1. American Association of SNAP Directors
The Return of the ABAWD
American Association of SNAP Directors
September 24, 2013
Ed Bolen, Center on Budget and Policy Priorities
Daniel Schroeder, University of Texas, Austin
Kathy Link, Utah Department of Workforce Services

2. FY 2006: Most states had partial waivers
It might be good to also point out that not all of these were on the October-September schedule. These varied, from one town in RI, to almost all of the state in other states.

3. FY 2013: Most states have statewide waivers
Most states eligible for statewide (3 were eligible but chose partial, 2 chose no waiver)

4. FY 2014: Most states still eligible for statewide
Note that I didn’t indicate what they’re actually doing, but just what they’re eligible for. Based off of EUC.

5. FY 2015: Fewer states eligible for statewide
Assuming states will be able to use a trigger notice from October-December 2013 to waive 2015, most states will still be eligible for statewide. AK and WV are close to dipping below the EUC threshold, so may not be eligible for partial. 4 others (KS, MT, HI, UT) have already dipped below and won’t be eligible for a statewide (unless their unemployment increases in the next few months).

6. FY 2016: Most states will need to request a partial waiver
3 states will probably be eligible for statewide, based on having unemployment rates above 20% above the national average for a 24-month period (CA, NV, RI). 2 others (NJ, NC) are close to that level, so may qualify. The others will need to request partial waivers.

7. Now is a good time to review ABAWD policy
Bad news:
The time limit causes hardship for many poor adults
It’s extremely complicated; could mean extra work and errors
Good news:
There’s more flexibility for states than often understood – now is the time to reassess options!

8. The Basics Who is an able-bodied adult without dependents?
Between 18 and 50 years old
Not disabled
Not raising dependent children
Not otherwise exempt
What must ABAWDs do?
Work for an average of 20 hours per week,
participate in a qualifying work activity for an average of 20 hours per week,
participate in workfare, or
Any combination
What happens if they don’t?
Limited to 3 months of SNAP benefits in a thirty-six month period.
How do they requalify?

9. Developing a Plan of Action
What areas can your state still waive?
Who is and is not subject to ABAWD requirements?
Who will the state individually exempt?
Who will be offered qualified training (and what activities qualify)?
How do you track all this?
Training

10. Waiver Options Ways to qualify Flexibility
Statewide or any area within a state
Recent 12 or 3 month average unemployment over 10 percent
Area has been designated a Labor Surplus Area for current fiscal year by DOL
24-month average unemployment rate 20 percent above national average
Low and declining employment to population ratio
Flexibility
Not limited to Fiscal Year timeline
Tip: the Center can help your state prepare a waiver request!

11. Exemptions Under 18 or 50 years or older
Parent of household member under 18
Residing in household with member under 18
Pregnant
Determined by state to be unfit for work
Already exempt from SNAP work requirements
Working an average of 20 hours per week

12. Flexibility with Exemptions
ABAWD definition of disabled: “determined by the State agency to be medically certified as physically or mentally unfit for employment”
Receiving temporary or permanent disability, including private disability
Is obviously mentally or physically unfit for work
Provides a statement from a State-approved medical personnel
In contrast, SNAP general definition requires receipt of a government disability-related benefit.

13. State Definition of “unable to work”
Several ways to qualify
Receive benefits, even temporary
Obviously unfit
3d party verification
Several options to verify
Physician
Physician’s assistant
Nurse
Nurse practitioner
Rep from doctor’s office
Psychologist
Social worker
Other medical personnel

14. Meeting the Work Requirement
Who can be offered a training or work slot?
What options are available?
SNAP E&T
Workfare
Other E&T
What is the state’s capacity
Identify existing E&T programs capacity to serve childless adults
Geographical saturation
Assess ability to expand
Taking the pledge

15. SNAP E&T Can Help Provide Services
100% federal funds
$99 million in FY 2012
50%-50% matching
$240 million in FY 2012
Pledge states
$20 million each year (CO, DE, NY, SD, TX in 2012)
Leveraging funds with community partners

16. E&T Options: 20 hours/week
Education and Training
Basic or vocational education, technical training, on-the-job training and up to half of required hours in job search
Workforce Investment Act programs
Can include job search
Funded by Department of Labor
Trade Act
Training for workers who have lost or may lose jobs
Funded by federal Department of Labor

17. Other Options: Hours Vary
SNAP Workfare
Placement at public and non-profit employers
Can be voluntary with no disqualification for failure to comply
Non-SNAP Workfare
Operated by non-SNAP government agency
Cannot use 100% E&T funding (but may match)
Work Experience
Placements at public and private (including for-profit) employers
Includes self-placement

18. The Individual or “15 percent” Exemption
Exemptions equal to 15 percent of the State’s ABAWD caseload subject to the time limit.
Each exemption extends eligibility to one person for one month (case months). Yes, this is confusing.
Developing an exemption policy:
Check what’s in the bank (or what you owe)
Extend the time limit by adding months to all affected individuals
Target specific geographic areas

19. Automating Exemptions
Rule: Exemptions apply to all individuals in an area not covered by a waiver
First, identify an ABAWD
Next, screen for exemption
If no exemption, then 12 month personal exemption
Tracking

20. Regaining Eligibility
How?
By working for 30 days, meeting an exemption or when the 36 month period ends.
The tricky part: An ABAWD who regains eligibility but then does not meet the work requirement can receive an additional 3 months of benefits.
Only once in a 3-year period
The 3 months must be used consecutively
This must be tracked
Tell clients to flag to let you know when they are working and can qualify for benefits.

21. Tracking It All Systems must be able to track:
36 month clock for each individual
Months in which individual did not meet requirements or be exempt
Months of regained eligibility
Just to make this more complicated
Countable months need not be consecutive
Must track breaks in participation
Only full benefit months count
System must be able to track use of individual exemptions

22. Implementing the ABAWD Three-Month Time Limit
Kathy Link
Utah Department of Workforce Services
September 2013

23. Decision to Implement Statewide
Executive Director made decision to implement the 3-month limit statewide
Decision made in part due to anticipation that Utah would eventually no longer qualify for a statewide waiver
Did not want to implement time limits at same time as ACA
No increase in E&T budget to implement ABAWD time limits
Decision was made to automate E&T and shift staff to case manage ABAWDs

24. Planning Process
Planning began in March 2011 with implementation target date of October 1, 2012
Workgroup formed consisting of:
Policy
Systems
Operations
Phase 1 Automate E&T
Stopped serving volunteers July 1, 2012 (now considered universal customers)
Participate 3 months out of 12

25. Phase 1 (cont.) Phase 2 ABAWD
Modeled SNAP E&T on Unemployment Insurance model
Send notice to mandatory participants with instructions to go online
Complete online assessment to determine if job ready
Complete workshops as assigned by assessment
Resume writing, interviewing skills, social networking, etc
Job search
Phase 2 ABAWD
Most workers did not know ABAWD policy
ABAWD time limits not in new eligibility system
Pulled out old ABAWD policy and current regulations

26. Policy and Program Decisions
Pledge state
ABAWD process
Automated referral made to employment counselor if 0, 1 or 2 months of ABAWD used
Manual referral made to employment counselor by eligibility if all 3 months used so can begin participation immediately
Meet with employment counselor before 4th month
First month of participation is job search and assignment to worksite
Second month and ongoing participate 24 hours per month of worksite

27. Implemented incrementally
Implementation
Implemented incrementally
All new applications beginning October 1 had time limit
Ongoing cases time limit began at first recertification after September 2012
Estimated 17,000 ABAWDs with ongoing cases. Approximately 2800 per month for first six months
Very limited number of 15% exemptions so limited criteria for use

28. Technology New eligibility system (eREP) implemented summer 2010
ABAWD not in production in system when decision made to implement time limits
System changes were made in two phases
October 1 changes –clock started ticking, notices created
January 1 changes-communicate with employment counseling system, ability to be both E&T and ABAWD

29. Two rounds of mandatory in-person training
Training Staff
Two rounds of mandatory in-person training
September 2012 trained on who is an ABAWD, what are work requirements, who is exempt, ABAWD processes, how system changes will work
December 2012 trained on additional systems changes and the more complicated situations including how to handle recipients who are both E&T and ABAWD
Q&A’s sent out to staff

30. Outcomes E&T ABAWD 15% participate
78% of cases that close, close for non-participation
22% of those who close have earnings within 6 months of closure
ABAWD
12% participate
82% of cases that close, close for non-participation
16% of those who close have earnings within 6 months of closure

31. Checklist Policy options Program options Implementation
Identify possible waiver options
Review exemption policy
Unfit for work
Verification
Use of 15% exemptions
Program options
Capacity of state E&T programs
Partnerships with other training programs
Implementation
Develop tracking system and policy
Training for staff
Notice and information to participants

32. Center on Budget and Policy Priorities
Questions?
Ed Bolen
Center on Budget and Policy Priorities