Pulling Dollars Out of Your Hat: Understanding Federal Funding

SNAP Employment & Training (E&T) Funds SNAP E&T can serve a population that’s otherwise very hard to reach and serve Flexible nature of the program allows States to integrate SNAP E&T with existing workforce development programs

Structure of Federal SNAP E&T Funding funds are extremely flexible There are three SNAP E&T funding streams States are not currently maximizing their use of E&T funds Federal SNAP E&T Funding Funds Participant Reimbursements Administrative Reimbursements Pledge State (ABAWD) Funds 100 Percent Funds

The Food and Nutrition Service (FNS) provides State Agencies (SA) with grant money to fund the administrative costs of planning, implementing and operating its SNAP E&T program in accordance with its approved State E&T plan A SA's receipt of its 100% Federal E&T grant is contingent on FNS's approval of the SA's E&T plan – FY 2016 plans are currently being reviewed FNS can reallocate unspent funds, but Farm Bill significantly reduced the amount of time we have to spend these funds

100 Percent Funds 90% of the annual 100% Federal E&T grant is allocated based on the number of work registrants in each State as a percentage of work registrants nationwide $90 million a year in formula funds, based primarily on number of work registrants reported on the 583 No State receives less than $50, % funding has been steadily eroded, in part because States aren’t spending this money

100 Percent Funds Cannot be used to determine whether an individual must be work registered or any other screening performed during the certification process, nor for sanction activity that takes place after the operator of an E&T component reports noncompliance without good cause Cannot be used for any participant reimbursements, such as transportation, uniforms or childcare

Pledge State (ABAWD) Funds 10% of the annual 100% Federal E&T grant will be allocated based on the number of ABAWDs in each State $20 million in additional funds for States that pledge to provide E&T services to all at risk ABAWDs Must be a qualifying component; education, training, workfare NOTE: Job search or job search training alone is not a qualifying activity Pledge States must provide services to all at-risk ABAWDs even if federal funds don’t fully cover the costs

CO FY 2014 Expenditures 100% Funds: Authorized: $2,453,217 Expended: $2,264, % Expended ABAWD Funds: Authorized: $1,371,680 Expended: $1,353, % Expended 50% Admin Funds: Authorized: $1,496,861 Expended: $668, % Expended 50% Participant Reimbursement: Authorized: $683,927 Expended: $181, % Expended

MPRO FY 2014 Expenditures 100% Funds: Authorized: $6,885,118 Expended: $5,001, % Expended ABAWD Funds: Authorized: $2,831,860 Expended: $2,627,312 93% Expended 50% Admin Funds: Authorized: $3,392,164 Expended: $1,921, % Expended 50% Participant Reimbursement: Authorized: $1,942,788 Expended: $472, % Expended

50% Reimbursement Funds Where the real potential of the program lies Covers Administrative and Participant Reimbursement costs Extremely flexible funding, but must still be approved in the State E&T Plan – Covers wide array of allowable costs – Can be aligned with other funding streams to fill in “gaps” Right now, this is largely an untapped resource

50% Administrative Funds Additional Administrative funds for the planning, implementing and operating of an E&T program 50% of all other administrative costs incurred by SA’s in operating E&T programs will be funded by the Federal government A SA does not have to spend all of its 100% E&T grant before claiming a 50% reimbursement for additional administrative expenses

50% Administrative Funds Cannot be used to determine whether an individual must be work registered or any other screening performed during the certification process, nor for sanction activity that takes place after the operator of an E&T component reports noncompliance without good cause Cannot be used for any participant reimbursements, such as transportation, uniforms or childcare

50% Participant Reimbursement SNAP regulations require SA’s to reimburse E&T participants, including volunteers, for all actual costs that are reasonable, necessary and directly related to participation in an E&T component FNS will reimburse 50% of SA payments for allowable expenses. – Dependent care costs – Transportation expenses – Books or training manuals – Uniforms – Personal safety items required for participation

50% Participant Reimbursement

SA’s may establish a cap on participant reimbursements Caps can vary within the State. – 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 SA can set different caps on transportation to meet local needs. Less than 20% of all E&T spending goes toward participant reimbursements

50% Participant Reimbursement Cannot be reimbursed if available through another government program or available at no cost to the participant through a private source, e.g., charitable donations Tuition must be the same for E&T participants as for students not participating in SNAP E&T. FNS will only pay for what is charged to the general public and not the overhead or total cost of instruction. Cannot be used for the purpose of overcoming barriers to participation that make clients exempt from Federal work registration altogether or from State E&T Program participation requirements – Drug or Alcohol counseling Cannot include the cost of meals away from home

Third Party Partnerships

What is a Third-Party Partnership? Sometimes also referred to as third-party “match” programs or third-party reimbursement programs E&T services are provided by third parties, such as community colleges and community based organizations Partners pay for services and get reimbursed 50% through Federal funding

Third-Party Reimbursement Models State contracts with local employment and/or education provider to provide E&T services Provider uses non-federal funds to pay for allowable expenses, and submits a claim for reimbursement through the State FNS reimburses State for 50% allowable expenses State passes reimbursement back to partner

Third-Party Reimbursement Models Benefits Maximize dollars already being spent to serve SNAP recipients Expand the types of services available without added State expenditures Allow CBOs and colleges to expand capacity and serve more individuals Create a new funding stream to pay for much needed participant supports Help organizations administer program Ideally, begins to align programs and systems Increase employment and earning for SNAP recipients Challenges Must establish in advance Can be administratively complex Must verify SNAP eligibility Anticipating service levels throughout the year Tracking non-federal funding sources Financing can be especially difficult for smaller CBOs

Thinking about E&T Differently A one size fits all E&T programs don’t work Programs should center on what is best for the individual Individual strengths, weaknesses and barriers must drive strategies for self-sufficiency Case management and participant supports must be integrated into E&T programs to mitigate barriers to success Leverage expertise from multiple sources

Using Third Party Models to Better Serve SNAP Recipients Establish partnerships with agencies, CBOs, and colleges to leverage expertise and resources Develop comprehensive array of services Conduct consistent and meaningful assessments with targeted referrals Leverage community resources to provide participant supports Allow co- enrollment with multiple partners

Alternative Funding Streams State, county or city funds Donations from private firms or non-profits Foundation funds Social venture funds (e.g. Goodwill store revenues) Community Development Block Grants (CDBG) State Need Grants State Worker Retraining Dollars State Opportunity Grants Tuition set-aside resources Other state training funds (ex-offender, homeless, non- custodial parents)

Enhanced Funding

Workfare savings —A political subdivision may share in the benefit reductions that occur when a workfare participant begins employment while participating in workfare for the first time First participation in workfare means performing work for the first time in a particular workfare program. The only break in participation that does not end the first participation will be due to the participant's taking a job which does not affect the household's allotment by an entire month's wages and which is followed by a return to workfare.

Calculating benefit reductions The benefit reduction equals the difference between the last allotment issued before the participant began the new employment and the first allotment that reflects a full months wages attributable to the new job. If the SA knows of other changes besides the new job that affect the household's allotment after the new job began, the SA will obtain the first allotment affected by an entire month's wages from the new job. The SA will then recalculate the allotment to account for the wages, earned income deduction, and dependent care deduction attributable to the new job.

Calculating benefit reductions The difference between the first allotment that accounts for the new job and the recalculated allotment will be the benefit reduction. The SA’s share of the benefit reduction is three times this difference, divided by two The SA will report its enhanced reimbursement to the State agency FNS will reimburse the SA The SA will, upon request, make available for review sufficient documentation to justify the amount of the enhanced reimbursement

Calculating benefit reductions Example: Jon was receiving $150 a month in SNAP benefits. Through participation in SNAP E&T Jon received a job and no longer received SNAP benefits. The amount of enhanced funding the SA is entitled to: $150 – 0 = $150 $150 x 3 = $450 $450/2 = $225

Calculating benefit reductions Example: Heather was receiving $125 a month in SNAP benefits. Through participation in SNAP E&T Heather received a job and reduced her SNAP benefits to $45 a month. The amount of enhanced funding the SA is entitled to: $125-$45 = $80 $80 x 3 = $240 $240/2 = $120

Questions? Chad Imker Senior Program Specialist U.S. Department of Agriculture Food and Nutrition Service Employment & Training Program (303) Reference: E Code of Federal Regulations: bin/ECFR?page=browse 2 CFR, 273.7, http:// bin/ECFR?page=browse E&T Toolkit

Cost Allocation

Funding Process CO submits E&T State plan to FNS/RO/SNAP (August 15) FNS/RO/SNAP approves State Plan by Sept 30 th FNS/RO/FM receives approval letter & waits for the allocated funds FNS/RO/FM receives the notification from FNS/NO of the allocation then we will fund the State Once the State receives these funds then they can fund the participating counties.

Cost Allocation Cost Allocation Process: CFMS (County Financial Management System) contains the logic needed to distribute county administrative cost pools base on staff assignments, time sheets, results of random moment sampling (RMS), and other appropriate bases.

Cost Allocation First method: 100% Direct Charge – This is where an employee works 100% of their time on one program. A certification should be done semi-annual. This certification needs to be signed by the employee and supervisor. Second Method: 100% Time Reporting – The State requires county employees who work on multiple activities: More than one Federal Award A Federal Award and a non-Federal Award An indirect cost activity and a direct cost activity Two or more indirect activities An unallowable activity and a direct or indirect cost activity

Cost Allocation Second Method: 100% Time Reporting – The State requires county employees who work on multiple activities: More than one Federal Award A Federal Award and a non-Federal Award An indirect cost activity and a direct cost activity Two or more indirect activities An unallowable activity and a direct or indirect cost activity

Cost Allocation Third Method: RMS (Random Moment Sampling) – Employees are coded to one specific cost pool according to their job title and duties. (IMRMS - Income Maintenance Random Moment Sampling and SSRMS – Social Services Random Moment Sampling) Random moment sampling statistics are used to allocate pooled administrative county costs.

Cost Allocation Administrative Costs: – State Development Personal Services, Contractual and Other Expenditures – Income Maintenance Training pass thru – Personal Services County Staff, other than Staff Development – County Contractual Personal Services – County Travel – County Operating Expenses – County Cost of Office Space – County Cost of Automated Data Processing – ADP – County Capital Outlays – County-wide Cost Allocation Plans – Special Projects. Costs of special projects are charged to the program benefited, based on program codes indicated on county reports

Questions? Michelle Montoya Grants Management Specialist Financial Management Mountain Plains Region