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Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Tuesday, March 12, 2019

Homonoff Presents Program Recertification Costs: Evidence From SNAP Today At NYU

HomonoffTatiana Homonoff (NYU) presents Program Recertification Costs: Evidence from SNAP at NYU today as part of its Tax Policy Colloquium Series hosted by Lily Batchelder and Daniel Shaviro:

We document low rates of recertification for the Supplemental Nutritional Assistance Program (SNAP) which we attribute to procedural issues associated with the recertification process. We find that current recipients — who must complete a recertification interview by the end of their recertification month — are 19 percent less likely to recertify when assigned an interview date at the end rather than at the beginning of the month. The results persist when conditioning on eligibility and are larger for long-term recipients and households with children, suggesting hassle costs associated with later interview dates worsen targeting efficiency both in terms of eligibility and need.

Conclusion. In this paper, we demonstrate that administrative burden associated with the SNAP recertification process leads to significantly lower rates of recertification success. Cases that are randomly assigned to initial interview dates at the beginning of the recertification month are 19 percent more likely to recertify than cases assigned to interviews at the end of the month. Our estimates are unchanged when conditioning on likely eligibility for the program. Such large differences in recertification success are particularly surprising given the ease with which cases may reschedule their assigned date. We find that the vast majority of the cases who fail recertification as a result of interview assignment successfully reapply for the program within the 90 days post-recertification, though we also find a small but significant effect of interview assignment on the likelihood of remaining off the program for over 90 days despite maintained eligibility. Additionally, the decrease in administrative costs associated with cases that churn more than offset the increase in costs of increased benefit distribution for these cases. While current federal law requires that SNAP recipients must complete a caseworker interview to recertify, the scheduling and timing of these interviews is at the discretion of the counties meaning that our suggested policy could be implemented without a waiver or a regulation change.

More generally, we document very low rates of overall recertification success despite high rates of estimated eligibility. Sunstein (2018) details the overwhelming amount of paperwork burden associated with government programs, pointing out that while some amount of administrative burden is necessary to ensure program integrity, excess "sludge" prevents individuals from accessing these programs (Thaler, 2018). Our results suggest that relaxing the recertification requirements — for example, lengthening recertification periods or waiving interview requirements for likely-eligible households — could lead to large decreases in type I errors.

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