Notices and Case and Procedural Reviews Mission Possible Reducing the Error Rate

Where Were We in FY 2012

Where are we in FY 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 FY Where are the errors coming from

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

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, 1/3 rd are due to no notice being sent, slightly less than 1/3 rd 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 CAPER South Dakota2.54% New Hampshire7.66% Iowa8.36% Alaska8.59% MOST IMPROVED CAPER South Carolina13.59%(31.02% in FY 12) Tennessee23.51%(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. or 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 30 th day (7 CFR 273.2(h)(3);  Client caused delay, notice of pending status must be sent on the 30 th 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,  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 30 th 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