Congress’ “One Big Beautiful Bill Act,” which passed last summer, could prove to be far more damaging to the Supplemental Nutrition Assistance Program in Illinois than most people know. A SNAP “death penalty” is built into the budget reconciliation law.
Before we go further, there’s a caveat: The U.S. Department of Agriculture’s Food and Nutrition Service has not yet released definitive guidance for how the federal government intends to enforce the law.
As I’ve told you before, Illinois’ SNAP “error rate” (providing too many benefits or not enough) was 11.6% last year, according to the U.S. Department of Agriculture. The new law requires states with error rates above 10% to pay 15% of the SNAP benefit costs.
That would translate to a $705 million price tag for Illinois — which is obviously money the state cannot afford.
Analyses from several experts claim if Illinois does not lower its error rate and cannot pay the full federal penalty of potentially hundreds of millions of dollars, then the SNAP program may disappear here.
The widely held assumption was if the state couldn’t pay the error rate penalty, then SNAP spending would be lowered by the same amount. And that could still happen if the coming federal guidance allows the state to reduce eligibility.
But benefits would have to be cut by up to 17% if none of the $705 million penalty can be paid. Not good in an era of rising grocery prices.
However, according to those experts, if the state can’t pay the penalty in the 2027 federal fiscal year, which begins next October, the entire SNAP program could quite possibly be shut down in Illinois.
An analysis by David Super, the Carmack Waterhouse professor of law and economics at Georgetown University, concluded “(I)f a state does not pay its state share, USDA could find the state in violation of the Act and terminate the state’s participation on that basis.”
The only option, according to Super, would be if the state cut SNAP eligibility, which would lower the cost of the program, and therefore, the state’s cost share.
This topic came up in testimony to an Illinois House appropriations committee last month by Illinois Department of Human Services Secretary Dulce Quintero. “The state match requirements are all or nothing,” Quintero told the committee. “If we’re unable to pay all of the state share, we will receive no federal funding, putting the entire SNAP program for Illinois at risk.”
Chloe Green with the American Public Human Services Association told the U.S. House Committee on Agriculture in September: “Absent any change to the current legislation, our understanding is that if states cannot pay the funding that has been shifted to them, they will not be able to operate a SNAP program.”
Again, this could change when the Food and Nutrition Service releases guidance.
The governor’s office is confident the state can lower the state’s error rate (and therefore the penalty) in the coming months.
It’s hiring 250 people to tackle the problem. It’s also retraining workers, rolling out some new tech to alert caseworkers to potential errors and to evaluate data collected from recipients, as well as “identify and resolve Integrated Eligibility System defects.” It’s requiring more info about shelter and medical costs (big reasons for the error rates). And it’s reinstating six-month eligibility periods instead of annual reviews and doing in-person interviews. It’s also conducting a public awareness campaign.
According to the Illinois Department of Human Services, “inadvertent” recipient errors make up two-thirds of the error rates. An example: “A customer applied for SNAP and reported $570 in monthly rent paid to the landlord. During Quality Control Review, Department of Human Services discovers their rent is $500, with $70 paid to the landlord for utilities and internet.”
Another third is blamed on agency errors: “A caseworker verifies the customer’s income as $525 but accidentally enters $255 in the eligibility system.”
Despite all the hype about fraud, Department of Human Services insists it’s “less than 0.10% of errors.”
Illinois’ error rate has historically been lower than 10.6%. The state claims a big reason for the increase is “technical errors.” Quintero told the House appropriations committee last month the feds “moved the goalposts” in 2022 by including technical mistakes in the error rates. New Jersey, Quintero pointed out, saw its error rate skyrocket from “below 4% to 35%” after that federal change.
Whatever the case, a whole lot is riding on the state’s effort to lower its error rates, including possibly the very existence of SNAP here.
- JS Mill - Monday, Dec 1, 25 @ 9:22 am:
If SNAP is important to the governor’s office, and I believe it is, then maximum effort needs to be applied here. There really isn’t any excuse for not fixing this issue.
- 44 - Monday, Dec 1, 25 @ 9:45 am:
10% seems like a high threshold to begin with. Would be nice not to waste our resources on “errors”. Gotta pay for those 250 workers.
- Think again - Monday, Dec 1, 25 @ 10:13 am:
=Despite all the hype about fraud, Department of Human Services insists it’s “less than 0.10% of errors=
Good that it is not fraud, but it points to perhaps a bigger problem: fraudsters can be clever and hard to stop. All these “inadvertent” errors point to systemic management problems. Do better
- thechampaignlife - Monday, Dec 1, 25 @ 10:39 am:
Maybe we should lean into the penalty and make everyone in the state eligible. That would give everyone an 85% discount on their food. /s
- Friendly Bob Adams - Monday, Dec 1, 25 @ 10:41 am:
This is a huge administrative task for DHS, even in the best of times. Accurately tracking the changing incomes and expenses of large numbers of people is difficult. And yes they need to do better.
But they are also facing a federal administration that would love to punish Illinois. We can be sure that they will be super-critical of anything done by Illinois.
- Mason County - Monday, Dec 1, 25 @ 11:27 am:
State needs to get its act in gear and stop the abuse and waste.
At the same time this newly signed legislation should not be retroactive- but only going forward.
- clec dcn - Monday, Dec 1, 25 @ 11:29 am:
I did this work for 34 years with DHS. Glad I am out now because they will come down hard on employees and anything else they can grab. The problem is that an error can be a customer error they put something down wrong and the information did not need to be verified so taken a face value. Also, I can tell you in the review process it is all about the rules the reviews use. Changes the rules even a small wording of the question or review and it changes everything. Caseworkers are certainly pressed for time, and the system can make errors at times. I can say that this area is not so much about fraud. The fraud is at the other end in benefits exchanged in various ways with others, once they reach the person’s account. There are many ways to do this, and it can be interesting.
- Just Me 2 - Monday, Dec 1, 25 @ 11:48 am:
sorry for long post — There is a theory in public administration regarding “fast” or “slow” administration.
The benefit of fast is obviously money goes out the door quickly to those who need it immediately, and then you instill heavy punishment for abuse under the assumption people won’t risk being caught.
The benefit of slow is that you ensure money is spent wisely upfront, but it can take a long time for the funds to be disbursed, and a lot of resources are spent doing that work.
The Pritzker embraced fast during the pandemic for a lot of programs like SNAP and rental assistance, but they never really bothered with the heavy punishment aspect for abuse (presumably they just didn’t have bandwidth to worry about it which is fair — remember the unemployment insurance nightmare?), and then they never adjusted their approach. Now everyone is accustomed to immediate money without a lot of diligence.
Time for some updates. This is an opportunity for J.B. to shine actually and prove he can manage big programs.
- ArchPundit - Monday, Dec 1, 25 @ 11:52 am:
Error rates, as Rich notes in the article, are determined by both under and over payments. Everyone should read to the end as well.
“…the feds “moved the goalposts” in 2022 by including technical mistakes in the error rates. New Jersey, Quintero pointed out, saw its error rate skyrocket from “below 4% to 35%” after that federal change.”"
The average across states is 10.9 percent. There is no suggestion of massive fraud as some want to claim–the overpayments are usually because of examples that the article points out which is really more about how to classify some payments the individual makes.
The entire point of this legislation was to cut the dollars going to the program not to incentivize better practices.
- ArchPundit - Monday, Dec 1, 25 @ 12:28 pm:
=== The problem is that an error can be a customer error they put something down wrong and the information did not need to be verified so taken a face value. Also, I can tell you in the review process it is all about the rules the reviews use. Changes the rules even a small wording of the question or review and it changes everything. Caseworkers are certainly pressed for time, and the system can make errors at times. I can say that this area is not so much about fraud.
Very good point. Bureaucracy matters and in this case you are measuring very flexible standards and you might get different responses from different auditors. None of this points to significant fraud. I would love to know the inter-rater reliability on the audits.
- Give Us Barabbas - Monday, Dec 1, 25 @ 12:54 pm:
At the risk of being mocked, I will opine, this might be a use case for applying some limited A.I. technology to the administrative issues of SNAP benefits determination and the filtering of applicants. It’s still going to take some discernment by a human being for bespoke cases, but the A.I. can at least catch the low-level entry errors and such. The harder cases are those where the clients are kinda-sorta making their way along, right on the edge of eligibility, but not yet stable enough in income to wean off SNAP. Living on the edge like that, your situation changes week-to-week, and any unexpected new expense or life event like car trouble, loss of day care, job changes, health problems, making rent, can radically change your level of need. SNAP helps those people dig their way out of a hole, and get to real stability, but the administrative processes are not nimble enough to deal with that. Life is a roller coaster at the best of times and the way the programs are administered assumes and is tuned for a straight and level road. Maybe A.I tools can help. I’m not sure they will find the right vendor to make that happen in a timely fashion, though. More likely they’ll do it sloppy and crude, and make a simple filter that gets them to just below the error threshold, but not humanely.
- Demoralized - Monday, Dec 1, 25 @ 1:20 pm:
==The entire point of this legislation was to cut the dollars going to the program not to incentivize better practices.==
This. Anybody that thinks this change was anything other than to kick people off of SNAP is fooling themselves. Republicans despise programs like this and jump at any chance they can get to kick people out of them.
- JS Mill - Monday, Dec 1, 25 @ 1:40 pm:
=This.=
I don’t disagree. But we need to put forward maximum effort so that this admin doesn’t have an actual reason to cut people off. They may still make up a reason and that would be on brand. I just don’t want to help them.
- Honeybear - Monday, Dec 1, 25 @ 1:47 pm:
As a Human Services Caseworker I can assure you, we’re training and tightening up as much as we can. We know that so much is riding on this. Please please please hold us in your prayers.
- Amalia - Monday, Dec 1, 25 @ 1:59 pm:
once upon a time a non lawyer class given at (John Marshall) UIC Law was about all the programs which income eligible folks could access. the idea was to teach non income eligible what was needed to ensure eligibility. the lesson I learned was that it was hard for people to navigate the system, like getting a Masters degree in poverty program access. The Feds currently have zero interest in making things easier for people in need. How does Illinois do that? 1) of course doing a better job filtering out the ineligible so the program runs more true 2) helping the eligible to understand how to operate as they use the system. every technology & class to do this needed 3) train those who serve the eligible to process correctly 4) government workers retraining to make sure it is all sent in right and ongoing connections to recipients and the sources they pay. I think a newspaper article in detail on how SNAP works and how to ensure correct specs would educate all of us, help to increase awareness. It’s hard to need access, hard to keep access. godspeed.
- ArchPundit - Monday, Dec 1, 25 @ 2:03 pm:
===I just don’t want to help them
Exactly. Even though I’m skeptical of the feds effort, it’s better to lower the rate and be as consistent as possible–which can help if it ends up in court.
- ArchPundit - Monday, Dec 1, 25 @ 2:04 pm:
===Please please please hold us in your prayers.
Will do and thanks.
- 40,000 ft - Monday, Dec 1, 25 @ 3:49 pm:
As a moderate, it’s super annoying that I’m lumped into a steaming pile of “Republicans despise programs like this.”
Not all of the people that believe in republican principles, are heartless like this comment proposes. Geez.