1. Alecia Eubanks, NJ SNAP Unit Supervisor
Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) and the One-Stop: The Foundation to Build a Better Future
Alecia Eubanks, NJ SNAP Unit Supervisor
New Jersey Department of Human Services, Division of Family Development

2. Background
Federal law as implemented by a 2004 state agency reorganization plan consolidated responsibility and authority for all employment-directed and workforce development activities from the NJ Department of Human Services (DHS) to the NJ Department of Labor and Workforce Development (LWD).
Since 2004, DHS has had a formal agreement through a Memorandum of Understanding (MOU) with LWD to provide a full range of employment and job readiness activities in the Work First New Jersey (WFNJ), SNAP, and Child Support programs. The structure and operation of the partnership between DHS and LWD was outlined in the Memorandum of Understanding (MOU).

3. Introduction
New Jersey regulations state that as a condition of eligibility for SNAP, each household member not otherwise exempt must register for and comply with SNAP work requirements.
New Jersey operates a mandatory SNAP E&T program for SNAP participants. Under a mandatory E&T program, a SNAP applicant or participant is required to work register unless determined as meeting an allowable exemption.
10: (a) and 10.4(c)

4. Roles and Responsibility
DHS is the state entity responsible for determining program eligibility and work registration requirement for all programs including SNAP, Temporary Assistance for Needy Families (TANF), and General Assistance (GA).
LWD is the state entity responsible for the administration, design, implementation, and operation of all workforce programs, activities, and initiatives.

5. Terminology E&T Certification: E&T Case Management:
the process of determining whether an individual must be work registered;
the work registration process;
further screening performed during the certification process; and
sanction activity that takes place after the operator of an E&T component reports noncompliance without good cause.
*The certification process is considered ended when an individual is referred to an E&T component for assessment or participation.
E&T Case Management:
Assessment of the individual – One-on-One, group, referrals to another third-party partner for assessment;
Individualized Plans for education, work or non-work components;
Supportive Services – transportation, child care, clothing or supplies for job and/or interview;
Retention services;
Job Placement;
Workfare;
Internship;
Placement Testing;
Educational Components. 
The charging of workers to E&T case management versus certification has been closely monitored in recent years and must be adequately reported. Examine the purpose of the activity to determine whether the cost is allowable (i.e. assessment for exemption from work registration vs appropriateness of activity).

6. Work Registration
The County Welfare Agency (CWA) is responsible for determining whether an individual meets an exemption or is required to work register.
In the event that Labor and Workforce Development (LWD) staff disagree with the CWA determination, LWD staff may request a reconsideration. The CWA’s determination thereafter is final.
10: (b) and (h)

7. General SNAP Work Requirements
SNAP participants who are not specifically exempted by law are subject to work requirements as a condition of eligibility. Non-exempt SNAP participants have to meet the following general SNAP work requirements:
Register for work;
Participate in a SNAP E&T program to the extent required (30 hours a week or average of 120 hours a month);
Participate in workfare, if assigned;
Accept suitable employment, if offered;
Do not voluntarily quit a job of 30 or more hours a week or reduce work effort to less than 30 hours per week.
10: (b)

8. SNAP Work Requirement Exemptions
SNAP participants who meet any of the following are exempt from work registration:
Under 16 years of age or age 60 and over. A person age 16 or 17 may still be exempt if attending school;
One parent or other household member responsible for the care of a child in the SNAP household under age 6;
Responsible for the care of an incapacitated person;
Enrolled at least half-time in an institution of higher education;
Physically or mentally unfit for employment;
Working at least 30 hours a week or average of 120 hours a month at federal minimum wage.
Regular participant in a substance abuse treatment program;
Participating in a TANF work activity;
Receiving or applying for Unemployment Insurance Benefits (UIB);
Receiving or applying for Supplemental Security Income (SSI);
Pregnant woman in the third trimester.
10: (b)

9. Able-Bodied Adults Without Dependents (ABAWDs)
ABAWDs are a subset of the general SNAP population. An ABAWD is a person who is:
Age 18 through 49;
An individual becomes an ABAWD beginning the month after their 18th birthday.
An individual becomes a non-ABAWD beginning the month of their 50th birthday.
Has NO minors in the SNAP household; and
Physically/mentally fit for employment.
10: (c)

10. ABAWD Background
The Food and Nutrition Act limits ABAWD eligibility for SNAP to 3 months in any 36-month period, unless the individual meets the ABAWD work requirement or is otherwise exempt.
States also may qualify to temporarily waive the 3-month time limit in areas with high unemployment or depressed labor markets.
10: (a)

11. ABAWD History
Since the 2008 economic crisis, most states operated under a statewide ABAWD time limit waiver.
New Jersey's statewide ABAWD waiver ended January 1, However, as of January 1, 2018, Atlantic, Cape May, and Cumberland counties were waived from the ABAWD time limit. As of March 1, 2018, the following counties were also waived from the ABAWD time limit: Burlington, Camden, Essex, Gloucester, Mercer, Passaic, Salem, Sussex, Union, and Warren. As of July 1, 2018, New Jersey applied its 15% exemptions for the remaining counties.
The ABAWD time limit waiver and/or use of 15% exemptions DOES NOT remove the work requirement as a general SNAP recipient.

12. ABAWD Work Requirement
As a subset of the general SNAP E&T population, ABAWDs must still meet the overall 30 hour average weekly work requirement. Of that 30 hour requirement, an ABAWD must meet one of the following:
Work an average of at least 20 hours per week (averaged monthly). Work may be paid, in exchange for goods or services (in-kind), or unpaid;
For an average of at least 20 hours per week, participating in and complying with the requirements of any program under the Workforce Innovation and Opportunity Act (WIOA) (formerly the Workforce Investment Act – WIA), or any program under section 236 of the Trade Act of 1974;
10: (a)

13. ABAWD Work Requirement cont’d
Participate in and comply with a workfare program (hours may vary by allotment calculation); or
Any combination of working and participating in a work program described above for an average of at least 20 hours per week.
For every month an ABAWD receives SNAP without meeting at least 20 hours of the work requirement, the ABAWD receives a countable month. ABAWD eligibility for SNAP is limited to 3 countable months in any 36-month period unless the ABAWD resides in an area waived from the time limit or covered by the 15% exemption.
10: (a) and (b)

14. Exempt ABAWDs The ABAWD provision does not apply if the individual is:
Under 18 or age 50 and over;
Living in a waived area;
Certified as physically or mentally unfit for work;
Living with a child under age 18 in the SNAP household or caring for an incapacitated household member;
Pregnant in any trimester (still subject to general SNAP work requirement until third trimester); or
Already exempt from SNAP work registration requirements (see slide 8):
10: (c)

15. Exempt ABAWDs Physically or mentally unfit for employment
An individual is determined to be physically or mentally unfit for employment if the individual:
Is receiving temporary or permanent disability benefits issued by governmental or private sources. This includes persons receiving:
Social Security Disability (SSA),
Supplemental Security Income (SSI) due to disability, and
100% disability through the Veterans Administration (VA).
10: (c)3

16. Exempt ABAWDs Physically or mentally unfit for employment continued
Is obviously mentally or physically unfit for employment as determined by the worker; or
Provides a written or verbal statement from a physician, physician’s assistant, nurse, nurse practitioner, designated representative of the physician’s office, a licensed or certified psychologist, a social worker, or other medical personnel declaring that the individual is physically or mentally unfit for employment. A med-1 can be used but is not a required form for SNAP.
10: (c)3

17. Allowable SNAP E&T Work Activities
Allowable SNAP E&T work activities or components are outlined in a yearly SNAP E&T plan approved by the United States Department of Agriculture Food and Nutrition Service (USDA FNS).
Allowable E&T activities or components may include:
Basic Education/Foundational Skills;
English Language Acquisition;
Job Retention;
Job Search or Job Search Training;
On-the-job Training.
Vocational (Career) or Technical Training;
Work Readiness Training;
Workfare or Community Work Experience.
Activities may not be time limited as in other programs.
*Refer to the current approved NJ SNAP E&T Plan for approved allowable activities.
10: (c)2; 10: , 10.13

18. SNAP E&T Allowances
Participants in an E&T program are entitled to a participant allowance through the CWA for costs that are reasonably necessary and directly related to participation in a SNAP E&T program.
Such costs include but are not limited to:
Dependent care costs;
Transportation up to $6 per day not to exceed $120 per month per participant without DFD approval;
Uniforms;
Personal safety items;
Books;
Training manuals.
As of August 2018, these E&T allowances are able to be issued by the Electronic Benefits Transfer (EBT) card for clients to withdraw the funds to pay for E&T allowances. EBT cards can also be used at a Point of Sale (POS) device with the Quest logo®
10:87-5.9(a)16xix and 10.4(c)5

19. Failure to Comply with SNAP E&T
If an individual subject to mandatory E&T participation fails to comply with work registration or a work activity requirement without good cause, the CWA shall follow disqualification procedures.
While LWD may refer for a disqualification, the CWA is responsible for the final determination of whether to impose a disqualification or if there was good cause.
Good cause includes circumstances beyond the control of the registrant such as, but not limited to, illness of the registrant or another household member, lack of transportation, lack of adequate child care for children up to age 12, or a victim of family violence.
Two hour travel limit exception.
10: , 10.10(b)4, 10.12(c)2i

20. Goal of the E&T Program
The Food and Nutrition Act states 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.
The goal of assessment and placement in work activities is ultimately to help SNAP recipients transition into family-supporting employment and reduce their need for SNAP.

21. Annual Outcome Measures
State agencies must submit an annual report on their E&T programs that includes the number of participants who have gained skills, training, work, or experience that will increase their ability to obtain regular employment
The first report was submitted January 1, 2018.
FNS to monitor State E&T programs and assess their effectiveness.
Provides FNS the authority to require modifications if outcomes are inadequate.

22. Annual Outcome Measures
Five separate reporting measures:
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;
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;
The median quarterly earnings of all 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 participants that completed a training, educational, work experience or on-the-job training component;
Participant characteristic detail.

23. Keys to Success Communication; Use of systems; Understanding policy;
Quality assessments;
Engagement of clients;
Quality and purposeful activities.

24. NJ SNAP Unit Supervisor
THANK YOU
QUESTIONS?
Alecia Eubanks
NJ SNAP Unit Supervisor