Letter for States on Mandatory SNAP Employment & Training
The SNAP Employment & Training (E&T) programs were mandated federally in 1985 to help individuals in SNAP households improve their employability through skills development, training, and work experience. States have flexibility in designing these programs, which can be offered on either a voluntary or mandatory basis. In mandatory programs, some or all SNAP recipients are required to participate. States must provide at least one service from a federally approved list, which includes options like job search assistance, education, workfare, self-employment support, and job training.
The Food and Nutrition Act of 2008 (FNA) and 7 CFR 273.7 govern the responsibility of states that operate mandatory E&T programs. This guidance outlines those requirements and includes recommendations that are not legally binding. However, noncompliance may subject a state or local program administration to additional federal scrutiny and loss of federal funds:
Work requirements: States must require nonexempt SNAP recipients to register for work as a condition of eligibility.
Mandatory E&T Program participation: If a state operates a mandatory E&T program, nonexempt recipients must participate in assigned activities.
Submission of annual E&T State Plan: States must submit a plan each year to FNS for approval to receive funding.
Sanctions for noncompliance: States must sanction individuals who do not comply with work requirements without good cause.
Case management: States must provide case management services to support participants in E&T programs.
Participant reimbursements: States must reimburse participants for necessary expenses like transportation and dependent care related to E&T participation. The federal government reimburses 50 percent of these allowable expenses.
Reducing sanction rates: While not legally required, the guidance encourages states to reduce sanction rates, citing research that sanctions can negatively impact employment outcomes. The focus is on modifying program designs to prevent excessive sanctions, particularly in mandatory E&T programs.
Evaluation of outcomes: The guidance recommends periodic review of program outcomes, such as job placement rates, to ensure programs align with SNAP E&T goals.
While there are legal requirements states must follow in the design and administration of their SNAP E&T programs, such as recognizing good cause for participant failure to comply with program conditions, states retain significant discretion and are not mandated to adopt recommendations related to sanction rates or outcome evaluations. However, the guidance suggests that states with higher-than-average sanction rates in mandatory E&T programs may face additional scrutiny. It indicates that mandatory E&T programs are usually subject to an annual “Management Evaluation,” and if states are unable to address findings from these evaluations, they “may be subject to fiscal penalties.”
State officials should consider that, while the recommendations in this guidance are non-binding, failing to adopt them may lead to additional scrutiny through the Management Evaluation process and potential penalties. FNS may use these evaluations to penalize states that do not align with federal recommendations. For states without a mandatory E&T program, the guidance discourages adoption of such programs due to the risk of increased federal oversight.
Letter for States on Mandatory SNAP E&T
June 18, 2024
