DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Food and
Nutrition
Service
DATE: October 7, 2022
1320 Braddock Place
Alexandria, VA
22314
SUBJECT: Disaster Supplemental Nutrition Assistance Program (D-SNAP)
Florida - 19 Counties – Approval – FY2023

TO: Willie Taylor

Regional Administrator
Southeast Regional Office

The Food and Nutrition Service (FNS) approves the Florida Department of Children
and Families’ (DCF) request to operate D-SNAP in 19 counties due to the impact of
Hurricane Ian which made landfall in Florida on September 28, 2022. President Biden
issued a major disaster declaration designating 9 counties as eligible for Federal
individual assistance on September 29, 2022. This declaration was later amended on
September 30 through October 4, 2022, to bring the total eligible for Federal individual
assistance to 19 counties. FNS approves Florida’s request to operate in the following 19
counties: Charlotte, Collier, DeSoto, Flagler, Hardee, Highlands, Hillsborough, Lake,
Lee, Manatee, Orange, Osceola, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns,
and Volusia.

The State agency estimates that approximately 742,845 new households may be eligible
for up to $512,955,721 in D-SNAP assistance, and that approximately 612,724 ongoing
SNAP households may be eligible for up to $65,365,849 in supplemental benefits.

The State agency will offer a hybrid model that includes in-person and virtual D-SNAP
operations. FNS is approving the use of virtual operations to facilitate the safety of
participants due to COVID-19. The State agency will allow applicants to apply using an
interactive telephone interview once the pre-registration has been submitted, and the
State will accept applications at an on-site facility in each county. If the applicant calls
to complete an interview and has not completed the pre-registration, the worker will ask
the applicant to call back once the pre-registration is completed.

FNS appreciates the State agency’s efforts to provide impacted households with
temporary access to food assistance, and given the constraints of COVID-19, approves
the novel telephonic procedure proposed for this specific request. FNS emphasizes that
use of telephone interviews in D-SNAP remains a novel practice that may pose risks to
the D-SNAP application process, customer service, and timely issuance of benefits.
Given these risks, FNS is approving this request with specific additional data
requirements, detailed below. FNS further notes that, absent the presence of COVID-19
or a similar pandemic, this novel procedure may not be approvable for future D SNAP
operations in Florida or elsewhere.

Additionally, DCF has requested to operate the D-SNAP using a novel operation and
schedule. It will operate in three phases with periods consisting of a pre-registration,
telephonic interview, and in-person application. The pre-registration period will begin 3

USDA is an Equal Opportunity Provider, Employer and Lender

DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 2

days prior to each phase and remain open for 7 consecutive days. After the first three days of
pre-registration, the State agency will begin the telephonic interview period of 4 days. In-
person applications will then occur on different 3-day periods after the telephonic interview
period closes and the pre-registration will re-open during the three days of on-site operation.

As of this approval, DCF has not identified all in-person sites and schedules in all phases. FNS
appreciates that DCF does not consider complete site identification at this point in its disaster
response as feasible. We are committed to working with DCF to ensure that families and
individuals have meaningful access to an in-person option, and to support program integrity
and customer service. As described below, DCF has committed to providing additional
information on scheduling and site locations in support of that goal.

FNS is approving this operation and its schedule due to the immediate needs of households
impacted by power outages, flooding, structural damage, and displacement from permanent
homes caused by Hurricane Ian. FNS notes such an operation and schedule may not be
approvable for future D-SNAP operations.

Furthermore, FNS reminds DCF of requirements related to merit personnel. Only State merit
staff can conduct the interview, screen for duplicate participation, and determine DSNAP
eligibility.

Conditions of Approval

FNS approves the State agency’s request and proposed alternative procedures detailed below,
subject to the following conditions:

 Regarding the requested novel procedure for telephone interviews, the State agency
will:
o Comply with additional evaluation and reporting measures outlined in the
Reporting section of this approval to determine the feasibility of these models
for future D-SNAP operations.
o Have sufficient staff to process applications and conduct telephone interviews in
a timely manner, with the ability to augment staffing as needed.
o Have a designated phone number for D-SNAP applicants.
o Notify FNS if the State changes these approved processes in any way or
encounters any issues with the approved processes.

 Application sites must be located in areas accessible by major roads and thoroughfares
that are passable and safe to travel.

 The State agency will ensure that all public communications and press materials provide
clear, accurate, and updated information about application site locations and hours of
operation.
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 3

 The State agency will ensure that each application site has human comforts (such as
water, and restroom facilities), reasonable accommodations for the elderly and disabled,
and sufficient security.

 Commercial channels of food distribution have been restored in the requested areas, and
there are a sufficient number of authorized retailers open and available to redeem D-
SNAP benefits.

FNS reserves the right to direct the State agency to modify or suspend any of these novel
procedures or any component of the D-SNAP operation in the event any issues emerge that
pose a significant risk to operations, access, including reasonable accommodations for the
elderly and disabled, or integrity.

Disaster Area

This approval is limited to the following 19 approved counties: Charlotte, Collier, DeSoto,
Flagler, Hardee, Highlands, Hillsborough, Lake, Lee, Manatee, Orange, Osceola, Pinellas,
Polk, Putnam, Sarasota, Seminole, St. Johns, and Volusia.

If the State agency wishes to expand D-SNAP to other counties that subsequently receive a
Presidential Disaster Declaration for Individual Assistance, it must submit a formal
modification request to FNS for approval.

Application Period and Sites

DCF has requested to stagger the application periods by county between October 13, 2022, and
November 22, 2022, to ensure adequate staffing capacity at each site. DCF is still working to
secure all application sites but has provided the tentative schedule of operations.

The State agency will operate the D-SNAP in 3 phases, as detailed below:

 Phase One: Charlotte, Collier, Lee, Sarasota, Desoto, Hardee, and Polk County will
accept telephonic applications once the pre-registration has been submitted and at an
on-site facility in each county during these periods:
o Pre-registration: October 10, 2022 through October 16, 2022
o Telephonic: October 13, 2022 through October 16, 2022
o On-Site: Between October 21, 2022 and November 22, 2022

 Phase Two: Pinellas, Orange, Manatee, Putnam, St. Johns, and Highlands County will
accept telephonic applications once the pre-registration has been submitted and at an
on-site facility in each county during these periods:
o Pre-registration: October 17, 2022 through October 23, 2022
o Telephonic: October 20, 2022 through October 23, 2022
o On-Site: Between October 27, 2022 and November 9, 2022
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 4

 Phase Three: Flagler, Osceola, Seminole, Hillsborough, Volusia, and Lake County will
accept telephonic applications once the pre-registration has been submitted and at an
on-site facility in each county during these periods:
o Pre-registration: October 24, 2022 through October 30, 2022
o Telephonic: October 27, 2022 through October 30, 2022
o On-Site: Between November 3, 2022 and November 20, 2022

For each phase, applicants may submit a pre-registration using the State’s online portal for 7
consecutive days. Following the first 3 days of pre-registration period, the State agency will
then conduct interviews via telephone to complete applications for 4 days. The pre-registration
will re-open for three days of on-site operation. FNS strongly encourages the State agency to
not have different on-site dates within each phase. FNS also encourages the State to have strict
pre-registration hours during the on-site operation and to have the on-site operation as close as
possible to when the telephonic interview period ends.

The State agency will consider the day an applicant completes their interview with State merit
eligibility staff as the filing date of the application, for in-person and virtual operations. FNS
notes this is the same standard used in traditional on-site D-SNAP operations, as well as recent
D-SNAP operations approved by FNS in other States with virtual application procedures.

Applicants will only be able to apply once they complete a pre-registration for D-SNAP via
telephone or at the application site in the county they live or work within that specific phase.
Once a phase is closed, applicants from that phase will not be allowed to apply in another
county.

If more than 7 days are needed to serve applicants in any of the affected counties, the State
agency may request an extension of the application period, with appropriate justification,
subject to FNS review and approval.

In-Person Operation
As mentioned above, FNS believes it is critical to identify all sites that will conduct in-person
operations as soon as possible. At the time of this approval, DCF has not provided complete
information on their sites and schedules for each phase. DCF has agreed to provide FNS a
revised schedule of operations once it has been finalized. Additionally, FNS understands that
the tentative schedule may change based on DCF's ability to procure sites and adequate staff for
D-SNAP operations. The State agency will notify FNS of any changes to this schedule due to
conditions affecting public safety or the ability to procure appropriate application sites in a
county.

DCF will ensure each site has the ability for applicants to complete pre-registration and paper
applications. The State agency will identify potential sites prior to each in-person operation.
DCF will consider factors such as site size and location, impact to the community, ease of
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 5

access, availability of adequate parking, availability, and ability to provide sufficient crowd
control. Upon selection of a location, DCF will consider how to serve elderly and disabled
applicants best.

Final Telephonic Phase

The State agency indicated in its supporting documents that it may need a final telephonic
event for elderly and disabled individuals who were unable to attend an on-site event. Should
the need for a specialized phase arise for this vulnerable population, FNS encourages the State
agency to formally request this operation near the end of their final phase. At that time, DCF
should provide FNS with appropriate justification and potential impact.

Merit Staff Requirements

Non-merit workers may not be used to perform any merit staff functions, including review of
applicant information prior to interviews, conduct interviews, eligibility determinations, or
duplicate participation checks but they can provide extensive support to staff and applicants.
Non-merit staff are permitted to act in the following capacities: translator/interpreter, greeter,
application assistant, pre-screener, and crowd control.

Approval of this D-SNAP operation allows DCF to use non-merit staff to serve as application
assistants to complete the pre-registration on-site. FNS will not permit the State agency to use
non-merit staff to conduct interviews confirming the accuracy of information submitted in pre-
registrations. The State agency agreed to this during meetings with FNS on October 5 and
October 6, 2022.

Benefit Period

For all counties providing D-SNAP, the State agency will determine eligibility based
on a household’s income, resources, disaster expenses, and other circumstances
from September 27, 2022, through October 26, 2022.

The State agency will certify eligible households for one month based on the FNS Fiscal Year
2023 Disaster Gross Income Limits (DGIL). The State agency will issue the maximum
allotment based on the Fiscal Year 2023 Maximum Allotments and Deductions, as updated
October 1, 2022.

Other Eligibility Criteria

 Only households that resided or worked in the approved county at the beginning of the
benefit period are eligible to apply.

 Household composition as it existed at the beginning of the benefit period (September

27, 2022) will be used in determining eligibility and benefits.
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 6

 Households that experienced food loss alone as their only disaster expense are eligible
to apply.

 If a household has received or expects to receive reimbursement for disaster expenses

during the benefit period, only the net amount of expenses paid or anticipated to be paid
shall be deducted.

Ongoing Households

Disaster supplements provide for equity in disaster assistance between new D-SNAP
households and ongoing Supplemental Nutrition Assistance Program (SNAP) households, as
supplements bring the benefits of ongoing SNAP households up to the maximum allotment for
their household size.

The State agency requested to issue automatic disaster supplements to all ongoing SNAP
households in the 19 approved counties. Based on the disaster impact data provided, FNS
approves this procedure for the following 16 counties: Charlotte, Collier, DeSoto
Flagler, Hardee, Highlands, Hillsborough, Lee, Manatee, Orange, Pinellas, Polk, Putnam,
Sarasota, Seminole, and Volusia. FNS will consider and evaluate any further data or supporting
documentation the State agency wishes to provide prior to implementation and may modify this
procedure if justified.

In the remaining 3 counties of Lake, Osceola, and St. Johns, the State agency may issue
automatic disaster supplements to ongoing households that have requested replacement benefits
since the disaster occurred, as well to those that submit a signed affidavit attesting to their
disaster expenses.

Ongoing SNAP households that already receive the maximum monthly allotment for their
household size are not eligible for disaster supplements.

Electronic Benefit Transfer (EBT) & Issuance

Although the State agency will make all efforts to process applications, issue benefits and
distribute EBT cards to eligible households who apply for D-SNAP within 3 days (72 hours),
consistent with FNS’ D-SNAP Guidance, FNS acknowledges that the continued impact of
COVID-19 along with the damage to infrastructure may cause delays.

The State agency maintains that it has a sufficient supply of EBT cards to issue to all
anticipated D-SNAP applicants. The State agency will carefully monitor the cardstock; the
number of applications received; and the number processed each day in order to arrange for the
production and delivery of additional cards if needed. The State agency will notify FNS
immediately should difficulties arise with card stock volume or production.
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 7

Quality Control and Program Integrity

The State agency will adhere to the verification requirements in FNS’ D-SNAP Guidance to the
maximum extent possible, which include:

 Mandatory verification of identity for the head of household.

 Where possible, verification of residency and loss of income or inaccessibility of
resources due to the storm.
 If questionable, verification of household composition and food loss used as a disaster
expense.
 For telephonic applications, applicants submit identity verification via the State’s online
portal.

The State agency will check for duplicate participation in SNAP and D-SNAP before
authorizing benefits for all household members. If this reveals an inactive SNAP case during
the D-SNAP benefit period, the State can use the identity verification associated with that case
to verify identify for the D-SNAP head of household.

The State agency may delay issuing benefits to verify questionable information or if it suspects
fraud, but for no more than 7 days from the date of application. Applicants whose identify
cannot be verified during the telephonic interview must be advised they have 7 days to provide
verification by submitting to their local DCF office. FNS does not approve the State agency’s
plan to mail a pending notice of verification required because of the potential mail delays.

The State agency must conduct anti-fraud efforts and inform households of the consequences of
committing fraud.

The State agency will review 100 percent of all applications from permanent, temporary, and
contract State agency employees who are involved with administration and operation of the D-
SNAP. These results must be included in the Post-Disaster Report.

Quality Control will exclude D-SNAP cases from its samples. However, the State agency will
conduct individual case reviews, as detailed below, to ensure D-SNAP eligibility and
allotments were correctly determined.

Reporting

During the application period, the State agency will provide daily reports, as well as a summary
report after operations end, with the following information for each approved county:

 The number of pre-registrations received.

 The number of households and persons approved for D-SNAP.
 The amount of disaster benefits issued to approved households.
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 8

 The number of telephone applications received.

 The number of on-site paper applications received.
 The number of households denied based on their eligibility.
 The number of pending cases remaining each day.
 The average issuance amount per household.
 The number households, persons and amount of supplements issued to ongoing
households.

The State agency must also provide FNS with additional daily data on its telephonic interview
operations including, but not limited to:

 Average wait time for an interview.

 Number of calls answered.
 Number of calls abandoned.
 Average call completion time.
 Number of client complaints regarding difficulty obtaining an interview.
 Number of fair hearing requests for telephonic interviews.
 Information regarding card issuance, such as number of cards picked up, number of
cards mailed, number of cards returned in the mail.

No later than 45 days after the close of D-SNAP operations, the State agency will submit an
FNS 292B report in the Food Program Reporting System (FPRS).

In addition, the State agency must report any replacement benefits issued to ongoing SNAP
households on the FNS-46 form in FPRS within 90 days after issuance.

No later than 6 months after the close of operations, the State agency will provide a
comprehensive Post-Disaster Report to the FNS Southeast Regional Office which will include
individual case reviews, problem analysis, and proposed improvements to the State’s D-SNAP
plan.

Given the initial information FNS has collected on the effectiveness of virtual D-SNAP
operations run by the State thus far, FNS is updating its methodology for determining the
number of case reviews for virtual D-SNAP operations. The State agency must review 1
percent of D-SNAP cases (no fewer than 50 cases but no more than 1,000 cases) to
ensure D-SNAP eligibility and allotments were determined correctly.
DocuSign Envelope ID: 6DE219A9-25ED-4538-977C-E8B703DE5002

Willie Taylor
Page 9

Authority

FNS approves this D-SNAP under the authority of section 412 of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act and section 5(h) of the Food and Nutrition Act
of 2008.

Sincerely,

Lizbeth Silbermann
Acting Associate Administrator
Supplemental Nutrition Assistance Program