| DATE: | August 2, 2021 |
| SUBJECT: | Supplemental Nutrition Assistance Program (SNAP) – Use of Virtual Disaster SNAP (D-SNAP) Operations in Remainder of FY 2021 and FY 2022 |
| TO: | All SNAP State Agencies All Regions |
Traditionally, state agencies conduct the Disaster Supplemental Nutrition Assistance Program (D-SNAP)1 via an entirely in-person application and interview process. Since the onset of the COVID-19 pandemic, the Food and Nutrition Service (FNS) has approved novel virtual components of D-SNAP operations as states were forced to shift to fully virtual or hybrid models to ensure social distancing. These novel operations used a mixture of methods and relied on virtual elements to varying degrees.
This memo provides states with information about how FNS will evaluate requests to use virtual components in D-SNAP operations for the remainder of FY 2021 and FY 2022 when necessary due to the COVID-19 pandemic. Additionally, this guidance provides states with best practices to ensure virtual D-SNAP operations do not compromise program access or integrity. Until more data are available regarding the effect of virtual D-SNAP on program access and integrity, FNS cannot determine if virtual D-SNAP operations should be widely used outside the context of COVID-19 or formalized in D-SNAP plans.
D-SNAP requests for the remainder of FY 2021
FNS expects virtual components in D-SNAP operations may be needed through the remainder of FY 2021 as state agencies continue to address social distancing needs and adapt to the COVID19 pandemic. State agencies may continue to request virtual components as needed, on a case-by-case basis. This is a continuation of FNS’s current practices.
D-SNAP state plans for FY 2022
FNS does not plan to provide general authorization for virtual operations in the FY 2022 D-SNAP plans due to the current lack of data to evaluate the impact of these models. States are not expected to include a plan for virtual operations in their FY 2022 D-SNAP plans.
D-SNAP requests in FY 2022
As in FY 2021, FNS will continue evaluating virtual D-SNAP components as part of individual D-SNAP requests on a case-by-case basis in FY 2022, until FNS can make a well-informed decision about the feasibility of virtual D-SNAP operations outside the context of the COVID-19 pandemic. Attachment 1 provides a list of capabilities FNS recommends state agencies have to address or mitigate common challenges in virtual D-SNAP operations, based on lessons learned throughout the COVID-19 pandemic. FNS expects states requesting to operate D-SNAP with virtual components in FY 2022 to demonstrate consideration of all the Tier 1 capabilities and at least three of the Tier 2 capabilities outlined in Attachment 1, to the extent possible while maintaining any needed social distancing requirements. FNS recommends that D-SNAP requests describe how the state agency will meet the goals of both tiers and what other practices they will employ to ensure access and program integrity are maintained. In practice, FNS expects requests will cover all of the goals of the Tier 1 capabilities and at least three of the Tier 2 capabilities. FNS will work with state agencies to develop alternative solutions and strategies if these benchmarks are not achievable in the context of a specific disaster.
Virtual D-SNAP Operations
FNS is not prescribing a specific model for virtual D-SNAP operations. D-SNAP is designed to be flexible and adaptable to meet the needs of the population served and the size, scope, and scale of the disaster. When determining how to operate virtual D-SNAP, states need to consider potential technological challenges and program access barriers to successfully conduct a virtual D-SNAP operation. To ensure these challenges do not negatively affect access to D-SNAP for eligible households or program integrity, FNS recommends that the state agency have certain capabilities to address or mitigate common challenges. These capabilities are described in detail in Attachment 1.
States should assess whether they are likely to experience any of the common challenges associated with virtual D-SNAP outlined in Attachment 2. In particular, FNS is concerned about ensuring equitable access between urban and rural areas, and for households that may struggle with telephonic or online D-SNAP processes (including the elderly, individuals experiencing homelessness, and individuals with disabilities). If states lack any of the listed critical capabilities to address a given challenge as described in Attachment 2, the state should indicate the alternative method it will use to address the associated challenges in its D-SNAP request for FNS review.
FNS is available to assist state agencies in developing D-SNAP plans and requests to respond to disasters during the COVID-19 pandemic. We also encourage states to continue sharing evaluation reports, best practices, and challenges to improve evaluation of novel virtual D-SNAP models.
State agencies with questions should contact their respective regional office representatives.
Jessica Shahin
Associate Administrator
Supplemental Nutrition Assistance Program
Attachments
1 Activities associated with operating D-SNAP are approved under Office of Management and Budget Control Numbers 0584-0336 and 0584-0037