Why did USDA flag my even-dollar transactions?
7 CFR 278.6(b)(1)
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If there’s a way to keep your store in the program, we’ll find it. That’s the whole job.
It’s one of the most common lines in an attachment and one of the easiest to answer, provided the answer is filed inside the ten days.
The inference
A genuine grocery sale lands on an arbitrary figure - $37.42, $61.09. A negotiated exchange of benefits for cash lands on a round one, because a number was agreed first. When a store shows many transactions at exactly $20, $40 or $100, the system reads intent.
Why real customers do the same thing
Households on a fixed monthly benefit shop to a budget, out loud, at the counter: stop me at forty. Butchers work the scale to a number a customer names. Regulars buy the same staples every week and land on the same total. Stores that price staples in round figures produce round baskets by arithmetic.
How to rebut it
Itemized register data for each flagged transaction, showing an actual basket adding to that number. A short pattern analysis showing how many of your total transactions were round versus the flagged subset. Statements from regular customers describing how they shop. And where meat or produce is sold by weight, the scale tickets that tie a dollar figure to a quantity.
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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.
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