NATIONALLY RECOGNIZED FEDERAL LAWYERS
Last Updated on: 21st August 2023, 05:40 am
USDA Investigation of EBT Transactions and Store Evaluation
When the USDA investigates a pattern of EBT transactions that are flagged for possible fraud or trafficking, they conduct a thorough investigation of the store. This includes field visits, inventory review, data analysis, and comparison to the overall look and feel of the store. The USDA aims to determine whether a store that looks a certain way can support the EBT transactions in question.
The USDA considers various factors when evaluating a retailer’s business:
- Store size
- Number of entrances
- Number of exits
- Number of cash registers
- Presence of shopping carts
- Presence of shopping baskets
- Size of counter space
- Presence of conveyor belt
- Merchandise assortment
- Availability of staple food items
- Availability of fresh foods
- Availability of ethnic foods
- Availability of fresh produce
- Availability of frozen food
- Proportion of snacks and beverages in the food inventory
- Acceptance of package deals or bulk packs
- Presence of high-priced food items
The USDA also examines a store’s EBT transaction history, particularly large transaction amounts, to determine if they make sense in relation to the store’s physical capabilities. For instance, if a store has limited counter space and no shopping baskets or carts, it raises suspicion as to how they can consistently process high-dollar transactions. In such cases, the USDA assumes that EBT transactions are being manipulated to conceal trafficking activities.
Another aspect the USDA considers is whether a store’s food selection consists mostly of “Minimal Food Inventory.” This refers to a selection primarily composed of inexpensive canned goods, packaged goods, limited varieties of canned fruits and vegetables, soups, cereals, pasta, flour, loaf bread, snack items, cookies, crackers, chips, and salty snacks. Accessory food items include carbonated beverages, flavored drinks, candy, gum, condiments, hot sauce, hot chocolate mix, pickles, BBQ sauce, mustard, ketchup, mayonnaise, pancake syrup, coffee, tea, canned broth, salad dressing, sugar, and sweeteners.
When reviewing a store’s EBT transactions in relation to trafficking evidence, the USDA examines whether there is a specific reason why customers choose to shop at that retailer over others. This could include the sale of unique ethnic food items, lower prices, bulk pricing, special services, custom packages, or other factors.
The USDA also reviews the quantity and quality of SNAP retailers in a given area and analyzes the types of business conducted by these stores. When investigating a store for trafficking, the USDA compares the store’s transactions with those of other SNAP retailers in the area. They compare average transaction amounts with other stores’ averages and the state average. If the store in question has a higher than average transaction amount, it raises suspicion and is considered a potential indicator of trafficking. If there is no logical explanation for one store having a higher EBT transaction average than others, the USDA suspects that the transaction history has been altered to conceal trafficking activities.