Open Letter to FNS

      Posted On: September 18, 2019

The following letter was sent to FNS in September of 2019 on behalf of markets and the organizations that support them around the country. See the PDF here. 

Brandon Lipps
Deputy Under Secretary Food, Nutrition and Consumer Services
United States Department of Agriculture
1400 Independence Ave SW
Washington DC 20250 

Dear Mr. Lipps, 

In a letter dated March 11, 2019, 374 organizations provided USDA Food and Nutrition Service (FNS) with documentation of the status of wireless EBT provision in many states, an analysis of the various systems in use, and specific recommendations for the use of FY 2019 appropriated funds provided by Congress to the agency to facilitate SNAP use in farmers markets. The recommendations were informed by conversations with more than 20 state agencies, the American Public Human Services Association (APHSA), the National Association of State Departments of Agriculture (NASDA), electronic payment companies, expert members of the e-Government Payments Council, and hundreds of farmers markets. It was based on the most thorough information gathering ever done of the mobile farm direct SNAP payment landscape and the policy approach suggested reflected an almost unanimous consensus among those very diverse sectors. 

Several representatives of the group had the opportunity to meet with FNS staff on March 28th and were told that the agency was seriously considering our proposal. There was no further communication until FNS’ publication of the recent solicitation on July 15, 2019. 

We were surprised to see FNS pursue the strategy outlined in the most recent solicitation as it makes no reference to the input provided in the March letter and charts a course for the next 4 years that appears to be a much less effective approach. 

Additionally we have the following concerns about the solicitation both in terms of approach and execution: 

  • The Solicitation as outlined will lock in one app as the only option supported by federal funds. Markets have different needs and one app will not support the needs of all markets in all communities 
  • For many markets the need for support goes beyond one year of app licensing. The additional costs that must be undertaken by a market to operate SNAP equipment will present a barrier for many farmers markets and direct marketing farmers 
  • The solicitation criteria for the app appear so narrow as to limit the apps to only one that meets the criteria listed in the solicitation 
  • Questions posed to FNS regarding the solicitation went unresponded to for a full month. When we did receive a response to our questions, the answer did not provide additional information and only referred us back to the solicitation. The lack of timely information has prevented us from having adequate time and information to respond to the solicitation 

We would greatly appreciate a response to our initial letter explaining why FNS chose not implement our recommendations and why instead FNS believes that the solicitation represents a better approach to addressing SNAP access for farmers markets and direct marketing farmers. 

Sincerely, 

Ben Feldman
Executive Director Farmers Market Coalition