A-133 Compliance Supplement - Food Stamp Cluster - Provisional 6/97
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The objective of the Food Stamp Program is to help low-income households buy the food they need for good health.


This description of Food Stamp Program procedures incorporates provisions of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Welfare Reform, P.L. 104-193, August 22, 1996). However, regulatory citations and form descriptions may be revised without any change in the policies described herein as the result of new regulations covering these legislative changes and regulatory streamlining that is currently underway in the Food Stamp Program. Food Stamp Program regulations are found in 7 CFR parts 271 through 285.


The U.S. Department of Agriculture (USDA), Food and Consumer Service (FCS) administers the Food Stamp Program in cooperation with State and local governments.

State welfare agencies (or county welfare agencies under the oversight of the State government) certify eligibility and provide benefits to households. FCS authorizes, monitors and investigates stores that redeem benefits, provides funding for State administration and benefits, and oversees the operation of State welfare agencies to ensure compliance with Federal law and regulations.

Federal Funding of Benefits and State Administrative Costs

The Federal Government pays 100 percent of the value of Food Stamp Program benefits and generally reimburses States for 50 percent of their costs to administer the program (7 CFR section 277.4(b)), except for those functions listed in Part III G., Matching. The Food Stamp Program is an open-ended entitlement program. Therefore, its authorizing statute places no cap on the amount of funds available to reimburse States for allowable administrative expenses. No reimbursement is allowed for State expenditures for activities undertaken as a condition of settlement of quality control claims against the State for low payment accuracy.


Eligibility for food stamps is based primarily on income and resources. Although welfare reform increases State design options that can affect benefits for recipients, a key feature of the Program is its status as an entitlement program with standardized eligibility and benefits.

Assessing Need

Households generally cannot exceed a gross income eligibility standard set at 130 percent of the Federal poverty standard (7 CFR section 273.9(a)(3)(i)). Households also cannot exceed a net income standard which is set at 100 percent of the Federal poverty standard (7 CFR section 273.9(a)(3)(ii)). The net income standard allows specified deductions from gross income, e.g., a standard deduction and deductions for medical expenses (elderly and disabled only), excess shelter costs, and work expenses. Non-financial eligibility criteria, only some of which affect benefit amounts, include: age, school status, citizenship, residency, household composition, work requirements, and disability status.

Application Process

The application process includes completing and filing an application form, being interviewed and having certain information verified. In addition to using information supplied by the recipients, welfare agencies use data from other agencies, such as the Social Security Administration, the Internal Revenue Service and the State employment security agency, to verify the household's identity and income.


Benefit amounts vary with household size and income. As required by law, allotments for various household sizes are revised October 1 of each year to reflect the cost of the Thrifty Food Plan, a model plan for a low-cost nutritious diet that is developed and costed by USDA. The maximum monthly Food Stamp Program benefit for fiscal year 1997 for a household of four is $400. Most households generally receive less that the maximum because maximum benefits are reduced by 30 percent of net income. During June 1996, 25 million persons received monthly food stamp benefits that totaled $1.8 billion.

The benefits each household receives are redeemed for food in participating retail stores. Historically, the benefit form has been a paper coupon issued in denominations of $1, $5 and $10. However, States are in the process of transferring to electronic benefit transfer (EBT) systems, whereby recipients receive a magnetic strip card which they can use to purchase food at retailers. Welfare reform legislation requires all States to use EBT by 2002. In September 1996, about 15 percent of aggregate benefits were delivered by EBT, and all States were in some stage of planning or implementing EBT systems. In a limited number of situations, recipients may receive their benefits in cash.

Benefit Redemption

Generally, households must use program benefits for foods to be prepared and consumed at home. There are, however, some exceptions to this general policy. For example, there are provisions for the homeless to redeem food stamps in authorized restaurants and for residents of some small institutional settings to participate in the program. Retailers redeem the food stamps through the banking system without the direct involvement of State governments. However, EBT increases State involvement in the redemption process because States must reconcile the benefits they issue to redemptions by retailers and to the amounts the banks pay the retailers.

State Responsibilities

A State administering the Food Stamp Program must sign a Federal/State Agreement that commits it to observe applicable laws and regulations in carrying out the program (7 CFR section 272.2(b)). Although the welfare reform legislation provided additional administrative flexibility, the Food Stamp Act remains highly prescriptive. Both the law and regulations prescribe detailed requirements for: (1) meeting program goals, such as providing timely service and rights to appeal; and, (2) ensuring program integrity, such as verifying eligibility, safeguarding coupon inventories, establishing and collecting claims for benefit overpayments, and prosecuting fraud.

To ensure that States operate in compliance with the law, program regulations, and their own Plan of Operations, each State is required to have a system for monitoring and improving its administration of the Food Stamp Program (7 CFR section 275.1(a)), particularly the accuracy of eligibility and benefit determinations. This performance monitoring system includes management reviews, reviews of quality control systems, and reporting to FCS on program performance. State agencies shall conduct a review once every year for large project areas, once every two years for medium project areas, and once every three years for small project areas, unless an alternative schedule is approved by FCS. Projects are classified as large, medium, or small based on State determinations. The State must also ensure corrective action in response to the detection of program deficiencies (7 CFR sections 275.2, 275.5, and 275.16-19).

Federal Oversight and Compliance Mechanisms

FCS oversees State operations through an organization consisting of headquarters, seven regional offices, and about 60 field offices.

FCS program oversight includes budget review and approval, reviews of financial and program reports and State management review reports, and on-site FCS reviews. Each year FCS headquarters conveys to its regions the concerns that were elevated to the national level through audits or other mechanisms. Regions combine this with their knowledge of individual States to inform the States of possible vulnerabilities to include in their internal management reviews and corrective action plans.

Although FCS uses technical assistance extensively to promote improvements in State operation of the Program, enforcement mechanisms are also available. In addition to the financial rewards and penalties related to payment accuracy, FCS has other mechanisms to recover other losses and the cost of negligence (7 CFR sections 276.2 and 276.3). For other forms of noncompliance, FCS has the authority to give notice and, if improvements do not occur, withhold administrative funds for failure to implement program requirements (7 CFR section 276.4).

Certification Quality Control System

The Food Stamp Program maintains an extensive quality control system required by law and regulation (7 CFR sections 275.10-14). The system provides State and national measures of the accuracy of eligibility and benefit amount determination (often referred to as payment accuracy), both underpayment and overpayment, and of the correctness of decisions to deny benefits.


States are required to select a statistically valid sample of cases and to review the cases for eligibility and benefit amount. Review methods in this sample are generally more intensive than those used in eligibility. States submit findings of all sampled cases, including incomplete and not-subject-to-review cases, to an automated database maintained by the Federal Government. State quality control data allow a State to be aware on an ongoing basis of its level of accuracy, and allow for the identification of trends and appropriate corrective action.

The applicable FCS regional office reviews each State's sampling plan annually and re-reviews a subsample of the State quality control reviews. The FCS re-review process provides feedback to each State on its quality control system. FCS uses the State's sample and the FCS subsample in a regression formula (described in regulation) to determine payment error rates. By law, the error rate is the combined value of overpayments and under payments to participating households. FCS headquarters also reviews its regional operations and provides technical assistance to assure consistency in the national quality control system.

Rewards and Penalties

States with error rates below 6 percent are rewarded with enhanced rates of administrative funding, up to an extra 10 percent for States that have an error rate below 5 percent (7 CFR section 277.4(b)(2)). States with error rates in excess of the national average are subject to penalties that are based on the amount of benefits issued in error. Those States pay a portion of the value of benefits in excess of the national average based on a sliding scale that increases as the State's error rate exceeds the national average (7 USC 2025(c)(1)(A) and 2025 (c)(1)(C)).

In practice, States do not pay the full amount of potential penalties. In January 1993, FCS settled a backlog of claims with States for the period 1986 through 1991 (governed by earlier penalty legislation that was replaced in 1993) at a reduced rate and allowed the States to reinvest the funds in the Program as unmatched dollars rather than pay the Federal Government directly. Claims since then cannot be pursued until the 1993 legislative changes are implemented through regulations. However, several States have settled potential claims for recent periods, using similar reinvestment methods rather than direct repayment to the Federal Government.

Corrective Action

There is a specific legislative requirement for corrective action by any State with an error rate above 6 percent (7 USC 2025 (c)(1)(B)). FCS maintains an extensive system of technical assistance for States as they develop and implement corrective action. FCS also monitors the implementation of corrective action plans.

Recent Error Rates, Enhanced Funding, and Penalties

For fiscal year 1995, the combined national error rate was 9.7 percent. The overpayment error rate was 7.3 percent; the underpayment error rate was 2.4 percent. State error rates ranged from 3.8 percent to 16.4 percent; nine States face potential liabilities totaling $73 million as the result of high error rates for Fiscal Year 1995. Error rates are updated annually.

Implications of Quality Control for the Compliance Supplement

The Food Stamp Program Quality Control system uses an intensive State review of more than 50,000 active cases across the United States to measure the accuracy of Food Stamp Program eligibility determinations and benefit amounts. An FCS re-review of more than 18,000 of those cases follows. These samples are statistically valid at the State and national level. Information from Federal program oversight indicates that this sampling system is operating adequately to provide assurances that FCS is measuring the accuracy of eligibility decisions and that these data provide a basis for corrective action to improve the accuracy of eligibility decisions. Therefore, the Quality Control System sufficiently tests individual eligibility in the Food Stamp Program.

However, in those situations where computer systems are integral to the operation of the program, e.g., automated eligibility determination, the auditor should perform necessary tests as to obtain assurance of the integrity of these systems. In those instance where multiple programs share the same systems, e.g., automated intake systems for AFDC, Food Stamps, Medicaid, etc., testing may be done as part of the work on multiple programs.


In developing the audit procedures to test compliance with the requirements for a Federal program, the auditor should first look to Part 2, Matrix of Compliance Requirements, to identify which of the 14 types of compliance requirements described in Part 3 are applicable and then look to Parts 3 and 4 for the details of the requirements.

Note: Generally, "E. Eligibility," "G. Matching," "I. Procurement," and "N. Special Tests and Provisions" only apply to State governments. However, when States have delegated to the local governments functions normally performed by the State as administering agency, e.g., eligibility determination, automated data processing (ADP) systems, and issuance of food stamps, the related compliance requirements will apply to the local government.

E. Eligibility

1. Eligibility for Individuals

The auditor is not required to test eligibility because detail testing of the individual casefiles is performed by the quality control unit and reviewed by FCS and the automated system supporting eligibility determinations and processing and tracking food stamp issuances is tested under III.N.1, ADP System for Food Stamps.

2. Eligibility for Group of Individuals or Area of Service Delivery - Not Applicable

3. Eligibility for Subrecipients - Not Applicable

G. Matching, Level of Effort, Earmarking

1. Matching

The State is required to pay 50 percent of the costs of administering the program. Exceptions to the 50 percent reimbursement rates are: (a) 100 percent grants to administer the Employment and Training Program (7 CFR section 277.4(b)(9)); and (b) an increased reimbursement rate for States with high benefit payment accuracy rates (7 CFR section 277.4(b)(2)) -- generally about eight States receive this money). The Food Stamp Program is a cost reimbursement program and private in-kind contributions are not allowable.

In order to satisfy quality control sanctions, States may negotiate a reinvestment plan whereby they agree to spend 100 percent of State funds on certain FCS-approved initiatives. The cost associated with these plans must be reasonable, necessary, and properly allocated to the Food Stamp Program. These costs may not be claimed for 50 percent Federal reimbursement (7 CFR section 275.23(e)(10)(I)(C)).

2.1 Level of Effort - Maintenance of Effort - Not Applicable

2.2 Level of Effort - Supplement Not Supplant - Not Applicable

3. Earmarking - Not Applicable

I. Procurement and Suspension and Debarment

ADP Systems Development - For competitive acquisitions of ADP equipment and services costing $5 million or more (combined Federal and State shares), the State must submit an Advanced Planning Document (APD) for the costs to be approved and allowable as charges to FCS. This threshold is for the total project cost. In addition, noncompetitive acquisitions of $1 million or more require an APD. Contracts resulting from noncompetitive procurements of more than $1 million also must be provided to FCS for review (7 CFR section 277.18).

L. Reporting

1. Financial Reporting

a. SF-269, Financial Status Report - Applicable

b SF-270, Request for Advance or Reimbursement - Applicable

c. SF-271, Outlay Report and Request for Reimbursement for Construction Program - Not Applicable

d. SF-272, Federal Cash Transaction Report - Not Applicable

2. Performance Reporting - Not Applicable

3. Special Reporting

Note: The requirement for State agencies to automate their food stamp program includes automation of reporting requirements (7 CFR section 272.10(b)(2)(vi). The testing to ensure accuracy and completeness of the following reports should be coordinated with the testing of the ADP System for Food Stamps (see III.N.1).

a. FCS-46 - Food Stamp Program Issuance Reconciliation Report (OMB No. 0584-0080). This monthly report is used to account for benefits issued during a report month for each issuance reporting point. The FCS-46 reports the reconciliation of food stamp benefits actually issued with the State's (or county's in county-run operations) Master Issuance File. The Master Issuance File contains records on all households eligible to receive benefits (such as a listing of the households and the benefits each is authorized to receive). Actual issuances may be recorded in the Record for Issuance (RFI) or alternative filing system. The RFI is created from the Master Issuance File and shows the amount of benefits the household is eligible to receive and the actual amount issued. Generally, one FCS-46 covers the entire State. However, a State may submit a separate FCS-46 for each type of issuance system (Authorization to Participate (ATP), mail issuance, EBT, or cash-out).

Key Line Items - The following line item contain critical information.

1. Line 6 - Total Issuance this month

2. Line 7 - Returns during current month

3. Line 9 - Value of authorized replacements(s) transacted

b. FCS-209 - Status of Claims Against Households (OMB No. 0584-0069). If a household receives more food stamp benefits than it is entitled to receive, the State must establish a claim against that household and demand repayment (7 CFR section 273.18 (a)). The State is required to create and maintain a system of records for monitoring these claims against households (7 CFR section 273.18 (l)). States use a variety of manual and computer systems as the source for the line items on the FCS-209. At a minimum, a system must be able to produce a detailed listing of cases that reconciles to the beginning and ending balances on the FCS-209. The State is required to remit the collected repayments to FCS as follows: 65 percent of the recovered funds from claims involving fraud or other intentional program violations; 80 percent of the recovered funds from claims involving inadvertent household errors; and 100 percent of the recovered funds from agency-error overpayments (7 CFR section 273.18 (h)(3)).

The State agency completes the FCS-209 on a quarterly basis to detail the State's activities relating to claims against households. The form is due no later than 45 days after the end of each calendar quarter and is submitted to FCS even if the State agency has not collected any payments (7 CFR section 273.18(I)(2)).

Key Line Items - The following line items contain critical information.

1. Line 3a Beginning Balance, and 13 Ending Balance - represent the beginning and ending balances, respectively, of the claims. Columns A, B, and C represent the number and amount of claims by claim type (i.e., intentional program violation, inadvertent household error, and State agency administrative error). The aggregate value of claims activity from the subunits should equal the State totals. The beginning and ending balances should represent the total of individual claims that comprise these balances.

2. Line 14 Cash, Check, and M.O. - represents total claims payments made in the form of cash, checks, or money orders.

3. Line 15 Food Stamps - represents all payments in the form of food stamps.

4. Line 16 Recoupment - represents the value of collections made through allotment reductions.

5. Line 17 Offset - represents the total value of collections made by offsetting restored benefits against outstanding claim balances.

6. Line 18b Cash Adj.(+ or -) - represents amendments or corrections to the collection summary of a previous report.

7. Line 18c Non-Cash Adj. (+ or -) - represents amendments or corrections to the collection summary of a previous report relative to the return of food stamps, recoupment, or offsetting transactions.

8. Line 19 Transfers (+ or -) - represents the claims that were contained in the collection summary of a previous report and which are being transferred from one claim category to another claim category.

9. Line 20a Cash Refunds - represents the value of cash refunds provided to households that overpaid claims.

10. Line 20b Non-Cash Refunds - represents the value of non-cash refunds provided to households that overpaid claims.

11. Lines 21 Total, and 28 Total Letter of Credit Adjustments - represent the Total Collection Summary and the Total Letter of Credit Adjustments. The aggregate value of claims collection activity from the subunits should equal the State totals.

c. FCS-250 - Food Coupon Accountability Report (OMB No. 0584-0009) . Monthly, State Agencies must submit an FCS-250 to FCS reporting monthly food stamp coupon issuance and inventory by an individual or consolidated site. The FCS-250, or equivalent information, is provided by each coupon issuer and bulk storage point that distributes food stamps. The reports are to be submitted within 45 calendar days after the last day of coupon issuance each month, and should reach the FCS by the 15th day of the second month following the last day of coupon issuance for the month (7 CFR section 274.4(b)(1)). Verification of FCS-250 information will likely require test work at individual coupon issuers or bulk storage points.

Key Line Items - The following line items contain critical information.

1. Line 14 Total Available - represents the total number of food coupons that were available for the month. (Testing this line will require verifying lines 8-13.)

2. Line 15 Ending Inventory - represents the total number of food coupons that were on hand at the end of the month.

3. Line 16 Inventory Difference - represents the monthly issuance activity for coupon issuers and an unauthorized shortage in inventory for bulk storage locations.

4. Line 19 Total Value of Coupon Books Issued - represents the total value of coupons issued during the month based on the physical inventory.

5. Line 22 Total Value of Coupons Issued Based on Documents - represents the total value of coupons issued according to records.

N. Special Tests and Provisions

1. ADP System for Food Stamps

Note: Reference III.E.1, Eligibility for Individuals, for why the testing of the ADP system for food stamps is under this special test and provision instead of under eligibility and Part 3, E.1.a (suggested audit procedures for eligibility for individuals relating to automated systems) for other guidance in this Supplement concerning testing ADP systems.

Compliance Requirement - State agencies are required to automate their food stamp program operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning the food stamp program (7 CFR section 272.10 and 277.18). This includes: (1) processing and storing all casefile information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households which have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and, (3) generating data necessary to meet Federal issuance and reconciliation reporting requirements.

Audit Objective - Determine whether the State administering agency's ADP system for food stamps is meeting the requirements to: (1) accurately and completely process and store all casefile information for eligibility determination and benefit calculation; (2) automatically cut off households at the end of their certification period unless recertified; and, (3) provide data necessary to meet Federal issuance and reconciliation reporting requirements.

Suggested Audit Procedures

a. Because of the diversity of ADP systems, both hardware and software, it is not practical for the Compliance Supplement to provide suggested audit procedures to address each system. However, the auditor should test the ADP system to ascertain if the system:

(1) Accurately and completely processes and stores all casefile information for eligibility determination and benefit calculation.

(2) Automatically cuts off households from food stamps at the end of their certification period unless the household is recertified.

(3) Provides data necessary to meet Federal issuance and reconciliation reporting requirements. Note: This testing should be coordinated with the testing of Special Reporting (see III.L.1).

2. EBT Reconciliation

Compliance Requirement - States that use Electronic Benefit Transfer (EBT) must have systems in place to reconcile all of the funds entering into, exiting from, and remaining in the system each day. This includes a reconciliation of the State's issuance files of postings to recipient accounts with the EBT contractor. States (generally through the EBT contractor that operates the EBT system) must also have systems in place to reconcile retailer credit activity as reported through the banking system to client transactions maintained by the processor and to the funds drawdown from the Federal Reserve Bank (FRB). States should maintain audit trails that document the cycle of client transactions from posting to point-of-sale transactions at retailers through settlement of retailer credits. The financial and management data that comes from the EBT processor is reconciled by the State to the FSP issuance files and settlement data to ensure that benefits are authorized by the State and that funds have been properly drawn down. States may only draw Federal funds for authorized transactions, i.e., supported by entry of a valid personal identification number (PIN) (7 CFR 274.12(j)(1)).

Audit Objective - Determine whether the State reconciles retailer activity to client transactions and to drawdown activity from the FRB.

Suggested Audit Procedures

a. Verify that the State has a system in place to reconcile total funds entering into, exiting from, and remaining in the system each day.

b. Select and test a sample of reconciliation(s) to verify that discrepancies are followed up and resolved. This is generally a contractor duty.

c. Verify that the State has a system in place to reconcile retailer credits against the information entered into the Automated Clearinghouse network and to the amount of funds drawn down by State or the State's fiscal agent (the EBT contractor).

d. Determine if the State or its contractor have recorded any non-Federal liabilities in the daily EBT reconciliation, i.e., transactions which cannot be charged to the program. If so, verify that the non-Federal liabilities were funded by non-Federal sources (i.e., the State or the contractor).

3. Issuance Document Security

Compliance Requirement - The State is required to maintain adequate security over, and documentation/records for, Authorization to Participate (ATP) cards, other documents authorizing issuance, EBT cards (7 CFR section 274.12(h)(3)), and the food stamp coupons themselves to prevent: coupon theft, embezzlement, loss, damage, destruction; unauthorized transfer, negotiation, or use of coupons; and alteration or counterfeiting of coupons and other documents authorizing issuance (7 CFR sections 274.7(b) and 274.11(c)).

Audit Objective - Determine whether the State maintains security over instruments used to authorize issuance of food stamp benefits.

Suggested Audit Procedures

a. Observe the physical security over food stamps, ATP cards, EBT cards, and/or other negotiable instruments used in the issuance process.

b. Verify that food stamp coupons, ATP cards, and EBT cards returned from the Postal Service are returned to inventory or destroyed.

4. Physical Inventory

Compliance Requirement - Each coupon issuer and bulk storage point that distributes food stamps is required to prepare a Food Coupon Accountability Report (FCS-250) to report monthly coupon issuance and inventory (7 CFR section 274.4(b)). Each State agency must assure that day-to-day operations of all coupon issuers comply with regulations by performing a triennial on-site review, including physical inventory, of each coupon issuer and bulk storage site under its direction (7 CFR section 274.1(c)).

Audit Objective - Determine whether the State agency has conducted required triennial on-site reviews, including physical inventories, at coupon issuers and bulk storage points.

Suggested Audit Procedures

Determine by inquiry or inspection of records that the State agency conducts the required triennial reviews of coupon issuers and bulk storage points to ensure physical inventories are appropriate, inventories are made as required, and differences between recorded and actual inventories are reconciled.

5. Food Coupon Inventory Levels

Compliance Requirement - State agencies must monitor the coupon inventories of coupon issuers and bulk storage points to ensure that inventories are neither excessive nor insufficient to meet the issuance needs and requirements. Inventory levels are not to exceed a "six-month supply," taking into account coupons on hand and on order (7 CFR section 274.7(a)(1)). State agencies must review the FCS-250 and other reports including shipping and transfers, returned and/or replaced mail-issuances, improperly manufactured or mutilated coupons, and reports of shortage or overage of food coupon books to ensure the accuracy of monthly inventories, compliance with required inventory levels, and accuracy and reasonableness of coupon orders.

Audit Objective - Determine whether food stamp coupon levels are neither excessive nor insufficient to meet the issuer's requirements.

Suggested Audit Procedures

Verify that the State agencies determine that inventory levels at coupon issuers and bulk storage points are neither excessive nor insufficient to meet the issuance needs and requirements, and that inventory levels do not exceed a six-month supply, taking into account coupons on hand and on order.

6. Quality Control Unit

Compliance Requirement - The State or local government must establish a quality control unit that is independent of program operations (7 CFR section 275.2(b)).

Audit Objective - Determine whether the quality control unit is organizationally independent of program operations.

Suggested Audit Procedures

Ascertain that the quality control unit is organizationally independent of program operations.

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