Overview of Civil Money Penalties
The USDA may impose a civil money penalty, known as a CMP, in lieu of permanent disqualification for trafficking. The CMP must be requested within 10 calendar days of receiving a charge letter from the USDA. The USDA does not give extensions for time to request a CMP in lieu of permanent disqualification.
Eligibility for Civil Money Penalty
In order to be eligible for a CMP, you must meet the four criteria established in Section 278.6(i) of the SNAP Regulations.
The Four Eligibility Criteria
- Criterion 1 – The firm had an effective compliance policy in place
- Criterion 2 – The compliance policy was in effect PRIOR to the violations
- Criterion 3 – The firm had developed and set up effective personnel training
- Criterion 4 – The firm ownership was not aware of, did not approve of, and did not benefit from trafficking
