535.1 Supplemental Nutrition Assistance Program Employment and Training Policy

Revised Guidance for Electronically mailing (E-mailing) the Agreement of Mutual Responsibility (AMR) (PA 1661) or Employment Development Plan (EDP) (PA 1531) for Signature, PFS-21619-535 (Revised February 28, 2024, Issued January 25, 2024)

Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) policy applies to individuals who receive SNAP, but are not receiving cash assistance, including ongoing Temporary Assistance for Needy Families (TANF), Transitional Cash Assistance (TCA), or Refugee Cash Assistance (RCA). Individuals who receive both cash assistance and SNAP must follow the E&T policy for TANF recipients noted in Cash Assistance Handbook (CAH) Chapter 135, Employment & Training Requirements.

Participation in E&T activities is voluntary for individuals receiving SNAP benefits. A SNAP recipient may volunteer to participate in any of the nine program activities available through the SNAP E&T program (See Appendix A, SNAP Employment and Training Activities).

7 CFR § 273.7(a)

SNAP recipients may be referred to any of the following contracted programs:

·       SNAP Employment, Advancement, & Retention Network (EARN) (Project Code: SD or SN) focuses on increasing employability through job skills training and case management; or

·       SNAP Keystone Education Yields Success (KEYS) (Project Code: SK) provides support and case management to SNAP recipients attending Pennsylvania’s 14 community colleges; or

·       SNAP 50/50 programs (Project Code: SZ) offer short-term trainings culminating in an industry-recognized credential and/or paid work experience opportunities for populations with barriers to employment.

Contracted program locations and descriptions may be found in Appendix B.

An individual who meets the criteria described in section 535.3 is considered a “work registrant”.  Work registrants are required to accept a bona fide offer of employment and may not voluntarily quit a job or reduce their hours below 30 hours per week (See: section 535.5).

To ensure compliance with Federal reporting requirements, all SNAP recipients must be identified with an appropriate Employment and Training Program (ETP) Status Code in eCIS. See section 535.3, ETP Participation Status Codes.

·        Enter the ETP status code corresponding to the appropriate exemption for all individuals who are exempt from work registration and do not volunteer for SNAP E&T. 

·        Enter ETP Status Code 30 in eCIS for all individuals who do not meet an exemption regardless of participation status

·        Enter ETP Status Code 40 in eCIS for all individuals who meet an exemption and volunteer.

The CAO will work together with a SNAP E&T volunteer to complete the Employment Development Plan, EDP, PA 1531 by telephone, mail, or electronically transmitting the completed form to the volunteer to obtain their signature.

535.11 Referring Individuals to SNAP E&T

Individuals who volunteer to participate in SNAP E&T will be referred to a contracted program that meets their needs and goals.  The CAO will refer SNAP E&T participants to a contracted program in accordance with the SNAP E&T referral guide below. The CAO may either make a direct referral (see: section 535.14) to a contracted program or approve a reverse referral (see: section 535.13) requested by a contracted program.

The CAO will only refer a SNAP E&T participant to a CAO-Directed project (Project Code: SA) if the participant is an ABAWD seeking to meet their work requirement through community service and does not wish to be referred to SNAP EARN.  ABAWDs seeking to meet the work requirement through any other activity must be referred to a contracted program.

The CAO will provide the contracted program with a copy of the signed EDP. In the case of an ABAWD subject to the time limit, the EDP should indicate that the individual is agreeing to participate for at least 20 hours per week.  A non-exempt ABAWD who fails to participate for 20 hours per week is not subject to sanction but may become ineligible for SNAP after three months in accordance with Chapter 536.

In the case of a non-ABAWD SNAP E&T volunteer, the EDP should indicate that the individual is agreeing to “participate for the hours of the program.” An individual who fails to comply with contractor program requirements cannot be sanctioned but will be terminated from the program.

SNAP participants must sign the EDP before special allowances for supportive services (SPALs) are authorized. Once the SNAP participant has signed the EDP and the contracted program has accepted the referral and opened at least one activity code, the CAO may authorize SPALs needed and required for participation in an approved activity. See Section 535.4, Special Allowances for Supportive Services.

535.12 Second and Subsequent Training Policy

For the purposes of second and subsequent training policy, the CAO will not consider the following to be countable past trainings:

·       past trainings that were not supported under Pennsylvania’s TANF or SNAP E&T programs;

·       completion of high school, a high school equivalency program, or an adult basic education program;

·       completion of an English as a second language program;

·       completion of a career readiness program that provides only general work skills training, including but not limited to, WorkKeys®; or

·       any occupation skills program where all requisite coursework was not completed; or

·       any occupation skills program where all requisite coursework was completed but individual was unable to obtain the required certificate, licensure, or industry credential

Requests for training do not need to be submitted to the Bureau of Employment Programs (BEP) when the individual’s training history is limited to the above scenarios.

The CAO will consider a request to pursue a progressively higher credential in the individual’s field (e.g. CNA to LPN) to be a continuation of the prior countable training, rather than a new countable training.  Requests for continuation do not need to be submitted to BEP for approval.

Obtaining BEP Approval for Second and Subsequent Trainings

Requests for second and subsequent countable trainings must be submitted to BEP for approval. BEP will approve the request when the individual is pursuing an occupation listed on the local Workforce Development Area’s High Priority Occupation (HPO) list, as published by the Department of Labor and Industry; AND

·       An individual is unable to become employed in their chosen field due to changes in physical or mental health status; OR

·       An individual no longer has the skill level or aptitude necessary to find employment in their chosen field; OR

·       An individual has a background that now prohibits employment in that field; OR

·       An individual is unlikely to find employment in that occupation in the area in which they reside that will end the individual’s dependency on SNAP benefits.

All second and subsequent training requests should be submitted to the BEP via email at RA-PWBEP.SNAP@pa.gov.

535.13 Reverse Referrals

Contracted programs may submit reverse referrals to the CAO using the Reverse Referral Form, PA 1951.  The goal of the PA 1951 is to assist SNAP recipients not yet enrolled in E&T who approach a contracted program requesting to participate in the SNAP E&T program and receive SPALs for which they are eligible to support the activity.  The reverse referral request is submitted to the CAO by the contracted program on behalf of the recipient.

The PA 1951 will provide information necessary for the CAO to determine if the recipient is eligible for a referral to a specific contracted program and ensure the service authorized is appropriate and allowable.

Within 15 calendar days of receiving the PA 1951, the CAO will:

·       Review the PA 1951 to determine whether the recipient is eligible to be enrolled in SNAP E&T;

·       Complete and/or update an EDP and obtain the recipient’s signature with the assistance of the E&T contractor;

·       Discuss annual and lifetime SPAL limits to support the E&T activity;

·       Determine if any SPALs are needed (such as childcare or transportation) to immediately support the E&T activity;

·       Return a completed copy of the PA 1951 to the recipient and the contracted program indicating whether the referral was approved or rejected;

·       Submit an electronic referral to the program via eCIS; and

·       Narrate when the PA 1951 was received, the outcome, and all actions taken

The institution of the PA 1951 does not change the policy or process for completing the AMR or EDP and submitting an electronic referral via eCIS if the activity is approved. A face-to-face appointment is not required. The EDP may be updated by telephone, and/or with the assistance of a contracted provider. A copy, signed and initialed by the recipient, must be returned to the CAO by either the recipient or contractor.  If a signed copy is not received by the CAO within 10 calendar days of the date the EDP was sent to the recipient for signature, the CAO will reject the reverse referral.

NOTE: The electronic referral to a contracted program and SPALs to support the activity may not be processed until the signed and completed EDP is returned to the CAO.

If the CAO determines the E&T referral is not appropriate, or if the individual and/or contractor does not return a completed EDP, the CAO must notify the recipient and the contracted program by returning a completed PA 1951 indicating that the reverse referral was rejected. The narrative must clearly explain why a referral is not appropriate.

535.14 Direct Referrals

A SNAP recipient does not need to provide a PA 1951 in order to be referred to SNAP E&T program by the CAO.  The recipient may instead contact the CAO directly to request to participate in SNAP E&T, complete or update an EDP, and, if eligible, be referred to an E&T program.  This is also known as a direct referral.

Exception: Most SNAP 50/50 E&T contractors have specific prerequisites participants must meet prior to being able to enroll.  CAOs are encouraged to discuss the appropriate circumstances for making direct referrals with each SNAP 50/50 prior to making any direct referrals.

Within 15 calendar days of receiving a direct request from a recipient, whether verbally, electronically, or in person, who is interested in participating with an E&T contractor, the CAO will:

·       Review whether the recipient is eligible to be enrolled in SNAP E&T;

·       Complete and/or update an EDP;

·       Discuss annual and lifetime SPAL limits to support the E&T activity;

·       Determine if any SPALs are needed immediately (such as childcare or transportation) to support the E&T activity;

·       Notify the recipient of the decision;

·       Submit an electronic referral to the program via eCIS; and

·       Narrate how the request was received, action taken, and the outcome.

Updated October 25, 2022, replacing January 3, 2022