A02 Clean DRAFT PWS - Retailer Investigations Projects.doc

Retailer Investigations Project January 14, 2021

PERFORMANCE WORK STATEMENT (PWS)

Supplemental Nutrition Assistance Program – Retailer Investigations Project

1. General: This is a non-personnel services contract to provide Retailer Investigations. The Government shall not exercise any supervision or control over the contract service providers performing the services herein. Such contract service providers shall be accountable solely to the Contractor who, in turn is responsible to the Government.

1.1 Description of Services/Introduction: The Contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to perform Retailer Investigations as defined in this Performance Work Statement except for those items specified as government furnished property and services. The Contractor shall perform to the standards in this contract.

The United States Department of Agriculture (USDA), Food and Nutrition Service, (FNS), Office of Retailer Operations and Compliance (ROC) assigns to the qualified Contractor to enhance Supplemental Nutrition Assistance Program (SNAP) integrity in the area of retailer investigations by providing personnel to:

1) Investigate retailers whose stores have been identified and reviewed by FNS and are suspected to be committing SNAP fraud

2) Suggest ways of identifying new methods of investigating possible fraudulent retailers

3) While investigating the store FNS has assigned, determine what other stores in the neighborhood if any that might be committing fraud and relay the information to FNS

4) Work with state and local partners in investigating SNAP fraud as directed by FNS

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

1.2 Background: 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 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 ROC manages the retailer application and reauthorization process, and reviews, prioritizes and investigates all stores which appear to be violating SNAP retailer regulations.

The Inspector General Act of 1978 specifically grants authority to the USDA’s Office of Inspector General (OIG) the responsibility to conduct all investigative activities within the department; however, the authority to conduct misdemeanor and limited felony level SNAP undercover investigations of authorized firms has been delegated to FNS. A Memorandum of Understanding (MOU) between the Office of Inspector General and the FNS at the USDA outlines the responsibilities of the parties for conducting investigations of firms and or persons suspected of violating SNAP regulations. Per the MOU criteria FNS notifies the USDA’s OIG before working particular cases. OIG 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 United States Secret Service is the overall cognizant Federal agency for crimes involving interstate electronic 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.

1.3 Objectives: The objective of the Retailer Investigations Project is to assist in ROC’s goal of eliminating fraud within SNAP. ROC is specifically tasked to examine and curtail fraudulent activities aggressively; ROC needs to increase resources by utilizing external certified undercover investigators. Outsourcing to a nationwide private investigative firm creates a resource pool of external certified undercover investigators throughout the United States and its territories.

5) 1.4 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. Contractor must be licensed and be available to work in every one of the 50 States and territories and must demonstrate the availability of having such licensed undercover investigators in all areas of the country (nationwide). These licensed undercover investigators will need to conduct undercover investigations of retailers who are suspected of attempting to defraud the SNAP. The Contractor shall complete all retailer investigations that are assigned to them and submit their findings to FNS. During the Base Year of this contract, it is estimated that 4,330 investigation be completed; for Option Year 1, it is estimated that 6,225 investigation be completed; for Option Year 2, it is estimated that 7,476 investigations be completed; for Option Year 3, it is estimated that 8,943 investigations be completed; and for Option Year 4, it is estimated that 11,144 investigations be completed. Investigations are assigned by FNS according to priority and the needs of the agency. Hence, investigations may vary in number from state to state and is unpredictable. The Contractor shall expect increases and reductions in casework in a given area without notice and must adapt accordingly.

1.5 Period of Performance: The period of performance shall be for one (1) Base Year of 12 months and four (4) 12-month option years. The Period of Performance reads as follows:

Base Year

6/1/2021-5/31/2022

Option Year 1

6/1/2022-5/31/2023

Option Year 2

6/1/2023-5/31/2024 Option Year 3

6/1/2024-5/31/2025 Option Year 4

6/1/2025-5/31/2026

1.6 General Information

1.6.1 Quality Control: The Contractor shall develop and maintain an effective Quality Control Program (QCP) to ensure services are performed in accordance with this PWS. The Contractor shall develop and implement procedures to identify, prevent, and ensure non-recurrence of defective services. The Contractor’s quality control program is the means by which assurance that the work complies with the requirement of the contract. The QCP will be delivered with the contractor’s proposal and is to be included in the evaluation factor.

1.6.2 Quality Assurance: The Government shall evaluate the Contractor’s performance under this contract in accordance with the Quality Assurance Surveillance Plan. This plan is primarily focused on what the Government must do to ensure that the Contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and the minimum acceptable defect rate(s).

1.6.3 Recognized Holidays: The Contractor has the flexibility to perform services on federal holidays as they wish.

1.6.4 Hours of Operation: The Contractor is responsible for conducting investigations and there are no set times in which these investigations should be conducted and no set days of the week.

1.6.5 Place of Performance: The work to be performed under this contract will be performed at retailer locations and at contractor/investigators’ facilities.

1.6.6 Type of Contract: This is a Firm Fixed Price contract.

1.6.7 Security Requirements: Contractor personnel performing work under this contract must have a NACI Tier 1 level of security which will be processed through USDA upon being assigned to this project.

1.6.7.1 Physical Security: The Contractor shall be responsible for safeguarding all government information provided for contractor use. The Contractor shall be responsible for properly protecting all information used, gathered, or developed as a result of this contract. The Contractor 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 Contractor’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 Contractor 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.

1.6.7.2 Key Control: Not applicable since no keys/key cards will be issued.

1.6.7.3 Sensitive Information Storage and Disclosure: Sensitive-but-Unclassified (SBU) information, data, and/or equipment will be disclosed only to authorize 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.

1.6.8 Special Qualifications: The Contractor is responsible for ensuring that all State Licenses (if applicable by State) are maintained current and that all investigators possess and maintain current Investigation Licenses (if required by States) during the execution of this contract.

1.6.8.1 Special Requirements: The Contractor is required to hire certified undercover investigators of diverse age, gender, ethnic, and cultural backgrounds to be effective and valuable assets to FNS. The requirement of an investigator to speak and understand several languages will aid in identifying other possible fraudulent target retailers without compromising themselves or the objective. The Contractor shall provide FNS with certified undercover investigators that have undergone an in-depth background check by the Contractor to include:

· Education Verification

· Statewide and National Criminal History Checks

· Prior Employment Verification

· Drug Test

· U.S. Citizenship verified through e-Verify

· Registration under individual State license requirements The certified undercover investigators 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 investigator.

The characteristics expected of an investigator:

· 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

· Previous experience as a law enforcement officer or experience working with law enforcement is preferred

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, contracted undercover investigators must be able to properly testify in court hearings. The Contractor needs to have the ability to provide preparation for both administrative and judicial hearings when necessary.

The certified undercover investigators shall travel to all retail stores identified in the assigned request for investigation (RFI) which will be issued weekly; but, depending on necessity, RFIs might be issued at more frequent intervals. Before the investigation begins, 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 investigator to adapt their technique to maximize investigative outcomes. Some investigations may require video surveillance work which the investigators must perform; if so, additional direction and training by FNS will be given to the Contractor.

Certified undercover investigators will not engage in any activity not authorized or first approved by FNS/ROC. Any audio or video recording of conversations between any involved parties is prohibited (unless previous written approval by FNS is obtained).

The following is prohibited:

· The carrying of weapons of any kind

· The use of non-employed staff of the Contractor

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

· Investigator will not use cash for the purchase of any items from the retailer or their representative

· Investigators are forbidden to purchase illicit or illegal drugs under any circumstances unless working with or under the direct supervision of the OIG or authorized law enforcement agency

· Use of illicit/illegal drugs and/or alcohol while conducting any work for FNS/ROC

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

1.6.9 Post Award Conference/Periodic Progress Meetings: The Contractor shall attend any post award conference convened by the contracting activity or contract administration office in accordance with Federal Acquisition Regulation Subpart 42.5. The Contracting Officer, Contracting Officers Representative (COR), and other Government personnel, as appropriate, may meet periodically with the contractor to review the contractor's performance. At these meetings the Contracting Officer will apprise the Contractor of how the Government views the Contractor's performance and the Contractor shall apprise the Government of problems, if any, being experienced. Appropriate action shall be taken to resolve outstanding issues. These meetings shall be at no additional cost to the Government.

1.6.10 Contracting Officer Representative (COR): The (COR) will be identified by separate letter. The COR monitors all technical aspects of the contract and assists in contract administration. The COR is authorized to perform the following functions: assure that the Contractor performs the technical requirements of the contract. Performs inspections necessary in connection with contract performance, maintains written and oral communications with the Contractor concerning technical aspects of the contract, issues written interpretations of technical requirements, monitors Contractor's performance and notifies both the Contracting Officer and Contractor of any deficiencies, authorized access to FNS systems, and processes on-boarding of personnel. A letter of designation issued to the COR, a copy of which is sent to the Contractor, states the responsibilities and limitations of the COR, especially with regard to changes in cost or price, estimates or changes in delivery dates. The COR is not authorized to change any of the terms and conditions of the resulting order.

1.6.11 Key Personnel: The following personnel is considered key personnel by the Government: Project Manager. The Contractor shall provide a Project Manager who shall be responsible for the performance of the work. The name of this person and an alternate who shall act for the Contractor when the manager is absent shall be designated in writing to the Contracting Officer. The Project Manager or alternate shall have full authority to act for the Contractor on all contract matters relating to daily operation of this contract. The Project Manager or alternate shall be available between the core hours of 10am through 3pm Monday through Friday except Federal holidays or when the government is closed. Qualifications for key personnel are listed below:

· Minimum of a 4 years college degree

· Minimum of 5 years investigative experience (i.e. government/private investigative work)

· Minimum of 5 years of senior management experience with proven ability to resolve client issues, adept at management and technical review to ensure quality

· Minimum of 2 years experience managing a country-wide field staff for government projects

· Knowledge of SNAP requirements, policies, and procedures

In addition, investigation supervisors, training staff, and a Quality Manager will need to be approved by FNS but are not key personnel.

1.6.12 Contractor Travel: Although it is not anticipated that there would be much overnight travel, on rare occasions, some overnight travel might be required. Therefore, certified undercover investigators must understand and agree to the possibility of multi-state overnight travel. Because of this, all investigators must possess an active, valid state driver’s license. Certified undercover investigators must also be available to work nights and weekends. Travel must be in accordance with the Federal Travel Regulation (FTR) contained in 41 Code of Federal Regulations (CFR), Chapters 300 through 304. This is a cost reimbursable line item. Travel shall not be made unless authorized by the COR. Payment will be made for actual expenses with proper supporting documentation.

1.6.13 Data Rights: The Government has unlimited rights to all documents/material produced under this contract. All documents and materials, to include the source codes of any software, produced under this contract shall be Government owned and are the property of the Government with all rights and privileges of ownership/copyright belonging exclusively to the Government. These documents and materials may not be used or sold by the Contractor without written permission from the Contracting Officer. All materials supplied to the Government shall be the sole property of the Government and may not be used for any other purpose. This right does not abrogate any other Government rights.

1.6.14 Confidentiality and Non-Disclosure: The Contractor 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 Contractor are the property of the U.S. Government and cannot be reproduced or retained by the Contractor. 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 Personally Identifiable Information (PII) shall be reported to FNS immediately upon discovering the incident.

2. Definitions and Acronyms:

2.1. DEFINITIONS:

2.1.1. CONTRACTOR - A supplier or vendor awarded a contract to provide specific supplies or service to the government. The term used in this contract refers to the prime.

2.1.2. CONTRACTING OFFICER - A person with authority to enter into, administer, and or terminate contracts, and make related determinations and findings on behalf of the government. Note: The only individual who can legally bind the government.

2.1.3. CONTRACTING OFFICER'S REPRESENTATIVE (COR) - An employee of the U.S. Government appointed by the contracting officer to administer the contract. Such appointment shall be in writing and shall state the scope of authority and limitations. This individual has authority to provide technical direction to the Contractor as long as that direction is within the scope of the contract, does not constitute a change, and has no funding implications. This individual does NOT have authority to change the terms and conditions of the contract.

2.1.4. DEFECTIVE SERVICE - A service output that does not meet the standard of performance associated with the Performance Work Statement.

2.1.5. DELIVERABLE - Anything that can be physically delivered, but may include non-manufactured things such as meeting minutes or reports.

2.1.6. KEY PERSONNEL - Contractor personnel that are evaluated in a source selection process and that may be required to be used in the performance of a contract by the Key Personnel listed in the PWS. When key personnel are used as an evaluation factor in best value procurement, an offer can be rejected if it does not have a firm commitment from the persons that are listed in the proposal.

2.1.7. PHYSICAL SECURITY - Actions that prevent the loss or damage of Government property.

2.1.8. QUALITY ASSURANCE - The government procedures to verify that services being performed by the Contractor are performed according to acceptable standards.

2.1.9. QUALITY ASSURANCE SURVEILLANCE PLAN (QASP) - An organized written document specifying the surveillance methodology to be used for surveillance of contractor performance.

2.1.10. QUALITY CONTROL - All necessary measures taken by the Contractor to assure that the quality of an end product or service shall meet contract requirements.

2.2. ACRONYMS:

3. GOVERNMENT FURNISHED ITEMS AND SERVICES:

3.1. Services: The Government will provide initial training to the Contractor and the contracted certified undercover investigators before the investigations start. This training will consist of, but not limited to:

· Mission Statement

· FNS Definitions and Terminology

· Fundamentals of Work

Upon initial training provided by FNS, the Contractor shall be responsible for the training of all staff, including providing training to new staff before the new staff conducts any investigations. All subsequent training shall be completed utilizing the same training techniques and operating procedures including any updates as provided by FNS/ROC.

3.2 Facilities: The Government will not provide any facilities or workspace to the Contractor.

3.3 Utilities: The Government will not provide any utilities for the Contractor’s use in performance of tasks outlined in this PWS.

3.4 Equipment: The Government will not provide any equipment to the Contractor.

3.5 Materials: The Government will provide fundamentals of work information, access to FNS data systems, and EBT cards. All personnel using FNS data systems must ensure that data integrity is maintained and all must adhere to PII security procedures. No FNS data will be put or stored on unauthorized systems. All materials, information, and data provided to the Contractor about work fundamentals is considered Sensitive-but-Unclassified (SBU) information. SBU information, data, and/or equipment will be disclosed only to authorize personnel on a Need-To-Know basis. The Contractor 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.

4. CONTRACTOR FURNISHED ITEMS AND RESPONSIBILITIES:

4.1 General: The Contractor shall furnish all facilities, supplies, equipment, and services required to perform work under this contract that are not listed under Section 3 of this PWS.

4.2 Materials: The Contractor shall provide all certified undercover investigators and employees with necessary materials needed to perform the services under this contract. The Contractor shall ensure that appropriate administrative, technical, and physical safeguards are established to ensure the security and confidentiality of FNS 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.

4.3 Equipment: The Contractor shall equip all investigators with Notepads/Tablets with Windows Operating System. Certified undercover investigators shall also have the ability to photograph evidence and items purchase and upload these photos from the field with equipment provided by the Contractor. The Contractor shall have the capability/equipment to conduct surveillance and appropriately document events in multiple states simultaneously and must possess all necessary equipment to do so including, but not limited to digital video recording and playback, the ability to upload and securely send large files to FNS as well as having staff trained in surveillance both on site and mobile when required.

5. Specific Tasks: The following are required deliverables. The Contractor is shall be encouraged to recommend additional deliverables that are appropriate to their particular solution.

5.1 Field Work Results: The contractor shall provide the results of the passes by entering them into the designated FNS system or reporting to FNS no later than the close of business on the day the field work was conducted.

5.2 Investigative Results: The contractor shall provide summary results of the investigations which shall include the following elements:

1) A list of stores investigated with the name of the investigator, the number of passes made, and the number of sanctionable investigations and the number of trafficking passes made.

2) Any other information or documents necessary to fulfill the objectives of the Retailer Investigations Project as stated in Section 4.

These investigative report results are due daily.

5.3 Management Reports: The contractor shall provide a management report by the 5th day of the month that summarizes the contractor’s activities including any management issues, status, recommendations, and suggested resolutions.

5.4 Itemized Deliverables List: The contractor must review all deliverables for quality before submission.

5.5 Performance Requirements Summary (PRS): The contractor must review all deliverables for quality before submission.

PERFORMANCE REQUIREMENTS SUMMARY (PRS)

Exceptional

Very Good

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

Exceptional

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

100% Inspection

Exceptional

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

Exceptional

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

Exceptional

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

Evaluation Exceptional

Very Good

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

· Attends scheduled meetings

· Available for ad-hoc meetings as necessary for contractual concerns

Evaluation Exceptional

Very Good

Satisfactory

Marginal

Unsatisfactory

and Rating

System(CPARS)

Rating Definitions

If an “unsatisfactory” rating is obtained, FNS has the right to opt out of the contract at any time after the unsatisfactory rates are issued. Ratings will be given to the contracted investigative firm(s) on a quarterly basis. Satisfactory ratings must be met and maintained quarterly. If a less than satisfactory rate is obtained, the Contractor must provide FNS with a written action plan which explains how the performance will be improved. Two consecutive quarters of less than satisfactory ratings may result in the immediate termination of the contract.

Along with the satisfaction of the objectives and constraints listed above, the Contractor 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

Contractor shall sign a confidentiality/non-disclosure agreement as some of the data and the FNS internal validation and investigative procedures are confidential.

FNS will collaborate with the contractor’s day-to-day operation. Weekly communication between the FNS and the contractor is paramount to the agreement. The contractor will be required to meet with the FNS representative as deemed necessary by the FNS upon reasonable notice.

No investigation will be conducted in any store other than those stores given to the contractor. Periodically, an investigation may be recalled from the contractor. When this occurs, no further action or visits to the store shall take place without the approval of FNS. Violating this provision may result in immediate termination of the contract. Independently received information, tips, complaints, or any other information received by the contractor regarding a store not currently assigned for investigation must be made known to FNS. If the information can be verified and the store is cleared for investigation, FNS will assign it to the contractor.

6. 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.

SNAP regulations are available online at https://www.ecfr.gov/cgi-bin/text-idx?sid=c5778aa81303fbd390e16a1c181a9bef&c=ecfr&tpl=/ecfrbrowse/Title07/7cfrv4_02.tpl.

7. Applicable Publications (Current Editions) Once approved by FNS, the destruction of items by the Contractor 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. https://www.gsa.gov/policy-regulations/regulations/federal-management-regulation-fmr/idtopicx2x38584