SPECIAL TESTS AND PROVISIONS – ADP SYSTEM FOR SNAP
Department of Health and Human Resources (DHHR)
Assistance Listing Number 10.551, 10.561, COVID-19 10.561
Management within the DHHR, Bureau for Family Assistance (BFA), appreciates and shares the auditors’ concern with SNAP program integrity as...
SPECIAL TESTS AND PROVISIONS – ADP SYSTEM FOR SNAP
Department of Health and Human Resources (DHHR)
Assistance Listing Number 10.551, 10.561, COVID-19 10.561
Management within the DHHR, Bureau for Family Assistance (BFA), appreciates and shares the auditors’ concern with SNAP program integrity as it relates to the Recipient Automated Payment and Information Data System (RAPIDS) ADP system. The BFA notes that 7 CFR § 272.10 begins with, “(1) Purpose. All state agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. Sufficient automation levels are those which result in effective programs or in cost effective reductions in errors and improvements in management efficiency, such as decreases in program administrative costs...” Within the RAPIDS ecosystem for SNAP administration, this automation includes data matching measures undertaken, in compliance with related federal rules as specified in 7 CFR § 272.8, 7 CFR § 272.16, etc., to automate the validation of client-provided, worker-input information while mitigating the additional administrative burden of secondary review for all worker interactions with a client’s case. Policy regarding state and federal data matching is laid out in Chapter 6 of the State’s Income Maintenance Manual (IMM) at https://dhhr.wv.gov/bfa/policyplans/Documents/ Binder4.pdf.
The primary data exchange system detailed in IMM Chapter 6 that is applicable to SNAP is the Income and Eligibility Verification System (IEVS) required by 7 CFR § 272.8. Systems mandated federally for inclusion in the IEVS include those operated by WorkForce WV, the Internal Revenue Service (IRS), and the U.S. Social Security Administration (SSA). A variety of other sources may also be queried for the purpose of validating client-provided information entered into RAPIDS by a worker, including Veterans Affairs (VA), Beneficiary and Earnings Data Exchange (BENDEX), Beneficiary Earnings and Exchange Record System (BEERS), National Directory of New Hires, and Prisoner Matching with the Department of Corrections as well as the Federal Data Services Hub (FDSH).
IMM Chapter 6, page 2 describes the purpose of data matching through the IEVS thusly:
Information obtained through IEVS is used for the following purposes:
• To verify the eligibility of the assistance group (AG).
• To verify the proper amount of benefits.
• To determine if the AG received benefits to which it was not entitled.
• To obtain information for use in criminal or civil prosecution based on receipt of benefits to which the AG was not entitled.
IMM Chapter 6, pages 2-3 further detail the points at which a match with the IEVS must take place:
A data exchange in the eligibility system occurs:
• When a new case is created;
• When a new person is added to a benefit;
• When a person’s demographic information is changed; and,
• On a periodic basis for all individuals in the eligibility system, depending on the type of benefit being received.
Requirements for independent verification of information when automated data matches fail or report a discrepancy with client-provided, worker-input information are spelled out in IMM 6.4.4.
The BFA believes that these automations, while perhaps not foolproof, are in keeping with both the word and intent of 7 CFR § 272.10, 7 CFR § 272.8, 7 CFR § 272.16, etc., which aim to automate processes in order to reduce administrative burden and associated costs, such as those that would be associated with a secondary review of all worker interactions with a client’s case.
Furthermore, page 4-10.551-9 of the Compliance Supplement 2023, which lays out the suggested audit procedures for this topic, recommends the use of the USDA-FNS SNAP System Integrity Review Tool (SIRT) to ensure that the State’s ADP system is in alignment with USDA-FNS requirements and ensure that automated processes within RAPIDS continue to comport with federal requirements for ADP systems. To our knowledge, the auditors neither utilized that tool to guide their work nor requested verification from the State that the SIRT had been completed and previously employed. To support this response, management advocates a review of the SIRT submitted to FNS on October 26, 2023 in preparation for the go-live stage of the West Virginia People’s Access to Help (WV PATH) Family Assistance pilot program; as there is no significant difference in system functionality between the Family Assistance module of WV PATH and the existing eRAPIDS system, the responses/comments/replies from both FNS and the State that are included in this version of the SIRT generally apply both to eRAPIDS and to PATH.
Throughout 2023, the BFA Division of Performance and Quality Improvement continued its ongoing SNAP case reviews, as well as its efforts to report compliance with monthly requirements for expanded supervisor case reviews conducted and tracked through the Rushmore case review system, as mandated in a December 7, 2022 memorandum to supervisors and made available to the auditors last year. Furthermore, the BFA developed additional worker training, including the reinstatement of face-to-face Statewide Payment Accuracy Conferences (held throughout the summer of 2023), with the aim to ensure that client information is accurately captured in RAPIDS so the APD can perform its automated functions with integrity.