With unemployment on the rise and food pantries seeing 40% more people seeking emergency food assistance, it is critical that California moves to a semi-annual reporting system which will ease the burden on food stamp participants and allow them to continue to receive the food assistance that they need.   California is one of the last states to make this important change, as 48 other states in the country already have a semi-annual reporting system.   The California Food Policy Advocates has drafted a letter to the USDA, signed and supported by many MAZON CA grantees, to urge them to reject the extension of California’s waiver to make participants report household changes every quarter and to report with more forms than federally required.  If USDA rejects the waiver extension, the Department of Social Services will be more likely to move towards semi-annual, simplified reporting, which will increase access to this vital program.   To learn more about this important effort, please see the USDA sign-on letter attached.

 

July 31, 2009

Janey Thornton

Deputy Undersecretary

Food, Nutrition and Consumer Services

United States Department of Agriculture

1400 Independence Ave., S.W.

Washington, DC 20250

Re: California SNAP Waiver Extension Request

Dear Ms. Thornton,

California has been making progress in improving the Food Stamp Program (our Supplemental

Nutrition Assistance Program).  Under the leadership of John Wagner, the Director of the

California Department of Social Services (CDSS), the state has most recently moved to remove

the asset test for households with children, made it easier for aged-out foster youth to obtain

food stamps, and begun developing a new name and brand for the program in California.  But

given our historic problems with participation, we certainly must do more.  We must follow

the lead of other states and take advantage of federal options to improve access and operate

more efficiently.  Continuing our efforts to increase participation will of course help low-

income Californians.  And, due to the size of our state, our efforts will also drive national

participation rates and contribute towards the President’s goal to eliminate childhood hunger

by 2015.

One of the single most important things we can do to increase participation while streamlining

program administration is to join the 48 other states who have moved to simplified reporting.

USDA, states and program experts have long heralded this option as one of the single most

important ways to improve participation.  We believe that USDA can play an important role in

getting this needed change moving once again in California.

Since 2002, California has operated a combined periodic-change reporting system for food

stamps with reports due on a quarterly basis.  This system has required a waiver, #2030030,

which was renewed twice.  When requesting an extension of the waiver in 2007, CDSS

indicated its commitment to moving to semi-annual reporting.  The current waiver is set to

expire on September 30, 2009.  To ensure that the transition to simplified reporting is not

held up any longer, we respectfully request that you reject further extensions of waiver

#2030030.

By rejecting another extension of the waiver, USDA will be honoring the commitments made

by CDSS.  Since 2005, the Western Regional Office of FNS has been encouraging California to

move to simplified reporting to enjoy the benefits of administrative relief, error rate reduction

and improved client access.  In 2007, CDSS asked for more time so that the semi-annual

reporting system could be developed.  We believe that rejecting an additional extension would

provide the impetus for accelerated movement toward semi-annual reporting.  The California

Legislature supports the move to semi-annual reporting. The County Welfare Director’s

Association and client advocate groups do as well.  Governor Schwarzenegger himself has

pushed a semi-annual reporting proposal.  We believe that the rejection of the waiver will

move California to the less frequent reporting system that all of these groups want.

USDA would be well within its authority to reject the waiver.  In fact, we believe the agency is

compelled to reject the waiver request because USDA can only approve waivers if they lead to

a “more effective and efficient administration of the program.”  We believe the current waiver

falls short of that standard, in terms of: 1) participation 2) administrative costs and 3) error

rates.

Participation

California ranks last among states on USDA’s food stamp participation rate measure for all

households.  And just as troubling, California is tied for last place with Rhode Island for

participation among the working poor.  There are a number of factors that contribute to this

poor performance, especially challenges with the application process.  But we also believe that

requirements on enrolled clients are deterring participation in the program.  Specifically, we

believe California’s quarterly reporting system, which imposes combined periodic and change

reporting requirements on clients, creates unnecessary and confusing paperwork hassles that

are causing needy families to fall off the program.  Caseload movement data suggest that a

large number of households in California are “churning” on and off the program, causing an

avoidable and costly re-application process for a significant number of households.  Given

these negative impacts of quarterly reporting on participation, we do not believe continuing

the waiver would be “effective” from a client participation standpoint.

Administrative Costs

California is also at the bottom of states in another important measure: administrative costs

per case.  According to USDA’s State Operations Report, no other state comes even close to

spending as much per food stamp case as California does.  California spends considerably more

than double the national average.  In these tight economic times, states must be more

efficient; the simplified reporting option exercised in nearly every other state reduces staff

workload, based on the analysis from Mathematica.  Given that USDA may only approve

waivers that would result in a “more effective and efficient operation” of the program, this

waiver extension should be rejected from an administrative efficiency standpoint.

Error Rate

Another important measure is error rate.  While California had a significant problem several

years ago, performance did improve.  However, the current waiver does not allow the state to

make even greater error rate improvements.  USDA’s own analysis has shown that simplified

reporting reduced errors significantly and that if all states, including California use this option,

the error rate reduction would be even greater.  Given the importance of program integrity,

USDA should not approve waivers, such as #2030030, that do not maximize error rate

reduction and do not result in a “more effective and efficient administration of the program.”

Impact of Rejection

California’s quarterly reporting system is established in state statute.  Our understanding is

that the rejection of the waiver does not eliminate California’s quarterly system but does

eliminate additional state-specific changes made to the quarterly system.  California could still

operate a quarterly reporting system under 7 CFR 273.12 (a) 4, however significant changes

would be needed to change the system to comply with existing (and newly unwaived) federal

regulations.

But we strongly believe that moving to semiannual reporting would be much more beneficial

than making these changes to the quarterly system.   Therefore, we believe that the rejection

of the waiver will provide the final impetus for establishing the desired 6-month reporting

system in state statute.

Conclusion

Much has changed since California first submitted a quarterly reporting proposal to the

previous administration in 2002.  The simplified reporting option was not yet an option under

the statute.  There was a considerable lack of information on the impact of reporting options

on participation, administration, and payment accuracy.  And in 2002, when the quarterly

system was approved, our country was not in such a deep economic crisis as it is now.  Our

current crisis makes food stamps even more important to struggling families and makes the

efficient operation of the program even more important, given tight federal and state budgets.

Thank you for considering this request.  We, the undersigned, are ready to provide additional

evidence and detail to explain these arguments further.   Please contact George Manalo-

LeClair with California Food Policy Advocates, (510-433-1122 ext 103, george@cfpa.net) for

further information.

Sincerely,

George Manalo-LeClair, Senior Legislative Advocate, California Food Policy Advocates

Ken Hecht, Executive Director, California Food Policy Advocates

Anne Holcomb, Executive Director, Food for People

Laurie True, Executive Director, California WIC Association

Lynn Kersey, Executive Director, Maternal and Child Health Access

Arturo Ybarra, Executive Director, Watts/Century Latino Organization

David Goodman, Executive Director, Redwood Empire Food Bank

Robert V. Shear, Executive Director, Mid Valley Recovery Services

Luis M. Lozano, Executive Director, The Beacon House Association of San Pedro

Aleta Cruel, Executive Director, Compton Welfare Rights Organization

Sue Sigler, Executive Director, California Association of Food Banks

Carl R. Hansen, Executive Director, Food Bank Coalition of San Luis Obispo County

Nancy Tivol, Executive Director, Sunnyvale Community Services

Lynis Chaffey, Executive Director, Inter-Faith Ministries

Kathleen Harmon, Executive Director, Interfaith Council of Amador

Douglas Ferraro, Executive Director, Hope-Net

David Cox, Executive Director, St. Joseph’s Family Center

George LeBard, Executive Director, Project MANA

Mary Buckley, Executive Director, Plowshares

Paul Ash, Executive Director, San Francisco Food Bank

Trish Ribail, Executive Director, Imperial Valley Food Bank

Paul Bellerjeau, Director of Programs, Second Harvest Food Bank of Santa Cruz County

Frank Tamborello, Director, Hunger Action LA

Janice Maseda, Director, Lutheran Social Services Los Angeles

Mary Agnes Erlandson, Center Director, St. Margaret’s Center/Catholic Charities of Los Angeles, Inc.

Lisa Perry, Director, Connections of Hope/ERG Community Services

Fred Summers, Director of Operations, SOVA Food & Resource Program, Jewish Family Services of Los Angeles

Joni Halpern, Esq., Director, Supportive Parents Information Network, Inc.

Mark Lowry, Co-Chair, Orange County Hunger Coalition

Jenn Sramek, Board President, Haight Ashbury Food Program

H. Eric Schockman, President, MAZON: A Jewish Response to Hunger

Mable Everette, President/CEO, Community Nutrition Education

Mara Schoner, President, Neighbor2Neighbor

Authur G. Kinslow, President, Christ Temple Church of Pomona

Beth Abrams, President, Beth Abrams’ Center for Peace, Arts, Justice, and the Environment

Paul S. Castro, CEO, Jewish Family Service of Los Angeles

Ilene Leiter, CEO, Kings’ Care – A Safe Place, Inc.

Mike Mallory, CEO, Second Harvest Food Bank of San Joaquin & Stanislaus Counties

Rabbi Marvin Gross, CEO, Union Station Homeless Services

Dana Wilkie, CEO, Community Food Bank

Jeff Dronkers, Chief Programs and Policy Officer, Los Angeles Regional Foodbank

Marla Feldman, California Program Director, MAZON: A Jewish Response to Hunger

Angie Cooper, Research Scientist, Public Health Institute

Susanna Sibilsky, Community Consultant, Sibilsky & Associates

Maya Hagege, Project Assistant, South LA Healthy Eating Active Communities

Mary Ann Kelly, RD, Consultant Dietitian, Dietitian of the Desert

Helen Anderson, Treasurer, Orange County Hunger Coalition

Deborah Waxman, Community Education and Outreach Coordinator, Food for People

Lisa Sherrill, Community Relations Manager, Food Bank of Contra Cost and Solano

Barbara Williams, Social Worker

Magud Franco, Office Administrator, Inglesia Apostolica Manantial de Vida

Marie M. Mugan, Administrative Services, Little Sisters of the Poor

Phil Huisman, Administrator, Shepherd’s Pantry

Reverend Will Wauters, Vicar, The Episcopal Church of the Epiphany

Rosa Murillo, Coordinator, St. Josephs God Parents

Amanda Davis, Family Services Case Manager, Ocean Park Community Center

Sonia Pereira, Dual Diagnosis Case Manager, Ocean Park Community Center Access Center

Carol Lazarovits, Outreach Coordinator, St. John Vianney Church

Joyce Hutson, Program Manager, Greater Richmond Interfaith Program

Amy Scott, Food Pantry Coordinator, Friends In Deed

Chuch Huston, Director, The AIDS Food Store, Inc.

Frederick Brown, Program Operations Manager, California Institute of Health & Social Services

Amy Tam, Youth Services Program Specialist, YouTHink

Jennifer Tracy, Food Stamp Outreach Coordinator, San Diego Hunger Coalition

Natalie Caples, Nutrition Education Coordinator, Community Food Bank

Merle Preston, Access to Care Manager – Community Healthy Programs, Neighborhood Healthcare

Gary Romriell, Food Bank Manager, Community Action Partnership of Kern

Maria G. Orozco, Community Referral Specialist, Chula Vista Community Collaborative

Marc Ross, Nutritional Specialist, Downtown Women’s Center

Victoria Beeher, Advocate, Mental Health Systems – Building Bridges Together

Pastor Roger R. Kuehn, Pastor of Church – Administrator of Food Pantry, Antioch Food Closet

Antoinette Nelson, Food Pantry Coordinator, First African Methodist Episcopal Church Los Angeles

Colleen Rivecca, Advocacy Coordinator, St. Anthony Foundation

Shelly Hahne, Hand Up Youth Pantry Coordinator, Jewish Family Service – Hand Up Youth Food Pantry

Eileen MacKusick, Lead Dietitian, Watsonville Community Hospital

Gianna Muir Robinson, Disaster Relief Coordinator, Jewish Family Service of San Diego

Cathy Mason, Office Manager, Trinity Baptist Church

Olga De Jesus, Program Coordinator – Failure to Thrive Program, Harbor UCLA Medical Center

Lane Tobias, Activist/Community Blogger, Mother Earth/OBrag.org

Hallie Roth, Case Management Supervisor, Jewish Family Service of San Diego

Sandy Rechtschaffen, Social Justice Coordinator, Congregation Emanu-El

Individuals:

Evonne Silva, Al Sheahen, Hilda Chan, Judy Karas, Creagh Miller, Susan Roberts, Michael

Keenan, Lisa Joy

cc.

Julie Paradis, Administrator for Food and Nutrition Services, USDA

Jessica Shahin, Associate Administrator for SNAP, USDA FNS

David Lazarus, Senior Advisor to the Secretary, USDA

Allen Ng, Regional Administrator, USDA FNS Western Regional Office

Dennis Stewart, Regional Director for SNAP, USDA FNS Western Regional Office