Policy Clarifications for Administering the SNAP Employment and Training Programs

During management evaluation reviews and technical assistance efforts, the Food and Nutrition Service (FNS) has identified many compliance issues in states that operate mandatory E&T programs that cause concern. This memorandum identifies and clarifies several statutory and regulatory requirements that state agencies operating mandatory E&T programs must implement to ensure adequate protections for SNAP applicants and recipients as well as proper administration of the program. Please distribute this memorandum as written to all state agencies, whether or not they operate a mandatory E&T program.

Screening for and Identifying Exemptions from the General SNAP Work Requirements

As a condition of eligibility for SNAP, certain household members must meet general work requirements. However, many household members are exempt from these work requirements for reasons such as age, fitness for work, childcare responsibilities, or because they are already employed or are in school. Among other requirements, non-exempt household members must register for work or be registered by the state and must participate in a SNAP E&T program or a workfare program if assigned by the state or they face disqualification. Given that a household member is at risk of losing SNAP benefits, it is extremely important that state agencies accurately determine whether a household member is exempt from the general work requirements.

Eligibility workers must determine whether an individual meets one of the Federal exemptions from the work requirements at application, recertification, and if appropriate, when changes in the household's circumstances are reported.  It is critical that eligibility workers understand these exemptions and that processes are in place to ensure that individuals are properly screened. The eligibility worker must explore whether the individual meets an exemption rather than placing the burden solely on the individual to self-report. The interview is the most important tool for identifying whether an individual meets an exemption. When the interview is conducted over the phone rather than in person, identifying exemptions can be more challenging, so it is critical that eligibility workers have resources and follow appropriate processes to ensure applicants and recipients are properly screened.