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USDA Food and Nutrition Service - U.S. DEPARTMENT OF AGRICULTURE DATE: November 14, 2025 SUBJECT: Supplemental Nutrition Assistance Program (SNAP) Questions and Answers on Quality Control (QC) Variance Exclusion TO: All SNAP State Agencies All Regions The Food and Nutrition Service (FNS) has issued a number of guidance documents on the implementation of SNAP related provisions in H.R. 1, the One Big Beautiful Bill Act of 2025 (OBBB). This memo provides answers to follow-up questions submitted by State agencies on the variance exclusion period for implementation of Section 10102: Modifications to SNAP Work Requirements for Able-Bodied Adults and Section 10103: Availability of Standard Utility Allowances Based on Receipt of Energy Assistance. A variance in SNAP QC represents a difference in an element of a basic program requirement or basis of issuance in which the information verified by the QC worker differs from the information used to certify the household. SNAP regulations at 7 CFR 275.12(d)(2)(vii) allow for a variance exclusion period during which States can exclude from the error rate any variances related to new SNAP regulations or changes in Federal law within the first 120 days of the required implementation date. State agencies with questions about this memo or other aspects of implementation, including requests for technical assistance, should contact their respective FNS regional office. Sincerely, Digitally signed by SASHA SASHA GERSTEN-PAAL Date: 2025.11.14 GERSTEN-PAAL 12:04:55 -05'00' For Ronald Ward Acting Associate Administrator Supplemental Nutrition Assistance Program Food and Nutrition Service Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314 USDA is an equal opportunity provider, employer, and lender. Guidance documents lack the force and effect of law, unless expressly authorized by statute or incorporated into a contract. USDA may not cite, use, or rely on any guidance that is not available through their guidance portal, except to establish historical facts.