Identity Authentication Pilot Projects – Conversion to State Option

Federal law requires state agencies to verify a Supplemental Nutrition Assistance Program (SNAP) applicant's identity and other critical information prior to certifying the household to participate in SNAP. In general, SNAP state agencies verify identity based on documentary evidence, such as a driver's license, obtained through the applicant or a third party. However, over the last 6 years, the Food and Nutrition Service (FNS) has conditionally permitted several state agencies to establish and conduct Identity Authentication Pilot projects. As a result of the projects' success in providing an innovative way for SNAP state agencies to provide maximum flexibility to utilize technology in streamlining program administration, FNS is now providing all state agencies the option to use Identity Authentication in verifying applicant identity.

In these projects, states gave the applicant the option to authenticate their identity using a set of multiple choice authentication questions produced by a third-party vendor based on electronically matched public records, in place of using traditional methods to authenticate identity. If the applicant responds to the set of multiple choice authentication questions correctly then the state considered their identity automatically verified. If the applicant answered incorrectly or opted out of the authentication questions, the state continued to give the applicant the opportunity to verify their identity using traditional methods and assisted the applicant in doing so. In addition, and consistent with federal law, states participating in the project continued to accept and begin processing any application that included at least the applicant’s name, address and signature, even if the application was otherwise incomplete.

These projects have proven to be an innovative way for state agencies to utilize technology to streamline program administration, and to date, have also yielded some promising results in customer service and administrative efficiencies. Just as importantly, these pilots have not identified any significant problems with the use of identity authentication questions so long as states follow certain conditions. Based on these outcomes, FNS has determined that it will no longer require states to request and receive federal approval to implement identity authentication processes as long as states follow certain basic conditions to protect applicant rights, maintain customer service and ensure compliance with federal law.

In making available the Identity Authentication Option, FNS continues its efforts to maximize state flexibility while improving customer service. States choosing this option, however, must ensure all of the following conditions are met:

• The use of an identity authentication process must be an option to applicants that they can choose to opt into or out of at any time during the application process without negative consequences.
• All applicants must be provided with clear and complete information regarding the state’s identity authentication process and how it can impact the processing of their application.
• Any application that includes at least the applicant’s name, address and signature must continue to be considered filed by the state, regardless of whether the application is otherwise incomplete or if the applicant chooses to opt in or out of Identity Authentication.
• The date an applicant submits a SNAP application with their name, address and signature continues to be the filing date for all SNAP application processing and benefit calculation purposes regardless of whether or when the applicant chooses to opt in or out of Identity Authentication.
• An applicant’s failure to pass, failure to finish, or decision to opt out of identity authentication cannot be the sole basis of a fraud referral.
• If an applicant fails in his/her attempt to use identity authentication or opts out of the identity authentication process, the state must revert to use of the traditional methods of identity verification, without penalty to the applicant, in terms of processing time or benefits. Such failure or decision to opt out must not impair any rights of an applicant to submit an application for SNAP benefits.
• States must comply with all applicable civil rights laws and regulations and ensure that identity authentication questions are accessible to individuals with Limited English Proficiency and the disabled, including those with visual impairments. States must also continue to comply with the Tri-Agency Guidance dated Feb. 18, 2011, available at:

  https://www.fns.usda.gov/sites/default/files/Tri-Agency_Guidance_Memo-021811.pdf

• Eligibility workers must receive sufficient training in the state’s identity authentication process to answer common questions from applicants and provide assistance as necessary.

If the state chooses to implement this option, identity authentication may be offered to households at the time of recertification as well as at initial application and applies to households submitting SNAP only applications and joint applications with Medicaid and/or TANF. Furthermore, while identify authentication services are generally automated and associated with online applications, they could encompass paper applications. In those cases, the eligibility worker would work with the applicant in completing the identity authentication process. All of the above conditions would apply in those cases, as well.

Any state currently awaiting response from FNS for a request to conduct an Identity Authentication Pilot project may move forward with implementation, provided its process aligns with the conditions above. States with current Identity Authentication Pilot project approvals are no longer required to submit evaluation data, and may continue implementation of their identity authentication processes, provided that they align with the conditions above.

FNS requests that states implementing the Identity Authentication Option notify their FNS regional office. Review of states’ identity authentication processes will be incorporated into future Management Evaluations to ensure that these innovations improve program administration and maintain high levels of customer service as intended, while remaining consistent with federal law and adhering to the guidance outlined in this memorandum.

FNS appreciates its strong partnership with states to improve technology and processes that enhance the customer experience while continuing to meet the needs of the households we serve as efficiently and effectively as possible.

Pursuant to the Congressional Review Act (5 USC 801 et seq.), the Office of Information and Regulatory Affairs designated this rule as not a major rule, as defined by (5 USC 804(2)). If you have questions about this memorandum, please reach out to your FNS regional office.

Lizbeth Silbermann
Director
Program Development Division
Supplemental Nutrition Assistance Program