Disaster Supplemental Nutrition Assistance Program (D-SNAP)
The Food and Nutrition Service (FNS) approves Tennessee’s request to operate D-SNAP in 12 counties in response to the impact of the severe storms, straight-line winds, and tornados that began on December 10, 2021. On January 14, 2022, President Joseph R. Biden issued a major disaster declaration with authorization for Federal individual assistance for the following counties: Cheatham, Davidson, Dickson, Gibson, Henderson, Henry, Lake, Obion, Stewart, Sumner, Weakley, and Wilson.
The State agency estimates that approximately 883 new households may be eligible for up to $367,199 in D-SNAP assistance. FNS recognizes that, given the aftermath of this disaster and the continued impact of COVID-19, households may be in need of temporary nutrition assistance.
The State agency has proposed to operate a D-SNAP with virtual components, primarily by conducting telephone interviews for applicants who complete an online pre-registration before and during the application period. FNS is approving the use of virtual operations to facilitate the safety of participants due to COVID-19 consistent with Supplemental Nutrition Assistance Program (SNAP) – Use of Virtual Disaster SNAP (D-SNAP) Operations in Remainder of FY 2021 and FY 2022 issued on August 2, 2021.
FNS appreciates the State agency’s efforts to provide impacted households with temporary access to food assistance, and given the constraints of COVID-19, approves the novel procedure proposed for this specific request. However, FNS reminds the State agency that the use of telephone interviews in D-SNAP remains a novel practice that may pose risks to the D-SNAP application process, customer service, and timely issuance of benefits. Given these risks, FNS is approving this request with specific additional data requirements, detailed below. FNS further notes that, absent the presence of COVID-19 or a similar pandemic, this novel procedure may not be approvable for future D-SNAP operations in Tennessee or elsewhere.
Conditions of Approval
FNS approves the State agency’s request and proposed alternative procedures detailed below, subject to the following conditions:
• Regarding the requested novel procedure for telephone interviews, the State agency will:
o Comply with additional evaluation and reporting measures outlined in the reporting section of this approval in order to determine the feasibility of these models for future D-SNAP operations.
o Have sufficient staff to process applications and conduct telephone interviews in a timely manner, with the ability to augment staffing as needed. o Have a designated phone number for D-SNAP applicants to call to complete an interactive interview.
o Notify FNS if the State changes these approved processes in any way or encounters any issues with the approved processes.
• The State agency will make reasonable accommodations for the elderly and disabled.
• The State agency will take reasonable measures to encourage social distancing and mitigate the spread of COVID-19.
• Commercial channels of food distribution have been restored in the requested counties, and there are a sufficient number of authorized retailers open and available to redeem D-SNAP benefits.
FNS reserves the right to direct the State agency to modify this novel procedure in the event any issues emerge that pose a significant risk to operations, access, including reasonable accommodations for the elderly and disabled, or integrity.
This approval is limited to the following counties: Cheatham, Davidson, Dickson, Gibson, Henderson, Henry, Lake, Obion, Stewart, Sumner, Weakley, and Wilson.
If the State agency wishes to expand D-SNAP to other counties that subsequently receive a Presidential Disaster Declaration for Individual Assistance, it must submit a formal modification request to FNS for approval.
Application Period & Procedures
The application period will be 5 days from Monday, February 14, 2022 to Friday, February18, 2022. The State agency will accept applications through its online pre-registration system and conduct telephone interviews for applicants through its call center from 8:00 a.m. to 4:30 p.m. Central Standard Time each day.
The State agency will notify FNS of any changes to this schedule. If the State needs more days to serve applicants in the approved counties, the State agency may request an extension of the application period, with appropriate justification, subject to FNS review and approval.
The State agency will provide accommodations for households with elderly or disabled or otherwise vulnerable members by allowing them to complete both their application and interview telephonically. All other applicants that cannot complete the online pre-registration or telephonic interview may do so by requesting an in-person appointment at their local office.
The State will require applicants who lived or worked in a specific disaster area to apply within that disaster county. Applicants will not be allowed to apply in a county in which they did not live or work.
The State agency will consider the day an applicant completes their interview with eligibility staff as the filing date of the application, for in-person and virtual operations. FNS notes this is the same standard used in traditional on-site D-SNAP operations, as well as recent D-SNAP operations approved by FNS in other States with virtual application procedures.
In order to mitigate the potential spread of COVID-19, the State agency will document in the case file that a client verbally attested to the information provided on the application. The State must document the client’s name, authorized representative if appropriate, date and time of application, a summary of the information to which the client verbally assents, and the client’s response indicating agreement or disagreement.
The State agency will determine eligibility based on a household’s income, resources, disaster expenses, and other circumstances from December 10, 2021, through January 8, 2022.
The State agency will certify eligible households for 1 month and issue the maximum allotment based on household size according to FNS’ Fiscal Year (FY) 2022 Disaster Gross Income Limits (DGIL).
Other Eligibility Criteria
• Only households that resided or worked in the approved county at the beginning of the benefit period are eligible to apply.
• Household composition as it existed at the beginning of the benefit period (on December 10, 2021) will be used in determining eligibility and benefits.
• Households that experienced food loss alone as their only disaster expense are not eligible to apply.
• If a household has received or expects to receive reimbursement for disaster expenses during the benefit period, only the net amount of expenses paid or anticipated to be paid shall be deducted.
As the State agency already issued emergency allotments (EA) under the Families First Coronavirus Response Act of 2020 for the month of December, ongoing SNAP households have already received the maximum allotment for their household size for the benefit month. Therefore, the State will not provide supplements to current SNAP households in the 12 counties.
The State issued replacement benefits if a household submitted an affidavit in a timely manner. The State will not accept affidavits for replacement benefits during the D-SNAP application period.
Electronic Benefits Transfer (EBT) & Issuance
The State agency affirms that it has a sufficient supply of EBT cards to issue to all anticipated D-SNAP applicants, and will carefully monitor the supply of card stock and the number of applications received and processed each day in order to arrange for the production and delivery of additional cards should the State’s estimate of applicant households prove to be too low. The State agency will notify FNS immediately should difficulties arise with card stock volume or production.
The State agency assures adequate staffing and appropriate separation of duties between DSNAP eligibility determination and EBT card issuance.
The State agency will mail D-SNAP EBT cards overnight to eligible households and maintains that mail service in the 12 approved counties is able to accomplish this goal. The PIN for the EBT card will not be included in the mailing with the EBT card.
Households who cannot receive mail will be allowed to pick up their D-SNAP EBT cards at one of the local offices in the 12 approved counties.
The State agency will provide eligible households with the following information:
• The EBT card will be active and ready for use.
• The location of the pre-assigned PIN number and instructions on how to contact the EBT Customer Service to change the PIN number.
• What items can and cannot be purchased with the D-SNAP benefits.
Program Integrity and Quality Control
The State agency will adhere to the verification requirements in FNS’ D-SNAP Guidance to the maximum extent possible, which include:
• Mandatory verification of identity.
• Where possible, verification of residency and loss of income or inaccessibility of resources due to the storm.
• If questionable, verification of household composition.
The State agency will check all household members for duplicate participation before authorizing benefits. If the duplicate participation check returns information from a SNAP case that was not active during the benefit period, the State can use the identity verification associated with that case to verify identify for the D-SNAP applicant.
The State agency may delay issuing benefits in order to verify questionable application information or if it suspects fraud, but for no more than 7 days from the date of application.
The State agency must conduct anti-fraud efforts and inform households of the consequences of committing fraud.
The State agency will review 100 percent of all applications from permanent, temporary, and contract State agency employees who are involved with administration and operation of the D-SNAP and include the results in its Post-Disaster Report, as detailed below.
Quality Control will exclude D-SNAP cases from its samples. However, the State agency will conduct individual case reviews, as detailed below, to ensure D-SNAP eligibility and allotments were correctly determined.
During the application period, the State agency will provide daily reports, as well as a summary report after operations end, with the following information for each approved county:
• Number of D-SNAP applications taken.
• Number of households and persons approved for D-SNAP.
• Total benefits for the households and persons.
• Total number of pending cases (cases not processed the day of application or held for 7 day processing).
• Number of households denied due to eligibility.
• Average issuance amount per household.
The State agency must also provide FNS with additional daily data on its telephonic interview operations including, but not limited to:
• Average wait time for an interview.
• Number of calls answered.
• Number of calls abandoned.
• Average call completion time.
• Number of client complaints regarding difficulty obtaining an interview. • Number of fair hearing requests for telephonic interviews.
• Information regarding card issuance, such as number of cards picked up, number of cards mailed, number of cards returned in the mail.
No later than 45 days after the close of D-SNAP operations, the State agency will submit an FNS-292B report in the Food Program Reporting System (FPRS).
No later than 6 months after the close of operations, the State agency will provide a comprehensive Post-Disaster Report to the FNS Southeast Regional Office which will include individual case reviews, problem analysis, and proposed improvements to the State agency’s D-SNAP plan.
Given the initial information FNS has collected on the effectiveness of virtual D-SNAP operations run by the State thus far, FNS is updating its methodology for determining the number of case reviews for virtual D-SNAP operations. The State agency must review 1 percent of D-SNAP cases (no fewer than 50 cases but no more than 1,000 cases) to ensure D-SNAP eligibility and allotments were determined correctly. While this is a higher percentage of cases than the State is required to review for traditional operations, this represents a lower number of case reviews than were required for previous virtual D-SNAP operations.
FNS approves this D-SNAP under the authority of section 412 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act and section 5(h) of the Food and Nutrition Act of 2008