California Department of Social Services – FOIA Case R011032-110725 – SNAP Data Reporting to USDA-FNS

R011032-110725
Pending

Summary

FOIA request submitted to the California Department of Social Services seeking administrative and policy records concerning the agency’s reporting of Supplemental Nutrition Assistance Program (SNAP) data to the U.S. Department of Agriculture Food and Nutrition Service (USDA-FNS) during FY 2024 and FY 2025

The request seeks records related to internal deliberations or directives concerning delayed or withheld SNAP data submissions, communications with the Governor’s Office or federal officials, guidance from USDA or HHS, and documents citing statutory, procedural, or political rationale for modifying or suspending reporting

It also seeks impact assessments or internal analyses regarding the effects of data non-submission on eligibility verification, funding, or public transparency, as well as policy materials referencing “data audits,” “data integrity reviews,” or “cleanup campaigns” since October 2023

This request is limited to administrative and policy records and expressly excludes personally identifiable recipient data

Procedural History & Updates

  • November 6, 2025 – California Public Records Act request received by California Department of Social Services (CDSS) (Reference No. R011032-110725).

  • May 6, 2025 – USDA issued initial letter to State agencies referencing Executive Order 14243 and requesting SNAP participant data from January 1, 2020 to present.

  • July 9, 2025 – USDA announced creation of the National SNAP Information Database (USDA/FNS-15) and required state data submissions.

  • July 23, 2025 – USDA issued data transmission directive detailing required data elements and establishing July 30, 2025 submission deadline.

  • July 25, 2025 – USDA issued compliance reminder letter stating failure to transmit data by July 30, 2025 may trigger noncompliance procedures.

  • July 29, 2025 – CDSS formally responded, stating it would not transmit the requested data and referencing pending multi-state litigation challenging the database.

  • August 12, 2025 – USDA issued advance notice to the Governor asserting California was out of compliance and warning of potential suspension or disallowance of SNAP administrative funding.

  • August 15, 2025 – Extended federal deadline for submission of SNAP participant data.

  • August 20, 2025 – USDA issued formal warning letter stating that failure to comply may result in disallowance of up to $338,326,748.10 per quarter in federal SNAP administrative funding.

  • August 19, 2025 – CDSS responded disputing USDA’s deadline and reiterating litigation-based objections.

  • September 18, 2025 – U.S. District Court for the Northern District of California issued order in California v. USDA, temporarily enjoining USDA from acting on the August 20, 2025 formal warning letter, including disallowance of SNAP funding.

  • September 19, 2025 – CDSS notified USDA that enforcement actions and compliance deadlines are stayed pending further court action.

  • February 9, 2026 – CDSS issued partial production of responsive records and stated additional supplemental productions are anticipated.

Request Details

Agency California Department of Social Services (CDSS)
Filed By True Signal Media (TSM)
Date Filed November 5, 2025
Statutory Deadline November 21, 2025

Document Types

FOIA Request

Investigation Campaigns

SNAP Fraud

Case Records

FOIA Request – 2025-11-07
Released: November 7, 2025
Original FOIA submission seeking administrative and policy records regarding California SNAP data reporting to USDA-FNS during FY 2024–FY 2025.
Download PDF (29 KB)
Partial Response – 2026-02-09
Released: February 9, 2026
CDSS partial production of responsive records with notice of continued rolling review and anticipated supplemental production.
Download PDF (162 KB)
USDA Letter to State Agencies – 2025-05-06
Released: May 6, 2025
USDA Food and Nutrition Service letter to state agencies referencing Executive Order 14243 and directing states and SNAP payment processors to provide comprehensive SNAP data, including personally identifiable information, to USDA.
Download PDF (274 KB)
USDA Follow-Up Letter to SNAP Agencies – 2025-07-09
Released: July 9, 2025
USDA letter to SNAP state agencies announcing creation of USDA/FNS-15 National SNAP Information Database and requiring SNAP data submissions from EBT processors or states beginning July 24, 2025.
Download PDF (616 KB)
USDA Data Transmission Directive – 2025-07-23
Released: July 23, 2025
USDA directive detailing required SNAP data elements, transmission procedures via Box platform, and July 30, 2025 deadline for state data submission.
Download PDF (277 KB)
USDA Compliance Warning Letter – 2025-07-25
Released: July 25, 2025
USDA letter reminding state agencies of July 30, 2025 SNAP data submission deadline and warning that failure to comply may trigger noncompliance procedures under 7 U.S.C. 2020(g).
Download PDF (114 KB)
CDSS Response to USDA Data Request – 2025-07-29
Released: July 29, 2025
California Department of Social Services letter declining to transmit SNAP participant data to USDA by the July 30, 2025 deadline, citing multi-state litigation, legal concerns, and technical impossibility.
Download PDF (168 KB)
USDA Noncompliance Notice to Governor – 2025-08-12
Released: August 12, 2025
USDA letter to Governor Gavin Newsom asserting California is out of compliance with SNAP data transmission requirements and warning of potential suspension or disallowance of federal SNAP administrative funding.
Download PDF (247 KB)
CDSS Response to USDA Noncompliance Notice – 2025-08-19
Released: August 19, 2025
California Department of Social Services letter responding to USDA’s August 12, 2025 noncompliance notice, reiterating pending multi-state litigation, requesting withdrawal or stay of data demands, and disputing feasibility of federal deadlines.
Download PDF (190 KB)
USDA Formal Warning & Funding Disallowance Notice – 2025-08-20
Released: August 20, 2025
USDA formal warning letter to California Department of Social Services stating that failure to comply with SNAP data transmission requirements may result in disallowance of up to $338,326,748.10 per quarter in federal SNAP administrative funding pursuant to 7 C.F.R. § 276.4
Download PDF (150 KB)
CDSS Response Following Court Injunction – 2025-09-19
Released: September 19, 2025
California Department of Social Services letter informing USDA that a federal court in California v. USDA temporarily enjoined USDA from acting on its August 20, 2025 formal warning letter, including disallowance of SNAP funding, and that related compliance deadlines are stayed pending further court action
Download PDF (178 KB)
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