The What and Why of the Farmers Market Legal Toolkit, Part 2: SNAP/EBT Implementation

      Posted On: March 12, 2018

By Darlene Wolnik, FMC Senior Researcher |

In partnership with the Northeast Organic Farming Association of Vermont (NOFA-VT), Center for Agriculture and Food Systems, and the Farmers Market Coalition, the Farmers Market Legal Toolkit was developed for market leaders looking for legal tools and resources to help them build resilient farmers markets in their communities. This is Part 2 of a three part series highlighting the uses of each section of the toolkit.

In 2013, I did a workshop for NOFA-VT at their Direct Marketing Conference, which is held in South Royalton at the beautiful Vermont Law School campus. On that visit, I spoke about the governance of markets and the need for the right incorporation and the right management structure based on that incorporation.

Directly after my workshop ended, I saw Laurie Ristino, the brand-new director of the Center for Agriculture and Food Systems making a beeline for me. “Hey!” she said enthusiastically, “can we talk about doing a project here at the Center for markets on incorporation issues?”

Soon after, she and I, along with NOFA-VT’s Direct Marketing director Erin Buckwalter, came up with a research project funded through NIFA’s Agriculture and Food Research Initiative to create a legal toolkit for markets. We decided to focus on the 3 areas where we had the most questions: Governance, SNAP/Currency, and General (mostly market day) Risks. This is a series of brief posts of what and why we decided to cover in the toolkit.


Of course, in terms of current legal questions for markets, this section of the Farmers Market Legal Toolkit was a must!

I like to remind market leaders that the push for these systems originated with the markets themselves around 2004 once the switch to electronic cards was completed by FNS in all 50 states. Those new systems were piloted through mostly private funding and refined through trial and error.

What that means is that the expertise was, and is, at the market level around how to design the right system and that market leaders continue to innovate new ideas to match the experience and their needs. As a result, there exist a number of excellent resources for markets to learn about the SNAP/token/wireless machine systems and plenty of expertise at the market and state level to assist our team as we built this section.

In the planning, we decided to stick to the issues that both NOFA-VT and FMC had heard about regularly:

These rules and best practices may change more rapidly than the other sections in the Toolkit, and so we hope we hear from those of you who have new systems or issues not covered here and if necessary, we will search for funding to update the site. In the meantime, if you have one such template or other documentation to share, upload it to the Resource Library here.

Please let us know how you use the site or email me when you add a new resource to the FMC Resource Library that would be useful for those in the Toolkit.

[Click here to read Part 1: Governance]