| DATE: | December 14, 2010 |
| SUBJECT: | 2008 Farm Bill Proposed Rule on SNAP Eligibility, Certification, and Employment and Training Provisions |
| TO: | Assistant Secretary for Civil Rights |
This responds to your memorandum of Aug. 13, 2010, in which you discussed the additional requirements necessary to receive your complete concurrence of the proposed rule, Supplemental Nutrition Assistance Program (SNAP): Eligibility, Certification, and Employment and Training Provisions of the Food, Conservation, and Energy Act of 2008. The additional requirements included a detailed outreach plan that describes the specific method(s) to notify minorities, women, and/or persons with disabilities of the proposed rule and the specific method(s) by which the effectiveness of the outreach activities will be determined.
To discuss these additional requirements, a meeting was held on October 7, 2010, between representatives of the Food and Nutrition Service (FNS) and the Office of Civil Rights, Policy Division, Office of Compliance, Policy and Training, at Park Office Center, Alexandria, Virginia. Discussion focused on the federal/state administration of SNAP and how this affects FNS' outreach and monitoring activities. Although SNAP is a federally-funded program based on Federal statute and regulations, state agencies administer the program at the state and local levels by conducting outreach to low-income households, taking applications and determining eligibility and benefit levels. SNAP regulations are directed to state agencies, which incorporate new regulatory requirements into their operations of the program. Similarly, FNS provides funding to state agencies to conduct outreach efforts to low-income households including those in the protected classes. FNS, through its seven regional offices, maintains a robust review schedule of state and local SNAP operations to determine compliance with federal program requirements and civil rights laws. FNS extrapolates information about household characteristics and average benefit levels from individual case record reviews and other national data sources.
As a result of this discussion, it was agreed that in lieu of the detailed outreach plan and evaluation of the outreach specified in your Aug. 13, 2010 memorandum, FNS would provide additional information that describes how the agency's combined efforts of outreach funding, monitoring, and national evaluations function to help ensure equal treatment for minorities, women, and persons with disabilities. This information is attached.
Kevin W. Concannon
Under Secretary
Food, Nutrition, and Consumer Services