Under Secretary Kevin Concannon sent a letter to all state SNAP Commissioners on Nov. 20, 2009 setting forth the Department's concern that outsourcing functions of the SNAP intake and application process has resulted in more complex and cumbersome enrollment procedures that have not furthered the mission of the program. Additional guidance intended to identify those areas of program administration that require review and approval from FNS as a condition of federal financial participation (FFP) was issued on Jan. 22, 2010.
Section 11(e)(6) of the Food and Nutrition Act of 2008 (Act) and CFR 272.4(a)(2) restricts SNAP certification interviews and final decision on eligibility determination to state merit system personnel. The January 2010 guidance memo further restricts tasks that involve any client contact to merit system personnel. The guidance requires states to seek approval from the Food and Nutrition Service (FNS) to use non-merit system personnel to interact with clients in a restricted capacity that is compliant with the Act, such as providing clients application assistance or case status information, in order to ensure continued Federal Financial Participation (FFP) support.
A number of states and regional offices have approached FNS with further questions about the use of non-merit staff in the SNAP application and recertification process. These questions primarily revolved around the use of temporary non-merit staff and staff funded with non-SNAP funds. The following Questions and Answers are meant to further clarify questions raised by states and regional offices and also expand upon prior guidance.
Program Development Division