c. QC Policy Memos 14-03thru16-02

OMB 0584-0074, APPENDIX C

SUPPLEMENTAL
NUTRITION ASSISTANCE
PROGRAM
QUALITY CONTROL
POLICY MEMO

SEP 08 2n14
Region:
Index No.:
Provision:

ALRO
QC 14-03
275.12(f)(2)

Subject: Quality Control Tolerance Level- FY 2015
The Agricultural Act of2014 (the Act) at Section 4019 set the Quality Control (QC)
Tolerance Level for excluding small errors at up to $37 for Fiscal Year (FY) 2014. FNS
set the tolerance at $37 for FY 2014. In addition, the Act requires FNS to adjust the
tolerance level for future years by the percentage by which the Thrifty Food Plan {TFP) is
adjusted under Section 3(u)(4) of the Food and Nutrition Act of2008. The first year the
TFP based adjustment will occur is FY 2015. FNS is adjusting the threshold using the
TFP for the 48 contiguous States and the District of Columbia. FNS calculated the
percentage change between the June 30, 2013 TFP (FY 2014) and the June 30, 2014 TFP
(FY 2015). FNS has applied that percentage to the $37 QC Tolerance Level, which
results in an increase to $38. Accordingly, State agencies shall use $38 as the QC
Tolerance Level for excluding small errors for FY 2015. All errors, regardless of dollar
amount, shall continue to be reported in accordance with existing policy.
Please contact your appropriate Regional Office if you have any questions regarding the
FY 2015 QC Tolerance Level.

~~w-./
Ronald Ward
Director
Program Accountability and Administration Division

October 16, 2014

S~PPLEMENTAL

NUTRITION ASSISTANCE
PROGRAM
QUALITY CONTROL
PcPLICY MEMO

Region:
Index No.:
Provision:
Chapter 13,

ALRO
QC 15-01
Handbook 310,
Section 1350.2

Subject: Update to the FNS Handbook 310, SNAP Quality Control
(QC) Review Handbook for FY 2015 to Implement a Two-Day Grace
Period for Issuing Notices of Denial in Conducting CAPER Reviews
The attached pages are effective for cases sampled beginning October 2014.

BACKGROUND
SNAP Quality Control (QC) implemented significant changes in the review process for
neg$tive actions beginning with the FY 2012 review period. Previously, the negative
revi~w focused almost exclusively on the validity of the negative action itself. The new
Cas~ and Procedural Error Rate (CAPER) reviews include elements focused on issues of
clie~t service, such as the timeliness of the action taken to deny, terminate, or suspend
SN,4P benefits, and the adequacy of notification of the action to the household, including
the ~imeliness of the notification.
Regplations at 7 CFR 273.2(g)(1) specify that the normal processing standard for a SNAP
appl~cation is 30 days. A household shall be provided the opportunity to participate as
sood as possible, but no later than 30 days following the date of application. In addition,
Sectiion 11(e)(3) of the Food and Nutrition Act of2008 ("the Act") specifies that the State
agency must process a household's application"... so as to complete certification ofand
pro*de an allotment retroactive to the period ofapplication to any eligible household
not ~ater than thirty days following its filing ofan application ... " Regulations at 7 CFR
273.~(g)(3) specify that households that are found to be ineligible shall be sent a notice of
deni~l as soon as possible, but not later than 30 days following the date of application. In
add¥on, the regulations at 7 CFR 273.2(g)(3) specify that in situations where the
hou~ehold has failed to appear for a scheduled interview and made no subsequent attempt
to c~ntact the State agency to reschedule the interview, or situations in which the
hou~ehold has been interviewed and asked to provide necessary verification,
and ~ubsequently failed to provide the verification, the State agency must deny the
hou~ehold SNAP benefits on the 30th day following the date of application.
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SNAP QC Policy Memo
Pag~2

A nlJmber of State agencies have indicated that it is not possible with current computer
systpms to require an eligibility worker to both wait until the 30th day before denying the
app~~cation and also notify the household of the denial action by the 30th day following
the ~ate of application. State agencies that have established administrative procedures
wh~rein all actions taken during a business day are "hatched" for the printing and mailing
ofhpusehold notification letters after the close of business on that day, and are not
act*lly mailed to the households until the next business day, cannot meet both of these
reg~latory requirements.

CH~NGE IN CAPER REVIEW POLICY
In response to the concerns raised by State agencies, FNS has decided to adopt a grace
period for the issuance of notices of denial. Any notice of denial regarding a negative
action under review that is sent to the household no later than two business days
following the date of the negative action taking place shall be considered adequate
regarding the timeliness of the notification to the household.
Thi~

grace period applies strictly to the matter of timing in determining the adequacy of
notification in QC CAPER reviews.
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Thi~ grace

period does not apply in the application processing timeliness reviews
by QC in order to determine eligibility for the high performance bonus
payments authorized under regulations at 7 CFR 275.24(b)(4).

con~ucted

Thi~ grace period applies only to the timeliness of the notification to the household of the
negttive action, not to the timeliness of the negative action itself. FNS has determined
that, provided any actual decision regarding an application for SNAP benefits continues
to n{eet the legal and regulatory timeframes for such actions, as specified in regulations at
7 C~R 273.2(g)(l) and Section ll(e)(3) of the Act, a slight delay in providing
notification will not significantly impact service to the household. Program requirements
sped,ifically provided for in the Act cannot be waived. Any negative actions which take
plac¢ more than 30 days following the date of application, and for which an appropriate
noti¢e of pending status was not sent, will continue to be considered invalid for QC
CA~ER review purposes.

SNAP QC Policy Memo
Page 3
EXAMPLES
E~ample of Timely Notification and Valid Application Processing: On 6/2
t~e household applies for SNAP benefits. On 6/10 the household is
i~terviewed and asked to provide verification of income by 6/20. The
hpusehold does not provide the requested verification. The 30th day
fq,llowing the date of application is 7/2, a Wednesday. The EW denies the
application on 7/2 for failure to provide verification and the household is
sent an appropriate notification to this effect on Thursday, 7 I 3. This action
i~ valid as the agency made proper notification to the household within two
bUsiness days of the decision to deny SNAP benefits.

Example of Timely Notification and Valid Application Processing: On 3/15.
the household applies for SNAP benefits and is scheduled for a certification
interview on 3/22. The household fails to attend the 3/22 interview and on
3V23 the EW sends the household a notice of missed interview (NOMI)
i~forming them that they must call to reschedule. The household does not
c~ll to reschedule the certification interview. The 30th day following the
d~te of application is 4/14, a Friday. The EW denies the application on 4/14
f~r failure to complete the required interview and the household is sent an
abpropriate notification to this effect on Monday, 4/17. This action is valid
a~ the agency made proper notification to the household within two business
dbys of the decision to deny SNAP benefits.
E~ample of Untimely Notification and Invalid Application Processing: On
9V26 the household applies for SNAP benefits. On 10/7 the household is
i~terviewed and asked to provide verification of income by 10/17. The
hpusehold does not provide the requested verification. The 30th day
f~llowing the date of application is 10/26, a Tuesday. The EW denies the
application on 10/26 for failure to provide verification and the household is
nt an appropriate notification to this effect on Friday, 10/29. This action
invalid as the agency failed to made proper notification to the household
:ithin two business days of the decision to deny SNAP benefits.

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SNAP QC Policy Memo
Pagr4

E~ample

of Timely Notification and Invalid Application Processing: On
9¥26 the household applies for SNAP benefits. On 10/7 the household is
ir'terviewed and asked to provide verification of income by 10/17. The
h lusehold does not provide the requested verification. The 30th day
fc llowing the date of application is 10/26, a Tuesday. The EW denies the
alplication on 10/27, Wednesday, for failure to provide verification and the
h lusehold is sent an appropriate notification to this effect on Thursday,
1 J/28. This action is invalid. Although the agency made proper notification
t()) the household within two business days of the decision to deny SNAP
b~nefits, the decision itself was made later than 30 days following the date
of application.

Please use the following chart to remove and insert pages to update your Handbook for
FY 2015 reviews.
PAGE CONTROL CHART
Dated
Insert Pa es
10-01-11
13-9 thru 13-10

Dated
10-16-14

Ple*e contact your appropriate Regional office if you have any questions regarding these
instructions.

~ncd~<.w,_f
Roqald K. Ward
Director
Pro$ram Accountability and Administration Division
I
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A~chments

FNS HANDBOOK 310

\

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clearly explain what the action was and why it was taken. (See
Section 1350.2);

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Step 3: Collateral and/or household contact for purposes of
obtaining verification supporting the reason given for the negative
action (optional) (See Section 1350.3); and

•

Step 4: Documentation and reporting of review findings (See
Section 1350.4).

13~0.1 Step 1: Determine Subject to Review Status. Review the
cir(1umstances of the action and determine if it is NSTR using Section 1332 as a
gui~e. If the action meets the circumstances to be NSTR then proceed to
135p.4 Step 4. If one of the NSTR reasons does not apply, the action is subject
to ~eview and the reviewer should continue to 1350.2 Step 2.
13~0.2 Step 2: Review of Action Sampled. The reviewer shall evaluate
the stated reason(s) for the negative action. Generally, the notice(s) to the
household will be the source of the information for the reason(s) for the
neaative action. If the reviewer cannot find the notice, the reviewer shall
review the case file .to determine if the reason(s) for the action can be found
an~ the method by which the action was provided to the household. During this
eva~uation the reviewer examines all of the information available to
detFrmine:
I

•

The reason for the negative action that was sampled;

•

Whether the household was appropriately notified of the reason(s)
for the negative action that was sampled. The notification to the
household will be considered timely, and therefore procedurally
appropriate, if it is sent to the household no later than 2 business
days following the regulatory required date of the negative
action;

•

Whether the action was procedurally appropriate for the
situation; and

•

Whether the validity of the action was adequately documented as
described in Section 1360.

In situations where there are multiple reasons for an action that are included
on~ notice, all reasons must be accurate and must clearly describe the
sit~ation so that the household is able to clearly understand why the negative
action has been taken. If there are reasons that have been indicated that are
not1 applicable or if any reason is not correct, the negative action will be
determined to be invalid.

10-16-14 (Change 1)

13 - 9

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FNS HANDBOOK 310
This determination shall take into account the additional application processing
req~irements of the negative action review found in Section 1340 to determine
that the eligibility worker followed all of the appropriate procedural steps.
The basic review process is as follows:
•

If the action results in the determination of a valid decision and
correct notice, then the review is complete and the reviewer shall
skip to Step 4 and document the review findings as specified in
Section 1350.4.

•

If the action is inadequately documented, then the reviewer may
proceed directly to Step 3 (Section 1350.3) to obtain the
necessary verification.

•

If the reviewer opts not to perform Step 3, the reviewer shall
proceed to Step 4.

•

Once the reviewer has determined the validity or invalidity of the
action, the reviewer shall go to Step 4 and document the review
findings as specified in Section 1350.4.

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Traf1sitional Benefits. In States with transitional benefits, if the eligibility
worker failed to establish transitional benefits for a household that should have
beer receiving transitional benefits, the action must be reviewed in
acc~rdance with review procedures specified in this section. The reviewer must
det~rmine if the household meets any of the following criteria that would
ren~er the action ineligible to receive transitional benefits:
1. the household lost its TANF cash assistance because of a sanction;
2. the household was disqualified from SNAP;
3. the household is in a category of households designated by the
State as ineligible for transitional benefits; or
4. the household returned to TANF.
If tt1e reviewer verifies that the household should have received TBA, the
actibn shall be coded as invalid.

13~0.3 Step 3: Collateral and/or Household Contact (Optional).
Thei. reviewer may contact the household or a collateral contact if the eligibility
elerhent(s) that caused the denial, termination, or suspension action to be
tak~n are insufficiently documented in the case record to confirm the validity
of t~e action. The reviewer shall not make a contact if the information
10-1'6-14 (Change 1)

13- 10

NOV 14 2014

SUPPLEMENTAL
NUTRITION ASSISTANCE
PROGRAM
QUALITY CONTROL
POLICY MEMO

ALRO
Region:
Index No.: QC 15-02
Provision: Handbook 310,
Appendix D

Subject: Update to the FNS Handbook 310, SNAP Quality Control
(QC) Review Handbook for FY 2015 to Implement the Revised FNS
245, SNAP Case and Procedural QC Review Schedule.
The attached pages are effective for cases sampled beginning October 2014.
BACKGROUND

SNAP Quality Control (QC) implemented significant changes in the review process for
negative actions beginning with the FY 2012 review period. Previously, the negative
review focused almost exclusively on the validity of the negative action itself. The new
Case and Procedural Error Rate (CAPER) review includes elements focused on issues of
client service, such as the timeliness of the action taken to deny, terminate, or suspend
SNAP benefits, and the adequacy of notification ofthe action to the household, including
the timeliness of the notification.
After two review periods (FY 2012 and FY 2013) using the previous version of the FNS
245, the program determined the data collected on that version was not accurately
recording the changes to the review process. As a result, during the FY 2014 review
period the Food and Nutrition Service submitted a revised review schedule and
instructions to the Office of Management and Budget (OMB). On October 31, 2014,
OMB approved the revised schedule for QC cases sampled beginning October 2014.
GENERAL CHANGES TO THE FORM'S LAYOUT
Section
I
II
III

IV
19 and 20

Changes Made
Labels changed from numbers to letters
Labels changed from letters to numbers
Reorganized elements, moved elements from section IV, and added new
elements and coding within
Moved some elements into section III
Labels changed from letters to numbers

SNAP QC Policy Memo
Page 2

IMP ACT OF POLICY MEMO 15-01 ON QUESTIONS IN SECTION III, #16
When responding to the questions in Section III, # 16 of the FNS 245 please remember
the following:
•
•

Questions 16 "a" and "b" refer to the timeliness of the action itself, not the notice.
Questions 16 "c" and "d" refer to the timeliness of the notice, not the action.
SNAPQCS has appropriate edits and warnings in place to be consistent with PM
15-01(issued October 16, 2014).

CHANGES TO THE SNAP QUALITY CONTROL SYSTEM (SNAPQCS)
The release date for the revised FNS 245 and instructions in SNAPQCS is scheduled for
Tuesday, November 18, 2014.
Please use the following chart to remove and insert pages to update your Handbook for
FY 2015 reviews.

Remove Pages
D-1 through D-2
D-3 through D-28

PAGE CONTROL CHART
Dated
Insert Pages
03-14-13
D-1 through D-29
10-01-11

Please contact your Regional office if you have any questions regarding these
instructions.

~t;:!Jctv~:/

Director
Program Accountability and Administration Division
Attachments

Dated
11-14-14

FNS HANDBOOK 310
FORM APPROVED OMB NO. 0584-0034

Expiration Date: 1013112017
U.S. DEPARTMENT OF AGRICULTURE • FOOD AI'«> NUTRITION SERVICE

SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM
CASE AND PROCEDURAL CASE ACTION REVIEW SCHEDULE
I. CASE MANAGEMENT INFORMATION (Not to be Transmitted)
B. lB.EPHONE NLM3ER

A. CASE NAME (laM, Firnt, Ml)

I I I II I I II I I I I
C. MAILING ADDRESS

D. ACTUAL ADDRESS/DIRECTIONS TO LOCATE

E. DATEASSIGNED

F. DATE COMPLETED/DISPOSED OF
!WIY

MONTH

!WIY

MONTH

YEAR

G. DATE CLEARED

YEI\R

MONTH

OJ OJ I I I I I

OJ ITJ I I I I I

!WII'

YEAR

ITJ OJ I I I I I

Re-viewer

SupeMsc>r

II. IDENTIFYING INFORMATION
1. REVIEW NUMBER

2. CASE NUMBER

II I I II I

I I I I I I I I I I I OJ I I I I

5. STRATUM

3. STATEANDLOCALAGENCYCOOE

6. NOTICE DATE

7. ACTION DATE

DAY

MONTH

YEAR

[I] ITJ I

[[]

I I II[[]

OJ I I I I I

8. ACTIONTYPE

9. CASE CLASSIFICATION

Y"...Aft

OA.Y

MOIITH

4. SAMPLE MONTH AND YEAR

ITJ I I I I I

D

D

Ill. ANALYSIS OF REVIEW ACTIVITY
1D. DiSPOSITION OF REVIEW
•l OlipOIIIIcn

D

D) NSTR

~-cn

11. FINDING

OJ

12. CASE RECORD REVIEW

a) ~ICOK!eG Reaoon lor Adl-

excluded - Individuals receiving benefits for
excluded
excluded
excluded
excluded
excluded
excluded

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Iraqi or Afghan Special Immigrants
LPR with 40 qualifying quarters of work
LPR with living in US 5 years ·
military connection
Refugee
Victims of Severe Trafficking

Element 140 - Residency
Nature codes:
003 088 096 0991-54-

>-

Agency failed to follow up on inconsistent or incomplete information
Improper denial or termination, not out of the project area
Policy incorrectly applied
Other
Improper denial - Homeless household denied for failing to provide address

Element 150 - Household Composition
Nature codes:
002 003 006 007008
009
010
011
096

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Ineligible person(s) included
Agency failed to follow up on inconsistent or incomplete information
Entitled to separate status
Eligible person(s) with no income, resources, or deductible expenses
excluded
Eligible person(s) with income excluded
Eligible person(s) with resources excluded
Eligible person(s) with deductible expenses excluded ·
Newborn infant improperly excluded
Policy incorrectly applied

(11-14-14)(Change 3)

D- 13

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Element 151 - Recipient Disqualification
Nature codes:
002 - Ineligible person(s) included
018- Eligible person(s) disqualified
096 - Policy incorrectly applied

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Element 160 - Employment & Training Programs
Nature codes:
004 - Agency failed to follow up on known and reported impending changes
018 - Eligible person(s) disqualified
054 - Failure to cooperate with work program when not required to register for
work program
060 - Household not notified of requirement to register with work program
096 - Policy incorrectly applied
155 - Individual inappropriately sanctioned

~

Element 161 -Time-limited participation
Nature codes:
004 018096 156 157 -

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Agency failed to follow up on known and reported impending changes
Eligible person(s) disqualified
Policy incorrectly applied
Improper denial - met ABAWD exemption
Months incorrectly calculated

Element 162 - Work Registration Requirements
Nature codes:
001
002
004
096
158

-

159 160161 162 -

Eligible person(s) excluded
Ineligible person(s) included
Agency failed to follow up on known and reported impending changes
Policy incorrectly applied
Eligible person(s) excluded - exempt from work requirements - care for
dependent under age 6 or incapacitated person
Eligible person(s) excluded - exempt from work requirements- due to age
Eligible person(s) excluded- exempt from work requirements- employed
Eligible person(s) excluded - exempt from work requirements - participation
in drug addiction or alcohol treatment program
Eligible person(s) excluded - exempt from work requirements - physically or
mentally unfit

(11-14-14)(Change 3)

D -14

FNS HANDBOOK 310
163 - Eligible person(s) excluded - exempt from work requirements - received or
applied for unemployment compensation
164 - Eligible person(s) excluded - exempt from work requirements - student
enrolled at least half time
165 - Eligible person(s) excluded - exempt from work requirements - subject to
and in compliance with TANF work requirements
~

Element 163 - Voluntary Quit/Reduced Work Effort
Nature codes:
016
017
096
166

Head of household did not voluntarily quit
Voluntary quit of non-head of household
Policy incorrectly applied
Improper Sanction - entire household sanction for non-head of household
voluntarily quit
167 - Household member met good cause

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Element 164 - Workfare and Comparable Workfare
Nature codes:
018 - Eligible person(s) disqualified
096 - Policy incorrectly applied
155 - Individual inappropriately sanctioned

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Element 165 - Employment Status/Job Availability
Nature codes:
004 - Agency failed to follow up on known and reported impending changes
018- Eligible person(s) disqualified
096 - Policy incorrectly applied

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Element 166 - Acceptance of Employment

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Nature codes:

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003 - Agency failed to follow up on inconsistent or incomplete information
018 - Eligible person(s) disqualified
096 - Policy incorrectly applied

(11-14-14)(Change 3)

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;;... Element 170 - Social Security Number
Nature codes:
018020 021 096 -

Eligible person(s) disqualified
Good cause for failure/refusal
Social Security Numbers provided
Policy incorrectly applied

Liquid Resources
;;... Element 211 - Bank Accounts or Cash on Hand
Nature codes:
003 024 031 074096 ;;...

Agency failed to follow up on inconsistent or incomplete information
Resource should have been exCluded
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

Element 212- Nonrecurring Lump-sum Payment
Nature codes:
003 004 024031 074 096 -

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Resource should have been excluded
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

;;... Element 213 - Other Liquid Assets
Nature codes:
003 004 024 031 074096 -

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Resource should have been excluded
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

(11-14-14)(Change 3)

D -16

FNS HANDBOOK 310
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Non-Liquid Resources
);>

Element 221 - Real Property

Nature codes:
003 004 024 027 028 029 031 074096 ~

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Resource should have been excluded
Used for self-employment
Fair market value incorrect
Equity value incorrect
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

Element 222- Vehicles
Nature codes:
003 004 024027028 029 031 074096 -

~

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Resource should have been excluded
Used for self-employment
Fair market value incorrect
Equity value incorrect
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

Element 224- Other Non-Liquid Resources
Nature codes:
003 004 024 027 028 029 031 074096 -

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Resource should have been excluded
Used for self-employment
Fair market value incorrect
Equity value incorrect
Incorrect limit applied
Improper denial - resource counted as income
Policy incorrectly applied

(11-14-14)(Change 3)

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Nature codes:
022 023 025 026 030 031 096 097-

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Element 225- Combined Resources

Did not transfer resources
Did not exceed limit
Incorrectly applied resources of non-Citizen sponsor
Included resources of a non-household member
Does not exceed prescribed limit
Incorrect limit applied
Policy incorrectly applied
Resource counted as income

INCOME·. (300) .·.· .. ·· ·..
Earned Income

»

Element 311 - Wages and Salaries
Nature codes:
003 004 032 033 034035 036 037 038 039 041 042 046 096 168 169 170 -

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Failed to consider or incorrectly considered income of an ineligible member
Rounding used/not used or incorrectly applied
Income from known/processed source included that should not have been
Household unemployed
Conversion to monthly amount not used or incorrectly applied
Averaging not used or incorrectly applied
MRRB household not temporarily over the limit
Employment status changed from unemployed to employed
Change only in amount of earnings
Failed to consider I anticipate month with extra pay date
Failed to consider or incorrectly considered reported information
Policy incorrectly applied
Improper income calculation
Improper calculation - Income included holiday or overtime pay
Improper calculation - Income averaged incorrectly

(11-14-14)(Change 3)

D -18

FNS HANDBOOK 310

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Element 312 - Self-Employment

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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004 - Agency failed to follow up on known and reported impending changes
*
032 - Failed to consider or incorrectly considered income of an ineligible member *
033 - Rounding used/not used or incorrectly applied
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034- Income from known/processed source included that should not have been
*
035 - Household unemployed
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036 - Conversion to monthly amount not used or incorrectly applied
*
037 - Averaging not used or incorrectly applied
*
038 - MRRB household not temporarily over the limit
*
039 - Employment status changed from unemployed to employed
*
041 - Change only in amount of earnings
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042- Failed to consider/anticipate month with extra pay date
*
046 - Failed to consider or incorrectly considered reported information
*
096 - Policy incorrectly applied
*
168 - Improper income calculation
*
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170- Improper calculation - Income averaged incorrectly
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171 - Income is Self-Employment income - not identified as Self-Employment
*
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Element 313- Other Earned Income
*
*
Nature codes:
*
003 - Agency failed to follow up on inconsistent or incomplete information
**

004 032 033 034035 036 037038 039 041 046 096 -

Agency failed to follow up on known and reported impending changes
Failed to consider or incorrectly considered income of an ineligible member
Rounding used/not used or incorrectly applied
Income from known/processed source included that should not have been
Household unemployed
Conversion to monthly amount not used or incorrectly applied
Averaging not used or incorrectly applied
MRRB household not temporarily over the limit
Employment status changed from unemployed to employed
Change only in amount of earnings
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

(11-14-14)(Change 3)

D -19

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Element 321 -Earned Income Deductions
Nature codes:
043 - Deduction that should have been included was not
046 - Failed to consider or incorrectly considered reported information
096 - Policy incorrectly applied
125 - Deduction applied to earnings after child support exclusion

~

Element 323- Dependent Care Deduction
Nature codes:
043 - Deduction that should have been included was not
046 - Failed to consider or incorrectly considered reported information
096 - Policy incorrectly applied

Unearned Income
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Element 331 - RSDI Benefits
Nature codes:
003
004
034
046
096

~

-

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

Element 332- Veterans Benefits
Nature codes:
003 004034046 096 -

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

(11-14-14)(Change 3)

D- 20

FNS HANDBOOK 310
)o>

Element 333 - SSI and/or State SSI Supplement
Nature codes:
003 004 034046 096 -

)o>

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

Element 334- Unemployment Compensation
Nature codes:
003 004 034046 096 -

)o>

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

Element 335 -Worker's Compensation
Nature codes:
003 004 034046096 -

)o>

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

Element 336- Other Government Benefits
Nature codes:
003
004
034
046
096

-

Agency failed to follow up on inconsistent or incomplete information
Agency failed to follow up on known and reported impending changes
Income from known/processed source included that should not have been
Failed to consider or incorrectly considered reported information
Policy incorrectly applied

(11-14-14)(Change 3)

D- 21

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Element 342- Contributions
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Errors in Child Support Payments should not be recorded in this Element. See
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Element 350.
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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004 - Agency failed to follow up on known and reported impending changes
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034- Income from known/processed source included that should not have been
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046 - Failed to consider or incorrectly considered reported information
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096 - Policy incorrectly applied
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* );> Element 343- Deemed Income
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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004 - Agency failed to follow up on known and reported impending changes
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034- Income from known/processed source included that should not have been
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046 - Failed to consider or incorrectly considered reported information
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096 - Policy incorrectly applied
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Element 344- TANF, PA OR GA
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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004 - Agency failed to follow up on known and reported impending changes
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034- Income from known/processed source included that should not have been
*
046 - Failed to consider or incorrectly considered reported information
*
096 - Policy incorrectly applied
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);> Element 345 - Educational Grants/Scholarships/Loans
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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004
- Agency failed to follow up on known and reported impending changes
*
034 - Income from known/processed source included that should not have been
*
046Failed to consider or incorrectly considered reported information
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096
Policy incorrectly applied
*

(11-14-14)(Change 3)

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FNS HANDBOOK 310
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Element 346- Other Unearned Income

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Nature codes:
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003 - Agency failed to follow up on inconsistent or incomplete information
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004 - Agency failed to follow up on known and reported impending changes
*
034- Income from known/processed source included that should not have been *
046 - Failed to consider or incorrectly considered reported information
*
096 - Policy incorrectly applied
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Element 350- Child Support Payments Received from Absent
Parent

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Nature codes:
*
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003 - Agency failed to follow up on inconsistent or incomplete information
*
004 - Agency failed to follow up on known and reported impending changes
*
034- Income from known/processed source included that should not have been *
046 - Failed to consider or incorrectly considered reported information
*
096 - Policy incorrectly applied
*
111 - Child support payments(s) not considered or incorrectly applied for initial *
month(s) of eligibility
*
112 - Retained child support payment(s) not considered or incorrectly applied
*
127 - Pass through not considered or incorrectly applied
*
170- Improper calculation - Income averaged incorrectly
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Other Deductions
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Element 361 -Standard Deduction
Nature codes:
043 - Deduction that should have been included was not
096 - Policy incorrectly applied

~

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Element 363 - Shelter Deduction
Nature codes:
043
047
051
053
096

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Deduction that should have been included was not
Failed to consider or incorrectly considered Shelter deductions
Incorrect amount used resulting from a change in residence
Incorrectly prorated
Policy incorrectly applied

(11-14-14)(Change 3)

D- 23

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Element 364- Standard Utility Allowance (SUA)
Nature codes:
043 - Deduction that should have been included was not
048 - Failed to consider or incorrectly considered SUA deductions
050- Incorrect standard used (not as a result of a change in household size or
move)
051 - Incorrect amount used resulting from a change in residence
052 - Incorrect standard used resulting from a change in household size
053 - Incorrectly prorated
096 - Policy incorrectly applied

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Element 365 - Medical Deductions
Nature codes:
043 - Deduction that should have been included was not
045 - Failed to consider or incorrectly considered Medical deductions
096 - Policy incorrectly applied

~

Element 366- Child Support Payment Deduction (includes
exclusions)
Nature codes:
040- Failed to consider or incorrectly considered Child Support deductions
(exclusions)
043 - Deduction (exclusion) that should have been included was not
096 - Policy incorrectly applied
111 - Child support payment(s) not considered or incorrectly applied for initial
month(s) of eligibility

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Element 371 -Combined Gross Income
Nature codes:
030- Does not exceed prescribed limit
031 - Incorrect limit applied
096 - Policy incorrectly applied

(11-14-14)(Change 3)

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FNS HANDBOOK 310
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Element 372 - Combined Net Income
Nature codes:
030 - Does not exceed prescribed limit
031 - Incorrect limit applied
096 - Policy incorrectly applied

Other
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Element 412 - Budgeting System
Nature codes:
063
064
065
096
101

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-

Deductions excluded that should not have been
Household improperly participating under retrospective budgeting
Household improperly participating under prospective budgeting
Policy incorrectly applied
Simplified reporting household

Element 413 -Application
Nature codes:
059 066 073 076 077078 079 081 082 096 117-

~

Household expedited and should have received postponed verification
Improper denial within 30-day period for missing interview(s)
Improper denial - failed to screen for expedited service
Failed to provide expedited service to expedited eligible household
Failed to issue a required Notice of Missed Interview (NOMI)
Denial before the 30th day
Incorrect use of allotment tables
Late denial agency failed to process the application timely
Improper denial for missing interview when interview never scheduled
Policy incorrectly applied
Failed to process the reapplication timely (recertification application)

Element 414- Joint TANF/SNAP Processing and Reporting
Nature codes:
067 - Improper termination/denial/suspension when TANF was terminated/
denied
068 - Benefits improperly terminated due to non-submission of monthly report
096 - Policy incorrectly applied

(11-14-14)(Change 3)

D- 25

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Element 415 -Verification
Nature codes:
003 - Agency failed to follow up on inconsistent or incomplete information
004 - Agency failed to follow up on known and reported impending changes
056 - Improper Denial/Termination -failure to provide - verification was received
or was in case file
069 - Improper denial prior to end of timeframe for providing verification
080 - No application or case record information to support
denial I termination I suspension
096 - Policy incorrectly applied
102 - Verification of income requested for a person not associated with current
application
103 - Verification of resources requested for a person not associated with current
application
105 - Verification was in case file
172 - Improper Denial/Termination - failure to provide -case should have been
processed without the deduction
173 - Improper Denial/Termination - failure to provide - categorically eligible
household with deemed eligibility elements
174- Improper Denial/Termination -failure to provide- failed to send a request
for contact
175 - Improper Denial/Termination - failure to provide - verification requested
was for another program
176- Improper Denial/Termination -failure to provide- household never notified
of needed verification
177 - Improper Denial/Termination - failure to provide - household not given at
least 10 days to provide
178 - Improper Denial/Termination - failure to provide - prior to the 30th day

»

Element 416- Action Type
Nature codes:
070 - Improper denial or termination when the case should have been suspended
071 - Improper suspension when the case should have been denied or terminated
072 - Improper termination or suspension for failure to meet reporting
requirements
096 - Policy incorrectly applied

(11-14-14)(Change 3)

D- 26

FNS HANDBOOK 310

»

Element 511 - Other
Nature codes:
005 - Computer programming error
012 - Computer user error (improper use of system or unauthorized process or
work around)
013 - Data entry and/or coding error (includes selection of incorrect codes)
055 - Failure to provide verification for a period of time not associated with
current application
084 - Information reported by a bank or financial institution contact inaccurate
085 - Information reported by a collateral contact inaccurate
086 - Information reported by an employer contact inaccurate
087 - Information reported by a landlord contact inaccurate
095 - Other public assistance case was terminated I denied
096 - Policy incorrectly applied
099 - Other. This code is to be used in situations not covered by the other existing
element codes.

»

Element 520- Arithmetic Computation
Nature codes:
061 - Benefit/allotment/eligibility incorrectly computed
062 - Incorrect use of allotment tables
096 - Policy incorrectly applied

»

Element 530- Transitional Benefits
Nature codes:
075 - Eligible for transitional benefits
096 - Policy incorrectly applied

»

Element 540 - Notices
Nature codes:
049
089
090
091
092
093
094
096

-

Failed to send notice of action
Notice did not include date of intended action
Notice did not include rights of household
Notice not clearly understandable
Notice reason does not match reason for action
Notice was not complete
Notice was sent to wrong address
Policy incorrectly applied

(11-14-14)(Change 3)

D- 27

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RESERVED
This section provides information for the evaluation of the action and case record.
This section will be completed for all cases by the State agency.

19.

Collateral and/or Household Contact- Enter the appropriate code
which reflects the decision of the reviewer to make a collateral and/or
household contact. The reason for contacting the collateral source or the
household (by telephone or a letter or in person) must be documented in
Section V- Narrative. The narrative must clearly address the element(s) in
question.
01 -No collateral or household contact was conducted.
02 -Telephone contact made to a collateral source - information in case
record regarding an element(s) was not clear and accurate.
03 -Telephone contact made to the household - information in case record
regarding an element(s) was not clear and accurate.
04 - Letter contact made to a collateral source - information in case record
regarding an element(s) was not clear and accurate. The reason for using
a letter must be documented on the FNS-245 Section V and a copy of the
letter included. The letter must clearly address the element(s) in
question.
05 - Letter contact made to the household - information in case record
regarding an element(s) was not clear and accurate. The reason for using
a letter must be documented on the FNS-245 Section V and a copy of the
letter included. The letter must clearly address the element(s) in
question.
06 - Face-to-face contact made to a collateral source - information in case
record regarding an element(s) was not clear and accurate.
07- Face-to-face contact made to the household - information in case record
regarding an element(s) was not clear and accurate

20.

Action Initiated By - Enter the appropriate two digit code to indicate the
initial event that prompted the action by the State agency. This information
will be used for administrative purposes and possibly to direct corrective
action.
01
02
03
04
05
06

- Reported information from the household
- Reported information from an automated source
- Reported information from other source
- Application for assistance submitted by the household
- Interim report completed by the household
- Interim report not submitted

(11-14-14)(Change 3)

D- 28

FNS HANDBOOK 310
07
08
09
10
11

- Failure to provide requested information from an application
- Failure to provide requested information from an interim report
- Re-certification for assistance submitted by the household
-Failure to provide requested information from a re-certification
- Other

OPTIONAL (FOR STATE SYSTEMS ONLY)
There is one line of spaces available for the State to code information to capture
additional data as designated by the State.

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SECTION·.V EXPLANATION Of·REVIEW FINDINGs· ..
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The narrative should contain a descriptive explanation of the circumstances from the *
case record regarding why the action was initiated, what information the agency used *
to arrive at the decision, what decision was made, and whether the notice that was
*
issued was specific, and clearly understandable. QC findings should summarize the
*
agreement or disagreement with the actions taken by the agency.
*
*
The narrative should answer these questions:
*
If no notice was sent, is it within the certification guidelines to not send a notice?
*
Did the action taken reflect what was known by the EW?
*
Did the EW make a mistake?
*
Did the notice reflect what the EW thought was happening?
*
Does the notice indicate what happened?
*
Is the notice ~learly understandable and specific about what was happening?
*
*

This section will be used to document the results of the review. The reviewer must
record information used to determine the validity of the action and, if necessary,
information on the status of the case as of the review date. The reviewer may
document a single element of eligibility or all elements, depending upon the
circumstances of each case. Documentation must be sufficient to support the
reviewer's decision on the status of the case (both a valid and an invalid
determination) and the identification of any variances, if the action was found to be
invalid.

(11-14-14)(Change 3)

D- 29

APR 29 2015

SUPPLEMENTAL
NUTRITION ASSISTANCE
PROGRAM
QUALITY CONTROL
POLICY MEMO

Region:
ALRO
Index No.: QC 15-03
Provision: FNS Handbook 310

Subject: Coding Changes to the FNS 380-1 Quality Control Review Schedule
and the FNS-245 SNAP Case and Procedural Case Action Review
Schedule
Revised Coding
The following code was added for coding of the FNS 380-1. This was made available in
SNAPQCS Release 5.0 and is for Fiscal Year (FY) 2014 and beyond:
1. Item 55 SNAP Program Work Registration code “6 -Should have been registered but was
not registered.”
One code was edited for coding of the FNS-245 to be consistent with coding of items with
similar definitions and was made available in SNAPQCS Release 6.2 also for FY 2014 and
beyond:
1. Item 14 d. Household Notice/Accuracy of Reason on Notice to Household is now
“00-No notice sent to household.” Previously the code was “99.”
Please use the following chart to remove and insert pages to update your FNS 310 Handbook.

Remove Pages
C-33 thru C-34
D-9 thru D-10

PAGE CONTROL CHART
Dated
Insert Pages
10-01-12
C-33 thru C-34
11-14-14
D-9 thru D-10

Dated
04-29-15
04-29-15

QC Policy Memo 15-03
Page 2
Please contact your appropriate regional office if you have any questions regarding these
instructions.
[Signed]
Ronald K. Ward
Director
Program Accountability and Administration Division
Attachments

Multiple races reported
18 –
19 –
20 –
21 –

(Hispanic or Latino) and (American Indian or Alaska Native) and White
(Hispanic or Latino) and Asian and White
(Hispanic or Latino) and (Black or African American) and White
(Hispanic or Latino) and (American Indian or Alaska Native) and
(Black or African American)
22 – (Hispanic or Latino) and Respondent reported more than one race and
does not fit into the above categories (code 18 through 21)

52. Citizenship Status - Enter the appropriate code.
1 - U.S. born citizen
2 - Naturalized Citizen
3 - Legal permanent resident with 40 quarters, military service, five years
legal United States residency, disability, or under 18 years of age.
4 – Reserved
5 – Person admitted as refugee, granted asylum or given a stay of deportation.
6 - Other eligible non-citizen
7 - Non-citizen legally in US who does not meet one of the above codes and
who is not receiving SNAP benefits but whose income and resources must
be considered in determining benefits.
8 – Other ineligible legal non-citizen (e.g. visitor, tourist, student, diplomat)
9 - Undocumented non-citizen
10 - Non-citizen, status unknown
99 – Unknown

53. Educational Level - Enter highest educational level completed for each
member of the household from the final QC determination:

0 - None
1 - Grade 1
2 - Grade 2
3 - Grade 3
4 - Grade 4
5 - Grade 5
6 - Grade 6
7 - Grade 7
8 - Grade 8
9 - Grade 9
10 - Grade 10
11 - Grade 11
12 - High school diploma or GED*
13 - Post secondary education (e.g. technical education or some college)
14 - College graduate or post-graduate degree
99 - Unknown
* If member attended grade 12 but did not graduate, use code 11.
10-01-12 (Change 5)

C - 33

54. Employment - Enter information on the current employment status of all
persons based on the final QC determination.

First box: Status
1–
2–
3–
4–
5–
6–
78–

Not in labor force and not looking for work
Unemployed and looking for work
Active duty military
Migrant farm laborer
Non-migrant farm laborer
Self-employed, farming
Self-employed, non-farming
Employed by other

Second box: Hours Worked
1–
2–
3–
4–
5–

Not employed
1-19 hours per week
20-29 hours per week
30-39 hours per week
40+ hours per week

55. SNAP Program Work Registration - Enter information on the current work
registration status of all persons as known by the State agency based on the
final QC determination:

*

12–
3456–

Federal exemption for disability
Federal exemption for a reason other than disability
Work registrant, not employment and training (E&T) participant
Work registrant, voluntary E&T participant
Work registrant, mandatory E&T participant
Should have been registered but was not registered

56. SNAP Program Employment and Training (E&T) Program Status -

Enter information on the current E&T program status of all household members
as known by the State agency based on the final QC determination:
0 – Not participating in E&T
1 – Participating in non-SNAP E&T (such as TANF)
2 – SNAP Job search or job search training
3 – SNAP E&T workfare or work experience
4 – SNAP E&T Work supplementation
5 – SNAP E&T education leading to HS diploma or GED
6 – SNAP E&T post secondary education leading to degree or certificate
7 – SNAP E&T remedial education (including adult education and English lessons
not leading to a degree)

04-29-15

C - 34

FNS HANDBOOK 310

(b) Notice Specific, Clear, and Understandable - Enter the

appropriate code regarding the notice to the household. The notice
must be specific regarding the reason for the action; the explanation of
the action must be clearly understandable. This measure is not to
evaluate the validity of the reason; it is to evaluate the clarity of the
notice.
1 - Yes, the reason for the action stated on the notice is specific, the
notice is clear and the notice is understandable for the action.
2 - No, either the reason for the action stated on the notice is not
specific, or the notice is not clear or the notice is not
understandable for the action; or any combination of the three. A
detailed and thorough explanation is required in Section V.
3 - No notice sent to household.

(c) Reason to HH Enter the appropriate code to indicate the reason for
the action as written on the notice.

01 - Resident of an institution not authorized by FNS
02 - Outside of project area or State
03 - Ineligible striker
04 - Ineligible noncitizen
05 - Ineligible student
06 - Ineligible boarder
07 - Missed scheduled interview(s)
08 - Failed to provide verification
09 - Refusal to cooperate
10 - Refusal to supply SSN
11 - Gross monthly income exceeds maximum allowance
12 - Net Monthly income exceeds maximum allowance
13 - Exceeds resource standard
14 - Transfer of resources
15 - Failure to comply, without good cause, with work registration/job
search requirements
16 - Voluntary quit
17 - Failure to submit/complete report
18 - Voluntary withdrawal after certification
19 - Termination/denial due to TANF termination/denial
20 - Intentional program violation
21 - Termination/denial due to program disqualification
22 - Termination/denial of household of able bodied adult(s) whose time
limited period of SNAP eligibility has expired
23 - Failure to comply, without good cause, with SNAP work
requirements
24 - Eligible for zero benefits
25 - Failure to access EBT benefits
11-14-14

D-9

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26 - Loss of contact with household
27 - Applicant/household deceased
28 - Not eligible for separate household status
29 - Not eligible due to status as fleeing felon, parole violation, drug
conviction etc.
30 - Reason for denial/termination/suspension not documented
31 – Household received benefits in another SNAP household for same
time period
32 – Household received benefits in another state for the same time
period
33 – Household received tribal commodities and is not eligible to
receive SNAP benefits
99 - Other
00 - No notice sent to household

(d) Accuracy of Reason on Notice to Household - Enter the

appropriate code to indicate if the reason on the notice to the household
was in accordance with policy and supported by the information in the
case record and if the reason matches 12(a), the recorded reason for the
action.
11 –
12 –
21 –
22 –
00 -

*

15.

Accurate, matches recorded reason.
Accurate, does not match recorded reason.
Inaccurate, matches recorded reason.
Inaccurate, does not match recorded reason.
No notice sent to household.

Procedural Requirements – This section must be filled out for all
completed reviews.

(a) Notice of Missed Interview – NOMI
1 – Required and completed correctly
2 - Required and not completed correctly
3 - Not required

(b) Request for Contact
1 – Required and completed correctly
2 - Required and not completed correctly
3 - Not required

04-29-15

D - 10

USDA
~
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Food and
Nutrition
Service

OCT Z9 2015
SUBJECT:

Fiscal Year 2016 Quality Control Tolerance Level ; §275 .12(±)(2)
Quality Control Policy Memo : 16-01

TO :

All SNAP State Agencies
All Regional SNAP Directors
Food and Nutrition Service

Park Office
Center
3101 Park
Center Drive
Alexandria
VA 22302

United States Department of Agriculture

The Supplemental Nutrition Assistance Program ' s Quality Control (QC) system
uses a tolerance level to set the threshold for determining which errors are
included in the national payment error rate calculation. Errors above the
threshold are included in determining error rates. Errors below the threshold are
still recorded and referred to the eligibility worker to make any necessary case
corrections, but are not included in the error rate calculation
Pursuant to changes in Section 4019 of the Agricultural Act of 2014 (the Act), the
Department set the QC tolerance threshold at $37 for fiscal year (FY) 2014. The
Act also requires the Food and Nutrition Service to adjust the FY 2014 tolerance
level for future years by the percentage by which the Thrifty Food Plan (TFP) is
adjusted under Section 3(u)(4) of the Food and Nutrition Act of2008, as
amended .
The first year the TFP based adjustment occurred was FY 2015 when it increased
from $37 to $38. There was no change in the FY 2016 TFP from FY 2015;
therefore, the tolerance threshold will remain at $38 for FY 2016.
For FY 2016, all State agencies shall use $38 as the QC Tolerance Level for
excluding small errors. All errors, regardless of dollar amount, shall continue to
be reported in accordance with existing policy. Please contact your Regional
Office if you have any questions regarding the FY 2016 QC Tolerance Level.

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Rohald K. Ward
Director
Program Accountability and Administration Division

An Equal Opportunity Provider and Employer

USDA
~

United Stat es Department of Agriculture

JAN 2 0 2016
Food and

Nutrition
Service

SUBJECT:

Integrity of the SNAP Quality Control System
Quality Control Policy Memo: 16-02
Preventing Bias, Misusing Error Review Committees and Third
Party Consultants, Federal Access to State Systems, and States'
Responsibility to Address Over and Under Issuances Identified by
Quality Control

TO:

All SNAP State Agencies
All Regional SNAP Directors

Par1c Offtee
Center

3101 Par1c
Center Drive

Alexandria
VA 22302

The Supplemental Nutrition Assistance Program's (SNAP) quality control system is an
integral component of FNS's responsibility to effectively administer the Program to
ensure families and communities receive critical nutrition assistance whi le practicing
strong public stewardshi p. As such, it is crucial that the quality control processes at the
State and federal level report valid statistical results. This memorandum is intended to
clarify existing regulatory and policy guidance to ensure awareness of our shared
responsibility to preserve the integrity of SNAP's quality control system, based on
findings from recent FNS reviews of State quality control operations. Furthermore, this
memorandum establishes new procedures regarding the use of third party consultants to
ensure that activities performed under contract are allowable SNAP administrati ve
expenses.

T he Review Process
The purpose of the SNAP quality control system is to determine the actual c ircumstances
of the household and assess the accuracy of the eligibility and benefit allotment
determination by State agencies. This measure is used to identify whether an improper
payment occurred. To ensure the validity of the statistical reporting, it is critical that all
sampled cases are reviewed using the same methodology and analysis. Following SNAP
regulations at 275. l 4(b), States must follow the procedures outlined in the FNS 3 10
handbook to conduct quality control reviews. The 3 10 Handbook provides guidance on
avoiding bias in the review process. It is the State's responsibility to establish procedures
to ensure the same methodology and analysis are used to review all cases to prevent bias
in its quality control system.
Quality control reviewers must verify all circumstances of the case in accordance with
FNS policy and may not fo llow different procedures when an error is identified. Any
attempt to single out error cases introduces bias into the quality control system. The
following are examples of procedures that introduce bias:
•

Applying second party review only to payment error cases. The purpose of the
second party review is to ensure the quality control work is done correctly

An Equal Opportunity Provider and Employer

following SNAP pol icies and procedures. Modifying State Quality Control
Reviewer (SQCR) findings to offset an error or hide household circumstances
from the quality control case file are against program rules. If a State elects to
implement second party review procedures, the emphasis of the review should
be on the accuracy of the findings, not ameliorating payment errors found during
the review. All types of cases, both error and non-error cases, should be
assessed as part of the second party review. Subjecting only error cases to
additional scrutiny introduces bias as error cases are being treated differently
from cases that were not found in error. If a State elects to implement second
party review procedures, then all cases or a sample of cases must be reviewed to
prevent bias. A second party review that provides additional scrutiny of cases
original ly found correct by the SQCR may yield errors that were not initially
identified.
•

Structuring SQCR performance metrics to encourage under counting errors. The
State's error rate or the number of cases with payment errors discovered by State
quality control should not factor into the performance rating for SQCRs. States
must take precaution to ensure that performance metrics for SQCRs do not
introduce bias by effectively encouraging the SQCR to under count errors.
Furthermore, States may not incentivize the SQCR to find that the eligibility
worker was correct in their initial determination. The objective of a SQCR is to
determine the actual circumstances of the household and evaluate the accuracy
of the initial determination and it's applicability to the sample month based on
applicable regulations and policy.

•

Treating error and non-error cases differently. As noted earlier, quality control
procedures do not allow error cases to be treated differently from non-error
cases. Using different processes to verify household composition, income,
deductions, or other information to offset or mitigate an error is not allowable.
States must follow the FNS 310 Handbook and use standardized processes to
determine monthly income and deductions that are consistent with Federal
quality control procedures and State policy options to ensure all cases are treated
the same.

Error Review Committees
The role of an error review committee is to review cases to assess trends for future
corrective action planning. This process allows States to identify error trends discovered
by quality control in order to implement process improvements or training to prevent
future errors during the eligibility and benefit determination process. Committees operate
most effectively when they include representation from quality control, policy, and
technical staff responsible for eligibility systems. This allows for a variety of
perspectives for how States may uti lize training, process improvements, or technology to
prevent future errors from occurring based on the root causes identified through the
quality control process.

Jn order to operate in accordance with SNAP policy, the error review committee may
only review individual cases for future corrective action planning after case results have
been transmitted to FNS. If a State uses an error review committee or supervisory review
to examine cases identified as errors in order to mitigate findings by a SQCR prior to
releasing case results to FNS, then the State has introduced bias into its quality control
system. All discussions of quality control findings by State staff, whether or not formal
committees are established, are considered error review committee activities by FNS and
are subject to this policy.

The Use of Third Party Consultants
If a State elects to procure services of a third party consultant to help assess quality
control processes, provide policy training, or manage any project that involves the
interpretation of FNS regulations, policies, or handbooks, the State must ensure that all
activities and deliverables performed by the third party consultant adhere to Federal
regulations and policy. Activities performed or deliverables provided by a third party
consultant that are not in accordance with Federal regulations or policies are unallowable
SNAP administrative expenses and are not eligible for federal reimbursement.

Furthermore, if a State intends to hire or already has in place an existing contract with a
third party consultant to train quality control reviewers regarding SNAP regulations,
policies, or handbooks to improve payment accuracy, FNS requires the following
procedures:
•

The State must notify FNS in writing of its intent to hire a consultant at least 30
calendar days prior to entering into a contract.

•

The State must submit to FNS a copy of the contract and supporting
documentation that outlines all tasks and deliverables to be performed by the
vendor. This is to be provided for all new contracts prior to ratification and all
existing contracts within 30 calendar days from the date of this memorandum.

•

The State must submit to FNS a copy of all deliverables provided by the vendor.

•

The State must notify FNS of any training sessions led by the vendor, including
the date, time, and location, at least 10 days in advance of the training. FNS
reserves the right to attend any training session without prior notice.

•

If the State schedules conference calls or meetings with the vendor to discuss
individual sampled cases, the State must document the discussion and any action
taken by the State within the case file. FNS reserves the right, upon request, to
participate in any conference calls, meetings, or emails between the State and the
vendor where individual sampled cases are analyzed.

Copies of requested documentation and notices stipulated above may be provided via
email to the FNS Regional SNAP Program Director. These procedures are effective
immediately.

Federal Access to State SNAP Eligibility and Quality Control Systems
States may not restrict Federal reviewer access to State systems, certification files, or any
information collected to determine the eligibility of a participant, or information
maintained within the State SNAP quality control system. Additionally, States are
required to provide Federal reviewers access to full certification case files and all data
collected by the State to determine SNAP eligibility upon request by FNS per section
16(c)(4) and (5) of the Food and Nutrition Act of 2008, and 7 CFR 275.21. This
information is necessary for Federal reviewers to conduct a thorough and independent
assessment of the case results reported to FNS.

Taking Action to Address State Quality Control Findings
In accordance with 7 CFR 275.12(f), the SQCR must report all information verified to be
incorrect during the review of an active case to the State agency for appropriate action to
be taken by the eligibility worker. The State must establish a process to ensure that all
incorrect information, variances and errors, regardless of the dollar amount, are reported
and acted upon in a timely manner. This includes issuing benefits to correct any underissuance and examining the case in the claims process to determine if a claim should be
established for any over-issuance found.

If you have any questions regarding the policies enclosed with this memorandum, please
contact Stephanie Proska, Quality Control Branch Chief, at 703-305-2437.

«~Kit/~
Ron\ld Ward
Director
Program Accountability and Administration Division
Supplemental Nutrition Assistance Program