Community Action and SNAP E&T:

A Flexible Approach to CAA Involvement

X-factors: CAA considerations 

A CAA that is considering engaging with its state’s SNAP E&T program as a third-party partner also needs to think about certain “x-factors”; factors that are familiar to CAAs, and as a result, could make CAAs particularly good partners for SNAP E&T. We identify a few specific “x-factors” below.

WIOA Collaboration

One such “x-factor” is the potential crossover of federal Workforce Innovation and Opportunity Act (WIOA) funding, which many CAAs receive, and how it impacts a CAA’s design and implementation of its SNAP E&T program. See the Department of Labor’s WIOA page for additional information about the WIOA program. Under WIOA, each state must develop its own workforce development plan to assist job seekers with employment and employment-related education and training, as well as to connect job seekers with employers in the state. WIOA state plans cover four years and include the various resources within the state that provide jobs- and workforce-related programs and services. Some states view their SNAP E&T program as one such resource and incorporate it into their WIOA state plans as part of an overall strategy to address employment needs. SNAP E&T also contemplates coordination between SNAP E&T and WIOA. The 2018 Farm Bill (see Laws and regulations) required state SNAP E&T agencies to include in their annual state SNAP E&T plans information about the extent to which SNAP E&T and WIOA coordinate efforts. Thus, as a starting point, CAAs should consult their state’s SNAP E&T plan to understand the state’s approach to coordinating WIOA and Snap E&T (see Find your state’s SNAP E&T plan).

Because both funding sources support workforce development, there are clear opportunities for SNAP E&T and WIOA to provide complementary programs and services. While WIOA covers workforce development for all job seekers in a state, SNAP E&T specifically targets low-income individuals that often face additional barriers to success, such as the lack of post-high school education, child care, transportation. Among federal workforce programs, SNAP E&T is unique in the flexibility that states have to design programs that provide education and supportive services alongside more traditional employment and training programs.

Recognizing that certain populations of job seekers require more support, WIOA stresses the need to align workforce development programs across a state, and it emphasizes the importance of job-related services for vulnerable populations. WIOA mandates that states prioritize serving certain individuals, including those receiving public assistance such as SNAP. Thus, a logical alignment of WIOA and SNAP E&T is for SNAP E&T to function as a partner in the WIOA “one-stop center” system. These one-stop centers, also known as American Jobs Centers (AJCs), co-locate a variety of employment services in one physical location, and connects customers directly to work-related training and education. The WIOA legislation already requires a number of partner programs, including CSBG employment and training activities, Temporary Assistance for Needy Families (TANF), Job Corps, and unemployment compensation programs, to provide access through the one-stop centers. 29 U.S.C. § 3151 (b)(1). Local workforce boards also have flexibility to include additional partners, including SNAP E&T programs. 29 U.S.C. § 3151(b)(2).

As a result, a CAA that runs a SNAP E&T program may play an important role in the state’s overall WIOA strategy for reaching low-income individuals. CAA staff certainly understand the challenges faced by individuals in low-income communities and have a history of providing supportive services to address education, childcare, transportation, and other barriers to help them navigate those challenges. See SJI’s SNAP E&T: Opportunities for Alignment with WIOA resource.

In some cases, CAAs are required partners for WIOA. A CAA is required to be a WIOA partner when it uses CSBG funding for any employment and training activities, as well as if it operates any of 12 other federally funded programs. See CAPLAW’s WIOA Q&A for Community Action. A CAA required-WIOA partner works with, and in some cases, funds or runs a one-stop center as part of WIOA. In that capacity, it possesses an intricate familiarity with the state’s WIOA plan and approach to workforce development. Any CAA in this position can use that understanding to inform its SNAP E&T activities. A CAA that is a required WIOA partner also likely has relationships with other WIOA partners in the state that it can build on (see Build SNAP E&T partnerships).

CAAs that offer SNAP E&T also can assist with the WIOA requirement that American Jobs Centers prioritize providing services to low-income individuals and recipients of public services. Not only do CAAs provide these services to vulnerable populations, but by working with American Jobs Centers, CAAs can help coordinate efforts between SNAP E&T and WIOA, potentially bridging any gaps that exist, connecting stakeholders, and helping to eliminate redundancies. CAAs have the potential to become “x-factors” themselves in the relationship between SNAP E&T and WIOA, to the benefit of both programs and the people they serve.

Some states have WIOA state plans that include SNAP E&T. Examples of such states include Michigan, Colorado, Tennessee, Minnesota, Massachusetts, Georgia, Connecticut, West Virginia, and South Carolina. See USDA FNS’ SNAP E&T and WIOA resource as well as SJI’s SNAP E&T: Opportunities for Alignment with WIOA resource. USDA has also provided a sample SNAP Employment and Training programs section of WIOA Combined State Plan. These samples can help CAAs identify alignment approaches in their states and how they may fit within them. Alignment examples include: placing SNAP E&T program staff in American Jobs Centers to provide information, coordinate services, handle referrals, and manage elements of program participation; making established WIOA training activities available to SNAP E&T participants; communicating across programs by developing participant tracking and data sharing systems.

TANF Compliance

Another “x-factor” for CAAs to be aware of relates to participant eligibility for SNAP E&T. Specifically, TANF recipients are not eligible to participate in SNAP E&T (narrow exceptions to this prohibition exist in Vermont, Wisconsin, Colorado, and Utah, so CAAs in those states should confirm with their state agencies prior to using SNAP E&T funds to serve TANF recipients). Any third-party partner involved in determining SNAP E&T eligibility and referring participants for program services must have a process in place that ensures participants are not TANF recipients (see Integration with CAA programs). Since CAAs serve low-income populations, including TANF recipients, they are more likely than other CBOs to have existing procedures in place to do this, which can then help CAAs determine the appropriate services each client is eligible to receive.

Additional Resources:  

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