You have the records a supermarket has. Use them like one.
Independent grocers are charged less often than corner stores and lose more when they are, because the dollar figures are larger and the civil money penalty formula runs off redemption volume. The advantage is that a real grocery keeps real records - scanning POS, multiple registers, weekly wholesale deliveries, inventory counts. Almost every claim in a charge letter can be tested against those systems, if the response is built like an audit instead of a letter.
We owe loyalty to only you.
When you’re looking online, you have multiple options. There are so many firms advertising SNAP defense. Thankfully, your search is over. Spodek Law Group P.C. offers premier white-glove service and we’re unafraid of fighting. Unlike firms that are more focused on their relationship with the agency than with you, we owe loyalty to only YOU. Your store, your family, your license.
One reason our firm has such a high success rate is that we’re selective about who we work with. If we’re choosing to work with you, it’s because we think we can make a positive impact. That’s vastly different from firms that take on any client willing to pay. When you reach out, you start with a risk-free consultation - and you can ask us anything you want, regardless of how long it takes.
If there’s a way to keep your store in the program, we’ll find it. That’s the whole job.
Six things that look wrong in aggregate and are ordinary in the aisles.
Reconcile the store. That’s the defense.
A grocery can do what a bodega cannot: show that purchases, sales and inventory tie out across the review period. When the food demonstrably existed and was demonstrably sold, the inference that benefits left as cash collapses.
Build the reconciliationFour systems your store already runs.
USDA FNS · 7 CFR 278.6
RETAILER DEFENSE
UPDATED 2026
Defending a full-service grocery against a SNAP charge letter
When FNS charges an independent grocery, the stakes are different from a corner store case. Redemption volume is higher, so the civil money penalty formula - built from average monthly SNAP redemptions - produces much larger numbers, and the business usually carries debt, leases and payroll that can’t survive an interruption. The compensating advantage is documentation. A real grocery runs scanning point-of-sale across multiple lanes, receives weekly warehouse and direct-store deliveries, and counts inventory. Very little in a charge letter can’t be tested against those systems.
The strongest move available to a grocer is a reconciliation. Take the review period, assemble every purchase - warehouse, DSD, produce, dairy, meat - and set it against departmental sales with shrink accounted for. If the store bought the food and sold the food, the theory that benefits were exchanged for cash has to explain where the groceries went. Very few charge letters survive that exercise intact, and no bodega can perform it. Grocers can, and most never do because nobody asks them to inside ten days.
The second move is granularity. Export transactions by register, department, cashier and tender type. Aggregate data hides what detail reveals: if the flagged activity concentrates in one lane on one shift, the case is about an employee rather than a practice, which reframes it entirely. That reframing is the substance of criterion 4 of 278.6(i) - ownership not knowing of, approving, benefiting from or participating in the conduct - and it’s what preserves a civil money penalty in lieu of permanent disqualification.
Scale also creates the ineligible-item problem. Hot bars, delis and prepared-food counters sit beside eligible groceries, and prepared food for immediate consumption isn’t eligible. A store with forty cashiers will have some of these transactions. Quantifying them yourself, from departmental data, is far better than letting the agency estimate. It also keeps an ineligible-item issue from being characterized as something broader.
Finally, the number itself. Where a penalty in lieu is in play, FNS calculates it from average monthly redemptions across a period it selects, subject to the caps at 7 CFR 3.91(b)(3). For a high-volume grocer both inputs matter enormously, and both are contestable - whether the redemption figures are right, and whether the period charged is the right period. That work is worth doing carefully, because the difference is measured in tens of thousands of dollars.
If your grocery has a charge letter, start the reconciliation tonight and call in the morning. Ten days is enough time to do this properly if the work starts immediately.
When the biggest cases break, we get the call. That same team answers your ten days.
When the networks need a federal file explained in plain English, they call us.
This bench answers its own phone. Put it on your case.
Tell us what happened. Eight fields, two minutes - and a lawyer reads it today.
Read us the first line of the letter. We’ll tell you what day you’re on.
Bring the envelope, the attachment, and your invoices if you have them. If you don’t have them, bring the letter. The consultation is risk-free, it stays between us, and it happens today - ask us anything, regardless of how long it takes.