Error Rates in 3SquaresVT Processing

Over the last few months there has been a great deal of media regarding Vermont’s “Agency Error Rates” in the 3SquaresVT (aka SNAP or food stamps) program.  Hunger Free Vermont has taken the lead on advocacy for the 3SquaresVT program for the last twenty years and has worked closely with the Department for Children and Families (DCF) through many administrations to ensure that all Vermonters have access to the benefits they need to feed their families. 

When DCF makes errors when processing 3SquaresVT applications it is the families who end up liable for the mistakes.  Per federal law, if a 3SquaresVT recipient is found to have been overpaid benefits (by $400 or more) then it is the responsibility of the recipient to repay the debt, not the state agency that made the mistake.  Families who apply for food assistance are often struggling to make ends meet and have low-paying or seasonal employment which makes accessing nutritious food on a daily basis difficult.  Many families wait until they have no other options before applying for 3SquaresVT, not wanting to ask for help. When DCF then makes a mistake processing the application and determines that a family is due less or more benefits than they are eligible for, it causes hardship.  The majority of errors in our state are made by overpaying families with an average annual overpayment of $979 for federal fiscal year (FFY) 2013.  When families are overpaid due to an agency mistake they don’t know they have been overpaid.  Families use the money on their EBT cards to buy food throughout the month and don’t know they had inaccurate benefits until the state catches the mistake and sends the family a notice that they must repay the overpayment debt even though the family was not at fault.  This not only causes a financial hardship for the family, but an emotional one as well.  Families are allowed to set up payment plans for the debt, but a new monthly debt, no matter how small, is difficult for families and puts them at greater risk for food insecurity when the debt competes with other household expenses like rent and heat.

In December, I testified to the House Committee on Human Services to share the stories of families who have received agency errors on their 3SquaresVT benefits.  I also conveyed the mounting costs for our state as agency errors persist. Vermont’s payment error rate has been above the maximum error rate threshold of 6% (set by the USDA) for over three years, and is being fined by the federal government. In 2012, Vermont received a federal sanction (monetary penalty) of $341,187 from the USDA due to an error rate of 8.53%. In 2013, the state received a second federal sanction of $135,606 due to an error rate of 6.96%, totaling in $476,793 in sanctions thus far. The current error rate for FFY 13 is 8.44% which means VT will be sanctioned by the USDA again in 2014.  DCF Deputy Commissioner, Richard Giddings stated at the House Committee on Human Services in December that the state estimates a fine of about $340,000 this year.  To date, the state has made $516,000 in overpayments to families due to agency errors in FFY 2011, 2012, and 2013 that Vermonters must pay back.

As DCF works to improve these error rates, Hunger Free Vermont recommends that families who receive overpayments due to agency errors during years in which Vermont is federally sanctioned be held harmless and not be required to pay back benefits they no longer can afford.  An overpayment creates financial and emotional burdens for low-income families.  Vermonters have expressed that the process can be both frightening and stressful.

Hunger Free Vermont and DCF want the same things.  We want a well-run and accessible 3SquaresVT program that Vermonters can use and trust in their time of need.  We applaud the work DCF is doing to reduce errors, improve access, and strengthen the integrity of this program.  As we work together to improve our systems we strongly recommend that Vermonters be held harmless for the debt created by agency errors.  We also recommend that Vermonters who receive overpayments be notified as to how to reduce the debt through the federal “compromised claim” process.  For more information on Hunger Free Vermont’s recommendations on this issue and information on 3SquaresVT error rates click here.