|DATE:||April 22, 2016|
|SUBJECT:||Supplemental Nutrition Assistance Program – Review of Major Changes in Program Design and Management Evaluations – Additional Guidance|
|TO:||All Regional Directors
Supplemental Nutrition Assistance Program
This memorandum provides additional implementation guidance regarding the final rule titled Supplemental Nutrition Assistance Program (SNAP) Review of Major Changes in Program Design and Management Evaluations (“Major Changes Rule”) published in the Federal Register on 1/19/2016.
As a reminder, the Major Changes Rule went into effect on 3/21/2016, and state agencies must now be in compliance with its provisions. Changes to the definitions of project areas that impact the requirements for State Management Evaluations (“MEs”) are effective 11/1/ 2016.
Like the 1/19/2016, and 2/11/ 2016, memoranda, this guidance is to assist state agencies as they implement provisions of the Major Changes Rule, and provides a list of questions and answers. Also included with this memorandum is a reissued copy of the Major Changes Notification Template (“Notification Template”) and the Major Changes Quarterly Reporting Template (“Reporting Template”), along with instructions for completing each.
State Notification Requirements Regarding a Major Change
7 CFR 272.15(a)(1) requires state agencies to notify FNS no less than 120 days prior to beginning implementation of a major change, as defined in 272.15(a)(2)(i)-(vi), or entering into contractual obligations to implement any proposed major changes. If
the State agency is unable to meet the 120 day deadline, the state agency must notify FNS as soon as they are aware of the major change and explain why they could not meet the deadline.
The attached Notification Template has been developed by the FNS National Office to facilitate the notification process, and is the preferred format for notifying FNS of major changes. The Notification Template requests the information and analysis state agencies are required to provide FNS when initially reporting a major change, as defined in 7 CFR 272.15(a)(3).
Submission of Notification Templates to FNS
State agencies should submit completed Notification Templates (signed by the appropriate state official), by e-mail to the FNS National Office at SNAPMajorChange@fns.usda.gov. State agencies are encouraged to copy their FNS regional office when emailing completed templates. State Reporting Requirements after Implementation of a Major Change
7 CFR 272.15(b) requires state agencies to report certain state-level information to FNS after implementation of a major change. State agencies must report monthly state-level information on a quarterly basis, beginning with the quarter prior to implementation of the major change. State agencies must also report certain information separately for households with elderly members and households with members that have a disability. Most of the information required by the rule must be disaggregated to provide sub-state information; FNS will base the extent and manner that sub-state information is to be disaggregated on the type of change, the state’s administrative structure, and consultations with the state. FNS may require the state to disaggregate all of the information required under the rule, if FNS determines that such data is necessary to evaluate the impact of the change.
Baseline Quarter Report
For the purposes of reporting for this rule, the “baseline quarter” is the three months prior to the month in which implementation of the change begins, and is the first quarterly report state agencies must submit to FNS. For example, if implementation of a change begins at any point in 4-2017, the baseline data for the change should encompass 1-2017, 2-2017, and 3-2017.
Ongoing Quarterly Reports
After the baseline quarter report, states are required to submit monthly data every quarter for a minimum of one year after the change is fully implemented. The first report after the initial baseline quarter report shall include the month in which implementation occurs. FNS recognizes that state agencies may implement a major change at any time of the month. For example, whether a state agency implements a change on 4-1 or 4-30, April, May, and June’s data would comprise the first quarter report, after the initial baseline quarter report.
The attached Reporting Template has been developed by the FNS national office to facilitate ease of reporting and is the preferred format for reporting. The Reporting Template contains spaces for state agencies to indicate which months of data are being reported. Each quarter, state agencies should complete and submit a new Reporting Template containing three months of data. Please also be aware that FNS may request additional information not included in the Reporting Template, in accordance with 7 CFR 272.15(b).
Submission of Reporting Templates to FNS
No later than 90 days after the end of each quarter, completed Reporting Templates should be emailed to SNAPMajorChange@fns.usda.gov. The state is encouraged to copy their FNS regional office when emailing their completed Reporting Template to the FNS national office.
If the state is unable to meet the above-referenced 90 day reporting deadline, the state should notify FNS as soon as it becomes aware of the delay and explain why the state is unable to timely report the data.
If you have any questions related to the implementation of the Major Changes Rule, please email SNAPMajorChange@fns.usda.gov.
Program Development Division
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.