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Rs-Attack-SNAP-in-IA.md

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SSB1105 and HF3: Erroneous Assumptions about Wages In Iowa and About the Cost to Raise a Family in Iowa. New SNAP & Medicaid 'Program Itegrity' Measures Build-In Material IT, Operational and Security Challenges

In the first week of the 2023 Iowa legislative session 38 Republican legislators introduced House File 3 targeting Supplemental Nutrition Assistance Program (SNAP).

The Iowa Dept of Human Services (HHS) describes their SNAP mission as providing:

"nutrition benefits to supplement the food budget of needy families so they can purchase healthy food and move towards self-sufficiency."

The Iowa Hunger Coalition has an exemplary and detailed review of the many ways that this proposed legislation will "result in taking food away from children," contrary to the stated HHS mission statement for SNAP. See their excellent work at:

Committee/Subcommittee discussions related to Senate Study Bill 1105 & House File 3 (and others relating to 'assistance' to Iowans) seem to be based on a collection of misunderstandings and false (maybe just too optimistic & fuzzy) assumptions about how much working Iowans currently get paid and how much it costs to raise a family in Iowa today.

Conservative American Compass documents how much time it takes an American worker to earn enough to pay for living essentials in a given year. The data underlying their recently-released 2023 report documents the sad economic situation for too many workers and their families in Iowa -- requiring more than 66 weeks of full time work for a 25 year old male at the median wage in Iowa to meet 52 weeks of family expenses -- needing to make up 14 weeks of wages. The situation is dramatically worse for Iowa females -- requiring more than 80 weeks of full time work at the median wage in Iowa for a 25 year old female to meet 52 weeks of family expenses -- needing to make up 28 weeks of wages. These large gaps account for a material portion of Iowa assistance program spending and services, including SNAP, Medicaid, and others (energy, rent, etc.). Please resist any changes that have the potential for resulting in reductions in assistance as you work through SSB1105 (and HF3).

Please ask your Senators and Representatives to consider the scale and scope of the gap between the costs of raising a family in Iowa and the real wages paid to workers in Iowa whenever evaluating resources for assistance programs of all types, especially Senate Study Bill 1105 & House File 3 (and others relating to 'assistance' to Iowans). Working Iowans use Food (and other) Assistance Because Their Wages Don't Meet Minimum Iowa Family Needs.

See: "Cost-of-Thriving Index Shows Middle-Class Life Unaffordable in America." https://americancompass.org/cost-of-thriving-index-shows-middle-class-life-unaffordable-in-america/

QUOTE: "The middle-class security once enjoyed by American families is increasingly out of reach. According to American Compass’s newly released Cost-of-Thriving Index (COTI), a basket of major annual costs for families took the typical male worker about 40 weeks to afford in 1985. In 2022, that figure had shot to 62 weeks, driven by stagnating wages and rising costs. This means that in 1985 a single full-time earner could support a family with room to save, but today, a comparable man could work all year and still come up ten weeks short."

After outlining the latest COTI report in an opinion essay today, Henry Olsen concluded that, "The economic challenge of our time is not increasing aggregate growth irrespective of who benefits. It is ensuring that most Americans who work can economically thrive in the lives they want to live. We are far from meeting that challenge."

In addition to limiting food choices (and more), this bill adds new data collection and data matching requirements for both SNAP and Medicaid applicants, as well as for current enrollees in both programs and additional identity verification measures. Legislators require the IOWA HHS to acquire and use all the data listed in the New Data Requirements section below. This will be a material and expensive program management, application development, data management, training and ongoing operations challenge -- one that seems likely to result in material errors and omissions that diminish the effectiveness of all other efforts to achieve the stated SNAP & Medicaid missions. These new requirements seem designed to result in additional suffering across populations who are -- in principle -- supposed to receive SNAP and Medicaid assistance at any given time.

Concentrating detailed and comprehensive data about Iowans into systems/services required by Iowa Law, and then expanding the number and range of personnel requiring access to that data is a sure path to enhancing the security risks that Iowans must manage. That information security risk management is not cheap and this new law will add materially to the cost of State government operations. Periodically responding to information security breaches (because they will occur) will also impose new and hard-to-predict expenses on State government and new workloads on State government personnel.

Call or write your Iowa State Representative to let them know about the negative implications of House File 3 and your feelings about it.

New Data Requirements / New Data Matching Challenges

a. Death records. On at least a monthly basis, information from the department including but not limited to death records.
b. Employment information. On at least a quarterly basis, information from the department of workforce development including but not limited to changes in employment or wages.
c. Residency information. On at least a monthly basis, information including but not limited to potential changes in residency as identified by out-of-state electronic benefit transfer transactions.
d. Incarceration information. On at least a monthly basis, information from the department of corrections.

2. State records —— households. The department shall receive and review all of the following information concerning individuals in households enrolled in the supplemental nutrition assistance program that indicates a change in circumstances that may affect eligibility:
a. Tax information. On at least a quarterly basis, information from the department of revenue including but not limited to potential changes in income, wages, or residency as identified by tax records.
b. Unemployment information. On at least a semi-monthly basis, information from the department of workforce development including but not limited to potential changes in employment, income, or assets.
(plus the following additional data requirements for applicants to and recipients of the Iowa Medicaid program:)
a. Death records. On at least a monthly basis, information from the department including but not limited to death records.
b. Employment information. On at least a quarterly basis, information from the department of workforce development including but not limited to changes in employment or wages.
c. Residency information. On at least a monthly basis, information including but not limited to potential changes in residency as identified by out-of-state electronic benefit transfer transactions.

3. Federal records —— households. The department shall cross-check information relating to individuals in households enrolled in the supplemental nutrition assistance program with federal databases including but not limited to all of the following, on at least a monthly basis:
a. Earned income information, death register information, incarceration records, supplemental security income information, beneficiary records, earnings information, and pension information maintained by the United States social security administration.
b. Income and employment information maintained in the national directory of new hires database and child support enforcement data maintained by the United States department of health and human services.
c. Payment and earnings information maintained by the United States department of housing and urban development.
d. National fleeing felon information maintained by the United States federal bureau of investigation.

(plus the following additional data requirements for applicants to and recipients of the Iowa Medicaid program:)
3. Real-time record review —— applicants. Prior to determining the eligibility of an applicant for Medicaid, the department shall access information for every member of the applicant’s household from the data sources specified in this section and shall conduct a review of nationwide public records data sources of physical asset ownership. The nationwide public records data sources may include but are not limited to records of real property and automobiles, watercraft, aircraft, luxury vehicles, and any other vehicles owned by the applicant.
4. Residency information —— applicants. Prior to determining the eligibility of an applicant for Medicaid, the department shall require proof of residency from the applicant. (Note: ...which seems to imply an already-required definition: "as identified by out-of-state electronic benefit 8 transfer transactions.")

The bill also introduces additional/new identity verification requirements (Section 2)

...prior to the department awarding public assistance benefits, an applicant shall complete a computerized identity authentication process to confirm the identity of the applicant. Identity authentication shall be accomplished through a knowledge-based questionnaire consisting of financial and personal questions.

Additional Resource