During this phase, the vendor builds the technology. This can include technical testing, input from agency staff, and piloting the system to assess its functionality and impacts. At this phase, advocates have identified flaws and bugs in the technology, as well as helped to conduct pilot tests to compare how the new tool works compared to the existing systems.
Are we missing any information sources, ways to participate, or case studies at the Building phase? Let us know using our contact form!
In the Building phase, formal sources of information are limited, making it difficult for advocates to know that an agency is working on benefits tech. It’s useful to highlight these information gaps so that advocates can demand more information throughout the lifecycle and intervene before harmful technology is used.
- Public records request: By the time benefits tech reaches the Building phase of the lifecycle, the agency will have developed a record of internal communications and communications with vendors about the purpose and design of the system. This could include emails, meeting notes, contracts, design specifications documents, etc. These are all documents that you can request through a public records request, often known as a Freedom of Information Act (FOIA) request, also sometimes called a Public Records Act (PRA) request or a Freedom of Information Law (FOIL) request. Check out our Public Records Request Guide for more information about this process and how to use it to learn more about benefits tech.
- Federal approval: For some benefits with federal funding (especially Medicaid and SNAP), state agencies might have to get approval from federal agencies to implement changes involving benefits tech. This usually involves a formal application the state agency completes and submits to the federal agency, which should be available through a public records request. In some cases, the federal agency might require the state agency to get input from people who receive benefits, their advocates, or the wider public.
- Promulgation: To implement certain kinds of changes involving benefits tech (especially those that will affect what benefits people receive and how much), the agency has to go through a formal process of publishing the proposed changes called “promulgation” or rulemaking. Here, the agency is required to share information with the public about the changes. The exact requirements vary from state to state, but common information includes the purpose of the changes, the projected costs, and the advantages and disadvantages of the changes. Promulgation often requires a chance for members of the public to give their thoughts on the changes through written comment or public meetings (see the ways to participate below). The agency may also have to provide information to the state legislature, which may also hold public hearings to approve the changes.
Ways to Participate
The list below highlights ways that advocates and people getting benefits can participate in the Building phase of the lifecycle. As with information sources, the ways for advocates to participate in shaping benefits technology are limited, especially early in the lifecycle. We seek to increase meaningful participation mechanisms throughout the lifecycle. This includes demanding more robust formal mechanisms as well as developing strategies for informally influencing the benefits tech lifecycle to prevent harmful benefits tech, or at least mitigate negative effects.
- Public comment: As part of the promulgation and federal approval processes we mentioned in the information sources above, you may be able to submit public comments in response to agencies posting proposed changes to the administration of benefits. Check out our Public Participation Advocacy Guide for tips on engaging in the public comment process.
- Agency meetings: Advocates can push for meetings with the agency to learn more and raise concerns. If you get information from a public records request that is concerning, you can raise the issue with the agency or otherwise advocate for changes.
- Media: Traditional and social media can be useful ways to put pressure on the agency and legislature to test and pilot benefits tech they are building or address other concerns. Check out our Media Advocacy Guide for tips.
- Community advocacy: Various interest groups affected by the agency’s decisions will often be in communications with the agency about possible changes. They often hold informal meetings. Having allies in those groups may get you an invitation to a meeting or, at least, information about what was discussed. If those groups’ goals match what’s best for people on the program, there may be a chance to work together. Check out our Community Building Advocacy Guide for more suggestions about working with community groups to push for changes to the benefits tech during the Building phase.
The following case studies are about challenges to benefits technology that began at the Building phase of the lifecycle.
In 2018, the Missouri Department of Health and Senior Services (DHSS) proposed a new algorithm for determining qualification for home and community based services (HCBS).
This guide will help you start piecing together why and how benefits tech is being used and how it is impacting people.
This framework provides strategies for resolving different types of technology problems, based on our experiences.
This guide will help you think through how you can use public records requests to help find out why the state decided to implement a benefits technology system, how they implemented it, and how they are using it.
This guide talks about ways that people impacted by benefits technology and advocates can use the public participation process to fight harmful benefits technology.