The Department of Government Efficiency team reportedly wants to use information from the IRS to investigate potential fraud in the Supplemental Nutrition Assistance Program (SNAP, formerly food stamps). Disclosure restrictions may prevent IRS from sharing the data. But prior analysis at the Urban Institute focused on improving tax administration shows that even if IRS did share the data, differences between how taxes and SNAP are administered likely make the data of limited value.
Income Standards Don’t Align
SNAP benefits are based on monthly family income, which SNAP can already verify using an electronic tool called The Work Number. This system contains information from millions of employment records and is updated each time a contributing employer processes payroll. Typically, families recertify for SNAP benefits every six to 12 months—periods that in most circumstances will not align with calendar years in tax data.
SNAP considers monthly income data because it is meant to fill in gaps when families don’t have enough resources to make ends meet. This is important because 40% of low-income, working-age adults report incomes that spike or dip at least 25% above or below average annual income in at least six months of the year. (The average duration of SNAP benefits is about eight months in non-pandemic years.)
Tax Data Have Only Limited Information On Assets
SNAP also considers assets in determining benefit eligibility. Tax data contain information on income from some, but not all, assets. And tax data contain no information on non-income-earning assets. For example, SNAP can consider the value of vehicles a family owns when determining benefits.
‘Units’ Are Not The Same
Another issue for data matching efforts is the mismatch between the SNAP “assistance unit” and a “tax unit.” The SNAP assistance unit consists of individuals who live together in the same residence and who purchase and prepare food together. These can change monthly if, for example, someone moves into or out of the household. Tax units, in contrast, are based on legal relationships and residency and determined annually.
As an example, marriages and divorces happen throughout the year. For tax data to be useful in verifying SNAP eligibility, DOGE analysts would need to know when marriages occurred or were dissolved to know whether income reported by couples on tax returns should be attributed to the SNAP unit. For tax purposes you are considered married if you are married on December 31 of the year.
The timing mismatch could lead to mistaken inferences. For example, a single parent could live with his or her children and receive SNAP benefits for part of the year. If that parent married before the end of the year, the SNAP unit would change. If the new addition to the unit had substantial earnings, the unit could become ineligible for SNAP—though they were eligible prior to the marriage. Tax data might incorrectly suggest the parent and children were ineligible for SNAP even before the marriage.
Child Custody And Residency Introduce Complications
DOGE analysts would also need to know where children live. In some cases, noncustodial parents can claim tax benefits. When that happens, inferring eligibility based on the tax unit claiming the child would be incorrect. Analysts could underestimate the benefit the custodial parent was eligible for and overestimate the benefits the noncustodial parent was eligible for.
Other Living Arrangements Do, Too
SNAP assistance units might also include grandparents living with children, unmarried couples, and multiple families that are “doubled up”—living together in a single household. All of these examples are likely to be a single SNAP unit that forms multiple tax units. But not everyone is required to file a tax return, which could lead to incomplete data when assessing SNAP unit income.
States Maintain SNAP Data
A final obstacle: Generally states control SNAP data. The federal government would need to execute special agreements with each state to access their SNAP data. This has proved to be difficult in the past and would add new administrative requirements for states—requirements they could find difficult to meet in a timely manner with fewer resources, as proposed in the recent congressional budget resolution.
Reporting Systems And Definitions Could Be Aligned, But Not Easily
One way to make IRS data more useful for determining SNAP eligibility in the future would be to require monthly income reporting for tax purposes. This would be a significant departure from current IRS practice and would likely present administrative challenges.
Policymakers could also harmonize eligibility definitions of “units” and use the same time periods across income support programs. But if SNAP units were determined by looking back over the past year as tax benefits are, they would be less responsive to economic changes than they are today.
Moreover, benefit programs typically have eligibility verification periods designed specifically to balance the likelihood of changes in income and resources against administrative burdens for participants and states. For example, older adults and people with disabilities typically may receive SNAP for a longer time period than working-age individuals subject to more frequent recertification and work reporting requirements.
IRS data certainly contain some information pertinent to SNAP benefit determination. But SNAP is not designed to operate over a calendar year and assess needs based on tax units. This limits the potential usefulness of IRS data in determining proper SNAP claims.
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