FNS Program Guidance on Human Pandemic Response

The U.S. Department of Health and Human Services (HHS) is the lead federal agency for federal pandemic response. Federal interagency partners support HHS, as requested, to assist state, local, tribal, and territorial partners in their pandemic preparedness and response activities. In some cases, responding to a public health emergency such as a human pandemic will require social distancing by keeping people from gathering in groups, including keeping children home from school and childcare in order to slow the spread of an infection.

FNS nutrition assistance programs have a role in responding to nutrition assistance needs during a human pandemic. Flexibilities already exist in some of the nutrition assistance programs that could support social distancing measures during a human pandemic such as alternatives to schools meals and mailing or electronic transmission of benefits.

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Automatic State Flexibilities

All USDA/FNS nutrition assistance programs, including SNAP, WIC, and the child nutrition programs, have flexibilities that allow them to respond to on-the-ground realities and support response and recovery efforts.

These programs are primarily administered at the state level and operated locally; states have a number of flexibilities that they may use without further approval from USDA to address the needs of participants during a public health emergency including:

  • In SNAP, state agencies can allow applications online (including via mobile app), by mail, or telephone, can extend certification periods to the maximum available, and can streamline the program by exempting households from certain requirements for good cause.
  • In WIC, states may postpone certain lab tests for up to 90 days, extend certification periods for up to 30 days, and provide up to three months of benefits in advance.
  • In school meals and other child nutrition programs, states may combine operations from multiple entities to serve and claim meals at a centralized location and expedite approval of summer feeding sites that may operate during unanticipated school closures.
  • In the food distribution programs, states have flexibility to adjust for the types of commodities provided in The Emergency Food Assistance Program (TEFAP), and to provide deliveries to homes or other convenient pick-up points, or allow participants to have a trusted representative pick up their food packages from the Food Distribution Program on Indian Reservations (FDPIR) or the Commodity Supplemental Food Program (CSFP).

Additional USDA Authorities

Even without a disaster declaration, USDA may grant waivers from certain program requirements. These options are even more robust in the event of a Major Presidential Disaster Declaration allowing individual assistance:

  • In SNAP, USDA/FNS can explore additional opportunities and flexibilities to help states streamline program administration and provide access for SNAP participants.
  • In WIC, in certain limited situations, a state or local area agency may conduct certification online or by phone. In addition, documentation requirements for initial certification may be waived in limited instances when they present an unreasonable barrier to participation. When a federal major disaster declaration has been issued, states may request approval to substitute certain food package items with similar items when WIC approved foods are unavailable. States are encouraged to contact FNS with questions regarding these requirements.
  • In school meals and other child nutrition programs, USDA can waive the requirements that meals are served in group settings, allow meals to be served at school sites during unanticipated school closures, allow school program operators to modify meal components or service times, and waive certain administrative requirements. When a Federal Major Disaster Declaration has been issued, USDA can allow summer and child care operators to modify meal components, and waive additional administrative requirements.
  • In the food distribution programs, USDA can allow state flexibility to set TEFAP income eligibility, certification duration, method of certification, and residency requirements, and in major Presidential disaster declarations allowing individual assistance and certain other emergency situations, allow states to provide a household commodity distribution program without verification of residency or income.

Partnering to Ensure Access to Food

States can employ these flexibilities as they develop a pandemic response strategy customized to the needs of their respective populations. They are encouraged to work with local public health officials, in coordination with other federal, state, and local programs, to understand the conditions and constraints under which these may be most appropriate and effective.

In addition, many USDA nutrition assistance programs have contingency funds and other reserve funding to cover any increases in enrollment that may result from an outbreak or pandemic. USDA always stands ready to work with Congress if additional resources are needed.

USDA Information
Federal Resources
03/13/2020