| DATE: | August 2, 2023 - Updated August 1, 2024 (see clarification) |
| SUBJECT: | SNAP - Updated Guidance for Improving State Agency 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) initial application processing timeliness (APT) rates. This memo replaces guidance from the memorandum dated March 18, 2016, Guidance for Improving State Timeliness Rates and Standardizing the Escalation Process.
Low APT rates have a real and significant impact on eligible households who struggle to put food on the table while their SNAP applications are stalled. Delays in receiving benefits are especially detrimental to households entitled to expedited service, who are most in need of immediate food assistance. While households may turn to food banks or other resources in times of hardship, SNAP remains one of our country’s strongest defenses against hunger. State agencies are required to operate the program in a manner that ensures all eligible applicants are certified to receive benefits in a timely fashion. Timely application processing an essential element of good customer service and ensures households have access to essential nutrition assistance.
The Food and Nutrition Act of 2008 (the FNA), requires that households have the opportunity to participate in SNAP within 7 days for expedited cases and 30 days for regular cases. While states agencies are required to process all SNAP applications within the timelines provided in the statute, FNS considers an APT rate of 95 percent and above acceptable performance.
FNS has long monitored APT rates as part of its oversight responsibility to ensure state agency compliance with SNAP program requirements under 7 CFR 275.3. FNS has also required corrective action when state agencies or FNS have identified deficiencies in APT. In 2014 and again in 2016, FNS streamlined and formalized its escalation process to identify poor performing state agencies and promote significant improvements in state agencies with APT rates falling below 90 percent on the upper bound of the 95 percent confidence interval.
For many reasons, including the suspension of certain quality control (QC) requirements in response to the COVID-19 public health emergency (PHE), FNS has lacked available data to follow the escalation process over recent years. FNS recognizes that the PHE presented unique circumstances for our state agency partners, which resulted in poor timeliness across the nation. While FNS’ previous escalation procedures provided a standardized process to address poor timeliness, they did not provide for or envision circumstances regarding the technical assistance and flexibility required as state agencies exit from the unprecedented COVID-19 pandemic and continue to face staffing and technology issues. Accordingly, FNS is revising its escalation procedures to better reflect the current realities on the ground.
The updated escalation procedures, effective Oct.1, 2023, build in some flexibility for FNS to engage state agencies when APT rates fall below acceptable performance while maintaining a standardized process. Updates to the escalation procedures include engaging in technical assistance earlier, setting state agency-specific benchmarks for improvement, and data validation of state agency-generated APT data.
While the process outlined in this memo serves to standardize escalation procedures, FNS may deviate from this process when a state agency's APT rate is particularly egregious, or because of other circumstances in the state agency, such as a large backlog or major systems issues. In these cases, FNS may proceed directly to the process under 7 CFR 276.4(d). In addition, 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.
In order to appropriately target state agencies with chronic timeliness issues, FNS will deviate from the escalation procedures and immediately proceed to an APT CAP when a state agency has a FNS QC APT rate below 85 percent for the two most recent consecutive quarters available as of Oct. 1, 2023.
State agencies with questions should contact their regional office representatives.
Moira Johnston
Acting Director, Program Development Division
Supplemental Nutrition Assistance Program