Food Insecurity in Central Texas

Policy Recommendation for SNAP Reform in Texas

Eddiemae Nash Nicolas Norboge Mary Rivera Michael Walter

The George Bush School of Government and Public Service Texas A&M University

Table of Contents
I. Executive Summary ............................................................................................................... 3 I. Food Insecurity Among the Working Poor in Texas .......................................................... 3
Food Insecurity in Texas........................................................................................................................ 3 Supplemental Nutritional Assistance Program ...................................................................................... 4 Texas SNAP Inefficiency......................................................................................................................... 4

II. State Comparisons ................................................................................................................... 5
Application Format ................................................................................................................................. 6 Application Processing ........................................................................................................................... 6 Fingerprinting ......................................................................................................................................... 6 Phone Application................................................................................................................................... 6

IV. Recommendations .................................................................................................................. 6
USDA Takes Action ............................................................................................................................... 6 Results of Implementation ...................................................................................................................... 8

V. Alternative Options................................................................................................................ 9 IV. Conclusion............................................................................................................................. 10

I. Executive Summary In our research we determined the size of the food hardship problem among the working poor in the Central Texas region served by the Capital Area Food Bank (CAFB). Over one-tenth of the population of the 21 counties served by CAFB is classified as poor, and a large portion of the poor are defined as working poor. We determined that poverty is congruent with food insecurity. Many poor households do not have the means to purchase an adequate amount of food and depend on other agencies to provide food. Food insecurity among the poor is a significant problem, and the US Department of Agriculture (USDA) implemented the Supplemental Nutrition Assistance Program (SNAP) in response to food insecurity. SNAP is a supplemental food program to help low-income families purchase nutritious foods. SNAP is partially funded by the federal government and administered by state governments. In Texas, SNAP is administered by the Health and Human Services Commission (HHSC). Although SNAP should reduce food insecurity, working poor families within Texas that are eligible for SNAP do not receive benefits. Many eligible SNAP applicants do not receive benefits because of inefficiencies with the HHSC and SNAP application. The HHSC does not have an appropriate number of employees to meet the demand to process SNAP applications, and the HHSC computer processing system is not compatible for processing SNAP applications in a timely manner. The Government has established its responsibility to assist the poor in purchasing food, and it is the responsibility of the state to ensure that poor Texans applying for SNAP receive benefits in a timely manner. To reduce hunger and food insecurity amongst the working poor in Texas we recommend the following strategies implemented by the HHSC: 1. Meet with other states who are successfully administering the program 2. Consider current state options that can simplify administrative burden 3. Suspend the finger imaging state requirement for SNAP 4. Establish a single and accountable point of contact for the corrective action plan (CAP) 5. Use community partners more extensively and efficiently in application assistance. 6. Assess phone capacity to maximize use of telephone interviews The six strategies are necessary for HHSC to react to the conditions of food insecurity among the working poor and to ensure efficient access to SNAP.

I.

Food Insecurity Among the Working Poor in Texas

Food Insecurity in Texas A record number of the population of the 21 counties served by the Capital Area Food Bank of Texas (CAFB) is experiencing food insecurity, which is “limited or uncertain access to nutritionally adequate and safe foods, or limited or uncertain ability to acquire acceptable foods in socially acceptable ways,” (USDA, b, 2009). Between 2006 and 2008, 16.8% of Texas residents were food insecure at some time during the year, and Texas has the highest food insecurity rate among all 50 states and the District of Columbia (USDA 2008). According to the CAFB, most of those who experience food insecurity are the working poor. The working poor are defined as those living at or below 200% of the federal poverty guidelines and has at least one member of the household employed (CAFB 2006). The region served by CAFB has a combined poverty rate of 14.27%, (See Appendix 1) and the state has a poverty rate of 15.8%. Of those classified as poor, 81% are working poor (Kluever 2005). The poverty

rates are indicative of food insecurity. The CAFB reports that 76% of clients have incomes below the federal poverty line and 82% of clients are food insecure (CAFB 2006); the statistics illustrate the correlation between poverty and food insecurity. The Texas population living at or below the 200% federal poverty line has rose from 36.5% to over 38% (Baylor 2009) in response to the economic downturn; thus, the rate of food insecurity will likely increase. Supplemental Nutritional Assistance Program The Supplemental Nutritional Assistance Program (SNAP) is a food assistance program designed to supplement the grocery costs for poor Americans. In Texas, the Health and Human Services Commission (HHSC) administers the program through a debit card system called Lonestar. Benefits are electronically transferred to an individuals Lonestar account, and the card is used like a debit card at grocery merchants. Despite the existing program, much of the Texas population eligible for SNAP do not participate in the program. According to data supplied by the CAFB, nearly 60% of those eligible for SNAP are not participants of the program. Also, only 27% of eligible clients that apply for SNAP are receiving benefits (CAFB 2006). Inefficiencies associated with HHSC administration are linked to low enrollment rates for eligible SNAP applicants and the small percentage of clients receiving benefits. Controversial application procedures and improper management prevent HHSC from processing SNAP applications in a timely manner. Texas SNAP Inefficiency The Texas SNAP program is being criticized for various management inefficiencies and controversial eligibility and application requirements. HHSC Inefficiency Low staffing of HHSC employees and the system used to process client applications complicate the SNAP administration. Many SNAP employees are frustrated with the Texas Integrated Eligibility Redesign System (TIERS) because of its inability to process SNAP applications by the federal time limit. TIERS is a browser-based computer system aimed at supporting and monitoring employees processing SNAP applications. USDA guidelines require that states take no longer than thirty calendar days to process 95% of SNAP applications; however, in September of 2009 Texas takes over the time-limit to process over 58% of applications (TSEU 2009). TIERS has received much criticism because the system does not meet federal performance standards. Low staffing of SNAP employees complicates the problem with TIERS further. HHSC requested the ability to hire 650 new staff members to meet federal time guidelines imposed on SNAP; however, the State Legislative Budget Board (LBB) approved only the immediate hiring of 250 employees (TSEU 2009). The delay in application processing created by TIERS and low levels of staffing cause many families to continue to endure hunger and depend on food pantries, but food pantries are stretched thin because of the bad economy.

Finger Imaging The fingerprinting requirement for the SNAP application also complicates the process. Finger-imaging on the SNAP application is a requirement imposed by the State, and is intended to reduce fraud. Although finger-imaging was intended to be beneficial, finger-prints deter eligible individuals from applying for SNAP. An Urban Institute report found that finger-printing requirements in the SNAP application can lead to a 4.3% reduction of SNAP recipients. The research suggests that fingerprinting requirements are intimidating to populations that fear the government and who are more likely to be in need of services like SNAP (Davenport 2009).

Lack of Outreach Organizations such as CAFB have advocated for policies to reduce food insecurity, but the state has refused to implement practical policies to prevent more families from experiencing hunger. HB1622, the Food Bank Bill, legislates funding for nonprofit organizations to provide food insecure children with nutritious food outside of school (TX HB1622). The Food Bank Bill was passed in the House and Senate, but was not funded by the Legislature. Although the bill was signed into law, it is inactive because there are no funds to implement the policies. Food Banks such as CAFB advocate for funding HB1622 because they want to increase hunger outreach. Although food banks and other community organizations have the potential to do significant hunger advocacy, a lack of coordination with HHSC and the state prevents SNAP outreach. Communication HHSC does not process SNAP applications in a timely manner because of limited phone capacity to complete telephone interviews. Interviews are a requirement to complete the SNAP application, and an interview can been done face-to-face or by telephone. Although telephone interviews are faster than onsite interviews, the HHSC does not have the phone capacity to meet the demand for telephone interviews. It is logical for the HHSC to complete most interviews by telephone because the majority of clients have access to a working phone. CAFB data shows that over 78% of clients have access to a working phone, as opposed to 49.2% having access to a working car (CAFB 2006). Limited phone capabilities add to the wait-time for completing SNAP applications, and further backlog the agency.

II. State Comparisons Texas 24,326,974 3,837,000 2,417,310 10 pages 3,400,000,000 139762.55 7,950 Yes No Yes $150,164,867 $141,988,412 Louisiana 4,410,796 835,000 659,650 15 pages 522,200,000 118391.33 5,057 No Yes Yes $49,159,488 $48,921,282 California 36,756,666 3,931,000 1,965,500 3 pages 2,700,000,000 73456.06 Not Available Yes No Yes $492,107,119 $565,090,916

Total Population Eligible Enroll (Monthly) Application Type (Length) Budget received (approx) Budget allocation per person per capital Staff Finger print Phone application Online application Federal administrative cost State administrative cost

The table above provides a comparison between Texas, Louisiana and California SNAP statistics. The impact on SNAP efficiency for each state is illustrated by the statistics. The state of Louisiana has the highest enrollment rate with a 79% while Texas has 63% and California 50% respectively. Areas for analysis are application format, ratio between enrollment and agency staff, use of fingerprints as part of the application process and availability of phone applications.

Application Format The application format for each state varies. While California’s application consists of only three pages, the application for Texas and Louisiana are ten to fifteen pages in length. Although the application for the state of Louisiana is fifteen pages, most of the questions asked are easy to comprehend, the Texas application questions are more complex and often difficult to understand. The complexity of the application often creates delays in allowing eligible applicants receive the benefits. SNAP applications should be written in manner that is comprehendible by all applicants Application Processing The ratio between enrollment and staff is significant. Texas has a ratio of 304 applications processed per staff member every month and Louisiana has a ratio of 130 applications processed per staff member. Even though Texas has larger staffing, the amount of applicants and those eligible for benefits are greater than Louisiana. In order for the state of Texas to have a more efficient program and be able to enroll a greater number of eligible people, the ratio between enrollments and agency staff should be more similar to the ratio for Louisiana.1 Fingerprinting A finger-print requirement is another difference between states states. Of the three mentioned above, Texas and California require finger-imaging to apply for benefits. Although the requirement was designed to detect duplicate aid fraud and save the states money, finger printing can lead to the reduction of SNAP recipients and intimidate the population. Phone Application Another resource that is provided by the state of Louisiana is the convenience to initiate the SNAP application by phone. This allows applicants with limited or no transportation to apply for benefits faster. The Texas HHSC should offer various methods to complete the SNAP application, similar to Louisiana. The Louisiana Department of Social Services (DSS) has one of the more efficient applications. The SNAP application for Louisiana is most accessible, and DSS has the better enrollment/staff ratio. The USDA also recently awarded the DSS $1.8 million in SNAP bonus for the best application processing time (USDA, a, 2009). HHSC should consider the procedures and standards of DSS to improve the program and provide the Texans a better service.

IV. Recommendations USDA Takes Action Officials of the USDA Food and Nutrition Service oversee and examine the systems of the Texas HHSC. On September 30, 2009, after several meetings with HHSC, the regional administrator for SNAP, William Ludwig, sent a letter to Tom Suehs, the commissioner of HHSC, warning him that unless changes were made to the SNAP program USDA would be forced to pull federal funding for SNAP within Texas. USDA identified the major problems discussed above and recommended six points of

                                                                                                               
1

Data was not available for California to be included in this section.

action for HHSC to be in statutory compliance. The letter also mandated that HHSC a Corrective Action Plan (CAP) with details on how HHSC will implement the federal mandate to the USDA within sixty days. As low enrollment in SNAP is a major factor to hunger in Texas, we recommend that HHSC follow the USDA’s recommendations in correcting the problems associated with eligibility verification and enrollment: 1. Meet with other states that are successfully administering the program. By meeting with states that are effectively administering the SNAP program, Texas will have the opportunity to learn which strategies and processes that provides the most efficient services. States such as Missouri, having a 98% participation rate (USDA 2009), may be able to provide options for Texas. In 2009 Agricultural Secretary Tom Vilsack and the Department of Agriculture awarded several states monetary bonuses for best program access and application processing times. Vilsack recognized the states and suggested that the rewarded states serve as models to other states (USDA, a, 2009). The Texas HHSC would benefit from meeting with and receiving recommendations from other states that are successfully administering SNAP. 2. Consider current state options that can simplify administrative burden The inefficiency of the Texas SNAP program is caused by burdens associated with the HHSC administration. The HHSC administration can ease problems associated with the SNAP program by simplifying application processing. The Louisiana DSS was recently awarded for outstanding performance and timeliness of administrating SNAP by the US Department of Agriculture (USDA, a, 2009). Louisiana DSS uses an internet-based system developed by Curam Software to process SNAP applications. Curam is a Social Enterprise Management (SEM) developer for computer operations and applications (Curam 2009). The DSS implemented a prescreening eligibility interface for DSS clients to access; the interface reduces confusion and wait-times at DSS offices. The DSS also uses on-site license scanners to verify the identity of applicants and reduce the time needed to process applications (Curam 2009). Unlike Louisiana, the HHSC currently uses the TIERS internet-based software to operate application processing; however, TIERS is inefficient in processing SNAP applications in a timely manner according to USDA guidelines (Hagert 2009). Administrative complications can be simplified by implementing an effective computer-based program to process SNAP applications. 3. Suspend the finger imaging requirement for SNAP David Davenport, CEO of the Capital Area Food Bank, in a letter to USDA Secretary Vilsack said, “According to the most recent USDA data, payment error rates for the 4 states that finger image were 6.93% compared to… [a] 5.49% national average,” (Davenport 2009). The fingerprint requirement is not having an effective impact on fraud reduction. According to the USDA, the four states that have fingerprint requirements have participation rates of 59.25% of eligible people, which is lower than the 67% national average. The data suggests that mandating fingerprints could be a contributing factor to low participation rates among the eligible.

4. Establish a single and accountable point of contact for the corrective action plan (CAP) State administrators for HHSC have expressed a desire to work with the USDA to improve SNAP within Texas; however, it will not be possible to successfully modify SNAP without implementing a

corrective action plan. HHSC does not have an overseer specifically for SNAP to monitor performance, and many of the performance inefficiencies of SNAP can be overlooked as a result of minimal accountability requirements (van Thiel 2002). A single point person for SNAP would establish a CAP and monitor its efficiency and effectiveness with the option of implementing a balanced scorecard management system to organize performance data and link operational areas (Kerr 2003). The fourth strategy ensures that improvements for SNAP are being made and closely monitored.

5. Use community partners more extensively and efficiently in application assistance. Community partners can help reach those individuals who may be eligible for assistance, but who either do not know the program well or are intimidated by the application and enrollment process. Lisa Goddard, the director of Advocacy for CAFB says, “For many federal programs and initiatives for low-income populations, nonprofits are well-suited for outreach. As a long-standing community resource, the Capital Area Food Bank has the access, trust and cultural competency needed to serve these high-needs populations,” (Goddard 2009). By tapping into the already existing social networks provided by nonprofit organizations, HHSC can increase the number of eligible people enrolled in SNAP. Last year, according to Goddard, CAFB was able to submit 66 applications for benefits but most of their outreach was restricted to the Austin area due to limited capacity and funding. With higher funding, the capacity to reach more rural areas could be expanded. 6. Assess phone capacity to maximize use of telephone interviews Currently, applicants of SNAP are required to undergo interviews for verification purposes. Within the HHSC, interviews can be completed either by telephone or face-to-face at agency offices. Initially interviews for the Texas SNAP application were only conducted by face-to-face; however, in July of 2009 policy was changed to allow telephone interviews to complete the initial application interview (HHSC 2009). Face-to-face interviews were required to reduce the fraud associated with income eligibility, but a report by the Center on Budget and Policy Priorities suggests that face-toface policy does not reduce fraud and are not necessary to verify incomes (Lueck 2009). Although telephone interviews were intended to ease the backlog of application processing at HHSC, the Center for Public Policy Priorities reports that staff shortages and lack of phone capacity to handle the demand of telephone calls contribute to inefficiency (Baylor 2009). Increasing phone capacity and maximizing the use of telephone interviews can improve the efficiency of SNAP. Benefits of Implementation By implementing these strategies, HHSC can react to present conditions of food insecurity amongst the working poor and ensure efficient access to SNAP in the future. The CAP point-of-contact will monitor the performance of SNAP within the state and ensure effectiveness and accountability for the changes implemented. Government has a responsibility to address the need of food insecurity among the working poor, and although the federal government has responded to hunger through SNAP, the Texas government has failed to properly execute SNAP policies. While nonprofits such as CAFB are a critical option for working poor families that do not have the means to purchase food, the working poor should not have to solely rely on charitable organizations to provide food if they qualify for SNAP. The state should be upheld to its role to effectively administer SNAP, and our recommendations address the problems that cause inefficiencies with SNAP. Implementing the strategies upholds the state to its role in relieving hunger, and ensures qualified working poor Texans receive food benefits from SNAP.

V. Alternative Options Due to the growing disparities encountered by the Texas working poor, state officials must work to increase enrollment in the program and increase application process efficiency. As stated previously, the inefficiency of Texas SNAP has concerned federal officials who insist that corrections be made to bring Texas administration of SNAP into compliance with federal requirements (Ludwig 2009). State legislators have suggested alternatives to reforming the state’s SNAP program. First, state legislators have questioned why action toward hunger should be taken. Some state legislators have suggested giving direct subsidies to food banks, and others have argued that simply hiring more SNAP workers will be the sole solution to food insecurity. These alternatives have been the most significant approaches taken by the Texas state legislature. Take No Action The first alternative proposed by some state legislators is to take no action. Although research insists otherwise, some lawmakers suggest that food insecurity is not a critical matter worthy of addressing or funding. Considering CAFB and the Central Texas region, the argument for inaction is problematic because unemployment and poverty have risen in Central Texas and caused increased need for food supplement. Taking no corrective action to improve SNAP will result in many Texans having to endure hunger. Texas unemployment rates have increased drastically, and unemployment for the Austin-Round Rock area served by CAFB has experienced a 36% increase from one year ago (Dept. of Labor 2009). Only 60% of Central Texas families earn the required income level for comfortable living, and the slightest change to family income or expenses threatens the financial security of families. Many times when families face financial hardship, they choose to reduce food costs to cover other expenses. SNAP supplements the costs of food for working poor families, and SNAP is a preventative method of hunger and food insecurity. Ultimately, if state legislators choose to do nothing, it will mean that more than 100,000 Central Texans will continue to remain food insecure. In addition, there SNAP benefits the state $632.6 billion (Crowe 2009). Allowing food insecurity and hunger to go unaddressed will have significant social and economic consequences for Texas in the years to come.

Increase Funding to Non-Profits Another alternative recently sought by state legislators is to increase funding to non-profits with the assumption that these groups can offer state services more efficiently than the state’s SNAP program. House Bill HB 1622, signed into law in June, was intended to direct free food to needy families through existing systems (food banks and food pantries etc.) with state appropriations (Texas HB 1622). While some food bank officials initially lauded this bill, it has problematic consequences. First, it shifts the responsibility of solving food insecurity away from state administrative responsibility to private groups who use workers who are not accountable for delivering critical state services. Because food banks and non-profits use volunteers as “employees,” they do not collect any salaries and therefore bear no responsibility on ensuring that food insecurity should be reduced. Secondly, it is unlikely that it will be politically feasible to appropriate the amount of taxpayer money that would be needed for this program to be successful. As of now, the LBB has failed to attach any funding to this program and has no indication of appropriating any funding to food banks in the future (Texas HB 1622). In effect, state legislators sought to shift food insecurity responsibility away from the HHSC to the CAFB without appropriating any funding. This also places an undue burden on food banks to provide state services. In a time when donations to food banks are down and demand for food is growing, failing to deal with problems associated with the SNAP program can be particularly problematic. Clearly, both

food bank organizations and the working poor would stand to lose, and the problem of food insecurity will still remain. Ultimately, delegating responsibility to food banks is not an effective way to deal with the state’s growing food insecurity problem and neglects the benefits that could come if this money were to be appropriated toward reforming the state’s SNAP program instead.

Increase Staffing for SNAP A third alternative proposed by state legislators is increasing the number of SNAP employees will solve food insecurity in Texas. State legislators have even moved recently to hire an additional 250 workers to the SNAP program to alleviate over-worked SNAP employees and to meet federal statutory requirements (Texas HB 2962). While it is true that this alternative will help in alleviating problems with the Texas SNAP program, it doesn’t go far enough. First, this alternative fails to consider that 41% of eligible working poor in Texas SNAP are not enrolled in the program (CAFB 2006). Improving processing efficiency means nothing if people that the program is intended to benefit are not able to complete applications for enrollment. Second, this alternative fails to address the potential benefits of reducing the length of the application, resulting in reduced resources required to process the applications. Hiring more SNAP employees does not solve other factors contributing to the inability for working poor to get SNAP benefits and is an expensive solution that does not to address food insecurity in Texas.

IV. Conclusion Our research of the 21 counties served by Capital Area Food Bank has allowed us to determine that a substantial population of the working poor in Texas suffers from food insecurity. Many of those that suffer from food insecurity qualify for SNAP but do no receive benefits. According to our research, food insecurity among the working poor that qualify for SNAP is largely attributed toward the ineffective administration of SNAP. The HHSC does not effectively administer SNAP because of complications with the application process and the HHSC does not have an efficient method for performance measurement. The rate of the food insecure amongst Texans is astonishing; however, progress can be made by improving HHSC administration and the SNAP application. It is the role of the state to reduce food insecurity and ensure that those eligible for SNAP are receiving benefits through successful administration of SNAP. To reduce food insecurity amongst the working poor in Texas w recommend policymakers consider simplifying the SNAP application process and restructuring the administration of HHSC. We suggest more coordinated partnership with community organizations to promote SNAP outreach as well. Finally, we also recommend implementing a corrective action plan to enforce and monitor the improvements of HHSC and SNAP. Implementing the strategies upholds the state to its role to relieve hunger, and ensures qualified working poor Texans receive food benefits from SNAP.

Appendix 1 Income and Poverty in the 21 Counties served by CAFB
By Name: By Poverty Percentage:

County Bastrop Bell Blanco Burnet Caldwell Coryell Falls Fayette Freestone Gillespie Hays Lampasas Lee Limestone Llano McLennan Milam Mills San Saba Travis Williamson Averages

Poverty Annual Percentage Income $51,563 12.60% $47,434 13.60% $49,320 10.60% $48,321 12.90% $43,846 16.70% $44,697 15.30% $30,265 27.70% $45,005 12.40% $40,664 13.60% $49,818 9.90% $55,132 13.70% $45,107 13.60% $44,875 12.30% $35,110 21.30% $41,521 12.40% $40,459 19.10% $39,427 17.30% $35,725 17.20% $34,908 19.80% $53,209 14.60% 6.00% $68,320 14.89% $44,986.95

County Williamson Gillespie Blanco Lee Fayette Llano Bastrop Burnet Bell Freestone Lampasas Hays Travis Coryell Caldwell Mills Milam McLennan San Saba Limestone Falls Averages

Poverty Annual Percentage Income 6.00% $68,320 9.90% $49,818 10.60% $49,320 12.30% $44,875 12.40% $45,005 12.40% $41,521 12.60% $51,563 12.90% $48,321 13.60% $47,434 13.60% $40,664 13.60% $45,107 13.70% $55,132 14.60% $53,209 15.30% $44,697 16.70% $43,846 17.20% $35,725 17.30% $39,427 19.10% $40,459 19.80% $34,908 21.30% $35,110 27.70% $30,265 14.89% $44,986.95

Source: US Census Bureau: Small Area Income and Poverty Estimates (SAIPE)

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