SNAP-Ed Compliance & Evidence-Based Requirements

The SNAP-Ed Compliance Framework

SNAP-Ed compliance operates under a layered framework that combines federal cost principles, program-specific guidance, and evidence-based programming standards. Implementing agencies must satisfy requirements at every level simultaneously. The primary compliance sources are:

• 2 CFR 200 (Uniform Guidance): The government-wide cost principles and administrative requirements for federal awards. All SNAP-Ed expenditures must comply with 2 CFR 200 requirements for allowability, allocability, and reasonableness.
• SNAP-Ed Guidance (annual): The FNS-issued policy document that specifies allowable activities, target population definitions, reporting requirements, and fiscal rules specific to SNAP-Ed.
• SNAP-Ed Toolkit: The official repository of evidence-based interventions that defines what programming approaches are acceptable for SNAP-Ed.
• State requirements: Additional compliance requirements imposed by the state SNAP agency through subgrant agreements and state policy.

Evidence-Based Programming Requirements

The evidence-based programming requirement is the defining compliance feature of SNAP-Ed. The Farm Bill mandates that SNAP-Ed activities be evidence-based, and FNS implements this requirement through the SNAP-Ed Toolkit. Understanding what "evidence-based" means in the SNAP-Ed context and how to demonstrate compliance is critical for every implementing agency.

SNAP-Ed Toolkit Tiers

The SNAP-Ed Toolkit categorizes interventions into three evidence tiers. Each tier reflects a different level of scientific evidence supporting the intervention's effectiveness:

FNS strongly encourages implementing agencies to prioritize Tier 1 and Tier 2 interventions. While Tier 3 interventions are permitted, agencies using them should have a plan for building the evidence base through formal evaluation. State SNAP agencies may impose additional restrictions on which tiers are acceptable within their state plans.

Using Non-Toolkit Interventions

Implementing agencies that wish to use interventions not currently in the SNAP-Ed Toolkit must demonstrate that the intervention meets equivalent evidence standards. This requires:

• Documentation of the theoretical basis for the intervention
• Published or documented evaluation data showing positive outcomes
• State SNAP agency approval for use in the state plan
• FNS concurrence through the state plan review process

In practice, using non-Toolkit interventions creates significant compliance risk. Unless you have strong evidence documentation and explicit state and FNS approval, the safest approach is to select from the Toolkit.

Curriculum Fidelity

When using a Toolkit intervention, implementing agencies must deliver it with fidelity to the original design. Curriculum fidelity means delivering the intervention as it was designed and tested, including:

• Dose: Delivering the full number of sessions specified in the curriculum, not abbreviated versions
• Content: Covering all core content areas as designed, without substituting or omitting key components
• Delivery method: Using the instructional methods specified (hands-on activities, demonstrations, group discussions) rather than converting to lecture-only formats
• Target audience: Delivering the curriculum to the population for which it was designed and tested

Cultural adaptations are permitted and encouraged, but structural modifications that change the intervention's core components may compromise the evidence base. Document any adaptations made and the rationale for each.

Allowable Activities

The SNAP-Ed Guidance defines specific categories of activities that are allowable under SNAP-Ed. All activities must be evidence-based, directed to SNAP-eligible populations, and consistent with the approved state plan.

• Direct nutrition education: Group classes, workshops, cooking demonstrations, grocery store tours, and other structured education sessions using Toolkit curricula
• PSE change activities: Working with institutions and communities to adopt policies, change systems, or modify environments that support healthy eating and physical activity
• Social marketing: Targeted nutrition messaging campaigns directed to SNAP-eligible populations using evidence-based social marketing principles
• Community and public health approaches: Population-level interventions that address nutrition and obesity prevention in communities with high SNAP-eligibility rates
• Physical activity education: Physical activity programming when integrated with nutrition education messages as part of a comprehensive obesity prevention approach
• Evaluation and research: Program evaluation activities, including data collection instruments, participant surveys, and evaluation staff time

Prohibited Activities

Certain activities are explicitly prohibited under SNAP-Ed, regardless of their connection to nutrition or health. Implementing agencies must ensure that no SNAP-Ed funds are used for:

• Individual nutrition counseling: One-on-one clinical nutrition counseling, medical nutrition therapy, or individualized diet plans. SNAP-Ed is a group education and community-level prevention program, not a clinical service.
• Clinical services: Health screenings (BMI, blood pressure, glucose testing), body composition assessments (unless solely for approved program evaluation), and other clinical or medical procedures.
• Food provision as a primary activity: While food samples for tasting during cooking classes are allowable, SNAP-Ed cannot fund food banks, food pantry operations, meal programs, or food distribution.
• Lobbying and political activities: Any activities intended to influence legislation, elections, or regulatory actions at the federal, state, or local level.
• Incentive payments: Cash payments, gift cards, or other monetary incentives to participants, unless specifically approved by the state and FNS as part of a research protocol.
• Supplanting other funds: SNAP-Ed funds cannot replace (supplant) existing funding for nutrition education activities. If an activity was previously funded by another source, SNAP-Ed cannot simply replace that funding.

Branding Requirements

FNS has specific branding requirements for SNAP-Ed materials and activities. Implementing agencies must follow these requirements for all participant-facing materials, signage, and communications:

• USDA nondiscrimination statement: All printed and digital materials must include the USDA nondiscrimination statement. The full statement is required for documents of one page or more; the abbreviated statement may be used on materials with limited space.
• Funding acknowledgment: Materials must acknowledge USDA/SNAP as the funding source. The specific language and logo usage requirements are detailed in the SNAP-Ed Guidance and may be supplemented by state-specific branding requirements.
• State branding: Many states have their own SNAP-Ed branding identities (such as "Eat Smart, Move More" in North Carolina or "CalFresh Healthy Living" in California). Implementing agencies must use the state-designated branding alongside or in place of generic SNAP-Ed branding.
• Dietary Guidelines alignment: All nutrition messages must be consistent with the current Dietary Guidelines for Americans and MyPlate. Messages that contradict or are inconsistent with official dietary guidance are not allowable.

EFNEP Coordination Requirements

SNAP-Ed and the Expanded Food and Nutrition Education Program (EFNEP) are both USDA-funded nutrition education programs serving low-income populations, which creates significant overlap potential. FNS requires documented coordination between SNAP-Ed and EFNEP to prevent duplication of services and ensure efficient use of federal resources.

Coordination requirements are particularly stringent for implementing agencies that also operate EFNEP programs — most commonly land-grant university cooperative extension services. Required coordination elements include:

• Service area delineation: Clear geographic or population-based boundaries between SNAP-Ed and EFNEP service delivery to minimize overlap
• Participant tracking: Systems to ensure that individuals are not simultaneously enrolled in both SNAP-Ed and EFNEP education series, preventing double-counting
• Staff role clarity: Clear documentation of which staff are charged to SNAP-Ed versus EFNEP, with appropriate time and effort reporting for staff who work on both programs
• Regular communication: Documented meetings or communications between SNAP-Ed and EFNEP program staff to coordinate activities and share referrals

PSE Change Documentation

Policy, systems, and environmental (PSE) change activities require specific documentation beyond what is needed for direct education. Because PSE changes are often multi-year efforts with incremental progress, implementing agencies must maintain clear records of their PSE work throughout the process.

• Baseline assessment: Documentation of the policy, system, or environment before the intervention began, including measurable indicators of the starting condition
• Implementation activities: Records of specific actions taken — meetings with decision-makers, technical assistance provided, materials developed, trainings conducted
• Stage of change tracking: Documentation of where each PSE initiative falls on the adoption continuum (readiness, adoption, implementation, maintenance)
• Outcome measurement: Quantifiable indicators showing the impact of the PSE change — number of people reached, changes in food availability, policy adoption documentation
• Partner agreements: Written agreements or memoranda of understanding with the institutions or organizations where PSE changes are being implemented

Inadequate PSE documentation is one of the most common compliance findings during FNS management evaluations. See the Common Mistakes section for detailed guidance on avoiding PSE documentation gaps.

Fiscal Compliance

As a subrecipient of federal funds, SNAP-Ed implementing agencies must comply with 2 CFR 200 cost principles and the specific fiscal requirements in the SNAP-Ed Guidance. Key fiscal compliance requirements include:

• Cost allocation: SNAP-Ed costs must be separated from costs charged to other programs, with documented allocation methodologies for shared costs
• Time and effort: Staff who work on SNAP-Ed and other programs must document their time allocation using methods consistent with 2 CFR 200 requirements
• Indirect costs: Implementing agencies charging indirect costs must have a current, approved indirect cost rate or use the 10% de minimis rate allowed under 2 CFR 200
• Procurement: Purchases of supplies, equipment, and contracted services must follow federal procurement standards, including documented competition for purchases above micro-purchase thresholds
• Single Audit: Implementing agencies expending $750,000 or more in total federal awards in a fiscal year must complete a Single Audit under 2 CFR 200 Subpart F

For comprehensive fiscal guidance, see the Budget & Financial Management section.

Monitoring and Oversight

SNAP-Ed implementing agencies are subject to monitoring from multiple levels:

State Monitoring

State SNAP agencies are responsible for monitoring their implementing agencies as part of their subrecipient oversight obligations under 2 CFR 200. State monitoring typically includes annual desk reviews of financial and programmatic reports, periodic on-site visits to observe programming and review documentation, and assessment of performance against plan objectives. States may use risk-based monitoring approaches, with higher-risk implementing agencies receiving more frequent and intensive oversight.

FNS Management Evaluations

FNS conducts periodic management evaluations (MEs) of state SNAP-Ed programs, which may include visits to implementing agency sites. During an ME, FNS reviewers examine:

• State SNAP-Ed plan implementation and compliance with the approved plan
• Evidence-based programming documentation and curriculum fidelity
• EARS reporting accuracy and completeness
• Fiscal records and 2 CFR 200 compliance
• EFNEP coordination documentation
• PSE change documentation and progress tracking
• Target population eligibility and site qualification documentation

Compliance Readiness Checklist

Use this checklist to assess your implementing agency's compliance posture before monitoring visits:

• All curricula used are in the SNAP-Ed Toolkit or have documented evidence equivalence
• Curriculum fidelity monitoring records are current and complete
• Site eligibility documentation is on file for every delivery location
• EFNEP coordination plan is documented and communication records maintained
• PSE change activities have baseline assessments and progress documentation
• Branding and nondiscrimination statements appear on all materials
• Time and effort records are current for all SNAP-Ed-funded staff
• No prohibited activities (individual counseling, clinical services) are charged to SNAP-Ed
• EARS data collection is accurate and complete for the current reporting period