Appendix G D-SNAPGuidanceJuly2014 (002)

Appendix G D-SNAPGuidanceJuly2014 (002).pdf

Supplemental Nutrition Assistance Program - Supplemental Nutrition Assistance for Victims of Disaster

Appendix G D-SNAPGuidanceJuly2014 (002).pdf

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Supplemental Nutrition Assistance Program (SNAP)

Disaster SNAP
Guidance

Policy Guidance, Lessons Learned, and Toolkits to Operate a
Successful D-SNAP

United States Department of Agriculture Food and Nutrition Service
July 2014

Alternative Public Burden Statement
Public reporting burden for this collection of information is estimated to vary
from 30 minutes to 1 hour per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information. An agency may not
conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number 0584-0336.
Other OMB control numbers associated with this D-SNAP Guidance are:
0584-0037, 0584-0064, and 0584-0083. Send comments regarding this burden
estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to: U.S. Department of Agriculture, Food
and Nutrition Services, Office of Policy Support, 3101 Park Center Drive, Room 1014,
Alexandria, VA 22302, ATTN: PRA (0584-0336). Do not return the
completed form to this address.

Policy Guidance

Policy

Contents
Introduction....................................................................................................................................... 1
Part 1. Policy Context ........................................................................................................................ 3
1.1.

D-SNAP vs. SNAP ...................................................................................................................... 3

1.3.

Context of D-SNAP in Government Disaster Response ............................................................... 5

1.2.

Authority .................................................................................................................................. 4
State Role ................................................................................................................................. 5
FNS Role ................................................................................................................................... 5

1.4.

USDA Role ................................................................................................................................ 6

Funding Issues.......................................................................................................................... 6
What Will FEMA Provide? ........................................................................................................... 7

Getting Help ............................................................................................................................. 6

Part 2. Policy Basics ........................................................................................................................... 8
2.1. Key Concepts .................................................................................................................................... 8
Allotment ................................................................................................................................. 8
Household Composition ........................................................................................................... 8

Application Period .................................................................................................................... 9
Benefit Period ........................................................................................................................... 9
Benefit Period Start Date ........................................................................................................... 9

2.2. Eligibility ......................................................................................................................................... 10

Residency ............................................................................................................................... 10
Purchase Food ........................................................................................................................ 11

Adverse Effects ....................................................................................................................... 11

Eligibility and Participation in Other FNS Programs .................................................................. 12
Disaster Gross Income Limit ................................................................................................... 12
Disaster Gross Income Key Terms ........................................................................................... 13

D-SNAP Allotments and Eligibility Standards ........................................................................... 13
Disaster Assistance Payments ................................................................................................. 14
Key D-SNAP Eligibility Questions ............................................................................................ 15

Disaster Guideline Income Limits including Disaster Expenses................................................. 17

2.3. Verification Basics .......................................................................................................................... 17

Virginia Disaster Standard Expense Deduction (DSED) ............................................................. 17

2.4. Issuance......................................................................................................................................... 18

Part 3. Planning................................................................................................................................ 19

3.1. Regional Planning............................................................................................................................ 19

Regional Plan.......................................................................................................................... 19

3.2.

State Training ......................................................................................................................... 20

State Planning ......................................................................................................................... 20
Roles and Responsibilities. ..................................................................................................... 21
Readiness Plan. ...................................................................................................................... 21

Implementation Plan. .............................................................................................................. 22
Other State-Specific Considerations ........................................................................................ 23

3.3. State Preparations ........................................................................................................................... 24
Training ................................................................................................................................. 24

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Data Collection ....................................................................................................................... 25
State Systems ......................................................................................................................... 26

Part 4. Requesting a D-SNAP ............................................................................................................. 27
4.1 Determining the Appropriate Disaster Response ............................................................................... 27

The Individual Assistance Declaration ..................................................................................... 29
Is D-SNAP Best? ...................................................................................................................... 30

Other Disaster Waivers ........................................................................................................... 31

4.2 Post Disaster / Pre D-SNAP Considerations ....................................................................................... 32
Immediate Response .............................................................................................................. 32
D-SNAP Timing ...................................................................................................................... 32

Continued Operation of Regular SNAP ..................................................................................... 33

4.3 Decisions to Be Made Prior to Request .............................................................................................. 33

Application Period .................................................................................................................. 33
Application Sites ..................................................................................................................... 34

Benefit Period ......................................................................................................................... 34

Supplements .......................................................................................................................... 35
Replacements ......................................................................................................................... 37

Food Loss ............................................................................................................................... 38

Disaster Standard Expense Deduction ..................................................................................... 39

4.4 Drafting the Request ........................................................................................................................ 41
Components of the D-SNAP request ....................................................................................... 42

4.5 Post-Approval .................................................................................................................................. 44
Changes to the D-SNAP after Implementation ......................................................................... 44

4.6 Additional Resources ........................................................................................................................ 45

Part 5. Operating a D-SNAP............................................................................................................... 46

5.1 Public Information ............................................................................................................................ 46

D-SNAP Eligibility Criteria ....................................................................................................... 47

D-SNAP & Ongoing Clients ..................................................................................................... 47

Where & When to Go ............................................................................................................... 47
What to Bring ......................................................................................................................... 48
Program Integrity ................................................................................................................... 48

Information for SNAP Retailers ................................................................................................ 48

5.2 Site Set-up ....................................................................................................................................... 48

Security .................................................................................................................................. 49

Staffing .................................................................................................................................. 50
Telecommunications............................................................................................................... 50

Human Comforts .................................................................................................................... 51

Site Layout ............................................................................................................................. 51

Posters & Notices ................................................................................................................... 52

Language Services .................................................................................................................. 52
Volunteers.............................................................................................................................. 53

5.3 Application Processing ..................................................................................................................... 54

Completing the Application .................................................................................................... 54

Screening ............................................................................................................................... 55
Duplicate Participation ............................................................................................................ 55

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Policy
Interview ................................................................................................................................ 56

Verification ............................................................................................................................. 58
Data Entry & Certification........................................................................................................ 59

Assistance to Ongoing Households ......................................................................................... 60
Special Cases.......................................................................................................................... 63
Onsite Review ......................................................................................................................... 63

5.4 EBT issuance .................................................................................................................................... 64

Replacing Cards and Benefits for Ongoing Clients ................................................................... 64
Reconciliation ......................................................................................................................... 64
Expungement ......................................................................................................................... 65

5.5 Daily Reporting ................................................................................................................................ 65

5.6 Fraud Prevention .............................................................................................................................. 66

Application/Issuance Site Controls .......................................................................................... 67
Information for Applicants ...................................................................................................... 67

Prevent Employee Fraud.......................................................................................................... 68

Monitoring and Reporting ....................................................................................................... 68

5.7 Changes to the D-SNAP .................................................................................................................... 69

Part 6. Post D-SNAP .......................................................................................................................... 70
6.2. Certification Reporting Post-D-SNAP ............................................................................................... 71
FNS-292B ............................................................................................................................... 71

Need Help with Reporting? ...................................................................................................... 71

FNS-388 ................................................................................................................................ 72

FNS-209 ................................................................................................................................ 72

6.3. Issuance Reporting and Reconciliation ............................................................................................. 73
Card production and delivery reconciliation ............................................................................ 73
Benefit authorization and posting reconciliation ...................................................................... 73

Benefit expungement.............................................................................................................. 74
Ensure complete reporting to FNS of disaster benefits issued .................................................. 74

6.4. Fair Hearings, Claims and Restored Benefits .................................................................................... 74

Fair Hearings .......................................................................................................................... 74
Claims .................................................................................................................................... 75

Restored Benefits ................................................................................................................... 76

6.5. Post-Disaster Review Report............................................................................................................ 76
Post-disaster Report ............................................................................................................... 76

Proposed Changes .................................................................................................................. 81

6.6. Conclusion ...................................................................................................................................... 82

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Policy

Introduction
Welcome to the revised guidance handbook for the Disaster Supplemental Nutrition
Assistance Program (D-SNAP). This handbook describes D-SNAP policy, provides

lessons learned from previous D-SNAPs, and contains toolkits to help SNAP offices
plan for, organize, and operate a D-SNAP.

What is D-SNAP?

D-SNAP provides temporary food assistance for households affected by a natural

disaster. A D-SNAP provides one month of benefits to eligible disaster survivors and

can facilitate the issuance of supplemental SNAP benefits for ongoing households. To

be eligible for D-SNAP, a household must live in the identified disaster area, have been
affected by the disaster, and meet certain D-SNAP eligibility criteria.

Why operate a D-SNAP?

D-SNAP is designed for situations where a large number of households have disaster-

related expenses not considered by the regular program and where the need is so
great that the vastly streamlined D-SNAP certification process is warranted.

Where does it happen?

An affected area must have received a Presidential declaration of “Major Disaster” with

Individual Assistance in order to request a D-SNAP.

When does it happen?

D-SNAP timing varies with the unique circumstances of each disaster, but always

begins after commercial channels of food distribution have been restored and families

are able to purchase and prepare food at home. Before operating a D-SNAP, a State
will ensure that proper public information, staffing and resources are in place.

Who does what?

The State has the primary role for planning, requesting, and operating a D-SNAP. The
Food and Nutrition Service (FNS) approves a State’s request to operate a D-SNAP and

supports the State’s D-SNAP efforts through policy guidance, training, and technical

assistance.

This D-SNAP guidance handbook will provide State agencies with the tools they need

to operate a successful D-SNAP that is consistent with the Stafford Act and established
D-SNAP policy. FNS recognizes that disaster situations and State agencies’ responses

D-SNAP Guidance |1

Policy
to them vary widely. The guidance is not designed to provide an exhaustive list of

problems that will arise or prescriptive solutions to those problems. Rather, it is

intended to help State agencies design a disaster plan and disaster response that
addresses their unique geographic, economic, political and demographic
circumstances, the nature of the disaster, and the scope of the damage.

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Policy

Part 1. Policy Context
The first part of this section provides a context for D-SNAP, including:
•
•
•

Distinction between regular SNAP and D-SNAP
D-SNAP authority

Broader government disaster response

This part also outlines the roles of the Department of Agriculture (USDA), FNS, and
States and provides resources for broader disaster assistance information.

1.1. D-SNAP vs. SNAP
D-SNAP is an entirely different program from the regular Supplemental Nutrition

Assistance Program (SNAP). The chart below compares the programs.
Figure 1. Comparison of Eligibility Standards for SNAP and D-SNAP
Eligibility Element

SNAP

D-SNAP

Disaster Status

N/A

Experienced an adverse effect as a result of

Identity of

Verified

Residency

Residence in State or

Living in disaster area at the time of the disaster,

applicant

Household

Composition

Project area is verified

Individuals who

purchase and prepare
meals together

disaster

State option to include those working in disaster
area. Verified where possible

Persons living and eating together at the time of
a disaster

Benefit amount

Varies depending on

Maximum allotment for household size

Restricted

Student, IPV,

Student, IPV, citizenship status, and work

Categories

work registration

Eligibility

circumstances

citizenship status, and

registration not applicable

restrictions apply

D-SNAP Guidance |3

Policy
Resources

Counted separately

No separate resource test. Accessible liquid

resources and income added together to find

Disaster Gross Income.
Income

Deductions &
Expenses

Must meet gross

Only net (take-home) income during the benefit

income test to qualify

period counted. Add to resources to find disaster

Deductions calculated

Maximum standard and shelter deductions

households.

standards. Use of net income eliminates need to

for eligible

gross income.

already incorporated into disaster eligibility
calculate earned income deduction.

Unreimbursed, out of pocket, disaster-related

expenses not expected to be reimbursed during

the 30-day disaster benefit period are allowed as
deductions.
Intentional

Penalties are 12

Violations

and permanent

Program

months, 24 months,

SNAP IPV not applicable in D-SNAP. D-SNAP IPV

counts toward disqualification in SNAP.

disqualification

More information on D-SNAP eligibility is detailed in subsequent sections, most
notably Eligibility.

1.2. Authority
The Robert T. Stafford Disaster Relief and Emergency Assistance Act provides the

Secretary of Agriculture with the authority to operate a D-SNAP when affected areas

have received a Presidential major disaster declaration and when commercial channels
of food distribution are available. The Food and Nutrition Act of 2008 provides the

Secretary of Agriculture with the authority to establish temporary emergency standards
of eligibility for households who are survivors of a disaster that disrupts commercial
channels of food distribution after those channels have been restored.

FNS has elected to approve the operation of D-SNAP under Stafford Act authority when
affected areas have received a Presidential disaster declaration for individual

assistance. Receipt of an individual assistance declaration is indicative of the need for
assistance at the household level in the affected area. Using this measure helps FNS

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Policy
and our State partners target D-SNAP resources to the hardest hit areas likely to

require intensive food assistance. Aligning D-SNAP with the President’s declarations of
individual assistance ensures that FNS is able to provide aid to affected households in
a consistent manner.

Figure 2. Determining Factors Required by D-SNAP Authorities
Food and Nutrition Act

Commercial channels
of food distribution
were disrupted.

Stafford Act

Commercial channels
of food distribution
are now available.

Presidential

declaration of “Major
Disaster assistance”

1.3. Context of D-SNAP in Government Disaster Response
D-SNAP is one important part of a broader government response in the aftermath of a

disaster. Effective collaboration and communication among various government
agencies is essential to serve those in need in the aftermath of a disaster.
State Role

The primary responsibility for providing emergency food assistance rests with the State
agency. State agencies must design their own D-SNAP Plans and update them

annually. After a disaster strikes, they must evaluate the need for a D-SNAP or another

feeding program and, if desired, submit to FNS a detailed request to operate a D-

SNAP. Once a D-SNAP has been approved, the State agency is responsible for

effectively implementing the program, ensuring program integrity, complying with Civil
Rights laws, and submitting daily reports. Once program operations close, the State

must perform post-disaster reviews and report their findings to FNS.
FNS Role
FNS provides disaster nutrition assistance in three ways:
•

Provides USDA Foods for shelters and other mass feeding sites;
D-SNAP Guidance |5

Policy
•

Provides USDA Foods for distribution directly to households in need in certain
limited circumstances,

•

Approves D-SNAP operations and provides funding for 100% of disaster benefits
and 50% of State administrative costs

The approval of a D-SNAP plan is not a legal determination by FNS of compliance with
Federal Civil Rights laws.

FNS supports the State’s efforts to provide D-SNAP benefits by providing policy

guidance, training, and technical assistance to State agencies as they plan, implement,
and assess their D-SNAP activities. FNS provides approval for State D-SNAP Plans and

State applications to operate the D-SNAP and uses the information provided in postdisaster reviews and assessments to improve D-SNAP policy, training, and technical

assistance.
USDA Role

The Federal government’s National Response

Framework designates various Emergency Support

Functions (ESFs) to coordinate and leverage Federal

resources to assist State and local disaster response
and recovery efforts. USDA is the lead agency for

ESF-11, Agriculture and Natural Resources, which

includes disaster nutrition assistance. Different

ESFs may be activated depending on the type and

Getting Help
To get assistance from any
other Federal agency, or any
other agency within USDA,
contact your Regional
Disaster Coordinator.

severity of a disaster. FNS staff participates at the National and Regional level when

ESF-11 is activated. For more information about coordinated Federal disaster

response, see the Toolkit for Regional Offices or contact your Regional Disaster
Coordinator.

1.4.

Funding Issues

FNS provides reimbursement of 50 percent of State administrative costs to operate a
D-SNAP, and funds 100 percent of benefits issued. States may not use any Federal

funds received from FEMA to obtain FNS matching funds. As FNS cannot provide

reimbursement for State expenditures made with funds that are Federal in origin,

States may not use any Federal funds received from FEMA to obtain FNS matching

funds.

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What Will FEMA Provide?
FEMA does not provide funds for the sole purpose of operating a D-SNAP. FEMA will
pay for extra expenses incurred by FNS in performance of its ESF-11 mission

assignment. FEMA may also contribute funds for staff assigned to perform functions
associated with both an ESF-11 mission assignment and the D-SNAP (e.g., staff
gathering information at D-SNAP sites for use in FEMA-required reports).

If a D-SNAP application site is at a location jointly staffed by FEMA, FEMA may provide
directly for the cost of leasing the facility, human comfort items for those waiting in
lines (e.g., portable toilets, tents), and other shared resources. The decision to co-

locate Disaster Recovery Centers (DRC) and D-SNAP sites should be coordinated early

with FEMA, FNS and the State agency so that needs are identified and agreements

made as to whether and to what extent FEMA will provide funding or other resources.

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Part 2. Policy Basics
As highlighted in the introduction, D-SNAP provides one month of benefits to eligible

disaster survivors and can facilitate the issuance of supplemental SNAP benefits for

ongoing households. To be eligible for D-SNAP, a household must live in the

identified disaster area, have been affected by the disaster, and meet certain D-SNAP

eligibility criteria.

This part describes the basics of D-SNAP policy, including:
•
•
•
•

Key concepts
Eligibility

Verification
Issuance

This section serves as a resource for common D-SNAP terms and definitions and how
they relate to D-SNAP benefits, eligibility, and issuance.

2.1. Key Concepts
Allotment
D-SNAP provides a full month’s allotment to households who may not normally qualify

for or participate in SNAP. The allotment for a household is equal to the maximum

monthly allotment for the household size provided under regular SNAP. D-SNAP

allotments are updated yearly and available on the FNS website.

As part of a D-SNAP, States should supplement the regular SNAP benefits of ongoing

households affected by the disaster to bring them up to the maximum allotment. For

more information, see Supplements.
Household Composition

Household composition is established as of the date the disaster struck. A household
includes those people living together, purchasing and preparing food together at the

time of a disaster. D-SNAP household does not include those people with whom

applicants are temporarily staying due to the disaster.

Example: Susan and her two children were affected by a tornado that struck their town.
All three of them are temporarily residing with Susan’s aunt until it is safe to return
home. When Susan applies for D-SNAP, she requests benefits only for herself and her
D-SNAP Guidance |8

Policy

children, as the three of them lived together and purchased and prepared meals
together before the disaster struck.
Application Period
The State agency may accept applications for D-SNAP benefits from new households
and requests for supplements from ongoing households only during the application

period. If the State is accepting requests for affidavits from ongoing households over
the phone and mailing the forms to the household, the request must be received

during the application period. Each State agency can determine an appropriate amount
of time, such as ten days, to allow for the return of the affidavit for supplements.

FNS generally approves application periods of 7 days, though States retain the option
to operate for fewer days as they deem appropriate to the circumstances. The State
should inform FNS, as part of the D-SNAP request, whether applications will be
accepted on Saturday or Sunday.

The State should not begin accepting applications until public information and

outreach have begun, trained staff and resources are in place, and State systems are
ready to begin D-SNAP processing and issuance. More information about D-SNAP
timing can be found in D-SNAP Timing.

State agencies that need to change the application period dates from those in their

approved D-SNAP request must seek FNS permission to do so. In limited

circumstances, if demand for D-SNAP benefits among the general community or

specific groups/areas remains significant, FNS may consider State requests to extend

the application period beyond 7 days. States requesting an extension should consider
the ongoing need of affected households as well as resource availability and program

integrity concerns. For more information on extensions, see Changes to the D-SNAP.
Benefit Period
The benefit period is critical to determining
household eligibility: it is the period during
which disaster-related expenses may be

counted and the start date used to determine

household composition and resources. Only

income, resources, and expenses during the

Benefit Period Start Date
The date the disaster struck (known
as the Incident Period) is included in
every Presidential Disaster
Declaration for Individual Assistance
and is available on FEMA’s website.

benefit period are considered in determining D-SNAP eligibility. The benefit period

approved by FNS for each D-SNAP is 30 days, except in extraordinary circumstances.
D-SNAP Guidance |9

Policy
The benefit period begins on the date of the disaster or the date of any mandatory

evacuation preceding the disaster. This date is generally the first day of the “Incident
Period” provided by the Presidential Disaster Declaration. In some instances, State

agencies may feel it is appropriate to select a date later than the first day because of

when the storm struck a particular area. States considering this option should discuss
the appropriate start date to the benefit period with each locality prior to the
submission of the initial D-SNAP request.

Example: The Presidential Disaster Declaration for Individual Assistance lists the
incident period for a hurricane in six South Carolina counties as June 13 – 15. The
State confers with each county and determines that the hurricane struck the State on
the 13th and that is the appropriate start date for the benefit period. In this instance,
the benefit period would be June 13 – July 12.
Example: The Presidential Disaster Declaration for Individual Assistance lists the
incident period for tornadoes and flooding in 2 Illinois counties as August 26 – 30.
The State confers with the counties and determines that County A was struck by the
tornadoes on August 26th, while County B was mostly affected by subsequent flooding
beginning on the 29th. The State opts to utilize separate benefit periods in each county
in order to adequately capture disaster expenses for all households. In this instance,
the benefit period would be August 26 – September 24 for County A and August 29 –
September 27 for County B.

2.2. Eligibility
To be eligible for D-SNAP, an applicant household must first meet basic criteria,
including:
•
•
•

Residing in the disaster area

Purchasing or planning to purchase food during the benefit period

Experiencing an adverse effect due to the disaster. Households meeting the

basic criteria will then be measured against the D-SNAP income limits in order
to determine eligibility.
Residency
In most cases, the household must have lived in the disaster area at the time of the

disaster. States may also choose to extend eligibility to those who worked in the

disaster area at the time of the disaster. When submitting their D-SNAP requests

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Policy
States should specify if they will serve households that a) lived in the disaster area or
b) lived or worked in the disaster area.

Residency Requirement

Example: Michael lives in County X and works in
neighboring County Y. His place of employment was
damaged in the disaster, so he was unable to work and
experienced a loss of income as a result. The State
agency has opted to serve those who lived or worked in
the disaster area, so Michael can apply for D-SNAP,
based on his employment in County Y and his lost
income due to the disaster.

As in the regular program,
States can only serve their
own residents through DSNAP. In large disasters
where families may have
temporarily relocated to
other States, FNS may
grant approval for various
options under the D-SNAP

Purchase Food

Evacuee Policy developed

The household must plan on purchasing food during

in the wake of Hurricane
Katrina.

the disaster benefit period or have purchased food

during that time if the benefit period has passed. This

would likely apply to the majority of households, except

after very large disasters where households may remain in shelters and be served
through congregate feeding throughout the benefit period.
Adverse Effects
Disaster-related adverse effects fall into three categories: loss of income, inaccessible

resources, and disaster expenses. The household must have experienced at least one
of the following adverse effects in order to be eligible.

Figure 3. Types of Disaster-Related Adverse Effects

Adverse Effects

Loss of

Income

Inaccessible
Resources
Liquid
Resources

Deductible
DisasterExpense
related
Expense

D - S N A P G u i d a n c e | 11

Policy
⁂ Lost or Inaccessible Income. Lost or inaccessible income includes reduction or

termination of income, or a delay in receipt of income during the benefit period due to
the disaster.

⁂ Inaccessible Liquid Resources. Inaccessible liquid resources (e.g., banks are closed

due to the disaster) during the benefit period. Note that this is an infrequent

occurrence, as household can usually access their resources via online banking or
ATMs even if bank branches are closed in the affected area.

⁂ Deductible Disaster-related Expenses. Out of pocket disaster-related expenses paid

(not only incurred) by the household that are not expected to be reimbursed during the
30-day benefit period. This can include damage to or destruction of the household's

home or self-employment business. Types of eligible expenses are described in more
detail in Adverse Effects.

Eligibility and Participation in Other FNS Programs
A household is not eligible for D-SNAP if it is already being served by the disaster

household distribution of USDA Foods, which is separately authorized under disaster

regulations. This disaster household distribution program is distinct from the normally
operating Food Distribution on Indian Reservations (FDPIR) and The Emergency Food

Assistance Program (TEFAP) as described below.

⁂ Food Distribution on Indian Reservations (FDPIR)
If a household received regular FDPIR benefits after the disaster occurred, it would not
be entitled to receive D-SNAP in the same month. FDPIR benefits received by a

household prior to the date the disaster struck should not be considered in

determining a household's eligibility for D-SNAP, since any benefits on hand at the
time of the disaster were likely destroyed.

⁂ The Emergency Food Assistance Program (TEFAP)
Households may participate in both TEFAP and the D-SNAP or SNAP in the same
month. However, if the TEFAP site offers an FNS approved disaster household

distribution of USDA Foods, a household may not simultaneously receive D-SNAP
benefits and a disaster household food package.
Disaster Gross Income Limit
Unlike regular SNAP, which includes separate tests for income and resources, D-SNAP
groups income and resources together under one test.

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The household's take-home income received (or

expected to be received) during the benefit period

plus its accessible liquid resources minus disasterrelated expenses (unreimbursed disaster related
expenses paid or anticipated to be paid out of

pocket during the disaster benefit period) shall not
exceed the Disaster Gross Income Limit (DGIL). In

D-SNAP Allotments and
Eligibility Standards
For the latest D-SNAP
allotments and eligibility
standards, go to:

calculating a household’s Disaster Gross Income,

http://www.fns.usda.gov/disast

income and resources. Resources are determined

SNAP_Handbook/guide.htm.

care must be taken to avoid the double counting of

ers/response/D-

on the first day of the benefit period; anything

received during the remainder of the benefit period would be counted as income.
Figure 4. D-SNAP Income and Resource Test

Total

Take-Home
Income

Accessible
Liquid

Resources

Deductible
DisasterRelated

≤

Expenses

Disaster

Gross Income
Limit

FNS calculates each year’s DGIL by adding together the maximum monthly net income
limit, the maximum standard income deduction amount, and the maximum capped

shelter expense deduction.

Disaster Gross Income Key Terms
The following are the definitions of terms related to the calculation of a household’s

disaster gross income. For more relevant terms, please refer to previous descriptions
in Key Concepts and Eligibility.
•

Income. The total take-home pay of household members. This includes:
o

Wages a household actually receives after all payroll withholding (payroll
withholding includes any automatic deductions from gross pay, such as

taxes, insurance premiums, contributions to 401(k) or other inaccessible

accounts, automatic payments to creditors, etc…)
o
o

Public assistance payments or other unearned income

Net self-employment income.

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Example: Laura Smith lives with her mother, Joan, and her three children. They are
not currently participating in SNAP. Their household was impacted by the disaster and
they apply for D-SNAP. Joan is employed and receives monthly take-home pay of
$1200, after payroll taxes and her health insurance premium are taken out. Laura
receives $850 in TANF benefits each month along
with $325 in SSI for her youngest child, who is
Disaster Assistance Payments
disabled. The family’s total income for D-SNAP
As mentioned in this part,
purposes is $1200 + $850 + $325 = $2375.
disaster assistance payments

•

Accessible Liquid Resources. Accessible liquid

are not considered accessible

resources include cash on hand, and funds in

liquid resources. However, the

first day of the benefit period. It does NOT

such as those from FEMA or

accessible checking and saving accounts on the

State must consider payments,

include:

home owners’ insurance, when

o
o
o

Retirement accounts,

determining deductible disaster

Disaster assistance received or expected

disaster-related expenses

Disaster insurance payments,

to be received during the benefit period,
o

Payments from Federal, state or

county/local government agencies or
disaster assistance organizations
(including disaster-related

Unemployment Compensation).

related-expenses. Deductible
include only those expenses
paid out of pocket and not
reimbursed during the disaster
period. For a disaster-related
expense that is reimbursed,
only the net expense is
deductible.

Example: On the day the disaster struck, Laura had
$50 in cash, and $250 in her checking account. Her mother, Joan, had an additional
$300 in her savings account. They are able to access the funds in their accounts.
They have applied for FEMA assistance for the property damage they incurred, but do
not anticipate receiving the payment before the benefit period ends. Their household’s
total accessible liquid resources are $50 + $250 + $300 = $600.
•

Inaccessible Liquid Resources or Income. Includes otherwise liquid resources that

are inaccessible (for instance, because a bank is closed due to the disaster) for a
substantial portion of the benefit period. Note that this is an infrequent

occurrence, as household can usually access their resources via online banking or
ATMs even if bank branches are closed in the affected area. Also includes receipt

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Policy
of income which has been delayed for a substantial portion of the benefit period
due to the disaster.

Example: Laura & Joan’s local bank is closed, but they are able to withdraw money
from the ATM. Laura is also able to access the paycheck and assistance payments that
are deposited directly into her accounts.
However, the doctor’s office where Joan
Key D-SNAP Eligibility Questions
works is located in a part of town affected
• Did the household live (or work)
by the disaster, and her boss has informed
in the disaster area when the
her that the office will be closed for two
disaster struck?
weeks. She is an hourly employee and will
• Does the household plan to
not earn wages during the time the office is
purchase food?
closed. The earnings she would normally
• Did the household receive FDPIR
receive during those two weeks would be
or household disaster
considered inaccessible and not counted in
determining the family’s Disaster Gross
distribution of USDA Foods after
Income. Since Joan anticipates returning to
the disaster struck?
work and being paid during the second half
• Did the household experience a
of the benefit period, her anticipated
disaster-related loss of income
earnings for that time would be counted as
or a disaster related expense
income.
that will not be reimbursed
•

Deductible Disaster-Related Expenses.

Includes expenses that the household
has paid or expects to pay out-ofpocket during the disaster benefit

during the benefit period?
•

Does the household meet the
disaster income and resource
test?

period. Note that, if the household has received or anticipates receiving a

reimbursement for these expenses during the disaster period, only the net expense
is deductible. In addition, expenses which are incurred but not paid during the

benefit period, such as those paid by credit card if the bill is due after the benefit

period ends, are not considered out-of-pocket and are not deductible. For a list of

examples of disaster-related expenses, please refer to Adverse Effects.

Eligible expenses may include the following, plus any reasonable disaster-related

expenses as determined by the State agency:
o
o
o

Home or business repairs

Temporary shelter expenses
Evacuation expenses

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Policy
o
o
o
o
o

Home/business property protection

Medical expenses due to personal injury
Disaster-related funeral expenses

Incurred vs. Paid

Disaster-related pet boarding fees

Only expenses actually paid

Expenses related to replacing

during the benefit period are

necessary personal and household

deductible. To determine if an

items, such as clothing, appliances,

expense was paid for out of

tools, and educational materials
o
o
o
o

pocket or merely incurred, the

Fuel for primary heating source
Clean-up items expense

worker must ask the household

Storage expenses

Expenses paid by credit card are

how they paid for the expense.

Disaster-damaged vehicle expenses

not deductible unless the bill is

Food lost or spoiled due to the disaster or extended
power outage may also be considered a disaster

also paid during the benefit
period.

expense. Including “food loss alone” as a criterion

for eligibility is optional and, if applicable, is included in the D-SNAP approval from

FNS. (For more information on use of food loss alone as an eligibility criterion, see

Food Loss).

Example: Joan’s car was damaged in the disaster and the total cost of the repair is
$700. Joan’s insurance covers $500 and she will pay $200 out of pocket to have it
repaired so she can continue to go to work. The full cost is not counted for D-SNAP
purposes; only the $200 Joan paid is considered a deductible expense. Laura and
Joan’s home was also damaged and repairs will cost $3000 in total; they’ve paid $400
out of pocket so far. They have not yet received FEMA assistance or reimbursement
from their home owners insurance and do not anticipate receiving those payments
until after the benefit period ends. They also lost $125 worth of food due to the
extended power outage following the disaster. In total, their deductible disasterrelated expenses are: $200 + $400 + $125 = $725.
Figure 5: Calculating the Smith Family’s D-SNAP Eligibility
Total

Take-Home
Income:
$2375

Accessible
Liquid

Resources:
$600

DisasterRelated

Expenses:
$725

Disaster

Gross Income
Limit:

$2821
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Disaster Guideline Income Limits including Disaster Expenses
With FNS approval, a State can choose to incorporate into their disaster income limits a
standard disaster expense component. Determining a household’s deductible
disaster-related expenses can be difficult and
time-consuming, particularly with high

applicant volume. Some States have found that
incorporating a standard disaster expense

deduction into the income limits can simplify

eligibility determination. States considering this
option should carefully consider if its use is
appropriate to the type and severity of the
disaster. Those interested in using these

specialized income limits should contact FNS
for technical assistance and approval. See

Disaster Standard Expense Deduction for more

information.

2.3. Verification Basics

Virginia Disaster Standard Expense
Deduction (DSED)
In 2005, the Virginia State agency
requested help from FNS in
developing disaster income limits
that incorporated a standard for
disaster expenses. FNS provided
technical assistance to develop
guidelines based on typical disaster
expenses in past Virginia disasters.
Virginia’s Disaster Standard Expense
Deduction has subsequently been
used by other States to simplify DSNAP application processing.

Verification rules are eased during a disaster to

reduce administrative burdens and to reflect the reality that households and eligibility
workers may not have access to usual verification sources. Verification requirements

in D-SNAP are three-tiered: 1) Identity must be verified; 2) residency and

loss/inaccessibility of income or liquid resources should be verified where possible;

and 3) household composition and food loss can be verified if questionable.

Each disaster is unique and the availability of verification will likely vary depending on
the circumstances. For example, in a disaster where strong winds caused extended
power outages, households would likely be able to provide proof of residency and

household composition, while households that lost their homes due to tornadoes or

hurricanes likely will not be able to provide these documents. When planning for DSNAP operations, preparing public information, and conducting staff training, States

should consider the types of verification (such as power outage maps, data matches,

etc…) that may be available to the agency, and to the household for a given incident.

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For more details on verification, including suggested ways to verify each item, please

refer to Verification.

2.4. Issuance

Each State must be prepared to issue D-SNAP benefits through its Electronic Benefits
Transfer (EBT) system during an emergency while successfully interacting with that

State’s eligibility system and their EBT contractor’s system. EBT issuance is a required
component of State Disaster Plans.

A State’s D-SNAP issuance plan should incorporate procedures for:
•

Ensuring that benefits are made available as soon as possible and no later than 3

calendar days (except in questionable cases in which issuance may be delayed up to
7 days) from the date the application was filed.
•
•

Accessing sufficient card stock to operate a D-SNAP.

Minimizing the number of times recipients return to a disaster assistance location
for benefit application and issuance. Ideally, this would require only one visit.

•

Providing easy integration and reconciliation with the State’s eligibility system and

the EBT processor’s database, as well as access to information on a State’s disaster
EBT system via on-line data and off-line reports.
•

Checking for duplicate participation of all household members.

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Part 3. Planning
Although it is impossible to be completely prepared for disasters, State agencies and
FNS Regional Offices thorough planning will mitigate the challenges of preparing to

operate a D-SNAP once the disaster has struck. This part outlines some pre-planning

activities that the Regional Office and State agency should perform to increase disaster
preparedness.

This part covers the following areas:
•
•
•

Regional Planning
State Planning

State Preparation Highlights

Taking these steps will help establish communication and planning between State and
Regional Offices (ROs), ensure that staff is trained and up to date on policy and

processes, and provide a foundation for States and FNS to respond quickly and
appropriately to the particular needs of a disaster.

3.1. Regional Planning
Every year, each FNS Regional Office (RO) should review its internal D-SNAP plan,

revise the plan and train staff as needed. The RO should also engage in annual contact

with its respective States to discuss disaster planning.
Regional Plan

The Regional Disaster plan is an internal guide that ensures timely, high-quality

assistance to States with preparing for disaster operations, including D-SNAP planning,
implementation, and assessment.
⁂ Contents

The Regional disaster plan can take any form, but should include:
•
•

Standard Operating Procedures for D-SNAP and other disaster programs
Administrative and Communication plan:
o
o
o
o
o

Names and responsibilities of all lead personnel

Detailed description of the role of the field offices
Outline of delegated authority

Established lines of communication

Names and off-hours phone numbers of relevant staff
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Policy
•
•

Regional fraud control plan

Training plan for State and Regional staff

State Training
ROs should take advantage of existing meetings, conferences, and site visits to engage

in D-SNAP training with the State agencies within its region.
⁂ Objectives
The objectives of these trainings are to:
•
•
•
•

Clarify roles of State agency and Regional Office
Establish clear lines of communication

Help States develop and update their disaster plans
Allow States to share experience and knowledge

Possible contact and training opportunities include:
•
•

Face-to-face meeting with State agency

Review of D-SNAP readiness during Regional reviews, including Program Access

Reviews and Management Evaluations
•
•
•

3.2.

Participation in State agency-led disaster exercise with follow-up discussion
RO presentation about disaster preparedness at other State meetings

Region-led disaster webinar or teleconference

State Planning

SNAP regulations require State agencies to maintain current disaster plans. Each State

agency must review its existing D-SNAP plan on an annual basis, revise if necessary,

and submit a copy to the RO by August 15 of each year. Alternative plan submission

dates may be negotiated with the ROs on a case by case basis as appropriate.
Each State D-SNAP plan must include:
1. Roles and Responsibilities

2. Resource Readiness Plan

3. Implementation Plan

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Policy
These three components must address the following elements:
Roles and Responsibilities.
•

Agencies and Responsibilities. Identity of county/local, State and Federal

government agencies with responsibilities for disaster assistance, including a

description of responsibilities for each agency. See Context of D-SNAP in

Government Disaster Response.
•

Points of Contact. Provide names, positions, and phone numbers of

county/local, State and Federal government officials and their back-ups who are

key contact persons during a disaster (including the State agency disaster
coordinator).
•

Community Partners and Roles. Identify private disaster relief agencies within
the State such as the Red Cross, Salvation Army, or community groups and a
description of their role in D-SNAP implementation. See Volunteers.

Readiness Plan.
•

Staffing and Resources. Identify staffing and

related resources available to assist in a disaster

County
Administered?
County
Administered?

disaster areas in need. Explain how the

shouldhave
haveplans
special
should
andplans
and agreements
in place
to
agreements
in place
to allow

and how they will be mobilized to target

State/counties will manage the increased

administrative burden associated with running a
D-SNAP and regular SNAP operations
simultaneously. See Staffing.
•

County
Countyadministered
administeredStates
States

allow for sharing of
for sharing of information,
information, resources, and
resources, and staff across
staff across county lines.
county lines.

Application System Development. Describe application systems to be used for

D-SNAP client management, including any workarounds to the regular SNAP

system, considerations associated with running SNAP and D-SNAP operations

concurrently, compliance with D-SNAP reporting requirements, etc.
•

Issuance System Development. Describe issuance systems to be used for D-

SNAP client management. For more information on contracting and developing

a D-SNAP issuance system. See the EBT Planning section in the Toolkit for State

Agencies.

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Policy
•

EBT Card Stock. Identify EBT card stock available, type of cards to be used,

steps and timeline for ordering additional cards, and any special procedures or
resources that will be needed to meet ongoing SNAP and D-SNAP issuance
timeframes. See EBT issuance.

•

Application Sites. Describe site selection procedures, including potential

application/issuance sites for disasters that vary in size and scope and any

agreements in place with those locations. If D-SNAP will operate out of local

offices, explain how application sites will handle running D-SNAP and SNAP
concurrently. See Application Sites.
•

Data. Identify general demographic data that can help the agency tailor its

response to a disaster. Identify available data and information from sources

such as Social Security, Supplemental Security Income, Medicaid, or communitybased organizations that can be used to locate vulnerable populations. Identify
resources for disaster impact data, including preliminary data assessments,
flood maps, or electrical outage data. See Data Collection.
Implementation Plan.
•

Public Information and Outreach. Describe public information strategy to
ensure timely, accurate information reaches those in need. Outline roles,

expectations, and responsibilities of any regular SNAP outreach partners

included in the State Outreach Plan that will assist with D-SNAP. Include

potential community partner activities focused on identifying and promoting

access for vulnerable populations, such as persons with disabilities and the

elderly. For more information on community partner involvement and D-SNAP

outreach, see the Outreach section in the Toolkit for State Agencies.
•

Retailer Communication. Describe procedures to notify retailers of new waivers

(i.e., Hot Foods) and new D-SNAP clients.
•

Procedures to Reduce Applicant Hardship. Outline steps State will take to

reduce hardship for D-SNAP applicants and ongoing caseload, including

provisions for security, human needs, language services, etc… See Human
Comforts.

•

Certification Process. Describe the specifics of the certification process

including potential application sites, staffing, separation of eligibility and
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Policy
issuance, and how application sites will manage large crowds. If online pre-

registrations, electronic applications, or other technologies are to be used by

workers or clients, describe that process and back-up systems in place if
technical issues are encountered. See Application Processing.

•

Client Materials. Include recipient application and client notices. See Part 1 in
the Toolkit for State Agencies.

•

Issuance Process. Describe how

benefits will be made available within
72 hours of D-SNAP application and

how to ensure continuation of ongoing
SNAP certification, issuance, and other

actions concurrently. Indicate how the

State will monitor stock levels and
ensure sufficient EBT card stock.

Describe EBT card reconciliation and

security procedures. See EBT issuance.
•

Emboss EBT cards?
D-SNAP can put a strain on State
processes. States that have timeintensive steps as part of the
issuance process, such as
individually embossing EBT cards,
should have a plan in place to ensure
benefits can be issued to a largevolume of D-SNAP applicants within
72 hours.

Security and Fraud Prevention Plan.

Describe how the State will ensure security and mitigate the risk of fraud,

including a specific plan for handling applications submitted by State agency

employees, procedures for handling questionable applications, and process for
checking all household members for duplicate participation. See Fraud
Prevention.

•

Disaster Reporting and Post-Disaster Review Report. Describe procedures to

ensure that required federal reporting and post-disaster review report will be
complete and timely. See Daily Reporting and Post-Disaster Review Report.
Other State-Specific Considerations
Plans should address any circumstances unique to the State that may affect D-SNAP

operations, including coordination of resources among County-level administrations,
how to serve isolated populations, development of “work-arounds” to allow SNAP

systems to accommodate D-SNAP operations, and contingency plans for local offices

located in flood plains or otherwise subject to closure.

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3.3. State Preparations
In addition to the State Plan, advance preparations, including training staff on D-SNAP
policy and procedures, establishing data collection contacts and procedures, and
readying State certification and issuance systems, will facilitate an efficient and

effective D-SNAP operation.
Training

States must provide introductory and ongoing training on disaster eligibility,

application, and issuance procedures to relevant county/local and State staff on a

regular basis. County or local eligibility staff and supervisors that will work on D-SNAP
certification and issuance should be trained or re-trained before beginning to work at
D-SNAP sites.

⁂ Content of Training
States should consider covering the general information below in their D-SNAP

training. Training sessions held prior to the start of disaster operations should include
information specific to the disaster, in addition to the following.
•

Overview of D-SNAP certification process, including any special D-SNAP

systems. See Application Processing.
•

Roles and responsibilities for each person (screener, eligibility worker,
supervisor, etc) and lines of supervision. See Staffing.

•

Eligibility policy including: eligibility criteria, calculating eligibility, identifying

the benefit period and deductible disaster-related expenses. See Eligibility.
•

Verification requirements, acceptable documentation, and procedures for

handling questionable applications. See Verification.
•
•

Application forms and client notices.

Issuance of benefits, including: use of allotment tables (if applicable), any onsite

card/PIN issuance activities (if applicable), client training on card usage, lost
card replacement, PIN changes, etc. See EBT issuance and the EBT Planning

Section in the Toolkit for State Agencies.
•

Fraud prevention, including: formal fraud control measures in place, duplicate
participation checks, special procedures for employee applications (including

that 100 percent reviews will be conducted of approved employee applications).
See Program Integrity and Fraud Prevention.

•

Compliance with Civil Rights laws, including providing reasonable

accommodations for applicants with disabilities.
•

Public information (who is authorized to issue statements to the media). See

Public Information.

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•

Personnel matters, including: transportation to sites, hours, breaks, pay, safety,
stress management, communication with disaster survivors. See Staff Comfort

& Health.
•

Role of outreach partners. See Volunteers and the Outreach section in the

Toolkit for State Agencies.
⁂ Staff Orientation Guide

A disaster orientation guide posted on the State’s website or provided on site can be
very helpful to staff during a disaster operation. FNS encourages States to develop

such a guide in advance and add updates depending on the particular circumstances of
the disaster and D-SNAP. A thorough orientation guide includes some or all of the
following:

General items
•
•
•

Time sheets

Safety information (e.g., water use, aftershock precautions)\
Fliers on preventing stress (see

http://mentalhealth.samhsa.gov/publications/allpubs/KEN-01-0098/)
•

General contact information for State agency, State Emergency Management,
Outreach partners

Disaster-specific information
•
•
•
•
•
•

Location of disaster service sites, contacts and phone numbers
Transportation arrangements to and from site(s)
Identification needed for access to site(s)
Lines of authority

Maps (showing sites, hotels, airport, etc.)

List of onsite contacts, their hotels, and phone numbers

Data Collection
Agencies should make an effort to obtain and update demographic data during pre-

disaster planning and establish plans for how to evaluate impacted populations once
the disaster has struck.
⁂ Demographic Data

Although demographic information is not a required component of the D-

SNAP plan, having gathered general data can help the agency tailor its response to a
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Policy
disaster. Data on the following elements for each County will help State agencies to
respond appropriately when a disaster strikes:
•
•
•
•

Income levels

Percentage of SNAP households
Primary languages spoken

Percentage of elderly/disabled and infant populations

⁂ Disaster Impact Data
The State should have a plan in place for gauging the impact of the disaster in order to

determine if D-SNAP is the appropriate response and, if so, target areas most in need.
This information is critical in making decisions about staffing, resource allocation, the
length of the application period, and the most appropriate D-SNAP application sites.
While FNS will consider various data sources in making a determination on mass

supplemental issuance, or mass replacements, FNS will ask the State to provide data or
other evidence that at least 50% of households in a certain defined area (i.e., county,
neighborhood, Zip Code, etc.) have been impacted by the disaster.

The most commonly used data are power outage charts and maps which indicate an

extended outage of four hours or more affecting the majority of the population. At
times, States have difficulty obtaining this information in post-disaster situations.

Developing contacts and lines of communication in advance will help ensure that State

agencies are able to get this information when they need it. FNS recommends working
with some or all of the following to establish connections in advance of a disaster:
•
•
•
•

Utility Companies

State Emergency Management
Governor’s Office

State LIHEAP Coordinator

State Systems
The State must have systems established and in place to ensure efficient and effective
D-SNAP certification, issuance and reporting, including checking for duplicate

participation. Refer to EBT Planning section in the Toolkit for State Agencies for more
information.

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Part 4. Requesting a D-SNAP
This section is designed to cover the time period from when the disaster strikes
through the submission and approval of the D-SNAP request. While good pre-

planning is crucial for successful programs, States must also be prepared to revise and
adapt their plans and to quickly develop the details of the request and logistics of the
program for each incident.

Topics covered in this section include:
•
•
•
•
•
•

Determining the Appropriate Disaster Response
Post Disaster/Pre D-SNAP Considerations

Decisions to be Made Prior to the Request
Drafting the Request
Post-Approval

Additional Resources

4.1 Determining the Appropriate Disaster Response

Each disaster is unique. FNS offers several options for States and communities
recovering from a disaster to provide food for their citizens, including:
•
•

USDA foods for shelters and other mass feeding sites

USDA foods for distribution directly to households in need in certain limited

circumstances
•
•

D-SNAP benefits provided directly to households for purchasing food

SNAP waivers to assist ongoing households in the affected area. See Other

Disaster Waivers.

Often, some combination of these options will be
utilized in order to meet the changing needs of

survivors through the response and recovery process.

The most appropriate response is also determined by
the scale and scope of the disaster and the type, if

any, of Presidential Disaster Declaration that has been
issued.

Useful Resource:
http://www.fema.gov/news/
disasters.fema includes an
updated list of disaster
declarations, including the
type of declaration and
approved areas.

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⁂ Be Proactive
Early and frequent communication among the State agency, FNS Regional and National
Offices is vital for successful programs. Disasters can sometimes be anticipated and,
whenever possible, States are encouraged to begin conversations about potential

responses with their respective Regional Offices prior to the date the disaster strikes.

After the disaster has struck, States should keep their Regional Offices apprised of any
activity related to preliminary damage assessments and requests for an Individual
Assistance declaration. ROs will promptly inform the National Office of any

developments and provide technical assistance to impacted States as they develop any
necessary waiver requests. The ROs will provide their analysis and submit State

requests to the National Office the same day they are received. Every effort will be

made to review and respond to State requests within 24 hours of their receipt by the
FNS National Office.

During each D-SNAP planning and implementation, a clear communication plan should
be established at the State, Regional, and National Office levels. In order to facilitate
timely and frequent communication and troubleshoot potential issues, ROs should

designate contact people for each disaster and provide off hours contact information
to the National Office in the event that questions need to be answered or approval

provided on evenings, weekends, or holidays. The National Offices strongly

recommends that each RO to collect this information from its respective State agencies
as well.

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The Individual Assistance Declaration

FNS policy provides that States may request to operate a D-SNAP once the President

has issued a major disaster declaration for Individual Assistance. Other types of major
disaster declaration include public assistance and hazard mitigation. A Major Disaster
Declaration usually follows these steps:

Figure 6: The Disaster Declaration Process
Local government responds, supplemented by neighboring
communities and volunteer agencies. If overwhelmed, turn to the
state for assistance

The State responds with state resources, such as the National
Guard and state agencies

Damage Assessment by local, state, federal, and volunteer
organizations determines losses and recovery needs

A Major Disaster Declaration is requested by the governor, based on
the damage assessment, and an agreement to commit state funds
and resources to the long-term recovery

FEMA Evaluates the request and recommends action to the White
House based on the disaster, the local community and the state's
ability to recover

The President approves the request or FEMA informs the governor it
has been denied. This decision process could take a few hours or
several weeks depending on the nature of the disaster

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Is D-SNAP Best?

The Individual Assistance declaration does not necessarily mean that D-SNAP is the

appropriate response, or that it should be implemented in all areas that received the
declaration. D-SNAP is designed for situations where a large number of households

have disaster-related expenses not considered by the regular program and where the

need is so great that the vastly streamlined D-SNAP certification process is warranted.

When developing a disaster response, FNS encourages States considering a D-SNAP to
gather as much information as possible about the extent of the damage, population

demographics in affected areas, and the readiness and availability of resources (such
as staff, application sites, etc.) in addition to the considerations noted below.

The following chart illustrates the process flow of determining the most appropriate
response to meet the food needs of disaster survivors. It’s important to remember

that as the decision points change over time (i.e., power is restored and households

that could not prepare food at home are now able to do so), so too does the response
indicated. For example, a county that was struck by a disaster 3 days earlier may be
best served by congregate feeding; however, two weeks later, D-SNAP could be the
appropriate response.

Figure 7. Evaluating Food Aid Options

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Policy
By the same token, conditions may vary so much within the disaster area that

household distribution of USDA foods may best serve one area, while the population in
another is in need of a D-SNAP. This could be the case if a small, isolated area and a

large, densely populated one were both struck by the same disaster. In the larger area,

retailers may be operational and roads passable, allowing household to use their DSNAP benefits. In the rural community, stores and congregate feeding sites may be
difficult to access and a household distribution of USDA food may best serve the

population.

Other Disaster Waivers

Certain SNAP waivers handled by FNS’ Retailer Policy and Management Division (RPMD)
can be utilized to assist ongoing households impacted by the disaster, either instead
of or in addition to a D-SNAP. State Agencies must provide waiver requests to their
FNS Regional Office, which transmit the requests to RPMD for processing. The

following three RPMD waivers are the most frequently requested and approved:
•

Automatic/Mass Replacements – Per SNAP regulations, replacement benefits are

always available by affidavit to SNAP households anytime they experience an

adverse effect causing them to lose food purchased with their benefits. This

waiver allows the replacement of a certain percentage of a household’s benefit

(depending on the time of the month and the State’s issuance cycle) without the
need to submit individual requests. This waiver may be granted without an IA

declaration. This waiver does not remove the responsibility of local offices to

process individual affidavits before or after the waiver implementation as
required by 7 CFR 274.6(a).
•

Hot Foods – A waiver of the hot foods exclusion in the Food and Nutrition Act

allows SNAP households to purchase hot, prepared foods at authorized retailers
with their EBT cards. FNS has the authority to grant this waiver when an IA

declaration has been issued and may extend the waiver to areas beyond those
that received the IA if households that lived in the disaster area have been
displaced or temporarily relocated to other parts of the State.

•

Timely Reporting – This waiver extends the 10-day timeframe in which SNAP

households must normally report the loss of food purchased with their benefits
and request replacement benefits. This waiver may be granted without an IA
declaration.

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4.2 Post Disaster / Pre D-SNAP Considerations

Before planning for the specific disaster program can begin, several other factors need
to be considered, including overall readiness for the program and how to balance the

needs of both ongoing and D-SNAP households.
Immediate Response

In an effort to speed aid to their citizens, States sometimes attempt to begin D-SNAP

operations too soon. As noted in the chart above, D-SNAP is not appropriate if

floodwaters have not receded, power has not been restored to the area, roads are
impassable, or retailers are not operational. Under these circumstances, FNS

encourages States to delay the implementation of D-SNAP operations until the

program can more effectively serve households as they begin to return to their homes
and regain the ability to shop, cook, and store food.
D-SNAP Timing

Experience has shown that it generally takes a minimum of one week following a

disaster before communities are ready for a D-SNAP – longer for large-scale disasters.

FNS believes it is in the best interest of both States and applicants if the program does
not begin too soon, when survivors are likely focused on their more immediate needs
and may not be able to appear at the D-SNAP site or use their benefits.

Past D-SNAP operations have shown that programs that start too early often have few

applications in the first several days. As the community begins to recover and word

spreads about the D-SNAP, application sites are sometimes overwhelmed with more

applicants than they are able to serve in the remaining days, which can cause security
issues. In such situations, the State agency often requests an extension of the

application period. Extended application periods result in increased staffing and

resource costs for the State and may increase the likelihood of fraud in the program.
Based on lessons learned in past disasters, FNS recommends beginning program
operations:
•
•

No earlier than 1 week after the disaster struck;

At least 2 days after FNS approval, to allow sufficient time for publicity, staff

training, and site preparations;
•

After preliminary damage assessments, power outage, flood and/or evacuation
maps are available in order to estimate the number of potential applicants and
areas where it may be appropriate to target mass replacements/supplements.

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In addition, before D-SNAP benefits can be issued, the State must determine if enough

authorized food retailers are open in and around the disaster area. States should work

primarily with their EBT contractors to determine how many authorized SNAP retailers
in a disaster area have working point-of-sale

(POS) terminals and available telecommunications
to process EBT transactions. If necessary, the
manual voucher process can be used.

Continued Operation of Regular SNAP

States preparing to operate a D-SNAP need to
plan appropriately for management of their

ongoing SNAP caseload, as the regular program

ALERT
FNS’ Retailer Policy and
Management Division can utilize
the ALERT system to help
identify how many authorized
retailers in the disaster area are
able to process transactions.

must continue uninterrupted during D-SNAP

operations. Ongoing clients may need replacement benefits or may contact or visit
their local offices to inquire about eligibility for supplements or D-SNAP benefits.

Ensuring the ongoing clients will continue to receive uninterrupted benefits and timely
actions on their cases is just as important as meeting the needs of new D-SNAP

applicants. The addition of the D-SNAP caseload can tax already busy offices and

planning for the effective sharing of resources between the two programs, including

bringing in staff from other jurisdictions, directing D-SNAP applicants to an alternate

site, and arranging for overtime pay are all important issues to consider before DSNAP operations can begin.

4.3 Decisions to Be Made Prior to Request

States must make a number of decisions before drafting and submitting a D-SNAP

request. The following items should be discussed and considered carefully in the days
following a disaster.

Application Period

FNS generally approves an initial application period of up to 7 days. States may opt to

use some or all of the 7 days at their discretion. Except in extreme circumstances, this
length of time has proven to be sufficient for all applicants in need and helps to
protect program integrity.

Application periods may be staggered across counties (or other areas) as needed to

maximize staff and resources. Applicants may also be instructed to come on a specific
day or days based on some arbitrary factor, such as the first initial of their last name,

in order to avoid overcrowding. All applicants at the site must be served, even if they
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do not come on their designated day. Providing a ‘catch-all’ day or two at the end of
the application period for anyone who missed their designated day is a best practice
with this approach. States choosing these options should clearly explain why they

believe it will better serve applicants and staff to do so and present a clear plan for

publicizing and responding to questions about the roll-out or specified applications
dates.

Application Sites

For each disaster, the State must determine the exact number and location of

application/issuance sites. In small-scale disasters, States may wish to use the local

office as the D-SNAP application site. In each disaster situation, the State should make
clear in its publicity materials if applicants may come to any site or each site is specific

to residents of a given county or local area. Where the State predicts a large number of

applicants or where local offices have sustained damage, FNS strongly recommends the

selection of an alternate site(s). Some commonly used alternate sites include:
•
•
•
•
•
•

Schools

Stadiums
Libraries

Mobile Vans

University auditoriums
Rented trailers/trucks

Some States have chosen to co-locate their D-SNAP site with a FEMA Disaster Recovery

Center (DRC). FNS cautions that DRCs may not continue operation for the entire

application period or may be overwhelmed by the number of D-SNAP applicants so

States choosing this approach should prepare good contingency plans for back-up
sites as needed. States may also consider collaborating with their local public

transportation authority and community partners to provide transport to and from

application sites for remote populations, the elderly, and persons with disabilities. See
the Application Site Selection Guide in the Toolkit for State Agencies, which includes

useful considerations in choosing the most appropriate sites.
Benefit Period

The benefit period is the 30-day timeframe in which household income, resources, and
disaster-related expenses are evaluated. The date the disaster struck (or the date a

mandatory evacuation order went into effect, if applicable) should generally be used as
the first day of the benefit period to ensure that all eligible disaster-related expenses
can be captured within it. Household composition for D-SNAP purposes is also

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established on the first day of the benefit period. For more information on

determining the benefit period see Benefit Period.
Supplements

Supplements are an essential component of the disaster response, bringing ongoing

SNAP households affected by the disaster up to the maximum allotment for their

household size. By virtue of their participation in the regular program, the food needs
of SNAP households are already known and the impact of additional disaster-related

expenses will weigh heavily on this low-income population. Supplemental benefits in

order provide parity between new D-SNAP households and ongoing clients, who are
not eligible for D-SNAP benefits.

Figure 8. Calculating the Supplemental Benefit Amount

The maximum
monthly
allotment for
a household
of 2 is $367

A two-person
household's
regular
monthly SNAP
allotment is
$212

The State can
issue the
household a
supplement of
$155

The request to issue supplements and the supporting justification should be included,

whenever possible, in the State’s D-SNAP waiver request. States should be aware when
drafting their D-SNAP plans and waiver requests that ongoing SNAP clients need not
appear in person at the D-SNAP site. Since their identity and circumstances are

already known to the State agency, it is not necessary that they fill out a complete D-

SNAP application or be interviewed in order to receive replacements (discussed in the
next section) or a supplemental issuance.
⁂ Individual vs. Automatic Supplements

In a given disaster, the State agency must decide if it is most appropriate to issue

supplemental benefits on an individual basis, via the filing of an affidavit by the

household, or automatically, to all ongoing SNAP households in a designated area.

Individual supplements work best in areas where there is a small-scale disaster and
applicant volume is not anticipated to be very high. In order for individual

supplements to be effective, the State agency must have the capacity to handle
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requests for supplements and issue the supplemental benefits while it is also taking
applications from and issuing benefits to new D-SNAP households.

In order to obtain a supplement, households may complete an affidavit of disaster loss
in person or by mail. A template can be found in the Toolkit for State Agencies. FNS
encourages States to allow ongoing clients to request affidavits over the phone and

submit them by mail, alleviating potential crowd control issues at the D-SNAP site or

local office. Ongoing clients must make their request for these affidavits during the D-

SNAP application period. If requests are being accepted by phone, the State agency
must provide the client with a reasonable timeframe, such as ten days, by which to
return or mail the affidavit.

States with the technological capabilities to provide affidavit forms online may do so.
The State can choose to have these online forms printed, signed, and returned to the

office, or electronically signed and submitted online, depending on the specifications

of the State’s system. The forms should only be made available during the application

period. State selecting this option must also provide alternative means of obtaining
and submitting affidavits for households that cannot or prefer not to access
documents online.

Automatic supplements generally work best when there is a large-scale disaster and
the State agency is able to identify households that experienced adverse effects as a
result of the disaster. Automatic issuance can help the State agency quickly and

efficiently meet the needs of ongoing clients, while freeing up staff and resources to

assist the population of new D-SNAP applicants. However, States should bear in mind

that, even in highly impacted areas, the issuance of automatic supplements will

provide these benefits to some households that were not affected. This waiver does

not preclude the State from accepting individual affidavits before or after the waiver
implementation as required by 7 CFR 274.6(a).

States must include their plan to issue automatic supplements in their D-SNAP

requests and must be able to effectively target the benefits to geographic areas that
were heavily impacted by the disaster. Ongoing SNAP households not receiving

automatic issuance but who were living in the disaster area and experienced disaster
losses may still request supplemental benefits via affidavit.

Targeting the benefits to where they are most needed can be achieved through the use
of data such as:

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•
•
•

Preliminary Damage Assessments

Flood or mandatory evacuation maps

Power outage information (outage maps, lists of affected Zip Codes, etc...)

The information that can best support the need for automatic issuance will vary by the
type and scale of the disaster and the parameters of the D-SNAP. FNS encourages

States to work closely with their respective Regional Offices in order to determine how
to best find, use, and evaluate available information in a post-disaster situation.
Requests for automatic supplements must be accompanied by some form of

supporting data which indicate that a majority of the population in given area has
suffered an adverse effect as a result of the disaster. It is important to note that

automatic supplements need not be issued only at the county level. For example, if
the data show that a given zip code within a declared county was most heavily

affected, automatic supplements can be targeted to those zip codes and individual

supplements via affidavit made available through the rest of the county.
Replacements

Per SNAP regulations, replacement benefits are always available on an individual basis
to ongoing SNAP households that lose food purchased with their benefits, provided

they report the loss within ten days. If a State believes that the severity of the disaster
would prevent households from requesting replacement benefits within the normal

timeframe, it can request a waiver of the timely reporting requirement in order to allow
impacted households sufficient time to report their losses and request replacement
benefits. This waiver request is handled by FNS’ Retailer Policy and Management
Division and does not require an IA declaration. Under the waiver, if the timely

reporting day end date falls on a weekend, the reporting period is extended to the next
business day.

⁂ Automatic/Mass Replacements

The automatic/mass replacement waiver allows a State agency to replace a

portion/percentage of currently certified households’ monthly SNAP allotments in a

disaster without the requirement that a household request a replacement, individually,
and travel to a local office to sign an affidavit of loss. Under this waiver, households

will not have the added burden of signing paperwork and local offices will not have to
process cases manually for each household needing a benefit replacement.

The replacement percentage is not fixed and generally depends on the time of the

month in which the disaster took place as well as the State’s issuance schedule. The
request for an automatic/mass replacement waiver is handled by RPMD and may be

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requested even if there is no disaster declaration or the State does not plan to operate
a D-SNAP.

The State needs to assess the extent of the losses to make a determination as to the

percentage of benefits to be replaced. The automatic/mass replacement waiver should

be submitted to the Regional Office. The Regional Office will forward the waiver
request to RPMD for consideration.

Although each request is handled case by case, RPMD considers various data sources

when making an automatic/mass replacement determination, such as evidence that 50
percent of the households in a defined area (i.e. county, zip code, and neighborhood)

have sustained damage that lead to food loss. The most commonly used data is power
outage charts or maps which indicate an extended outage of four hours or more

affecting the majority of the population. Four hours is the minimum power outage time
needed, but States may choose to designate a longer timeframe, if appropriate. In

addition, the likelihood of perishable vs. non-perishable food loss should be taken into

consideration. For example, during a power outage, only perishable food would be

lost, however, in a flooding situation, both perishable and non-perishable food items
may have been lost.
Food Loss

The loss of food due to the disaster can have a profound impact on vulnerable

households. Households already known to be most in need – ongoing clients – can

always request the replacement of lost food that was purchased with their SNAP

benefits. In recent years, many States have opted to allow new households whose only
adverse effect is food loss to qualify for D-SNAP if they are otherwise eligible. This

policy results in a higher number of eligible households which may lead to increased

crowds at D-SNAP sites. States interested in using food loss alone as a qualifying

factor for D-SNAP eligibility should carefully consider the needs of the effected

population and the resources available to serve large numbers of applicants.

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Figure 9. Questions to Consider in Using Food Loss Only

Is the State agency prepared to...
•Use disaster impact data to confirm households' residence in the areas most
likely to have experience extended power outages or other conditions that
would cause food loss?
•Designate alternate sites and have sufficient staffing to handle high
applicant volume?
•Issue benefits to large numbers of applicants in a timely manner?

It is D-SNAP policy that food loss should be verified where questionable. Any State

considering a “food loss only” eligibility policy should use available verification, such as

power outage maps showing affected homes or zip codes, to guard against fraud in

this area. The use of this information should be widely publicized and households
screened upon arrival to verify their residence in the affected area. Households
reporting excessively large amounts of food loss, or any other questionable

information, should be referred to fraud investigators or senior staff for further review
and the State may consider delaying issuance of D-SNAP benefits.
Disaster Standard Expense Deduction

With FNS approval, a State may choose to utilize a Disaster Standard Expense

Deduction (DSED) in lieu of actual disaster expenses incurred by a household, provided
that food loss alone is not the only qualifying expense. The DSED currently used by

several States is based on information gathered from actual disaster-related expenses
reported in a prior D-SNAP in which food loss alone was not a qualifying disaster

loss. As the DSED is designed to capture food loss along with other disaster-related

expenses, such as loss of income and damage to or destruction of property, it must
not be applied to cases in which food loss is the only disaster-related expense.

Only households with actual, unreimbursed disaster-related expenses equal to or

greater than $100 qualify for the DSED. Households with deductible disaster-related

expenses that fall below the $100 threshold should have their eligibility determined

using their actual expenses. If a household has disaster expenses which exceed the
DSED for its size, the State may, at its option, use actual expenses to determine

eligibility. This requires materials and worker training on both methods of eligibility

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determination. All applicants must list the type and value of their actual disasterrelated expenses on their D-SNAP applications.

For households with $100 of more in deductible disaster-related expenses, the DSED

is added to the Disaster Gross Income Limit (DGIL) and households whose take-home
pay plus available liquid resources is less than or equal to the DSED+DGIL would

qualify for D-SNAP benefits. The DSED-DGILs are updated annually and the amounts

for the appropriate fiscal year should be used for each disaster program.

Figure 10. Example Determining Eligibility with Disaster Standard Expense Deduction
The State computes DSED-DGILs using a DSED of
$1,187 for a 3-person household + the $2,151
DGIL for the same household size to arrive at a
limit of $3,338.

A 3-person household applies for D-SNAP and
attests that it has incurred deductible disasterrelated expenses during the benefit period.

The eligibility worker compares the household’s
actual take-home pay and liquid resources of
$3,072 to the limit of $3,338 and determines that
the household is eligible for D-SNAP.

States electing this option should include it, along with the approved income limits in

their D-SNAP plans. States may utilize the existing DSED or may create their own

based on actual expenses reported in past D-SNAPs. Any State wishing to create a new
DSED must do so in consultation with FNS. In reviewing State D-SNAP plans each year,

FNS Regional Offices must inform the National Office of any States that intend to utilize
the DSED option. While a State may deviate from its plan to either use a DSED or not

depending on the circumstances of a given disaster situation, FNS encourages

forethought in this area, as the use of the DSED requires updated annual figures,
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potential modifications to materials, including D-SNAP applications, and thorough staff
training.

As with any option, there are a number of issues to consider before making a decision

about the use of a DSED. FNS urges interested States to weigh these factors, to discuss
possibilities with their Regional Office, and to engage other States that have utilized a

DSED in the past to share lessons learned.

Figure 11. Best Practices of Utilizing a Disaster Standard Expense Deduction

DSED is best suited to disasters where:
•Most households incurred damages to their homes, not just power outages
•The number of applicants is likely to be high and the streamlined
certification process with the DSED would promote timely processing of
applications
•Disaster impact data, such as power outage, flood, or evacuation maps are
readily available to the State agency for verification
•Sufficient resources are in place and staff have been adequately trained on
both the normal D-SNAP and DSED eligibility calculations

4.4 Drafting the Request

D-SNAP requests must be submitted with a signed cover memorandum from the State

and should include thorough explanations of the components listed below. Well

documented requests can be considered and approved more quickly, minimizing the
time needed for follow-up and revisions. Providing careful consideration of these
components in the request helps give FNS a more complete understanding of the

situation on the ground, the State’s readiness to begin program operations, and

potential red flags that could inhibit the State’s ability to implement a successful
program. Submitting this information up front gives FNS and the State partners

adequate time to make any necessary changes without delaying the start of program
operations.

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When transmitting requests to the National Office, FNS Regional Offices should note

any deficiencies in the State requests. Requests should be transmitted to the NO the
same day they are received in order to minimize the time between submission and

approval. The National Office can review the request and begin preparing a response
at the same time the RO is working with the State agency to clarify questions and

obtain any additional information. FNS strongly encourages the use of the D-SNAP

Waiver Request Template included in the Toolkit for State Agencies. The template
includes fields for all of the components noted below.
Components of the D-SNAP request
•

Disaster. Describe the incident – what, when, where.

•

Area. Note the geographic area included in the IA declaration and explain any

differences between the area included in the declaration and the requested area

in which to operate the D-SNAP.
•

Application Period. Give the start and end dates of the application period. If it

will be staggered, give dates for each county/area. Note if application sites will
be open over the weekend or for extended hours.

•

Benefit Period. Note the start and end dates of the 30-day period. The start of

the benefit period should generally match the first day of the “incident period”
on the disaster declaration. If not, explain the reason for the difference.
•

Eligibility. Include information on any options the State has chosen, including

whether or not food loss only will be a qualifying expense and if households
that worked but did not live in the disaster area will be eligible.
•

Expenses. Is a disaster standard expense deduction (DSED) being used? If so,
include income limits.

•

Ongoing Households. Will supplements be automatic or individual (by affidavit)?

If automatic, describe who is eligible and include supporting data. Also,

indicate an estimate of the value of issuances for automatic supplements. If

individual, include information on the process for requesting supplements – by

phone/mail affidavit or in person at local office/D-SNAP application site.

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•

Affected population/anticipated number of applicants. Include total number of

people, homes, businesses, etc… impacted by the disaster, estimates of

anticipated D-SNAP applicants, number of ongoing households to be served,
and an explanation of how both estimates were derived.
•

EBT. Describe issuance procedures, the number of cards on hand, and plans for

requesting, receiving, and distributing additional cards as needed.
•

Logistics. Describe application site(s), plans for publicity, and security/crowd

control. Address potential access issues for the elderly and persons with

disabilities.
•

Staffing. Include plans for utilizing staff from other program areas, counties, or

States, as appropriate. Indicate number of staff available and how
staff/supervisors will be distributed among the application sites.
•

Public Information/Outreach. Describe how program information will be

disseminated to the public. List partner organizations involved and describe the

responsibilities of each, including the role of volunteers, if applicable. Examples
of partner activities include spreading D-SNAP information on behalf of the
State or providing onsite application assistance.
•

Duplicate participation. Indicate how/when checks will be conducted and

include information on any special circumstances, such as border State issues.
•

Program Integrity. Describe fraud prevention strategies and security measures

in place.
•

Employee applications. Describe procedure for identifying and handling

applications by State agency/State employees. See the Prevent Employee Fraud
section for full list of required measures.

•

Additional information. Include draft press releases, sample application,

Preliminary Damage Assessments, IA declaration, and map of disaster area. In
addition to these required items, any other supporting documentation may be
included.

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4.5 Post-Approval

In a post-disaster environment, everyone wants to ensure that survivors have access to

the resources they need, so D-SNAP requests and approvals move quickly. After a DSNAP has been approved, the program may need to change for various reasons, such
as the addition of a new county to the IA declaration, an overwhelming number of

applicants, or a policy decision made at the State level. These circumstances, as well
as options for handling the transition back to normal program operations are
discussed below.

Changes to the D-SNAP after Implementation

The Stafford Act gives FNS authority to approve D-SNAP requests and any changes to
the D-SNAP require signed waiver approval from FNS. As with the initial submission,
State agencies must submit written, signed requests for changes to a D-SNAP.

Regional Offices should provide informal notice of any potential changes (via phone or
email) to the National Office as soon as they become aware of the State’s desire to
submit the request.

These requests, and their corresponding approvals, are generally shorter and can be

approved more quickly than the initial waiver, since much of the information about the
disaster is already known. The three types of changes to the D-SNAP are listed below,

along with an explanation of each.

Expansion: After initial approval, a State agency may want to expand operations

because an additional county has been added to the IA declaration or because the State
determined that a previously declared county was in need of the program. While the

application period in the expanded area may differ from what was originally approved,

the benefit period will generally remain the same. In such cases, the State agency

should submit to FNS a request for expansion, detailing the impact of the disaster in
the new area, the application period, and the anticipated number of applicants and
ongoing clients that will be served. If the benefit period will change, for example,

because flooding due to the same storms struck another County at a later date, the
new benefit periods dates and justification should also be included.

Extension: In some cases, States may find that their initial application period is not

sufficient to serve all eligible households and they may wish to request that the

application period be extended. In considering extension requests, FNS carefully

weighs ongoing need in the area with program integrity concerns. Requests to extend
the D-SNAP application period must be submitted with sufficient time for FNS review

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and approval prior to the end of the initial application period and should be

accompanied with strong justification of the need for additional time. Note that once
the application period has ended and operations have closed, further extensions are
not permitted.

Modification: A request to change an aspect of the D-SNAP other than those

mentioned above is known as a modification. Most modifications, including any that

would affect applicant eligibility, should only be made prior to the start of the

application period to ensure that the eligibility criteria are applied equitably to all

applicants. Occasionally, modifications may be made after the program has begun,

such as when a State that was originally approved for individual supplements decides
to issue automatic supplements in a certain area. Because of the limited window of

time in which most modifications can be requested, FNS encourages State agencies to
carefully consider their desired program options prior to submitting their initial
request.

4.6 Additional Resources

Resources to assist States in drafting their D-SNAP requests and planning for program

operations, including application and affidavit templates, sample press releases, a site

selection checklist, and a list of State/Regional contacts can be found in the Toolkit for
State Agencies.

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Part 5. Operating a D-SNAP
This Section offers guidance for State agencies as they prepare to implement their
D-SNAPs.

Highlights include:
•
•
•
•
•
•
•
•

Public Information
Site Set-Up

Application Processing
EBT Issuance

Daily Reporting

Fraud Prevention

Changes to the D-SNAP

Troubleshooting Administrative Challenges

5.1 Public Information

It is essential to take a proactive approach to public information and outreach from the
start of the disaster response. Providing accurate, timely information to the public

about what D-SNAP is, how it works, and who may be eligible is a crucial first step in
ensuring a successful program. FNS recommends allowing at least 2 days from the
start of publicity efforts to the beginning of the application period to allow people

enough time to hear and absorb the messages being presented. Experience has shown

that offering clear, consistent information about the topics below is particularly

important for crowd control, efficient application processing, and program integrity.
In developing public information campaigns, States should utilize all available outlets

to reach people. Given the fast pace of D-SNAP and the increasing use of social media,
such as Facebook and Twitter, by the public, FNS encourages States to use these new

ways of communicating in addition to traditional means, such as press releases, radio

and television PSAs, State websites, and newspaper articles. If State policy allows, FNS

encourages State agencies to explore the use of social media to broadcast messages to
the public about the items below. At minimum, States should closely monitor social
media sites for misinformation and potential program integrity concerns.

Organizations with whom the State agency partners for SNAP outreach can also assist
in getting information out to the public about D-SNAP. However, the State must

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ensure that partner organizations have a solid understanding of D-SNAP, the ways in

which it differs from SNAP, and the specific eligibility criteria and operational details of
each program. Clearly defined roles and responsibilities as well as lines of

communication, as discussed in the planning section, will help outreach partners to
serve as an effective resource in disseminating accurate, up to date D-SNAP

information to the affected population.
D-SNAP Eligibility Criteria

States have reported varied experiences with publicizing D-SNAP eligibility criteria.
Some find that it helps keep ineligible people from coming to the application sites
while others feel that it can have a negative impact on program integrity. FNS

encourages all States to publicize the geographic criteria, including whether those who

lived or worked in the area may apply. The public must also be informed that all

applicants are required to bring proof of identification and should bring any other

verification documents they may have. States should carefully consider whether they

believe releasing the income limits and the use of food loss as a qualifying criterion is
in the best interest of their respective programs. Sample press releases in the Toolkit
for State Agencies offer examples of both releasing the specific information and of a

more general notice that advises low-income households with disaster-related

expenses that they may qualify.
D-SNAP & Ongoing Clients

Ongoing SNAP households may be confused about their D-SNAP eligibility. Disaster

benefits for SNAP clients come in the form of a supplemental issuance to bring their

benefit to the maximum monthly allotment for household size. Public information

materials should clearly indicate the State’s supplement policy and provide affected
SNAP households with directions on how and where to obtain their supplemental
benefits. If supplements are being issued automatically, the material should

encourage ongoing households not to come to the site in person. Public information

materials should provide a contact number or a website where SNAP households can

find answers to any questions about their disaster benefits, including supplements and
replacements.

Where & When to Go

Publicity materials must include application sites for each county or area and should

indicate at what site(s) households in a given area can apply. It is important to indicate

the operating hours/days at each site, including if they will be accepting applications
on weekends or beyond normal business hours. If supplements are being issued in-

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person via affidavit, FNS encourages States to direct ongoing clients to their regular
SNAP office and set up an alternate site for new D-SNAP applicants.
What to Bring

States should notify potential applicants of any required and recommended documents
to bring to the application site. Even where verification is not required, FNS

encourages States to request that applicants bring any documentation they have.

Verification requirements are discussed in more detail in Section 4.3.
Program Integrity

In addition to the notices posted at the application site, public information campaigns
prior to the start of D-SNAP operations should inform potential applicants that

duplicate participation checks will be in place and that there are civil and criminal

penalties for committing D-SNAP fraud. The policy of delaying benefit issuance and

conducting further review of questionable applications should also be publicized. The

State may also wish to inform the public that it will be using resources such as maps to
verify residency in an affected area and wage matches to verify income. See Fraud
Prevention for a complete discussion of this topic.
Information for SNAP Retailers
In addition to publicizing information about eligibility and application procedures, FNS
encourages States to share information about D-SNAP with their authorized retailers
and EBT contractors, particularly in large disasters. Information can include:
•
•
•

Disaster waivers (e.g., hot foods waiver)

Estimated number of new D-SNAP clients
Possible changes to EBT card design

5.2 Site Set-up

Selecting an appropriate site and designing a layout which allows for orderly and

efficient application processing will help ease the burden of administering a D-SNAP

and make the experience as comfortable as possible for applicants. A number of

checklists to assist in finding and preparing D-SNAP application sites are included in

the Toolkit for State Agencies, including:
•
•
•
•

Application Site Selection Guide

Application Site Supply Checklist
Human Comforts Checklist

Application Site Readiness Checklist

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Security

Ensure that the level of security is commensurate with the anticipated number of

applicants. A strong security presence can go a long way in minimizing fraud and

maintaining control of large crowds. Suggestions for improving security on site are

detailed in the following table.

Figure 12. Improving Onsite Security
EBT Security
•Restrict access to issuance storage sites by arranging seating, eligibility determination
areas, and queues away from this area
•Minimize the number of staff that have access to the issuance/storage sites
•Coordinate card security procedures with law enforcement personnel onsite

Staff/Applicant Security
•Arrange site to minimize crowd density during wait
•Provide private break rooms and bathrooms to staff
•Minimize visibility of special treatment for elderly/disabled individuals
•Post signs at certain places in line estimating the wait from that point. Include hours
and days of operation for clients who prefer to return at another time.
•Give out numbers to reduce disputes over places in line.

Crowd Control
•Direct applicants with special needs to appropriate lines/waiting areas
•Utilize a zigzag pattern to manage a long line and create staging areas to keep people
moving
•Use the PA systems to broadcast pre-recorded, looped informational messages in
multiple languages.
•May assign households specific days within the application period based on an
arbitrary factor, such as the first letter of last name
•If all applicants in line cannot be seen, designate a cut-off point and issue tickets to
those beyond the cut-off to for priority return the next day.

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Staffing

States should anticipate that staff residing in areas affected by the disaster will need
time away from work to prepare for or recover from the disaster, so not all

county/local staff will be available to contribute to the D-SNAP. In cases where the
number of available county/local staff is insufficient to staff D-SNAP sites, States

should consider temporarily transferring staff from unaffected areas of their State or
requesting assistance from neighboring States. State agencies may also hire

temporary staff to operate the D-SNAP, as long as that staff are hired under State merit
system rules. State agencies should note that employment records of temporary staff

are subject to the same record retention and D-SNAP application review rules as those
of permanent staff.

See the “Staffing Suggestions” chart in the Toolkit for State Agencies to help identify

some of the staffing needs an agency may have, and some possible sources for needed
staff. Approximate staffing levels assume an efficient all-paper process. State

agencies employing online pre-registration or web-based D-SNAP applications should

expect significant changes to staffing needs and plan accordingly. FNS suggests

completing this table with specific sources or staffing needs identified during pre-

disaster planning. Maintain a list of the names, potential duties, and phone numbers
for key staff for reference during a disaster response.
⁂ Staff Comfort & Health

A successful program cannot be run without the help of dedicated staff. Staff burnout
and turnover can be minimized by providing adequately for their needs. If possible,
staff should be provided with:
•
•
•
•
•
•
•

Private break rooms

Separate bathroom facilities.

Temporary housing (for out-of-town staff)
Antibacterial lotion/wipes
Onsite first aid
Water

Meals

Telecommunications

D-SNAP sites will vary in their telecommunications access. States should recognize

that these capabilities can vary from one D-SNAP to the next and even from site to site

within a single program. Whenever possible, FNS recommends that application sites
are equipped with copy machines, scanners, fax machines, landline and/or cellular
phones, laptop computers, wireless connectivity, and printers.

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Depending on the site’s capabilities and the potential for off-site access to the State’s

eligibility or D-SNAP system, client applications may be entered into the system either
on or off-site. In either case, the eligibility determination system used must have the

capability to gather and store information on all household members, not just the head
of household, and must be capable of performing duplicate participation checks for all

household members before determining eligibility. Additionally, the State agency must
check denied D-SNAP applications against the eligibility determination system each

day, so that households that are denied and later reapply are detected and referred to
fraud prevention staff.

Human Comforts

Addressing the human comfort needs of applicants is very important to the disaster

response effort. Applicants may not come prepared for a long wait and will need some
of their basic needs provided for at the application site. Ensuring that these needs are
met is not only good customer service, but is also beneficial to the staff onsite as it

may decrease the likelihood of crowd control issues.
Application/Issuance sites should offer
applicants:
•
•
•
•
•

Water

Protection from the elements
Bathrooms

Snacks, when feasible

Minor medical care, when feasible

Site Layout

Preparing the Site
Use the “Human Comforts
Checklist” found in the State
Agency D-SNAP Toolkit, to help
prepare your application site for
the general population and find
special suggestions for serving
elderly/disabled applicants.

As soon as sites are selected, planning for the

layout and traffic flow should begin. Developing a flow chart and utilizing it during

site set-up can assist in spotting potential bottlenecks and other trouble spots as well

as in identifying staffing, security, supply, and other administrative needs. Particular
items to consider include:
•

Long lines. Will it be problematic if lines extend outside? How will this impact

the number of applicants, public safety in the area, or local traffic flow?
•

Heavy traffic. Will traffic to the site overwhelm local roads or affect daily

commutes? Should local law enforcement be notified of potential traffic/parking
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issues? Can traffic signals be reprogrammed and signs directing people to
alternate routes be put in place if necessary?
•

Parking. Does the site have sufficient parking that will not adversely affect the

local neighborhood if there are large numbers of applicants?
•

Weather. Are all applicants protected from the elements while waiting? How

would the site be affected in the event of inclement weather?
•

Privacy. Are interview areas arranged to allow for applicant privacy?

•

Entrances/Exits. How will the public’s ability to access the site be controlled?

Any special considerations if the site is also being used for other purposes (i.e.,
FEMA DRC, normal public library activities, etc...)

The Toolkit for State Agencies contains sample floor plans, modeled after those used
successfully in previous D-SNAP operations, representing a variety of sites and
configurations.

Posters & Notices

A State agency must post duplicate participation, fair hearing, and fraud prevention

notices at all application sites. Informational materials about how to use an EBT card
and advice for using SNAP benefits may be helpful as well, since new D-SNAP

households may not be familiar with SNAP rules. Sample posters are included in the
Toolkit for State Agencies.

The State agency must provide a written copy of the eligibility determination, as well as
written notification of the option for an immediate onsite review for denied

applications and of fair hearing rights to all applicants. If duplicate checks are being

conducted off-site, the notice should inform clients that any eligibility determination is

preliminary and the final determination is contingent upon the subsequent checks to
be performed. These notices may be combined into a single document.
Language Services

As previously discussed, gathering demographic information prior to the disaster will
help States assess the need for language services in a given project area. States

should follow the same guidelines in D-SNAP as outlined in SNAP regulations in

determining the need for materials in other languages.

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It is important to keep in mind that the

population of D-SNAP applicants will extend

beyond the low-income population served by
the regular program, so the needs of single-

language minorities not living in low-income
areas should be considered as well.

As part of pre-disaster planning, the State
agency should translate materials into the

Outreach Coordinators
Each FNS Regional Office has an
Outreach Coordinator who can help
your State prepare to effectively
utilize volunteers and partner
organizations through both your
Outreach and D-SNAP plans.

major languages spoken by non-English speakers within the State. After translating

appropriate materials, States should keep an electronic copy on file for easy access and
use in a disaster. Please see the Toolkit for State Agencies for sample D-SNAP

application templates in English and Spanish.

In addition to translated materials, onsite interpretation services may be needed. State

should consider all resources available for providing assistance with language
interpretation at D-SNAP sites, including:
•
•
•
•
•
•
•

Current staff

Language lines
Universities
Churches

Community centers

Private assistance agencies

Advocate/legal services groups

Volunteers

In the wake of a disaster, members of the community are often eager to share their

time and skills in efforts to help those affected. Volunteers can be a great asset to D-

SNAP operations, when properly trained and utilized. States planning to use volunteers
should familiarize themselves with any State or local regulations surrounding the use
of volunteers and liability. Volunteers may not be used to handle any merit staff
functions, including interviews, eligibility determinations, duplicate participation

checks, or EBT issuance but can provide extensive support to staff and applicants in
the following ways:
•

Translation/Interpretation. Provide language services to applicants with limited

English proficiency.

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•

Greeter. Welcome applicants as they enter application site and direct them to

the appropriate area.
•

Application Assistant. Distribute

applications, pens, and clipboards. Help
those who have difficulty understanding
or completing the application.

•

Disaster Outreach
Find more information about
effective disaster outreach and the
use of partners in the Disaster
Outreach Toolkit.

Pre-Screener. Talk to applicants waiting

in line about general eligibility criteria (not potential eligibility of a particular
household); review applications for completeness before applicants are
interviewed.
•

Human Comforts. Distribute food/water, direct applicants to restrooms or

medical facilities, assist applicants with disabilities and the elderly.

5.3 Application Processing
Completing the Application

States are responsible for creating and updating their own D-SNAP applications and

may wish to use the FNS template as a guide (See the Toolkit for State Agencies for

application templates in English and Spanish). While FNS recommends developing a

State-specific form during the pre-planning process, the application must be adapted

to fit the parameters of each disaster program. For example, an application for a

program that is using a Disaster Standard Expense Deduction should not include the

normal Disaster Gross Income Limits. The application must include fields for the
collection of information on all individuals in a household and may not contain

questions designed to elicit information beyond the eligibility requirements outlined in
Eligibility. States are restricted from adding other eligibility requirements, without
specific FNS approval.

At the D-SNAP site, staff and/or volunteers should be available to distribute

applications and answer any questions from households as they complete the forms.

Ensure that applications are as complete as possible before clients reach the interview
stage; this will help keep the process moving quickly. Post signs with simple

instructions, verification requirements, definitions of terms, etc… to aid in this effort.
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⁂ Online D-SNAP Applications

As States explore the use of new technologies and update their existing systems, some

have moved toward online registration and/or application for disaster benefits. Several
States have developed online pre-registration systems which go live only during

disaster situations. These systems allow households to submit some of the required
D-SNAP application information in advance. The system can then perform duplicate

participation and other checks before the applicant appears in person at the D-SNAP

site for the interview and required verification.

Web-based application systems, used onsite by State agency staff, have also been

developed and tested by a number of States. These systems allow for real-time

interaction with the State’s eligibility system and eliminate the need for clients to

complete a paper application. States considering either of these options should confer
with their Regional Office to discuss feasibility based on the availability of resources
and technical infrastructure.
Screening

Deploying pre-screeners to the lines or to the pre-interview waiting area is another

strategy to control crowds and improve customer service. Screeners should be familiar

with basic eligibility requirements so that they can readily share this information with
applicants. No applicant should be discouraged from applying; screeners should

simply offer information so that each household may make an informed decision about
whether or not it is worthwhile to stay and apply. Screeners can also check that

applicants have required verification documents and can direct ongoing clients and
new D-SNAP applicants to the correct lines.
Duplicate Participation

As previously noted, information regarding
duplicate participation checks should be

announced in publicity materials and posted at the
application site. States may check for duplicate

Best Practice
States operating a D-SNAP in a
border area may also want to

information up front or may accept applications

consider running duplicate

upon the subsequent duplicate check.

eligibility system of neighboring

States are required to screen for duplicate

were impacted by the disaster.

and inform applicants that eligibility is contingent

checks against the SNAP
States, particularly if both States

participation in:
•
•

D-SNAP and SNAP

D-SNAP and household disaster distribution of USDA Foods
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•
•

Multiple D-SNAPs with overlapping benefit periods

Approved D-SNAP and denied D-SNAP applicants

Interview

The D-SNAP interview, though brief, is an important element in the certification

process as it allows the eligibility worker time to review potentially confusing concepts
(such as the benefit period and deductible disaster-related expenses) and verify

information presented on the application. The State agency must conduct an interview

with all new D-SNAP applicants prior to certifying the household for benefits. As in the

regular program, households unable to apply in person may designate an authorized
representative to apply on their behalf.

⁂ Alternative Procedures to Ensure Access to the Interview

All interviews must be conducted at the D-SNAP site, except under circumstances in
which the State agency determines special alternative procedures are required to

facilitate the interview for applicants otherwise unable to appear physically at the D-

SNAP application site. Best practices for the State agency to consider in providing
reasonable accommodations and interview access to the elderly, persons with

disabilities, and other vulnerable populations include:
•

Satellite application sites strategically located to serve vulnerable populations
(i.e. community or senior centers)

•
•

Special public transport to and from application sites

Home visits to conduct the interview for applicants with disabilities that make
them otherwise unable to visit the application site

•

Skype or similar technology to facilitate off-site interviews

FNS expects and encourages the State agency to

consider the potential needs of disaster survivors

with disabilities in their community and to include
any special accommodations and alternative

interview procedures as part of their D-SNAP plan

and disaster-specific D-SNAP request.

Skype Interview

In 2013, the Colorado State

agency connected applicants at
an isolated local office

with eligibility workers at the

central D-SNAP application site
using Skype, thereby providing

access to the interview for

households unable to access the
application site due to flooding.

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During the D-SNAP interview, the eligibility worker should ask about:
•

Proof of Identity for head of household
o

•
•
•

Confirm names and birthdays of other household members

Household composition as it existed the day the disaster struck
Residency (or employment, if applicable) in the disaster area

Income available/anticipated during the entire benefit period
o

Confirm places of employment for all working members of the household
and record this information on the application

•
•

Accessible liquid resources available at the start of the benefit period
Impact of the disaster on the household
o

What adverse effects did the household suffer (i.e., flooding, wind

damage, power outage)
o

How much did they pay (or do they anticipate paying during the benefit

period) for these expenses?
o

How did they pay for these expenses? (only expenses paid out of pocket
and not merely incurred, are countable)

Did they receive reimbursement for any of these expenses?

In the past, some States have struggled with conducting interviews for all applicants
each day. States that anticipate large crowds should plan for sufficient staff and

application sites large enough to accommodate the volume of applicants. Some States
have found it helpful to advise applicants to come on a specified day, assigning days

based on the first letter of last name, in order to disperse the crowds evenly across all
days of the benefit period. However, any applicant coming to the site on a day other
than the one assigned should still be interviewed and not told to return on the
specified day.

In the past State agencies that were overwhelmed by the number of applicants have
issued numbered tickets to applicants that cannot be interviewed on a given day so

that they may return and be seen early the next day. This option should only be

considered as a last resort and State agencies considering use of this tactic should

consult with FNS prior to implementing this strategy. States considering issuing tickets

should take care to:
•
•
•

Create tickets that cannot be copied

Associate ticket numbers with client names

Ensure that people do not leave the site with copies of the D-SNAP application

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States often distribute applications to people waiting in line in order to speed up the
application process. Note that, if a completed application is submitted and the

household is not able to be interviewed that same day, the date of submission, not the
date of interview, is considered the application filing date. The State agency will use

the filing date as the start of the 3-day period in which benefits must be issued if the

household is determined eligible.
Verification

Verification rules are eased during a disaster to reduce administrative burdens and to
reflect the reality that households and eligibility workers may not have access to the

usual verification sources. State eligibility staff should exercise reasonable judgment
when evaluating the truthfulness of applicant statements. Figure xx details the DSNAP verification requirements.

Public information campaigns should indicate that applicants are expected to bring all
available verification documents, including those that are not required. In addition,

FNS encourages the use of data matching systems, such as the income and eligibility
verification system (IVES) and the Beneficiary and Earnings Data Exchange (BENDEX),

whenever possible and recommends that States publicize their intent to verify

information through data matches in order to deter and detect fraud. The data in the
system will not be able to provide an updated picture of household circumstances
post-disaster; however, the matches may assist in finding unreported sources of

income and suspect cases could be referred to program integrity staff for further
investigation.

Figure 13. Verification Requirements

Applicant Information

Status

Identity

Mandatory for
applicant

Suggested Ways to Verify
•
•

Photo ID.

Two documents that verify identity and
residency.

•

Signed affidavit from a collateral contact
attesting to the identity of the applicant,
where other sources of identity are not
available.

Residency

Where possible

•

Utility bills, tax bills, insurance policies,

driver’s licenses, other ID with address, bills,
or other documents that establish the

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applicant’s home or work address.
Household composition

If questionable

• After taking the application, the eligibility

worker can ask the applicant to orally list the
names, ages, and birthdays of all household
members.

Loss or inaccessibility of
liquid resources or of

Where possible

• Obtain a list of banks/ATMs that were closed

due to the disaster and compare with damage
maps.

income

• Check with the State Banking Commission.

• Confirm that applicant’s place of work was

located within most seriously damaged area.

Food loss

If questionable

• Use maps or lists to verify that applicant lives
within an area affected by power outage,

flooding, evacuation, etc….

• Confirm with the power company.

⁂ Questionable Information

Each disaster is different and in some disasters it will be easier for households to

document and State agencies to verify information than in others. Eligibility staff

should consider this in making an eligibility determination. In addition to the interview
strategies noted above, States:
•

MUST refer clients without required verification or with inconsistent information
to onsite investigators or highly experienced staff/supervisors for review.

•

MAY delay the issuance of benefits for up to 7 days from the date of application

(instead of the normal 72 hours) to allow some verification or cross-checking

for those with questionable applications. Delayed issuance should always occur
when eligibility staff suspects fraud.

Data Entry & Certification

States may use their regular SNAP eligibility system or a separate D-SNAP system to

certify applicants, provided that they can conduct the required duplicate checks with
the system they select. Data on all household members for all applications (denied

and approved) must be entered into the system. This may be done onsite to allow for
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upfront certification. Alternatively, applications may be gathered at the site and

delivered to another location, such as the local or central office, for data entry and
processing.

⁂ Off-site Data Entry

States selecting this option should be prepared to deliver batches of applications

several times per day, depending on volume, and must take into consideration data

security and privacy concerns. The time delay associated with this method should also

be taken into account as delays in data entry can result in delayed issuance and benefit
access for households in need. Finally, the normal data entry cut off times built into

the system may need to be amended to ensure that benefits are accessible to the client
within 72 hours of application, except in questionable cases in which the State may
delay benefit issuance for up to 7 days, as noted above.
⁂ Separation of Duties

Certification and issuance responsibilities must be separated in order to minimize the
risk of employee fraud. Volunteers may not participate in any certification, interview,
data entry, or issuance functions.

Assistance to Ongoing Households

If SNAP clients are being served at the same site as new D-SNAP applicants, there

should be separate lines and workers designated to work with each group. Ongoing

households do not need to complete a D-SNAP application; they only need to complete
an affidavit of disaster loss (unless supplements/replacements are issued

automatically). In addition, SNAP households’ identities and circumstances are already
known to the State agency, so they need not participate in a D-SNAP interview.

Even if supplements/replacements are issued automatically or if ongoing households

are directed to their local offices to request disaster assistance, the D-SNAP site must
be prepared to handle some regular SNAP clients who come seeking help. The site

should have available affidavits of disaster loss <> and a separate
line to serve any ongoing clients.

The following chart details the differences in eligibility and applications requirements
for new D-SNAP households and ongoing SNAP clients.

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Figure 14. D-SNAP Applicants vs. SNAP Households

SNAP
Households

Sign affidavit
requesting
replacements and/or
supplements (unless
issued automatically)

D-SNAP
Applicants

Complete D-SNAP
application
Must apply in person

Do not need to apply
in person

Must complete DSNAP interview

No interview required

The options for providing disaster benefits to ongoing SNAP households are discussed

in greater detail in Section 4.3. Specific operational considerations for each option can
be found below.

⁂ Automatic Supplements
•
•
•

How will clients be notified?

How will the system be programmed to issue the supplement?
When will this occur?
o

FNS recommends issuing the supplemental benefit prior to the start of
the D-SNAP application period, if possible, as ongoing clients are less

likely to go to the site if they have already received their benefits.
⁂ Individual Supplements
•
•

How will clients be notified?

How can clients request a supplemental issuance?
o

FNS encourages States to allow clients to call their local offices and

request that an affidavit be mailed to them or to provide electronic forms
for mailing or secure e-signature/submission.
o

States can also elect to accept affidavits in person at local offices and/or
D-SNAP application sites.

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•

When will this occur?
o

Clients may only request supplements during the D-SNAP application
period. If affidavits are being mailed, request must be made during

application period and the State agency may determine a reasonable time
period within which the affidavits can be returned or mailed to the office
for processing.
o

Affidavits mailed to the local office must be postmarked by the last day of
the application period.

⁂ Automatic/Mass Replacements
•
•

How will clients be notified?

What will the replacement percentage be?
o

In requesting automatic replacements, States must determine an
appropriate percentage of the month’s benefits to be replaced,

depending on the timing of the disaster within the issuance cycle.
o

States should work closely with their Regional office and the Retailer
Policy and Management Division to determine the replacement rate.

•
•

How will the system be programmed to issue the replacement?
When will this occur?
o

FNS recommends issuing the replacement benefit prior to the start of the
D-SNAP application period, if possible, as ongoing clients are less likely
to go to the site if they have already received their benefits.

⁂ Individual Replacements
•
•

How will clients be notified if the timeframe for reporting has been extended?
How can clients request a replacement benefit?
o

FNS encourages States to allow clients to call their local offices and

request that an affidavit be mailed to them or to provide electronic forms

for mailing or secure e-signature/submission.
o

States can also elect to accept affidavits in person at local offices and/or
D-SNAP application sites. This decision may depend on the time period
during which replacements may be requested as the period may have
passed before D-SNAP operations begin.

•

When will this occur?
o

Clients may request replacements:



During the ten day period following the loss, or,

Under the extended timeframe for requesting replacements if the

State has been approved for a waiver of the reporting deadline.

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Special Cases

During D-SNAP operations, questions often arise about households with special

circumstances. The following chart details the appropriate handling of these cases.
Figure 15. Households with Special Circumstances

Household Circumstance

D-SNAP Eligibility

Applied for but not yet receiving SNAP

Eligible as a new D-SNAP applicant

Received D-SNAP benefits for another

Not eligible for D-SNAP

Ongoing SNAP households with mixed

Individuals considered part of the SNAP household

disaster within the same benefit period
eligibility

Not income eligible for D-SNAP but

can receive a supplemental issuance; others can
apply as new D-SNAP households

Not eligible for D-SNAP; State agency may provide

eligible for SNAP under Broad-based

application for regular SNAP and certify household

Temporarily residing in a shelter

Eligible for D-SNAP, if household is not expected to

Categorical Eligibility criteria

Zero-benefit households

for ongoing benefits as appropriate

remain in the shelter for the entire benefit period
Eligible as a new D-SNAP applicant

Onsite Review

FNS requires that States provide for immediate, onsite supervisory review for denied

applicants. Eligibility workers should notify applicants of the right to this review, and
that it will not affect their right to a fair hearing. Denied cases must be inputted into
the State’s system in order to allow for duplicate checks and may not be reopened;
clients whose circumstances have changed after they filed an application and were

denied must reapply for the D-SNAP during the application period. Previously denied
households that reapply must be referred to supervisory staff or investigators for
review.

5.4 EBT issuance

By the time D-SNAP operations begin, States will have already selected their method of
card issuance. During the application period, the State agency will need to maintain a
sufficient supply of EBT cards to ensure that certified households are able to access

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their benefits within 72 hours of application (except in cases of delayed issuance for

questionable applications). Pre-existing plans for storing and distributing cards within
the State may need to be adjusted based on actual applicant volume at various sites.
Replacing Cards and Benefits for Ongoing Clients

Ongoing SNAP recipients may lose their EBT cards in a disaster, especially when they
have to relocate quickly to avoid harm. The EBT disaster system design should

incorporate procedures for ongoing cases to receive replacement cards as soon as
possible. For example, if the normal EBT replacement process is to mail the

replacement card to the recipient’s home, and the disaster response requires card

delivery to a disaster issuance site or alternative address in a non-disaster area, the

State must be able to override the regular EBT system.

It is possible that SNAP and D-SNAP clients who have been issued replacement benefits
for food lost in the disaster may subsequently lose that food in a second disaster or

power outage. In both instances, the procedure for replacing these benefits is the

same for any other issuance: in order for the State to replace the benefits, the client
would need to file an affidavit of loss in a timely manner.
Reconciliation

The State agency must develop a system for reconciling both cards and benefits.

Cards shipped from a central location should be tracked until distributed locally to

households. Each issuance site needs to maintain a beginning and ending inventory

and track new cards received, total cards available, and cards issued. The method of

distribution for cards – whether drop shipped, pulled from blank card stock, or mailed

or delivered by some other means will most likely dictate the specific requirements for
reporting and reconciliation. If the State assigns PINs, they must also account for PIN
mailers or envelopes to ensure adequate security, except when the PIN is formulated

from the Primary Account Number. The State must also reconcile the number of cards
set-up with EBT accounts and the number of cards issued and then research and
explain any discrepancies.

It is important that States track disaster benefits separately from ongoing benefit

issuance. Some States have defined distinct disaster food benefit codes to allow them
to track the disaster benefits on their EBT contractor’s system, which eases benefit

reconciliation each day. The EBT contractor has added separate disaster benefit lines
to administrative screens to enable the States to track disaster benefit drawdown
distinctly from ongoing benefits. States also must adhere to FNS reconciliation

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guidelines so that they can compare benefits posted to accounts to benefits issued by
the State eligibility system.
Expungement

State agencies may request to use a shorter timeframe (typically 90 days) for

expunging disaster benefits than for expunging regular SNAP benefits. Following the
implementation of the Food and Nutrition Act of 2008, this waiver requires approval

from FNS. State agencies that wish to implement this waiver must submit it along with
their D-SNAP requests to their respective Regional Offices for transmittal to the

Retailer Policy and Management Division. Any State operating under this waiver must

inform D-SNAP households of the timeframe for expunging benefits. This waiver may

only be used when the State has received an IA declaration and is operating a D-SNAP.
System designers must work with the EBT contractor to develop a process for

expunging disaster benefits from the EBT system. To do this, the State system must

identify the disaster cases and benefits uniquely, which is required for FNS reporting,

as well. The EBT provider should make a corresponding report to the State agency to
identify the value of disaster benefits expunged.

5.5 Daily Reporting

A State operating a D-SNAP must submit a daily report to its FNS Regional Office. The

RO will share this with the FNS National Office on the day it is received. Daily reports

are used to monitor program progress, troubleshoot problem areas, inform FNS policy
officials, and respond to inquiries from the media and other government agencies.

The State agency should begin submitting reports to their Regional Office on the day

following the first day of D-SNAP operations and continue submitting the reports on a

daily basis until all applications are processed. Reports must be submitted each day

even if no or very few applications have been submitted.

FNS requires that all States utilize the daily reporting template found in the Toolkit for

State Agencies. Data should be submitted by county, as indicated in the template. The
reports must contain:
•
•
•
•
•
•

Number of new households approved

Number of ongoing households receiving supplements
Number of new persons approved

Number of ongoing persons approved for supplements
Number of new households denied

Value of new benefits approved

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•
•
•

Value of supplements approved

Average benefit per new household

Average benefit per ongoing household

States may use the daily reporting sheet to track replacement benefits as well;

however, replacements are not considered disaster benefits and need not be reported

on the daily DSNAP reports as they are to be reported separately after the D-SNAP. See

Certification Reporting Post-D-SNAP for more information, including form FNS-388

which should include replacement issuance.

In addition to the quantitative data, the inclusion of any qualitative information with
the daily reports will help keep State and Federal policymakers up to date on the

situation on the ground. FNS encourages State agencies to submit these anecdotal

observations, along with any questions or concerns, to their respective Regional Office
throughout the application period.

5.6 Fraud Prevention

Effective fraud prevention strategies must begin in the pre-planning phase. In the

wake of a disaster, the focus is often on how to get benefits to survivors as soon as

possible. Agencies must find a balance between responding quickly and encouraging
participation and protecting program integrity.

State agencies should work with investigative staff from the start of the disaster

response to ensure that program integrity issues are addressed proactively. Focusing

on integrity during all phases of the disaster response will also minimize the likelihood
that problems will need to be addressed through audits. Thorough training of all staff
and supervisors on D-SNAP policy and fraud prevention strategies will also aid in this

effort.

Application/Issuance Site Controls

An important aspect of fraud prevention is appropriate internal controls. In order to

ensure that only eligible households receive benefits and that the amount of benefits
issued is accurate, States operating a D-SNAP must:
•

Input information for all household members into the eligibility determination

system to prevent individuals from obtaining benefits as a member of more than

one household.

•

Input denied applications into the eligibility determination system each day, so

that households that are denied and later reapply are detected and referred to

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fraud prevention staff. Note that such households may be eligible if their

circumstances have changed.
•

Check for duplicate participation using onsite or offsite computer databases or
hardcopy participant lists. Update computer database or hardcopy participant
lists every day.

•

Refer clients without required verification or with inconsistent information to
onsite investigators or highly-experienced staff for review.

In addition, State agencies may:
•

Confirm household composition by asking applicants at the start of the

screening interview for names and dates of births for all household members
and then requesting they repeat the information later.
•

Delay issuance of benefits for up to 7 days from the date of application to allow

some verification and/or cross-checking, either for all applicants, or for those
with questionable applications.

•

Request that households bring verification of non-required items (household
composition, residency, income/resources, and food loss) provided that

applicants are not denied based solely on the unavailability of verification.
Information for Applicants

The more information applicants have about eligibility and verification requirements,

the less likely they are to inadvertently provide erroneous information. States should
distribute fliers or play recorded messages at sites (in appropriate languages) with:
•
•
•
•

Program requirements

Administrative, criminal, and civil penalties for fraud
Notice that anti-fraud measures are in place

Review procedures, including 100% review of employee cases and requirements
to repay any overissuance

•
•

Results of completed investigations and/or arrests for fraud

Any existing State hotline number, website, or email address for reporting
applicant or recipient fraud

•

Information on what cannot be purchased with SNAP benefits

Prevent Employee Fraud

FNS recognizes that, in many cases, State agency employees are among the disaster
survivors and some may be legitimately eligible for D-SNAP benefits. States should

take care to balance encouragement of eligible employees to apply for program

benefits with the real risk that some close to the program may take advantage of their

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access to fraudulently apply for or issue benefits. FNS requires that State agencies
take these special measures to prevent employee fraud:
•
•

Use separation of duties for certification and issuance.

Include a question on the D-SNAP application asking if anyone in the household

is employed by the State or State SNAP agency.

•
•

Utilize supervisors or investigators to conduct employee certification interviews

Audit all approved State agency employee applications and publicize that policy.
FNS expects the State agency to review all approved applications from its
employees and to communicate that to employees up front.

States can also exercise additional methods of preventing employee fraud, including:
•

Auditing applications from all State and/or County employees, not just those
employed by the State SNAP agency.

•
•
•

Auditing all applications from volunteers and others onsite, such as local police.

Auditing denied applications from State agency employees.

Conducting a wage match for all State/County employees prior to issuing

benefits, if possible, or as part of the post-disaster review process.

•

Maintaining updated inventory of office equipment/supplies and comparing the
original list with what is present at close-out.

Monitoring and Reporting

FNS Regional Office and State agency staff should monitor all fraud prevention efforts
throughout the application period. Specific fraud concerns (i.e., a household that

applied at two different sites) should be flagged and shared among all application sites
and staff. Program integrity procedures should be modified as needed during D-SNAP

operations. Ongoing fraud issues, particularly those concerning employees, should be
promptly reported to FNS, so that we may provide oversight and guidance in dealing
with the issues.

5.7 Changes to the D-SNAP

As discussed in Post-Approval, a State may request waivers subsequent to the initial

approval which modify, extend, or expand the D-SNAP. Changes that occur during the
application period can present special operational challenges. Public information

materials must be amended so that potential applicants are aware of the changes. The
opening of additional application sites may be taxing for employees that are already
working overtime in unfamiliar environments. States considering changes to their
programs should carefully evaluate the availability of resources, including staff,
funding, and application sites, before making a request.

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FNS also encourages States to gauge the presence of ongoing need in the area(s) being
considered for potential expansion or extension as extending the application period or

expanding into areas not as heavily damaged may not result in more eligible

households being served. Experience has shown that families most in need of benefits
will often come during the early days of the application period and counties receiving

an IA declaration at a later date may not have been impacted as much as those

declared first. In addition, if a disaster declaration is not issued until several weeks or
months after the disaster struck, households still in need of food assistance may be
better served by regular SNAP.

Any request for an amendment to the initial D-SNAP approval must contain an

explanation and supporting documentation for the desired change. Requests for

extension must be submitted prior to the expiration of the initial application period,
with sufficient time for FNS to consider and respond to the request before the
application period closes.

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Part 6. Post D-SNAP
This part of the guidance handbook covers a State’s activities after program operations
cease. After the D-SNAP application period ends, the State has several responsibilities
to conclude the D-SNAP.
These include:
•
•
•
•
•
•

Closing out the D-SNAP application/issuance sites

Transitioning to regular SNAP
Certification reporting

Issuance reporting and reconciliation

Fair hearings, claims and restored benefits

Post-disaster review and after-action report

6.1. Closing Out the Application/Issuance Site
Staff should follow their State agency protocols in closing down D-SNAP sites. The
check list below is designed to facilitate these efforts.
Figure 16. Close Out Checklist
Check
█

Subject
Files

Suggestions

•
•
•
•
•

█

Issuance
Records

•
•
•

Organize applicant files using State’s standard practices
Include issuance documents in files

Review files to determine duplication

Determine length to retain files – Federal standard is
minimum of 3 years

Put files in boxes marked with site and box number
Reconcile issuance at all sites

Put issuance logs and records in boxes marked with site and
box number

Forward to State office

█

EBT Cards

•
•

Take inventory of EBT cards

█

Equipment

•

Take inventory of all equipment (computers, copiers, FAX

Return EBT cards to secure storage site

machines, telephones) and other supplies, and compare with
initial inventory

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•

Return equipment to lender, as appropriate
Complete time sheets for all personnel, including temporary

█

Staff

•

█

Building

•

personnel. Records are subject to 3 year retention.

•

Clean as much as possible

Maintain security until site is emptied

6.2. Certification Reporting Post-D-SNAP
Since funding is obligated once benefits are posted to the EBT system, State agencies
will have estimated the amount of benefits to be issued and will have provided this

estimate to the FNS Regional Office financial management staff to ensure that funding
ceilings are not exceeded. States are responsible for compiling and transmitting the
following post-disaster reports in a timely manner.
FNS-292B
Within 45 days of the termination of a D-SNAP

operation, the State agency must submit its final
disaster figures on the FNS-292B Report of

Supplemental Nutrition Assistance Program Benefit

Issuance for Disaster Relief. All reports should be

submitted electronically in the Food Programs

Need Help with Reporting?
FNS can help. State agencies
should work closely with FNS
Regional Offices to ensure
proper reporting.

Reporting System (FPRS).

The FNS-292B must contain the following issuance data for D-SNAP operations:
•
•
•
•

Number of Households – new households issued D-SNAP benefits
Total Number of Persons Assisted - new persons issued D-SNAP benefits
Number of Certified Persons - ongoing households issued supplements
Value of Benefits Issued - total of benefits issued to new households and

supplements issued to ongoing households.

The FNS-292B report should not include the value of any replacements issued, as they
are not considered a disaster benefit. States should report the value of replacements

on the FNS 388 Monthly Issuance Report.

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FNS-388
The Monthly Issuance Report (FNS-388) shall reflect disaster issuance and participation

figures, including replacement benefits. Beginning October 1, 2014, States will be

required to complete the revised FNS-388, which will include detailed issuance and
participation figures for new D-SNAP households and ongoing SNAP households
receiving disaster supplements and/or replacement benefits.
FNS-209
In the Remarks section of the Status of Claims Against Households Report (FNS-209),

State agencies should indicate the number of claims established and collected against

D-SNAP benefits. These numbers must also be included in newly established claims

(line 4) and collection summary (lines 14, 16 and 18(a)). D-SNAP claims must be
identified on backup documentation in accounting systems for the FNS-209.
FNS-46

States should explain in the Remarks Section of the Issuance Reconciliation Report
(FNS-46) what portion of the D-SNAP was reported in the Gross, Returns, and Net

Issuance. Beginning October 1, 2014, States will be required to complete the revised

FNS-46, which will include detailed issuance and participation figures for new D-SNAP

households and ongoing SNAP households receiving disaster supplements and/or
replacements. The FNS-46 and FNS-388 should reconcile with the reported Net
Issuance.

Figure 17. Timeline for D-SNAP Reporting

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6.3. Issuance Reporting and Reconciliation
The State also must address reporting and reconciliation areas unique to EBT systems
including card production and delivery, benefit authorization, and posting.
Card production and delivery reconciliation
Cards shipped from a central location need to be tracked until distributed to

households. Each issuance site needs to maintain a beginning and ending inventory

and track new cards received, total cards available, and cards issued. Some households
may already have a card (active from a prior period of participation), which they may
continue to use for their new disaster benefit. State agencies must track benefits

issued on existing cards in order to prevent confusion over differences in the number
of households approved and number of new cards issued.

The method of distribution for cards – whether drop shipped, pulled from blank card

stock, or mailed or delivered by some other means will most likely dictate the specific

requirements for reporting and reconciliation. If the State assigns PINs, they must also

account for PIN mailers or envelopes to ensure adequate security, except when the PIN
is formulated from the Primary Account Number (PAN). Several State agencies have

used drop ship manifests and found the need to alphabetize and sort them by location,
either prior to delivery or at the delivery site. This method requires additional labor,

which the State should consider when planning staffing and logistics for a disaster site
operation. The State also should reconcile the number of cards set-up with EBT
accounts and the number of cards issued and then research and explain any

discrepancies. For example, if a site that entered and activated 200 cards in a day and
issued 220 cards that day, the State must explain the discrepancy.

States may be able to minimize costs for system modifications by defining these needs
during initial system interface and reporting design. Toward the end of the disaster

operation, each State should examine their existing EBT reporting and reconciliation
systems to determine whether modifications are necessary to prepare for the next
disaster.

Benefit authorization and posting reconciliation
States must track disaster benefits separately from ongoing benefit issuance. Some

States (e.g., Florida, South Carolina, and Louisiana) have defined distinct disaster food

benefit codes to allow them to track the disaster benefits on their contractor’s system,
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which eases benefit reconciliation each day. The EBT contractor has added separate

disaster benefit lines to administrative screens to enable the States to track disaster

benefit drawdown distinctly from ongoing benefits. States must also have a method in
place to allow for tracking of multiple D-SNAPs simultaneously, in the event the State

is struck by two disasters within a short timeframe. States also must adhere to FNS
reconciliation guidelines so that they can compare benefits posted to accounts to
benefits issued by the State eligibility system.
Benefit expungement
To reduce costs and encourage households to use their benefits promptly, several

State agencies have sought to expunge any unused D-SNAP benefits after a period of

60 or 90 days. FNS must approve any expungement period less than 12 months.
System designers need to work with the EBT contractor to develop a process for

expunging disaster benefits from the EBT system. The EBT provider should make a
corresponding report to the State agency to identify the value of disaster benefits
expunged.

Ensure complete reporting to FNS of disaster benefits issued
Since funding is obligated once benefits are posted to the EBT system, State agencies
will have estimated the amount of benefits to be issued and will have provided this

estimate to the FNS Regional Office financial management staff to ensure that funding
ceilings are not exceeded. This needs to be updated periodically.

6.4. Fair Hearings, Claims and Restored Benefits
After D-SNAP operations have concluded, States will still have to resolve any issues

associated with fair hearings, claims and restored benefits.
Fair Hearings

The requirement to conduct onsite supervisory reviews of denied applications should

help to minimize the number of fair hearings requested. Even so, hearing proceedings
may be ongoing for several months after the application period has ended.
⁂ Who May Request

Any household who applied for D-SNAP benefits and was denied benefits may request
a fair hearing. A household that disputes the household size used in calculating its
benefit amount may also request a hearing.

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⁂ Who May Not Request

Households who did not apply for D-SNAP benefits do not have a right to a fair

hearing. This includes households who were unaware of the D-SNAP or who were not

able to reach the site during the application period.
⁂ Supervisory Review

A household which has requested a fair hearing is entitled to an immediate onsite

supervisory review. Households not satisfied with the outcome of this review retain
the right to request a fair hearing through the normal process.
⁂ Withdrawal of Request

If a household wants to withdraw its request for a fair hearing, it may do so in writing.
⁂ Fair Hearing Reporting

The number of fair hearings is reported on the FNS-366B, Program Activity Statement.
Claims
In general, States should follow their FNS-approved procedures for establishing claims.
⁂ Pre-establishment Cost Effectiveness Determination

State agencies have the option to follow the established claims threshold of $125 set
forth in Section 273.18 (e)(2)(ii) of SNAP regulations or to establish a D-SNAP cost

effectiveness threshold amount for establishing D-SNAP claims. States must indicate

their chosen option in their D-SNAP plans and include this amount in their D-SNAP

plan for approval by the Regional office. If the State agency does not establish its own

D-SNAP cost-effectiveness threshold, it may follow the FNS threshold of $125 set forth

in Section 273.18 (e)(2)(ii) of SNAP regulations and include this amount in its D-SNAP

plan.

⁂ When to Establish Claims

If a household receives D-SNAP benefits to which it was not entitled, the State agency

must establish a claim against the household consistent with the claims collection

requirements of SNAP regulations. However, if a claim is established against a

household for an overpayment of SNAP benefits, this amount may not be collected
from the D-SNAP allotment.

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The State agency shall establish claims and issue repayment demand letters for overissuances which are the result of:
•
•
•

Intentional Program Violations (IPVs)
Inadvertent household errors
Agency errors

Restored Benefits
SNAP regulations require State agencies to issue restored benefits to households when
benefits were lost:
•
•

Due to an agency error

When a denial of benefits is subsequently reversed

This requirement also applies to D-SNAP benefits; State agencies should follow their

normal procedures for issuance in such cases. The accountability system must clearly
indicate that an issuance was a restored benefit.

6.5. Post-Disaster Review Report
The State agency must conduct a comprehensive review of general program

performance and reviews of individual cases along with a problem analysis on the

review findings. The State will then incorporate these findings, lessons learned, best

practices, and proposed improvements to the State’s systems, operational procedures,
and D-SNAP plan into its Post-Disaster Review Report. Reports should be transmitted

to their respective FNS Regional Offices who will review reports and submit them to the

National Office D-SNAP Team.

Note that D-SNAP applications are not subject to Quality Control review and are not
included when determining SNAP timeliness and payment accuracy rates.
Post-disaster Report
The post-disaster review report is comprised of four parts: comprehensive review,
individual reviews, problem analysis, and proposed improvements. State agencies

shall compile and submit to their FNS Regional Office their completed reports no later
than 6 months after the close of program operations. D-SNAP approvals will include

the due date for the final report. ROs are responsible for working with their respective
States to ensure the timely completion of the reviews, analysis, and submission of the
report. Upon receipt from the State Agency, the RO will review reports to ensure all

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required elements are included and will transmit them to the National Office D-SNAP

team.

Comprehensive Review

The comprehensive review should begin with an overview of the D-SNAP operation,

including where and when it took place, how it was staffed, and the total number of

applications approved and amount of benefits issued. The State should then describe

the systems or methods employed, document any major problems encountered, and

discuss the interventions used to solve those problems in the following areas:
•
•
•
•
•

Certification systems
Fraud control
Issuance

Public information and outreach

Program access issues (e.g. persons with disabilities, the elderly, and other
vulnerable populations)

•

Security

Individual Reviews

The individual reviews include both a sample of new public cases and a review of all

approved State agency employee cases.
⁂ Public Case Reviews

States must review a random sample of 0.5 percent of new D-SNAP cases, up to a

maximum of 500 cases with a minimum sample size of 25 cases. The sample should
include both approved and denied cases. Ongoing SNAP households that received

supplemental benefits should not be included in this sample nor should State agency

employee cases. Although State agencies may wish to consult with an FNS statistician
when devising a sampling plan, FNS does not require that they do so.
⁂ Employee Case Reviews

In addition to the review of public cases, States must review 100 percent of all

approved State agency employee applications and may, at its option, also review

denied applications from State agency employees. In addition to determining if the

appropriate action was taken on the employee cases, the State should verify that the
application was handled appropriately, by a supervisor or onsite investigator, as

detailed in the State’s D-SNAP plan. FNS encourages States to review applications of

other State employees not employed by the State SNAP agency, particularly if they were
involved in work at D-SNAP sites.

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For both reviews, no cases may be dropped for any reason. The State agency must

report information gathered even from incomplete case reviews. FNS does not require
State agencies to alter their sample size if a large number of case reviews are

incomplete; however, States are encouraged to do so in order to draw meaningful
conclusions from the findings.

The required components of the individual review – case record review, verification,

and interview – are detailed below.
 Case Record Review
o

States should review the household’s application for problems (such as
missing or inconsistent information, no identification provided, lack of

signature, etc.) and re-determine eligibility using the information given.

Additionally, the review should note any information the household has

given about their place(s) of employment at the time of the disaster,

which is helpful for both seeking verification of income and for locating
the client for their interview. States should note that at the time of
application, caseworkers should ask clients about their place of

employment at the time of the disaster and record that information on
the application.
 Verification:
o

States should focus the review of verification on identifying clients who

failed to accurately report information known to them about their

circumstances, such as residency, food loss, income sources, or loss of

work. States should not focus on clients who could not accurately project

their circumstances for the disaster benefit period.
o

Residency: The State should verify that the client lived (or worked, if

applicable) in the disaster area defined for that D-SNAP. Residency can

be verified by comparing the client’s stated address to maps or lists

compiled for use by workers during the operation of the D-SNAP. In

most cases, the State agency would not need to request additional
verification of residency from the household.
o

Food Loss. If the State agency allowed food loss as a sole qualifier for D-

SNAP eligibility, the State should confirm that the household resided in a

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geographical area that experienced extended power outages of the

length designated in the D-SNAP approval, flooding, or was otherwise

affected by the disaster in a way that would be expected to lead to food
loss. Verification can be achieved by comparing the client’s stated

address to maps of power outages, flooding, etc. In most cases, the

State agency would not need to request additional verification of food
loss from the household.
o

Income. Verification of income is intended to hold households

accountable for accurately reporting sources of income or loss of work

that were known to them at the time of the disaster. It is not intended to

penalize households for not being able to accurately predict their
income/employment during the benefit period.


To help in detecting unreported sources of income, States should
perform data matching, which should include wage matching,

income and eligibility verification systems (IEVS) matching, for

each case selected for review, Beneficiary & Earnings Data

Exchange (BENDEX) matching, and any other matching the State
agency normally uses to ensure that all known income sources

were disclosed. These sources may help in locating employers

that can be interviewed about the client’s employment status and
income at the time of the disaster. In addition, any information
found through the matches that conflicts with the information
provided on the application should be discussed with the
household during its interview.


If the wage match shows that the client was employed in the

months prior to the disaster and the client did not report this

income, the State agency should contact that last known employer

and inquire as to whether the client was employed there at the

time of the disaster. If the client was employed there at the time
of the disaster, the reviewer should inquire as to whether, at the

time of application, it was reasonable for the client to expect their
income to be interrupted due to the disaster. If the employer

states that the client should have had no reason to believe that

their income should have been interrupted due to the disaster, the
reviewer should explore the client’s rationale for reporting an

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expected interruption in income during the client interview. If it
appears that the client gave their best prediction of their

circumstances, then the reviewer should accept the household’s
statement of income. If the client was not employed at that

business at the time of the disaster or the employer refuses to
cooperate with the reviewer, and attempts to contact the

household have been unsuccessful, the State can discontinue
attempts to verify the client’s income.


If a BENDEX match finds undisclosed unearned income during the
benefit period, the State agency should explore with the client

during their interview why they believed that income would be

unavailable during the benefit period. Past experience has shown

that government benefits generally remain available post-disaster;
accordingly, there would have to be very unusual circumstances
present to support a household’s failure to report income from

these sources. However, unearned income from private sources,

such as alimony, direct child support and contributions, could be

delayed or unavailable if the individual responsible for contributing
these funds was also impacted by the disaster. If it appears that

the household gave its best prediction of their circumstances, then

the reviewer should accept the household’s statement of income.
o

Disaster-related Expenses. States should attempt to verify disaster-

related expenses through discussion with the household during the
interview. The reviewer should ask what expenses the household

incurred and confirm that they are consistent with what the household

reported at the time of application. The State review should also ensure

that the types of expenses claimed are appropriate. For example, if the

State agency is aware that the household lives in a rental unit, claims for

roof or window repair expenses would not be consistent with this type of
living situation and should be further explored.
 Client Interview
o

The purposes of the interview are to review the client’s statements on

their D-SNAP application, to explore any inconsistencies found through

data matching or other sources, and to gather the client’s reflections on

the quality of the D-SNAP service they received. States have the option of
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conducting either telephone or face-to-face interviews for all or any
clients.

States must make reasonable attempts to contact households and

schedule the interview, using the resources available to them in the

normal course of business, such as employers, internet searches, data

brokering services, credit reporting services, etc. States may conduct the

interview at the same time as a scheduled certification interview for SNAP,
if the household is now participating in the regular program. If the client

cannot be reached or does not attend the interview, the State should
continue to review the case and report the results.

Problem Analysis

After completing the individual reviews, the State agency shall conduct a problem

analysis, and create a separate list or chart for both the general public cases and the
State agency employee reviews. Each list should be further broken down by D-SNAP
project area (generally the County) and should include:
•
•

Number of cases with problems
Nature of the problem
o
o
o
o

•

Missing documentation in case file
Household error

State agency error

Intentional Program Violation

Number of incomplete case reviews due to inability to locate the client or client
failure to cooperate

•
•
•
•

Number of cases in which recipient claims were established
Value of claims

Value of restored benefits

Any further action taken against State agency employees as a result of findings

Proposed Changes
After conducting the reviews and problem analysis, State agencies should evaluate the
relative success of their D-SNAP implementation. This section of the report should
contain:
•
•
•

"Lessons learned" and best practices from the D-SNAP
Specific additions/changes to the State's disaster plan
Recommended changes to internal policies

D - S N A P G u i d a n c e | 81

Policy
•

Recommended additions or changes to this guidance handbook

FNS Regional Offices should take particular note of this section and work with the State

agency to incorporate any proposed changes into its next annual D-SNAP plan.

6.6. Conclusion
This guidance was designed with the needs of State agencies and Regional Offices in

mind. Lessons learned on the ground in past disasters have informed the policies and

procedures in this handbook. FNS intends this to serve as a tool for planning and

implementing successful D-SNAPs that quickly and effectively bring much-needed

food assistance to disaster survivors. FNS welcomes your insight on any of the topics
highlighted in this document and invites States to submit any recommended changes

to this document to their Regional Offices. Future additions will incorporate changes

and updates based on lessons learned and best practices.

D - S N A P G u i d a n c e | 82

File Type	application/pdf
File Title	Disaster SNAP Guidance
Subject	Policy Guidance, Lessons Learned, and Toolkits to Operate a Successful D-SNAP
Author	United States Department of Agriculture Food and Nutrition Servi
File Modified	2019-09-25
File Created	2014-07-03