tem. Although it is not clear why certain groups benefit disproportionately in the welfare system, it is certainly arguable that the method of welfare allocation is a root cause. Most states had unexplainable residuals with magnitudes and patterns over time when examined on an annual basis that indicate a non-random cause. Where people have discretion in promoting a program, evaluating need, or determining benefits, especially in complex systems, unintended side effects such as bias may easily arise. The delivery system itself can cause problems.