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A Program In Crisis

The Arkansas Supplemental Nutrition Assistance Program (SNAP), commonly referred
to as food stamps, is designed to assist households living at or near the poverty line with the
purchase of food. It currently serves more than one in seven residents of the state, making its
continued success and long-term sustainability vital. The Division of County Operations
(hereafter referred to as the agency) is charged with administering the program and has long
been hampered by high enrollment, persistent turnover and poorly written federal legislation
(due in large part to the politicized nature of SNAP). In an effort to meet ill-conceived
performance benchmarks set by the Congress, the agency promoted a culture that encouraged
fraud and deceit. This abandonment of principle would prove to be insufficient.
In a final push to meet guidelines for the timely processing of applications, the agency
implemented a series of directives at the county and state level that effectively reduced—and in
some cases eliminated—the ability of program specialists to accurately determine eligibility. As
a consequence, evidence used to determine eligibility is destroyed. Applications are
manipulated. Errors are covered up. Contacts with employers, those familiar with the
household’s living arrangements, and current/prospective recipients are fabricated,
misrepresented or omitted. Applicants known to the agency as not eligible are approved. While
others in desperate need, and meeting all program guidelines, are denied.

This preliminary report was prepared by a Program Eligibility Specialist over the course of
eighteen months of employment. During that time it has undergone two major rewrites. The
original intent of a log of best practices observed was abandoned once the magnitude of the
problem at the county level became known to the author. A full reworking designed to be
submitted to department heads was stopped midway through when the preponderance of
evidence pointed to an agency-wide malaise. A forward has been added, technical terminology
understood by those with program expertise has been replaced where possible, and a shift from
data-driven analysis to a second person narrative has been utilized in sections. All with the
intent of increasing accessibility to the general public.
It should be noted that this report was nearly committed to a third rewrite upon the author’s
discovery and confirmation of a heinous betrayal of the body public by a government sworn to
its protection. Ultimately it was determined that the matter, though grave in nature and
demanding urgent action, would have to be addressed in a different forum and approached with
great care. As its mishandling may result in widespread destabilization of the program.

A Program In Crisis
It is an all too common trait of man that he deems himself in higher regard than his
actions warrant: Righteously proclaiming universal injustice at the slightest offense to his
sensibilities; declaring nobility of purpose where his own desires lead him. The source of this
dichotomy has fueled millennia of debate. Empiricists of every age have proffered this is an
extension of self-love—we see of the world that which gives us pleasure and cloak behind a vail
of justification what would otherwise offer offense. While theologians are frequent to suggest
the source is the timeless struggle of imperfect beings called to a higher purpose. Whatever the
reason (causality without origin vs. creation), and wherever the truth may lie (quantifiability vs.
faith), this much is near universally agreed upon: We are often silent when our conscience
commands our voice to rise above the milieu and given to terrible bouts of false accusation
when we sense our self-interests in danger.
It is with this in mind that the sensible reader should gauge what has up to this point bade our
pen to remain still and what now calls it to action if ever he or she is to arrive at an impartial
determination of the facts such as they are at present. Are the conclusions herein drawn from
tainted motive? Does ill intent conspire to contort the truth? For our part we answer thusly:
Since the dawn of the Industrial Era men and women of means have argued that government
programs aimed to alleviate the suffering of the poor do little more than weaken the society they
claim to protect. When armed with the knowledge that abuses abound; when informed that
fraud and waste riddle that which they despise, it is certain such sentiments would callously
wield the cleaver where the careful application of the scalpel is called for. And it has been this
fear, that thousands of the least fortunate among us will find themselves stripped of what little
hope they have for a betterment of their condition that has, until now, acted to muzzle our
dissent and refrain from sounding the public alarm.
But when uncomfortable facts are hidden from public view to prevent agency embarrassment;
when deceit is encouraged; when the rooting out of fraud is deemed “unproductive”; when the
laws of the land are flagrantly disregarded; when lies become the basis from which matters of
the greatest public import are to be decided; when the actions of those entrusted with the
administration of the Supplemental Nutrition Assistance Program reveal the pursuit of selfinterest and not the public weal; and when those in need are turned away to improve agency
performance reports, then the question is no longer one of serving the downtrodden. For their
cause has long since been abandoned. The question is what is right and what is wrong.


A Program In Crisis
It is our solemn conviction that such a threshold has been crossed, leaving the course of
action clear. And while Arkansas SNAP serves to better the lives of hundreds of thousands of
Arkansans, this fact does not excuse its slide into mismanagement. On the contrary, it demands
immediate correction. It is this reality that necessitates our declaration that the Arkansas
Division of County Operations (as charged with the administration of SNAP) has become an
agency dogged by unsustainably high levels of attrition that rob it of critical skill sets. It is an
agency plagued by inexcusable inefficiencies, hampered by a department-wide mentality that
treats each division as its own fiefdom, obsessed with reporting an ever improving accuracy and
timeliness rate (no matter how farcical), flippant in regards to its abuse of the public trust,
indifferent to—if not complicit in—the commission of fraud on a multi-million dollar scale and
tasked with a legislatively amorphous mission that is beyond its current capabilities and
funding. It is an agency that is failing in mission, organization and execution and has resigned
itself to focusing on public appearances at the great cost of taxpayer funds and long-term
financial viability. In short, the Arkansas Supplemental Nutrition Assistance Program is a
program in crisis.


“A greater share of the nation’s food abundance”
Notable attempts to address unequal access to food staples began at the federal level in
the 1930’s, frequently under the auspices of ensuring national defense, but more likely
as a response to the Great Depression. These programs would ultimately fail for what
is now believed to be a combination of fraud, producer greed (in demanding their
goods be distributed regardless of nutritional value), and America’s entrance into the
Second World War which rapidly brought the labor force to statistical full
employment—thus ending widespread public demand for a national food distribution

A Brief History

Renewed interest began in earnest in President Johnson signs the Food Stamp Act of 1964
the early 1950’s, and by 1960 the
issue is once again being brought
up during prominent political
campaigns and national party
conventions. And while the solution
is sought at the federal level, the
impetus has changed. No longer is
the nation in the grips of double digit
unemployment. Quite the contrary,
the period between 1950 and the late
1960’s has become known as the
Golden Age of Capitalism for its rapid economic expansion. Ascertaining political
motives not directly experienced by the individual is necessarily speculative. Yet it
can be reasonably assumed that three main factors spurred Congress to act. One, the
defeat of the Axis Powers creating an increase in positive perception of the socioeconomic dynamic as it existed in America at the time, and the rise in fertility rate that
followed (commonly referred to as the “baby boom” experienced by the victorious
alliance). Two, the rapid urbanization of the Midwest. And three—and likely the most
influential—the continued transition of large swaths of the nation from agrarian-based
to post-resource-acquisition employment with a subsequent decrease in the percentage
of the population that grew its own food. These factors, or ones not dissimilar, would
culminate in the Food Stamp Act passed by the 88th Congress and subsequently
signed into law by President Lyndon Johnson on August 31, 1964 as Public Law 88525. Amendments to the act would begin to surface in less than two years time.


Modern Act Takes Shape
In 1977 Congress would pass the Food and Agriculture Act. It was the first major
overhaul of the program and would incorporate prior piecemeal changes made
between 1966 and 1976. Universal eligibility standards developed at the national
level, a work registration requirement for “able-bodied” adults, cost sharing between
federal and state governments for program administration, have now been added and/
or amended to address lessons learned along the way. The results of these efforts
were profound. By 1979 more than 17,000,000 Americans were receiving food
stamps—some 8% of the total population. This rapid expansion would come at a
price. Between 1969 and 1979 total program cost would increase by more than
1,000% when adjusted for inflation.

A Brief History

Source: Data obtained from US Department of Agriculture and Bureau of Labor Statistics

Calls of “welfare queens” living off the government dole, and counter accusations of
a wealthy elite oblivious to the plight of the poor would help define the political
lexicon of the late twentieth century. Periods of expanded eligibility would often be
met by a wave election at the federal level that would then seek to restrict access.
Such a wave took place in 1996. The 104th Congress that followed passed the
Personal Responsibility & Work Opportunity Reconciliation Act. It is notable (or
infamous, depending upon the point of view) for two major departures from prior food
stamp related legislation. First, it did not dispute that millions of people in America
were living at or below the poverty line. Instead, it effectively declared that a large
segment of them were no longer eligible to participate.


The End Of An Era
Second, it signaled the end of lockstep rural support for the act that had largely
been taken for granted. For many metropolis-based economists it seemed as if rural
Americans had tightened their belts and then inexplicably “voted against their own
best interests”.

A Brief History

The twenty years that followed would confirm the end of an era. The New Deal
coalition was no more. Franklin D. Roosevelt’s fireside chats, given in large part to
bypass unfavorable reporting in newsprint, and made possible by the radio, had been
replaced by the television. As the costs of broadcasting declined, viewpoints not
closely aligned with those of population centers began to spring up. The arrival of the
internet would accelerate the trend. The recording studio was replaced by the desktop
computer and the television camera had given way to the comparatively inexpensive
smartphone. Now, a lone individual could upload a video to the world wide web and
reach an otherwise ignored audience numbering in the tens of millions. For those who
felt marginalized it was the realization of freedom of expression and confirmation that
their opinions were shared by others. For urban-centered-majority-rule politics that
had grown accustomed to driving political discourse it was the arrival of “fake news”.
The food stamp program would feel the effects of this paradigm shift. The result has
been a patchwork of short term funding bills stitched together by an increasingly
fractious alliance. Agricultural subsidies that had been a staple of successful bills
since the 1970’s drew increasing criticism from America’s major cities and the
educational institutions that called them home. By their way of thinking crop
insurance, and marketing assistance loans for peanuts and upland cotton were wastes
of taxpayer money. The free market should determine which crops are planted, not the
government. For those in rural communities such sentiment is routinely met with
condemnation. The Agricultural Act of 2014 authorized more than $900 billion in
spending. Some seventy cents of every dollar was earmarked for SNAP while less
than a dime went to farmers. The truth, they counter, is that big cities created an
economic model that discounts the value of beef, dairy products, poultry, pork, wheat,
rice, cotton, fruits, vegetables and the raw materials for industry, construction and
pharmaceuticals not because they are intrinsically less valuable, but because they
don’t have them. Their models are the product of self-interest, not scientific analysis.
And for the monied interests who disagree they offer a simple experiment. You
withhold your “exotic financial products” and we’ll stop shipments of food. The true
foundation of economic power will soon reveal itself.


The End Of An Era
Today, the nation finds itself increasingly split into two camps. On one end, an
increasingly frustrated urban core that has lost the ability to effectively communicate
with rural America. The result has been fulsome praise for SNAP in their publications
that belies the reality of a program beset with severe legacy flaws that threatens its
long-term stability for fear that the mere mention of the word “reform” would usher
in deep cuts as it did in ‘97. On the other end, a growing and rapidly uniting front
that possesses a virtual monopoly on foodstuffs and controls more than 90% of the
highways/railways they travel on increasingly convinced that population centers are
plotting against them. For the more than thirty million people who rely on SNAP to
feed themselves and their families the stakes could not be higher.

A Brief History


Introduction to Eligibility
When placed into a three ring binder the laws and regulations that govern the
administration of SNAP are more than three inches thick and read like an encyclopedia. A
detailed explanation of those guidelines is therefore beyond the scope of this report. Instead, we
can focus on a general introduction to what qualifies a household to participate in SNAP and
how the state applies those guidelines so that we may better understand why certain rules were
broken and how best to go about fixing the underlying problem(s). The laws and regulations
can be thought to come from three sources. One, the Congress which set program guideposts
and established carveouts for certain groups through the years (members of the Hmong tribe
that assisted U.S. Forces during the Vietnam War, as an example). Two, the Secretary of the
United States Department of Agriculture as empowered by Congress to flesh out a functional
national program and three, powers reserved to the several states that allow them a limited
ability to sculpt the program to conform to local sensibilities and economic conditions. From
these three sources come the eligibility requirements that can, themselves, be broken down in to
three broad categories. We will call the first such category household composition.
When a person wishes to apply for SNAP in the state of Arkansas they are required to fill out a
form labeled Division of County Operations Form 215 or DCO 215 for short. On this form they
are instructed to list all of the people in their household who traditionally buy and prepare their
meals together, regardless of citizenship or immigration status. This is a federally mandated
requirement and is the household composition we have referred to. The state then reviews this
list during the application process to determine if any of the members listed are eligible to
participate based upon their citizenship or immigration status. If none are eligible the
application is denied. If at least one is eligible, or deemed likely eligible pending verification,
the consideration of the application continues to the second category, resources.
Congress has mandated a resource cap that cannot be exceeded by an otherwise eligible
household. For most households this is currently $2,250. For households containing an aged (60
or older) or disabled individual the cap is $3,500. This resource cap includes cash or those
assets that can be easily converted to cash. In theory it is intended to disqualify a household that
is deemed to have sufficient resources to purchase food without assistance and is often touted
by those who support the program as proof of strict eligibility guidelines that prevent waste. In
practice it is a provision that has: One, been watered down by a growing list of broadly defined
exemptions; and two, places a premium on the truthfulness of the applicant. A person with
$4,000 in gold coins in their home safe is ineligible. While a person with $4,000 in gold coins
in their home safe who does not disclose this asset to the state will almost certainly be approved
if otherwise eligible.


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