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household fails to designate one or designates one that is "unacceptable" to the
food stamp office. The food stamp office must notify the household of its
selection, but the proposed rule does not require the food stamp office to tell the
household that it may make its own suggestion. Thus, only those households that
know independently that they may make a suggestion of another collateral contact
will be able to participate in this process, and even those households' suggestions
can be rejected as "unacceptable" without regard to whether they are likely to
provide reliable information. For example, a food stamp office could establish a
policy that it will consider employment information acceptable only if it comes
from the employer's bookkeeper or that it will only contact a child's school (rather
than neighbors or other social service agencies) to verify children's presence in the
home. Indeed, a food stamp office could even adopt a policy of rejecting any
collateral contacts suggested by the household on the theory that such persons
might be biased in favor of the household.
Comments should urge retention of the current rules giving the household
primary control over the selection of collateral contacts and limiting food stamp
offices' authority to reject households' nominations to cases where reliable
information is unlikely to be obtained.
C
The manner in which collateral contacts are conducted. Neither current rules
nor those USDA is proposing address the manner in which an eligibility worker
conducts collateral contacts. The access guide USDA released as part of its food
stamp initiative in July 1999, however, instructs food stamp offices that they
should not inform the collateral contact that the applicant has sought food stamps.
Instead, the guide recommends that the contact be told only that the applicant has
requested services. In addition, the access guide points out that none of the
information supplied by the household should be shared with the collateral contact.
Finally, eligibility workers and investigators should avoid using the word "fraud"
since this will inevitably stigmatize the applicant or recipient household in question
and may implicitly disclose confidential information obtained from the household.
FNS, USDA, The Nutritional Safety Net: At Work for Families pp. 9-10 (July
1999). These practices are essential to complying with section 11(e)(8) of the
Food Stamp Act (7 U.S.C. § 2020(e)(8)), which limits the disclosure of
households' confidential information. Unless these limits on the way in which
collateral contacts may be conducted are included in regulations, however, they are
unlikely to be known, much less followed, by most eligibility workers. Comments
should urge that the final rules include these protections.
C
Scope of the protections on collateral contacts. As is the case with home visits,
some state agencies have disregarded the current restrictions on collateral
contacts, arguing that they are conducting "fraud prevention" investigations rather
than verification of the household's eligibility. Here again, the distinction between
verification and fraud prevention is semantic: verification is done to prevent fraud.
The violation of a household's privacy is the same whether the disclosure of
47
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"ocrText": "PPI Intern1 feb29fsregs_access.doc\nPage 47\nhousehold fails to designate one or designates one that is \"unacceptable\" to the\nfood stamp office. The food stamp office must notify the household of its\nselection, but the proposed rule does not require the food stamp office to tell the\nhousehold that it may make its own suggestion. Thus, only those households that\nknow independently that they may make a suggestion of another collateral contact\nwill be able to participate in this process, and even those households' suggestions\ncan be rejected as \"unacceptable\" without regard to whether they are likely to\nprovide reliable information. For example, a food stamp office could establish a\npolicy that it will consider employment information acceptable only if it comes\nfrom the employer's bookkeeper or that it will only contact a child's school (rather\nthan neighbors or other social service agencies) to verify children's presence in the\nhome. Indeed, a food stamp office could even adopt a policy of rejecting any\ncollateral contacts suggested by the household on the theory that such persons\nmight be biased in favor of the household.\nComments should urge retention of the current rules giving the household\nprimary control over the selection of collateral contacts and limiting food stamp\noffices' authority to reject households' nominations to cases where reliable\ninformation is unlikely to be obtained.\nC\nThe manner in which collateral contacts are conducted. Neither current rules\nnor those USDA is proposing address the manner in which an eligibility worker\nconducts collateral contacts. The access guide USDA released as part of its food\nstamp initiative in July 1999, however, instructs food stamp offices that they\nshould not inform the collateral contact that the applicant has sought food stamps.\nInstead, the guide recommends that the contact be told only that the applicant has\nrequested services. In addition, the access guide points out that none of the\ninformation supplied by the household should be shared with the collateral contact.\nFinally, eligibility workers and investigators should avoid using the word \"fraud\"\nsince this will inevitably stigmatize the applicant or recipient household in question\nand may implicitly disclose confidential information obtained from the household.\nFNS, USDA, The Nutritional Safety Net: At Work for Families pp. 9-10 (July\n1999). These practices are essential to complying with section 11(e)(8) of the\nFood Stamp Act (7 U.S.C. § 2020(e)(8)), which limits the disclosure of\nhouseholds' confidential information. Unless these limits on the way in which\ncollateral contacts may be conducted are included in regulations, however, they are\nunlikely to be known, much less followed, by most eligibility workers. Comments\nshould urge that the final rules include these protections.\nC\nScope of the protections on collateral contacts. As is the case with home visits,\nsome state agencies have disregarded the current restrictions on collateral\ncontacts, arguing that they are conducting \"fraud prevention\" investigations rather\nthan verification of the household's eligibility. Here again, the distinction between\nverification and fraud prevention is semantic: verification is done to prevent fraud.\nThe violation of a household's privacy is the same whether the disclosure of\n47"
}