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Revised Non-Merit System Personnel Guidance for Call Centers

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As of Feb. 6, 2020, this guidance is no longer current. Please visit here for guidance
that was released on that date.

DATE: December 19, 2017
SUBJECT: Revised Non-Merit System Personnel Guidance for Call Centers
TO: All Regional Directors
Supplemental Nutrition Assistance Program

As part of the U.S. Department of Agriculture’s (USDA’s) effort to increase cooperation with states to improve customer service, I would like to inform you about new flexibilities within the Supplemental Nutrition Assistance Program (SNAP) to assist in streamlining program administration within call centers. As you know, many states are moving toward greater integration among human service programs and are looking for better ways to merge their operations across programs to improve administrative efficiency and customer service. USDA’s Food and Nutrition Service (FNS) supports these innovative approaches.

SNAP is unique among federal programs in that the law requires states to use merit system personnel to certify applicant households. Specifically, the Food and Nutrition Act of 2008, as amended, and SNAP regulations require SNAP certification interviews and eligibility determinations to be conducted by state merit system personnel. FNS guidance released in recent years has further clarified the specific functions reserved for merit and non-merit system personnel. For instance, previous guidance has permitted states to use contractor staff, with FNS approval, for a limited set of functions related to SNAP participant contact like providing applicants or participants with general program information, office locations and referrals.

Consistent with USDA’s efforts to increase state flexibility within the bounds of the law, FNS is expanding allowable activities for states seeking to use non-merit system personnel in call centers. With FNS approval, states may now use non-merit personnel to provide basic case-specific information that is readily available in the system to a SNAP applicant or participant, such as application or case status, benefit issuance date, and status of submitted verifications. States have indicated this flexibility will provide improved customer service, reduce applicant and participant wait times, decrease workload on merit personnel staff, and allow for better coordination across multiple human service programs.

Accordingly, we are issuing a revised SNAP Call Center Support Policy, a copy of which is attached to this document. Please note that states must continue to request FNS approval to use non-merit system personnel in any of the indicated capacities. As before, states have the flexibility to use contractor staff for activities that do not involve SNAP participant contact, such as data entry and scanning without requesting FNS approval.

Please note that, as before, contractor staff will not be allowed to alter a SNAP applicant or participant’s case status or make any case changes, regardless if the contractor is working in a call center or in some other role. In addition, the SNAP interview and eligibility determination remain a merit system personnel responsibility, consistent with statute and regulation.

FNS would also like to remind states that, under the recently implemented Major Changes Rule at 7 CFR 272.15, the implementation of a call center or changes in the use of merit system personnel are considered by FNS to be a major change in program design. Pursuant to the rule, states are to inform FNS of an anticipated major change 120 days prior to its implementation.

FNS looks forward to reviewing any requests from states and working to ensure that our programs are run in the most efficient manner while maintaining a high level of customer service for SNAP households.

Lizbeth Silbermann
Program Development Division
Supplemental Nutrition Assistance Program


Page updated: December 03, 2021

The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.