Section 11 of the Food and Nutrition Act of 2008 (the Act) (7 USC.2020), as amended, requires the Department to develop standards for identifying major changes in the operations of state agencies that administer SNAP. Regulations at 7 CFR 272.15 require state agencies to notify the Department when planning to implement a major change in operations and to collect any information required by the Department to identify and correct any adverse effects on program integrity or access, including access by vulnerable households.
7 CFR 272.15(a)(2) outlines the categories of major changes to include:
- The closure of a local office,
- Substantial increased reliance on automated systems,
- Changes in operations that potentially increase difficulty for household reporting,
- The reduction or change of functions or responsibilities assigned to merit system personnel,
- A decrease in the number of merit system personnel involved in the SNAP certification process, or
- Other major changes identified by FNS.
States make such changes in operations based upon a variety of interrelated factors.
As decisions to make major changes to program operations rest with each individual state agency, the frequency and timing of the changes can only be estimated. Prior to any major change to state operations, regulations at 7 CFR 272.15(a)(3) require state agencies to provide descriptive information to FNS via email regarding the major change together with an analysis of its projected impacts on program operations. The regulations also set out requirements for the state to collect and report monthly state-level data on application processing metrics, beginning with the quarter prior to implementation of the major change. This data must be reported separately for elderly and/or disabled households.
This data is submitted on a quarterly basis to FNS via email. Reporting continues for at least one year after the change is completely implemented. Regulations at 272.15(b)(4) give FNS the authority to request additional data beyond the mandatory data reporting elements outlined at 272.15(a)(3). For example, depending upon the nature of the major change, states may be required to report more specific or timely information concerning the impact of the major change on payment accuracy, which could involve additional caseload data focused on households with specific characteristics.
FNS will work with states to determine what additional information is practicable and require only the data that is necessary to evaluate the impact of the major change. FNS national office and regional offices use data from states that are currently subject to Major Change Reporting to provide additional technical assistance to those states when needed. This information enables FNS to monitor the impact of states' changes and identify compliance and/or performance issues early.