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Pennsylvania Department of Human Services
Investigation into High Balances on Supplemental Nutrition Assistance Program Accounts
General Investigation Report Summary
Approved for Public Release
            In November of 2013, the Pennsylvania Office of Inspector General (OIG) initiated an investigation concerning allegations of high balances on certain Supplemental Nutrition Assistance Program (SNAP) accounts administered through the Pennsylvania Department of Human Services (DHS), formerly known as the Department of Public Welfare.  This issue was featured in “Target 11” news report by WPXI in Pittsburgh, Pennsylvania, on November 4, 2013.  In December of 2013, OIG provided DHS with a summary of its findings and recommendations to that date.  OIG next focused the second part of its investigation on twenty (20) individuals who at the time had the highest SNAP balances.  This part of the investigation also focused on determining whether any fraud was being committed.  In August of 2014, OIG completed its investigation and provided its findings and additional recommendations to DHS.
            DHS issues monthly SNAP benefits to assist qualified low-income households and individuals with purchasing food.  SNAP is commonly referred to as the “food stamp program.”  SNAP is a Federal program administered through DHS.  Individuals who qualify for SNAP benefits are issued an Electronic Benefits Transfer (EBT) card, which allows the user to make food purchases at stores authorized by the United States Department of Agriculture, Food and Nutrition Service (FNS) to participate as authorized SNAP retailers. 
            The Federal Food Stamp Act and associated regulations and certification policy (the Act) do not require an individual or household to completely spend SNAP benefits allotments in order to maintain eligibility.  If a SNAP benefits account is not used for three months, the state is allowed to “flag” the account as dormant.  The account may then be expunged based on guidelines established by the state.  However, SNAP benefits must again be made available upon reapplication or re-contact by the individual or household.  It is not appropriate to terminate benefits simply because they have not been used.  There is no requirement that the allotment must be spent monthly, over any other period, or at all.
            OIG focused its investigation on SNAP benefit accounts with balances between $5,000 and $45,000.  OIG reviewed records related to the 20 accounts with the highest SNAP balances within that category and the associated SNAP benefits recipients.
            The investigation revealed evidence of potential fraud regarding six individuals or households.  One individual, with a SNAP balance of $19,000, was receiving benefits from other Federal and State programs.  The individual was also allowing other SNAP recipients to use the individual's address to obtain benefits.  In five other cases, OIG discovered evidence that the applicants may not have reported income sources on their SNAP benefit applications. 
            OIG determined the remaining cases with high balances were not appropriately followed by DHS caseworkers, but no fraud was immediately revealed.
Conclusion and Recommendations
            Although Federal regulations do not require households to spend their monthly allotments, nor do they consider any stored-up benefits as resources or income, OIG alerted DHS to the fact that individuals who have attested to the need of government aid because of their “limited food purchasing power” continue to receive aid when they have accumulated a large SNAP funds balance.  The procedure with regards to high SNAP balances encourages waste.
Further, through its investigation, OIG was able to conclude that of the accounts reviewed, six of the individuals or households were suspected of committing fraud and several other accounts have high SNAP balances that could result in the waste of public resources.
OIG recommended that DHS should:
1)      Seek Federal approval to place a limit on the amount of SNAP benefits that may be accumulated, and to recover any monies over the limit amount;
2)      Review accounts with high balances to determine other sources of income or resources the recipients may be using;
3)      Routinely review the circumstances of any SNAP account with a high balance;
4)      Review the six accounts of suspected fraud, calculate overpayments where resources were not reported, and report these cases to OIG’s Bureau of Fraud Prevention and Prosecution; and,
5)      Follow-up on the high-balance accounts to determine whether waste may be occurring and whether SNAP benefits are being used appropriately.
Department/Agency Response
            DHS regularly reviews accounts with high SNAP balances and reports information evidencing potential fraud to OIG’s Bureau of Fraud Prevention and Prosecution (BFPP).  Pursuant to a Memorandum of Understanding between DHS and OIG, BFPP is responsible for investigating and prosecuting public assistance benefits fraud and conducting collection activities for DHS.  This partnership helps ensure that public assistance benefits are distributed fairly and equitably, and that the integrity of the Commonwealth’s public assistance programs is maintained.
Between July 1, 2013 and June 30, 2014, BFPP effectively collected and realized a savings of an excess of $22.4 million of public funds through its investigative and prosecutorial activities.
In addition to receiving reports from DHS, BFPP also receives and investigates reports of public benefits fraud from the public.  Information regarding potential fraud can be made to OIG’s toll-free fraud tipline at 1-800-932-0582, on OIG’s website, or by mail to: Office of Inspector General, 555 Walnut Street, 7th Floor, Harrisburg, PA 17101.  OIG will accept anonymous complaints of fraud.