August 30, 2023

Dear Mr. Taylor,

Thank you for your letter regarding Georgia’s efforts to improve SNAP administration.
First, I must express my gratitude for your leadership and support. It is always a pleasure
to work with SERO. In this response, we are confident that we will mitigate your concerns
by giving more insight into our work to better serve eligible households.

Current Statistics

As of Monday, August 28, the State of Georgia has 94,954 total pending renewals—1,491
of which are overdue with 854 pending state action. Although historical data reflects a
monthly average of 80,000 cases processed to completion by our employees, actual case
volumes remain much higher, due to the lingering effects of the pandemic, including
workforce shortages, record-setting inflation, and unaffordability of basic necessities for
many American families.

Fortunately, the Peach State continues to lead the nation as the best state for business
and raising a family, and we expect overall case volumes – and associated workloads – to
decline over time as more families secure financial independence and fully emerge from
COVID’s grip. Plus, our agency’s efforts continue to materialize as we aggressively hire
new staff, retain quality employees through pay raises and better benefits, improve
technology, and streamline workflow.

Federal Recommendations

Your letter recommended several ideas to improve SNAP administration in Georgia. For
each of those, we already plan to implement or have actually implemented.

• Lengthening Certification Periods: We recently extended certification periods by

securing your office’s approval earlier this year to lengthen SNAP ESAP
certification periods. Those system changes go live this November. Additionally,
we have shared with SERO how we are currently exploring the feasibility of
pursuing lengthened certification for more SNAP categories. Since we plan to
submit this request soon, we request SERO’S expedited review and approval.

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• Dedicated Staff: FNS recommends that we assign “dedicated staff to work through
the backlog.” We created a statewide renewal team for this very reason. It has been
up-and-running for several months now, and we created it after securing millions
in new funding as part of a forward-looking, multi-year strategy involving the
legislative process—again, no small feat.

• Resolve Staffing Issues: FNS also recommends that we identify the “root cause” of
our “staffing issue” and find new ways to increase employee retention. In the past
two years, Governor Kemp has increased state employee pay by $7,000 and
dramatically improved benefits with a higher state match for retirement
contributions, better healthcare options, and flexibility to cash-out accrued leave.
Importantly, Governor Kemp secured the General Assembly’s support to deliver
employee pay raises increases in concrete dollar amounts versus percentage-based
increases—a deliberate move to ensure that the lowest-paid state workers, which
includes so many of our eligibility case managers and supervisors, felt the biggest
impact. We will soon unveil a career ladder to further incentivize retention for our
eligibility workforce to reward their hard work and skill-building as they gain
tenure and leadership experience. Also, as you know, we have hired over 700 new
employees since January alone. Although your letter states that we still have nearly
500 vacancies, those are unfunded relics of an outdated personnel system, which
the State will be replacing for every agency over the next two to three years. To hire
those 700 employees, we fought hard – bolstered by the Governor’s support – to
secure millions in new funding through grueling legislative advocacy. Moreover,
compared to last year’s metrics, turnover across most job categories is decreasing.
Through higher pay, remote work flexibility, measured changes to job
requirements to expand applicant pools, and investments to improve the State’s
Integrated Eligibility System, Georgia now has more qualified, well-trained
eligibility staff to handle historically high caseloads, which – again – we expect to
decrease over time into more manageable volumes.

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• Solicit Input from Eligibility Staff: This initiative has been underway for many
months. We have been proactively soliciting input from our staff to think “outside
the box” and improve processes. In fact, I have asked veteran leadership staff from
the child welfare side of our agency to volunteer their time and expertise to develop
better cadencing models, review regular reports to identify ways to increase
productivity, and talk to our staff at all levels to get their ideas to change how we
do business and serve our clients. Deputy Commissioner John Hallman and
Assistant Deputy Commissioner Wesley Merritt will also embark on a “road show”
this September to visit at least two counties in each district, soliciting input and
creative ideas directly from staff. Again, these efforts take significant time,
resources, and passion.

Practical Considerations

Now that we have clarified our plans, I must reiterate that no state can hire its way out of
this crisis. We have poured our blood, sweat, and tears into hiring and retention. We have
raised pay, solicited feedback, kept you apprised at every turn, and recognized where we
need improvements. We have exhausted our options within the bounds of our authority.
We need our federal partners to take action.

Poignantly, the U.S. Centers for Medicare and Medicaid (CMS) already allows for more
casework automation, including ex parte renewals. This flexibility reduces red tape and
unnecessary churn for Medicaid members without compromising the program’s overall
integrity. Similar to our SNAP volume, Georgia has record-high Medicaid enrollment
these days, but CMS officials have alleviated states’ burdens by affording far more
flexibility through technology as we all slog through the unprecedented challenge of

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Medicaid unwinding. For this reason and others, it is wildly frustrating to have one federal
agency afford relief to Georgia’s clients and workforce only for its sister agency to ignore
or reject more tightly controlled forms of relief.

More BOT technology is the right path forward. Our employees value this type of
automation because it inverts the burden, taking it off our clients by lessening – if not
altogether eliminating – paperwork shuffling, staff processing errors, and benefit gaps.
Thus, your cited survey results are just too old to be reliable at this juncture, and they are
irreflective of significant investments over the last two years regarding workforce,
training, caseloads, pay raises, and more. Additionally, your cited error rates largely
reflect human – not BOT – error, which stemmed from manual “overrides” no longer in
practice due to better employee training and mentorship. Clearly evidenced in the
following graph, you can see that historic error rates for BOT-assisted cases are
dramatically lower than non-BOT-assisted cases except for a mere three months’ time,
which is easily distinguishable due to small sample sizes.

From a practical standpoint, Georgia has a solid case for our BOTs through existing
federal Medicaid flexibility, strong employee buy-in, and actual error rate data.

BOT vs Non-BOT Error Rates

25.00%

20.00%

15.00%

10.00%

5.00%

0.00%
Jul-21

Jul-22
Jun-21

Jun-22

Nov-22
Nov-20

Nov-21

Apr-23
Apr-21
May-21

Apr-22
May-22

Dec-22
Dec-20

Aug-21

Dec-21

Aug-22
Mar-22

Jan-23
Feb-23
Mar-23
Jan-21
Feb-21
Mar-21

Sep-21

Jan-22
Feb-22

Sep-22
Oct-21

Oct-22

Non-BOT BOT Cases

Legal Considerations

From a legal standpoint, Georgia’s case for BOTs remains solid. First, while 7 U.S.C. §
2020(e)(6)(B) restricts the use of non-merit-based state personnel in certification
activities, it does not mandate that all certification activities be undertaken by merit
personnel. Respectfully, your agency’s longstanding interpretation of these provisions is

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too narrow based on the actual text and documented objectives, and we have thoroughly
vetted applicable law and legislative intent to reach this conclusion.

Still, Georgia is not asking to outsource certification activities to non-merit-based

personnel. Machines will not replace people, and those people will remain merit-based
employees. Our staff will continue to be fully engaged in casework decision-making once
we go live with more BOT flexibility, which simply amounts to time-limited relief with
clear guardrails through a proven, common-sense solution already permitted for more
expansive use by federal Medicaid officials.

Also, Georgia’s SNAP ex parte demonstration project waiver technically stands approved
by operation of law. Pursuant to 7 U.S.C. § 2026(b)(1)(D), more than sixty (60) days have
elapsed since the Secretary’s receipt of such waiver, and your agency had no outstanding
requests for clarification when the clock ran out. We have the statutory right to move
forward unimpeded with implementation of ex parte BOT functionality, and there is no
basis for such approval to be rescinded or otherwise curtailed.

However, out of enormous respect for SERO and our close partnership, Georgia wishes
to pursue SNAP ex parte waiver implementation with FNS leadership’s vocal support.
This advocacy will immediately benefit the Georgians who rely on our collaboration to
make ends meet, and it will also diminish our fears of imminent retaliation for exercising
our rights under federal law. Please advise at your earliest convenience if we can expect
support for this initiative by federal leaders, and we thank you for your assistance.

Sincerely,

Candice L. Broce
Commissioner

47 Trinity Ave. S.W., Atlanta, GA 30334 | dhs.ga.gov