Yesterday the Coalition for Access and Opportunity, of which
CSSP is a member, held a briefing titled “Removing Red Tape: New Strategies for
Strengthening the Safety Net” in which a panel described the actions state and
local governments are taking to make their safety net programs more effective
and efficient. These programs include the Supplemental Nutrition Assistance
Program, Medicaid, the Children’s Health Insurance Program, Temporary
Assistance for Needy Families, the Child Care and Development Block Grant, and
the Low-Income Home Energy Assistance Program.
In the traditional human services paradigm, consumers receive
services by walking into a human service organization, meeting in person with a
case worker, and either supply the caseworker with their completed forms and
supporting documentation, or receive assistance from the case worker in filling
them out. The case worker then determines if the consumer is eligible for the
benefit. The advantage to this traditional method is that consumers receive
individualized support. On the other hand, consumers have to visit multiple
agencies to apply for a comprehensive package of services, they often have to
wait in long lines, and they are burdened with having to take time off of work,
which is risky to their employment status and earnings. In addition, this
process leads to heavy administrative costs to the agency.
To address these problems, many states have utilized the Internet
and sophisticated software systems and databases to simplify the way consumers
access safety net services. In May the Coalition for Access and Opportunity, released
a report titled “Moving
to 21st-Century Public Benefits: Emerging Options, Great Promise,
and Key Challenges” which examines promising practices across states to
propose a new model for modernizing the public safety net to make it easier and
less burdensome for families to receive benefits. Its recommendations include
changing eligibility rules and procedures to allow for more streamlined enrollment
into programs and for retaining eligible individuals for longer.
These eligibility rules changes include—
- Using other programs’ findings to “deem” consumers eligible for assistance without asking one agency to replicate or revise the work already done by a different agency.
- Basing eligibility on prior-year income tax records;
- Providing continuous eligibility by disregarding short-term income fluctuations; and
- Eliminating eligibility requirements that cannot be documented based on data matches. For example, consumers could opt for standardized rather than itemized deductions or disregards, and asset tests could be eliminated for some or all consumers.
- Using data matches, rather than consumer provision of information, to complete application forms and establish eligibility;
- Using electronic case records or data warehouses to serve multiple programs, so that information or documentation already received by one office can be used by others;
- “No wrong door” policies so that data received by one agency is forwarded to other agencies. This would minimize the number of agencies consumers have to physically enter, just to give the same information that they provided to other offices.
- Streamlining renewal by automatically granting continued eligibility based on data matches and by letting families provide missing information over the phone and online; and
- Default enrollment strategies that provide eligible consumers with assistance unless they affirmatively “opt out”.
The success of these policy changes will be determined by
how closely policymakers pay attention to the details of their implementation
and balance their priorities of saving administrative costs with increasing
access to consumers. Some areas that may
require attention include:
- Increased reliance on data must be met with strong security provisions to protect consumers’ privacy.
- Shaping eligibility rules to fit available data means they might disregard factors such as housing costs or asset values, which are factors that could help focus assistance on the people with the greatest need.
- Reforms that address multiple programs need to be carefully structured so that they do not import more restrictive rules into programs that are less restrictive.
- The use of Internet- and telephone-based enrollment pathways must not completely replace the traditional in-person model. Many low-income people have not filed federal income tax returns and may lack a data trail showing eligibility. Some people may not know how to use the technology or lack the language or literacy skills needed for online applications. Still others may not have access to computers, which is especially a concern for rural and frontier locales.
Utilizing technology has in some cases led to a dramatic
increase in enrollment among those who are eligible, which suggests that the
change was successful and merits the consideration of program modernization in
other states. However, in the excitement to take advantage of technology to
streamline enrollment and minimize administrative costs, it will be important
for policymakers to do a thorough assessment of the needs of the low-income
populations in their state or district. It is critical that in an effort to
better serve low-income families that states do not implement policy and
programs that may lead to some consumers falling through the cracks. Considering the usability and accessibility
of technology by different sub-populations is a critical aspect of ensuring
that streamlining access leads to the best outcomes for poor and low-income
families.
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