Senate Agriculture Committee’s Bipartisan Farm Bill Strengthens SNAP and Avoids Harming SNAP Households
June 22, 2018
The farm bill that passed the Senate Agriculture Committee on June 13 includes a bipartisan nutrition title that would reauthorize the Supplemental Nutrition Assistance Program (SNAP, formerly food stamps) and improve SNAP’s program integrity and operations. The bill also would expand the 2014 farm bill’s pilot program to test promising approaches to job training and other employment-related activities for SNAP participants and would make targeted investments in SNAP to help seniors and people with disabilities, as well as Indian Tribes. And, the bill would make changes to and increase funding for certain grant programs outside of SNAP.
This approach reaffirms SNAP’s importance for struggling households that can’t afford a basic diet without its help.This approach reaffirms SNAP’s importance for struggling households that can’t afford a basic diet without its help. It stands in stark contrast to the House farm bill’s SNAP provisions, which would end or cut benefits for more than 2 million individuals in more than 1 million households. In addition, Senate provisions improving program oversight and integrity and streamlining program operations would yield a stronger program for the 1 in 8 Americans who use SNAP benefits to afford food.
The nutrition title of the Senate Agriculture Committee farm bill would be cost neutral over the ten-year budget window, according to the Congressional Budget Office (CBO). Savings, primarily from SNAP, would be reinvested in SNAP and other nutrition grant programs. (See Table 1.)
|CBO Estimated Costs and Savings from the Nutrition Provisions of the Senate Agriculture Committee Farm Bill|
|CBO 10-year Cost Estimate (Outlays)|
|SNAP Benefits and Administration|
|Extending 2014 farm bill employment and training (E&T) pilots and other E&T changes||$235 million|
|Allowing 3-year certification periods for elderly and disabled households||$205 million|
|Conducting a pilot on earned income verification||$10 million|
|Prohibiting certain electronic benefit transfer (EBT) fees||$28 million|
|Strengthening Food Distribution Program on Indian Reservations (FDPIR)||$37 million|
|Creating a national interstate data match to prevent duplicate participation||-$588 million|
|Repealing performance bonuses that may incentivize quality control (QC) measurement issues||-$420 million|
|Changes to Other Nutrition Initiatives and Grants|
|Reauthorizing Food Insecurity Nutrition Incentive (FINI) program||$401 million|
|Increasing funding for The Emergency Food Assistance Program (TEFAP)||$106 million|
|Establishing Harvesting Health pilot projects||$20 million|
|Reauthorizing community food projects||-$40 million|
|Total Nutrition Title||-$6 million|
The main themes of the bill’s changes are:
- Strengthening the relationship between employers and SNAP employment and training;
- Strengthening program integrity;
- Modernizing and improving systems and technology;
- Making targeted SNAP improvements for certain populations; and
- Investing in other nutrition programs and initiatives to support healthy eating.
An appendix table includes a list of the provisions described below, with section numbers.
Strengthening Relationship Between Employers and SNAP Employment and Training
The bill contains changes to SNAP’s work-related provisions designed to encourage states to recognize and leverage more available job training for SNAP participants and incorporate the perspective of local employers into SNAP job training programs. It would also provide more resources to states that want to expand SNAP’s employment and training pilot projects focused on high-quality training for targeted populations, and it would encourage states to connect SNAP participants to workforce programs outside of SNAP’s Employment and Training program. Finally, it would consolidate SNAP’s multiple work requirement provisions, which are now spread across the Food and Nutrition Act, into one clear section.
Streamlining SNAP Work and Job Training Requirements
The bill would consolidate existing SNAP provisions related to work and work requirements, making it easier for states to effectively implement a complex set of rules. Currently, the interactions between SNAP’s time limit for childless adults and state Employment and Training (E&T) programs can be challenging for states to implement; the bill aims to streamline the provisions to ease administration. Current work requirements are as follows:
- SNAP limits eligibility for people aged 18 through 49 not raising minor children who are working less than 20 hours per week to just three months out of every three years (with some exemptions). States don’t have to offer people subject to this limit a job or training program to help them keep eligibility, and most states don’t. In 2016, at least half a million unemployed individuals lost SNAP benefits due to this rule, many of them very poor individuals who receive no other form of basic assistance.
- With limited exceptions, SNAP requires all working-age adults to register for work and accept a job if offered.
- States must operate E&T programs that can provide training opportunities to most adults able to work or impose work requirements of up to 30 hours a week on this population. Individuals who don’t comply are subject to loss of benefits — including benefits for children in the household.
Given the wide range of individuals participating in SNAP and the diversity of local labor markets, states have flexibility and discretion in the design of their E&T programs. They can establish criteria and provide programming for appropriate services in local labor markets. Alternatively, they can emphasize standardized, low-intensity employment services that do little to change longer-term employment and earnings but don’t strain limited resources.
The U.S. Department of Agriculture (USDA) provides $110 million a year in grants for employment and training programs. USDA also matches state spending for these programs above the amount of a state’s basic federal grant, as well as state spending for job-related costs such as participants’ child care and some transportation costs. USDA and states spent more than $700 million for SNAP employment and training programs in 2016. In addition to the programs states operate under SNAP E&T, ten pilot projects are now underway to test and evaluate promising efforts to improve employment and earnings gains among participants in SNAP work and training programs (see below).
The bill also requires states that offer job search as an E&T activity to offer at least one additional training component, and requires states to assist individuals who have not found suitable training.
Extending 2014 Farm Bill Employment and Training Pilots
The bill would increase funding for additional innovative SNAP E&T programs aimed at connecting participants to employment. It would also prioritize traditionally underserved populations: older workers, those recovering from substance abuse, the recently incarcerated, individuals with disabilities, and homeless individuals.
The bipartisan 2014 farm bill authorized and funded ten state pilot projects to test promising approaches to connecting SNAP E&T participants to the workforce and address the lack of credible data on the outcomes of SNAP E&T programs. Each pilot is in the midst of a rigorous evaluation that will track employment and earnings for years after individuals participate. This was widely acknowledged as necessary to identify approaches to job training in SNAP that would lead to improved outcomes for participants. Results aren’t yet available to inform this farm bill. However, the pilots proved popular with states — enabling them to target specific populations and experiment with novel approaches to providing services and support — and the Senate bill would allow additional states to apply to operate similar pilot programs, providing $185 million to fund them.
Improving Link Between SNAP Participants and Workforce Development
Research shows that job training programs that target the employment needs of local employers and train individuals for in-demand jobs in their community successfully increase employment and earnings. SNAP employment and training programs, however, don’t have a strong record of incorporating this perspective. The Senate Committee bill would require E&T programs to consult with workforce development boards and/or private employers to ensure that the services and supports provided through SNAP E&T reflect state or local employers’ current and projected needs.
In addition, the bill envisions a strong public-private partnership between SNAP’s federal- and state-funded E&T programs and local workforce efforts. USDA’s SNAP to Skills initiative, the training pilots created under the 2014 farm bill, and several innovative state programs have highlighted the potential gains from close coordination among employer-identified needs, training programs that equip individuals to meet those needs, and SNAP’s E&T program. The Senate Committee bill would promote employer training and better connect SNAP participants to existing workforce development efforts. For example, it would create a process to connect SNAP participants to private employers and non-profit organizations that already provide substantial, high-quality training or work experience. These entities, defined as “workforce partnerships,” are funded outside of SNAP E&T, thus potentially expanding the number of quality training opportunities for SNAP participants. The bill would also strengthen state efforts to increase employment among work-able SNAP participants by including the perspective of employer-based training efforts and community-based workforce development in the design and implementation of SNAP E&T programs.
CBO estimates that the provisions related to SNAP’s employment and training program in total would increase SNAP spending by $235 million over ten years. (Section 4103)
Strengthening Program Integrity
The Committee bill includes numerous provisions to enhance SNAP’s already strong program integrity.
Responding to SNAP Quality Control (QC) Concerns
SNAP has among the most rigorous systems of any federal public benefit program for sampling and re-reviewing SNAP eligibility determinations to ensure accuracy. Each month, under the SNAP QC system, states select a representative sample of SNAP cases, and independent state reviewers check the accuracy of the state’s eligibility and benefit decisions within federal guidelines. Federal officials then re-review a subsample of the cases and USDA annually releases state and national payment error rates based on these reviews. States are subject to fiscal penalties if their error rates are persistently above the national average and can receive bonuses for high or improving performance.
A 2015 report from USDA’s Office of Inspector General (OIG) alleged that some states, motivated in part by the bonus payments, had introduced bias and data measurement issues into their QC results. The OIG also found that USDA’s oversight of the QC system needed improvement. USDA agreed that the concerns had merit, undertook its own assessment of state error measurement procedures, and concurred that states weren’t measuring errors consistently and that some were out of compliance with USDA’s directions. The Department of Justice has negotiated settlements with a handful of states that allegedly engaged in improper practices. Since 2015, USDA has reviewed QC operations in all states, executed corrective action plan agreements, revised QC policy guidance and practices and procedures, and taken actions to improve federal oversight.
Food and Nutrition Service (FNS) Administrator Brandon Lipps testified before the Senate Agriculture Committee last fall that he believed state and FNS oversight of the QC system was on track to correct for the measurement error issues. USDA plans to release error rates for 2017 under the updated procedures on schedule by the end of June. The Senate Committee bill includes several provisions to ensure that these corrections endure and to hold states and USDA accountable in the QC process:
- Requiring USDA to update its regulations. The bill would require USDA to issue updated regulations within six months to ensure that the QC system produces accurate, statistically valid results. It would also require USDA to regularly review states’ QC processes and to debar individuals who knowingly submit false information to USDA.
- Expanding availability of state records for review to include eligibility systems. USDA’s 2015 and 2016 investigations found that some states hadn’t submitted sufficient documentation to USDA as part of the QC process. The bill would make clear that information in states’ eligibility systems should be available to USDA for certain purposes. States and USDA would need to resolve how to give USDA access to state systems while complying with other federal and state privacy laws.
- Eliminating most state performance bonuses. The bill would eliminate $42 million a year (out of the $48 million currently provided) in SNAP performance bonuses, cutting SNAP spending by $420 million over ten years. These modest, targeted payments reward states for high or improving performance related to program error rates, payment accuracy, and overall program access among SNAP-eligible individuals. The bill would allow the separate bonuses for timely state processing of applications to continue.
This aspect of the QC improvement provisions goes too far. It’s premature to eliminate bonuses for payment accuracy before giving the agency and states time to address the concerns raised by the OIG report, and the report didn’t indicate any problem with the bonuses for program access. Further, states use bonus payments to re-invest in SNAP, such as by improving technology, administration, and program integrity, so eliminating them would curtail states’ efforts to innovate.
CBO estimates this provision would cut spending on SNAP bonuses by $420 million over ten years. (Section 4110)
Creating National Interstate Data Match to Prevent Duplicate Participation
The bill would establish a duplicative enrollment database by expanding the National Accuracy Clearinghouse (NAC) to a nationwide, mandatory effort. The NAC, now implemented under a state-initiated contract between Mississippi and LexisNexis, lets five participating southern states (Alabama, Florida, Georgia, Louisiana, and Mississippi) share data on their SNAP participants to identify and prevent SNAP participation in more than one state. An evaluation of the NAC found that fewer than 0.2 percent of SNAP participants were dual participants (i.e., more than 99.8 percent were not).
Compared to the House proposal, the Senate Committee bill would make several important improvements. First, it would make clear that states’ procedures to follow up on matches using the NAC should balance the goals of preventing dual participation and providing timely access to SNAP benefits. Dual participation in multiple states is rare and, when it does occur, sometimes occurs when states are slow to act when households report a move (rather than as a result of recipient fraud). Preventing dual participation can be a customer service enhancement to clients if the proposal provides for helping participants who move across jurisdictions to disenroll from their original home state. The Senate proposal makes clear that, while preventing dual participation is a priority, states’ procedures should ensure that individuals who aren’t committing fraud don’t lose timely access to food benefits.
The bill also would limit the information that states would provide to the NAC to information that is needed and used for avoiding duplicate participation, and it would clarify that the information shall not be used for other purposes or retained for longer than is needed for that narrow purpose. As a result, the Senate’s version would carry less risk to SNAP participants’ privacy and data security.
CBO estimates that this provision would save $588 million over ten years. (Section 4109)
Conducting Pilot on Earned Income Verification
Federal law requires states to verify household income in order to determine eligibility and the level of SNAP benefits for which a household qualifies. Historically, states have asked clients to provide paper documentation such as copies of their pay using wage stubs, bank statements, or statements from their employers. Today, some companies aggregate employment and earnings data for millions of employers as a human resources service; the primary commercial data service to verify earned income is Equifax, which operates the Work Number. Many states have contracts with Equifax for verifying earned income for SNAP and the Department of Health and Human Services has a contract for Medicaid and health coverage under the Affordable Care Act.
The Senate Committee bill would provide $10 million for USDA to establish a pilot program to test strategies in up to eight states to improve the verification of the earned income of SNAP household members. USDA would assess the cost-effectiveness of several approaches to contracting with a commercial data service that consolidates earned income information before awarding the grants.
CBO estimates that this provision would cost $10 million. (Section 4107)
Requiring States to Act on Data Matches
States have numerous state and federal data matches available to verify SNAP household members’ income and other circumstances. Some matches contain recent and highly reliable information; others provide older information that may not be relevant for current eligibility. In some cases, states may need to follow up with SNAP households to gather more information to accurately determine whether the state needs to close the case or change the SNAP benefit level. The bill would clarify that the state must follow up and pursue further information from the household or other sources if the information from the match: (a) substantially differs from the information the household provided at certification, (b) includes recent information that the household was required to have reported to the state, or (c) comes from certain matches that are highly likely to indicate ineligibility (such as the Social Security Administration’s match of deceased individuals).
CBO estimates that this provision wouldn’t have an impact on federal expenditures. (Section 4106)
Modernizing and Improving Systems and Technology
Assessing and Improving Electronic Benefit Transfer (EBT) systems
The bill includes a comprehensive initiative to improve EBT systems, the mechanism by which clients obtain their benefits at local retailers. In recent years, EBT systems have been criticized for being unreliable, providing poor customer service, and not keeping pace with the retail environment and emerging technology. The bill would:
- Expand and clarify that EBT processors (the companies involved in various aspects of EBT transactions) may not charge SNAP authorized retailers “interchange” fees or other fees for “switching” or “routing” EBT transactions. This provision would sunset at the end of fiscal year 2022.
- Allow SNAP authorized vendors to use EBT equipment that enables them to accept SNAP benefits as payment at multiple locations, provided they comply with certain program integrity measures. This would likely benefit vendors that sell their products at multiple farmers’ markets.
- Require the Government Accountability Office (GAO) to study state EBT systems, including transfer-related fees, EBT equipment issues, and the causes of and potential solutions to problematic system outages.
- Require USDA to review at least five state EBT systems, focusing on customer service and data quality and protection.
- Require USDA, based on the findings of the GAO report and its own review, to issue regulations and guidance on SNAP EBT systems related to: (a) prohibiting fees on retailers, (b) minimizing system outages and improving system reliability, (c) setting standards for cost-effective customer service, and (d) using third-party entities to access EBT data for (or on behalf of) participating households, such as a mobile application to help participants manage their EBT balances.
- Require USDA to issue further guidance for SNAP retailers on how to select EBT equipment and service providers that provide sufficient transaction information to minimize the risk of fraudulent transactions and revise requirements for retailer applications.
CBO estimates that clarifying the prohibition on retailer fees would cost $28 million over ten years. (Section 4104)
Requiring Computer Systems to Be Piloted in Live-Production Environments
The bill would require major SNAP systems changes, for which the federal government provides matching funds, to be piloted in a live-production environment. Over the past several years, a few states have experienced serious disruptions in client service as they rolled out large-scale replacements of their eligibility and enrollment systems. This requirement would help ensure that state agencies prepare for and plan to identify and fix issues that could negatively affect SNAP operations before rolling out systems statewide.
CBO estimates that this provision wouldn’t affect federal expenditures. (Section 4111)
Making Targeted SNAP Improvements for Certain Populations
Allowing 3-Year Certification Periods for Elderly and Disabled Households
States may certify most households participating in SNAP for up to one year and may certify households with only members who are elderly (age 60 or older) or have a disability for up to two years. Over their certification periods, households must report certain changes to the state agency and states must adjust benefits in response to these changes. At the end of the certification period, households must reapply in order to continue receiving SNAP, which involves an interview with an eligibility worker (in person or often by telephone) and new documentation of income and certain expenses relevant to eligibility and benefit levels.
The bill would extend these certification periods from two years to three for households with only elderly or disabled members who have no earned income. Such households tend to live on fixed income from sources such as Social Security, so the change would reduce paperwork and office visits for households that are unlikely to experience changes. The bill would require the state to have at least one contact with households each year.
The bill would also allow states to establish up to three-year certification periods in the Commodity Supplemental Food Program, which provides USDA commodity food packages to low-income elderly individuals.
CBO estimates this provision would increase SNAP spending by $205 million over ten years. (Sections 4101 and 4202)
Strengthening Food Distribution Program on Indian Reservations (FDPIR)
An alternative to SNAP, FDPIR provides food packages to Native American families who prefer its benefits to SNAP and live in designated areas near reservations and in Oklahoma. The federal government covers 75 percent of administrative costs necessary to operate FDPIR, with Indian Tribal Organizations (ITO) contributing 25 percent. USDA can reduce or fully waive an ITO’s 25 percent match if it determines the ITO can’t meet it. About 40 percent of participating ITOs have waivers of all or part of their match, so the total federal share of FDPIR administration is approximately 80 percent. The bill would enhance the minimum federal administrative match, requiring USDA to cover no less than 80 percent of operational costs for each ITO. It also would newly allow ITOs to use other federal funding streams to meet their administrative match requirement. It would maintain USDA’s authority to waive some or all of the ITO share in cases of justified financial need.
The bill would also authorize the appropriation of $5 million for new demonstration projects through which ITOs, instead of USDA, would directly purchase commodities for FDPIR food packages. Finally, it would allow the ITOs and states that run FDPIR to use FDPIR funds both in the fiscal year for which they are appropriated and the following year.
CBO estimates that this provision would increase SNAP spending by $37 million over ten years. (Section 4102)
Investing in Other Initiatives to Improve Healthy Eating
Increasing Funding for The Emergency Food Assistance Program (TEFAP)
TEFAP supplements the diets of low-income Americans, including seniors and children, by providing emergency food through local agencies, primarily food banks. In fiscal year 2019, TEFAP will receive about $290 million in entitlement funding — less than the $326 million it received for fiscal year 2015, at the beginning of the current farm bill funding cycle.
The 2014 farm bill gave TEFAP a significant funding increase for fiscal year 2015 but reduced funding each succeeding year, to about $290 million in fiscal year 2019. The Senate Committee bill would increase TEFAP funding by about $5 million in 2019 and $8 million to $9 million a year in 2020 through 2023 under CBO’s baseline assumptions, with inflation adjustments in later years.
The bill also would require the Secretary to issue guidance outlining best practices to minimize food waste of commodities donated to state agencies and emergency feeding organizations. To support this effort, the bill would provide $4 million for each of the next five years for projects to harvest, process, or package donated commodities from certain agricultural sources to reduce waste and provide food to individuals in need. The federal government would pay half the costs. Finally, the bill would require state TEFAP plans to include a process for emergency feeding organizations and other eligible recipient agencies to provide input on community preferences and needs.
CBO estimates this provision would increase federal spending by $106 million over ten years. (Section 4115)
Reauthorizing Food Insecurity Nutrition Incentive (FINI) Program
The bill would reauthorize FINI grants, which provide incentives to improve nutrition and test the effectiveness of those incentives. Like the House farm bill, this proposal would rename the program after Gus Schumacher (an important early leader in connecting federal nutrition programs to producers through farmers’ markets and incentive programs); establish a training, evaluation, and information center for FINI grantees; and update program priorities (albeit differently than the House bill). Funding for the program would be made permanent and set at $50 million per year.
CBO estimates that this provision would increase federal spending by $401 million over ten years. (Section 4303)
Improving Retailers’ Incentives to Offer Healthy Foods
The bill would establish a more transparent and consistent process to allow authorized retailers to offer incentives to SNAP participants to purchase fruits, vegetables, low-fat dairy, whole-grain foods, or foods recommended for increased consumption by the federal dietary guidelines. Currently, retailers who wish, using their own resources, to offer SNAP participants discounts or incentives for healthy foods like those provided through FINI must seek a waiver. Not all retailers know about the option or can navigate a federal waiver process. This provision would make the approach potentially available to all authorized SNAP retailers. Incentives would be for healthy foods only; incentive programs could not limit the use of SNAP benefits by participating households.
CBO estimates this provision wouldn’t have an impact on federal expenditures, as stores would bear the cost of the incentive. (Section 4105)
Authorizing Pilot Projects to Improve Healthy Fluid Milk Consumption
The bill would authorize appropriations for pilot projects to test incentives to increase the purchase of fluid milk among SNAP households that do not consume sufficient fluid milk, based on the most recent dietary guidelines. The bill would authorize appropriations of $20 million for grants to government agencies or non-profit organizations and an independent evaluation to measure the impact.
CBO estimates this provision wouldn’t have an impact on federal expenditures as the funding is contingent on future appropriation. (Section 4108)
Establishing Harvesting Health Pilot Projects
The bill would provide new federal funding to establish a pilot project to allow a state or non-profit organization to work with a health care organization, such as a hospital, to provide fruits and vegetables as well as nutrition education to low-income patients who suffer from or are at risk of developing a diet-related health condition. The goal is to evaluate the effectiveness of a produce “prescription” program in reducing health care use and associated costs. Funding for the program, including its evaluation, would be $4 million a year for five years, for a total of $20 million.
CBO estimates this provision would increase federal spending by $20 million over ten years. (Section 4304)
Reauthorizing Community Food Projects
The bill would reauthorize and provides funding for community food projects, which are grants to certain local organizations in low-income communities that promote food security through community-based solutions, although at $5 million per year in lieu of the current $9 million.
CBO estimates this provision would decrease federal spending by $40 million over ten years. (Section 4113)
Maintaining Nutrition Education
The bill would continue state-level nutrition education efforts, require states to electronically report project evaluations, and expand the stakeholders involved in delivery, oversight, and evaluation to include the National Institute of Food and Agriculture and expanded food and nutrition education programs. It would not change funding levels. (Section 4114)
The bill would extend through 2023 the authorization of SNAP and other nutrition programs generally authorized under the farm bill. (Section 4112 and others)
|Nutrition Provisions of the Senate Agriculture Committee Farm Bill|
|Strengthening relationship between employers and SNAP employment and training||4103|
|Streamlining SNAP work and job training requirements|
|Extending 2014 farm bill employment and training pilots|
|Improving link between SNAP participants and workforce development|
|Strengthening program integrity|
|Responding to SNAP quality control (QC) concerns||4110|
|Creating a national interstate data match to prevent duplicate participation||4109|
|Conducting a pilot on earned income verification||4107|
|Requiring states to act on data matches||4106|
|Modernizing and improving systems and technology|
|Assessing and improving electronic benefit transfer (EBT) systems||4104|
|Requiring computer systems to be piloted in live-production environments||4111|
|Making targeted SNAP improvements for certain populations|
|Allowing 3-year certification periods for elderly and disabled households||4101 and 4202|
|Strengthening Food Distribution Program on Indian Reservations (FDPIR)||4102|
|Investing in other nutrition initiatives and grants|
|Increasing funding for The Emergency Food Assistance Program (TEFAP)||4115|
|Reauthorizing Food Insecurity Nutrition Incentive (FINI) program||4303|
|Improving retailers' incentives to offer healthy foods||4105|
|Authorizing Pilot Projects to Improve Healthy Fluid Milk Consumption||4108|
|Establishing Harvesting Health pilot projects||4304|
|Reauthorizing community food projects||4113|
|Maintaining nutrition education||4114|
|Reauthorizing SNAP||4112 and others|
 The text of the bill, S. 3042, the Agriculture Improvement Act of 2018, and other documents are available on the Senate Agriculture Committee’s website, https://www.agriculture.senate.gov/2018-farm-bill.
 Ed Bolen et al., “House Agriculture Committee’s Farm Bill Would Increase Food Insecurity and Hardship,” Center on Budget and Policy Priorities, June 7, 2018, https://www.cbpp.org/research/food-assistance/house-agriculture-committees-farm-bill-would-increase-food-insecurity-and.
 The states with pilot projects are: California, Delaware, Georgia, Illinois, Kansas, Kentucky, Mississippi, Virginia, Vermont, and Washington State. To find out more see https://fns-prod.azureedge.net/sites/default/files/snap/SNAP-ET-Pilot-Summaries.pdf.
 Statement of Brandon Lipps, Acting Deputy Under Secretary, Food, Nutrition and Consumer Services Administrator, Food and Nutrition Service, United States Department of Agriculture, Before the Senate Committee on Agriculture, September 14, 2017, https://www.agriculture.senate.gov/imo/media/doc/Testimony_Lipps.pdf.
 See National Accuracy Clearinghouse (NAC) Evaluation, Final Report, PCG, October 2015, p. 9, http://www.fns.usda.gov/sites/default/files/snap/NAC-Final-Evaluation-Report-FINAL-10-19-2015.pdf.
 7 C.F.R. § 253.11.