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SNAP Program Integrity and the National Accuracy Clearinghouse

Elevating Supplemental Nutrition Assistance Program (SNAP) Integrity

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The Supplemental Nutrition Assistance Program (SNAP) serves as one of the most critical pillars of the social safety net, providing real-time food and nutrition assistance to struggling households. However, SNAP is currently faced with growing rates of program and transactional fraud, particularly by way of dual state participation among SNAP households.

What can states do to reduce dual participation rates and reallocate SNAP resources to those who truly need it?

The answer starts with the SNAP National Accuracy Clearinghouse (NAC), an interstate data sharing platform aimed at enhancing program integrity. The promise of the NAC is to enable states to identify dual participation 鈥渃ollisions鈥� before they happen, and by doing so, promote a more effective, efficient, and equitable SNAP program. Given the broad-based impact of the NAC, states should seize this opportunity to re-evaluate their current-state SNAP delivery model as the demand for nutrition assistance rapidly climbs.

What is NAC and how will it work?

Simply put, the NAC will provide states and localities the confidence that SNAP benefits are being issued to families 鈥渁t the right place, at the right time.鈥� Ultimately, the NAC will serve as the single source of truth for interstate SNAP participation, offering near-real-time feedback on the status of individuals applying for SNAP or being added to SNAP households.

As with any database tool, the NAC will require daily information feeds of SNAP participants using key data elements (e.g., Social Security number, date of birth, surnames) that are maintained in a database, alongside a participant ID. When agencies receive an application for benefits or adding a household member to an active case, the NAC will provide a search function for the agency to determine a 鈥渕atch鈥� for the applicant in another state鈥檚 active rolls or a 鈥渃ollision鈥� when an active member is also active in another state. In addition to this preventative measure, the NAC will also identify unresolved duplicate participation by conducting bulk monthly matches. When the NAC finds a match, the system will creates a record of the collision and notify all relevant states of the participants involved, giving them a 10-day window to resolve the match and disclose their pursuant actions to each other (e.g., discontinuing benefit issuance to a participant).1

Four key goals

1

program
Enhance program integrity

2

payment
Reduce improper payments

3

customer
Improve customer experience

4

flow
Ensure fair and accurate distribution of SNAP benefits to eligible recipients across state lines

Legacy tools, lower performance

Currently, states are generally limited to quarterly identification of dual participation through the use of the Public Assistance Reporting Information System (PARIS). By replacing PARIS with the NAC states will have near-real-time ability to identify and prevent dual participation 鈥渃ollisions,鈥� resulting in reduced program administrative costs by way of benefit issuance and the downstream efficiencies gained from reduced overpayment and recoupment. The Food and Nutrition Service predicted in 2015 that using the NAC, instead of PARIS would save $114 million in annual nationwide estimated savings. In a 2014 pilot study of the NAC in five states, it helped avoid approximately $5.6 million in overpayments.2

How can state agencies prepare for NAC?

The NAC rule includes a phased approach, to allow for ample time for states to comply with this requirement by the October 2027 mandate.3 Dating back to the initial pilot implementation in 2014 this nearly decade-and-a-half journey presents promise, but not without proper preparation. What can states learn from the technical and operational hurdles overcome by the 鈥渆arly adopter鈥� states in implementing the NAC?

01
Make room for the NAC in your SNAP strategic road map.

States will need to allocate a significant amount of time and resources across the NAC's implementation life cycle, with some states embarking on a seven to nine month implementation plan. In addition to the requisite design and development activities, states should be ready to allocate considerable capacity to comprehensive testing, training, and change management given the scale of the technology and operational changes coming down the pike. The NAC presents a unique opportunity for states to review their SNAP strategic road maps, assessing their current capacity against what it takes to truly achieve their vision.

02
More than just a technology upgrade.

Implementing the NAC requires a team of cross-functional stakeholders who not only understand the technology changes, but also the ability to design the appropriate operational changes and policy applications required to effectively achieve the goal of reducing dual-state participation and improving SNAP program integrity. It is imperative that states not silo the NAC as simply another 'interface.' States should take this opportunity to take a wholesale review of their application and case processing operations, especially as demand for nutrition assistance continues to rise.

03
Data, privacy, and security take center stage with the NAC.

The NAC avails personal identifiable information (PII), including location information for clients potentially fleeing domestic violence or other dangerous household circumstances, to other states and potentially harmful actors. It is the state's responsibility to prevent the disclosure of any location information of these potential inter-state matches. As states begin to operationalize the technical and procedural changes related to the NAC, security, access, and provisioning must remain at the forefront of the testing, training, and go/no-go decisions as states join the NAC.

Let鈥檚 take this journey together

At 乐鱼（Leyu）体育官网 LLP, we have a team of health and human services practitioners focused solely on advancing a more equitable, effective and efficient SNAP program. Our SNAP Program Transformation Delivery team takes pride in working shoulder-to-shoulder with states to design outcomes-focused strategies across the people, process, and technology supporting their SNAP business. Our team stands ready to help you as you take the first steps in joining the NAC.聽

Our approach combines our deep programmatic and regulatory knowledge with our experience helping countless states successfully achieve their transformation objectives. Leveraging our toolkit of services specifically tailored to SNAP program delivery, we can help you re-imagine your strategic road map to make room for the NAC, establish the cross-functional governance and controls, and support end-user testing marrying the operational, technical, and security level components required for an effective NAC launch.

We are excited at the potential the NAC has to elevate SNAP program integrity, in addition to the opportunity it provides for states to take a zoomed out view of their SNAP program on many different levels. We can meet you wherever you are on your NAC implementation journey, so let's take this journey together.

Footnotes

  1. 鈥淚mplementation of the National Accuracy Clearinghouse Interim Final Rule Memo,鈥� US Department of Agriculture Food and Nutrition Service, October 5, 2022 (usda.gov)
  2. 鈥淣ational Accuracy Clearinghouse Pilot Evaluation Final Report,鈥� National Accuracy Clearinghouse (NAC) System Webinar, US Department of Agriculture Food and Nutrition Service, October 2015 (usda.gov)
  3. 鈥淪NAP National Accuracy Clearinghouse,鈥� US Department of Agriculture Food and Nutrition Service, October 8, 2024 (usda.gov)

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SNAP Integrity and the National Accuracy Clearinghouse

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Meet our team

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Amiran Gelashvili
Managing Director Advisory, Health & Government Solutions, 乐鱼（Leyu）体育官网 US
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Cindy Cohen
Housing Leader, 乐鱼（Leyu）体育官网 US
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Amiran Gelashvili
Managing Director Advisory, Health & Government Solutions, 乐鱼（Leyu）体育官网 US
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Cindy Cohen
Housing Leader, 乐鱼（Leyu）体育官网 US
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