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SIGNAL DISPATCH

New York’s SNAP Transparency Playbook: File an Extension, Change the Date, Repeat

Published: March 24, 2026 - 7:18 AM UTC Updated: 8:49 PM CDT By: Jordan Pierce - Transparency & Data Reporter

The New York Office of Temporary and Disability Assistance has responded to two separate FOIL requests seeking SNAP fraud data with the same boilerplate email — four times. An appeal was denied. The records still don't exist.

Two FOIL requests, five months, repeated boilerplate responses, and no records produced.

Dim government hallway lined with filing cabinets and stacks of manila folders, with a heavily redacted document in the foreground symbolizing delayed public records and FOIL transparency issues.

New York’s Office of Temporary and Disability Assistance has a system for handling uncomfortable public records requests. It involves five sentences, a deadline that moves every 30 days, and an appeals officer willing to call a copy-paste job a “reasonable explanation.”

True Signal Media has been on the receiving end of that system since November 2025 — twice simultaneously. Two separate Freedom of Information Law requests. Two different reference numbers. One identical response, sent repeatedly, with nothing changed but the date.


THE TWO REQUESTS

On November 6, 2025, True Signal Media filed FOIL request R001374-110625 with the New York State Office of Temporary and Disability Assistance (OTDA), seeking records related to the agency’s reporting — or failure to report — SNAP program data to USDA’s Food and Nutrition Service during FY 2024 and FY 2025. New York was among 21 states that declined to share SNAP enrollment data with federal authorities, a fact publicly flagged by USDA Secretary Brooke Rollins.

Seven days later, on November 13, 2025, TSM filed a second request — R001416-111425 — seeking SNAP fraud data, nonprofit sponsor oversight records, and documentation of New York’s decision not to cooperate with federal data-sharing requests.

Two requests. Same agency. Same subject matter. Same stonewalling.


THE EXTENSION PLAYBOOK — R001374-110625

Here is the complete timeline of OTDA’s response to request R001374:

▸ November 6, 2025 — TSM files request. OTDA acknowledges same day, promises response within 20 business days.

▸ December 9, 2025 — Extension #1 issued. New deadline: January 30, 2026. Reason given: “the need for proper review and the limited resources available at the agency.”

▸ January 30, 2026 — Deadline passes. No records. No communication. Nothing.

▸ February 9, 2026 — TSM files appeal, citing constructive denial under Public Officers Law § 89(3)(a). The law is clear: failure to comply with a stated date certain constitutes a constructive denial.

▸ February 10, 2026 — One day after the appeal, OTDA responds. Not with records. With Extension #2. New deadline: March 20, 2026. Same boilerplate. Different date.

▸ February 24, 2026 — The Appeals Officer issues a formal denial of TSM’s appeal, ruling that OTDA’s boilerplate extensions constitute a “reasonable explanation” and that no constructive denial occurred.

▸ March 20, 2026 — Deadline passes. No records. No communication.

▸ March 23, 2026 — Extension #3 issued. New deadline: April 22, 2026. Same boilerplate. Different date.

That is 137 days from filing to the latest extension — with zero records produced and zero substantive explanation given at any point.


THE BOILERPLATE — READ IT CAREFULLY

Every extension OTDA has sent TSM on both requests contains the following text, word for word:

“The Office of Temporary and Disability Assistance (OTDA) is currently conducting a diligent search to determine whether records responsive to your request are available. The agency needs additional time to complete the response to this request, given the need for proper review and the limited resources available at the agency. We estimate the agency will complete its search for, and review of, any responsive records by [DATE]. We will notify you if and when agency records are available for release.”

That is the entire message. Five sentences. One variable: the date at the end.

No explanation of what makes this request complex. No description of what records have been located so far. No indication of why the previous deadline was missed. No acknowledgment that the January 30 deadline passed without any contact whatsoever.

These responses are identical across multiple requests and multiple months, with no individualized explanation for either request.

The language never changes. Only the date does.


SIDE BY SIDE — TWO REQUESTS, ONE RESPONSE

R001374-110625 — Extension issued December 9, 2025: “…the need for proper review and the limited resources available at the agency. We estimate the agency will complete its search for, and review of, any responsive records by January 30, 2026…”

R001416-111425 — Extension issued December 15, 2025: “…the need for proper review and the limited resources available at the agency. We estimate the agency will complete its search for, and review of, any responsive records by March 20, 2026…”

One was appealed. One was not. Both received identical language. Both missed their deadlines. Both received new extensions on March 23, 2026 — the same day — with identical language and the same new deadline of April 22, 2026.

The appeal did not change the agency’s handling. Extensions continued using identical language.


THE SECOND REQUEST — R001416-111425

Request R001416-111425 followed a slightly different path — and arguably a worse one.

Filed November 13, 2025, OTDA sent an acknowledgment on November 14 promising a follow-up within five business days. The next communication TSM received was December 15, 2025 — a full month later, well past the five-business-day window — containing the same boilerplate extension email, setting a response date of March 20, 2026.

TSM pushed back on December 30, 2025, citing that Illinois and Colorado had already produced comparable SNAP fraud data in standard timeframes, and proposing a phased production schedule to facilitate prompt disclosure.

OTDA’s response to that detailed, documented challenge? A single sentence directing TSM to the appeals process — with no actual decision, no exemptions cited, no explanation of what records exist or don’t exist, no acknowledgment of the substance of TSM’s letter.

When TSM pointed out that the response contained no actual determination, OTDA replied on January 6, 2026 stating that TSM had “written OTDA stating that you would like to appeal” — a characterization that was not accurate — and that OTDA had provided “the information on how to correctly file an appeal.”

This request was never formally appealed. On March 23, 2026, TSM received the same boilerplate extension on R001416, pushing the new deadline to April 22, 2026.


THE APPEAL DENIAL — AND WHAT IT REVEALS

The February 24, 2026 appeal denial from OTDA’s Appeals Officer is worth examining closely, because it reveals exactly how this system is designed to work.

The Appeals Officer concluded that OTDA had not constructively denied TSM’s request because — and this is the key line — the agency provided “a response date in the extension letters with a reasonable explanation for such extensions given the circumstances of the request.”

The “reasonable explanation” the Appeals Officer is referring to is this: “the need for proper review and the limited resources available at the agency.”

That phrase appears in every single extension email. It is not tailored to this request. It does not describe what records are being reviewed or why they require additional time. It is boilerplate. And the Appeals Officer of the agency that sent the boilerplate has now officially ruled that the boilerplate constitutes a reasonable explanation.

The Appeals Officer also cited the “expansive scope” of TSM’s request as justification for the delays — a fair point in isolation, except that comparable states processed similar requests in standard timeframes. Illinois produced responsive SNAP fraud data. Colorado produced responsive records. New York, with the largest state SNAP program in the nation, cannot find time to even acknowledge what records might exist after 137 days.


WHY THIS MATTERS BEYOND THE PAPERWORK

This is not a story about bureaucratic slowness. It is a story about a documented pattern of using the extension mechanism as an indefinite delay tactic on requests the agency would prefer not to fulfill.

Consider what R001374 actually asks for: records covering fiscal years 2024 and 2025. That is not a historical archive request requiring a dig through decades of files. That is current operational data — records OTDA is actively maintaining right now to meet its own federal reporting requirements to USDA-FNS. There is no legitimate search burden that turns current-year records into a five-month, four-extension project. Four extensions and 137 days later, OTDA has not produced a single page.

New York was among 21 states that declined to share SNAP fraud data with federal investigators following the $240 million Feeding Our Future fraud case in Minnesota. USDA Secretary Brooke Rollins publicly asked: "What are they hiding?"

TSM filed these requests specifically to answer that question — to find out what records New York holds about its own SNAP fraud rates, nonprofit sponsor oversight, and its decision not to cooperate with federal data-sharing requests.

Five months in, the answer from OTDA is the same five sentences it has been since December: we're looking, we need more time, here's a new date.

The pattern is the answer.


TIMELINE AT A GLANCE

R001374-110625

Nov 6, 2025 .............. Filed

Nov 6, 2025 .............. Acknowledged

Dec 9, 2025 ............... Extension #1 → Jan 30, 2026

Jan 30, 2026 .............. Deadline missed. No contact.

Feb 9, 2026 ............... TSM Appeal filed

Feb 10, 2026 .............. Extension #2 → Mar 20, 2026 (issued after appeal)

Feb 24, 2026 .............. Appeal DENIED

Mar 20, 2026 .............. Deadline missed. No contact.

Mar 23, 2026 .............. Extension #3 → Apr 22, 2026

Apr 22, 2026 .............. PENDING

R001416-111425

Nov 13, 2025 .............. Filed

Nov 14, 2025 .............. Acknowledged (5 business days promised)

Dec 15, 2025 .............. Extension #1 → Mar 20, 2026 (one month later, not 5 days)

Dec 30, 2025 .............. TSM challenges timeline, proposes phased production

Dec 30, 2025 .............. OTDA responds with only appeal instructions — no determination

Jan 6, 2026 ............... OTDA mischaracterizes TSM's letter as an appeal request

Mar 20, 2026 .............. Deadline missed.

Mar 23, 2026 .............. Extension #2 → Apr 22, 2026

Apr 22, 2026 .............. PENDING


WHAT HAPPENS NEXT

TSM has notified OTDA that we are tracking this pattern and documenting it publicly. Both requests remain open. The April 22, 2026 deadline applies to both.

If OTDA misses that deadline — as it has every previous deadline — TSM will pursue Article 78 proceedings in New York court, the only avenue remaining after an appeal denial under POL § 89(4)(b).

We will report every development.


SOURCE DOCUMENTS

SOURCE DOCUMENTS

All correspondence referenced in this dispatch is on file with True Signal Media and available in FOIA Commons:

• FOIL Request R001374-110625 (filed Nov 6, 2025)

• FOIL Request R001416-111425 (filed Nov 13, 2025)

• TSM Appeal — R001374 (filed Feb 9, 2026)

• OTDA Appeal Denial — R001374 (issued Feb 24, 2026)

• All extension correspondence — both requests

[Link to FOIA Commons →] Coming Soon!

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ABOUT THIS DISPATCH
Signal Dispatch is True Signal Media's format for deep analysis of ongoing investigations, FOIA campaigns, and systemic patterns in government accountability. These pieces connect the documents to the larger story.

PROTECT NO ONE. DOCUMENT EVERYTHING. truesignalmedia.news

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