How to Streamline Verification of Eligibility for Medicaid and SNAP

Table of Contents

• Section 1: Executive Summary
• Section 2: Federal Verification Requirements 
  • Section A: Medicaid
    • General Principles in Medicaid
    • Medicaid Applications
    • Medicaid Renewals
  • Section B: SNAP
    • General Principles in SNAP
    • SNAP Applications
    • SNAP Periodic Reports and Other Changes
    • SNAP Recertifications
• Section 3: Data Sources to Verify Eligibility
  • Section A: Accessing Data Sources
  • Section B: Federal Data Sources
  • Section C: State Data Sources
  • Section D: Commercial Data Sources
• Section 4: Streamlining Verification

Section 1Executive Summary

This toolkit provides resources for advocates and state agencies seeking to streamline the eligibility verification process for Medicaid and SNAP.

Federal law requires the state and county agencies that administer Medicaid and SNAP to verify that a client is eligible before approving or renewing benefits. An agency may have to verify eligibility factors such as income, household size, assets, and citizenship or immigration status. There are three main methods of verification: obtaining client statements (known as self-attestation), accessing data from other agencies or commercial entities, or requiring the client to provide additional documentation.

In many cases, agencies can rely on a combination of client statements and available data sources to confirm eligibility factors without requiring additional documents from the client. This has several benefits:

• It lowers costs for agencies and clients by reducing administrative burden and expediting processing.^[1]
• It reduces the risk that an eligible client will be unable to obtain or keep benefits because they didn’t receive the notice requesting documents, they didn’t understand what they needed to do to verify their eligibility, or the agency didn’t properly process their documents.
• It improves accuracy.

Federal Medicaid and SNAP regulations lay out the factors that must be verified, what sources can be used, whether self-attestation is an option, and where states have flexibility. This toolkit provides detailed information on these regulatory requirements and options and available data sources. Advocates can use the toolkit to analyze state regulations, policy, and operational practices and identify opportunities to streamline verification. State agencies can also use the toolkit to better understand federal requirements and identify where state policies can be clarified or improved.

Section 2 of this toolkit, Federal Verification Requirements, outlines the requirements for Medicaid and SNAP at application and renewal. It covers policies for each program as well as the specific eligibility factors agencies must verify, when they may use self-attestation or data sources, and when paper documentation may be required.

Section 3, Data Sources to Verify Eligibility, lists federal, state, and commercial data sources that can be used to verify eligibility and explains how states can access this data.

Section 4, Streamlining Verification, discusses how agencies can combine policy, data sources, and operational practices to streamline eligibility determinations at various points in the eligibility process.

Table 1 summarizes the eligibility factors that must be verified for each program and the data sources available to meet that requirement.

Section 2Federal Verification Requirements

Federal Medicaid and SNAP regulations outline the specific eligibility factors that must be verified at application and renewal and what forms of verification are acceptable.

This section begins by explaining the general principles behind the federal requirements for each program. It then describes the specific rules for applications and renewals.

Section A: Medicaid

General Principles in Medicaid

Federal Medicaid regulations lay the groundwork for a streamlined application and renewal process that relies heavily on electronic data sources to verify client statements. The regulations require that agencies utilize all available and useful data sources and only request information from the client if they are unable to verify needed information through a data source.^[2]

The verification process is the same for determinations based on modified adjusted gross income (MAGI) (used for children, parents, pregnant people, and adults who are under 65 and not eligible based on a disability) and non-MAGI budgeting, (used for people who are 65 and older and people with disabilities) even though the eligibility rules differ.

There are three basic steps to verify Medicaid eligibility for all factors except citizenship and immigration status, which is discussed later in this toolkit.

1. The client completes an application or renewal form with information about their identity, income, household, and other factors affecting eligibility and attests to the information they provide.
2. The agency gathers information about the client from federal, state, and commercial data sources.
3. The agency compares the client statement to the data and determines if there are any differences that may affect eligibility. If the client statement and data sources are reasonably compatible, no further information is needed from the client. (See box.) If there is a difference that may affect eligibility, the agency can require either a reasonable explanation or paper documentation from the client to resolve the difference.^[3]

States set policy about which data sources they use to verify eligibility, when they accept client statements, and when they require documentation. For MAGI determinations, states must develop and submit plans outlining their approach to verification.^[4]

Medicaid Applications

At application, agencies cannot rely solely on self-attestation for citizenship or immigration status and must verify it through an electronic service or additional documentation before issuing benefits.^[7] If the client has stated that they are a citizen or hold an eligible immigration status, but the agency is unable to verify their status, the agency must approve coverage if the client is otherwise eligible and provide a reasonable opportunity period of at least 90 days while the client and agency work to verify their status.^[8] The client may need to provide a document verifying identity in conjunction with certain citizenship verification documents.^[9]

Agencies must verify Social Security numbers (SSNs), though limited exceptions apply, such as when a client is ineligible to receive an SSN.^[10]

Agencies must verify income through electronic data sources where possible.^[12] The agency compares the client statement and the data source and determines if any difference between them affects eligibility.

• If the statement and data source are reasonably compatible, the client’s self-attested income is used in making the eligibility determination.
• If they aren’t reasonably compatible, the agency may request a reasonable explanation or additional documentation, such as a pay stub, to resolve the discrepancy.^[13]
• If no information is available in data sources to verify income — as is common with self-employed clients, for example — the agency may request further documentation from the client, such as a self-employment ledger.

Agencies must use an asset verification system (AVS) to verify resources (assets) for seniors and people with disabilities in coverage groups with a resource limit.^[14] The agency compares the client statement to the AVS data and requests additional documentation if the two are not reasonably compatible.

Agencies may accept self-attestation of residency, age (date of birth), and household size or verify these factors through available data sources. The agency may only request additional documentation from the client if the data source contradicts the client statement or shows no information.^[15]

If a client states they are pregnant, the agency must accept that statement unless they already possess information that is contradictory to that statement.^[16]

There are other factors agencies may have to verify for certain groups, such as people seeking eligibility as a caretaker relative of a minor child, an American Indian or Alaska Native, or a former foster care youth. Agencies may accept the client statement, rely on a data source, or require additional documentation for these factors.

States have the option of conducting post-enrollment verification for all eligibility factors except citizenship or immigration status. (See Table 2.) Post-enrollment verification allows the agency to enroll the client in Medicaid based on the information they attested to on their application. The agency then compares the information to data sources and requests additional documentation, if necessary, usually within two months of enrollment. If the client doesn’t provide the requested documentation, the agency can terminate their coverage.

Medicaid Renewals

Agencies must conduct periodic renewals of Medicaid eligibility, usually every 12 months.^[17] At renewal, agencies must verify eligibility factors subject to change, such as income.^[18] Agencies must assume other factors have not changed, including citizenship status, and not attempt to re-verify those factors.

Agencies must first attempt to renew eligibility using information available from the case file and data sources. This process is known as an ex parte renewal.^[19] If the data sources confirm ongoing eligibility, the agency sends the client a notice that their eligibility has been renewed. The client isn’t required to take any action, unless the information on the notice is incorrect.

If the agency can’t confirm ongoing eligibility through data sources, it sends the client a pre-populated renewal notice which the client must complete, sign, and return.^[20] Eligibility workers then compare the statements on the renewal form to data sources and should only require clients to provide additional documentation if there is information in data sources that is not reasonably compatible with the client statement.

Section B: SNAP

General Principles in SNAP

Federal SNAP regulations require verification of several factors that determine a client’s eligibility and benefit amount. Agencies have the option to verify additional factors.

Eligibility factors for SNAP can be verified through documentary evidence, data sources, or collateral contacts, who are people outside of the household able to confirm their circumstances, such as an employer, landlord, or social service agency.

State agencies have a legal obligation to help clients obtain required verification documents. Eligibility workers must assist the client and must accept any reasonable documentary evidence they provide.^[21] Agencies cannot require specific documents and must use the best available information for income when other efforts fail.^[22] For example, if a client doesn’t receive a traditional paycheck and the employer refuses to verify their income, the agency must accept a client statement or other records provided by the client.

Some eligibility factors, such as dependent care and shelter expenses, are necessary to determine deductions when calculating the SNAP benefit amount. The state may require verification of those factors for the client to receive the deduction. However, if verification isn’t provided, the application must still be approved without the deduction if the client is otherwise eligible.

SNAP Applications

Federal regulations outline what agencies must verify for a SNAP application, though states have the option to verify more and must verify any questionable information.^[23] (See box.)

For certain clients, such as those subject to SNAP’s three-month time limit, the agency may need to obtain additional verification beyond those listed below. There are also factors that may need to be verified, such as disability for purposes of work registration, but verification is not required for the initial eligibility determination.

At application, agencies must verify:^[24]

• income (both earned and unearned);
• identity;
• Social Security number; and
• residency (with exceptions for certain clients, such as those experiencing homelessness).

If applicable, agencies must verify:^[25]

• immigration status of non-citizen clients;
• child support paid;
• hours worked and countable months in other states (for certain clients subject to the time limit);
• medical expenses (a deduction available only to elderly or disabled clients);
• unfitness for work (if the client is claiming an exemption from the student exclusion); and
• disability status.

If the client statement is considered “questionable,” agencies must verify:^[26]

• dependent care expenses;
• resources;
• shelter expenses;
• citizenship status;
• household composition;^[27] and
• other factors that affect eligibility or benefit levels.^[28]

Some SNAP applicants are entitled to expedited SNAP benefits, meaning they must be able to access their benefits within 7 days of applying instead of the regular 30-day timeframe. For expedited SNAP, agencies must verify identity before issuing benefits. Agencies must also make reasonable efforts to verify other factors within the expedited timeframe, but benefits cannot be delayed because those factors haven’t yet been verified.^[29] All factors must be verified for households to receive benefits beyond the one to two months of expedited benefits.

SNAP Periodic Reports and Other Changes

Many agencies conduct a SNAP periodic report (also known as an interim report or semi-annual report) between the application and recertification, usually at the six-month mark.

If an agency conducts a periodic report, agencies must ask the client if they have experienced changes in:^[31]

• unearned income of more than $125;
• employment, including starting or stopping a job, wage rate or salary, or change between part-time and full-time status; or a change of more than $125 in income;
• household composition;
• residence and shelter costs;
• resources (if the state has a resource/asset test);
• legal obligation to pay child support; and
• if subject to the three-month time limit, a change in work hours that brings the client below 20 hours per week.

If a client reports changes in any of these areas, the state must follow the same verification rules as at application: changes in income (and resources and child support, if applicable) must be verified while agencies can accept self-attestation for other factors. If a client reports no changes at the periodic report, the agency shouldn’t require any verification documents.

For changes that the client reports or that the state otherwise learns about during the certification period, the same basic verification rules apply. However, states have flexibility about whether they need to act or seek verification for certain changes. In some instances, such as when the state receives unclear information, states may not act or pursue verification until the next recertification or periodic report.^[32]

SNAP Recertifications

At a SNAP recertification (which is generally every year, though may be less frequent for households with elderly and disabled members), agencies do not have to re-verify all eligibility factors. They only must verify:^[33]

• a change in income if there is a change in the source or if the change is greater than $50/month;
• medical expenses if previously unreported or changed by more than $25/month;
• a change in the legal obligation to pay child support; and
• work hours for certain clients subject to the three-month time limit.

Agencies may choose to verify other information that has changed, as well as unchanged information if it is incomplete, inaccurate, inconsistent, or outdated. If they do so, they must follow the same verification rules as at application.^[34]

Section 3Data Sources to Verify Eligibility

Understanding how agencies access and use data can help identify ways to streamline determinations by increasing reliance on data sources and minimizing requests for the client to submit documentation.

Agencies can access a variety of federal, state, and commercial databases to verify eligibility. Under the Social Security Act, states must have an Income and Eligibility Verification System (IEVS), which they use to obtain data from federal and state sources to determine and renew eligibility for Medicaid, SNAP, and other programs.^[35]

For Medicaid, federal regulations require agencies to access information from certain data sources, to the extent they find them useful. These sources include SSA, IRS, quarterly wage data from state workforce agencies, and SNAP.^[36]

For SNAP, federal regulations require that agencies access certain data sources, including quarterly wage data, SSA, certain information from the IRS, and unemployment insurance data through their IEVS.^[37] States are also required to conduct data matching with the Electronic Disqualified Recipient System (eDRS),^[38] the National Directory of New Hires (NDNH),^[39] Systematic Alien Verification for Entitlements (SAVE),^[40] the Prisoner Update Processing System (PUPS),^[41] and SSA’s Death Master File (DMF).^[42]

Section A: Accessing Data Sources

Data Sources for Applications

When an agency receives a Medicaid or SNAP application, the system (or an eligibility worker) enters identifying information (usually SSNs) provided by the client into federal, state, and commercial databases. If the data sources confirm the information on the application, that eligibility factor is considered verified, and the client usually doesn’t need to submit any verification documents.

For example, the state agency that issues driver licenses and state IDs might return a match showing the client has an active ID in that state, confirming that they are a state resident. Or the SSA may return information confirming that a client is receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) and verifying the benefit amount.

In other instances, the data source may conflict with the client statement, provide information that wasn’t reported, or not show any information. If a client reports they have no income, but the state quarterly wage data shows they were working in the last quarter, the agency may send the client a request for information (RFI) and ask them to confirm that they are no longer working. SNAP agencies may also check databases to see if a client is disqualified or already receiving benefits in another state.

If the data source provides information that may affect eligibility, the agency may request additional documentation from the client, but they generally cannot take negative action without first making that request.

If no information is returned from the data sources to verify the client statement, the agency may need to request additional documentation from the client. For example, workers compensation usually can’t be verified through a data source, so clients must provide documentation.

When eligibility workers access data sources, they may have to log in separately to each relevant data source, enter the SSNs of all household members, and individually review each result. Other states have systems (sometimes referred to as spider systems) that take the household’s SSNs, automatically run them against all relevant data sources, and return the results to the eligibility worker, ideally in a way that is integrated into the eligibility system. States that add a new data source may at first require separate logins to that source until it can be fully integrated into the eligibility system.

Periodic Data Matches

Many agencies also periodically check data sources for current clients to identify relevant changes in circumstances, known as periodic data matches. For example, a state may run a match of clients against quarterly wage data and identify those whose income may have exceeded the eligibility threshold in the last quarter. Agencies also use matches to identify clients who have died, become incarcerated, or are receiving benefits in another state. If there is a match, the system may automatically generate a RFI to send to the client or may generate a task in the system for an eligibility worker to investigate further.

Renewals, Periodic Reports, and Recertifications

As in the application process, agencies run clients through multiple data sources at renewal (in Medicaid) and periodic report and recertification (in SNAP).

For Medicaid, this is first done as part of the ex parte process to attempt to confirm ongoing eligibility. If the agency is unable to renew the client through the ex parte process and the client is required to submit a renewal form, the agency then uses data sources to verify the information the client provides.

For SNAP, agencies do not always check data sources during a periodic report when the client reports no changes, but usually will do so if the client reports changes. Agencies do check data sources at the time of SNAP recertification to verify the information provided by the client on the recertification form.

Section B: Federal Data Sources

Federal Data Services Hub

The Federal Data Services Hub (“hub”) provides access to multiple data sources through a single connection. The hub was built to allow state Medicaid agencies and state-based health insurance exchanges to easily access multiple federal sources relevant for determining eligibility for Medicaid and qualified health plans.^[43] Most of these data sources were previously available to states but required multiple individual connections and data sharing agreements.

Through the hub, agencies can access information from SSA, Department of Homeland Security (DHS), Department of Veterans Affairs (VA), Equifax The Work Number (also known as TALX, a commercial data source), IRS, and other sources.^[44] However, some information from the hub can only be used for eligibility determinations for health insurance affordability programs like Medicaid, and cannot be used for SNAP determinations.^[45]

Social Security Administration

The SSA maintains several databases with information on SSNs; citizenship status; income from retirement, survivors, or disability benefits: death records: incarceration information; and more.

Agencies can access multiple SSA databases at once through various pathways. One pathway is through the State On-Line Query (SOLQ) interface, which allows agencies to access several SSA databases with income information in real time as they process an application or renewal. Agencies can also use a batch process called the State Verification & Exchange System (SVES) to access multiple SSA databases to identify changes in client information on a regular basis. For example, if a client receiving SNAP or Medicaid is newly approved for SSI, or their SSDI amount changes, that is identified through this batch exchange and the agency can update the income information in their SNAP or Medicaid case file.

Tables 4 and 5 describe SSA and other federal data sources useful to agencies administering Medicaid and SNAP.

Section C: State Data Sources

In addition to federal data sources, agencies have data-sharing agreements with other state agencies to gather information that may affect Medicaid and SNAP eligibility. State databases can be valuable sources of information to verify residency, income, and other important information. Table 6 shows examples of state data sources that may be useful for Medicaid and SNAP eligibility determinations. Note that agency names may differ across states.

Section D: Commercial Data Sources

Commercial data sources provide another valuable source of information for Medicaid and SNAP agencies, particularly for income and asset verification. Accessing these sources can be very costly for state agencies; some commercial services charge per match.^[55] But when used strategically, they can greatly reduce administrative burden on both clients and agencies and result in overall decreased costs.

Section 4Streamlining Verification

Streamlining verification accelerates case processing, reduces agency burden, and helps ensure eligible clients can obtain the supports they need. Agencies should set clear policy on what must be verified, maximize the use of self-attestation and data sources, and simplify the process for clients to submit documents when necessary.

Verification Policy

The first step in streamlining eligibility verification is setting clear policy.

For Medicaid, this includes accepting self-attestation when possible and setting clear policy for renewals on which factors are subject to change and must be asked about and verified. Clear policy is also needed on reasonable compatibility, which, when applied correctly, can significantly reduce verification requests. If the attestation and data source are both below the eligibility threshold, the difference doesn’t affect eligibility and no documentation should be required. Developing a policy and providing examples can help eligibility workers understand how to apply reasonable compatibility to different scenarios. In addition, agencies can program their systems to correctly apply the policy to applications and at renewal.

For SNAP, agencies can streamline the process by not requiring verification of factors like household expenses unless questionable. Agencies must clearly define when information is questionable. Without guidance, some eligibility workers may flag most cases as questionable and always request verification. This delays processing, creates additional workload for the agency, and increases the likelihood that an eligible household will lose benefits. Eligibility workers need clear information with examples to help them understand when to request verification. At the periodic report and recertification stage, client forms should include only the necessary questions, and eligibility workers should only verify changes when federally required to do so.

Finally, in both programs, agency culture plays a major role. If the agency culture emphasizes a fear of audits or negative quality control findings, eligibility workers are likely to request excessive verification, adding to their workload and increasing the likelihood that eligible clients won’t successfully access the program. Instead, the agency culture should prioritize “one-touch” processing, meaning the eligibility worker does everything possible to process the case in one sitting, including using data sources and collateral contacts to verify eligibility factors on the spot when possible. The one-touch approach encourages workers to use every resource available to process the case, rather than causing delays and increasing procedural denials by unnecessarily requesting documentation from the client.

Using Data Sources Wisely

Relying on federal, state, and commercial databases to verify eligibility where possible allows for fast and accurate eligibility determinations. At the same time, having more data is not always better. Agencies that administer SNAP and Medicaid should avoid providing eligibility workers with outdated, unreliable, or irrelevant data, such as information on property ownership for programs without an asset test.

States should also exercise caution when conducting periodic data matches. While such checks may identify clients who have experienced substantial changes in income, they often identify others who had small and temporary increases in income due to working overtime, for example. Such clients may lose coverage if they do not receive the RFI, don’t understand what they must do, or can’t obtain the required documents. Agencies should carefully set the parameters around these checks to avoid sending unnecessary RFIs that may lead eligible clients to lose coverage.

Simplifying Document Submission

While data sources can be used to verify most eligibility factors, sometimes the agency must request additional documentation from the client. If this proves necessary, agencies can limit confusion and burdens on clients by:

• using clear requests for information that specifically identify what is needed, such as the exact dates of pay stubs, so the client can provide the correct information;
• clarifying which alternatives are available to meet the verification requirements (for example, if the client can’t provide a pay stub);
• providing notifications by email and text, in addition to paper; and
• making it easy to submit documents through multiple channels, including by allowing a client to take a picture of the document with their smartphone and upload the information through a mobile-responsive client portal.

Streamlining verification through clear policy, maximizing the use of available data sources, and simplifying document submission reduces burden for agencies and helps ensure eligible clients can access and retain the health insurance and food assistance they need to thrive.