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Hello John!
We are writing to encourage folks to submit a comment in support of the U.S. Department of Agriculture (USDA)’s Proposed SNAP Employment and Training (E&T) rule, which implements provisions of the 2018 Farm Bill that modestly improve state programs. The Supplemental Nutrition Assistance Program (SNAP) plays a critical role in putting food on the tables of millions of people and has been shown to support work, stimulate economic growth, improve academic outcomes for children, and improve health outcomes for recipients. The SNAP E&T program supports a variety of education, training, workforce, and related services to increase the employability of SNAP recipients and, ultimately, reduces the need for SNAP.
In sharp contrast to other recent proposed changes to SNAP rules from the current administration, this proposed rule may help some participants find and keep jobs while addressing some of the problems that E&T programs face in engaging and supporting participants. An important change made in the Farm Bill added both apprenticeships and subsidized employment as allowable activities. We know that subsidized employment is an important equity tool that helps to fight the long-term harmful effects of unemployment, underemployment, and structural barriers to employment for high-barrier populations. Subsidized employment will be an absolutely necessary response to the economic implications of the COVID-19 pandemic—particularly for youth, young adults, justice-involved folks and college students. We ask that you consider in your comments what frame, structure, and employment mix in a subsidized employment program would most benefit the populations you serve.
In addition to subsidized employment, other rule changes of note include requiring case management, requiring stand-alone job search to be supervised, and asking about the processes for verifying SNAP eligibility. Increasing flexibility in both the initial eligibility determination and ongoing verification process can help extend crucial supports to individuals in need.
The rule also clarifies that “good cause” exemptions now apply when there isn’t an appropriate work activity for a mandatory E&T participant to complete. States must determine if good cause was the reason for recipients not completing their 20-hour work or training requirement. If implemented correctly, this ensures that individuals won’t lose SNAP benefits due to the lack of an opportunity to comply with E&T through no fault of their own. We ask that you also consider in your comments how good cause exemptions can be more inclusive of pandemic-related disruptions, similar to recent guidance from the Administration for Children and Families on Temporary Assistance for Needy Families (TANF) good cause exemptions.
Comments are due on June 17, 2020. We urge you to use this template comment and add language specific to your organization’s scope. By submitting comments, you will play an important part in recommending that the USDA’s Food and Nutrition Service allow states to provide subsidized employment as part of SNAP E&T as soon as the health emergency allows. To submit your comment, please click below.
SUBMIT COMMENT HERE
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