Appendix C.1 Email from National FNS Office

Appendix C.1 Email from National FNS Office

From:
To:
Cc:
Subject:
Date:
Attachments:

OMB Control Number 0584-0605
Expiration Date xx/xx/xxx

Balbes, Maribelle - FNS
AFND_MARO_SNAPMGT; AFND_MPRO_SNAPMGT; AFND_WRO_SNAPMGT; AFND_MWRO_SNAPMGT;
AFND_SERO_SNAPMGT; AFND_SWRO_SNAPMGT; AFND_NERO_SNAPMGT
FNS-SNAP-FO; Cole, Susan (Suzy) - FNS; Alstodt, Raisa - FNS; Marshall, Julie - FNS; Gersten-Paal, Sasha - FNS;
Luna, Jessica - FNS; Noble, John (David) - FNS
FW: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014
Wednesday, February 2, 2022 5:39:10 PM
4032 Policy Memo Final.pdf
image001.png

Good afternoon SNAP Regional Program Directors and Branch Chiefs:
This is a reminder that States must submit their annual written attestations for Section 4032
to you by March 31, 2022. Please send your State agencies a reminder to submit this. Please
forward these attestations to National Office ([email protected]) by April 7, 2022 and
retain for your own records as well.  
In order to meet the reporting requirements specified in Section 4032 of the Act, States must
confirm via email to their FNS Regional SNAP Program Director that in the immediately
preceding fiscal year (FY 21), they had the appropriate systems in place to meet the
requirements of regulations at 7 CFR 272.14 (deceased match) and 273 .16(i)(4) (eDRS) and
that they conducted the matches required by these regulations. State agencies are welcome
to use this exact wording per the attached memorandum, as both regulatory requirements
must be attested to in that both the appropriate system was in place and that the matches
were conducted as required by those regulations.
Additionally, please remind State agencies of the clarification the national office received from
the Office of General Counsel (OGC) as to what constitutes having the “appropriate systems”
in place. Having the appropriate system in place means complying with all the related
provisions in the corresponding regulation. This would include the following
actions: conducting the match, reporting matches, independent verification, notice to the
household, and opportunity to contest. Therefore, if the State process is not set up to ensure
compliance with all related provisions in the regulation, it would be inaccurate to attest that
the appropriate systems are in place in this yearly attestation. If this is the case, please notify
National Office of either open ME findings that exist or proceed with the escalation process as
described in the FY 2022 National ME-FMR Guide [Pages - Agencywide Resources (usda.net)].
For any questions, please contact Suzy Cole, Acting State Administration Branch Chief.
Thank you,
Maribelle
Maribelle Balbes

she/her/hers
Acting Director
Program Accountability and Administration Division (PAAD)

Supplemental Nutrition Assistance Program
National Office

Food and Nutrition Service
United States Department of Agriculture
Phone: 703-605-4272
Cell:      415-516-5379
[email protected]

From: Ward, Ronald - FNS
Sent: Tuesday, February 9, 2021 5:06 PM
To: AFND_SERO_SNAPMGT ; AFND_SWRO_SNAPMGT ; AFND_MARO_SNAPMGT ;
AFND_MPRO_SNAPMGT ; AFND_MWRO_SNAPMGT ; AFND_NERO_SNAPMGT ;
AFND_WRO_SNAPMGT
Cc: FNS-SNAP-FO ; Balbes, Maribelle - FNS ;
Alstodt, Raisa - FNS ; Marshall, Julie - FNS ;
McKenney, Alice - FNS ; Gersten-Paal, Sasha - FNS ; Luna, Jessica - FNS ; Dasgupta, Arpan - FNS

Subject: RE: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014

SNAP Regional Program Directors and Branch Chiefs:

This is a reminder that States must submit their annual written attestations to you by March 31, 2021,
attesting to the fact that they had appropriate systems in place to meet the regulatory required data
matches identified in the attached implementation memorandum and that they conducted those
matches for Fiscal Year 2020. 

Please forward a copy of written attestations submitted by State agencies via email to Raisa Alstodt,
Program Analyst at [email protected] in the State Administration Branch by April 7, 2021.

Additional reminders:

Please maintain these annual submissions per the agency’s record retention requirements.
Use existing escalation policy to alert SAB if a State agency fails to comply with the reporting
requirement.  Failure to comply would include:
The State agency fails to submit a written attestation by March 31, 2021.
FNS has an open ME finding in Fiscal Year 2020 indicating that the State failed to
adhere to 7 CFR 272.14 or 273.16(i)(4).

Questions about the state verification requirement can be sent to Maribelle Balbes, State
Administration Branch Chief.

Thank you,
Ronald Ward

Director, Program Accountability and Administration Division
Supplemental Nutrition Assistance Program

From: Ward, Ronald - FNS
Sent: Thursday, January 30, 2020 2:27 PM
To: AFND_MARO_SNAPMGT ; AFND_MWRO_SNAPMGT ; AFND_SWRO_SNAPMGT ;
AFND_MPRO_SNAPMGT ; AFND_NERO_SNAPMGT ; AFND_SERO_SNAPMGT ;
AFND_WRO_SNAPMGT ; Kain, Erica - FNS

Cc: Shahin, Jessica - FNS ; Griffin, Laura - FNS ;
Silbermann, Lizbeth - FNS ; Cole, Susan (Suzy) - FNS
; Gersten-Paal, Sasha - FNS ; Marshall,
Julie - FNS
Subject: RE: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014

SNAP Regional Program Directors and Branch Chiefs:

This is your annual reminder that States must submit their annual reports to you by March 31
attesting to the fact that they had appropriate systems in place to meet the regulatory required data
matches and that they conducted those matches for Fiscal Year 2019.

This is also a reminder that you should keep and maintain these annual submissions per the agency’s
record retention requirements as we have received a data call for this information from the House
Agriculture Committee and GAO in the past.

Please use existing escalation policy to alert us if a State fails to comply with the reporting
requirement.

Thank you,
Ron

From: Ward, Ronald - FNS
Sent: Tuesday, March 5, 2019 8:23 AM
To: Hobbs, Rebecca - FNS ; Balbes, Maribelle - FNS
; Crudup, Dwight - FNS ; Kamau,
Catrina - FNS ; Byrd, Vernzel Mosby - FNS
; Velasco, Sabina - FNS ; Fraley, Philip FNS ; Jones, Elaine - FNS ; Mikkelson, Julie
- FNS ; Cundari, Melissa - FNS
; MacMartin, Sandra - FNS ;
McCall, Brian - FNS ; Malveaux, Eugene - FNS
; Ratchford, Eric - FNS ; Jenkins,

Bill - FNS ; Gagliardi, David - FNS ;
Brathwaite, Bonnie - FNS ; Rodriguez, Alonso - FNS
; Henschel, Matthew - FNS
Cc: Shahin, Jessica - FNS ; Cohen, Jeff - FNS
; Griffin, Laura - FNS ; Silbermann, Lizbeth FNS ; Duffield, Jane - FNS ; Cole,
Susan (Suzy) – FNS ; Gersten-Paal, Sasha - FNS ; Conroy, Mary Rose - FNS
Subject: FW: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014
Importance: High

SNAP Regional Program Directors and Branch Chiefs:

This is your annual reminder that States must submit their annual reports to you by March 31
attesting to the fact that they had appropriate systems in place to meet the regulatory required data
matches and that they conducted those matches for fiscal year 2018.

This is also a reminder that you should keep and maintain these annual submissions per the agency’s
record retention requirements.  You may recall we received a data call for this information from the
House Agriculture Committee during last year’s Farm Bill deliberations.

Please use existing escalation policy to alert us if a State fails to comply.

Thank you,
Ron

From: Ward, Ronald - FNS
Sent: Thursday, March 08, 2018 4:55 PM
To: AFNG_SNAP NO RO LEADERSHIP
Subject: FW: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014
Importance: High

SNAP Regional Program Directors and Branch Chiefs:

This is your annual reminder that States must submit their annual reports to you by March 31
attesting to the fact that they had appropriate systems in place to meet the regulatory required data
matches and that they conducted those matches for fiscal year 2017.

This is also a reminder that you should keep and maintain these annual submissions per the agency’s
record retention requirements.  I would not be surprised at some point if there is a data call or audit
by GAO/OIG to review this information.

Thank you,
Ron

From: Ward, Ronald - FNS
Sent: Wednesday, March 01, 2017 8:05 AM
To: AFNG_SNAP NO RO LEADERSHIP
Subject: FW: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014
Importance: High

SNAP Regional Program Directors/Branch Chiefs:

As we begin March, I am forwarding a reminder that States must submit their annual report to you
by March 31 attesting to the fact that they had appropriate systems in place to meet the regulatory
required data matches and that they conducted those matches for fiscal year 2016. 

This reporting requirement was implemented in the last Farm Bill.  FNS has no discretion on whether
or not to penalize a State for failing to comply with this reporting requirement.  The statute only
provides FNS with discretion as to the amount of the financial penalty.  You may wish to proactively
remind your States of this reporting requirement if you have not already.

Thank you,
Ron

From: Ward, Ronald - FNS
Sent: Wednesday, March 23, 2016 3:02 PM
To: AFNG_SNAP NO RO LEADERSHIP
Cc: Thompson, Clyde - FNS; Stewart, Kelly - FNS
Subject: RE: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014

This is a reminder that the first report from States attesting to the fact that they had appropriate
systems in place to meet the regulatory required data matches and that they conducted those
matches is due to your office by March 31.  We are providing the States with flexibility as to how
that report should be submitted.

I am sending this reminder to make sure you are aware of the implications if a State fails to comply. 
This provision of the Farm Bill was unusually prescriptive in that it does not provide any discretion to
USDA on whether a State should be penalized for failing to comply.  The only discretion available to
USDA is the amount of that penalty.

Thus, it is imperative that your States submit a report as described in the attached memorandum by
the March 31st deadline.

Thank you,
Ron

From: Ward, Ronald - FNS
Sent: Tuesday, May 05, 2015 4:33 PM
To: AFNG_SNAP NO RO LEADERSHIP
Cc: Thompson, Clyde - FNS; Stewart, Kelly - FNS; Brown, Veronica - FNS
Subject: SNAP Implementation Memo of Section 4032 - Agricultural Act of 2014

Attached is a memorandum providing State agencies with further guidance on implementing Section
4032 of the Agricultural Act of 2014 (Farm Bill).  In the initial implementation of the Farm Bill, FNS
advised States that this provision should not be implemented until Federal rulemaking occurs.  After
further review, FNS has determined that this section can be implemented without additional
rulemaking.  This memorandum advises States that in order to meet the reporting requirements
specified in this Section, States must confirm via email to their FNS Regional SNAP Program Director
that in the immediately preceding fiscal year, they had the appropriate systems in place to meet the
requirements of regulations at 7 CFR 272.14 and 273.16(i)(4) and that they conducted the matches
required by these regulations.

The first report, covering Fiscal Year 2015, is not due to each Region until March 31, 2016.

Please share this information with your State agencies.  The State Administration Branch is planning
a conference call with the Regions to address any questions that you may have regarding this
provision.  Additional information will be forthcoming regarding a call.

Thank you,
Ronald Ward, Director
Program Accountability and Administration Division
Supplemental Nutrition Assistance Program
USDA, Food and Nutrition Service
PH:  703-305-2523