SNAP – Waiver of the Interview Phaseout to Support Unwinding from the COVID-19 Public Health Emergency

DATE:	March 26, 2024
SUBJECT:	Supplemental Nutrition Assistance Program (SNAP) - Waiver of the Interview Phaseout to Support Unwinding from the COVID-19 Public Health Emergency
TO:	All SNAP State Agencies All Regions

The Food and Nutrition Service (FNS) is committed to supporting states as they unwind from the COVID-19 Public Health Emergency (PHE). FNS understands that several states are struggling to return to normal practices without compromising timely and accurate service and have expressed interest in a time-limited extension of their waivers of the interview beyond the current waiver approval timeframe. Under the waiver, state agencies may waive the interview for SNAP applicants at initial application or recertification or both, provided that the state has verified the applicant's identity and completed all other mandatory verifications. The state agency must contact the household if any information on the application is questionable, or verification is incomplete.

FNS is offering certain states the opportunity to request a short-term interview waiver or waiver extension. FNS recognizes that unwinding from the PHE and staffing challenges have put a continuing strain on states and is providing additional time for states to return to normal processing regarding the interview.

Criteria for Interview Waiver Approval or Extension

FNS is offering short-term approvals of the unwinding interview waiver only for state agencies that were approved previously for the "Waiving of the Certification Interview" waiver. Additionally, since FNS does not plan to approve further extensions of the "Streamlining Recertification Procedures" waiver, state agencies that were approved for this waiver may request to waive the interview at recertification only to ease the transition to routine recertification requirements.¹

A waiver of the interview does not eliminate a state agency's requirement to contact a household under specific circumstances. State agencies must continue to interview any individual who requests an interview. The state may not waive the oral explanation of work requirements for households with members subject to mandatory Employment and Training (E&T).

FNS would also like to remind states that they must screen all work registrants for possible exemptions, consistent with current statutory or regulatory requirements. Additionally, the state agency must provide an opportunity for the household to ask questions about the work requirements, including SNAP E&T, and about the simplified reporting requirements, even if the interview is waived.

States are eligible for the short-term approval of the interview waiver if they have a currently approved waiver of the interview or a waiver of the interview that has lapsed. States are eligible for this waiver for up to 6 months or until Oct. 31, 2024, whichever is sooner. FNS is continuing to approve this waiver under the extraordinary circumstances criterion due to challenges associated with unwinding from the pandemic.

Within 60 days of beginning the waiver, all states must submit a phaseout plan with detailed information on how the state plans to transition off the waiver and resume SNAP interview schedules in accordance with regulatory requirements. States should engage with their FNS regional office as soon as possible, but not later than 30 days after submission, to discuss the development of this plan. Each phaseout plan must detail how the state will ensure that it will resume interviews. FNS expects states to resume interviews for all applications requiring an interview by the month following the end the approval period. States have flexibility in how they design the phaseout of the interview waiver but should be aware that FNS does not plan to approve additional extensions of this waiver.

Considerations

FNS continues to believe that the interview is an integral part of the application and renewal process to ensure recipients receive accurate benefits. The interview allows states to understand a household's circumstances more fully, to screen for special and/or complex circumstances that might not be captured via the application, and to explain the household's rights and responsibilities. FNS encourages state agencies to consider whether this waiver is appropriate for their needs, especially in respect to customer service, program access, and the accuracy of benefits.

Additionally, FNS highly encourages state agencies to consider how they will address their state payment error rates and other quality control data when using these waivers. State agencies should reach out to their regional offices for technical assistance related to identifying relevant data points for this analysis.

Process for Requesting Waivers

State agencies must submit all requests through the SNAP Waiver Information Management System (WIMS). Please refer to the WIMS state user manual for detailed instructions on how to request in WIMS. All waivers will contain the same terms and conditions as previously approved.

The waiver conditions include a requirement that state agencies will submit final evaluation data for each waiver, as outlined in the conditions, within 45 days of the end of the waiver period.

Available Resources

FNS strongly encourages state SNAP agencies to review the State SNAP Interview Toolkit. The toolkit describes that SNAP interview requirements and provides information on promising best practices. The toolkit is a resource for state SNAP agencies as they conduct interviews, train staff, and look for ways to improve their interview processes.

FNS regional offices stand ready to assist states as they develop their phaseout plans and identify strategies to ensure they are prepared and ready to reintroduce interviews. FNS regional offices will also monitor states to ensure they are planning to resume interviews by the end of the month following the month of the approval period.

Moira Johnston
Director
Program Development Division
Supplemental Nutrition Assistance Program

¹ As described in the August 15, 2022, memo entitled, "(SNAP) - Temporary Administrative Waivers Available to State Agencies to Support Unwinding from the COVID-19 Public Health Emergency."

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