Fill - Free fillable USDA Food and Nutrition Service Supplemental Nutrition Assistance (USDA Food and Nutrition Service) PDF form

Version 1.02 9/30/2016 OMB Control No.: 0584-0606

Expiration Date: 03/31/2019

According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not

required to respond to, a collection of information unless it displays a valid OMB control number. The valid OMB

control number for this information collection is 0584-0606. The time required to complete this information collection

is estimated to average 20 hours per response, including the time for reviewing instructions, searching existing data

sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

USDA Food and Nutrition Service

Supplemental Nutrition Assistance Program

Electronic Benefits Transfer

Online Purchasing Pilot

Request for Volunteers

September 15, 2016

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page i

Table of Contents

Table of Contents ............................................................................................................. i

Tables ............................................................................................................................. v

Figures ............................................................................................................................ v

Glossary of Terms ...........................................................................................................vi

Chapter 1 – Introduction .................................................................................................. 1

1.1 Overview ............................................................................................................ 1

1.2 Purpose .............................................................................................................. 1

1.3 Background ........................................................................................................ 1

1.3.1 Internet Shopping Workgroup ...................................................................... 2

1.3.2 Acculynk Solution ........................................................................................ 3

1.3.2.1 Mandatory Use of Acculynk .................................................................. 3

1.3.2.2 Routing Through Acculynk .................................................................... 4

1.3.2.3 Acculynk Commercial PIN-Debit Services ............................................ 4

1.3.3 Economic Changes ..................................................................................... 4

1.3.4 Agricultural Act of 2014 (Farm Bill) .............................................................. 5

1.4 Online Purchasing Pilot Vision ........................................................................... 5

1.4.1 Demonstration Authority and Evaluation...................................................... 5

1.4.2 Report to the Secretary................................................................................ 6

1.4.3 PIN Debit vs. Credit Transactions ................................................................ 6

1.5 Pilot Description ................................................................................................. 7

1.5.1 Pilot Participants .......................................................................................... 8

1.5.2 Integration with Acculynk ............................................................................. 8

1.5.3 Pilot Activities ............................................................................................ 10

1.5.3.1 Initial Pilot ............................................................................................ 11

1.5.3.2 Rollout to Additional Areas and Retailers ............................................ 11

1.6 Partner Responsibilities ................................................................................... 12

1.6.1 Food and Nutrition Service ........................................................................ 12

1.6.2 Participant Website .................................................................................... 12

1.6.3 Acculynk .................................................................................................... 14

1.6.4 EBT Processor .......................................................................................... 15

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page ii

Chapter 2 – Detailed Requirements .............................................................................. 17

2.1 Introduction ...................................................................................................... 17

2.2 Rules and Standards Governing EBT .............................................................. 17

2.2.1 FNS SNAP Laws, Rules and Policies ........................................................ 17

2.2.2 State Laws and Regulations ...................................................................... 21

2.2.3 Quest Operating Rules .............................................................................. 21

2.2.4 Technical Standards .................................................................................. 22

2.3 Basic Requirements to Participate as an EBT Internet Retailer ....................... 22

2.3.1 Authorization by FNS as a SNAP Retailer ................................................. 23

2.3.1.1 Application for Authorization as a SNAP Retailer ................................ 23

2.3.1.2 SNAP Retailer Eligibility ...................................................................... 24

2.3.1.3 Eligibility Determination ....................................................................... 25

2.3.1.4 Special Situations................................................................................ 25

2.3.2 Acculynk Requirements ............................................................................. 28

2.3.2.1 Contract .............................................................................................. 28

2.3.2.2 Specifications ...................................................................................... 28

2.3.2.3 Coding Requirements ......................................................................... 29

2.4 Operational System Requirements .................................................................. 29

2.4.1 Mandatory Transaction Types ................................................................... 29

2.4.1.1 Online PIN Purchase ........................................................................... 30

2.4.1.2 EBT PINless Refund ........................................................................... 32

2.4.1.3 Other Mandatory Transaction Types ................................................... 34

2.4.1.4 Optional Transaction Type .................................................................. 34

2.4.1.5 Prohibited Transaction Types ............................................................. 34

2.4.2 Purchase Checkout Process for SNAP and Cash EBT ............................. 36

2.4.2.1 Order Destination and Timing ............................................................. 36

2.4.2.2 Definition of Eligible SNAP Foods ....................................................... 38

2.4.2.3 Eligible Product Identification .............................................................. 39

2.4.2.4 Ability to Accept Split Tender .............................................................. 39

2.4.2.5 Selection of EBT Payment Method ..................................................... 40

2.4.2.6 Customer Fees ................................................................................... 41

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page iii

2.4.2.7 Calculation of SNAP Payment ............................................................ 41

2.4.2.8 Authorization of SNAP Purchase Transaction ..................................... 42

2.4.2.9 Calculation and Authorization of Cash EBT ........................................ 42

2.4.2.10 Denial Responses .............................................................................. 42

2.4.3 Customer Receipt and Notification ............................................................ 43

2.4.4 Equal Treatment ........................................................................................ 44

2.4.4.1 Sales Taxes ........................................................................................ 45

2.4.4.2 Manufacturer’s Coupons ..................................................................... 47

2.4.4.3 Website Design ................................................................................... 47

2.4.5 Nonprofit Cooperatives and CSAs ............................................................. 47

2.4.6 Security and Privacy .................................................................................. 48

2.4.6.1 PCI Certification .................................................................................. 48

2.4.6.2 Use of Cookies .................................................................................... 50

2.4.6.3 Security Practices and Policies ........................................................... 50

2.4.6.4 Privacy Practices and Policies ............................................................ 51

2.5 Waivers and Conditions ................................................................................... 52

2.5.1 PINless Refund .......................................................................................... 52

2.5.1.1 Conditions ........................................................................................... 53

2.5.2 PIN-Entry Method ...................................................................................... 53

2.5.2.1 Conditions ........................................................................................... 54

2.5.3 Printed Receipt .......................................................................................... 54

2.5.3.1 Conditions ........................................................................................... 55

2.5.4 Product Display ......................................................................................... 57

2.5.4.1 Conditions ........................................................................................... 57

2.5.5 Prepayment ............................................................................................... 57

2.5.5.1 Conditions ........................................................................................... 58

2.5.6 Card Must Be Present ............................................................................... 59

2.5.6.1 Conditions ........................................................................................... 59

2.5.7 Equal Treatment ........................................................................................ 59

Chapter 3 – Pilot Application, Selection and Evaluation ................................................ 60

3.1 Issuing Agency ................................................................................................. 60

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page iv

3.2 Overview .......................................................................................................... 60

3.3 Announcement ................................................................................................. 60

3.4 Points of Contact .............................................................................................. 60

3.5 RFV Timetable ................................................................................................. 61

3.6 Letter of Intent .................................................................................................. 61

3.7 Questions ......................................................................................................... 62

3.8 State and Community Partners ........................................................................ 62

3.9 Proposals ......................................................................................................... 63

3.9.1 Submission ................................................................................................ 63

3.9.2 Content ...................................................................................................... 63

3.9.2.1 RFV Participation Application Form .................................................... 63

3.9.2.2 FNS-252 SNAP Application for Stores, FNS-252-C FNS Corporate

Supplemental Application, or Chain Spreadsheet .............................................. 64

3.9.2.3 Additional Documentation for Retailer Application .............................. 65

3.9.2.4 Signatures ........................................................................................... 65

3.9.3 Proposal Format ........................................................................................ 66

3.9.4 Withdrawal of Proposal .............................................................................. 66

3.10 Participant Selection ..................................................................................... 66

3.10.1 Baseline Requirements .......................................................................... 66

3.10.2 Evaluation Process ................................................................................. 67

3.10.3 Selection Criteria .................................................................................... 68

3.10.3.1 Privacy and Data Security – 30% ....................................................... 68

3.10.3.2 System Changes and Rollout Plan – 30% .......................................... 68

3.10.3.3 Customer Service – 20% .................................................................... 68

3.10.3.4 Website Business Model – 20% ......................................................... 68

3.10.4 Selection Announcement ....................................................................... 69

3.11 Project Management ..................................................................................... 69

3.11.1 Communication ...................................................................................... 69

3.11.2 Project Plan ............................................................................................ 69

3.11.3 Joint Application Design ......................................................................... 70

3.11.4 System Design and Development .......................................................... 70

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page v

3.11.5 System Testing ....................................................................................... 70

3.11.6 Training and Marketing Materials ........................................................... 71

3.11.7 Evaluation Preparation and Planning ..................................................... 71

3.11.8 Implementation and Rollout .................................................................... 72

3.12 Online Purchasing Pilot Evaluation ............................................................... 72

3.12.1 Evaluation Contractor Responsibilities ................................................... 73

3.12.1.1 Online Purchasing Implementation Analysis ...................................... 73

3.12.1.2 Online Purchasing Impact Analysis .................................................... 73

3.12.1.3 Online Purchasing Integrity Analysis .................................................. 73

3.12.1.4 Report to the Secretary ...................................................................... 74

3.12.1.5 Data Collection Process ..................................................................... 74

3.12.2 Retailer Responsibilities ......................................................................... 74

3.12.2.1 Applicants ........................................................................................... 75

3.12.2.2 Pilot Participants ................................................................................. 76

Appendix A – State Specific Information ....................................................................... 77

Appendix B – Letter of Intent ......................................................................................... 78

Appendix C – Statement of Support from Community Organizations ............................ 79

Appendix D – Request for Volunteers (RFV) Participation Application Form ................ 80

Appendix E – FNS Retailer Application Forms ............................................................ 107

Appendix F – Evaluation Data Collection .................................................................... 118

Appendix G – ANSI Standard X9.58 Coding ............................................................... 123

Tables

Table 2-1 – FNS SNAP Policy Citations ........................................................................ 18

Table 3-1 – RFV and Pilot Timeline .............................................................................. 61

Table 3-2 – Documentation Requirements .................................................................... 72

Table A-1 – State Specific Information .......................................................................... 77

Table G-1 – X9.58 Modifications for Online Transactions ........................................... 123

Table G-2 – X9.58 EBT Specific Message Coding ...................................................... 124

Figures

Figure 1-1 Acculynk Sample PIN Entry Screen ............................................................... 9

Figure 1-2 Acculynk Transaction Flow .......................................................................... 10

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page vi

Glossary of Terms

Term

Acronym

Explanation

Definition

ANSI

American National

Standards Institute

Promotes United States voluntary

consensus and conformity to standards and

systems across and within various industries

and sectors of the economy

API

Application

Program Interface

Set of routines, protocols, and tools for

building software applications that specify

how software components should interact

Applicant

Entity proposing to volunteer its website for

the EBT Online Purchasing Pilot by

submitting a formal response to this

solicitation

BIN (also

known as

IIN)

Bank Identification

Number (Issuer

Identification

Number)

First six digits of the PAN which are used to

identify the card issuer and route

transactions for authorization

CVV (also

known as

CVN, CVC)

Card Verification

Value (Card

Verification

Number, Card

Verification Code)

A 3- or 4-digit code recorded on the back of

a commercial credit/debit card which allows

a retailer to verify that the person making a

purchase is actually in possession of the

card. The code is not embossed on the card

or included in the magnetic stripe. For

online transactions, this code is sometimes

referred to as CVV2 or CVN2.

DES

Data Encryption

Standard

PIN encryption method required by FNS

regulations and the EBT payment industry –

current standard is DES3

Eligible

Food

Defined by the Food and Nutrition Act of

2008 as any food or food product for home

consumption and also includes seeds and

plants which produce food for consumption.

The Act prohibits the following items from

being purchased with SNAP benefits:

alcoholic beverages, tobacco products, hot

food, and any food sold for on-premises

consumption. Additional information can be

found at

http://www.fns.usda.gov/snap/eligible-food-

items.

EBT

Electronic Benefits

Transfer

Debit card system for government cash and

food assistance benefits

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page vii

Term

Acronym

Explanation

Definition

EBT

Processor

Company contracted by a State agency to

run a turnkey transaction processing system

for EBT

Farm Bill

Common name for the Agricultural Act of

2014 (PL-113-79)

FIS

Fidelity National

Information

Services, Inc.

One of the three EBT processors

participating in this pilot.

FNS

Food and Nutrition

Service

The agency within USDA that administers

domestic government food assistance

programs

Internet

Retailer

Any website specifically authorized by FNS

to accept EBT cards and redeem SNAP

benefits online

ISO

International

Organization for

Standardization

Performs the same functions as ANSI, but at

the international level

PAN

Primary Account

Number

The 16-19 digit EBT card number entered as

payment for purchases

Participant

or Selected

Site

Retailer website selected through this RFV

to participate in this pilot project

PCI

Payment Card

Industry

Credit and debit card industry and individual

organizations such as Discover, MasterCard

and VISA

PCI

Certification

Official assurance that merchant is in

compliance with the industry’s set of security

and privacy rules

PII

Personally

Identifiable

Information

Information that can be used to uniquely

identify, contact, or locate a single person or

can be used with other sources to uniquely

identify a single individual

Personal

Identification

Number

Cardholder selected four-digit identifier

required to be entered for all electronic EBT

transactions

POS

Point of Sale

Usually refers to the terminal or other device

used to generate transaction requests at the

time a purchase is made

Retailer

Entity authorized by FNS to accept EBT

cards and redeem SNAP benefits

RFV

Request for

Volunteers

Document to solicit partners to voluntarily

participate in a pilot program at no cost to

the government

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page viii

Term

Acronym

Explanation

Definition

ROD

Retailer Operations

Division

Division within FNS Regional Operations

and Support responsible for retailer

authorization, fraud detection and monitoring

RPMD

Retailer Policy and

Management

Division

Division within FNS SNAP that is

responsible for EBT, policy development,

system support and program innovation

SNAP or

Program

Supplemental

Nutrition

Assistance

Program

Formerly known as the Food Stamp

Program, SNAP is a domestic Federal

nutrition assistance program that provides a

basic safety net to ensure that low income

Americans receive adequate nutrition

State

Agency

Organization within State government

responsible for contracting with an EBT

processor and operating SNAP and cash

assistance programs

TPP

Third Party

Processor

Commercial entity contracted by merchants

to route transactions for card issuer approval

and manage settlement

UAT

User Acceptance

Testing

Testing of all functional aspects of system

changes related to EBT online purchasing

USDA

United States

Department of

Agriculture

The Federal department responsible for

agricultural production, rural services and

food assistance programs

Website

Applicant’s online purchasing system, its

owners and its development staff

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 1

Chapter 1 – Introduction

1.1 Overview

The Agricultural Act of 2014 (PL-113-79), also known as the Farm Bill, calls upon the

Secretary of the United States Department of Agriculture (USDA) to authorize retail

food stores to accept Supplemental Nutrition Assistance Program (SNAP or Program)

benefits via online transactions, subject to the results of a multi-retailer pilot project

(pilot) conducted to test the feasibility of allowing such transactions. The USDA’s

Food and Nutrition Service (FNS) will be conducting these projects in order to collect

sufficient information to provide the Secretary with a recommendation on whether

allowing online purchases with SNAP benefits is in the best interest of the Program.

This Request for Volunteers (RFV) combines the need to conduct a pilot project with

the extensive groundwork started by an FNS industry work group in 2010-2011, and

invites retailers currently operating websites that sell SNAP-eligible foods and that

meet the inventory requirements to be authorized as a SNAP retailer, to apply for

participation in the projects.

This chapter provides information about past, present and future activities related to

authorization of Internet Retailers to accept SNAP and cash Electronic Benefits

Transfer (EBT) benefits online. Chapter 2 provides details on the requirements and

conditions for participation in the pilot, and Chapter 3 addresses the application

process and timeframes.

1.2 Purpose

Online grocery shopping has been a reality for many years. FNS sees this as an

opportunity to address the needs of the elderly and disabled, who often cannot easily

go out to shop. It will also be beneficial for those that lack consistent access to

transportation or live in areas considered to be food deserts.

The purpose of this RFV is to solicit a small number of experienced online food

retailers to test the implementation of EBT online purchasing and to prepare all

necessary parties to accept and process EBT transactions originating from websites.

FNS also plans to conduct an evaluation of the pilot as it proceeds, to determine

client usage and satisfaction.

1.3 Background

For many years it was technologically impossible to use EBT cards online due to the

requirement that every EBT electronic transaction include a customer-entered

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 2

personal identification number (PIN). Signature transactions and purchase ‘pre-

authorization’ are not allowed in the EBT environment. The government programs

that use EBT are exempt from certain requirements of Regulation E which governs

consumer protections for credit and commercial debit cards. If someone steals a

client’s EBT benefits, they are not replaced. Therefore, the PIN is viewed as the

ultimate form of identification in the EBT world. Secure PIN-entry requires an

American National Standards Institute (ANSI) compliant device that can encrypt the

PIN using the Data Encryption Standard (DES) algorithm from the point of entry.

Computer keyboards and mobile devices are not ANSI-compliant for PIN-entry. Until

a few years ago, all secure online PIN solutions required special user hardware

and/or software and were impractical. Online purchases made with a commercial

credit or debit card typically required the customer to enter a card verification value

(CVV) to prove that they have the card in their possession. EBT cards do not have

CVVs. Most Internet Retailers still do not accept PIN-based transactions. Instead,

they handle commercial branded debit cards like signature-based credit cards for

online transactions.

Over the years we have received increasing numbers of inquiries from Internet

Retailers looking to accept EBT transactions, as well as from SNAP clients and

advocates asking why they cannot shop online. We had to explain the barriers

caused by the PIN requirement, but were not able to offer a solution.

1.3.1 Internet Shopping Workgroup

In fall of 2008, an open discussion on ways to surmount this problem was held

at an EBT industry meeting. That led to establishment of an Internet Shopping

Workgroup with representatives from FNS, State agencies, EBT processors

and other technical consultants.

This group worked diligently to identify technical and Program policy issues

that relate directly to online commerce. A technical subgroup came together to

address each technical issue and develop logical standard solutions. This was

done to ensure that EBT remains interoperable across State borders and

follows common standards applicable to all online transactions, regardless of

the retailer, State or processor. These were thoroughly documented and

shared with a group of retailers and third party processors (TPP) that had

expressed interest in online EBT or were already active in the EBT community.

FNS held a conference call with this larger group to review the changes and

field questions. As there were no significant concerns expressed, it was

agreed that the documented modifications could be used for a pilot. See

Section 2.2.4, Technical Standards and Appendix G – ANSI Standard X9.58

Coding for specific details about the changes.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 3

FNS also identified over 25 legislative, regulatory, policy and operations issues

and decided how to handle each. These cover a wide range of concerns and

are discussed in Sections 2.3 Basic Requirements to Participate as an EBT

Internet Retailer, 2.4 Operational System Requirements and 2.5 Waivers and

Conditions.

1.3.2 Acculynk Solution

In February 2009, a company named Acculynk announced that they had an

online PIN-entry solution that had been accepted by regional banking

networks. The Internet Shopping Workgroup contacted Acculynk and held

several meetings. They are the technology provider of PaySecure™, a

software-only service for Internet PIN debit payments that utilizes a graphical

PIN-pad for the secure entry of a consumer’s PIN online. The customer

requires no special hardware, software or security certificates; they only need

their card number and PIN. PaySecure™ is the standard for Internet PIN

debit, with 4 issued patents and over 20 pending patents; 11 Electronic Fund

Transfer (EFT) network partnerships; 6,000+ U.S. merchants live; and 9,000+

bank issuers.

After serious review and discussions with Acculynk, the Internet Shopping

Workgroup agreed that PaySecure™ would be the best solution for EBT’s

PIN-entry and security concerns. It is secure and intuitive for the user and

requires little change for EBT processors. However, the service does charge

the merchant a fee similar to other payment cards, and websites will need to

determine whether the transaction and upfront development costs are a good

business decision.

1.3.2.1 Mandatory Use of Acculynk

FNS is aware that several other companies are in the process of

developing alternative secure PIN-entry solutions. However, as of the

date of this RFV’s release PaySecure™ is the only method that is

payment card industry (PCI) certified and proven in the marketplace.

Therefore, unless the applicant is aware of another recognized, PCI-

compliant, PIN-entry solution, for this pilot, FNS will require all selected

sites to contract with Acculynk for PIN-entry services. Given that any

new method would require thorough testing and PCI certification, it is

not feasible for participating retailers to design and implement their own

methods for PIN capture for use in the pilot.

We will continue to require that Internet Retailers use an industry

recognized, PCI compliant, method for Internet PIN-entry. If the pilot

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 4

project is successful, FNS will review any new PIN-entry solutions to

ensure that they meet minimum standards.

1.3.2.2 Routing Through Acculynk

For the demonstration, Acculynk will also act as the TPP, routing all

transactions directly to the EBT processor’s gateway. Therefore, any

Acculynk fees would be instead of, not in addition to, the fees the

retailer pays to its current credit/signature debit TPP. This service will

require a contract between Acculynk and the retailer. Acculynk has

agreed to limit the contract length to coincide with the pilot start and end

dates identified in Section 3.5, RFV Timetable.

1.3.2.3 Acculynk Commercial PIN-Debit Services

As noted above, Acculynk also provides secure PIN-entry services for

purchases made with commercial debit and bank Automated Teller

Machine (ATM) cards. Neither FNS nor Acculynk requires acceptance

of commercial PIN-debit as a condition of participation in this pilot

project. Participating retailers are permitted to negotiate with Acculynk

for these services.

Online merchants may wish to discuss the potential cost differential

between signature, PIN, and PINless debit with Acculynk in order to

make an informed decision. If they opt to do so, retailers selected for

pilot participation may implement commercial PIN or PINless debit

before, during or after EBT implementation. As part of the evaluation of

the pilot project, FNS is very interested in comparing the EBT versus

the commercial customer experiences and perceptions and, with the

retailer’s permission, would like to include the latter group for data

collection, voluntary surveys and interviews.

1.3.3 Economic Changes

Because most grocery websites charge fees for delivery, some thought that

EBT customers could not afford to shop online. Others felt that few SNAP

clients had access to personal computers. The EBT population had been

generally overlooked by most online grocery services. However, economic

changes have caused the SNAP caseload to grow. Currently there are 43

million people receiving SNAP benefits totaling $5.4 billion per month. Cellular

technology has also increased Internet access. As a result, many online sites

have come to recognize that SNAP customers represent a significant market.

More and more Internet Retailers have expressed interest in accepting EBT.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 5

1.3.4 Agricultural Act of 2014 (Farm Bill)

In February 2014, Congress passed the Farm Bill. Section 4011(b)

establishes additional requirements for acceptance of SNAP benefits by

Internet Retailers and calls for a pilot project to test the feasibility of allowing

certain retailers to accept SNAP benefits through online purchases if they can

meet designated criteria. Specifically, the Farm Bill requires any retailer

wanting to participate in the pilot project to submit a plan that includes, among

other things:

• A method for ensuring that only eligible foods can be purchased with

SNAP benefits online; the Act prohibits the use of SNAP funds for

payment of delivery, ordering, convenience, or other fees or charges

• A description of how households will be educated about the availability

and process for online purchasing

• Adequate testing of the online purchasing process before launching

• Provision of data requested by FNS that will allow for the evaluation of

access, ease of use and program integrity

In lieu of requiring a narrative plan, FNS has developed an application form

that addresses all of the necessary requirements. The RFV outlines the

additional legislative, regulatory and operational requirements for participation

in the Online Purchasing Pilot in Chapter 2, and addresses the application

process in Chapter 3.

1.4 Online Purchasing Pilot Vision

Eventually, FNS hopes to incorporate Internet Retailers into our regular authorization

process. But due to the nature of online purchasing, FNS must revise regulations,

develop a standard authorization process addressing unique concerns related to

Internet Retailers, and analyze and strengthen the processes for monitoring and

detecting fraud for online transactions to address the unique nature of Internet

commerce. FNS expects this pilot will provide the data needed to inform these

activities. Because this is indeed a pilot, it is being conducted within the confines of

the current EBT system, other than where waivers to existing requirements can be

granted.

1.4.1 Demonstration Authority and Evaluation

FNS has authority to waive SNAP regulations, but not the law. However,

Under Section 17 of the Food and Nutrition Act of 2008 (7 U.S.C. 2026) the

Secretary may undertake research that will help improve the administration

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 6

and effectiveness of SNAP. This provides authority to conduct demonstration

projects that deviate from law, but requires an evaluation component.

The evaluation will involve analysis of additional transaction, user account and

customer service data and statistics submitted to FNS (or an FNS-selected

evaluation contractor) from the EBT processor, retailer website, Acculynk

and/or State agencies. It will also include interviews with PIN debit customers,

Internet Retailer representatives, State agency staff, Acculynk and EBT

processors. The process for submitting such data will include appropriate

restrictions on the exchange of personally identifiable information (PII).

FNS will use the collected information to assess the impact of online

purchasing for the various parties involved in the pilot, identify implementation

issues and analyze program integrity concerns. Evaluation requirements are

addressed in more detail in Section 3.12.

1.4.2 Report to the Secretary

The Farm Bill also requires FNS to submit a report of its findings based on the

results of the evaluation to the Secretary of Agriculture. The Secretary will

subsequently make a recommendation based on that report and other criteria

deemed appropriate by that office to Congress on whether or not online

shopping should be implemented program-wide. Should the Secretary

recommend implementation, FNS will develop the process for ongoing

authorization of Internet Retailers in SNAP, including the necessary regulatory

and policy changes that specifically address web-based merchants, their

eligibility to participate in SNAP and their responsibilities as authorized

retailers.

1.4.3 PIN Debit vs. Credit Transactions

Online PIN debit transactions differ significantly from credit and signature debit

transactions. The Fair Credit Billing Act (PL93-495), which applies only to

revolving credit accounts, prohibits retailers from actually charging the

customer until the goods are about to be delivered, shipped or picked up.

Therefore, the “purchase” transaction actually consists of a preauthorization,

where the retailer transmits the customer’s card number, billing address, CVV

and estimated amount of the sale. This estimate can be padded sometimes

by a significant amount. If approved, a hold for that amount is placed against

the customer’s remaining credit limit. When the order is ready, the retailer

transmits a second “advice” message with the final amount (which may be

higher or lower than the originally authorized amount) when the customer is no

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 7

longer present. This finalizes the sale amount and releases the hold on any

remaining funds. Split orders can also be debited separately.

Because the EBT infrastructure requires a PIN for every purchase transaction,

and PINs may never be stored, the above dual transaction process cannot be

supported. The only way that EBT can work online is to debit the account in

real time upon approval of the online transaction. When completing the order

for an EBT transaction, the retailer must provide an immediate refund of any

overestimated value, out of stock items or substitutions. Because the

customer will not be present to enter a PIN, which is a requirement for in-store

refunds, Internet Retailers will be authorized to perform a special type of

refund transaction with no PIN for both SNAP and cash EBT. This non-PIN

refund will also be available for Internet Retailers to perform subsequent

product returns or other customer credits.

These differences require a significant change in mindset regarding system

logic and workflow for online transactions. See Section 2.4.1.1.2, EBT PIN

Purchase Process for more specific details.

1.5 Pilot Description

Due to the number of system modifications that must occur prior to SNAP recipients

actually using their EBT cards to purchase groceries online, the scope of this pilot will

be very limited. The pilot requires a commitment from States, EBT processors, and

retailers. Each State establishes a contract with a host processor to authorize EBT

transactions. Allowing online purchases will require significant system upgrades for

both the EBT processor and the State where a selected Internet Retailer is

conducting business. As of release of version 1.02 of this RFV, three EBT

processors have agreed to perform these system upgrades for the pilot in a limited

number of States. They are Fidelity National Information Systems, Inc. (FIS),

Solutran and Xerox State and Local Solutions

Our primary objective with this RFV is to identify a small number of qualified Internet

Retailers accepting transactions from customers living in States that will be actively

processed by one of the above companies for the duration of the pilot. Because they

will be in the process of reprocurement or conversion to a new processor during the

In January 2016, Xerox announced that they plan to split into two independent companies by 2017.

On June 16, 2016, they advised that the company that will take on their business process outsourcing,

including EBT processing services, will be called Conduent. This change is expected to occur prior to

pilot operations. In the meantime, and throughout this RFV, we continue to refer to their current name.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 8

pilot period, the following States will NOT be considered for the pilot: AK, CA, HI,

NC, VA, VI, WI and WV . Note, however, that many of the remaining States have

concerns about the level of effort required to support implementation of the Online

Purchasing Pilot. It will be essential for the State to approve the use of their system

for the pilot. FNS will work closely with potential participants to negotiate State

approval of their proposed pilot areas. We recommend that retailer applicants

contact the States in which they are interested to gain support prior to responding to

this RFV. See Appendix A, Table A-1 for a list of States and their EBT processors.

Our second objective is to select a variety of website types, sizes, geographical

locations, business models and distribution methods in order to ensure that any

future Program changes address the full scope of potentially eligible Internet

Retailers. This objective will be achieved by using a rigorous application evaluation

process as outlined in Section 3.10, Participant Selection.

1.5.1 Pilot Participants

In order to launch the pilot project, FNS has decided to limit the pilot to only

certain types of SNAP retailers. Group living and dining facilities, meal

delivery services and restaurants will be excluded, but may be considered in

the future if authorization of Internet Retailers is implemented nationwide. All

other types of food merchants that meet the eligibility requirements specified in

Section 2.3.1.2, SNAP Retailer Eligibility may apply.

Additionally, FNS will consider such factors as online sales expertise and track

record of the applicant, past customer satisfaction, product delivery in food

deserts or to other vulnerable populations, data security and privacy practices

and ability to make all necessary system changes to support SNAP

redemption as part of the selection process. See Section 3.10 for more

information about the participant selection process.

1.5.2 Integration with Acculynk

The requirements for calculating a SNAP transaction total and

recommendations on how to design the payment type selection screen are

discussed in detail in Section 2.4.2, Purchase Checkout Process for SNAP

and Cash EBT. When that is complete, the website will send the transaction

to Acculynk through a secure Internet connection, rather than to its regular

TPP. Then the PaySecure™ PIN-pad will be invoked and appear over the

checkout screen (see Figure 1-1 below). PaySecure™ does not allow PIN

entry via the keyboard, so the customer must use the mouse pointer or touch

screen to select the numbers. The cardholder enters the PIN and Acculynk’s

system scrambles the numbers on the pad after each digit is selected. The

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 9

procedure has the look and feel of the POS PIN selection process and is very

intuitive for the user.

Figure 1-1 Acculynk Sample PIN Entry Screen

When the customer selects ‘SUBMIT”, Acculynk returns control to the website.

The website will then use the PaySecure™ Application Program Interface

(API) to request card authorization. Acculynk will route the transaction to the

correct State’s EBT authorization system. The message response received by

Acculynk will be returned to the retailer as a response to the API call.

Settlement will be handled directly by Acculynk for the pilot. Acculynk will

provide the website with settlement and reporting information. See the

transaction and settlement funds flow diagram on the following page.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 10

Figure 1-2 Acculynk Transaction Flow

1.5.3 Pilot Activities

In all, FNS expects that the Online Purchasing Pilot will involve two to three

State agency EBT systems and three to five Internet Retailer participants in

the demonstration and evaluation process. However, FNS reserves the right

to select fewer or more participants or State agencies depending on the

quantity and quality of applications received. If the early stage of the pilot is

deemed a success, FNS expects to allow selected retailers to continue

acceptance of online EBT purchases through the duration of the two-year pilot

period, and may opt to expand to additional retailer participants and/or States.

Any additional retailers would be selected from the original pool of applicants

that responds timely to this RFV. FNS will work with all of the EBT processors

and States to develop a rollout strategy to implement online transactions

nationwide.

A shopper checks out at the website.

2. When prompted, the shopper enters the PIN number using the PaySecure PIN Pad, hosted by Acculynk.

3. When PIN collection is complete, the website makes an authorize request to Acculynk.

4. Acculynk routes the authorization request to the appropriate debit network or EBT processor.

5. The debit network routes the authorization request to the appropriate issuing bank, where the PIN is confirmed and funds are

verified and removed. Authorization approval goes back through the network and Acculynk to the website

6. The debit networks or EBT processors fund Acculynk and provide reporting.

7. Acculynk funds the website and provides reporting.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 11

Selected participants may opt to start their pilot in a single State or part of a

State. If the participant plans a statewide pilot, then customer usage can be

determined by the Bank Identification Number (BIN) assigned to that State’s

EBT card. If the selected site wishes to pilot in a smaller area, then it will be

the participant’s responsibility to manage limitation to eligible EBT cardholders

within the designated area, e.g., by ZIP code.

Once the participating retailers are selected, they, along with Acculynk, the

EBT processor and FNS will have approximately eight months to finalize

waiver agreements (see Section 2.5, Waivers and Conditions), to perform

necessary contract negotiations, and to design, develop, test and implement

changes to systems and workflow.

1.5.3.1 Initial Pilot

The initial implementation will begin with only one retailer participant,

selected at FNS discretion. This retailer must operate in a single State

for a minimum of one month, but potentially longer depending on

results, to ensure that transaction processing and all periodic and data

collection processes work as planned for the EBT processor, Acculynk

and the retailer.

1.5.3.2 Rollout to Additional Areas and Retailers

Upon successful completion of the initial pilot, that participant may

expand to additional Internet-ready States or areas at a rate that is

agreeable to the participant, EBT processor(s) and State agencies. At

that time, FNS will also allow additional selected retailers to begin their

pilots. As with the initial stage, each new participant must operate in a

single State, or part of a State, for a minimum of one month before

further expansion. In addition, each new State system added to the

pilot must run for at least one month with one selected retailer before

adding additional participants. Participants must commit to actively pilot

for a minimum of nine months in order to generate sufficient experience

and data for the proposed evaluation. In order to support this phasing

approach and ensure that selected participants have the opportunity to

operate for the minimum time period, the pilot will operate for a total of

two years.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 12

1.6 Partner Responsibilities

1.6.1 Food and Nutrition Service

The FNS SNAP Retailer Policy and Management Division (RPMD) is

responsible for EBT, policy development, retailer systems support and

program innovations such as this Online Purchasing Pilot. The Regional

Operations and Support’s Retailer Operations Division (ROD) is responsible

for retailer authorization, fraud detection and monitoring. For the pilot, FNS

will be responsible for the following:

1. Overall management of the pilot project

2. Issuance of RFV and responses to related inquiries

3. Evaluation and selection of participants

4. Authorization of participants as SNAP Internet Retailers

5. Notification of new Internet Retailer authorizations and deauthorizations

to EBT processor and Acculynk

6. Interpreting and making determinations about SNAP legislation,

regulations and policies applicable to participants

7. Approval of necessary waivers

8. Review and approval of all technical documentation for design and

development of EBT online purchasing system modifications

9. User acceptance testing (UAT) of all participant, EBT processor and

Acculynk systems

10. Monitoring and assessing pilot implementation

11. Approving rollout to additional States and EBT processors

12. Identifying lessons learned and making appropriate changes to near-

term process

13. Reporting to Secretary and Congress as mandated in the Farm Bill

14. Noting necessary legislation for addressing Internet Retailers in SNAP

15. Establishing regulations (including changes to current regulations) and

associated standard operating procedures for future Internet Retailer

authorization process

16. Working with industry leaders on related future changes to operating

rules and message standards

1.6.2 Participant Website

Applicants for this RFV must make a substantial commitment to carry out the

project without any form of payment from the government. To be considered

responsive, applicants must thoroughly address all mandatory requirements

detailed in Section 3.9, Proposals and in the Instructions for Completion of the

Online Purchasing Pilot RFV Participation Application Form. The applicant

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 13

must also agree that, if selected, it will comply with all of the following

requirements:

1. Meeting all conditions for FNS retailer eligibility and authorization

2. Continuing to meet these requirements after authorization

3. Ensuring equal treatment of EBT customers except for sales tax

exclusion and other Program or pilot-specific requirements.

4. Complying with conditions of all online purchasing waivers issued by

FNS

5. Submitting all additional documentation required for SNAP licensing

based on the site’s business model that may subsequently be

requested by FNS

6. Complying with FNS rules regarding acceptance of SNAP funds only for

eligible foods and fraud prevention.

7. Reporting changes of ownership or address

8. Being reauthorized at least every five years

9. Entering into a contract with Acculynk for secure PIN-entry services

using PaySecure™ for all SNAP, and if desired, cash EBT transactions

and/or commercial PIN debit payment acceptance

10. Conforming to Acculynk specifications related to message format,

system interfaces and other technical requirements including PINless

refunds (see Section 2.3.2.2 for more information)

11. Submitting all EBT purchase transactions to Acculynk for PIN-entry and

routing

12. Identifying SNAP-eligible foods in its product database and updating as

new products are added

13. For SNAP transactions, programming the system to meet all

requirements specified in Section 2.4, Operational System

Requirements

14. If opting to accept cash EBT, programming the system to meet cash

requirements specified in Section, 2.4 Operational System

Requirements

15. Ensuring that EBT purchase and refund transactions contain additional

mandatory SNAP/cash EBT data elements

16. Providing documentation for SNAP-related website design changes to

FNS and allowing for comments and recommendations

17. Allowing FNS to perform testing of website’s EBT functionality and

interfaces with Acculynk

18. Piloting in first State for a minimum of one month to ensure that all

systems are operating properly and a minimum of nine months overall

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 14

19. Working in good faith with FNS, the EBT processor and affected State

agencies to establish a schedule of rollout to other States from which

the website accepts sales

20. Maintaining Payment Card Industry (PCI) certification for its online

shopping site

21. Providing adequate service levels and timely delivery/pickup/shipping to

EBT customers in accordance with FNS-approved waivers

22. Prohibiting the sale or sharing of PII data belonging to EBT cardholders

without explicit consent of the EBT customer

23. Continuing to ensure that the website employs optimal security and

privacy practices

24. Working with FNS and the evaluation contractor to identify appropriate

methods to collect evaluation data from their employees, the system

and customers

25. Providing ongoing evaluation data as required by the RFV and the FNS

evaluation contractor

1.6.3 Acculynk

Acculynk has agreed to work with retailers, FNS and the EBT processor to

ensure the success of EBT online purchasing. Acculynk will be responsible for

the following:

1. Certifying to the EBT processor’s message specifications for online

purchasing

2. Developing and clearly documenting message format and interface

specifications for websites to use for all SNAP and cash EBT

transactions

3. Obtaining FNS approval of these specifications to ensure that they meet

regulatory and ANSI standards

4. Programming necessary changes for EBT

5. Allowing FNS to test EBT functionality and interfaces with websites and

EBT processor

6. Verifying that the participant is PCI-compliant

7. Testing and certifying that the selected site conforms to their standards

8. Contracting with each pilot participant for secure PIN-entry services

using PaySecure™ for all SNAP and cash EBT transactions

9. Ensuring that all websites submitting EBT transactions through them

have been authorized by FNS to accept SNAP benefits for online

transactions

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 15

10. Using PaySecure™ to collect and process PIN data and DES encrypt

results

11. Converting data submitted by website and encrypted PIN to EBT

processor’s specified format

12. Validating completeness of data prior to transmission

13. Routing transactions to EBT processor for authorization

14. Receiving message responses and transmitting them back to the

website

15. Assigning a unique identification number to each approved transaction

that must be used for subsequent refunds

16. Validating refunds against original purchases to ensure that their total

value does not exceed the purchase amount

17. Settling funds for all online EBT transactions to the participant

18. Providing daily and monthly transaction and settlement reports to the

participant

19. Working with evaluation contractor to provide information on

implementation process and lessons learned

20. Providing other contracted services negotiated with the participant

1.6.4 EBT Processor

The EBT processor for each pilot State will work closely with FNS and

Acculynk to ensure that online EBT transactions are properly received,

processed, transmitted and settled. The EBT processor will be responsible for

the following:

1. Designing, developing and implementing changes necessary for online

purchasing

2. Making system changes and revising TPP certification specifications to

implement X9.58-2013 changes necessary for online purchasing

3. Establishing an agreement with Acculynk and certifying them as a TPP

under the updated specifications

4. Adding fields to transaction records to capture delivery/pickup/shipping

street address and ZIP

5. Submitting pilot design details and related documents for FNS review

and approval

6. Accepting online transactions only from Acculynk to ensure the integrity

of PIN-entry

7. Checking all transactions against the current list of FNS-authorized

stores to ensure that:

a. The Internet Retailer is currently authorized by FNS as an Internet

Retailer

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 16

b. Online purchase transactions from any merchant not authorized by

FNS as an Internet Retailer are denied

c. PINless refunds from any merchant not authorized by FNS as an

Internet Retailer are denied

d. Regular POS (i.e., card present) transactions performed by an

Internet Retailer are denied

8. Validating that transactions conform to their specifications

9. Validating remaining requirements (account, card number PIN, funds,

etc.)

10. Approving or denying the transaction

11. Sending the response message back to Acculynk

12. Storing and securing transaction data and including them in existing

reports and files

13. Creating a separate, expanded daily file of transactions performed by

pilot participants for submission to FNS

14. Settling funds for all participants to Acculynk

15. Allowing FNS to test EBT functionality and interfaces with Acculynk and

retailer websites

16. Maintaining a test system to allow end to end testing for Acculynk and

retailer websites as needed

17. Reporting to State agencies and FNS

18. Working with evaluation contractor to provide information on

implementation process and lessons learned

19. Fulfilling any additional State agency requirements

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 17

Chapter 2 – Detailed Requirements

Parts of this chapter address requirements that apply equally to Internet sites and to

brick and mortar stores. Therefore, retail chains and stores that are currently

authorized to accept SNAP benefits may already be familiar with much of the content

of this section. Even so, we recommend that they read all of the requirements very

carefully.

2.1 Introduction

Large scale SNAP and cash EBT programs have been operating successfully since

the mid-1990s. Over time, various rules and standards have been developed and

issued by different organizations to bring operational order to the payment process.

These rules and standards were designed to facilitate fair and equitable treatment of

EBT customers, minimize the potential for fraud, standardize processes for retailers

and ensure interoperability among States. They work very well for face-to-face

transactions where the card is present, the customer enters a PIN to prove identity

and payment is made at the same time as goods are exchanged.

Due to the nature of Internet commerce, however, a number of changes to these

rules are required. Chapter 2 describes the necessary rule changes, requirements

for Internet sites to participate in this project, system operations, transaction flow,

waivers needed and their conditions.

2.2 Rules and Standards Governing EBT

We expect that many potential applicants for this pilot project already redeem EBT

benefits at their brick and mortar locations and thus are familiar with these rules and

standards. This section provides an overview of all of the documented requirements

that have an impact on EBT transactions, regardless of the merchant type or method

of operation. For those that have never participated in EBT, we provide links so that

you can become more familiar with the basic requirements.

2.2.1 FNS SNAP Laws, Rules and Policies

SNAP is governed by the Food and Nutrition Act of 2008 and United States

Code of Federal Regulations (CFR) Title 7 Parts 271 – 285. For the purposes

of this RFV, the most pertinent Parts of the SNAP regulations are 274,

Issuance and Use of Program Benefits and 278, Participation of Retail Food

Stores, Wholesale Food Concerns and Insured Financial Institutions. In

addition, a number of policy memoranda provide further interpretation of the

regulations.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 18

Table 2-1 lists key requirements for retailers accepting EBT.

Table 2-1 – FNS SNAP Policy Citations

Citation

Requirement

SEC 3, [7 U.S.C.

2012](k)(1)

Limits bottle or can deposit fees that can be paid for with

SNAP benefits only to the reimbursable amount and container

product types specified by State law, whether or not the

deposit fee is included in the shelf price.

SEC 3, [7 U.S.C.

2012](o)(1)(A)

Defines “Retail food store” as an establishment or house-to-

house trade route that sells food for home preparation and

consumption and meets one of the following criteria: offers for

sale, on a continuous basis, a variety of at least seven foods

in each of four categories of staple foods (meat/poultry/fish,

bread/cereals, vegetables/fruits, dairy), including perishable

foods in at least three of the categories (Criterion A

); or has

more than 50 percent of the total gross retail sales of the

establishment or route in staple foods (Criterion B);staple

foods are defined at SEC 3 [7 U.S.C. 2016] (q).

SEC 7 [7 U.S.C.

2016](b)

Benefits issued to eligible households shall be used by them

only to purchase food from retail food stores which have been

approved for participation in SNAP.

The following States currently have container deposit laws covered under the Act: California,

Connecticut, Hawaii, Iowa, Massachusetts, Maine, Michigan, New York, Oregon, and Vermont.

FNS is still in the process of implementing this Farm Bill requirement and it is unclear whether a final

rule will be published before the start of pilot operations or if current regulations at 7 CFR

278.1(b)(1)(i)(A) will remain in force. See Section 2.3.1.2, SNAP Retailer Eligibility for further

information.

The Agricultural Act of 2014 amended the Food and Nutrition Act of 2008 from the original language

requiring that SNAP benefits be used only to purchase food in retail food stores authorized for

participation in SNAP. This change was made specifically to allow SNAP benefits to be redeemed by

online retailers.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 19

Citation

Requirement

SEC 7 [7 U.S.C.

2016](k)(2)

A retail food store seeking to accept SNAP benefits through

online transactions shall establish recipient protections

regarding privacy, ease of use, access, and support similar to

the protections provided for transactions made in retail food

stores; ensure benefits are not used to pay delivery, ordering,

convenience, or other fees or charges; clearly notify

participating households at the time a food order is placed of

any delivery, ordering, convenience, or other fee or charge

associated with the food purchase and that any such fee

cannot be paid with benefits provided under the Act; ensure

the security of online transactions by using the most effective

technology available that FNS considers appropriate and cost-

effective and that is comparable to the security of transactions

at retail food stores; and meet other criteria as established by

FNS.

SEC 7 [7 U.S.C.

2016](k)(4)(B)

To be eligible to participate in an online purchasing

demonstration project, a retailer shall submit a plan for FNS

approval that includes a method of ensuring that benefits may

be used to purchase only eligible items under this Act; a

description of the method of educating participant households

about the availability and operation of online purchasing;

adequate testing of the online purchasing option prior to

implementation; provision of data as requested by FNS to

analyze the impact of the project on participant access, ease

of use, and program

integrity; reports on progress, challenges,

and results, as determined by FNS; and such other criteria,

including security criteria, as established by FNS.

SEC 3 [7 U.S.C.

2012](o)(4)

Adds community supported agriculture (CSA) as a retailer

type authorized to accept advance payment from SNAP

benefits for agriculture shares.

SEC 10 [7 U.S.C.

2019]

Retail food stores authorized to accept and redeem benefits

through online transactions may accept benefits prior to the

delivery of food if the delivery occurs within a reasonable time

of the purchase, as determined by FNS.

274.7(a) and

278.2(a)

SNAP benefits may be accepted by an authorized retail food

store only from eligible households or the households’

authorized representative, and only in exchange for eligible

foods; eligible foods are defined at 7 CFR 271.2

274.7(c)

No minimum dollar amount per transaction or maximum limit

on the number of transactions shall be established. Nor shall

transaction fees be imposed on SNAP households using the

EBT system to access their benefits.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 20

Citation

Requirement

274.8(a)(2)

Transactions require primary account number (PAN), unique

terminal identification number, and retailer identification

numbers assigned by FNS, and require verification of a PIN

for all transactions (purchases, refunds, voids, and balance

inquiries) except manual vouchers.

274.7(f) and

278.2(b)

SNAP benefit shall be accepted for eligible foods at the same

prices and on the same terms and conditions applicable to

cash purchases of the same foods at the same store, except

that tax shall not be charged on eligible foods purchased with

SNAP benefits. No retail food store may single out SNAP

clients for special treatment in any way.

274.8(b)

POS terminals must meet ANSI and International

Organization for Standardization (ISO) standards where

applicable.

274.8(b)

Requires use of EBT ISO 8583 Processor Interface Technical

Specifications contained in the ANSI standard X9.58, which

delineates a standard message format for retailers and third

parties.

274.8(b)(3)(ii)(C)

and 274.8(b)(6)(iii)

PIN encryption utilizing the DES algorithm shall occur from the

point of entry in a manner which prevents the unsecured

transmission of the PIN between any points in the system.

274.8(b)(6)(i)

Balance information shall not be displayed on the screen of

the POS terminal except for balance-only inquiry terminals.

274.8(b)(7)

Households shall be provided printed receipts at the time of

transaction, with date, merchant's name and location,

truncated card number, transaction type, transaction amount,

and remaining balance for the SNAP account. The

household's name shall not appear on the receipt.

274.8(b)(9)

Minimum transaction set must include refund transactions. All

transactions involving refunds for goods originally purchased

with SNAP benefits, whether from an error in scanning or the

return of an item, must be credited to the SNAP EBT account.

The customer may not receive cash refunds or store credit.

278.2(e)

Except as provided by SEC 3 [7 U.S.C. 2012](o)(4) and SEC

10 [7 U.S.C. 2019] above, food retailers may not accept

SNAP benefits before delivering the food. The only additional

exception is for n

onprofit food buying cooperatives, which may

accept benefits up to 14 days prior to food delivery

Policy Memo

BRD/EBT 2001-1

Card must be present for key entered transactions.

Pending publication of regulations, non-profits and agricultural producers operating using a CSA

model are also authorized to accept SNAP benefits up to 14 days prior to food delivery.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 21

Citation

Requirement

BRD Policy Memo

2007-1

When a manufacturer’s coupon is used for an item purchased

with SNAP, the discount or amount of funds saved must be

credited to the SNAP EBT account (or only the net value

deducted). Crediting the SNAP benefit account eliminates a

potential avenue for fraud. Sales tax, if applicable, that must

be collected from the customer for the coupon savings, must

also be paid by SNAP customers, but with another type of

tender.

Please note that while the Federal government itself must comply with online

website accessibility standards under Section 508 of the Americans with

Disabilities Act, these requirements are not mandatory for retailers under this

pilot. However, FNS encourages selected participants to provide such access

to its customers. Applicants with Section 508 compliant sites will be

considered more favorably in the selection process.

2.2.2 State Laws and Regulations

Approximately 35 State agencies also issue cash benefits through EBT. The

remaining States use other methods such as prepaid branded electronic

payment cards. Cash programs are the responsibility of the States, not FNS.

States generally favor allowing Internet Retailers authorized by FNS under this

pilot to accept cash EBT as well. Funds from the cash account may be used

to pay for SNAP-ineligible products such as paper goods or for fees. While

each State has its own eligibility rules and payment levels, cash EBT accounts

and transactions are handled in a very similar manner to SNAP accounts.

Some States have features to block certain merchant type codes in order to

limit card usage to what Federal and State laws deem suitable for cash

recipients. However, SNAP-authorized food retailers do not generally fall into

those categories.

2.2.3 Quest Operating Rules

Both SNAP and cash EBT are governed by the Quest Operating Rules in most

States. The remaining States generally follow the same rules except for some

small differences in adjustment policies. The Quest Operating Rules are

published by the National Automated Clearinghouse Association (NACHA).

They outline the responsibilities of issuers, acquirers, merchants, and third

party service providers and address issues such as settlement, error

resolution, and use of the Quest mark.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 22

At least one provision will require modification for online purchasing. Quest

Operating Rules currently prohibit refunds to the cash account. Cash refunds

never apply to eligible items purchased using SNAP benefits. However, cash

account refunds may be needed for online transactions in which a refund is

necessary for items that were originally purchased with cash EBT benefits

because there is no other way to reimburse the customer for overpayments or

returned items. This has been brought to the attention of the committee

responsible for the rules. We do not expect that there will be any problems

making the necessary modifications once the pilot project is complete.

2.2.4 Technical Standards

As noted above, FNS rules require that the EBT transaction messages arriving

at the EBT processors for authorization must meet specifications contained in

the EBT version of the ISO 8583 transaction message standard. The name of

this standard is X9.58. For brick and mortar stores, it is the responsibility of

the merchant’s TPP to convert transaction data to this standard. The

merchant must then conform to the TPP’s EBT message specifications.

A number of changes were made to X9.58 in 2013 to accommodate online

transactions. Acculynk will act as the TPP for the Online Purchasing Pilot

transactions, and will be responsible for coding them to meet X9.58

specifications for online purchases and refunds. This will not be the

responsibility of the pilot participants, who instead must code to Acculynk’s

EBT message specifications (see Section 2.3.2.2). For those desiring

additional information, Appendix G – ANSI Standard X9.58 Coding contains a

summary of changes and messaging codes applicable to online SNAP

retailers.

2.3 Basic Requirements to Participate as an EBT Internet

Retailer

Any retailer wishing to participate in the Online Purchasing Pilot should be sure that

they will be able to meet these basic requirements. Every selected site must

successfully complete the activities described in this section. Failure to do so within a

For more information click on the following:

Complete Quest Operating Rules

Appendix A – State Specific Information for listing of Quest States

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 23

reasonable time will result in the retailer being dropped from the pilot, having their

Internet Retailer SNAP authorization withdrawn, and being replaced by another

participant.

2.3.1 Authorization by FNS as a SNAP Retailer

In order to redeem SNAP benefits, food merchants must meet the eligibility

requirements outlined in Federal regulations. Once the store has been

licensed by FNS it must continue to comply with those and other FNS rules

governing EBT and interaction with SNAP customers. Retailer fraud and

collusion with customers to trade SNAP benefits for cash or ineligible products

such as alcohol and cigarettes are grounds for disqualification, in some cases,

permanently.

2.3.1.1 Application for Authorization as a SNAP Retailer

Every applicant for this RFV must complete a SNAP Retailer application

as described below, and enclose it electronically with their RFV

response (see Section 3.9.1

for proposal submission instructions). Do

NOT use the FNS online application process to apply as an Internet

Retailer for this pilot project. Please bear in mind that these forms were

designed for brick and mortar retailers, so some questions will not

apply. Copies of the application forms can be found in Appendix E –

FNS Retailer Application Forms.

2.3.1.1.1 FNS-252-C Corporate Supplemental Application

For supermarket chains that have more than ten brick and mortar

locations authorized to accept SNAP, FNS assigns a corporation

ID number to link each location to the corporate level information.

Applicants that already have multiple locations authorized in this

manner should complete Appendix E – Form FNS-252-C,

Corporate Supplemental Application. As an alternative, an

applicant that already has a corporation ID may provide an

updated copy of its FNS-developed chain retailer spreadsheet

with a new row added to reflect appropriate data for its website.

If you need a copy of this spreadsheet, please contact the FNS

SNAP Retailer Service Center at (877) 823-4369.

For more information about program rules that apply to retailers please

download our FNS Retailer Training Guide.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 24

2.3.1.1.2 FNS-252- Supplemental Nutrition Assistance

Program Application for Stores

All other applicants must complete the full application, Appendix

E – Form FNS-252. You must also provide digitally scanned

copies of the following:

1. One current business license in your name or the name of

your business

2. Government issued photo identification for all owners,

partners, and corporate officers; and in Community

Property States, spouses of owners and partners

3. Government issued Social Security Number

documentation for all owners, partners, and corporate

officers; and in Community Property States, spouses of

owners and partners

2.3.1.2 SNAP Retailer Eligibility

To be eligible for authorization, the applicant’s website must sell food

for home preparation and consumption, normally displayed in a public

area,

which meets one of two criteria, briefly described below.

1. Criterion A: The website must offer for sale, on a continuous

basis, a variety of qualifying foods in each of four categories of

staple foods (meat/fish, breads/cereals, fruits/vegetables and

dairy)

2. Criterion B: More than 50 percent of the total gross retail sales of

the website must consist of staple foods

As previously noted, FNS is in the process of implementing enhanced

eligibility rules, as required by the Farm Bill. These changes may affect

the definition of staple foods and increase the minimum variety of food

types, stock keeping units and perishable products required for

eligibility.

There is a possibility that these changes will be implemented prior to

the start of pilot operations. Your website and order fulfillment site(s),

In an internet environment, this means that the products must be readily available on a consistent

basis (i.e. not “sold out” or otherwise out of stock or on backorder on the website or in the warehouse).

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 25

e.g., warehouse, brick and mortar store, etc., must meet the staple food

requirements in effect at the time of FNS-authorization.

2.3.1.3 Eligibility Determination

This is normally determined by visual inspection, marketing structure,

business licenses, accessibility of food items offered for sale, tax

records, purchase and sales records, counting of stock keeping units, or

other inventory or accounting recordkeeping methods that are

customary or reasonable in the retail food industry. FNS reserves the

right to request additional documentation of food sales such as noted

above if needed.

Brick and mortar stores often receive an onsite visit prior to

authorization. Depending on the size and nature of the business

conducted on your website, we may request an onsite visual inspection

of your warehouse or other stock location.

Applicants that fail to provide the necessary information and onsite

access, or do not meet the requirements identified in Section 2.3.1.2,

SNAP Eligibility, will not be selected for this pilot.

2.3.1.4 Special Situations

There are additional issues and requirements for certain types of

retailers. These are described below.

2.3.1.4.1 Retailers Excluded from the Pilot

FNS authorizes a variety of retailer types that provide prepared

meals for SNAP clients. These include, but are not limited to

communal dining facilities, group homes, shelters, rehabilitation

centers, meals on wheels programs and restaurants. Because

this pilot project is designed to evaluate online purchasing of

food products for home preparation and consumption, meal

services and restaurants may not apply for pilot participation.

For information about the current retailer eligibility requirements go to Retail

Store Eligibility USDA Supplemental Nutrition Assistance Program.

For information on the proposed changes go to Enhancing Retailer Standards

in the Supplemental Nutrition Assistance Program (SNAP). Final regulations

may contain substantial changes from this proposed rule.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 26

2.3.1.4.2 Retailers Already Eligible to Charge Customers in

Advance

Nonprofit food buying cooperatives and agricultural producers

that offer community supported agriculture (CSA) shares are

currently eligible to accept SNAP benefits up to 14 days in

advance of delivery. While they are allowed to apply for pilot

participation, there are additional website design issues. These

retailers should pay special attention to Section 2.4.5, Nonprofit

Cooperatives and CSAs.

2.3.1.4.3 Sites Owned by Already Authorized Retailers

Under FNS rules, each store location is authorized individually

based on its own circumstances and inventory. The eligibility of

websites owned by already authorized, or otherwise eligible,

retailers will be based on the products actually sold on the

website and stocked at the fulfillment site(s) for online orders, not

on their in-store inventories. The website will be authorized as

an Internet Retailer store type under a separate FNS number

and be treated by FNS as a distinct retail firm.

2.3.1.4.4 Multiple Website Operations

Just as different store locations require separate FNS

authorization and receive separate FNS numbers, online

merchants that run multiple websites for different populations or

a single website that can direct different populations to different

product inventories require separate FNS authorization. This is

because the product inventory available to each of the

populations will be different, perhaps significantly, and product

inventory is what is used to determine a retailer’s eligibility to

redeem SNAP benefits.

In addition, FNS’s ability to monitor transactions and identify

potentially fraudulent activity depends on an understanding of the

geographic limitations of any retailer’s customers.

As an example, a company that provides home delivery of its full

line of products in its own local area, but also ships a more

limited inventory of products nationally will require two separate

FNS authorizations. Eligibility for each operation will be based

on the level of sales and products sold under that operation only.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 27

If the applicant‘s website(s) falls under this description, only one

of the operations will be selected for the pilot. The response to

the RFV must provide a description of the overall operation and

potential FNS authorizations that will be required in the future.

However, the application itself and all related answers to specific

questions must be limited to just one of the operations.

2.3.1.4.5 Delivery Services

Independent delivery services

that do not have their own food

inventory and only deliver/ship products obtained at other retail

establishments are not eligible to be authorized as FNS retailers

and, therefore, may not apply to be pilot participants

2.3.1.4.6 Third Party Products

Many websites serve as an aggregator or marketplace for other

businesses or individuals. The website’s purpose is to list the

products belonging to these third parties and, in many cases,

accept online payment for them. If the website owner has no

food inventory of its own and merely purveys products owned,

stored and shipped by the third parties, they do not meet the

qualifications for SNAP authorization, and may not apply for the

Online Purchasing Pilot.

However, some website owners do have their own food

inventory, but also feature products sold and shipped directly by

third parties. These sites must meet the eligibility requirements

identified in Section 2.3.1.2 based solely on their own inventory

and sales. Furthermore, at least 50% of their SNAP-eligible food

sales must come from their own inventory. Third party products

will not be considered SNAP-eligible and they may not be

purchased on the website with SNAP EBT benefits. They may,

however, be purchased with cash EBT benefits. This must be

clearly explained on the site so that SNAP clients understand the

difference between the two product sources, and know which

products are eligible and which are not.

The Farm Bill does identify a new retailer type: non-profit or government organizations that purchase

and deliver groceries for elderly and disabled individuals who are unable to shop for food. However,

FNS is conducting a separate evaluation of these entities, and they are not eligible to participate in the

Online Purchasing Pilot as well.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 28

2.3.2 Acculynk Requirements

Acculynk is the payment processor for this EBT pilot and also sets pricing for

the PaySecure™ platform. All pilot applicants must agree to work in good faith

with Acculynk to negotiate services and pricing for secure PIN-entry, refund

handling, transaction routing and settlement.

Selected participants must contract directly with Acculynk for these services,

and conform to their specifications and requirements.

2.3.2.1 Contract

It is absolutely required for a selected participant to have such a

contract in place if it wishes to participate in this pilot. We recommend

that you contact Acculynk (see Section 3.4, Points of Contact) soon

after reading this RFV, to discuss services, pricing structure, and

requirements for EBT. If a selected site fails to have a contract in place

within a reasonable time, FNS reserves the right to select another

applicant for the pilot. Without an Acculynk contract, the website will

not be authorized to accept any EBT benefits.

2.3.2.2 Specifications

Selected websites must conform to Acculynk’s message specifications

and other requirements. The following EBT specific information must

be included in the message for all purchases and refunds:

2.3.2.2.1 Static Data that May be Contained in an Acculynk

Table for the Retailer

• Terminal ID

• Card Acceptor ID Code

• Card Acceptor Name/Location

• National Point of Service Condition Code

• Merchant Type

• FNS Authorization Number

2.3.2.2.2 Variable Data that Must be Submitted with Each

Transaction

• Card Number - PAN

• Account Type (SNAP or cash)

• Transaction Type (purchase, refund, balance inquiry)

• Amount

• Date and Time

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 29

• Delivery Address Line 1 (28 characters)

• Delivery ZIP Code (9 characters)

2.3.2.2.3 Data Not Applicable to EBT Transactions

• Expiration Date (default is 4912)

• Card Verification Value (CVV)

2.3.2.2.4 Important Data Returned in Response

• Approval/Denial Response Code

• SNAP Account Balance

• Cash Account Balance

2.3.2.3 Coding Requirements

The PIN-entry process requires the addition of PaySecure™ EBT code

to the checkout page. Coding can typically be done with minimal

technical resources, with implementation time of two to four weeks.

The process uses a combination of industry standard Simple Object

Access Protocol (SOAP) based application program interfaces and

JavaScript which supports a number of features (some optional).

The Acculynk technology team, including a project manager, quality

assurance specialist and web developer will be available throughout the

implementation process to assist merchants.

2.4 Operational System Requirements

This section describes the EBT-specific functionality that websites authorized as

SNAP Internet Retailers must provide.

2.4.1 Mandatory Transaction Types

The full set of face-to-face SNAP transactions that EBT processors and TPPs

for brick and mortar stores are required to provide are:

• PIN POS Purchase

• PIN POS Refund

• PIN POS Void

• PIN POS Balance Inquiry

• POS Reversal

For more information about Acculynk message specifications contact the

Acculynk representative identified in Section 3.4, Points of Contact.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 30

• Manual Voucher Authorization (signature based)

• Manual Voucher Clear

• Adjustment

However, retailers themselves are not required to use manual vouchers or

allow in-lane balance inquiry if they do not wish to do so (although an

alternative balance inquiry process must be available). Cash EBT transaction

requirements usually include:

• PIN POS Purchase

• PIN POS Purchase with Cash Back

• PIN POS/ATM Cash Only Withdrawal (cash received without

purchase)

• PIN POS Balance Inquiry

• PIN POS Void

• POS/ATM Reversal

• Adjustment

Essentially, every electronic EBT transaction initiated by a customer or retailer

requires the cardholder to enter a PIN. However, the Internet environment has

additional challenges that must be considered. Therefore, the transaction

types that websites must be able to perform will be substantially different from

those done in brick and mortar locations. Internet Retailers must be able to

support the types of transactions addressed below.

2.4.1.1 Online PIN Purchase

Unlike commercial credit and debit, signature-based transactions are

not allowed under EBT. The PIN is the only form of identification that

the EBT client has. Therefore, FNS will continue to require that every

purchase or other debit to the customer account be accompanied by a

securely entered PIN. The only PIN-entry method that FNS will accept

at this time is Acculynk’s PaySecure™. Any website that wishes to

accept cash EBT must meet the same conditions for cash account

debits.

EBT PINs may never be stored for future use in subsequent

transactions, either in the website or in any other system maintained by

the retailer. The PIN must always be captured and immediately

encrypted by Acculynk for each payment transaction. Acculynk does

not store the PIN value after the transaction response is received,

either. In addition, neither Acculynk nor the EBT processors support

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 31

preauthorization as done in the credit/signature debit environment. As

a result, SNAP and cash EBT transactions must always be performed in

real time at the time of online PIN entry, with immediate debit of funds

from the cardholder’s account and settlement to the retailer within two

business days.

For this reason, EBT also cannot support standing orders (a one-time

order for specific products to be delivered at a regular interval, such as

monthly, usually at a discount). Selected participants must prohibit the

use of EBT cards for standing orders.

2.4.1.1.1 Special Needs of Food Retailers

This creates some problems for the grocery and Internet

industries. Many supermarkets that provide home delivery, or

put together orders for pickup, deal with products that are sold by

weight (e.g., produce, meats, fish and deli items). Therefore,

prices for those items are only estimated and could be less or

more once the order is fulfilled.

There may be instances where an item is not available at the

time the order is put together. Companies have different ways of

dealing with this: substitute with a similar product which could

cost more or less, backorder, split the delivery, or remove the

product from the order total.

2.4.1.1.2 EBT PIN Purchase Process

Based on input from State and industry partners, FNS has

established the following guidelines for use during the pilot. The

website may “pad” the amount initially debited from the

customer’s EBT account by no more than 10 percent of the

calculated price of any weighed items, but must provide a

subsequent refund for any amount overcharged. For example, if

the total EBT order comes to $50, of which $15 is calculated for

weighed meat and produce, the Internet Retailer may “pad” the

debited amount by up to $1.50 (10 percent of $15), and charge

the customer up to $51.50. This must be clearly explained to the

customer before the transaction is submitted for authorization.

Once the order is fulfilled, if the final price is less than the

amount originally debited from the customer, the website must

provide an immediate refund to credit the difference back to their

account using the process described in Section 2.4.1.2, EBT

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 32

PINless Refund. So if, in the above example, the weighed items

actually totaled $15.25, the retailer would provide a refund of

$1.25. If the final price is more than the amount originally

debited, the retailer is liable for the difference and may not

charge the EBT customer.

Because of the inherent delay built into online commerce, FNS

will provide a waiver to all pilot participants, allowing them to

collect funds up to seven (7) calendar days in advance of

customer receipt of goods. Therefore, items cannot be

backordered longer than that timeframe. This waiver and all of

its related conditions are discussed more thoroughly in Section

2.5, Waivers and Other Conditions, Prepayment.

The actual mechanics of selecting and performing a SNAP PIN

purchase are described more thoroughly in Section 2.4.2,

Purchase Checkout Process for SNAP and Cash EBT.

2.4.1.1.3 Denial for Insufficient Funds

It should be noted that if a transaction is denied for insufficient

funds, the return message will include current account balances

for both the SNAP and cash accounts. This information should

be presented on the screen to the client so that they can opt to

perform another transaction for a lesser amount or select

different tender.

2.4.1.2 EBT PINless Refund

This is a new EBT transaction type developed specifically for Internet

Retailers. Although most States do not support POS refunds for cash

EBT accounts, pilot participants will use the PINless refund process for

both SNAP and cash EBT. In almost all cases, refunds will be

performed when the customer is offline, and therefore, it will not be

possible to capture the cardholder PIN. This transaction type will only

be accepted from Internet Retailers; it may not be used by any brick

and mortar stores. The process will be used for all instances where

funds are due back to the customer. In addition to refunds for

overestimated costs, as described above, it may be used for out of

stock and returned items. At a minimum, there must be a process in

place for human entry of a PINless refund transaction (e.g., through a

customer service representative); however, websites are encouraged to

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 33

integrate automated refund processes into their existing operations for

the issues described above.

FNS will provide a waiver to each selected site to allow PINless

refunds. In no case may shipping charges be deducted from money

refunded for items purchased with SNAP. The full value of any returned

food item purchased with SNAP must be credited back to the client’s

SNAP account. Any shipping charges due for SNAP returns must be

paid through an alternative payment method. Refunds for items

purchased with cash EBT are not subject to these restrictions. This

waiver and all of its related conditions are discussed more thoroughly in

Section 2.5.1, Waivers and Conditions, PINless Refund.

2.4.1.2.1 FNS Timeliness Requirements for Refunds

EBT refunds at brick and mortar locations are processed when

the client is present to enter the PIN, so they are immediate.

This is not the case for the online environment. FNS will expect

that refunds for overestimated weight, substitutions, and out of

stock items be made at the time the order is fulfilled or shortly

thereafter. Post-delivery refunds, such as those for returned

items or customer complaints, must be processed within two (2)

company business days after receipt of the returned item or

complaint.

2.4.1.2.2 Acculynk Refund Process

All PINless refunds must flow through Acculynk and comply with

their specifications. These transactions must contain the

authorization number of the original approval so that refunds can

be accurately traced. Acculynk maintains a database of all

approved transactions for up to 18 months. When a refund

request is submitted Acculynk matches it against their database

to ensure that it does not exceed the value of the original

purchase. The system can track multiple refunds for the same

purchase, ensuring the total of all refunds does not exceed the

original purchase amount. If the value of the refund is excessive,

Acculynk denies the transaction and sends it back to the website

without forwarding it for authorization.

2.4.1.2.3 Website Refund Process

Because refunds are sometimes needed based on emails,

telephone calls, and receipt of products returned in the mail,

every site must have a method to securely enter refund requests

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 34

manually. The right to do so must be limited to authorized

personnel using a password protected user ID. This may be set

up in any manner that is effective for the website, as long as it

can produce a transaction message that meets Acculynk

specifications.

Websites that estimate for weighed items, or have the potential

for out of stock products or substitutions, should also consider

developing code to automatically create refund transactions at

the time the order is finalized to correct overcharges.

Automation of this process will help ensure that resulting refunds

are timely.

2.4.1.2.4 Refund Notification

EBT customers must receive a receipt or other notification for

every refund so that they have a record of the transaction and

remaining balances (see Section 2.4.3 Customer Receipt and

Notification for information on content, method and timing).

2.4.1.3 Other Mandatory Transaction Types

Websites must be prepared to handle reversals and adjustments in

accordance with Acculynk specifications. PINs are not required in

reversal messages.

2.4.1.4 Optional Transaction Type

Websites may also employ a void transaction for the last purchase

made, but if they do so, the customer must enter the PIN again. EBT

processors cannot accept PINless voids. These are usually necessary

when a clerk has miskeyed the sale amount so the need for them in the

online environment is almost non-existent. Therefore, voids will not be

a mandatory transaction type for Internet Retailers. If a situation arises

where the sale must be cancelled after it has been processed, the

website may perform a PINless refund instead.

2.4.1.5 Prohibited Transaction Types

The FNS authorization for all participants in the pilot will be as an

Internet Retailer, only (store type code IR). The valid list of Internet

Retailers will be shared with the EBT processor and Acculynk to ensure

that only approved retailers perform online transactions. In addition,

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 35

they will be used by the EBT processor to prevent any retailer coded as

IR from doing the following types of transactions:

2.4.1.5.1 Unsupported Transactions

The follow types of transactions identified above in Section 2.4.1

for brick and mortar stores are not relevant to Internet Retailers

and, therefore, may NOT be performed by pilot participants:

• SNAP Manual Voucher Authorization (signature based)

• SNAP Manual Voucher Clear

• PIN Purchase with Cash Back

• PIN Cash Only Withdrawal (cash received without

purchase)

2.4.1.5.2 Transactions Not Allowed for Online Retailers

EBT processors will also use the IR retailer type code to ensure

that approved Internet Retailers do not use their online FNS

number to perform any face-to-face transactions involving a brick

and mortar type electronic cash register, stand beside POS

terminal or hand-held wireless device that accepts a swiped or

key-entered card.

Any currently authorized FNS retailer may continue to do these

types of transactions using their existing FNS authorization

number(s). This includes a small number of Internet Retailers

that currently have a special FNS waiver to allow for online

ordering, with subsequent SNAP payment accepted at the time

of delivery using a wireless or mobile POS device. All other

online-only retailers that apply for this pilot demonstration will be

limited only to the allowable online transaction types discussed in

the Sections 2.4.1.1 through 2.4.1.3.

2.4.1.5.3 Store and Forward

In order to keep lane traffic moving and prevent the need for

returning items to their shelves, some brick and mortar retailers

opt to do store and forward transactions when their system

cannot communicate with the EBT processor for authorization.

The retailer accepts full liability for these transactions if they are

subsequently denied for any reason, including bad PIN or

insufficient funds. Please note that store and forward

transactions will not be supported for this pilot project. FNS will

revisit this issue after successful completion of the pilot.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 36

2.4.2 Purchase Checkout Process for SNAP and Cash EBT

This section identifies EBT specific issues that must be considered and

addressed once the customer has filled the “cart” or “basket” and is ready to

complete the purchase.

2.4.2.1 Order Destination and Timing

Online food businesses use a variety of methods to get completed

orders into the customers’ hands. Many deliver the order, themselves,

to the customer’s home or other specified local address. Some ship the

order using the post office or a commercial service such as UPS or

FedEx. Others have the customer come to a specific location to pick up

the order. The merchant may have a single pickup location, or might

allow the customer to select from a list of designated stores or other

locations.

As previously noted, it is mandatory for Internet Retailers to provide a

delivery or pickup street address and ZIP code in every EBT

transaction.

In addition, many online sites also allow the customer to specify the

date and time that they would like to have their order delivered or ready

for pickup. Other retailers may designate a very limited timeframe that

will be available for delivery or pickup in a given area. Those that ship

orders commercially also may offer customer flexibility to specify

method and speed of delivery. EBT customers must be offered the

same destination, method and timing options given to credit/debit

customers. Except as noted below and in Section 2.4.5, Nonprofit

Cooperatives and CSAs, all EBT orders must be in the customers’

hands (or a refund provided) within seven calendar days.

2.4.2.1.1 Customer-Selected Options

When the retailer requests the customer to specify a delivery or

shipping address, they usually collect up to two address lines,

city, State and ZIP. The Address Line 1 and the ZIP code

entered by the customer (or selected from their stored

addresses) must be included in the transaction message

submitted to Acculynk.

If the merchant allows every customer the ability to designate the

date and time for local delivery/pickup, their EBT customers will

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 37

be allowed to select a date, for their own convenience, that is

more than seven calendar days after payment.

Applicants should describe policies and maximum timeframes for

customer-scheduled orders. FNS reserves the right to set a

shorter maximum timeframe for EBT customers if we consider

that excessive.

FNS plans to examine the reasonableness of the seven day

timeframe during the formal pilot evaluation and is interested in

gathering data on these sales to determine the range of delivery

timeframes requested by EBT customers.

2.4.2.1.2 Retailer-Designated Options

If the retailer requires all customers to come to one specific site

to pick up their orders, the address and ZIP code of that site will

be the EBT delivery address for all EBT transactions submitted

to Acculynk. If the customer chooses from a menu or list of store

locations or other distribution points, or the merchant assigns a

location from such a list, the address and ZIP code for that

pickup location must be included in the transaction message.

In addition, FNS will require the retailer to provide a record of the

full pickup site address to the customer (See

Section 2.4.3

Customer Receipt and Notification). Therefore, the location

menu must be associated with a system table that also includes

the complete street address and ZIP code of each location.

If the retailer has limited delivery or pickup in certain areas or

locations (e.g., only once per month) they may not accept

payment by EBT for those deliveries until seven days before

actual delivery. The requirements for nonprofit food buying

cooperatives and CSAs (see Section 2.4.5

) include a more

detailed explanation of how limited distribution schedules must

be handled.

2.4.2.1.3 Split Orders

Some online merchants, especially those that use commercial

shipping, and/or have multiple warehouses, support split orders.

Many also allow the customer to designate that different items

from a single order be delivered to different addresses. FNS will

not prohibit the use of split orders for the online pilot as long as

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 38

the entire order is shipped early enough to meet the required

seven-day timeframe.

However, because FNS requires that every transaction be

associated with a delivery location, the entire SNAP order must

be delivered/shipped to the same address. Therefore, the

retailer must prohibit EBT customers from selecting multiple

addresses for a single order. One alternative would be to require

the customer to submit the split order as separate SNAP

transactions that include different addresses. PIN-entry would

be required for each transaction.

2.4.2.2 Definition of Eligible SNAP Foods

Federal regulations stipulate that SNAP benefits may only be

exchanged for eligible foods. Therefore, it is essential that the checkout

process mirror, as closely as possible, that used by in-lane integrated

supermarket systems. SNAP benefits may only be used to pay for the

following:

• Foods for the household to eat, such as:

o breads and cereals

o fruits and vegetables

o meats, fish and poultry

o dairy products, and

o other accessory foods such as coffee; tea; cocoa; soda;

non-carbonated beverages such as sports drinks, punches,

and flavored waters; candy; condiments and spices

• Seeds and plants which produce food for the household to eat

• State-mandated container deposits for eligible products (because

the products cannot be sold without the containers); any deposit

amount beyond that required by the State, such as a

manufacturer or retailer-imposed bottle deposit, may not be paid

with SNAP benefits

Households cannot use SNAP benefits to pay for:

• Alcohol or tobacco products

• Any nonfood items, such as:

o pet foods

o soaps, paper products, and household supplies

o vitamins and medicines

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 39

o any product sold with a “Supplement Facts” label instead of

a “Nutrition Facts” label

• Food that will be eaten in the store

• Hot foods

• Live animals

• Fees for bags (or other delivery/pickup/shipping containers)

whether or not imposed by State or local law

• Fees of any kind, regardless of when they are charged, including

those for:

o shipping and/or handling

o delivery

o processing

o membership

o registration

Although the law also allows SNAP benefits to be used by certain

Alaskan natives to purchase hunting and fishing equipment, these

products will not be allowable for the Online Purchasing Pilot.

2.4.2.3 Eligible Product Identification

If the applicant only sells eligible products as described above, product

identification will not be an issue. However, the vast majority of online

food retailers also carry products that are not SNAP-eligible. Because

there is no human intervention to perform visual identification of eligible

foods in an online purchase, it is essential that the website’s product

database be able to differentiate eligible and ineligible products

automatically. The response to the RFV must describe how SNAP-

eligibility of products will be determined, and whether this capability

already exists or requires further development.

2.4.2.4 Ability to Accept Split Tender

Since many SNAP customers will need to use a separate payment

method for part of the transaction (e.g., for ineligible items or fees),

most sites will need to accommodate split tender. It is also essential

that SNAP customers be allowed to choose the amount of SNAP

benefits that they will use for each purchase, and pay for some or all

For more information about determining SNAP-eligible foods go to:

SNAP Eligible Food Items

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 40

SNAP-eligible products with a different method. Acceptable forms of

payment could include the cash EBT account, commercial debit/credit,

gift cards, or other forms of payment accepted by the website. Other

options acceptable to FNS would be:

1. Requiring that each order be limited to a single tender type

2. Waiving all fees for SNAP customers (but see Section 2.4.4,

Equal Treatment)

3. Allowing the customer to pay cash for necessary fees at the time

of delivery or pickup

Applicants must address the various methods that they will consider for

payment of ineligible items and fees.

2.4.2.5 Selection of EBT Payment Method

Most in-lane POS terminals have the following payment options from

which the customer chooses before or after swiping the card: Credit,

Debit, and EBT. In many cases, customers select “EBT” to use their

SNAP benefits and “Debit” or “Credit” to use their cash EBT accounts.

In other stores the customer selects “EBT" for both and the POS then

prompts them to choose “SNAP" or “Cash”. Either method is

acceptable, or alternatively the website could list both SNAP EBT and

Cash EBT as initial options. The retailer may also opt to display the

Quest logo as a visual identifier.

The screen for card number entry must be able to accept between 16

and 19 digits. This varies by State and the merchant may want to

validate the correct length after entry.

For a list of BIN numbers and card number lengths for each State, see

Appendix A - State Specific Information.

The Quest Logo seen below is recognized by most EBT customers as the

universal indicator of EBT acceptance, similar to a Discover, MasterCard or

VISA logo.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 41

In addition, please note that EBT cards do not have expiration dates

CVVs, so most SNAP customers will be confused about how to respond

if prompted for these values. Therefore, FNS recommends that the

card number entry screen of EBT cards not request these values.

Since expiration date is a required data element for track 2 of the

magnetic stripe, most EBT cards use a default value of 4912

(December 2049). It is recommended that the website automatically

pass this default value on in the transaction message forwarded to

Acculynk for all EBT cards.

2.4.2.6 Customer Fees

The Farm Bill requires the Internet Retailer to ensure that SNAP

benefits are not used to pay for delivery/pickup/shipping, ordering,

convenience, handling or other fees or charges. It also requires clear

notification to participating SNAP households at the time a food order is

placed of any delivery, ordering, convenience, or other fee or charge

associated with the food purchase and that any such fee cannot be paid

with SNAP benefits. If the retailer charges such fees, this notice must

display as soon as the customer selects SNAP EBT as the payment

method. The customer must also be given the opportunity to terminate

the purchase or select a different form of tender before the sale is

finalized.

SNAP benefits also may not be used to cover any manufacturer or

retailer-imposed food/beverage container deposit (they may only be

used for the reimbursable amount and container product types specified

by State law – see Section 2.2.1 for allowable States). Nor can SNAP

be used for fees for bags, or other delivery/pickup/shipping containers

(regardless of State or local law).

2.4.2.7 Calculation of SNAP Payment

If SNAP EBT is selected for payment type, the site must limit the total

transaction to the subtotal of all SNAP-eligible items. The value

requested for authorization may not exceed that subtotal. However, the

SNAP customer must be given the chance to enter a lower value if they

wish, since the funds remaining in the SNAP account may not be

Florida recently changed their card to include a true expiration date; however, they are not one of the

States currently available for the Online Purchasing Pilot.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 42

sufficient to cover the full amount calculated or the customer may wish

to budget funds so that SNAP is not used too quickly.

This may be accomplished by allowing the customer to enter a specific

lower value, or they can be prompted to delete or move one or more

line items from their SNAP total, thereby reducing the total to the

desired level. The retailer applicant may also propose an alternative to

these solutions. See the last two paragraphs of Section 2.4.4.1, Sales

Taxes for further information on how the sales tax calculation process

may affect this decision.

2.4.2.8 Authorization of SNAP Purchase Transaction

When the SNAP amount has been determined and the website is ready

to request authorization for the purchase, the transaction must be

passed to Acculynk for PIN-entry using their message specifications.

The approval or denial response will come back to the website from

Acculynk. If approved, the website would automatically require the

customer to designate another payment method for the balance of the

total sale including fees, if applicable.

If the customer is unable to find a payment method with sufficient funds

to cover the balance, and the website needs to cancel the original

SNAP transaction, it would submit a forced reversal of the SNAP

transaction through Acculynk.

2.4.2.9 Calculation and Authorization of Cash EBT

Cash EBT transactions are not restricted. Cash benefits linked to the

EBT card may be used for fees and virtually any SNAP-eligible or

SNAP-ineligible product available on the website. These must also be

passed to Acculynk for PIN-entry using their message specification.

The response and reversal procedures are similar to SNAP.

2.4.2.10 Denial Responses

If the transaction is denied, Acculynk will provide a reason code. The

website must immediately provide the EBT customer with an onscreen

explanation of the denial reason in order to enable correction. If the

denial is based on insufficient funds, the retailer must also display the

remaining SNAP and cash EBT account balances that Acculynk returns

with the denial message.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 43

In the brick and mortar environment, many electronic cash register

systems then automatically display the appropriate remaining balance

on the POS terminal and ask the customer if they wish to do a new

transaction for that amount instead. The new submission requires

reentry of the PIN but usually does not require a new card swipe.

Applicant retailers may wish to mirror this process or offer the customer

the opportunity to delete one or more line items from their order or

“move” them to the subtotal for a different payment type.

2.4.3 Customer Receipt and Notification

Federal regulations prohibit the onscreen display of balance information

except for balance-only inquiry terminals. They also require a printed paper

receipt to be provided at the time of the SNAP transaction. At a minimum this

information must include the date, merchant's name and location, transaction

type (e.g., purchase or refund), transaction amount, and remaining balance for

the SNAP account. It must also identify the SNAP customer's account number

(the PAN) using only a truncated number (last four digits) or a coded

transaction number. According to regulation, the household's name shall not

appear on the receipt except when a signature is required on a manual

transaction voucher. States also require that the remaining balance of the

cash account be printed on all receipts.

The retailer’s and customer’s information needs are very different for online

transactions than they are for in-store shopping. Receipts are generally

displayed on the screen or sent in an email or text message, which the site

cannot force the customer to print. These are not as easily lost as paper

receipts, so the danger of including the cardholder’s name is outweighed by

necessity. The delivery/pickup/shipping address and time are also critical.

Also, in lieu of, or in addition to, the website’s physical location, the notice

needs to display other website contact information such as a telephone

number and/or email address. Finally, we understand that companies that

make home deliveries may also need to obtain confirmation of receipt by

obtaining a signature.

Therefore, FNS will provide a waiver to all pilot participants, allowing screen

display of balance information, electronic receipts in place of paper, inclusion

of the customer name and, if necessary, collection of a delivery confirmation

signature. Websites must display, at a minimum, the following information on

the screen after each online transaction is approved:

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 44

• Company Name

• Contact Information (physical address optional if not currently provided

for other customers)

• Date of transaction

• Time of transaction if included for other customers

• Transaction Type

• Truncated Account Number

• Transaction Amount

• Remaining SNAP Balance

• Remaining Cash Balance

• For purchases only:

o Delivery/pickup/shipping address

o Actual or estimated delivery/pickup/shipping date

o Actual or estimated delivery/pickup time if appropriate

o Itemized fees for delivery/pickup/shipping, ordering, convenience,

handling or other fees or charges

o Itemized fees for bags or other delivery/pickup/shipping containers

Furthermore, for all purchase and refund approvals, whether conducted online

or offline, the customer must be issued an electronic notification (e.g., email)

including all of the above information within 24 hours of transaction completion

or the system must securely retain the customer’s order history online so that

they (and no one else) can easily retrieve the above information. In lieu of an

electronic receipt for refunds provided at the completion of order fulfillment

(e.g., for weight overestimates or out of stock items), the retailer may provide a

paper receipt for the refund along with the order. This may be combined with

the final itemized order listing or on a separate paper receipt. This waiver and

all of its related conditions are discussed more thoroughly in Section 2.5.3,

Waivers and Conditions, Printed Receipt.

2.4.4 Equal Treatment

Federal regulations at 274.7(f) and 278.2(b) stipulate that SNAP benefits shall

be accepted for eligible foods at the same prices and on the same terms and

conditions applicable to cash purchases of the same foods at the same store,

except that tax shall not be charged on eligible foods purchased with SNAP

benefits. In addition, retailers shall not establish special checkout lanes which

are only for SNAP households.

This means that SNAP customers must be treated according to the same

policies established for all other customers, especially in the area of privacy,

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 45

use of customer data, item returns and refunds, non-delivery, remedies for

spoilage and other customer complaints. However, FNS is very interested in

these policies and the level of service provided to all customers. Therefore, all

applicants must provide copies of or links to these policies. FNS will consider

this information when evaluating and selecting the pilot participants.

SNAP customers are subject to all of the same fees as other customers; they

just cannot use their SNAP benefits to pay these fees. Not only must SNAP

clients be given no less than the rights and levels of service given to other

customers, they may not be given any special privileges or offers that are not

available to other customers.

The only exceptions to the equal treatment rule are described below. If the

applicant proposes any other differences in treatment between SNAP

customers and those using other forms of payment, FNS will require an equal

treatment waiver as described in Section 2.5.7, Waivers and Conditions, Equal

Treatment.

2.4.4.1 Sales Taxes

State sales tax is specifically exempted by law for all products

purchased with SNAP benefits. In general, Internet sites are governed

by the laws in which the corporate office is located and by those in

which any of their retail stores or distribution warehouses are located.

They usually are only required to collect sales taxes for products

purchased by residents of those governing States or for products

delivered to addresses in those States.

It will be necessary for each website to review their own sales tax

liabilities and make appropriate programming changes to the tax

calculation processes on their website.

Many States have no sales tax on any food items. Some charge sales

tax only for certain types of goods such as soft drinks and snack foods.

Others charge sales tax on all food products. If the selected participant

is required to charge sales tax on any SNAP-eligible items, the system

must be reprogrammed to exclude sales tax for all foods purchased

with SNAP benefits. Any part of the sale paid by another tender,

including cash EBT, is subject to sales tax in accordance with

applicable State law. This is true even if some those items are SNAP-

eligible.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 46

For instance, if all food is taxable, and the cart contains $100 worth of

SNAP-eligible food, but the customer only has $60 left in their SNAP

account, the $60 portion covered by SNAP is not taxable, but the $40

portion covered by cash EBT or a commercial debit card is taxable.

If this occurred in a State where only some food is taxable, then the

taxable items would be the first ones covered by the SNAP benefit.

Only if the total of all taxable food exceeds the SNAP payment should

tax be charged. In the above example, if $20 of the SNAP-eligible

items were taxable, those items would be covered by the $60 SNAP

payment and no tax would be charged for food. However, if $70 of the

SNAP-eligible items were taxable, tax would be chargeable for the $10

that exceeded the SNAP payment.

New Jersey is an exception to the above generalities. According to

their tax regulations, if a customer uses SNAP to purchase any items in

the basket, then all SNAP-eligible items are non-taxable.

If a site is responsible for collecting sales tax from multiple States, the

programming process for calculating the tax amount for each State

must be examined to ensure that it is modified in accordance with the

above requirements.

Retail chains that are already authorized to accept SNAP at brick and

mortar locations may wish to consider porting the code that calculates

sales tax from their electronic cash register systems to their website.

Many websites that are required to charge sales tax in multiple States

or in States where county or local government also charge taxes at

various rates, opt to use a tax calculation service provider such as ADP,

Inc.’s Taxware. These services usually do the calculation by comparing

each line item in the basket to the tax requirements for the designated

location, and they cannot calculate tax for a partial item if the customer

does not have sufficient SNAP funds to cover the entire item and

wishes to split the cost between SNAP and another tender. This will

have an impact on how the applicant addresses the requirements of

Section 2.4.2.7, Calculation of SNAP Payment.

Websites that use a tax calculation service may opt to reprogram their

site to exclude non-taxable SNAP-eligible items, as described above,

from the list of items sent to the calculation service for processing.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 47

2.4.4.2 Manufacturer’s Coupons

Websites that accept manufacturer’s coupons may need to pay special

attention to how sales tax is charged for items purchased with such

coupons. Because the EBT system is capable of applying credit to a

recipients account, all transactions involving cents-off or cash-back

must be credited to the SNAP EBT account or netted out of the sale

before debiting the SNAP account.

When a manufacturer’s coupon is used, sales tax, if applicable, usually

applies to the coupon amount and must be paid by the customer,

including SNAP customers. This may appear to be punitive to a SNAP

customer as sales tax is waived on eligible food items purchased with

SNAP benefits. However, cents-off coupons are a form of payment

separate from SNAP benefits and are governed by State law (i.e. these

are not under the purview of FNS).

Using manufacturers’ coupons is completely voluntary and families that

choose to use them are able to stretch their SNAP benefits

considerably. For example, if a SNAP recipient redeems a dollar-off

coupon and pays five cents in sales tax the recipient ultimately has an

extra dollar in SNAP benefits to use to purchase additional eligible food

items.

Crediting the SNAP benefit account also improves Program integrity by

eliminating a potential avenue for fraud, and eliminates the perception

that recipients can exchange or get cash in return for SNAP benefits.

2.4.4.3 Website Design

Although Internet Retailers may not charge EBT customers different

prices for products, they may identify SNAP-eligible items as such on

the website, and may create pages that list only SNAP-eligible items for

customer convenience.

2.4.5 Nonprofit Cooperatives and CSAs

Most nonprofit food buying cooperatives (co-ops) depend on the services of

members or volunteers to collect orders and distribute the purchased foods to

customers at reduced prices. Because of the financial savings that can be

gained by SNAP clients through this purchasing model, nonprofit co-ops are

allowed by law to collect funds for payment in advance. Co-ops must make

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 48

the food available within 14 days from the date they receive the SNAP

benefits.

In addition, the 2014 Farm Bill added CSA as a business model authorized to

accept advance payment and FNS has established a 14 day time limit for them

as well.

FNS will not extend this time limit for online sales made through any co-op or

CSA websites. As a result, there are special website design requirements for

these business models.

Retailers that distribute orders at multiple pickup sites must have a system

table containing the address of each site, as described in Section 2.4.2.1.2. In

addition, the website must be set up so that SNAP clients are not allowed to

pay more than 14 days in advance of the scheduled delivery for the specified

distribution location. Thus, if a customer attempts to use SNAP benefits for a

purchase prior to that timeframe, the system must advise the customer that it

is too early to accept payment, and identify the earliest date that they can use

SNAP benefits for the purchase

If the co-op/CSA has a single delivery date for every distribution site, this can

be greatly simplified by blocking all SNAP transactions attempted more than

14 days prior to delivery. In this case, the site can contain a general

announcement of the next date when SNAP purchases will be accepted.

However, if there are different dates for different sites, FNS recommends that

this information also be incorporated into the system table so that the specific

date for that location can be calculated and displayed.

If desired, the website may allow the SNAP customer to select the items they

wish to purchase in advance and store them until they are allowed to return

and complete the sale.

2.4.6 Security and Privacy

It is imperative to ensure that every Internet Retailer that FNS authorizes to

redeem SNAP benefits is secure, has adequate measures to prevent fraud, is

compliant with credit/debit card industry security standards and protects their

customers’ privacy.

2.4.6.1 PCI Certification

Our preeminent requirement is that the Internet Retailer’s website be

compliant with the PCI Data Security Standard. Before a merchant can

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 49

be authorized to accept MasterCard or VISA, they must be certified as

PCI-compliant by their acquiring institution. This certification is

performed annually and covers a wide spectrum of security and privacy

issues. FNS requires that every website authorized for SNAP be PCI-

certified and maintain that certification for the life of the pilot. To be

approved for this pilot, applicants must currently accept, at a minimum,

Discover, MasterCard, and/or VISA. Acculynk will verify that the

certification is valid and up to date.

PCI addresses the secure encryption and handling of sensitive data,

such as card numbers and PINs while “at rest”, i.e., being temporarily or

permanently stored. Compliance is not determined based on specific

mandatory requirements. The actual methods and protocols employed

by any given organization to achieve compliance will vary and must be

continually upgraded and improved. However, there are many

recognized industry “best practices”, which used in combination

safeguard sensitive data and customer privacy.

Applicants must identify the best practices that they currently employ to

achieve PCI compliance. These may include:

• Tokenization

• Device fingerprinting – comparison of current hardware/software

characteristics to user’s previous usage such as physical device,

browser version, IP address, app vs. browser, etc.

• Use of secure sockets layer (SSL) technology or other strong

firewall configuration

• Minimum browser standards – version, 128-bit encryption, etc.

• Required use of logon IDs and passwords for internal and

external access to website

• Strong policies for ID/password format/content and handling of

forgotten IDs/passwords

• Established user roles restricting update/view of PII and card

data based on business need to know

• Use of sitekeys or other customer/site authentication

• Use of commercial security/encryption products for both data in

transit and at rest

• Trust seal certification

• Stringent information security policies for all company and

contractor personnel

• Regular use and update of anti-virus software or programs

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 50

• Restricted physical access to personal data stored on the system

2.4.6.2 Use of Cookies

Some websites use “cookies” to store data related to access and use of

the site on the customer’s personal computer, smartphone or tablet.

FNS is very concerned about the use of cookies by FNS-authorized

Internet Retailers. Many SNAP customers rely on public computers at

places like libraries or schools for Internet access. To ensure optimum

security for online EBT transactions, FNS would prefer that cookies not

be used at all. However, it they are required for your system, it is

essential that no PII data be recorded by the retailer on any user access

devices.

Applicants must identify whether they use cookies, and if so, whether

they:

• Retain PII data

• Can be easily deleted or avoided

2.4.6.3 Security Practices and Policies

FNS will require a copy of or link to the website’s security practices and

policies. We expect that this would explain to the customer, in easily

understood language, the precautions that the website has taken to

secure customer data and the site’s liability should there be a breach

that results in customer loss. It may also provide best practices and tips

for the customer to follow in such areas as password selection and

phishing.

FNS further expects all pilot participants to accept responsibility for any

monetary loss or other damage to EBT customers that results from

employee or subcontractor fraud, or external hacking resulting from

failure to adequately secure the website and databases under the

control of the retailer or any subcontractor. FNS requires applicants to

agree that, if selected, they will replace all SNAP benefits that are

stolen as a result of such breaches.

As noted in Section 2.4.4, Equal Treatment, SNAP customers must be

treated the same as those using other forms of payment. However,

FNS has discretion in selection of participating retailers for a pilot

project and wishes to ensure that we select sites that have published

policies that are relatively easy for customers to find and afford a

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 51

reasonable level of protection against a breach and, should one occur,

its aftermath. Therefore, a website that has no published security

policies available to customers or has what we consider inadequate

policies in relation to other applicants will not be selected.

2.4.6.4 Privacy Practices and Policies

It is common practice among many businesses and non-profit

organizations to sell or share subscription and other data to outside

parties. Web sites collect a substantial amount of data about

demographics and purchasing behavior. Due to legislative privacy

requirements it is necessary for FNS to ensure that personal

information such as name, address, or email address collected by

SNAP Internet Retailers is not compromised, sold, rented, or given

away free to any third party without authorization. Websites that do

share data at the individual level (e.g., with a supplier so they can send

discount offers directly to a SNAP client’s email address) must obtain

explicit consent from EBT customers to release such information. In

other words the EBT customer must “opt in” to allow such sharing and

not have to “opt out” to prevent the sharing.

The only valid exceptions are for services directly related to the sale,

such as third parties performing functions like delivering or shipping the

groceries, processing EBT card payments, analyzing aggregate data,

and providing customer service. These agents may not use the PII data

for other purposes.

Sensitive data such as credit card information may never be sold,

rented or given away free to third parties under any circumstances. All

applicants must agree in writing, that the website will not share any

private data with third parties for any current or future application or

venture without the explicit consent of the EBT customer.

Internal use of personal information for marketing purposes does not

require explicit customer approval, but the customer must have the

opportunity to unsubscribe or opt out of receipt of such materials in the

future.

FNS expects that each applicant website will have published privacy

policies with a clearly identified, easy to find link from the home page.

This must meet the above requirements and describe any exceptions

for data use or sharing (which might include such reasons as fraud

protection and credit risk reduction, purchase of the company and its

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 52

assets, or compliance with law, e.g., by subpoena). The policy should

describe exactly how the website itself will or will not use information

about individual customers, and with whom the data is and is not

shared. Applicants must provide a copy of or link to the website’s

privacy practices and policies for FNS review.

The content and clarity of current policies will be considered during the

participant selection process. If the applicant is accepted as a

participant, FNS may require revisions of the policy to conform to these

requirements.

2.5 Waivers and Conditions

This section describes all of the waivers that will be given to Internet Retailers to

facilitate their ability to participate in the Program. These waivers will remain in effect

for the duration of the retailer’s participation in the pilot.

Each waiver details what must be done in place of the regulatory requirement and

comes with a set of conditions that must be met to maintain the waiver. Each

selected pilot participant must agree, in writing, that they will abide by those

requirements and conditions. This is a prerequisite for pilot participation and

authorization as an Internet Retailer. FNS reserves the right make necessary

reasonable modifications to the conditions identified below before finalizing the

written agreement.

Failure to comply with the conditions is grounds to rescind the waiver. If problems

come to the attention of FNS, we will provide written notice and give the participant

ten business days to reestablish compliance. If not corrected within that timeframe,

FNS may rescind the waiver. If that happens, the Internet Retailer is no longer

eligible to accept SNAP EBT and FNS will issue a notice of involuntary withdrawal.

After that, no more SNAP transactions will be accepted from the website. FNS will

provide a consolidated waiver packet to each Internet Retailer selected for this pilot,

addressing the seven waivers listed below. Retailers will be required to attest in

writing to their understanding of the waivers and conditions, as well as all penalties.

2.5.1 PINless Refund

Section 274.8(a)(2) of the regulations requires verification of a PIN for all

transactions except manual vouchers. Because the customer will usually not

be available to enter a PIN when a refund must be processed, it is necessary

for Internet Retailers to perform refunds without PINs. This conforms to

Acculynk’s process for handling refunds.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 53

Every website will receive a waiver from the PIN requirement for refund

transactions.

2.5.1.1 Conditions

• The waiver will require that all PINless refund transactions go

through Acculynk

• The website must maintain a secure, controlled method for a

limited number of employees authorized to enter PINless refunds

• The website may never deduct the cost of shipping from the

refund amount; the full value of the food item returned must be

credited back to the customer’s SNAP account and any shipping

charges must be paid through an alternative payment method

• Refunds for returned items or other customer-initiated events

must be processed within two company business days

• Electronic notice must be provided or online history updated in

conformance with Section 2.4.3, Customer Receipt and

Notification within 24 hours of refund completion

• If FNS receives complaints about refunds taking excessive time,

the website may be put on notice that they must provide periodic

reports about refund timeliness for SNAP customers

• If problems with timely refunds continue the waiver will be

rescinded and pilot participation terminated

2.5.2 PIN-Entry Method

Section 274.8(b) of the regulations requires that PINs be entered only through

ANSI-compliant POS devices. Sections 274.8(b)(3)(ii)(C) and 274.8(b)(6)(iii)

provide that PINs must be encrypted, at a minimum, from the point of entry.

Personal computers, smartphones and tablets commonly used for online

access do not meet the ANSI requirements for PIN-entry devices or allow

encryption from the point of entry. Acculynk’s PaySecure™ is the only FNS-

approved PIN-entry product for the Online Purchasing Pilot.

However, it does not strictly comply with regulations because it uses a special

process to collect the PIN from a secure overlay screen. Therefore, every

website selected for the pilot will receive a waiver from these sections of the

regulations.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 54

2.5.2.1 Conditions

• The website must contract with Acculynk for secure PIN-entry

services and carry out their responsibilities for that contract

• The waiver will require that all PINned transactions go through

Acculynk’s PaySecure™

• The website must conform to all Acculynk PIN-entry

requirements and standards

• The website must continue to maintain its PCI certification and

accept industry payment cards such as Discover, MasterCard,

and/or VISA

• The site must continue to maintain a secure system that ensures

the security and privacy of EBT customer data

2.5.3 Printed Receipt

Section 274.8(b)(6)(i) of the regulations prohibits the onscreen display of

SNAP account balance information. Section 274.8(b)(7) requires that

households must be provided printed receipts at the time of transaction, with

date, merchant's name and location, truncated card number, transaction type,

transaction amount and remaining balance for the SNAP account. The

household's name shall not appear on the receipt and no signature may be

required except for manual vouchers.

Internet sales do not generate printed receipts. Sites can, however, provide

the following after the authorization is complete:

• A confirmation invoice screen showing company name, order number,

transaction date, delivery/pickup/shipping address, actual or estimated

delivery date/time, data on individual items purchased, subtotal, tax,

shipping/delivery fee amount, final total, payment method and last 4

digits of the card number used. They do not normally display the

website’s physical location. Instead they provide a phone number

and/or email address for customer questions. Also, customer name is

usually displayed as part of the billing or shipping address.

• A subsequent email to the customer containing all of the information

above. Some sites provide follow-up emails when the order is shipped

or available for delivery. An email address is required for almost all

Internet commerce.

• A printed invoice, included with the order, which details the actual

items, unit pricing, subtotal, tax, shipping/delivery fee amount, and final

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 55

total. Some home delivery and pickup sites require the customer to

sign for delivery confirmation.

There is no set pattern on how refunds are documented in the online

environment, but web retailers have the capability to provide the customer with

an email or text message containing information similar to that listed in the

above bullets. Some sites provide secure online order history in addition to, or

in place of, electronic messages.

Every website will receive a waiver from the requirements to provide printed

receipts and display the store location (if not displayed for other payment type

customers). The waiver will also allow the website to display account

balances and the customer name, both onscreen and in electronic receipts,

and to collect a signature to confirm delivery or customer pickup.

2.5.3.1 Conditions

The waiver will require that:

• For all denials, the website must provide an immediate screen

display describing the reason the transaction was denied (e.g.,

invalid card number, invalid PIN, insufficient funds, etc.), and the

customer shall be offered the opportunity to perform the

transaction again, select a different payment method, or opt out

of the sale

• In instances where the denial is for insufficient funds, the website

must also display the remaining balances for SNAP and cash.

The site may opt to:

o Use the remaining balance data that comes back in the

denial message to pre-fill the amount entered for the new

transaction attempt, as long as the customer is allowed to

enter a lower value

o Require the customer to delete individual SNAP basket

line items or move them to a non-SNAP basket for

payment with another tender, until a subtotal less than or

equal to the remaining SNAP balance is achieved

• For all approved purchases, the site must provide both an

immediate confirmation screen that the client can print or save if

desired, and within 24 hours a subsequent email or text

acknowledgement. Both must include, at a minimum, transaction

date and time, merchant name, merchant phone number or other

appropriate contact information, delivery/pickup/shipping

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 56

address, actual or estimated delivery/pickup/shipping date (and

time if known), transaction Program (SNAP or cash EBT), total

amount debited from SNAP and/or cash EBT account for the

purchase, remaining balances for SNAP and cash EBT, and the

truncated PAN. The site may also include the customer and/or

delivery/shipping address names.

• In lieu of, or in addition to, a subsequent email or text message

for purchases, the retailer may maintain a secure online

customer order history that they (and no one else) can easily

retrieve.

• All refunds require issuance of an email or text message to the

customer within 24 hours, containing, at a minimum, transaction

date and time, merchant name, merchant phone number or other

appropriate contact information, transaction Program (SNAP or

cash EBT), total amount credited to the SNAP and/or cash

account for the refund, remaining balances for SNAP and cash,

and the truncated PAN.

• In lieu of an electronic receipt for refunds provided at the

completion of order fulfillment (e.g., for weight overestimates or

out of stock items), the retailer may provide a paper refund

receipt containing the above information with the order. This

may be combined with the final itemized order listing or on a

separate paper receipt.

• If site policy calls for return shipping, or original shipping costs if

they were waived, to be debited from a refund amount, it may not

be debited from SNAP benefits. The full value of any returned

item purchased with SNAP must be refunded back to the

customer’s SNAP account. Sites must cover return shipment

costs themselves, or ask the customer to pay those costs with an

alternate form of tender. On the other hand, purchases made

from the cash EBT account may have shipping or other

processing fees deducted, if such fees are assessed to

customers using other payment methods.

• The merchant address fields included in the transaction message

submitted to Acculynk must be coded in the same manner as

credit/commercial debit transactions (usually done by including a

customer service number in the “city” field), so that this

information can be appropriately displayed by the EBT system

for customer use. FNS also requires a ZIP code as part of the

merchant address.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 57

2.5.4 Product Display

Section 278.1(b)(1)(i) of the regulations describes the depth of stock

requirements that retailers must meet to be eligible to accept SNAP

redemptions. These are addressed more fully above in 2.3.1.2, SNAP Retailer

Eligibility. FNS will not waive these basic requirements for Internet Retailers.

However, there is one clause at 278.1(b)(1)(i) (A) that requires the food

products which substantiate eligibility to be offered for sale and normally

displayed in a public area on a continuous basis. The intent is that ample

numbers of physical, qualifying items be stocked on the store’s shelves at all

times. Display of the actual physical items is not possible in the virtual

environment of online commerce.

Therefore, every website will receive a waiver from the requirements to have

physical products on display.

2.5.4.1 Conditions

• The website must still meet the basic Criterion A or B

requirements addressed in Section 2.3.1.2

• The food products that substantiate eligibility must be displayed

on the website in sufficient numbers and available stock keeping

levels to meet the ample quantity, variety and perishable

requirements on a continuous basis

• The retailer’s distribution facility (e.g., warehouse or brick and

mortar store where the order is filled) must also meet the ample

quantity, variety, and perishable requirements on a continuous

basis

2.5.5 Prepayment

Section 278.2(e) of the regulations currently stipulates that food retailers may

not accept SNAP benefits before delivering the food. The only exception is for

nonprofit food buying cooperatives, which may accept benefits up to 14 days

prior to food delivery.

However, the 2014 Farm Bill authorizes CSAs to be treated in the same

manner as nonprofit co-ops. It also allows Internet Retailers to accept SNAP

benefits prior to the delivery of food and gives FNS the authority to establish a

reasonable timeframe for advance payment. After consulting with industry

experts, FNS has determined that for this pilot project a reasonable timeframe

is seven calendar days. Therefore, except as noted below, all online orders

must be in the customer’s hands within that timeframe.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 58

• For websites that allow the customer to select their desired date and time

for delivery or pickup, EBT customers may be allowed select a date that

goes beyond seven days (see Section 2.4.2.1.1, Customer Selected

Options)

• Non-profit food buying cooperatives and CSAs are already allowed to

accept payment up to 14 days in advance (see Section 2.4.5, Nonprofit

Cooperatives and CSAs for additional information; their customers may not

select a date that goes beyond 14 days.

2.5.5.1 Conditions

• Prior to submitting the transaction for authorization, the site must

clearly explain the seven-day policy

• If the merchant allows EBT customers to designate the date and

time for local delivery/pickup, those customers will be allowed to

select a date, for their own convenience, that is more than seven

days after payment

• Websites that do not allow the customer to select their own

delivery/pickup time must provide the estimated receipt date, and

allow the client to opt out before the sale is finalized

• The retailer must prohibit the use of EBT cards for standing

orders

• If the retailer allows split orders, all portions of the order must be

received by the customer within the mandatory timeframe

• The retailer must prohibit the use of multiple delivery addresses

for a single EBT transaction

• If by the fifth day after the transaction it is clear that the seven-

day limit will be exceeded, the site must notify the client by email

or phone of the expected new receipt date and offer the

opportunity for an immediate, full refund instead

• Refunds that result from overestimated weighed products,

substitutions, or out of stock items must be made to the client

immediately after fulfillment of the order

• The site must maintain statistics that document how long it

normally takes between the time that the sale is finalized and the

time that the customer receives the food order

• If FNS receives frequent complaints about late deliveries the

website may be put on notice that they must provide periodic

reports about delivery timeliness for SNAP customers

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 59

• If problems with timely delivery continue the waiver will be

rescinded and pilot participation terminated

2.5.6 Card Must Be Present

Policy Memo BRD/EBT 2001-1 requires that the EBT card must always be

present when a customer performs a transaction, be it swiped, key-entered, or

by manual voucher. In the online environment, the customer key-enters the

card number each time, or selects a card number that was key-entered at

some previous time and then stored securely online. Because EBT cards do

not contain a CVV, it is not possible for the website to determine if customers

have the card in hand at the point in time that they enter the card number.

Therefore, FNS will provide every Internet Retailer selected for the pilot project

with a waiver from the “card must be present” requirement.

2.5.6.1 Conditions

• Transaction messages must always be coded as “card not

present” for Internet transactions

• The participant must notify FNS whenever significant changes

are made to the site’s policies and practices regarding refunds,

customer complaints, privacy and security, and provide a copy of

or link to the revised information

2.5.7 Equal Treatment

Federal regulations at 274.7(f) and 278.2(b) require equal treatment for SNAP

clients. They may be treated no worse and no better than any other

customers (see Section 2.4.4, Equal Treatment for more information). The

above requirements, waivers and conditions address most foreseen

differences. The retailer may propose some additional limited preferential

treatment for SNAP customers. These will require additional waivers. FNS

will tailor these to the circumstances and may attach conditions for approval.

Examples of such preferential treatment include:

• Waiving or reducing fees only for SNAP customers

• Allowing SNAP customers to pay cash on delivery for fees

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 60

Chapter 3 – Pilot Application, Selection and

Evaluation

3.1 Issuing Agency

This RFV is being issued by the USDA Food and Nutrition Service.

3.2 Overview

Awardees for this solicitation will receive no Federal or State funds. As a result, this

RFV and the responding retailer applications are not subject to normal contracting or

grant award requirements. FNS SNAP staff will coordinate the evaluation of

applications and will be responsible for the selection of the retailer websites for this pilot.

3.3 Announcement

This RFV has been shared with national and State-level food retailer and Internet

merchant associations in order to reach the appropriate audience. It has also been

shared directly with organizations that have previously expressed interest to FNS in

SNAP online purchasing.

3.4 Points of Contact

All questions and comments about this solicitation must be directed to the individuals

listed below. Other contacts within FNS are not authorized to respond to questions.

This is so that all parties will receive consistent answers and instructions.

A copy of this RFV may be downloaded from the FNS public website at:

Online Purchasing Pilot Request for Volunteers

All questions about this RFV should be directed to:

Patrick Kelley

Retailer Policy and Management Division

Supplemental Nutrition Assistance Program

USDA Food and Nutrition Service

3101 Park Center Drive, 4

Floor

Alexandria, VA 22302

Patrick.Kelley@fns.usda.gov

(703) 756-0230

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 61

3.5 RFV Timetable

The following are significant dates for this solicitation:

Table 3-1 – RFV and Pilot Timeline

Date

Event

September 15, 2016

Release of RFV

October 7, 2016

Letter of Intent (LOI) and Written

Questions Due to FNS

Mid-October, 2016

Conference call/Webinar with all Retailer

Website Owners Submitting LOI

October 21, 2016

Posting of Q&As

November 7, 2016

Applications Due to FNS

December 31, 2016

Selected Retailer Websites Announced

January 1, 2017 – July 15, 2017

Contracting with Acculynk, Development

and Testing

August 15, 2017 – August 31, 2019

Initial Pilots and Subsequent Rollouts

July 1, 2018

Report to Secretary of USDA

October 1, 2018

Decision on Future of Online Purchasing

3.6 Letter of Intent

Retail grocery website owners interested in submitting an application to participate in

the SNAP EBT Online Purchasing Pilot are asked to submit a Letter of Intent (LOI) with

contact information. FNS also seeks advance information on the State(s) where

retailers would like to conduct their pilots. This response should be made to FNS by

5:00 pm Eastern Daylight Savings Time (EDT) on the LOI Due Date listed in the above

RFV Timetable. Submitting an LOI does not obligate a website owner in any way, but

will provide useful information to FNS to prepare for the review and selection process.

In turn, FNS will invite all LOI respondents to participate in a conference call roundtable

discussion with Acculynk and FNS to review obligations and expectations of the RFV as

an aid in developing application responses. All respondents will also be on the list to

receive a link to any Q&As developed. Non-retailers interested in the RFV process may

All questions about the Acculynk PaySecure™ service should be directed to:

Collin Flotta

Acculynk

3225 Cumberland Boulevard, Suite 550

Atlanta, GA 30339

cflotta@acculynk.com

(678) 894-7028

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 62

also submit contact information, as requested in the LOI, to be included in conference

calls and Q&A distribution.

The LOI must be emailed. FNS thanks website owners in advance for their cooperation

with this request. The LOI should be submitted to the email address of the FNS contact

listed in Section 3.4, Point of Contact.

3.7 Questions

Applicant websites should submit any RFV clarification questions by email to the FNS

contact listed in Section 3.4, Point of Contact. These questions will be compiled with

their responses and posted on the FNS website. Questions will not be identified by

individual or website affiliation. Answers to clarification questions received in time will

be reviewed during the conference call/webinar scheduled with FNS and Acculynk

(Section 3.5, RFV Timetable). FNS will provide interested parties with a link to Q&As

whenever they are posted or updated.

3.8 State and Community Partners

It is essential for FNS to obtain early concurrence from State agency partners. FNS will

advise States of the interest evidenced by potential applicants in their Letters of Intent,

and work to encourage State involvement and buy-in. However, many of them have

very legitimate concerns about their State’s participation in the Online Purchasing Pilot.

Several are in the process of converting to new EBT vendors or have other major

systems projects under development that require their complete attention. Others have

had significant staff turnover and do not believe they have the manpower or expertise to

support a pilot.

However, we hope that a show of retailer interest in online purchasing and the potential

broad benefit to clients in their State will have a positive impact. Should the State(s)

listed in your Letter of Intent agree to further discussion, FNS will share relevant contact

information for the State’s EBT Manager. If none of the listed States agree to

participate we will advise the affected retailer in order to allow identification of other

potential pilot locations.

While not a requirement of the RFV, FNS believes that the success of the Online

Purchasing Pilot with will be greatly enhanced by the involvement of non-profits, health

organizations, local government and other community partners who have an interest in

expanding shopping opportunities for SNAP households. Advocates for the elderly and

disabled, as well as those promoting healthier food options for inner city and rural

clients without easy access to supermarkets would support the availability of online

Please see Appendix B – Letter of Intent for the required content of the LOI.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 63

SNAP retailers. Most would also be willing to assist in marketing and training activities

shortly before and during pilot operations.

FNS encourages applicants to seek out such community partners and will give greater

consideration during the selection process to those that do so. If you obtain such

commitment, please include a statement of support from each partner. A content

description for this statement of support is included in Appendix C.

3.9 Proposals

Applicants must carefully follow the instructions provided below. Applications which do

not meet the requirements will not be reviewed or considered.

3.9.1 Submission

All applications must be sent to the FNS contact listed in Section 3.4, Point of

Contact, and must be received by 5:00 pm EDT of the Application Due Date,

listed in Section 3.5, RFV Timetable. All applications must be submitted

electronically by email and contain all of the documents described below. Late

and/or incomplete applications will not be considered in this pilot. If the website

owner’s email software does not allow ZIP file attachments as described in

Section 3.9.3, Proposal Format then the applicant should make alternate

arrangements with the FNS Point of Contact to submit the electronic portion of

the application by mail or hand delivery by the date and time specified above.

Applicants should retain a copy of the proposal and all of its attachments for their

own records. They should also retain the original signature pages for the RFV

application and the retailer application. If you are selected for participation in the

Online Purchasing Pilot, FNS will need the original signatures.

3.9.2 Content

To be considered complete the application must include the following documents:

3.9.2.1 RFV Participation Application Form

FNS has chosen not to require applicants to submit a narrative plan

addressing the large volume of technical issues, operational requirements

and website design variables addressed in Chapter 2 of the RFV. Instead,

we have created a standardized PDF form containing a series of specific

yes/no, multiple-choice and fill in the blank questions arranged in a simple,

straightforward manner. These address the information we need to

understand your business model, website design and ability to make the

necessary changes required to support online payment with EBT benefits.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 64

It also includes a section where applicants must assure their

understanding of legal and project participation responsibilities and agree

to comply with those requirements. Applicants should carefully read each

assurance and respond with “Yes” or “No”. They may also select

“Qualified Yes”, but must explain the issues they have with the

requirement and any conditions they wish to apply to the assurance. Be

advised that a “No” response to any of these assurances may be grounds

for non-selection as a pilot participant. Should a “Qualified Yes”

explanation result in significant deviation from the intent of the assurance,

FNS reserves the right to consider it equivalent to a “No” response.

The form requires the applicant to include electronic versions of the

following supplemental information in the response:

• Samples or screenshots of current customer notifications for

o Proof of purchase

o Refund

• Description of protocols and “best practices” employed by the

website to secure data and protect cardholder information

We believe that this format will benefit both applicants and government, by

reducing time and effort for Internet Retailers to apply, and simplifying

FNS review and selection of pilot participants.

See Appendix D – Request for Volunteers (RFV) Participation Application

Form for a facsimile of the application form, as well as instructions to

download and complete the Adobe pdf form. All volunteers must use this

pdf form to respond to the RFV.

If there is insufficient room to respond to a question so that it displays

completely on the form, or more explanation is needed, applicants may

include a separate document with the application to expand on their

responses. If that is done, the appropriate block of the form should

indicate that the response is continued elsewhere, and the separate

document should identify the related application page and item numbers

for each continuation. These additional explanations should be concise

and to the point.

3.9.2.2 FNS-252 SNAP Application for Stores, FNS-252-C FNS

Corporate Supplemental Application, or Chain

Spreadsheet

More information about these forms can be found in Section 2.3.1.1,

Application for Authorization as a SNAP Retailer. Only websites owned by

and doing business as a supermarket or other large chain that has at least

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 65

ten brick and mortar locations already authorized to accept SNAP, may file

the FNS-252-C form. If the chain has access to their chain spreadsheet,

which was developed by FNS, they may substitute it for the FNS-252-C,

by adding a row at the bottom showing the appropriate information for the

website operation. All other applicants must complete, sign and submit

the regular FNS-252 form.

When completing any of the above retailer application forms, and

identifying the store or site location, please enter the complete address of

the primary inventory location for your website, for example a warehouse,

depot, farm or store. FNS, at its discretion, may opt to schedule an onsite

visit of the location, similar to those done for new brick and mortar

applicants. If you plan to fulfill orders at multiple chain store locations, you

should list your corporate address or the location of your website data

center, instead.

3.9.2.3 Additional Documentation for Retailer Application

Retailer websites that are not eligible to submit form FNS-252-C are

required to provide all three forms of documentation listed in Section

2.3.1.1.2, FNS-252- Supplemental Nutrition Assistance Program

Application for Stores. This type of documentation is required of all SNAP

retailers and there are no exceptions to the requirement. Retailers that

are eligible to submit form FNS-252-C have previously provided this

documentation and FNS already has copies on file for the corporation.

Other SNAP retailers, even those already authorized by FNS, will need to

submit these documents as we require the documentation for our records.

FNS reserves the right to request additional documentation if needed to

authorize your website as an FNS retailer. Such documentation may

include additional business licenses, tax records, purchase and sales

records, counting of stock keeping units, or other inventory or accounting

recordkeeping.

3.9.2.4 Signatures

The RFV Participation Application Form, the FNS-252 and the FNS-252-C

each have a signature page. The appropriate forms must be signed by an

owner or company official who is authorized to make the necessary

assurances and commitments contained in the documents. Scanned

copies of the completed signature pages should be included with the

electronic submission of the proposal. The full application forms should

be submitted in their original Adobe format, not scanned.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 66

3.9.3 Proposal Format

The proposal must consist of a ZIP file named “Online Purchasing RFV

Response from XXXXXXXXX.ZIP”, where “XXXXXXXXX” should be replaced

by the name of the company or the store’s website. Each file within the ZIP file

must also be clearly labeled to include the company or store’s website name in

the file name itself, for example “FNS-252 from XXXXXXXXX.pdf” or “RFV

Participation Application Continuation Sheet from XXXXXXXXX.docx”.

Scanned photo IDs, Social Security Cards and/or signature pages should be in

an easily read format such as .pdf, .jpg or .tif, and also include the name of the

applicant’s website in the file name. Any attachment to the RFV Participation

Application Form and/or statements of support from community partners (see

Section 3.8, State and Community Partners) should be in Microsoft Word or .pdf

format and use the naming conventions described above. The ZIP file should be

submitted as an attachment to the submittal email as described above in

Section

3.9.1, Submission, unless the applicant is unable to attach a ZIP file, in which

case the applicant should follow the alternative instructions provide by the FNS

Point of Contact.

3.9.4 Withdrawal of Proposal

An applicant may withdraw its proposal in writing at any time. This should be

submitted to the email address of the FNS contact listed in Section 3.4, Point of

Contact.

3.10 Participant Selection

Every application must meet minimum requirements to be considered responsive to the

RFV. Those that fail to do so will be designated as non‐responsive and eliminated from

further evaluation and consideration. FNS will review the remaining responses and

evaluate them in accordance with established criteria. As discussed in Section 1.5,

Pilot Description, FNS expects to select three to five retailers for pilot participation.

Should a selected participant fail to contract with Acculynk or be unable to comply with

the operational requirements identified in Section 2.4, FNS reserves the right to select

another participant from the remaining pool of respondents to this RFV.

3.10.1 Baseline Requirements

FNS will prescreen each application to confirm that it includes all of the essential

attachments, including signatures, listed in Section 3.9, Proposals, and that all

questions have been answered in accordance with the application instructions.

Proposals that do not pass this initial screening will be considered non-

responsive.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 67

FNS will then review the responsive applications to ensure that they comply with

the following baseline requirements:

1. The applicant meets all eligibility criteria to become an authorized FNS

retailer and is not classified as a meal service

2. Neither the retail organization nor or its owners have any:

a. previous or suspected SNAP violations

b. State or local licensing violations

c. other Federal or State violations of rule or law

3. The applicant has responded “Yes” (or “Qualified Yes” with an

explanation acceptable to FNS) to every assurance in Section R of the

RFV Participation Application Form

4. The website is PCI certified

5. Either the website never shares PII data outside of the organization or

only does so with the customer’s explicit permission

6. There is no evidence that false information has been deliberately

submitted

Applications that do not meet these baseline requirements will be eliminated from

further review and consideration.

3.10.2 Evaluation Process

The remaining responsive applications will be reviewed by a panel of FNS

program and technical representatives. In order to ensure selection of a variety

of retailer business models, FNS will group applicants into the following

categories:

1. Large national and regional chain stores

2. Internet-only businesses without brick and mortar operations

3. Other business models including:

• Agricultural producers

• Delivery routes

• Non-profit cooperatives

• Smaller local chains

• Independent stores

We plan to select at least one website organization from each category.

However, if FNS determines that it would best serve the purposes of the Program

to select more than one retailer’s website in any category FNS reserves the right

to do so. Or, FNS may determine that there are no suitable candidates at all in a

given category.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 68

3.10.3 Selection Criteria

FNS will evaluate all applications, regardless of grouping, using the following

criteria and corresponding percentage weights. FNS reserves the right to

consider certain other conditions in making its final decision on pilot participants.

For example, it is essential that at least one State in the selected applicant’s

implementation and roll-out plan agrees to participate in the pilot.

3.10.3.1 Privacy and Data Security – 30%

Pilot participants must have adequate methods in place to ensure system

and data security, as well as customer privacy, in order to prevent

compromise of SNAP household privacy, identity theft and other fraud.

Applications will be carefully evaluated for strong data security systems

and policies and the use of industry-recommended practices.

3.10.3.2 System Changes and Rollout Plan – 30%

Responses will be assessed to determine if applicants are able and willing

to make required changes to their website to handle SNAP eligible foods,

sales tax and fees; FNS policies regarding refunds, notification and their

timeliness; and interfaces with Acculynk for PIN entry and transaction

routing. FNS will also review to determine if the system changes and

rollout plan will meet the pilot launch date. Applications that include an

initial pilot or rollout areas that target specific low-income populations, food

deserts or other vulnerable geographic locations will receive greater

consideration.

3.10.3.3 Customer Service – 20%

Applicants with a variety of policies that are favorable to customers,

including SNAP households, will be more positively rated. Such policies

may include, but are not limited to, convenient ordering, shorter delivery

windows, customer-specified delivery day/time, easy access to order

history, waiver of fees, flexibility in returns, no order minimums and timely

attention to customer complaints.

3.10.3.4 Website Business Model – 20%

Applicants with a longer and more established online presence will be

considered more favorably than websites with limited time in business

and/or lower annual transaction and sales totals. In evaluating this area,

FNS will consider fee structure and amounts, variety and pricing of food

product inventory, delivery methods, geographic coverage, how and

where customer orders are filled, the number of warehouses or other

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 69

currently unauthorized inventory points which must be visited and

monitored, the nature and volume of third party sales, and the complexity

of website design.

3.10.4 Selection Announcement

FNS hopes to advise participants of their selection by the date listed in Section

3.5, RFV Timetable. Non-selected applicants will be notified shortly after

confirmation that the participants have signed the necessary waiver agreements,

as described in Section 2.5, Waivers and Conditions.

Highly rated applicants who are not initially selected for the pilot may be invited to

participate at a later point, especially if implementation issues arise with any of

the selected participants. If this happens, it may be necessary for the applicant

to submit an updated copy of the FNS-252 form.

Because there is no monetary award involved in this solicitation, there will be no

formal protest procedures. However, non-selected applicants may request a

conference call with FNS to review the reasons for our decision. Details on how

to request such a conference will be made available at the time the applicant is

notified of non-selection.

3.11 Project Management

In order to ensure that the selected participant’s system correctly incorporates the

necessary EBT changes and completes this work timely FNS will require the participant

to communicate status regularly and provide certain project management materials, as

identified below:

3.11.1 Communication

After selection, FNS will designate a Project Coordinator to be the primary

contact for the participant for the Online Purchasing Pilot. FNS expects to

schedule regular biweekly conference calls to discuss project status, challenges,

progress and results with the following parties, as appropriate:

• Participant website staff

• FNS

• Acculynk

• Applicable EBT processor

• State agency

3.11.2 Project Plan

Within 30 days after selection, FNS expects the participant to submit a written

plan outlining milestones and tasks the participant considers essential to

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 70

development, design and implementation of EBT online purchasing. At a

minimum, the plan should address starting and completion dates for the primary

activities discussed below, and sharing of necessary documentation.

The plan should also provide contact information for the retailer’s own or

contracted staff responsible for primary functions identified below who are critical

to the success of the project. The plan and contact information should be

updated and shared with FNS if any changes occur.

3.11.3 Joint Application Design

It is essential that the participant have a complete understanding of the system

and procedural requirements and identify the modifications that will be required

to implement EBT online purchasing. Appropriate staff from the participant, FNS

and Acculynk will be critical to this process. Ideally these discussions can be

handled through conference calls and/or Webinars, but if the participant believes

that a face to face meeting would be more productive, FNS is willing to travel to a

location of the participant’s choice.

FNS expects the participant to document those modification requirements in

writing and to share them with FNS. Sufficient time should be allowed for FNS

review and comment prior to initiation of any significant changes. The participant

should address these discussions and submission of resulting documentation in

their Project Plan.

3.11.4 System Design and Development

In order to ensure that design decisions conform to the operational requirements

identified in Section 2.4 of the RFV, the participant should allow sufficient time in

the Project Plan for design and development activities. FNS expects the

participant to provide design documentation (of screens, notices, process flow,

and functionality), and to provide demonstrations of completed modules via

webinar. As the scope and complexity of changes will vary from one participant

to the next, any additional documentation needs will be mutually determined

between FNS and the participant.

During this time period, the participant will also need to complete negotiations

with Acculynk and sign a contract. The participant will work directly with the

assigned Acculynk project manager to implement the necessary interfaces and

message formatting required to submit transactions for PIN-entry, authorization

and response.

3.11.5 System Testing

The participant will test interfaces and messaging for purchases and refunds

directly with Acculynk. Acculynk will also test its interfaces and messaging with

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 71

the EBT processors. FNS also expects to test the modifications that each EBT

processor develops for the online purchasing pilot.

Once this testing is completed and the participant has finished development of

their internal system and process flow changes, the system will be ready for end

to end testing. FNS plans to conduct onsite end-to-end testing for each selected

participant. The participant must provide a test platform and access to the test

facility to perform this testing. To the extent possible, the testing must mirror the

production environment and interfaces, so that test transactions flow from the

participant’s system through Acculynk to the EBT processor test platform.

FNS will be responsible for developing scenarios and test scripts for the full

scope of SNAP and cash EBT transactions. These will address all potential

situations for both purchases and refunds, customized to the participant’s

business model and functionality. FNS will share the scripts and other test

requirements in advance for the participant’s review and suggestions.

The participant should address internal testing, Acculynk interface testing and

end to end testing in the Project Plan’s timeline.

3.11.6 Training and Marketing Materials

The participant will be responsible for training of internal staff and new EBT

customers as needed, as well as marketing and promotional strategies to ensure

that EBT customers are aware of the availability of online purchasing. Such

materials must be shared in advance with FNS to ensure that they are clear,

complete and reasonable. As noted in Section 3.8

, FNS encourages applicants

to partner with community organizations to assist in this effort.

3.11.7 Evaluation Preparation and Planning

FNS will require each participant to design and implement an online survey to

gather information from PIN debit customers. This will be voluntary to the

customer and may be integrated into the checkout and payment stream or set up

as a separate process performed after delivery. In addition, FNS and the

participant must share project data as described in Section 3.12, Online

Purchasing Pilot Evaluation. Prior to implementation, the retailer must work

closely with FNS and its evaluation contractor to determine the most effective

methods, format, content, timing and procedures for each. Mutually approved

versions of the survey tool and data transmission specifications should be

completed at least 30 days before implementation.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 72

3.11.8 Implementation and Rollout

Every selected participant must operate their initial pilot for a minimum of one

month prior to any expansion to additional areas, either within or outside of the

initial State. Expansion beyond State borders will be dependent on the new

State and EBT processor’s readiness. Each new State implementation will also

require a minimum of one month of operation with the first retailer before other

retailers may expand to that State. The participant must pilot for a minimum of

nine months overall and may continue to do so up until the end of the pilot

period.

FNS will require a variety of data and assistance from the retailer before, during

and after pilot implementation/rollout in order to satisfy the evaluation component

(see Section 3.12).

The above requirements for submission of documentation and materials to FNS are

summarized in Table 3-2.

Table 3-2 – Documentation Requirements

Document

Description

Project Plan/Timeline

Identification of and timelines for tasks and

deliverables. Due within 30 days of selection

Requirements Documentation

Description of necessary system and procedural

changes required to implement the pilot

Design Documents

Screen and notice content/layout, process flows,

functional descriptions

Test Scenarios and Scripts

Comments and recommendations on FNS

scripts

Training and Marketing

Materials

Materials for internal training, EBT customer

marketing and customer instruction/training to

be submitted for approval prior to

implementation.

Online Customer Survey

Design, content and process description for

online survey of PIN debit customers

Data Transmission

Specifications

Descriptions, file layouts, procedures and

timetables for data sharing

Evaluation Data

Throughout the life of the project and

immediately after completion

3.12 Online Purchasing Pilot Evaluation

FNS plans to conduct a study of this pilot project and will obtain the services of an

independent evaluation contractor to collect data and perform interviews with the

participating website’s staff and PIN debit customers as well as representatives from

community partners, Acculynk, the EBT processors, affected State agencies and FNS.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 73

3.12.1 Evaluation Contractor Responsibilities

The evaluator will be tasked with three areas of analysis and addition

deliverables as identified below. Data collection requirements to support the

evaluation may continue through the full two years of the pilot demonstration or

FNS may determine that a shorter period will be sufficient for our needs.

3.12.1.1 Online Purchasing Implementation Analysis

The evaluator will collect information to describe project design,

operations, and outcomes for each selected participant, and identify

specific lessons learned, challenges and recommendations regarding

implementation, level of effort, interaction among key players, multiple

forms of tender, and ability to meet FNS and Acculynk requirements. This

will allow FNS to identify necessary improvements in policies and

practices for potential nationwide implementation of online purchasing with

SNAP benefits.

3.12.1.2 Online Purchasing Impact Analysis

The selected evaluation contractor will document the impact of the pilot on

SNAP participants as far as ease of use, participant access, and customer

satisfaction, both overall and as they may vary by household

characteristics, among different retailer business models, and between

online and in-store purchasing. The evaluation contractor will also be

responsible for analyzing data collected through the required retailer-

initiated online survey. FNS expects study topics to examine, among

other things, delivery fees, tenders used in place of cash, and customer

service issues and how they are perceived by EBT clients in comparison

to commercial PIN debit customers.

3.12.1.3 Online Purchasing Integrity Analysis

The evaluation contractor will also identify the potential impact of online

purchasing on program integrity overall and as it may vary with household

and retailer characteristics. FNS expects to collect a variety of data from

participating Internet Retailers, EBT processors, Acculynk and SNAP

State agencies hosting the pilot projects to perform this analysis. Areas of

immediate concern include transaction security, privacy of PII data, and

the potential for new methods of fraudulent behaviors in the online

environment. FNS is extremely interested in studying the relationships

between delivery addresses, other addresses retained in customers’

online profiles (e.g., “billing address”), and the address data reported by

SNAP clients to the State agencies issuing SNAP benefits.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 74

3.12.1.4 Report to the Secretary

The contractor will use the data collected for the above analyses during

the first six months of operation to produce a report to the Secretary with

recommendations on future rollout, as required by the Farm Bill. FNS

expects that this will give us sufficient evidence to determine whether

online SNAP purchasing should be expanded to all States and, if so, the

best implementation strategy.

The Farm Bill requires the Secretary to determine that implementation in

all States is in the best interest of the Program, before FNS can move

forward and formalize interim procedures for ongoing authorization of

Internet Retailers. One reason for the decision to pilot for two years is so

that there will be ample time to develop the procedures with no

interruption in service for the pilot retailers and their EBT customers.

Ultimately, requirements for online purchasing and Internet Retailer

eligibility will be addressed in regulation.

3.12.1.5 Data Collection Process

The evaluator will propose the actual data collection methods used for the

above study areas, but FNS expects these to include, at a minimum:

1. Short online customer surveys conducted by the retailer as

described above

2. Additional, more in depth interviews of a random sample of SNAP,

cash EBT and other PIN debit customers of the Internet Retailer –

the retailer will need to work closely with FNS and the evaluator to

help identify the customers to be sampled and to facilitate

communication with the selected interview subjects

3. Collection of a variety of data from each participating retailer to

identify potential customer service and fraud concerns – see

Appendix F - Evaluation Data Collection, for more details on the

type of data that FNS expects the contractor to examine

4. Interviews with retailer and/or contracted staff, including those

fulfilling orders and handling customer complaints – FNS and the

evaluation contractor will work with the retailer to identify the

appropriate personnel and optimal timing of such interviews

3.12.2 Retailer Responsibilities

Selected participants are required to partake fully in the pilot’s evaluation and to

cooperate with FNS and its selected evaluation contractor by collecting and

providing necessary data, working together to develop and implement an online

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 75

survey, and facilitating the interview process for customers and employees in

order to ensure proper and timely progress in all aspects of the evaluation.

3.12.2.1 Applicants

To be eligible for participation in the Online Purchasing Pilot, interested

applicants must agree to cooperate fully with the evaluation contractor that

will be selected and overseen by FNS. Section R of the RFV Participation

Application Form (See Appendix D) requires each applicant to make the

following assurances related to the to the pilot evaluation. The intent of

each assurance is addressed in parentheses:

R17. We agree to provide the system data, statistics and customer

survey responses required by FNS to assess pilot operations to

FNS and/or its selected evaluation contractor (to ensure that data

necessary to properly evaluate the pilot, as identified in Appendix F

is provided as required to FNS)

R18. We agree to cooperate with FNS and the evaluation contractor to

identify a large enough sample of PIN debit customers to answer

research questions designed for the formal evaluation, to obtain

their prior informed consent, and to identify appropriate content and

format for the required retailer-initiated online survey (to ensure that

the retailer assists the evaluation contractor in identifying a sample

of customers for interviews and obtain their consent, and to ensure

that the retailer contributes to the design, language and format for

the required retailer online customer survey)

R19. We agree to facilitate access (including updated contact infor-

mation) for evaluation contractor interviews or site visits with retailer

staff, evaluation sample PIN debit customers, and other key

participants in the pilot project (to ensure that the retailer provides

necessary, up to date information for the evaluation contractor to

contact and set up interviews or site visits with customers, retailer

staff and/or contractors, community partners and other key staff for

the purposes of collecting responses to evaluation questions)

R20. We agree to work in cooperation with FNS and the evaluator to

trouble-shoot and resolve issues and refine procedures (to address

unforeseen problems and adjust processes and procedures as

needed to resolve those issues)

R21. We agree to make all efforts to maintain the integrity of the

evaluation and ensure the quality of the data provided to FNS and

the evaluation contractor (to ensure that the evaluation contractor is

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 76

able to complete the evaluation in a manner that meets the levels of

quality and integrity expected by FNS).

See Section 3.9.2.1, RFV Participation Application Form and instructions

for form completion in Appendix D for additional information on how to

respond to the above assurances.

3.12.2.2 Pilot Participants

Evaluation-related responsibilities of selected retailers will include the

following tasks:

• Facilitating access to data necessary for the evaluation (the list of

data items potentially required for the evaluation can be seen in

Appendix F)

• Working with the evaluation contractor to assemble the data

needed to select an adequately sized random sample of PIN debit

customers for them to interview and evaluate

• Developing and implementing, in cooperation with FNS and the

evaluation contractor, procedures and materials to ensure legally

effective informed consent from participants in the evaluation

sample

• Facilitating access (including updated contact information as

needed) so that the evaluation contractor can perform interviews

and site visits with sampled customers, retailer staff, and other

partners or stakeholders in pilot operations

• Working in cooperation with the evaluator to trouble-shoot and

resolve issues and refine procedures to the extent feasible

• Making every effort to maintain the integrity of the evaluation and

ensure the quality and integrity of the data provided to the

contractor

• Other reasonable assistance, as needed to ensure the success of

the evaluation

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 77

Appendix A – State Specific Information

This table shows who the EBT processor will be by the time that the Online

Purchasing Pilot begins. Please note that only those States that are NOT in

process of reprocurement or conversion at that time may be selected by the

applicant for the initial pilot and any rollout increments. The States are shown in

red are NOT available for pilot.

The table also lists the BIN numbers (first six digits of card number) used to

identify the State’s EBT card, the length of their card number, their Quest

membership and whether they include cash on their EBT card (those that do not

use a separate pre-paid, branded debit card, which is already usable for online

purchasing).

Table A-1 – State Specific Information

State

BIN #

Quest/

Non-

Quest

PAN

(if not

16)

EBT

Proces-

sor

Cash

Y/N

State

BIN #

Quest/

Non-

Quest

PAN

(if not

16)

EBT

Proces-

sor

Cash

Y/N

507695

JPM

507714

Solutran

507680

FIS

508161

FIS

610093

FIS

508132

FIS

507706

FIS

507716

FIS

507719

Xerox

507701

FIS

507681

FIS

610434

Xerox

600890

Xerox

586616

FIS

507707

FIS

507715

FIS

507713

Xerox

600486

Xerox

508139

FIS

507700

Xerox

508148

Xerox

508147

Xerox

578036

FIS

507693

FIS

507698

JPM

600760

Xerox

627485

Xerox

507682

FIS

507692

FIS

610470

Xerox

601453

Xerox

508132

FIS

507704

Xerox

507702

FIS

601413

FIS

610098

FIS

507709

FIS

601036

Xerox

504476

Xerox

622044

Xerox

600875

Xerox

507721

JPM

600528

Xerox

507705

FIS

507703

Xerox

507710

FIS

507711

Xerox

507708

FIS

610423

FIS

507720

JPM

507683

FIS

505349

FIS

507718

Xerox

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 78

Appendix B – Letter of Intent

Retail grocery website owners interested in submitting an application to participate in

the SNAP EBT Online Purchasing Pilot are asked to submit a Letter of Intent (LOI) to

apply for the pilot. Please see Section 3.6, Letter of Intent for more information on the

purpose of the LOI. Internet merchants should address all items below. Other parties

interested in pilot related conference calls and Q&As may also submit an LOI and

should provide the contact information requested in the first three lines. This response

may be made by submitting the information to the FNS Contact identified in Section 3.4,

Point of Contact by 5:00 pm EDT on the LOI Due Date listed in Section 3.5, RFV

Timetable. The LOI must be emailed. FNS thanks Internet Retailers in advance for

their cooperation with this request.

Subj: EBT Online Purchasing Pilot Letter of Intent

Company Name and Address:

Company Contact Name for RFV:

Contact Telephone: Contact Email:

Grocery Website Address/Link:

Available State(s) where you would be interested in conducting a pilot:

Non-available State(s)

of future interest:

These would be the States shown in red in Table A-1 of Appendix A (only if they become available

before the end of the pilot).

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 79

Appendix C – Statement of Support from Community

Organizations

As described in Section 3.8, State and Community Partners, FNS encourages RFV

Applicants to work with community partners such as non-profits, health organizations,

local government and other community organizations to obtain support and assistance

for pilot implementation and operation.

Applicants who opt to do this should obtain a statement of support from each partner

organization and include it with their application. This statement should be on the

organization’s official letterhead and can be provided in letter or outline form, but must

address the following:

1. Organization’s complete address

2. Identification of the type of organization, (e.g., health, government, non-profit,

etc.)

3. Short description of the organization’s mission or primary activities and how that

interacts with SNAP clients

4. Reasons they wish to partner with the retailer in the implementation of the Online

Purchasing Pilot

5. Description of the activities (e.g., outreach, training, etc.) or other assistance that

they plan to provide as a partner

6. Full name, telephone number and email address of organization’s primary

contact for the partnership

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 80

Appendix D – Request for Volunteers (RFV)

Participation Application Form

All respondents to the RFV must complete this application and submit it in the manner

described in Section 3.9.1, Submission. The form itself includes brief instructions on its

completion. More detailed line by line directions are included in this Appendix,

immediately following the application form.

Please respond to all questions as instructed. If there is insufficient room to respond to

a question so that it displays completely on the form, or more explanation is needed,

applicants may include a separate attachment and refer to a page and item number in

the appropriate block of the application form. Each item addressed in the attachment

should also contain a reference to the application question number to which it refers.

The form included on the following pages is a facsimile of the Adobe version

(onlinepurchasing-rfvapp.pdf) contained in the onlinepurchasing-rfv-

application-packet.zip file, available at SNAP Online Purchasing Pilot

Request for Volunteers Application Package. Please use the referenced pdf

file and complete it electronically to submit your final response to this RFV.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 81

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 82

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 83

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 84

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 85

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 86

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 87

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 88

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 89

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 90

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 91

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 92

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 93

Instructions for Completion of the Online Purchasing

Pilot RFV Participation Application Form

You must use the electronic pdf version of this form to apply. Type all text or numeric

responses in the boxes provided. Most questions offer response options. If only one

response is allowed, there will be radio buttons (a small circle: ◌) immediately to the left

of each potential response. If the question allows multiple answers, there will be a

checkbox (a small box: ) immediately to the left of each response. Each question

requires a response unless otherwise instructed.

Please be sure to read the Privacy Act Statement contained in Section S of the

application before you start. This mirrors the language from the FNS-252 SNAP

Application for Stores. Except as noted in that statement, data contained in your

application will not be shared beyond FNS and the evaluation contractor selected by

FNS.

Section A – Applicant Identifying Information

A1. Enter the name of your company as it is recognized by customers at your website, i.e. the

name you are doing business as.

A2. Enter the link to get to your website, e.g., https://www.fns.usda.gov/

A3. Enter the full name of the person who will be the primary contact for the application process

and duration of the pilot.

A4. Enter the primary telephone number for the person listed in A3.

A5. Enter the email address for the person listed in A3.

A6. Enter the street address where the person listed in A3 is stationed or can receive mail.

A7. Enter the city of the address in A6.

A8. Enter the State of the address in A6.

A9. Enter the ZIP code of the address in A6.

Section B – Volunteer Business Category and Experience

NOTE: If you have multiple, distinct websites which are eligible for participation in SNAP, each of those

websites is considered a separate “FNS retailer” and each will need to obtain a separate FNS

authorization to participate in SNAP. This application is limited to only one of your websites.

B1. Click on the button which best describes your business; if none apply, select “Other” and

describe your business in the box directly below that.

B2. Click on the button for “Yes” or “No”; examples of multiple websites, even if accessed by the

same initial link, would be a) one that offers a full line of groceries for local delivery and another

that offers a more limited selection of foods that can be shipped nationally, b) one that offers a

different set of local products in different areas around the country. If you select “Yes”, explain

the differences in the box directly below the question.

B3a. Enter the number of years your company has been in business whether online or brick and

mortar in the “All Sales” column and the number of years you have been selling food products

in the “Food Sales” column.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 94

B3b. Enter the number of years your company has operated your website for online purchasing in

the All Sales column and the number of years you have been selling food products on the

website in the Food Sales column.

B3c. Enter the estimated number of online purchase transactions performed on your website in

calendar year 2015 in the All Sales column and the estimated annual number of online

purchases in 2015 that included food products in the Food Sales column.

B3d. Enter the estimated gross sales that resulted from online purchases through your website

during calendar year 2015 in the All Sales column and the estimated gross sales of food

products purchased through the website in 2015 in the Food Sales column.

Section C – Website Business Model

C1. Identify all delivery methods used for products sold on your website by checking the

appropriate boxes. If you select “Customer Pickup”, whether at retailer-owned stores or other

designated locations, enter the number of different pickup locations in the box to the right of

“Number of Pickup Sites” and respond to the question “Are all pickup site addresses identified

in the system?” by clicking on the button for “Yes” or “No” (see Section 2.4.2.1.2

of the RFV for

further information). If you select “Other” explain the delivery method(s) in the box directly

below.

C2a. Identify the type of facility where your food inventory is stored and you put together the orders

placed on your website. Check all boxes that apply to your operation. If you select “Other”

explain the delivery method(s) in the box directly below.

C2b. If you selected “Single warehouse”, “Multiple national warehouses” or “Multiple regional

warehouses” under question C2A, identify the city and State of each warehouse location in the

box directly below the question.

C3. If you selected “Multiple national warehouses”, “Multiple regional warehouses”, checked more

than one box under question C1, or more than one box under C2a, you must identify whether

these carry the same food products at each location and use the same delivery methods for all

customers at those locations by selecting “Yes” or “No”. If you select “No” explain the delivery

method(s) in the box directly below. An example requiring a “No” response is a warehouse set

up to deliver a full grocery line to local customers and a different warehouse that stores a

smaller set of food items and ships them nationwide. Another example would be a site that

does home delivery in multiple cities around the country, but the products sold in each city are

locally produced and vary by location (see Section 2.3.1.4.4

of the RFV for more information).

C4a. Click on “Yes” if your website is set up to allow any third party companies, farmers, vendors or

other individuals/organizations to sell and/or ship products directly to customers from their own

inventories, regardless of which party accepts payment (see Section 2.3.1.4.6

for more

information). Click on “No” if your website does not allow third party sales and all products sold

on the site come from your own inventory; if you click on “No”, skip to question D1.

C4b. If you responded “Yes” to question C4a you must answer this question. Click on “Yes” if food

sales from your own company inventory represent 50% or more of total food sales from all

sellers that do business on your website. Click on “No” if food sales from your own inventory

are less than 50% of the total value of food sold on your website by all sellers.

C4c. If you responded “Yes” to question C4a you must answer this question. Click on “Yes” if you

will be able to reprogram your website to limit SNAP sales only to products from your own

corporate inventory, otherwise, click on “No”.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 95

Section D – SNAP Authorization Status

D1. Click on the button which best describes your current FNS authorization status. If you select

“Currently Authorized Individual Retailer”, enter the 7-digit authorization number that was

assigned to you by FNS in the box to the right of “FNS number”. If you select “Currently

Authorized Chain”, enter the 7-digit corporation number assigned to you by FNS, if known, in

the box to the right of “FNS Corporation #”. If none of the first four options apply, select “Other”

and provide an explanation in the box to the right of that option.

Section E – Website’s Geographic Coverage

E1. If your website sells to customers located in all 50 States, DC, Guam and the Virgin Islands,

check the box to the left of “All”. Otherwise, check the box to the left of each State or territory

where customers may make purchases from your website

E2a. Click on “Yes” if any States where you do business charge sales tax on some or all food

products. Click on “No” if there are no States where you do business that charge Sales tax on

food; if you click on “No”, skip to question E3a.

E2b. If you responded “Yes” to question E2a you must answer this question. List each State where

your website normally charges tax for all food products in the box to the right of the question. If

no States tax all food products, enter “none”.

E2c. If you responded “Yes” to question E2a you must answer this question. List each State where

your website normally charges tax only for some food products (e.g., snacks and carbonated

beverages) in the box to the right of the question. If no States tax just some food products,

enter “none”.

E2d. If you responded “Yes” to question E2a you must answer this question. Click on “Yes” if you

use a tax calculation service provider, otherwise click on “No”’

E2e. If you responded “Yes” to question E2a you must answer this question. Click on “Yes” if you

will be able to reprogram your website to ensure that items purchased with SNAP benefits are

exempt from all State sales taxes, otherwise click on “No”.

E3a. Click on “Yes” if your website sells any products that require a container deposit, regardless of

the entity imposing the deposit fee, Click on “No” if you do not sell any products requiring a

container deposit; if you click on “No”, skip to question E4a.

E3b. If you responded “Yes” to question E3a you must answer this question. Click on “Yes” if any

State(s) where you do business have a law that requires you to collect container deposits (see

Section 2.2.1, footnote 2

of the RFV for a list of States with such laws). Click on “No” if there

are no States where you do business that require collection of container deposits.

E3c. If you responded “Yes” to question E3a you must answer this question. Click on “Yes” if you

will be able to reprogram your website to prevent use of SNAP benefits to pay for any container

deposit fees except for those fees specifically required by State law, otherwise click on “No”.

E3d. If you responded “Yes” to question E3a you must answer this question. Click on “Yes” if your

website is responsible for accepting empty containers and repaying the customer for the

deposits. Click on “No” if such containers can only be redeemed at other locations (e.g., a

State redemption center or one of your brick and mortar locations).

E4a. Click on “Yes” if your website collects any fees for bags or other delivery containers based on

State or local laws or for any other reason, even if such fees are not charged to all customers.

Click on “No” if you never charge fees for bags or other delivery containers; if you click on “No",

skip to question F1a.

E4b. If you responded “Yes” to question E4a you must answer this question. Click on “Yes” if you

will be able to reprogram your website to prevent the use of SNAP benefits to pay for any fees

for bags or other delivery containers; otherwise, click on “No”.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 96

Section F – Pilot and Rollout Plan

NOTE: States or territories marked with an asterisk (*) at Question E1 are NOT available for the purposes

of this demonstration pilot and may not be selected by the website as responses to any of the questions

in Part F. For those States that ARE marked with an asterisk, the State agency must still subsequently

agree to allow the pilot to be implemented in their State.

F1a. Enter the State or part of a single State (e.g., a city, metro area, county or set of ZIP codes)

where you would prefer to conduct your initial pilot for a minimum of one month. If you are

selected as a pilot participant, FNS will work with you to gain that State’s approval to perform

the pilot there, but that approval cannot be guaranteed.

F1b. Enter up to two additional States or portions of a single State that would be acceptable as

alternate locations for your initial pilot if we are unable to obtain State permission for your first

choice.

F1c. If you would like to roll out to an additional State or portion of a State during the course of the

pilot, enter the name of the next State or area to which you would like to expand; if you have no

rollout plans, enter “None”.

F1d. If you would like to expand further to a third State or portion of a State for the pilot, enter the

name of that State or area that will be your next and final rollout location; if you have no further

rollout plans, enter “None”.

F2a. Click on “Yes” if any of the areas identified in section F1 specifically target SNAP client

populations (low-income groups, food deserts or other vulnerable geographic areas) in need of

delivery or pickup services, and describe those groups/areas in the box directly below the

question. Otherwise, click on “No”.

F2b. Click “Yes” if you are partnering with a local government and/or non-profit group to provide

input or assistance in your efforts to design system changes, market to SNAP clients or other

efforts. Click on “No” if you are not partnering with such groups, and skip to question F3.

F2c. If you responded “Yes” to question F2b you must answer this question. Enter the name(s) of

your partner group(s) in the box below the question. You must also attach a statement of

support from each identified group (See Appendix C

of the RFV for sample statement content).

F3. Identify the estimated amount of time that you will require to be ready to start your pilot if you

are selected. Take into consideration the tasks identified in the question and in Sections 1.6.2

2.3.2 and 2.4 of the RFV.

Section G – Fee Structure

G1. Identify all fee types that you charge for submitting orders on your website by checking the

appropriate boxes under this question. If you check a box involving a fixed fee or single dollar

amount, enter the appropriate dollar amount in the box to the right of each selected item. If you

select a variable fee, indicate the potential range of the fee (lowest amount to highest) in the

box to the right of each selected item. If you have any types of fees that are not listed, check

“Other” and explain in the box immediately below.

G2. Click on “Yes” if you plan to reduce or completely waive some or all fees for EBT customers

during the pilot, and explain your plans (elimination of fees or reduction and if reduced, what

you will charge instead) in the box immediately below. Otherwise, click on “No”.

G3. Click on “Yes” if you will be able to reprogram your website to identify all fees, as listed in

question G1, to the EBT customer before the EBT transaction is processed and offer the

opportunity to cancel the order before the sale is final; otherwise, click on “No”.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 97

Section H – Payment and Processing Methods

H1. Identify the name of the transaction processor or merchant service provider that currently

handles your credit and signature debit business in the box to the right of the question.

H2. Identify all payment methods that you currently accept on your website by checking the

appropriate boxes under this question. If you accept any payment methods not listed, check

“Other” and explain in the box immediately below.

H3. Click on “Yes” if you are willing to accept cash at the time of delivery or pickup for SNAP-

ineligible costs such as fees and non-food products; otherwise click on “No”.

H4. Click on “Yes” if your website is capable of accepting multiple payment methods (e.g., SNAP

and commercial debit) for a single order. Click on “No” if you can only accept one payment

type for the order.

H5. Click on “Yes” if you wish to accept cash EBT as a separate payment method in addition to

SNAP. Click on “No” if you only wish to accept SNAP EBT, not cash EBT. Click on “Unsure” if

you are still evaluating that option (cash EBT requires additional design considerations and

may be added later).

H6. Click on “Yes” if you want to add commercial PIN debit (a separate service offered by Acculynk

and described in Section 1.3.2.3

of the RFV) at the same time as you add EBT. Click on “No” if

you are not interested in this service. Click on “Unsure” if you are still evaluating that option

(requires additional negotiation and design considerations; may be added later).

H7a. Click on “Yes” if you accept manufacturers’ coupons for products sold on your website;

otherwise click on “No” and skip to question H8a.

H7b. If you responded “Yes” to question H7a you must answer this question. Click on “Yes” if any

States require customers to pay sales tax on savings from manufacturers’ coupons and list

those States in the box below the question; otherwise click on “No”.

H8a. Click on “Yes” if you accept store coupons (e.g., from weekly flyers) for products sold on your

website; otherwise click on “No” and skip to question H9.

H8b. If you responded “Yes” to question H8a you must answer this question. Click on “Yes” if these

store coupons are subject to tax in the same way as manufacturers’ coupons; otherwise click

on “No” and explain how tax on store coupons is handled by your website in the box directly

below the question.

H9. Identify each method you currently use to process your commercial credit/debit sales by

checking the appropriate boxes under this question. If any current method is not listed, check

“Other” and explain in the box immediately below.

H10a. Click on “Yes” if you allow a single order to be split up for delivery, pickup or shipping. Click on

“No” if you require the entire order to be delivered, picked up or shipped together and skip to

question I1a.

H10b. If you responded “Yes” to question H10a you must answer this question. Click on “Yes” if you

ever fulfill these split orders from different locations (e.g., stores or warehouses), otherwise click

on “No”.

H10c. If you responded “Yes” to question H10a you must answer this question. Click on “Yes” if you

ever allow a single order to be split between two or more different delivery, pickup or shipping

addresses, otherwise click on “No” and skip to question I1a.

H10d. If you responded “Yes” to question H10c you must answer this question. Click on “Yes” if you

will be able to reprogram your website to limit each EBT order to a single address; otherwise,

click on “No”

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 98

Section I – Non-Profit Cooperatives and Community Supported Agriculture (CSA)

NOTE: This section of the application pertains only to non-profit cooperatives and to agricultural

producers that markets agricultural products directly to consumers through a CSA share arrangement,

authorized by the Family Nutrition Act to accept advance payment for SNAP purchases up to 14 days in

advance of delivery. If your organization does not fall into one of these categories, skip to question J1.

See

Section 2.4.5 for special technical requirements for these retailer types.

I1a. Enter the number of days each month that you normally deliver to customers or provide order

pickup in the box to the right of the question.

I1b. Click on “Yes” if you distribute food to customers on different days for different locations (some

days you provide delivery/pickup to one location and on other days you provide delivery/pickup

to a different location). Click on “No” if you have only one delivery/pickup location or you

distribute to all locations on each delivery/pickup day.

I1c. Click on “Yes” if you distribute orders to some or all delivery/pickup locations on multiple days

each month. Click on “No” if you only provide delivery/pickup on one day per month at each

location.

I1d. Enter the average number of days that you provide delivery/pickup at each site in the box to the

right of the question.

I1e. Click on “Yes” if you will be able to reprogram your website to ensure that SNAP sales cannot

be performed earlier than 14 days before the scheduled delivery/pickup date for their location;

otherwise click on “No”.

I1f. Click on “Yes” if you will be able to reprogram your website to inform the customer of the first

date that they can come back to the website to place an order if they attempt to make a

purchase more than 14 days before the scheduled delivery/pickup date for their location;

otherwise click on “No”.

Section J – Handling of SNAP-Eligible Foods

J1. Click on “Yes” if your website sells pet foods, vitamins, health and beauty items, paper or

cleaning products, alcohol, tobacco or any other SNAP-ineligible products. Click on “No” if you

only sell foods that are SNAP-eligible on your website and skip to question J4a.

J2a. If you responded “Yes” to question J1 you must answer this question. Click on “Yes” if your

website currently identifies which products are SNAP-eligible and which are not, otherwise click

on “No”.

J2b. If you responded “Yes” to question J2a explain how your system identifies which products are

SNAP-eligible and which are not in the box below the question and skip to question J3a. If you

responded “No” to question J2a, explain the method you plan to implement to identify the

difference in the box below the question.

J2c. If you responded “No” to question J2a you must answer this question. Indicate how much time

you will need to implement the ability to identify which products are SNAP-eligible and which

are not in the box below the question.

J3a. If you responded “Yes” to question J1 you must answer this question. Click on “Yes” if you will

be able to reprogram your website to calculate a SNAP subtotal for the order, excluding any

fees and SNAP-ineligible products, otherwise click on “No”.

J3b. If you responded “Yes” to question J1 you must answer this question. Click on “Yes” if you will

be able to reprogram your website to limit the maximum amount requested in the SNAP

authorization request to the value calculated under question J3a, otherwise click on “No”.

J3c. If you responded “No” to question J3a or “No” to question J3b, explain how you will ensure that

SNAP benefits are never used for fees or SNAP-ineligible products in the box below the

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 99

question. An example would be that your website will waive fees for SNAP customers and not

allow comingling of SNAP-eligible and SNAP-ineligible products in the same purchase.

J4a. Click

on “Yes” if you will be able to reprogram your website to allow, or it already does allow, the

customer to use a smaller amount of their SNAP benefits than the amount calculated for the full

SNAP subtotal under question J3a, and to pay the balance with another form of tender (

see

Section 2.4.2.7), otherwise click on “No”.

J4b. Click on “Yes” if you plan to allow customers to perform EBT balance inquiries online (a

separate EBT transaction type requiring entry of a PIN so that the customer can determine the

balances remaining in both their SNAP and cash EBT accounts). Click on “No” if you do not

plan to allow balance inquiries on your website.

J4c. Click on “Yes” if you will be able to reprogram your system to display the available balances

when an EBT transaction is denied for insufficient funds (SNAP and cash balances are always

returned in the denial response when there are insufficient funds in an EBT account). Click on

“No” if you will not be able to display remaining balances.

J4d. Identify all methods that you will use to aloe the customer to reduce the SNAP amount paid by

checking the appropriate boxes under this question. Note that if you indicate that the system

automatically replaces the SNAP subtotal with the value of the remaining SNAP benefits (first

box) you are still required to allow the customer to reduce the SNAP amount even further by

checking the second box. If a method you will use is not listed, check “Other” and explain in

the box immediately below

Section K – Weighed Products, Substitutions and Out of Stock Items

K1a. Click on “Yes” if any products on your website have variable pricing based on weight (e.g.,

produce, meats, fish, deli products), otherwise, click on “No” and skip to question K2a.

K1b. If you responded “Yes” to question K1a you must answer this question. Identify all methods

that you currently use to estimate pricing of weighed items by checking the appropriate boxes

under this question. If a method you use is not listed, check “Other” and explain in the box

immediately below.

K1c. If you responded “Yes” to question K1a you must answer this question. Identify all methods

that you currently use to handle final pricing of weighed items by checking the appropriate

boxes under this question. If a method you use is not listed, check “Other” and explain in the

box immediately below.

K1d. If you responded “Yes” to question K1a you must answer this question. Click on “Yes” if you

will be able to reprogram your system to limit any additional estimated value for weighed items

for EBT customers to no more than 10 percent over the total value of all weighed items,

otherwise click on “No”.

K1e. If you responded “Yes” to question K1a you must answer this question. Click on “Yes” if you

will be able to reprogram your system to advise EBT customers about your weight estimation

policies in advance of weighed product selection, otherwise click on “No”.

K1f. If you responded “Yes” to question K1a you must answer this question. Click on “Yes” if your

website advises the customer of the total amount added for weight estimation padding before

the sale is final.

K1g. If you responded “No” to question K1f you must answer this question. Click on “Yes” if you will

be able to reprogram your system to advise EBT customers about your weight estimation

policies in advance of weighed product selection, otherwise click on “No”.

K2a. Identify all methods that you currently use to handle items that are out of stock at the time the

order is fulfilled by checking the appropriate boxes under this question. If a method you use is

not listed, check “Other” and explain in the box immediately below.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 100

K2b. If you checked more than one box for question K2a, explain how you decide which action to

take and how you notify the customer of that action in the box below the question.

Section L – Order, Refund and Delivery Confirmation and Completion

L1a. Identify all delivery methods that you currently use for items sold on your website by checking

the appropriate boxes under this question. If a method you use is not listed, check “Other” and

explain in the box immediately below. For each item you select enter your estimate of the

average time between completion of the online payment transaction and the customer having

the purchased goods in hand in the Average Time column. For each item you select enter the

maximum time that any order has taken from completion of online transaction to customer

receipt of goods in the Maximum Time column.

L1b. Explain in the box below the question whether and how the customer can select the location,

date and time for delivery or pickup as well as any limitations that may be imposed on their

ability to do so.

L2a. Identify all of the methods you use to provide proof of purchase to customers after completion

of the online order by checking the appropriate boxes under this question. If a method you use

is not listed, check “Other” and explain in the box immediately below. For each method you

select, include in your application package a scanned sample or a screen shot of the proof of

purchase notification.

L2b. If your website sends a notification to the customer via email or text message, indicate when

this happens by checking the appropriate boxes under the question. If the time period is not

listed, check “Other” and explain in the box immediately below.

L2c. Click on “Yes” if your notifications include the date, time and location of delivery, pickup or

shipping, otherwise click on “No” and provide an explanation in the box immediately below.

L2d. Click on “Yes” if you will be able to reprogram your website or fulfillment system to meet content

specifications for receipts as required by regulation, especially EBT account balances (see

Sections 2.4.3 and 2.5.3

of the RFV), otherwise, click on “No”.

L2e. Click on “Yes” if you provide an itemized paper receipt at the time of delivery, pickup or

shipping, otherwise click on ”No”.

L3. Click on “Yes” if you provide online tracking of delivery, pickup or shipping on your website and

explain how this process works in the box immediately below. If you do not provide online

tracking click on “No”.

L4. If you allow customers to place a one-time order, in advance, for specific products to be

delivered at regular intervals (monthly, every two months, etc.) for a price that is lower than the

regular price of the products, click on “Yes, at reduced price”. If you allow standing orders as

described in the previous sentence, but at the regular price, click on “Yes, at same price”. Click

on “No” if you do not allow standing orders.

L5a. Click on “Yes” and skip to question L6a if you will be able to reprogram your website or

fulfillment system to automatically generate any refund due to an EBT customer (e.g., for

underweight or out of stock items) after the order is completed, otherwise click “No”.

L5b. If you responded “No” to question L5a you must answer this question. Explain how you will

ensure that EBT customers receive any refund due after the order is completed.

L6a. Identify all methods that you will use to provide proof of any refund given at order completion

(including account balanced after the refund) by checking the appropriate boxes under this

question. If you will use a method that is not listed, check “Other” and explain in the box

immediately below.

L6b. Identify the timing of the notifications identified in question L6a by checking the appropriate

boxes below the question. If the timing is not listed, check “Other” and explain in the box

immediately below.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 101

L6c. Click on “Yes” if you will be able to reprogram your website or fulfillment system to meet FNS

content requirements for the refund notices identified in question L6a (see Sections 2.4.3

and

2.5.3 of the RFV), otherwise click on “No”.

L7a. Click on “Yes” if you allow a customer to cancel an order that has been completed online but

not yet put together for delivery/pickup/shipping; otherwise click on “No” and skip to question

M1a.

L7b. If you responded “Yes” to question L7a you must answer this question. Identify all methods

that customers can use to cancel an order by checking the appropriate boxes below the

question. If you allow a method that is not listed, check “Other” and explain in the box

immediately below.

L7c. If you responded “Yes” to question L7a you must answer this question. Click on “Yes” if you

require some form of customer authentication or use other security when a customer cancels

an order, otherwise click on “No”.

L7d. If you responded “Yes” to question L7a you must answer this question. Explain how you will

ensure that the customer receives a complete refund after the order is cancelled in the box

immediately below.

L7e. If you responded “Yes” to question L7a you must answer this question. Explain how the

customer is notified of the cancellation and refund.

L7f. If you responded “Yes” to question L7a you must answer this question. Click on “Yes” if you

will be able to reprogram your website or fulfillment system to meet FNS content requirements

for the refund notices (see Sections 2.4.3 and 2.5.3

of the RFV) identified in question L7e,

otherwise click on “No”.

Section M – Problem Handling

M1a. Identify the reasons you will allow a customer to return a product for a refund after the customer

receives the order by checking the appropriate boxes below the question. If there is a reason

that is not listed, check “Other” and explain in the box immediately below. If you check the box

for “We never allow refunds…” skip to question N1a.

M1b. If you indicated that you allow refunds in question M1a you must answer this question. Click on

“Yes” if you require the customer requesting the refund to return the product to you. Click on

“No” if you never require the customer to return the product and skip to question M2a. Click on

“It depends…” if there are certain circumstances when you require the product to be returned

and others that do not require a product return and explain those circumstances.

M1c. If you responded “Yes” or “It depends” to question M1b, identify the methods that customers

may use to return the product by checking the appropriate boxes below the question. If there is

a method that is not listed, check “Other” and explain immediately below.

M1d. If you responded “Website arranges shipping deducting costs from refund” or “Website

arranges shipping deducting any original free shipping from refund” to question M1c, you must

explain, in the box immediately below, how you will handle either of these situations for a

SNAP-only purchase, because shipping costs cannot be charged to SNAP benefits or deducted

from a SNAP refund.

M2a. If you indicated that you allow refunds in question M1a you must answer this question. Click on

“Yes” if your post-delivery refund process is automated and skip to question M3a, otherwise

click on “No”.

M2b. If you responded “No” to question M2a you must answer this question. Explain how you will

ensure that the customer receives a post-delivery refund if one is required.

M3a. If you indicated that you allow refunds in question M1a you must answer this question. Explain

how you notify a customer that you have completed a post-delivery refund when one was due

in the box below the question.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 102

M3b. If you indicated that you allow refunds in question M1a you must answer this question. Click on

“Yes” if you will be able to reprogram your website or refund system to meet FNS content

requirements for the notices (see Sections 2.4.3 and 2.5.3

of the RFV) identified in question

M3a, otherwise click on “No”.

Section N – Accessibility

N1. Explain how you plan to educate EBT customers about the ability of your website to accept

SNAP and cash EBT payment online and how the system operates for EBT payments in the

box below the question.

N2. Click on “Yes” if your website is available in any languages besides English and list those

languages in the box immediately below, otherwise click on “No”.

N3. Click on “Yes” if your website complies with the Americans with Disabilities Act Section 508

accessibility requirements (see Section 2.2.1

of the RFV), otherwise click on “No”.

Section O – Privacy and Security

O1a. Click on “Yes” if you retain any Personally Identifiable Information (PII) on any of your systems

related to online purchasing (website, order fulfillment, customer service, etc.). PII includes

name, address, email address, etc. (see Section 2.4.6.4

of the RFV). If you do not retain PII in

your systems, click on “No”.

O1b. Click on “Yes-Required” if every customer must create a stored user account in order to

purchase products from your website. Click on “Yes-Optional” if customers can create a user

account if desired but could opt instead to shop as a “”guest” and enter all pertinent data for

every purchase. Click on “No” if there are no stored user accounts for your website.

O1c. Identify which issues your website addresses in its online privacy policies by checking the

appropriate boxes below the question.

O1d. Click on “Yes” if you ever sell customers’ PII or share it with third parties that are not essential

to the sale, delivery or customer service processes and explain what data is shared and with

whom in the box immediately below. Otherwise “Click on “No”.

O1e. Click on “Yes” if an individual customer can opt out of data sharing with other parties in order to

protect their PII, otherwise click on “No” and skip to question O2a.

O1f. If you responded “Yes” to question O1d, you must answer this question. Explain how the opt-

out process works and provide a link to your online instructions for the process in the box below

the question.

O2a. Click on “Yes” if your website uses cookies (see Section 2.4.6.2

of the RFV) to facilitate future

access to the site, otherwise click on “No” and skip to question O3a.

O2b. If you responded “Yes” to question O2a you must answer this question. Click on “Yes” if PII

(e.g., account number, login ID, etc.) is ever stored in cookies, otherwise click on “No” and skip

to question O3a.

O2c. If you responded “Yes” to questions O2a and O2b you must answer this question. Click on

“Yes” if these cookies can easily be avoided or deleted, otherwise click on “No”. Please provide

further explanation of either response, describing how cookies can be deleted or why it cannot

easily be done

O3a. Click on “Yes” if customers store payment card numbers and related data in your website in

order to make a purchase. Click on “No” and skip to question O4 if you do not allow users to

store card information in your system.

O3b. If you responded “Yes” to questions O3a you must answer this question. Click on “Yes” if

customers can opt NOT to store their card number in your website and enter the number for

each sale. Click on “No” if customers must store their card number in your website.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 103

O4. Click on “Yes” if card number display on screens and in notices is always truncated to the last 4

digits (except when the customer is initially entering the card number), otherwise click on “No”

O5. Click on “Yes” if your website is Payment Card Industry (PCI) certified as compliant with their

rules on protection of “data at rest” (e.g., card numbers), otherwise click on “No”.

O6. Attach a pdf or Word document describing the protocols and best practices that you use to

secure cardholder PII data and card numbers. The methods listed in the application are meant

to be examples, not a list of requirements. None of them are specifically mandated for the pilot,

but a combination of some of these practices is usually required to achieve PCI certification.

Please identify the names of any third party security products or services that you use.

Section P – Website Policies

P1. Provide customer links to your website’s written policies in each box to the right of the five listed

categories. If any of these policies are not available for customers to see on your website, you

may instead attach a pdf or Word document describing those policies. If you have no written

policies for one or more of these areas, enter “None” in the box to the right of the applicable

topic.

Section Q – Pilot and SNAP Retailer Application Documentation

NOTE: This section provides a checklist of items to include with this Online Purchasing Pilot application

form. For most retailers all of these items are required in order for you to participate in the pilot as an

FNS-authorized retailer. This checklist also assists FNS in making sure that we have received all of the

attachments/files that you included in your application package. Failure to provide a complete application

package is a reason to eliminate you from consideration as a pilot participant. If you replied “Yes” to

Question B2 or “No” to Question C3 on the application form, you may be required to complete multiple

SNAP retailer applications for rollout; however, only one application is required for initial response to the

RFV.

Q1. Click on “Yes” if you have included your SNAP retailer application (see Sections 2.3.1.1, 3.9.2.2

and Appendix E of the RFV). Click on “No” if you have not included the application and skip to

question Q3.

Q2. If you responded “Yes” to question Q1, you must answer this question. Click on “FNS-252” if

you have completed and included the standard SNAP Application for Stores. This version is

required if you are not currently authorized by FNS to redeem benefits at any other location or if

you are currently authorized to redeem SNAP benefits at one or more locations but do not

qualify as a corporate chain (see Section 2. 3.1.1.2

of the RFV). If you are currently authorized

by FNS as a corporate chain and have entered your FNS corporation number under question

D1, the full FNS-252 is not required. Click on “FNS-252-C” if you completed and included the

Corporate Supplemental Application form or click on “Chain spreadsheet” if you have access to

your existing chain spreadsheet and have added all required information applicable to your

website to a new line in the spreadsheet (see

Section 2.3.1.1.1).

Q3. Click on “Yes” if you have included scanned copies of photo IDs and Social Security Number

(SSN) documentation for every company owner and/or corporate officer, otherwise click “No”.

These are required for all applicants that completed the FNS-252 form (see Section 2.3.1.1.2

the RFV). Applicants eligible to submit a 252-C or corporation spreadsheet already have the

necessary photo IDs and SSN documentation on file with FNS and do not need to submit them

again.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 104

Q4. Click on “Yes” if you have included a scanned copy of your business permit (see Section

2.3.1.1.2 of the RFV), otherwise click on “No”. These are also required for all applicants that

completed the FNS-252 form.

Q5. Click on “Yes” if you have included scanned copies or screen shots of all notices and receipts

(See questions L2a and L6a), otherwise click on “No”.

Q6. Click on “Yes” if you have included your response to question O6 (security protocols and best

practices), otherwise click on “No”.

Q7. Click on “Yes” if you have included a separate response to question P1 (website policies),

otherwise click on “No”.

Q8. Click on “Yes” if you had insufficient room within any other text box(es) to respond to the

question(s) and it was necessary to continue the response in a separate document, otherwise

click on “No”.

Q9. Click on “Yes” if you responded “Yes” to question F2b and are attaching letters of support from

local government or non-profit groups, otherwise click on “No”,

Q10. If you responded “No” to Q1, Q3, Q4, Q5 or Q6 you must answer this question. Explain the

reason for each “No” response.

Section R – Assurances

Carefully read each assurance in this section and for each one click on “Yes” if you agree to follow the

requirement, click on “No” if you do not agree to follow the requirement, or click on “Qualified Yes” and

explain your issues and/or any additional conditions you wish to apply to the assurance. Be advised that

a “No” response to any of these assurances may be grounds for non-selection as a pilot participant.

Should a “Qualified Yes” explanation result in significant deviation from the intent of the assurance, FNS

reserves the right to consider it equivalent to a “No” response. The intent of each assurance is as follows:

R1. As indicated in Section 1.3.2.1

of the RFV, all pilot participants must use an FNS-approved

secure PIN-entry service provider for both purchases and refunds. At this time and until FNS

approves additional companies for this service, the only approved provider is Acculynk.

R2. As indicated in Section 2.4.1.5.2 of the RFV, EBT processors will only approve online purchase

transactions and PINless refunds from retailers specifically authorized by FNS as Internet

Retailers and will not approve any face to face POS or paper voucher transactions for Internet

Retailers. You must have a separate FNS authorization number to perform these face to face

transactions.

R3. As noted above for assurance R1, you must use Acculynk as your secure PIN-entry service

provider for this pilot. You will be required to sign a contract with Acculynk for those services

and adhere to their requirements and message formats. You must agree to negotiate with

Acculynk on terms and pricing if you are selected as a pilot participant. If you are unable to

come to agreement with Acculynk and fail to sign a contract, you will be dropped from the pilot

and your FNS authorization as an Internet Retailer will be terminated.

R4. As indicated in Section 2.4.2.6

of the RFV, the Agriculture Act of 2014 requires all Internet

Retailers to clearly identify all fees before completing the purchase transaction and explain that

they may not be paid for with SNAP benefits. If EBT customers are not willing or able to pay

these fees with an alternate tender they must be able to terminate the order before it is

finalized.

R5. As indicated in Section 2.4.5 of the RFV, EBT customers must receive their orders within 14

days if the retailer is a non-profit cooperative or a CSA. For all other Internet Retailers,

customers must receive their orders within seven calendar days unless the customer

specifically requests a later delivery date (see

Section 2.4.1.1.2). Refunds for overweight or out

of stock items must be issued immediately after completion of the order. All other refunds must

be issued within two business days (see

Section 2.4.1.2.1).

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 105

R6. As indicated in Section 2.4.1.2.3, of the RFV all refunds for online orders must be transmitted

through Acculynk in accordance with their message format requirements and because there

are no PINs required, the ability to generate refunds must be limited only to authorized

personnel.

R7. As indicated in Section 2.4.4 of the RFV, by law SNAP clients must be treated in the same

manner as other customers. There are some notable exceptions with the pilot requirements,

covered under the waivers in

Section 2.5. Section 2.5.7 provides the applicant with flexibility to

propose some limited additional deviation, which will also require a waiver. If so, the applicant

should respond to this question with “Qualified Yes” and explain their additional proposed

differences in the explanation box.

R8. As indicated in Section 2.5 of the RFV, the Online Purchasing Pilot will result in deviation from a

number of SNAP regulatory requirements. Therefore, FNS will issue a set of conditional

waivers, as explained in the RFV, to pilot participants and require written agreement from each

participant that they will abide by those conditions. Failure to do so will be grounds for

terminating your participation in the pilot and your authorization as an Internet Retailer.

R9. As indicated in Section 2.4.6.1 of the RFV all retailers participating in the pilot and performing

online transactions must be certified as PCI-compliant and must maintain that certification as

long as they are authorized by FNS as an Internet Retailer. Failure to do so will be grounds for

terminating your participation in the pilot and your authorization as an Internet Retailer.

Acculynk will validate compliance.

R10. As indicated in Section 2.4.1.1 of the RFV, retailers must never capture or store PIN data even

if it is encrypted. Customers must enter their PIN for every transaction (except for refunds) at

the time of the online purchase or balance inquiry and the retailer must turn over all

responsibility for PIN entry and capture to Acculynk.

R11. As indicated in Section 2.4.6.3 of the RFV, FNS will hold all retailer participants liable for any

monetary losses or other damage to EBT customers as described in the assurance. Retailers

are responsible for ensuring the security of PII data.

R12. As indicated in Section 2.4.6.4 of the RFV retailers may not share PII with outside parties

without the explicit permission of the EBT customer. This is true even if the terms and

conditions of the website for other customers allow such data sharing.

R13. As indicated in Section 2.4.6.1 of the RFV, Internet Retailers must have in place a security

program and best practices to protect PII, as reported in the response to question P1. Retailers

will be expected to maintain or improve this level of security as long as they are authorized by

FNS as an Internet Retailer.

R14. As indicated in Section 3.11.1 of the RFV, selected pilot participants will be required to report

on progress, challenges and results. FNS has opted to handle this through regular conference

calls with all appropriate parties to be held at mutually agreeable dates, times and intervals.

R15. As indicated in Section 3.11 of the RFV FNS will require documentation from each selected

participant such as, but not limited to, a project timeline, business requirements identification

and analysis; description of EBT related functional design changes to the system, work flow

and customer service; copies of changes to screens, notices and reports; and test results.

R16. As indicated in Section 3.11.5 of the RFV, participating retailers will be expected to thoroughly

test EBT system changes before putting them into production. This includes testing of

Acculynk message formats, end to end testing with the EBT processor, successful completion

of an FNS-developed test script, identification and correction of issues and regression testing.

FNS expects to participate in several days of onsite testing at the retailer’s facility.

R17. As indicated in Section 3.12.2.2 and Appendix F of the RFV, FNS will require selected retailers

to participate in a formal evaluation of the pilot. FNS has identified the type of data and

summary statistics that we expect our evaluation contractor to collect from each participating

retailer. This initial list may be modified during the course of the pilot. If the applicant is unable

to comply with any of the data collection and evaluation requirements in the above cited

sections, they should respond to this question with “Qualified Yes” and identify the areas of

concern.

R18. As indicated in Section 3.12.2.2 of the RFV, selected retailer participants must work with the

evaluation contractor to develop content and process flow for the retailer-initiated online

customer survey, and to identify a sample of EBT (and if applicable, commercial PIN debit)

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 106

customers for the evaluation contractor to conduct additional research through interviews or

other means.

R19. As indicated in Section 3.12.2.2

of the RFV, selected retailer participants must work with the

evaluation contractor to facilitate necessary interviews or site visits with appropriate retailer

staff, sampled customers and other key participants.

R20. As indicated in Section 3.12.2.2 of the RFV, selected retailer participants will be required to

assist FNS and the evaluation contractor, as needed, when issues occur and require resolution,

and be available to for consultation and input to refine evaluation procedures when appropriate.

R21. As indicated in Section 3.12.2.2 of the RFV the retailer must agree to exercise due diligence to

ensure the integrity of the evaluation and the quality of the data the retailer provides to FNS

and the contractor.

Section S – Privacy Act Statement

The individual signing the form must have the authority to make the assurances and commitments

identified in Sections R and S of the RFV Participation Application Form (see Section 3.9.2.4

of the RFV

for additional information).

On page 12, enter the name of the person that will sign the application in the box above “Print Name”.

Enter the date signed in the box above “Date Signed”. Enter the full title of the signer in the box above

“Print Title”. Print page 12, and once it has been signed, scan a copy of the signed page to include in the

application package. See Section 3.9.1

of the RFV for instructions on submission of the application,

signature page and attachments.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 107

Appendix E – FNS Retailer Application Forms

All applicants responding to the RFV must complete the appropriate FNS retailer

application form. Only chain stores that have an FNS ROD corporate contact and have

completed the FNS-252-C for brick and mortar stores in the past are eligible to submit

the FNS-252-C for this pilot. We already have the necessary documentation on file for

corporate applicants who are eligible to submit the FNS-252-C. Alternatively, the chain

may submit their updated chain spreadsheet. Please complete the form or spreadsheet

electronically as instructed in Section 3.9.2.2, FNS-252 SNAP Application for Stores, or

FNS-252-C FNS Corporate Supplemental Application, or Chain Spreadsheet, and

attach it to your response.

All other applicants must complete the full form FNS-252 and submit it along with

digitally scanned copies of the following documentation, as discussed in Section 3.9.2.3,

Additional Documentation for Retailer Application and Section 2.3.1.1.2, FNS-252-

Supplemental Nutrition Assistance Program Application for Stores, i.e.:

1. One current business license in your name or the name of your business

2. Government issued photo Identification for all owners, partners, and corporate

officers; and in Community Property States, spouses of owners and partners

3. Government issued Social Security Number documentation for all owners,

partners, and corporate officers; and in Community Property States, spouses of

owners and partners

The following pages contain facsimiles of the FNS-252 and FNS-252-C forms.

The forms on the following pages are facsimiles of the Adobe PDF files for the

application forms (FNS-252.pdf and FNS-252-C.pdf) used by retailers to

apply for authorization as an FNS SNAP retailer. These are contained in the

onlinepurchasing-rfv-application-packet.zip file along with this solicitation

document, available at SNAP Online Purchasing Pilot Request for Volunteers

Application Package. Please use the appropriate Adobe file based on your

corporate status and complete it electronically to submit with your final

response to this RFV.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 108

FNS-252

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 109

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 110

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 111

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 112

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 113

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 114

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 115

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 116

FNS-252-C

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 117

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 118

Appendix F – Evaluation Data Collection

Prior to developing the RFV, FNS met multiple times with a varied group of Internet

Retailers, Acculynk, EBT processors and other industry experts interested in the design

of the Online Purchasing Pilot. This was done to ensure that the pilot requirements

were workable and would not cause undue hardship for participating retailers. During

these calls we discussed the type of data that was available from the various parties

and would be useful for the pilot evaluation. All agreed that the data elements identified

in this Appendix could be shared with FNS for evaluation purposes.

The evaluation contractor and FNS will work closely with each data provider (EBT

processor, Acculynk, State agency and participating retailer) to identify the best sources

and methods of collecting the data, as well as timing and frequency. FNS proposes to

collect the following types of data, but reserves the right to collect additional information

that may be recommended by the evaluator or the data providers themselves.

If an applicant is unable to comply with any of the proposed requirements identified

below, they should respond to question R17 of the application with a Qualified Yes and

identify their areas of concern (see Section 3.9.2.1 for more information on such a

response).

X9.58 Transaction Data for EBT Transactions

FNS will collect the following transaction message data from the EBT processor.

However, in order for FNS to cross reference any transaction information that is only

available to the retailer, it may be necessary for the retailer to include some of these

elements as well.

• Terminal ID

• Card Acceptor ID Code

• Card Acceptor Name/Location

• National Point of Service Condition Code

• Merchant Type

• FNS Authorization Number (only for SNAP transactions)

• Card Number – last four digits

• Account Type (i.e., SNAP, cash)

• Transaction Type (e.g., purchase, refund)

• Amount

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 119

• Delivery Address Line 1

• Delivery ZIP Code

• Response Code

• SNAP Account Balance

• Cash Account Balance

• Settlement Date

Other PIN Debit Transaction-Related Data

FNS proposes to collect the following additional transaction level data directly from the

retailers. However, we realize that some retailers may only be able to provide summary

level statistics or averages for certain types of desired data. FNS will discuss this in

detail with each selected participant during the design phase of the project.

• Amount of time required for transaction from beginning of checkout to completion

of purchase

• Time between order and fulfillment

• Whether or not a refund was required at fulfillment and reason

o Weight estimate

o Out of stock

o Substitution

• Time between fulfillment and delivery

• Type of notifications and/or receipt(s) issued to customer (email, text, paper, etc.)

• Timing of receipt notification

• Delivery method (home delivery, pickup, commercial shipping, other)

Summary Level Data

FNS would like to receive the following information. The evaluation contractor will

determine in advance which data would be submitted monthly, quarterly or at the end of

the pilot. FNS will also work with Acculynk to determine which, if any, data is more

easily gathered through Acculynk instead of each retailer.

• Number and breakdown of orders placed online with EBT cards

o SNAP only

o Cash EBT only

o SNAP and cash EBT combo

o SNAP and credit/debit combo

o Cash EBT and credit/debit combo

o SNAP, cash EBT and credit/debit combo

• Number of orders placed online with commercial PIN debit cards

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 120

• Number of orders placed online with credit cards

• Number of repeat customers

o EBT customers

o Commercial PIN debit customers

• Number of new EBT customers

• Number of EBT customers that created online profiles

• Breakdown of EBT profiles by ZIP code

• Number of EBT orders placed by guests (no profile)

• High level breakdown by delivery type

o Company delivers to customer designated address

o Company delivers to preset distribution points

o Customer pickup at store or other company location

o Shipping by mail or parcel service

o Other

• Detailed breakdown by delivery type

o For home delivery

 Breakdown by ZIP code

 Unable to deliver (and reasons if available)

o For pickup/delivery at set alternate location

 Breakdown by location

 Failure to pick up

o For pickup in store or other company

 Breakdown by location

 Failure to pick up

o For shipping

 Breakdown by method (FedEx, UPS, USPS, etc.)

 Breakdown by ZIP code

 Success of shipping (on time, late, never delivered)

• Number of profiles with delivery addresses that do not match billing address

• Number of profiles listing multiple EBT cards

• Number of EBT cards listed in multiple profiles (e.g., many users list same card

number)

• Number of billing addresses listed in multiple profiles (many users living at same

address)

• Number of delivery addresses listed in multiple profiles (many users receiving

delivery at same address)

• Number of customers with more than one delivery address in profile

• Number of transactions using multiple tender

• Number of transactions performed by EBT cardholders using multiple cards for

SNAP-eligible foods

o Multiple SNAP cards

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 121

o Multiple Non-SNAP tenders

o SNAP and other tender(s)

• Types of tender used for non-SNAP costs on SNAP transactions and volume

breakdown

o Credit

o Signature debit

o PIN debit

o Gift card

o PayPal

o Other

o Cash on delivery

• Breakdown of store locations fulfilling orders (if that model used)

• Breakdown of warehouse locations for orders (if more than one)

o Number of transactions fulfilled from multiple warehouses by primary and

secondary locations

• Average time between order and

o Fulfillment

o Delivery/receipt

• Number of refunds issued to EBT cards

o To SNAP accounts

o To cash accounts

• Breakdown of reasons for refunds

o Overestimate of weight

o Out of stock item

o Order cancellation

o Dissatisfaction with product(s)

o Excessive time to complete order

o Non-receipt of order

o Other

• Breakdown of refund type

o Full

o Partial

o Reduced (e.g. money deducted to cover return shipping or original free

shipping is not allowed for SNAP but may affect other tender used by

SNAP clients)

• Number of refunds involving actual product return

• Breakdown of customer service calls received from EBT customers and reasons

Customer Survey Responses

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 122

FNS will require the selected retailers to conduct online surveys to collect data

regarding the customer experience and satisfaction. The retailer, FNS and the

evaluation contractor will need to work cooperatively to identify questions/content and

the optimal timing/methods for conducting the surveys, and to assure commonality of

approach across the Internet Retailers participating in this pilot.

FNS also expects the retailer to provide the data necessary for the evaluation contractor

to select a random sample of customers and to contact them directly for structured

interviews. Between the two efforts, FNS wishes to collect data from or through the

retailer to address the following:

• Satisfaction with the online shopping experience

• Satisfaction with the online checkout/payment process

• Perceived security of online payment process

• Time spent on shopping process prior to checkout

• e-Receipt method

• Satisfaction with e-receipt, when applicable

• Satisfaction with delivery process

• Satisfaction with delivery of paper receipt

• Satisfaction with refund process

• Ease of using multiple forms of payment

• Ease of order cancellation process

• Satisfaction with spoiled products policy

• Satisfaction with quality of perishable foods

• Challenges faced by clients using online payment systems

• Other comments and feedback as identified by retailer, evaluation contractor,

and FNS

Geospatial Analysis

FNS will require the evaluation contractor to perform geospatial and other analyses that

will require the SNAP client’s home address and the address of the closest large SNAP

authorized retailer, the date of benefit issuance, and other data which will require the

contractor to obtain administrative data from States participating in the pilot project or

their EBT processors, and from FNS itself. Unfortunately, the home address data on file

at State agencies and EBT processors is not always current. Therefore, FNS will

appreciate any assistance that the retailer can provide to cross match that data to the

billing addresses in their records in order to identify and share information about

discrepancies. FNS will discuss the retailer’s ability to assist with this effort at the time

of selection.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 123

Appendix G – ANSI Standard X9.58 Coding

X9.58 – Financial Transaction Messages – Electronic Benefits Transfer (EBT) –

Supplemental Nutrition Assistance Program (SNAP) and Cash Benefit Programs, is the

United States EBT version of the ISO 8583 standard. As noted in Section 2.2.4,

Technical Standards, all transactions received by EBT processors must be in the X9.58

format. For the Online Purchasing Pilot, this will actually be Acculynk’s responsibility,

not the retailer’s. Acculynk will provide their proprietary message format standard to

interested applicants. The information in this Appendix is provided primarily as

background for retailer technical staff.

A number of changes were made to X9.58 to accommodate online transactions. An

industry technical workgroup developed the necessary modifications, which will be used

for the duration of the pilot. These have since been incorporated into the 2013 version

of the standard. The full Standard is copyrighted by the X9 organization and therefore

cannot be shared with prospective applicants. It is available for purchase ($60.00) at

ANSI eStandards Store. However, the relevant information is summarized below.

For applicants already knowledgeable about EBT transactions, the online modifications

are summarized in Table G-1 below.

Table G-1 – X9.58 Modifications for Online Transactions

Bit

Data Element Name

Condition

3-1

Processing Code

Transaction type

For online purchases and refunds, the only valid

values are “01”, goods and services for purchases,

“02” debit adjustment, “20” returns for refunds, and

“22” credit adjustment.

3-2

and 3-

Processing Code

Account Types

For cash refunds, account type code 3-2 should

always be “00” and account type code 3-3 should

always be “96”. Therefore the full processing code

for an online cash refund should be “200096”.

22-1

Point of service entry

mode - Card reading

method

For online purchases and refunds, value = “01”,

manual (key entry).

22-2

Point of service entry

mode - Cardholder

verification method

For online purchases and refunds, value = “3”, online

PIN.

Point of service PIN

capture code

For online purchases, length of PIN captured (always

actual PIN length, e.g., “04”); for online refunds value

= “00”.

52 PIN data

Mandatory for online EBT purchase; not used for

online EBT refunds

58-1 Terminal class

For online purchases, value is “101”, unattended,

customer operated and off premises. For online

refunds, value is “111”, unattended, card acceptor

operated and off premises.

USDA FNS – SNAP EBT Online Purchasing Pilot Request for Volunteers Page 124

Bit

Data Element Name

Condition

58-2 Presentation type

For online purchases, value is “0100”, customer

present, card not present, device does not have card

retention capability and original presentment; for

online refunds; for online refunds, value is “1100,

customer not present, card not present, device does

not have card retention capability and original

presentment.

58-3 Security condition

For online purchases and refunds, value is “0”, no

security concern

58-4 Terminal type code

For online purchases and refunds, value is “25”,

Internet

111-1

Additional data dataset

identifier

“IT”, Internet Transaction

111-2

Additional data length

“037”

111-3 Additional data

Shipping address (ans 28) and shipping ZIP code (an

9); mandatory when terminal type code (bit 58-4) =

“25”

Applicants who are not currently accepting EBT at brick and mortar locations may also

wish to familiarize themselves with existing X9.58 coding that is unique to EBT. Key

data elements are listed in Table G-2.

Table G-2 – X9.58 EBT Specific Message Coding

Bit

Data Element Name

Condition

3 Processing Code

For cash purchases, value is “009600”, for SNAP

purchases, value is “009800” and for SNAP refunds,

value is “200098”.

54-1

Additional amounts,

account type

Value is “96” for cash EBT benefit, “98” for SNAP

EBT benefit

54-2

Additional amounts,

amount type

Value is “01”, ending balance

54-3

Additional amounts,

amount

Amount formatted as x + n 12

54-4

Additional amounts,

currency code

Value is “255”

111-1

Additional data dataset

identifier

“EB” (Required only for SNAP)

111-2

Additional data length

“007” (Required only for SNAP)

111-3 Additional data

FNS authorization number (n 7) (Required only for

SNAP)

Additional X9.58 changes may be needed based on lessons learned from the pilot.

These will be considered during the 2018 review of the X9.58 standard.

Download
Save PDF to desktop

Email
Email completed PDF

Send for Signing
Email for others to sign

Print
Print document

NAME

USDA Food and Nutrition Service Supplemental Nutrition Assistance (USDA Food and Nutrition Service)

View Audit Log
Print With Audit Log
Duplicate Document

Fill Online, Printable, Fillable, Blank USDA Food and Nutrition Service Supplemental Nutrition Assistance (USDA Food and Nutrition Service) Form

Related forms

Fillable USDA Food and Nutrition Service Supplemental Nutrition Assistance (USDA Food and Nutrition Service)

Fill Online, Printable, Fillable, Blank USDA Food and Nutrition Service Supplemental Nutrition Assistance (USDA Food and Nutrition Service) Form

Related forms

First 20 documents completely FREE!