Policy Options

You have flexibility in how you administer SNAP. However, you should review the effectiveness of your eligibility interviews and processes to ensure program integrity. Regarding interviews, you are encouraged to conduct face-to-face interviews. You may also provide telephone interviews and accept telephonic and gestured signatures. You should carefully evaluate your use of telephone interviews and ensure they are used appropriately. These policy options are provided by regulation and do not require a waiver.

Telephone and Face-to-Face Interviews

You may conduct face-to-face interviews at the SNAP office or other mutually acceptable locations, including a household’s residence. While not common, if an interview will be conducted at the household’s residence, you must schedule it in advance with the household. You have the option to use telephone interviews for all applicant households, for specified categories of households, or on a case-by-case basis because of household hardship situations, as determined by the state. 7 CFR 273.2(e)(2)

• A state that chooses to interview households by telephone instead of the face-to-face interview must specify this choice in its State Plan of Operation and describe the types of households that will be routinely offered a telephone interview in place of a face-to-face interview.
• You must inform each applicant of the opportunity for a face-to-face interview at the time of application and recertification.
• You must grant a face-to-face interview to any household that requests one, even if you have elected the option to routinely provide telephone interviews.
• You must provide any household that meets hardship criteria a telephone interview.
• The hardship conditions include illness, transportation difficulties, care of a household member, hardships related to residency in a rural area, prolonged severe weather, or work or training hours that prevent the household from participating in an in-office interview.
• You may provide a home-based interview only if a household meets the hardship criteria and requests one.
• The use of telephonic interviews may not affect the length of a household’s certification period.

Telephonic and Gestured Signatures During an Interview

You have the option to accept telephonic signatures or gestured signatures for individuals unable to provide spoken assent. Gestured signatures mean a household’s attestation or assent through a purely visual language, such as American Sign Language. 7 CFR 273.2(c)

• You cannot force any household to use unwritten signatures.
• If you choose to explore this option, we recommend that you first consult legal counsel to verify that the verbal assent constitutes a valid signature under state law.
• This state option applies to applications submitted at initial certification and recertification.
• This state option allows people with less acute vision, less acute hearing, or limited mobility to apply more easily, and allows you to accept applications and conduct interviews with less administrative burden.
• If you choose to adopt this option, it must specify in your State Plan of Operations that you have accepted this option.
• When an application is being taken over the phone simultaneous with the interview, you must treat the date of the spoken signature as the date of application. In addition, you must allow the household the opportunity to review all information taken orally and make corrections as appropriate.
• Your system for accepting spoken signatures must comply with SNAP’s bilingual requirements for the use of appropriate bilingual personnel and printed material in the administration of the program.