BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:   May 4, 2011

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                Felipe Fuentes, Chair

                    AB 6 (Fuentes) - As Amended:  April 12, 2011 

          Policy Committee:                              Human 
          ServicesVote:4 - 2 

          Urgency:     No                   State Mandated Local Program: 
          Yes    Reimbursable:              Yes

           SUMMARY  

          This bill changes a number of policies related to the 
          administration of CalFresh (formerly Food Stamps) and California 
          Work Opportunity and Responsibility to Kids program (CalWORKs).  
          Specifically, this bill: 

          1)Requires counties to convert from a quarterly to a semi-annual 
            reporting system for CalWORKs and CalFresh no later than 
            January 1, 2013.

          2)Eliminates the Statewide Finger Imaging System (SFIS).

          3)Requires the Department of Social Services (DSS) and the 
            Department of Community Services and Development to design, 
            implement and maintain a "Heat and Eat" program by January 1, 
            2013.

           FISCAL EFFECT  

          1)First year costs for the three program changes required by 
            this bill would be approximately $11 million ($8 million 
            TANF/GF). By the second year, the remaining up front 
            automation and training costs for Semi Annual Reporting (SAR) 
            would be fully offset by one half year of administrative 
            savings for a net savings of $17 million ($16.5 million 
            TANF/GF). On-going savings and workload relief for counties in 
            the CalFresh and CalWORKs programs would likely be 
            approximately $77 million ($51 million TANF/GF).

            In addition, these changes would likely bring in an additional 
            $850 million in federal Supplemental Nutritional Assistance 








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            Program (SNAP) funding and $23 million in additional sales tax 
            revenue for the General Fund. 

             a)   Semi Annual Reporting (SAR)

               i)     One-time costs of $20 million ($15 million TANF/GF) 
                 for systems changes and providing notices to participants 
                 about the implementation of the new reporting 
                 requirements. 

               ii)    DSS estimates on-going annual administrative savings 
                 of approximately $75 million ($36 million TANF/GF) as a 
                 result of the implementation of SAR.


               iii)   On-going annual CalWORKs grant costs of 
                 approximately $19 million (TANF/GF) as a net result of 
                 some CalWORKs recipients receiving slightly higher grants 
                 than they would under the current quarterly reporting 
                 system where the grant is adjusted more often due to 
                 earnings and other individuals receiving slightly less 
                 than they would under the current system.


               iv)    Assuming a 5% increase in CalFresh recipients due to 
                 the implementation of SAR, Californians could receive 
                 approximately $400 million in federal SNAP (CalFresh) 
                 benefits.


               v)     Absent the adoption of SAR through this legislation, 
                 the federal government will require the state to convert 
                 to straight quarterly reporting for its CalFresh caseload 
                 by September 30, 2011. DSS estimates the cost of the 
                 conversion would be approximately $7.2 million in up 
                 front automation changes with an ongoing annual 
                 administrative cost of $24 million ($12 million GF). 
                 Therefore, adoption of SAR allows the state to avoid 
                 these costs.


             b)   SFIS Elimination

               i)     There is no additional CalWORKs cost associated with 
                 the elimination of finger imaging. In previous years, DSS 








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                 has asserted that the elimination of finger imaging for 
                 CalWORKs recipients would result in a $60 million 
                 increase in costs due to duplicate aid fraud. This 
                 estimate is based on a pre-welfare reform study of the 
                 General Relief caseload in the county of Los Angeles. 
                 California's State Auditor, the federal government, an 
                 audit of the states of New York and Texas and a 
                 feasibility study in Maryland refute that assertion. For 
                 a more detailed discussion of the DSS SFIS elimination 
                 estimate, please see the comments section below.

               ii)    The Office of Systems Integration (OSI) estimates 
                 one-time decommissioning costs of $11 million ($7.4 
                 million TANF/GF) to shut down the finger imaging system 
                 throughout the state. Those costs include paying $7 
                 million in an outstanding loan for the equipment and 
                 paying Hewlett Packard (the vendor) $1.8 million to 
                 travel throughout the state to pack up the 275 finger 
                 imaging machines. These costs would occur only if the 
                 governor fails to adopt the 2011-12 budget passed by the 
                 Legislature, which eliminates the finger imaging of In 
                 Home Supportive Services recipients.  If that requirement 
                 remains in state law, the machines would not be 
                 decommissioned. 

               iii)   Assuming an increase in the CalFresh caseload of 
                 4.3%, based on a recent Urban Institute study, 
                 administrative costs for the program could increase by 
                 $27 million ($9 million GF).  Those costs, however, would 
                 be partially offset by the on-going savings due to the 
                 elimination of SFIS of $13 million ($9 million TANF/GF)


               iv)    Assuming a 4.3% increase in CalFresh recipients due 
                 to the elimination of finger imaging, Californians could 
                 receive approximately $352 million in federal SNAP 
                 (CalFresh) benefits.


             c)   "Heat and Eat" Program 

               i)     On-going administrative savings of approximately $12 
                 million ($8 million GF) associated with eligibility 
                 workers no longer having to calculate the utility 
                 allowance for CalFresh recipients. The administrative 








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                 savings would be modestly offset by the on-going 
                 administrative costs to add the federal Low-Income Home 
                 Energy Assistance Program (LIHEAP) benefit to the 
                 electronic benefit transfer (EBT) card of approximately 
                 $800,000 ($500,000 GF).  

               ii)    In order to allow all CalFresh recipients to benefit 
                 from the Standardized Utility Allowance (SUA), a modest 
                 LIHEAP benefit must be offered to each recipient. Up to 
                 $500,000 in federal LIHEAP funding could be set aside for 
                 90 days each year for recipients.  Based on the 
                 experience of other states, it is assumed that only a 
                 small number of recipients will actually redeem the 
                 benefit. Therefore, of the $500,000, $355,000 would be 
                 returned to the LIHEAP program to be reallocated to other 
                 LIHEAP recipients and $145,000 would likely be redeemed 
                 by CalFresh and CalWORKs participants. 

               iii)   Approximately 150,000 CalFresh recipients should see 
                 an increase in their monthly federal benefits. On 
                 average, those benefits will increase by 13% ($46 per 
                 month).  That increase will result in Californians 
                 receiving an additional $83 million in federal SNAP 
                 (CalFresh) benefits.

             d)   Additional Federal CalFresh Benefits

               Assuming a 9.3% increase in food stamps cases and increases 
               in the CalFresh benefits for 150,000 current CalFresh 
               families, Californians would receive approximately $850 
               million in additional federal food stamp benefits. Further, 
               this bill would allow the children in these families to be 
               eligible for free school meals, which are primarily 
               federally funded. Approximately $45 million dollars in 
               additional federal funding could flow to the state to 
               provide these children with free school lunches and 
               breakfasts. Finally, several million dollars in increased 
               federal child welfare services funds could be received by 
               the state.

             e)   Increased Sales Tax

               To the extent this bill increases food stamp participation, 
               the state could expect to receive additional state GF 
               revenues due to increased sales tax. Studies show that low 








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               income families spend approximately 45% of their income on 
               taxable goods. By providing these families with food 
               stamps, 45% of the money previously used by the family to 
               purchase food would now be used for taxable goods. Based on 
               this assumption, $850 million in additional CalFresh 
               benefits would result in $23 million in additional sales 
               tax revenue for the General Fund. 

           COMMENTS  

           1)Rationale  . The current complexity of the CalFresh program is 
            hurting participation. United States Department of Agriculture 
            (USDA) studies show that only 50% of eligible Californians 
            receive CalFresh benefits. Among working families, California 
            is last in the nation, reaching less than one-third (31%) of 
            the eligible families. This bill is designed to improve 
            participation and create efficiencies in the program by 
            continuing the practice of aligning eligibility requirements 
            for both the CalWORKs and CalFresh programs.

           2)Federal Denial of CalFresh Quarterly Reporting Waiver  . The 
            current federal waiver which allows California to align the 
            reporting requirements for CalWORKs and CalFresh cases expired 
            at the end of March this year.  The federal government over 
            the last two years has demanded that California move their 
            CalFresh program to the semi-annual reporting schedule 
            contained in this bill.  Absent that change, the two programs 
            will be separated and CalWORKs will maintain the current 
            modified quarterly reporting requirements (with a requirement 
            to report certain changes in family income) and CalFresh 
            recipients will revert to a straight quarterly reporting 
            system (where changes in income are not reported during the 
            interim months). This bifurcation means that families who 
            receive both benefits, essentially all CalWORKs recipients, 
            will need to navigate a system that requires them to report 
            changes in their circumstances one way for CalWORKs and a 
            different way for CalFresh.  This would create significant 
            confusion for both the recipients and the eligibility workers 
            and would likely result in an increase in the state's CalFresh 
            error rate, which could bring with it financial penalties for 
            the state.

            Since the implementation of the CalWORKs program in 1998, the 
            state has worked consistently to align the requirements of the 
            two programs, both for administrative ease for the eligibility 








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            worker and to provide simplification for recipients who are 
            eligible for multiple programs. Failing to pass this 
            legislation that allows the state to move both programs to a 
            semi-annual reporting schedule, the state will need to begin 
            bifurcating the programs and reversing the policy direction of 
            the last 13 years. 

            In the most recent letter to the administration, the United 
            States Department of Agriculture has allowed the state to 
            extend their waiver until September 30, 2011, in order to give 
            the Legislature enough time to pass AB 6 and for the governor 
            to sign the bill. 
                
            3)Why the Old DSS SFIS "Savings" Estimate Does Not Hold Up  . For 
            many years DSS has defended the $15 million annual state 
            investment in SFIS by suggesting the system "saved" over $60 
            million in fraudulent welfare payments. This estimate is based 
            on a Los Angeles county study of their General Relief program. 
            Since that time, both the State Auditor and the USDA have 
            questioned the validity of that original study.  In their 
            audit of DSS' finger imaging system, the State Auditor noted:

             "In its eagerness to implement SFIS, Social Services based 
            its estimates of the savings that SFIS would produce on an 
            evaluation of Los Angeles County's fingerprint imaging system, 
            rather than conducting its own statewide study. We have 
            concerns that the methods Los Angeles County used to develop 
            its savings estimate do not allow for the results to be 
            extrapolated statewide. Further, Social Services' use of this 
            data assumes that conditions in Los Angeles County hold true 
            in other counties. Similar concerns were expressed by the 
            United States Department of Agriculture as early as 1998."

            Beyond the flawed nature of the initial study, it is important 
            to note that the nation reformed welfare in the time since the 
            study was conducted. Since 1998, under CalWORKs, recipients 
            are required to participate in work activities as a condition 
            of receiving a CalWORKs grant. Because of these requirements, 
            it becomes difficult for a person to commit multi-county 
            duplicate aid fraud because they would need to work or 
            participate twice as many hours to meet the requirements for 
            each grant. In addition, EBT cards have replaced paper stamps 
            in the CalFresh program and paper checks in CalWORKs therefore 
            it makes  duplicate aid fraud less lucrative for people who 
            could previously sell or trade their food stamps.








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            Finally, SFIS is not the only fraud protection system in place 
            in both programs. With the advance of technology, the state 
            has been able to develop a myriad of automated matching 
            programs that detect attempted fraud.  There are many data 
            matches in the program which allow counties to check the 
            information provided by applicants. Among others, CalWORKs, 
            CalFresh and MediCal data is double-checked against data from 
            the Franchise Tax Board, Social Security Administration, 
            Prison and Death Records, Employment Development, records 
            already in the Medical Eligibility Determination System 
            (MEDS), and an Income and Eligibility Verification System 
            (IEVs). Therefore, the integrity of the programs remains 
            protected even if the finger imaging requirement is removed. 

           4)USDA Opinion  . In a letter provided to former Assemblymember 
            John Laird, on a similar bill dealing with semi-annual 
            reporting (AB 2844 of 2008), the USDA strongly encouraged the 
            state to move to a semi-annual reporting process. According to 
            USDA findings from other states, semi-annual reporting should 
            have numerous positive impacts for California, such as:

             a)   Improving the state's food stamps error rate by limiting 
               the number of changes that would need to be reported by 
               food stamps participants. 

             b)   Significantly reducing county administrative workload 
               due to less frequent certifications and interviews, fewer 
               reapplications following closures, and fewer periodic 
               report forms to process. 

             c)   Providing greater access to food stamps for eligible 
               families because there would be fewer terminations due to 
               incomplete recertifications, less frequent recertification 
               reviews, and more time to provide case managements and 
               other services designed to assist clients. 

             d)   Increasing the number of families that receive food 
               stamps based on the study of four states that saw an 
               increase in participation once they adopted semi-annual 
               reporting. The USDA also notes that there is no known 
               correlation between simplified reporting and an increase in 
               fraud.  










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          5)Quarterly Reporting Grant Impacts  . With the change from a 
            monthly reporting system to quarterly reporting for CalWORKs 
            and Food Stamps, the prior administration estimated that there 
            would be a significant cost associated with families 
            continuing to receive grants for two months for which they are 
            no longer entitled. However, once the system was implemented, 
            the actual data on grant payments showed that this concern was 
            unfounded. Given the state's experience with the move from 
            monthly to quarterly reporting, there is no evidence to 
            suggest that a move from quarterly to semi-annual reporting 
            would have a significant cost impact on CalWORKs grants. While 
            the fiscal section of this analysis acknowledges DSS' 
            assumption that there will be a grant cost in the CalWORKs 
            program, it may be that those costs are not borne out once 
            semi-annual reporting is implemented.   



          6)USDA Study  .  The United States Department of Agriculture 
            recently released a study that concluded that fingerprinting 
            is a statistically significant barrier for individuals who may 
            otherwise apply for food stamps. 
           
          7)Urban Institute Study  .  In March 2007, the Urban Institute 
            released a study examining a total of 25 specific policies 
            thought to affect food stamp program participation. The 
            Institute found strong evidence demonstrating the use of 
            fingerprinting reduces willingness to participate in the food 
            stamps program. 


           8)School Meals Program  . School meal programs are also 
            underutilized. Only half of income eligible students receive 
            lunch at school, and 18% receive school breakfasts. Some 
            low-income children with incomes between 133% and 185% of the 
            federal poverty level, currently ineligible for food stamps, 
            may not receive school meals because their families cannot 
            afford the 40 cents required for a reduced price lunch and 30 
            cents for breakfast. The children in new food stamps 
            households would be eligible for free school meals.  



          9)Additional Federal Child Welfare Services Funds.  The federal 








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            government awards funding to states through the Promoting Safe 
            and Stable Families (PSSF) program that can be used in the 
            Child Welfare Services program for efforts to reduce the 
            incidences of child abuse and neglect, and to promote 
            stability and permanency for at-risk children within families. 
            The federal government sets a capped amount for funding and 
            then awards those funds to states and territories based upon 
            the number of children in each state who are receiving food 
            stamps. Despite serving over 25% of the national child welfare 
            caseload, California receives less than 15% of the federal 
            PSSF funds because of the low food stamps participation rate. 
            To the extent this legislation increases food stamps 
            participation among families with children, California's share 
            of the PSSF funding should increase.  



          10)Related Legislation  . The SAR and SFIS portions of this 
            legislation have appeared in the budget and in various bills 
            over the years.  Those bills include:  



              a)   AB 1642 (Beall) 2010 - held in Assembly Appropriations
             b)   AB 1057(Beall) 2009 - held in Assembly Appropriations
             c)   AB 2844 (Laird) 2008 - vetoed 
             d)   AB 1382 (Leno) 2007 - vetoed 
             e)   AB 3029 (Laird) 2006 - died at desk
             f)   AB 696 (Chu) 2005 - vetoed 
             g)   AB 2013 (Steinberg/Lieber) 2004 - died in the Senate 
               without hearing 
                
            11)Chaptering Problem  .  AB 959 (Jones) and AB 1400 (Committee on 
            Human Services) both amend Welfare and Institutions Code 
            Section 11265.1, which is repealed by this legislation. 
            Chaptering language will eventually be necessary in all three 
            bills.  

           
           Analysis Prepared by  :    Julie Salley-Gray / APPR. / (916) 
          319-2081 












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