535.4 Special Allowances for Supportive Services

SNAP recipients who volunteer to participate in SNAP E&T may be eligible to receive Special Allowances for supportive services (SPALs). A SPAL is authorized to enable participation in an activity. Consideration should always be given for the least costly, most practical item or service to meet the need. See Desk Guide for Special Allowances for Supportive Services.

7 CFR 273.7(d)

Eligibility for SPALs is not connected to the number of participation hours or a specific number of attendance days. Instead, eligibility for a SPAL is based on whether or not it is needed and required to support an allowable activity

EXCEPTIONS: SNAP recipients are not eligible to receive SPALs to maintain employment outside of the 90-day SNAP job retention period. Also, expedited SNAP household members are not eligible to receive SPALs until eligibility for ongoing SNAP benefits is determined.

In order to receive a SPAL (or childcare) under SNAP, an individual must be receiving SNAP, but not ongoing TANF, Transitional Cash Assistance (TCA), or Refugee Cash Assistance (RCA).  Individuals receiving ongoing TANF may be eligible for SPALs and childcare under the TANF program (see: Cash Assistance Handbook, Chapter 135.6).  Individuals receiving Diversion or TCA may be eligible for childcare only under “former TANF” rules (see: Cash Assistance Handbook, Chapter 183.711).

SNAP recipients who also receive SSI (A/J/M) and whose child(ren) receive TANF, may volunteer to participate in SNAP E&T and may receive SPALs, but may not receive SNAP-funded childcare.  In such cases, the CAO should explain ineligibility to the client, suppress the 715 – Letter of Potential Child Care Eligibility notice, and prepare a manual PA-162 notice notifying the household of child care ineligibility.

The CAO will issue SPALs when:

·        Participation is not possible without the allowance;

·        The individual does not already have the requested item;

·        The item or service is not available from another source or at no cost to the individual; and

·        All other options have been exhausted;

NOTE: The CAO may not consider federal financial aid received by an E&T participant under Title IV of the Higher Education Act of 1965 to be a resource available to the participant that reduces their need for a special allowance.  Such aid commonly includes, but is not limited to, Pell Grants, Federal Secondary Education Opportunity Grants (SEOG or FSEOG), federal Stafford and Perkins student loans, and income from a federal work-study job.  However, if a participant voluntarily chooses to pay for an item or service from their excess grant or work-study benefits prior to requesting a SPAL, then the CAO may not authorize a duplicate payment or repay the student for a purchase they already made.

Under the terms of their contract with the Bureau of Employment Programs, some contracted programs provide certain items or services at no cost to the individual, either directly or through referral to another source.  Not all contracted programs are contracted to provide such items.  The CAO should work with the contracted programs in their area to determine the circumstances in which these items or services may be available through the contracted program.  If the contracted program does not provide a needed item or service to a participant, the CAO should review for SPAL eligibility.

Time Frames for Approving or Denying a Request for a SPAL

Special allowances for all supportive services will be paid by the CAO in advance of the date that payment is required by the service provider, consistent with the requirements and time frames discussed in this section.    

55 Pa. Code § 165.42(a)

When the CAO obtains or receives verification within five (5) calendar days after the request for a special allowance for supportive services, the CAO will authorize payment no later than ten (10) days after the date of request.   

 55 Pa. Code § 165.45

When the CAO obtains or receives verification more than five (5) calendar days following the request for a special allowance, the CAO will authorize payment no later than five (5) calendar days after the receipt of verification.

NOTE:  In some circumstances it might not be possible to issue a payment via EBT, local issuance check or restricted endorsement check before the date payment is required by an item or service provider. Under these circumstances as with all others, the payment for an approved special allowance request must be authorized within the required time frame, regardless of the length of time needed by the CAO to issue the payment.

When the last day or authorization of payment falls on a weekend or holiday, the CAO will authorize payment on or before the working day immediately preceding the weekend or holiday.

Case Narrative

The CAO must narrate the basis for issuing a SPAL in the case record.  A sample narrative template may be found in Appendix C .

If an individual has been paying for or receiving a recurring item or service (e.g. bus pass) without assistance, the CAO will not issue ongoing SPALs to pay for the item or service unless circumstances have changed that have made it necessary for the individual to request the allowance.

Special Allowance Verification Form

The Special Allowance Verification Form, PA 1883, is used to confirm that the item or service requested is reasonable and necessary to enable participation in SNAP E&T.

The CAO will confirm the need for the allowance by using the PA 1883 in one of several ways.  In most cases, the E&T provider will refer a SNAP E&T participant to the CAO for determination of eligibility for a special allowance.  The provider will confirm that the item/service requested is required to enable participation in the activity by completing the PA 1883.

In other cases, the SNAP E&T participant may come directly to the CAO without a provider referral.  In these cases, the CAO should review verification provided by the individual that confirms the need for the requested item or service.  The CAO may also provide a copy of a blank PA 1883 to the participant to furnish to the education and training provider who will complete the form and return it to the CAO for determination of eligibility.

Ineligibility

If the SPAL Verification Form:

·        Is not returned to the CAO; or

·        Indicates that the requested item or service is not needed/required; or

·        The individual is ineligible for any other reason

Then the CAO will deny the request within required time frames for issuing a SPAL, send a PA/FS 162 notice of ineligibility, and narrate why the request was denied, the time frames, and that a notice was sent.

Estimates

The CAO will request an estimated cost of the required items. The estimate may be produced by the retailer or service provider or can be obtained online.

The CAO may:

·        Research and develop a list with a range of prices for commonly requested items in the area (e.g. a county bus pass).

·        Negotiate costs with local retailers for common items and advise individuals of the availability of these items.

NOTE:  The CAO may not direct individuals to make their purchases at a particular store, but if the individual chooses to purchase the item(s) at a store that charges more, it will be the individual’s responsibility to pay the difference.

An exception may be granted if the individual lives in a rural area where prices may be inflated, but the cost of traveling to stores with lower costs would be unreasonable.

Mileage

Cost estimates are not required for SPALs for mileage. The CAO will use a website that calculates mileage to a given location and the return trip. The mileage rate for participation in E&T activities is 20¢ per mile. Narrate the calculation used to determine the SPAL amount.

·        The individual must provide verification of car ownership prior to the issuance of a mileage SPAL. If verification already exists in the record, the individual does not have to re-verify;

·        If the individual is using a car they do not own to participate, the CAO will require a letter from the owner of the car stating the individual has permission to use the car to participate in the SNAP E&T activity;

·        The individual may request a SPAL of 20¢ per mile to pay a volunteer driver to offset the driver’s costs when being transported to and from program activities.  The individual must provide verification that the car is owned by the volunteer driver prior to issuance of a mileage SPAL.

If the individual must transport their child to or from a child care facility immediately before and after participation in an E&T activity, the CAO must calculate mileage in each direction by adding the distance from the individual’s home to the child care facility and the distance from the child care facility to the location of the E&T activity.  If a SNAP E&T participant receives a mileage SPAL that accounts for mileage to and from the child care facility, then the participant may not claim the mileage as part of a SNAP Dependent Care deduction (see: Chapter 560.5).

Mileage SPALs may also include the costs of estimated tolls and parking fees which are reasonable and necessary for participation in SNAP E&T.

Receipts

An original receipt verifies the item/service was purchased with the SPAL and the SPAL was used for its intended purpose. The original receipt must be provided by the individual within 14 days of receiving the benefit.

Restricted Endorsement Checks or money orders that have been cashed will not be considered a receipt. A receipt showing the purchase/repair must be provided by the individual.

If the individual must retain the original receipt for warranty purposes, it is acceptable for the CAO to make a copy to keep in the case record.

When the CAO issues a public transportation SPAL and a receipt is not available, individuals can provide the CAO with a copy of the pass (for monthly passes) or the CAO can confirm through collateral contact, transit authority websites or other publications the amount (for daily fares) and narrate this information in lieu of a receipt.

The CAO should confirm that the individual is still participating in SNAP E&T before authorizing ongoing transportation SPALs.

Failure to provide receipts can result in an overpayment but does not prevent a SNAP E&T participant from receiving SPALs in the future.

Overpayments

Indicate on the EDP, PA 1531, that an overpayment will be filed if:

·        A receipt is not provided within 14 days; or

·        The amount issued was $10 or more than the amount reflected as spent on the receipt; or

·        The allowance is not used for its intended purpose.

NOTE: When the individual does not attend the activity (zero attendance hours) then the allowance has not been used for its intended purpose and an overpayment should be processed

Narrate that the individual was advised of the receipt verification policy.

If the individual provides the receipt at any time, the CAO should end the overpayment. If the reimbursement process has already begun, repayment will be stopped.
See Supplemental Handbook Section 910.2, When Does An Overpayment Exist.

Method of Issuance

SNAP special allowances related to employment and training activities are processed as One-Time Issuances (OTIs). See Cash Assistance Handbook Section 180.4, The One-Time Issuance.

Special allowances for supportive services will be paid by the CAO in advance of the date that payment is required by the provider to enable the individual to participate in SNAP E&T activities.

Most SPALs are issued via Electronic Benefit Transfer (EBT); however, car repair SPALs must be issued by restricted endorsement through local CAO-issued check.

Ongoing SPALs can only be authorized for a one-month period and must be reviewed before each authorization to ensure that:

·        The recipient remains eligible; and

·        The individual is participating in an approved, allowable activity.

535.41 SPAL Limits

Annual and lifetime limits apply to SPAL issuances.  The CAO will use the program year to track annual limits.  A program year runs from July 1 through June 30.

See section 535.43 for a list of SPALs that may be issued by the CAO and the annual and lifetime limits that apply to each type of SPAL.

When authorizing a SPAL for a SNAP E&T participant, the CAO should always use the 200-series of SPAL issuance codes.

535.42 Volunteer Driver

The E&T participant can request a SPAL of 20¢ per mile to pay a volunteer driver to offset the driver’s costs when being transported to program activities. The SPAL must be issued to the participant via EBT. The participant is then responsible to pay the volunteer driver.

The CAO may approve a SPAL for a car repair for a volunteer driver who is part of the SNAP household.

The CAO may not approve a SPAL for a car repair for a volunteer driver who is not part of the SNAP household.

The CAO may not approve a car purchase for any driver, including a volunteer driver.

535.43  Types of Special Allowances for Supportive Services

ESA-17263-135 SPALs Beyond 12 Months Voc-Ed Time (linked August 7, 2014)

Individuals who request a SPAL from the CAO may be eligible to receive the following items and services:  

55 Pa Code § 165.46

Pre-expenditure approval at the management level is required for all SPALs except mileage (250), public transportation (268), taxi (272), and car/van pool (267).

For car repairs, required repairs include those needed to pass state safety or emissions inspection or to return the vehicle to safe or legal operating condition. An automobile mechanic authorized to perform Pennsylvania state inspection will indicate by written estimate if the repair is necessary to pass state inspection. Documentation of verification received from the mechanic shall be maintained with the case record.

SNAP E&T participants may not receive a SPAL to purchase a car.  Only TANF RESET participants may be eligible to receive a SPAL for car purchase.

 535.44 Unemployed vs Employed

Unemployed

Unemployed individuals who receive SNAP benefits may participate in any activity except SNAP job retention (AC-93).  Unemployed individuals may receive SPALs to support participation in the SNAP E&T activity or activities in which they are participating.

Employed

Employment is not an allowable activity for SNAP E&T participants.  If an employed SNAP-only recipient wishes to volunteer for SNAP E&T, they may do so, however they must agree to perform an activity in addition to their employment.  In such cases, the SNAP E&T participant is eligible only for SPALs (and childcare) which support their participation in the SNAP E&T activity, but they are not eligible for SPALs and childcare to support their unsubsidized employment.

An exception exists for SNAP E&T participants who find employment while participating in a different SNAP E&T activity.  These individuals may be enrolled in the SNAP job retention activity (AC-93) for 90 days following their placement in a job, and may receive SPALs and childcare for the 90-day period.  The CAO is not required to verify that the job resulted directly from participation in SNAP E&T – verification the job offer was accepted while the individual was participating in SNAP E&T is sufficient.

If an individual finds employment while participating in SNAP E&T and meets the criteria to participate in the SNAP job retention activity (AC-93)  but SNAP benefits close for any reason other than a sanction or disqualification, the individual may still receive services and SPALs under the SNAP job retention activity for the full 90-day period.  In such cases, the CAO should email RA-PWBEP.SNAP@pa.gov before closing the budget for instructions on how to proceed.

Updated October 25, 2022, Replacing May 19, 2021