Policy memo (214.64 KB)
| DATE: | August 8, 2024 |
| SUBJECT: | SNAP - Guidance for Improving State Agency Recertification Application Processing Timeliness Rates: Standardizing the Escalation Process |
| TO: | All SNAP State Agencies All Regions |
The purpose of this memorandum is to advise state agencies on the steps the Food and Nutrition Service (FNS) will take to monitor and engage state agencies with poor Supplemental Nutrition Assistance Program (SNAP) recertification application processing timeliness (RPT) rates. This policy is effective Jan. 1, 2025.
Low RPT rates have a real and significant impact on eligible households who struggle to put food on the table while their SNAP recertification applications are stalled. For households who depend on monthly SNAP issuance to make ends meet, an untimely recertification can affect their food budget as strongly as an untimely action on an initial application. State agencies must operate SNAP in a manner that ensures all eligible applicants receive benefits in a timely fashion. Timely recertification application processing is an essential element of good customer service and ensures households have access to essential nutrition assistance.
The Food and Nutrition Act of 2008 requires that households who file an application for recertification by the 15th day of the last month of the expiring certification period and complete all required actions are entitled to a decision by the end of their certification period. If eligible, the state agency must issue benefits to maintain the household’s normal date of issuance. While states agencies are required to process all SNAP applications within the timelines provided in the statute, FNS considers a FNS RPT rate of 95 percent and above acceptable performance.
The RPT measure, collected through the quality control process, historically captured both agency-caused and client-caused delays that result in untimely benefit issuance. FNS will continue to collect, disaggregate, and report RPT data broken down by agency and client-caused delays to provide state agencies with technical assistance in reviewing potential root causes for delays. However, to trigger the escalation procedures, FNS will remove client-caused delays when calculating the RPT rate and use only agency-caused delays to monitor state agency compliance with statutory requirements.
These recertification escalation procedures utilize the same 5-step approach as the Initial Escalation Procedures, issued Aug. 3, 2023. While the process (see Attachment 1) serves to standardize escalation procedures, FNS may deviate from this process when a state agency's FNS RPT rate is particularly egregious, or because of other circumstances in the state agency, such as large backlog or major systems issues.
There is built in flexibility for FNS to engage state agencies when FNS RPT rates fall below acceptable performance, while maintaining a standardized process. To appropriately target state agencies with chronic recertification timeliness issues evident at the time of this policy’s effective date, FNS will immediately proceed to a RPT corrective action plan when a state agency has a FNS RPT rate below 90 percent for the two most recent consecutive quarters of data available as of the February 2025 quarterly report.
FNS will use the FNS RPT rate to initiate escalation procedures, as this measure reflects how well the state is meeting statutory requirements for recertification timeliness for households who have completed all required actions. However, FNS may use data from either the state RPT rate or FNS RPT rate to release the state from escalation. The state RPT rate aligns with how states report recertification timeliness on the FNS 366-B, Program Activity Statement. The state RPT rate will consider whether a recertification application was submitted timely or untimely, and how well the state met the appropriate regulatory timeframe for processing that application. (See Attachment 2)
The recertification escalation procedures include engaging in technical assistance, setting state agency-specific benchmarks for improvement, guidance on calculating a state RPT rate, and data validation of state agency-generated RPT data. The suggested actions or requirements at each step of the escalation procedures are only examples; individual state agencies may be directed to follow alternative processes.
State agencies with questions should contact their regional office representatives.
Moira Johnston
Acting Director, Program Development Division
Supplemental Nutrition Assistance Program