From October 2023 to September 2024, Dakota County had a Supplemental Nutrition Assistance Program (SNAP), payment error rate of 10%.
One in $10 of SNAP payments in that timeframe being incorrect is a staggering amount given that the program serves more than 10,000 residents or 2.2% of Dakota county.
But what does that error rate mean, and where does it come from?
Tiffinie Miller-Sammons, Deputy Director of Employment and Economic Assistance at Dakota County, oversees the administration of all public assistance programs in Dakota County from medical assistance to SNAP.
Given the forthcoming changes to SNAP coming down the from the federal level, Miller-Sammons laid out what exactly that error rate is, where it comes from, and what changes are coming to Dakota County SNAP.
SNAP Error Rate
The Snap payment error rate is simply a measure of how accurately states determine eligibility and payment amounts.
The payment error rate is determined by taking a sample of cases and dividing the amount of total error dollars by the total amount of benefits provided.
For example, if $5,000 were found to be issued in error out of a total sample of $100,000 of benefits, the payment error rate would be 5%.
For Dakota County from October 2023-September 2024, the SNAP payment error rate was 10%, more than a point over the State of Minnesota’s error rate for that same period of 8.9%, but below the national error rate of 10.93% for fiscal year 2024.
While error can come from a number of sources, “the SNAP payment error rate is not a fraud,” said Miller-Sammons.
Error can come from incorrect payments, through either overpayments or underpayments, to deductions, exemptions, all the way down to regular human error like issues in data entry.
Interpretations of applications for benefits can be another source of error.
“Even as someone who has done this for 20 years, the way we ask questions is confusing,” said Miller-Sammons.
For example, the application asks about owned assets. If the applicant is still paying off their home or their car, is that an asset? Misinterpretations like this can lead to over- or under-payments which add to the error rate.
In fiscal year 2024, the latest data available to Dakota County, 41% of dollars in error came from household mistakes, or from residents applying for benefits. The remaining 59% comes from errors within Dakota County.
Dakota County’s SNAP error rate is often dependent on staff workload and recent changes to SNAP policy, which can cause error due to employees and applicants not being up to date on new legislation.
“Every year its completely different,” said Miller-Sammons.
Adding to that workload, in recent years, the number of residents in Dakota County receiving SNAP has grown.
In 2024, there were 10,269 SNAP recipients in Dakota County. That number is up nearly 20%, almost 2000 cases since 2019 numbers of 8,288 cases.
As to why those numbers are up, Miller-Sammons points to the same reasons that have been noted for years: inflation across staple foods and rising housing costs.
Reducing the SNAP Error Rate
As to how to reduce the error rate, Miller-Sammons referenced issues of technology and proactivity.
Of the various assistance programs that exist in Minnesota, from cash assistance to medical assistance to SNAP, many use different programs which can increase the workload of “large data entry that determines eligibility.”
One such issue of eligibility is determining income and assets. Dakota County is currently piloting a program called TRUV Income Verification that verifies applicant’s income and assets externally. External verification can avoid household errors on applications as well as expedite the application process itself.
Proactivity—in making sure that recipients are getting what they qualify for in a timely manner—often has to do with a personal touch.
When Dakota County workers hear from SNAP recipients it can often happen “when they go out to purchase food” and the card gets declined for any number of reasons.
This type of situation, when benefits get denied, can cascade where benefits that were supposed to go towards other expenses now have to go towards food.
Rather than wait until a potential crisis occurs, “having the availability to reach out to people, especially for renewal,” would potentially stop such issues from happening as well as reduce the County’s error rate.
While Miller-Sammons “would like it as an expectation,” that level of availability and proactivity is not always the norm.
Fraud
Another factor to the SNAP error rate is fraud. SNAP fraud does occur, but according to Miller-Sammons, the most common type of SNAP fraud is the theft of SNAP benefits from recipients, which wouldn’t affect the SNAP error rate.
Stolen electronic benefits transfer (EBT) cards in particular are a focus for fraud. EBT cards do not have chips and are not equipped for touchless payment, which means they have to swiped in order to pay.
Swiping leaves EBT cards vulnerable to skimming, a common form of credit card fraud.
“Skimming occurs when devices illegally installed on or inside ATMs, point-of-sale (POS) terminals, or fuel pumps capture card data and record cardholders’ PIN entries,” according to the FBI’s page on fraud.
Using the captured card data, scammers can create fake purchases on that card and thereby ‘skim’ funds from buyers.
Other methods of fraud used in Dakota County have been phishing where SNAP recipients receive texts or emails from scammers posing as county or state officials seeking information.
“Throughout SNAP benefits, it’s not a high fraud area especially because of how managed it is,” said Miller-Sammons, referencing overlapping oversight from federal, state—and in Minnesota’s case—county levels.
SNAP Changes
Changes are coming down to SNAP through shifts in penalties for error rate, work requirements, and eligibility from the Big Beautiful Bill, which was signed by President Trump on July 4.
Some of the changes are quite clear.
Work requirements have broadly been expanded throughout SNAP. According to Miller-Sammons, the most significant change is raising the age of those exempt from work requirements from 54 to 64.
That expansion means that SNAP recipients up to the age of 64, with some exceptions, must show proof of working at least 80 hours per month.
This expansion of work requirements echoes many previous changes to the program except that—as the name ‘big beautiful bill’ would suggest—it is a notably larger change than many of those done in the past.
Other exemptions from work requirements have ended like those for veterans, those experiencing homelessness and recipients under the age of 24 who have aged out of foster care. These changes to exceptions are estimated to affect 450 people in Dakota County, according to Miller-Sammons.
Along with work requirements comes paperwork.
Proving one is working, and by doing so navigating county bureaucracy, can raise its own barriers to assistance. Lack of transportation to get to a county service center, low literacy skills, low digital skills, lack of internet, and homeless can get in the way of otherwise qualifying people receiving benefits.
“We see a lot of people who really need that help […] and they just don’t have the ability,” to spend the time proving eligibility said Miller-Sammons.
Other cuts to funding from the bill, like the cuts to federal reimbursement of administrative costs which were cut in half, leaves counties like Dakota County now paying for 75% of staffing costs surrounding SNAP.
For other changes, however, “There’s still a lot of unanswered questions,” said Miller-Sammons.
In particular, who will be on the hook for penalties for high SNAP error rates is an unknown for Dakota County.
If the state’s error rate is above the federal standard of 6%, starting in 2028, states must now pay a fine.
Given that Minnesota is one of 10 states that has county-administered SNAP, how will that fine be split among counties in not clear.
Will counties get a percent of the cost share across the state? If a county has an error rate below 6% but the state doesn’t, will they still have to pay the fine?
The answer to questions of cost sharing could impose steep costs on the county in what is already expected to a tough budget year. The Dakota County board is currently considering nearly $8.5 million worth of cuts to county services.
For Miller-Sammons, the changing coming to SNAP are relevant to even those who do not receive them: “It’s vital that people know about these changes even if it doesn’t affect them, because someone they know or love will be affected.”