After reviewing FNS management evaluation findings and state monitoring reports across the SNAP-Ed network, certain compliance failures appear repeatedly. These are not obscure edge cases — they are predictable, preventable patterns that cost implementing agencies credibility and, in some cases, funding. This guide documents the most common mistakes, explains why they happen, and provides specific corrective actions for each.
Mistake #1: Using Non-Evidence-Based Curricula
The problem: Implementing agencies deliver nutrition education using curricula that are not in the SNAP-Ed Toolkit and have not been formally approved through the state plan process. This is consistently one of the most cited compliance findings during FNS management evaluations.
Why it happens: Educators may be familiar with curricula from previous positions or other programs (such as EFNEP) and continue using them without checking the Toolkit. Organizations may develop their own materials internally, assuming local expertise is sufficient evidence. Sometimes Toolkit curricula are modified so substantially that they no longer resemble the tested intervention.
How to prevent it:
- Maintain a master list of approved curricula for your agency and share it with all educators
- Require supervisor approval before any new curriculum or material is used in SNAP-Ed programming
- Check the SNAP-Ed Toolkit (snapedtoolkit.org) before selecting any intervention for your state plan submission
- If using non-Toolkit curricula, obtain explicit state agency and FNS approval with documented evidence equivalence before delivery
- Document cultural adaptations separately from structural modifications to demonstrate fidelity
For detailed requirements on evidence-based programming, see the Compliance & Evidence-Based Requirements section.
Mistake #2: Serving Ineligible Populations
The problem: SNAP-Ed programming is delivered at sites or to populations that do not meet the SNAP-eligible target population criteria. This can result in disallowed costs for activities that should not have been charged to SNAP-Ed.
Why it happens: Educators are eager to serve as many people as possible and may not verify site eligibility before scheduling programming. Schools near the 50% free/reduced-price meal threshold may fluctuate above and below the eligibility cutoff between school years. Community sites may accept all comers without considering whether the population is predominantly SNAP-eligible.
How to prevent it:
- Establish a formal site qualification process with annual re-verification
- Maintain current free/reduced-price meal data for all school sites and update at the start of each school year
- Document the basis for community site eligibility using census data, SNAP participation data, or institutional proxy data
- Create a site eligibility file for each delivery location with supporting documentation
- Train educators on target population criteria and the importance of site qualification before scheduling
Mistake #3: Inadequate PSE Change Documentation
The problem: Implementing agencies report PSE change activities but cannot provide adequate documentation of what changes were made, the baseline condition, implementation activities, or the resulting impact. PSE changes are listed in annual reports without supporting evidence.
Why it happens: PSE change is newer to many SNAP-Ed programs than direct education, and agencies may not have established documentation systems for these activities. PSE work is often collaborative with external organizations, making documentation more complex. Staff may view PSE change as informal relationship-building rather than a documented compliance activity.
How to prevent it:
- Create a PSE tracking template that captures baseline, activities, stage of change, and outcomes for each initiative
- Obtain written agreements or memoranda of understanding with partner organizations before beginning PSE work
- Photograph environmental changes (garden installations, cafeteria modifications, signage improvements)
- Collect copies of adopted policies (wellness policies, vending machine standards, nutrition guidelines)
- Document the estimated population reach for each PSE change with the data source used for estimation
Mistake #4: EARS Reporting Errors
The problem: Implementing agencies submit inaccurate EARS data — duplicated participant counts, missing demographic data, inflated indirect reach estimates, or misclassified activities. These errors undermine the national SNAP-Ed data quality and can trigger follow-up inquiries from FNS.
Why it happens: Data collection systems may not track individual participants across sessions, leading to duplicated counts. Demographic data is collected inconsistently or estimated rather than self-reported. Indirect reach is estimated using inflated assumptions. Year-end data compilation rushes lead to transcription errors.
How to prevent it:
- Use unique participant identifiers to enable unduplicated counting across sessions and programs
- Collect demographic data at the first session of every education series using standardized forms
- Use conservative estimation methods for indirect reach and document all assumptions
- Compile and review data quarterly rather than waiting for year-end
- Have a second staff member review EARS data before submission to the state agency
For detailed EARS guidance, see the Reporting & EARS Guide.
Mistake #5: Supplanting Other Nutrition Education Funds
The problem: SNAP-Ed funds are used to replace (supplant) funding that was previously supporting nutrition education activities from other sources, rather than supplementing existing efforts with new or expanded programming.
Why it happens: When other funding sources decrease or end, implementing agencies may shift those activities to SNAP-Ed without recognizing the supplanting issue. Organizations that receive both SNAP-Ed and EFNEP may inadvertently shift costs between programs when staffing changes occur. Budget pressures may tempt agencies to use SNAP-Ed as a funding backstop for previously funded positions.
How to prevent it:
- Maintain a funding matrix showing all nutrition education funding sources and the specific activities each funds
- When other funding decreases, document that SNAP-Ed activities are new or expanded rather than replacement
- Keep historical budget records showing what each funding source supported in prior years
- Ensure cost allocation methodologies clearly distinguish SNAP-Ed from EFNEP and other program costs
Mistake #6: Exceeding Indirect Cost Rate Limits
The problem: Implementing agencies charge indirect costs at rates that exceed what is allowable under their state SNAP-Ed subgrant agreements, even when their federally negotiated rate is higher. This results in cost disallowances and required repayments.
Why it happens: University implementing agencies often have negotiated indirect cost rates of 40% to 60% or higher, but state SNAP agencies frequently cap indirect costs for SNAP-Ed at lower rates (15% to 25% is common). Fiscal staff may apply the institution's standard rate without checking the SNAP-Ed subgrant terms. The difference between the negotiated rate, the de minimis rate, and the state-imposed cap can be confusing.
How to prevent it:
- Review the state subgrant agreement for any indirect cost rate caps before building the budget
- Communicate the applicable SNAP-Ed indirect cost rate to fiscal staff processing expenditures
- Set up accounting system controls that prevent charging indirect costs above the allowed rate
- Monitor quarterly financial reports to catch indirect cost rate errors early
For more on indirect costs and 2 CFR 200 cost principles, see the Budget & Financial Management section.
Mistake #7: Insufficient Needs Assessment Documentation
The problem: Implementing agencies cannot produce needs assessment documentation that justifies their programming choices, target populations, and service area selections when asked during monitoring visits. The connection between identified needs and program design is weak or absent.
Why it happens: Needs assessment is treated as a one-time exercise during the plan development phase and not maintained as a living document. Data sources are not cited or preserved. Generic national nutrition data is used instead of local or state-specific data. The implementing agency relies on the state's needs assessment without developing area-specific documentation.
How to prevent it:
- Maintain a documented needs assessment specific to your service area with cited data sources
- Include local SNAP participation data, BRFSS health indicators, food environment data, and community input
- Create explicit linkages between identified needs and each programmatic intervention in your plan
- Update the needs assessment annually with new data, even if the plan cycle is multi-year
- Keep copies of all source documents and data files used in the assessment
Mistake #8: Branding and Nondiscrimination Violations
The problem: SNAP-Ed materials and communications do not include required USDA nondiscrimination statements, funding acknowledgments, or state-specific branding. Materials contain nutrition messages inconsistent with the Dietary Guidelines for Americans.
Why it happens: Educators develop supplemental materials without knowing the branding requirements. Materials from curriculum publishers may not include state-specific branding. The USDA nondiscrimination statement is long and agencies are unsure which version to use. Social media posts and digital content may be created quickly without going through a branding review process.
How to prevent it:
- Create material templates that include all required branding elements pre-loaded
- Establish a review process for all new materials before distribution, including digital and social media content
- Maintain a reference sheet with the current USDA nondiscrimination statement (full and abbreviated versions)
- Verify that all nutrition messages align with the current Dietary Guidelines and MyPlate before distribution
- Conduct an annual audit of all active materials to ensure branding compliance
Mistake #9: Missing EFNEP Coordination Documentation
The problem: Implementing agencies that operate in areas where EFNEP is also active cannot document how the two programs coordinate to avoid service duplication. This is particularly common at universities that administer both programs.
Why it happens: SNAP-Ed and EFNEP may be managed by different departments or individuals within the same organization. Coordination happens informally but is never documented. Staff turnover breaks communication channels between the two programs. Some implementing agencies are unaware that documented EFNEP coordination is a compliance requirement.
How to prevent it:
- Establish a formal coordination agreement between SNAP-Ed and EFNEP programs
- Hold and document regular coordination meetings (at least quarterly) between SNAP-Ed and EFNEP staff
- Map service areas for both programs to identify overlap zones and agree on service boundaries
- Maintain a shared referral system so participants are directed to the appropriate program
- Include the coordination plan in your annual state plan submission
Mistake #10: Curriculum Fidelity Drift
The problem: Over time, educators modify evidence-based curricula so extensively that the delivered intervention no longer resembles the tested version. Sessions are shortened, core components are skipped, delivery methods are changed, and the evidence base that justified the intervention is compromised.
Why it happens: Educators accommodate time constraints at delivery sites by abbreviating sessions. Certain components (hands-on cooking, physical activity) are dropped because of facility limitations. Experienced educators believe their modifications improve the curriculum without understanding that changes to core components invalidate the evidence basis. New staff are trained by experienced educators who have already drifted from the original design.
How to prevent it:
- Conduct fidelity checks at least quarterly through supervisor observations of education sessions
- Create fidelity checklists for each curriculum that define required vs. optional components
- Train new educators directly from the original curriculum materials, not from modified versions
- Establish a process for requesting and documenting approved adaptations
- Hold annual refresher training on curriculum delivery standards
Building a Compliance Culture
Most SNAP-Ed compliance failures stem from the same root causes: inadequate documentation systems, insufficient staff training on federal requirements, and treating compliance as an annual reporting exercise rather than an ongoing operational practice. Implementing agencies that avoid these common mistakes share several characteristics:
- Compliance is integrated into operations: Documentation happens at the point of service, not at year-end. Data collection systems are designed to serve both programming and compliance needs.
- Staff understand the "why": Educators and coordinators understand why evidence-based requirements, site eligibility, and reporting accuracy matter — not just what they are required to do.
- Quality assurance is proactive: Regular internal reviews catch issues before monitoring visits find them. Fidelity checks, data quality reviews, and documentation audits happen on a schedule.
- Federal guidance is read and applied: The annual SNAP-Ed Guidance document is reviewed at the start of each fiscal year, and changes from the prior year are communicated to all staff.