About once every five years, Congress reauthorizes the farm bill, a multiyear law that allows policymakers to make changes to a host of agriculture and food programs; the next reauthorization is slated for 2023. The Supplemental Nutrition Assistance Program’s Employment and Training program (SNAP E&T) will be included in the bill, and the renewal provides Congress an opportunity to strengthen the program. SNAP E&T, an essential tool for promoting stable employment, helps SNAP participants fulfill any work requirements to which SNAP may subject them by providing case management alongside job search services, education, training, and work experience.
The program’s unique flexible reimbursement structure also creates capacity for quality workforce training programs in communities that lack adequate federal and state workforce investment. Many individuals facing employment barriers, such as those returning home from prison, who have limited education, or who have trouble accessing reliable transportation or child care, rely on E&T program partners for work-based learning, credentialing, and paid work experience. However, administrative hurdles hold E&T back, as does a lack of resources that limits the number of people the program can reach and the supports and opportunities it can offer. SNAP E&T could help more people meet their career goals by disregarding income earned during work-based learning activities, increasing available funds to expand essential supportive services, and continuing to improve access to technical assistance.
SNAP E&T capabilities are limited under current law
11.75 per hour
amount earned working 40-hour weeks that would cause a participant with a child to lose SNAP benefits and E&T
The last farm bill, passed in 2018, expanded eligible uses of E&T funds
to include subsidized work-based learning activities. Its problematic implementation, however, provides a clear example of how lacking SNAP E&T services can be. Chief among the problems is that the income earned from these work-based learning activities, such as transitional jobs, internships, apprenticeships, or credential-based training programs, is not disregarded when determining SNAP eligibility
. As a result, SNAP recipients participating in E&T may see reduced benefits before their training is even complete
for earning too much money—or lose access to SNAP entirely. This cuts off a valuable source of food assistance for people and families
who have not yet found stable financial footing.
8.75 per hour
amount earned working 40-hour weeks that would cause an AWAWD household to lose SNAP benefits and E&T
Since individuals enrolled in E&T must be applying for or receiving SNAP benefits, the fact that there is no income disregard may also mean that their access to work or training opportunities and receipt of E&T services can be revoked. According to Center for American Progress calculations, a participant who earns $11.75 an hour and has a child can completely lose their benefits and E&T access by working 40 hours per week. (see Figure 1) The picture is bleaker for able-bodied adults without dependents (ABAWDs), who are typically subject to a three-month time limit for benefits if they are not employed. A one-person ABAWD household can lose all SNAP benefits and access to E&T after earning just $8.75 per hour working 40-hour weeks.
As of 2023, minimum wages are either equal to or higher than $11.75 and $8.75 in 20 and 30 states, respectively. This means that subsidized work-based learning through the E&T program remains inaccessible to large numbers of people across the country, and participants in states with lower minimum wages can still receive significantly reduced SNAP benefits as a result of their enrollment. Such restrictions disincentivize SNAP recipients from working—even though the E&T program is meant to help them fulfill work requirements. This is particularly harmful since research suggests that such intensive subsidized employment models can be effective because they offer valuable work experiences, and a wage, to those with significant employment barriers. Moreover, these opportunities are not the only critical structures lacking in SNAP E&T.
Support services such as ensuring access to transportation, child care, and necessary clothing and supplies are essential pieces of any program aiming to serve economically disadvantaged participants, as they help provide the financial assistance many people need in order to complete an education or training regimen. SNAP E&T provides participants access to supportive services, and its flexibility on which support services it allows leads many community-based organizations to seek E&T funding. But not every participant can receive the same level of help. A report conducted for the U.S. Department of Agriculture’s Food and Nutrition Service found that more than 40 percent of surveyed E&T participants said they never received supportive services during their time with the program, despite nearly 90 percent of surveyed providers stating they offered at least one form of such services. This disconnect leads to fewer people starting or completing a program: They may be unaware of the help they can receive or may require help that a program does not offer, as programs often underestimate the level of need.
Indeed, in recent years, SNAP E&T typically has had low participation rates. An estimated 214,000 people participated in fiscal year 2021, but even in FY 2019, before the COVID-19 pandemic, there were just 406,000 enrollees, while 10.7 million people were subject to SNAP work requirements. While these requirements can be fulfilled in various ways, they too often result not in increased employment but in SNAP recipients’ food assistance being cut off. Making the E&T program more accessible through an earned income disregard and strengthened supportive services would help attract more participants and allow them to keep their benefits; however, administrative complexities embedded in an already small funding structure can limit the capacity for expansion.
Funding for the E&T program is allocated through two main methods: 100 percent and 50/50 funds. The former is provided to states through grants meant to cover the operating costs of running the program and can include additional funds for states that pledge to serve ABAWDs at risk of approaching their three-month time limit and losing benefits. The 100 percent funds comprised $124 million in federal spending in FY 2022. 50/50 funds, meanwhile, received around $512 million in FY 2022; these funds are meant to reimburse 50 percent of the cost of allowable expenses and can be used for administrative purposes if 100 percent funds are already drained to keep the program running, and to reimburse costs related to ensuring participation, such as supportive services. Even though more 50/50 funds are available than 100 percent funds, E&T providers can struggle with affording their share of expenses, as well as with accessing reimbursements. Starting in 2020, the Food and Nutrition Service provided temporary National Partnership Grants to national nonprofit organizations that work with providers both new to and familiar with the E&T program to help them share best practices and learn how to navigate the system, reducing the barrier to entry.
To allow SNAP E&T to continue to evolve and help more people achieve their career goals, Congress should use the 2023 Farm Bill to address the glaring gaps in the program. The following are three ways the federal government can make an immediate impact.
Disregard income earned from E&T activities when determining eligibility for SNAP benefits
Participants should not be faced with the possibility of completely losing their food assistance and access to E&T services in the event that the program finds them a good training opportunity with a wage. Congress should incorporate the Training and Nutrition Stability Act, H.R. 3087, into the broader 2023 Farm Bill in order to correct this error and eliminate the current disincentive to work in SNAP E&T.
Increase 100 percent funding, and raise the reimbursement rate from 50 percent to 100 percent
The smaller $124 million pot of 100 percent funding is not enough for states to expand and innovate within their programs, and administrators often report that insufficient funding makes it difficult for them to increase access to more supportive services. Congress should provide additional 100 percent funds and fully reimburse extra costs, instead of supplying a 50 percent match. This will give E&T programs the flexibility they need to conduct more extensive outreach and support their participants to keep them engaged.
Expand access to technical assistance
The temporary SNAP E&T National Partnership Grants help expand provider access to E&T, as they allow for more enhanced lines of communication to form through more structured, collaborative networks. As E&T grows, Congress should make these grants permanent in order to simplify proper navigation of the program’s environment and orientation of new providers.
SNAP E&T can be much more than a way to fulfill a work requirement; it can be the start of an entirely new livelihood for people with significant barriers to employment. In order to make the most of what E&T has to offer, Congress must ensure that the program is easily accessible and unhindered by a lack of resources.