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Opportunities to Streamline Enrollment Across Public Benefit Programs

November 2, 2017
BY

Sonal Ambegaokar, Social Interest Solutions, and Zoë Neuberger and Dorothy Rosenbaum, Center on Budget and Policy Priorities[1]

Using information collected by one public benefit program to help enroll low-income people for other benefits for which they qualify makes programs more efficient and reduces hassles for struggling families.  Recognizing this, Congress has provided requirements and options to use data gathered by one program in another.  In some cases, a program can use another program’s eligibility determination to eliminate a duplicative process.  In other cases, a program can use data (such as income) that another trusted program has collected and verified to reduce burdens on state and local administrators and enable applicants to avoid having to provide the same paperwork to multiple offices.  But the rules are specific and can be hard to navigate across multiple programs.  An administrator of a child care, energy assistance, or Medicaid program may not be aware of all of the available connections across health and human services programs in the state or community.

This guide is designed to help state and local policymakers and program officials identify opportunities under federal law to streamline the application and enrollment process.This guide is designed to help state and local policymakers and program officials identify opportunities under federal law to streamline the application and enrollment process by relying on eligibility determinations made by other programs.  We refer to these cross-enrollment opportunities as “linkages” between programs.  This guide can help stakeholders identify linkages they would like to establish or strengthen and find the details they need to implement them. 

The following sections explain the importance of cross-enrollment opportunities and how states can strengthen them, followed by diagrams illustrating linkages among major federal benefit programs that assist low-income families and individuals.[2]  The diagrams capture whether the linkages are required or optional and whether they streamline the enrollment process or make it automatic.  State leaders overseeing multiple programs may find this guide helpful as they think about how to better connect systems or generate efficiencies.  Managers or program administrators who oversee a single program may find this guide useful in understanding the potential linkages they can leverage to increase efficiency, as well as the ways in which other programs can use their own eligibility work to assist their clients.

Appendix A contains a checklist of the optional linkages and those available through pilot programs or waivers so that states can consider whether to pursue them.  Appendix B describes important cross-enrollment opportunities that do not fall into the subset of linkages that we focus on in the rest of the guide.  Appendix C provides detailed information about each linkage, including statutory and regulatory citations, for state officials interested in strengthening or implementing a given linkage.  Appendix D provides background information on each of the programs we examined as well as the programs to which they are linked. 

Cross-Enrollment Can Simplify Administration and Improve Access

State and local agencies administer public benefit programs that help vulnerable populations make ends meet and support those who may not be able to work due to a disability — providing children, for instance, with affordable health care, safe housing, and adequate nutrition.  Individuals eligible for one program are often eligible for (and could benefit from) other programs.  Often, however, program staff spend time on duplicative work because they gather the same information from a family multiple times.  These unnecessary administrative steps increase the cost of operating benefit programs and can lead to many eligible individuals not receiving benefits for which they qualify.

State administrators have taken steps within programs to simplify the application and enrollment process for eligible individuals by, for example, using technology and improving business processes.  For instance, individuals can apply online or by phone and can upload or email copies of required documents instead of mailing a paper application or providing copies in person.  Interviews are often waived or can be done by phone.  High-quality data matches can further lower paperwork burdens.  Also, a single agency sometimes administers multiple programs.  But unless data sharing across programs is allowed, such joint administration often does not reduce duplicative information gathering.

Program rules for cross-program efficiencies can create additional opportunities for streamlining.  In some instances, participating in one program automatically confers eligibility for another; beneficiaries do not even have to apply.  For example, in 33 states and the District of Columbia, an individual whom the Social Security Administration (SSA) has found eligible for Supplemental Security Income (SSI) is automatically eligible for and enrolled in the state Medicaid program.[3]

In other instances, the application process is simplified by relying on an eligibility determination made by another program or information gathered through another program’s application process.  For example, the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) considers applicants income eligible if they receive Medicaid benefits; this is referred to as “adjunct eligibility.”  WIC staff can usually use an automated online or telephone system to confirm Medicaid eligibility, rather than reviewing income documentation for all family members and calculating whether the family is under the limit for a family of that size.  Even though applicants still must undergo WIC’s nutritional risk assessment before being approved for WIC benefits, adjunct eligibility simplifies an important part of the enrollment process for families and staff.  Whenever such simplifications are in place, it is important for programs to continue to allow applicants to provide documentation that they meet eligibility criteria if it cannot be obtained directly from another source, so that streamlining efforts do not inadvertently create barriers to program participation.  States are required to implement certain simplifications, while others are available as options or through pilots.  States interested in strengthening integration across programs can use this report to identify options they have not yet adopted or pilots for which they wish to apply.  States can also strengthen implementation of required program linkages to ensure that they operate effectively for all program participants to which they apply.

Navigating Linkage Opportunities

Many benefit programs are linked to at least one other program.  We examined 17 federal programs, listed in Table 1, to identify linkages that allow participants in one program to skip some or all steps in the application process for another program.[4]  Appendix D provides background information on each of the programs we examined as well as the programs to which they are linked. 

TABLE 1
17 Programs Examined for Linkages
  Program Acronym
Food Assistance
  Supplemental Nutrition Assistance Program SNAP
  National School Lunch Program[5] NSLP
  Special Supplemental Nutrition Program for Women, Infants, and Children WIC
 Health
  Medicaid[6]  
  Medicare  
  Medicare Savings Programs MSP
  Low-Income Subsidy LIS
 Income Supports
  Temporary Assistance for Needy Families TANF
  Supplemental Security Income SSI
  Federal Unemployment Insurance Benefits UI
  Earned Income Tax Credit EITC
  Child Tax Credit CTC
  Pell Grants and Other Post-Secondary Financial Aid Pell
  Child Care and Development Fund CCDF
Housing and Utilities
  Housing Assistance[7] Housing
  Low Income Home Energy Assistance Program LIHEAP
  Lifeline  

Although there is great variation in how programs are linked, certain patterns emerge.  (See Table 2.)  Some programs tend to conduct their own eligibility determinations and are heavily relied on by other programs, though their mechanisms vary.  Generally these programs, like SSI or the Supplemental Nutrition Assistance Program (SNAP), have a rigorous eligibility determination process and an administrative structure that ensures a high degree of accuracy in making such determinations. 

How Do We Define a “Linkage” in This Report?

A “linkage” is an existing federal eligibility rule that permits or requires one program to adopt in whole or in part another program’s eligibility findings at the initial application stage to allow the applicant to bypass some or all of the eligibility determination process to reduce duplicative information gathering.

In contrast, some programs rely heavily on eligibility determinations by other programs.  Generally these programs, like the National School Lunch Program (NSLP) or Lifeline (which provides discounted access to phone and broadband services), are highly decentralized and do not have full-time caseworkers.

A few programs play both roles.  In some instances Medicaid relies on eligibility information gathered by SNAP or SSI, but programs like WIC and Lifeline rely on Medicaid’s eligibility determinations. 

A few major programs have very few linkages or none at all.  For example, of the 17 programs we reviewed, three — Unemployment Insurance, the Earned Income Tax Credit (EITC) and the Child Tax Credit (CTC) — are not linked to any other benefit programs.  We discuss them briefly below, but we do not include diagrams for them.

TABLE 2
Summary of Linkages Among Programs
Primarily Provides Information to Other Programs SNAP
TANF
SSI
Provides Information to Other Programs and Relies on Information From Other Programs WIC
Medicaid
MSP
LIS
Housing
Primarily Relies on Information From Other Programs NSLP
Medicare
Pell
CCDF
LIHEAP
Lifeline
Not Connected to Other Programs UI
EITC
CTC

Steps States Can Take to Facilitate Cross-Enrollment

Program administrators or policymakers who oversee multiple programs play a critical role in establishing and strengthening cross-enrollment between programs to simplify program operations and ensure that low-income people receive the full package of benefits for which they qualify.  Specific steps these stakeholders may wish to consider include:

  • Improving the effectiveness of existing linkages.  This report focuses on a subset of cross-enrollment opportunities, specifically those that streamline the application and enrollment processes by relying on eligibility determinations made by other programs.  We refer to these opportunities as “linkages.”  States may wish to assess the effectiveness of existing linkages between programs and strive for continuous improvement.  Measures like improving data matching algorithms, establishing more robust referral mechanisms, streamlining business processes, and notifying program participants of their potential eligibility for other benefits can strengthen linkages so that they are more likely to result in families receiving the benefits for which they qualify.  

    An example from the school meals program is illustrative.  Under long-standing federal rules, all children in households that receive SNAP benefits are eligible for free school meals.  Since 2008, however, every school district has been required to automatically enroll these children for free school meals using data matching rather than requiring an application, known as “direct certification.”  But even so, at first more than 1 in 4 children (29 percent) who should have been automatically enrolled were not.  In 2008, the Agriculture Department (USDA) began measuring and publishing state performance annually.  In 2010, Congress established performance benchmarks.  States that do not meet the benchmarks must develop improvement plans.  High-performing states received bonuses for a few years.  Grant funding has been available to help states invest in improvements.  The share of eligible children who are automatically enrolled has increased from 71 percent to 91 percent since 2008.[8] 

  • Implementing optional linkages, waivers, and pilot projects that have not been adopted.  Many linkages are available as options or through waivers or pilot projects to promote cross enrollment.  These optional linkages are summarized in the checklist in Appendix A, which policymakers and stakeholders can use to identify opportunities they may wish to pursue.  The diagrams of programs with linkages in the next section and the table in Appendix C describe in more detail the different types of linkages and the federal rules that govern them. 
  • Establishing or strengthening other streamlining opportunities.  In addition to the linkages we focus on in this report, states can pursue other important activities that facilitate cross-enrollment.  Joint applications allow families to provide information only once to apply for multiple programs.  Many states have joint Medicaid/SNAP/TANF applications through their health and human services agencies.  Streamlining renewals is an important way of reducing gaps in benefits and the administrative costs of repeated eligibility determinations.  For example, Medicaid agencies are expected to check recent SNAP income information before initiating a Medicaid renewal.  If the information meets the state’s “reasonable compatibility” rules, the state need not contact the household for additional income documentation.  We briefly explain some of these types of additional streamlining approaches in Appendix B.  

Opportunities Regarding Several Large Benefit Supports with No Linkages

Three of the benefit supports we reviewed ― UI, the EITC, and the CTC ― are large income support programs for low-income families that do not have any linkages to other programs, despite being available to many of the same populations.  As a result, we do not include these three programs among the diagrams in the next section.

There are structural reasons that help explain why there are not existing linkages between these three programs and other programs for which the same low-income families are likely eligible.  The EITC and CTC are administered through the federal tax system based on annual income, and are delivered as an offset to income taxes (and as a refundable tax credit if the amount exceeds tax liability) to those who file taxes.[9]  Therefore they are not generally referred to as “programs” even though they provide important income support to low-income people.  UI, the federal-state system that temporarily helps people who have lost their jobs (and qualify for benefits based on their past work history) is typically administered by state labor departments.  Many workers who work in part-time jobs, in nontraditional jobs, or in jobs with volatile work schedules ― as many low-income recipients of public benefit programs do ― cannot qualify for Unemployment Insurance.

While there are no linkages into or out of these three programs, they nonetheless are large programs that can provide substantial support to low-income families and individuals in making ends meet and improving their circumstances.  As a result, states could take additional steps to ensure that people take advantage of these important benefits.  For example, staff who come into contact with participants in the other programs could be trained on eligibility rules and processes for UI and the EITC and CTC.  Also, the state websites that have information about available resources to support individuals and families could include information on these programs and help connect people to them.  By taking modest steps like these, state officials can help low-income participants in the programs they oversee boost their incomes and cover basic living expenses.

Linkage Opportunities Illustrated

This report focuses on program linkages that allow potentially eligible individuals to skip some or all steps in the initial application process.  In the diagrams that follow, we illustrate the different types of linkages for 14 of the federal benefit programs we reviewed, listed in Table 1, that provide critical support to a substantial number of low-income people and have overlapping eligibility requirements.[10]  There are 14 diagrams — one for each program indicated at the center.  The same linkage may appear in two diagrams, one showing the linkage into a program and the other showing a linkage out of the other program.  We also illustrate linkages into these programs from, or out of these programs to, additional benefit programs.  Appendix D provides additional information about each program shown in the diagrams, such as enrollment, funding, eligibility criteria, and the basic application process.[11] 

In addition to identifying linkages, we characterize the nature of the connection.  There are many variations in how information from one program is used in another, but we focus on three key features: the direction in which information flows, the extent to which the connection simplifies the application process (that is, whether it enrolls someone automatically or streamlines the application process in a more limited way), and whether a state or local agency must implement it or has the discretion to choose.  For every linkage identified between two programs, the diagrams indicate whether the linkage results in automatic or streamlined enrollment, and whether it is required, optional, or a pilot or waiver that must be applied for.

  • Direction.  Linkages between programs generally do not flow in both directions.  For instance, Lifeline uses eligibility determinations from many other programs to streamline enrollment, but no programs have a streamlined application for Lifeline enrollees.  The following diagrams indicate the direction in which information flows.  We describe programs that provide streamlined paths for participants to other benefits as providing linkages to another program.  We describe programs that rely on other programs’ eligibility determinations as drawing on linkages from another program.
  • Automatic vs. Streamlined.  We describe as automatic those linkages that allow participants in one program to be enrolled in another program without a separate application and with little or no involvement by the participant because there is an established data sharing mechanism.[12]  For example, when a child begins receiving foster care assistance, the child is categorically eligible for Medicaid; the Medicaid agency is notified of the child’s eligibility and can automatically enroll him or her for Medicaid benefits without a separate application.  We describe as streamlined those linkages that eliminate one or more steps in the application process by allowing enrollment in one program to satisfy some eligibility requirements for another program; individuals must still take additional steps to enroll in the additional program.  For example, WIC applicants who already receive Medicaid, SNAP, or TANF cash assistance do not have to provide income documentation if they or the agency can document participation in one of those programs, but they must complete the other steps in the eligibility determination process.  In some instances there are multiple linkages between programs, with one automatic and one streamlined.  For example, children in households receiving SNAP benefits can be automatically enrolled for free school meals without any involvement by the applicant; if, however, children are missed in the automatic enrollment process, the family can complete a streamlined application in which the SNAP case number is provided in lieu of income and household information.
  • Mandatory vs. Optional vs. Pilot.  In some instances, states are required (by the program’s federal eligibility rules) to implement linkages between programs to help streamline enrollment.  Generally these requirements apply statewide, regardless of whether the program is county or state administered, though implementation may vary based on each state’s program structure, existing processes, and data sharing agreements.  In other instances, states are allowed, but not required, to link eligibility across programs.  Sometimes states must notify the federal agency when electing an option and generally options must be implemented statewide.  But in some programs, local agencies choose whether to adopt certain options.  For example, under the NSLP, school districts choose whether to adopt certain options, and under the housing assistance programs, local housing authorities make such decisions for the housing assistance they administer.  There are also instances when a state agency must apply to participate in a pilot project or for a waiver to implement a linkage, subject to approval by a federal agency.  The process for seeking approval varies.  For example, the Centers for Medicare & Medicaid Services (CMS) initially encouraged states to seek waivers to use SNAP enrollment data to streamline enrollment into Medicaid, but later created a state option, along with the waiver option, to allow more states to adopt the practice.  Under a waiver or pilot project, linkages between programs may be time limited and often they are evaluated to assess their effectiveness.

This report focuses on identifying the presence and type of linkages between programs.  It is worth noting that some of the linkages we identify are widely used and many individuals or families are enrolled using them, while others are state options that are used by only a few states.  For example, 19 states are participating in a USDA demonstration project that allows them to use Medicaid data to enroll children for free or reduced-price school meals. By contrast, only a few states use the option that allows them to use data from the school meals program to enroll children in Medicaid.

Figure 1
Summary of Linkages
This chart indicates the linkages among the 17 programs we reviewed.  Programs listed in the left-hand column provide a linkage  ̶  or streamlined opportunity  ̶  to enroll in one, many, or none of the programs listed in the top row. 

 

Diagrams Illustrating Linkages

In this report we define a “linkage” as an existing federal eligibility rule that permits or requires one program to adopt in whole or in part another program’s eligibility findings at the initial application stage to allow the applicant to bypass some or all of the eligibility determination process to reduce duplicative information gathering.

The following diagrams illustrate three features of linkages:

Linkages - Arrow

 

  • Direction.  A linkage from a program indicates that some or all of its eligibility determination can be used to streamline enrollment into another program.  A linkage into a program indicates that it can use another program’s eligibility determination to simplify enrollment.
Linkages - Legend 1

 

  • Automatic vs. Streamlined.  We describe as automatic those linkages that allow participants in one program to be enrolled in another program without a separate application and with little or no involvement by the participant because there is an established data sharing mechanism.  We describe as streamlined those linkages that eliminate one or more steps in the application process by allowing enrollment in one program to satisfy some eligibility requirements for another program; individuals must still take additional steps to enroll in the additional program.  Some programs have multiple linkages, both automatic and streamlined, offering multiple opportunities for cross-enrollment.
Linkages - Legend 2

 

  • Mandatory vs. Optional vs. Pilot.  In some instances, states are requiredunder a program’s eligibility rules to implement linkages between programs to help streamline enrollment.  In other instances, state or local agencies are allowed, but not required, to link eligibility across programs.  There are also instances when a state agency must apply to participate in a pilot project or for a waiver to implement a linkage, subject to approval by a federal agency.

 

Appendix A: Optional Cross-Enrollment Opportunities

This checklist can serve as a guide for stakeholders who wish to assess what additional linkages they could implement to streamline eligibility determinations and ensure that low-income individuals get the full package of benefits for which they qualify.  The linkages listed below are options for a state or local agency or are available through a pilot program, and are organized by the program into which individuals or families would be enrolled.  These linkages are also identified in the diagrams in this report.  Details and citations to the statutory and regulatory authority for these options are available in Appendix C.

NSLP

  • Direct Certification Based on Program Participation.  States or school districts may automatically enroll students in households receiving TANF cash assistance, Food Distribution Program on Indian Reservation (FDPIR) benefits, or in foster care for free school meals by matching student data with TANF, FDPIR, or foster care data.
  • Medicaid Direct Certification.  In states that have been approved to participate in a USDA demonstration, school districts may use Medicaid income data to automatically enroll income-eligible students for free or reduced-price school meals.  
  • Direct Certification Based on Categorical Eligibility.  School districts may automatically enroll students who are homeless, migrant, runaway, in Head Start, or in foster care for free school meals based on a list or a designation provided by an appropriate official. 

SNAP

  • Broad-Based Categorical Eligibility.  States may adopt the asset and income tests for households that receive certain TANF-funded benefits in place of the SNAP tests.
  • Combined Application Project.  In states that have been approved to participate in a USDA demonstration, the state SNAP agency can partner with the SSA to have it provide a simplified SNAP application to households who only receive SSI, as well as provide individuals with a simpler enrollment process with a standardized or simplified SNAP benefit determination.

Medicaid

  • Express Lane Eligibility.  States may determine children enrolled in SNAP, TANF, NSLP, or other programs to be eligible for Medicaid or the Children’s Health Insurance Program (CHIP).
  • Targeted Enrollment Waiver Strategy.  States may determine non-disabled, non-elderly household members enrolled in SNAP to be financially eligible for Medicaid.
  • Targeted Enrollment State Plan Option.  States may determine non-disabled, non-elderly household members enrolled in SNAP, TANF, or other means-tested programs to be financially eligible for Medicaid.
  • Automatic Eligibility for SSI.  States can enter into an agreement with the Social Security Administration under Section 1634 of the Social Security Act to adopt an individual’s SSI eligibility determination for Medicaid eligibility through use of electronic data transfer.

Housing Assistance

  • Safe Harbor Under Calculation of Income. Once implementing regulations are issued, state and local public housing agencies and private subsidized housing owners will be able to adopt a household’s income determination from SNAP, Medicaid, and TANF (and potentially other federal low-income programs) to satisfy the income calculation for public housing, Housing Choice Vouchers, and Project-Based Rental Assistance. The option requires data sharing agreements between the housing agency and the agency providing data.  

Child Care and Development Fund

  • Deem Financial Eligibility Based on SNAP or Medicaid Participation. Because states have very broad discretion to set eligibility rules for child care subsidies, they may import the financial eligibility determination of another program, such as SNAP or Medicaid, without having to separately collect income verification or recalculate information.  The state would need only to collect from families the additional information unique to child care eligibility, such as detailed information about employment or providers.

Appendix B: Additional Cross-Enrollment Approaches

There are many opportunities to facilitate cross-enrollment that are outside the focus of this report but can play an important role in streamlining program operations and helping low-income individuals receive the full package of supports for which they qualify.  This Appendix highlights additional approaches for states to consider as part of streamlining or horizontal integration efforts.

  • Joint Applications.  When multiple programs require almost identical information to determine eligibility, a joint application allows applicants to provide the relevant information once for two (or more) programs at the same time, improving accuracy and reducing duplication.  For example, many state human services agencies offer a joint application process for TANF, SNAP, and Medicaid, and sometimes other programs. 
  • Area Eligibility.  Rather than making individual eligibility determinations, there are options to provide benefits to all individuals in a high-poverty area.  For example, the “community eligibility” option under the NSLP allows school districts to serve meals at no charge to all students without processing applications if 40 percent or more of the students in a school, group of schools, or district have been directly certified for free meals based on participation in another program.  The school district gets reimbursed based on a formula that reflects the poverty level of the participating schools.[13] 
  • Recertification or Renewal.  Most programs require participants to periodically re-establish eligibility, usually about once a year.  States can, at that time, make use of information that is gathered through one program’s recertification process to extend eligibility in another program.  For example, when a family updates its SNAP eligibility through the regular SNAP recertification process, the state could use that same information to automatically extend the Medicaid eligibility period for another 12 months, avoiding the need for Medicaid to duplicate the entire recertification process a few months later using the same data provided to SNAP.[14]  Similarly, Medicaid agencies can check recent SNAP income information before initiating a Medicaid renewal.  If the information meets the state’s “reasonable compatibility” rules, the state need not contact the household for additional income documentation and can complete what is known as an ex parte renewal.
  • Streamlining Verification.  Programs can share information across programs to simplify the verification of eligibility.  For example, states may rely on their department of motor vehicles database to verify state residency, their vital statistics database to verify citizenship through birth records, or third-party data such as credit records to verify identity.  Another example arises in the school meal programs.  A sample of approved school meal applications are selected for verification each year.  Traditionally school districts send a letter to the household requesting documentation of eligibility. But school districts are allowed to conduct “direct verification” instead, confirming eligibility without contacting the household by, for example, looking up selected students in a SNAP or TANF database.  Nonetheless, programs must continue to allow applicants to provide documentation that they meet eligibility criteria if it cannot be obtained directly from another source.
  • Targeted Outreach. States can use information about an individual’s qualification for one program to target outreach for another program.  For example, during a SNAP telephone recertification interview, an eligibility worker could explain to a senior citizen that he or she may also qualify for help with paying for Medicaid cost sharing or prescription drugs through Medicare (the LIS) or a state program.  States can also use information obtained from current recipients — such as child care expenses, knowledge that there is a child in the household, or earned income — to notify them that they may be eligible for the EITC or CTC.
  • Simplified Application.  There may be a subset of participants in one program who are highly likely to be eligible for another program.  For example, individuals receiving SSI who are very low-income, disabled, or over the age of 65 are highly likely to also be eligible for SNAP.  The SNAP agency can provide SSI recipients with a simplified application (through the Food and Nutrition Service’s Elderly Simplified Application Program, for example) that requests only the information that cannot be obtained from data matching with the SSA’s records.[15]
  • Federal Data Services Hub.  The Federal Data Services Hub allows states to verify certain eligibility factors, such as income and citizenship or immigration status of applicants for Medicaid, CHIP, and health insurance through the Affordable Care Act marketplaces using data from agencies such as the SSA, the Internal Revenue Service, and the Department of Homeland Security.  The hub allows an eligibility determination for these three programs to generally be made in real time after an application is submitted electronically.  CMS recently gave state agencies permission to use SSA data obtained through the hub to help streamline SNAP and TANF eligibility determinations along with Medicaid determinations.[16]  Three states — Montana, Oregon, and Pennsylvania — are piloting this approach.[17]
  • Adopting Eligibility Rules.  There are instances when programs can streamline the eligibility determination process by adopting another program’s eligibility rules (and thus its findings) for specific eligibility criteria.  This is similar to how linkages operate, but narrower in scope. For instance, under SNAP program rules, a state agency can apply TANF’s rules for how vehicles are counted toward the SNAP asset limit.  There is also an option within SNAP to conform with TANF or Medicaid income rules for certain types of excluded income. 

Appendix C:  Detailed Information About Linkages

This Appendix provides detailed information about the different types of linkage for the 14 programs we reviewed for this report, which are illustrated in the diagrams.  Below we list the linkages in and linkages out of each of the 14 programs.  Every linkage includes: a) the name that linkage is commonly known by; b) a brief description of how the linkage operates; c) whether it is mandatory or optional for a state to implement; d) whether the linkage provides automatic or streamlined enrollment; and e) the underlying federal authority for the linkage. When there is more than one linkage between two programs, we have numbered them to distinguish between them.  Appendix D provides background information on each of the programs we examined as well as the programs to which they are linked. 

The 14 programs are grouped in the table as follows: 

Food Assistance Programs  ̶  SNAP, NSLP, WIC

Health Programs  ̶  Medicaid, Medicare, MSP, LIS

Income Support Programs  ̶  SSI, TANF, Pell, CCDF

Housing and Utilities Programs  ̶   Housing, LIHEAP, Lifeline

Food Assistance Programs

Supplemental Nutrition Assistance Program (SNAP, Formerly Food Stamps)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Categorical Eligibility SSI recipients are “categorically” eligible for SNAP, though they must still provide information on their income and expenses for their benefit amounts to be determined. Mandatory S 7 U.S.C. § 2014(a); 7 C.F.R. § 273.2(j)(2)(i)(D); 7 C.F.R. § 273.2(k); 45 C.F.R. § 205.25
  SSI-CAP (Combined Application Project) Certain SSI households may apply using a simplified SNAP process and standardized or simplified benefit determination. States may use either the “standard” or “modified” model. CAP pilots are active in 17 states, but FNS and SSA are not currently approving new projects.[18] Pilot S 7 C.F.R. § 273.2(j)(2)(i)(D); 45 C.F.R. § 205.25; 7 C.F.R. § 272.3(c); “Combined Application Projects: Guidance for States Developing Projects,” U.S. Department of Agriculture, Food and Nutrition Service, March 2005.
  Categorical Eligibility Households that receive TANF cash assistance or certain other services funded through TANF or maintenance of effort requirements are “categorically” eligible for SNAP, though they must still provide information on their income and expenses for their benefit amounts to be determined. Mandatory S 7 U.S.C. § 2014(a); 7 C.F.R. § 273.2(j)(2)(i)(A); 7 C.F.R. § 273.2(j)(2(i)(B); 7 C.F.R. § 273.2(j)(2(i)(C)
  Categorical Eligibility General Assistance (GA) recipients are “categorically” eligible for SNAP, though they must still provide information on their income and expenses for their benefit amounts to be determined. Mandatory S 7 U.S.C. § 2014(a); 7 C.F.R. § 273.2(j)(4)
  Broad-Based Categorical Eligibility (BBCE) States can raise the asset test and income tests for households that receive certain TANF-funded benefits. State Option S 7 C.F.R. §§ 273.2(j)(2)(ii) and (j)(2)(iii)
  Direct Certification School districts must “directly certify” students in households receiving SNAP benefits for free school meals by matching student data with SNAP data at least three times each school year. Mandatory A 42 U.S.C. § 1758(b)(4); 7 C.F.R. §§ 245.6(b)(1) and (3)
  Categorical Eligibility Families indicate a case number on a school meal application in lieu of providing household and income information. Mandatory S 7 C.F.R. § 245.6(c)(5)
  Express Lane Eligibility (ELE) Through an “express lane agency,” states may determine children who receive SNAP, TANF, and other programs to be eligible for Medicaid or CHIP. State Option A or S 42 U.S.C. § 1396a(e)(13); CMS State Health Officials Letter #10-003, “Express Lane Eligibility Option,” February 4, 2010
  Targeted Enrollment Strategy Waiver States may determine non-disabled or non-elderly adults or children who receive SNAP to be financially eligible for Medicaid without a separate application. Waiver authority is limited to SNAP enrollees, state operational need, and duration. States may also apply to use this waiver with TANF in the same way. Waiver S 42 U.S.C. § 1396a(e)(14)(A) (stating “the Secretary may waive such provisions of this subchapter and subchapter XXI as are necessary to ensure that States establish income and eligibility determination systems that protect beneficiaries”); CMS State Health Officials Letter #13-003 “Facilitating Medicaid and CHIP Enrollment
and Renewal in 2014
,” May 17, 2013 CMS Informational Bulletin, "Extended Use of the Targeted Enrollment ‘SNAP Strategy’ under Section 1902(e)(14)(A) of the Social Security Act," July 19, 2017 (reaffirming availability of both state option and waiver for this linkage).
  Targeted Enrollment State Plan Option States may determine “highly likely to be eligible” adults or children who receive SNAP, TANF, or other programs to be financially eligible for Medicaid without a separate application. The state option for this linkage is not limited in scope or duration. State Option S CMS State Health Officials Letter # 15-001, “Policy Options for Using SNAP to Determine Medicaid Eligibility and an Update on Targeted Enrollment Strategies,” August 31, 2015
  Qualifying Low-Income Consumer Individuals can forgo the regular application process with the Lifeline service provider with proof of enrollment in another program of any household member (using either paper documentation or electronically via Lifeline’s National Verifier). Mandatory S 47 C.F.R. § 54.409(a)(2)
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(iii); 45 C.F.R. § 96.84(b)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(B) (SNAP included as means-tested program)
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving SNAP benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(ii)(I); 7 C.F.R. §246.7(d)(2)(vi)
  Safe Harbor Under Calculation of Income Public housing agency or private subsidized owner may use may use the income determination from another program to satisfy its income calculation at time of application, if data sharing is permitted by the other state agency. State/Local Option S Pub.L. 114-201; 42 U.S.C. § 1437a. (Effective after regulations issued. See Amendment to 42 U.S.C. § 1437a)
  Deemed Eligibility Because states have very broad flexibility to determine eligibility for child care subsidies, they may deem recipients of another program, like SNAP, to be financially eligible. States then need only collect from families the additional information that is needed for child care. State Option S 42 U.S.C. § 9857(b)(1); 45 C.F.R. §§ 98.16(h)(7), 98.46; Gina Adams and Hannah Matthews, “Confronting the Child Care Eligibility Maze: Simplifying and Aligning with Other Work Supports,” December 2013.
National School Lunch Program (NSLP)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Direct Certification School districts must “directly certify” students in households receiving SNAP benefits for free school meals by matching student data with SNAP data at least three times each school year. Mandatory A 42 U.S.C. § 1758(b)(4); 7 C.F.R. §§ 245.6(b)(1) and (3)
  Direct Certification States or school districts may “directly certify” students in households receiving TANF cash assistance for free school meals by matching student data with TANF data. State/Local Option A 42 U.S.C. § 1758(b)(5)(A); 7 C.F.R. § 245.6(b)(2)
  Direct Certification States or school districts may “directly certify” students in households receiving FDPIR benefits for free school meals by matching student data with FDPIR data. State/Local Option A 7 C.F.R. § 245.6(b)(2)
  Direct Certification States or school districts may “directly certify” a foster child for free school meals by matching student data with foster care data. State/Local Option A 42 U.S.C. § 1758(b)(5)(E); 7 C.F.R. § 245.6(b)(2)
  Direct Certification In states that have been approved to participate in a USDA demonstration, school districts may “directly certify” students for free or reduced-price school meals by matching student data with Medicaid income data. Pilot A 42 U.S.C. § 1758(b)(15); 42 U.S.C. § 1769(c); “Request for Applications to Participate In Demonstration Projects to Evaluate Direct Certification with Medicaid,” U.S. Department of Agriculture, Food and Nutrition Service, January 27, 2016
  Categorical Eligibility Families indicate a case number on a school meal application in lieu of providing household and income information. Mandatory S  7 C.F.R. § 245.6(c)(5)
  Categorical Eligibility Families indicate a case number on a school meal application in lieu of providing household and income information. Mandatory S  7 C.F.R. § 245.6(c)(5)
  Categorical Eligibility Families indicate a case number on a school meal application in lieu of providing household and income information. Mandatory S 7 C.F.R. § 245.6(c)(5)
  Categorical Eligibility Families indicate that a child is a foster child on a school meal application in lieu of providing household and income information. Mandatory S 7 C.F.R. § 245.6(b)(8)
  Categorical Eligibility/Direct Certification School districts may approve Head Start students for free school meals based on documentation provided by Head Start staff. Local Option A 7 C.F.R. §§ 245.6(b)(2) and (6)
  Categorical Eligibility/Direct Certification School districts may approve homeless or runaway students for free school meals based on a list provided by a homeless liaison, shelter director, or other appropriate official. Local Option A 42 U.S.C. §§ 1758(b)(5)(B) and (C); 7 C.F.R. §§ 245.6(b)(2) and (6)
  Categorical Eligibility/Direct Certification School districts may approve migrant students for free school meals based on a list provided by a Migrant Education Coordinator or other appropriate official. Local Option A 42 U.S.C. § 1758(b)(5)(D); 7 C.F.R. §§ 245.6(b)(2) and (6)
  Categorical Eligibility/Direct Certification School districts may “directly certify” foster children for free school meals by matching student data with child welfare data or based on documentation provided by a foster care caseworker or other appropriate official. Local Option A 42 U.S.C. § 1758(b)(5)(E); 7 C.F.R. §§ 245.6(b)(2) and (6)
  Express Lane Eligibility (ELE) Through an "express lane agency," states may determine children who receive NSLP to be financially eligible for Medicaid or CHIP. Additional information on citizenship and immigration status is required. State Option S 42 U.S.C. § 1396a(e)(13); CMS State Health Officials Letter #10-003, “Express Lane Eligibility Option,” February 4, 2010
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in an eligible program and the household adjusted gross income is below $50,000. Expected Family Contribution (EFC) is automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(C) (NSLP included as means-tested program)
 
Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving SNAP benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(ii)(I); 7 C.F.R. §246.7(d)(2)(vi)
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving Medicaid benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(iii)(l) [full-scope] and 42 U.S.C. § 1786(d)(2)(A)(iii)(II) [pregnancy-related]; 7 C.F.R. § 246.7(d)(2)(vi)
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving TANF benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(ii)(II); 7 C.F.R. § 246.7(d)(2)(vi)
  Adjunct Eligibility States also have the option of establishing automatic income eligibility based on participation in other state-administered programs that routinely require documentation of income and have an income limit at or below WIC’s. State Option S 7 C.F.R. § 246.7(d)(vi)(B)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in an eligible program and the household adjusted gross income is below $50,000. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(E) (WIC included as means-tested program)
 

Health Programs

Medicaid (Full-Scope)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Automatically Linked Eligibility (in States With “1634 Agreements” With SSA) SSI individuals are categorically eligible for Medicaid as a mandatory category. In states with an agreement with SSA, an individual is automatically enrolled in Medicaid upon approval of SSI benefits without a separate Medicaid application through use of electronic data transfer. The state Medicaid agency adopts the SSI eligibility determination in whole and issues the Medicaid card. State Option A 42 C.F.R. § 435.120; 42 C.F.R. § 435.909(b)(1); 42 C.F.R. § 435.541(a)(2); 20 C.F.R. §416.2111; SSA POMS § SI 01715.010
  Categorical Eligibility (in States Without “1634 Agreements” With SSA) SSI individuals are categorically eligible for Medicaid as a mandatory category. In states without an agreement with SSA, an SSI recipient must apply for Medicaid with the state agency through the regular application process. The Medicaid agency may adopt some or all of the SSI eligibility determination, such as the disability determination or resource requirements, to streamline the enrollment process. State Option S 42 C.F.R. § 435.120; 42 C.F.R. § 435.121(a); 42 C.F.R. § 435.541(c)(3)
  Categorical Eligibility Individual is automatically enrolled into Medicaid once approved for Foster Care, Guardianship, or Adoption Assistance under Title IV-E of the Social Security Act. Mandatory A 45 C.F.R. § 435.145(b)(1) and (2)
  Express Lane Eligibility (ELE) Through an “express lane agency,” states may determine children who receive SNAP, TANF, and other programs to be eligible for Medicaid or CHIP. State Option A or S 42 U.S.C. § 1396a(e)(13); CMS State Health Officials Letter #10-003, “Express Lane Eligibility Option,” February 4, 2010
  Express Lane Eligibility (ELE) Through an “express lane agency,” states may determine children who receive NSLP to be financially eligible for Medicaid or CHIP. Additional information on citizenship and immigration status is required. State Option S 42 U.S.C. § 1396a(e)(13); CMS State Health Officials Letter #10-003, “Express Lane Eligibility Option,” February 4, 2010
  Targeted Enrollment Strategy Waiver States may determine non-disabled or non-elderly adults or children who receive SNAP to be financially eligible for Medicaid without a separate application. States may also apply to use this waiver with TANF in the same way. Waiver S 42 U.S.C. § 1396a(e)(14)(A) (stating “the Secretary may waive such provisions of this subchapter and subchapter XXI as are necessary to ensure that States establish income and eligibility determination systems that protect beneficiaries”); CMS State Health Officials Letter #13-003 “Facilitating Medicaid and CHIP Enrollment
and Renewal in 2014
,” May 17, 2013 CMS Informational Bulletin, “Extended Use of the Targeted Enrollment ‘SNAP Strategy’ under Section 1902(e)(14)(A) of the Social Security Act,” July 19, 2017 (reaffirming availability of both state option and waiver for this linkage).
  Targeted Enrollment State Plan Option States may determine “highly likely to be eligible” adults or children who receive SNAP, TANF, or other programs to be financially eligible for Medicaid without a separate application. The state option for this linkage is not limited in scope or duration. State Option S CMS State Health Officials Letter # 15-001, “Policy Options for Using SNAP to Determine Medicaid Eligibility and an Update on Targeted Enrollment Strategies,” August 31, 2015
  Direct Certification In states that have been approved to participate in a USDA demonstration, school districts may “directly certify” students for free or reduced-price school meals by matching student data with Medicaid income data. Pilot A 42 U.S.C. § 1758(b)(15); 42 U.S.C. § 1769(c); “Request for Applications to Participate In Demonstration Projects to Evaluate Direct Certification with Medicaid,” U.S. Department of Agriculture Food and Nutrition Service, January 27, 2016 
  Safe Harbor Under Calculation of Income Public housing agency or private subsidized owner may use the income determination from another program to satisfy its income calculation at time of application, if data sharing is permitted by the other state agency. State/Local Option S  Pub.L. 114-201; 42 U.S.C. § 1437a. (Effective after regulations issued. See Amendment to 42 U.S.C. § 1437a)
  Qualifying Low-Income Consumer Individuals can forgo regular application process with Lifeline service provider with proof of enrollment in another program of any household member (using either paper documentation or electronically via Lifeline’s National Verifier). Mandatory S 47 C.F.R. § 54.409(a)(2)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(F) (Medicaid included as “other [means-tested] programs as identified by Secretary”)
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving Medicaid benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(iii)(l) [full-scope] and 42 U.S.C. § 1786(d)(2)(A)(iii)(II) [pregnancy-related]; 7 C.F.R. §246.7(d)(2)(vi)
  Deemed Eligibility Periodic state data matching with SSA to deem MSP eligibility for Medicaid recipients who begin to qualify for Medicare. Mandatory A 42 C.F.R. § 407.17(a); 42 C.F.R. § § 407.42(a)(2) and 407.42(a)(7); SSA POMS §§ HI 00815.001, 00815.006
  Deemed Subsidy Eligible Full benefit dual-eligibles are deemed eligible for LIS by SSA without a separate application required. Mandatory A 42 C.F.R. § 423.773(c)(1)(i); 20 C.F.R. § 418.3105; SSA POMS § HI 03001.005
  Deemed Eligibility Because states have very broad flexibility to determine eligibility for child care subsidies, they may deem recipients of another program, like SNAP or Medicaid, to be financially eligible. States then need only collect from families the additional information that is needed for child care. State Option S 42 U.S.C. §9857(b)(1); 45 C.F.R. §§ 98.16(h)(7), 98.46; Gina Adams and Hannah Matthews, “Confronting the Child Care Eligibility Maze: Simplifying and Aligning with Other Work Supports,” December 2013.
Medicare
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Deemed Eligibility Individuals are categorically eligible and automatically enrolled by SSA into Medicare after 24 continuous months of receiving SSDI benefits. Mandatory A 42 U.S.C. § 426(b)(2)(A); 42 C.F.R. § 406.12(a)(1); SSA POMS §§ HI 00801.146, HI 00805.040, RS 01601.160
 
Medicare Savings Programs (MSP)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Deemed Eligibility Periodic state data matching with SSA to deem MSP eligibility for Medicaid recipients who begin to qualify for Medicare. Mandatory A 42 C.F.R. § 407.17(a); 42 C.F.R. § § 407.42(a)(2) and 407.42(a)(7); SSA POMS §§ HI 00815.001, 00815.006
  Simplified Application SSA automatically sends information from an individual’s completed LIS application to the state Medicaid agency to determine MSP eligibility. Mandatory S 42 U.S. C. § 1396u–5(a)(4); 2 C.F.R. § 423.904(c)(2); SSA POMS § HI 00815.024
  Deemed Subsidy Eligible Individuals enrolled in MSP are deemed eligible for LIS by SSA without a separate application required. Mandatory A 45 C.F.R. § 423.773(c)(1)(iii); 20 C.F.R. § 418.3105; SSA POMS § HI 03001.005
(Low-Income Subsidy (LIS, “Extra Help”)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Deemed Subsidy Eligible SSI recipients who become newly eligible for Medicare are deemed eligible for LIS by SSA without additional information required. Mandatory A 42 C.F.R. § 423.773(c)(1)(ii); 20 C.F.R. § 418.3105; SSA POMS §§ HI 00801.139 and HI 03001.005
  Deemed Subsidy Eligible Full benefit dual-eligibles are deemed eligible for LIS by SSA without a separate application required. Mandatory A 42 C.F.R. § 423.773(c)(1)(i); 20 C.F.R. § 418.3105; SSA POMS § HI 03001.005
  Deemed Subsidy Eligible Individuals enrolled in MSP are deemed eligible for LIS by SSA without a separate application required. Mandatory A 45 C.F.R. § 423.773(c)(1)(iii); 20 C.F.R. § 418.3105; SSA POMS § HI 03001.005
  Simplified Application SSA automatically sends information from an individual’s completed LIS application to the state Medicaid agency to determine MSP eligibility. Mandatory S 42 U.S. C. § 1396u–5(a)(4); 42 C.F.R. § 423.904(c)(2);
SSA POMS § HI 00815.024
 

Income Support Programs

Temporary Assistance for Needy Families (TANF)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Direct Certification States or school districts may “directly certify” students in households receiving TANF cash assistance for free school meals by matching student data with TANF data. State/Local Option A 42 U.S.C. § 1758(b)(5)(A); 7 C.F.R. § 245.6(b)(2)
  Categorical Eligibility Families indicate a case number on a school meal application in lieu of providing household and income information. Mandatory S 7 C.F.R. § 245.6(c)(5)
  Categorical Eligibility Households that receive TANF cash assistance or certain other services funded through TANF or maintenance of effort requirements are “categorically” eligible for SNAP, though they must still provide information on their income and expenses for their benefit amounts to be determined. Mandatory S 7 U.S.C. § 2014(a); 7 C.F.R. § 273.2(j)(2)(i)(A); 7 C.F.R. § 273.2(j)(2(i)(B); 7 C.F.R. § 273.2(j)(2(i)(C)
  Broad-based Categorical Eligibility (BBCE) States can raise the asset test and income tests for households that receive certain TANF-funded benefits. State Option S 7 C.F.R. §§ 273.2(j)(2)(ii) and (j)(2)(iii)
  Express Lane Eligibility (ELE) Through an “express lane agency,” states may determine children who receive SNAP, TANF, and other programs to be eligible for Medicaid or CHIP. State Option A or S 42 U.S.C. § 1396a(e)(13); CMS State Health Officials Letter #10-003, “Express Lane Eligibility Option,” February 4, 2010
  Targeted Enrollment State Plan Option States may determine “highly likely to be eligible” adults or children who receive SNAP, TANF, or other programs to be financially eligible for Medicaid without a separate application. The state option for this linkage is not limited in scope or duration. State Option S CMS State Health Officials Letter # 15-001, “Policy Options for Using SNAP to Determine Medicaid Eligibility and an Update on Targeted Enrollment Strategies,” August 31, 2015
  Safe Harbor Under Calculation of Income Public housing agency or private subsidized owner may use the income determination from another program to satisfy its income calculation at time of application, if data sharing is permitted by the other state agency. State/Local Option S Pub. L. No. 114-201; 42 U.S.C. § 1437a. (Effective after regulations issued. See Amendment to 42 U.S.C. § 1437a)
  Adjunct Eligibility Applicants are income-eligible for WIC if they or the WIC staff document that they are receiving TANF benefits. Mandatory S 42 U.S.C. § 1786(d)(2)(A)(ii)(II); 7 C.F.R. §246.7(d)(2)(vi)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(D) (TANF included as means-tested program)
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(i); 45 C.F.R. § 96.84(b)
  Supportive Services TANF recipients who are participating in work activities who qualify for supportive services may or may not require a separate application to receive child care subsidies. In some states, eligibility for child care subsidies may be automatic for some TANF recipients. State Option S 42 U.S.C. § 9858c(c)(3)(D); 45 C.F.R. §§ 98.46, 260.31(a)(3)
 
Supplemental Security Income (SSI)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Automatically Linked Eligibility (in States With “1634 Agreements” With SSA) SSI individuals are categorically eligible for Medicaid as a mandatory category. In states with an agreement with SSA, an individual is automatically enrolled in Medicaid upon approval of SSI benefits without a separate Medicaid application through use of electronic data transfer. The state Medicaid agency adopts the SSI eligibility determination in whole and issues the Medicaid card. State Option A 42 C.F.R. § 435.120; 42 C.F.R. § 435.909(b)(1); 42 C.F.R. § 435.541(a)(2); 20 C.F.R. §416.2111; SSA POMS § SI 01715.010
  Categorical Eligibility (in States Without “1634 Agreements” With SSA) SSI individuals are categorically eligible for Medicaid as a mandatory category. In states without an agreement with SSA, an SSI recipient must apply for Medicaid with the state agency through the regular application process. The Medicaid agency may adopt some or all of the SSI eligibility determination, such as the disability determination or resource requirements, to streamline the enrollment process. State Option S 42 C.F.R. § 435.120; 42 C.F.R. § 435.121(a); 42 C.F.R. § 435.541(c)(3)
  Categorical Eligibility SSI recipients are “categorically” eligible for SNAP, though they must still provide information on their income and expenses for their benefit amounts to be determined. Mandatory S 7 U.S.C. § 2014(a); 7 C.F.R. § 273.2(j)(2)(i)(D); 7 C.F.R. § 273.2(k); 45 C.F.R. § 205.25
  SSI-CAP (Combined Application Project) Certain SSI households receive a simplified SNAP process and standardized or simplified benefit determination. States may use either the “standard” or "modified" model. CAP pilots are currently active in 17 states, but FNS and SSA are not currently approving new projects.[19] Pilot S 7 C.F.R. § 273.2(j)(2)(i)(D); 45 C.F.R. § 205.25; 7 C.F.R. § 272.3(c); "Combined Application Projects: Guidance for States Developing Projects," U.S. Department of Agriculture, Food and Nutrition Service, March 2005.
  Qualifying Low-Income Consumer Individuals can forgo regular application process with Lifeline service provider with proof of enrollment in another program of any household member (using either paper documentation or electronically via Lifeline’s National Verifier). Mandatory S 47 C.F.R. § 54.409(a)(2)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(A) (SSI included as means-tested program)
  Deemed Subsidy Eligible SSI recipients who become newly eligible for Medicare are deemed eligible for LIS by SSA without additional information required. Mandatory A 42 C.F.R. § 423.773(c)(1)(ii); 20 C.F.R. § 418.3105; SSA POMS §§ HI 00801.139 and HI 03001.005
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(ii); 45 C.F.R. § 96.84(b)
 
Pell Grants and Other Post-Secondary Financial Aid (Pell)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(A) (SSI included as means-tested program)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(D) (TANF included as means-tested program)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(B) (SNAP included as means-tested program)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(C) (NSLP included as means-tested program)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(E) (WIC included as means-tested program)
  Simplified Needs Test Students can forgo certain questions on the online application by using the Simplified Needs Test (SNT) if any household member currently or previously enrolled in another program. Expected Family Contribution (EFC) automatically determined as zero. Mandatory S 20 U.S.C. § 1087ss(b)(1)(A)(i)(IV) (Simplified Needs Test); 20 U.S.C. § 1087ss(d)(2)(F) (Medicaid included as “other [means-tested] programs as identified by Secretary”)
 
Child Care and Development Fund (CCDF)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Supportive Services TANF recipients who are participating in work activities who qualify for supportive services may or may not require a separate application to receive child care subsidies. In some states, eligibility for child care subsidies may be automatic for some TANF recipients. State Option S 42 U.S.C. § 9858c(c)(3)(D); 45 C.F.R. §§ 98.46, 260.31(a)(3)
  Deemed Eligibility Because states have very broad flexibility to determine eligibility for child care subsidies, they may deem recipients of another program, like SNAP or Medicaid, to be financially eligible. States then need only collect from families the additional information that is needed for child care. State Option S 42 U.S.C. § 9857(b)(1); 45 C.F.R. §§ 98.16(h)(7), 98.46; Gina Adams and Hannah Matthews, “Confronting the Child Care Eligibility Maze: Simplifying and Aligning with Other Work Supports,” December 2013.
 

Housing and Utilities Programs

Housing Assistance (Housing)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Safe Harbor Under Calculation of Income Public housing agency or private subsidized owner may use the income determination from another program to satisfy its income calculation at time of application, if data sharing is permitted by the other state agency. State/Local Option S Pub.L. 114-201; 42 U.S.C. § 1437a. (Effective after regulations issued. See Amendment to 42 U.S.C. § 1437a)
  Qualifying Low-Income Consumer Individuals can forgo regular application process with Lifeline service provider with proof of enrollment (e.g., copy of lease agreement) in another program of any household member (using either paper documentation or electronically via Lifeline’s National Verifier). Mandatory S 47 C.F.R. § 54.409(a)(2)
 
Low Income Home Energy Assistance Program (LIHEAP)
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(i); 45 C.F.R. § 96.84(b)
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(ii); 45 C.F.R. § 96.84(b)
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(iii); 45 C.F.R. § 96.84(b)
  Categorical Eligibility Individuals can forgo the regular application process with proof of enrollment in another program of any household member. Mandatory S 42 U.S.C. § 8624(b)(2)(iv); 45 C.F.R. § 96.84(b)
 
Lifeline
Linkages From Linkages To Name of Linkage Description Mandatory/
Optional/Pilot
Automatic or Streamlined Federal Authority
  Qualifying Low-Income Consumer Individuals can forgo regular application process with Lifeline service provider with proof of enrollment in another program of any household member (using either paper documentation or electronically via Lifeline’s National Verifier). Mandatory S 47 C.F.R. §§ 54.409(a)(2) and (b)
 

Appendix D:  Descriptions of Selected Federal Benefit Programs

This Appendix provides background information on each of the 17 benefit programs we examined as well as additional programs
to which they may be linked.

Programs Reviewed for Linkages (Alphabetical Order)
Program Description Total Enrollment Federal Funding Eligibility Application Process
Child Care and Development Fund (CCDF) Financial assistance to low-income families who need child care due to work, work-related training, and/or attending school. 1.4M children & 847K families/per month (FY 2015) $5.4B (FY 2015) Families with children under 13 with incomes below 85% of state median income.     Varies by area:  families can apply online, at social service agencies, through resource and referral agencies, or directly through providers.
Child Tax Credit (CTC) Tax credit to offset cost of raising children, worth up to $1,000 per eligible child under the age of 17. CTC is partially “refundable” – if the CTC exceeds the amount of federal income tax owed, the filer may receive part or all of the difference in the form of a refund check. Refundable portion begins phasing in for income over $3,000.   20M families (tax year 2015) Refundable portion: $27B (tax year 2015) Tax filer with children under 17. Refundable CTC begins phasing in at a rate of 15¢ per dollar of earnings above $3,000; begins phasing out at adjusted gross incomes above $75,000 for head of household filers and $110,000 for married couples. Apply through filing taxes.
Earned Income Tax Credit (EITC) Tax credit for working people with low to moderate income. Credit is refundable, so filers can claim even if taxes are not owed or not required to file. 26 states and D.C. also have state EITCs that supplement the federal credit.   28M workers and families received the EITC (2015) Federal EITC provided (refundable and non-refundable portions):  $69B (2015) Available to low- and moderate-income workers with and without kids. Total income must be below annual limit, which varies by filing status and number of children in the household. Apply through filing taxes.
Pell Grants and other post-secondary financial aid Federal grants or subsidized loans for secondary education tuition for low- and middle-income students. 7.6M (2015) $27.6B (2015)   GED or HS diploma. Apply online at FAFSA.ed.gov.
Lifeline Monthly discount of $9.25 on landline or wireless phones and broadband service to eligible households. 12.5M (2015) $1.5B (2015) Income below 135% FPL or enrollment in specific government benefit programs. Apply with qualifying phone/service provider.
Low Income Home Energy Assistance Program (LIHEAP) Financial assistance for eligible low-income households for heating and cooling energy costs, weatherization, and energy-related home repairs. 6.3M (FY 2014) $3.4B (FY 2015) Income below 150% FPL. Apply at local LIHEAP provider. Varies by state.
Low-Income Subsidy (LIS) (“Extra Help”) Financial assistance to eligible individuals for cost-sharing for Medicare Part D (drug coverage). 12.1M (2015) $25.6B (2015) Eligible with income below 150% FPL; resources must be less than $13,820 individual/$27,600 couples for partial LIS. Apply with Social Security Administration (SSA).
Medicaid Public health coverage program that provides comprehensive medical services to eligible low-income adults, children, pregnant women, elderly adults, and people with disabilities. 68.8M (FY 2015) $348B (FY 2015) Elderly disabled, children under 19-21, pregnant women, and low-income adults (including parents/caretakers and others in Medicaid expansion states). Varies by state. Apply online, by phone, by mail, or in person with state Medicaid agency.
Medicare Public health coverage program that provides comprehensive medical services to eligible individuals who are over 65 years old or disabled. 55.5M (2015) $648B (2015) Must have sufficient SSA work history to qualify. No income or resource test. SSA enrolls eligible individuals at time of open enrollment prior to 65th birthday. May apply online.
Medicare Savings Programs (MSP) Medicaid financial assistance to eligible individuals for Medicare premiums and cost-sharing. 8.8M (2013) $8B (FY 2015) Must be Medicare recipient with income below 135% FPL and meet resource test (if applicable). Apply at state Medicaid agency.
National School Lunch Program (NSLP) Free or low-cost breakfast and lunch to eligible children in school. The School Breakfast Program relies entirely on the National School Lunch Program to make eligibility determinations. 29M approved for free or reduced-price school lunch (FY 2015) $12.0B (FY 2015) Income at or below 130% FPL: free meals. At or below 185% FPL: reduced-price meals. Families submit a paper or online application to the school district.
Housing Assistance (Housing)   Financial assistance to help low-income families afford housing. Includes HUD’s Housing Choice Voucher (HCV) program, public housing, and Project-Based Rental Assistance. 4.4M households (2016) $35.5B (FY 2015 outlays) Families must have income at or below 80% of the local area median income at the time they first receive assistance. Apply to local or state Public Housing Agency (PHA) for public housing and Section 8 Vouchers or to private owner for Section 8 project-based rental assistance.
Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Food, nutrition education, breastfeeding support, and referrals for low-income women, infants, & children up to age 5 who are at nutritional risk. Average monthly participation: 8M individuals (FY 2015) $6.35B (FY 2015 budget authority) Low-income pregnant or postpartum women, infants, and children up to age 5 at nutritional risk. Income at or below 185% FPL or participating in Medicaid, SNAP, or TANF. Apply at local WIC clinic.
Supplemental Nutrition Assistance Program (SNAP) (Food Stamps) Benefits to low-income individuals to purchase food at authorized retailers. 44.2M (FY 2016) $70.9B (FY 2016) Applicants must have income and resources below certain limits. Benefits are based on income and certain deductible expenses. Apply at local/state agency. Call FNS hotline or visit SNAP’s “Contact Us” page to find local SNAP office.
Supplemental Security Income (SSI)   Cash assistance to individuals with disabilities and the elderly. 8.3M (2015) $56B (2015) Seniors and disabled adults and children with limited income/resources. Apply at SSA.
Temporary Assistance for Needy Families (TANF) Cash assistance to low-income individuals with dependents under the age of 19. Benefits may also include child care assistance, job preparation, & work assistance. 4.1M cash assistance (FY 2015) $16.5B (FY 2015) $31.7B (state & federal) Children under 19; pregnant or single parent or caretaker relative with limited income/resources (varies by state). Apply at state/local agency in person.
Unemployment Insurance Benefits (UI) Financial assistance for eligible individuals who are unemployed; supplement to state unemployment insurance benefits. 6.5M (2015) $32B (FY 2015) Varies by state. Apply at state agency.
Additional Programs to Which Programs Above Are Linked
Children’s Health Insurance Program (CHIP) Public health coverage that provides comprehensive medical services to children in families with incomes too high to qualify for Medicaid. 8.4M (FY 2015) $9.7B (FY 2015) Children under 19 with household income higher than Medicaid eligibility level (varies by state). No resource test. Apply online, by phone, by mail, or in person with state Medicaid or CHIP agency.
Foster Care and Adoption Assistance Board and care payments for eligible children who are under the supervision of the state and placed in foster family homes or child care institutions that are safe and licensed, or payments to stabilize families that adopt children with special needs who cannot be reunited with their families. 166K Foster Care (FY 2015); 445K Adoption Assistance (FY 2015) $7.3B (FY 2015) Children under 19 who are currently or in the past were removed from their homes as the result of maltreatment, lack of care, or lack of supervision. Apply at local/state agency.
Food Distribution Program on Indian Reservations (FDPIR)   Food assistance to low-income households, including the elderly, living on Indian reservations, and to Native American families residing in designated areas near reservations. 89K (FY 2015) $143M (FY 2015) Income-eligible American Indian and non-Indian households residing in approved areas near a reservation or in Oklahoma with at least one person who is a member of a federally recognized tribe. Apply at local State Distributing Agency/Indian Tribal Organization (ITO), or contact the Food and Nutrition Service Regional Office for further assistance.  
  General Assistance/General Relief (GA/GR) State-funded cash assistance for very low-income individuals who do not qualify for other public assistance. Monthly benefit in most states is less than 25% of the FPL. ($200/month on average). Varies by state. N/A Single adult, who may be disabled or otherwise unemployable. Apply through local/state agency.
  Head Start Assistance for children ages 5 and under from low-income families to help promote school readiness through education, health, social, and other services. 1.1M (FY 2015) $8.6B (FY 2015) Children ages 5 and below whose family is homeless, receiving TANF or SSI, or low income. Foster children are eligible regardless of the foster family’s income. Apply through local office, or contact a Head Start office for further assistance.
Homeless or Runaway Students   Educational support for homeless children under the McKinney-Vento Homeless Assistance Act (McKinney-Vento).  Social services and educational support for homeless or runaway youth under the Runaway and Homeless Youth Act (RHYA). 1.3M McKinney-Vento (2013-2014); 30-50K RHYA (in recent years) $65M McKinney-Vento (2015); $114.1M RHYA (FY 2015) McKinney-Vento supports children who lack a fixed, regular, and adequate nighttime residence.  RHYA supports youth under age 22 who are homeless or live in a shelter. Each school district’s McKinney-Vento local homeless education liaison identifies and supports homeless students.  Runaway and homeless youth may apply at local Basic Centers or call 1-800-RUNAWAY (786-2929) or 800-621-4000.
Migrant Education Program Educational and support services for eligible migratory children. 214K (2012-2013) $375M (2015) Children between the ages of 3 and 21 who are migratory agricultural workers or fishers or who move with a parent or guardian who is a migratory agricultural worker or fisher. Migrant children are identified and enrolled by local program coordinators.
Social Security Disability Insurance (SSDI)/Title II Disability Benefits Benefits for workers unable to work due to disability. Individuals with recent and substantial work generally eligible and may also receive SSI at same time. 11M (FY 2015) $143B (FY 2015) Under 66 and with severe, work-limiting disabilities expected to last 12+ months or result in death. No income or resource test.  SSDI beneficiaries are eligible for Medicare after receiving benefits for 24 months (2 years). Apply at SSA or online.  
Tribal Programs Cash and certain other assistance for members of federally recognized Indian tribes. Various programs Various programs Generally, Native American/American Indian enrolled in a federally recognized American Indian tribe or Alaska Native village, residing on or near an Indian reservation, and low income. Varies by program.
Veterans’ and Survivors’ Pension Income for eligible, low-income veterans and their survivors. 506K (FY 2015) $5.5B (FY 2015) Low-income veterans or their survivors who meet minimum service requirements and are either: over 65, disabled, in skilled nursing, or receiving SSDI or SSI. Apply with Department of Veterans Affairs.

End Notes

[1] The authors greatly appreciate the individuals at the Center on Budget and Policy Priorities, Social Interest Solutions, and the Center for Law and Social Policy (CLASP) who provided information and reviewed drafts of this report.

[2] An interactive version of the diagrams is available at www.cbpp.org/linkagesinteractive.

[3] “Medicaid and the Supplemental Security Income (SSI) Program,” Program Operations Manual System (POMS) Section SI 01715.010, Social Security Administration (SSA), https://secure.ssa.gov/poms.nsf/lnx/0501715010, accessed March 20, 2017.  Under Section 1634 of the Social Security Act, a state can request SSA to make Medicaid eligibility determinations and the state must provide Medicaid coverage to recipients of federally administered state supplementary payments (SSPs).

[4] We selected these 17 programs because they provide important supports to large numbers of low-income people.  We examined each to identify all the programs to which it is linked and we illustrate these linkages in the diagrams in this report.  Three of the programs are not linked to any others and therefore do not appear in the diagrams. 

[5] The School Breakfast Program relies entirely on the National School Lunch Program to make eligibility determinations.  Thus, when a child is approved to receive free or reduced-price lunches, the child also receives free or reduced-price breakfasts if the school offers them. 

[6]  In this report, Medicaid refers to full Medicaid coverage, (i.e., for children, adults, pregnant women, and elderly or disabled individuals), not limited Medicaid benefits such as for only family planning services or time-limited Refugee Medical Assistance under the Office of Refugee Resettlement (except that Medicaid coverage of Medicare cost-sharing for elderly and disabled Medicare beneficiaries is included under “Medicare Savings Programs”).

[7] Housing Assistance includes the Department of Housing and Urban Development’s Housing Choice Voucher (HCV) program, public housing, and Project-Based Rental Assistance.

[8] See Quinn Moore et al., Direct Certification in the National Lunch Program: State Implementation Progress, School Year 2014–2015, U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, December 2016, https://fns-prod.azureedge.net/sites/default/files/ops/NSLPDirectCertification2015.pdf, and similar reports for earlier school years.  For a more detailed discussion of direct certification and the steps states can take to improve performance, see Madeleine Levin and Zoë Neuberger, “Improving Direct Certification Will Help More Low-Income Children Receive School Meals,” Food Research and Action Center and Center on Budget and Policy Priorities, July 25, 2014, http://www.cbpp.org/research/improving-direct-certification-will-help-more-low-income-children-receive-school-meals.

[9] Many low-income families who are eligible for the EITC and CTC do not receive the benefit because they may be exempt from filing taxes if their income is below the tax filing thresholds set by the IRS.   See “Publication 501- Exemptions, Standard Deduction, and Filing Information,” Internal Revenue Service.

[10] See the interactive diagrams at www.cbpp.org/linkagesinteractive.

[11] Appendix D includes information on additional programs that are linked to one of the 17 programs listed in Table 1.

[12] For automatic linkages, it is important to clearly inform applicants how information they provide may be shared with other programs and allow the applicant to opt out.  Without such mechanisms, implementing a linkage could lead to confusion or erode trust when individuals are notified they are eligible for programs for which they did not specifically apply.

[13] For an explanation of how community eligibility works, see Becca Segal et al., “Community Eligibility Adoption Rises for the 2015–2016 School Year, Increasing Access to School Meals,” Center on Budget and Policy Priorities and Food Research & Action Center, updated May 13, 2016, https://www.cbpp.org/research/food-assistance/community-eligibility-adoption-rises-for-the-2015-2016-school-year.  For more recent information about which schools are eligible and which schools have adopted community eligibility, see the Food Research & Action Center’s resources available at http://www.frac.org/community-eligibility.

[14] For a more detailed discussion of opportunities to integrate SNAP and Medicaid renewals see, Jennifer Wagner and Alicia Huguelet, “Opportunities for States to Coordinate Medicaid and SNAP Renewals,” Center on Budget and Policy Priorities, February 5, 2016, http://www.cbpp.org/research/health/opportunities-for-states-to-coordinate-medicaid-and-snap-renewals.

[15] See U.S. Department of Agriculture, Food and Nutrition Service, “Elderly Simplified Application Project (ESAP) Guidance,” https://fns-prod.azureedge.net/sites/default/files/snap/ESAP_Guidance.pdf.  

[16]  “FAQs: States’ Use Of The SSA Data Set Via The Centers For Medicare & Medicaid Services’ (CMS) Hub for Supplemental Nutrition Assistance Program (SNAP) & Temporary Assistance for Needy Families (TANF) Eligibility,” Centers for Medicare & Medicaid Services, January 19, 2017, http://www.aphsa.org/content/dam/aphsa/pdfs/NWI/FAQ_Expanded%20Use%20of%20SSA%20Hub%20Data%20for%20SNAP%20and%20TANF%20Eligibility_2232017.pdf.  For more information on the status of implementation, see Social Security Administration, “Open Government Plan 4.1: Plan Milestones and Completion Report, Flagship and Major Initiatives,” updated September 2017, https://www.ssa.gov/open/plan-progress-4.1.html.

[17] “Federal Low-Income Programs: Eligibility and Benefits Differ for Selected Programs Due to Complex and Varied Rules,” U.S Government Accountability Office, GAO-17-558, June 29, 2017, note 64, https://www.gao.gov/products/GAO-17-558.

[18] “State Options Report - Supplemental Nutrition Assistance Program,” U.S. Department of Agriculture, Food and Nutrition Service, October 1, 2015, p. 21 (stating “FNS and SSA are not soliciting proposals for new demonstrations of this type”).

[19]Ibid.