NACS, along with SIGMA, filed a formal comment letter in response to the Food & Nutrition Service’s (FNS) proposal to survey large retailers about their participation in the Supplemental Nutrition Assistance Program (SNAP) and, specifically, about their anti-fraud measures. While NACS supports the integrity of SNAP and FNS’s efforts to lower fraud within the program, NACS urges the agency to design a survey that is user friendly, comprehensive, and secure.

With respect to handling business sensitive information in the survey, NACS stated, “In order to enhance the quality, utility, and clarity of the information to be collected, FNS must ensure (at minimum) that the survey data will be anonymized and not released to the public even if it is the subject of a Freedom of Information Act (FOIA) request. Stores will be reticent to share specific data about their SNAP fraud detection and prevention techniques if it is possible to tie the information back to a specific retailer (or even a specific store), or if the information will be publicly disseminated (whether through a FOIA request or hacking).”

NACS also urged FNS, who proposed surveying a company’s SNAP representative and store managers, to consider the time cost to businesses and to allow the company to choose the employee best suited to answer questions about SNAP. To ensure the survey’s effectiveness, it is essential that the agency speak to the person who is the most equipped to answer its questions and can dedicate the appropriate time to the inquiry.

Though the agency only intends to survey large retailers, a majority of the convenience store industry is comprised of small retailers, highlighted NACS. Those small retailers have operations and capacity that is vastly different from larger retail companies.

“NACS and SIGMA believe FNS should specifically survey small retailers to uncover what their fraud prevention techniques are and the extent to which those techniques have proven successful. Acquiring data from both large and small retailers would provide the Agency with critical information that would assist the Agency in ensuring that any future policy proposals would not be unduly burdensome on retailers, and small retailers in particular,” stated the letter.

FNS will review the comments submitted about the proposed survey before moving forward with its implementation. Please stay tuned to the NACS Daily for more information.