Request for Information: Supplemental Nutrition Assistance Program (SNAP) Quality Control Integrity and Modernization, 25425-25426 [2018-11849]

Agencies

• DEPARTMENT OF AGRICULTURE
• Food and Nutrition Service

[Federal Register Volume 83, Number 106 (Friday, June 1, 2018)]
[Notices]
[Pages 25425-25426]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-11849]


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Federal Register / Vol. 83, No. 106 / Friday, June 1, 2018 / 
Notices

[[Page 25425]]



DEPARTMENT OF AGRICULTURE

Food and Nutrition Service


Request for Information: Supplemental Nutrition Assistance 
Program (SNAP) Quality Control Integrity and Modernization

AGENCY: Food and Nutrition Service (FNS), USDA.

ACTION: Notice.

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SUMMARY: In order to accurately estimate improper payments in the 
Supplemental Nutrition Assistance Program (SNAP, the Food and Nutrition 
Service (FNS) has undertaken significant steps to strengthen its 
measurement process, the SNAP Quality Control system. Improvements 
include new training, policy clarifications, procedural improvements, 
and clarification of existing documentation requirements necessary to 
substantiate case findings. FNS has also implemented new policies to 
improve accountability and eliminate the potential for bias in the 
reporting system. FNS is considering proposals for a regulatory reform 
of its SNAP's Quality Control system in order to align the regulations 
with new policy and procedural requirements. FNS's intent is to achieve 
three objectives from reforming the Quality Control system: (1) 
Strengthen the integrity and accountability of the Quality Control 
system, (2) increase transparency in the process, and (3) use 
technology to improve improper payment estimates. Thus, FNS is issuing 
this Request for Information in order to obtain State government and 
other stakeholder perspectives as the Agency considers how to best to 
proceed with reforming the SNAP Quality Control system.

DATES: Written comments must be received on or before July 31, 2018.

ADDRESSES: Comments may be sent to Stephanie Proska, Chief, Quality 
Control Branch, Program Accountability and Administration Division, 
Food and Nutrition Service (FNS), U.S. Department of Agriculture, 3101 
Park Center Drive, Room 822, Alexandria, VA 22302. Comments may also be 
emailed to [email protected]. Comments will also be accepted 
through the Federal eRulemaking Portal. Go to https://www.regulations.gov and follow the online instructions for submitting 
comments electronically.
    All comments submitted in response to this notice will be included 
in the record and will be made available to the public at 
www.regulations.gov. Please be advised that the substance of the 
comments and the identity of the individuals or entities commenting 
will be subject to public disclosure.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of this request for information should be directed to Stephanie 
Proska at (703) 305-2437.

SUPPLEMENTARY INFORMATION:  The purpose of SNAP's Quality Control 
system is to measure improper payments consistent with Federal law. In 
addition to QC requirements in the Food and Nutrition Act of 2008, as 
amended, SNAP must comply with requirements in The Improper Payments 
Information Act of 2002 (IPIA), as amended by the Improper Payments 
Elimination and Recovery Act of 2010 (IPERA) and the Improper Payments 
Elimination and Recovery Improvement Act of 2012 (IPERIA). This 
legislation requires federal agencies to estimate the annual amount of 
improper payments. Federal law further directs the Office of Management 
and Budget (OMB) to establish guidance requiring federal agencies to 
classify errors. OMB defines error types as: Documentation and 
administrative errors--errors caused by the absence of supporting 
documentation necessary to verify the accuracy of a payment; 
authentication--errors caused by an inability to authenticate 
eligibility criteria through third-party databases or other resources 
because no databases or other resources exist; and verification 
errors--errors caused by the failure or inability to verify recipient 
information.
    All suggestions received in response to this notice shall be 
considered in the development of proposed rulemaking, particularly 
those that articulate how the reform will improve adherence to Federal 
laws and OMB guidance, as well as contribute to improved accuracy and 
reduction of bias in the case review or measurement process.
    With these general interests in mind, FNS is seeking information 
from stakeholders on the following particular questions:
    1. What regulatory changes should FNS consider to further enhance 
the integrity of the quality control system necessary to ensure the 
accuracy of improper payment estimates?
    2. In January 2016, FNS published a study evaluating how to enhance 
SNAP Quality Control completion rates. The study made a number of 
recommendations regarding how to improve case completion rates. What 
benefits, implementation challenges, or administrative factors, 
including cost implications, should FNS consider when evaluating the 
following recommendations:
    a. Require more contact attempts to reach clients?
    b. Require a greater variety of contact methods to be used?
    c. Revise procedures for scheduling and conducting interviews?
    d. Require client education of the QC process and a client's 
responsibility to cooperate with QC reviews at the point of application 
and recertification in order to raise awareness for recipients?
    3. SNAP currently requires field QC investigations to include a 
personal interview, almost exclusively performed in person. SNAP allows 
for a State option to conduct phone interviews for QC cases where 
households receive $100 or less in monthly benefits. SNAP also allows 
for a State option to conduct video conferences in lieu of an in person 
interview. What factors should FNS consider and what are the cost 
implications of allowing for an expanded use of telephone or video 
interviews in lieu of in-person interviews? What measures should a SNAP 
State agency take to ensure the accuracy of the case and thoroughness 
of verifications if telephone interviews were allowed for all QC case 
reviews?
    4. What electronic databases do State quality control reviewers 
currently have access to in order to verify information? Do you 
recommend FNS consider expanding Federal and State reviewer access to 
electronic databases and, if so, what factors or challenges would you 
anticipate?
    5. Should FNS consider revising staffing standards, per 7 CFR 
275.2(b), to

[[Page 25426]]

ensure there are a sufficient number of State quality control reviewers 
staffed in order to complete cases within prescribed time periods?
    6. Federal regulations at 7 CFR 275.23(b)(iii) require FNS to 
adjust a State agency's regressed error rate for failing to complete 98 
percent of its required sample size. FNS is considering a proposal to 
increase the adjustment as the current formula may not effectively 
deter mitigation strategies that encourage error prone cases to be 
dropped. What factors should FNS consider in adjusting a State agency's 
regressed error rate for incomplete cases?
    7. In both OIG's review of SNAP's QC system and FNS' own QC 
integrity reviews it was found that one tactic used to minimize the 
reporting of errors was to drop cases that were subject to QC review. 
What policies or procedures should FNS consider to ensure that only 
cases that cannot be verified are dropped while also discouraging the 
over-use of dropping cases?
    8. FNS uses a two-step process in order to determine a case's final 
payment error amount, referred to as Comparison I and Comparison II. In 
an audit, USDA's Office of Inspector General expressed concerns that 
the existing two-step process does not conform to regulatory 
requirements and that it does not accurately measure errors because 
Comparison II is not applied to all cases. This inconsistency raises 
concerns of underreporting payment errors. What recommendations should 
FNS consider in revising the use of Comparison I and Comparison II to 
reflect a more accurate account of a sampled case's payment error 
amount?
    9. FNS is interested in recommendations that incentivize quality 
control reviewers to accurately report case results. Performance 
requirements that focus exclusively on timeliness of the case reviews 
without any qualitative measure may inadvertently lead to inaccurate 
case results. What factors should FNS consider in establishing 
qualitative metrics for quality control case reviews?
    10. What concerns or barriers, if any, would exist if FNS were to 
mandate the use of the SNAP Quality Control System (SNAPQCS) as a means 
of reporting case results and documentation to FNS for all QC 
Worksheets? This is based on an assumption that a State would retain 
the option to maintain its own internal quality control system, 
provided that case results were reported to SNAPQCS.
    11. Are there any data elements that FNS should consider collecting 
through the quality control system as part of the FNS form 380-1 in 
order to better understand SNAP case record information and/or patterns 
over time or across States? This includes information that would 
further FNS's knowledge of potential bias in the payment error rates.
    12. Are there additional recommendations FNS should consider to 
encourage a greater use of technology to enhance the accuracy of case 
reviews in QC?
    13. FNS is interested in improving the transparency of the QC 
process. What factors should FNS consider if FNS were to require all 
State QC procedures be in writing and submitted to FNS as part of an 
annual state plan?
    14. What factors should FNS consider in revising the current 
corrective action planning requirement as a result of payment errors, 
incomplete cases, or negative case actions?
    To get a quick overview of the referenced Financial Reporting 
Requirements set by OMB, visit https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A136/a136_revised_2013.pdf and 
https://comptroller.defense.gov/Portals/45/documents/micp_docs/Authoritative_Laws_and_Regulations/OMB_Circular_A-123_Appendix_C.pdf. 
For an overview of the SNAP QC Completion Rate study, visit https://fns-prod.azureedge.net/sites/default/files/ops/SNAPQCCompletion.pdf and 
for an overview of USDA's OIG audit of SNAP's Quality Control Process 
for SNAP Error Rates, visit https://www.usda.gov/oig/webdocs/27601-0002-41.pdf. FNS has verified the website addresses in this document, 
as of the date this document publishes in the Federal Register, but 
websites are subject to change over time.

    Dated: May 24, 2018.
Brandon Lipps,
Administrator, Food and Nutrition Service.
[FR Doc. 2018-11849 Filed 5-31-18; 8:45 am]
 BILLING CODE 3410-30-P