Ideas can make processes better and UCOWF is offering its perspective for making the SNAP program more fiscally-sound and effective. With a roaring economy and extremely low unemployment, UCOWF believes it is time for lawmakers to look at ways to improve program integrity.
In a letter to the US House of Representatives Committee on Government Oversight, UCOWF President Jack Heacock offered UCOWF’s assistance in any Welfare Reform legislation by lending our perspective on fraud. To demonstrate our value, Heacock provided 23 ideas that, if implemented, would improve the integrity of the SNAP program without costing additional tax dollars. In fact, implementing these ideas would prevent dollars from being lost to fraud in the first place.
Among the ideas provided, several are of particular concern to UCOWF.
- High on our list is re-purposing the bonus incentive (CFR 275.24(b)(3)(i)) now provided to states for increasing participation in SNAP and instead, providing the dollars as an incentive for implementing fraud prevention processes.
- Reward states a portion of the annual cost-avoidance savings for reinvestment into fraud detection and prevention programs, consistent with the recommendations of the US Government Accountability Office.
- Increase the percent of state-retained share of fraud and household error collections from the current 35% and 20% levels, respectively, to encourage collections. Furthermore, UCOWF would recommend the mandate that any state-retained share of collections must be used to fulfill all state-validated fraud prevention, detection, and investigation programs and initiatives before being used for any other purpose.
- Providing states a role in the approval process for merchants who apply to the Food and Nutrition Service (FNS) for a SNAP retailer authorization. States must bear the consequences for bad actors allowed into the SNAP program; states should be allowed a say in who FNS authorizes as a retailer and validate the need for a merchant to be authorized at the location the merchant proposes to operate.
- Leveling the playing field for states concerning the burden of proof needed for disqualifying recipients suspected of trafficking their SNAP benefits, matching the standard FNS uses to disqualify a merchant suspected of trafficking.
There are other commonsense ideas that tweak the existing program rules in order to provide greater integrity and strengthen the ability of states to recoup losses caused by fraud and error in other programs. Specifically, expanding the Treasury Offset Program (TOP) to allow states to collect debts from fraud and household error in Medicaid and TANF could vastly improve efforts to extinguish debts in those programs. A debt in Medicaid and or TANF is a debt owed to the taxpayers. Collecting that debt by intercepting federal payments and applying them to the debt just makes sense regardless of the federal assistance program involved.
None of the ideas advanced in Heacock’ s letter intend to limit assistance provided to those who truly need it. UCOWF simply offers ideas that will improve stewardship of taxpayer dollars primarily in the SNAP program. By repurposing dollars intended for other SNAP initiatives and directing them towards prevention, detection, investigation and recovery efforts, along with increased authority given to states to administer SNAP, program integrity will increase proportionately to the states’ increased ability to prevent and fight fraud.