Community Action and SNAP E&T:
A Flexible Approach to CAA Involvement
Expense options
A CAA can receive SNAP E&T funding in one of two ways: as 100 percent funds or 50/50 funds. These options reflect the two different ways that USDA FNS may allocate funds to a state agency. A CAA may receive one or both types of funding, at the state’s discretion. Remember to check your state SNAP E&T plan to see how the state utilizes the different funding options and the roles that CAAs may play (see Find your state’s SNAP E&T plan).
100 percent funds
A CAA may receive 100 percent funds for its SNAP E&T program expenses. These grants, referred to as “100 percent funds” because they are 100 percent federal funds, cover the CAA’s administrative costs of planning and implementing a SNAP E&T program. 100 percent funds cannot be used for the costs of non-E&T program components, such as determining SNAP eligibility or disqualification. 100 percent funds can pay for certain, designated program expenses such as the provision of tuition, case management, and job development and retention. However, 100 percent funds cannot be used to reimburse participants for costs related to their participation in SNAP E&T, unlike 50/50 funds (see 50/50 funds below).
100 percent funds are limited in that they are awarded to states each year based on a formula tied primarily to the numbers of SNAP Work Registrants in the state. Funding is not based on the number of participants in a state’s E&T program and states are not required to spend all of their 100 percent funds. If the funds have not been spent by the end of the federal fiscal year, USDA FNS can recover the unobligated funds and reallocate them to other states that request additional 100 percent funds. Historically, many states have underspent their 100 percent allocations and consistently returned the funds to USDA FNS.
50/50 funds
It is far more common for a CAA to receive “50/50 funds”. Under this model, a CAA pays for all of its SNAP E&T administrative and program costs up front with non-federal funds, and then requests reimbursement for 50 percent of those expenses from the state in the form of 50/50 SNAP E&T funding. 50/50 funds thus differ from 100 percent funds in that only 50 percent of the funding is provided by SNAP E&T; a CAA must cover the remaining 50 percent with other, non-federal funds.
50/50 funds help states grow their SNAP E&T programs to reach more participants, as third-party partners commit to contributing 50 percent of their SNAP E&T costs under this model. These “50/50 funds” may cover costs that exceed what a CAA covers with its 100 percent funds, since 50/50 funds may be used for additional administrative costs associated with case management and referrals. Also, while 100 percent funds cannot be used for program participant reimbursements, CAAs may use 50/50 funds for those costs, such as transportation, dependent care, training supplies, books, uniforms, licensing fees, and other costs that are reasonable and necessary for program participation.
In many instances, CAAs already offer similar workforce programs and services, and the 50/50 funding model increases their capacity for these efforts. For example, a CAA may operate a transportation program that serves clients by transporting them to work, school, or medical appointments. If the CAA expands that program to include SNAP E&T participants as part of its state’s SNAP E&T program, the CAA could claim 50 percent reimbursement for the costs of transporting those participants.
Since CAAs must front the costs of SNAP E&T under the 50/50 funding model, and ultimately will only receive reimbursement for 50 percent of their total costs, CAAs must ensure that they have enough non-federal funding to meet these cash flow obligations. The Office of Management and Budget’s (OMB’s) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance) prohibits using one federal award to meet the cost sharing requirements of a different federal award, unless the authorizing statute of the federal award explicitly permits using the funding as a match or cost share. 2 C.F.R. § 200.306(b)(5). As such, most federal awards cannot be used to pay the CAA’s cost sharing portion of its SNAP E&T 50/50 funds. One exception is Community Development Block Grant (CDBG) funding, which may be used to pay a required non-federal share for another federal grant program. 42 U.S.C. § 5305(a)(9). Federal CDBG rules clarify that the cost sharing or matching section of the Uniform Guidance does not apply to CDBG grantees and subrecipients. 24 C.F.R. § 570.502(a)(2). This means that CAAs that receive CDBG may consider using this funding to cover the 50 percent cost sharing requirements of 50/50 SNAP E&T funding.
No federal cap currently exists for the total reimbursement a third-party partner could seek under the 50 percent funds option, although states can place caps on these funds and may include limits on reimbursements in the agreement with a partner. A state’s reimbursement amounts and types must be included in the state plan and any changes in reimbursements must be reviewed and approved by FNS. Thus, a CAA partner’s capacity can be informative for a state when it is preparing its plan and setting its funding levels. (See USDA FNS’ resources, SNAP E&T Program Toolkit; SNAP E&T State Plan Handbook; SNAP E&T Operations Handbook). While grant recipients are not required to spend their 100 percent funds (if any) before claiming a 50 percent reimbursement for additional expenses, it makes the most sense from a financial management standpoint to do so.
Fiscal operations
A CAA must consider its participation in SNAP E&T from an operations standpoint to ensure it possesses the fiscal capacity to facilitate the program. CAAs must possess billing and invoicing processes that enable them to receive timely reimbursement of SNAP E&T funding. USDA FNS sets fiscal standards for third-party partners to manage SNAP E&T funds. These standards will be communicated in the provider handbooks and program contracts developed by state SNAP E&T agencies. Keep in mind that fiscal responsibilities, including cost allowability, for all SNAP E&T funding (100 percent funds and 50/50 funds) are governed by the Uniform Guidance (see Laws and regulations).
Additional Resources:
This project has been funded at least in part with Federal funds from the U.S. Department of Agriculture. The contents of this publication do not necessarily reflect the view or policies of the U.S. Department of Agriculture, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.
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