The effect of administrative burden on state safety‐net participation: Evidence from food assistance, cash assistance, and Medicaid

• Published date: 01 March 2023
• Author: Ashley Fox,Wenhui Feng,Megan Reynolds
• Date: 01 March 2023
• DOI: http://doi.org/10.1111/puar.13497

RESEARCH ARTICLE

The effect of administrative burden on state safety-net

participation: Evidence from food assistance, cash assistance,

and Medicaid

Ashley Fox

1

|Wenhui Feng

2

|Megan Reynolds

3

1

Department of Public Administration and

Policy, Rockefeller College of Public Affairs and

Policy, Albany, New York, USA

2

Department of Community Health, Tufts

University School of Medicine, Boston,

Massachusetts, USA

3

Department of Sociology, University of Utah,

Salt Lake City, Utah, USA

Correspondence

Ashley Fox, Department of Public

Administration and Policy, Rockefeller College of

Public Affairs and Policy, 135 Western Avenue,

Albany, NY, USA.

Email: afox3@albany.edu

Funding information

Robert Wood Johnson Foundation Public Health

Law Program (Grant/Award Number: 72274)

Abstract

Administrative burden in social welfare programs is increasingly recognized as a bar-

rier to eligible individuals’access to their legally entitled benefits. Using composite

indices of administrative rules for three major safety-net programs (Temporary Assis-

tance to Needy Families, Supplemental Nutrition Assistance Program, and Medicaid)

that vary in the degree and type of costs conferred on claimants across states

between 2000 and 2016, we examine the effect of rule burden on program participa-

tion using two-way fixed effects models. We find that each program contained

numerous rules that confer a high degree of learning and compliance costs, and

psychological costs to a lesser extent, though to varying degrees. Reducing costs asso-

ciated with burdensome administrative rules was associated with higher program

inclusivity across the programs, with relaxing some rules contributing more than

others. Rules that automate enrollment/renewal, link eligibility with other programs

and reduce asset tests seem especially promising. Easing burdensome administrative

rules can increase access to services to which claimants are legally entitled.

Evidence for Practice

•Means-testing in U.S. safety-net programs imposes steep administrative burdens

on low-income applicants that are likely to deter program uptake.

•With welfare reform in 1996 and the decoupling of eligibility for different safety-

net programs, burdensome administrative rules in Temporary Assistance to

Needy Families have sharply increased whereas Supplemental Nutrition Assis-

tance Program and Medicaid have increasingly moved in the direction of efforts

to decrease administrative complexity.

•We find that states’adoption of program rules that reduced burden was associated

with increased enrollment across the three programs though to differing degrees.

In each program, specific program rules matter more than others for uptake.

•Rules that shift the burden of proof from the claimant to the state (eligible until

proven otherwise) and rules that impose an active effort on the part of the state

to identify potentially eligible claimants (opt-out rather than opt-in), seem to

matter more.

•We conclude that administrative rules, separate from eligibility criteria, are con-

sequential in affecting safety-net program uptake, consistent with concerns that

administrative burden may constitute a form of bureaucratic disentitlement.

INTRODUCTION

It is estimated that as many as 40 million unemployment

claims were filed in the United States in the wake of

COVID-19-induced layoffs, beginning March 2020.

Applicants faced long wait times and uncertain outcomes,

with at least 44% of claims ultimately denied

(Cohen, 2020; Hess, 2020). The application process was no

less challenging. For instance, in Wisconsin, applicants

could only apply online if they possessed a Wisconsin

Received: 12 June 2021Revised: 21 March 2022Accepted: 23 March 2022

DOI: 10.1111/puar.13497

Public Admin Rev. 2023;83:367–384. wileyonlinelibrary.com/journal/puar © 2022 American Society for Public Administration.367

driver’s license and wait times to reach a representative

by phone were over an hour (if applicants could get

through at all). In New York, recipients of regular unem-

ployment insurance were required to document at least

three work search activities (each occurring on a different

day) each week to maintain benefits.

1

These are examples of how administrative rules can lead

an individual to experience a policy’s implementation as

onerous (Christensen et al., 2020;Herd&Moynihan,2018).

Beyond the already onerous demands imposed by federal

requirements, variability in the administration of many

U.S. safety-net programs across, and often within, states

adds a layer of complication to the safety-net enrollment

process. Despite the complexity in federal and local adminis-

trative dictates, there is no central database capturing all

rules and their interactions; in other words, there is presently

no means through which citizens can easily check their eligi-

bility for public assistance. Rather, they must undertake sub-

stantial research or subject themselves to rigorous scrutiny

and significant paperwork demands in the hopes they will

qualify (Campbell, 2014). Administrative burdens of this sort

represent potentially significant barriers to safety-net pro-

gram enrollment, effectively denying benefits to many eligi-

ble individuals. Estimates suggest that for every 100 families

in poverty in 2015, only 23 received cash assistance to

which they should be eligible based on income alone from

the Temporary Assistance to Needy Families (TANF) pro-

gram (Floyd et al., 2017). Likewise, over 3.7 million children

were found to be eligible for Medicaid or State Children’s

Health Insurance Programs (SCHIP) but were uninsured in

2012 (Kenney et al., 2015). These gaps in what Bruch

et al. (2021)refertoas“program inclusiveness”raise ques-

tions about why so many potentially eligible individuals do

not enroll in programs to which they are likely to be legally

entitled.

This article examines the impact of burdensome

administrative rules and their potential role in contribut-

ing to under-enrollment. We focus on three major

U.S. safety-net programs—Temporary Assistance for

Needy Families (TANF), Supplemental Nutrition Assistance

Program (SNAP), and Medicaid. As we discuss below,

TANF burden increased substantially with the shift from

cash assistance to block-granting in 1996. Recent revi-

sions to SNAP and Medicaid enrollment and renewal pro-

cedures, on the other hand, have largely shifted burdens

in the other direction—from claimants to the state. Using

a novel dataset of safety-net eligibility, enrollment/

renewal, and compliance rules for TANF, SNAP, and Med-

icaid between 2000 and 2016, this study examines the

relationship between administrative easing of enrollment

rules and program take-up. We hypothesize that states

that have reduced burdensome administrative rules over

time will see larger increases in the share of low-income

individuals participating in safety net programs, adjusting

for other program characteristics and state-level variables.

We leverage variation across three programs with differ-

ent degrees of state administrative discretion to examine

how program burden is associated with program uptake.

While the effect of TANF burden on program enrollment

has been studied extensively, the cumulative effect of

burden in other means-tested safety-net programs has

received less explicit attention, especially in comparison

to related programs.

BACKGROUND

Administrative burden in safety-net

programs

Administrative burden has been conceptualized along

three dimensions that citizens face in their interactions

with government: learning costs, psychological costs, and

compliance costs (Moynihan et al., 2015). Learning costs

are those incurred as citizens seek to understand eligibility

guidelines, the nature of benefits, and how to access ser-

vices. Compliance costs are those required to complete ini-

tial and reenrollment applications, provide documentation

of their standing, and avoid or respond to discretionary

demands. Psychological costs include those associated

with the stigma of participating in an unpopular program,

as well as the loss of autonomy and increase in stress aris-

ing from eligibility maintenance requirements. Taken

together, these burdens are both consequential and dis-

tributive (Moynihan et al., 2015). They are consequential in

terms of citizens’perceptions of government—and the

extent of material support they receive. They are distribu-

tive in that the least advantaged tend to face dispropor-

tionate burdens even as they have fewer resources with

which to manage and overcome them (Christensen

et al., 2020; Herd & Moynihan, 2018).

Research on administrative burden departs from that

of “red tape”in focusing on those aspects of the bureau-

cratic apparatus that covertly inhibit program participa-

tion from the citizen’s vantage point (Madsen

et al., 2020). Where red tape is generally concerned with

how government rules and procedures are experienced

by bureaucrats, administrative burden is generally con-

cerned with how these factors are experienced by citi-

zens. Although bureaucrats, especially at the street-level,

may also feel hamstrung by inflexible eligibility and

enrollment processes, red tape applies exclusively to

rules that lack a legitimate purpose (Bozeman, 2000,

p. 12). Arguably, even though burdensome safety-net

program rules may be onerous, they typically serve a

legitimate end, albeit often to use obfuscation to tacitly

deny the claims of otherwise eligible beneficiaries. For

instance, beyond simply providing income maintenance

during bouts of unemployment, requiring recipients to

document work searches is intended to ensure that

claimants are making active progress towards finding

paid employment. Likewise, asset tests aim to ensure

that only families without significant savings or other

assets receive public assistance (Gehr, 2018). These rules

368 ADMINISTRATIVE BURDEN ON STATE SAFETY-NET PARTICIPATION