Friends without Public Benefits
Broken contracting leaves MA families mired in paperwork
Nothing turns people off the welfare state like applying for welfare. Long forms of bewildering personal questions, followed by demands to verify it by uploading paychecks, leases, report cards; then a phone interview scheduled for Wednesday, 11am two weeks from now. If you wait it out – there’s no status tracking – and the sphinx of bureaucracy deems your responses acceptable, congratulations! You’ll get a little relief: any single program gives you just enough that it’s worthwhile applying, but by no means lets you breathe easy.1 Then you can do it all over a year later, and hope the sphinx once again purrs contentedly.
None of this is new, unfortunately. Since my wife Ariella worked a year helping Bostonians apply, reapply, appeal denials for benefits,2 and numerous family members have navigated food assistance and MassHealth insurance (Medicaid), I’ve been fascinated and horrified with the labyrinth built by the Commonwealth of Massachusetts for benefit applicants. Tens of millions more Americans wound through the maze to get unemployment assistance during COVID, bringing forth headlines and promises to improve.
In Massachusetts, those promises were carried forward by my two state legislators. They passed a law in 2022 to create a single application for the myriad of state benefits. Over 600,000 MA residents with Medicaid are likely eligible for SNAP (food stamps), and a common application for these programs and other means-tested benefits is supposed to close the “SNAP gap.” Just weeks ago, the Boston Globe checked in on the effort.3 Status update: stalled out in contracting.
The Department of Transitional Assistance is working to build a centralized hub that would do just that, but a spokesperson for the office declined to commit to a timeline, explaining that the office is in final contract negotiations with a vendor.
Officials said the first iteration of the tool would not come until after 2025 and would not initially include affordable housing programs. Instead, it will focus on SNAP and cash benefits for children, older adults, and people with disabilities, and it would leverage federal dollars to partially fund its creation.
Those funds are pending federal approval but state officials said they expect them to come through.
This ‘single front door’ to state benefits is currently locked, due to procurement problems. After trial and error, I found bid solicitation BD-25-1039-EHS01-EHS02-108789. The bid was released October 18, 2024, and remains unawarded more than 6.5 months later. $18 million was allocated towards the project in June 2023, so even preparing the solicitation took 15 months.4 The money’s been there for 2 years, and our state government doesn’t even know who’s gonna do the work.
A quest to rescue poor families from bureaucracy is itself mired in bureaucracy. Almost farce, but properly tragic for my neighbors who are missing meals. In this article, I’ll ask – and try to answer – what’s taking so long?
While the contract sleeps
tl;dr: You don’t need a contract to make progress, but it looks like this common application is stuck until the contract starts. MA’s limited effort so far has focused on making a shell app, not on talking to benefit applicants, hiring experienced builders, or simplifying the application process.
Progress doesn’t need to wait for a contract, necessarily. Ann Lewis recently wrote about projects “that accidentally wasted a billion dollars,” and their original sin is usually dumping a big budget onto a large contract for a single vendor. Alas, Massachusetts has not built momentum towards a common benefits application in the meantime. Instead of prioritizing people or simplifying paperwork, the focus has been on tech.
Specifically, they built an app. It’s called MyServices – missed opportunity not going with “CommonWealth” or “Mass Whole”5 – and the RFP suggests that it will be the home of a future common benefits app. Right now, MyServices lets you check your eligibility for health insurance, view your health insurance card, check on documents related to your health insurance… yeah, it’s basically a duplicate of the MassHealth apps, with a link to the website where you apply for cash benefits. There might have been voter registration forms at one point, but not when I logged in. Best I can tell, MyServices is basically the same as it was in September 2023.6
Integration projects like the common app, where you’re mushing together data and processes from different government programs, can fail for several reasons. Spinning up a new app and logging into MassHealth is relatively easy. Massachusetts could have taken its 2 year, $18 million head start to tackle these risks:
All about people: talk to beneficiaries
tl;dr: the team building a common app should talk and listen to applicants.
Journalists at the Globe or advocates at Greater Boston Legal Services add a lot to this conversation, because they Actually Talk To People. State caseworkers Talk To People too, and state legislators. Not just any People, though – the MyServices team should chat with folks who are applying for public benefits.
There’s no wrong way to Talk To People.7 Project leaders could set aside an hour a week, and listen to applicants share their experiences. They could hire a User Experience (UX) Researcher as a state employee or on contract, or get help from Massachusetts Digital Services.
The Integrated Eligibility & Enrollment (IE&E) governance diagram from page 8 of the solicitation puts the “Program Director” or “Program Management Office” two or three faint gray lines away from “Advisors & Advocates”. While I love these advocates (I’m in fact married to one), there’s no substitute for Actually Talking To People who are applying. Many others have written about why this is true. People outside bureaucracy or organization are uninhibited, and can react honestly without being looked at askance by their colleagues. Moreover, applicants’ interactions with government stories reveal blind spots a program manager wouldn’t think of. If you build without Actually Talking To People, you risk making a tool no one wants to use, or a tool that people have to use, but get pissed off at.
Talk To People doesn’t mean asking what exactly you should build, how you should build it, where the login button should be – though you can get design feedback once there’s a product that’s ready to be shown. Talk To People is also distinct from User Acceptance Testing (UAT), which verifies that a product does its job. Though I keep saying Talk To People, the key point is to listen, with empathy and an open mind.
Still all about people: hiring
tl;dr: Hiring a product manager and technical lead early on would reduce risk.
For a fraction of the $18 million allocated towards IE&E back in 2023, Massachusetts could have hired an experienced product manager and an excellent technical lead.8 Public benefit IT projects often fail, but it’s not rocket science, either; there are plenty of people who have delivered systems that work, and could contribute to MA’s efforts. The Globe cites Colorado as one example:
Often, individuals who need affordable housing could also benefit from state insurance, subsidized transportation, or heating and energy assistance.
More than a decade ago, Colorado unveiled a one-stop-shop digital tool called the Program Eligibility and Application Kit, or PEAK, to help residents apply to state and federal programs all at once, with automatic renewals in some cases.
“They did it on a shoestring budget. A lot of people volunteered out of their regular roles,” said Mike West, the product owner of PEAK who manages a staff of seven that keeps the tool working smoothly. The original cost for the tool was around $600,000 state officials estimate.
A product manager could Actually Talk To People and conduct the user research I described. If they’re trusted by the power centers of the somber “IE&E Governance Structure” chart, the PM can also fight requirements sprawl, by prioritizing which features are essential to the common app, and which ones add bloat and delay. A technical lead is a necessary check on the vendor who will eventually be hired: are their software choices sensible and well-implemented, or will costs blow up in two years because of lock-in and tech debt?
Make Applications Super Simple (MASS)
tl;dr: besides building the common app, Massachusetts should continue efforts to simplify benefit eligibility rules.
Hiding behind complicated government websites, silently frustrating citizens with obtuse language and obscure user flows, are typically complicated government rules. Just for SNAP, Massachusetts has over 230 pages of rules. Even before they start writing user stories, a good PM is a half-time archeologist, following “this is the way we do things” back to the actual rules and pushing back against rigidity. A tech lead can help, too, by exploring automations for cumbersome manual processes. Submitting paystubs to four different benefits programs every year, as the Globe describes, is one example – let’s check early on whether MassHealth income data can be shared with the SNAP software. If there are data compatibility issues, a hands-on engineer could help the systems talk to each other; if you’re told the rules and regs forbid it, a proactive PM can push for better rules or creative solutions.
To MA’s credit, there was progress simplifying applicants’ path to benefits, for at least a few years. A new SNAP application rolled out in 2018 reduced the number of questions most users encounter from 90 to 40. In 2021 and 2022, a checkbox was added to the MassHealth application which automatically submits applicants’ info for SNAP as well, which over 100,000 applicants have taken advantage of. But forward momentum halted there, as far as I can tell. Many of those 100,000+ applications were denied:
Despite this success, eligible households continue to be denied at high rates for missing the mandatory SNAP application interview, because of insufficient information shared between MassHealth and DTA [which administers SNAP], or for other reasons tied to difficulty getting help from DTA.
In 2023, Massachusetts requested a federal waiver “that would enable some newly approved MassHealth recipients to be directly certified for SNAP” by loosening the interview requirement – which would get some people benefits immediately, and give caseworkers more time for other applicants.9 The exact same language appeared in a state report a full year later, continuing “[t]his waiver is currently still under review with the federal government.” Sometimes, the buck does stop elsewhere.
Waiting for Godot: six months in contract purgatory
tl;dr: It was supposed to take 6.5 months from solicitation release to contract award, but we’re already behind schedule. My best guesses for why: sprawling requirements give evaluators too much to review; Supplier Diversity Program requirements distract from core goal of helping SNAP applicants; and RFP looks to control risk with 14 different KPIs, instead of setting bold goals.
It took a few weeks to write this article, and it was a little bit like Waiting for Godot.10 In the Globe article published April 13, a state spokesperson “declined to commit to a timeline” for launching the common application, “explaining that the office is in final contract negotiations with a vendor.” Given that aspirational “final,” I figured an award was coming soon. After all, the RFP itself expected a May 1 contract start date.
Yet each day, before I start writing, the bid page stares back at me, no award yet announced. This, too, is a sphinx: stony, unblinking, the haphazard index of “File Attachments” yielding no signed contract, no indication that the “final contract negotiations” are concluded. I email the procurement coordinators to ask; perhaps I’m missing an update somewhere, and the ink is already drying. No response. I’m baffled: How can we spend a year writing a solicitation, schedule for 6 months to award the contract, and still not meet that milestone?
One bureaucratic fun fact makes the long wait still more unlikely. The RFP notes: “To be eligible to bid on this RFQ, the bidder must be a qualified vendor under ITS81.” Massachusetts already has pre-vetted a list of IT vendors who won a spot on ITS81, a blanket contract for “IT Project Services and GIS.” It took at least seven months, from November 2023 to June 2024 for that parent contract to be awarded.11 In theory, these pre-qualified vendor pools are supposed to make subsequent competitions faster, since you have strong bidders ready to go. Here, no such luck.
Where’s Godot? What’s taking so long? From the outside, here are my best guesses:
Requirements sprawl
tl;dr: proposals should focus on how they’ll build MyServices, not project management.
A familiar un-favorite flavor of solicitation sins, this RFP just crams in too much stuff. The solicitation requires proposals to address three “activities”:
“Activity 1: Project Management and Implementation Support” is described for more than two pages.
“Activity 3: Reports and other Deliverables Associated with Software Releases and Maintenance of System Documentation” is a hair under two pages.
“Activity 2: Development Support to Maintain, Stabilize, and Enhance the Source Code of the MyServices System” gets half a page
The substance is lost in the sprawl. Activity 2 is where the common application actually gets built, but it’s just one of three activities the vendor is accountable for. It’s also just one of three activities vendors need to address in their bid. Responses have no page limits, so a thorough vendor could easily write a dozen pages about each activity. No wonder we’ve been stuck in contract purgatory for so long!
I feel bad for the evaluators who spent months assessing 30 vendors’ descriptions of how they “understood” their responsibility for “[f]acilitating daily communication with EOHHS Project Manager” (Activity 1), or their “ability to provide” a “Monthly Steering Committee Report” (Activity 3). The core competency we should hire contractors for is deploying a working benefits application, but vendors and government employees alike are getting sludged down by too much stuff.
Naturally, you need to pay for someone to manage engineers, document technical choices, and log bugs. If it’s not in the RFP, vendors may low-ball by omitting overhead costs for their bid. But an RFP could easily call out these required services without demanding that vendors share their philosophy for making burn reports or their worthiness to produce the 14 distinct project management outputs listed in Table 1. Besides, eligible vendors already had to prove their experience with government work to get on the ITS81 blanket contract. Pick the vendor who is best positioned to deliver a common benefits application; don’t waste time evaluating the rest.
Amid the “too much stuff,” some stuff is still missing. The RFP does not ask for any of the product management skills I described above, like user research or hacking bureaucracy to simplify eligibility. If those roles are being filled by government employees off-contract, all the better, but I fear those jobs aren’t getting done.
Everything bagel-ism vs. everything bagels
tl;dr: SNAP helps communities by putting food on everyone’s table. Vendors should focus on getting people SNAP, not passing profits onto small businesses.
Finicky evaluation metrics were my next thought – maybe Godot is waiting for the selection team to fill out an elaborate scoring rubric. But no, the section on “Response Evaluation” starts quite sensibly – proposals get a composite rating from “Excellent” to “Poor” based on several aspects (suggested approach, qualifications of key personnel, experience, etc.), and then assessed for whether their proposal offers good value for the proposed cost. Thorough without being burdensome, encourages vendors to submit alternative approaches, balances price vs. value instead of just accepting the cheapest bid. Good stuff!
Besides the vendors’ ideas for improving MyServices, “at least 25% of the available evaluation score must be dedicated to the evaluation of the bidder’s SDP Commitment” if you solicit bids off the ITS81 blanket contract. SDP stands for the Supplier Diversity Program, and the “commitment” is a requirement to spend at least 1% of contract sales with certified diverse businesses. Higher commitments receive higher scores.
Bids need to include an SDP Plan, shown above. Vendors already submitted an SDP Plan to get onto the blanket contract, but they could increase their commitment to help win this solicitation. The SDP Plan needs to list which certified business or non-profits a vendor will support if they win; what their relationship will be; how the partner was certified; and the total SDP percentage commitment.
It took me a beat to realize that SDP is not a set-aside or preference for small businesses. The SDP form clarifies in bold that “ALL Bidders” need to submit a supplier diversity plan, including certified diverse businesses. If you’re certified as a diverse business, can you propose yourself as an SDP Partner? Probably not. Can you register a second company, get it certified, and then partner with Totally A Different, LLC? Hmm…
First concern is the paperwork. If you’re heaping on forms and sales commitments, that’s extra hoops for smaller companies to jump through, extra spreadsheets clogging evaluators’ laptop screens, and extra compliance checkboxes for the contracting team.
The bigger issue is everything bagel-ism (paywall free link), where every government project is asked to solve every social issue at the same time:
You might assume that when faced with a problem of overriding public importance, government would use its awesome might to sweep away the obstacles that stand in its way. But too often, it does the opposite. It adds goals — many of them laudable — and in doing so, adds obstacles, expenses and delays. If it can get it all done, then it has done much more. But sometimes it tries to accomplish so much within a single project or policy that it ends up failing to accomplish anything at all.
Personally, I find Ezra Klein’s “everything bagel” metaphor less than clarifying – as the editorial continues, everything bagels are delicious “because they add just enough to the bagel and no more.”12 Everything bagels are so good that I think everyone should be able to buy them. And tens of thousands of families in Massachusetts could, if they weren’t being schmeared out of SNAP by contracts slower than molasses!
Dollars to donuts, the focus should be on building the common application as SNAPpy as possible. And instead of incentivizing bids to raise costs with higher small business commitments, let’s take any leftover dough and hire more caseworkers, so that applicants can complete their phone interviews and get a pizz’a the benefits they deserve.
When the moon hits your eye like a big KPI
tl;dr: focus on a few high-impact performance incentives, instead of 14 operational targets. Incentivize helping people, not just a pretty app with no users.
Food puns aside, “final contract negotiations” are the most likely culprit delaying an award, per the Globe article a month ago. Those negotiations are probably focused on KPIs (key performance indicators, or measures the contractor will be graded on once they start working), according to the RFP:
Bidders should describe how KPIs will be collected, shared, and reviewed for continuous improvement and propose metrics which can be included as KPIs. Please note, it is anticipated that KPI minimum service levels and associated financial crediting requirements will be the subject of negotiation for the SOW(s) resulting from this RFQ. [formatting kept from the original documents]
Minimum service levels make a lot of sense for IT contracts, and it’s good to pay for performance, too. This solicitation may go a step too far, though, by loading in 14 different KPIs, asking vendors to propose yet more, and then reviewing every metric annually for modifications. If you’re negotiating about 14 different KPIs, on three dimensions (definition, minimum service levels, financial crediting requirements), you’re already haggling over 42 fairly technical points. Given that no hands can touch keyboards to help people get SNAP until this contract is signed, the government should prioritize fewer KPIs in exchange for faster delivery and less overhead.
Counterargument: fewer KPIs mean the government’s accepting more risk. It’s true that without minimum standards for, say, “Number of Vendor executed regression test cases” (KPI #13), a vendor could deliver fragile software that breaks every week. To thread that needle, the final contract should set fewer, but better, KPIs. Right now, very few people use MyServices, because it doesn’t do anything useful. Failing to add essential functionality is a bigger risk than disrupting existing features.
The 14 starter-pack KPIs13 are predominantly concerned with preventing bugs and bad performance (KPIs 2, 4, 6, 7, 8, 11, 12, 13, 14) and completing project management documentation (1, 3, 9, 10). Just one KPI, #5, is based on user feedback, and the suggested method (pop-up surveys in the app) would only capture the people who open MyServices. The vendor’s incentive is to work as deliberately as possible, delivering crisp, clean software that no one uses.
Massachusetts allocated millions of dollars to build a common application. Let’s set a clear goal: deliver a working SNAP/MassHealth application in 6 months. Integrate an additional benefit program every year after that. The contract can describe what “working” means – and if you get it done, you should be paid for your success. If applicants and caseworkers say that MyServices 2.0 is making their life easier, that can be another incentive.
MA families have waited years for relief from the paperwork. It would be penny-wise, pound-foolish to make them wait longer.
What we can do
Clearly, my relationship to this project is an unusual one. If I didn’t decide to start writing about contracting, I’d barely know about it. Though I occasionally help my family with their benefits, the delay doesn’t really impact me.
Still, it’s sad, or maybe frustrating. Here we have a good idea, for a common application. There’s no opposition. Other states got it done a while ago. There’s even funding. But it’s been almost three years, nothing’s happened, and there’s no timeline for anything happening. Unlike my last post, “Alchemy for aliens”, we’re not wasting money,14 just time.
I’m not sure how I can help the common application along at this point. My best hope is to show legislators and civil servants that people really care about delivery, not just intention; and to raise awareness of the tradeoffs of the prevailing “big contract, everything bagel, move slowly” approach. I will email this article to my legislators and the original bill sponsors, as well as to the governor and agency heads. If you’d like to email your legislators, look up their info here. Let me know if you hear back, or you have other suggestions about levers we can pull.
Going forward, I’d like to build tools that help citizens advocate for effective delivery, by helping them follow along early in the process. My theory is that reviewing RFIs (Request for Information) or solicitations soon after they’re released and then writing in with constructive feedback might make a difference. I built the Sole Source Spotter on a similar idea, and I’d love to expand it to cover a wider range of notices, and state/local governments, too. If you want to work together on making this a reality, get in touch; if you’d like to support this work financially, shoot me a note or make a donation here.
Finally, please subscribe and share if you’d like to stay updated on this work. I’m truly grateful for all the feedback on my first post, and your encouragement absolutely helps me stay engaged with the bizarre workings of government management.
Currently up to $753/month for a family of two living in non-subsidized housing in Massachusetts, via Temporary Aid to Families with Dependent Children (you’re eligible for 24 months in a 5-year period); or $536 for groceries through SNAP… plus $20 extra for buying local produce!
Highly recommend donating to Greater Boston Legal Services, they do incredible casework and advocacy.
$18 million was allocated in July 2023 via the FY24 budget, and that was upped to $23.9 million for FY25 (which started last summer). In June 2023, the Mass Law Reform Institute celebrated the allocation of $18m in the FY2024 capital investment plan. The same item in the FY2025 plan was allocated $23.9m. The item is called “Integrated Eligibility and Enrollment Readiness”, described as “Planning to modernize and integrate the eligibility and enrollment process for state benefits agencies.” Emphasis added by me; per Sam Marullo’s post on Jennifer Pahlka’s blog, Planning isn’t progress.
Comment your wicked smaht suggestions for app names here on Substack, or email Gov. Healey.
An FAQ page was published September 27, 2023, and hasn’t changed much since then, according to Internet Archive
When I worked on Federal government procurement policy, I made a post on a government-wide knowledge sharing website, Open Opportunities. It basically said: I’m a data scientist, I analyze contracting policy, but I don’t know very much about government contracting. If you’re an acquisitions professional, come tell me what you do every day. And dozens of people volunteered to chat for 30 minutes, to share their experience and give feedback on my projects. I also had an open Google Calendar appointment schedule which I’d share with acquisitions groups, so they could easily set up meetings with me. I think I learned something from those conversations, hopefully you agree!
Unfortunately, Open Opportunities looks to have been axed recently, per this 404 page. I guess “knowledge sharing” or “learning how TF anything actually works” is woke now.
There are probably limitations on how funds in the capital investment plan can be used to hire employees, and it’s also often difficult for the public sector to hire. Let’s fix that!
Federal rules require an interview in order to receive SNAP. In Massachusetts, the interview is now usually over the phone. The Federal government sometimes grants individual states waivers, to test whether loosening certain practices make a program more effective.
A play by Samuel Beckett in which two men “engage in a variety of discussions and encounters while awaiting the titular Godot, who never arrives.” (Wikipedia)
I get seven months from the time elapsed between November 1, 2023 when the ITS81 solicitation opened, and June 20, 2024, the “entered date” on the Master Blanket Purchase Order for the relevant category on ITS81.
I usually go for straight poppy, though.
Listed here, if this blog isn’t long enough for you already:
“Percentage of Vendor resource staffed time of total capacity by role”
“Count of incidents/defects where resolution times exceeded standards, e.g. more than 24 hours for a critical item”
“Number of resource changes, including EOHHS requested resource changes, Vendor staff turnover, etc.”
“Count of deliverables not meeting Commonwealth acceptance”
“Average System Usability Scale (SUS) and/or Customer Satisfaction Score (CSAT) as measured via user surveys”
“Errors experienced by users”
“The count of minutes the system was unavailable due to an error or defect in the application”
“The count of webpage load times exceeding 3.8 seconds”
“Turnaround time on requests for project estimates/impact analysis”
“Number of Vendor assigned user stories/requirements committed to in a Sprint that were not delivered for testing by deadline (unless reprioritized by EOHHS)”
“Number of Defects identified in UAT and Production (not caused solely by acts/omissions of EOHHS)”
“Number of documented Vendor test cases associated with work prioritized in Sprints (across all testing areas, including automation)”
“Number of Vendor executed regression test cases”
“Number of failed or rejected deployments”
I’d argue that we are wasting a ton of money, by foregoing Federal dollars that are, for now, guaranteed. Closing one-twentieth of MA’s SNAP gap by enrolling 15,000 more families of two would add $90 million annually to MA’s economy. MA’s political leaders rightfully reject Republican attempts to cut SNAP benefits or add burdens on beneficiaries, but the poor follow-through on a common app has the same impact on our neighbors and the state’s economy.