Developing_Models_for_Tribal_Administration_of_SNAP_PWS_DRAFT.pdf

FOOD AND NUTRITION SERVICES (FNS) ON BEHALF OF

THE OFFICE OF POLICY SUPPORT (OPS)

PERFORMANCE WORK STATEMENT (PWS)

Developing Models for Tribal Administration of SNAP

1.0 INTRODUCTION

The United States Department of Agriculture (USDA) Food and Nutrition Service (FNS) is seeking a qualified Contractor to conduct a study that will develop models for potentially transitioning the Supplemental Nutrition Assistance Program (SNAP) from a State-administered to a Tribally-administered program for Tribal members or in parts of Indian Country. The study will identify the specific activities, resources, and requirements necessary to transition SNAP from State to Tribal1 administration. The study will determine how program services, functions, and activities could transition and how that varies by the size or the resources of the Tribe and the

State-Tribal relationship. The study will also determine whether statutory or regulatory changes would be necessary to allow for the change in administration. The study shall result in an implementation plan that identifies the activities, resources, and requirements for several models of Tribal administration based on the extent to which a Tribe would choose to administer the program (i.e., the services, functions, and activities they would conduct/assume).

The Contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to conduct the study

“Developing Models for Tribal Administration of SNAP” as defined in this Performance Work

Statement except for those items specified as Government furnished property and services.

2.0 BACKGROUND

2.1 SNAP Administration

The Supplemental Nutrition Assistance Program (SNAP) is the foundation of America’s nutrition safety net, the nation’s first line of defense against hunger, and a powerful tool to improve nutrition among those with low incomes and few resources. SNAP provides eligible low-income households with electronic benefits that can be used to purchase eligible food from authorized retailers.

USDA’s FNS administers SNAP at the national level. FNS sets standards for household eligibility and benefit levels, monitors compliance with regulations and proper payment of

1 “Tribe” in this document refers to Indian tribes or Indian Tribal Organizations (ITOs). An Indian Tribe is: “(1) any

Indian tribe, Band, or other organized Indian group, for example, a Rancheria, Pueblo, or colony, and including any

Alaska Native village or regional or village corporation (established pursuant to the Alaska Native Claims Settlement

Act (85 Stat. 688)), and that is on a reservation and recognized as eligible for Federal programs and services provided to Indians because of their status as Indians; or (2) any Indian tribe or Band on a reservation holding a treaty with a

State government.”

An ITO is: “(1) The recognized governing body of any Indian tribe on a reservation; or (2) the tribally recognized intertribal organization which the recognized governing bodies of two or more Indian tribes on a reservation authorize to operate the Food Stamp Program or a Food Distribution Program on their behalf.” (7 CFR § 253.2, https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-B/part-253.)

https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-B/part-253 benefits through the SNAP Quality Control System, authorizes and monitors retailers accepting benefits, facilitates connections with Electronic Benefits Transfer (EBT) host processors, and provides program guidance and technical assistance to States.

States process household applications, including verifying applicant eligibility and certifying eligible households to receive SNAP benefits. They are also responsible for benefit issuance, case management, and for operating their State’s SNAP Employment and Training (E&T), SNAP-Ed, Disaster SNAP (D-SNAP), and SNAP outreach programs. Other State responsibilities include developing and maintaining a State Plan of Operation, ensuring compliance with regulations, securing an income and eligibility verification system, providing EBT and other systems and related plans to support benefit issuance, and ensuring program integrity by participating in the

SNAP Quality Control (QC) system and investigating suspected recipient fraud. States administer

SNAP locally through local offices or by passing Federal administrative funds to county agencies

(“county-administered”). State local offices or county offices are generally responsible for accepting and processing applications, interviewing clients, determining eligibility and benefits per Federal guidelines, and maintaining SNAP caseload data.

SNAP’s statutes, regulations, and waivers provide State agencies with various policy options that enable State agencies to adapt their programs to meet the unique needs of their households.

States have considerable flexibility to choose among policy options to better target benefits, streamline program administration, and improve coordination with other programs. For example, States may determine appropriate timelines for reporting changes in household circumstances, determine disqualification periods for failing to comply with work requirement programs, and request an administrative waiver to waive recertification interviews for elderly and disabled individuals with no earned income.

2.2 Tribal Administration of SNAP

Despite disproportionately high rates of poverty and food insecurity,2 not all eligible American

Indian or Alaska Native (AI/AN) households participate in SNAP. Twenty-one percent of AI/AN households participated in SNAP in 2022.3 Several challenges complicate SNAP participation by

AI/AN households, including perceived ease of enrollment, access to local SNAP offices, access to grocery stores, and comfort in government offices and with electronic benefits.4 Most AI/AN tribal areas are rural and further from supermarkets than the U.S. population in general.5 Instead of SNAP, many households participate in the Food Distribution Program on Indian Reservations

(FDPIR) because they do not have easy access to SNAP offices or authorized food stores. FDPIR provides USDA Foods to low-income households living on Indian reservations, and to American

Indian households residing in approved areas. Households may not participate in both SNAP and

2 https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=100417;

https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=105269.

3 U.S. Census Bureau, 2022 American Community Survey 1-Year Estimates, Table S0201, Selected Population

Profile in the United States.

4 A Comparison of the Food Distribution Program on Indian Reservations (FDPIR) and the Supplemental

Nutrition Assistance Program (SNAP). Contractor and Cooperator Report No. 58, December 2009.

https://www.ers.usda.gov/publications/pub-details/?pubid=84310.

5 https://www.ers.usda.gov/amber-waves/2015/december/measuring-the-food-access-gap-in-native-american-tribal-areasmeasuring-the-food-access-gap-in-native-american-tribal-areas/;

https://www.ers.usda.gov/publications/pub-details/?pubid=43908 https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=100417 https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=105269 https://www.ers.usda.gov/publications/pub-details/?pubid=84310 https://www.ers.usda.gov/amber-waves/2015/december/measuring-the-food-access-gap-in-native-american-tribal-areasmeasuring-the-food-access-gap-in-native-american-tribal-areas/ https://www.ers.usda.gov/amber-waves/2015/december/measuring-the-food-access-gap-in-native-american-tribal-areasmeasuring-the-food-access-gap-in-native-american-tribal-areas/ https://www.ers.usda.gov/publications/pub-details/?pubid=43908

FDPIR in the same month, and many households move back and forth between programs to meet their household needs.6

One option to make the program more appealing and accessible to AI/AN households is Tribal administration of SNAP. Under current law, States are responsible for administering SNAP in

Tribal areas. States are expected to consult with Tribes while developing their State Plans and ensure that SNAP is administered in a way that is responsive to the needs of AI/ANs. Under current law, a Tribe can submit a request to FNS to operate SNAP as a separate State agency if it can show that a State is not responsive to Tribal concerns in their administration of SNAP. FNS must also find that the State has failed in its administration of the SNAP program and determine the Tribe is capable of administering SNAP. There are currently no Tribes that administer SNAP as a designated State agency. However, three States (Washington, Minnesota, and Wisconsin) currently partner with Tribes to allow Tribal employees to conduct SNAP certification functions like the interview and eligibility determinations.

Washington has a non-merit demonstration project that allows the State to waive merit personnel provisions in the Food and Nutrition Act, which require that personnel performing SNAP certification functions, including the interview and eligibility determination, must be employed in accordance with current standards for a merit system of personnel administration. Under this project, Tribal non-merit system employees can perform SNAP eligibility and certification activities. Under this demonstration, the Port Gamble S’Klallam Tribe in Washington State operates a Community Service Office (CSO), which acts as a Department of Social and Health

Services (DSHS) local office, and is responsible for taking applications, conducting interviews, determining eligibility and benefit levels, and issuing EBT cards, while the State agency maintains the eligibility and EBT systems, conducts management evaluations and quality control procedures, provides support and oversight, and provides the matching administrative funds. This project is being expanded to five additional Tribes in the State.7

Minnesota and Wisconsin, which are county-administered SNAP programs, partner with certain

Tribal offices to operate like county offices. Several Tribes in these States conduct eligibility interviews and case determinations. Tribal employees in Minnesota and Wisconsin, are recognized by the States as merit-employees. As in Washington, State Agencies in Minnesota and

Wisconsin are still responsible for much of the SNAP administrative process and for providing support and oversight.

About half of Tribes participating in a previous study, “Feasibility of Tribal Administration of

Federal Nutrition Assistance Programs,” expressed interest in administering SNAP.8 Tribes identified several potential benefits of Tribal administration of SNAP, including having the ability to provide direct and culturally appropriate services to Tribal members who need assistance. Tribal administration of SNAP is also consistent with Indian self-determination and self-governance and would advance Tribal food sovereignty. Tribes also identified potential challenges, including meeting the legal requirement to demonstrate State agency failure in

6 A Comparison of the Food Distribution Program on Indian Reservations (FDPIR) and the Supplemental

Nutrition Assistance Program (SNAP). Contractor and Cooperator Report No. 58, December 2009.

https://www.ers.usda.gov/publications/pub-details/?pubid=84310.

7 https://www.fns.usda.gov/blog/fncs-supports-food-sovereignty-tribal-nations 8 https://www.fns.usda.gov/fdpir/feasibility-tribal-administration-federal-nutrition-assistance-programs https://www.ers.usda.gov/publications/pub-details/?pubid=84310 https://www.fns.usda.gov/blog/fncs-supports-food-sovereignty-tribal-nations https://www.fns.usda.gov/fdpir/feasibility-tribal-administration-federal-nutrition-assistance-programs administering SNAP; engaging States to share leadership, responsibilities, information, and funding; and the wide variability in resources, roles, and opportunities across Tribes.

2.3 Tribal Administration of Other FNS Nutrition Assistance Programs

The Indian Self-Determination and Education Assistance Act of 1975 (Public Law 93-638) provides authorization for Tribes to administer “programs, functions, services and activities”

(PFSAs) in select departments (the Indian Health Service and the Bureau of Indian Affairs) through contracts with or grants from States. This is commonly called “638 authority.” The

2018 Farm Bill authorized the USDA to enter into a limited number of multiyear contracts with

Tribes under 638 authority to procure domestic meat, fish, grains, and fresh produce for their

FDPIR programs. Demonstration projects with 8 Tribes began in began in October 2021 and an additional 8 Tribes began in August 2023.

Tribes are also participating in the administration of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), which provides supplemental food, nutrition education, and referrals to health care and other social services to low-income, nutritionally at-risk women, infants, and children up to 5 years of age. WIC is administered locally by 89 WIC State agencies, including 33 ITOs. The programs administered by ITOs are not exclusive to tribal members provided participants meet the ITO’s residency requirements.9

Starting in summer 2024, the Cherokee Nation, Chickasaw Nation, Mississippi Band of Choctaw

Indians, and Osage Nation will partner with States to launch Summer Electronic Benefits

Transfer (EBT) programs. Through Summer EBT, States, territories, and Tribes can receive grants to provide funds on an EBT card every month for each eligible child to buy food at grocery stores, farmers markets, or other authorized retailers during the summer months.10 Tribes can choose to deliver benefits through their State’s SNAP or WIC EBT benefit systems. Both Tribes will serve children in participating school districts regardless of whether they are members of the

Tribe.

2.4 Models for Administering of SNAP

Depending on necessary statutory or regulatory changes, Tribes could choose to transition SNAP administration in whole or in part. Partial administration would be Tribes administering just some portion of SNAP, like Tribes are doing in Washington, Minnesota, and Wisconsin. Complete administration of SNAP would encompass all of the activities generally conducted by the SNAP

State agency, including developing and maintaining the State Plan of Operation, ensuring compliance with regulations, securing income/eligibility verification and EBT/benefit issuance systems, ensuring program integrity, and planning and overseeing SNAP E&T, SNAP-Ed, D-

SNAP, and SNAP outreach programs. Complete administration would also include application processing, eligibility verification, certification and recertification interviews, benefit issuance, case management, and maintaining SNAP caseload data.

This study will result in an implementation plan11 that outlines the process to transition services, functions, and activities from States to Tribes. The plan will identify the specific activities, 9 https://www.fns.usda.gov/wic/wic-eligibility-requirements 10 https://www.fns.usda.gov/sebt/implementation 11 The implementation plan may be one or more documents based on the findings of the study and discussion with

FNS.

https://www.fns.usda.gov/wic/wic-eligibility-requirements https://www.fns.usda.gov/sebt/implementation resources, requirements, and statutory or regulatory changes necessary to transition SNAP administration from State to Tribal administration, including timelines and costs associated with the transition and ongoing administration. The plan will address different models or scenarios for

Tribal administration of SNAP based on the extent to which a Tribe opted to administer SNAP, and clearly delineate the specific activities, resources, requirements, and statutory or regulatory changes necessary to transition SNAP in each model or scenario. The plan will also consider variation across Tribes on factors such as the size or the resources of the Tribe and experience administering other federal programs.

FNS envisions that this study will use qualitative and quantitative methods to address the study objectives and research questions, including: (1) conducting site visits with Tribes about the resources and activities needed for transition to and ongoing administration of SNAP, the associated costs, and logistical and contextual considerations; (2) conducting interviews and document/data collection from States on the resources and activities needed to transition SNAP administration to Tribes/ITOs, costs, and logistics; and (3) collecting extant data, conducting subject matter expert (SME) interviews, and reviewing documents and literature to gather information for planning and cost estimation.

3.0 SCOPE/OBJECTIVES

The Contractor shall conduct a study to identify the activities, resources (including financial resources), requirements, and regulatory/statutory changes (“requirements”) necessary to transition to Tribal Administration of SNAP. The study will also develop an implementation plan for transition that accommodates different models or scenarios for Tribal administration of

SNAP. One scenario could be complete administration of SNAP. Additional scenarios could include assumption of application processing and eligibility verification or additional activities like benefit issuance or case management and referral to a SNAP E&T program.

Specifically, the Contractor will provide an updated study plan, obtain OMB clearance, acquire and analyze data, develop the implementation plan, and provide a briefing to FNS on the implementation plan and findings. The study plan shall clearly describe how each objective and research question will be addressed and answered.

3.1 Study Objectives and Research Questions

The Contractor shall address the following study objectives and research questions. Contractors may propose additional research questions to address each objective.

Objective 1: Identify the specific activities, resources, and requirements necessary to transition from State to Tribal administration of SNAP in whole or in part. Include what is needed from Tribes/ITOs, FNS, and States. Consider how transition/administration needs may vary by the size, resources, and geographic location and dispersion of the Tribe and Tribal experience administering similar programs.

1. What services, functions, and activities are associated with transition to and ongoing administration of SNAP?

2. For the services, functions, and activities identified in Question 1, what activities, staff resources, financial resources, technological and physical infrastructure, data, and plans/procedures are needed? For example, what activities and resources are needed for:

a. Planning/designing the program.

b. Processing applications, including initial and recertification, information verification, and maintaining participant records.

c. Delivering benefits and providing oversight of redemption/reimbursement.

d. Maintaining program integrity, such as ensuring that the correct benefits are provided to the proper individuals, preventing and addressing fraud, and conducting management evaluations, Quality Control reviews, and civil rights compliance reviews.

e. Providing financial management and budgeting.

f. Completing reporting requirements.

g. Designing and operating SNAP E&T, SNAP-Ed, and Disaster SNAP.

h. Conducting SNAP outreach.

3. What would be the one time and ongoing administrative costs to Tribes for operating

SNAP?12

4. What would be required for Tribes located across multiple States to operate SNAP?

5. What would be required for Tribes in a consortium to jointly administer SNAP?

Objective 2: Identify statutory or regulatory changes, waivers, or special provisions that would be needed to transition from State to Tribal administration of SNAP in whole or in part.

1. What statutory changes need to be made to the Food and Nutrition Act of 2008 or other relevant federal legislation and what would be involved in making those changes?

2. What regulatory changes need to be made to the program and what would be involved in making those changes?

3. What accommodations could be made through waivers or existing flexibilities of current regulations?

4. What types of changes might Tribes need to make to Tribal laws and what are the processes and timelines for making such changes?

Objective 3: Develop a detailed implementation plan with specific steps, timelines, and costs for transitioning SNAP from State to Tribal administration in whole or in part. The plan should be sequential, and the timeline should clearly show overlapping steps as well as dependencies. It should clearly delineate the steps, timelines, and costs to transition SNAP in each Tribal administration model or scenario. Steps that are contingent upon statutory or regulatory changes should include time required for enacting such changes. The plan should note which steps are the sole or shared responsibility of the Tribe, affected States, and FNS. It should also show which components can be independently operated by Tribes without State oversight. It should also identify fixed and variable costs, and one time and ongoing administrative costs to

Tribes for operating SNAP. The plan should also consider staffing, infrastructure, and other resource needs for each step. Finally, the plan should include the challenges, options, and decision points.

3.2 Study Considerations and Constraints

12 Administrative costs shall be calculated for overall SNAP administration as well as for operating specific/defined portions of the program.

As part of the study plan, in their technical quote, the Contractor shall describe their approach and plans for addressing specific study considerations and constraints. These include, but are not limited to, the following:

1. FNS expects to recruit 10 Tribes to participate in site visits, provide data and other information, and provide feedback on the implementation plan. FNS plans to share information about the study and solicit interest in participating in the study at a recurring consultation meeting with USDA and Tribes in December 2024 or the earliest possible meeting in 2025, as well as through wide national outreach. The Contractor shall work closely with the COR and designated representatives from the FNS Office of Tribal

Relations and the program office to support outreach to and recruitment of Tribes, including preparing presentation slides and materials for use in meetings with Tribal leaders, presenting information at the consultation meeting, and preparing responses to requests for more information. The Contractor should plan attend this meeting in person for two days and include up to two team members with extensive experience engaging with Tribes.

2. The Contractor shall also provide support to FNS in selecting Tribes. FNS expects to recruit Tribes that vary in terms of size/resources, location (e.g., located in rural and urban areas, located across multiple States), experience administering SNAP or other Federal programs, and other factors. As Tribes are recruited, the Contractor is expected to work with them to assess the need for Tribal Institutional Review Board (IRB) or other approvals and obtain approval as needed.

3. The Contractor should expect to convene a Technical Working Group (TWG) of up to 8 members. The TWG will meet virtually two times during the study: first, to discuss the data collection design and, second, to discuss the first revised draft of the implementation plan. Some members of the TWG will be asked to review the data collection instruments.

Members of the TWG will also be asked to recommend individuals who could pretest the draft data collection instruments. The TWG members will be selected in consultation with

FNS and shall include a mix of individuals who have experience with Tribal administration of federal programs These may include FNS National and Regional Office staff, Tribal leaders or their representatives, and State agency staff.

4. The Contractor shall describe how they will conduct a literature review and environmental scan to gather information for planning and cost estimation, including program guidance, regulations, manuals, reports, and other documents related to SNAP, SNAP E&T, and other program components. The environmental scan shall also identify extant data, as appropriate, to calculate costs and other estimates. The literature review and environmental scan should be started with Task 2 to inform subsequent tasks.

5. Contractors should plan to conduct interviews with subject matter experts, including key stakeholders at the Federal, regional, and State levels, and with other interested parties, such as State EBT processors, about the activities, resources, and requirements to transition to Tribal administration of SNAP, the associated costs, and logistical elements such as timelines. Contractors should expect that the interviews will be conducted by phone or virtually.

6. In depth interviews with SNAP State agency staff will gather detailed information on the activities, resources, requirements, necessary to transition to Tribal administration of

SNAP, the associated costs, and logistical elements. FNS will work with the Contractor to select a subset of six to ten States for in depth interviews and extant data/documentation collection, including States in which the selected Tribes are located. Key informants may include SNAP State agency directors, staff responsible for monitoring and data, and other

State agency staff identified in consultation with FNS. Contractors should expect that the interviews will be conducted by phone or virtually.

7. The study will require Office of Management and Budget (OMB) approval of information collection activities for the collections with Tribes, States, and SMEs. Allow at a minimum 52 weeks for OMB’s final approval from the date of the publication of the

Federal Register 60-day Notice. The Contractor shall discuss how the project timeline would be flexible enough to accommodate an earlier approval date and how the timeline will align with other data collection and analysis activities. The Contractor shall also discuss how they will approach unanticipated revisions if necessary (e.g., changes requested by the USDA Office of the Chief Information Officer or OMB).

8. To align with principles of Tribally-driven participatory research, FNS expects to engage

Tribes early in the study through the consultation meeting and formation of the TWG.

Contractors should have a plan to solicit feedback from Tribes on the findings of the study and the implementation plan. This includes necessities like obeying any Tribal customs, protecting Tribal data, and getting permission from the Tribe before entering Tribal boundaries. Contractors may propose additional strategies to support the participatory nature of the study. Contractors shall also include considerations taken regarding Tribal data sovereignty and indigenous traditional ecological knowledge (ITEK) to the extent possible.13

9. FNS expects the implementation plan to include the requirements and process to transition other program components, including SNAP Employment and Training (E&T), SNAP-

Ed, Disaster SNAP (D-SNAP), from State to Tribal administration.

10. A key component of the implementation plan will be cost estimation. The final plan should identify fixed and variable costs, and one time and ongoing administrative costs to

Tribes for operating SNAP. It should also consider potential impacts on the Federal cost share. Administrative costs shall be calculated for overall SNAP administration as well as for operating specific/defined portions of the program. In their proposals, Contractors are expected to present a plan for estimating the transition to and ongoing administrative costs, including any known assumptions and how the Contractor will identify and obtain potential sources of data to estimate initial and ongoing costs.

11. Contractors should consider the following points in estimating service populations for future program administration. Tribes often provide services beyond the reservation.

Tribes may also provide services to non-Tribal members living in their service area. In addition, what constitutes Tribal membership varies among Tribes.

12. Other study constraints identified by the Contractor and their proposed approach for addressing them and meeting the study objectives.

4.0 SPECIFIC REQUIREMENTS/TASKS

The Contractor shall provide all management, supervision, labor and equipment, planning, scheduling, and coordinating to ensure effective performance of all services and/or supplies as described in the Performance Work Statement (PWS). In addition, the Contractor shall provide

FNS with bi-weekly updates of their progress towards meeting the objectives. These updates can be by email, telephone, or other means that are mutually acceptable to the Contractor and FNS

13 https://www.whitehouse.gov/wp-content/uploads/2021/11/111521-OSTP-CEQ-ITEK-Memo.pdf.

https://www.whitehouse.gov/wp-content/uploads/2021/11/111521-OSTP-CEQ-ITEK-Memo.pdf

COR. All drafts of deliverables shall be in final form and thoroughly proofread. When multiple drafts are necessary, each subsequent draft shall be reflective of FNS’s feedback on the prior draft and include a summary of all changes made with justifications for any feedback not incorporated.

In addition, the Contractor shall submit a clean and a tracked changes version of all revised documents.

4.1 Task 1: Project Orientation Meeting and Reporting

Orientation Meeting

The Contractor, in cooperation with FNS’ Contracting Officer Representative (COR), shall prepare an agenda for the meeting, which will be held virtually by video or teleconference within two (2) weeks of award. The purpose of this meeting is to ensure mutual understanding of project objectives, priorities, and expectations. The meeting shall cover items including, but not limited to, the following:

• An overview of the Contractor’s technical approach for addressing the study objectives;

• A description of the tasks to be performed in sufficient detail for FNS staff who have not read the PWS, technical quote, or contract to understand them;

• A clarification of all project activities and tasks and a discussion of the proposed schedule of deliverables;

• Anticipated challenges and strategies to address them; and

• Establishing official protocols for all project communication, substantive and financial reporting requirements, and procedures for the approval of contract deliverables.

At least one (1) week prior to the Project Orientation Meeting, the Contractor shall submit to the

COR a Project Orientation Meeting agenda. Within one (1) week after the orientation meeting, the Contractor shall submit to FNS a draft memorandum summarizing the orientation meeting.

This summary memorandum shall include all issues discussed at the meeting, the conclusions reached, and follow up items and next steps. FNS will provide comments on the draft version of the memo. The final project orientation summary memorandum is due within three (3) weeks of the orientation meeting.

Monthly Progress Reports

Each month, the Contractor shall prepare and submit monthly progress reports to FNS in an FNS-approved format by the 10th of each month,14 beginning one (1) month after award. Each report shall include a:

• Cover page with task order title, number, award date, period of performance covered by the report and number in the sequence of monthly reports;

• Description of activities, by subtask(s), that were carried out during the reporting period and staff involved in completing the task(s);

• Clear description of any technical problems or issues, along with proposed steps to resolve them;

• Clear description of any contractual problems or issues, including delays encountered, along with proposed steps to resolve them;

• Description of activities planned for the next reporting period by subtask;

14 If the 10th of the month falls on a weekend or holiday, the report will be due on the next business day.

• Project schedule that shows, by subtask and deliverable, the dates on which work started, was expected to end, and actually ended; and

• Table listing all project deliverables in the first column, due dates listed in the contract in the second column, the date submitted to the COR in the third column, the date accepted by the COR in the fourth column, and the date when the invoice for the deliverable was submitted in the fifth column.

All monthly progress reports shall be submitted in electronic format directly to the FNS COR and

Contracting Officer (CO). In addition, the Contractor shall notify the COR, by phone or e-mail, of any schedule delays.

4.1 Deliverables:

Deliverable 1.1 – Project Orientation Meeting Agenda and Presentation Materials

Deliverable 1.2 – Draft Project Orientation Meeting Summary Memorandum

Deliverable 1.3 – Final Project Orientation Meeting Summary Memorandum

Deliverable 1.4 – Monthly Progress Reports

4.2 Task 2: Prepare Updated Study Plan

The Contractor shall update the study plan offered in their technical quote and submit a complete study plan that further details their approach for addressing the scope of work. The study plan in the technical quote shall clearly state how the study objectives will be accomplished and the technical expertise needed to address the study objectives and research questions. The study plan shall also address the study considerations and constraints noted under the Scope/Objectives section above. At a minimum, the study plan shall include:

• A discussion of the relevant background, study objectives, and research questions.

• A crosswalk that identifies the research questions, the information needed to answer the research questions, sources of data, and modes of collection.

• Details of the approach to determine the underlying assumptions for the plan and cost estimations, including the State options and waivers available under SNAP.

• A plan for convening the TWG, describing the criteria for selection of members, types of potential members, their roles and responsibilities, plans for inviting members to participate and managing ongoing communications, and plans for managing meeting logistics.

• An instrument development plan that describes the approach to developing and testing the interview guides and any other data collection instruments. This includes a discussion of the sources that will inform the content of the instruments (as applicable), proposed length, modules, topic areas, and example questions. The plan shall also describe how and with whom the Contractor will pretest the instruments.

• A plan to support FNS in recruitment of Tribes. As noted, FNS expects to recruit at least

10 Tribes to participate in site visits and provide feedback on the implementation plan.

The plan should describe the materials the Contractor plans to prepare, which should describe the purpose, methods, and time schedule of the study and provide a clear description of what will be asked of Tribes that agree to participate. The plan should also describe how the Contractor will coordinate with Tribes who agree to participate in the study on IRB or other approvals required by the Tribe.

• A plan for gathering extant data and reviewing literature and publicly available documentation, including a discussion of the scope of the review/scan (types of materials to be included, approach to identifying materials), and a description of software that will be used for information management and analyses and any anticipated challenges or limitations.

• Details of the Contractor’s approach to conducting SME interviews, including the types of information to be collected, plans for identifying and engaging respondents, scheduling, and conducting interviews, documenting notes, and processing the data for analysis.

Contractors should expect that the interviews will be conducted by phone or virtually.

• A detailed plan for the site visits with Tribes to include a proposed schedule, composition of the site visit team, the types of individuals to be interviewed, the approach to coordinating site visits with the Tribe, the types of information that will be collected, and plans for follow-up after the site visit.

• A detailed plan for conducting interviews with States, including the types of individuals to be interviewed, the approach to outreach and scheduling, the types of information that will be collected, and plans for follow-up after the interview. This plan should also include information on types of documents or data to be collected to inform cost estimations or other assumptions in the implementation plan.

• Proposed schedule for data collection including the timing of the SME interviews, site visits, State interviews, and other data collections.

• A description of how the Contractor will select and train experienced data collectors.

• A description and rationale for all analytic techniques, including cost or other estimation approaches. This should include a description of all analyses to be performed, including both qualitative and quantitative analysis and the software that will be used.

• A description of methods for ensuring data accuracy, completeness, and quality control across all data collections, and any related concerns or issues that could impact fulfillment of study objectives and research questions.

• A detailed description of major tasks, events, and deliverables to organize and structure the work. This section shall include the proposed scheduling and sequencing of tasks and the identification of any key non-deliverable dates.

• A description of the implementation plan format and content, including how the

Contractor plans to present the plan in a way that accounts for each Tribal administration model or scenario. All versions (draft, revised and final) shall undergo a quality control review prior to FNS submission. The final version of the report shall be 508 compliant.

• A description of the approach to brief FNS program staff and policy officials on key findings and the implementation plan.

The updated study plan shall address any issues with or refinements to the contractor’s approach for conducting the study in the technical quote. The update to the study plan shall reflect the discussion with FNS at the project orientation meeting and describe any proposed elaborations or changes made, along with a justification for those changes.

A draft updated study plan shall be submitted to FNS within six (6) weeks of contract award. A revised updated study plan (track changes and clean version) shall be submitted within twelve

(12) weeks of contract award and the final version (track changes and clean version) of the updated study plan incorporating FNS comments shall be submitted within eighteen (18) weeks of contract award. Updates or edits to the study plan shall not be construed to change the scope of work specified in the contract. Should revisions to the contract be required, they must be made with the approval of the FNS Contracting Officer.

4.2 Deliverables:

Deliverable 2.1 – Draft Updated Study Plan

Deliverable 2.2 – Revised Updated Study Plan

Deliverable 2.3 – Final Updated Study Plan

4.3 Task 3: Convene Working Group

The Contractor shall convene a technical working group (TWG) consisting of up to eight members. While the TWG members shall advise the Contractor on issues related to data collection and the implementation plan, the TWG is not expected to reach consensus and is not a decision-making body.

The Contractor shall draft recruitment materials, including a study description of up to two pages to be included in outreach to potential TWG members. The study description should describe the study, specify the roles and expectations of the TWG, and outline the process for engaging the

TWG across the study period. The Contractor shall also describe the approach to selecting TWG members and provide a list of potential TWG members. The list of TWG members shall include names, organizational affiliations, and a brief description of their expertise and its relevance to the objectives of the TWG.

It is expected the Contractor will engage the TWG on multiple occasions over the period of performance to provide feedback on data collection topics and protocols, to review data collection instruments, and to review the first revised implementation plan Contractors should propose an approximate timeline for these activities that coordinates with the anticipated activities of the project.

The Contractor shall consult with and receive approval from the COR prior to scheduling any meeting of members of the TWG. Topics for all meetings shall be developed by the Contractor in consultation with the COR. The Contractor shall be responsible for all logistics for TWG meetings. TWG meetings shall be virtual.

The Contractor shall be responsible for the preparation of all meeting materials and an agenda for each TWG meeting. Draft materials shall be submitted to the COR six (6) weeks in advance of the scheduled meeting to allow for review and approval. The Contractor shall address comments received from the COR and distribute final materials to TWG members and the COR no later than three (3) weeks prior to each meeting.

The Contractor shall submit draft written summaries of the TWG meetings to the COR for review and approval no later than three (3) weeks following the meeting. The Contractor shall submit a final summary two (2) weeks after receipt of COR comments.

4.3 Deliverables:

Deliverable 3.1 – Recruitment materials and list of potential members

Deliverable 3.2 – Draft agenda and meeting materials

Deliverable 3.3 – Final agenda and meeting materials

Deliverable 3.4 – Draft meeting summary memorandum

Deliverable 3.5 – Final meeting summary memorandum

4.4 Task 4: Review Literature and Documents and Gather Extant Data

The literature review and environmental scan should be started with Task 2 to inform study design and subsequent tasks. The contractor shall identify services, functions, and activities associated with transitioning SNAP from State to Tribal administration and ongoing Tribal administration. The contractor shall review the statutes and regulations authorizing the SNAP to understand the legal requirements for administering the program. In addition, the contractor shall review existing program guidance, manuals, reports, and other relevant documents. The contractor shall also be responsible for obtaining any publicly available documents for Tribes and

States participating in the study, publicly available extant data, or FNS data needed to establish assumptions and calculate costs or other estimates.

The Contractor shall prepare a summary memorandum on the results of the literature review/environmental scanning. At a minimum, this memo shall include an overview of the research activities conducted, a summary of the findings, and a detailed description of data identified for use in establishing assumptions and calculating estimates.

The Contractor shall submit the Draft Literature Review Memorandum within fifty-six (56) weeks of award. The Contractor shall revise the memo in response to FNS’ comments and submit the Final Literature Review Memorandum within sixty-two (62) weeks of award.

4.4 Deliverables:

Deliverable 4.1 – Draft Literature Review Memorandum

Deliverable 4.2 – Final Literature Review Memorandum

4.5 Task 5: Develop Data Collection Procedures and Instruments

The Contractor shall develop all instruments, procedures, and recruitment materials necessary to implement the methodology in accordance with the Final Updated Study Plan. The data collection procedures and instruments shall include a crosswalk between the information to be collected and the research questions and study objectives being addressed, as applicable.

Any instructions to Tribes or States to provide extant data or other information should include the specific information required and all details necessary for them to be able to provide the information (e.g., specifications, definitions, time periods, what the data will be used for).

Draft recruitment materials and data collection instruments and procedures shall be submitted to

FNS for review twenty-four (24) weeks after award. After revising the revised instruments based on FNS comments and with approval from FNS, the Contractor shall conduct pretesting of the interview guides no more than 9 individuals identified in consultation with the TWG. The purpose of pretesting is to address respondent comprehension, response burden, and whether the questions elicit the desired information. The Contractor must obtain institutional IRB approval prior to pre-testing instruments. The Contractor should address how they plan to obtain IRB approval prior to the pre-test and IRB amendments prior to submission of the draft OMB ICR

(Task 6.)

The Contractor shall revise the instruments based on pretest findings and prepare a memorandum on the pretest results within two (2) weeks of the end of the pretest. The memorandum shall include a question-by-question analysis of the pretest, results of the pretest, and the changes made to the interview guides or other instruments as a result.

The final memorandum shall be submitted within week three (3) weeks after receiving FNS comments. The final version of the data collection instruments and materials shall be submitted within forty (40) weeks of award.

4.5 Deliverables:

Deliverable 5.1 – Draft Materials and Instruments

Deliverable 5.2 – Revised Materials and Instruments

Deliverable 5.3 – Draft Memorandum on Pre-Test Results

Deliverable 5.4 – Final Memorandum on Pre-Test Results

Deliverable 5.5 – Final Materials and Instruments

4.6 Task 6: Develop Paperwork Reduction Act (PRA) Clearance Package

When developing the project schedule, the Contractor shall allow, at a minimum, 52 weeks for

OMB’s final approval from the publication of the 60-day notice in the Federal Register. The approval process may take less than this amount of time; Contractor are advised that the amount of time for clearance is directly related to the quality of the initial submission of the OMB package.

The final 60-day notice shall not be approved until it is published in the Federal Register. The final OMB package shall not be approved by the COR until OMB provides final clearance. For reference, recently published FNS Federal Register Notices are available online at www.federalregister.gov. Recently cleared FNS OMB packages are available online at www.reginfo.gov.

The Contractor shall prepare the required publication notices and clearance package for submittal to OMB to obtain approval for all data collection activities in all components of the evaluation subject to the requirements of the PRA. The clearance package shall provide an explicit, concise description of the direct links between the study objectives, research questions, variables, instrument items, data analysis plans and desired products. The OMB data collection package shall contain copies of all recruiting materials and data collection instruments and a supporting statement (Parts A and B) as set forth in 5 CFR 1320, Controlling Paperwork Burdens on the

Public, the USDA Information Collection Package Submission Guidelines:

http://www.ocio.usda.gov/policy-directives-records-forms/information-collection/information-collection-package and OMB guidance including, but not limited to, OMB Guidance on Agency

Survey and Statistical Information Collections and Revisions to the Standards for the

Classification of Federal Data on Race and Ethnicity. Note that scripts are required to be prepared and included in the OMB package for all communications (either by telephone, mail, email, or internet) with all persons and organizations contacted for data collection purposes. It shall include a summary of public comments received in response to the 60-Day Federal Register Notice concerning the information collection and any actions taken in response to these comments. If necessary, study instruments and scripts shall be modified by the Contractor to reflect comments from OMB. The Contractor shall include OMB-required statements on all data collection forms http://www.ocio.usda.gov/policy-directives-records-forms/information-collection/information-collection-package http://www.ocio.usda.gov/policy-directives-records-forms/information-collection/information-collection-package and recruitment materials being administered to respondents and participants on the estimated burden of the data collection. The Contractor will also provide all the information necessary for completing the 83-I form.

For purposes of calculating response burden, the time required in communications with respondents and separately for non-respondents contacted in the project must be included in the burden table. The OMB package shall be submitted in MS Word format. The burden table shall be submitted in MS Excel as an appendix.

The Contractor shall submit a draft Federal Register Notice inviting public comment on the proposed information collection to the COR for review and approval within thirty-two (32) weeks after award. The Contractor shall submit a final Federal Register Notice that addresses FNS comments within thirty-six (36) weeks of award.

The Contractor shall submit a draft OMB information collection package to the COR for review and approval within forty (40) weeks after award. The Contractor shall submit a revised OMB information collection package that addresses FNS comments within forty-six (46) weeks after award.

The Contractor should be aware that the OMB data collection package will be reviewed by multiple groups within FNS including staff in the Office of Policy Support (OPS) and the

Planning and Regulatory Affairs Office (PRAO), as well as USDA’s Office of the Chief

Information Officer (OCIO) and USDA’s National Agricultural Statistics Service (NASS), and external reviewers.