SNAP – Depth of Stock and the Magic of 21 Days

A store (or “firm” as they are called in the federal regulations) which participates in the Supplemental Nutrition Assistance Program, otherwise known as “SNAP” contains a litany of rules and regulations which a store must abide by if they are to maintain their eligibility to accept payments by Electronics Benefits Transfer, or “EBT”.Depending on the size of the firm, it is important to keep in mind a concept called “Depth of Stock”. The regulations require that a firm must maintain three stocking units per staple food variety. Look to next month’s blog for additional information about what constitutes a “staple food variety,” but that discussion can wait until another day.If a firm does not maintain three stocking units, the firm’s ability to accept EBT could be denied or withdrawn because of a shortfall in the stocking units.However, there is a provision in the regulations which allows for a firm to avoid this withdrawal or denial if they can show that, no more than 21 days prior to an agency inspection, the firm had ordered and/or received the required stock.Thanks to this provision, it is possible for stores to implement certain good practices and procedures which maintain their stock in accordance with SNAP regulations. If you have concerns about how you maintain a stock of staple foods in your store, be sure to reach out to your attorney for advise on what you can do to protect your continued participation in SNAP.