Consolidate Non-Commodity Nutrition Assistance Programs into HHS, Rename HHS the Department of Health and Public Welfare, and Establish the Council on Public Assistance Departments of Agriculture and Health and Human Services
Summary of Proposal: This proposal moves the non-commodity nutrition assistance programs currently in the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) into the Department of Health and Human Services’ (HHS) Administration for Children and Families (ACF), and renames HHS the Department of Health and Public Welfare (DHPW). The proposal also establishes a Council on Public Assistance, comprised of all Federal agencies that administer public benefits, with statutory authority to set cross-program policies including uniform work requirements.
The Challenge
USDA and HHS are currently responsible for administering the Federal Government’s major public assistance programs, not including housing programs. However, State and local governments, the entities delivering these services to participants, often administer many of these programs under a single Agency. For example, when a person goes to apply for services through the Temporary Assistance for Needy Families (TANF) program and for nutrition assistance through the Supplemental Nutrition Assistance Program (SNAP), they often go to a single State agency office to do so. Unfortunately, that single State agency currently must follow two separate sets of reporting, regulatory, and other administrative requirements – one set imposed by HHS for TANF, and another by USDA for SNAP. This creates unnecessary administrative burden and potential duplication, using up resources that could be better used helping families move towards self-sufficiency. In addition, because these programs are currently administered by different Federal departments, they are often not well coordinated.
This proposal moves a number of nutrition assistance programs currently housed in USDA – most notably SNAP and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) – to HHS and, acknowledging the addition of these programs to the Agency, renames HHS the Department of Health and Public Welfare (DHPW). To provide for even more coordination across all Federal public assistance programs, this proposal also establishes a permanent Council on Public Assistance, housed in DHPW and composed of all agencies that administer public benefit programs, including USDA, the Center for Medicare and Medicaid Services, the Department of Housing and Urban Development (HUD), and others. This Council would have statutory authority to set certain cross-program policies, including on uniform work requirements.
The Opportunity
This proposal will better align the administration of these public assistance programs at the Federal level with how they are often administered at the State and local levels. This will reduce administrative burdens and duplications of effort that currently exist for State and local governments. It will also ensure that policies are applied consistently across all programs, potentially reducing confusing, complex, and sometimes contradictory requirements across programs that can make it difficult for both States and participants to follow the rules.
What We’re Proposing and Why It’s the Right Thing to Do
Move Non-Commodity Nutrition Assistance Programs and Rename HHS CACFP provides reimbursement for meals served by participating child and adult care providers, rather than a direct benefit to the household. However, for the same coordination reasons as the near-cash programs, we recommend moving it to HHS to align with the Head Start and Child Care programs operated by ACF. Other programs include the Summer Food Service Program, the Food Distribution Program on Indian Reservations, the Special Milk Program, Assistance to Nuclear Affected Islands, and Disaster Assistance (not including Disaster SNAP). FNS currently administers 15 nutrition assistance programs, which can be separated into two major categories: “near-cash” benefit programs and commodity-based programs. Near-cash programs provide money to low-income households, including through an electronic benefit transfer card or voucher, to allow participants to buy food through retail outlets. Commodity-based programs deliver actual food to eligible entities, who in turn provide a meal or food benefit to participants. Near-cash benefit programs do not need to leverage USDA’s expertise in food procurement or delivery, nor do they primarily fit with USDA’s core mission of supporting American farmers and agriculture. Rather, these programs are designed to support low-income Americans, a mission area better situated in DPHW. Specifically, the Administration proposes to move SNAP, WIC, the Child and Adult Care Food Program (CACFP)1, and the Farmers’ Market Nutrition Programs into ACF. USDA, whether with a smaller FNS or a different division, would continue to administer the commodity-based programs, including the National School Lunch and School Breakfast Programs, The Emergency Food Assistance Program, the Commodity SupplementalFood Program, and others.
Moving the near-cash benefit programs into ACF would allow for better and easier coordination across programs that serve similar populations, ensuring consistent policies and a single point of administration for the major public assistance programs. This single point of administration would lead to reduced duplication in State reporting requirements and other administrative burdens, and a more streamlined process for issuing guidance, writing regulations, and approving waivers. Having all the major public assistance programs under one agency would also create more synergies within the Agency, allowing ACF to develop a more holistic understanding of how programs interact with each other, which itself could lead to better policy analysis and outcomes. For example, as States have provided more TANF benefits through non-cash assistance, SNAP enrollment has grown due to individuals becoming “categorically” eligible for SNAP. This has resulted in some unintended consequences, such as families becoming eligible for SNAP through the receipt of a TANF pamphlet or other non-cash assistance. The Fiscal Year (FY) 2019 Budget proposed to tighten these loopholes, but combining these public assistance programs under one agency would help to increase awareness of these interactions and improve policy development that prevents such unintended consequences. With the move of these non-commodity programs, the welfare portfolio at HHS increases significantly. The proposal renames HHS the Department of Health and Public Welfare to more accurately reflect the mission of the Agency and raise the profile of non-health related programs within the Agency.
Reform Plan and Reorganization Recommendations
Establish Council on Public Assistance As part of this initiative, the Administration also proposes to create a permanent Council on Public Assistance within the DHPW that would accomplish the goal of ensuring a unified, coordinated focus on cross-cutting welfare and workforce issues at the State and local levels, and to drive Federal-level program reforms.
The Council would be given statutory authorities and responsibilities, including but not limited to:
- Approving service plans and waivers requested by States under Welfare-to-Work projects, assuming enactment of the FY 2019 Budget proposal;
- Designing uniform work requirements to be implemented across all welfare programs;
- “Tie-breaker” authority to resolve disputes when multiple agencies disagree on a particular policy;
- Designing cross-program standards for program applications, data verification, and program integrity;
- Facilitating information sharing and collection as well as regulatory and other policy guidance coordination across affected agencies; and
- Recommending programmatic and operational changes to eliminate barriers that it identifies at the Federal, State, and local levels to getting welfare participants to work.
The Council would be housed at DHPW and composed of agency heads or their representatives from USDA (including from the smaller, reformed FNS focused only on commodity programs), HUD, the proposed Department of Education and the Workforce, the Office of Management and Budget, and others, as appropriate, and chaired by DPHW senior leadership.
Creating this Council would further break down silos between agencies operating public assistance programs by establishing an interagency coordination and support structure to carry out the welfare reform agenda of the Administration with high-level visibility. Because this Council would become the Administration’s welfare policy-making apparatus, this proposal would consolidate policymaking functions across the different agencies, likely reducing administrative resources and duplication in current policymaking functions, and would ensure that Federal public assistance programs are well aligned and focused on promoting opportunity and economic mobility.