Appendix H Employment and Training Toolkit June 2021

Appendix H - SNAP E&T Toolkit

United States Department of Agriculture
Food and Nutrition Service

Supplemental Nutrition Assistance Program
Employment and Training Program
Toolkit
Revised 2021

Food and Nutrition Service
U.S. Department of Agriculture
Revised June 2021 1

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Issuing
Agency/Office:
Title of
Document:
Document ID:
Z-RIN:
Date of
Issuance:
Replaces:
Summary:

FNS/SNAP
SNAP E&T Toolkit 1
[leave blank]
[leave blank]
June, 16, 2021
Document replaces earlier version of the State E&T Toolkit
Provides guidance to State agencies to develop their E&T programs

FNS intends to seek OMB approval for the State agency and E&T provider burden associated with reviewing
the SNAP E&T Toolkit.

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INTRODUCTION ..................................................................................................................................................... 5
USE OF THE TOOLKIT ................................................................................................................................................5
ACKNOWLEDGEMENTS..............................................................................................................................................6
CHAPTER 1 – E&T PURPOSE AND PROGRAM DESIGN ............................................................................................. 7
PURPOSE OF SNAP EMPLOYMENT AND TRAINING (E&T)................................................................................................8
DESIGNING AN E&T PROGRAM WITHIN THE WORKFORCE DEVELOPMENT SYSTEM ...............................................................9
E&T STATE PLANS .................................................................................................................................................12
STATE AGENCY RESPONSIBILITIES ..............................................................................................................................14
CASE MANAGEMENT IN E&T ...................................................................................................................................16
E&T COMPONENTS ...............................................................................................................................................19
WORKFARE ..........................................................................................................................................................27
WORKFORCE PARTNERSHIPS ....................................................................................................................................29
WORK SUPPLEMENTATION ......................................................................................................................................29
CIVIL RIGHTS AND SNAP E&T .................................................................................................................................30
CHAPTER 2 – E&T ELIGIBILITY AND PARTICIPATION ............................................................................................. 32
GENERAL WORK REQUIREMENT ...............................................................................................................................33
E&T ELIGIBILITY ....................................................................................................................................................34
ABLE BODIED ADULTS WITHOUT DEPENDENTS ............................................................................................................37
SCREENING, ASSESSMENT, AND REFERRAL IN E&T .......................................................................................................40
PARTICIPANT REIMBURSEMENTS...............................................................................................................................44
NON-COMPLIANCE WITH MANDATORY E&T...............................................................................................................47
GOOD CAUSE .......................................................................................................................................................49
PROVIDER DETERMINATIONS ...................................................................................................................................51
E&T PARTNERS.....................................................................................................................................................53
REPORTING ..........................................................................................................................................................56
CHAPTER 3 – FUNDING ........................................................................................................................................ 63
FUNDING BASICS ...................................................................................................................................................64
FUNDING REALLOCATIONS.......................................................................................................................................67
ABAWD PLEDGE FUNDING.....................................................................................................................................69
CHAPTER 4 – ALLOWABLE COSTS ......................................................................................................................... 73
ALLOWABLE COSTS - GENERAL .................................................................................................................................74
ALLOWABLE COMPONENTS AND RELATED E&T COSTS..................................................................................................81
THIRD PARTY REIMBURSEMENTS ..............................................................................................................................84
CASH DONATIONS .................................................................................................................................................86
IN-KIND EXPENSES .................................................................................................................................................88
BUILDING SPACE ...................................................................................................................................................92
PROPERTY PROCUREMENT AND MANAGEMENT ...........................................................................................................94
INDIRECT COST POLICY ...........................................................................................................................................95

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Introduction
The purpose of this Toolkit is to provide State agencies with guidance and resources to
plan and implement Employment and Training (E&T) Programs under the Supplemental
Nutrition Assistance Program (SNAP, formerly called the Food Stamp Program). In
1987, Congress established the Food Stamp Employment and Training Program to
assist able-bodied food stamp recipients in obtaining employment. From its conception,
the purpose of the E&T Program has been to help SNAP households gain skills,
training, work, or experience that will increase self-sufficiency and help participants
move into better jobs.
Since the publication of the previous version of the Toolkit, the Agricultural Act of 2014
(also known as the 2014 Farm Bill) and the Agriculture Improvement Act of 2018 (also
known as the 2018 Farm Bill) made several significant improvements to E&T. Through
these pieces of legislation, Congress tasked the Department and State agencies with
reviewing and bolstering the quality and accountability of E&T programs for SNAP
participants, while retaining State flexibility. Many State agencies are stepping up to
provide targeted trainings and work supports to help SNAP participants gain the skills
needed to succeed in an ever-changing labor market.
All State agencies must implement an E&T program consisting of at least one E&T
component and case management. In addition, E&T programs must be provided
through the statewide workforce development system, and State agencies must consult
with the State workforce development boards, or local employers or employer
organizations, if that would be more effective or efficient, in the design of their E&T
programs. As State agencies work to improve their E&T programs through partnership
with the local workforce development system, the following chapters provide guidance
on the following aspects of an E&T program:
•

Chapter 1 - reviews the purpose and program design of E&T programs;

•

Chapter 2 - reviews E&T eligibility and participation;

•

Chapter 3 - reviews E&T funding; and

•

Chapter 4 - reviews allowable costs.

Use of the Toolkit
This Toolkit is designed to build a foundation of the policy knowledge that State
agencies may need as they sustain and grow their E&T programs. In addition to being
a policy resource for State agencies, the Toolkit may also be helpful as a training
resource for onboarding new staff, a primer for potential providers, or a go-to resource

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for existing staff. Some of the material in this Toolkit is tied directly to the Food and
Nutrition Act of 2008 (the act) and SNAP regulations. Other material, such as Statespecific examples and recommended best practices are not Federal requirements, but
are meant to be resources that may help State agencies better meet the employment
and training needs of low-income households. Links within the document lead to other
sections of the document itself or helpful Internet resources.
As a living document, this Toolkit will be updated periodically to reflect new information
on best practices, updated resources, and changes to Federal legislation or regulations.
If you have comments or questions on this Toolkit, you can contact your Regional Office
for more information. The Food and Nutrition Services (FNS) encourages State
agencies to share tools that can be included in future updates to this Toolkit, such as
desk guides, evaluation forms, or proposals that will improve the efficiency and
effectiveness of SNAP E&T programs.

Acknowledgements
FNS would like to acknowledge and thank the staff, State partners, and nongovernment organizations who have provided important feedback on Toolkit updates.

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Chapter 1 – E&T Purpose and
Program Design

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Purpose of SNAP Employment and
Training (E&T)
What is the purpose of a SNAP E&T program?
The Food and Nutrition Act (the Act) of 2008 provides that the purpose of the
Employment and Training (E&T) program is to provide Supplemental Nutrition
Assistance Program (SNAP) participant’s opportunities to gain skills, training, work, or
experience that will increase their ability to obtain regular employment and meet state or
local workforce needs. Additionally, the E&T program offers a way for SNAP recipients
to meet work requirements stipulated in the Act.

What makes up a SNAP E&T program?
All SNAP E&T programs must provide case management and at least one E&T
component. State agencies have a lot of discretion in the design of their programs, but
must submit an annual State E&T plan to Food and Nutrition Service (FNS) for review
and approval.

Does a State have to operate a SNAP E&T program?
Yes. The Act requires all State agencies administering a SNAP program to operate an
E&T program.

How much flexibility does a State agency have in designing their E&T
program?
State agencies have a lot of flexibility in designing their SNAP E&T programs. As stated
above, all State agencies must provide case management and at least one E&T
component; however, State agencies have discretion within broad statutory and
regulatory boundaries to determine how their E&T program will operate. For instance,
State agencies have discretion to determine the types of activities and services that will
be offered within components, the entities that will provide those activities and services,
the target population for services, and the areas of the State where the E&T program
will operate.
A State agency should tailor its E&T program to meet the needs of participants and the
local workforce needs, thereby increasing the likelihood of recipients gaining the skills
and credentials they need to obtain a better job.

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What is an effective State E&T program?
State agencies are tasked with delivering high-quality E&T programs that demonstrate a
commitment to the values of equity 2, inclusion, and equal opportunity for those who are
served. The best E&T programs promote access, remove barriers, and effectively
support all E&T participants to ensure they gain the skills and credentials needed to
succeed at new and better jobs, all while maintaining access to much-needed nutrition
assistance. FNS highly encourages State agencies to examine program impact by race
and ethnicity, and make program improvements to support equity, inclusion, and equal
opportunity.

Designing an E&T Program within the
Workforce Development System
What is the workforce development system?
The workforce development system can be generally defined as the organizations and
activities that prepare people for employment, help workers advance in their careers,
and ensure a skilled workforce exists to support local industry and the local economy
over time. An effective workforce development system ensures job seekers can obtain
the skills and credentials they need to move toward economic self-sufficiency, and
employers have the skilled workforce they need to grow their businesses and drive
strong local economies. Organizations in the workforce development system can
include, but are not limited to, American Job Centers, State and local workforce
development boards, community colleges, government agencies, community based
organizations, adult education and English Language Learner (ELL) service providers,
employers and industry, and other occupational training providers. E&T plays an
important role in the workforce development system by connecting SNAP participants to
workforce development services and providing supports that help SNAP participants
persist and succeed in workforce development services.

The term “equity” means the consistent and systematic fair, just, and impartial treatment of all individuals,
including individuals who belong to underserved communities that have been denied such treatment, such as
Black, Latino, and Indigenous and Native American persons, Asian Americans and Pacific Islanders and other
persons of color; members of religious minorities; lesbian, gay, bisexual, transgender, and queer (LGBTQ+)
persons; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by
persistent poverty or inequality. (Executive Order 13985)
2

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Does the State agency need to work with the workforce development
system?
Yes. Partnering with effective providers in the workforce development system can help
State agencies improve employment outcomes for SNAP participants and ensure that
State agencies have available services to meet the unique barriers and employment
goals of SNAP participants. Regulations at 7 CFR 273.7(c)(5) require that each
component of the State agency’s E&T program must be delivered through its statewide
workforce development system, unless the component is not available locally through
such a system.
In addition, the regulations require that all State agencies design and implement E&T
programs in consultation with the State workforce development board, or in consultation
with private employers or employer organizations, if the State agency demonstrates that
this would be more effective or efficient. FNS has long encouraged State agencies, as
a best practice, to regularly reach out to leaders within the broader workforce
development system to make use of their employment networks, data on workforce
needs, and other resources.

What is the State workforce development board?
The State workforce development board is a unique entity, created under the Workforce
Innovation and Opportunity Act (WIOA), separate from the State Department of Labor or
local workforce development boards. The State workforce development board is
established by the Governor, and is charged with assisting the Governor oversee the
State’s workforce development system. Professional staff, such as an Executive
Director, commonly support the members of the State workforce development board.

How should the State agency consult with the workforce development
boards?
The requirement that State agencies consult with the State workforce development
board, or employer organizations, if this would be more effective or efficient, in the
design of their E&T program allows the State agency to capitalize on the expertise of
the board, or employers, by seeking input on topics such as, but not limited to:
•

What are the in-demand and high growth occupations in the State and local
communities?

•

What skills, certificates, or credentials do employers in high-growth and indemand industries prioritize when making hiring decisions?

•

Are there workforce development service providers the State agency should
be working with to become E&T providers?

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•

What is the role for the State’s American Job Centers in serving SNAP
participants? How can E&T support American Job Centers in serving E&T
participants?

State agencies must demonstrate that they consulted in the E&T State plan, and include
the outcomes of that consultation. One way State agencies could demonstrate they
consulted with their State workforce development board, or employers or employer
organizations, if this would be more effective or efficient, would be to include in their
E&T State plan information about: when they consulted with their State workforce board
(i.e. the date(s) of these conversations); who they spoke with; what they spoke about;
and how they incorporated this information into the design of their E&T program. State
agencies may also develop their own methods for demonstrating their consultation with
their State workforce development board, or employers or employer organizations, as
applicable.

How should the State agency coordinate with WIOA title I programs?
State agencies are required to include in their E&T State Plan the extent to which they
are coordinating with title I of the Workforce Innovation Opportunity Act (WIOA). FNS
encourages State agencies to coordinate E&T services with WIOA title I, to the extent
appropriate services are available.
WIOA includes five titles: Workforce Development Activities (title I), Adult Education and
Literacy (title II), Amendments to the Wagner-Peyser Act (title III), Amendments to the
Rehabilitation Act of 1973 (title IV), and General Provisions (title V).
Title I, whose programs are primarily administered through the Employment and
Training Administration (ETA) of the U.S. Department of Labor (DOL), includes the
Adult, Dislocated Workers, and Youth State formula grant programs, multiple national
programs, and Job Corps. WIOA title I authorizes programs and activities that support
job training and related services to unemployed and underemployed individuals. WIOA
title I also establishes the brick-and-mortar system of American Job Centers as a means
of delivering and coordinating workforce development activities.
When considering the extent of coordination of E&T services with WIOA title I programs,
State agencies should primarily focus on if and how SNAP E&T participants will utilize
WIOA Adult services through the American Job Centers. Basic employment services
commonly available through the WIOA Adult program include, but are not limited to,
intake and orientation, initial assessment of skill levels including literacy, numeracy, and
English language proficiency, as well as aptitudes, abilities (including skills gaps), and
supportive service needs, the development of an individual employment plan (IEP), and
job search activities. Additional services up to and including skills training may also be
available through the WIOA Adult program.

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State agencies that choose to utilize WIOA title I services as part of their E&T program
should have a clearly articulated vision for the types of services E&T participants will
receive through the American Job Centers. When State agencies use E&T funds to pay
for WIOA title I services, these services should be above and beyond those services
that are readily available to the general public through the American Job Centers. While
State agencies can capitalize on the workforce development expertise and
infrastructure available through the American Job Centers, they remain responsible for
ensuring that E&T participants receive case management and participant
reimbursements, and receive appropriate employment and training services. The State
agency must also include individuals who receive E&T services under WIOA title I in
their Annual Outcome Report.

E&T State Plans
What is an E&T State plan?
An E&T State plan is an annual document submitted by the State agency to FNS for
review and approval describing the State’s E&T services and activities for the upcoming
year including the State’s E&T budget. Regulations at 7 CFR 273.7(c)(6) outline the
required elements of the annual E&T State plan. To facilitate the collection of State
plan information, FNS has developed an E&T State Plan Template for State agencies to
use when they submit their plans. Additional information about the information
requested in the E&T State Plan Template can be found in the E&T State Plan
Handbook. All E&T State plans are public documents.

Can a State agency receive reimbursement for E&T services without
an approved E&T State Plan?
No. FNS may only reimburse a State agency for allowable E&T activities included in an
approved E&T State plan. State agencies may submit updates to their E&T State plan
through a State plan amendment to FNS for review. State agencies may conduct E&T
activities outside an approved E&T State plan or State plan amendment, but the State
agency risks not being reimbursed if FNS does not later approve the E&T State plan or
State plan amendment.

When are E&T State plans due?
E&T State plans for the upcoming fiscal year are due August 15th. It is very important
that State agencies submit their E&T State plans on time to allow FNS sufficient time to
review and approve the plan before the start of the Federal fiscal year on October 1st.

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What should a State agency do if they want to change their E&T State
plan?
State agencies that want to change their E&T State plan should submit an E&T State
plan amendment to their FNS Regional office. State agencies should wait for FNS
approval before implementing the change, or else risk not being reimbursed if the
amendment is denied. The proposed changes must be submitted for approval at least
30 days prior to planned implementation.

What types of changes require an E&T State plan amendment?
If a State agency plans on making significant changes to its E&T State plan, the State
agency must submit plan revisions to the appropriate FNS Regional office for approval.
The following are examples of changes that require a formal modification of the E&T
State plan:
•

Major changes in components (e.g., adding, deleting, or modifying a component).

•

Significant changes in State policy (e.g. major changes to State E&T
exemptions).

•

When FNS approves the State agency’s request for additional 100 percent
Federal funds and the funds will be used to make significant changes to the State
E&T program.

•

Changes in the amount of 50 percent reimbursement funds requested.

•

Change in the method of providing participant reimbursements.

•

Shifting 50-50 funds between administrative and participant reimbursement
categories.

•

Adjustments to outcome reporting measures or methodology for data collection.

•

The SNAP E&T budget exceeds $100,000 and there is a change in activities that
result in a change of 5 percent or greater of the total program budget.

•

Amounts budgeted for indirect costs are transferred to absorb increases in direct
costs.

What is a WIOA Combined State plan?
WIOA was 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. Under WIOA, States must outline
a four-year strategy for the State’s workforce development system by developing a

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Unified State Plan that includes operational plans for WIOA’s core programs and
mandatory partners.
State agencies have the option to submit a Combined State Plan that includes the core
programs as well as other optional Federal employment and training programs,
including SNAP E&T and Work programs authorized under section 6(o) of the Act.
However, even if SNAP E&T is included in the State’s WIOA Combined State Plan, the
State agency must still submit certain elements of the E&T State plan to FNS on an
annual basis. For more information on these requirements, see the March 14, 2016
memo, “Supplemental Nutrition Assistance Program Employment and Training, WIOA
Unified and Combined State Plans.”

Where can a State learn more about writing an E&T State plan?
State agencies can learn more about writing a comprehensive E&T State plan by
reviewing the E&T State Plan Template and Handbook.

State Agency Responsibilities
What are the State’s responsibilities when operating an E&T
program?
The State agency has the responsibility to administer an E&T program that offers case
management and at least one E&T component to all E&T participants. The State
agency also has several responsibilities related to developing and managing the E&T
program, including, but not limited to:
•

Developing high-quality E&T programs based on local workforce needs and
designed to help SNAP get new or better jobs;

•

Consulting with State workforce development boards, or local employers or
employer organizations if the State agency determines that would be more
efficient, in the design of the State E&T program;

•

Developing an annual E&T State Plan that accurately summarizes the State
agency’s planned activities for the upcoming Federal fiscal year by August
15th;

•

Including in the E&T State plan the extent to which the State agency has
coordinated with title I of WIOA;

•

Developing State-specific criteria to determine eligibility for E&T programs;

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•

Ensuring E&T providers and other E&T contractors are providing high quality
services and fulfilling all applicable requirements for E&T programs and
services;

•

Conducting Management Evaluations of sub-entities engaged in the State
E&T program to ensure program compliance;

•

Providing all required reporting data in a timely manner;

•

Using E&T funds appropriately; and

•

Ensuring compliance with all Civil Rights requirements.

State agency responsibilities to E&T participants are detailed in the requisite sections of
the Code of Federal Regulations.

What are the State’s responsibilities to E&T participants?
The State agency has many responsibilities to ensure individuals participating in E&T
receive high-quality E&T services that provide the individual with necessary skills to that
meet employers’ needs. These responsibilities include, but are not limited to:
•

Screening individuals against State-specific criteria to determine if it is
appropriate to require an individual to participate in E&T (i.e. mandatory E&T),
or if it is appropriate to refer an individual to the State’s E&T program;

•

Referring eligible individuals to the E&T program and ensuring the participant
has the information necessary to access the program;

•

Providing participant reimbursements that are both reasonably necessary and
directly related to participation in the E&T program. If a State agency is
unable to provide participant reimbursements to a mandatory E&T participant
that would enable the individual to participate, the State agency must exempt
the individual from mandatory E&T;

•

Ensuring the E&T participant receives both case management and at least
one E&T component;

•

Determining if an individual has good cause for non-compliance with the
requirement to participate in E&T;

•

Taking one of four action steps, if an individual receives a provider
determination, to connect the individual with more appropriate services;

•

Sending appropriate notices and other necessary communications in a timely
fashion to E&T participants. These notices include, among others, the
consolidated work notice and the notice of adverse action, as well as
information about how to access E&T programs and services;

•

Providing E&T programs that are committed to the values of equity, inclusion,
and equal opportunity for those who are served; and

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•

Ensuring compliance with all Civil Rights requirements.

State agency responsibilities to E&T participants are detailed in the requisite sections of
the Code of Federal Regulations.

What are the State agency’s responsibilities to E&T providers?
The State agency must also be responsible to E&T providers. Additional responsibilities
include, but are not limited to:
•

Ensuring E&T providers are well-informed of all E&T program policies and
regulations, Civil Rights policies, and State-specific regulations;

•

Providing technical assistance to ensure E&T providers offer high quality
services;

•

Establishing financial systems to manage reimbursement for E&T provider
services;

•

Establishing data management systems to track E&T participants engaged
with provider programs and services; and

•

Establishing good working relationships with E&T providers to better
understand the services offered and ensure E&T participants referred to
providers are well-matched to those services.

State agency responsibilities to E&T providers are detailed in the requisite sections of
the Code of Federal Regulations.

Case Management in E&T
What is case management in E&T?
Case management in E&T is a set of services to guide and support E&T participants as
they engage with an E&T program. Case management services can include, but are
not limited to: comprehensive intake assessments, individualized service plans,
progress monitoring, or coordination with service providers. In accordance with the Act,
all E&T participants must receive case management and at least one E&T component.

Is case management an allowable expense in E&T?
Yes. Case management services when offered as part of an E&T program are
allowable.

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Who must receive case management services in E&T?
All E&T participants must receive case management services as part of the E&T
program.

What are the required elements of case management?
Case management services must be designed to support the participant as the
participant progresses through an E&T program. For that reason State agencies have
flexibility to offer a variety of services and tailor those services to the needs of the
participant. The Act provides examples of allowable case management activities, but
State agencies may offer additional services, as appropriate. It is also important that
the provision of case management services not be an impediment to participation in
E&T. To this end, State agencies also have the responsibility to ensure that case
management services are provided through an efficient administrative process and
targeted to the needs of participants.

Is there a limit to the types of activities that can be included in case
management?
Yes. State agencies have flexibility in the types of services offered through case
management, but can only use E&T funds for allowable components, activities, and
participant reimbursements. For instance, a case manager may conduct an
employability assessment and determine an individual likely struggles with substance
use disorder. The case manager can identify helpful resources in the community and
refer the individual to substance use disorder services as part of E&T case
management, but State agencies cannot use E&T funds to pay for substance use
disorder treatment services, as substance use disorder treatment services are not an
allowable activity in the E&T program.

What does it mean that the provision of case management services
should not be an impediment to participation?
Case management services are intended to help, not hinder participation in E&T. More
pointedly, case management, particularly in a mandatory E&T program, should not
create barriers that make it difficult for the participant to comply with the requirements of
E&T. For instance, State agencies should do their best to accommodate the needs and
access issues of participants when arranging case management appointments. The
State agency should ensure that case management meetings and provision of services
serve a purpose in advancing the success of the E&T participant, and are not simply
“box checking” activities that misuse the participant’s time. Further, the flexibility
provided within case management also allows State agencies to adjust the timing and
frequency of case management appointments. For instance, if a participant met with a

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case manager early in the E&T program, and the participant is otherwise successfully
participating in the assigned E&T component, the case manager could determine that
further appointments will only be scheduled on an as-needed basis. In addition, if a
participant misses a case management appointment, but is successfully attending the
E&T component, the State agency may decide to reach-out and determine the need for
re-scheduling the case management appointment, rather than immediately reporting the
missed appointment as non-compliance.

How will FNS determine that case management services are not an
impediment to participation?
State agencies are required to describe in their E&T State plan how they will provide
efficient and targeted case management to all E&T participants. FNS also reviews
State agency processes during management evaluations. If a State agency is not
providing efficient services to participants that are targeted to facilitate success in the
E&T component, FNS will require that the State agency take corrective action. As
always, FNS will be ready to provide technical assistance.

Who can provide case management?
State agencies have flexibility in how they deliver case management services. State
agencies can offer case management through State agency employees, E&T providers,
or through other means like contractors.

When must an E&T participant receive case management?
State agencies have flexibility in how they deliver case management services. As a
best practice, State agencies should provide case management services soon after
referral to E&T and periodically, as needed, throughout a participant’s progression
through an E&T program. Regular engagement with case management services
ensures the participant is well-supported to successfully complete the program.

What are the responsibilities of the case managers?
Case managers must support E&T participants as they progress through the E&T
program. Participation in case management must not be an impediment to successful
completion of an E&T program or otherwise complying with the requirements of E&T.
In addition, if a case manager becomes aware of a participant circumstance that may
qualify that participant for an exemption from a work requirement or good cause for noncompliance with a work requirement, the case manager must provide that information to
the appropriate staff in the State agency who can then make the determination. Note

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that if the case manager is employed by an E&T provider, the E&T provider must also
notify the State agency of non-compliance with a work requirement within 10 days.

E&T Components
What is an E&T component?
An E&T component is a broad category of employment or training activities defined by
the Act. An E&T program offered by a State agency must include one or more of these
components:
•

Supervised job search

•

Job search training

•

Workfare

•

Work experience

•

Education

•

Self-employment training

•

Job retention

•

Activities provided under the 2014 E&T pilots that the Secretary of the United
States Department of Agriculture determines have a demonstrable impact on
reducing dependency and improving self-sufficiency. (Note: evaluation results
from the pilot projects are expected by the end of 2021.)

What is an E&T activity?
E&T activities are specific types of employment or training offerings that compose an
E&T component. E&T components are made up of E&T activities. For instance, the job
search training component is made up of several activities including employment
assessments, assistance with resume writing and interview skills, instruction on
performing a job search, and other similar activities.

What is supervised job search?
Supervised job search was added as an E&T component by the Agriculture
Improvement Act of 2018 (also known as the 2018 Farm Bill). Supervised job search
replaced the job search component. Supervised job search programs are those that
occur at State-approved locations at which the activities of participants are directly
supervised and the training and activities of participants tracked in accordance with
guidelines issued by the State agency.

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Supervised job search may be conducted independently or within a group setting, and
may also be conducted remotely, in-person, or a combination of both. State agencies
should tailor the delivery of supervised job search services to the particular needs of
participants. State agencies must also provide the necessary participant
reimbursements required for participation (e.g. laptops and hotspots as needed for
remote job search conducted on the internet or transportation vouchers for in-person job
search). State agencies may also tailor how they track participation using a range of
options from automated computer processes to informal job application counts shared
by the participant.
State agencies must also ensure that supervised job search activities have a direct link
to increasing the employment opportunities of individuals engaged in supervised job
search. That is, a participant in supervised job search must be likely to find a job
through the activity, and there must be appropriate jobs available for that participant in
the community.

How should State agencies supervise job search?
Participants in supervised job search must have at least one meeting a month with a
qualified staff member to review job search activities, get feedback, troubleshoot issues,
and discuss next steps. This meeting may occur remotely or in-person, and be
synchronous with the job search activities or asynchronous. Interactive software or
other types of automated processes on a computer do not meet the requirement for
engagement with a qualified staff person at least once a month. In between meetings
with a qualified staff person, the State agency may use other supervisory techniques
such as software that tracks time spent logged into a job search website, or computer
assessments that automatically identify next steps for the participant.

What is unsupervised job search?
Unsupervised job search is job search that does not meet the definition of supervised
job search. Unsupervised job search is not an E&T component; however, it can be
allowable in certain circumstances as detailed below.

Will FNS reimburse for job search that does not meet the definition of
supervised job search?
Job search that does not meet the definition of supervised job search can be included
as a subsidiary activity within a broader E&T component, so long as it makes up less
than half the time spent in the broader E&T component. For instance, a State agency
may offer an education component teaching E&T participants computer programming
skills. During the last week of the course, participants are expected to engage in
unsupervised job search for several hours a day. So long as the time spent searching
for a job makes up less than half the time in the computer programming course, the

20

unsupervised job search is an allowable activity, and the State agency may seek
reimbursement.

Can job search count toward the able-bodied adults without
dependents (ABAWD) work requirement?
Job search, whether supervised or unsupervised, can count towards the ABAWD work
requirement, so long as job search makes up less than half of the time spent in the
requirement. For instance, if an ABAWD takes a job training class for 20 hours a week
to count towards the ABAWD work requirement, no more than 10 hours can be spent
doing job search (supervised or unsupervised) during that week.

What is job search training?
Job search training is a component that enhances the job readiness of participants by
teaching them job seeking techniques, increasing job search motivation and boosting
self–confidence. This component may consist of job skills assessments, and other
direct training or support activities. These are distinct from “work readiness” activities,
which are included in the education component.
Job search training differs from supervised job search because of the need to conduct
training activities.

What is E&T workfare?
E&T workfare is a component in which SNAP recipients work off the value of their
household’s monthly SNAP allotment through an assignment at a private or public nonprofit agency, including community-based organizations. In lieu of wages, workfare
participants receive compensation in the form of their household’s monthly benefit
allotment. The primary goal of workfare is to improve employability and encourage
individuals to move into regular employment while improving the community. Workfare
assignments cannot replace or prevent the employment of regular employees.
Workfare assignments must provide the same benefits and working conditions provided
to regular employees performing comparable work for comparable hours.
There are also several types of workfare outside of the E&T program, and which are not
E&T components. For example, ABAWDs can elect to participate in comparable
workfare, which may be self-initiated to fulfill the ABAWD work requirement, if this is a
State option. In a self–initiated workfare program, ABAWDs voluntarily participate and
find their own workfare job assignments to remain eligible for SNAP.

21

What is work experience?
A work experience program is designed to improve the employability of household
members through actual work experience or training, or both, and to enable individuals
employed or trained under such programs to move promptly into regular public or
private employment. Work experience is a planned, structured learning experience that
takes place in a workplace for a limited period of time. Work experience may be paid or
unpaid, as appropriate, and consistent with other laws such as the Fair Labor Standards
Act. Work experience may be arranged within the private for-profit sector, the non-profit
sector, or the public sector. Labor standards apply in any work experience setting
where an employee/employer relationship, as defined by the Fair Labor Standards Act,
exists.
A work experience program may include either a work activity or a work-based learning
program. Both work activities and work-based learning opportunities must involve a
planned and structured learning experience.
•

A work activity is performed in exchange for SNAP benefits that provides an
individual with an opportunity to acquire the general skills, knowledge, and work
habits necessary to obtain employment. The purpose of work activity is to
improve the employability of those who cannot find unsubsidized full-time
employment.

•

A work-based learning program in SNAP E&T is a sustained interaction with
industry or community professionals in real world settings to the extent
practicable, or simulated environments at an educational institution that foster indepth, firsthand engagement with the tasks required in a given career field, that
are aligned to curriculum and instruction. Work-based learning emphasizes
employer engagement, includes specific training objectives, and leads to regular
employment. Work-based learning can include internships, pre-apprenticeships,
apprenticeships, customized training, transitional jobs, incumbent worker training,
and on-the-job training as defined under WIOA. Work-based learning can
include both subsidized and unsubsidized employment models whereby E&T
funds are used to subsidize the participant’s wage.

A work experience program must:
•

Not provide any work that has the effect of replacing the employment of an
individual not participating in the employment or training experience program;
and

•

Provide the same benefits and working conditions that are provided at the job
site to employees performing comparable work for comparable hours.

22

What is education?
The education component includes a wide range of activities that improve basic skills
and the employability of SNAP participants. Such programs include Adult Basic
Education (ABE), basic literacy, English as a Second Language (ESL), high school
equivalency (GED), career and technical education (CTE), and other post-secondary
education. Education components can offer SNAP participants an opportunity to earn
postsecondary credentials valued by employers and industry, including certificates and
degrees, industry-recognized credentials, and licensures. Education may also include
“work readiness” activities, such as general skills building, developing good work habits,
and building a work history. FNS can only approve education components that
establish a direct link to job–readiness.
There are specific rules regarding what can be charged to an E&T education
component. Activities charged to E&T may not supplant non-federal funds for existing
educational services and activities and E&T may not be charged more than what the
general public would pay for the same service. There are also regulations pertaining to
students enrolled in institutes of higher education and their eligibility for SNAP at 7 CFR
273.5.

What is self-employment training?
Self-employment training is a component that improves the employability of participants
by training them to design and operate a small business or another self–employment
venture.
E&T participants receive technical assistance in developing business plans and in
creating financial marketing plans. Participants also learn how to access small business
grants and other business support services.

What is job retention?
The job retention component is meant to provide support services for at least 30 days
and up to 90 days to individuals who have secured employment. Individuals are eligible
to receive job retention services if they received SNAP benefits in the month of or the
month before they start job retention, and may receive job retention services after
leaving SNAP unless unless the individual is leaving SNAP due to a failure to comply
with the general work requirement or an intentional program violation. The participant
must have secured employment after or while receiving other E&T services. There is no
limit to the number of times an individual may receive job retention services, as long as
the individual has re-engaged with E&T prior to obtaining new employment.

23

What kinds of job retention services can be paid for with E&T funds?
Job retention can include services like job coaching and troubleshooting issues that
may impact employment. For instance, a job coach could help a participant find
constructive ways to handle a dispute with a fellow employee, or help a participant
identify a child care provider. Participants in job retention may also receive participant
reimbursements that are reasonably necessary and directly related to participation in
job retention, like clothing required for the job, equipment or tools required for a job,
transportation, and child care.
State agencies may use their 100 percent Federal E&T grants to pay the costs of
administering job retention services, as with any approved E&T activity. However,
participant reimbursements under the job retention component must be funded by the
State agency, with 50 percent Federal reimbursement.

What kinds of activities from the 2018 E&T pilots are allowable?
The 2018 Farm Bill permits activities from the 2014 Farm Bill E&T pilots to become
allowable E&T activities if those activities, based on results from the independent
evaluation, have a demonstrable impact on the ability of participants to find and retain
employment that leads to increased household income and reduced reliance on public
assistance. The results of the independent evaluation are expected in late 2021.

How are allowable E&T components identified on the FNS-583?
State agencies must report participation in E&T components on the FNS-583. The
following table cross-walks the names of the components (and common activities within
those components) with their acronym on the FNS-583.
FNS-583 Acronym
SJS
JST
JR
SET
W
EPB
EPC
EPEL
EPIE

Description
Supervised Job Search
Job Search Training
Job Retention Services
Self-Employment Training
Workfare
Educational Program, Basic Education and/or Foundational
Skills Instruction (includes High School Equivalency
programs)
Educational Program, Career and/or Technical Education
Programs or Other Vocational Training
Educational Program, English Language Acquisition
Educational Program, Integrated Education and Training or
Bridge Programs

24

EPWRT
EPO
WA
WBLI
WBLI-SUB
WBLOJT
WBLOJT-SUB
WBLPA
WBLPA- SUB
WBLTJ
WBLTJ – SUB
WBLO
WBLO – SUB

Educational Program, Work Readiness Training
Educational Program – Other. State must provide
description
Work Activity
Work-based learning, Internship
Work-based learning, Internship, Subsidized by E&T
Work-based learning, On-the-job Training
Work-based learning, On-the-job Training, Subsidized by
E&T
Work-based learning, Pre-apprenticeship/Apprenticeship
Work-based learning, Pre-apprenticeship/Apprenticeship,
Subsidized by E&T
Work based learning, Transitional Jobs
Work based learning, Transitional Jobs, Subsidized by E&T
Work-based learning- Other, State must provide description
Work-based learning- Other, State must provide description,
Subsidized by E&T

What level of effort must each component entail?
The level of participation depends on the component, but must be sufficient to
effectively and efficiently provide the participant with the necessary training to move into
employment. In other words, the E&T participant should be making satisfactory
progress towards employment. Note that the hours of participation for mandatory
participants in workfare or in a work experience component, along with the hours
worked by other household members, must not exceed the value of the monthly
allotment divided by the higher of the applicable State or Federal minimum wage. Also
note that level of effort for an E&T component is a separate concept from the number of
hours an ABAWD must work or engage in job training as part of the ABAWD work
requirement.

What is the maximum amount of time a participant can spend in an
E&T program?
The State agency cannot mandate more than 120 hours per month. In addition, the
hours worked by a mandatory participants in a work component (i.e. work experience or
workfare), plus the hours worked by other household members, cannot exceed the
value of the household monthly benefit divided by the higher of the applicable Federal
or State minimum wage. Mandatory and voluntary participants in work-based learning
can volunteer to work more hours, so long as the voluntary E&T participant receives the
same compensation for comparable work for comparable hours earned by non-SNAP
E&T participants, and no minimum wage laws are violated. However, participants in a
work activity or workfare cannot work additional hours, even on a voluntary basis,
because their participation is limited to working off the value of their benefit.

25

What guidance is available to help determine whether an E&T activity
or service may be approved?
Activities are specific offerings within an E&T component. To be allowable, an activity
must fit within one of the E&T components listed at 7 CFR 273.7(e)(2). Services are
other types of offerings within an E&T program, most specifically including case
management services. All E&T components and services must support the purpose of
the E&T Program in accordance with section 6(d)(4) of the Act. The purpose of the E&T
program is to assist members of SNAP households in gaining skills, training, work, or
experience that will increase their ability to obtain regular employment and meet State
or local workforce needs.
If an E&T activity or service does not support the purpose of E&T, it is not approvable.
For instance, participation in a drug or alcohol treatment and rehabilitation program is
not an allowable activity or service in E&T because it is not directly providing
participants with the skills or training to obtain employment. In addition, these services
are not an allowable participant reimbursement. An E&T case manager may identify
the need for substance use disorder treatment and make a referral, but E&T cannot pay
for the treatment and time spent in treatment cannot count toward the mandatory E&T
requirement. Also note, that regular participants in a drug addiction or alcohol treatment
and rehabilitation program must be exempt from the general work requirement, and
consequently are exempt from mandatory E&T. Case managers must inform the
appropriate State agency staff of a participant’s participation in a treatment program, so
that the State agency staff can determine if the individual should receive an exemption.
In addition, an activity must entail a certain level of effort and may not delay the
individual’s eligibility for benefits or issuance of benefits. For instance, a State agency
may choose to serve applicants in E&T, but participation in E&T must not delay the
processing of the participant’s application.

May mental health services be provided under E&T?
Mental health services are not generally allowable under E&T. As stated above, to be
an allowable E&T activity, service, or participant reimbursement, the activity, service, or
participant reimbursement must further the purpose of E&T. The provision of mental
health services does not further the purpose of E&T.
Individuals deemed mentally unfit in accordance with the work registration exemptions
at 7 CFR 273.7(b), or individuals with other types of mental health challenges who may
be exempt from the requirement to participate in E&T by State agency criteria, cannot
be mandatory E&T participants. State agencies may choose to serve individuals with
mental health challenges in E&T and through the provision of case management
services, identify potential mental health challenges and make referrals to mental health
services, but E&T cannot fund mental health services.

26

May an E&T component address substance use disorders?
Generalized anti-drug, anti-alcohol and mental health discussions are permissible as
part of an approved component, as they are important topics related to employability
and maintaining a job. The amount of time spent on such discussions should not be
more than would normally be dedicated to other employability topics. For instance, if a
training component covers job search, interview preparation, dress, hygiene, etc., then
the drug, alcohol or mental health discussions should take up no more time than the
other sub-topics.
As stated above, to be an allowable E&T activity or service, the activity or service must
further the purpose of E&T. The provision of substance use disorder treatment does not
further the purpose of E&T. Case managers may identify potential substance use
disorders and make appropriate referrals to agencies that can help. However,
substance use disorder treatment, defined as behavior modification therapy for those
who use drugs or alcohol to the detriment of themselves and others, is not an allowable
E&T activity.

Workfare
What types of workfare are there?
There are several types of workfare programs, including SNAP E&T workfare, optional
workfare authorized under Section 20 of the Act, comparable workfare, and others.
With the exception of SNAP E&T workfare, all other forms of workfare are operated
outside of the E&T program and are not E&T components. State agencies may only
use SNAP E&T funds for E&T workfare. The requirements for SNAP E&T workfare,
among other types of workfare, are outlined at 7 CFR 273.7(m).

How long can a SNAP participant participate in E&T workfare?
In accordance with 7 CFR 273.7(e)(4)(ii), the time spent by household members
collectively each month in an E&T work program (e.g. workfare and work experience
components) along with any additional workfare hours must not exceed the number of
hours equal to the household’s monthly allotment divided by the higher of the applicable
Federal or State minimum wage. Thus, the maximum number of hours that a SNAP
participant can spend in workfare must be calculated on a household basis considering
the number of hours other household members spend working, in an E&T work
program, or in workfare.
In addition, the total hours of participation in an E&T program for an individual in a
month, together with any workfare hours or hours worked for compensation (in cash or
in-kind), must not exceed 120.

27

What is SNAP E&T Workfare?
SNAP E&T workfare is operated as part of an E&T program as a component and must
comply with all E&T program requirements (e.g. participants must receive case
management, participant reimbursements, etc.).

What kinds of organizations can the State agency partner with to
implement SNAP E&T workfare?
SNAP E&T workfare may only be performed at public or private nonprofit agencies.
Under a SNAP E&T workfare program or an optional workfare program, contractual
agreements must be established between the operating agency and a workfare
placement organization.

What other laws do State agencies need to comply with to implement
workfare?
Workfare programs and placements are subject to the Fair Labor Standards Act (FLSA)
and minimum wage laws apply. States with questions about FLSA requirements should
work with their State Wage and Hour Division to ensure workfare programs comply with
all Federal requirements.

Can E&T funds be used for workfare outside of an E&T program?
No. E&T funds may only be used for the cost of planning, implementing, and operating
a SNAP E&T program. Workfare outside of an E&T program, including optional
workfare and comparable workfare, is not part of a SNAP E&T program. Optional
workfare has its own line on the State’s SF-778 Budget Form and its own letter of credit
within the SNAP accounting system.

Should a State agency include workfare in its E&T State plan?
It depends. If a State agency intends to offer E&T workfare as part of its E&T program,
then E&T workfare must be included in the E&T State plan, along with any other
components the State agency plans to offer. In addition, if a State agency is choosing
to take the ABAWD pledge, and the State agency intends to offer any type of workfare
as a qualifying activity, the State agency should indicate this intention in the ABAWD
pledge section of the E&T State plan.

Where can I learn more about different types of workfare?
The Federal requirements for workfare are found in 7 CFR 273.7(m).

28

Workforce Partnerships
What is a workforce partnership?
A workforce partnership is a partnership between the State agency and employers or
other employment entities to create new ways for SNAP participants to gain highquality, work-related skills, training, work, or experience that will increase the ability of
the participants to obtain regular employment. Workforce partnerships must meet
certain criteria to be certified by the State agency, and comply with certain reporting
requirements.

Are workforce partnerships part of an E&T program?
No. Workforce partnerships are not part of an E&T program. Workforce partnerships
are part of the broader SNAP program. No funds from the Act may be used to support
workforce partnerships.

Can participation in a workforce partnership count toward mandatory
E&T?
Yes. A mandatory E&T participant can meet their mandatory E&T requirement through
participation in a workforce partnership.

Can participation in a workforce partnership count toward the
ABAWD work requirement?
Yes. An ABAWD can meet the ABAWD work requirement though participation in a
workforce partnership.

Where can I learn more about workforce partnerships?
Workforce partnerships are described in greater detail in 7 CFR 273.7(n).

Work Supplementation
What is work supplementation?
Work supplementation is a State option that allows a State agency to provide work and
training opportunities to households receiving both SNAP and Temporary Assistance for

29

Needy Families (TANF) benefits by supplementing the wage of the participant with the
cash value of the SNAP and TANF benefits. To operate a work supplementation
program, the State agency must submit for FNS approval a work supplementation plan.
For more information about work supplementation, see the regulations at 7 CFR
273.7(l).

Is work supplementation part of an E&T program?
No. Work supplementation is not part of an E&T program. Work supplementation is a
State option in the broader SNAP program. E&T funds may not be used to support a
work supplementation program.

How does work supplementation affect SNAP work requirements?
A SNAP recipient participating in a work supplementation program must be excused
from meeting any other work requirements.

Civil Rights and SNAP E&T
How do Civil Rights laws and regulations apply to E&T programs?
State agencies administering SNAP E&T programs must:
•

Comply with Federal law and ensure that individuals eligible for and
participating in E&T are not discriminated against based on race, color,
national origin, age, sex (including gender identity and sexual orientation),
religious creed, disability and political belief.

•

Ensure policies are implemented in accordance with Title II of the Americans
with Disabilities Act (ADA)/ Americans with Disabilities Act Amendments Act
(ADAAA) and Section 504 of the Rehabilitation Act requirements.

•

Ensure locations are physically accessible to individuals with disabilities and
free auxiliary aids and services and other reasonable modifications are
provided.

•

Verify effective communication is provided to individuals with disabilities (i.e.,
Braille, large print, sign language interpreter, etc.).

•

Display the appropriate And Justice For All poster in a prominent area for the
public to view.

•

Ensure public websites that provide information regarding E&T have the full
nondiscrimination statement, or a direct hyperlink to it, on their respective
program home webpages.

30

•

Ensure there are no substantive differences in client referrals to E&T activities
based on race and/or ethnicity.

•

Ensure staff involved in all levels of E&T (i.e. managers, supervisors, frontline
staff, volunteers, etc.) receive annual Civil Rights training.

•

Ensure meaningful access to persons with limited English proficiency (LEP).

•

Translate vital documents based on the results of the State agency’s
language assessment of what languages other than English are spoken most
frequently statewide and provide interpreter services to program applicants
and participants free of charge.

•

Notify program applicants and participants of the availability of free language
assistance services.

•

Ensure that citizenship and immigration status does not give rise to
discrimination.

How does the requirement to provide reasonable modifications apply
to E&T?
The ADA requires public entities to make reasonable modifications to allow participants
with disabilities to participate in programs. If the public entity can demonstrate that a
particular modification would fundamentally alter the nature of its service, program, or
activity, it is not required to make that modification. However, SNAP State agencies are
expected to begin a conversation with SNAP participants and potential E&T participants
during eligibility to learn of any potential accessibility concerns. The State agency
should then consider the participant’s concern and make timely and reasonable
modifications to serve the household in E&T.

Where can I learn more about the applications of Civil Rights to E&T?
The SNAP E&T Guidance on Civil Rights Requirements provides more information of
the application of civil rights requirements in E&T programs.

31

Chapter 2 – E&T Eligibility and
Participation

32

General Work Requirement
What is the SNAP general work requirement?
As a condition of SNAP eligibility, individuals must comply with the SNAP general work
requirement unless exempt from the requirement. Individuals required to comply with
the general work requirements are referred to as work registrants.
The general work requirements entail:
•

Registering for work at time of application and every 12 months thereafter;

•

Participating in a E&T program, if assigned by the State agency;

•

Participating in a workfare program, if assigned by the State agency;

•

Providing information on employment status to the State agency;

•

Reporting to an employer, if referred by the State agency and if the potential
employment is suitable;

•

Accepting a bona fide offer of suitable employment; and

•

Not voluntarily quitting a job without good cause or reducing work hours to
less than 30 hours per week.

All SNAP recipients that do not meet a Federal exemption, as described in 7 CFR
273.7, must work register or be registered by the State agency. Most State agencies
include a general work registration statement on the SNAP application.

Who is a work registrant?
A work registrant is a SNAP applicant or recipient who must comply with the general
work requirement because he or she does not meet one of the following Federal
exemptions from the general work requirement:
•

Already working at least 30 hours a week (or earning wages at least equal to
the federal minimum wage multiplied by 30 hours);

•

Meeting work requirements for another program (TANF or unemployment
compensation);

•

Taking care of a child under 6 or an incapacitated person;

•

Unable to work due to a physical or mental limitation;

•

Participating regularly in an alcohol or drug treatment program; or

33

•

Studying in school or a training program at least half-time (but college
students are subject to other eligibility rules).

What are the other SNAP work requirements?
In addition to the general work requirement, a SNAP work registrant may also be
required to participate in E&T (i.e. mandatory E&T) if they do not meet a State-specific
exemption from E&T. A SNAP work registrant may also qualify as an ABAWD and be
required to comply with the ABAWD work requirement.

E&T Eligibility
Who is eligible to participate in E&T?
SNAP applicants and participants are eligible to participate in E&T. E&T participants
can be either mandatory or voluntary.

What is a mandatory E&T participant?
A mandatory E&T participant is a work registrant who does not meet a State-specific
exemption from E&T (i.e. required to participate as a condition of eligibility for SNAP)
and is referred to an E&T program by the State agency.

What does it mean to meet a State-specific exemption from E&T?
All work registrants must participate in E&T if required to by the State agency; however,
State agencies have broad authority to exempt work registrants from the requirement to
participate in E&T. Exemptions vary by State agency and can include geographic
location, pregnancy, and low-English proficiency. Some State agencies may exempt
certain work registrants from the requirement to participate in E&T, but require others to
participate. State agencies may choose to require verification of an exemption from the
requirement to participate in E&T. In these cases, State agencies should not refer
individuals to E&T until after the period of time to provide the exemption passes, and the
State confirms the individual is not exempt. Many State agencies exempt all work
registrants from E&T and run completely voluntary E&T programs. It is important to
note that if a work registrant meets a State-specific E&T exemption the recipient must
still meet the general work requirement.
When determining who will not be exempted from E&T, and therefore required to
participate in E&T, State agencies should consider how best to balance available
resources for E&T programs with the number of work registrants in the State. It is the
State agency’s responsibility to ensure there is an appropriate and available opening in

34

an E&T program for every applicant or recipient required by the State agency to
participate in E&T.

What is a voluntary E&T participant?
Voluntary E&T participants are SNAP recipients who are exempt from mandatory E&T
participation, but choose to pursue E&T. Because voluntary participants are exempt
from mandatory E&T, they cannot be disqualified for failure to comply. State agencies
may choose to exempt all SNAP work registrants from mandatory E&T and only serve
volunteers. Further, State agencies can choose to serve non-work registrants (who are
by statute exempt from mandatory E&T) as volunteers. Other State agencies may
focus on serving mandatory participants, but also allow some SNAP participants to
volunteer. State agencies have the authority to establish criteria for voluntary
participation in E&T. For instance, a State agency could decide to serve voluntary
participants who live in a certain geographic location or decide to serve ABAWDs who
volunteer for E&T.

What is the difference in administrative responsibilities to run a
mandatory versus voluntary program?
State agencies that run mandatory E&T programs have additional responsibilities
compared to State agencies that run only voluntary E&T programs. State agencies
administering mandatory E&T programs must ensure that individuals referred to E&T
have been properly screened for an exemption from mandatory E&T using Statespecific criteria, and ensure there is an appropriate and available opening in an E&T
program for that participant. If there is not an appropriate and available component,
then the State agency must provide good cause. State agencies must also exempt
individuals from mandatory E&T if the costs of participant reimbursements exceed the
State agency cap, or if the participant reimbursement is not available. All mandatory
E&T participants must also receive the consolidated work notice and oral explanation
explaining the mandatory E&T requirement, in addition to other work requirements, as
applicable. If a mandatory E&T participant fails to comply, the State agency must
establish if the non-compliance was without good cause, and issue a Notice of Adverse
Action, if appropriate.
State agencies that focus on voluntary rather than mandatory participants may save
administrative time because eligibility workers spend less time determining noncompliance and good cause, issuing Notice of Adverse Action letters, and rescheduling
missed appointments with clients. Less time spent on these activities translates to more
time and resources that can be dedicated to service delivery. If a voluntary participant
repeatedly fails to comply with an E&T activity or service, the State agency may
discontinue E&T for that individual or place him or her in a different activity.

35

Can a State agency enroll a voluntary participant in E&T without
screening and referring the participant?
To be considered a voluntary E&T participant, an individual must knowingly volunteer
for the E&T program, be screened by the State agency to determine if the individual
meets State-specific criteria for voluntary participation, be referred by the State agency
to an approved and appropriate E&T component, and be provided appropriate
participant reimbursements. These requirements also apply to participants who have
been reverse referred to the State agency by an E&T provider.

Can a State agency limit the number of voluntary participants it
serves?
SNAP regulations do not limit the number of volunteers that can participate in an E&T
program; however, State agencies can choose to limit the number of people they serve
through their E&T program. This includes the number of volunteers.
State agencies have the authority to establish State-specific criteria regarding who will
participate in their E&T programs. (Note this does not mean that State agencies have
the authority to discriminate against protected classes.) For example, a State agency
could limit the number of volunteers it will serve based on existing financial resources or
where there are appropriate E&T providers. In addition, State agencies do not have to
serve volunteers (i.e. a State agency may choose to serve only mandatory participants).
This information should be included in the E&T State plan.

Are all work registrants required to participate in E&T?
All work registrants are required to participate in E&T unless they meet the criteria for a
State-specific exemption from E&T. State agencies must establish screening criteria to
determine which work registrants will be required to participate in E&T and which will be
exempt. State agencies can choose to exempt all work registrants from the requirement
to participate in E&T – in other words, the State agency can choose to run an all
voluntary E&T program.
Alternatively, the State agency may choose to exempt certain types of work registrants
from the requirement to participate in E&T. The criteria used to determine who is
required to participate in E&T must not discriminate against protected classes and must
be applied consistently.

36

What is the difference between a work registrant and a mandatory
E&T participant?
The terms “work registrants” and “mandatory E&T participants” are often confused or
used interchangeably. However, it is important that State agencies understand the
difference between these two terms, as their meanings are very distinct and have
corresponding provisions in the SNAP regulations.
Work registrants are SNAP participants who have not met any Federal exemptions from
the SNAP general work requirement and are therefore required to register for work or
be registered by the State agency. All work registrants are mandatory E&T participants,
unless they meet a State-specific E&T exemption from the requirement to participate in
E&T. If a work registrant meets a State-specific E&T exemption from the requirement to
participate in E&T, then that individual is a work registrant, but not a mandatory E&T
participant. If a work registrant meets a State-specific exemption from E&T and
chooses to volunteer for E&T, then that individual is also not a mandatory E&T
participant and remains a work registrant.
As a result, not all work registrants are mandatory E&T participants, but all mandatory
E&T participants are work registrants.

Is there an age limit for who can participate in E&T?
A person younger than 16 years of age or a person over the age of 60 is exempt from
the general work requirement. Some 16 or 17 years olds must work register (those who
are the head of a household and are not in school or “an employment training program”
at least halftime). Sixteen and 17 year olds who are exempt from work registration and
individuals over 60 may volunteer for E&T.
There are special considerations for serving high school students in E&T. States
agencies should review the December 20, 2020 memo “Use of SNAP Employment and
Training funds for SNAP recipients who are attending high school.”

Able Bodied Adults without Dependents
Who is an ABAWD?
ABAWD stands for an able bodied adult without dependents. ABAWDs are subject to
the ABAWD work requirement. An individual is not subject to the time limit for ABAWDs
if he or she meets one of the following exemptions:
•

Under 18 or 50 years of age or older;

37

•

Unable to work cue to a physical or mental limitation;

•

Responsible for a dependent child or residing in a household where a
household member is under age 18;

•

Is otherwise exempt from the general work requirements; or

•

Is pregnant.

What is the ABAWD work requirement?
ABAWDs are limited to three months of SNAP benefits in a three-year period (the time
limit) unless they are fulfilling the ABAWD work requirement. ABAWDs can fulfill the
ABAWD work requirement by doing any one of the following things:
•

Work at least 80 hours a month. Work can be for pay, for goods or services
(for something other than money), unpaid, or as a volunteer;

•

Participate in a work program at least 80 hours a month. A work program
could be SNAP Employment and Training or another Federal, State, or local
work program;

•

Participate in a combination of work and work program hours for a total of at
least 80 hours a month;

•

Participate in workfare for the number of hours assigned each month (the
number of hours will depend on the amount of the SNAP benefit.)

In certain specific circumstances, State agencies have the ability to waive the time
limit. State agencies may also extend SNAP eligibility to a limited number of ABAWDs
subject to the time limit through “discretionary exemptions.” Each discretionary
exemption extends eligibility to one ABAWD for one month. The quantity of
discretionary exemptions available to the State agency is equal to 12 percent of the
State’s caseload that is subject to the time limit.
Learn more about ABAWDs.

What is the ABAWD time limit?
ABAWDs are limited to three full months of SNAP benefits in a three-year period unless
they are fulfilling the ABAWD work requirement or otherwise exempt. ABAWDs who
have reached the time limit can regain eligibility by fulfilling the ABAWD work
requirement for 30 consecutive days.

38

What is an ABAWD waiver?
An ABAWD waiver temporarily waives the time limit for all ABAWDs residing within the
geographic area covered by the ABAWD waiver. An ABAWD time limit waiver does not
waive the general SNAP work requirement.

Can ABAWDs participate in E&T?
ABAWDs may participate in E&T to fulfill the ABAWD work requirement and remain
eligible for SNAP. In fact, some State agencies require ABAWDs participate in E&T as
mandatory participants, although State agencies are not required to do so. However, if
the E&T component does not provide at least 80 hours a month, the ABAWD must
identify other opportunities to fulfill the balance of the hours beyond participation in E&T.
It should also be noted that supervised job search and job search training, when offered
as components of an E&T program, are not qualifying activities that may fulfill the
ABAWD work requirement. However, job search, including supervised job search, or job
search training activities, when offered as part of other E&T program components, are
acceptable as long as those activities comprise less than half the total required time
spent in the components.

Are all ABAWDs mandatory E&T participants?
No. State agencies have the authority to use State-specific criteria to exempt individual
work registrants or categories of work registrants from E&T participation. If an ABAWD
meets a State-specific E&T exemption, he or she is not required to participate in E&T.
However, State E&T exemptions do not absolve ABAWDs from the ABAWD time limit.
For example, Joe is an ABAWD receiving SNAP benefits and residing in County A. The
State agency exempts all work registrants in County A from the requirement to
participate in E&T, so Joe is not a mandatory E&T participant. However, County A does
not have an ABAWD waiver, and as a result Joe is subject to the ABAWD time limit. In
order to avoid receiving a countable month against the ABAWD three month
participation time limit, Joe must work, volunteer to participate in an E&T program or
another qualifying work program for at least 80 hours a month, or participate in workfare
in order to remain eligible for SNAP. Because he is not a mandatory E&T participant,
Joe cannot be disqualified for failure to comply with E&T if he does not participate in
E&T.

39

Screening, Assessment, and Referral in
E&T
What does it mean to screen for E&T participation?
All State agencies must screen to determine if an individual should be referred to E&T.
Screening is the process to determine if an individual meets State-specific criteria to
participate in E&T. All work registrants are required to participate in E&T unless they
meet a State-specific E&T exemption. If a State agency chooses to serve volunteers in
E&T, State agencies must also screen volunteers to determine if they meet Statespecific criteria for voluntary participation. Individuals who are identified as potential
E&T participants (i.e. reverse referrals) must also be screened by the State agency to
determine if the individual meets State agency criteria to participate in E&T. After a
State agency determines an individual meets State-specific criteria to participate in
E&T, either for voluntary or mandatory E&T, the State agency must refer that individual
to the E&T program.

Is screening an allowable E&T cost?
Screening for E&T is a SNAP certification function, not an E&T function. As a result,
screening for E&T is not an allowable E&T cost.

What does it mean to assess a SNAP E&T participant?
A SNAP participant should be assessed prior to placement in a specific E&T
component. Assessment should include an in-depth evaluation of employability coupled
with employment goals and skills assessments. This can be done by an E&T
counselor, case manager, or an E&T service provider. The results of the assessment
should be matched with criteria for participation for individual components and specific
activities. Please note that the objective of the assessment is to determine the most
appropriate E&T component for an E&T participant, not to determine whether the
participant is subject to the SNAP general work requirement or should be referred to
E&T. The latter steps are part of the SNAP certification process, and are not allowable
E&T expenses.
The following is a list of skills or knowledge that could be examined with suggested
assessment tools.

40

Skill or Knowledge

Assessment Tool

Literacy Level

Standardized tests, one-on-one
interview/observations (i.e. client’s ability
to read and complete forms in case file).

Communication Skills (including English
proficiency)
Education

Standardized test, one-on-one interview

Employment History
Employment-Related Skills, Abilities and
Interests
Employment Barriers and Steps
Necessary to Overcome Barriers

Questionnaire, resume, or one-on-one
interview
Questionnaire, resume, or one-on-one
interview
Questionnaire, one-on-one interview, or
online assessment
Questionnaire or one-on-one interview

Many local workforce investment boards have extensive resources for assessment.
State agencies can partner with local workforce boards and American Job Centers to
maximize existing, experienced, and local resources.

Who can provide assessments?
An assessment can be completed in a variety of ways. Some State agencies use a one
or two page form that the participant completes. Others allow the E&T coordinator to
objectively assess the participant in-person. Some State agencies partner with other
related programs or offices (WIOA, American Job Centers) or non-governmental
agencies to provide a more comprehensive assessment.
With the requirement that all E&T participants receive case management, in addition to
at least one component, the assessment can be incorporated into the overall case
management that the participant receives.

Are assessments an allowable E&T cost?
Assessments are conducted on individuals who have been determined eligible for
participation in E&T. As a result, assessments are an allowable E&T cost.

What does it mean to determine the criteria for participation in an E&T
component?
State agencies should be matching E&T participants with the E&T components and
activities that meet their training needs and where participants are most likely to be

41

successful in obtaining training or experience that leads to new skills to obtain a better
job. As such, State agencies are highly encouraged to determine criteria for
participation in E&T components and activities that consider the types of participant
skills, knowledge, or experience that are most likely to lead to success in the
component.

Can a State agency serve TANF participants in E&T?
E&T funds cannot be used to serve recipients of TANF cash assistance. Before
placement in an E&T program, there must be a mechanism to ensure that the
participant is not a TANF cash recipient. Note: By statute, VT, WI, CO and UT are
authorized to spend a limited amount of E&T funds on TANF cash recipients.

Can a State agency serve SNAP applicants in E&T?
Yes. Both SNAP applicants and SNAP participants can be referred to E&T programs
and receive E&T services.

Are there specific policies related to serving SNAP applicants?
Yes. The State agency must screen applicants to determine if it is appropriate for them
to participate in E&T, refer the applicant to E&T, provide the applicant with participant
reimbursements, and inform the applicant of E&T participation requirements including
how to access the component and consequences for failing to participate. The State
agency must not impose requirements that would delay the determination of an
individual’s eligibility for benefits or in issuing benefits to any household that is otherwise
eligible.

When does an individual become a SNAP E&T participant?
An individual becomes an E&T participant once he or she is referred to an E&T
program. This definition holds for both mandatory and voluntary E&T participants.

What are the major steps in the flow of a SNAP applicant from
application to referral to an E&T program?
The following flow chart explains the basic steps as an individual progresses from
application to referral to an E&T program.

42

What is an employment plan?
While not a requirement for SNAP E&T participants, many State agencies create
employment plans (EP) for each participant to document the services the State agency
will provide based on the participant’s interests and goals that were uncovered in the
employment assessment. An employment plan could include the following:
•

Employment objective (should be consistent with assessment).

•

Activities to be undertaken (i.e. E&T components, case management) to
achieve objective.

•

Tentative dates, times and locations for each activity.

•

Hours of activity required each week.

•

Services provided by agency (e.g. child care, transportation).

•

Statement of participant’s responsibilities and consequence of failing to
comply.

•

Signature of participant and eligibility worker or E&T coordinator.

43

Participant Reimbursements
What are participant reimbursements?
State agencies are required to pay for or reimburse E&T applicants and participants,
including E&T volunteers, for all expenses that are reasonably necessary and directly
related to participation in an E&T program. FNS will reimburse 50 percent of State
agency payments for allowable participant reimbursements. Participant
reimbursements include—but are not limited to—dependent care, transportation, books
and supplies, clothing and uniforms, and personal safety items.

Are there guidelines to assess whether a participant expense is an
approvable participant reimbursement?
State agencies have flexibility to determine the types of participant reimbursements that
will be offered to applicants and participants, within certain guidelines. In order to be
allowable, participant reimbursements must be reasonably necessary and directly
related to participation in an approved service or component in an E&T program, and
meet all Federal cost principles (2 CFR 200.404), including what a “prudent person”
would pay. State agencies must include participant reimbursements in their E&T State
plans, which are subject to review and approval by FNS.
Participant reimbursements cannot:
•

Be available through another government program or available at no cost to
the participant through a private source,

•

Be used to support a client’s regular employment unless the participant is
enrolled in the job retention component and the participant reimbursements
are linked to participation in that component, and

•

Be used to, among other things, pay bad debt such as outstanding fines or
fees, or make on-going regular payments.

The E&T State Plan must contain information about the participant reimbursements
offered by the State agency and their cost. The FNS Regional Office must review and
approve the E&T State Plan.

What if a State agency cannot provide sufficient participant
reimbursements for an individual?
State agencies may set caps on the amount of reimbursements that will be paid.
However, if a State agency cannot pay for or reimburse participants, or the individual’s

44

allowable monthly expenses exceed the State agency cap, then the State agency must
exempt the participant from E&T or find another suitable component for which the
participant’s expenses do not exceed the State’s ability to pay. Voluntary participants
should be informed that expenses in excess of the State agency’s allowable
reimbursement amount will not be paid with E&T funds.

If an individual is exempt from the general work requirement, and
consequently from mandatory E&T, but volunteers to participate in
E&T, can the State agency provide a participant reimbursement that
overcomes the reason for the exemption from the general work
requirement?
If an individual is exempt from the general work requirement and would like to volunteer
for E&T, but requires a special accommodation to participate in the component that is
otherwise an allowable E&T expenditure (e.g. a sign language interpreter, or special
computer software), those items or services can be provided as participant
reimbursements. This is allowable even if in doing so, the participant reimbursement
overcomes an exemption from the general work requirement. Note this only applies to
voluntary participants.

May the State agency use TANF reimbursement guidelines for E&T?
The significant differences that exist between E&T and TANF Work Programs preclude
FNS from allowing State agencies to cover the entire array of expenditures considered
suitable under TANF guidelines. A person participating in a TANF Work Program is
exempt from participation in SNAP E&T. In addition, State agencies are prohibited from
expending any Federal E&T funds on Title IV cash assistance recipients.

Can both voluntary and mandatory participants receive participant
reimbursements?
Yes. State agencies are required to provide payments to both mandatory and voluntary
applicants and participants for expenses that are reasonably necessary and directly
related to participation in the E&T program.

Can the State agency cap participant reimbursements?
State agencies may establish a cap on participant reimbursements. Caps can vary
within State agencies, as well. For example, if one area of the State has higher
transportation costs than others, such as a metropolitan area with bus vouchers versus
a rural area where participants need gas cards, the State agency can set different caps
on transportation to meet local needs.

45

What happens if a participant’s costs to participate in E&T exceed
what the State agency can pay?
State agencies must provide payment to mandatory and voluntary applicants and
participants in the E&T program for expenses that are reasonably necessary and
directly related to participation in the E&T program. Mandatory participants must be
exempted from E&T if their participation expenses exceed the State agency’s allowable
reimbursement amount, or the State agency cannot provide the necessary service.
Voluntary participants should be informed that expenses in excess of the State agency’s
allowable reimbursement amount will not be paid with E&T funds.

Can a State agency create a standardized reimbursement package for
E&T participants? For example, if an E&T participant is placed in a
CTE program can the State agency give him or her a standardized
reimbursement package to cover tuition, books, transportation, and
childcare?
No. A State agency must reimburse the actual costs of transportation and other costs
that it determines to be reasonably necessary and directly related to participation in the
E&T program up to the maximum level of reimbursement established by the State
agency. Not all E&T participants incur the same costs for participation in an E&T
component. For example, two E&T participants may be placed in a CTE course; one
participant may need reimbursements for books and transportation, while the other
participant only needs reimbursement funds for books because they bike to class. The
E&T program can only pay for the actual cost of participation.
A State agency may create a method for participant allowances that reflects the
approximate costs of participation and this method must be approved by FNS through
the E&T State plan. This method must be reasonable and verifiable. If a State agency
has an approved method to provide participant reimbursements, it must still give
participants an opportunity to claim actual expenses up to the maximum level of
reimbursements established by the State agency.

When should SNAP participants be informed and offered participant
reimbursements?
Starting with screening, through referral to E&T, and during any subsequent
assessment and case management, E&T participants should be regularly informed of
their right to receive participant reimbursements, and the types of participant
reimbursements available. The State agency must also inform all mandatory
participants of their right to be exempted from mandatory E&T if the cost of participant
reimbursements exceed the State cap or the State agency is unable to provide the
reimbursements. This information is also required to be part of the consolidated written

46

notice and oral explanation that all households with members subject to a work
requirement must receive at application, recertification, whenever a member loses and
exemption, and whenever a new member joins the household. As a best practice, the
State agency’s initial screening should identify any participant reimbursement necessary
for successful participation in E&T, and connect the individual to those resources if
referred to E&T.

Do participants have to submit receipts to receive participant
reimbursements?
State agencies have flexibility in how they establish the value of participant
reimbursements. States agencies can provide the payments in advance (e.g. a bus
voucher for the month), or ask participants for receipts. However, State agencies must
be prepared, at FNS request, to demonstrate that participant reimbursements are
reasonable, necessary and directly related to participation in the program.

Can E&T case managers or providers provide participant
reimbursements?
Yes. E&T case managers and providers can provide participant reimbursements to
E&T participants. To be reimbursable the costs must be reasonably necessary and
directly related to participation in the E&T component. The State agency must establish
procedures with E&T providers to ensure participant reimbursements are appropriately
administered.

Can E&T 100 percent funds be used to pay for participant
reimbursements?
No. By statute, E&T 100 percent funds cannot be used to pay for participant
reimbursements. Only E&T 50/50 funds can be used to pay for participant
reimbursements.

Non-compliance with Mandatory E&T
What happens if a mandatory E&T participant does not comply with
mandatory E&T?
The State agency must disqualify mandatory E&T participants who fail to comply
without good cause with E&T program requirements. Compliance in an E&T program is
defined by the State agency, but at minimum should include some level of effort to
perform the first act required by the program, i.e. attending the first training session or

47

making the first job contact. A disqualification for failure to comply applies only to
mandatory participants and not to voluntary participants.

What process must the State agency follow if an E&T participant has
failed to comply with mandatory E&T?
If the State agency has partnered with E&T providers, those partners have 10 days to
inform the State agency of the noncompliance. Whether the State agency has
partnered with E&T providers or not, as soon as the State agency learns of the
individual's noncompliance it must determine whether good cause for the
noncompliance exists. Within 10 days of establishing that the noncompliance was
without good cause, the State agency must provide the individual with a notice of
adverse action. If the State agency offers a conciliation process as part of its E&T
program, it must issue the notice of adverse action no later than the end of the
conciliation period. The good cause determination is a standalone activity that cannot
be blended into the conciliation process or issuance of the notice of adverse action.

What information must the notice of adverse action contain?
The notice of adverse action must explain in easily understandable language the
particular act of noncompliance committed and the proposed period of disqualification.
The notice must also specify that the individual may request a fair hearing and may, if
appropriate, reapply at the end of the disqualification period. Information must be
included on or with the notice describing the action that can be taken to avoid the
disqualification before the disqualification period begins. More information about the
Notice of Adverse Action can be found in the Model Notice Toolkit.

When does the disqualification period begin?
The disqualification period must begin with the first month following the expiration of the
10-day adverse notice period, unless a fair hearing is requested.

What is a conciliation process?
When an individual fails to comply with the general work requirements or mandatory
E&T, the State agency may offer a conciliation process. During the conciliation period
the individual must take action to come into compliance. If a State agency will offer a
conciliation process, it must include the procedures that will be used and the length of
the conciliation period in the E&T State plan.

48

Good Cause
When does an E&T participant have good cause for failure to comply
with mandatory E&T?
The State agency is responsible for determining good cause when a SNAP recipient
fails or refuses to comply with SNAP work requirements. Since it is not possible to
enumerate each individual situation that should or should not be considered good
cause, the State agency must take into account the facts and circumstances, including
information submitted by the employer or E&T provider and by the household member
involved, in determining whether or not good cause exists.
Good cause includes circumstances beyond the member's control, such as, but not
limited to, illness, illness of another household member requiring the presence of the
member, a household emergency, the unavailability of transportation, or the lack of
adequate child care for children who have reached age six but are under age 12. State
agencies may also provide good cause for leaving employment as defined at 7 CFR
273.7(h)(1) and (2).
State agencies must also provide good cause for non-compliance with mandatory E&T
when the State agency is unable to identify an appropriate and available slot in an E&T
program for a mandatory E&T participant.

What does it mean that a State agency is unable to identify an
appropriate and available slot in an E&T program for a mandatory
participant?
State agencies running mandatory E&T programs have the responsibility to ensure
appropriate E&T slots are available for all participants required to participate in E&T. If
a SNAP participant is required to participate in E&T, and there is not an appropriate slot
available, the E&T participant must not be found to have failed to comply with
mandatory E&T. The lack of an appropriate and available slot is not the fault of the E&T
participant and the State agency must provide good cause until an appropriate and
available opening is identified and the participant is informed. Note that State agencies
have the responsibility to not only ensure enough slots are available, but to ensure that
individuals are referred to appropriate components that are well-matched to the
participants’ needs and will advance the participants’ training or experience.

49

An E&T provider reported that a mandatory participant did not show
up or stopped participating. Can the State agency disqualify the
individual for noncompliance?
No. E&T providers must notify the State agency within 10 days of the noncompliance,
but E&T providers cannot make determinations of whether good cause exists and
consequently if an individual should be disqualified. Regulations at 7 CFR 273.7(i)
provide that the State agency is responsible for determining good cause when a SNAP
participant fails or refuses to comply with SNAP work requirements. The determination
of good cause is a certification function and must be performed by State SNAP agency
merit system personnel.
In determining good cause, the State agency must take into account the facts and
circumstances, including information submitted by providers, employers, and by the
household member involved, in determining whether good cause exists. This means
that a State agency cannot act on an incidence of noncompliance with work
requirements based solely on information from an employer or an E&T provider without
first attempting to obtain information from the SNAP participant.

What role do case managers play in determining good cause?
Determining good cause is an eligibility function and not an E&T function. As such, E&T
case managers cannot determine good cause. However, E&T case managers must
report circumstances that may indicate a participant has good cause to the appropriate
staff in the State agency who can then use that information to make a good cause
determination.

Does an ABAWD still have to comply with the ABAWD work
requirement if they received good cause for failure to comply with
mandatory E&T?
If an ABAWD was required by the State agency to participate in SNAP E&T and
received good cause for failure to comply with E&T, then the ABAWD must also receive
good cause for failure to comply with the ABAWD work requirement, with one exception.
If the ABAWD received good cause for non-compliance with mandatory E&T because of
a lack of an appropriate and available opening in an E&T program, then the ABAWD
must not receive good cause from the ABAWD work requirement, unless the ABAWD
should receive good cause for some other reason. This exception exists because
ABAWDs have other ways of meeting the ABAWD work requirement beyond SNAP
E&T.

50

Provider Determinations
What is a provider determination?
An E&T participant may receive a provider determination when the E&T provider
determines the individual is not a good fit for the E&T component in which the individual
is participating. The E&T provider then informs the State agency of the provider
determination and the State agency must take one of four actions to identify a program
or service that may be a better fit for the individual.

What criteria must the E&T provider use to make a provider
determination?
Only the E&T provider has the authority and responsibility to make the provider
determination. Since E&T providers know their programs best, providers have flexibility
to use their own judgment to determine if an individual is not a good fit for their program.
E&T providers must not discriminate against protected classes when making provider
determinations. State agencies should review provider determinations to ensure E&T
providers are making reasonable decisions about which individuals are not a good fit for
their programs. State agencies must ensure E&T providers adhere to all Civil Rights
laws.

What is the difference between provider determinations and good
cause?
Provider determinations are based on criteria, specific to an E&T provider, that establish
who is likely to be successful in a particular E&T component. Individuals with a provider
determination cannot be disqualified for failure to comply with mandatory E&T while the
State agency determines the next step for that individual. Only E&T providers have the
authority and responsibility to make provider determinations. On the other hand, good
cause criteria are used to identify individuals who, through no fault of their own, are not
compliant with a SNAP work requirement (i.e. general work requirements, mandatory
E&T, and the ABAWD work requirement). Individuals who receive good cause for lack
of compliance with a work requirement cannot be disqualified so long as they have good
cause. Only eligibility workers can determine good cause.

How long does the E&T provider have to inform the State agency of
the provider determination?
The E&T provider has 10 days to inform the State agency of the provider determination.

51

How long does the State agency have to inform the participant of the
provider determination?
The State agency has 10 days to inform the participant of the provider determination.

What does the State agency have to tell the individual with the
provider determination?
The State agency must inform the individual of the provider determination and explain
the next steps. The State agency must also inform the individual that a provider
determination does not mean the individual is being disqualified, and provide contact
information if the individual has questions. In the case of an ABAWD who has received
a provider determination, the State agency must also notify the ABAWD that the
ABAWD will accrue countable months toward their three-month participation time limit
the next full benefit month after the month during which the State agency notifies the
ABAWD of the provider determination, unless the ABAWD fulfills the work requirements,
or the ABAWD has good cause, lives in a waived area, or is otherwise exempt.

What action must the State agency take to ensure the individual with
a provider determination is connected to a program with a better fit?
The State agency must take one of the following four actions for an individual with a
provider determination:
1) Refer the individual to an appropriate E&T component. The State agency may
refer the individual to another E&T component; however, as a best practice the
State agency should consider if an individual who has already received a
provider determination is a good candidate for E&T, or if the fourth option below
would be a better fit.
2) Re-assess the individual’s mental and physical fitness. If the individual is not
determined mentally or physically fit, then the individual must be exempted from
mandatory E&T. The State agency may also re-assess the individual for other
exemptions from the general work requirements, mandatory E&T, or the ABAWD
work requirement, as applicable.
3) Refer the individual to an appropriate workforce partnership, if applicable. If the
State agency has certified one or more workforce partnerships, the State agency
may refer an individual to a workforce partnership at the option of the individual.
The State agency must provide individuals with sufficient information about
workforce partnerships to make an informed decision about participating.
4) Coordinate with other Federal, State, or local workforce or assistance programs
to identify work opportunities or assistance for the individual. The State agency
may decide that an individual with a provider determination would be better

52

served by a program outside E&T or a workforce partnership. If the State agency
chooses this option, the State agency must exempt the individual from
mandatory E&T.

When must the State agency take one of the four actions above?
The State agency must take one of the four actions by the individual’s next
recertification.

Can an individual with a provider determination be disqualified for
failure to comply with E&T?
No. An individual with a provider determination cannot be found to have refused without
good cause to participate in mandatory E&T from the time the E&T provider makes the
provider determination until the State agency takes one of the four actions.

How does a provider determination affect ABAWDs?
If an ABAWD is also a mandatory E&T participant, and the ABAWD receives a provider
determination, then the ABAWD cannot be disqualified for failure to comply with the
mandatory E&T requirement. However, the ABAWD is still subject to the ABAWD work
requirement unless the ABAWD has good cause, lives in a waived area, or is otherwise
exempt. ABAWDs subject to the ABAWD work requirement who receive a provider
determination must find another way to fulfill the ABAWD work requirement.
ABAWDs who receive a provider determination will accrue countable months toward the
three month participation time limit the next full benefit month after the month during
which the State agency notifies the ABAWD of the provider determination, unless the
ABAWD fulfills the work requirements in accordance with 7 CFR 273.24, or the ABAWD
has good cause, lives in a waived area, or is otherwise exempt.

E&T Partners
What are E&T partners?
State agencies have flexibility in how they deliver their E&T programs. State agencies
frequently partner with organizations in the community, such as American Job Centers,
community colleges, and community-based organizations, to serve a greater number of
SNAP participants and diversify their E&T component offerings. Partners should have
the expertise and experience to provide high-quality employment and training services
to SNAP participants.

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How are E&T partners funded?
State agencies must enter into a formal agreement with an E&T provider to deliver
services to E&T participants. State agencies may fund E&T partners with 100 percent
funding. If they use State funds, or other non-Federal funds, FNS will provide them with
50 percent reimbursement for allowable expenses.
As 100 percent Federal funds and State funds tend to be limited, in order to grow their
programs, many State agencies enter into partnerships with E&T providers who agree
to provide E&T services to SNAP recipients using their own non-Federal funds. State
agencies then submit these expenditures to FNS as their own. FNS reimburses the
State agencies 50 percent, who then pass reimbursement on to the E&T provider. FNS
has historically referenced partnerships funded this way as “third-party partnerships.”
Third-party partners can receive some 100 percent funding, particularly if they are a
new partner and are building their E&T programs.
For more information on reimbursing E&T providers and allowable costs see Chapter 4.

Can E&T providers provide case management?
Yes. E&T providers can provide case management to E&T participants.

What are the responsibilities of E&T providers?
State agencies must establish an agreement with E&T providers to provide E&T
services and provide oversight to ensure the third party provider complies with all
applicable E&T laws and regulations.
Not all organizations will be a good fit as an E&T provider for a State’s E&T program.
E&T providers must be prepared to identify eligible SNAP participants, identify and track
non-Federal expenditures eligible for reimbursement (as applicable), and collect and
report participant data to the State agency. Depending on the agreement with the State
agency, E&T providers may take on additional responsibilities, such as providing
participant reimbursements and providing E&T case management services.
Partnerships won’t always be a one-size-fits-all approach and State agencies should
carefully consider their own needs for the E&T program as they partner with various
organizations. State agencies should regularly monitor and conduct audits of E&T
providers to ensure that all fiscal and E&T laws and regulations are being met. There
are some activities that are the sole responsibility of the State agency that should never
be taken on by an E&T provider. Among other things, these include screening for work
registrant status, and determining good cause for noncompliance with mandatory E&T.

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What is an intermediary?
An intermediary provides support to State agencies by centralizing and performing a
number of required and essential administrative tasks that a State agency would
otherwise be required to do (note: intermediaries may not perform certification tasks like
screening and issuing SNAP notices). Thus, an intermediary may increase capacity
and support E&T programs by leveraging established leadership roles, key
partnerships, and expertise within the workforce and employment and training arena.

What should a State agency consider if they would like to partner with
an intermediary?
The benefits of an intermediary include:
•

Support expansion of the E&T program by assuming administrative and
operational tasks.

•

Provide flexibility that may not be available within the State agency & State
government.

•

Expedite the process of securing E&T partners.

•

Integrate E&T within the workforce arena by leveraging an intermediary’s
established roles, partnerships, and expertise.

•

Provide access to key partners with limited administrative capacity, but strong
connections to priority populations and communities.

•

Focus on specific workforce arenas and/or target populations, for example:
o Community College/workforce education arena.
o Services for specific populations.
o Services to specific geographic areas.

If a State agency chooses to work with an intermediary, the State agency still remains
responsible for the SNAP E&T program and must be significantly involved in monitoring
the work of the intermediary. Thus, when deciding whether or not to use an
intermediary model, the State agency needs to evaluate their ability to manage the
intermediary versus the amount of benefits derived from having an intermediary. In
addition, when choosing an intermediary, State agencies should consider that an
intermediary needs strong knowledge of E&T policy, particularly fiscal issues, as well as
knowledge of working with partners in the local workforce development system. The
State agency should also consider how the intermediary will be funded; the State
agency may need to use 100% funds (and possibly other funds) to support the
intermediary. Lastly, State agencies using intermediaries should establish clear roles,
responsibilities, and levels of authority to ensure programs are well-managed.

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How can State agencies learn more about identifying and working
with E&T providers?
The SNAP E&T Operations Handbook: A Step-by-Step Guide to Developing,
Implementing, and Growing a SNAP E&T Program is a “soup to nuts” guide for State
agencies and other stakeholders on how to build a SNAP E&T program using E&T
providers, and specifically third-party partners to deliver services. It outlines a “Plan,
Implement, Grow” framework that State agencies can use to thoughtfully plan their
SNAP E&T program growth. In the Handbook, State agencies will find helpful step-bystep information on the following topics:
•

Developing a third-party partnership strategy and implementation plan.

•

Building a system for data tracking, reporting and analysis.

•

Securing third-party partnerships.

•

Building a participant referral system.

•

Building a participant eligibility confirmation system.

•

Third-party providers and invoicing.

Reporting
What is the reporting life cycle?
FNS encourages State agencies to think how the E&T State Plan, the FNS-583, and the
Annual Outcome Report collectively tell a story about the operation of the State’s E&T
program over the course of the year. In the E&T State Plan, the State agency lays out
the plan for the E&T program for the upcoming fiscal year. On the FNS-583, the State
agency reports on E&T program implementation for each quarter. On the Annual
Outcome Report, the State agency reports on outcomes for the E&T program. State
agencies should examine the data in each report and assess whether they align with
one another or signal that program changes should be made for the subsequent fiscal
year. For example, if a State estimates that 250 participants will enroll in an education
component but the 583 data reports only 12 participants, the State could either explore
the component to determine why there is so little take-up or adjust the estimate of
participation for the subsequent fiscal year.

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What reports are required in E&T?
Federal regulations require State agencies to report on their E&T activities in two
Federal reports: the E&T Program Activity Report (also known as the FNS-583) and the
Annual Outcome Report.

What is the FNS-583?
The FNS-583 or Quarterly Participation Report is a quarterly report documenting how
many individuals participated in E&T. The State agency submits an E&T Program
Activity Report to FNS no later than 45 days after the end of each Federal fiscal quarter.
The report contains monthly figures for:
•

Participants newly work registered;

•

Number of ABAWD applicants and recipients participating in qualifying
components;

•

Number of all other applicants and recipients (including ABAWDs involved in
non-qualifying activities) participating in components; and

•

ABAWDs subject to the three month time limit who are exempt under the
State agency's discretionary exemption allowance.

The State agency must also submit annually, on its first quarterly report, the number of
work registrants in the State on October 1 of the new fiscal year.
The State agency must submit annually, on its final quarterly report:
•

The number of individuals of applicants and participants required to
participate in E&T;

•

The number of individuals who began participation in an E&T program;

•

The number of individuals who began participation in an E&T component;

•

The number of applicants and participants determined ineligible for failure to
comply with E&T requirements;

•

A list of E&T components it offered during the fiscal year and the number of
ABAWDs and non-ABAWDs who participated in each; and

•

The number of ABAWDs and non-ABAWDs who participated in the E&T
Program during the fiscal year.

Each individual must be counted only once.

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What is the Annual Outcome Report?
State agencies must submit an Annual Outcome Report by January 1 for the preceding
Federal fiscal year. The annual report must contain the following information
summarizing the E&T activities for the past year.
•

The number and percentage of E&T participants and former participants who
are in unsubsidized employment during the second quarter after completion
of participation in E&T. And the number and percentage of these participants
who:
o Are voluntary vs. mandatory participants;
o Have received a high school degree (or GED) prior to being provided
with E&T services; and
o Are ABAWDs.

•

The number and percentage of E&T participants and former participants who
are in unsubsidized employment during the fourth quarter after completion of
participation in E&T. And the number and percentage of these participants
who:
o Are voluntary vs. mandatory participants;
o Have received a high school degree (or GED) prior to being provided
with E&T services; and
o Are ABAWDs.

•

Median average quarterly earnings of the E&T participants and former
participants who are in unsubsidized employment during the second quarter
after completion of participation in E&T. And the number and percentage of
these participants who:
o Are voluntary vs. mandatory participants;
o Have received a high school degree (or GED) prior to being provided
with E&T services; and
o Are ABAWDs.

•

The total number and percentage of participants that completed an
educational, training work experience or an on-the-job training component.
And the number and percentage of these participants who:
o Are voluntary vs. mandatory participants;
o Have received a high school degree (or GED) prior to being provided
with E&T services; and
o Are ABAWDs.

•

The number and percentage of E&T participants who:

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o Are voluntary vs. mandatory participants;
o Have received a high school degree (or GED) prior to being provided
with E&T services;
o Are ABAWDs;
o Speak English as a second language;
o Are male vs. female
o Are within each of the following age ranges: 16-17, 18-35, 36-49, 5059, 60 or older.
•

Outcome measures for all E&T components identified in a State's E&T State
plan related to components that are designed to serve at least 100
participants a year.

•

State agencies that have committed to offering all at-risk ABAWDs
participation in a qualifying activity and have received Pledge funds must
include:
o The monthly average number of individuals in the State who are at-risk
ABAWDs;
o The monthly average number of individuals to whom the State agency
offers a position in a qualifying activity;
o The monthly average number of individuals who participate in such
programs; and
o A description of the types of employment and training programs the
State agency offered to at risk ABAWDs and the availability of those
programs throughout the State.

Can the State agency examine additional measures in the Annual
Outcome Report?
Yes. State agencies are encouraged to collect additional information that can improve
program performance, particularly information that can improve equity, inclusion, and
equal opportunity for those who are served. For instance, State agencies may track
and report component outcomes by race or ethnicity.

What is an Outcome Measure?
An outcome measure is used to determine the effect – both positive or negative – of an
intervention or training. Outcome measures should be quantifiable. Below are
examples of outcome measures that may be used to determine the effectiveness of an
E&T component. Outcome measures are different from process measures.
•

The percentage of E&T participants who received a credential by the
completion of the training.

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•

The average wage of participants 6 months after completion of the
component.

•

The percent of E&T participants employed 4 months after completion of the
component.

How is an outcome measure different from a process measure?
A process measure is used to determine if a particular intervention was provided.
Unlike an outcome measure, it is not used to determine if the intervention had an effect.
Process measures can be used in E&T to measure how a training was delivered like the
number of people who attended a component, the number of services provided, or the
length of the training. The following are examples of process measures that may be
used to measure how a training was delivered, but should not be used in place of an
outcome measure:
•

The number of E&T participants who completed an E&T component;

•

The number of transportation vouchers distributed to E&T participants; and

•

The number of E&T participants who sat for a credential exam.

Where can I find out more about the E&T Annual Outcome Report?
FNS has provided more information on this website pertaining to the Interim Rule.

How does FNS use the data from the FNS 583 and Annual Outcome
Report?
FNS uses data from the FNS-583 and annual outcome report to monitor program
performance and outcomes, and to identify areas where FNS can offer technical
assistance to improve the program.

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E&T Notices
What notices are required in E&T?
There are no E&T specific notices; however, any notice in the broader SNAP program
may be provided to an E&T participant if the conditions for that notice apply. Among the
required notices most commonly sent to E&T participants are:
•

The consolidated work notice; and

•

The notice of adverse action.

A State agency may also choose to provide certain informational notices to E&T
participants, which are not required, but improve communication with E&T participants.
For instance, a State agency may provide an E&T participant with a notice informing
them of an E&T appointment. State agencies may also choose to send a notice to an
E&T participant with a provider determination informing the individual of that
determination.

What is a consolidated work notice?
The consolidated work notice is a notice provided to any SNAP household where at
least one household member has a work requirement (i.e. the general work
requirement, mandatory E&T, and the ABAWD work requirement). The notice must
include all pertinent information related to each of the applicable work requirements,
including:
•

An explanation of each applicable work requirement;

•

Which individuals are subject to which work requirement;

•

Exemptions from each applicable work requirement;

•

An explanation of the process to request an exemption (including contact
information to request an exemption);

•

The rights and responsibilities of each applicable work requirement;

•

What is required to maintain eligibility under each applicable work
requirement;

•

Pertinent dates by which an individual must take any actions to remain in
compliance with each applicable work requirement;

•

The consequences for failure to comply with each applicable work
requirement;

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•

An explanation of the process for requesting good cause (including examples
of good cause circumstances and contact information to initiate a good cause
request); and

•

Any other information the State agency believes would assist the household
members with compliance.

If an individual is subject to mandatory E&T, the written notice must also explain the
individual’s right to receive participant reimbursements for allowable expenses related to
participation in E&T, up to any applicable State cap, and the responsibility of the State
agency to exempt the individual from the requirement to participate in E&T if the
individual’s allowable expenses exceed what the State agency will reimburse. In
addition, the State agency must provide a comprehensive oral explanation to the
household of each applicable work requirement pertaining to individuals in the
household.

When must the State provide the consolidated work notice?
The consolidated work notice must be provided during eligibility, when a previously
exempt household member or new household member becomes subject to these work
requirements, and at recertification.

What is the notice of adverse action?
The notice of adverse action is a notice sent to a SNAP household when the State
agency intends to disqualify the household or a member of the household from eligibility
for SNAP benefits.

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Chapter 3 – Funding

63

Funding Basics
How is E&T funded?
E&T is funded through three major funding streams: 100 percent funds, 50/50 funds,
and ABAWD Pledge funds. Each of these types of funding is discussed more below.

What are E&T 100 percent funds?
FNS provides State agencies with grant money to fund the administrative costs of an
E&T program. These grants are often called 100 percent funds, because it is 100
percent Federal funding. E&T 100 percent funds can be used for any allowable cost
that is necessary and reasonable for the planning, implementation, and operation of a
State E&T program. This can include hiring a consultant to improve administration,
marketing the E&T program, salaries for third-party providers, as well as State agency
administration of E&T.
E&T 100 percent funds are appropriated annually for E&T programs and distributed to
State agencies based on a formula. A State agency is not obligated to spend all of its
E&T grant money. If these funds have not been spent by the end of the Federal fiscal
year, FNS can reallocate the unobligated, unexpended funds to State agencies that
request additional 100 percent grant money. Additional allocations are subject to
availability.

Are there expenses that 100 percent grant money may not be used
for?
Yes. 100 percent grant money cannot be used to cover other non-E&T processes, such
as the determination of SNAP eligibility or disqualification from SNAP. 100 percent
funds can also not be used for participant reimbursements. Additional information about
allowable and unallowable costs can be found in the section on allowable costs.

How are 100 percent funds distributed to State agencies?
In the Spring, FNS distributes a preliminary allocation memo that approximates the
amount of 100 percent funds each State agency will receive for the upcoming fiscal
year.
The initial allocation of 100 percent Federal funding is based on a formula. Ninety
percent of the grant is based on the number of State work registrants relative to
nationwide statistics. The remaining ten percent is based on the number of ABAWDs in

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a State. Funding is NOT based on the number of participants in an E&T program. No
State receives less than $100,000.
E&T 100 percent funds are two year allocations, but are only available to State
agencies for one fiscal year. Any 100 percent funds that are not spent during the first
fiscal year are recovered by FNS at the end of the fiscal year to be reallocated to other
State agencies for the second fiscal year according to a reallocation formula.

If the number of people participating in the E&T program falls, will the
State’s allocation be reduced for the coming year?
No. E&T grants are based on State work registrants and the number of ABAWDs.
Grants are not based on actual participation. State agencies decide who they will serve
and can exempt individuals, categories of work registrants or all individuals from
mandatory participation in an E&T program. Individuals receiving a State-specific
exemption from mandatory E&T are still counted as work registrants.

What are 50/50 funds?
There are two kinds of 50 percent reimbursement that a State agency can claim. The
first kind is a 50 percent reimbursement for additional administrative costs for the
planning, implementing and operating of an E&T program that exceed the 100 percent
grant.
The second kind of 50 percent reimbursement that a State agency can claim is for
participant reimbursements.

Is there a difference in what can be paid for with 100 percent funds
versus 50/50 funds?
Both 100 percent funds and 50/50 funds can be used to pay for the administrative costs
of the E&T program. However, E&T 100 percent funds cannot be used for any
participant reimbursements, such as transportation, uniforms, or childcare. Only 50/50
funds can be used to cover the costs of participant reimbursements.

May a State agency receive reimbursement for expenses paid for by
the E&T grant?
No. The 100 percent grant may be used to fund 100 percent of the administrative costs
of planning, implementing, and operating a State E&T program in accordance with the
State E&T plan. FNS cannot reimburse State agencies for E&T grant expenditures

65

since that that would be reimbursing Federal funds with Federal funds, which is
unallowable.

Does a State agency have to spend all of its 100 percent funds?
A State agency is not obligated to spend all of its E&T 100 percent funds. If these funds
have not been spent by the end of the Federal fiscal year, FNS will reallocate the
unobligated, unexpended funds to other States that have requested additional 100
percent grant money according to a reallocation formula.
While a State agency does not have to spend all of its 100 percent funds, FNS strongly
encourages State agencies to work with their FNS regional offices to identify local
opportunities to advance the training opportunities for SNAP participants.

Does a State agency have to use all their 100 percent funds before
seeking 50 percent reimbursement of eligible costs?
A State agency does not have to spend the entirety of its 100 percent grant before
claiming a 50 percent reimbursement for additional administrative expenses; however,
spending the 100 percent Federal grant first on allowable administrative costs of
planning, implementing and operating an E&T program makes more sense from a
financial management standpoint.

Are the 50/50 funds a reimbursement or a match?
SNAP E&T is a reimbursement program. In a reimbursement program, in order to be
eligible for payment, funds for allowable activities must be expended, after which FNS
reimburses the State for 50 percent of expenditures. As long as the State agency
records total outlays, FNS will reimburse the State agency 50 percent of the total
outlays. In a matching program, the amount of funds made available to the State
agency is simply matched, usually on a dollar per dollar basis. The distinction means
that under SNAP regulations, cash contributions cannot be used for administrative
costs. The reimbursement model requires that an expense occurred.

Can a State agency use an unallowable cost as the State share to
draw down Federal 50 percent reimbursement?
No. The State agency is reimbursed 50 percent of all allowable administrative costs to
an E&T program. Unallowable costs cannot be charged to the Federal government or
put up as a State expense for 50 percent reimbursement.

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Funding Reallocations
What funds does FNS reallocate?
Every year each State agency receives a specified amount of 100 percent funds. Any
100 percent funds that are not spent by the State agency by the end of the fiscal year
are recouped by FNS and reallocated to other State agencies based on reallocation
criteria.

What criteria does FNS use to reallocate 100 percent funds?
The 2018 Farm Bill established the following reallocation formula for E&T 100 percent
funds:
•

Priority A. Not less than 50 percent shall be reallocated to requesting State
agencies that were awarded grants to operate SNAP E&T pilots under 2014
Farm Bill to conduct E&T pilot programs and activities that FNS determines
have the most demonstrable impact on the ability of participants to find and
retain employment that leads to increased household income and reduced
reliance on public assistance.

•

Priority B. Not less than 30 percent shall be reallocated to State agencies
requesting funds to implement or continue E&T programs and activities that
FNS determines have the most demonstrable impact on the ability of
participants to find and retain employment that leads to increased household
income and reduced reliance on public assistance and that is targeted
toward:
o
o
o
o
o
o

•

Individuals 50 years of age or older;
Formerly incarcerated individuals;
Individuals participating in a substance abuse treatment program;
People with disabilities seeking to enter the workforce;
Other individuals with substantial barriers to employment; or
Households facing multi-generational poverty to support employment
and workforce participation through an integrated and family-focused
approach to providing supportive services.

Priority C. The remainder of the funds shall be reallocated to requesting
State agencies to use for allowable E&T programs and activities that FNS
determines have the most demonstrable impact on the ability of participants
to find and retain employment that leads to increased household income and
reduced reliance on public assistance.

67

When does a State agency need to request reallocated 100 percent
funds?
The State agency should include a request for reallocated funds in the E&T State plan
for the year the State agency would plan to use the reallocated funds. The request must
include a separate budget and narrative explaining how the State agency intends to use
the reallocated funds. FNS will review all State agency requests for reallocated funds
and notify State agencies of the approval of any reallocated funds to allow State
agencies approximately 270 days to use the funds. FNS’ approval or denial of requests
for reallocated funds will occur separately from the approval or denial of the rest of the
E&T State plan.

What information does the State agency need to provide FNS to
request reallocated 100 percent funds?
The State agency request for reallocated funds must contain the following information
for proper review and consideration to occur:
•

The specific amount of additional funds requested.

•

Indicate if the request is to conduct E&T programs and activities authorized
as part of the requesting State’s 2014 Farm Bill pilot (priority A above).

•

Indicate if the request is to target a highly-barriered population and state the
targeted population including any specific characteristic of the individuals to
be targeted, such as disabled veterans (priority B above).

•

Indicate if the request is to conduct other E&T programs and activities that
would meet the requirements of priority C.

•

A detailed plan for the use of the additional funds that includes:

68

New or existing services or initiatives the funds will support.
Cost of these services.
Partners involved.
The location where the services will be provided.
Specific components or activities that will be provided and the
estimated number of participants to be served in each component.
o How the proposed plan enhances existing services or builds new
opportunities for participants to gain access to employment and
training services.
o Any information the State agency has on how the use of additional
funds will support E&T programs and activities that have a
demonstrable impact on the ability of participants to find and retain
employment that leads to increased household income and reduced
reliance on public assistance.
o Any other useful details to better explain the proposed plan for the use
of the additional funds.
o
o
o
o
o

Will a State receive all the reallocated funds they request?
Possibly. FNS must balance requests from many State agencies against the
reallocation criteria and available funds for reallocation. In making reallocation
decisions, FNS aims to maximize the impact of the reallocated funds on advancing the
purpose of E&T.

ABAWD Pledge Funding
What is the ABAWD pledge?
The Act appropriates $20 million every year to State agencies that pledge to serve all
at- risk ABAWDs by offering them a slot in a qualifying activity that fulfills the ABAWD
work requirement. State agencies that pledge must have at-risk ABAWDs that they are
prepared to serve on October 1st. A State agency under a statewide ABAWD waiver
cannot pledge because there are no at-risk ABAWDs.

What is an at-risk ABAWD?
An at-risk ABAWD is an ABAWD who is in the last month of the three month ABAWD
time limit who is not exempt from the ABAWD work requirement, is not subject to an
ABAWD waiver, and has not received a discretionary exemption from the ABAWD work
requirement. At-risk ABAWDs can be either applicants or recipients.

69

What is a qualifying activity?
Qualifying activities include education, training, and workfare activities that fulfill the
ABAWD work requirement. Job search, both supervised and unsupervised, is not a
qualifying component, but it can be offered as part of other E&T components as long as
it comprises less than half of the total required time an ABAWD spends in the E&T
component.

How does a State agency request to be a pledge State?
A State agency must make the request to become a pledge State in the annual E&T
State plan. The request must include the following information:
•

A commitment to comply with the requirements of the pledge;

•

The estimated costs of complying with the pledge;

•

A description of management controls to meet the requirements of the
pledge;

•

A discussion of the State capacity and ability to serve vulnerable ABAWDs;

•

Information about the size and special needs of the State ABAWD population;
and

•

Information about the education, training, and workfare components that the
State will offer to allow ABAWDs to remain eligible.

FNS will review the information in the E&T State plan and may require the State agency
to correct certain deficiencies, including opening findings from a management
evaluation, in order to be eligible to pledge. FNS will not accept any pledges after the
start of the fiscal year.

How does FNS decide how much each pledge State will receive?
Pledge grants are allocated based on the number of ABAWDs in each participating
State as a percentage of ABAWDs in all the participating States. These figures are
taken from FNS quality control data.

What if the amount of pledge funds received by a State agency is not
enough to provide a slot in a qualifying activity to all at-risk
ABAWDs?
By taking the pledge, State agencies are committing serve all at-risk ABAWDs in the
State by offering them a slot in a qualifying activity. If the pledge funds received by a

70

State agency are insufficient to cover this commitment, the State agency must use
additional State funds to ensure that every at-risk ABAWD is served. Also note that the
amount of pledge funds received by a State agency may fluctuate year-to-year,
depending on how many States request and are approved to pledge.

When does the State agency have to offer the qualifying activity?
The regulations do not specify a time-frame for when the State agency has to make the
offer of a qualifying activity. However, the regulations do state that the additional funds
are to be used by the State agency to defray the cost of offering a slot in a qualifying
activity to an at-risk ABAWD applicant or recipient. The regulations also provide that
while a State agency may use a portion of the pledge funding to provide E&T services
to ABAWDs who do not meet the at-risk criteria, the State agency must guarantee that
the ABAWDs who meet the at-risk ABAWD criteria are provided the opportunity remain
eligible.
These regulations taken as a whole make it clear that pledge States must be active and
intentional in their attempt to offer opportunities for at-risk ABAWDs. One way to do this
is to offer these opportunities in the third month. However, given the length of time it
may take to engage and enroll an ABAWD in a qualifying activity, as a best practice
State agencies should attempt to engage the ABAWD as early as possible in their
eligibility period. Thus, a State agency may comply with this requirement by providing
information on the availability of qualifying activities at certification or recertification, as
long as the State agency informs the ABAWD again in their third month that a slot is
available in a qualifying activity.

Does an actual slot in an education, training, or workfare program
need to underlie an offer to an at-risk ABAWD?
Yes, there must be an actual slot. The regulations at 7 CFR 273.37(d)(3)(x) specifically
state that a “slot must be made available” to serve the ABAWD and allow the ABAWD to
remain eligible. In order to make an offer that would permit an ABAWD to remain
eligible for SNAP, an actual slot must exist to allow the ABAWD to meet the ABAWD
work requirement. State funds expended through an approved E&T State plan to meet
the pledge are eligible for 50 percent reimbursement. If a State agency fails, without
good cause, to meet its pledge commitment, the State agency may be disqualified from
participating in subsequent fiscal years.

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Does self-initiated workfare meet the definition of an offer of a
qualifying education, training or workfare opportunity for States
pledging to offer such services?
No. Self-initiated workfare, where the participant finds his or her own workfare slot, does
not meet the definition of an offer of a slot in a qualifying activity. While self-initiated
workfare is one way for an ABAWD to meet the ABAWD work requirement, a pledge
State must take an active and intentional approach to offering an ABAWD a slot in a
qualifying activity. In self-initiated workfare, the participant must take the action and
initiative, thus self-initiated workfare does not meet the conditions of the pledge.

If a pledge State has findings from a SNAP E&T Management
Evaluation (ME) review related to meeting the pledge State
requirements that are unresolved, are they eligible for pledge State
status in the following year?
In order to be approved as a pledge State, the State agency must address any E&T
management evaluation (ME) findings that relate to meeting the pledge State
requirements and be in compliance by October 1st. If a State agency does not address
its deficiencies by the beginning of the new fiscal year, the State agency will not be
allowed to participate as a pledge State.

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Chapter 4 – Allowable Costs

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Allowable Costs - General
Are there general guidelines that can be used to assess whether E&T
expenditures are allowable?
To be allowable, expenditures must be valid obligations of the State, local government,
subrecipient, or contractor and must be necessary, reasonable and allocable charges
under an approved E&T State plan. Allowable costs are specified in Office of
Management and Budget (OMB) cost circulars, SNAP regulations, and FNS policy
guidance.
The following conditions apply to allowable costs for E&T products or services:
•

Must directly relate to an approved E&T component or service, i.e., allocable;

•

Must be necessary and reasonable;

•

Must not be for products or services that are outside the scope of the E&T
program; and

•

Must not be a general expense required to carry out the overall
responsibilities of a State or local government, such as a State’s funding for
education provided for by statute.

The E&T State Plan must contain information about the product or service and its cost.
The Regional Office must review and approve the E&T State Plan in order for a State to
receive reimbursement.

What do the terms “reasonable and necessary” mean when applied to
costs?
All costs covered by E&T must meet a “reasonable and necessary” test.
A cost is reasonable if, in its nature and amount, it does not exceed that which would be
incurred by a prudent person under the circumstances prevailing at the time the
decision was made to incur the costs. Thus, reasonable costs:
•

Provide a program benefit generally commensurate with the costs incurred;

•

Are in proportion to other program costs for the function that the costs serve;
and

•

Are what a prudent person would incur in like circumstances.

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A cost is necessary if it is needed in the performance of the program. Thus, necessary
costs:
•

Are incurred to carry out functions of E&T;

•

Cannot be avoided without adversely affecting program operations;

•

Do not duplicate existing efforts; and

•

Are the net cost after applicable credits. For example, an organization
receives a 5 percent discount for paying for an item with cash that has a list
price of $100, so the organization only pays $95. The organization must
identify the cost of the item as $95 in the SNAP budget.

Where can I find the regulations on allowable costs?
Regulations on allowable costs can be found in the following sections of the Code of
Federal Regulations.
•

OMB regulations: 2 CFR 200

•

Departmental rules: 2 CFR 400

•

SNAP rules: 7 CFR 271 through 285

What are the documentation, reporting and recordkeeping
requirements required for contracts?
For there to be a State agency obligation to pay, there must be legal documents that tie
any expenditure to a payment process, i.e. contract, invoices, checks, etc. Generally
Accepted Accounting Standards apply to the entire contract performance and payment
system. The contract must stipulate the terms and conditions for the entire process,
including performance reporting, invoicing, and payment by the State. There must be a
written trail which may be reviewed by FNS and audited by USDA. 2 CFR 200
(Appendix II) provides direction on what grantees and subrecipients should include as
contract provisions and 2 CFR 200.334 provides that records must be maintained for
three years after grantees or subrecipients make final payments and all pending matters
are closed. These are Federal requirements.

What are the differences in the meanings of costs, expenditures, and
State agency obligations?
“Expenditure” is the correct term when talking about cash outlays. “Costs” is a more
general term that basically means the monetary value assigned to something that has
or will be spent by the grantee. This general term “cost’ may or may not be due for
payment.

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“State Obligation to Pay” is used as a term of art to imply that certain commitments have
been made by a grantee or implementing agent, for which there is a legal requirement
for payment. Generally these result in a commitment to a cost or expenditures as
defined by legal documents, such as contracts or memorandum of understanding.
2 CFR 200.1 provides definitions of financial terms for Federal grants.

What are direct costs?
Direct costs are defined in 2 CFR 200.413 as costs that can be identified specifically
with a particular final cost objective such as:
•

Staff salaries and benefits of employees for the time devoted and identified
specifically to E&T;

•

Cost of materials acquired, consumed, or expended specifically for the
intended purpose (i.e. E&T);

•

Equipment and other approved capital expenditures; and

•

Travel expenses incurred specifically to carry out E&T.

Are there other cost categories?
E&T budgets may include indirect costs as well. Indirect costs are costs incurred by a
State agency or a subrecipient in support of allowable activities that are directly charged
to sponsoring Federal or State agencies. Indirect costs are covered in the following
section. State agencies must charge their indirect costs in accordance with an
approved indirect cost rate agreement.

What administrative expenses are allowable?
Allowable administrative costs are operational costs for E&T, including all administrative
expenses that are reasonable and necessary to operate approved E&T activities.
Allowable administrative expenses include, but are not limited to:
•

Salaries and benefits of personnel involved in SNAP E&T and administrative
support;

•

Office equipment, supplies, postage, and copying/printing costs;

•

Lease or rental costs;

•

Maintenance expenses;

•

Other indirect costs; and

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•

Charges for travel for the purpose of fulfilling the approved E&T State plan
objectives based on official State, local, or university travel regulations. Some
States only allow the use of a State rate for personally owned vehicles (POV).
Other States allow the choice of using the State POV rate or the rate the IRS
announces annually as the federal standard POV rate to calculate the cost of
operating a vehicle for business travel. See the current IRS rate for business
miles.

What administrative expenses are unallowable?
Unallowable costs per 2 CFR 200 for State and local governments include:
•

Bad debts, uncollected accounts or claims, and related costs as outlined in 2
CFR 200.426.

•

Contributions to an emergency reserve or similar provision for unforeseen
events (contingencies). (Note: These are not insurance payments which are
allowable.)

•

Contributions and donations (usually these are political in nature).

•

Costs that are primarily for entertainment, amusement or social activities.
(Note: Meals are cited in the OMB regulations as unallowable but within the
context of training, meals might be allowable.)

•

Fines, violations or penalties for failure to comply with Federal, State, or Local
laws.

•

Costs of general government, such as the Governor’s office. Costs that may
be directly charged to a Federal grant may be allowable; such as if a person
assigned to the governor’s office devotes 100 percent of his/her time to
SNAP. Each situation, however, must be judged on its own merit.

•

Payments to third parties as part of an indemnification agreement.

•

Losses not covered by permissible insurance.

•

Legislative expenses.

•

Shortfalls in one grant cannot be charged to another Federal grant (Recovery
of Costs under Federal Funding Agreements). (Note: This is not the same as
charging two Federal grants for a share of the costs of the activity if both
agencies benefit from the activity funded. However, an allocation basis must
be established for sharing the costs in proportion to the benefit each
receives.)

•

Alcoholic beverages.

•

Advertising and public relations unless used for recruitment of staff,
acquisition of material for the grant, or publishing the results of the grant.
(Note: Paid media buys for educational purposes via an outreach program are

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not precluded by this provision, but note that radio, television and billboard
advertisements that promote SNAP benefits and enrollment are unallowable
costs under SNAP regulations.)
•

Alumni activities.

•

Commencement and convocations.

•

Legal fees that result from a failure to follow Federal, State or Local Laws. If
certain conditions are met, the Federal government may allow some legal
fees in accordance with 2 CFR 200.435.

•

Executive lobbying.

•

Goods and services for private use.

•

Housing and personal living expenses.

•

Fundraising and investment management.

•

Interest costs, with certain exceptions.

•

Political party expenses.

•

Costs incurred before approval of the outreach plan (pre-agreement costs).

•

Scholarships and student aid (except for Institutes of Higher Education).

•

Student activity costs.

•

Travel is allowable but with restrictions as to amount and level of
transportation cost (for example, no first class tickets).

Are subscriptions and professional activity costs allowable?
Cost of memberships for the institution (with staff who work directly on SNAP E&T
activities) in business, technical, and professional organizations are allowable. The cost
must be prorated according to the percentage of time spent by the employees working
on SNAP E&T and consistent with the effort to promote the provision of quality SNAP
E&T activities (2 CFR 200.)
Professional registration or license fees paid by individuals are not allowable since the
fees are considered personal expenses, not institutional expenses.
Conference fees and related travel expenses must be justified and reasonable. The
conference attendance must have a direct link to the activities in the E&T State plan and
the provision of quality SNAP E&T services and activities.

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Is outreach for E&T an allowable cost?
Outreach directed to individuals already enrolled in SNAP to inform them about the
State E&T program is allowable. If a State agency intends to use any radio, television,
or billboards advertisements to conduct this outreach, the State agency must ensure
they do not promote SNAP benefits or enrollment, but can provide information about
E&T to SNAP participants. State agencies may also use social media and websites as
part of an informational campaign to encourage participation in E&T among SNAP
participants.

If E&T services are provided on tribal land, how should those services
be reimbursed?
E&T programs administered on reservations may receive enhanced reimbursement. In
accordance with 7 CFR 281.9(a), if a State agency administers an E&T program on a
reservation, 75 percent of all approved administrative costs incurred on the reservation
for residents of the reservation may be reimbursed by E&T funds. In addition, in some
cases the State agency may receive enhanced reimbursement for E&T activities and
services incurred off the reservation for residents of the reservation when the State
agency is administering SNAP on that reservation.

How are reasonable staff wages and benefits determined?
Staff wages and benefits are set on a reasonable hourly basis in line with the duties
being performed in the E&T State plan, or the Federal minimum hourly wages
established by the United States Department of Labor. The wages under the E&T State
plan are not necessarily the same as wages paid to the individual when they perform
the duties for which they may be credentialed. Their benefits and wages must relate to
the E&T task they perform.
Staff time claimed for E&T activities cannot be used as a reimbursement item for any
other Federal grant. Staff wages eligible for reimbursement may not be based on the
number of people that apply for SNAP (e.g., a set fee for every application submitted by
the staff person). Hourly wages or other forms of compensation for time spent
performing allowable E&T activities are reimbursable. No entity that receives funding
under the FNA may pay staff per application, regardless of the source of funding for
staff wages.
Additionally, the cost of staff time must conform to the established written policy of the
State agency or subrecipient, and be consistently applied to both Federal and nonFederal activities.

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How does one allocate staff time when staff perform work on different
grants?
If Staff perform work chargeable to different grants or programs, the cost of staff time
must be shared across the grants or programs. This is called cost-allocation, a
requirement of 2 CFR 200, Subpart E.
Time sheets or random-moment time study can be used to capture staff time spent on
SNAP E&T activities. Most States have methods to determine how staff time is spent.
However, FNS understands that subrecipients doing SNAP E&T for the first time may
not have the systems in place to evaluate staff time in this manner.
To estimate staff resources for the project budget, a subrecipient may use the State
agency’s cost allocation method. After the project is approved and in operation, the
subrecipient should use time sheets, a random moment time study, or other methods as
approved by FNS to track actual staff time spent on SNAP E&T activities.
As discussed above, a State or subrecipient may not base staff compensation on the
number of people who apply for SNAP.

Must an agency charge the E&T grant the same amount it charges
other grants or payees?
Yes. If the agency provides the same services to multiple grants or payees, the E&T
grant must be charged the same amount as other grantees. If the agency provides a
discount to other grants or payees for the same services, the agency must provide the
same discount to E&T.

When determining the value of allowable goods and services for
reimbursement, may a profit be included?
If the entity is allowed to make a profit (a for-profit entity or not-for-profit entity in certain
circumstances), a reasonable profit may be included in the cost of goods and services
charged to E&T. Government entities are forbidden from charging a profit. Companies
are required to declare their profit/non-profit status with the IRS. Although a profit may
be included, the cost of goods and services must pass the reasonable costs test by
being consistent with market prices for comparable goods and services.
Issues regarding profits normally do not come up in the E&T program since most
grantees and subrecipients are government entities and forbidden from making a profit.
When grant funds pay for services in the private sector, profits are being paid. As long
as the entity is allowed to make a profit a profit may be included in the costs of the
services provided.

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If dealing with for-profit or not-for-profit entities, the profit normally will be built into the
cost of the service being purchased and the profit percentage may not be included as a
number. When an entity says it will perform some service for $75 per case, a judgment
as to whether that charge is necessary and reasonable must be made. If there is a
profit in that $75, the profit is not really being accepted or rejected. The guard against
overcharge is the determination that the expenditure is necessary and reasonable. This
is determined by looking at costs of salaries, supplies and other charges.
Contracts that specify that cost plus a percentage of costs will be used to calculate the
charge are not allowed so grantees and subrecipients may not recognize a profit using
this methodology.

Allowable Components and Related E&T
Costs
May the E&T grant be used to fund an education component?
Yes. Section 6(d)(4)(B)(V) of the Act and 7 CFR 273.7(e)(2)(vi) identify as an allowable
component educational programs or activities to improve basic skills and literacy, or
otherwise improve employability, including educational programs determined by the
State agency to expand the job search abilities or employability of those subject to the
program. However, States implementing the education component must be aware of
how several cost principles relate directly to this component. Due to the unique nature
and rules for the education component, State agencies are encouraged to work with the
FNS Regional offices to determine whether a proposed E&T education component is
allowable.
In general, E&T funding should be used to provide new programs to enhance the
employability of SNAP participants, rather than supplant present State funding for
existing activities. In addition, all E&T activities, including educational activities, must
adhere to Federal cost principles. Federal regulations at 2 CFR 200.444(a)(5) provide
that Federal funds cannot be used for the general costs of State or local government.
This includes general types of government services normally provided to the general
public, such as public education. Lastly, SNAP regulations at 7 CFR 273.7(d)(1)(ii)(C)
have specific requirements for E&T funds used for education. These regulations state
that Federal funds made available to a State agency for the education component shall
not be used to supplant non-Federal funds used for existing services and activities that
promote the purposes of the education component.
In practice this means E&T funding should not be used to provide educational activities
in a State where those same educational activities were already provided by the State
or local government. This includes primary and secondary education, as well as other

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educational activities where the State is providing those educational services. For
example, a State may make a commitment to provide high school equivalency
preparation services to every State resident. In this case, the State has declared their
obligation to fund these services for any State resident and E&T funding could not be
used to supplant the funding for that obligation.
Moreover, when determining the amount to charge the E&T grant, the State agency
must not charge more than what the general public or the client would pay if not
participating in E&T. At an institution of higher education, a State may provide funding
to support the education of students which effectively reduces the amount of tuition
charged to the general public. The State agency may not charge E&T for the difference
between the actual costs of instruction and the tuition and fees that are charged to the
general public. For instance, the actual cost (i.e. faculty time, space) of providing a
community college course may be $750 per student, but the community college only
charges tuition and fees of $500 per student to the general public. The State may not
charge $750 to the E&T grant, since this is not the charge to the general public.

Can E&T funds be used to pay for services associated with high
school?
No. State agencies may not use SNAP E&T funds to pay for costs associated with
programs or courses offered through public high schools. Federal regulations at 2 CFR
200.444(a)(4) provide that Federal funds cannot be used for the general costs of State
or local government. This includes general types of government services normally
provided to the general public, such as public education.
This is true even if the course meets the purpose of SNAP E&T. For example, if a
public high school offers a curriculum choice for a class that leads to an industrywide
credential, SNAP E&T funds cannot be used to pay for any costs associated with that
class.
States agencies should review the December 20, 2020 memo “Use of SNAP
Employment and Training funds for SNAP recipients who are attending high school” if
approached to provide E&T services for high school students.

What if an educational activity, such as vocational training, is
provided by State or local government, but space and funds are
limited and more classes would be required to serve E&T
participants? Can a State agency use E&T funds to pay for additional
slots?
It depends. If the activity is provided as a result of a State commitment to offer the
service to any qualifying individual, then using E&T funds to pay for SNAP participants

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to receive those services would constitute supplanting (as in the example above). This
holds even if the State’s funds are insufficient to cover the number of individuals for
whom the State has committed to provide education services
However, if a training is funded through the State or local government and the State has
only committed to serve a limited number of individuals, E&T funds can be used to
supplement the State or local funding to cover additional “slots” for E&T participants.
This enhances the capacity of the State or local government above and beyond what it
currently is to enable additional SNAP E&T participants to receive the training. As in all
E&T components, reimbursements for education activities must be reasonable,
necessary, and allocable.

What if a community-based organization offers educational activities?
Can a State agency use E&T funds to pay for E&T participants?
A State agency may use E&T funds to pay for educational activities at communitybased organizations provided that they supplement the capacity of the organization to
serve E&T participants without displacing existing funds for current students. The
community-based organization would also need to figure out the per student cost of its
educational activities and allocate costs to the E&T program accordingly. If the
community-based organization charges other grants for these services, the E&T
program must be charged consistently with how the other grants are charged. Costs
charged to the E&T program must be reasonable and necessary. Funds used to
receive reimbursement must not be from a Federal source and cannot be used to meet
the matching requirements of another program.

May E&T funds be used for medical screening to determine physical
or mental fitness for work if a State’s TANF program requires such
screening?
E&T participation commences with the start of participation in an E&T program – either
case management or a component. Consequently, activity prior to an applicant’s
participation in an E&T component, such as this medical screening, may not be charged
to E&T.
However, this charge may be an appropriate administrative charge to the certification
process. Section 6(d)(1)(D)(iii)(II) of the Act prohibits a State agency from using a
meaning, procedure, or determination for SNAP that is less restrictive than what is used
for TANF. Although there is no Federal definition or requirements for establishing
physical or mental incapacity for TANF, State agencies do have flexibility to make their
own eligibility and payment rules. State agencies are prohibited from using Federal
TANF funds to pay for medical services.

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The expense associated with a doctor’s examination or medical assessment required to
substantiate that an individual is unable to participate in work or training activities, or to
establish eligibility under the deprivation factor of incapacity, is an allowable cost for
determining SNAP eligibility. Therefore, SNAP administrative funds (not E&T funds) for
determining eligibility may be used to reimburse State agencies for half of their
expenses for such verification, as this cost is considered reasonable and necessary to
the program. Again, although this may be an allowable SNAP certification cost, E&T
funds cannot be used for this purpose.

May the State agency use E&T funds to pay for solicitation of contract
proposals? For example, if a State agency is issuing a "Request for
Applications" to select three to five contractors to perform E&T
statewide, is the State agency allowed to charge its advertising costs
for the procurement of those services to E&T?
Yes. SNAP regulations allow advertising as an allowable charge if it is being done for
the procurement of goods and services. This assertion is supported in 7 CFR 277
Appendix A, Paragraph A (2)(b) and by the OMB Cost Circular at 2 CFR 200.421.

Third Party Reimbursements
What State or private spending can be used as the State share for a
50/50 reimbursement?
General State funds, local tax levies, donations from private firms or non-profit
organizations are appropriate sources for the State share of E&T funding.
Subrecipients of a State agency, or third-party funders and providers of approved E&T
services, can fund E&T activities and the State agency can reimburse them with 50
percent Federal funds. For nongovernmental organizations, there must be a cash
outlay for the SNAP E&T goods or services provided in order to receive a 50 percent
reimbursement. In-kind contributions from non-government organizations are not
allowable as charges to FNS programs.
The State share of E&T funding for a 50 percent reimbursement cannot be from a
Federal source. Federal E&T funds cannot be used to reimburse expenses paid with
other Federal funds unless specified by Federal legislation.

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If the State agency has agreed to only reimburse a subrecipient a
portion of the subrecipient’s expenditures, may the State agency
receive 50 percent reimbursement based on the subrecipient’s full
expenditure?
For nongovernmental organizations, there must have been a cost (expenditure) for the
goods or services that were provided in order for them to qualify for reimbursement in
E&T. For example, if a non-profit subrecipient spent actual cash for an allowable
activity, 50 percent of the allowable outlay will be reimbursed to the State agency,
provided the following conditions are met: 1) the subrecipient spent funds that did not
include any Federal funds; and 2) the expenditure was for an allowable E&T activity
approved in the E&T State plan. FNS reimburses 50 percent of allowable expenditures
regardless of whether the State agency actually pays the full cost for the activity.
Therefore, regardless of what percentage of allowable expenditures a State agency
agrees to reimburse a subrecipient, FNS has a legal obligation to reimburse 50 percent
of expenditures spent on allowable E&T activities. The State agency must then pass
those funds on to the subrecipient. For instance, the State agency has an agreement
with a subrecipient to reimburse 45 percent of the subrecipient’s allowable E&T
expenditures. The subrecipient expends $100,000 on allowable E&T activities. FNS
will reimburse the State agency $50,000 for the allowable E&T expenditures. The State
agency will then reimburse the subrecipient $45,000.
FNS cautions against contracts where the State agency agrees to reimburse a
subrecipient a fixed amount (e.g. $45,000) rather than a percentage of expenditures
(e.g. 45 percent). Funding in the E&T program is based on an expenditure model. FNS
must only reimburse the State agency for 50 percent of allowable expenditures. Thus, if
the State agency has an agreement with a subrecipient to reimburse $45,000 and the
subrecipient only expends $80,000 on allowable services, FNS is only able to reimburse
the State agency $40,000 (50 percent of expenditures). To avoid improper payments,
FNS recommends State agencies review or audit these types of funding agreements.

How is the amount of reimbursement determined?
Consider this example, the State agency enters into an agreement to pay an
organization one half of the cost of the services it provides. Services costing $120,000
are provided; the negotiated amount that must be paid to the organization by the State
agency is $60,000.
FNS reimburses 50 percent of allowable costs. In this example, the Federal
reimbursement will be $60,000. It does not matter that this is the total amount that will
be charged to the State agency for the services. As long as the government receives
goods or services contracted to be provided consistent to their worth, the Federal
government reimburses the expenditures at a full 50 percent, whether or not the State
agency actually pays the subrecipient any State funds for the services provided. This

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transaction does not short-change the Federal government because the full value
($120,000) of the services was provided. FNS’ concern is not whether the State agency
actually paid the subrecipient full price for expenditures, but rather whether there were
allowable expenditures for which FNS has an obligation to pay. The amount that FNS
reimburses can then be provided to the subrecipient based on the agreement between
the State agency and the subrecipient.
In a similar example, if the subrecipient had expenditures of only $60,000, the
reimbursement would be $30,000. The reimbursement will always be 50 percent of
allowable expenditures in the approved E&T State plan, regardless of how much the
State agency actually pays on the bill (0 percent, 20 percent, 50 percent, or 80 percent).

Why aren’t the services that the State agency doesn’t have to pay for
(that is, the amount the contractor agrees to absorb) a cash donation
or an in-kind?
If there is an expenditure for allowable goods and services approved in the E&T State
plan, it is not in-kind. Also, since no cash is exchanged, a cash donation is not involved.
The State agency may receive reimbursement from FNS for 50 percent of the
expenditure.

Cash Donations
Is the State agency allowed to receive reimbursement for private cash
donations?
Under certain conditions, reimbursement may be provided for private cash donations
spent on E&T. Private cash donations are cash donations from a private source that is
not operating under formal agreement with the State agency to provide local SNAP
services. SNAP regulations at 7 CFR 277.4(c)(2) provide that matching costs may
consist of project costs financed with cash or in-kind contributions donated by other
non-Federal public agencies and institutions. Paragraph (d) provides that except as
prohibited by paragraph (e) (which prohibits matches for in-kinds from nongovernmental entities for SNAP), all such contributions are allowable when certain
conditions are met. Therefore, in order for expenses paid with cash donated to a State
agency to be allowable for reimbursement, the State must obtain a waiver from the
Regional Office. The waiver is basically a statement that four conditions will be met:
•

The cash is under the control of the state (the entity making the donation has
no influence on how the money is spent);

•

The cash will not revert to the donor;

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•

There are no strings attached to the cash; and

•

There will be no advertising use of the cash donation, but acknowledgement
of the donation can be made, such as this action was made possible thru a
donation from Safeway Groceries, or something along those lines.

A waiver is needed for each cash donation. Only cash donations to the State agency
from third parties that are not operating under formal agreement with the State agency
to provide local SNAP services are considered relevant to this section of regulations.

May State agencies obtain general blanket waivers for prior approval
in the event they might receive a private donation, providing there are
also blanket assurances of compliance to the four conditions cited
above?
No. Each private donation warrants separate scrutiny. FNS will not provide approvals
of prospective blanket waivers because there is no information provided in such
waivers, making it not possible to provide the necessary assurances as they pertain to a
specific donation. Such waivers should be sought when a specific cash donation is
impending at which point FNS will process the waiver expeditiously.

Is cash held by local subrecipients considered private cash that may
be Federally reimbursed only after a private cash donation waiver has
been approved?
No, a waiver is not necessary in this situation. Funding held by a State subrecipient of
the State agency is not considered to be private cash and need not be donated to the
State agency in order to be expended for SNAP purposes or Federally reimbursed.
Nothing in Federal policy requires that cash from subrecipients be subjected to the
waiver requirements for private cash donation nor donated to the State agency in order
to be expended for SNAP purposes or Federally reimbursed. This funding is simply a
financial resource of the subrecipient. Consistent with the State plan, the subrecipient
may spend the cash it holds on approved E&T activities and submit its billings to the
State agency, at which point the State agency my reimburse the subrecipient for 50
percent of the subrecipient’s allowable expenses. (Note that States may have different
operating policies.)

Are there limitations on the types of private entities that may make
cash donations for which the State agency may receive
reimbursement?
Cash donations may be accepted from any entity as long as the State agency obtains a
waiver from the Regional Office and the cash donation meets waiver conditions.

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Once the State agency receives the private cash donation (as long as
the donation meets private cash donation conditions and a waiver has
been approved), may the state utilize other organizations to perform
the actual services (public or private)?
Yes. The money may be thought of as State revenue to be spent on allowable program
expenditures by the State agency and its subagents.

In-Kind Expenses
What is the definition of an "in-kind"?
In Federal grants, “in-kind” means a non-cash contribution, usually the value of
volunteer time. But it may also be things like office space. Requirements at 2 CFR
200.967 CFR 3016.3 define third party in-kind contributions as property or services
which benefit a Federally assisted project or program and which are contributed by nonFederal third parties without charge to the grantee or a cost-type contractor under the
grant agreement. FNS does not consider cash to be an in-kind, although some State
agencies may identify cash as an in-kind from a subrecipient or use the term to mean
the funds provided by a subrecipient.

What are common examples of in-kinds?
Examples of in-kind benefits may include:
•

Space donated to a government entity, such as a church basement or a
private university classroom, when the private entity does not expect
reimbursement for use of this space. If the private entity normally charges
rent, the standard rental value can be used as an in-kind value. If not, the
value of the privately owned, donated space would be calculated at
depreciation value or the use allowance rate.

•

A volunteer’s time at a non-Federal, public entity providing SNAP E&T
services. An example would be instructors at a State community college that
volunteer to tutor E&T students outside of class and on-top of their normal
workload without payment. There is no cost outlay. As with other expenses
charged to a Federal grant, a volunteer’s time cannot be billable to any other
Federal grant.

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What types of entities are allowed to receive reimbursements for inkinds?
According to SNAP regulations at 7 CFR 277.4(e), only governmental entities may
receive reimbursements for in-kinds. A governmental entity is defined as any
organization of State or local government that is supported by funds derived from
general tax revenues (receipts) of a State or locality specifically allocated from
appropriate budgetary authority such as a State legislature, county or local government.
Examples of governmental entities that may receive reimbursements for in-kinds
include:
•

Public entities, which are an arm of government;

•

Public libraries;

•

State universities; and

•

State community colleges.

What types of entities are not allowed receive Federal
reimbursements for in-kinds?
Entities that may not receive reimbursement for in-kinds include:
•

Private entities, even if under contract with State government;

•

Private university;

•

Private nonprofits (such as YMCA); and

•

Public/private organizations. *

*There can be entities that are technically classified as public but do not initially appear
to be public entities. For example, in one case USDA Office of General Counsel ruled
that the Almond Board was an instrument of government because it was allowed to
collect taxes. If there are any doubts about the public nature of a third party contributor,
the question should be referred to the Regional Office.

What basis is used to determine whether an entity may receive
reimbursements for in-kinds?
To make this determination, the entity’s establishing authority and work activity need to
be known. For SNAP, only governmental entities may receive reimbursements for inkinds, per 7 CFR 277.4(e).

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What basis is used to determine whether a contribution is “in-kind”
and if it is, whether it is allowable?
The key to understanding policy regarding an in-kind is to know whether the goods or
services that were made on behalf of SNAP E&T incurred costs and were in the
approved E&T State plan. If costs were incurred, then it is not an “in-kind”. If in-kinds
(services and goods that were free to the provider) were used, you will need to know
whether the provider entity is a governmental entity, which is the only type of entity that
may receive reimbursement for in-kinds for SNAP.
Using space as an example:
•

If space is paid for, then it would qualify as an expenditure that may be
reimbursed;

•

If space was free, no costs were incurred, it is an in-kind and may be
reimbursed by SNAP if provided by a governmental entity; and

•

If space was free, no costs were incurred, it is an in-kind, but may not be
reimbursed if provided by a non-governmental agency. This limitation is
unique to SNAP.

Using staff as an example:
•

If paid staff devote 10 percent of their time doing an allowable program
activity, the costs for that 10 percent are considered expenditures that may be
reimbursed;

•

If unpaid staff (volunteers) devote 10 percent of their time doing an allowable
program activity and the provider is a governmental entity, the value of the
services rendered may be reimbursed; and

•

If unpaid staff (volunteers) devote 10 percent of their time doing an allowable
program activity and the provider is not a governmental entity, the value of
their services may not be reimbursed. Again, this limitation is unique to the
SNAP.

Are Federal reimbursements for private in-kinds allowed by SNAP?
No. SNAP only allows State and local governments to charge for in-kinds (non-cash) as
outlays to SNAP, per 7 CFR 277.4(e). As a result, in-kinds from a for-profit entity
cannot be reimbursed. The status of the subrecipient must be established to determine
whether in-kinds are allowable.

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May a State agency seek 50 percent reimbursement or use the E&T
grant to pay for an allowable in-kind from a governmental entity?
Yes. The State agency may seek reimbursement for 50 percent of the value of the
allowable in-kind or expend the 100 percent E&T grant. For example, if a governmental
entity donated space worth $100, the State agency could receive Federal
reimbursement of $50 (one-half the value of the donated service/item) or expend $100
of the 100 percent E&T grant. (See calculating the value of space in government
owned buildings.) For services, the State agency may receive Federal reimbursement
for one-half of the common market rates for the services rendered or expend the 100
percent E&T grant. The value of the service actually rendered must be considered. For
example, if a medical doctor were to volunteer to hand out pamphlets, the value of the
service would not be calculated using doctor’s wages. In addition, if more than one
entity benefits from the donation of goods or services, they should be cost allocated.
For example, if donated computer equipment is used by both SNAP E&T and TANF,
both programs must bear a portion of the cost.

How should a value be set for volunteer services?
As described earlier, volunteer services from private organizations are not eligible for
Federal reimbursement. Use the following principles to set a value for non-Federal
government volunteer service to a State agency:
•

Compute the volunteer’s wages on a reasonable hourly basis in accordance
with the duties being performed for SNAP E&T or based on the Federal
minimum hourly wage established by the United States Department of Labor;

•

Record time for the volunteer; and

•

Do not use the value of the volunteer’s time as a match for any other Federal
grant.

How should a value be set for donated goods?
Use the following principles to set a value for donated goods from a non-Federal
governmental entity to the State agency:
•

Compute the value for goods (other than publicly owned space) on
reasonable fair market value; and

•

Do not use the value of the donated good as a match for any other Federal
grant.

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Building Space
What kind of building space expenses may be incurred?
A State agency or subrecipient can incur expenses related to four possible types of
building space:
•

Space in a publicly (government) owned building;

•

Space in a publicly (government) rented building;

•

Space in a privately owned building; or

•

Space in a privately rented building.

How should a value be set on building space owned by the State
agency?
The costs of space owned by the State agency (publicly owned) may only be recovered
with a depreciation schedule, plus applicable charges for utilities, maintenance, and
general upkeep. Cost for space owned by a public entity cannot be reimbursed based
on private market rental rates, regardless of whether it is direct billed or donated (2 CFR
200.436). SNAP E&T share of the costs should be calculated using the percentage of
square footage used for SNAP E&T. Use allowance is no longer allowable under 2 CFR
200.

What is the policy for calculating privately owned building space
rented by the State agency?
Example: Project Budget Narrative for a Project Involving One Privately Rented
Building:
Here is an example assuming that 6 of the 10 staff in a rented building are involved with
SNAP E&T. The 6 staff average 21% of their time on SNAP E&T. Note that staff
salaries are not used in the calculation.
•

Total square feet occupied = 5,000 sq ft

•

Total staff = 10; SNAP E&T staff = 6; 6 ÷ 10 = .6

•

5,000 sq ft × .6 staff= 3,000 sq ft

If staff average only 21% of their time on SNAP E&T, then 3,000 sq ft × .21 = 630 sq ft
that can be charged to the SNAP E&T program. 630 ÷ 5,000 = .126

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If rent is $100,000 per year then $100,000 × .126 = $12,600 that can be budgeted for
SNAP E&T activity building space.
Example: Project Budget Narrative for a Project Involving Two Privately Rented
Buildings
There are two calculations for this example. The first is a calculation involving multiple
persons at a building conducting outreach, and the second is a calculation involving one
person at a separate location conducting outreach. Note that staff salaries are not used
in the calculation. Below are the calculations for each location:
Calculation for Main Office Space
Location: 123 Main Street, Main Office, MyState (multiple people at location)
•

Total square feet occupied = 5,000 sq ft

•

Total staff = 10; SNAP E&T staff = 6;

•

SNAP E&T staff percentage (SNAP E&T staff ÷ total staff) = 6 ÷ 10 = 60%

•

Square footage used by SNAP E&T staff = 3,000 sq ft

•

Average % of time each SNAP E&T staff member devotes to SNAP = 40%

•

Chargeable SNAP E&T square feet (average % of time times square footage
used by SNAP E&T staff): 40% times 3000 sf = 1200 sq ft

•

% of square feet chargeable to SNAP E&T: (1200 ÷ 5000) = 24%

•

Yearly Rent: $250,000

•

Main Office SNAP E&T Occupancy (total rent times % of square feet
chargeable to SNAP E&T):
o 24% times $250,000 = $60,000

Calculation for Satellite Office Space
Location: 99 Eastern Blvd, Mytown, MyState (1 person at satellite location)
•

Total Square Feet: 200 sq ft

•

Total Staff: 1

•

SNAP E&T staff: 1

•

SNAP outreach staff percentage (SNAP E&T staff ÷ total staff): 1 ÷ 1 = 100%

•

Square footage used by SNAP E&T staff: 200 sq ft

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•

Average % of time each SNAP E&T staff member devotes to SNAP E&T
Program: 50%

•

Chargeable SNAP E&T square feet (average % of time times square footage
used by SNAP E&T staff): 50% × 200 sq ft = 100 sq ft

•

% of square feet chargeable to SNAP E&T (100 sf ÷ 200 sf) = 50%

•

Yearly Rent: $22,000

•

Satellite Office SNAP E&T Occupancy (total rent times % of square feet
chargeable to SNAP E&T): 22,000 times 50% = $11,000

Total for Main Office Space and Satellite Location: $60,000 + $11,0000 = $71,000

What is the calculation for publicly owned building space rented by
the State agency?
The calculation is the same for privately rented building space.

What is the calculation for building space expenses incurred by
subrecipients?
If the subrecipient owns the space it occupies, it incurs building-related costs and claims
SNAP reimbursement for the portion allocable to SNAP E&T. Examples of such cost
items include depreciation, maintenance, security, taxes, insurance, utilities, etc. Such
costs are generally parallel to those incurred by the State agency for space it owns and
occupies (as outlined above).
If the subrecipient occupies space rented from another entity, rent is the principal
occupancy cost for which it claims reimbursement from the State agency. The landlord
sets the subrecipient’s periodic rental payment to recover the cost items (depreciation,
maintenance, security, taxes, insurance, utility, etc.) and also to provide for a profit.
However, some lease agreements may provide for the tenant (that is, the subrecipient)
to pay one or more of those cost items directly; the principal example is utilities.

Property Procurement and Management
What are the rules for property procurement and management?
Prior Federal approval must be received before the State agency may procure or
request reimbursement for equipment valued at more than $5,000. Review and
approval of equipment purchases are normally conducted during review of the proposed
budget when the E&T State plan is submitted to the appropriate Regional Office.

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Budget reviews ensure that proposed equipment requests do not duplicate previous
year’s equipment purchases for the same project.
Inventory records must be maintained for equipment that is paid for in full, or in part,
with Federal funds. A physical inventory is required every two years.

What special considerations are there for States that would like to
operate a laptop loaner program?
State agencies may use SNAP E&T funds —50 percent Federal reimbursement funds
or direct Federal grant funds — to purchase laptops or other computer equipment that
may be loaned to E&T participants. In addition, State agencies must follow Federal cost
principles regarding disposition of equipment.

Indirect Cost Policy
What are indirect costs?
Indirect costs are costs incurred by a State agency or a subrecipient in support of
allowable activities that are directly charged to sponsoring Federal or State agencies.
Indirect costs are often a single amount expressed as a percentage in a project budget.
Indirect costs are also called overhead costs.
Indirect costs are determined either through an approved indirect cost rate or cost
allocation plan that details how the costs are to be shared by the funding agencies.
Indirect cost rates are documented through an indirect cost plan approved by a
cognizant agency. Indirect cost rate plans are usually associated with larger entities.
Small and mid-size subrecipients acting as State agency contractors or subrecipients
may not have an approved indirect cost plan. A cost allocation plan, also approved by a
cognizant agency, is a more extensive plan that combines many different allocations.
Cost allocation plans are most often used by larger grantees.

Which cost items are inherently indirect?
Very few costs are indirect. Most of the cost outlays associated with a project are direct
costs. Classification as direct or indirect normally depends on treatment in the
accounting system prescribed by the State agency. Examples of indirect costs may
include:
•

Staff that support general office administrative functions;

•

Financial staff that handle all billing activities; and

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•

General building maintenance and utility expenses.

What is a cognizant agency?
A cognizant agency is the Federal agency recognized by the Office of Management and
Budget (OMB) as having the predominant interest in terms of program dollars. FNS is
the cognizant agency for a few State agencies although the U.S. Department of Health
and Human Services is the cognizant agency for most. The Federal agency that
provides the most Federal money becomes the cognizant agency for that organization.
FNS may request additional documentation in support of the submitted indirect cost
rate. The State agency and subrecipients should ensure that the approved indirect cost
plan or cost allocation plan from the Federally assigned cognizant agency is available
for FNS review, if needed.

What is acceptable documentation of an approved indirect cost plan?
Supporting documentation can consist of a scanned letter or electronic correspondence
from the cognizant agency to the State agency. State agencies are responsible for
ensuring that indirect costs included in the E&T State plan are supported by an indirect
cost agreement approved by the appropriate cognizant agency and are claimed in
accordance with that agreement.
A subrecipient may have an indirect cost rate already approved by a Federal cognizant
agency because it may receive Federal funding for other activities directly from the
Federal government.

What is an example of an indirect cost rate already approved by a
Federal cognizant agency that should be used in the E&T State plan?
One example is a subrecipient that has an indirect cost rate plan approved for its SNAP
Outreach Plan activities. The same indirect cost rate should be used in both the SNAP
Outreach Plan and the E&T plan.

What if a State agency partners with a subrecipient that does not have
an approved indirect cost rate plan or cost allocation plan?
FNS has determined that under 2 CFR 200.332 the prime grantee (in this case, the
State agency) is responsible for determining the appropriate rate in collaboration with
the subrecipient, unless the subrecipient has an approved Federally recognized indirect
cost rate negotiated between the subrecipient and the Federal Government.

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In the absence of an approved indirect cost rate plan, a State agency and its
subrecipient can make one of three choices each Federal fiscal year. The first two
choices assume that a subrecipient has overhead costs that the project benefits from
and that are not included in the direct cost category.
•

Choice 1: Use the Federal de minimis rate of 10 percent.

•

Choice 2: Seek approval from the cognizant agency to use an indirect cost
rate developed for the project.

•

Choice 3: Use no rate (zero) and do not ask for reimbursement of indirect
costs.

What are the Federal requirements for a subrecipient using the
Federal de minimis rate of 10 percent?
A subrecipient must have indirect costs that benefit the project, which are not already
recouped through direct costs charged to the project. For some small projects all costs
may be directly charged.
The 10 percent rate is the Federal de minimis indirect cost rate that can be used on
Federally funded projects in the absence of a rate approved by a cognizant agency. The
10 percent standard rate may be used indefinitely, and is determined by multiplying 0.10
by the total direct costs.
The 10 percent rate is not to replace a rate approved by a cognizant agency. It is
possible that a State agency or subrecipient has an approved indirect cost rate less
than10 percent. The correct rate to use is the current rate approved by the cognizant
agency, even if it is lower than 10 percent.
If a State agency or subrecipient elects to use the 10 percent indirect cost rate, it must
provide a statement about the types of costs it is seeking to recover through use of the
de minimis rate. The types of costs included in this statement are then compared to the
direct costs charged to the grant. The same costs (such as supervisors, administrative
support, utilities) cannot be included in both categories.

What is involved if a subrecipient wants to develop its own indirect
cost rate plan?
If a subrecipient does not have an approved indirect cost rate or cost allocation plan
from a cognizant agency, the subrecipient may seek approval from the State agency to
use a rate developed by or for it. The State agency must indicate its acceptance of the
subrecipient’s indirect cost rate in the E&T State plan. If the State agency does not
accept the indirect cost rate, the FNS Regional Office also will not accept the rate. In

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addition, the FNS Regional Office may accept or reject the rate based on the rate
computation documents provided.
The State agency should retain documentation of its indirect cost rate review process
for FNS review if needed. In the event a State agency has approved a plan which is
later determined to be unacceptable, indirect costs charged through that plan may be
disallowed.
Contracted accounting services to develop an indirect cost rate are an allowable
program cost. Such costs may be included in the E&T plan budget as either direct or
indirect costs. Note that only the proportionate share of the costs of developing the
indirect cost rate for SNAP E&T may be charged.
If the State agency approves a rate in excess of 10 percent, then supporting
documentation should be provided to FNS. FNS will not approve this portion of the
budget until supporting documentation of the requested rate above 10 percent is
received and found acceptable.

Can a subrecipient organization use the approved indirect cost rate
plan of the State agency?
A subrecipient cannot use the State agency’s approved indirect cost rate. Indirect costs
vary by organization and program. If a subrecipient incurs overhead or indirect costs, it
must have its own, unique indirect cost rate plan or justify use of the 10 percent de
minimus rate.

Can a State agency or subrecipient charge for building space as a
direct cost and use the 10 percent Federal de minimis rate for indirect
costs?
Building space cannot be included as both a direct cost and an indirect cost in a project
budget. Normally, building space is not included in the indirect rate, but if it is, the State
agency or subrecipient cannot claim any additional costs for building space.

Why would a subrecipient choose not to use an indirect cost rate?
It is possible for a subrecipient to incur no indirect costs. For example, a subrecipient
may be entirely dedicated to SNAP E&T and all costs are direct costs. Another
example is a subrecipient whose indirect costs are so low and/or minimal (support staff
spend minimal time on SNAP E&T or there are minimal building maintenance costs)
that it does not want reimbursement because the cost of calculating indirect costs would
be higher than the funding received.

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In a project involving multiple subrecipients, does the lead
subrecipient make the decision concerning the indirect cost rate for
all subrecipients?
Each subrecipient makes its own choice concerning the indirect rate it will use.

If one organization is in multiple State E&T plans, should it use the
same indirect cost rate for each project?
If an organization has an approved indirect cost rate from its cognizant agency, it must
use that rate in each E&T State plan. If the organization does not have an approved
indirect cost rate, it may use different rates for each project following the guidelines
above.

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USDA’s Non-Discrimination Statement
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA)
civil rights regulations and policies, USDA, its Mission Areas, agencies, staff offices,
employees, and institutions participating in or administering USDA programs are
prohibited from discriminating based on race, color, national origin, religion, sex, gender
identity (including gender expression), sexual orientation, disability, age, marital status,
family/parental status, income derived from a public assistance program, political
beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity
conducted or funded by USDA (not all bases apply to all programs). Remedies and
complaint filing deadlines vary by program or incident.
Program information may be made available in languages other than English. Persons
with disabilities who require alternative means of communication to obtain program
information (e.g., Braille, large print, audiotape, American Sign Language) should
contact the responsible Mission Area, agency, or staff office; the USDA TARGET
Center at (202) 720-2600 (voice and TTY); or the Federal Relay Service at (800) 8778339.

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