SNAP - QC System Resumes Nationwide July 2021: Expectations, Special Review Procedures and Optional Face-to-Face Interview Waiver

Section 4603(a)(2) of the Continuing Appropriations Act, 2021 and Other Extensions Act (PL 116-159), as amended by the Consolidated Appropriations Act, 2021 (PL 116-260) allowed state agencies to suspend QC sampling and reviews from June 1, 2020, through June 30, 2021. Beginning with the July 2021, sample month, state agencies are expected to resume regular SNAP QC operations.

This memo provides guidance regarding the resumption of regular QC operations.¹ In addition, there are two attachments to this letter.

Attachment 1

• Includes information on special review procedures specific to coding FNS form 380-1 regarding the temporary increase in SNAP benefits provided in the above referenced legislation and The American Rescue Plan Act of 2021 (PL 117-2).
• Provides details on how to implement the variance exclusion for the student eligibility provisions in PL 116-260.

Attachment 2

• Includes information for requesting a blanket waiver to allow state agencies to conduct a telephone interviews in lieu of the face-to-face interviews for QC.

To prepare for a return to regular QC operations beginning with the July 2021, sample month, please review the following reminders and expectations:

Sampling and Review Process

• Cases must be sampled and reviewed in accordance with all governing laws, including but not limited to: Section 16(c) of the Food and Nutrition Act of 2008, as amended, and SNAP regulations at 7 CFR 275. Food and Nutrition Service (FNS) SNAP policy memos and handbooks, including the FNS Handbook 310 and FNS Handbook 311, provide clarification on these requirements
• State agencies must resume enforcement of penalties for households that refuse to cooperate with QC reviewers found in 7 CFR 275.12(g)(1)(ii).

Evaluations of QC Data

• Completion rates will be calculated for FY 2020 and FY 2021. FY 2020 will be based on five months of reviews (October 2019-February 2020) and FY 2021 will be based on three months of reviews (July-September 2021).
• State reporting monthly charts will resume when QC resumes. However, per the FNS guidance issued on Feb. 19, 2021, no annual state or national payment error rates will be announced for FY 2020 or FY 2021.

Avoiding Bias

• State QC employees reassigned during the QC suspension to make eligibility determinations, are not permitted to conduct the QC review for any cases they performed eligibility actions on per regulations at 7 CFR 275.2(b).
• State QC must ensure any policy inquiries sent to state eligibility policy counterparts, to clarify the correct application of policies, do not include QC case specific details.
• FNS is ready to provide technical assistance to state agencies as they seek to maintain operations and serve clients during the current public health emergency.

State agencies with questions should contact their respective regional office representatives.

Ronald K. Ward
Director
Program Accountability and Administration Division
Supplemental Nutrition Assistance Program

Attachments

• Special Review Procedures Due to Recent Legislative Actions
• QC Face-to-Face Interview Waiver for July 2021 - Dec 2021 Flexibility to Allow Telephone Interview in Lieu of Face-to-Face Interviews for Quality Control Case Reviews

¹ QC operations are covered under the following approved OMB information collections: 0584- 0074, 0584-0034, 0584-0299, and 0584-0303.