Transcript CAPER Reduction

Notices and Case and
Procedural Reviews
Mission Possible
Reducing the Error Rate
Where Were We in FY 2012
Error Breakdown by Element
25.00%
20.00%
15.00%
10.00%
5.00%
0.00%
23.20%
9.88%
6.45%
3.78%
3.09%
Where are we in FY 2013
Error Breakdown by Element
25.00%
20.00%
15.00%
10.00%
5.00%
0.00%
22.96%
10.05%
5.16%
4.42%
3.33%
Need for improvement!
25.00%
20.00%
15.00%
10.00%
5.00%
0.00%
FY 2012
FY 2013
Where are the errors coming from
U.S. Total
(State
reported
figures)
Overall
CAPER (%)
State agency
Determination
Errors (% of
CAPER)
Notice
Procedural
Errors (%
Errors (% of
of CAPER) CAPER)
Timeliness
Errors (% of
CAPER)
FY-2012
23.20
42.58
27.79
16.30
13.33
FY-2013
22.96
43.76
22.46
19.27
14.51
So, what does this mean?
(FY 2013 Data)
Cases Where Variance Primarily Due to Notice
5.16%
22.96%
How do the notice errors
breakdown?
All Notice Errors for FY 2013
No Notice Sent
28.13%
33.06%
Incorrect Information
on Notice
Incomplete Notice
6.40%
32.40%
Unclear Notice
Notable Findings in the FY 2013 Data
 Almost half (48%) of the State agency determination
errors are due to policy incorrectly applied. Second
most frequent reason is that households were denied
for failure to provide verification that was either
already received or not required.
 Of the notice errors, 1/3rd are due to no notice being
sent, slightly less than 1/3rd are due to incorrect
information on the notice, and approximately 28% are
due to an unclear notice.
Best Performers for FY 2013
BEST CAPER
South Dakota
New Hampshire
Iowa
Alaska
2.54%
7.66%
8.36%
8.59%
MOST IMPROVED CAPER
South Carolina
Tennessee
13.59% (31.02% in FY 12)
23.51% (46.28% in FY 12)
Things SNAP is Doing To help…
 We have engaged a contractor to review and analyze SNAP
online applications and notices of adverse action. Purpose
is to:
 Develop best practices;
 Develop templates that States can use;
Contractor is currently evaluating each State’s notices and
online applications. We have some results of the contractor’s
review.
We will get to these shortly.
A revised FNS-245 Form
 We are making changes to the FNS-245 to enhance
data collection. One notable change is we will now
gather information on how late a notice goes out.
This will enable us to gauge the difference between
the worker decision and the date the notice goes to
the client.
[email protected], or
http://www.regulations.gov and follow online
instructions
CAPER QC Guidance
Items of note:
 Majority of verification errors are where the verification is
already in the case file;
 If required notice is not sent, decision will be invalid;
 The reason on the notice must always be correct;
 Case record must support reason on notice;
 If more than one reason listed on notice, each reason listed
must be correct;
 Reason on notice must not simply rely on regulatory or
manual citations.
Additional CAPER Guidance
 Denial is invalid if application is denied after 30 days
and application has not been pended. Rules on
pending application:
 State agency caused delay, notice of pending status
must be sent by the 30th day (7 CFR 273.2(h)(3);
 Client caused delay, notice of pending status must be
sent on the 30th day (7 CFR 273.2(h)(2);
Notice Policy Guidance
 FNS issued a policy memo on best practices in developing
effective notices on May 29, 2014.
 Currently building on this by developing more detailed
guidance to help States improve their notices.
 Based on review of negative notices from State agencies.
 Will present guiding principles and sample notices
 Anticipated release in October.
 FNS will host webinars following publication.
Guiding Principles
Most Effective Notices
Guiding Principles
Task Completion
 Put key information up front; make it clear & direct.
 Emphasize what clients can do.
Navigation
 Use clear visual grid to help clients see individual
notice pieces and the whole.
 Group related information together & use descriptive
headings
Guiding Principles
Presentation
 Ensure easy readability of font type/size.
 Use additional graphical elements to support client
Comprehension
 Keep sentences short, simple, & active.
 Use common words, definitions, & examples.
Guiding Principles
Other Compliance
 Be compliant with policies and regulations!
Other Ideas
 Waiver to deny household after 10 days for failure to
provide verification is available and may help States
to avoid late denials.
 Consider an early cut-off on 30th day, for example 10
a.m. Workers would then be able to process a denial
for failure to submit verification. Ensure that the
notice is mailed within the FNS approved timeframe.
 Consider Electronic Notices.
Finally
 Talk to your regional office about problems you are
encountering. This begins the conversation that
ultimately involves the national office on ways to
reduce your CAPER and improve client service.
Questions?