SNAP/EBTLegal TopicsSelling SNAP- Eligible FoodsSNAP Training Requirements

Selling SNAP-Eligible Foods

Woodcut illustration of SNAP-eligible food

SNAP Training Requirements

Once a farmers market becomes authorized to accept SNAP benefits, FNS requires the market to train any employees—part-time, full-time, or volunteer—on how to comply with the federal requirements for selling SNAP-eligible foods.

  1. Is SNAP training required?
  2. Who must be trained?
  3. What are the training requirements?
  4. What happens if training requirements aren’t followed?
  1. Is SNAP training required?

    The statute and regulations governing the SNAP program do not directly require retailers (like farmers markets and direct marketing farmers) to train their personnel regarding SNAP rules.

    However, when farmers markets apply for SNAP authorization, the application process requires them to certify that they understand their “responsibility to ensure that training be completed for all of the owners and employees (paid or unpaid, full-time or part-time, including family members) working in their store.” On this basis, FNS expects that farmers markets ensure their personnel are trained.

    Additionally, having a training program in place can sometimes reduce penalties if a retailer violates SNAP regulations. When FNS finds that a retailer has violated SNAP rules, it can disqualify the retailer from accepting SNAP benefits. But the retailer may request a monetary penalty instead if it can show that it had policies in place to prevent SNAP violation, like “an effective personnel training program.” (See relevant statute and regulations.)

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  3. Who must be trained?

    According to the FNS, a SNAP-authorized farmers market is required to train “all of the owners and employees (paid or unpaid, full-time or part-time, including family members) working [there].”  Markets operating SNAP systems should train vendors, as well, as a violation of SNAP rules by a vendor (in a market-operated SNAP system) may result in penalties for the market.

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  5. What are the training requirements?

    FNS has published a resource on “SNAP Training Expectations.” This resource offers guidance on FNS’ expectations of SNAP training. The information below is derived from this resource.

    First, the market should review FNS training materials and SNAP Program rules.

    Second, the market should document SNAP training for all store owners, employees, volunteers, and new employees (within 30 days of employment), whether full-time or part-time. Markets operating SNAP systems should train vendors, as well. Documentation must include:

    • The names of the individuals trained;
    • The individuals’ dates of employment;
    • The date the training occurred;
    • A record of the materials used in the training;
    • Signatures of all participants to attest that they completed the training.

    Third, at least once each calendar year, the market should conduct a periodic, documented, SNAP “refresher training.” “Refresher training” documentation must include the same documentation as an initial SNAP training (listed above), as well as the date of the initial training.

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  7. What happens if training requirements aren’t followed?

    The market organization and its “responsible official” are responsible for fulfilling training requirements.

    A market may be penalized in three different ways for violating SNAP provisions.

    • First, FNS can disqualify the market from the SNAP program on a temporary or permanent basis;
    • Second, FNS can levy monetary penalties (fines) against the market;
    • Third, the market’s “responsible official” can be barred from future SNAP authorization.

    To learn more about penalties for violation of SNAP rules, generally, click here.

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Farmers Market Legal Toolkit