INELIGIBLE-ITEM CHARGES RUN SIX MONTHS TO THREE YEARS · 7 CFR 278.6(e)(3)-(5)
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SNAPVIOLATIONS.COM / VIOLATIONS / INELIGIBLE ITEMS
INELIGIBLE ITEMS · 7 CFR 278.6(e)(3) · (e)(4) · (e)(5)

Soap, paper towels, a hot sandwich. The term depends on which.

This is the charge most stores actually get. Not cash for benefits - a pattern of ringing up things SNAP doesn’t cover. Paper goods, cleaning supplies, pet food, cigarettes, beer, hot prepared food eaten in the store. The sanction isn’t permanent, and that’s the whole opportunity: where your case lands on the ladder is argued, not fixed, and the difference between six months and three years is the record you file in ten days.

THE CHARGE AT A GLANCE
DEFAULT SANCTION
Six months to three years
YOUR WINDOW
10 days from receipt
WAY OUT
Hardship penalty under 278.6(f)
Where a disqualification would leave participating households without a comparable store, FNS may take money instead of the term.
WHAT MOVES IT
Whether the record reads as intent, as a pattern, or as carelessness and poor supervision. Those are three different rungs.
WHO IS DEFENDING YOUR STORE
If you’re reading this, USDA is threatening your store and you need serious help - we get it. Spodek Law Group P.C. is second generation, practicing since 1976, and dramatized in Netflix’s Inventing Anna. We owe loyalty to only you.
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THE FIRM · WHY US

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.

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THE SIMPLE BELIEF
We should only take on clients we can actually help.
01 · A PERSON ANSWERS
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WHAT THE LETTER IS REALLY SAYING

The ladder turns on two words: pattern, and costly.

01
Common nonfood items
Soap, toilet paper, diapers, pet food, cleaning supplies, cigarettes, beer. A pattern of accepting benefits for these draws a one-year term on a first sanction under 278.6(e)(4).
02
Costly or conspicuous items
Appliances, electronics, auto parts, tools, gift cards. The regulation treats these as harder to explain away, and a first-sanction pattern draws three years under 278.6(e)(3).
03
Hot and prepared food
Hot coffee, a heated sandwich, anything intended for immediate consumption. Deli counters and gas stations get charged here constantly, often over a warmer that was never supposed to take EBT.
04
The word pattern
A pattern means more than one, established across the review period. A single mis-rung item isn’t the charge. What FNS calls a pattern is challengeable, and challenging it’s often what drops the term.
05
Carelessness, not intent
278.6(e)(5) sets six months where the record shows carelessness or poor supervision rather than a deliberate practice. Getting a case onto this rung is a real win, and it’s an evidentiary argument.
06
Second and third sanctions
Escalation is automatic: a prior one-year term makes the next three, a prior three makes five, and a third sanction of any kind ends the authorization. A quiet first case gets expensive later.
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THE DEFENSE · FIVE MOVES

Your register knows what was in the basket. Prove it.

Ineligible-item cases are won on product data, not on argument. The agency has amounts and dates. You have the itemized record of what was actually sold, and the store rules the clerk was working under.

Start the response today
01
Pull the itemized sales
POS exports and Z-tapes for every flagged date. A basket list against an amount is the strongest document in this kind of case, and most stores have it without knowing.
02
Attack the word pattern
How many transactions, over how many days, out of how many thousands? If the flagged set is a fraction of a percent of your SNAP volume, that’s an argument against a pattern and against intent.
03
Show the system
Register signage, EBT-blocked product codes, the tender rules in your POS, the shelf tags. A store that engineered against ineligible sales is a store that was careless at worst.
04
Argue the rung
Move the case from (e)(3) to (e)(4), or from (e)(4) to (e)(5). Each step is measured in months of authorization, and each is supported by different evidence.
05
Raise hardship early
If the neighborhood has no comparable store, 278.6(f) lets FNS take a money penalty instead of shutting your terminal. That showing needs census and competitor facts, not adjectives.
THE TEN DAYS · WHAT TO PULL TONIGHT

Four documents decide whether it’s six months or three years.

Walk us through them →
ITEMIZED RECEIPTS
Every flagged transaction, item by item. If the basket was groceries and the amount is simply large, the charge has a hole in it.
PRODUCT FILE
Your POS product list showing which SKUs are flagged EBT-eligible. A configured system is evidence of a program, not of a practice.
STORE RULES
Written instructions to clerks about what can’t be rung on EBT, signage photos, and signed acknowledgements. Dated matters more than detailed.
THE NEIGHBORHOOD
Distance to the nearest supermarket, transit access, the households who shop with you. This is the raw material of a hardship argument under 278.6(f).
THE BRIEFING
SNAP INELIGIBLE ITEMS
7 CFR 278.6(e)(3)-(5)
RETAILER DEFENSE
UPDATED 2026
ON CALL 24/7
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The ineligible-item charge, and why the term is negotiable

Ineligible-item cases arrive the same way trafficking cases do - a charge letter, an attachment of transactions, and ten days - but they carry a very different ceiling. The sanction is a term, not a permanent bar, and the regulation lays out the terms in a ladder: roughly six months where the record shows carelessness or poor supervision, one year for a pattern involving common nonfood items, three years where the items were costly or conspicuous, and escalation on any second or third sanction.

That ladder is the case. Nothing in the letter is final, and the rung you land on is a conclusion drawn from evidence the agency assembled without you. A deli that heated sandwiches for EBT customers isn’t the same as a store selling appliances off the books, and a clerk who rang detergent through on a busy Friday isn’t a practice. Those distinctions are worth months of authorization, and they’re argued with documents.

The most useful document in almost every one of these cases is the itemized sale. FNS works from amounts and dates; your point-of-sale system holds the basket. When the flagged transaction turns out to be forty dollars of groceries and one four-dollar item that should have been split tender, the shape of the charge changes. When the flagged set is thirty transactions out of eleven thousand, the claim of a pattern gets weaker, and with it the claim of intent.

The second document is the system. Stores that configured EBT eligibility in the POS, posted rules at the register, trained clerks and kept the signed sheets are stores that built a program and had it fail occasionally. That’s the definition of carelessness rather than practice, and it’s the argument for the lowest rung. Owners routinely have this material and never file it, because nobody told them the letter was the only chance.

There’s also a money exit that most owners never hear about. Where a disqualification would cause hardship to participating households - the classic case being a neighborhood with no comparable store within a reasonable distance - 7 CFR 278.6(f) allows FNS to impose a civil money penalty instead of the term. That showing is built from geography and shopper facts, not from sympathy, and it has to be made in the response rather than after the terminal goes dark.

If your letter charges ineligible items, don’t treat it as the small version of a trafficking case. Treat it as the one case where the number is genuinely movable - and move it inside the ten days. Call us today and bring the attachment and last month of register data.

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THE BENCH

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Second generation, practicing since 1976. Your case isn’t handed to a paralegal and a template - a lawyer reads the attachment, calls your wholesaler, and drafts the response. Every client holds the senior partner’s cell number.
Spodek Law Group - the team
SPODEK LAW GROUP P.C. · NEW YORK
Todd Spodek
Todd Spodek
MANAGING PARTNER
Ralph Franco
Ralph Franco
SPODEK LAW GROUP P.C.
Jeremy Feigenbaum
Jeremy Feigenbaum
SPODEK LAW GROUP P.C.
Claire Banks
Claire Banks
SPODEK LAW GROUP P.C.
Alex Zhik
Alex Zhik
SPODEK LAW GROUP P.C.
QUESTIONS · INELIGIBLE ITEMS
01 My clerk rang up detergent once. Is that a pattern?
Almost certainly not, and saying so with numbers is the defense. A pattern means repeated conduct across the review period. One or two transactions out of thousands supports carelessness at most, which is the six-month rung, and sometimes supports no sanction at all.
02 We took EBT for hot coffee. Everyone does.
Everyone gets charged for it too. Hot and prepared foods intended for immediate consumption aren’t eligible, and warmers next to the register generate these cases constantly. The fix in the response is showing the volume was incidental and that the store has since blocked the SKUs.
03 Can I pay instead of losing EBT for a year?
Sometimes. 278.6(f) permits a money penalty in lieu of a term disqualification where the disqualification would cause hardship to participating households. It turns on whether your customers have a comparable alternative nearby, so the argument is geographic and needs to be filed with the response.
04 Is this going to become a trafficking case?
It can, if the file grows. Large ineligible-item volume sometimes gets re-read as an exchange of benefits for something other than eligible food, which is the trafficking definition. That’s one reason to answer precisely rather than broadly, and to keep the response consistent with your records.
SEND THE LETTER TO COUNSEL

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WHAT HAPPENS NEXT
Today. A lawyer reads the letter and fixes your real deadline from the receipt date. You’ll know where you stand before we hang up.
Day one. If trafficking is charged, the written penalty request goes in immediately.
Days two to nine. Invoices, register data, inventory and the compliance file get assembled.
Before day ten. The response is filed, transaction by transaction, with exhibits.
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THE ASK

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.

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THE HARD RULES, IN ONE PLACE
Ten days from receipt. No extensions, for any reason. The rung is argued from evidence - it isn’t fixed by the letter. A hardship penalty must be raised in the response, not after. Second and third sanctions escalate automatically. Unanswered transactions in the attachment read as conceded.
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