Tennessee is on its way to implementing SNAP improvements — but change won’t be simple

The state acknowledges there are problems with how it runs the Supplemental Nutrition Assistance Program, and a special mediator just signed off on the first phase of an improvement plan.

Otherwise known as SNAP or food stamps, the program helps about 700,000 Tennesseans pay for food. The state’s Department of Human Services manages that service, and the agency was sued last year. Plaintiffs charge that they were wrongly denied benefits or wrongly had their benefits canceled. For each, the appeals process ran months longer than legally allowed — in which time, some lost their homes or delayed needed medical care.

Since then, the two sides have been working on an improvement plan.

The federal court put a special mediator on the case. Late last week, he signed off on some of the early steps. They tackle a handful of the systemic concerns raised in the lawsuit.

Some of the solutions in the initial remediation are pretty straightforward.

For example, beneficiaries awaiting new debit cards in the mail didn’t have tracking information. DHS agreed to have its vendor provide that information, so the recipients can better anticipate when their cards will arrive.

But other changes will require several months of intense work. This initial plan offers a glimpse into how labor intensive and complicated implementing reforms can be.

The lawsuit illustrates the difficulty several beneficiaries had when their benefits were wrongly canceled. Many of the stories involved communication issues. Among them: The state’s letter notifying people that their applications or re-verification had been rejected failed to explain why.

DHS agreed to start listing the reason — like the applicant missed an interview or the household income is too high. Although that sounds simple, DHS told the court it would take at least 26 weeks for its contractor, Deloitte, to make the changes. It laid out each step.

“The first stage, Discovery, ensures that the vendor fully understands the requested system change and that the scope of work is frozen before design begins,” DHS attorneys wrote in a legal filing. “Discovery typically takes between six and eight weeks. Without this control, requirements can shift mid-cycle, directly increasing the risk of introducing defects that cannot be adequately traced or validated.”

The filing goes on to explain six more stages.

Uncertain timeline

Each quarter, Deloitte carries out an agreed upon list of maintenance and updates on the portal, charging the state $2.5 million for its service. And this change to the rejection notification could be part of the regularly scheduled maintenance, meaning it would come at no extra cost.

“However, this assumes that other system modifications do not exhaust the work hours contemplated by that budgeted amount,” the filing reads.

If the amount of work would exceed the cap set for the quarter, DHS says it would have to report the estimated cost to the court.

“Or, if DHS is ordered to implement these revisions with a new, off-cycle contract with its vendor, DHS will need to prepare a new scope of work, obtain a quote and determine budget feasibility, determine a timeline for the project and, after receiving the required internal approvals, complete the procurement process.”

The estimated completion for the changes, according to the remediation plan, is June 2026. But that’s not a definite date.

“Until the extent of the design complexity is known … DHS cannot estimate the hours this will take. The notice changes will also require policy changes, internal procedure updates, and staff training.”