Letter on Mandatory SNAP E&T

Dear State Commissioner:

In advance of state agencies submitting their SNAP E&T state plans for federal fiscal year 2025 (FY 25), the Food and Nutrition Service (FNS) is reminding states of the requirements states must meet when operating a mandatory E&T program. This letter and its attachment provide useful information to state agencies currently considering or implementing this policy option. FNS’ goal is to help state agencies fulfill the purpose of the SNAP E&T program, which is to provide opportunities for SNAP recipients to gain skills, training, work, or experience that will increase their ability to obtain regular employment. The FNS resource, State Responsibilities for Operating SNAP Employment and Training Programs, provides a comprehensive list of state requirements when operating SNAP E&T programs.

As state SNAP agencies grow and strengthen their SNAP E&T programs, states that operate mandatory programs are encouraged to periodically examine program outcome data, including program completion, job placement and sanctions, to evaluate whether their program continues to meet the purpose of SNAP E&T as defined in the Food and Nutrition Act of 2008, as amended (FNA). The FNA requires that states operate E&T programs that effectively prepare SNAP participants for employment and increase the number of SNAP participants who obtain and retain employment. FNS research has found that sanctions for non-compliance with E&T can negatively impact earnings and employment.¹ Similarly, studies that examine the effects of Temporary Assistance for Needy Families (TANF) sanctions find that individuals who are sanctioned have higher barriers to employment, often don’t understand the sanction process, and tend to be younger and are more likely to be Black. Furthermore, individuals who are sanctioned are less likely to be working than those who leave for other reasons, and those who are working tend to have lower earnings.²

States that operate programs with high sanction rates should consider program modifications to ensure that the program’s purpose of increasing participants’ ability to obtain employment is being met. The state’s E&T program planning process is an excellent opportunity to assess the need for such adjustments. The FNS’ SNAP to Skills project has created numerous resources to help states improve their E&T programs, including information on human centered design and workforce development best practices. The FNS SNAP E&T webpage also includes helpful resources, such as the Growing and Strengthening SNAP E&T Programs series. States can also find materials to help market their E&T program on FNS’ More than a Job webpage.

As a reminder, states must submit their annual state SNAP E&T plan by Aug. 15 for FNS approval to receive federal SNAP E&T funds. Plans not in compliance with the FNA may be denied funding and states can be required to resubmit plans until they meet the statutory requirements. Per SNAP regulations at 7 CFR 273.7(d)(1)(ii)(B), states must operate a SNAP E&T program regardless of whether federal SNAP E&T funds are received.

If you have any questions, please contact Rachel Gragg, Acting Director, SNAP Office of Employment and Training at Rachel.Gragg@usda.gov.

Sincerely,

Cathy Buhrig
Associate Administrator
Supplemental Nutrition Assistance Program
U.S. Department of Agriculture

Attachment

• Appendix

¹ Shiferaw, Leah, James Mabli, and Gretchen Rowe. Sanctions in SNAP E&T Mandatory Program: Lessons from the SNAP E&T Pilots, U.S. Department of Agriculture, May 2022.
² Kirzner, Rachel. TANF Sanctions: Their Impact on Earnings, Employment & Health. Drexel University. March 2015.