or unable to take time off from work to apply in person. Food stamp rules require an interview before food stamps can be approved. This interview must generally be face-to-face, but states may conduct interviews over the phone in hardship situations, such as when a family's work schedule prevents the family from applying in person. States should use this flexibility liberally. For more information, see http://www.fns.usda.gov/
  fsp/rules/Memo/02/AccessforWorkingFamilies.htm

III. ACTING TO WELCOME LEGAL IMMIGRANTS BACK TO THE FOOD STAMP PROGRAM

The 1996 welfare law made most legal immigrants ineligible for food stamps. Starting April 1, 2003, however, all immigrants who have been in the United States legally for five years will again be eligible. Starting October 1, 2003, all immigrant children will be eligible regardless of how long they have lived here. And, as of October 1, 2002, all immigrants receiving disability benefits became eligible regardless of date of entry into the U.S.

The 1996 cuts have caused great hardship among legal immigrant families. In 2001, the Urban Institute reported that 37 percent of all children of immigrants nationwide lived in families encountering difficulties in or worried about affording food.⁶ The restoration is thus enormously important to the immigrant community, but poses challenges to states and communities. The food stamp eligibility rules for immigrants have changed repeatedly, leading to widespread confusion in a population that often is already isolated from traditional sources of information. Many immigrants also fear (incorrectly) that receiving food stamps will cause them to be considered a "public charge," with severe immigration consequences.

The following are suggestions for seizing the opportunity to enroll immigrants into the Food Stamp Program, alleviating hardship and bringing federal dollars into the state.

• Reach out to immigrant communities. Immigrants will not know to apply without effective outreach. The federal government will reimburse states for 50 percent of the cost of outreach activities, and is translating food stamp informational materials into 34 languages. A state's investment in outreach should rapidly pay for itself in new federal food stamp dollars flowing to state residents. For more information, see "Good Choices in Hard Times: Fifteen Ideas for States to Reduce Hunger and Stimulate the Economy": http://www.frac.org/html/news/stimulus021202.htm
  
  
• Retain state food stamp replacement programs. In the wake of the 1996 eligibility restrictions, some states created food stamp replacement programs for some or all immigrants made ineligible by the 1996 law. The 15 states with such programs will now see a budget savings as the federal government again picks up the cost of food stamps for many of the immigrants. States must make sure their programs stay in place until the federal restorations are phased in, however, to ensure that immigrants stay connected with the Food Stamp Program, and after then to reach those not covered by the new federal rules. Once a family loses food stamps, it may never return. States currently without state replacement programs may want to consider creating one now: the small investment in state-funded food stamps for the few remaining ineligible legal immigrants should more than pay for itself through increased numbers of immigrants receiving federally-funded food stamps. Instead of a message that immigrants are eligible if they fall within one of numerous categories, the message would be "all low-income legal immigrants are eligible." Such a message should greatly increase the numbers of immigrant applicants, the vast majority of whom would be eligible for federally-funded food stamps. For more information, see FRAC's Opportunities to Maximize the Effects of Immigrant Restorations in the Food Stamp Reauthorization Act of 2002 .
  
  
• Prepare to enroll as many immigrants as possible on April 1, 2003. States must start accepting applications on March 1, 2003 from immigrants seeking food stamps starting in April. With USDA permission, however, states may accept applications before March. USDA has said it will approve any state's request to start accepting applications on February 1, and will consider requests to start earlier. USDA has also urged states to review their existing records to identify immigrants who may be eligible starting in April, to let them know of the restoration. For more information, see Get Ready for Food Stamp Reauthorization Changes in Your State: http://www.frac.org/pdf/implementation081402.PDF
  and USDA's recent guidance at
  http://www.fns.usda.gov/
  fsp/rules/Legislation/pdfs/Non_Citizen_Guidance.pdf
  
  
• In families where immigrants remain ineligible, boost their children's food stamp benefits by changing income-counting rules. Many immigrant families even with ineligible adults include at least one United States citizen, typically a child. Such children can receive food stamps while the ineligible immigrant does not. States can boost food stamp benefit allotments for the eligible members of these mixed families by disregarding the ineligible members' income. Since the ineligible members can't get food stamps, they need their income for their food and other essentials. If the parents are ineligible, applying this option would typically mean that the children (with no income of their own) would receive the maximum food stamp allotment. Adopting this rule can greatly increase immigrant families' food resources, at no cost to the state. A special rule ensures that households with ineligible immigrant members do not receive more benefits than similarly situated households in which all members are citizens. For more information, see "Good Choices in Hard Times: Fifteen Ideas for States to Reduce Hunger and Stimulate the Economy":
  http://www.frac.org/html/news/stimulus021202.htm and FRAC's analysis of Immigrant Access to Food Stamps: http://www.frac.org/text%20documents/sonya.pdf.