SNAP Retailer Representation
If you run a store that accepts SNAP benefits, getting a notice that your SNAP authorization is withdrawn can feel like a punch to the gut. It stops your business from helping customers who rely on food assistance. But there's hope. Our team at Metropolitan Law Group has handled EBT license reauthorization cases just like yours.
In this article, we're going to discuss how we won a recent case where the USDA issued a SNAP authorization withdrawal against a Pensacola, Florida authorized retailer. The USDA first denied the retail food store's license reauthorization application, but we fought back. In the end, the withdrawal was rescinded and the store got its license reauthorized for another five year term.
This article will walk you through what a SNAP authorization withdrawal means for your store, why it happens, and how we use creative strategies to fix it. If you're facing this issue, read on. We offer help and an assistance program for SNAP reauthorization.
Understanding SNAP Authorization Withdrawals
The Supplemental Nutrition Assistance Program (SNAP) is designed to help low-income families buy food. Accordingly, Congress authorized the United States Department of Agriculture (USDA) to license retail food stores to participate in the program. An initial authorization is difficult to get, but once your application is granted you are licensed for 5 years.
Every five years after the store is authorized, you must go through the reauthorization process. This process usually involves updating your inventory, sales, and business information with the USDA's Food and Nutrition Service (FNS) through their online program. Unfortunately, there are a lot of problems baked into the computer program the USDA uses. This program, the Store Tracking, Authorization and Redemption System (STARS), is not user friendly and often rejects applications without a reason.
Reauthorizations usually involve four phases:
SNAP Reauthorization Application
The online SNAP reauthorization application can only be submitted once the Agency sends you a Reauthorization Customer Number and a password.
Document and Information or Production:
Once the Agency receives your reauthorization application and evaluates your revenue (looking to see what your sales numbers and percentages are), they'll ask you to produce records. Sometimes, these records include: personal and business tax returns; an affidavit reporting any criminal convictions the ownership may have since the last application; copies of any convictions or licenses that have been suspended; supplier invoices to prove your inventory records, and bills of sale for any new acquisitions.
Agency Evaluation:
The Agency will then look to see if your records show any new grounds for them to issue a licensure denial. Often times, the USDA will claim that you don't have enough food items to qualify, or that sales records indicate that you're a restaurant. However, the USDA evaluates your revenue with an eye to proving you wrong.
Store Visit:
The last step is usually a Store Visit from a third party contractor. During this visit, the Agency's contractor will complete a "Store Visit Report" which will discuss your inventory, business practices, and other items that affect your continued eligibility to participate in SNAP. They will take photos of your store, your cash register(s), the terminal you use to process debit cards/EBT cards, and your storage areas. After this phase, they may conduct another Agency Evaluation, but typically they issue the reauthorization.
As you might imagine, things go wrong with reauthorizations all the time, leaving stores to have their SNAP authorization withdrawn.
The Case: How SNAP Authorization Was Withdrawn and Then Reinstated
In November of 2024, the USDA sent a letter to one of our clients saying their SNAP authorization was withdrawn. The reason? The Agency claimed the store didn't respond to a reauthorization request two months prior, on September 20, 2024. According to the USDA, the September letter listed specific items that had to be produced: an affidavit about owners, copies of business licenses, articles of incorporation, property deeds or leases, bank letters, and tax returns.
The store owner was completely unaware of the September letter. He checked his mail and emails but found nothing from the USDA at all. The Agency couldn't even give him a delivery confirmation on the letter, so there was no trace it had ever reached the store. My client argued with the USDA's representative, and asked how could he could respond to something he never saw? The USDA's representative said he'd have to re-apply.
That's where we came in. We immediately filed a request for administrative review. This kept our client's SNAP license active, and allowed us to go over the representative's head to a different office. We submitted a thirty page brief in support of our client, and argued that the USDA failed to deliver the notice properly, breaking rules under 7 USC §2023.
But we didn't stop there. Since this was a reauthorization issue, not a violation for things like selling ineligible items, we argued that a fresh SNAP application was redundant. Our client had been authorized for years, so the Agency knew who the owners were and knew how our client's operations worked.
Our legal strategy was two-fold. First, challenge the delivery. The law requires proper notice and if the USDA can't prove they sent it correctly, the withdrawal might not hold. Second, we utilized our client's long history with the Agency to demonstrate that many of the records the Agency requested weren't really necessary. Utilizing our proprietary library of cases, we compared our client's authorization and notice issue to our past wins where the Agency reversed the SNAP authorization withdrawal.
Our strategy worked. By April 2025, we submitted a detailed brief to the Administrative Review Branch. In April of 2025, the USDA sent a new letter. They rescinded the decision to withdraw the store's SNAP authorization, and issued a reauthorization approval. This completed both the case and the application, and our client was finished with the process.
This win shows that even when the USDA says no, our firm can push back in an effective way and get our client reauthorized to participate in SNAP.
Why Choose Metropolitan Law Group for SNAP License Issues?
The fact is, we're experts in SNAP and Electronic Benefit Transfer (EBT) cases. In this authorization win, we turned a SNAP authorization withdrawal into a full renewal, all without our client losing any business. Better yet, we did so with a flat, fixed rate fee that saved our client money.
Our approach is simple: Listen to you, gather facts, and fight hard. We use the laws, our experience, and our proprietary case law library to your advantage. Many clients say we saved their stores. Many USDA program specialists hate us for it, but we're always proud to represent our retailers.
If your SNAP authorization is withdrawn, or you're worried it might be, reach out. Call us or fill out our contact form. We're here to help stores like yours get back on track.
EXPERT SNAP VIOLATION ATTORNEYS
The Most Wins in the Nation
Metropolitan Law Group features the most SNAP retailer success stories of any firm in the nation. For more than a decade, SNAP retailers have trusted our firm to protect their interests. No other firm has as many wins in SNAP trafficking, ineligible items, and authorization withdrawals than we do.
Best Pricing in the Industry
Our firm features fixed-fee pricing for our SNAP Violation Attorneys' representation to avoid large costs to our clients. A recent survey of other firms specializing in EBT licensing found that our prices were consistently lower than all of the other firms, and featured higher quality representation.
Industry Leading Legal Strategy
Since 2012, our attorneys have pioneered the best and most successful SNAP violation strategies in the nation. Our novel approaches to SNAP trafficking defense, ineligible item sales defense, and SNAP license application denials have resulted in hundreds of success stories for clients who otherwise would have lost their licenses.
Nationwide Representation
Our SNAP Violation attorneys represent retail food stores in all 50 states. We handle administrative cases, as well as Administrative Reviews, Judicial Reviews, and appeals. Our attorneys have appeared in matters before U.S. District Courts, U.S. Circuit Courts, and the United States Supreme Court. No case is too big or too small. Get your expert representation today.
