COVID-19, Supplemental Nutrition Assistance Program Online Purchasing — Inspection Report 27801-0003-22
Summary
USDA Office of Inspector General inspection report 27801-0003-22, dated August 2021, on controls over the SNAP Online Purchasing Pilot during the pandemic. The Food and Nutrition Service began the pilot in 2014, and online transactions grew from more than $18.9 million to more than $1.5 billion cumulatively. The report finds the agency used the same approval criteria when adding States and retailers but had not updated its pilot risk assessment, leaving it open to fraud and abuse. It also finds retailers' privacy protections relied on their own attestation, and recommends an updated risk assessment and monitoring controls.
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“COVID-19, Supplemental Nutrition Assistance Program Online Purchasing — Inspection Report 27801-0003-22.”
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United States Department of Agriculture
COVID-19—Supplemental Nutrition
Assistance Program Online
Purchasing in Response to the
Coronavirus Disease 2019
Inspection Report 27801-0003-22
August 2021 OFFICE OF INSPECTOR GENERAL
COVID-19—Supplemental Nutrition Assistance
Program Online Purchasing in Response to the
Coronavirus Disease 2019
Inspection Report 27801-0003-22
OIG reviewed FNS’ controls over the SNAP Online Purchasing Pilot in response to
the COVID 19 pandemic.
OBJECTIVE WHAT OIG FOUND
Our objectives were to address In 2014, the United States Department of Agriculture’s (USDA)
the following questions: (1) Food and Nutrition Service (FNS) initiated a Supplemental
What criteria did FNS use to Nutrition Assistance Program (SNAP) Online Purchasing Pilot
approve States and retail food
(pilot), which would allow households to make online purchases
stores to accept SNAP benefits
through online transactions
using SNAP benefits. The pilot requires online transactions to
during COVID‑19? (2) What be secure, private, easy to use, and provide similar support to
risks has FNS identified during that found for SNAP transactions in a retail store. In response
the transition to allow SNAP to the coronavirus disease 2019 (COVID-19) pandemic, FNS
benefits online? (3) What expanded the pilot from 6 States in March 2020 to 46 States
controls does FNS have to by the end of December 2020. Between March and December
ensure retail food stores meet 2020, the total value of online SNAP purchase transactions
online transaction program increased from more than $18.9 million to more than $1.5
requirements? billion cumulatively.
We found that FNS used the same approval criteria it used for
the original pilot selections when adding additional States and
REVIEWED retailers. We also identified that FNS has not updated its risk
assessment of the SNAP Online Purchasing Pilot since creating
We reviewed FNS’ process for the pilot in 2014. Without updating its risk assessment to
approving States and retailers assess new risks in the rapidly evolving e-commerce market,
through June 2020, and analyzed the pilot could be susceptible to fraud and abuse—particularly
SNAP Online Purchasing as FNS rapidly expanded the pilot between March and
Pilot data related to online December 2020.
transactions through
December 2020. Finally, although we found FNS had established criteria and
program requirements for retailers to be eligible to participate
in the pilot, FNS did not establish controls to effectively
RECOMMENDS monitor, evaluate, or document how participating retailers
protect SNAP participants’ online personal information.
FNS should perform an updated
Instead, the agency relied on retailers’ assurance and
risk assessment and establish
a policy to periodically perform
attestation that online retailers will protect the privacy of
assessments to identify any SNAP participants’ information. In order to proactively
new risks and re-evaluate ensure that SNAP participants’ personal information is not
existing ones. FNS should also compromised, sold, shared, or given to any third party without
establish controls for monitoring, authorization, FNS needs to better monitor, evaluate, and
evaluating, and documenting document retailers’ compliance with safeguarding participants’
retailers’ requirements personal information.
pertaining to the use of
SNAP participants’ personal FNS generally concurred with our findings and
information.
recommendations, and we accepted management decision on all
recommendations.
OFFICE OF INSPECTOR GENERAL
United States Department of Agriculture
DATE: August 25, 2021
INSPECTION
NUMBER: 27801-0003-22
TO: Cindy Long
Acting Administrator
Food and Nutrition Service
ATTN: Melissa Rothstein
Director
Office of Internal Controls, Audits and Investigations
FROM: Gil H. Harden
Assistant Inspector General for Audit
SUBJECT: COVID-19—Supplemental Nutrition Assistance Program Online Purchasing in
Response to the Coronavirus Disease 2019
This report presents the results of the subject review. Your written response to the official draft
is included in its entirety at the end of the report. We have incorporated excerpts from your
response, and the Office of Inspector General’s (OIG) position, into the relevant sections of the
report. Based on your written response, we are accepting management decision for all 3
inspection recommendations in the report, and no further response to this office is necessary.
Please follow your internal agency procedures in forwarding final action correspondence to the
Office of the Chief Financial Officer (OCFO).
In accordance with Departmental Regulation 1720-1, final action needs to be taken within 1 year
of each management decision to prevent being listed in the Department’s annual Agency
Financial Report. For agencies other than OCFO, please follow your internal agency procedures
in forwarding final action correspondence to OCFO.
We appreciate the courtesies and cooperation extended to us by members of your staff during our
inspection fieldwork and subsequent discussions. This report contains publicly available
information and will be posted in its entirety to our website (http://www.usda.gov/oig) in the
near future.
Table of Contents
Background and Objectives ....................................................................................1
Objective 1: What criteria did FNS use to approve States and retail food
stores to accept SNAP benefits through online transactions during
COVID‑19? ...............................................................................................................3
a. How were FNS criteria different from the criteria used for approving the
original demonstration projects? ........................................................................3
b. What impact, if any, could changes to the criteria have on the integrity of
the program? .........................................................................................................3
Objective 2: What risks has FNS identified during the transition to allow
SNAP benefits online? .............................................................................................4
a. What risks did FNS accept without implementing an internal control? .......4
b. What controls did FNS establish to manage those risks it did not accept? ..4
Recommendation 1 ........................................................................................5
Recommendation 2 ........................................................................................6
Objective 3: What controls does FNS have to ensure retail food stores meet
online transaction program requirements?...........................................................7
Recommendation 3 ........................................................................................8
Scope and Methodology .........................................................................................10
Abbreviations .........................................................................................................11
Agency’s Response .................................................................................................13
Background and Objectives
Background
The Supplemental Nutrition Assistance Program (SNAP), administered by the United States
Department of Agriculture’s (USDA) Food and Nutrition Service (FNS), provides nutrition
benefits to supplement the food budgets of needy families so they can purchase healthy food and
move towards self-sufficiency. The 2014 Farm Bill mandated a demonstration project to test the
feasibility and implications of allowing retail food stores (retailers) to accept SNAP through
online transactions. 1, 2 In 2014, FNS initiated a SNAP Online Purchasing Pilot (pilot), which
would allow households to make online purchases using SNAP electronic benefits transaction
(EBT) cards. The pilot requires these transactions to be secure, private, easy to use, and provide
similar support to that found for SNAP transactions in a retail store. The use of SNAP benefits
to pay fees of any type—such as delivery, service, or convenience fees—is not allowed.
On September 15, 2016, FNS released a request for retailer volunteers to solicit applications for
a 2-year SNAP Online Purchasing Pilot. On January 5, 2017, FNS announced the selection of
eight pilot States and seven retailers for the initial pilot launch. 3 As of March 2020, six States
and four retailers were participating in the pilot program (see Figure 1). 4
.
Figure 1. In March 2020, Six States Accepted SNAP Online Transactions.
In March 2020, due to the coronavirus disease 2019 (COVID-19) pandemic, health officials
recommended limiting visits to grocery stores and ordering food online for home delivery or
curbside pickup if possible. Other factors, such as limited or halted public transportation and
increased warnings for high-risk individuals, also impeded some SNAP recipients’ ability or
willingness to visit supermarkets. In response to the pandemic, FNS approved in quick
succession other States to participate in the SNAP Online Purchasing Pilot, and there was a steep
1
Agricultural Act of 2014, Pub. L. No. 113-79, 128 Stat. 649 (2014 Farm Bill).
2
The demonstration project is referred to as the SNAP Online Purchasing Pilot in this report.
3
The eight States selected to be part of the pilot were Alabama, Iowa, Maryland, Nebraska, New Jersey, New York,
Oregon, and Washington.
4
The six States participating in the pilot in March 2020 were Alabama, Iowa, Nebraska, New York, Oregon, and
Washington. In response to the pandemic, FNS approved States not part of the original pilot beginning in
April 2020.
INSPECTION REPORT 27801-0003-22 1
rise in online SNAP monthly transactions. By the end of December 2020, online SNAP benefits
were expanded to 46 States and Washington, D.C. Therefore, participating households and
online SNAP benefits redeemed increased greatly, as noted in Figure 2.
Figure 2: The Expansion of the SNAP Online Pilot in Response to the Pandemic.
Objectives
Our objectives were to address the following questions:
1. What criteria did FNS use to approve States and retail food stores to accept SNAP
benefits through online transactions during COVID-19?
a. How were FNS criteria different from the criteria used for approving the original
demonstration projects?
b. What impact, if any, could changes to the criteria have on the integrity of the
program?
2. What risks has FNS identified during the transition to allow SNAP benefits online?
a. What risks did FNS accept without implementing an internal control?
b. What controls did FNS establish to manage those risks it did not accept?
3. What controls does FNS have to ensure retail food stores meet online transaction
program requirements?
2 INSPECTION REPORT 27801-0003-22
Objective 1: What criteria did FNS use to approve States and retail
food stores to accept SNAP benefits through online transactions
during COVID‑19?
a. How were FNS criteria different from the criteria used for approving the
original demonstration projects?
b. What impact, if any, could changes to the criteria have on the integrity of
the program?
After the pandemic began in March 2020, FNS used the same criteria, from the request for
volunteers (RFV) handbook, that the agency used to establish the pilot selections to authorize
additional States and retailers to accept SNAP benefits through online transactions. 5 We
determined that there was no impact to the integrity of the program since FNS did not change its
approval criteria.
FNS used the RFV handbook both when the agency established the pilot and after the start of the
pandemic. The handbook describes the application and selection process FNS uses to enroll
retailers in the pilot. It also outlines the legislative, regulatory, and operational requirements for
participation in the pilot. For example, the handbook outlines the requirements retailers must
meet in order to participate in the pilot, including security and privacy, transaction processing,
and online checkout process requirements. The handbook also outlines FNS’ and the EBT
processors’ responsibilities in the online pilot.
While the criteria remained the same after the start of the pandemic, FNS created a new,
simplified application to quickly expand the pilot to additional States. Before the pandemic,
interested retailers initiated the application process and submitted a 12-page application from the
RFV handbook. These retailers were responsible for coordinating with the States where they
wished to operate. As a result of the pandemic, in March 2020, FNS developed a simplified,
3-page application to allow the pilot to expand to new States. 6 The 3-page application allowed
additional States to initiate the application process and participate in the pilot using currently
approved retailers. FNS continues to use the 12-page application from the RFV to approve new
retailers for the SNAP Online Purchasing Pilot.
5
USDA FNS, Electronic Benefits Transfer Online Purchasing Pilot Request for Volunteers (Sep. 15, 2016).
6
In a press release on April 8, 2020, USDA announced that FNS had created a simplified template to ease the
process for States wishing to enter the pilot.
INSPECTION REPORT 27801-0003-22 3
Objective 2: What risks has FNS identified during the transition to
allow SNAP benefits online?
a. What risks did FNS accept without implementing an internal control?
b. What controls did FNS establish to manage those risks it did not accept?
FNS has not updated its risk assessment of the SNAP Online Purchasing Pilot since the pilot was
created in 2014. This occurred because FNS did not establish a process to periodically assess
and document risks that could impact the integrity of this pilot. Without updating its risk
assessment, the pilot could be susceptible to fraud and abuse—particularly as FNS rapidly
expanded the pilot from 6 States in March 2020 to 46 States by December 2020. Between
April 2019 and March 2020, SNAP recipients used more than $18.9 million in SNAP benefits to
purchase groceries online. By the end of December 2020, online SNAP purchase transactions
increased to more than $1.5 billion cumulatively.
The Office of Management and Budget (OMB) Circular A-123 states that identifying risk is a
continuous process. Agencies must regularly review and monitor risk to identify whether it still
exists, new risks have arisen, and changes have occurred in the likelihood and impact of risks. 7
The Standards for Internal Control in the Federal Government states that changing conditions
often create new risks, or changes to existing risks can prompt management to perform a risk
assessment to identify, analyze, and respond to any new, resulting risks. 8
Due to the pandemic, FNS expanded the pilot from the original eight States and seven retailers
announced in 2017 to allow all States and retailers to apply for participation. This swift
expansion of the pilot beginning April 2020 changed the condition, which created the
opportunity for new risks to emerge. Because of the potential for new or changing risks, we
asked FNS officials for all risk assessment documentation related to the pilot since the pandemic
started.
In response to our request, FNS officials provided a risk assessment of the SNAP Online
Purchasing Pilot. However, we found that FNS had not updated its risk assessment since it was
performed in 2014. The risk assessment identified a total of 11 risks. 9 For each risk, FNS
presented how the risk was identified and possible mitigation and method of testing. Of the
11 risks identified for the pilot, FNS determined that none was greater than moderate. 10 While
we consider this to be an important assessment, the document shared did not describe how the
assessment was prepared, who prepared it, or the date it was completed. When we requested
clarification, FNS responded that the risk assessment was prepared by SNAP personnel and
industry representatives in 2014. According to FNS, the purpose of the risk assessment was to
7
OMB, Management’s Responsibility for Enterprise Risk Management and Internal Control, Circular A-123
(July 15, 2016).
8
Government Accountability Office, Standards for Internal Control in the Federal Government (Sep. 2014).
9
FNS considers these areas of risk as potential issues related to retailers participating in the pilot.
10
In contrast, SNAP is identified as a high-risk program under the Improper Payment Information Act of 2002, as
amended. OMB Circular A-123 states high risks could preclude or highly impair an entity’s ability to achieve its
goals, while a medium risk could significantly affect the entity’s ability to achieve its goals.
4 INSPECTION REPORT 27801-0003-22
determine whether to move forward with a pilot. Further, FNS officials stated they applied the
same risk assessment prepared in 2014 to expand the pilot due to the pandemic because they had
not identified any new threats.
We determined that personnel did not identify new threats, or update existing risks or mitigation
measures because FNS had not established a process to periodically assess and document risks
that could impact the integrity of its SNAP Online Purchasing Pilot. We asked FNS how many
re-evaluations of the 2014 assessment were completed and whether they have identified new
risks or changed the risk level for the original risks identified in 2014. FNS officials stated that
monitoring risk is part of the ongoing evaluation of the pilot implementation and operation,
adding that they continuously monitor the pilot and online transactions for fraud detection.
Although FNS officials stated that the evaluation of risks is ongoing within the pilot, the
documentation provided was not sufficient to ascertain when reviews were conducted or the
extent of the reviews. We also asked which of the risk(s) identified in the assessment FNS
determined to tolerate and which risk(s) they could not tolerate and, therefore, implemented
controls to mitigate the risk(s). FNS officials responded that FNS will do all it can to mitigate
the risk(s) identified; however, the documentation provided was not sufficient to identify the
tolerance for the risk(s).
As stated in the Background section of this report, the SNAP Online Purchasing Pilot saw a
significant increase after the start of the pandemic. From April 2019 to March 2020, six States
were participating, with a total transaction amount of more than $18.9 million. By
December 2020, 46 States and Washington, D.C., were participating, with a total transaction
amount of more than $1.5 billion cumulatively.
While offering SNAP recipients access to purchase groceries online in the midst of a pandemic is
a positive step, the rapid expansion potentially leaves the pilot susceptible to the risk of fraud and
abuse. 11 E-Commerce is a quickly expanding market with evolving technology and risks. FNS’
risk assessment from 7 years ago may not identify risks in an evolving market. Risk assessments
can help FNS identify and mitigate hazards; however, the effectiveness of these assessments
relies upon current information. Therefore, FNS should regularly assess whether new risks have
arisen or whether the controls in place are sufficient to mitigate those potential hazards. In order
for FNS to both provide valuable online SNAP service and ensure the safety and efficacy of
these transactions, FNS needs to update its risk assessment and establish a policy to periodically
conduct these assessments.
Recommendation 1
Perform and update the SNAP Online Purchasing Pilot risk assessment to reflect how FNS will
mitigate and test potential risks.
Agency Response
11
During our inspection, no indication of retailer or recipient fraud came to our attention.
INSPECTION REPORT 27801-0003-22 5
FNS concurs with this recommendation and will review, update (if/as necessary), and
formally document the results of the SNAP Online Purchasing Pilot risk assessment,
including testing and risk mitigation.
OIG Position
We accept FNS’s management decision on this recommendation.
Recommendation 2
Establish a policy to periodically perform assessments to identify any new risks and re-evaluate
existing ones related to the SNAP Online Purchasing Pilot.
Agency Response
FNS concurs with this recommendation. FNS will establish internal operational guidance
(policy) to undertake the process described in response to Recommendation 1 on a
periodic basis, to identify new risks or changes to existing risks.
OIG Position
We accept FNS’s management decision on this recommendation.
6 INSPECTION REPORT 27801-0003-22
Objective 3: What controls does FNS have to ensure retail food
stores meet online transaction program requirements?
Although we found FNS had established criteria and program requirements for retailers to be
eligible to participate in the pilot, FNS could not illustrate how the agency verified that the four
retailers we reviewed complied with privacy practices and policies to participate as EBT online
retailers. 12 FNS did not establish controls to effectively monitor, evaluate, or document how
participating retailers are protecting SNAP participants’ online information. Instead, the agency
relied on retailers’ assurance and attestation that online retailers will protect the privacy of SNAP
participants’ information. In order to proactively ensure that SNAP participants’ personal
information is not compromised, sold, shared, or given to any third party without authorization,
FNS needs to better monitor, evaluate, and document retailers’ compliance with safeguarding
participants’ personally identifiable information (PII).
According to OMB Circular A-123, Federal agencies are ultimately responsible for the services
and processes provided by third-party service organizations as they relate to the agency’s ability
to maintain internal control over operations, reporting, and compliance with laws and
regulations. 13 If the processes provided by the third-party service organization are significant to
an agency’s internal control objectives, then the agency is responsible for establishing controls
that complement the third-party controls. Additionally, FNS’ RFV handbook states, that due to
privacy requirements, FNS must ensure that personal information such as name, address, or
email address collected by SNAP online retailers is not compromised, sold, rented, or given
away to any third party without authorization. 14 The RFV handbook also requires third-party
websites that share data at the individual level to obtain explicit consent from EBT customers to
release such information. The RFV handbook states “the EBT customer must “opt in” to allow
such sharing and not have to “opt out” to prevent the sharing.” 15
FNS is responsible for managing, monitoring, and assessing the implementation of the SNAP
Online Purchasing Pilot. Because of this responsibility, we asked FNS officials about the
agency’s internal controls to ensure retailers adhere to pilot requirements, including those related
to safeguarding SNAP participants’ personal information. In response, FNS officials stated that
the agency provides a template business requirements document to assist retailers in
documenting how they will meet FNS’ pilot requirements. FNS officials also stated that, as part
of the application process, they require retailers to attest that they are responsible for ensuring
that PII would not be compromised, sold, rented, or given to any third party without
authorization. FNS officials explained that compliance will be assessed as part of the
reauthorization of online retailers as part of normal monitoring and oversight. FNS officials
further stated that participating retailers are required to provide a link to their website’s security
practices and policies. FNS noted their review of a retailer’s website security practices and
12
Four retailers were approved and actively participating in the pilot at the beginning of our fieldwork in July 2020.
During our fieldwork, FNS started approving additional retailers, but we did not assess those approvals. The four
retailers we reviewed accounted for more than 99 percent of all transactions in our scope.
13
OMB, Management’s Responsibility for Enterprise Risk Management and Internal Control, Circular A-123
(July 15, 2016).
14
USDA FNS, SNAP Electronic Benefits Transfer Online Purchasing Pilot Request for Volunteers (Sep. 15, 2016).
15
Ibid.
INSPECTION REPORT 27801-0003-22 7
policies covers whether the retailer explains to the customer the precautions that the retailer has
taken to secure customer data and the retailer’s liability should there be a breach that results in a
loss to the customer.
To verify that retailers adhere to all online purchasing requirements before participating in the
pilot, FNS officials stated that the agency conducts robust end-to-end testing. As part of FNS’
end-to-end testing, FNS officials stated that the agency reviews retailers’ policies on their
websites during the vetting process to verify that either: (1) retailers provide assurances that they
do not sell or share data with third parties, or (2) retailers who sell or provide data to third parties
provide EBT customers an “opt out” option. However, FNS policy, as detailed in the RFV
handbook, provides that the EBT customer must have an “opt in” option when providing third
parties data and an “opt out” option for using data for internal marketing purposes.
Our assessment of FNS end-to-end user acceptance summary reports for the four retailers found
that FNS personnel verified that the retailer’s system had met FNS’ functional requirements for
the implementation of SNAP Online Purchasing Pilot. However, it did not include evidence that
FNS’ personnel reviewed retailers’ privacy practices and policies to ensure compliance with the
safeguarding of SNAP customers’ PII, such as if retailers provided “opt in” or “opt out” options
to EBT customers when applicable. Further, FNS could not demonstrate that FNS personnel
reviewed any of the four pilot retailers’ websites in the manner required.
When we reviewed the website links to retailers’ website policies that FNS provided, we found
that none of the four retailers’ websites explain to the EBT customer the retailers’ liability in the
event of a data breach—an FNS requirement. 16 Additionally, one retailer’s website required the
customer to establish an email and a password to access their security and privacy policies while
another retailer’s website was not functioning properly and not allowing anyone to access.
Because FNS did not adequately document its end-to-end testing, it is difficult to determine if
FNS visited the site links, as the agency should have identified these issues.
We agree that end-to-end testing is a critical oversight control. To ensure this testing identifies
any potential non-compliance with online transaction requirements to safeguard PII, FNS needs
to establish better guidance and monitoring. By doing this, FNS can better ensure SNAP
participants’ personal information is not compromised, sold, shared, or given to any third party
without authorization.
Recommendation 3
Establish controls for monitoring, evaluating, and documenting SNAP Online Purchasing Pilot
retailers’ requirements pertaining to the use of SNAP participants’ personal information.
Agency Response
We reviewed the website links for three of the four retailers on February 25, 2021, and the remaining retailer on
16
March 15, 2021.
8 INSPECTION REPORT 27801-0003-22
FNS concurs with this recommendation, and will establish internal operational guidance
to include controls for monitoring, evaluating, and documenting pilot retailers’
requirements pertaining to the use of SNAP participants’ personal information.
OIG Position
We accept FNS’s management decision on this recommendation.
INSPECTION REPORT 27801-0003-22 9
Scope and Methodology
Our inspection scope covered FNS’: (1) implementation of the SNAP Online Purchasing Pilot
from February through June 2020; and (2) data related to participating households and online
transactions from April 2019 through December 2020.
We conducted our fieldwork from July 2020 through March 2021. During our fieldwork, we
experienced delays in the agency providing documents and access to staff that were necessary for
our oversight of FNS COVID-19 SNAP Online Purchasing Pilot activities. In some instances,
the agency took up to 61 days to deliver documentation to the Office of Inspector General (OIG).
These delays were incurred as FNS officials followed review processes established for
COVID‑19 engagements. We ultimately received all requested information from FNS; but, these
delays impacted our ability to timely conduct fieldwork.
To accomplish our inspection objectives, we:
• Examined relevant laws, regulations, policies, and procedures.
• Reviewed relevant documentation and responses related to FNS’ implementation of the
SNAP Online Purchasing Pilot.
• Interviewed FNS officials to discuss FNS’ criteria for approving States and retailers,
FNS’ risk assessment, and FNS’ controls used to ensure retailers meet online transaction
program requirements.
• Reviewed FNS’ website to obtain policies, guidance, and the number of participating
retailers and States with regards to the SNAP Online Purchasing Pilot.
• Reviewed SNAP transaction data to identify the dollar amount of online transactions and
number of households participating in the SNAP Online Purchasing Pilot.
We assessed the reliability of data by reviewing existing information and the systems that
produced them and interviewing agency officials knowledgeable about the data. From these
efforts, we believe the information we obtained is sufficiently reliable for this report.
We conducted this inspection in accordance with the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. Those standards
require that we obtain sufficient, competent, and relevant evidence to provide a reasonable basis
for our findings, conclusions, and recommendations based on our inspection objectives. We
believe that the evidence obtained provides a reasonable basis for our findings, conclusions, and
recommendations based on our review.
10 INSPECTION REPORT 27801-0003-22
Abbreviations
COVID-19..............................coronavirus disease 2019
EBT ........................................electronic benefits transfer
FNS ........................................Food and Nutrition Service
OIG ........................................Office of Inspector General
OMB ......................................Office of Management and Budget
PII...........................................personally identifiable information
RFV ........................................request for volunteers
SNAP .....................................Supplemental Nutrition Assistance Program
USDA.....................................United States Department of Agriculture
INSPECTION REPORT 27801-0003-22 11
12 INSPECTION REPORT 27801-0003-22
Agency’s Response
Food and Nutrition Service
Response to Inspection Report
INSPECTION REPORT 27801-0003-22 13
Food and
Nutrition
Service
DATE: August 17, 2021
1320 INSPECTION
Braddock NUMBER: 27801-0003-22
Place
Alexandria
, VA TO: Gil H. Harden
22314 Assistant Inspector General for Audit
FROM: Cindy Long /s/
Acting Administrator
Food and Nutrition Service
SUBJECT: COVID-19: Supplemental Nutrition Assistance Program Online
Purchasing in Response to Coronavirus Disease 2019
This letter responds to the official draft report for inspection number 27801-0003-22, COVID-
19: Supplemental Nutrition Assistance Program (SNAP) Online Purchasing in Response to
Coronavirus Disease 2019. Specifically, the Food and Nutrition Service (FNS) is responding to
the three recommendations in the report.
FNS generally concurs with the recommendations and supports the Office of Inspector General’s
(OIG) objectives to assess the procedures, risks, and controls for the SNAP Online Purchasing
Pilot. During the timeframe that OIG conducted this inspection, FNS successfully expanded a
six-State and retailer pilot to 47 States and the District of Columbia, and hundreds of additional
retailers. This resulted in providing SNAP online purchasing access to over 2 million
households, which include seniors, the disabled, and those who are immunocompromised.
Priority was necessarily placed on maximizing the ability of families to have safe and secure
options for accessing food with their SNAP benefits during the unprecedented COVID-19
pandemic.
Although FNS did not have a formal process in place for documenting changes to the existing
comprehensive risk assessment, the risks associated with online purchasing and the expansion of
online purchasing were continually reviewed and considered as part of pilot operations,
including during the pandemic expansion. The security and integrity of all aspects of SNAP
benefit redemption remain a priority for the Agency.
In addition, FNS always strives to meet OIG timeframes for providing information, as we
appreciate that delays can impact OIG’s ability to complete their work on schedule. The FNS
delays in providing OIG information for this inspection resulted from internal clearance
processes that all USDA agencies were required to follow for COVID-19 engagements (as OIG
noted in the report), as well as the unique nature of this engagement which occurred while FNS
was in the midst of expanding the pilot as a part of the response to COVID-19.
USDA is an Equal Opportunity Provider, Employer and Lender
Gil H. Harden
Page 2
OIG Recommendation 1:
Perform and update the SNAP Online Purchasing Pilot risk assessment to reflect how FNS will
mitigate and test potential risks.
FNS Response:
FNS concurs with this recommendation and will review, update (if/as necessary), and formally
document the results of the SNAP Online Purchasing Pilot risk assessment, including testing and
risk mitigation.
Estimated Completion Date:
September 1, 2022
OIG Recommendation 2:
Establish a policy to periodically perform assessments to identify any new risks and re-evaluate
existing ones related to the SNAP Online Purchasing Pilot.
FNS Response:
FNS concurs with this recommendation. FNS will establish internal operational guidance
(policy) to undertake the process described in response to Recommendation 1 on a periodic
basis, to identify new risks or changes to existing risks.
Estimated Completion Date:
September 1, 2022
OIG Recommendation 3:
Establish controls for monitoring, evaluating, and documenting SNAP Online Purchasing Pilot
retailers’ requirements pertaining to the use of SNAP participants’ personal information.
FNS Response:
FNS concurs with this recommendation, and will establish internal operational guidance to
include controls for monitoring, evaluating, and documenting pilot retailers’ requirements
pertaining to the use of SNAP participants’ personal information.
Estimated Completion Date:
September 1, 2022
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