USDA SNAP Program Integrity Data Team: Preliminary Report

Introduction

U.S. Department of Agriculture and the Food and Nutrition Service (FNS) use SNAP eligibility data to ensure the integrity of government programs, including by cross referencing SNAP recipient eligibility against federally maintained databases, identifying and eliminating duplicate enrollments, and performing additional eligibility and program integrity checks specified herein. This Standard Operating Procedure (SOP) establishes a framework for state SNAP agencies to share data with the USDA/FNS for fraud, waste, and abuse detection and program integrity purposes. The SOP balances federal data access requirements under Executive Order 14243 and the Food and Nutrition Act with privacy protections, minimizes unnecessary data collection, and incorporates security standards while maintaining public trust and compliance with applicable law.

Data Requested from States

Data requested from states can be found in Appendix A. Only data elements necessary to achieve specific, legally permissible goals, such as fraud detection, duplicate enrollment prevention, and program integrity checks, were collected and used. The scope of data collection was limited to excluding sensitive personally identifying information (PII) unless directly relevant to these goals (i.e., the collection of data elements spelled out in the Privacy Impact Assessment, found in Appendix B). Data derived from third-party sources (employment verification databases, financial institution records, and property records) that states use for verification but are not part of applicant-reported information are excluded and were not requested. The applicable system of records notice for this protocol is USDA/FNS-15, "National Supplemental Nutrition Assistance Program (SNAP) Information Database," as found in Appendix C.

Data Transfer and Security

The SNAP Information Database's infrastructure and operational procedures were designed to ensure the highest levels of security and compliance. The primary storage location is the Amazon Web Services (AWS) GovCloud (US) region, with backup and disaster recovery systems in a secondary AWS region. No storage, processing, or backup activities occur outside of GovCloud or other federally secure environments. All infrastructure adheres to Federal Risk and Authorization Management Program (FedRAMP) High Baseline standards. Data are encrypted to prevent AWS personnel from accessing unencrypted information, with encryption keys managed exclusively by federal USDA personnel, ensuring no access by AWS or third-party vendors.

Access controls are robust, requiring multi-factor authentication for all access points. USDA implements role-based access control (RBAC) following the principle of least privilege, with access limited to specifically designated employees within the FNS Program Integrity Division. Comprehensive access logging and audit trails are maintained for a period equal to the data retention period, with quarterly access reviews conducted by the USDA. Access is immediately revoked upon employee termination or assignment changes.

Encryption standards ensure that all data is encrypted both at rest and in transit, with encryption keys managed solely by USDA federal personnel, and no keys are held by commercial vendors. Data segregation and compartmentalization practices are in place, with SNAP data isolated in a separate, dedicated AWS GovCloud environment and not directly integrated with other USDA systems. Access is restricted to individuals with specialized oversight, who are required to take annual training on procedures for handling sensitive data, sign and attest to confidentiality requirements, and submit personal financial disclosures.

Finally, all data transfers are conducted using secure tools that meet or exceed FedRAMP High Baseline standards, ensuring the integrity and security of the data throughout the transfer process.

States were provided individual multi-factor authenticated access to the AWS location to securely pass data to specific federal USDA personnel who then moved data into secure analysis environment. Access to state data was limited to USDA personnel who meet the requirements outlined above and access was not granted to outside agencies.

Processing

States store and organize their data very differently, so state-specific processing procedures were developed to rapidly read in and synchronize data across all states when received. Special attention was paid to coordinating date fields, ensuring true recipients' data were in fact active participants in SNAP, and removing duplication. Some states provided multiple instances of a given recipient when their data were updated (i.e. address change), and care was taken to ensure current information was being considered. Data were arranged into tidy format, such that a single row per active recipient and a single column per category of data were created. States were consulted during this process to ensure proper interpretation of data formats and column definitions.

Flagging State Data

USDA employed a foundational fraud, waste, and abuse verification that focused on identity verification, income and eligibility verification, immigration status, reported residential and mailing addresses, verification of disqualified recipients, as well as non-recipient household member data. USDA cross referenced state supplied data against auxiliary data from other sources including Social Security Administration (SSA), Systematic Alien Verification for Entitlements (SAVE), and other internal FNS data sources to establish data integrity. Date of birth, household size, and spending patterns were used to glean insight on income and eligibility verification. No official flag or determination was made with regard to income, but spending patterns were linked to eligibility data from internal FNS data sources. SSA data coupled with SAVE data were used to flag possible immigration status discrepancies. The FNS Electronic Disqualification Recipient System was used to flag recipient disqualification status.

In addition to the core fraud detection functions, USDA employed additional techniques including flagging intrastate and interstate duplication, deceased individuals, synthetic identity patterns (new social security numbers [SSNs] with inconsistent biographical data), and geographic anomalies (such as high out-of-state transactions). Intrastate and interstate duplication flags were raised on individual social security numbers that were duplicated within (intrastate) or between states (interstate). Deceased individuals and synthetic identity patterns were flagged based on links with SSA data and consistency within state active eligibility data (i.e. same names and birth dates assigned to different SSNs, heads of household with unrealistic birthdates, or data that fit typical dummy-data patterns, such as SSNs of 123-45-6789 or similar configurations).

Reporting to States

After analysis, identified data discrepancy flags were returned to some of the state agencies with a summary of all flag counts by zip code and an identified category tab for each of the flags described above. States were asked to review a sample of each flag in each of the respective categories and provide feedback on the efficacy of the flagging procedure. States were encouraged to provide final disposition of each case review. USDA personnel will use feedback to improve initial data read in or state-specific flagging or output procedures.

Exclusions

Data was not used for tax administration or tax compliance, immigration enforcement, law enforcement investigations beyond coordination regarding criminal and administrative SNAP violations, administration of non-SNAP federal assistance programs (e.g., Medicaid, Temporary Assistance for Needy Families, housing assistance), sharing with foreign governments or international organizations, commercial use or transfer to private entities, or determining federal eligibility for benefits other than SNAP.

Table 1. SNAP Participation and Data Supplied by State Agency

State/Territory	SNAP Participation June 20251	Responded to Data Request?
Alabama	732,974	Yes
Alaska	66,572	Yes
Arizona	886,806	No
Arkansas	241,210	Yes
California	5,477,070	No
Colorado	614,911	No
Connecticut	361,655	No
Delaware	118,766	No
District of Columbia	140,716	No
Florida	2,928,850	Yes
Georgia	1,385,834	Yes
Guam	39,285	Yes2
Hawaii	149,284	No
Idaho	132,534	Yes
Illinois	1,869,744	No
Indiana	580,902	Yes
Iowa	266,947	Yes
Kansas	186,560	No
Kentucky	593,934	No
Louisiana	791,032	Yes
Maine	163,056	No
Maryland	665,084	No
Massachusetts	1,079,234	No
Michigan	1,474,701	No
Minnesota	448,841	No
Mississippi	356,756	Yes
Missouri	660,033	Yes
Montana	80,066	Yes
Nebraska	149,699	Yes
Nevada	492,270	Yes
New Hampshire	75,489	Yes
New Jersey	821,038	No
New Mexico	458,019	No
New York	2,955,731	No
North Carolina	1,350,026	Yes
North Dakota	51,179	Yes
Ohio	1,437,112	Yes
Oklahoma	691,754	Yes
Oregon	772,310	No
Pennsylvania	1,941,067	No
Rhode Island	141,801	No
South Carolina	570,687	Yes
South Dakota	75,329	Yes
Tennessee	682,128	Yes
Texas	3,457,259	Yes
Utah	174,386	Yes
Vermont	64,094	Yes
Virginia	813,228	Yes
Virgin Islands	20,610	Not required
Washington	903,442	No
West Virginia	269,687	Yes
Wisconsin	687,133	No
Wyoming	26,927	Yes

TOTAL

41,575,762

¹ Preliminary data as of September 2025.
² Guam was not required to provide data but voluntarily responded to the request.

Table 2. SNAP Eligibility Data Discrepancies for 29 State Agencies - Data as of July 1, 2025

Issue	Total Count 29 State Agencies	Median State Count1	Median State Percent2	Annual Implied Dollars3
Intrastate Duplication	247,575	467	0.10%	558,529,200
Interstate Duplication	108,670	2,057	0.50%	245,159,520
Deceased (per SSA record)	185,986	2,005	0.60%	419,584,416
Dummy SSN	441,572	2,462	1.20%	996,186,432
No SSN Found	26,333	254	0.10%	59,407,248
Disqualified but Active	4,442	56	0.03%	10,021,152

¹ Median count of each item for 29 state agencies supplying data.
² Median percent of records per state for each item in 29 state agencies supplying data.
³ Calculated as $2256 per recipient annually ($188 per month).

Intrastate Duplication: Recipients with same identifiers (SSN) that show up multiple times within a state.

Interstate Duplication: Recipients with same identifiers (SSN) that show up in multiple states.

Deceased (per SSA Record): Based on SSA lookup, the recipient is deceased.

Dummy SSN: Recipient has a non-normal SSN (i.e. 111-11-1111 or 999-99-9999).

No SSN Found: Recipient does not have an SSN in data provided.

Disqualified but Active: Recipient has been identified as a disqualified participant but is still active on state agency rolls.

Data Summary

The review of SNAP eligibility data across 29 State agencies identified several categories of discrepancies that could signal improper or erroneous benefit issuance. The largest issues by volume were cases with dummy or missing SSNs and intrastate duplication, together representing hundreds of thousands of records. Interstate duplication and deceased individuals appearing as active participants also showed substantial counts. Although the median percentage of each issue within States appear small, general under 1.2%, the implied annual financial exposure is significant. Dummy SSNs and intrastate duplication together account for more than $1.5 billion in estimated annual risk. Overall, the findings indicate that even small error rates can translate into substantial fiscal impact when applied across large caseloads, underscoring the importance of strengthened data-matching and eligibility verification controls.

These results highlight the need for targeted oversight, improved data integrity efforts, and sustained collaboration with states to reduce vulnerabilities and ensure program accuracy.

• Appendix A - Information SNAP Database: SNAP Eligibility Data Elements
• Appendix B - USDA Privacy Impact Assessment Fiscal Year 2025
• Appendix C - Federal Register Notice: Privacy Act of 1974; System of Records