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Compilation Report of States' Compliance with Requirements for the Issuance and Use of Supplemental Nutrition Assistance Program Benefits (7 CFR, Part 274)

Report Information

Date Issued
Report Number:
Report Type
Food and Nutrition Service
TFC Consulting, Inc. (TFC), an independent licensed Certified Public Accounting firm, was contracted by the Department of Agriculture (USDA), Office of Inspector General (OIG) to conduct an agreed-upon procedures engagement (AUP) to assess aspects of five selected States’ compliance with the Supplemental Nutrition Assistance Program (SNAP) regulations. TFC was also responsible for providing the Food and Nutrition Service (FNS) with recommendations to enhance program efficiency and effectiveness.
Joint Report
Agency Wide
No (location specific)

United States

Questioned Costs
Funds for Better Use


Issue a clarification memorandum reiterating the importance of State compliance with 7 CFR §274.3, Retailer Management, with an emphasis that: • The State agency must have an executed agreement between the State, (or it’s agent, the EBT Contractor) and each Exempt Retailer • The agreement must contain the minimum required content • A new agreement must be timely executed when there is a vendor name and/or FNS number change.

Issue a clarification memorandum to reiterate that State agencies (and their EBT Contractors) shall keep such records as may be necessary to determine program compliance (e.g., exempt retailer agreements), and records shall be available for inspection and audit within a reasonable time.

Review 7 CFR, Part 274 and associated guidance to identify areas that require update, revision, or improvement and based on FNS’ review, determine which sections and/or related guidance merit revision and initiate the process to revise, as deemed appropriate.