4-Step SNAP E&T Assessment Process
Step 2 – Conduct online research about SNAP E&T in your state/county
Step 3 – Estimate SNAP E&T funding
In order to participate in SNAP E&T, a social enterprise must first obtain approval from a SNAP E&T office or staffperson within a SNAP department or division (“SNAP agency”). Beyond the initial approval and planning phases, a social enterprise continuously interacts with a SNAP agency on processes of contracting, client eligibility determination for SNAP and SNAP E&T, reporting, billing, audit, and ongoing client coordination. A positive relationship with a SNAP agency will help these processes go smoothly.
A SNAP agency is usually located within a state human services agency – unless the social enterprise is in California, Colorado, Minnesota, North Carolina, North Dakota, New Jersey, New York, Ohio, Virginia, or Wisconsin, where it is typically found within a county human services agency. A state SNAP agency is overseen by the USDA Food and Nutrition Service, whereas a county SNAP agency is overseen by a state SNAP agency.
SNAP E&T exists in every state, but states have significant variations in their geographic coverage, services offered, program requirements, funding, and partnerships with community service providers.
The process for obtaining buy-in from a SNAP agency varies significantly by location. In many cases, buy-in is relatively easy. However, it is not uncommon for a county or state SNAP agency to choose not to partner with a social enterprise. Their reasons often include:
- insufficient capacity or interest in taking on a planning and oversight role
- lack of expertise in SNAP E&T partnerships
- lack of appreciation for community partnerships or the services offered
- preference for offering SNAP E&T services themselves, if competition is perceived
- concern for the quality of services of a potential community partner
- concern about liability
- concern for duplication of services
In many cases, approaching a SNAP agency carefully after determining the current environment of SNAP E&T in your SNAP agency’s jurisdiction is likely to improve the odds of getting to “yes”. Online research is an important first step in determining the current environment of SNAP E&T in your area and should ideally be completed before approaching your SNAP agency (Step 5).
The following online research tips are followed by suggested questions for and implications of your online research.
Online Research Tips
Search online for your state SNAP Employment & Training Plan. If the plan is online, it will be a rich resource that answers most of the questions below. If you live in a state with county SNAP agencies (as listed above), search for a similar county plan.
The USDA web page may link to your state’s SNAP website, which may also contain important information.
Search in your browser as well as news articles with the following terms: your state or county name in combination with SNAP Employment & Training, SNAP E&T, and/or your state’s name for SNAP Employment & Training.
Questions for Online Research
Please look online for answers to as many of the following questions as possible:
1. What is the state name for the SNAP benefit, if it is not called SNAP? What is the name of the SNAP agency?
2. Are nonprofits or other non-government entities providing SNAP E&T?
The SNAP agency is more likely to have an existing infrastructure through which it contracts with service providers such as a standard proposal or application process, processes for billing and reporting, etc. You may have a better chance of obtaining buy-in – unless they have closed the program to new service providers or have local requirements that don’t align with your social enterprise. Take note of the contact information for current service providers, including any social enterprises, in this step.
Also, look out for an intermediary agency that contracts with the SNAP agency and then subcontracts with SNAP E&T providers for purposes of oversight and billing. If this appears to be the case, when you get to Step 4 you may need to contact the intermediary instead of the SNAP agency.
The SNAP agency may not yet have made partnerships a priority, and may be less flexible about adding new partners. In this case, you may need a more extensive effort to obtain buy-in, as described in Step 4.
3. Does your SNAP agency operate a mandatory SNAP E&T program, where some or all non-exempt SNAP recipients must meet SNAP work requirements to maintain SNAP?
Non-participation may lead to temporary or permanent loss of SNAP benefits. Clients who lose SNAP are no longer eligible for SNAP E&T. See the box at the end of this page for more information on mandatory programs.
You may have more challenges with client eligibility for SNAP E&T, particularly if you are in a state where all SNAP E&T clients are mandatory and your program offers very limited hours, or your clients do not participate for a consistent number of hours.
Client eligibility for SNAP E&T will not be limited in this way. SNAP recipients may volunteer to participate in SNAP E&T without penalty for non-participation, unless they are ABAWDs (see ABAWD Work Requirements below).
4. Does your county or state have a SNAP Able-Bodied Adults without Dependents (ABAWD) waiver?
States without ABAWD waivers or with partial waivers may be found in the latest report on this USDA FNS web page. The areas without ABAWD waivers are expected to grow significantly in the future. In areas without ABAWD waivers, some SNAP recipients are required to participate in work and/or SNAP E&T activities at least 80 hours per month or participate in workfare in order to receive SNAP benefits more than 3 out of 36 months. See the box at the end of this page for more information on ABAWDs and ABAWD work requirements, which are different than work requirements of a mandatory SNAP E&T program.
There is almost no risk that ABAWDs in your social enterprise will lose SNAP eligibility due to ABAWD rules, no matter how few hours your social enterprise offers clients.
ABAWDs in your social enterprise may lose SNAP (and therefore SNAP E&T eligibility) if they spend less than 80 hours/month in work and/or SNAP E&T activities. In this case, you may want to augment the hours you offer ABAWDs or refer them to volunteer activities to make up a combined 80 hours. You can also offer workfare, with its lower requirement of 12 hours/month on average.
5. Is the SNAP agency restricting its SNAP E&T program to certain client demographics or services beyond those allowable at the federal level?
For example, the SNAP agency may only allow SNAP E&T services to be offered to ABAWDs, while your social enterprise also serves parents of young children, or the agency may only fund SNAP E&T vocational training, while your social enterprise also provides work experience.
You may be unable to bill SNAP E&T for all your clients and services that would otherwise be eligible under federal rules, because SNAP agencies are given tremendous discretion in how they design their programs. Please add any state-defined limitations into your estimate of federal funding in Step 4. If your clients or services fill a much-needed gap in the state and are otherwise allowable by the feds, you may want to highlight this in your messages to your SNAP agency in Step 5.
You should be able to bill SNAP E&T for all clients and services that are eligible under federal rules.
6. Is there a formal application process in place, a description of provider requirements, or a list of allowed services?
You may want to review the requirements to see if you qualify. If you qualify, you can skip Step 5 – unless you want to be especially careful that you are well-positioned to be accepted into the program. If you do not qualify, please complete Step 5. Either way, make sure to complete Step 4 before applying.
This is not a reason for concern. Please move on to Step 4 and 5 after completing this Step.
Two Types of Work Requirements That Might Impact Client Eligibility
SNAP Work Requirements
Healthy, non-elderly adult SNAP recipients without small children must register for work under federal rules, unless they are already working 30 or more hours per week or are otherwise exempt. Work registration requirements include registering with the state as looking for work, accepting a suitable job if offered one, and not voluntarily quitting or reducing hours of a job without good cause if the job is 30 or more hours a week, or the pay is equal to 30 hours at minimum wage (without good cause). Some SNAP recipients are exempted from work registration through reasons such as receipt of unemployment insurance or enrollment at least half-time in school, training or higher education.
States have discretion to add a SNAP work requirement in which some or all work registrants must participate in SNAP E&T on a mandatory basis. Participants in these mandatory SNAP E&T programs can lose their SNAP benefits for one to six months, or, in some cases, permanently, if they fail to participate in SNAP E&T for a minimum number of hours defined by the state [link to Question 3 above]. In order to attract SNAP recipients to mandatory programs, states can partner with trusted service providers that operate programs with a successful track record.
States can also choose to enroll work registrants and other SNAP recipients into a SNAP E&T program on a voluntary basis. These voluntary programs do not subject individuals to sanctions that reduce food security.
ABAWD Work Requirements
A smaller group of work registrants who are between 18 and 49 years old, not living in a household with a minor child or pregnant, and mentally and physically able to work are sometimes referred to as “Able-Bodied Adults Without Dependents” or ABAWDs. These recipients are generally subject to ABAWD time limits that only allow SNAP to be received for 3 months in a 36-month period, unless they are working and/or participating in a work program such as SNAP E&T for at least 80 hours per month, or participating in workfare for fewer hours. SNAP recipients who lose benefits due to this ABAWD time limit may regain eligibility after they have met work requirements for 30 days. States may also exempt 12 percent of their ABAWD caseload from the ABAWD time limit.
States have the option of waiving ABAWD time limits in areas of high unemployment. However, fewer states can utilize these ABAWD waivers lately as a result of reduced unemployment rates, and pending federal rules can significantly limit ABAWD waivers in the future. Some states have new interest in expanding SNAP E&T programs as a way of helping unemployed and under-employed workers meet ABAWD work requirements and avoid time limits.
If the answers to your online research are positive or you cannot find much information online, you are ready to move on to Step 4.
If the answers are not what you’d expected, you may still be able to make a SNAP E&T program work for you. For example, you can ask your SNAP agency to include nonprofit providers even if they have not so far, or to expand their target population and services. However, it may take some time and effort to persuade the SNAP agency. If you are hoping for an easy fit without any extra effort, you may choose to end the assessment process at this point.
More information on the potential for federal drawdown and influence strategies are available in Steps 4 and 5.