Policy Memo (140.20 KB)
| DATE: | March 14, 2016 |
| SUBJECT: | Supplemental Nutrition Assistance Program Employment and Training WIOA Unified and Combined State Plans |
| TO: | Regional Directors Supplemental Nutrition Assistance Program All Regions |
This memorandum provides guidance to state agencies on the Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) requirements when opting to submit E&T plan components as part of the Workforce Innovation and Opportunity Act (PL 113-128) Combined State Plan.
Background on WIOA and Combined State Plan Options
WIOA was signed into law on July 22, 2014. WIOA is designed to help job seekers access employment, education, training, and support services to succeed in the labor market and to match employers with the skilled workers they need to compete in the global economy. WIOA places an emphasis on targeting low-income adults and youth with limited training and skills to help them overcome barriers to economic self-sufficiency. It also emphasizes sector-based training and career pathways that respond to in-demand and emerging jobs and industries.
Under WIOA, states must outline a four-year strategy for the state’s workforce development system by developing a Unified State Plan that includes operational plans for the WIOA’s core programs. States have the option to submit a Combined State Plan that includes the core programs as well as additional federal employment and training programs, including:
- Employment and Training Programs under the Supplemental Nutrition Assistance Program (programs authorized under section 6(d)(4) of the Food and Nutrition Act of 2008 (7 USC 2015(d)(4)); and
- Work programs authorized under section 6(o) of the Food and Nutrition Act of 2008 (7 USC 2015(o))
With WIOA’s emphasis on services to low-income adults and job-driven training as well as the option to include SNAP’s employment, training, and work programs in the Combined State Plan, state agencies have an opportunity to advocate for the unique needs of SNAP clients in their state’s workforce development system.
States choosing to submit a Combined State Plan are required to incorporate all of the common planning elements required in the Unified State Plan, as well as additional elements describing how the state will coordinate the optional programs with the core programs and elements required by the optional program(s) that are included in the Combined State Plan. States that include SNAP E&T or Optional Workfare in the Combined State Plan are not required to submit separate plans to the Food and Nutrition Service (FNS).
The major content areas of the Unified or Combined State Plan include strategic and operational planning elements. More information on the WIOA Unified and Combined State Plan requirements and process may be obtained through the Training and Employment Guidance Letter (TEGL) published by the Department of Labor entitled TEGL 14-15 – Workforce Innovation and Opportunity Act (WIOA) Requirements for Unified and Combined State Plans. This TEGL is available at http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=3363.
SNAP E&T plan requirements
The SNAP E&T and Optional Workfare requirements included in the Information Collection Request (ICR) Workforce Innovation and Opportunity Act (WIOA) Unified and Combined State Plan Requirements, published under Office of Management and Budget (OMB) control number 1205-0522, are the requirements as specified for the SNAP E&T State Plan under 7CFR 273.7(c)(i) through 273.7(d)(vi) and §273.7(m). Because the WIOA Unified or Combined State Plan covers a four-year period, states that choose to include SNAP E&T or Optional Workfare in the Combined State Plan must provide details for each year covered by the Combined State Plan.
In order to ensure that sufficient information necessary for FNS to do a thorough and comprehensive review of the SNAP E&T requirements, states must provide a narrative response in the WIOA plan portal. In addition, state agencies must submit the tables described in Attachment 1 that provide the component details, participant levels, operating budget and fiscal year planned program costs to their FNS regional office. In the online WIOA plan portal, state agencies should indicate in their response that these elements have been transmitted to FNS.
Funds may not be available when SNAP E&T portions of a Combined State Plan under WIOA are approved. FNS’s obligation after approving a SNAP E&T plan submitted as part of a Combined State Plan is contingent upon the availability of an appropriation from which payment can be made. Any FNS funding resulting from an approval of a SNAP E&T plan submitted as part of a Combined State Plan is subject to FNS receiving sufficient funds (in the Program Financial Control System for FNS) to fund this and all prior approved SNAP E&T plans submitted as part of a Combined State Plan in their entirety in the time and date order received. Federal reimbursement to states for 50 percent of state administrative expenditures and for participant reimbursements is subject to the above conditions.
Instructions for Plan Submission
For the initial four-year Unified and Combined State Plans (July 1, 2016-June 30, 2020), states must submit their plans by April 1, 2016 using the online submission portal hosted by the Rehabilitative Services Administration (RSA) servers. The portal allows the entire State Plan to be available concurrently to the Departments of Labor, Education, Agriculture and other federal departments if their programs are included. The submission portal is available along with other State Plan resources at https://rsa.ed.gov/login.cfm?mode=form&usp=Y#skipnav. Instructions on how to request state user accounts are available on the web link provided. State SNAP agencies must designate a user to enter SNAP E&T requirements in the plan portal.
The portal will permit multiple users within a state to enter portions of the state’s plan at the same time. This will allow program partners to enter content specific to their program directly, as well as collaboratively enter content that is common to all state plan partners. Once state users enter all data and text into the portal, they may review the plan in its entirety, make edits and updates where needed, and view progress in entering plan information across programs. While multiple individuals in the state may enter content into the portal, only one individual may submit the entire plan on behalf of all included programs through the portal for Federal review. The portal includes a certification that the official state “submitter” has the authority to do so.
Initial State Combined Plan and Modifications
States that include SNAP E&T in the Combined State Plan that is due on April 1, 2016, should include SNAP E&T information relating to activities, operating budget, planned costs, and anticipated participation for federal fiscal years (FFYs) 2017 through 2020 using FFY 2016 as a basis. Once FFY 2017 allocation information is available, states must submit modifications to the SNAP E&T portion of the Combined State Plan in order to access the full allocation amount. Such modifications will be submitted through the online WIOA State Plan portal and to the FNS regional office.
Moira Johnston
Director
SNAP Office of Employment and Training