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    "ocrText": "PPI Intern1 - feb29fsregs_access.wpd\nPage 55\ncircumstances. As long as QC holds states strictly accountable for facts they did not know when\nthey acted, states will want to maintain intense pressure on households to provide more\ninformation.\nComments should urge that the food stamp regulations be amended to provide that a\nvariance between the amount of food stamps a household actually received and the amount it\nwould have received if the food stamp office had had perfect information should not be counted\nin determining a state's error rate where the food stamp office relied upon certain types of\nhigh-quality verification specified by USDA. Under this proposal, USDA would issue a list\n(perhaps as part of its QC manual) of types of highly reliable forms of verification, such as\ncomputer-generated wage stubs or utility bills. If a food stamp office verified a household's\nstatements using one of these methods and the information later turned out to be in error, any\nvariance in benefits would not count as an error because the food stamp office had relied on\ndocumentation that USDA had determined is ordinarily highly reliable. This proposal would be\nanalogous to employment laws that forbid companies from hiring non-citizens that lack work\nauthorization, but immunize an employer from liability if it has verified an employee's identity and\nwork authorization by examining any of the types of documents on an officially approved list.\nThis would not excuse states from verifying information supplied by households. It also\nwould not immunize states from liability for errors resulting from households' failure to report\nchanges. And it would not excuse states for errors they make misreading or misprocessing the\nverification they do have. This policy would, however, allow a state that obtains computerized\npay stubs covering the most recent month to forego any further demands for verification from the\nhousehold. Under current rules, if those pay stubs were defective and failed to capture all of the\nwages the recipient had in fact received from the employer, the state would be liable for an error.\nThis risk of liability has driven some food stamp offices to press households to provide statements\nfrom their employers (an additional burden for the food stamp office, the worker, and the\nemployer alike).\nAs other highly reliable means of verification were identified, USDA could update its list\nof the types of verification that will be treated as conclusively valid. For example, new technology\nis allowing some states' computerized wage reporting systems to provide access to a worker's\nearnings record with only a relatively short delay. USDA might determine that if a computerized\nwage data system could meet certain specifications, states could check households' statements\nwith those systems and conclusively rely upon the household's statements as supported by the\nwage data system.\nThis new QC exemption could not be applied to all or even most forms of verification.\nNonetheless, recognizing that a food stamp office has fulfilled its obligations and need not -\nindeed, should not - go further once it has obtained a highly reliable form of documentation could\nease the verification pressures on states and households alike. This approach should be especially\nhelpful in reducing verification demands placed on working poor households. Including this in the\nfinal rules likely would please states at least as much as - and, most likely, considerably more than\n- some of the more troubling procedural changes proposed in these rules. Although USDA's\nproposed regulations do not explicitly address QC issues, they do embrace a complete revision of"
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