Final_Draft_6-22-2018_-_P-18-347_-_Investigation_Augmentation_Project_-_Performance_Work_Statement_(004).pdf

USDA, FNS, SNAP, Investigation Augmentation Project, Performance Work Statement i | P a g e

SUPPLEMENTAL NUTRITION

ASSISTANCE PROGRAM

INVESTIGATION

AUGMENTATION

PROJECT

PERFORMANCE WORK

STATEMENT

Prepared for:

U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS)

3101 Park Center Drive Alexandria, VA 22302 ii | P a g e

April 13, 2018

Glossary and Acronym Listing

Reference Definition ALERT Anti-Fraud Locator Using Electronic Benefits

Transfer (EBT) Retailer Transactions

RPMD Retailer Policy and Management Division

CFR Code of Federal Regulations

CNP Child Nutrition Programs

COR Contracting Officer’s Representative

CPARS Contractor Performance Rating System

EBT Electronic Benefits Transfer

FBI Federal Bureau of Investigation

FNS Food and Nutrition Service

OIG Office of the Inspector General

PPI Personally Identifiable Information

POC Point of Contact iii | P a g e

PRWORA

Personal Responsibility and Work Opportunity Reconciliation Act 1996

QAS Quality Assurance Surveillance

ROD Retailer Operations Division

SLEB State Law Enforcement Bureau

SNAP Supplemental Nutrition Assistance Program (formerly known as the Food Stamp Program)

STARS Store Tracking and Redemption System

USDA United States Department Of Agriculture

WIC Women, Infants, and Children iv | P a g e

Table of Contents

1. INTRODUCTION

2. BACKGROUND

2.1 FOOD AND NUTRITION SERVICE (FNS) AND THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM

(SNAP) 1

2.2 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP) AND ASSOCIATED FRAUD

2.2.1 Use of EBT and Trafficking

2.2.2 Monitoring, Investigating, and Prosecuting Retailer Fraud

2.3 STORE TRACKING AND REDEMPTION SYSTEM (STARS)

3. SCOPE

4. OBJECTIVES

5. TRAINING

6. INVESTIGATIONS

7. TECHNOLOGY AND OPERATIONAL CONSTRAINTS

8. DEMONSTRATION AND ASSESSMENT

9. 11. STANDARDS, REGULATIONS, AND GUIDELINES

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1. Introduction The United States Department of Agriculture (USDA), Food and Nutrition Service (FNS), Retailer Operations Division (ROD) seeks a qualified contractor to enhance the Supplemental Nutrition Assistance Program (SNAP) in the area of retailer investigations. It is seeking personnel and advanced methods to:

1) Investigate retailers whose stores have been identified and reviewed by FNS and are suspected to be committing SNAP fraud by performing undercover work and posing as SNAP recipients.

2) Identify new methods of investigating possible fraudulent retailers.

3) Determine what other stores in the neighborhood could be committing fraud.

ROD is seeking to enhance Program Integrity by reducing the number of fraudulent retailers and increasing the awareness of zero tolerance toward fraud within the retailer communities.

2. Background

2.1 Food and Nutrition Service (FNS) and the Supplemental Nutrition Assistance Program

(SNAP)

FNS administers the nutrition assistance programs of the USDA. The mission of FNS is to provide children and needy families better access to food and a healthier diet through its food assistance programs and comprehensive nutrition education efforts. In addition to providing access to nutritious food, FNS also works to empower program participants with knowledge of the link between diet and health.

FNS was established on August 8, 1969, but many of the food programs originated long before FNS existed as a separate agency. The Supplemental Nutrition Assistance Program (SNAP), which is the cornerstone of USDA's nutrition assistance programs, began in its modern form in 1961, but it had its origins in the Food Stamp Plan to help the needy in the 1930's. The benefits were first issued in the form of stamps. When the program was reconstituted in 1961, the benefits were issued in the form of a “Food Stamp Program” coupon. Over time, coupons were replaced by Electronic Benefits Transfer (EBT), which was built on the same technology utilized by commercial debit cards. As of October 1, 2008, the Food Stamp Program’s name was changed to the SNAP. In June 2009, paper coupons were de-obligated, and EBT became the sole method of SNAP benefit issuance.

FNS works closely with the States in the administration of the SNAP; this is most salient on the recipient side. States determine most administrative details regarding distribution of food benefits and eligibility of participants while FNS provides funding to cover most of the States' administrative costs. On the retailer side, FNS’s Retailer Operations Division (ROD) manages the retailer application and reauthorization process, and reviews, prioritizes and investigates all stores which appear to be violating SNAP retailer regulations.

USDA’s Office of Inspector General (OIG) has the responsibility for all investigative activities within the department. The OIG, through a Memorandum of Understanding, has given FNS, ROD the authorizty to conduct investigations and take administrative action. In ROD, the Retailer Investigative Branch (RIB) performs the undercover investigations.

FNS’s Retailer Management Centers (RMC) are responsible for the authorization and compliance of retailers participating in the program. Firms that are authorized to participate in the program are investigated to determine whether or not they comply with the program regulations. Retailers that are found to be non-compliant are subject to ROD taking Administrative action, which can be in the form of warnings, disqualifications, and other sanctions, The OIG, often with ROD’s assistance, conducts criminal and civil investigations that may lead to arrests, prosecution, and convictions of violators of this program.

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2.2 Supplemental Nutrition Assistance Program (SNAP) and Associated Fraud SNAP helps low-income individuals and families obtain a more nutritious diet by supplementing their income with benefits to purchase nutritious food (for example, meat, dairy, fruits, and vegetables) but not items such as soap, tobacco, or alcohol. FNS pays the full cost of SNAP benefits and 50 percent of the states’ administrative costs and is responsible for promulgating program regulations and ensuring that state officials administer the program in compliance with program rules. The states determine whether households meet the program’s income and asset requirements, calculate monthly benefits for qualified households, and issue benefits to participants on an electronic benefits card.

On the retailer side, FNS approves retail firms and community meal services and programs to be able to exchange food for SNAP benefits. The Agency accepts and reviews store and meal service applications for approval by using a Store Tracking and Redemption System (STARS). STARS maintains store identification, location, ownership, and monitoring data. STARS also maintains investigative, sanction, authorization, and redemption information. Retailers may not legally accept SNAP benefits without being authorized to do so by FNS. STARS provides State EBT processors FNS authorization data to allow only authorized entities to operate within the EBT system.

In the fiscal year 2017, more than $63 billion in client benefits were redeemed in over 263,000 participating stores, farmers’ markets, direct marketing farmers, homeless meal providers, treatment centers, group homes, and others authorized to accept SNAP. The Program served more than 42 million participants, with the average household receiving a little over $254 in benefits per month.

2.2.1 Use of EBT and Trafficking

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) required each state agency to implement an EBT system to distribute benefits electronically. Before EBT, recipients used highly negotiable food stamp coupons to pay for allowable foods. The last state completed its implementation of EBT in June of 2004.

Under the EBT system, recipients receive an EBT card imprinted with their name and a personal account number or unique PIN number. Benefits are automatically credited to the recipients’ accounts once a month. In a legitimate transaction, recipients swipe their EBT card, which works like a debit card, through an electronic point-of-sale machine at the grocery checkout counter. They enter their card identification number to access their EBT accounts and to authorize the transfer of benefits to the retailer’s bank account to pay for eligible food items. In a trafficking transaction, cash is received, usually at a discounted rate, instead of groceries.

2.2.2 Monitoring, Investigating, and Prosecuting Retailer Fraud In addition to approving retailers to participate in the program, FNS has the primary responsibility for monitoring their compliance with requirements and administratively disqualifying those who commit EBT transactions in exchange for cash or non-food items. FNS collects and monitors EBT transaction data to detect suspicious patterns of transactions by retailers. The data and the data analysis are made by the Anti- Fraud Locator using Electronic Benefits Transfer (EBT) Retailer Transactions (ALERT) system and are available to program analysts and investigators, who are responsible for assessing the case and suggesting appropriate recommendations for action to be taken.

FNS notifies the USDA’s Office of the Inspector General (OIG) before working a case. OIG has access to EBT data and the ALERT system and may choose to open an investigation on a case developed by FNS or open cases on its own for possible criminal or civil prosecution. OIG may also work with the Federal Bureau of Investigation (FBI), and other Federal agencies, to investigate retailers for criminal prosecution.

The U.S. Secret Service is the overall cognizant Federal agency for crimes involving interstate electronic

3 | P a g e violations and may also be involved in some cases. Also, some states have State Law Enforcement Bureau (SLEB) Memorandums of Understanding with FNS that allow them to initiate retailer investigations provided they first obtain clearance from FNS. More commonly, the SLEBs investigate and take action on fraud and program abuse by recipients.

When trafficking is proven, FNS administratively penalizes the store owners, usually by permanent program disqualification or, in limited circumstances, a civil money penalty instead of disqualification.

Store owners who sell ineligible goods but do not traffic are subject to disqualification periods that range from six months to three years. FNS sends a formal charge letter to the retailer detailing the charges and potential penalties.

The retailer may attempt to rebut the charges. However, if the retailer does not respond or cannot provide sufficient evidence to justify specific redemptions, then a determination letter is sent executing the program disqualification. The retailer may appeal the decision, first to the FNS Administrative Review Branch and later to the appropriate federal district court.

2.3 Store Tracking and Redemption System (STARS)

STARS supports the federal government’s management of retailer participation in SNAP. Federal STARS users are located in the FNS National Office, Regional Offices, Retailer Investigations Branch, and USDA Office of Inspector General. Non-Federal users include contract staff performing support functions, SLEBs, and State Agencies administering the Special Supplemental Program for Women, Infants, and Children (WIC).

Information on retailers that participate in SNAP is stored in STARS. It provides automated support for benefit redemption activity, retailer authorization, monitoring, investigation, on-going participation, withdrawal, and disqualification of stores.

3. Scope FNS must ensure that all store owners obey the program’s rules and regulations and that those who do not are (at a minimum) removed from the program. FNS has implemented systems for identifying firms that pose a risk to the program’s integrity. Retailers found violating the program may be disqualified from the program, assessed civil money penalties, or fined. Serious violations can result in the prosecution, either civil or criminal, of store owners and employees at the Federal, State, or local levels.

Due to the insufficient amount of investigators, there is a desire to acquire additional resources to assist the current team of federal investigators. These extra resources are needed to be employed to effectively and efficiently help reduce and deter this criminal activity. ROD is seeking assistance from investigative service suppliers to provide Contracted Undercover Investigators (CUI) who will be able to act as undercover SNAP recipients and conduct surveillance of retailers and others who are suspected of attempting to defraud the SNAP Program.

4. Objectives The objective of the SNAP Investigation Augmentation Project is to assist in ROD’s goal of eliminating fraud within SNAP. ROD is specifically tasked to examine and curtail fraudulent activities aggressively;

ROD needs to increase resources by utilizing Contracted Undercover Investigators (CUI). These CUIs need to be of diverse age, gender, ethnic, and cultural backgrounds to be effective and valuable assets to FNS. By matching and utilizing the appropriate CUI to a social enclave, he/she will be able to assimilate

4 | P a g e and gain acceptance with a suspected fraudulent retailer. The requirement of a CUI to speak and understand several languages will aid in identifying other possible fraudulent target retailers without compromising themselves or the objective.

CUIs will go into stores acting as SNAP recipients. CUIs will make purchases using SNAP benefits. The purchases will include both, eligible and ineligible SNAP items. In addition to these purchases, CUIs will also attempt to exchange SNAP benefits for cash, a practice known as trafficking. CUIs will then write accurate reports about their visits to the stores; documenting all items purchased and all items refused to be sold with SNAP benefits, all trafficking attempts and successes, and all comments made at the store by both the clerk(s) and the CUI. Outsourcing to a nationwide private investigative firm will create a resource pool of CUIs throughout the United States.

MINIMUM MANDATORY REQUIREMENT This is for a national contract. The vendor should be licensed and be available to work in every state and must DEMONSTRATE the ability to provide contract investigators nationwide. FNS anticipates issuing the first task order to conduct investigations in specific areas of the country and intends to issue additional task orders in the base and/or option years to continue to expand towards nationwide. The area(s) for the initial task order will be determined or made known at the time that the contract is awarded. Those unable to begin work in one or more nationally chosen areas at the time the contract is awarded should not respond to the RFP.

It is anticipated that FNS will award a single Indefinite Delivery/Indefinite Quantity (IDIQ) contract, and individual phases of the SNAP Investigation Augmentation Project services will be procured through issuance of separate and discrete Task Orders for specified quantities of investigations in certain areas of the country at fixed per-visit prices. The term of this acquisition shall be up to a maximum of five (5) years (so a resulting IDIQ contract will include one Base Year and four additional Option Years). FNS reserves the right to issue one or more task orders for each contract year at its sole discretion.

The investigative firm(s) will provide ROD with CUIs, which have undergone an in-depth background check to include:

• Education Verification

• Statewide and National Criminal History Checks

• Prior Employment Verification

• Drug Test

• Registration Under Individual State License Requirements

• U. S. Citizenship verified though E-Verify

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The CUIs must possess a high degree of self-discipline and moral character. These traits will guide behavior to legally acceptable and ethical methods of investigation. All aspects of the investigation must be carefully calculated, and no actions will be taken which might jeopardize the case, harm the integrity of FNS, or compromise the safety of the CUI.

The characteristics expected of a CUI:

• Professionalism

• Adaptability

• Excellent Reasoning Ability

• Excellent Oral Communication

• Excellent Written Skills

• Exceptional Observation Skills

• Excellent Listening Skills

• Bilingual or Multilingual

• Computer Literate

• Patience

• Initiative

• Ability to sit and stand for long periods of time

Investigations sometimes result in civil prosecution action against retailers under the False Claims Act.

Evidence of violations discovered in an investigation can be the basis for criminal prosecution if escalated by OIG or other federal law enforcement agencies. Therefore, CUIs must be able to properly testify in court hearings. The combination of delegated investigative authority, stringent administrative sanctions, and civil prosecutions provides FNS with a powerful deterrent and contributes significantly to voluntary compliance by the majority of authorized firms.

SNAP investigations are the primary mission of RIB, and the use of CUIs will assist RIB in stopping fraudulent retailers and expectantly deter other retailers from conducting unauthorized practices with SNAP benefits.

CUIs must understand and agree to the possibility of extensive multi-state overnight travel; and because of this, all CUIs must possess an active, valid state driver’s license. CUIs must also be available to work nights and weekends.

The Contractor must equip all CUIs with Notepads/Tablets with Windows Operating System.

Investigative workloads vary based upon information the RIB receives from various resources, or external law enforcement agency requirements to support a criminal referral, the required resource pool of CUIs will fluctuate; meaning the need for various age, gender, and ethnicities may vary with assignments.

The Contractor shall assign to this contract the following key personnel: CUI Supervisors.

5. Training

5.1 INITIAL TRAINING

FNS will supply initial training to the Contractor and the CUI’s before the investigations start.

This training will consist of but not be limited to:

• Mission Statement

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• FNS Definitions and Terminology

• Fundamentals of Conducting Store Visits

• Donations and Trafficking Cash Handling

• Required Reports and Report Writing

• Identification of Clerks

• EBT Card use and Handling

• Required FNS Reports and STARS System

5.2 ON-GOING TRAINING

Upon initial training provided by FNS, the Contractor shall be responsible for the training of all staff, including providing training to new staff within three days of being hired. Contract staff should not be allowed to conduct any on-site store visits before receiving training. Based on feedback from FNS, the Contractor may need to conduct follow-up training for staff, as necessary. For example: if an investigator is achieving only negative or no result investigative results, FNS may determine that the CUI is in need of further training before being allowed to continue investigative work on their own.

Based on a review of investigation results, FNS will determine if there is a need to conduct follow-up training sessions. Such training will be held at a location to be determined by FNS. If after such additional training, the CUI is still achieving negative or non-positive results, FNS reserves the right to request the contractor immediately replace the CUI. The Contractor, throughout the term of the contract, shall be responsible for providing its staff with refresher training that covers topics that impact the on-site store visits. FNS may wish to participate in the development of training as necessary.

6. Investigations

6.1 CONDUCTING STORE VISITS

The CUI shall travel to all retail stores identified in the assigned request for investigation (RFI).

Before entering the store, the investigator will have reviewed any pertinent documents supplied by FNS such as hours when EBT activity may peak, store visit photos as well as the demographics of the area enabling the CUI to adapt their technique to maximize investigative outcomes.

Some investigations may require video surveillance work which the CUIs must perform; if so, additional direction and training by FNS will be given to the Contractor.

CUI will not engage in any activity not authorized by FNS. For example, the CUI will not engage in:

• Any audio or video recording of conversations between any involved parties (unless previous written approval by FNS is obtained)

• The carrying of weapons of any kind

• The use of non-employed staff of the contracting agency

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• Threatening, coercing or any promises for providing information or engaging in any conduct which may jeopardize the investigation or the integrity of FNS.

• CUI will not use cash for the purchase of any items from the retailer or their representative.

Investigations will be assigned after the award of the contract. This decision will be made by FNS.

Regardless, the timeframe for starting investigations will remain the same unless mitigating reasons are presented and agreed upon by FNS.

6.2 EBT CARDS

The CUI will be provided an EBT card(s) in an undercover name of which they feel best fits their undercover role. These EBT cards are issued at no cost to the vendor and are the property of FNS; they shall be safeguarded at all times. The EBT card is only to be used for the purchase of eligible and ineligible items and trafficking purposes between the CUI and the Retailer. Any misuse of any EBT card may result in the immediate termination of the contract.

6.3 LOST OR STOLEN EBT CARD

EBT cards lost, stolen or misplaced shall be reported immediately to the FNS liaison1. If a CUI fails to report such lost, stolen, or misplaced card to the Contractor, said investigator would be relieved of any FNS contract work. If the Contractor fails to report any lost, stolen, misplaced or misused EBT card within 24 hours, the contract may be terminated.

6.4 ITEMS PURCHASED

All items purchased by the CUI will be processed in accordance with the FNS guidelines2. Items will be donated to local charities to be determined by FNS and done daily or by the next day (if purchased after donation center hours). The charities approved by FNS will be required to sign a receipt attesting to the donation. Items not fit for donations such as ineligible items (beer, cigarettes, etc.) will be destroyed by Contractor management and witnessed by an FNS staff member or representative.

6.5 LOSS OF PURCHASED ITEMS

Any items purchased by the CUI which become lost or missing due to circumstances beyond the contractor's control shall be reported to the FNS liaison within 24 hours of said loss. Failure to report such loss may result in the termination of the contract.

6.6 TRAFFICKING CASH

Any cash received from the retailer or their representative during an investigation conducted by the CUI shall be turned over to the Contractor’s Manager where it will be recorded and secured until the cash is surrendered to FNS. At no time should the cash be utilized, replaced, and/or kept by the CUI.

6.7 IMPROPER HANDLING OF TRAFFICKING CASH

1 The contractor will have one main FNS POC for their communications with FNS which will be designated after contract award.

2 The detailed guidelines and procedures for investigations are sensitive and will therefore be provided to the selected contractor after contract award.

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Any improper handling use or misuse of trafficking cash will result in the immediate termination of the contract. Any loss of trafficking cash through means uncontrollable by the contractor or CUI shall be reported within the first 24 hours. Failure to report such loss may result in the termination of the contract.

7. Technology and Operational Constraints All contracted personnel using FNS data systems must ensure that data integrity is maintained and all must adhere to Personally Identifiable Information (PII) security procedures. No FNS data will be put or stored on unauthorized systems.

Security The Vendor shall be responsible for properly protecting all information used, gathered, or developed as a result of this contract. The Vendor shall implement procedures that ensure appropriate administrative, technical, and physical safeguards are established for the security and confidentiality of government information, data, and/or equipment. The Vendor’s procedures shall be consistent with Government, OMB Circular A-130, Management of Federal Information Resources, the Computer Security Act of 1987, the Federal Information Security Management Act of 2002 (FISMA), and the Privacy Act. In addition, during all activities and operations on government premises, the Vendor shall comply with the policies, rules, procedures and regulations governing the conduct of personnel or protection of government facilities and data as expressed by USDA, written or oral.

(a) Sensitive Information Storage and Disclosure Sensitive-but-Unclassified (SBU) information, data, and/or equipment will be disclosed only to authorized personnel on a Need-To-Know basis. The holder shall ensure that appropriate administrative, technical, and physical safeguards are established to ensure the security and confidentiality of this information, data, and/or equipment is properly protected. When no longer required, this information, data, and/or equipment will be returned to Government control; destroyed; or held until otherwise directed. Destruction of items shall be accomplished by tearing into small parts; burning; shredding or any other method that precludes the reconstruction of the material, consistent with GSA guidelines.

(b) Protection of Information All information about the USDA networks and/or the security posture of any USDA information asset gathered or created under this contract will be considered SBU information. It is anticipated that this information will be gathered, created and stored within the primary Government work location. If the Vendor personnel must remove any information from the primary work area they should protect it to the same extent they would their proprietary data and/or company trade secrets. If the Vendor must remove any materials from the primary work location prior approval must be obtained from the COR.

(c) Security and Privacy The use of any information that is subject to the Privacy Act will be utilized in full accordance with all rules of conduct as applicable to Privacy Act Information.

(d) Security Classification The preparation of the deliverables under this contract will be completed at a Sensitive-But-Unclassified (SBU) level unless otherwise stated, in writing, by the COR.

(e) Facility Access

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All Vendor personnel who work at the USDA/FNS site must have approval for facility access; the Vendor must supply the names and other required information of those employees selected to perform the work to the COR.

(f) Special Requirements All work performed must meet and comply with all National Institute of Standards & Technology (NIST), other government-wide laws and regulations, and USDA and OCIO (Office of the Chief Information Officer) directives, guidelines, and requirements for protection and security of Information Technology. Such directives and guidelines include, but are not limited to:

• Computer Security Act of 1987

• Federal Information Security Management Act (FISMA)

• OMB Circular A-130, Management of Federal Information Resources

• Presidential Directive Decision 63, Critical Infrastructure Protection (CIP)

• Presidential Directive Decision 67, Enduring Constitutional Government and Continuity of Government Operations

• Homeland Security Presidential Directive 7

• NIST’s Guide for Developing Security Plans for Information Technology Systems

(Special Publication 800-18)

• U.S. Government “Plain Language” Guidelines

• http://www.ocio.usda.gov/directives/files/dm/DM3535-000.htm

(g) Confidentiality and non-Disclosure The Vendor may have to access proprietary information and shall be required to sign non-disclosure and conflict of interest statements. The preliminary and final deliverables and all associated working papers, and other material deemed relevant by the agency that have been generated by the Vendor are the property of the U.S. Government and cannot be reproduced, or retained by the Vendor. When no longer required, this information, data, and/or equipment will be returned to Government control. All documents and information pertaining to network vulnerabilities, security policy, operational procedures or related functions shall be maintained under absolute accountability and relinquished to the COR upon completion of the contract.

Any unauthorized disclosure or breach of PII shall be reported to FNS immediately upon discovering the incident.

• Time Constraint: Investigations must be completed within 30 days of having received the assignment (unless FNS approval for an extension is granted before the deadline).

• Documentation: All visits to the store need to be fully documented.

8. Demonstration and Assessment FNS will select one vendor for this project. Based on the results of the base year, 4 option years may be exercised. The first task order in the base year will include approximately 150 investigations. Additional work/locations, through additional task orders may be executed in the base year; however, the base year will not exceed 1,000 investigations. In the option years, FNS expects to increase both the areas of coverage (eventually achieving nationwide coverage) as well as the total number of investigations. It is anticipated that subsequent option years, if exercised, will involve a minimum of 500 investigations up to a maximum of 1500 investigations.

http://www.ocio.usda.gov/directives/files/dm/DM3535-000.htm

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Along with the data already provided in this Performance Work Statement, the Agency will be providing additional details on the available data, agency documentation procedures, and the STARS system to the vendor(s) upon contract award due to the sensitive nature of these documents.

Along with the satisfaction of the objectives and constraints listed in Sections 4 and 5 above, the vendor will be assessed based on:

• Sanctionable success rate (a sanctionable investigation is an investigation consisting of at least one trafficking pass; or at least three passes consisting of the purchase of ineligible items)

• Trafficking success rate (trafficking success is an investigation consisting of at least one trafficking pass)

• The accuracy of reporting information in reports and/or STARS

• Speed – turnaround time from issuance of a case to completion

Firm selected to participate in this project will need to sign a confidentiality/non-disclosure agreement as some of the data and the FNS internal validation and investigative procedures are confidential.

9. Standards, Regulations, and Guidelines Federal Regulations at CFR 278.1: Approval of retail food stores and wholesale food: Includes a description of stores for eligibility and details on owner and store documentation requirements, the use of information provided on the applications by, among others, entities contracted by FNS. There is specific language limiting the use of owner SSNs and business EINs to the federal government. The regulations specify that a permanently disqualified store owner may not be reauthorized or otherwise seek ways to circumvent the penalty.

Federal Regulation at CFR 278.6: Disqualification of retail food stores and wholesale food concerns, and the imposition of civil money penalties instead of disqualifications: Lays out the terms and procedures for administrative sanctions and disqualifications.

Federal Regulation at CFR 274.1: Issuance system approval standards: Provides basic description and requirements on State agencies to establish Electronic Benefits Transfer systems of issuance.

Federal Regulation at CFR 274.8: Functional and technical EBT system requirements: Provides detailed information on the performance and security of State agency EBT processor systems.

2.3 Store Tracking and Redemption System (STARS)