Notices and Case and Procedural Reviews

Mission PossibleReducing the Error Rate

0.00%

10.00%

20.00%23.20%

9.88% 6.45% 3.78% 3.09%

Error Breakdown by Element

Where Were We in FY 2012

0.00%

10.00%

20.00%22.96%

10.05%5.16% 4.42% 3.33%

Error Breakdown by Element

Where are we in FY 2013

Repor

ted

CAPER

Deter

min

atio

n Er

rors

Notice

Erro

rs

Proc

edur

al E

rror

s

Tim

elin

ess Er

rors

0.00%

10.00%

20.00%

FY 2012FY 2013

Need for improvement!

U.S. Total(State reported figures)

Overall CAPER (%)

State agency Determination Errors (% of CAPER)

Notice Errors (% of CAPER)

Procedural Errors (% of CAPER)

Timeliness Errors (% of CAPER)

FY-2012 23.20 42.58 27.79 16.30 13.33

FY-2013 22.96 43.76 22.46 19.27 14.51

Where are the errors coming from

22.96%

5.16%

Cases Where Variance Primarily Due to Notice

So, what does this mean?(FY 2013 Data)

33.06%

32.40%6.40%

28.13%

All Notice Errors for FY 2013

No Notice SentIncorrect Informa-tion on NoticeIncomplete NoticeUnclear Notice

How do the notice errors breakdown?

Almost half (48%) of the State agency determination errors are due to policy incorrectly applied. Second most frequent reason is that households were denied for failure to provide verification that was either already received or not required.

Of the notice errors, 1/3rd are due to no notice being sent, slightly less than 1/3rd are due to incorrect information on the notice, and approximately 28% are due to an unclear notice.

Notable Findings in the FY 2013 Data

Best Performers for FY 2013

BEST CAPERSouth Dakota 2.54%New Hampshire 7.66%Iowa 8.36%Alaska 8.59%

MOST IMPROVED CAPERSouth Carolina 13.59% (31.02% in

FY 12)Tennessee 23.51% (46.28% in

FY 12)

We have engaged a contractor to review and analyze SNAP online applications and notices of adverse action. Purpose is to: Develop best practices; Develop templates that States can use;

Contractor is currently evaluating each State’s notices and online applications. We have some results of the

contractor’s review. We will get to these shortly.

Things SNAP is Doing To help…

We are making changes to the FNS-245 to enhance data collection. One notable change is we will now gather information on how late a notice goes out. This will enable us to gauge the difference between the worker decision and the date the notice goes to the client.SNAPHQ-Web@fns.usda.gov, orhttp://www.regulations.gov and follow online instructions

A revised FNS-245 Form

Items of note: Majority of verification errors are where the

verification is already in the case file; If required notice is not sent, decision will be invalid; The reason on the notice must always be correct; Case record must support reason on notice; If more than one reason listed on notice, each reason

listed must be correct; Reason on notice must not simply rely on regulatory

or manual citations.

CAPER QC Guidance

Denial is invalid if application is denied after 30 days and application has not been pended. Rules on pending application: State agency caused delay, notice of pending

status must be sent by the 30th day (7 CFR 273.2(h)(3);

Client caused delay, notice of pending status must be sent on the 30th day (7 CFR 273.2(h)(2);

Additional CAPER Guidance

FNS issued a policy memo on best practices in developing effective notices on May 29, 2014.

Currently building on this by developing more detailed guidance to help States improve their notices. Based on review of negative notices from State

agencies. Will present guiding principles and sample notices

Anticipated release in October. FNS will host webinars following publication.

Notice Policy Guidance

Guiding Principles

Most Effective Notices

Task Completion Put key information up front; make it clear &

direct. Emphasize what clients can do.

Navigation Use clear visual grid to help clients see

individual notice pieces and the whole. Group related information together & use

descriptive headings

Guiding Principles

Presentation Ensure easy readability of font type/size. Use additional graphical elements to support

client

Comprehension Keep sentences short, simple, & active. Use common words, definitions, & examples.

Guiding Principles

Other Compliance Be compliant with policies and regulations!

Guiding Principles

Waiver to deny household after 10 days for failure to provide verification is available and may help States to avoid late denials.

Consider an early cut-off on 30th day, for example 10 a.m. Workers would then be able to process a denial for failure to submit verification. Ensure that the notice is mailed within the FNS approved timeframe.

Consider Electronic Notices.

Other Ideas

Talk to your regional office about problems you are encountering. This begins the conversation that ultimately involves the national office on ways to reduce your CAPER and improve client service.

Questions?

Finally