A compromise method seems possible which could incorporate the best elements of standard and consolidated deductions. BLS costof-living and cost-of-food data are available by region, and by urban vs. rural area within region. The USDA could develop a standard deduction formula, but index it for major differences in cost-of-living levels. Similarly, bonus value of stamps would be adjusted for costof-food differences. The maximum number of schedules required could be 28, and probably far fewer, since many areas would be substantially the same. The fact that the deduction and bonus levels were determined by the Federal Government would eliminate the possible incentive to states to drive up program costs. In addition, it would have sufficient authority based on acceptance of BLS data to avoid "equal protection of the laws suits" which might be brought against state-set levels for a 100 percent program.

The subcommittee is developing legislation to provide for this

method.

B. RELATIONS WITH HEW

The large overlap of food stamp and AFDC recipients has caused many persons to suggest that the program be transferred to HEW. However, the subcommittee has concluded that such a transfer would aggravate the loss of the program's primary objective of enhancing nutrition, and would drive it to being simply an income transfer. Since poverty and malnutrition are related but not congruent, this would be a serious loss to the welfare of the nation.

Since there is such a large overlap, however, the subcommittee sees that several areas of coordination with HEW are necessary if efficient spending practices are to be achieved as follows:

1. USDA and HEW should develop a single form for eliciting information required for eligibility certification and reporting of data about participants.

2. USDA and HEW should develop a joint outreach program. The Assistant Secretary of HEW for SRS recently testified that while only 60 percent of AFDC recipients are enrolled in food stamps, HEW does no outreach in informing them of their automatic eligibility under the law.

3. USDA and HEW should develop and submit to Congress a proposal for a cooperative nutritional status monitoring system. The Health and Nutrition Examination Survey (HANES) developed by HEW (NCHS) is oriented to monitoring the nutritional status of a nationwide sample, with some differentiation of socioeconomic groups. It should be expanded to meet the objective of monitoring the distribution of nutritional status among geographic areas and more narrowly defined demographic groups. It would then provide a means for targeting the food stamps program-particularly its outreach efforts-on areas of low nutrition. It appears that this monitoring objective could be performed by establishing two additional components to the Survey:

(a) A systematic analysis of the relationship of demographic groups' nutrition levels in the nation-wide sample to the nutritional status of geographic areas with a high concentration of these social groups.

(b) A regular method of following up the nation-wide survey with small-sample surveys of nutritional status of counties whose demographic composition seems to make them "high risk" areas. This effort should be coordinated with the USDA's program for evaluating the impact of the food stamp

program.

C. OUTREACH AND TARGETING

In general, there seems to be need for improvement in three types of outreach efforts:

1. Assisting the states to mount public information campaigns to make potentially eligible persons aware of the program, its objectives, its separation from welfare and their potential eligibility.

2. Working with other programs which are likely to have high concentration of eligible persons-such as AFDC, compensatory education, community development, maternal and child healthto make participants aware of nutritional needs and of the existence of the program.

3. Developing better data about nutritional status of demographic groups and geographic areas of the country. Beyond clearly defining the target population in nutritional as well as income criteria, better data is needed as a guide to program management and evaluation. While outreach is mandated as a general effort for all areas, it would seem reasonable to focus intensive outreach efforts on specified high-risk areas. A more detailed discussion of how to obtain appropriate data is included in the recommendations about relationships with HEW.

It is clear from the testimony of both Department of Agriculture and State witnesses that the Federal Government has not taken an active role in assuring that the program is administered in such a way as to assure either an adequate degree of quality control or providing accessibility of the program to applicants. Long waits and multiple trips to certification offices have become common. The Administrator of the Food and Nutrition Service was unable to provide the subcommittee with a firm rationale for national goals of reducing certification error, with a clear set of administrative procedures designed to achieve these goals or with an organized approach to outreach. The subcommittee's recommendations in the following two areas are designed to provide a workable level of program administration so that Congress and the people can be assured that the program is being run efficiently and responsively. We have emphasized the creation of structures which will encourage innovative efforts by the States and recognize that they each face different problems.

D. SUGGESTIONS FOR QUALITY CONTROL, ADMINISTRATIVE EFFICIENCY AND PROGRAM ACCESSIBILITY

1. Pre-screening should be accomplished by extensively interviewing potential clients before applications are made. Community Action Organizations could be used for prescreening.

2. Comprehensive training program of all certification workers in conjunction with the revision of the certification regulations. Quality control workers should monitor the course. USDA should explore using temporary public service job holders as workers to meet temporary heavy caseload induced by the recession.

3. USDA should establish a realistic set of goals to be achieved in 1, 2 and 5 years. Separate tolerance levels should be set for percent eligiblity errors, percent benefit level errors and total bonus value errors. USDA should require, and submit to Congress, a plan from each state on how it intends to meet error tolerance goals, including specific administrative mechanisms, anticipated caseloads and manpower needs.

E. PROGRAM EVALUATION AND EXPERIMENTATION

The subcommittee is concerned that the food stamp program has grown very large with a minimum evaluation of its operation and benefits to clients. From 1970 to January 1, 1975, only seven evaluation studies concerning food stamps had been completed by the Food & Nutrition Service. Only two of these related to nutritional effects. As of January 1, 1975, only three more evaluations are in progress, none of them dealing with nutritional impacts. Most of the evaluations cover very small samples in one or a few counties, leading to results which are not generalizable for a nationwide program serving 17 million participants. Recent contracts to develop program policy are working from census data and minimum available data about participants. The dearth of good program data was testified to by GAO, private researchers and state administrators. The Health and Nutrition Examination Survey (HANES) is the first large-sample study which will provide data about nutritional status of participants and non-participants. However, according to the director of the survey, it is questionable to what degree the survey will be able to differentiate the impact of food stamps from other factors affecting nutrition. We have already discussed the expansion of this survey under our recommendations for relations with HEW. We further recommend that:

1. USDA prepare and submit to Congress a plan for evaluating the major objectives of the program, including nutritional intake, nutritional status, equity among income and age groups, regional equity and the effects of outreach programs. The plan should include cost and time requirements.

2. Congress enact legislation authorizing the Secretary of Agriculture to conduct experimental programs under conditions different from those possible under the nationwide regulations. USDA should submit an annual report to Congress covering: issues considered, innovations attempted, evaluation of effects and need for further study. No specific authority for research and evaluation is presently authorized or appropriated for the Food Stamp Act.

APPENDICES

APPENDIX A

FOOD STAMP ACT OF 19641

AN ACT To strengthen the agricultural economy; to help to achieve a fuller and more effective use of food abundances; to provide for improved levels of nutrition among low-income households through a cooperative Federal-State program of food assistance to be operated through normal channels of trade; and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That this Act may be cited as "The Food Stamp Act of 1964".

DECLARATION OF POLICY

SEC. 2. It is hereby declared to be the policy of Congress, in order to promote the general welfare, that the Nation's abundance of food should be utilized cooperatively by the States, the Federal Government, local governmental units, and other agencies to safeguard the health and well-being of the Nation's population and raise levels of nutrition among low-income households. The Congress hereby finds that the limited food purchasing power of low-income households contributes to hunger and malnutrition among members of such households. The Congress further finds that increased utilization of food in establishing and maintaining adequate national levels of nutrition will promote the distribution in a beneficial manner of our agricultural abundances and will strengthen our agricultural economy, as well as result in more orderly marketing and distribution of food. To alleviate such hunger and malnutrition, a food stamp program is herein authorized which will permit low-income households to purchase a nutritionally adequate diet through normal channels of trade.2 (7) U.S.C. 2011.)

DEFINITIONS

SEC. 3. As used in this Act

(a) The term "Secretary" means the Secretary of Agriculture. (b) The term "food" means any food or food product for home consumption except alcoholic beverages and tobacco and shall also include seeds and plants for use in gardens to produce food for the personal consumption of the eligible household.

(c) The term "coupon" means any coupon, stamp, or type of certificate issued pursuant to the provisions of this Act.

(d) The term "coupon allotment" means the total value of coupons to be issued to a household during each month or other time period.

1 Pub. L. 88-525, 78 Stat. 703, approved August 31, 1964, as amended.

* Section 2 was amended by Pub. L. 91-671, 84 Stat. 2018, approved January 11, 1971.

Subsection (b) was amended by Pub. L. 93-86, 87 Stat. 248, approved August 10, 1973, to make imported foods and seeds and plants eligible for purchase with food coupons.

(e) The term "household" shall mean a group of related individuals (including legally adopted children and legally assigned foster children) or non-related individuals over age 60 who are not residents of an institution or boarding house, but are living as one economic unit sharing common cooking facilities and for whom food is customarily purchased in common. The term "household" shall also mean (1) a single individual living alone who has cooking facilities and who purchases and prepares food for home consumption, (2) an elderly person who meets the requirements of section 10(h) of this Act, or (3) any narcotics addict or alcoholic who lives under the supervision of a private nonprofit organization or institution for the purpose of regular participation in a drug or alcoholic treatment and rehabilitation probram. No individual who receives supplemental security income benefits under title XVI of the Social Security Act shall be considered to be a member of a household or an elderly person for any purpose of this Act for any month if such person receives for such month, as part of his supplemental security income benefits or payments described in section 1616(a) of the Social Security Act (if any), an amount equal to the bonus value of food stamps (according to the Food Stamp Schedule effective for July 1973) in addition to the amount of assistance such individual would be entitled to receive for such month under the provisions of the plan of the State approved under title I, X, XIV, or XVI, as appropriate, in effect for December 1973, assuming such plan were in effect for such month and such individual were aged, blind, or disabled, as the case may be, under the provisions of such State plan or under Public Law 92-603, as amended." The Secretary of Health, Education, and Welfare shall issue regulations for the implementation of the foregoing sentence after consultation with the Secretary of Agriculture. Residents of federally subsidized housing for the elderly, built under either section 202 of the Housing Act of 1959 (12 U.S.C. 1701q), or section 236 of the National Housing Act (12 U.S.C. 1715z-1) shall not be considered residents of an institution or boarding house for purposes of eligibility for food stamps under this Act.8

(f) The term "retail food store" means an establishment, including a recognized department thereof, or a house-to-house trade route which sells food to households for home consumption. It shall also mean a political subdivision or a private nonprofit organization or institution that meets the requirements of sections 10(h) or 10(i) of this Act." (g) The term "wholesale food concern" means an establishment which sells food to retail food stores for resale to households.

(h) The term "State agency", with respect to any State, means the agency of State government which is designated by the Secretary for purposes of carrying out this Act in such State.10

The definition of household in subsection (e) was amended by Pub. L. 91-671, 84 Stat. 2048, approved January 11, 1971, to require that, with some exceptions, a household shall consist of related individuals and to include an elderly person.

The second sentence was amended by Pub. L. 91-671, 84 Stat. 2048, approved January 11, 1971 and was further amended by Pub. L. 93-86, 87 Stat. 246, approved August 10, 1973.

The third sentence, added by Pub. L. 93-86, 87 Stat. 246, replaced the following sentence which was added by Pub. L. 92-603, 86 Stat. 1492, approved October 30, 1972: Effective January 1, 1974, "No person who is eligible (or upon application would be eligible) to receive supplemental security income benefits under title XVI of such Act shall be considered to be a member of a household or an elderly person for purposes of this Act."

7 The fourth sentence was added by Pub. L. 93-86, 87 Stat. 246, approved August 10, 1973.

The last sentence of subsection (e) was added by Pub. L. 93-86, 87 Stat. 249, approved August 10, 1973. The last sentence of subsection (f) was added by Pub. L. 91-671, 84 Stat. 2048, approved January 11, 1971 and amended by Pub. L. 93-86, 87 Stat. 249, approved August 10, 1973.

10 Pub. L. 92-603, 86 Stat. 1491, approved October 30, 1972, substituted this definition for the definition in Pub. L. 88-525 (78 Stat. 703), approved August 31, 1964.