> ![](media/image1.wmf){width="1.28125in" height="0.88125in"}
>
> **Disaster Supplemental Nutrition Assistance Program Guidance**
>
> **A Guide for Program Planning,**
>
> **Implementation and Assessment**
>
> ![](media/image2.jpeg){width="4.266666666666667in"
> height="2.8430555555555554in"}

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orientation, and marital or family status. (Not all prohibited bases
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To file a complaint of discrimination, write to USDA, Director, Office
of Civil Rights, Room 326-W, Whitten Building, 14th and Independence
Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and
TDD). USDA is an equal opportunity provider and employer.

**Table of Contents**

  --------------------------------------------------------------------------
  **Chapter**                                                    **Page**
  -------------------------------------------------------------- -----------
  **Chapter 1 -- Introduction**                                  

  [Objectives](#OLE_LINK1)                                       5

  [Organization and Use of Guidance](#OLE_LINK2)                 5

  [Authority to Operate a Disaster Supplemental Nutrition        6
  Assistance Program (D-SNAP)](#OLE_LINK3)                       

  [Context of D-SNAP in Government Response](#OLE_LINK5)         7

  [Comparing the D-SNAP and SNAP](#OLE_LINK103)                  10

  [Additional Resources](#OLE_LINK6)                             12

  **Chapter 2 -- Pre-disaster Planning**                         []{.mark}

  [Overview](#OLE_LINK7)                                         13

  [Regional D-SNAP Plan](#OLE_LINK8)                             13

  [Annual Regional Disaster Meeting](#OLE_LINK9)                 13

  [State Agency D-SNAP Plan](#ole_link10)                        15

  [Optional Pre-disaster Plans](#OLE_LINK11)                     16

  **Chapter 3 -- The Disaster Response**                         []{.mark}

  **Section 1. General**                                         []{.mark}

  [Overview](#OLE_LINK29)                                        17

  [Certification System](#OLE_LINK52)                            17

  [Eligibility Criteria](#OLE_LINK59)                            18

  [Income and Resource Tests](#OLE_LINK60)                       20

  [Verification](#OLE_LINK61)                                    23

  [Recipient Application](#OLE_LINK13)                           24

  [Issuance/EBT](#OLE_LINK16)                                    24

  [Language Issues](#OLE_LINK91)                                 41

  [Public Information and Outreach](#OLE_LINK30)                 42

  [Program Integrity/Fraud Prevention](#OLE_LINK31)              46

  [Security](#OLE_LINK15)                                        48

  [Staffing](#OLE_LINK14)                                        50

  [Training](#ole_link93)                                        54

  [Funding Issues](#OLE_LINK32)                                  56

  **Section 2. Developing the Appropriate Disaster Response**    []{.mark}

  [Overview](#OLE_LINK33)                                        57

  [Disaster Assistance Response Team](#OLE_LINK34)               57

  [Damage Needs Analysis](#OLE_LINK35)                           57

  [Evaluating Disaster Response Options](#OLE_LINK36)            61

  [Developing Terms of D-SNAP](#OLE_LINK37)                      64

  [Request to Operate the D-SNAP](#OLE_LINK38)                   69

  [Requests To Modify, Extend, or Expand the                     72
  D-SNAP](#OLE_LINK39)                                           

  **Section 3. Application/Issuance Sites**                      []{.mark}

  [Overview](#OLE_LINK47)                                        74

  [Choosing the Application/Issuance Sites](#OLE_LINK48)         74

  [Lay Out and Traffic Flow](#OLE_LINK49)                        76

  [Equipping the Application/Issuance Site](#OLE_LINK51)         79

  [Human Comforts](#OLE_LINK54)                                  83

  **Section 4. Command Centers**                                 []{.mark}

  [Overview](#OLE_LINK40)                                        88

  [Who Operates Command Centers](#OLE_LINK41)                    88

  [General Options](#OLE_LINK42)                                 89

  [Coordinating Fraud Prevention](#OLE_LINK43)                   90

  [Coordinating Public Relations](#OLE_LINK44)                   91

  [Coordinating Staff Issues](#OLE_LINK45)                       92

  [Coordinating Reporting](#OLE_LINK46)                          92

  **Chapter 4 -- Post-disaster Follow-up**                       []{.mark}

  [Overview](#OLE_LINK65)                                        93

  [Closing Out the Application/Issuance Site](#ole_link66)       93

  [Returning to the Regular SNAP](#OLE_LINK67)                   94

  [Reports](#OLE_LINK68)                                         95

  [Claims and Restored Benefits](#OLE_LINK69)                    96

  [Fair Hearings](#OLE_LINK70)                                   96

  [Post-Disaster Review](#OLE_LINK71)                            97

  [After-Action Report](#OLE_LINK72)                             100
  --------------------------------------------------------------------------

**Chapter I**

Introduction

[]{#OLE_LINK1 .anchor}Objectives

This Disaster Supplemental Nutrition Assistance Program (D-SNAP)
guidance document supplements the D-SNAP regulations with procedures and
controls to help agencies implement the regulations. As disasters and
State agencies' responses disasters vary widely, the Food and Nutrition
Service (FNS) did not design the guidance to provide an exhaustive list
of problems that will arise or prescriptive solutions to those problems.
Instead, this guidance 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.

[]{#OLE_LINK2 .anchor}Organization and Use of Guidance

**Organization**

The guidance has been organized into three major areas:

-   Pre-disaster planning

-   The disaster response

-   Post-disaster follow-up

**Using the Guidance**

To use the guidance effectively and make it a more useful tool:

-   Review the entire guidance to become familiar with its substance,
    organization, and format,

-   Use the guidance in pre-disaster planning exercises and disaster
    training,

-   Customize the guidance by filling in charts, tables, and other
    templates with additional ideas, contact people, phone numbers, and
    the like, and

-   Access updates to the D-SNAP Guidance and information on other FNS
    disaster programs by visiting the FNS Disaster Assistance webpage at
    [www.fns.usda.gov/disasters/disaster.htm](http://www.fns.usda.gov/disasters/disaster.htm).

**Improving the Guidance**

This guidance is an evolving document. The guidance will be updated
periodically and Regions and States will be notified when changes have
been posted to the online document. State agencies should contact the
appropriate FNS Regional Office with:

-   Techniques, procedures, or tools not included in the guidance which
    have proven to be particularly effective

-   Issues or problems that arise that are not addressed in the guidance

-   Scenarios and other experiences that would help other agencies
    prepare for or respond to disasters.

[]{#OLE_LINK3 .anchor}Authority to Operate the D-SNAP

**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 provides the Secretary of
Agriculture with the authority to establish temporary emergency
standards of eligibility for households who are victims of a disaster
that disrupts commercial channels of food distribution after those
channels have been restored.]{.mark}

[]{.mark}

[As the D-SNAP provides an entire month's benefits and is
administratively challenging for State agencies to deliver, FNS must
target D-SNAP resources to areas where they are most needed. Therefore,
for the vast majority of disasters, the FNS has elected to approve the
operation of the D-SNAP under Stafford Act authority when affected areas
have received a Presidential declaration for individual assistance. This
is because project areas that have Presidential declaration of
individual assistance clearly contain an appreciable number of
households in need of personal assistance and are much more likely to
require intensive food aid than areas without such a declaration. We
believe that aligning our aid with the President's declarations of
individual assistance will allow us to provide aid to affected
households in a consistent manner.]{.mark}

[]{.mark}

[Should there arise an extraordinary situation that does not receive a
Presidential declaration for individual assistance, yet merits some
nutrition response beyond the regular program, FNS can consider use of
the Food and Nutrition Act authority, but only after consulting with
officials empowered to exercise the authority of the Stafford
Act.]{.mark}

**Determining Factors**

+---------------------------------------+--------------+---------------+
| **Table 1. Authorities to Operate     |              |               |
| D-SNAP**                              |              |               |
+---------------------------------------+--------------+---------------+
| **Factor**                            | **Required   | **Required    |
|                                       | for**        | for Stafford  |
|                                       |              | Act?**        |
|                                       | **Food and   |               |
|                                       | Nutrition    |               |
|                                       | Act?**       |               |
+---------------------------------------+--------------+---------------+
| Presidential declaration of \"Major   | No           | Yes           |
| Disaster\"                            |              |               |
+---------------------------------------+--------------+---------------+
| Commercial channels                   | Yes          | No            |
|                                       |              |               |
| of food distribution **disrupted**    |              |               |
+---------------------------------------+--------------+---------------+
| Commercial channels                   | Yes          | Yes           |
|                                       |              |               |
| of food distribution **available**    |              |               |
+---------------------------------------+--------------+---------------+

[]{#OLE_LINK5 .anchor}Context of D-SNAP in Government Response

**State Role**

The primary responsibility for providing emergency food assistance rests
with the State agency. State agencies must design their own D-SNAP Plan,
evaluate the need for a D-SNAP or another feeding program should a
disaster strike, submit to FNS a detailed request to operate a D-SNAP,
effectively implement the D-SNAP, perform post-disaster reviews, and
report their findings to FNS.

**FNS Role**

FNS provides food assistance in three ways:

-   Provides food for shelters and other mass feeding sites.

-   Provides food for distribution directly to households in need in
    certain limited circumstances.

-   Provides disaster SNAP benefits.

FNS supports the State's efforts to provide D-SNAP benefits by providing
policy guidance, training, and technical assistance to State agencies as
they can 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 post-disaster
reviews and assessments to improve D-SNAP policy, training, and
technical assistance.

**USDA Role**

USDA is the lead agency for Emergency Support Function **(**ESF)-11
Agriculture and Natural Resources and FNS is the lead agency within USDA
for the nutrition assistance functions under ESF-11. The FNS Disaster
Task Force coordinates all ESF-11 nutrition assistance activities within
USDA and with FEMA, other support agencies, and State and county/local
disaster officials.

**Getting Help**

To get assistance from any other Federal agency, or any other agency
within USDA, contact the FNS Disaster Assistance Coordinator (Brenda
Lisi, <Brenda.Lisi@fns.usda.gov>, [703-305-2041).]{.mark}

**Other Federal Assistance**

There are 6 support agencies to assist USDA in fulfilling the ESF-11
function of providing, storing and transporting food to disaster areas.
Most of these functions will not be relevant to the D-SNAP. However,
when operating a D-SNAP, other Federal agencies may be needed to help
carry out non-food related functions (e.g., to build D-SNAP facilities,
provide potable water, etc.). A list of the most common non-food related
needs and the agencies that can assist are listed below.

**List of ESF-11 Support Agencies**

+--------------+-------------------------------------------------------+
| **Table 2.   |                                                       |
| Agency       |                                                       |
| Emergency    |                                                       |
| Support      |                                                       |
| Functions**  |                                                       |
+--------------+-------------------------------------------------------+
| **Agency**   | **Responsibilities**                                  |
+--------------+-------------------------------------------------------+
| Department   | -   Assess the availability of DOD food supplies and  |
| of Defense   |     storage facilities for dry, chilled, and frozen   |
|              |     food, and arrange for their delivery and          |
|              |     distribution.                                     |
|              |                                                       |
|              | -   Assess the availability of DOD transportation or  |
|              |     material handling equipment and personnel.        |
|              |     **Note**: this obligation is limited to the       |
|              |     posts, camps, and stations within or adjacent to  |
|              |     the disaster area.                                |
+--------------+-------------------------------------------------------+
| Department   | -   Determine which foods are fit for human           |
| of Health    |     consumption and identify potential problems of    |
| and Human    |     contaminated food.                                |
| Services     |                                                       |
|              | -   Provide health education concerning food          |
|              |     preparation and storage.                          |
+--------------+-------------------------------------------------------+
| Department   | -   Assess the availability of all modes of           |
| of           |     transportation that are equipped to keep food     |
| Tr           |     cold or frozen.                                   |
| ansportation |                                                       |
|              | -   Coordinate with the General Services              |
|              |     Administration to arrange for transportation of   |
|              |     emergency food supplies into and within the       |
|              |     designated area.                                  |
+--------------+-------------------------------------------------------+
| American Red | -   Identify and assess the requirements for food and |
| Cross        |     distribution services for the critical emergency  |
|              |     phase, and for longer term needs after the        |
|              |     emergency phase is over.                          |
|              |                                                       |
|              | -   Coordinate the food distribution efforts of other |
|              |     volunteer organizations.                          |
+--------------+-------------------------------------------------------+
| Department   | -   Coordinate the recovery and restoration of        |
| of Homeland  |     critical infrastructure including the allocation  |
| Security     |     and prioritization of resources and demographic   |
|              |     data about the disaster area.                     |
|              |                                                       |
|              | -   Provide consolidated information on State, local, |
|              |     and private sources of food to help determine the |
|              |     types and quantities of food FNS must provide.    |
+--------------+-------------------------------------------------------+
| E            | -   Provides technical assistance in determining the  |
| nvironmental |     suitability of food and water for human           |
| Protection   |     consumption.                                      |
| Agency       |                                                       |
|              | -   Identify potential hazardous materials impact on  |
|              |     the food supply.                                  |
+--------------+-------------------------------------------------------+

**Other Federal Assistance**

The following table identifies some sources of federal assistance that
do not relate *directly* to the ESF-11 objectives of obtaining,
transporting and distributing food.

+-------------------+-----------------------------+--------------------+
| **Table 3. Other  |                             |                    |
| Federal           |                             |                    |
| Assistance**      |                             |                    |
+-------------------+-----------------------------+--------------------+
| **Agency**        | **Responsibility**          | **Contact**        |
+-------------------+-----------------------------+--------------------+
| Army Corps of     | Public works and            | FNS Disaster       |
| Engineers         | engineering (ESF-3)         | Assistance         |
|                   | includes:                   | Coordinator:       |
|                   |                             | Brenda Lisi,       |
|                   | Providing potable water     | 703-305-2041,      |
|                   |                             | <Brenda.           |
|                   | Structural inspection for   | Lisi@fns.usda.gov> |
|                   | damage assessment           |                    |
+-------------------+-----------------------------+--------------------+
| Forest Service    | Fighting fires (ESF-4)      |                    |
|                   |                             |                    |
|                   | FS can provide FNS with     |                    |
|                   | supplies including: tents,  |                    |
|                   | trailers, portable          |                    |
|                   | buildings, ropes, etc.      |                    |
|                   |                             |                    |
|                   | FS can provide staff to     |                    |
|                   | assist as appropriate.      |                    |
+-------------------+-----------------------------+--------------------+
| Department of     | Providing technical         |                    |
| Homeland Security | services (ESF-5) such as:   |                    |
|                   |                             |                    |
|                   | Aerial reconnaissance       |                    |
|                   |                             |                    |
|                   | Meteorology and seismology  |                    |
|                   |                             |                    |
|                   | Structural engineering      |                    |
|                   |                             |                    |
|                   | Flooding and dam safety     |                    |
|                   |                             |                    |
|                   | Law enforcement issues      |                    |
+-------------------+-----------------------------+--------------------+
| GSA               | Resource support (ESF-7),   |                    |
|                   | including emergency         |                    |
|                   | provision of office space,  |                    |
|                   | equipment and supplies      |                    |
+-------------------+-----------------------------+--------------------+
| Department of     | Provision of emergency      |                    |
| Energy            | power and fuel to support   |                    |
|                   | immediate disaster response |                    |
|                   | functions (ESF-12)          |                    |
+-------------------+-----------------------------+--------------------+
| National Guard    | Transporting or guarding    | Governor\'s Office |
|                   | electronic benefits         |                    |
|                   | transfer (EBT) cards        |                    |
|                   |                             |                    |
|                   | Crowd control or other      |                    |
|                   | application/issuance site   |                    |
|                   | security                    |                    |
+-------------------+-----------------------------+--------------------+

[]{#OLE_LINK103 .anchor}Comparing the D-SNAP and the SNAP

**Introduction**

The D-SNAP is a *completely* different program from the regular
Supplemental Nutrition Assistance Program (SNAP). The chart below
compares the programs. See also the briefing sheet in *Publications --
Developing the Response* comparing the D-SNAP with a Modified SNAP.

+--------------+-------------------+----------------------------------+
| **Table 4.   |                   |                                  |
| SNAP vs.     |                   |                                  |
| D-SNAP**     |                   |                                  |
+==============+===================+==================================+
| *            | **SNAP**          | **Typical Disaster SNAP**        |
| *Eligibility |                   |                                  |
| Element**    |                   |                                  |
+--------------+-------------------+----------------------------------+
| Disaster     | N/A               | One of the following:            |
| Status       |                   |                                  |
|              |                   | -   Damage to home or            |
|              |                   |     self-employment property     |
|              |                   |                                  |
|              |                   | -   Disaster related expenses    |
|              |                   |                                  |
|              |                   | -   Income source disrupted      |
|              |                   |                                  |
|              |                   | -   Inaccessible liquid          |
|              |                   |     resources                    |
|              |                   |                                  |
|              |                   | -   Food loss                    |
+--------------+-------------------+----------------------------------+
| Identity of  | Verified          | Verified                         |
| applicant    |                   |                                  |
+--------------+-------------------+----------------------------------+
| Residency    | -   Project area  | -   Disaster area                |
|              |                   |                                  |
|              | -   Verified      | Verified if possible             |
+--------------+-------------------+----------------------------------+
| Household    | As defined in 7   | -   Persons living and eating    |
| Composition  | CFR 273.1(a)      |     together at the time of a    |
|              |                   |     disaster                     |
|              |                   |                                  |
|              |                   | -   Does NOT include members of  |
|              |                   |     a household with whom        |
|              |                   |     applicants are temporarily   |
|              |                   |     staying during the disaster. |
+--------------+-------------------+----------------------------------+
| Benefit      | Benefit           | Maximum allotment for household  |
| amount       | calculation       | size                             |
|              | according to 7    |                                  |
|              | CFR 273.10        |                                  |
+--------------+-------------------+----------------------------------+
| Alien Status | -   Citizenship   | Citizenship and alien status is  |
|              |     and alien     | NOT Applicable                   |
|              |     status is     |                                  |
|              |     verified      |                                  |
|              |                   |                                  |
|              | -   Applicant     |                                  |
|              |     must sign     |                                  |
|              |     statement     |                                  |
|              |     under penalty |                                  |
|              |     of perjury    |                                  |
|              |     that          |                                  |
|              |     information   |                                  |
|              |     is correct    |                                  |
+--------------+-------------------+----------------------------------+
| Students     | As defined in 7   | Status is not applicable         |
|              | CFR 273.5         |                                  |
+--------------+-------------------+----------------------------------+
| Social       | Failure to        | Failure to provide SSNs of       |
| Security     | provide SSNs of   | household members does NOT       |
| Numbers      | household members | result in [denial. States may    |
| (SSN)        | results in denial | request SSN on their D-SNAP      |
|              |                   | application, but the application |
|              |                   | must indicate that a household   |
|              |                   | will not be denied benefits for  |
|              |                   | failure to provide a             |
|              |                   | SSN.]{.mark}                     |
+--------------+-------------------+----------------------------------+
| Work         | Yes               | No                               |
| Requirements |                   |                                  |
+--------------+-------------------+----------------------------------+
| Resources    | -   Cannot exceed | -   No separate resource test    |
|              |     \$2,000 if    |                                  |
|              |     there is NOT  | -   Only liquid resources are    |
|              |     an elderly    |     counted                      |
|              |     household     |                                  |
|              |     member        | -   Verified WHERE POSSIBLE      |
|              |                   |                                  |
|              | -   Cannot exceed | -   (See Chapter 3: [Income and  |
|              |     \$3,000 if    |     Resource                     |
|              |     there is an   |     Tests](#OLE_LINK60))         |
|              |     elderly       |                                  |
|              |     household     |                                  |
|              |     member        |                                  |
|              |                   |                                  |
|              | -   Verification  |                                  |
|              |     is optional   |                                  |
+--------------+-------------------+----------------------------------+
| Income       | -   Special       | -   Only net (take-home) income  |
|              |     provisions    |     expected to be received      |
|              |     for elderly   |     during the benefit period    |
|              |     and           |     counted. [Take-home pay is   |
|              |     handicapped   |     defined as wages a household |
|              |                   |     actually receives after      |
|              | -   Verified      |     taxes and *all* payroll      |
|              |                   |     withholding, public          |
|              |                   |     assistance payments or other |
|              |                   |     unearned income, and net     |
|              |                   |     self-employment              |
|              |                   |     income.]{.mark}              |
|              |                   |                                  |
|              |                   | -   No special provisions for    |
|              |                   |     elderly and handicapped      |
|              |                   |                                  |
|              |                   | -   Verified WHERE POSSIBLE      |
|              |                   |                                  |
|              |                   | -   (See Chapter 3: [Income and  |
|              |                   |     Resource                     |
|              |                   |     Tests](#OLE_LINK60))         |
+--------------+-------------------+----------------------------------+
| Expenses     | Deductions        | -   Maximum standard and shelter |
|              | include:          |     deductions [already          |
|              | standard, earned  |     incorporated into disaster   |
|              | income, excess    |     eligibility                  |
|              | shelter,          |     standards]{.mark}            |
|              | dependent care,   |                                  |
|              | and medical       | -   [Disaster-related expenses   |
|              | (elderly/disabled |     that are not expected to be  |
|              | members only).    |     reimbursed during the 30-day |
|              |                   |     disaster benefit period are  |
|              |                   |     allowed]{.mark}              |
|              |                   |                                  |
|              |                   | -   [(See Chapter 3: [Income and |
|              |                   |     Resource                     |
|              |                   |     Tests](#OLE_LINK60))]{.mark} |
+--------------+-------------------+----------------------------------+
| Intentional  | Penalties are 12  | -   Disqualification status from |
| Program      | months, 24        |     regular program does NOT     |
| Violations   | months, and       |     disqualify an applicant from |
|              | permanent         |     the D-SNAP                   |
|              | disqualification  |                                  |
|              |                   | -   Committing IPV in the D-SNAP |
|              |                   |     WILL count towards           |
|              |                   |     disqualification in the      |
|              |                   |     regular SNAP                 |
+--------------+-------------------+----------------------------------+

[]{#OLE_LINK6 .anchor}Additional Resources

The table below includes some additional resources on disasters.

+-------------------------+--------------------------------------------+
| **Table 5. Additional   |                                            |
| Resources**             |                                            |
+-------------------------+--------------------------------------------+
| **Resource**            | **Description**                            |
+-------------------------+--------------------------------------------+
| *The National Response  | FEMA\'s formal all-hazards response plan   |
| Plan*                   | for domestic incidents required by Public  |
|                         | Law 93-288.                                |
|                         | [www.dhs.gov/xprepresp/committe            |
|                         | es/editorial_0566.shtm](http://www.dhs.gov |
|                         | /xprepresp/committees/editorial_0566.shtm) |
+-------------------------+--------------------------------------------+
| *An Advocate's Guide to | Published by the Food Research and Action  |
| the Disaster Food Stamp | Center, this guide provides basic D-SNAP   |
| Program*                | information to non-profits interested in   |
|                         | supporting State agencies as they deliver  |
|                         | the D-SNAP.                                |
|                         | [www.frac.org/pdf/D-SNAPguide06.pdf        |
|                         | ](http://www.frac.org/pdf/dfspguide06.pdf) |
+-------------------------+--------------------------------------------+
| *FNS Commodity Program  | Guidance on providing congregate feeding   |
| Disaster Manual*        | or household distribution in response to a |
|                         | disaster:                                  |
|                         | <http://www.fns.usda.gov/fdd/programs      |
|                         | /fd-disasters/CommodityDisasterManual.pdf> |
+-------------------------+--------------------------------------------+
| *Tips for Managing and  | Developed by the Department of Health and  |
| Preventing Stress:\     | Human Service's Substance Abuse and Mental |
| A Guide for Emergency   | Health Services Administration, this tip   |
| and Disaster Response   | sheet includes information on identifying  |
| Workers*                | and managing excess stress amongst workers |
|                         | during disaster recovery.                  |
|                         | <http://mentalhealth.sam                   |
|                         | hsa.gov/publications/allpubs/KEN-01-0098/> |
+-------------------------+--------------------------------------------+
| *Guide to Distributing  | The Electronic Benefits and Services       |
| Assistance after a      | Council's guide is based upon              |
| Disaster:  Lessons      | conversations with government officials    |
| learned from the 2004   | and EBT contractors.                       |
| and 2005 Gulf Coast     | <http://ebt.nacha.org/docs/Guide_to_D      |
| Hurricanes*             | istributing_Assistance_After_Disaster.pdf> |
+-------------------------+--------------------------------------------+
| *A Consumer\'s Guide to | Developed by the USDA Food Safety and      |
| Food Safety: Severe     | Inspection Service to help consumers keep  |
| Storms and Hurricanes*  | food safe in preparation for and after     |
|                         | disasters.                                 |
|                         | <http://www.fsis.usda.gov/fact_sheets/Seve |
|                         | re_Storms_and_Hurricanes_Guide/index.asp>. |
+-------------------------+--------------------------------------------+
| *FNS Disaster           | Information on the D-SNAP, program         |
| Assistance Webpage*     | flexibilities available to the Child       |
|                         | Nutrition Program and WIC in the event of  |
|                         | a disaster, disaster-related program data  |
|                         | for recent disasters, and other disaster   |
|                         | resources.                                 |
|                         |                                            |
|                         | <http:                                     |
|                         | //www.fns.usda.gov/disasters/disaster.htm> |
+-------------------------+--------------------------------------------+

**Chapter 2**

Pre-Disaster Planning

[]{#OLE_LINK7 .anchor}Overview

Although it is impossible to be completely prepared for disasters, as
States cannot predict the timing or extent of damage for a given
disaster, State agencies and FNS Regional Offices can take actions that
lead to the best possible level of disaster preparedness. This chapter
will outline some pre-planning activities that the Regional Office and
State agency should perform to increase disaster preparedness.

[]{#OLE_LINK8 .anchor}Regional Disaster SNAP Plan

**Annual Plan**

The Regional Office should prepare a D-SNAP plan and review it each year
to ensure that it is current and complete. [The Regional D-SNAP plan is
intended to be an internal guide for Regional staff that ensures that
all aspects of assistance to States in D-SNAP planning, implementation,
and assessment are performed expeditiously and with a high degree of
quality.]{.mark} The Regional Office should distribute copies of their
plan to appropriate Regional, Field Office and State agency staff, [but
are not required to submit copies to National Office.]{.mark}

**Contents**

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

-   Administrative plan:

    -   Names and job descriptions of all lead personnel

    -   Detailed description of the role of the field offices

    -   Outline of delegated authority

    -   Established lines of communication

    -   Names and home phone numbers of relevant staff

-   Regional fraud control plan developed with USDA's Office of
    Inspector General (OIG)

-   Training plan for state and Regional FNS staff.

[]{#OLE_LINK9 .anchor}Annual Regional Disaster Meeting

**Annual Meeting**

To the extent feasible, each Regional Office should conduct an annual
disaster training meeting with the State agencies within their region.
[The training can either be specific to the D-SNAP or general in nature,
addressing disaster planning across FNS programs.]{.mark}

**Objectives**

The objectives of a Regional disaster meeting are to:

-   Clarify roles of State agency and Regional Office

-   Develop good communication

-   Allow States to share experience and knowledge

-   Review and update operational plans

-   Help States develop State disaster plans

**[Attendees]{.mark}**

[A D-SNAP-specific meeting should include leadership and key staff
representing as many of the following areas as possible:]{.mark}

-   [State SNAP agency director's office]{.mark}

-   [D-SNAP operation, planning, and evaluation]{.mark}

-   [EBT/issuance]{.mark}

-   [Information technology]{.mark}

-   [Public affairs]{.mark}

-   [Program integrity/fraud prevention]{.mark}

-   [Civil Rights]{.mark}

[]{.mark}

[A general disaster meeting should include the persons above, plus
Regional and State agency leadership and staff from these areas of
expertise:]{.mark}

-   [Food Distribution]{.mark}

-   [SNAP]{.mark}

-   [WIC]{.mark}

-   [OIG]{.mark}

-   [Emergency Planning]{.mark}

[]{.mark}

If feasible, the Regional Office should invite representatives from the
American Red Cross, the Salvation Army, and other community
organizations that provide disaster assistance.

**Annual State Contact**

If an annual regional meeting is not possible, the Regional Office
should contact each State to cover the material that would have been
addressed at the meeting. The Region should give special attention to
providing opportunities for States to exchange information with each
other, such as participation in a Federal or State-sponsored exercise.

Contacts could include:

-   Attendance of State agency-led disaster workshop

-   Face-to-face meeting with State agency

-   [Review of D-SNAP readiness during State Agency Operations
    Review]{.mark}

-   Participation in State agency-led disaster exercise with follow-up
    discussion

-   Regional Office presentation about disaster preparedness at other
    State meetings.

State Agency Disaster SNAP Plan

[]{#ole_link10 .anchor}

**Requirements**

The State Agency is required to maintain a current D-SNAP plan. Each
State agency should review their existing D-SNAP plan on an annual
basis, revise it if necessary, and submit a revised copy to their
Regional Office by August 15 of each year. States that wish to obtain an
alternative date for submission of their plans can negotiate that date
with their Regional office. *[State agencies that will no submit a
revised D-SNAP Plan because their previously-approved plan remains
current must send a letter to their Regional Office by August 15 stating
that their plan remains current.]{.mark}*

State agencies must include in their [core]{.mark} D-SNAP plan the
elements listed in Table 6.

  ------------------- ------------------------------------- ----------------------------
  **Table 6. Core                                           
  D-SNAP Plan                                               
  [Required]{.mark}                                         
  Contents**                                                

  **()**              **Required Contents**                 **Location in Guidance**

                      Identification of county/local, State For Federal agency
                      and Federal government agencies with  responsibilities, see
                      responsibilities for disaster         Chapter 1: [Context of
                      assistance, including a description   D-SNAP in Government
                      of responsibilities for each agency.  Response](#OLE_LINK5).

                      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).   

                      Identification of private disaster    See Chapter 3:
                      relief agencies within the State such [Staffing](#OLE_LINK14)
                      as the Red Cross, Salvation Army, or  
                      community groups and a description of 
                      their role in D-SNAP implementation.  

                      General description of the            See Chapter 3:
                      certification process                 [Certification
                                                            System](#OLE_LINK52)

                      Public information plan               See Chapter 3: [Public
                                                            Information and
                                                            Outreach](#OLE_LINK30) and
                                                            [Coordinating Public
                                                            Relations](#OLE_LINK44)

                      Procedures to reduce applicant        See Chapter 3: [Human
                      hardship                              Comforts](#OLE_LINK54)

                      Fraud prevention plan                 See Chapter 3: [Program
                                                            Integrity/Fraud
                                                            Prevention](#OLE_LINK31) and
                                                            [Coordinating Fraud
                                                            Prevention
                                                            Efforts](#OLE_LINK43)

                      Caseworker training plan              See Chapter 3:
                                                            [Training](#ole_link93) and
                                                            [Coordinating Staff
                                                            Issues](#OLE_LINK45)

                      Post-disaster review plan             See Chapter 4: [Post
                                                            Disaster
                                                            Review](#OLE_LINK71)
  ------------------- ------------------------------------- ----------------------------

[]{#OLE_LINK11 .anchor}

Optional Pre-Disaster Plans

**Introduction**

Although plans for the subject areas below elements are not required and
it is not necessary for them to be submitted with the State D-SNAP Plan,
FNS recommends including them in at least the planning process so that
the State agency is fully-prepared to deliver the D-SNAP. *[In
particular, FNS strongly encourages States to develop a robust
Issuance/EBT plan so that they are fully prepared to deliver D-SNAP
benefits in the complex post-disaster environment.]{.mark}*

*[States should maintain their optional pre-disaster plans, especially
the Issuance/EBT plan, with their core plan for ease of use when
operating a D-SNAP.]{.mark}*

  -------------- ------------------------------------- ----------------------------
  **Table 7.                                           
  Optional                                             
  Pre-disaster                                         
  Plans**                                              

  **()**         **Subject Areas**                     **Location in Guidance**

                 Language issues                       See Chapter 3: [Language
                                                       Issues](#OLE_LINK91)

                 Recipient application                 See Chapter 3: [Recipient
                                                       Application](#OLE_LINK13)

                 Staffing                              See Chapter 3:
                                                       [Staffing](#OLE_LINK14)

                 Security                              See Chapter 3:
                                                       [Security](#OLE_LINK15)

                 Issuance/EBT                          See Chapter 3: [Issuance/EBT
                                                       Plan](#OLE_LINK16)
  -------------- ------------------------------------- ----------------------------

**Demographic Data**

Additionally, agencies should try to obtain demographic data during
pre-disaster planning. Although demographic information is not a
required component of the D-SNAP plan [and it is impossible to gather
demographic data on a specific disaster area before a disaster strikes,
having gathered general data at least by project area can help the
agency tailor its response to a disaster. Data on the following elements
would be helpful to properly outfitting a D-SNAP site:]{.mark}

-   Income levels

```{=html}
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```
-   [Helpful for predicting the number of potentially eligible
    households.]{.mark}

```{=html}
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```
-   Percent of elderly population

```{=html}
<!-- -->
```
-   [Helpful for designing accessible application/issuance
    sites.]{.mark}

-   [For more information, see [Elderly and Disabled
    Provisions](#OLE_LINK101)]{.mark}

```{=html}
<!-- -->
```
-   [Percent of infant population](#OLE_LINK101)

```{=html}
<!-- -->
```
-   [Helpful when planning for human comforts at application/issuance
    sites.]{.mark}

-   [For more information on human comforts, see [Human Comforts Tools
    and Actions](#OLE_LINK102)]{.mark}

```{=html}
<!-- -->
```
-   Primary language(s) spoken:

```{=html}
<!-- -->
```
-   [Essential for provision of service in appropriate
    languages.]{.mark}

-   [For more information, see Chapter 3: [Language
    Issues](#OLE_LINK91)]{.mark}

[]{.mark}

# Chapter 3

The Disaster Response

**Section 1. General**

[]{#OLE_LINK29 .anchor}Overview

This chapter contains material covering the actual disaster response.
The details of a D-SNAP will vary with each disaster and the State's
desired response, but the basic principles and framework contained in
this chapter will apply to any disaster.

[]{#OLE_LINK52 .anchor}Certification System

**Overview**

The certification system includes three areas:

-   Completing the application

-   Application screening

-   Interview and certification.

**Completing the Application**

Clients must complete a simple D-SNAP application. See *Publications -
Certification Process* for [an application template]{.mark} and Chapter
3: [Recipient Application](#OLE_LINK13) for information on designing a
D-SNAP application.

States can speed the certification process by making sure applicants
have completed their applications before they are seen by a screener or
eligibility worker. To help this process:

-   Applicants need a place to write that is protected from the
    elements. It is helpful to distribute clipboards that are the same
    size as the application.

-   Staff or volunteers can be assigned to answer questions, spot
    language issues, and help fill out the application if the applicant
    cannot read or write

-   Signs could be posted with basic information on completing the
    application, required verification, etc.

**Application Screening**

Formal application screening will also speed the certification process.
Before the applicant is interviewed, a screener can check:

-   To see if the application is complete

-   To see if the applicant has required verification of identity

-   For duplicate or on-going participation as appropriate (**Note**:
    Volunteers can assist with screening, but may not conduct duplicate
    participation checks).

**Interview and Certification**

The interview area should be set up to protect applicants\' privacy to
the extent feasible. During this stage, the eligibility worker should:

-   Conduct the interview

-   Verify information as required or appropriate

```{=html}
<!-- -->
```
-   Determine eligibility (eligibility may also be determined later, as
    long as the application is processed and benefits are available to
    the client within [3 calendar days of the date the application was
    filed).]{.mark}

-   Prepare a file for the applicant (or for off-site file creation,
    place the application/worksheet in the bin for pick-up by shippers
    for bundling and shipping to the scanners).

(Note: Volunteers cannot perform any interview or certification
functions).

**Policy**

To ensure that applicants are treated consistently:

-   All staff, including volunteers, should be trained on the policies
    appropriate to their job

-   A system should be established to provide consistent policy guidance
    on questions that arise during the disaster operation (e.g., a
    \"hotline\" can be set up to answer policy questions or managers or
    supervisors can conduct policy question and answer sessions before
    the start of operations each day).

**On-Site Review**

The State agency should try to provide for immediate, on-site
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. Please note that clients whose
circumstances have changed after they filed an application and were
denied must reapply for the D-SNAP during the application period.
Clients *do not* have the right to reopen their denied case in order to
have their eligibility recalculated because their personal circumstances
have changed during or after the application period.

[]{#OLE_LINK59 .anchor}Eligibility Criteria

+----------------+-----------------------------------------------------+
| []{#OLE_LINK98 |                                                     |
| .              |                                                     |
| anchor}**Table |                                                     |
| 8. Household   |                                                     |
| Eligibility    |                                                     |
| Requirements** |                                                     |
+================+=====================================================+
| *              | **The household\...**                               |
| *Requirement** |                                                     |
+----------------+-----------------------------------------------------+
| Residency      | -   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.      |
|                |                                                     |
|                | -   May be eligible if temporarily living outside   |
|                |     of the disaster area, but within the State at   |
|                |     the time of the disaster.                       |
+----------------+-----------------------------------------------------+
| Purchase Food  | Must plan on purchasing food during the disaster    |
|                | benefit period.                                     |
+----------------+-----------------------------------------------------+
| Adverse Effect | Must have experienced at least one of the following |
|                | adverse effects:                                    |
|                |                                                     |
|                | -   [Food lost due to disaster or spoiled due to    |
|                |     power outage (for more information on use of    |
|                |     food loss alone as an eligibility criterion,    |
|                |     see [Table 24: Program                          |
|                |     Options](#OLE_LINK97)).]{.mark}                 |
|                |                                                     |
|                | -   Damage to or destruction of the household\'s    |
|                |     home or self-employment business.               |
|                |                                                     |
|                | -   [Lost or inaccessible income, including         |
|                |     reduction or termination of income, or a delay  |
|                |     in receipt of income for a substantial portion  |
|                |     of the benefit period.]{.mark}                  |
|                |                                                     |
|                |     -   [Inaccessible liquid resources (e.g., banks |
|                |         are closed due to the disaster) for a       |
|                |         substantial portion of the benefit period.  |
|                |         However, in this day of electronic banking  |
|                |         and ATMs, closed brick-and-mortar banks may |
|                |         not cause inaccessibility of                |
|                |         resources.]{.mark}                          |
|                |                                                     |
|                | -   Disaster-related expenses not expected to be    |
|                |     reimbursed during the [30-day]{.mark} [benefit  |
|                |     period. Eligible expenses may include the       |
|                |     following plus any reasonable disaster-related  |
|                |     expenses as determined by the State agency      |
|                |     :]{.mark}                                       |
|                |                                                     |
|                | ```{=html}                                          |
|                | <!-- -->                                            |
|                | ```                                                 |
|                | -   [Home or business repairs]{.mark}               |
|                |                                                     |
|                | -   [Temporary shelter expenses]{.mark}             |
|                |                                                     |
|                | -   [Evacuation expenses]{.mark}                    |
|                |                                                     |
|                | -   [Home/business property protection]{.mark}      |
|                |                                                     |
|                | -   [Medical expenses due to personal               |
|                |     injury]{.mark}                                  |
|                |                                                     |
|                | -   [Disaster-related funeral expenses]{.mark}      |
|                |                                                     |
|                | -   [Disaster-related pet boarding fees]{.mark}     |
|                |                                                     |
|                | -   [Expenses related to replacing necessary        |
|                |     personal and household items, such as clothing, |
|                |     appliances, tools, and educational              |
|                |     materials]{.mark}                               |
|                |                                                     |
|                | -   [Fuel for primary heating source]{.mark}        |
|                |                                                     |
|                | -   [Clean-up items expense]{.mark}                 |
|                |                                                     |
|                | -   [Disaster-damaged vehicle expenses]{.mark}      |
|                |                                                     |
|                | -   [Storage expenses]{.mark}                       |
+----------------+-----------------------------------------------------+
| Income and     | -   Total net (take-home) income received during    |
| Resource Test  |     the benefit period, plus accessible liquid      |
|                |     resources, minus eligible disaster-related      |
|                |     expenses shall not exceed the disaster gross    |
|                |     income limit (defined in [Table 9. Definitions  |
|                |     of Terms](#OLE_LINK99)).                        |
|                |                                                     |
|                | -   The disaster gross income limit may with FNS    |
|                |     approval include within it a predetermined,     |
|                |     standard deduction for disaster expenses. For   |
|                |     more information, see [Disaster Guideline       |
|                |     Income Limits including Disaster                |
|                |     Expenses](#ole_link96).                         |
+----------------+-----------------------------------------------------+
| Special Cases  | In past disasters, questions have arisen on the     |
|                | following special cases:                            |
|                |                                                     |
|                | -   An applicant who is staying in a shelter, but   |
|                |     not expected to remain there for the entire     |
|                |     benefit period, IS eligible for D-SNAP          |
|                |     benefits.                                       |
|                |                                                     |
|                |     -   If an applicant for the D-SNAP has an       |
|                |         application pending for the regular         |
|                |         program, then he/she is NOT an on-going     |
|                |         recipient for purposes of determining       |
|                |         eligibility or amount of disaster benefits. |
|                |                                                     |
|                |     -   *Ongoing* clients who are residents of      |
|                |         institutions and otherwise meet the         |
|                |         eligibility criteria can receive            |
|                |         [supplemental benefits.]{.mark}             |
|                |                                                     |
|                |     -   [Households cannot receive more than one    |
|                |         D-SNAP allotment in any benefit period. If  |
|                |         a State operates two programs for two       |
|                |         different disasters in the same project     |
|                |         area, they would need to ensure that        |
|                |         households only participate in one program  |
|                |         in any benefit period. States should        |
|                |         remember that if a second disaster destroys |
|                |         the benefits obtained from a D-SNAP serving |
|                |         victims of the first disaster, the State    |
|                |         can choose to issue replacement benefits to |
|                |         affected households.]{.mark}                |
+----------------+-----------------------------------------------------+

**Eligibility and Participation in Other FNS Programs**

***Food Distribution on Indian Reservations (FDPIR)***

FDPIR benefits received by a household *prior* to the date of
implementation of the D-SNAP should *not* be considered in determining a
household\'s eligibility for D-SNAP, since whatever benefits were on
hand at the time of the disaster were presumably destroyed in the
disaster. However, if a household received regular FDPIR benefits
*after* the disaster occurred, it would *not* be entitled to receive
D-SNAP in the same month.

***The Emergency Food Assistance Program (TEFAP)***

When considering D-SNAP eligibility for TEFAP recipients, it is
important to distinguish between regular TEFAP distributions and the
distribution of commodities to households in a disaster. Under regular
TEFAP distributions, households may participate in both TEFAP and the
D-SNAP or SNAP in the same month. However, under a household *disaster*
commodity distribution, households cannot receive both D-SNAP and
disaster commodities.

[]{#OLE_LINK60 .anchor}Income and Resource Tests

**Introduction**

A household must meet the income and resource test in order to qualify
for the D-SNAP.

**Test**

The household\'s net (take-home) income received (or expected to be
received) during the benefit period plus its accessible liquid resources
minus a deduction for disaster-related expenses (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.

[As income and resources are added together for the eligibility
determination process, care should be taken to not double count
income/resources. For example, if during the Disaster Benefit Period a
household receives \$500 income and deposits it in their checking
account, that money can only be counted as either \$500 income or \$500
in resources, but *cannot* be double-counted as both income and a
resource as a total of \$1000 in income and resources.]{.mark}

The following are the definitions of terms related to the income and
resource tests.

+--------------+-------------------------------------------------------+
| []           |                                                       |
| {#OLE_LINK99 |                                                       |
| .an          |                                                       |
| chor}**Table |                                                       |
| 9.           |                                                       |
| Definitions  |                                                       |
| of Terms**   |                                                       |
+==============+=======================================================+
| **Term**     | **Definition**                                        |
+--------------+-------------------------------------------------------+
| Accessible   | -   Includes cash on hand, and funds in *accessible*  |
| Liquid       |     checking and saving accounts.                     |
| Resources    |                                                       |
|              | -   It does NOT include IRA accounts, disaster        |
|              |     insurance payments, or disaster assistance        |
|              |     received or expected to be received during the    |
|              |     benefit period, and payments from Federal, state  |
|              |     or county/local government agencies or disaster   |
|              |     assistance organizations. This includes           |
|              |     disaster-related Unemployment Compensation.       |
+--------------+-------------------------------------------------------+
| [Application | -   [Period during which the State agency may accept  |
| Pe           |     applications for D-SNAP benefits from new         |
| riod]{.mark} |     households and applications for supplements from  |
|              |     ongoing households. FNS generally approves        |
|              |     application periods of 7 days.]{.mark}            |
|              |                                                       |
|              | -   [State agencies that need to change the           |
|              |     application period dates from those in their      |
|              |     FNS-approved D-SNAP request must seek FNS         |
|              |     permission to do so. Specifically, States may     |
|              |     request an extension of the application period if |
|              |     it appears that demand for D-SNAP benefits        |
|              |     remains high after the initial application period |
|              |     has ended. For more information on extensions,    |
|              |     see [Requests to Modify, Extend, or Expand the    |
|              |     D-SNAP](#OLE_LINK39).]{.mark}                     |
+--------------+-------------------------------------------------------+
| Income       | The total net (take-home) pay of household members.   |
|              | Includes the wages a household *actually receives*    |
|              | after taxes and *all other payroll withholding*       |
|              | [(including contributions to 401K or other            |
|              | inaccessible accounts, automatic payments to          |
|              | creditors, and the like),]{.mark} public assistance   |
|              | payments or other unearned income, and net            |
|              | self-employment income.                               |
+--------------+-------------------------------------------------------+
| Inaccessible | -   Inaccessible liquid resources (e.g., the bank is  |
| Liquid       |     closed due to the disaster) for a substantial     |
| Resources or |     portion of the benefit period. [State agencies    |
| Income       |     should remember that in this day of electronic    |
|              |     banking, closed brick-and-mortar banks may not    |
|              |     cause inaccessibility of resources.]{.mark}       |
|              |                                                       |
|              | -   Delay in receipt of income for a substantial      |
|              |     portion of the benefit period                     |
+--------------+-------------------------------------------------------+
| Disaster     | -   FNS calculates each year's DGIL by adding         |
| Gross Income |     together the maximum monthly net income limit,    |
| Limit (DGIL) |     the maximum standard income deduction amount, and |
|              |     the shelter expense deduction.                    |
|              |                                                       |
|              | -   [For current Disaster Gross Income Limits and     |
|              |     Allotment tables, see                             |
|              |     [http://www.fns.usda.gov/disasters/respon         |
|              | se/D-SNAP_Handbook/guide.htm](http://www.fns.usda.gov |
|              | /disasters/response/DFSP_Handbook/guide.htm).]{.mark} |
|              |                                                       |
|              | []{.mark}                                             |
+--------------+-------------------------------------------------------+
| Deductible   | -   Expenses that the household has paid or expects   |
| Disa         |     to pay *[out-of-pocket]{.mark}* during the        |
| ster-related |     disaster benefit period. Please note:             |
| Expenses     |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   If the household has received or anticipates      |
|              |     receiving a reimbursement for these expenses      |
|              |     during the disaster period, only the net expense  |
|              |     is deductible.                                    |
|              |                                                       |
|              | -   [If the household pays expenses using a credit    |
|              |     card and will pay their credit card bill after    |
|              |     the disaster benefit period, that expense is not  |
|              |     considered out-of-pocket and is not               |
|              |     deductible.]{.mark}                               |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   [Examples of deductible disaster-related          |
|              |     expenses:]{.mark}                                 |
|              |                                                       |
|              | ```{=html}                                            |
|              | <!-- -->                                              |
|              | ```                                                   |
|              | -   [Home or business repairs]{.mark}                 |
|              |                                                       |
|              | -   [Temporary shelter expenses]{.mark}               |
|              |                                                       |
|              | -   [Evacuation expenses]{.mark}                      |
|              |                                                       |
|              | -   [Home/business protection]{.mark}                 |
|              |                                                       |
|              | -   [Disaster-related personal injury                 |
|              |     expenses]{.mark}                                  |
|              |                                                       |
|              | -   [Disaster-related funeral expenses]{.mark}        |
|              |                                                       |
|              | -   [Disaster-related pet boarding fees]{.mark}       |
|              |                                                       |
|              | -   [Expenses related to replacing necessary personal |
|              |     and household items, such as clothing,            |
|              |     appliances, tools, and educational                |
|              |     materials]{.mark}                                 |
|              |                                                       |
|              | -   [Fuel for primary heating source]{.mark}          |
|              |                                                       |
|              | -   [Clean-up items expense]{.mark}                   |
|              |                                                       |
|              | -   [Disaster-damaged vehicle expenses]{.mark}        |
|              |                                                       |
|              | -   [Disaster-related moving and storage              |
|              |     expenses]{.mark}                                  |
|              |                                                       |
|              | []{.mark}                                             |
|              |                                                       |
|              | NOTE: Take care not to mistakenly equate a            |
|              | household's total disaster losses with D-SNAP         |
|              | disaster expenses. For example, a family might report |
|              | the destruction of their \$80,000 home. However, only |
|              | that household's *out-of-pocket* expenses that are    |
|              | *not expected to be reimbursed* during that benefit   |
|              | period would be considered for determination of       |
|              | eligibility, not the entire value of their destroyed  |
|              | home.                                                 |
+--------------+-------------------------------------------------------+
| Disaster     | The [budgeting period for the D-SNAP (only income,    |
| Benefit      | resources, and expenses during the benefit period are |
| Period       | considered for D-SNAP eligibility). The benefit       |
|              | period approved by FNS for each D-SNAP is 30 days,    |
|              | except in extraordinary circumstances.]{.mark} The    |
|              | benefit period begins on the date of the disaster or  |
|              | the date of any *mandatory* evacuation preceding the  |
|              | disaster.                                             |
+--------------+-------------------------------------------------------+
| Maximum      | -   An allotment equal to the maximum monthly         |
| Disaster     |     allotment established for the regular SNAP for    |
| Benefit      |     the appropriate household size.                   |
|              |                                                       |
|              | -   [States may choose to supplement the regular SNAP |
|              |     benefits of ongoing households to bring them to   |
|              |     the maximum allotment. For more information, see  |
|              |     [Supplements](#OLE_LINK81).]{.mark}               |
|              |                                                       |
|              | -   [For current Disaster Gross Income Limits and     |
|              |     Allotment tables, see                             |
|              |     [http://www.fns.usda.gov/disasters/respon         |
|              | se/D-SNAP_Handbook/guide.htm](http://www.fns.usda.gov |
|              | /disasters/response/DFSP_Handbook/guide.htm).]{.mark} |
+--------------+-------------------------------------------------------+
| Shelter      | The maximum excess shelter expense deduction from the |
| Expense      | regular SNAP                                          |
| Deduction    |                                                       |
+--------------+-------------------------------------------------------+

**Disaster Guideline Income Limits including Disaster Expenses**

[]{#ole_link96 .anchor}With FNS approval, a State can choose to
incorporate into their disaster income limits a standard disaster
expense component. Eligibility workers often find it difficult and
time-consuming to determine a household's qualifying disaster-related
expenses, so a standard disaster deduction incorporated into the income
limits can greatly simplify eligibility determination. States that
develop a standard disaster expense do not have to collect information
on disaster expenses from applicants. States with an interest in these
specialized income limits should contact FNS for technical assistance
and approval.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Disaster Expense Deduction in Disaster Gross Income Limits            |
|                                                                       |
| In 2005, the Virginia State agency requested help from FNS in         |
| developing disaster income limits that incorporated a standard for    |
| disaster expenses. FNS has developed guidelines based on typical      |
| disaster expenses in past Virginia disasters.                         |
+-----------------------------------------------------------------------+

[]{#OLE_LINK61 .anchor}Verification

**Introduction**

Verification rules are eased during a disaster to reduce administrative
burdens and to reflect the reality that households and eligibility
workers will not have access to usual verification sources. Some things
must be verified, some things should be verified where possible, and
others can be verified if questionable.

**Verification Process**

The table below describes the verification requirements.

+------------------+------------+--------------------------------------+
| **Table 10.      |            |                                      |
| Verification**   |            |                                      |
+==================+============+======================================+
| **Applicant\'s** | **Status** | **Suggested Ways to Verify**         |
|                  |            |                                      |
| **Information**  |            |                                      |
+------------------+------------+--------------------------------------+
| Identity         | Mandatory  | -   Photo ID                         |
|                  |            |                                      |
|                  |            | -   Two documents that verify        |
|                  |            |     identity and residency           |
|                  |            |                                      |
|                  |            | -   A signed affidavit from a        |
|                  |            |     collateral contact attesting to  |
|                  |            |     the identity of the applicant,   |
|                  |            |     when other sources of identity   |
|                  |            |     are not available                |
+------------------+------------+--------------------------------------+
| Residency        | Where      | -   Utility bills, tax bills,        |
|                  | Possible   |     insurance policies, driver's     |
|                  |            |     licenses, other ID with address, |
|                  |            |     bills, or other documents that   |
|                  |            |     establish the applicant's home   |
|                  |            |     or work address.                 |
+------------------+------------+--------------------------------------+
| Household        | If         | -   After taking the application,    |
| Composition      | qu         |     the EW can ask applicant to      |
|                  | estionable |     orally list the names, ages, and |
|                  |            |     birthdays of all household       |
|                  |            |     members.                         |
+------------------+------------+--------------------------------------+
| Loss or          | Where      | -   Obtain a list of banks that were |
| inaccessibility  | possible   |     closed due to the disaster and   |
| of liquid        |            |     compare with damage maps. [State |
| resources or of  |            |     agencies should remember that in |
| income           |            |     this day of electronic banking,  |
|                  |            |     closed brick-and-mortar banks    |
|                  |            |     may not cause inaccessibility of |
|                  |            |     resources.]{.mark}               |
|                  |            |                                      |
|                  |            | -   Check with the State Banking     |
|                  |            |     Commission.                      |
+------------------+------------+--------------------------------------+
| Food Loss        | If         | -   See if residence is within the   |
|                  | qu         |     most seriously damaged areas.    |
|                  | estionable |                                      |
|                  |            | -   Check with the power company.    |
|                  |            |                                      |
|                  |            | ***NOTE**: A power outage lasting    |
|                  |            | over 4 hours will cause food         |
|                  |            | spoilage in most circumstances.*     |
+------------------+------------+--------------------------------------+

A copy of this table is included in the Eligibility/Verification Chart
in *Publications -- Certification Process* (along with eligibility
criteria, maximum allotments, etc.) so that the State agency can copy
and distribute it during a disaster.

[]{#OLE_LINK13 .anchor}Recipient Application

**Adapting the FNS Template**

State agencies must develop their own recipient applications since there
is no official FNS form for this purpose. Please see *Publications --
Certification Process* for template client applications in English and
Spanish. If a State agency uses this template to develop an application,
they *must* adapt it to reflect the D-SNAP they design. When adapting
the template, State agencies should consider the following:

-   A State-specific template is best developed during the pre-disaster
    planning process, so that it can be quickly adapted for local use
    after a disaster has occurred.

-   Any application must include questions designed to elicit
    information only on the household eligibility requirements listed in
    [Table 8 Household Eligibility Requirements](#OLE_LINK98). *States
    are restricted from adding other eligibility requirements, such as
    citizenship, without specific FNS approval.*

-   [The application must include fields for the collection of
    information on *all* individuals in a household.]{.mark}

-   States with significant language minorities should translate the
    application into appropriate languages (please see Chapter 3:
    [Language Issues](#OLE_LINK91)).

[]{.mark}

[]{#OLE_LINK16 .anchor}Issuance/EBT

**Introduction**

Each State should be prepared to implement a disaster EBT system that
can deliver SNAP benefits during an emergency, while successfully
interacting with that State's eligibility system and their EBT
contractor's system. Although they are not required to do so, States are
very strongly encouraged to maintain a disaster issuance plan and share
it with FNS. States that have not conducted D-SNAP issuance planning
activities will find that they are at a significant disadvantage when
disasters do occur.

**FNS Expectations**

FNS has several expectations for an EBT disaster issuance system:

-   FNS expects an EBT system that is easy to access and use for
    recipients, and State and county/local staff.

-   FNS expects a disaster application and issuance process that
    minimizes the number of times recipients return to a disaster
    assistance location for benefit application and issuance. Ideally,
    this would require only one visit. If recipients must return to pick
    up their EBT cards, FNS expects cards and benefits to be available
    as soon as possible, but no later than 3 calendar days from the date
    the application was filed.

-   FNS expects the disaster EBT system to provide easy integration and
    reconciliation with both the State's eligibility system and the EBT
    processor's database, and ready access to information on a State's
    disaster EBT system via on-line data and off-line reports.

**Contract and Design Requirements**

The State must use one basic guiding principal in designing their
contract that will drive many other aspects of the disaster response
system: client must have their benefits available to them within 3
calendar days from the date they filed their application. Specific
considerations include:

-   Will the cards be ordered, set up, pinned, etc., only after a case
    is approved?

-   Will cards be pre-made, stored, and ready to be issued before a
    disaster ever strikes?

Many factors will need to go into making this decision:

-   What kinds of and what size disasters does the State expect?

-   How comfortable is the State that necessary data can be captured and
    communicated in order to create cards and still meet necessary time
    frames?

-   Can PINs be created using an over-the-counter issuance approach?

FNS has provided as an example a *[Sample Request for Proposal Language
for EBT Services during a Disaster](#ole_link86),* located at the end of
this chapter. States are not required to use this contract language, but
may find it helpful.

[States are encouraged to revisit the EBT portion of their D-SNAP Plan
whenever their EBT contract is up for renewal, to ensure that
innovations desired for their D-SNAP are included in the new
contract.]{.mark}

***When to Contract***

Implementation of the EBT disaster response system may require extensive
negotiations and work with a State's EBT processor to design, develop,
and incorporate an EBT disaster system within the processor's current
operating platform. Whether this is best done as part of the Request for
Proposals (RFP) process or done once the State has a contract in hand
should be considered carefully by the State.

Advantages of building requirements in up front may be that the State
can:

-   Take advantage of competition in terms of getting competitive
    pricing for the disaster system

-   Know upfront what those costs will be

-   Have the requirements in place for the disaster system at the point
    in time when the full contract is signed.

The disadvantage of building requirements into the original procurement
is:

-   The possibility that offerors may not understand the State's needs
    and may tend to overprice their offers to minimize their risk.

The answer as to which approach may be more suitable for a State may be
in how well the State can specify its needs as part of the original
procurement. One approach would be to permit flexibility to negotiate
disaster design features after the contract is awarded.

Disaster EBT system design and development also requires working with a
State's information technology (IT) staff to integrate the disaster
system with a State's eligibility system.

It is also worthwhile considering changes to the State's eligibility
system that would enable the State to better meet the needs of emergency
issuance. For example, States that decide to issue pre-made cards with a
partial benefit immediately available are likely to have to change their
eligibility and/or EBT interfaces.

***State Program Expectations***

Prior to negotiations with a contractor, State Program and EBT staff
should determine, to the degree possible, what general features are
needed in the overall design of the EBT disaster response system. As
part of this preliminary design phase, a State should strive to
delineate its expectations of how the State wants its EBT disaster
system to operate. The State should address particular requirements such
as:

-   Card and benefit issuance

-   PIN assignment and selection

-   Card handling and security

-   Data entry and access

-   Disaster issuance reconciliation and reporting

-   Reporting for all aspects of disaster activities, such as the number
    of cards issued vs. used, percent of benefits redeemed by day, and
    customer service call center data.

In finalizing contractual arrangements for an EBT disaster system,
States and their contractors should address which party will be
responsible for the specific activities. The State should address the
following key areas and related activities in the disaster system
design.

***Retail access points and equipage***

***Terminal availability***

[Before disaster SNAP benefits can be issued, the State must determine
if there is an adequate number of authorized food retailers open to
deliver food assistance.  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 or if manual vouchers
need be used.   State agencies may also contact the Benefit Redemption
Division through their FNS Regional or Headquarters EBT contact for
current store status information.   FNS can determine, through the ALERT
system, which authorized retailers in any geographic area are able to
process transactions.]{.mark}

+-----------------------------------------------------------------------+
| > ***State Experience***                                              |
| >                                                                     |
| > Terminal Availability                                               |
|                                                                       |
| ***South Carolina***                                                  |
|                                                                       |
| South Carolina relies on its contractor to determine which retailers  |
| have operating POS devices and telecommunication connections after a  |
| disaster strikes. Florida, on the other hand, completes an annual     |
| pre-season readiness assessment in April to May of each year.         |
+-----------------------------------------------------------------------+

***Manual vouchers***

The usual manual voucher process can be used if phone lines are working,
even if electricity is out. The manual voucher process entails the
retailer calling into the EBT host's call center, receiving approval for
the purchase amount with an authorization number, and the recipient
signing the voucher. The retailer can later run the voucher through its
point-of-sale equipment once electricity is restored. If the State has a
manual voucher ceiling written into its EBT Contract for disasters, then
the process below can apply.

If retailers are open but unable to communicate with the EBT host
computer to process electronic transactions, the State may want to have
in place an emergency manual voucher process. In defining this process,
the State would need to consider:

-   Establishing [ceiling]{.mark} limits (i.e., a maximum per
    transaction amount guaranteed to the retailers without making an
    authorizing call).

-   Providing operating retailers an ample supply of manual voucher
    forms with instructions on how to use them.

-   [Instructions can be provided to EBT-only retailers by the State's
    EBT vendor or to retailers using independent Third Party Processor
    (TPP) equipment by their TPP vendor.]{.mark}

The manual voucher process is time consuming for all parties involved.
To the degree possible, the State should strive to make a manual voucher
process as easy to transact as it can. In addition, consideration will
need to be given to potential resource demands a manual voucher system
can bring with it, particularly on customer service centers, which will
need suitable staffing and ability to accept larger than usual call
volumes to accommodate the increased demand.

EBT processors usually give retailers 15 calendar days from the
authorization date to redeem manual vouchers. This timeframe may need to
be extended during a disaster. Also, it is inadvisable for retailers
using manual vouchers during a disaster to accept out-of-state recipient
cards. It is difficult for EBT vendors to process these types of
transactions, and the retailer most likely will be responsible for the
associated costs.

**Disaster EBT Cards and PINs**

***Issuance System Design***

Issuance of EBT cards and PINs to eligible households is one of the key
elements to be decided by States as they develop their EBT disaster
response system. In designing the system, the State should address:

-   Card production

-   Card storage

-   Card delivery and security

-   PIN issuance/selection and security

-   Account setup and access.

States have varied in how they have addressed these areas of system
functionality. In part, such variances depend on how account setup and
card issuance occur in the ongoing EBT system:

-   Are cards issued over-the-counter or are they mailed in the regular
    program?

-   Are PINs assigned or do recipients select them?

-   What linkages already exist between the State's eligibility system
    and the EBT system to facilitate account setup?

Variance in disaster issuance also depends on the severity of the
disasters a State expects to experience. Some States experience
disasters that can overwhelm the selection of PINs in an
over-the-counter situation. Other States are more likely to experience
disasters that are very localized in impact, and less likely to
overwhelm the over-the-counter PIN selection and card issuance process.

***Pre-established disaster EBT cards***

Among the scope of alternatives for card issuance, States may choose to
have pre-established disaster EBT cards loaded with a limited amount of
benefits which are ready to go at the time eligibility is determined.
States vary in how they approach pre-established cards.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Pre-established EBT Cards                                             |
|                                                                       |
| South Carolina and Florida are two States that employ similar, yet    |
| different, approaches. The idea common to these States is to make     |
| certain that little needs to be done to issue cards to an eligible    |
| household. Both States are concerned that without such an approach,   |
| the demands of a large disaster would overwhelm the ability to print, |
| deliver, and enable cards to be issued in an acceptable time-frame.   |
|                                                                       |
| In both States:                                                       |
|                                                                       |
| -   Households are required to make only one visit to the disaster    |
|     benefit intake center at which time, if deemed eligible, they are |
|     issued a ready-to-use card.                                       |
|                                                                       |
| -   Cards are pre-printed and have a pre-assigned PIN. Households     |
|     should be able to change these PINs when access to the call       |
|     center is available.                                              |
|                                                                       |
| -   Because the actual amounts to be issued to the household may not  |
|     be known at the time of this visit, the accounts can be set up    |
|     with a pre-determined dollar amount -- e.g., \$50 or \$100 --     |
|     that can be used immediately once they receive their card and     |
|     PIN. Any additional benefits owed to the household are added      |
|     later. (This functionality may or may not be used in Florida      |
|     dependent on the severity of the disaster circumstances.)         |
|                                                                       |
| *South Carolina*                                                      |
|                                                                       |
| Pre-established cards and benefits are immediately accessible through |
| specific disaster EBT cards after the cards are produced and system   |
| linkages made. Prior to the opening of the disaster intake sites, the |
| State system sends account set-up and benefit files to its contractor |
| for already-produced disaster cards. The account set-up and benefit   |
| files link the batch of cards produced for the disaster to the        |
| correct pre-funded accounts. Card and PIN are active from the time    |
| the card number, account set-up, and benefit are received by the EBT  |
| system, and before the cards are ever issued, thus enabling immediate |
| access.                                                               |
|                                                                       |
| *Florida*                                                             |
|                                                                       |
| This option would be used in instances of Level 2 or 3 severity       |
| without a wide geographical scope. Florida creates pre-established    |
| EBT accounts with a benefit amount set up for use once the account is |
| activated. In Florida's case, the benefits are accessible as soon as  |
| State staff link the card to one of the pre-established EBT accounts, |
| using an on-line administrative terminal that is connected to the EBT |
| system. The State staff also enter a cross-reference to the           |
| eligibility case number to enable any other benefits to be added      |
| later if the family has been found to be eligible for a higher amount |
| than initially made available. Using this option, the on-line entry   |
| is made at the point the disaster EBT card is issued to the recipient |
| to eliminate any lag time between card issuance and benefit access.   |
+-----------------------------------------------------------------------+

***Card production***

Decisions on card production are critical in terms of developing the
solution for disaster responses. Basic choices include whether to
produce cards in advance, to produce necessary quantities once a
disaster strikes, or some combination of the two. Options abound in this
area:

-   States may want to have the capability to produce their own disaster
    cards locally or in-house rather than producing cards under their
    normally contracted off-site card production.

-   If States choose to continue using their regular card production
    contractor, States should consider negotiating a separate, expedited
    process to produce emergency EBT cards in disaster situations.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Card Production                                                       |
|                                                                       |
| ***North Carolina***                                                  |
|                                                                       |
| North Carolina provides a good example of how demand can quickly      |
| exceed ability to produce a large volume of cards in a short time     |
| period if suitable advance arrangements are not in place. In their    |
| 1999 experience with Hurricane Floyd, North Carolina found that       |
| relying on the standard contractor provisions to produce and deliver  |
| disaster EBT cards and PINs to counties hit by the hurricane led to a |
| series of problems. Over 70,000 new households were found eligible to |
| receive disaster SNAP benefits. However, the card contractor was only |
| able to produce 10,000 cards per run. While several production runs   |
| could be done in a single day, these runs had to be completed when    |
| transportation was scheduled to pick up the cards. To expedite        |
| delivery of the cards to over 30 counties devastated by Hurricane     |
| Floyd, the State chose to fly its own plane to Houston to pick up EBT |
| cards. In the end, the production run schedule along with the         |
| transportation and local distribution timing meant expedited card     |
| delivery to everyone found eligible for disaster benefits could not   |
| be accomplished. \[Note: North Carolina's current disaster plan       |
| provides for a supply of cards to be produced in advance and ready to |
| be issued should a disaster strike.\]                                 |
|                                                                       |
| ***South Carolina***                                                  |
|                                                                       |
| South Carolina was able to respond to Hurricane Floyd a little        |
| differently. The State, which had the capability to produce its own   |
| EBT cards, do card set-up, and provide PINs to those cards in advance |
| of the hurricane arriving, was able to produce 50,000 disaster EBT    |
| cards prior to Floyd hitting the mainland. This was sufficient --     |
| they used approximately 10,000 cards \-- given the smaller impact of  |
| Floyd on the State. A larger disaster may have required additional    |
| card production. As with other areas of the disaster response system, |
| the magnitude of the disaster clearly influences card production      |
| decisions. If Hurricane Floyd was not so significant in its impact,   |
| North Carolina's card producer may have been able to keep up with the |
| demand as well. Card production has not proved to be an issue in the  |
| smaller-scale disasters.                                              |
+-----------------------------------------------------------------------+

***Card storage and security***

States must have secure facilities to house disaster EBT cards and
procedures in place for handling and reconciling card storage and
distribution. If a state develops and warehouses a stock of pre-made,
disaster EBT cards, the cards must be stored in a secure,
climate-controlled facility. Even if the State is not warehousing
pre-made disaster cards, during the process of disaster card issuance,
the State will need to establish in-state card storage and security
procedures for the temporary housing of EBT cards prior to issuance.
This includes the handling of cards at county/local offices where they
are distributed. Security measures must be coordinated with local
police, National Guard or other security personnel.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Florida stores disaster EBT cards in another state in a secure,       |
| climate controlled, MasterCard/VISA® facility with prepared manifests |
| for reconciliation and control. South Carolina stores blank card      |
| stock within the State because they produce their own EBT cards.      |
| South Carolina minimizes the risk associated with pre-loaded cards by |
| delaying account set-up and PIN procedures until the day prior to     |
| delivery to the disaster site. The State also uses secure delivery    |
| procedures along with manifest reconciliation and control procedures. |
| North Carolina's new disaster response system also stores pre-made    |
| cards at a facility in the State.                                     |
+-----------------------------------------------------------------------+

***PIN Issuance***

States can choose amongst several alternatives for PIN assignment to EBT
cards:

-   PIN selection by clients

-   Pre-PINed, pre-activated EBT cards

-   Pre-PINed EBT cards that require activation

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| PIN Issuance                                                          |
|                                                                       |
| ***South Dakota***                                                    |
|                                                                       |
| South Dakota has continued to provide for PIN selection during its    |
| disasters by having several PIN-select devices dispatched to each     |
| disaster issuance site. These devices require a telephone line to     |
| allow households to choose their PIN and to activate the card on the  |
| EBT system.                                                           |
|                                                                       |
| ***South Carolina, North Carolina, and Louisiana***                   |
|                                                                       |
| South Carolina, North Carolina, and Louisiana all chose to pre-PIN    |
| their States' disaster EBT cards using four digits of the Primary     |
| Account Number (PAN) as the PIN. The States decided to use the PAN    |
| digits for the PIN so the card would be active at the point of        |
| issuance without any further activity required on the part of the     |
| State or recipient, thereby reducing the burden on disaster victims   |
| and easing training requirements. However, having the PIN clearly     |
| available on the card face does raise benefit security issues if a    |
| card is lost or stolen. North Carolina has since indicated it would   |
| not use this method again while South Carolina would repeat the       |
| process in the future, as it did not have any losses as a result of   |
| this approach.                                                        |
|                                                                       |
| ***Florida***                                                         |
|                                                                       |
| Florida's response system uses a different procedure to assign a PIN  |
| to each card. In advance, along with the production of cards, a PIN   |
| assignment alternative is chosen based on the alternative used for    |
| card issuance. For support of on-site card issuance, the plan         |
| currently includes PIN creation based on the last four digits in the  |
| customer's case number. The case number is randomly generated and     |
| available via the state and contractor Customer Service Helplines,    |
| the website and eligibility notices.                                  |
+-----------------------------------------------------------------------+

***Site Delivery Capability***

In designing a disaster issuance system, designers must be aware that
conventional card delivery systems, such as mail or overnight express,
may not be able to reach disaster areas. The disaster plan should
include alternative methods for delivering EBT cards to various issuance
sites.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Delivery Capability                                                   |
|                                                                       |
| ***North Carolina***                                                  |
|                                                                       |
| For Hurricane Floyd, North Carolina sent the Governor's plane to      |
| Texas several times to pick up batches of cards at the production     |
| plant. The plan made several stops to drop off portions of the        |
| shipments to locations where cars were waiting to transport the cards |
| to issuance sites. The State had to time this procedure carefully,    |
| and at each drop-off point, staff had to take the time to sort        |
| through the batches, selecting the cards designated for each site by  |
| the individuals' names on the cards and manifest.                     |
|                                                                       |
| ***Florida***                                                         |
|                                                                       |
| To the extent possible, Florida intends to drop-ship cards into       |
| areas. Since their cards are not name-specific, there is no extra     |
| step required to sort by name and issuance site.                      |
+-----------------------------------------------------------------------+

***Household Card Delivery and Issuance***

State designers should develop procedures for delivering EBT disaster
cards to recipients when mail is interrupted or when households are
temporarily housed outside the disaster area. In major disasters, mail
service may be interrupted altogether or may be unavailable
inconsistently due to conditions in certain neighborhoods. States with a
high number of displaced households will also have difficulty ensuring
that households received mailed EBT cards. In both instances, States
should consider onsite issuance to avoid a large number of returned EBT
cards.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Overall PIN and Issuance Strategies                                   |
|                                                                       |
| ***Florida***                                                         |
|                                                                       |
| As Florida has experienced disasters of varying degrees of severity   |
| and damage, they maintain readiness to implement four varieties of    |
| card issuance: mail and three forms of on-site issuance.              |
|                                                                       |
| **Mail** --                                                           |
|                                                                       |
| This is Florida's primary form of card issuance to regular SNAP       |
| clients and can be used with all disaster levels.                     |
|                                                                       |
| -   The goal for customer receipt of mailed cards is 3 calendar days  |
|     from the date they filed their application.                       |
|                                                                       |
| -   Cards require no activation upon receipt.                         |
|                                                                       |
| -   Cards show the cardholder's name.                                 |
|                                                                       |
| -   Cards are mailed to the client's address stored in the            |
|     eligibility system and are not forwarded by the post office.      |
|                                                                       |
| -   The PIN is four digits of the primary cardholder's case number,   |
|     as printed on the Notice of Eligibility. Clients can change their |
|     PIN number by calling the EBT customer service number.            |
|                                                                       |
| **Onsite** -- All Onsite Operations                                   |
|                                                                       |
| Onsite issuance also can be used for all disaster levels. For all     |
| onsite operations:                                                    |
|                                                                       |
| -   Cards do not require activation. They become active upon system   |
|     action to set up the EBT account.                                 |
|                                                                       |
| -   The cardholder's name is not present on the card.                 |
|                                                                       |
| -   The applicant/recipient will be required to sign and date the     |
|     manifest to validate acceptance of the card. This may be          |
|     accomplished by swiping the EBT card through a POS or card reader |
|     in an automated environment.                                      |
|                                                                       |
| -   The PIN is four digits of the primary cardholder's case number as |
|     printed on the "Notice of Eligibility", which may be presented to |
|     the household onsite or mailed to them. The client may change     |
|     their PIN by calling the EBT customer service number.             |
|                                                                       |
| **Onsite** - Manual                                                   |
|                                                                       |
| This option does not require electricity and telecommunications.      |
|                                                                       |
| -   After completing a paper application and the initial eligibility  |
|     screening, the applicant will be directed to the EBT section with |
|     their application and the following steps occur:                  |
|                                                                       |
| -   The applicant will be asked to provide positive identification.   |
|                                                                       |
| -   The worker verifies ID, reviews paper application, and completes  |
|     paper worksheet.                                                  |
|                                                                       |
| -   The applicant brings the application and worksheet to the EBT     |
|     tent/line.                                                        |
|                                                                       |
| -   The worker checks to ensure documents are present.                |
|                                                                       |
| -   The EBT staff person will accept the application, select the next |
|     consecutive EBT card from their inventory, ensure that the card   |
|     number on the card matches the card number on the manifest, and   |
|     then places a sticker from the manifest on each copy of the paper |
|     application.                                                      |
|                                                                       |
| -   The applicant will be required to sign and date the manifest on   |
|     the appropriate line.                                             |
|                                                                       |
| -   The EBT staff person will give the applicant an EBT card,         |
|     training materials, informational flier and provide instructions  |
|     regarding the PIN and when the card will be able to be used. The  |
|     time frame for benefit availability with this option will be      |
|     determined by the backroom processing time frames.                |
|                                                                       |
| -   The EBT staff person will place the original page of the paper    |
|     application in the designated area for pick-up and delivery to an |
|     off-site processing center.                                       |
|                                                                       |
| ## Onsite - Automated                                                 |
|                                                                       |
| #                                                                     |
| # This option requires access to electricity and telecommunications.  |
|                                                                       |
| ## Individuals are pre-registered by int                              |
| ernet or phone and are processed on site through the express process. |
|                                                                       |
| -   The individual pre-registers by the internet or phone.            |
|                                                                       |
| -   The individual arrives at the site and is directed to the express |
|     line for pre-registered applicants.                               |
|                                                                       |
| -   The worker then swipes or enters driver's license in a point of   |
|     sale (POS) machine or card reader.                                |
|                                                                       |
| -   The individual acknowledges application by virtue of presenting a |
|     valid Florida ID.                                                 |
|                                                                       |
| -   The worker then swipes the applicants EBT card in a point of sale |
|     (POS) machine or card reader to link to the electronic            |
|     application.                                                      |
|                                                                       |
| -   The EBT staff person will accept the application, ensure that the |
|     number on the card matches the card number on the manifest, and   |
|     then place a sticker from the manifest on the EBT flier and void  |
|     the second sticker on the manifest.                               |
|                                                                       |
| -   The EBT staff person will give the applicant an EBT card,         |
|     training materials, and provide instructions regarding the PIN    |
|     and when the card will be able to be used.                        |
|                                                                       |
| -   Benefits for this option should be available within two - three   |
|     days, dependent on streaming into the eligibility system.         |
|                                                                       |
| ## Onsite - Special Needs                                             |
|                                                                       |
| This option requires access to electricity and telecommunications and |
| approval of a special waiver for this population.                     |
|                                                                       |
| -   Individuals register by internet or phone. Identity is verified   |
|     by computer match(s) to process this application and no           |
|     face-to-face interview is required.                               |
|                                                                       |
| -   The individual completes the application on the internet or, by   |
|     phone.                                                            |
|                                                                       |
| -   The individual's identity is verified by computer match(s).       |
|                                                                       |
| -   Application is processed, and the FLORIDA interface sends the     |
|     data to EBT.                                                      |
|                                                                       |
| -   The EBT card is mailed to the applicant.                          |
|                                                                       |
| -   The "Notice of Eligibility" is mailed to them at the same time as |
|     the EBT card. This notice contains the applicants (PIN) which is  |
|     four digits of the primary cardholder's case number.              |
+-----------------------------------------------------------------------+

**Telecommunications Needs**

In designing an EBT disaster issuance system, States, together with
their EBT contractors, should consider potential telecommunication
issues. This includes considering what telecommunication alternatives
will be available if there are significant failures in regular
telecommunications systems in the disaster area. In most cases,
telecommunications can be restored to a disaster area by the time a
Disaster Program is approved. From experience, telecommunications are
among the earliest services to be reactivated in a disaster area.
However, the most severe disasters may leave telecommunications
inoperable for longer periods of time.

Alternatively, functioning telecommunications may reach their maximum
capacity for use, as in Louisiana in the aftermath of Hurricane Katrina.
Cell towers were inundated with calls and communications were restricted
to those who could get a signal, preventing easy access to benefit call
centers and the ability to change a card's PIN. Situations requiring
alternative processes include:

***Retailers unable to communicate with the EBT host computer***

In this case, States might consider operating a manual EBT voucher
process. One option might be to establish floor limits on those vouchers
when the retailer cannot make calls at the time of transaction.

***Telecommunication issues between disaster application/issuance sites
and state eligibility, card production and distribution systems***

States should prepare alternative procedures for handling applications
and card and benefit distribution when the state's eligibility and EBT
systems cannot communicate with staff taking disaster applications and
issuing EBT cards and benefits. As technology evolves, new options for
remote access to State and contractor systems become available. States
can now set up laptops with software that allows users at a remote
disaster site to connect with an EBT host system. To successfully make
use of this technology, States should:

-   Create and maintain an inventory of user identification numbers.

-   Make a sufficient number of dial-up ports available or have
    alternatives such as buying bandwidth and creating a mobile telecom
    environment with a local area network and supporting satellite
    linkages.

-   Consider whether or not limited dial-up capability will suffice for
    a disaster of a large scale or whether changes must be made,
    potentially on short notice.

-   Offer training to users on the types of technology deployed.

-   Make certain they have the ability to troubleshoot modem problems or
    other technological problems.

-   Consider the potential impact of weather and disaster site
    conditions on the function of the equipment.

Cellular and satellite telecommunication options are emerging as
potential solutions. States adopting any such technology must thoroughly
test it prior to a disaster event to ensure it is sufficiently
accessible and reliable and can transmit information quickly. Again,
there may be limited cell service during peak hours in a larger
disaster.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Issuance with Alternative Telecommunications at Site                  |
|                                                                       |
| ***Florida***                                                         |
|                                                                       |
| Florida has updated their technology to include a suite of tools that |
| allow full use of the Florida eligibility determination system and    |
| EBT when the telecommunications infrastructure is interrupted.        |
| Components include:                                                   |
|                                                                       |
| -   Laptops and card readers                                          |
|                                                                       |
| -   Mobile, handheld computers with card reader capability            |
|                                                                       |
| -   Barcode scanning devices                                          |
|                                                                       |
| -   Electronic signature capture                                      |
|                                                                       |
| -   Mobile satellite equipment                                        |
|                                                                       |
| -   Internet-based pre-application for clients                        |
|                                                                       |
| Clients are able to pre-register for benefits on the internet prior   |
| to arrival at a disaster site. When the client arrives at the site,   |
| workers using handheld device or laptop screen with a card reader     |
| swipe the client's Florida-issued driver's license or identification  |
| card. The client's pre-application information appears on the         |
| handheld device or laptop screen and is reviewed with the client. The |
| worker then swipes the EBT card, which links the card to the case.    |
| The worker places a bar-coded sticker on a flier about their EBT card |
| and voids a second sticker on the manifest. The worker gives the      |
| client their EBT card, training materials, and the EBT flier with the |
| bar code as a receipt. After eligibility is determined in a           |
| back-office (not disaster site) process, the State mails the customer |
| a Notice of Eligibility that contains their PIN. The PIN is also      |
| available via the State EBT Customer Service Helpline as well as the  |
| website. Communication between technology at the site and the Florida |
| eligibility system is ensured by location of a portable antennae      |
| (dish) that transfers information from the site, to a satellite, and  |
| then to the eligibility system.                                       |
+-----------------------------------------------------------------------+

**Recipient and Retailer Training and Customer Service**

***Recipient training***

When developing an EBT Disaster system, design staff needs to keep in
mind that many of the applicants for disaster benefits are first time
recipients. The disaster system design will need to provide for EBT
training and the disaster plan should include information on how and
when the State will train clients and what material they will distribute
to clients. Training should include:

-   Eligible food items for purchase.

-   How to use the EBT card.

-   Unusual policies not used for the regular program. For example, if
    the State plans to expunge the disaster benefits from the EBT
    account after a more limited time frame than is done in the ongoing
    program.

States also may want to consider ways to inform ongoing recipients of
changes in the normal EBT system due to the disaster. Use of recorded
messages on State hot lines or on the EBT audio response unit (ARU) may
help in this regard. For example, such messages could convey information
about the specific geographic area(s) impacted by the disaster or
identify those areas not impacted.

***Retailer training***

Retailer training is also a critical consideration, given that EBT
operations and practices may differ with each disaster response and that
there will be many first time recipients using EBT. Retailer training
should include:

-   Information on any changes to floor limits or the need to obtain an
    approval code.

-   Information on disaster manual vouchers, if they differ from those
    used during ongoing operations.

-   Differences in card features (e.g., no recipient name, different
    color).

As with recipient-targeted messages, States may want to consider ways to
inform retailers of changes to the status of emergency processing due to
the disaster circumstances. States often choose to use ARU messages,
which can be placed at the beginning of any greeting on the retailer
toll-free customer service number or the automated voucher approval
toll-free number that is often printed on the back of client cards.
States may also consider sending mass emails or auto-dialed recorded
mass telephone messages. In any case, it is imperative for States to
develop some method of communicating with retailers that is not mail
dependent, as mail systems may be impeded in major disaster and any
information or vouchers sent out to retailers through the mail may be
delayed.

***Customer service***

During a disaster, and even prior to a disaster, States and their
contractors should expect a significant spike in customer service calls.
Designers should consider the impact of an unusually large influx of
recipient callers with questions about their EBT accounts. Designers
should also expect an increase in retailer calls, especially in areas
where emergency manual voucher use is approved. The increase in calls
from both recipients and retailers may be compounded by any decision to
expedite or streamline recipient training. Consequently, State must take
the training approach into consideration when planning for customer
service demands.

The development of scripts for customer service personnel -- some of
whom will be new to the job \-- will assist them in providing
appropriate assistance during a possibly chaotic time. State should
examine provisions for updating the scripts to ensure callers get the
most current information, as it becomes available.

**Data entry accessibility**

Data entry is another one of the critical considerations in an EBT
disaster response system. In many EBT disaster response designs, data
may need to be transmitted to the State's eligibility system and on to
the EBT contractor before cards can be issued and/or the recipients can
access benefits.

***On-site data entry***

In order to enter data on-line from the disaster application/issuance
sites, the State will likely need to deploy computers, laptop or
otherwise, to the site. These computers need to have the necessary
hardware features to achieve on-line communication as well as to handle
the software necessary to communicate with the State's eligibility
system. In making these decisions, States will need to consider the cost
of portable equipment, available access to electricity and/or sufficient
battery capability, equipment security and storage, and capability to
communicate with the State's eligibility system and/or the State's EBT
contractor processing system from a remote location. The State must also
consider data security from the point of obtaining application
information at the site to completion of eligibility determination and
delivery of benefits under less than ideal conditions.

***Off-site data entry***

If State system designers decide to enter data off-site (i.e., away from
the disaster application/issuance site), then attention must be given to
several areas. Design features must focus on:

-   Data collection document handling and security at disaster benefit
    issuance sites.

-   Data entry form delivery and drop-off points.

-   Access to data entry terminals and data entry staffing.

-   Cut-off times for non-disaster, benefit program data entry, and the
    overall time delay between entering applicant data and recipients'
    receipt of EBT cards and benefits.

These areas involve major workload considerations that impact other
areas such as card production and benefit access. Specifically, delays
in data entry can lead to delays in benefit access and, minimally,
complicate public announcements regarding the timing of benefit access.

***Data entry cut-off times***

Designers need to be aware of system data entry cut-off times for
entering disaster related benefit eligibility and issuance information.
Cut-off times may not only impact data entry options, but impact other
design elements as well, such as card production and delivery and staff
availability.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Data Entry Cut-off Times                                              |
|                                                                       |
| ***North Carolina***                                                  |
|                                                                       |
| In North Carolina, nightly batch processing of the State's issuance   |
| data created benefit accounts resulting in card production the next   |
| day. For applications entered after the nightly data entry cut-off,   |
| cards were not produced the next day unless the EBT contractor and    |
| card vendor scheduled an extra batch run.                             |
|                                                                       |
| Louisiana sent batch files every two hours after Katrina. Thus, most  |
| recipients were issued a card and able to use their benefits that     |
| same day.                                                             |
+-----------------------------------------------------------------------+

**On-going caseload benefits & card delivery**

***Card replacement for on-going caseload***

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 and protocols for
ongoing cases to receive replacement cards as soon as possible. The EBT
system may need to recognize that these ongoing recipients need to get
their replacement card more quickly than under ordinary circumstances
and in a different manner. 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.

States may also consider allowing the customer service contractor to
make address changes without requiring the household to contact their
county or local office to prompt an address change from the State's
eligibility system. If a State chooses this process, the system must
ensure that such changes appear on the State's eligibility system and
the State must take measures to address any risk of fraud. To ease the
burden on current recipients, the card replacement process ideally
should not affect the recipients' current PIN.

States may apply for a waiver that allows for the PAN on an EBT card to
be key-entered at a retailer location with the card not present, if the
card was lost in a disaster. States may also request a waiver to issue
regular monthly benefits early for impending natural disasters.

Program policy makers and design staff should work together to determine
whether or not they will replace lost disaster EBT cards. Designers
should be involved, at least at the advisory level, to provide
decision-makers with the pros and cons of the options concerning card
replacement policy.

**Reporting and Reconciliation**

The State also must address reporting and reconciliation areas unique to
EBT systems:

-   **Card production and delivery reconciliation**:

> Cards shipped from a central location need to 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. Since some
> households may already have a card (active from a prior period of
> participation), they may continue to use their existing card if
> available, even though they have received a new benefit for the
> disaster. Because of these existing cards, differences between the
> number of households approved for disaster benefits and the number of
> cards issued will arise and potentially create confusion.
>
> 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 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 issued 220 cards, the State would need to obtain an
> explanation.
>
> State 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**

> It is important that States 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, 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 guidelines so that they can compare benefits posted to
> accounts to benefits issued by the State eligibility system.

-   **Benefit expungement**

> To reduce costs and ensure security is not compromised, several State
> agencies have sought to limit the duration of disaster benefits to 60
> to 90 days. FNS must approve any expungement period less than the
> number of months available for non-disaster SNAP benefits. System
> designers need to work with the EBT contractor to develop a process
> for expunging disaster benefits from the EBT system. To do this, the
> State system must be able to 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.

-   **FNS notification of disaster benefits issued**

> Since funding is obligated once benefits are posted to the EBT system,
> State agencies should estimate the amount of benefits to be issued and
> provide this estimate to the FNS Regional Office financial management
> staff to ensure that funding ceilings are not exceeded. This needs to
> occur several days in advance of the initial day of a disaster program
> and should be updated periodically.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| FNS Notification of Issuance                                          |
|                                                                       |
| South Carolina's and Florida's EBT systems enable the State agency to |
| report on benefit usage each day compared to the dollar amount of     |
| benefits issued. The tracking feature enables an after-the-fact       |
| review of benefit usage until all benefits are either redeemed at     |
| food retailers or expunged.                                           |
+-----------------------------------------------------------------------+

**System Testing**

The State should test their disaster response systems before use during
an actual disaster. Moreover, State agencies should consider conducting
periodic tests of the EBT disaster system to ensure that it remains
up-to-date. For EBT, we ask for at least annual testing. The State
should consider at least the following factors during their periodic
tests:

-   Modifications that have been made to software or equipment that may
    impact the disaster design.

-   Training needs of new staff that is not yet acquainted with the
    disaster system.

+-----------------------------------------------------------------------+
| ***Sample Request for Proposal Language***                            |
|                                                                       |
| []{#ole_link86 .anchor}***for EBT Services during a Disaster***       |
|                                                                       |
| Disaster preparation and contingency planning covers three areas. The |
| first is the Contractor's system; the second is the State's           |
| eligibility systems; and the third is natural disasters impacting a   |
| large number of the State's population.                               |
|                                                                       |
| **Contractor Systems**                                                |
|                                                                       |
| The Contractor shall provide an alternate means of authorization of   |
| EBT transactions during short-term outages, when switching over to    |
| the back-up site is not considered appropriate.  The response to this |
| requirement shall also include how the Contractor will notify both    |
| the State and the retailer community that an outage is occurring, and |
| alternate means of authorizations are currently in place.             |
|                                                                       |
| However, in the event of a disaster impacting the availability of the |
| Contractor's primary data processing site, the Contractor shall have  |
| available a back-up site for host processing and telecommunications   |
| network services.  The Contractor shall have the EBT hot back-up site |
| begin processing transactions within one hour of a disaster           |
| declaration.                                                          |
|                                                                       |
| The Contractor's disaster recovery plan shall also include a State    |
| notification process as well as disaster declaration criteria and     |
| timeframes that are acceptable to the State.  The Contractor shall    |
| notify the State immediately upon Contractor's decision to move to a  |
| disaster back-up site to provide EBT services.  If the Contractor is  |
| providing EBT services to multiple States, the disaster recovery plan |
| shall address the timing and order of recovery of the State as        |
| compared to the other agencies being processed.  The recovery of the  |
| State of Alabama's EBT system shall not be delayed because the        |
| Contractor is recovering other States' EBT systems.                   |
|                                                                       |
| The disaster back-up site shall be tested annually, and the           |
| Contractor shall provide the State with copies of such test results   |
| within thirty (30) days of receipt of the test results.               |
|                                                                       |
| ### State Systems                                                     |
|                                                                       |
| The Contractor shall support the recovery of the State's eligibility  |
| and EBT interface systems at a back-up site in the event of a         |
| disaster at the State's primary data center.  This support shall      |
| consist of providing connectivity to the State's back-up site to      |
| support the transmission of data files and reports between the State  |
| and the EBT Contractor.  Initial support may consist of only dial-up  |
| access until a more robust solution can be implemented.  The          |
| connectivity during the initial days of a disaster may also consist   |
| of passing tape cartridges between the Contractor and the State.  In  |
| either case, the Contractor shall provide support to the State in     |
| ensuring that benefits are still being provided to clients through    |
| the EBT system during the recovery of the State's data processing     |
| systems.  Following the declaration of a disaster by the State and    |
| movement to a back-up data center, the Contractor shall work with the |
| State technical staff to provide EBT administrative terminal support. |
|                                                                       |
| ### Natural Disasters within State                                    |
|                                                                       |
| The EBT contractor shall support providing benefits to State clients  |
| subsequent to the occurrence of a natural disaster within the State.  |
| The basic assumption in this scenario is that there is sufficient     |
| infrastructure available within the retailer community to support EBT |
| as a means for benefit payments.  This section provides the           |
| requirements to the EBT contractor for providing these benefits.      |
|                                                                       |
| The State's plan in supporting natural disasters is to maintain an    |
| inventory of pre-embossed and pre-encoded EBT cards within the State  |
| that would be used in the event of a disaster.  Following the         |
| declaration of a disaster supporting expedited issuance of SNAP       |
| benefits by USDA, the State would issue the disaster EBT cards to     |
| eligible clients within the disaster areas.  Following the issuance   |
| of the card, the State would update the respective EBT account on the |
| Contractor's EBT system through the batch interface with the          |
| associated demographic information, including the assigned case       |
| number and client name.  Benefits would also be added to the EBT      |
| account through the batch interface.                                  |
|                                                                       |
| To support the State's plan for EBT disaster services, the Contractor |
| shall establish and maintain on the EBT database predefined disaster  |
| accounts and the related EBT card.  The Contractor shall create       |
| 25,000 EBT accounts to be used for disaster services, and the         |
| associated EBT cards and system assigned PINs.  These EBT accounts    |
| shall remain on the Contractor's EBT system until utilized for a      |
| disaster.  The EBT cards and PIN mailers shall be delivered to the    |
| State in EBT account number ascending sequence.  The State will store |
| the cards and related PIN mailers until they are needed for a         |
| disaster.  The EBT account number shall be used as an identifier on   |
| both the Card and PIN mailer, so the two can be matched and provided  |
| to clients during a disaster.  The Contractor shall work with the     |
| State during the design phase of the project to finalize and document |
| these requirements.                                                   |
|                                                                       |
| For localized disasters impacting a small geographic area, such as an |
| area hit by a tornado, the Contractor shall support the option of     |
| drop shipping all requested EBT cards to a specified address within   |
| the impacted area.  The impacted area would be identified by zip      |
| code.  Following written notification by the State, the State         |
| requires that all EBT cards that would normally be mailed to clients  |
| within the impacted zip codes instead be dropped shipped to the       |
| location specified by the State.  The EBT cards would be dropped      |
| shipped until written notification is received from the State to      |
| discontinue drop shipping and begin mailing cards again.  This is a   |
| Fee for Service option that should be priced separately in the        |
| Respondent's pricing proposal.                                        |
+-----------------------------------------------------------------------+

[]{#OLE_LINK91 .anchor}Language Issues

**Introduction**

Most states have communities of non-English speakers that may be
eligible for and apply for D-SNAP benefits. State agencies should
prepare translated materials and confirm access to interpreters for
these communities well in advance of disasters.

**Needs Analysis**

State agencies should determine in advance whether there could be a need
for translated materials and interpreters. They may use the same
criteria as for the regular program (see 7 CFR 272.4, summarized below).
State agencies should consider the needs of single-language minorities
throughout the state, not just single-language minorities in low-income
areas, as disasters are not limited to low-income areas.

+-----------------------+-----------------------------------------------+
| **Table 11. Language  |                                               |
| Service               |                                               |
| Requirements**        |                                               |
+-----------------------+-----------------------------------------------+
| **Resource**          | **Guideline**                                 |
+-----------------------+-----------------------------------------------+
| Program information   | -   In project areas with less than 2,000     |
| materials             |     low-income households if approximately    |
|                       |     100 or 5 percent of those households are  |
|                       |     of a single language minority, or         |
|                       |                                               |
|                       | -   In project areas with a certification     |
|                       |     office that provides bilingual service.   |
+-----------------------+-----------------------------------------------+
| Program information   | -   In offices that provide service to areas  |
| materials,            |     containing 100 single language minority   |
| certification         |     households, or                            |
| materials (including  |                                               |
| applications) and     | -   In project area with a total of less than |
| interpreters          |     100 low-income households if a majority   |
|                       |     of those households are of a single       |
|                       |     language minority, or                     |
|                       |                                               |
|                       | -   In project areas with a seasonal influx   |
|                       |     of non-English-speaking households, if    |
|                       |     during the seasonal influx the number of  |
|                       |     single-language minority low-income       |
|                       |     households which move into the area meets |
|                       |     or exceeds the requirements in the        |
|                       |     paragraphs above.                         |
+-----------------------+-----------------------------------------------+

**Sources of Assistance**

The State agency should identify and coordinate with community
organizations or professional language services that can assist with
language services in the event of a disaster. Identify those contacts
and any arrangements made in the chart located in Chapter 3, [Public
Information and Outreach](#OLE_LINK30) so the information is available
at the time of a disaster.

Possible sources for translation services and interpreters include:

-   Current staff

-   Translation services

-   Universities

-   Churches

-   Community centers

-   Private assistance agencies

-   Advocate/legal services groups

**Translations**

To the extent possible, the State agency should translate materials into
these major languages during pre-disaster planning. After translating
appropriate materials, States should keep an electronic copy on file for
easy access and use in a disaster. Please see *Publications --
Certification Process* for client applications in English and Spanish.

Materials that require translation might include:

-   Client applications

-   General information handouts

-   Eligibility requirements

-   Fraud flier/posters

-   D-SNAP-related public web or hotline recording content

-   Press releases for use on television and radio

[]{#OLE_LINK30 .anchor}Public Information and Outreach

Experience with disasters has taught that it is essential to take a
proactive approach to public information and outreach from the start of
the disaster response. Planning ahead is critical to adequate disaster
response. State agencies that already perform outreach for their regular
SNAP and have an outreach plan may wish to add to it a contingency plan
for outreach during a disaster. Any disaster outreach plan should
specifically outline the roles of any partner organizations. For
information on creating an outreach plan, please see the SNAP Outreach
Toolkits for State and county/local agencies and non-profit partners at
[www.fns.usda.gov/SNAP/outreach/tool-kits.htm](http://www.fns.usda.gov/fsp/outreach/tool-kits.htm).

State agencies should pursue a public information and outreach approach
that best suits the needs of their population and the characteristics of
the disaster at hand. States should consider, but are not required, to
use any of the following approaches to public information and outreach.
Add to the table any additional actions identified by your State agency
during pre-disaster planning.

+------------------------------------------------------+---------------+
| **Table 12. Public Information and Outreach          |               |
| Actions**                                            |               |
+======================================================+===============+
| **Action**                                           | **When**      |
+------------------------------------------------------+---------------+
| Arrange with FEMA to have initial press releases     | Immediately   |
| given \"priority use\" in official FEMA statements.  |               |
+------------------------------------------------------+---------------+
| Issue press release(s) with:                         | Any time      |
|                                                      | after FNS has |
| > [When the D-SNAP is scheduled to begin]{.mark}     | approved the  |
|                                                      | State's       |
| -   D-SNAP eligibility and verification requirements | request to    |
|                                                      | operate a     |
| > Civil and criminal penalties for fraud             | D-SNAP        |
| >                                                    |               |
| > Proper use of SNAP benefits                        |               |
| >                                                    |               |
| > Non-discrimination statement                       |               |
|                                                      |               |
| -   [Location and operating hours of                 |               |
|     application/issuance sites]{.mark}               |               |
|                                                      |               |
| -   [Special provisions (e.g. approved               |               |
|     waivers)]{.mark}                                 |               |
|                                                      |               |
| -   [Instructions for on-going participants and      |               |
|     applicants with special needs]{.mark}            |               |
|                                                      |               |
| -   [Fraud control measures]{.mark}                  |               |
+------------------------------------------------------+---------------+
| Contact advocate community groups during as part of  | During the    |
| disaster planning to enlist their support with       | disaster      |
| outreach efforts and address their concerns.         | planning      |
| Community partners [should refer to the SNAP         | process       |
| Outreach Toolkit for Community Organizations         |               |
| supplement on the D-SNAP at                          |               |
| [www.fns.usda.gov/SNAP/outreach/tool-kits.htm]       |               |
| (http://www.fns.usda.gov/fsp/outreach/tool-kits.htm) |               |
| and]{.mark} FRAC's "Advocate's Guide to the Disaster |               |
| Food Stamp Program" at                               |               |
| [www.frac.org/pdf/D-SNAPgu                           |               |
| ide06.pdf](http://www.frac.org/pdf/dfspguide06.pdf). |               |
+------------------------------------------------------+---------------+
| Contact retailers with information:                  |               |
|                                                      |               |
| -   On whether temporary IDs will be issued or       |               |
|     required                                         |               |
|                                                      |               |
| -   On any relevant waivers (e.g. hot food waiver)   |               |
|                                                      |               |
| -   On the estimated number of new SNAP clients      |               |
|                                                      |               |
| -   To post in their stores regarding D-SNAP sites,  |               |
|     hours, etc.                                      |               |
+------------------------------------------------------+---------------+
| Set up news conferences to make major announcements. | As            |
|                                                      | appropriate   |
+------------------------------------------------------+---------------+

**Sample Press Releases**

Examples of press releases are included in *Publications -- Public
Affairs*.

**Public Information by Call Center and Internet**

As the public increasingly relies upon call centers and the web to do
business, FNS and State agencies should be prepared to provide D-SNAP
information using these tools. Although potential clients living in
disaster areas might have limited access to the web, experience has
shown that their friends and family outside of the disaster area will
seek information on their behalf.

FNS already provides via our toll-free SNAP information line
(800-221-5689) the telephone numbers for State SNAP hotlines. FNS also
posts on our national website State hotline numbers and web addresses
that provide regular SNAP information. FNS posts information in both
English and Spanish.

To ensure that clients are given the correct State contact information,
States should confirm the accuracy of their contact information with FNS
in advance of any expected disasters or after the disaster has occurred.
States should update their contact information with FNS should it change
during the disaster response. States should indicate to FNS whether or
not their toll-free hotlines can be accessed by out-of-state callers and
if not, should provide to FNS a version of the toll-free number that
might be accessed from out-of-state (containing a local area code), if
available.

+----------------------+--------------------------------+-------------+
| **Table 13.          |                                |             |
| Potential Partners** |                                |             |
+======================+================================+=============+
| **Community**        | **Suggestions for Contact**    | **Local     |
|                      |                                | Contacts**  |
+----------------------+--------------------------------+-------------+
| Rural/agricultural   | -   Community churches         |             |
|                      |                                |             |
|                      | -   Agriculture/extension      |             |
|                      |     offices                    |             |
|                      |                                |             |
|                      | -   Local papers/radio/TV      |             |
|                      |     stations                   |             |
|                      |                                |             |
|                      | -   Community partner's        |             |
|                      |     websites                   |             |
+----------------------+--------------------------------+-------------+
| Elderly & Disabled   | -   Advocate groups (e.g.      |             |
|                      |     AARP)                      |             |
|                      |                                |             |
|                      | -   Retirement/health care     |             |
|                      |     facilities                 |             |
|                      |                                |             |
|                      | -   Post materials in banks,   |             |
|                      |     stores                     |             |
|                      |                                |             |
|                      | -   Local papers/radio/TV      |             |
|                      |     stations                   |             |
|                      |                                |             |
|                      | -   Community partner's        |             |
|                      |     websites                   |             |
+----------------------+--------------------------------+-------------+
| Deaf and Hearing     | -   Advocate groups            |             |
| Impaired             |                                |             |
|                      | -   Colleges/universities for  |             |
|                      |     the deaf                   |             |
|                      |                                |             |
|                      | -   Targeted publications      |             |
|                      |                                |             |
|                      | -   Local papers and TV        |             |
|                      |     stations                   |             |
|                      |                                |             |
|                      | -   Community partner's        |             |
|                      |     websites                   |             |
+----------------------+--------------------------------+-------------+
| Non-English Speaking | -   Advocate/community groups  |             |
|                      |                                |             |
|                      | -   Local churches             |             |
|                      |                                |             |
|                      | -   Language-specific          |             |
|                      |     papers/radio/TV            |             |
|                      |                                |             |
|                      | -   Community partner's        |             |
|                      |     websites                   |             |
+----------------------+--------------------------------+-------------+

**Hard-to-Reach Populations**

Special efforts should be made to contact segments of the community that
may not be able to be reached through the mainstream media. State
agencies should consider setting up a TTY/TDD service to answer
questions from deaf or hard-of-hearing populations. This could be
coordinated with FEMA to provide easy, one-stop access to information
for the deaf community.

Arrange with television stations to provide close-captioned public
service announcements regarding disaster aid and the D-SNAP. Publicize
the TTY/TDD number during those announcements. The table below contains
ideas on how to reach some of those groups. Add any additional groups
and list specific contacts in the last column.

**Important: Lines of Authority**

Establish clear lines of authority that delineate who can speak to the
press, draft and clear press releases, and handle other aspects of
public relations at command centers and application/issuance sites. Make
sure all staff is aware of the lines of authority and who can speak to
the press. If FEMA has established a Joint Information Center (JIC),
determine the extent to which press releases, etc. must be coordinated
with this office.

**Interviews in Other Languages**

Designated public affairs contacts should be prepared to handle requests
for interviews in languages other than English.

**Public Information at the Application/Issuance Site**

States may wish to include application/issuance site leadership on their
public information, but should take care to develop a clear chain of
command between State level public information staff and
application/issuance site staff for initiating or responding to
opportunities to communicate with the media. Any of the following
actions could be undertaken at the application/issuance sites. Add any
ideas developed in pre-disaster planning.

+-----------------+----------------------------------------------------+
| **Table 14.     |                                                    |
| Onsite Public   |                                                    |
| Information     |                                                    |
| Strategies**    |                                                    |
+=================+====================================================+
| **Action**      | **Examples**                                       |
+-----------------+----------------------------------------------------+
| Serve as point  | -   Arrange news conferences to make major         |
| of contact for  |     announcements                                  |
| information on  |                                                    |
| the D-SNAP from | -   Prepare press releases and/or public service   |
| the disaster    |     announcements addressed to project area (e.g.  |
| area            |     location and hours of operation, parking and   |
|                 |     transportation, elderly and disabled           |
|                 |     provisions)                                    |
|                 |                                                    |
|                 | -   Distribute copies of food safety fliers. See   |
|                 |     copy in *Publications -- Application/Issuance  |
|                 |     Site* or                                       |
|                 |     <http://www.fsis.usda.gov/fact_she             |
|                 | ets/Severe_Storms_and_Hurricanes_Guide/index.asp>. |
|                 |                                                    |
|                 | -   Issue information on use of SNAP benefits (see |
|                 |     samples in *Publications --                    |
|                 |     Application/Issuance Site*)                    |
|                 |                                                    |
|                 | -   Coordinate/organize tours by government        |
|                 |     officials and the media                        |
|                 |                                                    |
|                 | -   Contact local advocate and community groups    |
|                 |     respond to questions/concerns from public,     |
|                 |     Congress, etc.                                 |
+-----------------+----------------------------------------------------+
| Issue press     | -   Ask for more volunteers to help with human     |
| releases or     |     comfort efforts, etc.                          |
| public service  |                                                    |
| announcements   | -   Request that elderly and disabled send         |
| that address    |     authorized representatives to apply for them   |
| specific        |     (included requirements for representation)     |
| issues/problems |     identify special provisions/locations for      |
| that have       |     elderly and disabled                           |
| developed at    |                                                    |
| the site        | ```{=html}                                         |
|                 | <!-- -->                                           |
|                 | ```                                                |
|                 | -   Reiterate any verification or eligibility      |
|                 |     requirements that appear to be causing         |
|                 |     problems at the site                           |
|                 |                                                    |
|                 | -   Notify public of extended hours/days of        |
|                 |     operation                                      |
+-----------------+----------------------------------------------------+
|                 |                                                    |
+-----------------+----------------------------------------------------+

[]{#OLE_LINK31 .anchor}Program Integrity and Fraud Prevention

Agencies must develop strategies to prevent fraud and ensure program
integrity from the start of the disaster response. Government agencies
and the public will be supportive of disaster response efforts, but will
still expect the State to operate a D-SNAP responsibly. Agencies must
find a balance between responding quickly to meet emergency food needs
and encouraging the eligible public to participate in the program and
protecting program integrity by ensuring that benefits only go to
eligible participants and that these eligible participants receive the
correct amount of benefits.

**Work with Partners**

Agencies should work with the USDA OIG and State or county/local
investigative staff from the start of the disaster response to ensure
that program integrity issues are addressed proactively. Working with
partners during all phases of the disaster response will also minimize
the likelihood that problems will need to be addressed through audits.

**[Required]{.mark} Application/Issuance Site Controls**

-   [Input information on *all* household members into the eligibility
    determination system to prevent persons from obtaining benefits as a
    member of more than one assistance unit.]{.mark}

-   [Input denied applications into the eligibility determination system
    each day, so that households that are denied and later reapply are
    detected and referred to fraud prevention staff.]{.mark}

-   [Check for duplicate participation using onsite or offsite computer
    databases or hardcopy participant lists. Update computer database or
    hardcopy participant lists every day.]{.mark}

-   Refer clients [without required]{.mark} verification or with
    inconsistent information to onsite investigators or
    highly-experienced staff for review.

**[Optional Application/Issuance Site Controls]{.mark}**

-   [To check household size, ask applicants at the start of screening
    interview for names and dates of births for all household members.
    Ask applicant to repeat information later.]{.mark}

-   Delay issuance of EBT cards to allow some verification and/or
    cross-checking, either for all applicants, or for those with
    questionable applications.

-   Issue temporary IDs to certified households.

**Provide Information to Applicants and Retailers**

The more information applicants have about eligibility and verification
requirements, the less likely they are to inadvertently provide
erroneous information. Distribute fliers or press releases or play
recorded messages at sites (in appropriate languages) with:

-   Program requirements

```{=html}
<!-- -->
```
-   Administrative, criminal, and civil penalties for fraud

-   Notice that anti-fraud measures are in place

-   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.

Communicate with retailers to let them know:

-   Whether temporary IDs will be issued or required

-   Of any relevant waivers (e.g., hot food waiver)

-   The estimated number of new SNAP clients

See *Publications -- Application/Issuance Site* for sample materials.

**Check for Duplicate Participation**

States must perform duplicate participation checks before determining
eligibility. States can use either a technology-based or paper
duplication participation check system. Some States employ simple
laptop-based databases or live access to the eligibility determination
system at each application/issuance site or at a command center where
information from several application/issuance sites is consolidated.
States without access to technology at their sites may choose to supply
hardcopy lists of current participants to sites on a daily basis,
although some States have found that use of hardcopy lists is cumbersome
at larger sites.

If applications are taken onsite, but "back room" operations are used
for application processing, duplicate participation can be checked prior
to confirming eligibility determination. Onsite, applicants can be
advised of potential eligibility, yet instructed that official
eligibility will be determined off site and that they will be notified
of their eligibility after it has been determined.

**Prevent Employee Fraud**

Take these special measures to prevent employee fraud:

[Required Measures]{.mark}

-   Use separation of duties for certification and issuance.

-   Use special authorization procedures and/or locations for employees
    applying for disaster benefits.

-   Audit all employee applications, and publicize that policy. FNS
    expects States to review all employee applications and to
    communicate that to employees up front. Although many employees may
    be legitimately eligible, they should still be made aware of the
    review process.

[Optional Measures]{.mark}

-   Inventory office equipment/supplies and compare at close-out.

**Monitor Efforts**

Specific fraud prevention measures should be monitored by Regional
Office and State agency staff and modified as appropriate.

[]{#OLE_LINK15 .anchor}Security

**Introduction**

State agencies should prepare for security functions essential for
D-SNAP operation. State agencies should contact local law enforcement
authorities during the D-SNAP planning process for help in determining
the level of security services needed and to form agreements on what
kind of services local law enforcement can provide. State agencies may
need to supplement security from local law enforcement with help from
private security firms and may need to make agreements with private
security firms in advance, as well.

**Application/Issuance Site Security**

Security at the application/issuance site is crucial. The State agency
should discuss with local law enforcement authorities during the D-SNAP
planning process how to design and locate sites to reduce crowd control
and other security problems, determine the level of security needs for
application/issuance sites, and make agreements for onsite security
services. Contact private security firms to arrange for private security
guards for application/issuance sites, if needed.

  ------------------------- ---------------- -------------- --------------
  **Table 15. Public or                                     
  Private Security                                          
  Contacts**                                                

  **Entity**                **Contact**      **Phone        **Security
                                             Number**       Needs**

                                                            

                                                            

                                                            
  ------------------------- ---------------- -------------- --------------

**EBT Card Security**

States must ensure the security of EBT cards during storage,
transportation, and issuance. States should arrange security for:

-   Any stock of pre-made, disaster EBT cards stored in a permanent
    facility inside or outside of the State.

-   Transportation of cards from permanent storage facilities to
    temporary storage and distribution sites and vice versa.

-   Storage of cards held at temporary storage and distribution sites.

-   EBT handling at application/issuance sites.

FNS recommends the following EBT card security measures at
application/issuance sites:

-   Develop the application/issuance site lay out and traffic flow to
    minimize the movement of EBT cards

-   Keep EBT cards out of sight of applicants

-   Keep EBT card shipment boxes and trays closed prior to actual need

-   Store cards in vaults or safes on site (arrange overnight security)

-   Remove EBT cards from site by secure carrier each night

FNS recommends maintaining a list of possible EBT card storage sites,
complete with an evaluation of security needs.

  ------------------------- ---------------- -------------- --------------
  **Table 16. Secure                                        
  Storage sites for EBT                                     
  Cards**                                                   

  **Entity**                **Contact**      **Phone        **Security
                                             Number**       Needs**

                                                            

                                                            

                                                            
  ------------------------- ---------------- -------------- --------------

FNS Recommends maintaining a list of secure carriers contacts for EBT
card transportation.

  ------------------------- ---------------- -------------- --------------
  **Table 17. Secure                                        
  Carriers for EBT Cards**                                  

  **Entity**                **Contact**      **Phone        **Security
                                             Number**       Needs**

                                                            

                                                            

                                                            
  ------------------------- ---------------- -------------- --------------

[]{#OLE_LINK14 .anchor}Staffing

**Anticipating Staffing Levels**

To the extent possible, an agency should identify in advance of a
disaster the staff it will need to operate a D-SNAP. States should plan
not only for the staff needed at D-SNAP sites, but also for increased
staffing at all work areas that support the D-SNAP off site, such as at
EBT or general State call centers or at case processing centers off
site.

States should anticipate that staff residing in areas affected by the
disaster will need time away 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 inadequate county/local staff is available
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 rules as those
of permanent staff.]{.mark}

Table 18, which begins on the following page, identifies 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 higher technology for any portion of
the process should expect significant changes to staffing needs. States
planning to use volunteers should familiarize themselves with any State
or local regulations surrounding the use of volunteers and liability.

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.

+-------------+----------------------------+-------------+------------+
| **Table 18. |                            |             |            |
| Staffing    |                            |             |            |
| Su          |                            |             |            |
| ggestions** |                            |             |            |
+=============+============================+=============+============+
| **Staff**   | **Duties**                 | **Possible  | **Staffing |
|             |                            | Sources**   | Levels**   |
+-------------+----------------------------+-------------+------------+
| Site        | Overall responsibility for | -   C       | One per    |
| Manager     | setting up site, running   | ounty/local | site       |
|             | day-to-day operations, and |     staff   |            |
|             | shutting down site at      |     in      |            |
|             | conclusion of D-SNAP.      |             |            |
|             |                            |    affected |            |
|             |                            |     and     |            |
|             |                            |     n       |            |
|             |                            | on-affected |            |
|             |                            |     areas   |            |
|             |                            |             |            |
|             |                            | -   State   |            |
|             |                            |     agency  |            |
|             |                            |     staff   |            |
|             |                            |             |            |
|             |                            | -   FNS     |            |
|             |                            |             |            |
|             |                            |    Regional |            |
|             |                            |     and     |            |
|             |                            |     Field   |            |
|             |                            |     Office  |            |
|             |                            |     staff   |            |
|             |                            |             |            |
|             |                            | -   Staff   |            |
|             |                            |     from    |            |
|             |                            |     other   |            |
|             |                            |     states  |            |
+-------------+----------------------------+-------------+------------+
| Assistant   | Assists site manager,      |             | One for    |
|             | which may include handling |             | smaller    |
| Site        | communications, reporting, |             | sites,     |
| Manager     | coordination of daily      |             | additional |
|             | activities, or other       |             | for larger |
|             | duties as planned or       |             | sites      |
|             | needed.                    |             |            |
+-------------+----------------------------+-------------+------------+
| Supervisors | Supervise eligibility,     |             | One per 10 |
|             | fraud prevention,          |             | e          |
|             | issuance, or other staff.  |             | ligibility |
|             |                            |             | workers    |
+-------------+----------------------------+-------------+------------+
| Eligibility | Eligibility/certification  |             | Expect     |
| Workers     | process                    |             | e          |
|             |                            |             | ligibility |
|             |                            |             | workers to |
|             |                            |             | intake 6   |
|             |                            |             | applicants |
|             |                            |             | per hour.  |
+-------------+----------------------------+-------------+------------+
| Bi-lingual  | Interviews non-English     |             | Expect     |
| Eligibility | speaking applicants.       |             | e          |
| Workers     |                            |             | ligibility |
|             |                            |             | workers to |
|             |                            |             | intake 6   |
|             |                            |             | applicants |
|             |                            |             | per hour.  |
+-------------+----------------------------+-------------+------------+
| Issuance    | Issue EBT cards to clients |             | One        |
| Worker      | onsite or otherwise        |             | issuance   |
|             | prepare client case for    |             | clerk for  |
|             | issuance.                  |             | every 9-10 |
|             |                            |             | e          |
|             |                            |             | ligibility |
|             |                            |             | workers    |
+-------------+----------------------------+-------------+------------+
| Application | Screens applications for   |             | One        |
| Screener    | potential eligibility. May |             | screener   |
|             | perform checks for         |             | for every  |
|             | existing FS case, SSNs, or |             | 2-3        |
|             | receipt of other benefits  |             | e          |
|             | as technology allows.      |             | ligibility |
|             |                            |             | workers    |
+-------------+----------------------------+-------------+------------+
| Fraud       | Evaluates applications     |             | As needed  |
|             | flagged by eligibility     |             |            |
| Prevention  | worker for suspicious      |             |            |
| Staff       | content.                   |             |            |
+-------------+----------------------------+-------------+------------+
| Shipper     | Prepares boxes of          |             | One for    |
|             | applications or other      |             | smal       |
|             | materials for shipping to  |             | ler/medium |
|             | State or county/local      |             | sites      |
|             | offices, if needed.        |             | (with      |
|             |                            |             | back-up)   |
|             |                            |             | and two    |
|             |                            |             | for larger |
|             |                            |             | site       |
+-------------+----------------------------+-------------+------------+
| Offsite     | Key enters information     |             | Depends on |
| Key-entry   | from paper applications    |             | volume of  |
| worker      | into the State's           |             | paper      |
|             | eligibility system         |             | ap         |
|             | offsite, when technology   |             | plications |
|             | is not available at the    |             |            |
|             | D-SNAP site.               |             |            |
+-------------+----------------------------+-------------+------------+
| Tro         | Helps applicants in line   |             | One per    |
| ubleshooter | by identifying language or |             | ten        |
|             | other problems and         |             | e          |
|             | answering basic questions. |             | ligibility |
|             | Alerts management to       |             | workers    |
|             | issues requiring their     |             |            |
|             | intervention.              |             |            |
+-------------+----------------------------+-------------+------------+
| On-site     | Conduct on-site reviews    | -           | 1 or 2 per |
| reviewer    |                            | Eligibility | site,      |
|             |                            |     worker  | depending  |
|             |                            |             | on number  |
|             |                            | Supervisors | of         |
|             |                            |             | applicants |
|             |                            | -   State   |            |
|             |                            |             |            |
|             |                            |   reviewing |            |
|             |                            |             |            |
|             |                            |   officials |            |
+-------------+----------------------------+-------------+------------+
| Call center | Respond to calls from      | -   Current | Depends    |
| specialists | applicants or recipients   |     call    | upon       |
|             | at State or county/local   |     center  | a          |
|             | social services general    |             | nticipated |
|             | information call centers   | specialists | call       |
|             | or at EBT helpdesk call    |             | volume     |
|             | centers                    | -           |            |
|             |                            |   Temporary |            |
|             |                            |     hires   |            |
+-------------+----------------------------+-------------+------------+
| Volunteers  | *Human comfort*            | -           |            |
|             |                            |   Community |            |
|             | Assist elderly or disabled |     or      |            |
|             | and distribute water and   | ganizations |            |
|             | food.                      |             |            |
|             |                            | -   Local   |            |
|             |                            |     ethnic  |            |
|             |                            |     groups  |            |
|             |                            |             |            |
|             |                            | -           |            |
|             |                            |    Churches |            |
+-------------+----------------------------+-------------+------------+
|             | *Translating/interpreting* |             |            |
|             |                            |             |            |
|             | Helps interpret during the |             |            |
|             | application process.       |             |            |
|             | Translate materials that   |             |            |
|             | have not been prepared in  |             |            |
|             | advance of the disaster.   |             |            |
+-------------+----------------------------+-------------+------------+
|             | *Application Assistant*    |             |            |
|             |                            |             |            |
|             | Handout applications, pens |             |            |
|             | and clipboards to          |             |            |
|             | applicants. Help clients   |             |            |
|             | with difficulty completing |             |            |
|             | the application.           |             |            |
+-------------+----------------------------+-------------+------------+
|             | *Greeter*                  |             |            |
|             |                            |             |            |
|             | Greets applicants at site  |             |            |
|             | entrance and directs       |             |            |
|             | applicants to appropriate  |             |            |
|             | area. Alerts human comfort |             |            |
|             | staff of clients needing   |             |            |
|             | special assistance.        |             |            |
+-------------+----------------------------+-------------+------------+
|             | *Screener*                 |             |            |
|             |                            |             |            |
|             | Perform pre-screening that |             |            |
|             | does not involve access to |             |            |
|             | the State eligibility      |             |            |
|             | system or to client case   |             |            |
|             | information.               |             |            |
+-------------+----------------------------+-------------+------------+
| Medical     | Minor medical treatment    | -   Red     | A medical  |
| Staff       |                            |     Cross   | team or    |
|             |                            |             | ambulance  |
|             |                            | > Hospitals | has        |
|             |                            | >           | sometimes  |
|             |                            | > Health    | been able  |
|             |                            | > care      | to remain  |
|             |                            | > or        | on-site.   |
|             |                            | ganizations |            |
|             |                            | >           |            |
|             |                            | > Public    |            |
|             |                            | > health    |            |
|             |                            | > offices   |            |
+-------------+----------------------------+-------------+------------+
| Security    | Ensure public safety and   | -   Local   | As         |
| Personnel   | crowd control at           |     law     | a          |
|             | application/issuance       |             | ppropriate |
|             | sites. Provide security    | enforcement | to size of |
|             | for EBT cards at           |             | site,      |
|             | application/issuance       | -   Private | number of  |
|             | sites, at storage          |             | a          |
|             | facilities, and/or in      |    security | pplicants, |
|             | transit.                   |     firms   | and        |
|             |                            |             | presence   |
|             |                            |             | of EBT     |
|             |                            |             | cards      |
+-------------+----------------------------+-------------+------------+
|             |                            |             |            |
+-------------+----------------------------+-------------+------------+

Training

[]{#ole_link93 .anchor}

States should provide introductory and ongoing training on disaster
eligibility, application, and issuance procedures to relevant
county/local and State staff. County or local eligibility staff that
will work the D-SNAP site should be given introductory or refresher
training before beginning to work at D-SNAP sites.

**Content of Training**

States should consider covering the following information on in their
D-SNAP training. Fill in any additional information to be included in
disaster training as determined during pre-disaster planning.

+--------------------------------------------+-------------------------+
| **Table 19. Training Content**             |                         |
+============================================+=========================+
| **Content**                                | **Location in           |
|                                            | Guidance**              |
+--------------------------------------------+-------------------------+
| Overview of the D-SNAP certification       | See Chapter 1:          |
| process                                    | [Comparing the D-SNAP   |
|                                            | and the                 |
|                                            | SNAP](#OLE_LINK103)     |
+--------------------------------------------+-------------------------+
| Roles and responsibilities for each        |                         |
| position (screener, eligibility worker,    |                         |
| supervisor, etc) and lines of supervision  |                         |
+--------------------------------------------+-------------------------+
| Eligibility, including:                    | See Chapter 3:          |
|                                            | [Eligibility            |
| -   Eligibility criteria                   | Criteria](#OLE_LINK59)  |
|                                            | and [Income and         |
| -   Calculating eligibility                | Resource                |
|                                            | Test](#OLE_LINK60) and  |
| -   Approved D-SNAP waivers that affect    | *Publications --        |
|     eligibility                            | Certification Process*  |
+--------------------------------------------+-------------------------+
| Verification requirements and acceptable   | See Chapter 3:          |
| documentation                              | [Ver                    |
|                                            | ification](#OLE_LINK61) |
|                                            | and *Publications --    |
|                                            | Certification Process*  |
+--------------------------------------------+-------------------------+
| Applicant applications and other forms     | See *Publications -     |
|                                            | Certification Process*  |
+--------------------------------------------+-------------------------+
| Issuance of Benefits, including:           | See Chapter 3:          |
|                                            | [Iss                    |
| -   Use of allotment tables, if applicable | uance/EBT](#OLE_LINK16) |
|                                            |                         |
| -   Any onsite card/PIN issuance           |                         |
|     activities, if applicable              |                         |
|                                            |                         |
| -   Client training on card usage, lost    |                         |
|     card replacement, PIN changes, etc.    |                         |
+--------------------------------------------+-------------------------+
| Use of automation                          |                         |
+--------------------------------------------+-------------------------+
| Fraud Prevention, including:               | See Chapter 3:          |
|                                            | [Coordinating Fraud     |
| -   Formal fraud control measures in place | Prevention              |
|                                            | Efforts](#OLE_LINK43)   |
| -   Duplicate participation checks         | and [Program            |
|                                            | Integrity/Fraud         |
| -   Special procedures for employee        | P                       |
|     applications, including that 100       | revention](#OLE_LINK31) |
|     percent reviews will be conducted of   |                         |
|     employee applications                  |                         |
+--------------------------------------------+-------------------------+
| Public information:                        | See Chapter 3: [Public  |
|                                            | Information and         |
| -   Who is authorized to issue statements  | Outreach](#OLE_LINK30)  |
|     to the media                           | and [Coordinating       |
|                                            | Public                  |
|                                            | Relations](#OLE_LINK44) |
+--------------------------------------------+-------------------------+
| Personnel matters                          |                         |
|                                            |                         |
| -   Transportation to sites                |                         |
|                                            |                         |
| -   Hours                                  |                         |
|                                            |                         |
| -   Breaks                                 |                         |
|                                            |                         |
| -   Pay                                    |                         |
|                                            |                         |
| -   Safety                                 |                         |
|                                            |                         |
| -   Stress management                      |                         |
|                                            |                         |
| -   Communication with disaster victims    |                         |
+--------------------------------------------+-------------------------+

**[Staff Comfort and Health]{.mark}**

If possible, staff should be provided with:

-   Private break rooms

-   Separate bathroom facilities.

-   [Temporary housing (for out-of-town staff)]{.mark}

-   Water

-   Meals, such as:

```{=html}
<!-- -->
```
-   Canteen service provided by the Red Cross on-site

-   Bag lunches prepared and delivered by community or church groups

-   Pre-packaged military meals (MRE\'s) [or heater meals]{.mark}
    purchased by site manager

-   Meals provided by contracted service providers

-   Bag lunches brought by staff and kept in designated coolers or
    refrigerators.

[State agencies might wish to consider reducing risk of injury and
disease to staff by:]{.mark}

-   [Ensuring that staff have received tetanus immunizations (when
    environmental conditions are still poor)]{.mark}

-   [Providing to front-line staff antibacterial lotions or
    wipes]{.mark}

-   [Making available on-site first aid]{.mark}

**Orientation Guide**

A disaster orientation guide is extremely helpful to all staff during a
disaster operation. If possible, a guide or packet can be prepared which
includes some or all of the following:

-   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 supervision

-   Time sheets

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

-   List of contacts, their hotels, and phone numbers

-   Safety information (e.g., water use, aftershock precautions)

-   Fliers on preventing stress (see
    <http://mentalhealth.samhsa.gov/publications/allpubs/KEN-01-0098/>)

**Coordinating Staffing Issues at a Command Center**

See Chapter 3, [Coordinating Staff Issues](#OLE_LINK45).

[]{#OLE_LINK32 .anchor}Funding Issues

**General Rule**

As with the regular SNAP, FNS will provide reimbursement of 50 percent
of State administrative costs to operate a D-SNAP. As FNS cannot provide
reimbursement for State expenditures made with funds that are Federal in
origin, States will not be able to use any Federal funds received from
FEMA to use to obtain FNS matching funds. Additionally, FEMA does not
provide funds for the sole purpose of operating a D-SNAP.

**What Will FEMA Provide?**

-   FEMA will pay for extra expenses incurred by FNS in performance of
    its ESF-11 mission assignment (e.g. overtime for Disaster Field
    Office staff).

-   FEMA *may* 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/issuance 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. Whether 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.

**Important**

All issues, especially possible co-location of D-SNAP
application/issuance sites and FEMA DRC\'s, should be negotiated with
FEMA, through appropriate channels, as early as possible in the disaster
response.

**Section 2. Developing the Appropriate Disaster Response**

[]{#OLE_LINK33 .anchor}Overview

The first element of the disaster response is to determine whether a
D-SNAP should be run, and if so, to develop the specifics of the
program. Each State agency is responsible for determining whether or not
to operate a D-SNAP and designing a D-SNAP response that is appropriate
to the disaster at hand. There are three things that must be done during
this phase:

-   Analyze the damage

-   Evaluate response options and strategies

-   Negotiate and solidify the details of the D-SNAP through the D-SNAP
    application process.

**Timing Varies With Disaster**

The relative timing of the three tasks will vary depending on all the
circumstances of a disaster, including:

-   Whether there was any notice that the disaster would strike

-   The severity, scope and type of damage

-   The extent of the State agency\'s experience operating a D-SNAP.

[]{#OLE_LINK34 .anchor}Disaster Assistance Response Team (DART)

**Background**

FNS has collected a wealth of information and experience concerning
D-SNAP response through years of assisting States through a large number
and variety of disasters. Agencies need access to the lessons learned in
other disasters, but cannot completely plan ahead because of the
unexpected and diverse nature of disasters. To address these realities
FNS headquarters [can activate]{.mark} a Disaster Assistance Response
Team (DART) composed of FNS National Office [and Regional Office
staff]{.mark} in response to *major* disasters to provide guidance to
State agencies by phone, fax, and/or email, and as deemed necessary by
FNS, through on-site assistance.

**Objectives**

The DART\'s objectives are to provide the following services:

-   Educate State and Regional office staff about available options

-   Help the State agency evaluate all program options

-   Help negotiate the details of the D-SNAP, if requested or needed.

[]{#OLE_LINK35 .anchor}Damage Needs Analysis

**Analysis is Critical**

A comprehensive, in-depth analysis of a disaster situation is critical
to determining the appropriate response necessary by FNS. The damage
needs analysis provides the basis of the D-SNAP request. States and
regional FNS offices rely heavily on the hard data provided in the needs
analysis to justify the type and scope of the disaster response to the
general public, advocate groups, and government officials. FEMA, in
concert with State and county/local government, will conduct a
Preliminary Damage Assessment (PDA) for the purpose of determining
eligibility for a major disaster declaration. State agencies should use
FEMA's PDA as the basis for their community food assistance needs
analysis.

**Damage Needs Analysis Team**

Regional and State officials may wish to assemble a Damage Needs
Analysis Team of staff who are familiar with the geographical area or
have experience with disasters or needs analysis. FNS field office
personnel and county/local public assistance office employees are an
excellent resource at this stage because they are often the first at the
scene and familiar with the locale.

The Damage Needs Analysis Team's work is a partnership between State,
county/local and Federal staff. It should contribute to the development
of trust and cooperation necessary to serve those in need in a timely
and appropriate manner.

**Objectives**

The objectives of the Damage Needs Analysis Team will be to:

-   Gather data on the extent and kinds of damage. This should include:

    -   FEMA's PDA

    -   Data on the availability of commercial channels of food
        distribution

    -   Demographic data for the affected areas.

-   Work up an analysis of the appropriateness of providing a D-SNAP or
    other food assistance to affected households, which should include
    suggestions for limiting the project area to the smallest area that
    can serve those in need of disaster assistance.

[]{#OLE_LINK83 .anchor}**Commercial Channels of Food Distribution**

**Note:** *Proof of disruption of commercial food channels is not
required for Stafford Act declarations, but is required for Food and
Nutrition Act declarations. However, Food and Nutrition Act declarations
will be used only in extraordinary circumstances.*

The presence of any of the factors below indicates that commercial
channels of food distribution were disrupted.

-   Limited access to retail food outlets because of damage to roads,
    bridges, or mass transit within the disaster area

-   Delivery of supplies to food outlets were significantly hampered

-   Retail food outlets forced to close for a significant period of time

-   Normal operating hours of food outlets reduced to the extent that a
    household\'s ability to purchase food was significantly reduced

-   Reduced supplies of food outlets causes significant reduction in
    household\'s opportunity to purchase food

-   Power failure occurred which severely restricted the operation of
    food outlets for a significant period of time

Commercial channels of food distribution are considered to have been
restored when conditions have improved to the extent that households
have reasonable access to food outlets with sufficient food supplies.

**Considerations**

The Damage Needs Analysis Team should take into account some or all of
the following considerations while conducting the needs analysis.

  ------------------------------ ----------------------------------------
  **Table 20. Damage Needs       
  Analysis Considerations**      

  **Consider**                   **Damage report recommendations**

  Level of response needed       Which feeding programs are appropriate
                                 in each area (mass feeding, household
                                 food distribution, D-SNAP).

  Number of people in need in    Location and number of potential
  particular areas               certification sites.

  Defining the geographic area   Alternative ways to define disaster
  to be served by the D-SNAP     areas (e.g., by power grid location, by
                                 neighborhood, by town, by county).
  ------------------------------ ----------------------------------------

**Needs Analysis Procedures**

The Damage Needs Analysis Team will conduct an analysis of need for a
D-SNAP. The team(s) should use whatever of the information in the chart
below is appropriate to develop their analysis. A copy is included in
*Publications -- Developing the Response* for use as a checklist.

+--------+----------------------------------+-------------------------+
| *      |                                  |                         |
| *Table |                                  |                         |
| 21.    |                                  |                         |
| Damage |                                  |                         |
| Needs  |                                  |                         |
| An     |                                  |                         |
| alysis |                                  |                         |
| Check  |                                  |                         |
| list** |                                  |                         |
+========+==================================+=========================+
| **(    | **Possible Sources**             |                         |
| )Infor |                                  |                         |
| mation |                                  |                         |
| to     |                                  |                         |
| Eval   |                                  |                         |
| uate** |                                  |                         |
+--------+----------------------------------+-------------------------+
|        | Availability of State agency     | -   County/local staff  |
|        | assets, such as computer systems |                         |
|        | and county/local offices.        |                         |
+--------+----------------------------------+-------------------------+
|        | Other damage assessments         | FEMA\'s ESFs            |
|        |                                  |                         |
|        |                                  | American Red Cross      |
|        |                                  |                         |
|        |                                  | State Emergency         |
|        |                                  | Management              |
|        |                                  |                         |
|        |                                  | Highway Patrol/National |
|        |                                  | Guard                   |
|        |                                  |                         |
|        |                                  | Insurance companies     |
+--------+----------------------------------+-------------------------+
|        | Availability of authorized       | -   FNS field office    |
|        | grocery stores in area           |     staff               |
|        |                                  |                         |
|        |                                  | -   [FNS Benefit        |
|        |                                  |     Redemption          |
|        |                                  |     Division]{.mark}    |
|        |                                  |                         |
|        |                                  | -   County/local public |
|        |                                  |     assistance office   |
|        |                                  |     staff               |
|        |                                  |                         |
|        |                                  | -   Grocery store       |
|        |                                  |     headquarters        |
|        |                                  |                         |
|        |                                  | -   EBT services        |
|        |                                  |     provider            |
+--------+----------------------------------+-------------------------+
|        | Location and expected duration   | -   Power companies     |
|        | of power outages. *State should  |                         |
|        | discuss data needs in advance    | -   State Emergency     |
|        | with power companies.* *States   |     Management          |
|        | with multiple power providers,   |                         |
|        | especially, must be prepared to  |                         |
|        | work with various sources to     |                         |
|        | establish expectations on the    |                         |
|        | quantity, quality, and           |                         |
|        | timeliness of requested data.*   |                         |
+--------+----------------------------------+-------------------------+
|        | Media reports                    | -   Television news,    |
|        |                                  |     internet, or radio  |
+--------+----------------------------------+-------------------------+
|        | Extent of disaster\'s effects,   | Advocate groups         |
|        | especially on food needs, on     |                         |
|        | particular groups.               | Local ethnic groups     |
|        |                                  |                         |
|        |                                  | Churches                |
+--------+----------------------------------+-------------------------+
|        | Population and demographic       | State agency            |
|        | statistics on:                   |                         |
|        |                                  | FEMA                    |
|        | Income levels (including FS/TANF |                         |
|        | participation)                   | Material from           |
|        |                                  | pre-disaster planning   |
|        | Percentages of infant and        |                         |
|        | elderly populations              |                         |
|        |                                  |                         |
|        | Primary languages spoken         |                         |
+--------+----------------------------------+-------------------------+
|        | ZIP code and topographical maps  | Post office             |
|        | of the expanded area             |                         |
|        |                                  | State agency            |
|        |                                  |                         |
|        |                                  | State/local fire        |
|        |                                  | dept/office             |
+--------+----------------------------------+-------------------------+
|        | Maps showing areas affected and  | -   FEMA                |
|        | intensity                        |                         |
+--------+----------------------------------+-------------------------+
|        | FEMA aerial assessments          | -   FEMA                |
+--------+----------------------------------+-------------------------+

**Important: Floods**

The full extent and nature of damage from flooding cannot be assessed
until flood waters have crested and receded. Because the decision to
operate a D-SNAP may have to be made before this, some provisions of the
D-SNAP may have to be modified to reflect the true nature and extent of
damage revealed by receding flood waters. For information on modifying,
extending, or expanding D-SNAP operations see [Requests to Modify,
Extend, or Expand the D-SNAP](#OLE_LINK39).

[]{#OLE_LINK36 .anchor}Evaluating Disaster Response Options

**What Food Assistance Programs?**

The D-SNAP will not be appropriate for every disaster. FNS assists
disaster victims with food in three ways:

-   Provides food for shelters and other mass feeding sites.

-   Provides food for distribution directly to households in need in
    certain limited circumstances.

-   Provides disaster SNAP benefits.

States must decide which program(s) is needed in the affected areas.
Some important factors in deciding which program to operate include:
whether or not households can prepare food at home (intact cooking
facilities and access to power), whether or not commercial retailers are
operating, and the size and population density of the affected area.

**Availability of Commodities**

Even if a disaster does not disrupt the retail food system and the SNAP
is operating, FNS may be asked to donate USDA commodities for congregate
feeding. The agency that distributes commodities in each State is
responsible for oversight of the distribution of commodities to disaster
organizations and their use. Commodities are mainly used for congregate
feeding. Less commonly, they are issued to households for preparation
and consumption at home. For more information, see the *FNS Commodity
Program Disaster Manual* which can be found at
<http://www.fns.usda.gov/fdd/programs/fd-disasters/CommodityDisasterManual.pdf>
on the FNS Food Distribution Program website.

+----------------------------------+-----------------------------------+
| > **Table 22. Evaluating Food    |                                   |
| > Aid Options**                  |                                   |
+----------------------------------+-----------------------------------+
| > **If\...**                     | > **Then\...**                    |
+----------------------------------+-----------------------------------+
| -   Commercial retail operations | > A household commodity           |
|     **are not** yet available,   | > distribution program may be an  |
|     and                          | > interim measure until retailers |
|                                  | > are operational and the D-SNAP  |
| -   Households **can** prepare   | > is operational.                 |
|     food at home                 |                                   |
+----------------------------------+-----------------------------------+
| -   Commercial retail operations | > Congregate feeding may meet the |
|     **are not** yet available,   | > needs of the community until    |
|     and                          | > retailers are operational and   |
|                                  | > they can prepare food at home.  |
| -   Households **cannot**        |                                   |
|     prepare food at home         |                                   |
+----------------------------------+-----------------------------------+
| -   Commercial retail operations | > A D-SNAP or modified SNAP       |
|     **are** available, and       | > should be operated.             |
|                                  |                                   |
| -   Households **can** prepare   |                                   |
|     food at home                 |                                   |
+----------------------------------+-----------------------------------+
| -   Commercial retail operations | > Congregate feeding may meet the |
|     **are** available, and       | > needs of the community until    |
|                                  | > they can prepare food at home.  |
| -   Households **cannot**        |                                   |
|     prepare food at home         |                                   |
+----------------------------------+-----------------------------------+
| -   There is a fairly small,     | > A household commodity           |
|     isolated affected            | > distribution program may be an  |
|     population, and              | > option for a small, isolated    |
|                                  | > area.                           |
| -   That population\'s food      |                                   |
|     needs are not being          |                                   |
|     completely met by congregate |                                   |
|     feeding                      |                                   |
+----------------------------------+-----------------------------------+
| -   The disaster has affected    | > A D-SNAP could be operated in   |
|     both densely and sparsely    | > the densely populated areas,    |
|     populated areas, **and**     | > and a household food            |
|                                  | > distribution program could be   |
| -   Commercial channels of food  | > considered where commercial     |
|     distribution are available   | > channels of food are not yet    |
|     in **only** the              | > available.                      |
|     densely-populated areas,     |                                   |
|     **and**                      |                                   |
|                                  |                                   |
| -   The food needs of the        |                                   |
|     sparsely-populated area are  |                                   |
|     not being completely met by  |                                   |
|     congregate feeding           |                                   |
+----------------------------------+-----------------------------------+

**Modified versus Disaster SNAP**

A full-blown D-SNAP [may]{.mark} not be appropriate for every disaster.
In some disasters, an agency may want to operate the regular SNAP with
waivers of some regulatory provisions. A list of waivers that have been
approved in past disasters is included in *Publications -- Waivers*.

States should not request a modified SNAP with so many waivers that it
approximates a D-SNAP. If a State wishes to employ the full or
nearly-full range of disaster-related waivers, they should simply
request a D-SNAP. States should consult FNS if they are uncertain
whether or not a D-SNAP or modified SNAP best suits the situation at
hand.

Additionally, FNS urges States to develop template D-SNAP or waiver
proposals for disasters common to their State well before disasters
strike, as evaluating disaster options and crafting proposals is
extremely challenging in the immediate aftermath of a disaster.

There are four main issues that differentiate the D-SNAP from the
regular SNAP that MUST be evaluated to determine whether the regular
program can be modified to appropriately respond to the needs of
disaster victims:

1.  ***D-SNAP Eligibility & Verification Criteria***

> Under the D-SNAP, eligibility criteria are relaxed so that applicants
> who might not otherwise qualify for the regular program can receive
> disaster benefits. Verification rules are also eased to reduce
> administrative burdens and to reflect the reality that households and
> eligibility workers will not have access to usual verification
> sources. Specifically:

-   Maximum deductions are used (also eases administrative burden)

-   Only accessible liquid resources counted (e.g. bank accounts)

-   Verification of applicant\'s identity is the only mandatory element

-   Deduction for disaster-related expenses (that are not expected to be
    reimbursed during the 30-day disaster benefit period) is allowed.

2.  ***D-SNAP Amount of Benefits***

> Under the D-SNAP, an eligible household *always* receives the maximum
> allotment for the household size. The maximum allotment is not only
> more efficient administratively, but it more accurately reflects a
> household\'s needs during the aftermath of a disaster (e.g., staple
> food and spices may need replacing, and food prices may be temporarily
> higher).
>
> States operating a Modified SNAP will use normal SNAP budgeting
> procedures, which may result in households receiving less than the
> maximum allotment.

3.  ***D-SNAP Time between Application and Receipt***

> Under the D-SNAP, eligible applicants must receive their benefits
> either immediately after certification, or if delayed issuance is
> approved, within [3 calendar days of filing their application.]{.mark}
>
> It is VERY important to clients in the immediate aftermath of a
> disaster to get benefits quickly. Under the regular program, clients
> may not receive benefits for 30 days. Even if expedited service is
> used, the eligibility workers may not be able to process new
> applicants so quickly using the regular program\'s eligibility and
> verification requirements.

4.  ***D-SNAP Potential Pool of Applicants***

> Under the D-SNAP, the potential pool of applicants is expanded. An
> applicant\'s status as any of the following is not relevant to his or
> her eligibility for the D-SNAP:

-   Student

-   Striker

-   Citizen or alien

-   Work program participant

-   Someone disqualified under the regular program.

> If the rules regarding one group are waived in a particular disaster
> (so that that group is temporarily eligible for disaster benefits),
> make sure the remaining \"excluded\" groups do not appear to be
> singled out.

**Factors to Evaluate Options**

Use the table below to help decide whether a D-SNAP or a regular program
with waivers would be appropriate.

  -----------------------------------------------------------------------
  **Table 23. Disaster versus Modified    
  SNAP**                                  
  --------------------------------------- -------------------------------
  **Factors to Suggest D-SNAP**           **Factors to Suggest Regular
                                          Program with Waivers**

  Damage is so severe or widespread that  Affected population small
  regular application procedures would be enough so that local offices
  too cumbersome                          can respond to needs

  Affected populations need benefit of    Affected population mostly the
  less strict D-SNAP eligibility criteria same population that is already
  and/or access to benefits more quickly  eligible for SNAP benefits
  than regular program can provide        

  Nature of disaster is such that many    No impact on access to
  households will not have verification   documents
  required by regular program             

  Number of waivers that would be         Only minor or very few
  required in order to adequately address modifications needed to regular
  victims\' needs would be confusing and  program in order to adequately
  administratively difficult to implement meet victims\' needs
  -----------------------------------------------------------------------

[]{#OLE_LINK37 .anchor}Developing the Terms of the D-SNAP

**Evaluate D-SNAP Options**

After it is determined that a D-SNAP is appropriate, the DART can help
State and Regional officials evaluate program options for the D-SNAP.

The table below includes the major elements to be decided, program
options, and some determining factors. Add any options identified in
pre-disaster planning. See *Publications -- Developing the Response* for
a copy of the table.

+---------+--------------------------+---------------------------------+
| []{#OLE |                          |                                 |
| _LINK97 |                          |                                 |
| .       |                          |                                 |
| anchor} |                          |                                 |
| **Table |                          |                                 |
| 24.     |                          |                                 |
| Program |                          |                                 |
| Op      |                          |                                 |
| tions** |                          |                                 |
+=========+==========================+=================================+
| **      | **Program Options**      | **Relevant Factors**            |
| Issue** |                          |                                 |
+---------+--------------------------+---------------------------------+
| Time    | Suggested length: 5 to 7 | -   Number of potential         |
| for     | days.                    |     applicants                  |
| ac      |                          |                                 |
| cepting | **Note:** it is better   | -   Potential for fraud         |
| appli   | to start with fewer days |                                 |
| cations | and extend the D-SNAP if |                                 |
|         | necessary.               |                                 |
+---------+--------------------------+---------------------------------+
| Re      | May restrict eligibility | -   Number of potential         |
| sidency | to households who lived  |     applicants                  |
|         | in the disaster area at  |                                 |
|         | the time of the disaster | -   [If area hit was major      |
|         | or can extend            |     employment center for       |
|         | eligibility to those who |     surrounding communities     |
|         | worked in the disaster   |     (suburban residents who     |
|         | area at the time of the  |     lost work in urban area may |
|         | disaster.                |     need assistance)]{.mark}    |
|         |                          |                                 |
|         |                          | []{.mark}                       |
+---------+--------------------------+---------------------------------+
| Food    | Allow food loss as a     | -   State agencies are in the   |
| Loss    | sole criterion for       |     best position to decide on  |
|         | eligibility.             |     the use of loss of food     |
|         |                          |     (food damaged by disaster   |
|         |                          |     event or spoiled due to     |
|         |                          |     power outage, which is      |
|         |                          |     likely when outages exceed  |
|         |                          |     4 hours) as an eligibility  |
|         |                          |     factor when food loss is    |
|         |                          |     the only loss to the        |
|         |                          |     household due to the        |
|         |                          |     disaster. The State agency  |
|         |                          |     will need to consider its   |
|         |                          |     ability to handle [a        |
|         |                          |     substantial number          |
|         |                          |     of]{.mark} applications if  |
|         |                          |     food loss without other     |
|         |                          |     disaster related losses is  |
|         |                          |     used as an acceptable       |
|         |                          |     D-SNAP eligibility          |
|         |                          |     qualified. The State agency |
|         |                          |     *must* include in their     |
|         |                          |     request to FNS to operate a |
|         |                          |     D-SNAP a statement in       |
|         |                          |     regard to its decision on   |
|         |                          |     use of food loss as an      |
|         |                          |     eligibility factor.         |
|         |                          |                                 |
|         |                          | -   States electing food loss   |
|         |                          |     as a sole eligibility       |
|         |                          |     criterion and also issuing  |
|         |                          |     individual supplements to   |
|         |                          |     ongoing households should   |
|         |                          |     amend their affidavit to    |
|         |                          |     include food loss as an     |
|         |                          |     eligibility criterion for   |
|         |                          |     supplements.                |
+---------+--------------------------+---------------------------------+
| I       | -   Immediate on-site    | -   Number of potential         |
| ssuance |     issuance             |     applicants                  |
| Method  |                          |                                 |
|         | -   Mailing of EBT cards | -   Availability of adequate    |
|         |     and PINS             |     EBT cards (pre-PINed or     |
|         |                          |     not) at the time of         |
|         | -   Pick-up of EBT cards |     issuance                    |
|         |     after date of        |                                 |
|         |     application          | -   Site security               |
|         |                          |                                 |
|         |                          | -   Reliability of mail system  |
+---------+--------------------------+---------------------------------+
| Tr      | [States have the option  | -   [See Chapter 3:             |
| eatment | to offer mass            |     [Repl                       |
| of      | replacement of benefits  | acements](#ole_link100)]{.mark} |
|         | lost due to food         |                                 |
| o       | destroyed in the         |                                 |
| n-going | disaster (households may |                                 |
| cases   | always request           |                                 |
|         | individual replacements, |                                 |
|         | even without a disaster  |                                 |
|         | declaration).]{.mark}    |                                 |
+---------+--------------------------+---------------------------------+
| []      | [States have the option  | -   [See below]{.mark}          |
| {.mark} | to offer individual or   |                                 |
|         | mass supplements up to   |                                 |
|         | the maximum allotment    |                                 |
|         | for ongoing              |                                 |
|         | households.]{.mark}      |                                 |
+---------+--------------------------+---------------------------------+

[]{#OLE_LINK81 .anchor}**Supplements**

States may issue supplemental benefits to allow ongoing clients to
receive the same maximum benefit as clients participating in the D-SNAP.
*Supplements are authorized under the provisions of the D-SNAP, so any
plans to issue supplements must be included in the State's D-SNAP
request*. Under waiver approval, supplements can be issued to households
either individually or automatically, depending upon the circumstances
of the disaster and the State's capabilities in the aftermath of the
disaster.

A supplement is the difference between the household's normal monthly
SNAP allotment and the applicable maximum monthly allotment for their
household size. *[Example:]{.underline} One-person household's regular
monthly allotment is \$82, and the maximum allotment allowed is \$152,
then the supplement would be \$70.*

The State agency can elect to issue supplements to ongoing households
who have received replacements of benefits destroyed during that same
disaster. The amount of any supplement issued to a household also
receiving a replacement should still equal the difference between the
maximum allotment for their household size and their actual regular SNAP
allotment.

***Individual Supplements***

Individual supplements work best in areas where there is only a
small-scale disaster and the State agency can administer individual
supplemental benefits to ongoing households at the same time as taking
applications for D-SNAP benefits from new households.

As an ongoing household's income status is already known and verified,
the *State is not required to have the household complete a separate
disaster application*. However, [FNS requires that household file an
affidavit, by mail or in person, which must include an attestation that
they have lost income or incurred disaster-related expenses. Households
must complete the affidavit during the application period approved by
FNS for the entire D-SNAP operation.]{.mark} States that elect to use
food loss as a sole eligibility criterion for their new D-SNAP
applicants should amend their affidavit to allow ongoing clients to
attest to food loss for eligibility for individual supplements. Please
see *Publications -- Certification Process* for an example affidavit
template that can be adapted for State use.

[]{.mark}

[States that are considering requiring households complete a disaster
application will need to decide whether or not to require households to
mail in the disaster application or appear at the D-SNAP
application/issuance site or at any separate site for ongoing
households. States should include the following factors in their
calculus:]{.mark}

-   [Number of on-going recipients]{.mark}

-   [Total number of potential recipients]{.mark}

-   [Staffing/security at application/issuance or processing
    site]{.mark}

-   [Size of application/issuance site]{.mark}

[]{.mark}

***Automatic Supplements***

Automatic supplements generally work best when there is a large-scale
disaster by allowing the State agency to more quickly and efficiently
meet the needs of ongoing clients affected by the disaster.

The decision to issue an automatic supplement depends on the severity
and scope of the disaster event and the ability of the State to address
the needs of ongoing households at the same time new households apply
for the disaster benefits.

The advantages of issuing automatic supplements include:

-   Everyone affected by the disaster gets help;

-   Households receive the same applicable maximum allotment that new
    applicant households would receive under the D-SNAP.

-   Reduces the administrative burden of providing supplements
    individually to ongoing households in addition to providing disaster
    benefits to new applicant households at the same time.

**Replacements**

[]{#ole_link100 .anchor}States must replace food destroyed during a
household misfortune. States can choose to replace all or a portion of
on-going households benefits, depending upon the circumstances of the
disaster.

Replacement benefits are authorized under the terms of the regular SNAP
at 7 CFR 274.6(f). Replacements can be issued either:

-   Individually, without waiver approval, by having the household file
    an affidavit; or

-   Automatically, with waiver approval, to all ongoing households
    affected by the disaster.

States can issue replacements without operating a D-SNAP, simply by
providing individual replacements. States can also issue replacements
concurrent with a D-SNAP, but should take steps to prevent ongoing
households receiving the replacement from applying for and receiving a
*full* D-SNAP benefit. States wishing to provide some level of D-SNAP
benefits to ongoing households already receiving a replacement can issue
a supplement to raise the benefit to the maximum allotment (see Chapter
3: [Supplements](#OLE_LINK81)).

***Replacement Timeline***

The regulations at 7 CFR 274.6 state that replacement issuances shall be
provided to households within 10 days after report of non-delivery or
loss (15 days if issuance was by certified or registered mail) or within
two working days of receiving the signed household statement, whichever
date is later. This regulation was written before modern issuance
systems were in place. Nowadays, State agencies are capable of providing
replacement benefits in a much shorter timeframe. FNS expects State
agencies to endeavor to provide benefits in two days. These same
regulations set a 10 day deadline for households to request an
individual replacement. States may request a waiver of this regulation
to provide households additional time to request a replacement

***Individual Replacements***

Households that file an affidavit for individual replacements must:

-   Have experienced loss of food purchased with SNAP benefits;

-   Appear in person at the county/local office to file the affidavit or
    mail in the affidavit within 10 days of the loss (*although States
    can request to a waiver to extend this period*); and

-   Get no more than the household's normal monthly allotment.

Please see *Publications -- Certification Process* for an example
affidavit template that can be adapted for State use.

Because the household's income status is already known and verified,
most states do not require the household to complete a separate disaster
application. As long as the household's claim appears reasonable, there
is little or no scrutiny of these affidavits. The cost of the
replacement benefits is part of the program's normal SNAP costs.
Therefore, replacement benefits are not to be reported as D-SNAP costs
on the FNS-292, but should be reported on the FNS-388 Monthly Issuance
Report.

Individual replacements generally work best in small-scale disasters, as
they are considered inefficient administratively (States have to issue
replacements to each individual household in addition to providing
regular disaster benefits to new applicant households).

The disadvantages of issuing individual replacements include:

-   Notifying households that they are eligible for replacement
    benefits, which is suggested, but not required, can be cumbersome.
    States can choose to mail eligible families a notice and an
    affidavit form or use media, such as radio or newspaper, to notify
    the eligible public. States should keep in mind that households who
    have vacated their homes might not return in time to find and act
    upon the notice. Also, mail service may be interrupted or slow in
    some areas due to post-disaster conditions. Additionally,
    individuals must have an operational county/local office to receive
    and process their affidavit.

-   Even carefully worded media spots can lead to the receipt of a high
    number of inquiries from clients not in the area eligible for
    replacements.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Individual Replacements                                               |
|                                                                       |
| Individual replacements would not have been possible under Hurricane  |
| Katrina because many local offices were closed and because most       |
| families had evacuated the State and could not return to their homes. |
+-----------------------------------------------------------------------+

***Mass Replacements***

Mass replacements can be issued automatically *with waiver approval*.
The decision to issue mass replacements depends on the severity and
scope of the disaster event and the ability of the State to address the
needs of ongoing households at the same time new households apply for
disaster benefits.

At least 50 percent of ongoing participants in certain defined areas
(e.g., by neighborhood or ZIP code) must have sustained damages that
lead to food loss in order to issue mass replacements. The amount
replaced cannot exceed a household's normal monthly allotment.

The percentage of benefits replaced depends on a variety of factors,
such as:

-   When in the month the disaster occurred;

-   Whether or not the damage to the community likely lead to food loss
    (keep in mind that power outages lasting at least 4 hours are almost
    certain to lead to food loss);

-   What kind of food loss likely occurred (perishable and/or
    non-perishable).

Mass replacements generally work best when there is a large-scale
disaster by allowing the State agency to more quickly and efficiently
meet the needs of ongoing clients affected by the disaster.

The advantages of issuing mass replacement include:

-   Everyone affected by the disaster gets help;

-   Regardless of whether replacements are issued individually by
    affidavit or en masse, there is minimal cost risk attributable to
    the SNAP for the value of replacement benefits (this is why
    replacement benefits are not to be reported as D-SNAP costs);

-   Reduces the administrative burden of providing disaster benefits to
    ongoing and new applicant households at the same time as ongoing
    households would not have to report a loss or appear in person to
    file an affidavit.

States may wish to use media, such as radio or newspaper, to notify the
eligible public that they will issue replacements for certain areas.
This can help reduce the number of inquiries to the State agency by
eligible persons concerned about their benefits, but can also lead to
inquiries from clients not residing in the area eligible for replacement
benefits.

**Defining Disaster Areas**

[]{#ole_link82 .anchor}Delineating the geographical area in which the
D-SNAP will run is *crucial* to the success of the D-SNAP. The agency
must define an area that strikes a balance between being large enough to
serve those in need, and being limited enough to reduce the possibility
that people will apply and qualify for benefits who were not seriously
affected by the disaster.

Some appropriate delineating factors could include:

-   ZIP code

-   Neighborhood or subdivision

-   Power grid location

-   City/town

-   County

***Power Company Contacts***

State agencies are urged to establish contact with appropriate power
company personnel during the planning process to discuss how they can
supply data to the State agency immediately after a disaster, as
establishing contacts with power companies in the aftermath of a
disaster is very difficult. Appropriate power company contacts can
generally be found by contacting the State emergency management agency.
States with multiple power providers, especially, must be prepared to
work with various sources to establish expectations on the quantity,
quality, and timeliness of requested data.

***[Non-eligible Households in Disaster Areas]{.mark}***

[States should be mindful that households from areas in which the State
will not operate a D-SNAP may have contact with households in areas
receiving D-SNAP benefits and may not understand they may not be
eligible for benefits and why. For example, residents of multiple
counties may be temporarily housed in the same shelters or private
homes. State agencies operating D-SNAP application/issuance sites where
households from areas not eligible for D-SNAP benefits also may be
sheltered should consider distributing regular SNAP applications,
offering accelerated service to these households, and distributing
information about residence and eligibility.]{.mark}

**Comparison Chart**

*Publications -- Disaster Comparison Chart* compares some provisions of
some recent disaster programs.

[]{#OLE_LINK38 .anchor}Request to Operate the D-SNAP

**Introduction**

The request to operate the D-SNAP is made by the State agency to FNS and
consists of an informal request followed by a formal written request for
permission to operate the D-SNAP. FNS will endeavor to handle all
disaster waiver requests within 24 hours. The efficiency of our response
to a request can be greatly improved if all the information we need to
evaluate the request is included in the initial request.

When the State agency submits an informal request usually over the
phone, FNS and the State agency will negotiate and agree on the terms of
the program. When FNS receives the formal written request, it can
approve it without further delay.

**Submitting the Request**

This table describes the necessary steps for submitting the request.
Please see *Publications -- Example Request to Operate a D-SNAP* for an
example request.

  ---------------------------------- ------------------ ------------------
  **Table 25. Submitting D-SNAP                         
  Request to FNS**                                      

  **Request**                        **How**            **When**

  Informal                           By phone or fax to With adequate time
                                     the Regional       for FNS to
                                     Office             consider and
                                                        respond to the
                                                        request.

  Formal                             In writing (either With adequate time
                                     by regular mail or for FNS to
                                     emailed copy of    consider and
                                     the signed         respond to the
                                     original) to the   request.
                                     Regional Office    
  ---------------------------------- ------------------ ------------------

**Contents: Informal Request**

The informal request shall include as much of the supporting information
needed for the formal request as possible.

**Contents: Formal Request**

The formal request shall include the following information (State
agencies may wish to cut and paste the requirements from this table into
their letter to FNS applying for a D-SNAP):

+------------------------------+---------------------------------------+
| **Table 26. D-SNAP Request   |                                       |
| Requirements**               |                                       |
+==============================+=======================================+
| **Requirement**              | **Specifics**                         |
+------------------------------+---------------------------------------+
| Date and type of disaster    |                                       |
+------------------------------+---------------------------------------+
| Description of geographic    | Provide maps, if available.           |
| areas in need of assistance  |                                       |
|                              | Please see Chapter 3: [Defining       |
|                              | Disaster Areas](#ole_link82)          |
+------------------------------+---------------------------------------+
| Statutory prerequisites      | A statement that commercial channels  |
|                              | of food distribution are available    |
|                              | (or estimate on when they will be     |
|                              | restored), and a statement that       |
|                              | either:                               |
|                              |                                       |
|                              | -   A presidential declaration has    |
|                              |     been granted, or                  |
|                              |                                       |
|                              | -   Commercial channels of food       |
|                              |     distribution were disrupted       |
|                              |                                       |
|                              | See Chapter 3: [Commercial Channels   |
|                              | of Food Distribution](#OLE_LINK83)    |
+------------------------------+---------------------------------------+
| Determination that           | If food loss due to power outage is a |
| low-income households have   | criterion, include:                   |
| lost food or are unable to   |                                       |
| purchase sufficient          | -   Duration of power outage.         |
| nutritious food              |                                       |
|                              | -   Geographical limits of outage     |
|                              |                                       |
|                              | -   Percentage of customers affected  |
|                              |     by outage                         |
|                              |                                       |
|                              | -   Indication of whether food loss   |
|                              |     alone will or will not qualify a  |
|                              |     household for the D-SNAP.         |
|                              |                                       |
|                              | **Note**: Outages of over 4 hours are |
|                              | associated with food spoilage.        |
+------------------------------+---------------------------------------+
| Include substantiation that  | -   D-SNAP needed to account for      |
| food needs of these          |     household disaster-related        |
| households cannot be met by  |     expenses not normally deducted    |
| the regular SNAP.            |     for regular SNAP.                 |
|                              |                                       |
|                              | -   State agency could not adequately |
|                              |     serve the expected volume of      |
|                              |     applicants using regular SNAP.    |
+------------------------------+---------------------------------------+
| Estimate of the number of    | -   Give separate figures for         |
| households expected to apply |     on-going and new applicants       |
+------------------------------+---------------------------------------+
| Expected length of           | -   Not to exceed 7 days.             |
| application period           |                                       |
|                              | -   Give starting and ending dates,   |
|                              |     if known.                         |
|                              |                                       |
|                              | **Note:** It is better to request     |
|                              | fewer days *initially* and then       |
|                              | extend the D-SNAP if necessary.       |
+------------------------------+---------------------------------------+
| Expected length of the       | -   Give starting and ending dates.   |
| benefit period               |                                       |
+------------------------------+---------------------------------------+
| Description of any           | -   Complete description. See         |
| additional waivers requested |     *Publications -- Waivers* for     |
|                              |     examples of additional waivers    |
|                              |     approved in past disasters.       |
+------------------------------+---------------------------------------+
| Description of residency     | -   Indication of whether working,    |
| requirement                  |     but not living, in the disaster   |
|                              |     area will be considered           |
|                              |     residence. See Ch. 3 --           |
|                              |     [Eligibility                      |
|                              |     Criteria](#OLE_LINK59)            |
+------------------------------+---------------------------------------+
| Description of security plan | -   Brief description. See Ch. 2 --   |
|                              |     [Security](#OLE_LINK15)           |
+------------------------------+---------------------------------------+
| Description of crowd control | -   Brief description. See Ch. 3 --   |
| measures                     |     [Crowd Control](#OLE_LINK55)      |
+------------------------------+---------------------------------------+
| Description of fraud control | -   Brief description. See Ch. 3 --   |
| measures                     |     [Program Integrity and Fraud      |
|                              |     Prevention](#OLE_LINK31)          |
+------------------------------+---------------------------------------+
| Description of process by    | Where applicable, specify different   |
| which applications will be   | procedures for:                       |
| processed and benefits       |                                       |
| issued                       | -   Ongoing households                |
|                              |                                       |
|                              | -   New applicants                    |
|                              |                                       |
|                              | -   Special needs populations         |
|                              |     (elderly, disabled, SSI           |
|                              |     recipients)                       |
|                              |                                       |
|                              | Estimate how long it will take to     |
|                              | process applications.                 |
+------------------------------+---------------------------------------+
| Indication of whether or not | See Chapter 3:                        |
| the State will supplement    | [Supplements](#OLE_LINK81)            |
| the allotments for           |                                       |
| previously-certified regular |                                       |
| SNAP households, bringing    |                                       |
| each to the maximum          |                                       |
| allotment for its household  |                                       |
| size.                        |                                       |
+------------------------------+---------------------------------------+
| [Indication of whether or    | [See Chapter 3 :                      |
| not the State will issue     | [Replacements](#ole_link100)]{.mark}  |
| mass replacements for        |                                       |
| previously-certified regular |                                       |
| SNAP households that lost    |                                       |
| benefits in the              |                                       |
| disaster.]{.mark}            |                                       |
+------------------------------+---------------------------------------+
| Procedures to coordinate     |                                       |
| with other State agencies to |                                       |
| obtain additional workers,   |                                       |
| if needed.                   |                                       |
+------------------------------+---------------------------------------+
| Description of planned       | See Chapter 4: [Post-disaster         |
| post-disaster review         | Review](#OLE_LINK71)                  |
| activities                   |                                       |
+------------------------------+---------------------------------------+

**FNS Action on the Request**

FNS will either approve or deny the request. FNS will email the decision
and supporting documents to the State agency.

**Contents of Approval**

The approval from FNS will include:

Disaster certification and issuance procedures

Geographic areas where the procedures will be used

Length of the application and benefit periods

Description of any approved waivers

Reporting requirements.

[]{#OLE_LINK39 .anchor}Requests to Modify, Extend, or Expand the D-SNAP

In some cases, States will learn after their operation of the D-SNAP has
begun that they will need to modify the program with additional waivers,
extend the application or benefit period, or expand the program to
additional geographic areas.

**[Request for Modification]{.mark}**

[States can modify their program with additional policy waivers in order
to adequately serve their population.]{.mark}

**[Request for Extension]{.mark}**

[State agencies may find that extension of the application or benefit
period is necessary to best serve affected households. When making a
decision to extend the program, the State agency should consider the
conditions in each project area, as not all project areas may need an
extended program.]{.mark}

[]{.mark}

***[Extension of the Application Period]{.mark}***

[If significant number of disaster-affected households cannot be served
during the original application period, the State agency may apply for
permission from FNS to extend the application period. State agencies
should include in their request confirmation that a significant number
of eligible households were not served and are expected to apply if the
application period is extended. Note: extensions of the application
period do not automatically change the benefit period. For example, if
the benefit period is December 1 to December 30, and the State agency
chooses to extend the application period into January because program
was implemented late, the eligibility worker should still use December
as the budgeting/benefit month.]{.mark}

[]{.mark}

***[Extension of the Benefit Period/Additional Benefits]{.mark}***

[If extraordinary circumstances indicate a need by the eligible public
for more than one month's benefits, the State agency may apply for
permission from FNS to extend the benefit period and provide additional
benefits for an additional half or full month. To extend the benefit
period, the State agency must provide confirmation that the regular SNAP
is not available to meet the ongoing needs of disaster victims and/or
any other data that would support an extension. States should note that
a second month of benefits will only be approved under *extraordinary*
situations, such as those that were present after Hurricane Katrina. For
most disasters, States should plan to transition still-needy people to
the regular SNAP.]{.mark}

[]{.mark}

**[Request for Expansion]{.mark}**

[State agencies may find that they need to expand their D-SNAP to
encompass geographical areas not included in the original approval (such
as when FEMA provides disaster declarations for additional counties
after operation of the D-SNAP has already begun). The State agency can
request expansion of their D-SNAP to new areas by submitting to FNS a
request that includes all information normally requested for an initial
request to operate a D-SNAP, but for the new geographical areas.]{.mark}

[]{.mark}

[States agencies should note that the benefit period for an expansion
will be the same as the benefit period for their initial approval (a 30
day period that starts on the date of the disaster or mandatory
evacuation order). However, the State agency can specify a new
application period for the added geographical areas.]{.mark}

**Submitting the Request for Modification, Extension, or Expansion**

This table describes the necessary steps for submitting a request for
modification, extension, or expansion.

  ------------------------------------------------------------------------
  **Table 27. Submitting                         
  the Request for                                
  Extension**                                    
  ----------------------- ---------------------- -------------------------
  **Request**             **How**                **When**

  Informal                By phone or fax to the Before original approval
                          Regional Office.       period expires, with
                                                 adequate time for FNS to
                                                 consider and respond to
                                                 the request.

  Formal                  In writing to the      With adequate time for
                          Regional Office.       FNS to consider and
                                                 respond to the request.
  ------------------------------------------------------------------------

**Section 3. Application/Issuance Sites**

[]{#OLE_LINK47 .anchor}Overview

**Contents**

This section addresses issues involving the setting up and running of
the application/issuance sites.

**Checklists**

The following checklists are included in *Publications* for use during a
disaster.

-   Damage Needs Analysis Checklist (*Publications -- Developing the
    Response*)

-   Application/Issuance Site Selection Guide (*Publications --
    Application/Issuance Site*)

-   Application/Issuance Site Supply Checklist (*Publications --
    Application/Issuance Site*)

-   Human Comforts Checklist (*Publications -- Application/Issuance
    Site*)

-   Application/Issuance Site Readiness Checklist (*Publications --
    Application/Issuance Site*)

-   Site Closeout Checklist (*Publications -- Application/Issuance
    Site*)

[]{#OLE_LINK48 .anchor}Choosing the Application/Issuance Sites

**State Agencies Choose Application/Issuance Sites**

The State agency decides the exact number and location of
application/issuance sites. In small-scale disasters where county/local
public assistance offices are undamaged, States may wish to operate the
D-SNAP at public assistance offices. Where the State predicts a large
number of applicants or where public assistance offices have sustained
damage, the State may wish to choose an alternate site. States that wish
to co-locate their D-SNAP with a FEMA DRC must be coordinate this early
with FNS and FEMA.

[States should consider establishing application/issuance sites outside
of the disaster area when large numbers of households have left the
disaster area, especially when access back into the disaster area is
difficult. In such cases, application/issuance sites may be operated in
Social Services offices or mass sites in neighboring communities, even
neighboring counties, where affected households are temporarily housed.
Should a State agency choose to operate application/issuance sites
outside of the disaster area, they should take care to advertise the
program in the communities where affected households are temporarily
housed.]{.mark}

**Factors in Choosing the Sites**

Consider the factors in Table 28 when determining the number and
placement of centers. Add ideas identified in pre-disaster planning.

+----+------------------------------+----------------------------------+
| *  |                              |                                  |
| *T |                              |                                  |
| ab |                              |                                  |
| le |                              |                                  |
| 2  |                              |                                  |
| 8. |                              |                                  |
| Ap |                              |                                  |
| pl |                              |                                  |
| ic |                              |                                  |
| at |                              |                                  |
| io |                              |                                  |
| n/ |                              |                                  |
| Is |                              |                                  |
| su |                              |                                  |
| an |                              |                                  |
| ce |                              |                                  |
| Si |                              |                                  |
| te |                              |                                  |
| S  |                              |                                  |
| el |                              |                                  |
| ec |                              |                                  |
| ti |                              |                                  |
| on |                              |                                  |
| G  |                              |                                  |
| ui |                              |                                  |
| de |                              |                                  |
| ** |                              |                                  |
+----+------------------------------+----------------------------------+
| ** | **Examples**                 |                                  |
| () |                              |                                  |
| Fa |                              |                                  |
| ct |                              |                                  |
| or |                              |                                  |
| ** |                              |                                  |
+----+------------------------------+----------------------------------+
|    | Can the site be co-located   |                                  |
|    | with FEMA\'s DRC?            |                                  |
+----+------------------------------+----------------------------------+
|    | Public transportation and/or | Shuttle service from other       |
|    | adequate parking available?  | location, parking limited to     |
|    |                              | handicapped cars, large          |
|    |                              | conference center type facility  |
+----+------------------------------+----------------------------------+
|    | Site accessible to trucks or | Sanitation and medical services, |
|    | other large vehicles?        | delivery of food, water,         |
|    |                              | supplies, etc.                   |
+----+------------------------------+----------------------------------+
|    | Adequate space and/or        | Protection from the elements,    |
|    | facilities to address human  | space for portable toilets,      |
|    | comfort concerns?            | food/water tent, etc.            |
+----+------------------------------+----------------------------------+
|    | Space large enough to serve  | Space for tents or trailers,     |
|    | the expected number of       | large auditoriums, space for     |
|    | applicants?                  | waiting                          |
+----+------------------------------+----------------------------------+
|    | Issuance facility can be     | Isolated rooms or areas,         |
|    | adequately secured?          | building protected from public   |
|    |                              | access, parts that can be closed |
|    | (Consult with local police   | off by security, traffic flow    |
|    | on site selection and        | directed away from issuance      |
|    | security issues).            | sites                            |
+----+------------------------------+----------------------------------+
|    | Accessible to the elderly    | Wheelchair ramps, bathroom       |
|    | and disabled, or can they be | facilities, separate             |
|    | made more accessible?        | location/room for elderly &      |
|    |                              | disabled, plenty of seating      |
|    |                              | available                        |
+----+------------------------------+----------------------------------+
|    | In close proximity to all    | Several sites spread             |
|    | affected segments of the     | geographically over the area,    |
|    | community?                   | large centrally-located stadium  |
|    |                              | with easy access, mobile vans to |
|    |                              | elderly/disabled centers.        |
+----+------------------------------+----------------------------------+
|    | Adequate power?              | Electricity, generators and fuel |
+----+------------------------------+----------------------------------+
|    |                              |                                  |
+----+------------------------------+----------------------------------+

**Co-Locating With FEMA DRC**

In some disasters, co-location of the D-SNAP site and FEMA\'s DRC may be
an appropriate way to provide one-shop service for disaster victims. In
very large disasters, however, D-SNAP crowds may be disruptive to FEMA
efforts at the DRC. If co-location is desired, the State agency and FNS
must coordinate this with FEMA *as early as possible* to reach
agreement, including what costs/services FEMA will provide.

**Advice on Choosing Sites**

When choosing application/issuance sites, the State agency should
consider seeking advice from:

-   Other State agencies which have run the D-SNAP

-   Federal government agencies, particularly FNS

-   The Damage Needs Analysis team

-   The Disaster Assistance Response Team

-   Local or State police or other security personnel.

**Some Options**

Application/Issuance sites have been operated in schools, county/local
public assistance offices, stadiums, police stations, libraries, mobile
vans, and out of rented trailers and tents.

**Potential Sites Checklist**

A copy of the chart identifying relevant factors (with space for
comments) is included in *Publications -- Application/Issuance Site*.
The chart can be used as a checklist to evaluate specific sites.

[]{#OLE_LINK49 .anchor}Lay Out and Traffic Flow

**Important**

Establish the lay out of the application/issuance site and traffic flow
through the site immediately. Develop a flow chart identifying the lay
out and traffic flow through the site and use it while setting up and
managing the site. The chart will assist in:

-   Spotting potential bottlenecks and other trouble spots

-   Identifying staffing, security, supply and other administrative
    needs.

**Issues to Address**

The lay out and traffic flow through the site should address the
following issues.

+---------------------+---------------------------------+--------------+
| **Table 29. Site    |                                 |              |
| Layout Guidance**   |                                 |              |
+=====================+=================================+==============+
| **Issue**           | **Layout Solution**             | **For        |
|                     |                                 | Additional   |
|                     |                                 | I            |
|                     |                                 | nformation** |
+---------------------+---------------------------------+--------------+
| EBT Card Security   | -   Restrict access to issuance | Chapter 3:   |
|                     |     storage sites by arranging  | [Is          |
|                     |     seating, eligibility        | suance/EBT]( |
|                     |     determination areas, and    | #OLE_LINK16) |
|                     |     queues away from this area. |              |
|                     |                                 |              |
|                     | -   Block all but one door into |              |
|                     |     issuance area               |              |
+---------------------+---------------------------------+--------------+
| Staff/Applicant     | -   Arrange site to minimize    | Contact      |
| Security            |     crowd density during wait   | local police |
|                     |                                 | and private  |
|                     | -   Provide private break rooms | security     |
|                     |     and bathrooms to staff      | companies    |
|                     |                                 |              |
|                     | -   Minimize visibility of      |              |
|                     |     special treatment for       |              |
|                     |     elderly/disabled to people  |              |
|                     |     waiting in long lines       |              |
+---------------------+---------------------------------+--------------+
| Crowd Control       | -   Arrange for the queue to    | See Chapter  |
|                     |     move from one station/event | 3: [Crowd    |
|                     |     to another to give clients  | Control](    |
|                     |     to feel a sense of progress | #OLE_LINK55) |
|                     |     and reduce their anxiety.   |              |
|                     |                                 |              |
|                     | -   Post signs at intervals     |              |
|                     |     throughout the queue to     |              |
|                     |     alert clients to the        |              |
|                     |     estimated wait time from    |              |
|                     |     that point and to inform    |              |
|                     |     new arrivals of the queue's |              |
|                     |     starting point. Combined,   |              |
|                     |     these will calm those with  |              |
|                     |     a long wait and discourage  |              |
|                     |     people from "cutting" in    |              |
|                     |     line.                       |              |
|                     |                                 |              |
|                     | -   Manage a long queue at a    |              |
|                     |     compact site with a zigzag  |              |
|                     |     queue, formed with ropes or |              |
|                     |     other movable barriers.     |              |
+---------------------+---------------------------------+--------------+
| Human Comforts      | -   Arrange queues to maximize  | See Chapter  |
|                     |     protection from elements    | 3: [Human    |
|                     |                                 | Comforts](   |
|                     | -   Place water/food station(s) | #OLE_LINK54) |
|                     |     near areas of long wait     |              |
|                     |                                 |              |
|                     | -   Place toilets to maximize   |              |
|                     |     privacy (away from lines)   |              |
|                     |                                 |              |
|                     | -   Set up special areas for    |              |
|                     |     those waiting for shuttles  |              |
|                     |     and rides.                  |              |
+---------------------+---------------------------------+--------------+

**Consult Police**

Consult with police or other security personnel in developing or making
changes to the lay out and traffic flow within the site. In previous
disasters, the lay out of the application/issuance site, including the
location of portable toilets, has been at issue because of reports of
threatened robberies or violence.

**Suggested Aids**

Some suggested aids to address the lay out and traffic flow issues are
listed in the table below. Add any additional ideas developed during
pre-disaster planning.

+-----------------+----------------------------------------------------+
| **Table 30.     |                                                    |
| Layout          |                                                    |
| Suggestions**   |                                                    |
+=================+====================================================+
| **Tools**       | **Examples**                                       |
+-----------------+----------------------------------------------------+
| Ropes and       | -   To establish lines                             |
| barriers        |                                                    |
|                 | -   To block or limit access to secure areas       |
|                 |                                                    |
|                 | -   To direct traffic flow through site            |
+-----------------+----------------------------------------------------+
| Signs           | -   IN/OUT                                         |
|                 |                                                    |
|                 | -   Household size signs on issuance lines         |
|                 |                                                    |
|                 | -   Expected wait times. Example: "There is a 3    |
|                 |     hour wait from here".                          |
|                 |                                                    |
|                 | -   Site hours of operation. Example:              |
|                 |     "Applications will be taken at this site until |
|                 |     7:00 p.m. every day through Friday\"           |
+-----------------+----------------------------------------------------+
| Check points    | -   Set up check point just outside the facility   |
|                 |     to give applicants a number and to help        |
|                 |     control who comes into the site                |
|                 |                                                    |
|                 | -   Set up check point before applicants enter     |
|                 |     issuance area to ensure that only approved     |
|                 |     households can enter                           |
|                 |                                                    |
|                 | -   Stop applicants before they get to interview   |
|                 |     area and let them in one at a time to see      |
|                 |     eligibility worker to ensure applicants have   |
|                 |     completed application and to maximize          |
|                 |     confidentiality of interviews                  |
+-----------------+----------------------------------------------------+
|                 |                                                    |
+-----------------+----------------------------------------------------+
|                 |                                                    |
+-----------------+----------------------------------------------------+

**Sample Floor Plans**

Sample floor plans, modeled after plans used successfully in previous
disasters, have been developed for some common situations and are
included in *Publications -- Application/Issuance Site*. Samples include
plans for the following spaces:

-   General - One large room in a building (e.g. civic center type
    building)

-   Multi-building site (e.g. school)

-   An arena or stadium.

-   Florida model

[]{#OLE_LINK51 .anchor}Equipping the Application/Issuance Site

**Equipping the Site**

After the lay out, traffic flow, and staffing issues are addressed, the
site manager can determine how to equip the site. These issues involve
the physical plant itself.

**Supplies**

Suggestions for supplies for the certification system are included in
the table below. Add any additional ideas developed in pre-disaster
planning, and add to supply checklist included in *Publications --
Application Issuance Site*.

  --------------------------------------------------------------------------------------------
  **Table 31.                                                                         
  Application/Issuance                                                                
  Site Supplies**                                                                     
  ---------------------- --------------------- ------------ ------------- ----------- --------
  **For**                **Item**              **Number**   **Sources**   **Notes**   **()**

  Physical Plant         Tables                                                       

                         Chairs                                                       

                         Generators                                                   

                         Fuel                                                         

                         Fans or heaters                                              

                         Tents                                                        

                         Copy machines                                                

                         Computers                                                    

                         Printers                                                     

                         Surge protectors                                             

                         Extension Cords                                              

                         Garbage bags                                                 

                         Garbage cans                                                 

                         Barricades (flexible                                         
                         preferred)                                                   

                         Caution tape                                                 

                         Message board                                                

                         Erasable markers                                             

                         Dollies                                                      

                         Porta-potties with                                           
                         service                                                      

                         Hand washing stations                                        

                         Dumpsters                                                    

                         Cones                                                        

                         Tower lighting                                               

                         Fire extinguishers                                           

                         Bins or garbage cans                                         
                         for clipboard storage                                        

                         Numbers/tickets                                              

                                                                                      

                                                                                      

  Communication          Bull horns                                                   

                         Radios                                                       

                         Walkie-talkies                                               

                         Cell Phones                                                  

                         Fraud flyers                                                 

                         Eligibility flyers                                           

                         EBT card guidance                                            
                         flyers                                                       

                         Shopping tips flyers                                         

                         Signage                                                      

                         PA equipment &                                               
                         recording on how to                                          
                         complete application                                         

                         Cameras or                                                   
                         video-cameras so                                             
                         offsite staff can get                                        
                         visuals                                                      

                                                                                      

  Issuance               EBT cards                                                    

                         Issuance                                                     
                         documents/manifests                                          

                         Allotment tables                                             

                         EBT card readers                                             

                         Secure onsite EBT                                            
                         card storage                                                 

                                                                                      

                                                                                      

  Certification          Applications                                                 

                         Calculators                                                  

                         Batteries for                                                
                         calculators, radios,                                         
                         etc.                                                         

                         Staplers                                                     

                         Staples                                                      

                         File folders                                                 

                         Clip boards (to match                                        
                         form size)                                                   

                         Pens                                                         

                         Eligibility and                                              
                         verification                                                 
                         checklists                                                   

                         Rubber bands                                                 

                         Storage bins                                                 

                         Scissors                                                     

                         Box cutters                                                  

                         Trays                                                        

                         Packing tape                                                 

                         Phone books                                                  

                         Map of affected area                                         

                         List of ongoing                                              
                         clients                                                      

                                                                                      

                                                                                      

  Human Comforts         Coolers                                                      

                         Ice                                                          

                         Water                                                        

                         Water containers                                             

                         Cups                                                         

                         Toilet paper                                                 

                         Paper towels                                                 

                         Sunblock                                                     

                         Insect repellant                                             

                         First aid kits                                               

                         Rain ponchos                                                 

                         Meals ready to eat                                           
                         (MRE) or heater meals                                        

                         Food for the                                                 
                         ill/elderly/infants                                          
                         (cookies, crackers,                                          
                         juice, baby food,                                            
                         infant formula)                                              

                         Golf carts                                                   

                         Wheel chairs                                                 

                                                                                      

                                                                                      
  --------------------------------------------------------------------------------------------

**Technology**

***General***

If possible, the application/issuance site should have a copy machine,
laptop computers, and printers.

***Eligibility Determination System***

Client applications may be processed onsite or offsite, depending upon
the tools available to the State agency. States can choose to determine
eligibility using a special D-SNAP program or may determine eligibility
in the regular SNAP determination system that has been temporarily
modified to determine eligibility based on D-SNAP policies. 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 input denied
applications into the eligibility determination system each day, so that
households that are denied and later reapply are detected and referred
to fraud prevention staff.]{.mark}

***Communications***

Application/issuance sites should be equipped with telephones (including
cellular service and phones, if landlines are not available), fax
machines, and wireless connectivity/email capability for laptops. To
avoid problems and confusion, especially in large application/issuance
sites, having and using portable radios, walkie-talkies, and cell phones
is essential. Note that cell phone systems can overload when too many
people call at the same time. States may wish to have cell phones
telephone numbers pre-assigned to individual staff members and those
phone numbers/staff names stored on an emergency phone list in advance
of disasters.

+-----------------------------------------------------------------------+
| ***State Experience***                                                |
|                                                                       |
| Application/Issuance Site Technology                                  |
|                                                                       |
| Florida and Louisiana are investing in access to satellite service to |
| allow their onsite computers to communicate with their eligibility    |
| determination system when public communications and other essential   |
| services are unavailable. Florida has purchased a mobile dish         |
| (antenna) that allows computers at the application/issuance site to   |
| transmit data to the satellites to which they've subscribed. The      |
| satellites then transmit the data to the FLORIDA system for           |
| processing.                                                           |
|                                                                       |
| Additional technologies employed by Florida that can facilitate the   |
| onsite application/issuance process include laptops with attached     |
| card (EBT and driver's license) readers, handheld computers with card |
| readers, barcode scanning technology, electronic signature capture,   |
| and an online pre-registration application. The technologies are      |
| integrated into Florida's new automated application and issuance      |
| process:                                                              |
|                                                                       |
| -   The customer pre-registers by internet or telephone, which        |
|     includes providing a driver's license or state-issued             |
|     identification number. The information is saved in an electronic  |
|     application.                                                      |
|                                                                       |
| -   The customer arrives at the site and gets in the express line for |
|     pre-registered applicants.                                        |
|                                                                       |
| -   A worker using a laptop or handheld computer with card reader     |
|     swipes or enters the customer's driver's license number, which    |
|     calls up the client's information from pre-registration and       |
|     serves as an electronic signature.                                |
|                                                                       |
| -   The worker swipes the customer's EBT card to link it to their     |
|     electronic application.                                           |
|                                                                       |
| -   The worker places a bar-coded sticker on an EBT flier and voids a |
|     second sticker on the EBT manifest.                               |
|                                                                       |
| -   The customer is given their EBT card, training materials, and an  |
|     EBT informational flier with the bar code as a receipt.           |
|                                                                       |
| The customer leaves the application/issuance site. Their Notice of    |
| Eligibility, which also contains their PIN, is mailed to them upon    |
| approval of benefits. The PIN is also available via ARU or the Food   |
| For Florida website.                                                  |
+-----------------------------------------------------------------------+

**Inventory**

To help decrease the likelihood of employee theft and to provide
internal controls, prepare an inventory of supplies and equipment to
compare against the close-out inventory (see Chapter 4: [Closing out the
Application/Issuance Site](#ole_link66)).

The Supply Checklist in *Publications -- Application Issuance Site* can
be used effectively as an inventory sheet. Place a copy of the completed
inventory in the handbook in Chapter 4: [Closing out the
Application/Issuance Site](#ole_link66).

**Severe Weather Plan**

Depending on the local climate, facilities and the set up, the site
manager should develop a severe weather plan. In previous disasters,
large tents had to be evacuated during lightening storms and hundreds of
applicants moved to safety.

[]{#OLE_LINK54 .anchor}Human Comforts

**Important**

Addressing the human comfort needs of applicants is very important to
the disaster response effort. Applicants are unlikely to be able to come
prepared for a long wait and will need some of their basic needs
provided for at the application/issuance site. Not only must these
issues be addressed for humanitarian reasons, but also to decrease the
likelihood of crowd control problems.

**All Applicants**

Application/Issuance sites should offer the following for all
applicants.

-   Water

-   Protection from the elements

-   Bathrooms

-   Snacks, when feasible

-   Minor medical care, when feasible.

**Human Comforts Checklist**

Use the table below as a checklist. Add any additional ideas developed
during pre-disaster planning. A copy is included in *Publications --
Application/Issuance Site*.

+---+------------------+----------------------------------------------+
| [ |                  |                                              |
| ] |                  |                                              |
| { |                  |                                              |
| # |                  |                                              |
| O |                  |                                              |
| L |                  |                                              |
| E |                  |                                              |
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| L |                  |                                              |
| I |                  |                                              |
| N |                  |                                              |
| K |                  |                                              |
| 1 |                  |                                              |
| 0 |                  |                                              |
| 2 |                  |                                              |
| . |                  |                                              |
| a |                  |                                              |
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| c |                  |                                              |
| h |                  |                                              |
| o |                  |                                              |
| r |                  |                                              |
| } |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
| T |                  |                                              |
| a |                  |                                              |
| b |                  |                                              |
| l |                  |                                              |
| e |                  |                                              |
| 3 |                  |                                              |
| 2 |                  |                                              |
| . |                  |                                              |
| H |                  |                                              |
| u |                  |                                              |
| m |                  |                                              |
| a |                  |                                              |
| n |                  |                                              |
| C |                  |                                              |
| o |                  |                                              |
| m |                  |                                              |
| f |                  |                                              |
| o |                  |                                              |
| r |                  |                                              |
| t |                  |                                              |
| s |                  |                                              |
| T |                  |                                              |
| o |                  |                                              |
| o |                  |                                              |
| l |                  |                                              |
| s |                  |                                              |
| a |                  |                                              |
| n |                  |                                              |
| d |                  |                                              |
| A |                  |                                              |
| c |                  |                                              |
| t |                  |                                              |
| i |                  |                                              |
| o |                  |                                              |
| n |                  |                                              |
| s |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
+===+==================+==============================================+
| * | **Need**         | **Suggestions**                              |
| * |                  |                                              |
| ( |                  |                                              |
| ) |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
+---+------------------+----------------------------------------------+
|   | Water/Food       | -   Water tanker trucks with drinkable water |
|   |                  |                                              |
|   |                  | -   Several smaller water stations           |
|   |                  |                                              |
|   |                  | -   Small snacks available in case of        |
|   |                  |     illness                                  |
|   |                  |                                              |
|   |                  | -   Baby food [and formula]{.mark} for       |
|   |                  |     infants                                  |
|   |                  |                                              |
|   |                  | -   Red Cross canteen                        |
|   |                  |                                              |
|   |                  | -   Other volunteer-run canteen              |
|   |                  |                                              |
|   |                  | -   Support staff to man water station(s)    |
|   |                  |                                              |
|   |                  | -   Locate application/issuance site(s) near |
|   |                  |     mass feeding site(s)                     |
+---+------------------+----------------------------------------------+
|   | Protection from  | -   Tents for shade/protection from rain     |
|   | the Elements     |                                              |
|   |                  | -   Fans/heaters as appropriate              |
|   |                  |                                              |
|   |                  | -   Use indoor stadium/coliseum              |
|   |                  |                                              |
|   |                  | -   Run lines through hallways/breezeways    |
|   |                  |                                              |
|   |                  | -   Develop severe weather alternatives      |
+---+------------------+----------------------------------------------+
|   | Bathrooms        | -   Portable toilets located to provide some |
|   |                  |     privacy and accessible to the            |
|   |                  |     elderly/disabled.                        |
|   |                  |                                              |
|   |                  | -   Toilets serviced at least once a day     |
+---+------------------+----------------------------------------------+
|   | Medical Care     | -   Ambulance or rescue squad on-site        |
|   |                  |                                              |
|   |                  | -   Volunteer doctors, nurses, other health  |
|   |                  |     care workers to handle emergencies       |
+---+------------------+----------------------------------------------+

**Elderly and Disabled Provisions**

Special provisions should be made for the elderly and disabled to ensure
their safety and comfort.

+---+------------------+----------------------------------------------+
| [ |                  |                                              |
| ] |                  |                                              |
| { |                  |                                              |
| # |                  |                                              |
| O |                  |                                              |
| L |                  |                                              |
| E |                  |                                              |
| _ |                  |                                              |
| L |                  |                                              |
| I |                  |                                              |
| N |                  |                                              |
| K |                  |                                              |
| 1 |                  |                                              |
| 0 |                  |                                              |
| 1 |                  |                                              |
| . |                  |                                              |
| a |                  |                                              |
| n |                  |                                              |
| c |                  |                                              |
| h |                  |                                              |
| o |                  |                                              |
| r |                  |                                              |
| } |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
| T |                  |                                              |
| a |                  |                                              |
| b |                  |                                              |
| l |                  |                                              |
| e |                  |                                              |
| 3 |                  |                                              |
| 3 |                  |                                              |
| . |                  |                                              |
| E |                  |                                              |
| l |                  |                                              |
| d |                  |                                              |
| e |                  |                                              |
| r |                  |                                              |
| l |                  |                                              |
| y |                  |                                              |
| a |                  |                                              |
| n |                  |                                              |
| d |                  |                                              |
| D |                  |                                              |
| i |                  |                                              |
| s |                  |                                              |
| a |                  |                                              |
| b |                  |                                              |
| l |                  |                                              |
| e |                  |                                              |
| d |                  |                                              |
| P |                  |                                              |
| r |                  |                                              |
| o |                  |                                              |
| v |                  |                                              |
| i |                  |                                              |
| s |                  |                                              |
| i |                  |                                              |
| o |                  |                                              |
| n |                  |                                              |
| s |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
+===+==================+==============================================+
| * | **Need**         | **Suggestions**                              |
| * |                  |                                              |
| ( |                  |                                              |
| ) |                  |                                              |
| * |                  |                                              |
| * |                  |                                              |
+---+------------------+----------------------------------------------+
|   | Facilitate their | -   Choose sites that are served by public   |
|   | access to the    |     transportation. Notify local paratransit |
|   | site.            |     authorities of location of sites.        |
|   |                  |                                              |
|   |                  | -   Designate parking spots near site        |
|   |                  |     entrance for elderly or disabled use     |
|   |                  |     only.                                    |
|   |                  |                                              |
|   |                  | -   Make sure site is physically accessible  |
|   |                  |     to the elderly and disabled.             |
|   |                  |                                              |
|   |                  | -   Have staff or volunteers assist elderly  |
|   |                  |     or disabled clients from their cars/bus  |
|   |                  |     using wheelchairs or golf carts and      |
|   |                  |     escort them to the elderly/disabled      |
|   |                  |     area.                                    |
+---+------------------+----------------------------------------------+
|   | Reduce their     | -   Create a special                         |
|   | wait             |     waiting/eligibility/issuance             |
|   |                  |     determination area for use by the        |
|   |                  |     elderly and disabled only. Volunteers or |
|   |                  |     staff can help identify elderly or       |
|   |                  |     disabled persons in the regular queue or |
|   |                  |     their cars/bus and can escort them to    |
|   |                  |     the special waiting/eligibility/issuance |
|   |                  |     area where they can be seated during     |
|   |                  |     their wait and given quick service.      |
|   |                  |                                              |
|   |                  | -   Eligibility and issuance staff assigned  |
|   |                  |     to the elderly/disabled site should be   |
|   |                  |     equipped with large print, Braille, or   |
|   |                  |     audio versions of their State            |
|   |                  |     application materials. Staff should be   |
|   |                  |     prepared to provide especially attentive |
|   |                  |     service to clients who might need extra  |
|   |                  |     explanation of questions on the          |
|   |                  |     application, assistance filling in the   |
|   |                  |     application, or extra explanation of use |
|   |                  |     of the EBT card. States should consider  |
|   |                  |     having on hand a sign language           |
|   |                  |     interpreter to assist clients who        |
|   |                  |     require one.                             |
|   |                  |                                              |
|   |                  | -   Volunteers or staff should be on hand to |
|   |                  |     assist the elderly and disabled with     |
|   |                  |     completing their application and moving  |
|   |                  |     from their seat to the interview and     |
|   |                  |     issuance tables.                         |
+---+------------------+----------------------------------------------+
|   | Make them more   | -   Instead of assembling waiting elderly    |
|   | comfortable      |     and disabled persons into a standing     |
|   | while at the     |     queue, agencies should consider seating  |
|   | site.            |     the elderly and disabled in a covered    |
|   |                  |     waiting area, using tear-off numbers or  |
|   |                  |     any other appropriate system to keep     |
|   |                  |     track of each individual's place in the  |
|   |                  |     queue.                                   |
|   |                  |                                              |
|   |                  | -   States should arrange for heating or     |
|   |                  |     cooling equipment at the                 |
|   |                  |     elderly/disabled site if the community   |
|   |                  |     is experiencing temperature extremes.    |
|   |                  |                                              |
|   |                  | -   Station first-aid staff at the           |
|   |                  |     elderly/disabled waiting area or         |
|   |                  |     close-by for emergencies.                |
|   |                  |                                              |
|   |                  | -   Station volunteers or other human        |
|   |                  |     comforts staff in the elderly/disabled   |
|   |                  |     area to offer snacks and beverages to    |
|   |                  |     applicants and to periodically query     |
|   |                  |     applicants about any immediate human     |
|   |                  |     comforts needs they might have.          |
|   |                  |                                              |
|   |                  | -   Make sure that bathrooms are easily      |
|   |                  |     accessible from the elderly/disabled     |
|   |                  |     area (short distance, free of            |
|   |                  |     obstacles). States using portable        |
|   |                  |     toilets should arrange for an            |
|   |                  |     appropriate number of                    |
|   |                  |     handicapped-accessible portable toilets  |
|   |                  |     and hand washing units. Volunteers or    |
|   |                  |     human comforts staff may need to escort  |
|   |                  |     clients to the bathrooms.                |
+---+------------------+----------------------------------------------+
|   | Allow them to    | All regulations governing the use of an      |
|   | use an           | authorized representative for the SNAP apply |
|   | authorized       | to the D-SNAP, including:                    |
|   | representative   |                                              |
|   |                  | -   The authorized representative            |
|   |                  |     designation must be made in writing by   |
|   |                  |     the head of the household, the spouse,   |
|   |                  |     or another responsible member of the     |
|   |                  |     household.                               |
|   |                  |                                              |
|   |                  | -   State must verify the identity of the    |
|   |                  |     authorized representative and the        |
|   |                  |     applicant.                               |
|   |                  |                                              |
|   |                  | For complete regulations on this subject,    |
|   |                  | see CFR 273.2 (n).                           |
+---+------------------+----------------------------------------------+
|   | [Go to           | -   [States may operate the D-SNAP in a      |
|   | them]{.mark}     |     mobile unit, such as a bus or van,       |
|   |                  |     visiting neighborhoods where large       |
|   |                  |     numbers of elderly or disabled           |
|   |                  |     households reside.]{.mark}               |
|   |                  |                                              |
|   |                  | -   [States may send caseworkers to          |
|   |                  |     individual client homes, when resources  |
|   |                  |     allow it.]{.mark}                        |
+---+------------------+----------------------------------------------+

**Controlling Use of Special Provisions**

Evaluate and monitor crowd control implications of special provisions
made for elderly and disabled applicants. The table below addresses some
ways that special provisions for the elderly and disabled can raise
crowd control issues.

+---------------------------+------------------------------------------+
| **Table 34. Controlling   |                                          |
| Use of Special            |                                          |
| Provisions**              |                                          |
+===========================+==========================================+
| **Issue**                 | **Solution**                             |
+---------------------------+------------------------------------------+
| There are too many        | -   Issue a public service announcement  |
| elderly and disabled      |     suggesting that elderly and disabled |
| applicants to serve       |     applicants send authorized           |
| appropriately             |     representatives to apply for them.   |
|                           |                                          |
|                           | -   Issue a public service announcement  |
|                           |     asking community for more volunteers |
|                           |     to help with elderly and disabled.   |
|                           |                                          |
|                           | -   Increase issuance and/or             |
|                           |     certification staff for elderly or   |
|                           |     disabled clients.                    |
|                           |                                          |
|                           | -   Create separate area or site to      |
|                           |     serve elderly or disabled clients.   |
+---------------------------+------------------------------------------+
| People are feigning       | -   Have nurses/other medical            |
| illness, injury or        |     professionals screen for special     |
| disability to get faster  |     treatment.                           |
| service                   |                                          |
|                           | -   Make special/faster service less     |
|                           |     conspicuous to crowd in regular      |
|                           |     line.                                |
|                           |                                          |
|                           | -   Send people who do not fall into the |
|                           |     \"special\" group back to the        |
|                           |     \"regular\" line to reduce the       |
|                           |     likelihood that people will try to   |
|                           |     take advantage of the special        |
|                           |     service.                             |
+---------------------------+------------------------------------------+

[]{#OLE_LINK55 .anchor}Crowd Control

**Importance of Crowd Control**

Crowd control measures are critical to the operation of the
application/issuance site. In past disasters, very large crowds have
caused unanticipated problems, and even smaller crowds raise issues that
can be addressed in advance. Issues that should be addressed include:

-   Managing the crowd

-   Security

-   Regulating the number of people in line

**Specific Suggestions**

The table below lists some suggestions to address crowd control issues.

  ---------------------------------------------------------------------------------
  **Table 35.                        
  Crowd Control                      
  Strategies**                       
  -------------- ------------------- ----------------------------------------------
  **()**         **Issue**           **Some Suggestions**

                 Regulating the      Give out a certain amount of numbers each day
                 number of people in and tell people who don\'t get numbers to come
                 line (the length of back the next day (eligibility workers should
                 the wait)           be able to see 6 applicants an hour).

                                     Toward the end of the day, cut off the line
                                     for new-comers (security at the entrance,
                                     block off parking lot, put security officer at
                                     end of line.

                                     Post signs at certain places in the line
                                     estimating the wait from that point and
                                     listing hours and days of operation.

                                     Issue public service announcements suggesting
                                     that applicants come later in the day, later
                                     in the application period, come to another
                                     location, etc.

                                     Have volunteers screen for basic requirements
                                     (residence in area, ID, etc.) in line to
                                     reduce the risk of many people waiting who are
                                     not eligible.

                                     Direct applicants with special needs (e.g.
                                     elderly/disabled, non-English speaking,
                                     on-going participants) to appropriate lines
                                     for special handling.

                 Managing the crowd  Use ropes, barriers, or the facility\'s
                                     features to direct the crowd. Manage a long
                                     queue at a compact site with a zigzag queue,
                                     formed with ropes or other movable barriers.

                                     Post directional signs (e.g. IN/OUT, \"Wait
                                     Here Until Number is Called\").

                                     Use bullhorns or public address system to
                                     instruct/inform crowd. Use prerecorded, looped
                                     informational messages in multiple languages
                                     to inform the crowd about the application
                                     process, what will be needed, and the various
                                     areas located at the site.

                                     Arrange for the queue to move from one
                                     station/event to another to give clients to
                                     feel a sense of progress and reduce their
                                     anxiety.

                                     Post signs at intervals throughout the queue
                                     to alert clients to the estimated wait time
                                     from that point and to inform new arrivals of
                                     the queue's starting point. Combined, these
                                     will calm those with a long wait and
                                     discourage people from "cutting" in line.

                 Security            Give out numbers to reduce risk of arguments
                                     over someone\'s place in line.

                                     Have plenty of security officers present and
                                     visible.

                                     Keep SNAP benefit instruments out of sight of
                                     the crowd.
  ---------------------------------------------------------------------------------

**Section 4. Command Centers**

[]{#OLE_LINK40 .anchor}Overview

**Contents**

This section addresses issues involving the setting up and running of
the command centers.

[]{#OLE_LINK41 .anchor}Who Operates Command Centers

**General**

The State and Federal government may each operate their own command
centers, although there may be some overlap. The State and Federal
government may set up and operate command centers as indicated below.

+---------------------+------------------------------------------------+
| **Table 36.         |                                                |
| Government Command  |                                                |
| Centers**           |                                                |
+---------------------+------------------------------------------------+
| Government Agency   | > Command Center                               |
+---------------------+------------------------------------------------+
| FNS                 | > FNS may set up command centers at            |
|                     |                                                |
|                     | -   FNS headquarters                           |
|                     |                                                |
|                     | -   Regional Office.                           |
+---------------------+------------------------------------------------+
| FEMA                | In a major disasters and emergencies, FEMA may |
|                     | establish                                      |
|                     |                                                |
|                     | -   Regional Response Coordinating Centers     |
|                     |     (RRCC). FNS will provide ESF-11 staff if   |
|                     |     requested.                                 |
|                     |                                                |
|                     | -   Joint Field Office (JFO) FNS will provide  |
|                     |     ESF-11 staff if requested.                 |
|                     |                                                |
|                     | -   Disaster Field Office (DFO) in the State   |
|                     |     Emergency Services Facility which will     |
|                     |     operate as a joint State/Federal Center.   |
|                     |     FNS will provide ESF-11 staff if           |
|                     |     requested.                                 |
|                     |                                                |
|                     | -   Joint Information Center (JIC) to          |
|                     |     coordinate information. FNS will provide   |
|                     |     staff as appropriate.                      |
+---------------------+------------------------------------------------+
| State               | State government may establish                 |
|                     |                                                |
|                     | -   Emergency Services Facilities co-located   |
|                     |     with FEMA/FNS.                             |
|                     |                                                |
|                     | -   State Emergency Operations Center.         |
+---------------------+------------------------------------------------+
| State SNAP Agency   | The SNAP Agency may set up a command center at |
|                     |                                                |
|                     | -   the Emergency Services Facilities          |
|                     |                                                |
|                     | -   the State Emergency Operations Center      |
|                     |                                                |
|                     | -   the State or County/local SNAP office      |
+---------------------+------------------------------------------------+

[]{#OLE_LINK42 .anchor}General Options

**Concept of Command Center**

The spectrum of what a \"command center\" is and how it is operated can
range from a designated contact person operating out of his or her
office to a fully-staffed, centrally-located, conference center equipped
with computers and telephone banks which is shared by FEMA, FNS and the
State agency, and at which nightly meetings are held to discuss
developments in the disaster response.

The important factor in the command center concept is that it be a focal
point for information, to resolve issues, and get things done. Even if
there is no command center, there should be a clear identification of
contact people, lines of communication, etc.

**Activities to Coordinate**

The command center can coordinate D-SNAP efforts, as appropriate, which
might include the following activities:

  -------------------------------------------------------------------------
  **Table 37. General Command Center             
  Activities**                                   
  ---------------------------------------------- --------------------------
  **Coordinate**                                 **Reference**

  Fraud prevention efforts                       See Chapter 3:
                                                 [Coordinating Fraud
                                                 Prevention
                                                 Efforts](#OLE_LINK43) and
                                                 [Program Integrity/Fraud
                                                 Prevention](#OLE_LINK31)

  Public relations                               See Chapter 3: [Public
                                                 Information and
                                                 Outreach](#OLE_LINK30) and
                                                 [Coordinating Public
                                                 Relations](#OLE_LINK44)

  Staffing issues                                See Chapter 3:
                                                 [Staffing](#OLE_LINK14)
                                                 and [Coordinating Staff
                                                 Issues](#OLE_LINK45)

  Reporting                                      See Chapter 4:
                                                 [Reports](#OLE_LINK68)

  Acquisition/distribution of supplies           See *Publications:
                                                 Application Issuance Site*

  Hotline for problems at application/issuance   
  sites, policy issues, questions from           
  applicants, reports of fraud, etc.             
  -------------------------------------------------------------------------

**Location**

Consider the following factors to evaluate locations for command
centers:

Accessibility to staff, press

Appropriate proximity to disaster areas

Availability of adequate space, power, telephone lines

Security of site.

**Operation Varies With Disaster**

As with most other aspects of the disaster response, the operation of
command centers, and the interplay between command centers and
application/issuance sites will vary with the nature and scope of the
disaster.

[]{#OLE_LINK43 .anchor}Coordinating Fraud Prevention

**General**

The command center(s) can effectively coordinate fraud prevention and
program integrity efforts in the disaster area, and undertake any major
fraud prevention activities that would be beyond the scope of any single
application/issuance site.

**Specific Suggestions**

Any of the following actions could be undertaken at the command center
level. Add any ideas developed during pre-disaster planning.

+-------------------------------+--------------------------------------+
| **Table 38. Command Center    |                                      |
| Anti-fraud Activities**       |                                      |
+===============================+======================================+
| **Action**                    | **Examples**                         |
+-------------------------------+--------------------------------------+
| Coordinate with OIG and State | -   OIG could agree to send one      |
| agency investigative staff    |     staff member to each             |
|                               |     application/issuance site        |
|                               |                                      |
|                               | -   Audit and information tracking   |
|                               |     procedures could be developed    |
+-------------------------------+--------------------------------------+
| Coordinate with law           | -   State-wide security plan could   |
| enforcement                   |     be developed with State police   |
|                               |     officials                        |
|                               |                                      |
|                               | -   Benefit distribution security    |
|                               |     could be coordinated with        |
|                               |     armored carriers and national    |
|                               |     guard                            |
+-------------------------------+--------------------------------------+
| Set up and administer         | -   Application/issuance sites       |
| system(s) to check for        |     should use ongoing data system   |
| duplicate participation       |     if at all possible and be        |
|                               |     prepared to use other available  |
|                               |     computer databases and systems   |
|                               |     to determine if applicants are   |
|                               |     applying at more than one site   |
|                               |                                      |
|                               | -   Coordinate policy at             |
|                               |     application/issuance sites to    |
|                               |     ensure some check is made        |
+-------------------------------+--------------------------------------+
| Coordinate public relations   | -   Publicize investigations and     |
| efforts to combat fraud       |     arrests for fraud                |
|                               |                                      |
|                               | -   Publicize that fraud control     |
|                               |     measures are in place            |
|                               |                                      |
|                               | -   Set up toll-free number(s) for   |
|                               |     public to report fraud           |
+-------------------------------+--------------------------------------+
|                               |                                      |
+-------------------------------+--------------------------------------+
|                               |                                      |
+-------------------------------+--------------------------------------+

[]{#OLE_LINK44 .anchor}Coordinating Public Relations

**General**

The command center can serve as a focal point for information from the
disaster area on the D-SNAP, and can also coordinate public relations
and outreach activities at the application/issuance sites. Any of the
following public relations activities could be undertaken at the command
center. Add any ideas developed in pre-disaster planning.

+---------------------+------------------------------------------------+
| **Table 39. Command |                                                |
| Center Public       |                                                |
| Relations           |                                                |
| Activities**        |                                                |
+=====================+================================================+
| **Action**          | **Examples**                                   |
+---------------------+------------------------------------------------+
| Serve as focal      | -   Set up news conferences to make major      |
| point from disaster |     announcements                              |
| area on D-SNAP      |                                                |
|                     | -   Prepare press releases, public service     |
|                     |     announcements that affect whole disaster   |
|                     |     area (e.g. fraud measures, eligibility     |
|                     |     requirements)                              |
|                     |                                                |
|                     | -   Coordinate with FSIS to issue instructions |
|                     |     on food safety during the disaster         |
|                     |     recovery and to obtain copies of FSIS      |
|                     |     fliers on food safety in a disaster (see   |
|                     |     example of flier in *Publications --       |
|                     |     Application/Issuance Site* or at           |
|                     |     <http://www.fsis.usda.gov/fact_sheets/S    |
|                     | evere_Storms_and_Hurricanes_Guide/index.asp>.) |
|                     |                                                |
|                     | ```{=html}                                     |
|                     | <!-- -->                                       |
|                     | ```                                            |
|                     | -   Coordinate tours by government officials   |
|                     |     and media                                  |
|                     |                                                |
|                     | -   Contact advocate groups to assist with     |
|                     |     outreach and service to constituent groups |
|                     |                                                |
|                     | -   Respond to questions/concerns from media,  |
|                     |     public, Congress                           |
+---------------------+------------------------------------------------+
| Coordinate          | -   Identify staff that can issue press        |
| a                   |     releases, make statements, etc.            |
| pplication/issuance |                                                |
| site public         | -   Monitor media coverage and report to       |
| relations and       |     application/issuance sites                 |
| outreach efforts    |                                                |
|                     | -   Assist with press releases and other media |
|                     |     issues                                     |
+---------------------+------------------------------------------------+
| Coordinate with     | -   Provide press releases to State and        |
| State and local     |     county/local offices for input and/or for  |
| officials           |     those offices to release                   |
+---------------------+------------------------------------------------+
|                     |                                                |
+---------------------+------------------------------------------------+

**Lines of Authority**

Establish clear lines of authority as to which staff is authorized to
issue press releases and speak to the press. Instruct other staff to
refer questions to the appropriate person.

[]{#OLE_LINK45 .anchor}Coordinating Staff Issues

**Issues**

In some disasters, it may be helpful to allow the command center to
coordinate staffing issues centrally. Issues that can be effectively
coordinated, especially in large disasters, include:

Identifying and scheduling staff

Travel, hotel arrangements

Hours, time sheets

Training

Development of orientation packets.

**Office Manager**

In some disasters, a staff member has been assigned to act as an
\"office manager\" for the duration of the disaster. With staffing
coordination as the office manager\'s primary function, he or she can
most effectively perform these functions, in coordination with
decision-makers.

**Training**

The command center can coordinate input into training eligibility and
other site workers. (In some disasters it has been helpful to have FNS
staff on hand during that training.) The command center may also assist
by providing training materials or other references (e.g.,
Eligibility/Verification Chart).

[]{#OLE_LINK46 .anchor}Coordinating Reporting

The command center can coordinate the development of systems at the
application/issuance sites so that information is properly captured for
the daily and after-disaster reports. If appropriate, the command center
should consolidate the daily reports provided by each
application/issuance site and submit one report to FNS through the
region.

Please see Chapter 4, [Reports](#OLE_LINK68) for information on
reporting requirements.

**Chapter 4**

Post-Disaster Follow-Up

[]{#OLE_LINK65 .anchor}Overview

This chapter covers the period following the disaster application
period.

Closing Out the Application/Issuance Site

[]{#ole_link66 .anchor}

+-----------------+---------------------------------------------+------+
| **Table 40.     |                                             |      |
| Closing Out     |                                             |      |
| Checklist**     |                                             |      |
+-----------------+---------------------------------------------+------+
| **Subject**     | **Suggestions**                             | **   |
|                 |                                             | ()** |
+-----------------+---------------------------------------------+------+
| Files           | > Organize applicant files using State's    |      |
|                 | > standard practice                         |      |
|                 | >                                           |      |
|                 | > 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                                |      |
+-----------------+---------------------------------------------+------+
| Issuance        | > Reconcile issuance at all sites           |      |
| Records         | >                                           |      |
|                 | > Put issuance logs and records in boxes    |      |
|                 | > marked with site and box number           |      |
|                 | >                                           |      |
|                 | > Forward to State office                   |      |
+-----------------+---------------------------------------------+------+
| EBT Cards       | > Take inventory of EBT cards               |      |
|                 | >                                           |      |
|                 | > Return EBT cards to secure storage site   |      |
+-----------------+---------------------------------------------+------+
| Equipment       | > Take inventory of all equipment           |      |
|                 | > (computers, copiers, FAX machines,        |      |
|                 | > telephones) and other supplies, and       |      |
|                 | > compare with initial inventory            |      |
|                 | >                                           |      |
|                 | > Return equipment to lender, as            |      |
|                 | > appropriate                               |      |
+-----------------+---------------------------------------------+------+
| Staff           | -   Complete time sheets for all personnel, |      |
|                 |     including temporary personnel. Records  |      |
|                 |     are subject to 3 year retention.        |      |
+-----------------+---------------------------------------------+------+
| Building        | > Clean as much as possible                 |      |
|                 | >                                           |      |
|                 | > Maintain security until site is emptied   |      |
+-----------------+---------------------------------------------+------+

Returning to the Regular SNAP

**Evaluation of Need**

Near the end of the application period, State agencies should note the
number of people left to serve and determine whether or not to extend
the D-SNAP or return to the regular program. For guidance on extending
the D-SNAP, see Chapter 3: [Requests to Modify, Extend, or Expand the
D-SNAP](#OLE_LINK39). For guidance on transitioning to the regular
program, see below.

**Transitioning to the Regular SNAP**

In past disasters, most State agencies have found that the D-SNAP
adequately served the population affected by the disaster. Upon
completion of the D-SNAP, States generally return immediately to the
regular program.

After extraordinarily severe disasters, State agencies may need to
operate with waivers to the regular program to ease the transition from
the D-SNAP to the regular program for the State agency and clients.
Although waivers to transition to the regular SNAP are not routinely
approved by FNS, States experiencing extraordinarily severe conditions
may wish to consider them. States applying for transitional waivers must
provide adequate justification for the need for transitional waivers in
their request to FNS and invocation of disaster authority. Please see
*Publications -- Waivers* for transitional waivers that [can help State
agencies transition to the regular SNAP.]{.mark}

**Waivers**

There are situations which might warrant waivers of the regulations
governing the regular program following the D-SNAP.

  --------------------------------------- -------------------------------
  **Table 41. Post-D-SNAP Waivers**       

  **Situation**                           **Example**

  There is a large population [of         The State agency could suspend
  households that could not be eligible   [work registration]{.mark}
  for the regular SNAP because of         requirements.
  inability to meet work requirements     
  during the disaster recovery            
  period.]{.mark}                         

  The State agency needs administrative   The State agency could apply to
  relief. For example, the State has had  extend certification periods to
  to displace workers to assist in        ease the eligibility workers\'
  disaster relief efforts.                administrative burdens.
  --------------------------------------- -------------------------------

Please see *Publications - Waivers* for a list of transitional waivers
to the regular program that FNS has granted to States in the past. The
list is not exhaustive, so States should approach FNS with requests for
waivers not listed if they predict they will help the State effectively
transition to the regular program.

[]{#OLE_LINK68 .anchor}Reports

State agencies are responsible for compiling and transmitting the
following reports in a timely fashion:

**[Daily SNAP Report]{.mark}**

[Every day, starting with the first day the D-SNAP is operated, the
State agency shall submit to their FNS Regional Office a report on
applications processed and benefits issued. Daily reports are used by
FNS and other Federal agencies to monitor program process and are useful
to the State agency and FNS as the basis for judging whether or not
extensions of the program are necessary.]{.mark}

[]{.mark}

[If nothing different is specified in the memorandum approving the
D-SNAP request, the daily report shall contain the following
elements:]{.mark}

-   [Number of new households approved]{.mark}

-   [Number of ongoing households receiving supplements]{.mark}

-   [Number of new persons approved]{.mark}

-   [Number of ongoing persons approved for supplements]{.mark}

-   [Number of new households denied]{.mark}

-   [Value of new benefits approved]{.mark}

-   [Value of supplements approved]{.mark}

-   [Average benefit per new household]{.mark}

-   [Average benefit per ongoing household]{.mark}

[]{.mark}

[The State agency should begin submitting reports to their FNS Regional
Office on the day after the first day the D-SNAP is operated and should
continue submitting the reports until all applications are processed.
If, in the first few days of program operation the State has no
processed applications yet to report, they should still send a negative
report to their FNS Regional Office.]{.mark}

[]{.mark}

[**Note**: FNS now requires State agencies to use the Excel daily
reporting template entitled *Publications -- D-SNAP Daily Reporting
Sheet for submission of daily reports*]{.mark}.

[]{.mark}

**[FNS-292]{.mark}**

[Within 45 days of the termination of a D-SNAP operation, the State
agency shall submit its final disaster figures on the FNS-292 Report of
Food Stamp Benefit and Commodity Distribution for Disaster Relief in the
Food Programs Reporting System (FPRS).]{.mark}

[]{.mark}

[The FNS-292 should contain the following issuance data for D-SNAP
operations:]{.mark}

-   [*Number of Households* -- new households issued D-SNAP
    benefits]{.mark}

-   [*Total Number of Persons Assisted* - new persons issued D-SNAP
    benefits]{.mark}

-   [*Number of Certified Persons* - ongoing households issued
    supplements]{.mark}

-   [*Value of Benefits Issued* - total of benefits issued to new
    households and supplements issued to ongoing households.]{.mark}

[]{.mark}

[The FNS-292 report should *not* include the value of any replacements
issued.  States should report the value of replacements on the FNS-388
Monthly Issuance Report.]{.mark}

**FNS-388**

The Monthly Issuance Report (FNS-388) shall reflect disaster issuance
and participation figures, including replacement benefits.

**Other Reports**

Other regularly-submitted issuance and benefit inventory reports shall
also reflect disaster issuance.

[]{#OLE_LINK69 .anchor}Claims and Restored Benefits

Note: in general, States should follow their FNS-approved procedures for
establishing claims.

**Establish Claims**

The State agency shall establish claims and issue repayment demand
letters for over-issuances which are the result of:

-   Intentional Program Violations (IPVs)

-   Inadvertent household errors

-   Administrative errors

**When to Establish Claims**

Claims shall be established as soon as possible, but no later than six
months after the close of the disaster operation.

**Restored Benefits**

Pursuant to 7 CFR 273.17, the State agency shall restore to households
the amount of SNAP benefits that were lost:

-   Due to an agency error

-   When a denial of benefits is subsequently reversed

The accountability system must clearly indicate that an issuance was a
restored benefit.

[]{#OLE_LINK70 .anchor}Fair Hearings

**Who May Request**

Any household who applied for D-SNAP benefits and were denied benefits
may request a fair hearing.

**Who May Not Request**

Households who never applied for the D-SNAP for any reason 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 expedited supervisory review which in no way shall interfere
with the applicant\'s right to a fair hearing.

**Withdrawal of Request**

If a household wants to withdraw its request for a fair hearing, it may
do so verbally or in writing. Verbal withdrawals must be followed up by
a written confirmation of the verbal withdrawal to the State agency.

**Fair Hearing Reporting**

The number of fair hearings is reported on the FNS-366B, Program
Activity Statement.

[]{#OLE_LINK71 .anchor}Post-disaster Review

**[Review]{.mark} [Components]{.mark}**

[The State agency shall conduct both a comprehensive review of general
program performance and reviews of individual cases. The State agency
should then conduct a problem analysis on the review findings and
compile and transmit to their FNS Regional Office a post-disaster review
report.]{.mark}

[]{.mark}

**[Review Methodology]{.mark}**

***[Comprehensive Review]{.mark}***

[For the following subjects, the State should describe the systems or
methods employed and document any major problems encountered and the
interventions used to solve those problems: certification systems, fraud
control, issuance, public information and outreach, program
accessibility, and security.]{.mark}

[]{.mark}

***[Individual Reviews]{.mark}***

[State must review a random sample of 0.5 percent of new cases (not
ongoing cases that received supplements), up to a maximum of 500 cases
with a minimum sample size of 25 cases. Although State agencies may wish
to consult with an FNS statistician when devising a sampling plan, it is
not required by FNS.]{.mark}

> []{.mark}

[States also still must review 100 percent of all approved State agency
(as defined in 7 CFR 271.2) employee cases. States have the option of
reviewing employee cases before or after the cases are certified. States
also have the option of reviewing cases of any other State employees,
but are not required to do so.]{.mark}

[]{.mark}

[For both samples, no cases selected for review should be dropped for
any reason. The State agency should report information gathered even
from incomplete case reviews. We will not require the State agencies
alter their sample size even if a large number of case reviews are
incomplete; however, State agencies may find it prudent to do so in the
interest of good management.]{.mark}

[]{.mark}

[Essential components of individual reviews are:]{.mark}

[]{.mark}

1.  [[*Case Record Review*:]{.underline} States should review the
    client's application for problems (such as missing or inconsistent
    information, lack of signature, etc.) and recalculate their
    eligibility using the information given. Additionally, the review
    should note any information the client has given on their place 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 query clients about their place of employment at
    the time of the disaster and record that information on the
    application.]{.mark}

[]{.mark}

2.  [[*Verification*:]{.underline} States should focus their review on
    identifying clients who failed to report accurately information
    known to them about their circumstances, such as residency, food
    loss, income sources, or loss of work, not on clients who could not
    accurately project their circumstances for the disaster benefit
    period.]{.mark}

[]{.mark}

-   [*Residency*: The State should verify that the client lived in the
    disaster area defined for that D-SNAP. Residency can easily 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.]{.mark}

-   [*Food Loss*: If the State agency allowed food loss as a sole
    qualifier for D-SNAP eligibility, they should confirm that the
    household resided in a geographical area that experienced power
    outages lasting longer than four hours, experienced flooding, or
    otherwise was 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.]{.mark}

-   [*Income:* Verification of income is intended to hold households
    accountable for accurately reporting sources of income or work loss
    that were *known* to them at the time of the disaster, not to hold
    households responsible for not being able to accurately predict
    their future income/employment during the benefit period.]{.mark}

> []{.mark}
>
> [To help in detecting unreported sources of income, States should
> perform data matching for each selected case, which should include
> wage matching, income and eligibility verification systems (IEVS)
> 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. States do
> not need to wait for wage data to become current in order to perform
> the wage match, as wage matches are generally two quarters behind. At
> the time of the case reviews, the State should use the wage matching
> data they have available to them.]{.mark}
>
> []{.mark}
>
> [If the wage match shows that the client was employed in the months
> prior to the disaster, they 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 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.]{.mark}
>
> []{.mark}
>
> [If an IEVS 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. It has been our experience 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, may well be delayed or unavailable. If it
> appears that the client gave their best prediction of their
> circumstances, then the reviewer should accept the household's
> statement of income.]{.mark}
>
> []{.mark}

-   [*Disaster-related Expenses:* States do not need to verify any
    disaster-related expenses, as clients are not required to retain
    receipts for their disaster-related expenses and therefore likely
    will not be able to verify their expenses.]{.mark}

> []{.mark}

3.  [[Client Interview]{.underline}: The purposes of the interview are
    to review the client's statements on their D-SNAP application,
    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
    conducting either telephone or face-to-face interviews for all or
    any clients.]{.mark}

[]{.mark}

> [States must make a reasonable attempt to contact the client to
> schedule the interview, using the resources available to them in the
> normal course of business, such as internet searches, data brokering
> services, credit reporting services, etc. States may conduct the
> interview at the same time as a scheduled certification interview for
> the regular SNAP, if the household is now participating in the regular
> SNAP. If the client cannot be reached or does not attend the
> interview, the State should continue to review the case and report the
> results. Some State agencies wanted FNS to prescribe a certain type of
> contact or a certain number of contacts, such as three attempts by
> telephone, before abandoning the attempt to contact and interview the
> household. We believe that such detailed requirements are impractical
> and unnecessary. FNS has listened to State agency requests for
> reduction in the number of D-SNAP case reviews. Consequently, FNS
> expects that State agencies will exercise due diligence in their
> attempts to complete these reviews and will produce meaningful
> results. We believe that reviewers will expend the appropriate level
> of resources so that most reviews will be completed.]{.mark}
>
> []{.mark}

***[Problem Analysis]{.mark}***

[After completing the individual reviews, the State agency shall conduct
a problem analysis, which should include the number of cases with
problems and should be broken down by D-SNAP project area, the type of
household (State agency employee or general public cases), the nature of
the problem (client or worker-caused; income- or resource-related; math
error, etc.), the number of case reviews that were not complete due to
inability to locate the client or client failure to cooperate, and the
number of cases in which recipient claims were established.]{.mark}

[]{.mark}

***[Post-disaster Report]{.mark}***

[State agencies shall compile and submit to their FNS Regional Office a
report containing the results of the comprehensive review and the
individual reviews within 6 months of the close of each D-SNAP
operation. FNS appreciates that States experiencing catastrophic
disasters may be challenged to deliver their post-disaster report within
6 months, so we will negotiate extensions of due dates with these States
agencies on a case-by-case basis.]{.mark}

**Changes to the State Agency D-SNAP Plan**

The State agency shall [update their State Agency D-SNAP Plan to reflect
lessons learned during the post-disaster review process.]{.mark}

**[Sample]{.mark}**

[A sample Post-disaster Review Report can be found in *Publications --
Post-disaster Review Reports.*]{.mark}

[]{#OLE_LINK72 .anchor}After-action Report

**After-Action Report**

After the disaster and formal post-disaster review activity is over,
agencies may want to conduct an informal, internal review of its
disaster response and compile an after-action report. The report can
contain:

-   \"Lessons learned\"

-   Specific additions/changes to the State\'s disaster plan

-   Recommended changes to internal policies

-   Recommended additions or changes to this handbook.