Pulling Dollars Out of Your Hat: Understanding Federal Funding

SNAP Employment & Training (E&T) Funds

• SNAP E&T can serve a population that’s otherwise very hard to reach and serve

• Flexible nature of the program allows States to integrate SNAP E&T with existing workforce development programs

Structure of Federal SNAP E&T Funding

50-50 funds are extremely flexible

There are three SNAP E&T funding streams

States are not currently maximizing their use of E&T

funds

Federal SNAP E&T Funding

50-50 Funds

Participant Reimbursements

Administrative Reimbursements

Pledge State

(ABAWD) Funds

100 Percent Funds

100 Percent Funds

• The Food and Nutrition Service (FNS) provides State Agencies (SA) with grant money to fund the administrative costs of planning, implementing and operating its SNAP E&T program in accordance with its approved State E&T plan

• A SA's receipt of its 100% Federal E&T grant is contingent on FNS's approval of the SA's E&T plan – FY 2016 plans are currently being reviewed

• FNS can reallocate unspent funds, but Farm Bill significantly reduced the amount of time we have to spend these funds

100 Percent Funds

• 90% of the annual 100% Federal E&T grant is allocated based on the number of work registrants in each State as a percentage of work registrants nationwide

• $90 million a year in formula funds, based primarily on number of work registrants reported on the 583

• No State receives less than $50,000

• 100% funding has been steadily eroded, in part because States aren’t spending this money

100 Percent Funds

• Cannot be used to determine whether an individual must be work registered or any other screening performed during the certification process, nor for sanction activity that takes place after the operator of an E&T component reports noncompliance without good cause

• Cannot be used for any participant reimbursements, such as transportation, uniforms or childcare

Pledge State (ABAWD) Funds

• 10% of the annual 100% Federal E&T grant will be allocated based on the number of ABAWDs in each State

• $20 million in additional funds for States that pledge to provide E&T services to all at risk ABAWDs

• Must be a qualifying component; education, training, workfare

NOTE: Job search or job search training alone is not a qualifying activity

• Pledge States must provide services to all at-risk ABAWDs even if federal funds don’t fully cover the costs

CO FY 2014 Expenditures

100% Funds:Authorized: $2,453,217 Expended: $2,264,603.73 92.31% Expended

ABAWD Funds:Authorized: $1,371,680 Expended: $1,353,645.57 98.69% Expended

50% Admin Funds:Authorized: $1,496,861 Expended: $668,713.57 44.67% Expended

50% Participant Reimbursement:Authorized: $683,927 Expended: $181,104.63 26.48% Expended

MPRO FY 2014 Expenditures

100% Funds:Authorized: $6,885,118 Expended: $5,001,180 72.6% Expended

ABAWD Funds:Authorized: $2,831,860 Expended: $2,627,312 93% Expended

50% Admin Funds:Authorized: $3,392,164 Expended: $1,921,610 56.6% Expended

50% Participant Reimbursement:Authorized: $1,942,788 Expended: $472,234 24.3% Expended

50% Reimbursement Funds

• Where the real potential of the program lies

• Covers Administrative and Participant Reimbursement costs

• Extremely flexible funding, but must still be approved in the State E&T Plan– Covers wide array of allowable costs– Can be aligned with other funding streams to fill in

“gaps”

• Right now, this is largely an untapped resource

50% Administrative Funds

• Additional Administrative funds for the planning, implementing and operating of an E&T program

• 50% of all other administrative costs incurred by SA’s in operating E&T programs will be funded by the Federal government

• A SA does not have to spend all of its 100% E&T grant before claiming a 50% reimbursement for additional administrative expenses

50% Administrative Funds

• Cannot be used to determine whether an individual must be work registered or any other screening performed during the certification process, nor for sanction activity that takes place after the operator of an E&T component reports noncompliance without good cause

• Cannot be used for any participant reimbursements, such as transportation, uniforms or childcare

50% Participant Reimbursement

• SNAP regulations require SA’s to reimburse E&T participants, including volunteers, for all actual costs that are reasonable, necessary and directly related to participation in an E&T component

• FNS will reimburse 50% of SA payments for allowable expenses.– Dependent care costs – Transportation expenses – Books or training manuals – Uniforms – Personal safety items required for participation

50% Participant Reimbursement

50% Participant Reimbursement

• SA’s may establish a cap on participant reimbursements

• Caps can vary within the State. – For example, if one area of the State has higher transportation

costs than others, such as a metropolitan area with bus vouchers versus a rural area where participants need gas cards, the SA can set different caps on transportation to meet local needs.

• Less than 20% of all E&T spending goes toward participant reimbursements

50% Participant Reimbursement

• Cannot be reimbursed if available through another government program or available at no cost to the participant through a private source, e.g., charitable donations

• Tuition must be the same for E&T participants as for students not participating in SNAP E&T. FNS will only pay for what is charged to the general public and not the overhead or total cost of instruction.

• Cannot be used for the purpose of overcoming barriers to participation that make clients exempt from Federal work registration altogether or from State E&T Program participation requirements– Drug or Alcohol counseling

• Cannot include the cost of meals away from home

Third Party Partnerships

Third Party Partnerships

What is a Third-Party Partnership?

• Sometimes also referred to as third-party “match” programs or third-party reimbursement programs

• E&T services are provided by third parties, such

as community colleges and community based organizations

• Partners pay for services and get reimbursed 50% through Federal funding

Third-Party Reimbursement ModelsState contracts

with local employment

and/or education provider to

provide E&T services

Provider uses non-federal funds

to pay for allowable

expenses, and submits a claim for

reimbursement through the State

FNS reimburses

State for 50% allowable expenses

State passes reimbursement back to partner

Third-Party Reimbursement ModelsB

enefits

• Maximize dollars already being spent to serve SNAP recipients

• Expand the types of services available without added State expenditures

• Allow CBOs and colleges to expand capacity and serve more individuals

• Create a new funding stream to pay for much needed participant supports

• Help organizations administer program

• Ideally, begins to align programs and systems

• Increase employment and earning for SNAP recipients

Challe

ng

es

• Must establish in advance

• Can be administratively complex

• Must verify SNAP eligibility

• Anticipating service levels throughout the year

• Tracking non-federal funding sources

• Financing can be especially difficult for smaller CBOs

Thinking about E&T Differently

• A one size fits all E&T programs don’t work

• Programs should center on what is best for the individual

• Individual strengths, weaknesses and barriers must drive strategies for self-sufficiency

• Case management and participant supports must be integrated into E&T programs to mitigate barriers to success

• Leverage expertise from multiple sources

Using Third Party Models to Better Serve SNAP Recipients

Establish partnerships

with agencies, CBOs, and colleges to leverage

expertise and resources

Develop comprehensiv

e array of services

Conduct consistent and

meaningful assessments with targeted

referrals

Leverage community resources to

provide participant supports

Allow co-enrollment

with multiple partners

Alternative Funding Streams

• State, county or city funds

• Donations from private firms or non-profits

• Foundation funds

• Social venture funds (e.g. Goodwill store revenues)

• Community Development Block Grants (CDBG)

• State Need Grants

• State Worker Retraining Dollars

• State Opportunity Grants

• Tuition set-aside resources

• Other state training funds (ex-offender, homeless, non-custodial parents)

Enhanced Funding

Enhanced Funding

• Workfare savings—A political subdivision may share in the benefit reductions that occur when a workfare participant begins employment while participating in workfare for the first time

• First participation in workfare means performing work for the first time in a particular workfare program. The only break in participation that does not end the first participation will be due to the participant's taking a job which does not affect the household's allotment by an entire month's wages and which is followed by a return to workfare.

Calculating benefit reductions

• The benefit reduction equals the difference between the last allotment issued before the participant began the new employment and the first allotment that reflects a full months wages attributable to the new job.

• If the SA knows of other changes besides the new job that affect the household's allotment after the new job began, the SA will obtain the first allotment affected by an entire month's wages from the new job. The SA will then recalculate the allotment to account for the wages, earned income deduction, and dependent care deduction attributable to the new job.

Calculating benefit reductions

• The difference between the first allotment that accounts for the new job and the recalculated allotment will be the benefit reduction.

• The SA’s share of the benefit reduction is three times this difference, divided by two

• The SA will report its enhanced reimbursement to the State agency

• FNS will reimburse the SA

• The SA will, upon request, make available for review sufficient documentation to justify the amount of the enhanced reimbursement

Calculating benefit reductions

Example:Jon was receiving $150 a month in SNAP benefits. Through participation in SNAP E&T Jon received a job and no longer received SNAP benefits.

The amount of enhanced funding the SA is entitled to:

$150 – 0 = $150 $150 x 3 = $450$450/2 = $225

Calculating benefit reductions

Example:Heather was receiving $125 a month in SNAP benefits. Through participation in SNAP E&T Heather received a job and reduced her SNAP benefits to $45 a month.

The amount of enhanced funding the SA is entitled to:

$125-$45 = $80$80 x 3 = $240$240/2 = $120

Questions?

Chad ImkerSenior Program SpecialistU.S. Department of AgricultureFood and Nutrition ServiceEmployment & Training Programchad.imker@fns.usda.gov(303) 571.6188

Reference:• E Code of Federal Regulations:

http://www.ecfr.gov/cgi-bin/ECFR?page=browse 2 CFR, 273.7, 273.24

• E&T Toolkit

Cost Allocation

Funding ProcessCO submits E&T State plan to FNS/RO/SNAP (August 15)

FNS/RO/SNAP approves State Plan by Sept 30th

FNS/RO/FM receives approval letter & waits for the allocated funds

FNS/RO/FM receives the notification from FNS/NO of the allocation then we will fund the State

Once the State receives these funds then they can fund the participating counties.

Cost Allocation

• Cost Allocation Process:

CFMS (County Financial Management System) contains the logic needed to distribute county administrative cost pools base on staff assignments, time sheets, results of random moment sampling (RMS), and other appropriate bases.

Cost Allocation

• First method: 100% Direct Charge– This is where an employee works 100% of their time on one

program. A certification should be done semi-annual. This certification needs to be signed by the employee and supervisor.

• Second Method: 100% Time Reporting– The State requires county employees who work on multiple

activities:• More than one Federal Award• A Federal Award and a non-Federal Award• An indirect cost activity and a direct cost activity• Two or more indirect activities• An unallowable activity and a direct or indirect cost

activity

Cost Allocation

• Second Method: 100% Time Reporting

– The State requires county employees who work on multiple activities:

• More than one Federal Award• A Federal Award and a non-Federal Award• An indirect cost activity and a direct cost activity• Two or more indirect activities• An unallowable activity and a direct or indirect cost

activity

Cost Allocation• Third Method: RMS (Random Moment Sampling)

– Employees are coded to one specific cost pool according to their job title and duties. (IMRMS - Income Maintenance Random Moment Sampling and SSRMS – Social Services Random

Moment Sampling)

Random moment sampling statistics are used to allocate pooled administrative county costs.

Cost AllocationAdministrative Costs:

– State Development Personal Services, Contractual and Other Expenditures

– Income Maintenance Training pass thru– Personal Services County Staff, other than Staff Development– County Contractual Personal Services– County Travel– County Operating Expenses– County Cost of Office Space– County Cost of Automated Data Processing – ADP– County Capital Outlays– County-wide Cost Allocation Plans– Special Projects. Costs of special projects are charged to the

program benefited, based on program codes indicated on county reports

Questions?

Michelle MontoyaGrants Management SpecialistFinancial ManagementMountain Plains Region303-844-0319Michelle.Montoya@fns.usda.gov