August 18, 2022
During COVID-19, U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) has had enhanced authority from Congress to grant state SNAP agencies greater flexibility on enrollment procedures. In new policy guidance, FNS has clarified that, even after the COVID-19 Public Health Emergency Declaration (PHE) and its enhanced authority ends, it can use its normal waiver authority to approve requests for continuation of some of those workarounds.
Promoting Effective and Efficient Administration
As we discussed in an earlier FRAC Chat, increased need and demand for services in the pandemic, coupled with greater use of remote operations, presented challenges for conducting Supplemental Nutrition Assistance Program (SNAP) enrollment. SNAP state administrators have reported that “certification and interview adjustment waivers were critical for managing caseloads, removing barriers to enrollment for new SNAP applicants, and maintaining benefit access for current SNAP beneficiaries.”
Some of the temporary flexibilities that states have had were pursuant to statutory relief enacted by Congress only so long as the PHE was in place, while others were based on FNS’ inherent waiver authority. Although it is unclear when the PHE will end, FNS anticipates that SNAP state agencies may continue to grapple with capacity issues.
In a memorandum dated Monday, August 15, 2022, FNS explains, “SNAP State agencies, many of which have integrated systems and application processing, anticipate challenges in meeting SNAP federal requirements due to the end of the PHE and requirements associated with Medicaid unwinding and initiating Medicaid redeterminations.” Therefore, it advised, “FNS is offering administrative waivers for certification processes using our authority to approve waivers under 7 CFR 272.3(c)(1)(i) due to extraordinary temporary situations or when they would result in a more effective and efficient administration of the program.”
Specific waivers that FNS anticipates approving include those for streamlining recertification procedures, waiving interviews at initial application or recertification, allowing alternative methods of recording telephonic signatures, and handling address changes submitted without updated shelter cost information.
Lessons Learned to Inform Permanent Improvements
The recent guidance indicates that approved waivers would continue no longer than 12 months after the PHE is lifted. It makes an exception, however, for the telephonic signature waiver “because it would result in more effective and efficient administration of the program.”
FNS should remain open to using more of its inherent waiver authority to allow more practices that proved effective during COVID-19 on a permanent basis. Feedback from customers, administrators, and community partners can help inform decisions about which workarounds worked well and could be adapted for ongoing operations.
Strengthen SNAP Agenda
Advocates should partner with states to identify additional areas for waivers that also would “result in more effective and efficient administration of the program” and urge FNS to consider granting them on a permanent basis.
Advocates also should urge members of Congress to sponsor and pass legislation to improve SNAP benefit adequacy and equitable access on a permanent basis. These include bills to increase SNAP allotments and extend SNAP to Puerto Rico, American Samoa, and the Northern Mariana Islands (H.R. 4077/S. 2191); to end SNAP time limits (H.R. 1753); and to improve SNAP access for college students (H.R. 1919).
Bresnahan C, Ellison C, Green C, Headrick G, Ji Yeun Lee C, Lyons M, Moran A, Tse J. SNAP Waivers and Adaptations During the COVID-19 Pandemic: A Survey of State Agency Perspectives in 2020. Baltimore, MD: Johns Hopkins Bloomberg School of Public Health, 2021 at p. 41 (issued with American Public Human Services Association), available at https://files.constantcontact.com/391325ca001/43b432bd-bdde-4525-8e63-a1b0293de236.pdf