Those of us who work with HHS public sector clients know that change is inevitable, whether it is driven by new legislation, changes in administration, or just continuous process improvement of government programs. This blog explains some of the ways the 2018 Farm Bill, passed by Congress and signed by the President in December 2018, may launch the need for technology support.
At a high level, the 2018 Farm Bill reauthorizes SNAP (Supplemental Nutrition Assistance Program) - formerly known as the Food Stamp program – through 2023. While the final version of the bill does not call for significant change to SNAP eligibility, it does include several provisions related to SNAP Employment & Training (E&T), as well as a variety of other changes regarding Electronic Benefits Transfer (EBT), Quality Control (QC), SNAP-Ed Reporting, and the use of SNAP for online food purchases.
The two changes that will most likely require new technology initiatives at the State level are as follows:
1-The legislation mandated the establishment of the National Accuracy Clearinghouse (NAC) - a technology-based solution designed to curb interstate dual participation in SNAP. The premise of the NAC is simple – states contribute daily files of their active SNAP participants in a common format to a centralized database. The states then submit information requests to the database on program applicants, and the NAC looks for overlapping information on a range of data points, such as Social Security Numbers, names, and dates of birth (DOB), to determine if the individual is already a SNAP recipient in another state.
The Farm Bill required USDA/FNS to issue guidance for nationwide implementation of the NAC within eighteen months of enactment, and regulations have yet to be released. The legislation requires these regulations to “incorporate best practices and lessons learned” from the NAC pilot conducted in five southeastern states in 2014-15. The evaluation of the pilot found that states that integrated the NAC into their eligibility systems realized significantly better outcomes (i.e. prevention of dual participation) than those that did not. So, in addition to the creation of contributory files, which are necessary for the NAC to match information, states can expect to develop ways to effectively incorporate the information returned from the database into eligibility systems and business processes.
The full NAC evaluation can be found via the USDA/FNS website at:
2-While the Farm Bill’s changes to SNAP eligibility provisions were limited, the administration has proposed changes with large impacts via the rulemaking process in the months following passage. Most notable is limiting the scope of Broad-Based Categorical Eligibility (BBCE). States have utilized this provision to increase or eliminate resource (asset) limits and increase income limits for SNAP. By re-defining what makes a family categorically eligible, an estimated 3 million people could lose their SNAP benefits. States have modified their eligibility systems to accommodate BBCE-related policies, and these would need to be re-visited when the proposed rule becomes final.
We will continue to monitor the federal website for guidance and implementation of the final rule. Many states will be evaluating the impact of these changes on their programs and systems; identifying these changes will be a good place to begin developing requirements for necessary technology modifications.
Additional information on the Farm Bill’s provisions can be found on the USDA/FNS website - https://www.fns.usda.gov/snap/snap-provisions-agriculture-improvement-act-2018-information-memorandum.