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Operational Considerations

Key considerations for interviews include the use of call centers, non-merit pay staff and how to provide services to LEP individuals.

Interviews from Call Centers

Advancements in technology and business process innovations, including the use of call center staff to conduct interviews, can give you more options to serve households and improve administrative efficiency and effectiveness while continuing to meet federal requirements. For states that establish call centers, the centers must be fully functional, be appropriately staffed, have the system capacity to handle a large volume of calls, and be able to measure essential aspects of customer service(for more information about on-demand waivers, see Waivers).

  • The implementation of a call center, including any change in the functions or responsibilities currently assigned to state employees, is considered a major change. 7 CFR 272.15
  • States are required to submit a Major Changes Notification at least 120 days before implementing a major change.
  • We will review the submission and, if the change is considered a major change under the rule, respond with the state’s necessary reporting requirements.

Use of Non-Merit Pay Staff to Interview

State employees hired under a merit system are the only employees who may conduct SNAP certification interviews and determine eligibility. 7 CFR 272.4(a)

While non-merit staff cannot conduct the actual interview, we have provided guidance on tasks they can complete, with our approval. See Revised Guidance for Use of Vendor/Private Staff in Call Centers: 2020 Update.

Language Services for LEP Households

States must provide LEP households with bilingual personnel during the interview if a substantial number of households with low income speak the same non-English language (and who do not contain adults fluent in English as a second language) in that area of the state. The state must meet its obligations under Executive Order 13166 and Title VI of the Civil Rights Act of 1964 by supplying competent language services to all LEP households free of cost. 7 CFR 272.4(b), 7 CFR 273.2(e)(2)(iv)

Generally, it is not acceptable to rely on an individual’s family members or friends to provide interpreter services. In rare emergency situations, the state or recipient may rely on a person’s family members or other persons whose language skills and competency in interpreting have not been established.