Testimony of Zack Mason, Bread for the City

Council of the District of Columbia

 Committee on Housing

Performance Oversight Hearing: Department of Human Services (DHS)

March 5, 2025

My name is Zack Mason, and I am the Medical-Legal Partnership (MLP) Staff Attorney at Bread for the City, a non-profit organization located in Southeast and Northwest DC. Bread for the City provides food, clothing, medical, legal, and social services to thousands of low-income District residents each year. The majority of our clients rely on the DC Department of Human Services (DHS) for public benefit programs such as Medicaid, SNAP, TANF, Interim Disability Assistance (IDA), and the DC Healthcare Alliance. Our Public Benefits team, comprised of both attorneys and non-legal staff members, advises patients on their public benefit eligibility, informally advocates for clients who are not receiving the benefits to which they are legally entitled, and represents clients before the Office of Administrative Hearings (OAH) to ensure the equitable resolution of their public benefits matters. Bread for the City thus has a vested interest in critically monitoring the efficiency and efficacy with which DHS manages its public benefits programs. 

For years, Bread for the City has raised myriad concerns before this Council regarding DHS, including, but not limited to: public benefit applicants receiving redundant, and often erroneous, document verification requests; extensive delays in DHS providing recipients their undisputed benefits, even after an OAH judge has ordered it; DHS “losing” materials, including entire benefit recertifications and applications, that applicants submit in-person at DHS Centers; recipients being placed in the incorrect programs or not receiving the correct level of determined assistance; and the chaotic, post-pandemic medical insurance redetermination period 

These problems with DHS operations generally persist, to varying degrees. In recent months, however, DHS has demonstrated a concerted effort to address our concerns and materially improve its management of DC’s public benefits programs. Today, my testimony implores DHS to continue this trend by maximizing operational efficiency and re-committing to timely case resolution. We urge the Council to both hold DHS accountable for enacting these improvements and prioritizing the allocation of increased funding that will enable DHS to do so.

1. DHS Has Improved Its Management of Public Benefits Systems 

Since we last testified before this Council, Bread has noticed a considerable improvement in how DHS resolves problems for public benefits recipients. Notably, we have observed more transparency from DHS caseworkers and personnel, enabling us to troubleshoot clients’ concerns collaboratively. This, in turn, makes it more likely that recipients’ issues can be addressed and resolved expediently. If the DC Department of Health Care Finance (DHCF) Provider Portal indicates that a client has conflicting “end” and “recertification” dates for their Medicaid or Alliance, for example, DHS will provide advocates with a detailed diagnosis of the issue, which then helps to demystify an otherwise alarming experience for our clients. When disagreements arise between advocates and DHS regarding a client’s SNAP benefit amount, we have found that caseworkers are more willing to reveal their precise calculations with us. By exchanging “SNAP math,” we cut down on the time it would otherwise take to decipher why our respective benefits calculations do not match and clarify whether the difference in calculations is a matter of policy disagreement or mathematical error. In turn, DHS can issue the proper SNAP disbursements to recipients without undue delay. 

DHS’ team of data analysts and IT specialists has been particularly adept at quickly resolving both client-specific and system-wide technical issues with District Direct. For instance, late last December, a group of advocates noticed that a District Direct glitch was improperly requiring primary household members of mixed-status households to disclose sensitive details regarding their immigration status, or re-enter citizenship information that DHS already had on file, in order to submit otherwise-straightforward SNAP recertifications. Despite the hectic holiday season, DHS’ data analysts promptly responded to advocates’ concerns and resolved this issue by the start of the new year. 

DHS has also stepped up to support benefits recipients when the federal government does not. After the 2025 American Relief Act1failed to extend states’ authority to allocate federal funds for reimbursing victims of SNAP skimming, DHS committed its own funds to replace electronically-stolen Food Stamps. These actions demonstrate to advocates that DHS’ pledge to serve benefits recipients is not mere lip service. 

2. DHS Must Increase Efficiency to Avoid Over-Burdening OAH 

Despite the aforementioned improvements, DHS remains, at times, a frustratingly inefficient agency. Their processing delays are well-publicized: DHS only timely processed 48% 

1 “The American Relief Act, 2025, is absent of an extension in authority for the replacement of SNAP benefits stolen via card skimming, card cloning, and other similar fraudulent methods. Thus, SNAP benefits that are stolen on or after Dec. 21, 2024, are not eligible for replacement using federal funds.” Cathy Buhrig, “Sunset of Replacement of Stolen Benefits Plans,” Supplemental Nutrition Assistance Program (Dec. 23, 2024).

of SNAP applications submitted in the fiscal year 2023;2it issued timely determinations for fewer than 60% of all MAGI Medicaid and CHIP applications received between January and March 2024.3 Fittingly, then, Bread for the City’s most pressing concerns with how DHS manages its public benefits programs can be boiled down to the agency’s lack of expediency. 

For the past few months, Bread for the City has aggregated most of our non-urgent case inquiries and client concerns, submitting them to DHS via an “escalation spreadsheet” each Friday. DHS agreed to respond to these queries by Wednesday of the following week. DHS has instituted this system of case resolution with other legal organizations for some time, in the hopes of streamlining the resolution process, rather than having to field numerous inquiries from individual advocates within the same organization. While we appreciate DHS’s willingness to try new ways to efficiently handle advocate concerns, we have been experiencing inconsistencies in DHS’ responses to our spreadsheets that have frustrated the process. 

Because the spreadsheet is not “live,” in the sense that DHS personnel and Bread for the City advocates cannot edit it in tandem, we need to wait until DHS has fully responded to all of our inquiries before we can do any follow-up or submit new inquiries. As a result, complex case inquiries often elicit incomplete or terse responses from DHS caseworkers, forcing Bread advocates to re-escalate the same concerns, week after week. DHS also frequently fails to abide by the weekly response schedule upon which they initially insisted, further delaying case resolution. 

When DHS does not provide timely, constructive responses, or otherwise fails to respond at all, it defeats the purpose of merging all of our weekly inquiries into one document. Advocates often resort to filing Fair Hearing Requests at OAH for matters that may actually not be contested. Our clients are left waiting for weeks or months to get their benefits issues resolved, where a diligent caseworker could have read the inquiry and timely responded to remedy the problem. 

Already back-logged, OAH is often tasked with bearing the weight of DHS’ inefficiency. Once we file a Fair Hearing request, the matter proceeds to a brand-new set of eyes at DHS during the Administrative Review Conference (ARC). If the matter then proceeds to the hearing stage, DHS policy analysts are frequently unprepared, or they have failed to communicate with the ARC’s Hearing Examiner in advance, resulting in avoidable continuances. When a matter is 

2 FY 2023 Reported SNAP Application Processing Timeliness, https://www.fns.usda.gov/snap/qc/timeliness/fy23 (last visited Mar. 2, 2025).

3 MAGI Application Processing Time Snapshot Report: January 2024 – March 2024, 

https://www.medicaid.gov/state-overviews/downloads/magi-app-process-time-snapshot-rpt-jan-mar-2024.pdf (last visited Mar. 2, 2025). 

timely reviewed and resolved by a DHS caseworker via the spreadsheet process, however, it avoids at least two additional DHS staff members at higher pay grades getting involved. 

Even in cases featuring prepared policy analysts and legitimate disputes of fact or law, DHS unnecessarily delays proceedings. We currently represent a victim of SNAP skimming, where the matter has already been investigated by the Office of Program Review, Monitoring, and Investigation (OPRMI). Although there is no evidence to suggest the victim’s EBT card was not skimmed, DHS refuses to afford the victim the benefit of the doubt. In anticipation of a third status hearing, DHS recently produced 26, labeled exhibits. The contested reimbursement is $283. Surely, conserving OAH and DHS staff resources, avoiding extensive litigation costs, and freeing up DHS analysts is worth more than simply reimbursing the client. 

Clients have also shared experiences with Social Service Representatives (SSRs) that suggest front-line DHS staff have received insufficient training and policy education. Simple questions regarding the status of submitted applications and recertifications are met with vague assurances to “not worry about it” and unfulfilled promises that “someone will reach out, soon.” Posing the exact same question to different SSRs often yields contradictory answers, confusing benefits recipients on how to proceed with their cases. For example, one recent Bread for the City client unknowingly failed to comply with the Office of the Attorney General’s (OAG) Child Support Services Division (CSSD), regarding the identity of her daughter’s father, because two different DHS representatives incorrectly assured the client that the child support sanction on her TANF benefit had already been lifted. 

During a recent SNAP recertification interview, DHS subjected one Bread client to two hours of combative, circular questioning. The SSR repeatedly pressed her to give information she had already provided. She incorrectly insisted the client include a non-mandatory family member on her SNAP case. She refused to accept the client’s signed, “no income” letter, which clarified her last date of employment and included the names/contact information of her former supervisors, as proof that the client does not currently receive income. She demanded the client provide two “living with” letters; this demand is not within the purview of a SNAP interview, as it’s a TANF-related requirement, and is also in contravention of DHS’ own October 2024 policy amendment allowing prospective TANF recipients to submit self-attestations on DHS letterhead. To add insult to injury, the SSR terminated the SNAP interview without actually marking it as completed in the system. Although she promised to resume the SNAP interview the following day, the interviewer never called the client back. 

When advocates cannot rely on timely responses from DHS caseworkers, we are forced to lean on the adjudicative authority of OAH to settle disputes; similarly, when front-line staff are ill-equipped to resolve straightforward case questions and concerns, benefits recipients are

forced to pursue relief via Fair Hearings. This dynamic, where OAH must do the work DHS can more readily perform, is not sustainable. 

3. The Council Can Help DHS Remedy Its Systemic Inefficiency By Increasing the Agency’s Funding 

DHS cannot constructively address advocates’ concerns without more resources. Additional funding would encourage DHS to invest in state-of-the-art data-sharing platforms that allow advocates and caseworkers to contemporaneously edit “live” escalation sheets, while reliably protecting clients’ confidential information. 

DHS could also use an enhanced budget to expand its roster of caseworkers, policy analysts, and SSRs. Having more caseworkers reduces the number of discrete case inquiries for which each must be responsible, thereby slashing the time it currently takes to receive meaningful responses from DHS. The likelihood of a policy analyst appearing at the first Fair Hearing date, well-prepared and unlikely to demand an avoidable continuance, increases when there is a larger pool from which to pull. With increased funding, DHS could also afford to hire new SSRs and, most crucially, retain supervisory SSRs who have the time to better-educate their colleagues in ESA policy and internal case handling processes. DHS would drastically improve its success rate in resolving benefits recipients’ issues at the first point-of-contact. Recipients would, in turn, feel less compelled to retain legal assistance that will necessarily drain caseworker and policy analyst resources. 

If DHS does not have the means to hire and properly train additional staff, our complaints will be met with increasingly unsatisfactory responses from an overburdened agency, fueling a mutually contentious working relationship between advocates and DHS. In turn, OAH will continue to be stretched beyond its limits, acting as an administrative Band-Aid for the woes of an inefficiently-managed public benefits regime.

4. Closing 

Public assistance programs should not require the intervention of legal advocates and vocal community members to be timely and high-functioning. Bread for the City’s testimony today is a clarion call for the efficient, equitable management of public benefits programs for all DC residents. Respectfully, we implore the Council to demand greater efficiency from DHS and to prioritize enhancing their financial ability to meet this demand. Thank you.