DETERMINATIONS · TEN DAYS FROM RECEIPT · 7 CFR 278.6(b)(1)
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DETERMINATIONS

What is a SNAP determination letter?

7 CFR 278.6(c) SPODEK LAW GROUP P.C. · UPDATED
THE SHORT ANSWER
It’s the decision. FNS has weighed the charge letter, your response and its own file, and imposed a sanction. A permanent disqualification takes effect the day you receive it, and you have ten days to request administrative review.
THE DEADLINE, EVERY TIME
10
DAYS FROM RECEIPT
7 CFR 278.6(b)(1)
FNS doesn’t grant extensions. In a trafficking case the civil money penalty request has to be inside that filing or 278.6(b)(2)(iii) forecloses it permanently.
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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We should only take on clients we can actually help.
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IN BRIEF
DETERMINATION LETTERS
7 CFR 278.6(c)
RETAILER DEFENSE
ON CALL 24/7
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Charge letter and determination letter get used interchangeably by owners, and they’re opposite ends of the process. The charge letter is an allegation with a deadline. The determination is the outcome.

What it contains

Under 7 CFR 278.6(c) the regional office reviews the letter of charges, any response, and whatever else is in its file, then issues the determination stating what was found and what sanction applies. If the finding is trafficking, the sanction is normally permanent disqualification, and the letter will also address whether the store was found eligible for a civil money penalty in lieu.

When it starts biting

A permanent disqualification takes effect immediately on receipt, whether or not review is requested. Term disqualifications generally wait for review to conclude. Firms determined eligible for a penalty in lieu may keep accepting benefits while review is pending - which is the practical reward for having asked in the first ten days.

The clock that starts now

Ten days from receipt to request administrative review under 7 CFR 279, in writing. New evidence is allowed at that stage, so everything the regional office never saw can still go in. After the final agency decision, thirty days to file in district court under 7 U.S.C. 2023, reviewed de novo.

IT IS THE DECISION
Not an allegation. The sanction is stated and, if permanent, immediate.
TEN MORE DAYS
Administrative review must be requested within ten days of receipt.
STILL WINNABLE
Review accepts new evidence; court review is de novo.
GENERAL INFORMATION · NOT LEGAL ADVICE Speak with counsel now →
FREE DEADLINE CHECK
Tell us the date on the envelope. We’ll tell you what day you’re on.
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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.
SEND THE LETTER TO COUNSEL

Tell us what happened. Eight fields, two minutes - and a lawyer reads it today.

RISK FREE · CONFIDENTIAL · ANSWERED WITHIN 24 HOURS, GUARANTEED
Counsel reading a client file
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.

Call 212 300 5196
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THE RULES BEHIND THIS ANSWER
Ten days from receipt. No extensions, for any reason. The CMP request must be in that first filing. A clerk’s conduct is attributed to the store. Unanswered transactions read as conceded. Ten more days to seek review after a determination.
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