Approval of Supplemental Nutrition Assistance Program Outreach Plans

This memorandum sets forth Supplemental Nutrition Assistance Program (SNAP) State Outreach Plan approval policies. This guidance is based upon a similar memo regarding SNAP Employment & Training (E&T) Plans, issued May 30, 2012.

Starting in fiscal year (FY) 2015, the Food and Nutrition Service (FNS) will no longer provide conditional approval of state outreach plans. FNS has found that conditional approvals pose additional and unnecessary administrative burdens to state agencies and to FNS. Therefore, regional offices (ROs) should only approve outreach plans in full or in part. ROs should deny state outreach plans that are wholly unacceptable.

FNS will not release 50 percent federal reimbursement funds to a state agency's letter of credit without an approved outreach plan in place. Further, state agencies cannot claim outreach reimbursements or draw from the state letter of credit without an approved outreach plan in place.

Please apply this guidance in the review and approval of FY 2015 plans, which are due Aug. 15, 2014. Please share this guidance with your state agencies.

Annual Outreach Plans

State outreach plans for each fiscal year are due by Aug. 15 of the prior year. To ensure plans are approved and implemented at the start of each federal fiscal year (Oct. 1), FNS encourages state agencies to:

• Submit plans early, but no later than Aug. 15;
• Use suggested formats and any optional templates provided in the Outreach Toolkit;
• Be as short and concise as possible, while still being responsive to guidance in the Outreach Toolkit; and
• Consider submitting a multi-year outreach plan.

The SNAP Outreach Toolkit is located at the following link: https://www.fns.usda.gov/snap/outreach.

Upon receipt of an outreach plan, the FNS RO has until Sept. 30 to approve, deny, or request additional information. While most state agencies have their plans approved by Oct. 1, some state agencies begin the new fiscal year without approval of all aspects of their plans. Additional clarifications are sometimes necessary due to lack of clarity, documentation, or essential information.

FNS will approve a plan in full, in part, or not at all. If only portions of the plan are approvable, FNS will approve those portions. FNS will no longer provide contingent approval as a valid approval option.

After approval, state agencies may proceed with approved activities with full assurance that they will be reimbursed. state agencies choosing to start activities without FNS approval risk not receiving reimbursement for these activities. FNS will not consider retroactive reimbursement of outreach activities that are not approved on or before Sept. 30.

Plan Amendments

The state agency must submit plan revisions to its RO for approval prior to implementation of the planned activities. Prior approval is required when a plan amendment alters the nature or location of components.

Examples include:

• Major changes in components (e.g., adding, deleting, or modifying a component)
• Significant changes in state policy (e.g., major changes to state outreach rules)
• Requests for additional 50 percent federal reimbursement funds
• Changes in the location of approved activities or in the community partners conducting the work.

Examples of Plan Submission and Approval Scenarios

1. Approval of a Timely Received Plan - The state agency submits an approvable plan on Aug. 15 and the RO approves it on or before Sept. 30. Cost reimbursement begins Oct. 1.
2. Approval of a Timely Received Plan Requiring Clarification - The state agency submits a plan on Aug. 15 that contains components that are not clear or not approvable. On Sept. 30, the RO grants approval of the approvable components and invites the state agency to submit clarifying information for the denied components. Cost reimbursement for the approved components begins Oct. 1. Clarifying information is submitted to the RO on Nov. 15. The RO reviews the clarifying information--as time allows--and approves the revised components of the plan on Dec. 31. Full cost reimbursement begins Jan. 1.
3. Approval of an Untimely Submitted Plan - The state agency submits an approvable plan on Nov. 15. The RO reviews the plan as time allows and approves it on Dec. 31. Cost reimbursement begins Jan. 1.
4. Approval of an untimely Submitted Plan Requiring Clarification - The state agency submits a plan on Nov. 15 that contains components that are not clear or not approvable. The RO reviews the plan as time allows and grants approval of the approvable components on Dec. 31. Cost reimbursement for the approved components begins on Jan. 1. With its partial denial, the RO invites the state agency to submit clarifying information for the denied components. Clarifying information is submitted to the RO on Dec. 1. The RO reviews the clarifying information as time allows and approves revised components of the plan on Jan. 31. Full cost reimbursement begins Feb. 1.

Lizbeth Silbermann
Director
Program Development Division