What are the four criteria for a SNAP civil money penalty?
7 CFR 278.6(b)(1)
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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.
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The regulation calls them minimum standards, which is the important word. They aren’t a scoring system where three out of four earns partial credit. Published agency decisions routinely deny penalty requests where a single criterion was thin.
Criterion 1 and 2 - the policy, and when it existed
FNS looks for written and dated statements of firm policy reflecting a real commitment to preventing violations. Then it asks whether that policy and program were in operation at the location where the violations occurred, before they occurred. A policy drafted the week the charge letter arrived proves the opposite of what it needs to prove.
Criterion 3 - training you can document
Not that you told people. That you trained them, and can show it: signed and dated acknowledgements, ideally for the clerks who worked the flagged shifts, plus whatever materials the training used. This is where most requests fail and where most stores could have won.
Criterion 4 - ownership clear of it
A factual showing that ownership didn’t know, approve, benefit or participate. Schedules, till assignments, the write-up or termination that followed, and payroll records do more work here than any statement. Firearms or controlled-substance trafficking by ownership or management removes eligibility entirely, as does a third trafficking offense.
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