Preliminary Report on the Feasibility of Computer Matching in the National
School Lunch Program
EXECUTIVE
SUMMARY
The Child Nutrition and WIC Reauthorization Act of 2004
(PL 108-265) directed the Secretary of Agriculture to conduct a study of
the feasibility of using computer technology (including data mining) to
reduce overcertification, waste, fraud and abuse in the National School
Lunch Program (NSLP). Prior to enactment of this legislation, USDA's Food
and Nutrition Service (FNS) contracted with Abt Associates, Inc. to study
the feasibility of expanding computer matching for certification of school
meal benefits. This study draws on experts in data matching and privacy
issues, and will survey State Child Nutrition Directors, State Education
officials, and State Medicaid officials to learn about current computer
matching capabilities and issues involved in expanding matching. A final
report will be available in April 2006.
To meet the requirements of the Act, FNS asked Abt Associates to
prepare a preliminary report on the feasibility of computer matching in
the NSLP. The report summarizes the results of an expert panel on computer
matching, and exploratory interviews with three states. The full
preliminary report is available at www.fns.usda.gov/oane.
This summary provides background information and preliminary findings on
the feasibility of computer matching.
Certification and Verification of Eligibility
for the National School Lunch Program
FNS provides reimbursement for meals served under the NSLP and School
Breakfast Program (SBP) to millions of children each school day. Children
are eligible for free meals if household income is at or below 130 percent
of the poverty level, and eligible for reduced price meals if household
income is between 130 and 185 percent of the poverty level. Children are
categorically eligible for free meals if enrolled in the Food Stamp
Program (FSP), the Food Distribution Program on Indian Reservations (FDPIR),
or some Temporary Assistance to Needy Families (TANF) programs.
Currently, children are certified for NSLP through application or
direct certification. School officials may directly certify a child's
categorical eligibility based on data provided by the FSP, FDPIR, or TANF
programs. In 2001-02, 61 percent of public school districts used direct
certification. In these districts, about 25 percent of students receiving
free meals were directly certified, and another 18 percent of students
receiving free meals were categorically eligible-meaning that their
applications indicated participation in FS, TANF or FDPIR. (Gleason et
al., 2003).
Children who are not directly certified may apply for free or
reduced-price meals. The NSLP relies on self-declaration of eligibility
and requires no documentation of income or program participation with
applications. Self-declaration minimizes the cost of application
processing and the barriers to the program. A USDA pilot study conducted
in SY2001-02 found that requirements for up-front documentation of income
were associated with reduced rates of certification among eligible
students (Burghardt et al., 2004). Current regulations require
verification of up to three percent of applications; in SY2000-01, 34
percent of households selected for verification lost benefits because they
failed to respond to requests for documentation of eligibility.
Current Use and Benefits of Direct
Certification and Computer Matching
NSLP agencies are authorized to use computer matching for three
purposes: to directly certify categorically eligible children enrolled in
FSP, TANF, or FDPIR; to directly verify income or categorical eligibility
reported on applications using information from means-tested programs such
as FSP, TANF, and Medicaid; and to use wage and benefit information
maintained by government agencies to verify income information reported on
applications. Direct verification of income eligibility was recently
authorized by the Child Nutrition and WIC Reauthorization Act of 2004 and
has not yet been implemented. Computer matching with wage and benefit data
for income verification is authorized by NSLP regulations, but USDA is not
aware of any State or local agencies using this method of verification.
Computer matching is currently used by numerous State Child Nutrition
agencies and School Food Authorities (SFAs) to directly certify children
for free meals. An electronic file containing information for children in
food stamp or TANF households is compared to a file of children enrolled
in school. Children who are matched through this comparison can be
directly certified for free meals without their households taking any
action. While there are no current data on the exact percentage of
children certified by computer matching, our study will survey State
agencies to determine the prevalence of computer matching.
Where computer matching is not used, other methods of direct
certification are the letter method and manual matching. Many States mail
letters to food stamp and TANF households, and the letters are taken to
schools in lieu of NSLP applications. Some SFAs manually match student
records with a list of children in food stamp or TANF households to
directly certify children.
Benefits of Computer Matching for Direct Certification
Direct certification reduces the burden of application for many
households and SFAs, and has been found to increase certification among
eligible children (Jackson, et al., 2000). With direct certification, the
NSLP uses the certification and verification processes conducted by other
means-tested programs. Thus, directly certified children do not have to be
verified by NSLP, and SFAs do not have the problem of household
nonresponse to verification requests.
Computer matching may be less burdensome and quicker than other methods
of direct certification. With the letter method, States or SFAs send
letters that can be used in lieu of applications, but this method works
only if households receive the letters and take them to the school. With
computer matching, SFAs may directly certify children prior to the start
of the school year and send a notification letter to households. There is
very little paperwork for SFAs, and no effort required from households
(assuming passive consent). State-level computer matching has advantages
over district-level matching, because the process is centralized and
implemented in the same way for all school districts in the State, and
each district does not have to obtain computer matching software or
expertise. Computer matching can be performed several times during the
year to certify students who move to a new school district during the
school year.
One study found that direct certification is highly accurate, insofar
as certified children are indeed eligible for benefits (Gleason et al.,
2003). But no studies have examined the match rate the percentage of
school-age children enrolled in food stamps or TANF who are correctly
matched and thereby directly certified. Officials interviewed for this
study reported that computer matches based on Social Security Number (SSN)
yield high match rates, but matches based on name, date of birth, and
other identifiers are not expected to identify all eligible children. To
compensate for less than perfect match rates, a State may send letters to
food stamp households with school-age children who are not matched to
student enrollment files.
Options for Expanding Computer Matching
Computer matching could be expanded by increasing its use with Food
Stamp and TANF programs, by increasing the number of means-tested programs
that can be used to direct certify children, by implementing direct
verification, and by matching to wage and benefit information to verify
income eligibility for children not enrolled in means-tested programs. Key
ingredients for computer matching, and possibilities for expansion, are
described below.
Key Ingredients for Computer Matching
A computer matching system for direct certification or direct
verification requires three key ingredients:
-
Electronic database of student records,
-
Electronic database of school-age children enrolled in a
means-tested program, and
-
Common identifiers (such as name and date of birth) in the student
enrollment database and the database of the means-tested program.
Electronic Database of Student Records: A potentially large
barrier to State-level computer matching is the need for an electronic
student enrollment database available to the State agency. Many State
Education agencies have a Statewide Student Information System (SSIS), or
are developing an SSIS that could be used for NSLP computer matching.
Other States have developed systems to collect student enrollment data
from school districts specifically for direct certification. Student
enrollment data can be collected via e-mail, physical exchange of disks,
or Internet file transfer. E-mail and the physical exchange of disks
require labor time and may entail mailing costs. In Arizona, SFAs use an
Internet file transfer system to upload student records to the computer
matching system and download match results.
Common Identifiers: Computer matching requires common
identifiers in the files being matched, such as Social Security Number (SSN),
or name and date of birth. SSNs are unique identifiers and yield high
match rates, but computer matching based on SSN is limited by the
availability of SSNs in student enrollment records. According to the
Family Educational Records Privacy Act (FERPA), schools can request a
child's SSNs, but cannot require it. Furthermore, State agencies can
request SSNs from school districts, but school districts are free to
withhold the SSN for confidentiality reasons. There can be significant
variation in the availability of student SSNs across districts within a
State. Thus, States need to use a combination of identifiers to maximize
the proportion of eligible children who are directly certified through
computer matching.
Electronic Database of Children in Other Means-Tested Programs:
NSLP computer matching is currently limited to direct certification of
children enrolled in food stamps and some, but not all, State TANF
programs. These programs maintain eligibility data in electronic form at
the State level, and collect Social Security Numbers (SSNs) and other key
identifiers that can be used for computer matching. SSN disclosure is a
condition of eligibility for these programs.
Expansion of NSLP computer matching to other means-tested programs
would be most beneficial if focused on programs enrolling a large number
of school-age children who are not already enrolled in food stamps or TANF.
Taking into account this and other criteria, the best candidate is
Medicaid, and the State Children's Health Insurance Program (SCHIP) is
also worthy of consideration.
Expansion of Computer Matching to Medicaid and SCHIP
Four key characteristics of Medicaid make it suitable for NSLP computer
matching:
-
The program is administered at the State level;
-
SSN disclosure is a condition of eligibility;
-
The eligibility information system is integrated with the databases
of Food Stamp and TANF recipients in 35 States; and
-
The income eligibility level for children is consistent with free
school meal eligibility in 33 States.
Medicaid income eligibility for children is consistent with reduced
price meal eligibility in 13 States, and is above the school meals
eligibility level in 5 States. In these States, income information would
need to be obtained from the Medicaid program to determine NSLP
eligibility category (free or reduced price). A possible limitation in
some States is that the statewide eligibility information system may not
include income data for all categories of Medicaid enrollees.
There is no readily available information about the suitability of
SCHIP information systems for NSLP computer matching. Interviews with two
States indicated that SCHIP and Medicaid eligibility information systems
are not necessarily integrated, and income information collected on SCHIP
applications may not be available in electronic form. In addition, SCHIP
enrollees are not required to disclose their SSN. SCHIP income eligibility
is between 130 and 185 percent of poverty in 10 States, and above 185
percent of poverty in 41 States. Therefore, SCHIP eligibility alone cannot
be used to directly certify or verify children for free meals in any
State, but SCHIP income information could be widely used for certification
or verification.
The primary limitation of NSLP computer matching with Medicaid and
SCHIP is uncertainty about the implications of the Health Insurance
Portability and Accountability Act (HIPAA). HIPAA limits the disclosure of
medical records. All Medicaid records are considered protected under HIPAA
and SSNs are considered part of Protected Health Information (PHI). The
implication of HIPAA is that use of Medicaid data for direct certification
or direct verification may not be possible without legislation or
regulations authorizing Medicaid agencies to release these data.
For direct certification or verification of categorical eligibility
under current rules, the only information needed from the matching process
is that a match is found with FSP or TANF records. As discussed above, if
computer matching is expanded to additional means-tested programs such as
Medicaid and SCHIP, then in some States, and for some programs,
certification and verification of NSLP eligibility will require income
information collected by the means-tested program. Medicaid and SCHIP
programs with income eligibility limits above the NSLP limit for free
meals (130 percent of poverty) do not need to disclose household income to
NLSP, but would need to provide an indicator of household income within
the NSLP ranges for free, reduced price, and paid meals.
NSLP agencies were recently authorized to use data from Medicaid and
other means-tested programs for direct verification of NSLP eligibility.
However, because verification operates on a much smaller scale than
certification, States may need authorization to conduct direct
certification with Medicaid data before they have sufficient incentive to
conduct direct verification using Medicaid.
Feasibility of Computer Matching to Verify Wage and Benefit
Information
Computer matching to wage and benefit information is an option for
verifying NSLP income applications from households that are not
participants in means-tested programs. This type of computer matching is
the least feasible option for the NSLP.
The FSP, TANF, and Medicaid programs verify income eligibility through
the Income Eligibility and Verification System (IEVS) and other computer
matches. The IEVS data sources include benefits data maintained by the
Social Security Administration, quarterly wage data and unemployment
insurance benefits maintained by State Wage Information Collection
Agencies (SWICAs), and unearned income and bank account data from the
Internal Revenue Service.
The IEVS and other income data sources have several important
requirements that limit the feasibility of this type of computer matching
for the NSLP. First, specific legal authority may be needed to use IEVS
and other data sources, and data sharing agreements must be negotiated.
NSLP income verification is conducted by individual SFAs, but it is not
feasible for every SFA to establish data sharing agreements and maintain
ongoing communications with agencies that provide income verification.
A second limitation is that all IEVS computer matches are based on
Social Security Number (SSN), and income data are reported for
individuals, not households. All relevant household members must be
identified for verification of household income, and their SSNs must be
obtained. Currently, the only SSN obtained on NSLP applications is that of
the adult signing the application. The current NSLP verification process
obtains SSNs of all adult household members, but the process entails
burden for the SFA and the non-response rates are high.
Finally, follow-up is an essential part of the income verification
process, because sources of income data may reflect reporting errors,
particularly with data provided by employers or individuals. Most results
of computer matching with income data are not sufficiently accurate and
current to be used on their own to deny benefits. Income discrepancies
require follow-up with the applicant, and the follow-up process would be
very similar to the existing NSLP income verification process. Thus,
computer matching to verify income information will not reduce the level
of SFA effort for verification.
Preliminary Findings and Future Research
Computer matching for NSLP direct certification and verification is
feasible, as indicated by the computer matching systems that are currently
in place. Our research to date indicates that it may be possible to expand
data matching to more Food Stamp or TANF recipients, as well as to
children enrolled in Medicaid/SCHIP; but there are likely to be technical,
legal and resource barriers to overcome.
Preliminary results indicate that a statewide computer matching system
is more efficient and effective than district-level matching. If so, more
widespread use of this approach could increase direct certification among
children receiving food stamps and TANF. Preliminary results also indicate
that the Medicaid program would be well-suited for identifying NSLP-eligible
children through computer matching in many states. However, a full
assessment of the feasibility of these approaches requires more
information about current computer matching practices and capabilities and
about the variations in available data on school-age children and their
receipt of Medicaid and other programs among states.
Our study will determine the prevalence of three key ingredients needed
for widespread computer matching: an electronic database of student
records, electronic databases containing information on school-age
children's participation in other means-tested programs, and common
identifiers in these databases. It will also identify promising practices
with regard to matching and identify legal and technical barriers that may
prevent more matching.
Last modified: 12/04/2008
|