The “New” SNAP (Food Stamp) Time Limit

An informational webinar, December 15, 2015Presented by:

Community Legal Services and the Coalition Against Hunger

with our partners:

1

Overview of today’s webinar1. Introductions and ABAWDs SNAP Time Limit Rule Basics, Kathy

Fisher, Policy Manager, Coalition Against Hunger

2. Importance of Screening ABAWDs for Exemptions, Louise Hayes, Staff Attorney, Community Legal Services

3. Implementing the Time Limit at CAOs and Examples, Sandra Willis, Division Director of SNAP Policy, PA Department of Human Services

4. Community Service, Tamila Lay, Director, Division of Employment and Training Policy, PA Department of Human Services

5. Planning so Individuals Do Not Lose SNAP Benefits, Rochelle Jackson, Public Policy Advocate, Just Harvest

2

Basics of the 3-Month Time Limit: WHAT & WHY

What is the time limit?

• A federal rule that puts a time limit on SNAP for “Able-Bodied Adults without Dependents” also called “ABAWDs”

Why?

• This rule was created by Congress as part of welfare reform in 1996

• High unemployment due to the recession qualified PA for a statewide waiver since 2009

• This waiver is now expiring

3

Basics of the 3-Month Time Limit: WHAT (cont’d)

ABAWDs will be limited to 3 months* of SNAP benefits in a 3 year (36 month) period unless they:

• Work or participate in a work program at least 20 hours per week (averaged monthly)

• Are in school or training

• Qualify for an “exemption”

• Volunteer or perform community service for 26 hours per month

*Partial months of benefits do not count toward the 3 month limit

4

Basics of the 3-Month Time Limit: WHO

Who is an ABAWD?

Individuals receiving SNAP who:

• Are age 18 through 49

• Do not have a child under age 18 as part of their SNAP household

• Do not meet an exemption

• Do not live in a geographically waived area; and

5

Basics of the 3-Month Time Limit: WHEN

When does the rule go into affect?

• The rule will apply (again) in 2016.

• PA will use an option within the law to exempt all ABAWDs for Jan. and Feb. (so they will not count toward 3-month time limit)

• ABAWDs who are not exempt will be required to meet work, training, or volunteer/community service hours starting March 1

• The first month an ABAWD could lose SNAP due to the time limit will be June 2016.

It’s important to help all ABAWDs meet exemptions, find work, education & training, or volunteer slots ASAP!

6

Basics of the 3-Month Time Limit: WHERE

The time limit will apply in some areas and not others, because areas with high rates of unemployment can qualify for a “geographic waiver” that exempts them from the rule

In Pennsylvania the time limit:

• Will not apply in at least 24 counties and 12 cities with high unemployment

• Will apply in 29 counties that were not eligible for a waiver

• May or may not apply in 14 other counties, as well as some cities and smaller municipalities (DHS’ waiver request to USDA is pending)

See map on next slide7

8

Overall categories of Exemptions

Exemption Explanation

Disability Receiving temporary or permanent disability benefits

“Unfit for Work”*Medical professional certifies individual cannot work

(or unfitness is obvious)

Pregnancy Being pregnant (may need to provide proof)

Meets an “ETP”

Exemption**

Meets any of the federal or state “Employment and

Training Program” (ETP) exemptions

* See next slide **Details to follow (slide XX)

9

SNAP Time Limit Medical Exemption Form

10

Any ABAWD who cannot work due to medical reasons should have his/her medical provider fill out a “SNAP Time Limit Medical Exemption Form” (also called a “PA 1921”)

Employment & Training Program (ETP) Exemptions

• Cares for ill or incapacitated person in the same home (does not need to be same SNAP household)

• Applied for or receives Unemployment Compensation

• Enrolled in school or training at least half time

• Participating in a drug or alcohol treatment program or a mental health treatment program;

• Homeless

• Expected to return to work within 60 days

• Travel time to work, education, training, or volunteer site is 2 or more hours (round trip)

• Migrant/seasonal farm worker expected to work within 30 days

• Full Time VISTA volunteer (Title I DVSA)

11

Implementing ABAWDs Time Limit at CAOs SNAP applications & recertifications processed by the CAO will include an ABAWD determination. CAO workers will review all individuals age 18-49 to determine what category he/she is in:

Exempt• Has a child under 18

in the SNAP household

• Disabled or receives federal or state disability

• Is pregnant• Meets a federal or

state exemption (see

previous slide)

Has met ABAWDs requirements

• Works at least 20 hrs/week averaged monthly

• Participates in an approved education or training program 20 hours/week*

• Volunteers or performs community service at least 26 hours/month

*Job search does not count

Is not exempt and has not met ABAWDs

requirements (and not in a waived area)

• The 3-month time limit applies

12

CAOs to Inform ABAWDs of Time Limit

For individuals that do not meet an ABAWD exemption during the SNAP interview, CAO workers are to:

• Explain that starting March 1, 2016 they will only be eligible for 3 months of SNAP benefits within the 3 year period if they do not meet an ABAWD work requirement, exemption, or geographical waiver.

13

14

ABAWD Exemption Example 1

• Derrick: 34-year-old man

• Lives in a non-waived area with his girlfriend, Amber, and her 13-year-old son, Jeremiah

• They purchase and prepare meals together

• They apply for SNAP benefits and are found eligible

• Does Derrick meet any ABAWD exemptions?

15

ABAWD Exemption Example 1

Yes. Derrick does meet an ABAWD exemption because Jeremiah is under age 18 and is a part of the same SNAP household.

16

• Mark: 24-year-old single man

• Moved into a non-waived geographic area

• Currently receiving unemployment compensation

• Mark applies for SNAP

• Does Mark meet any ABAWD exemptions?

ABAWD Exemption Example 2

17

ABAWD Exemption Example 2

Yes. Mark does meet an ABAWD exemption because he is receiving unemployment compensation.

18

ABAWD Exemption Example 3

• Janice: a 47-year-old single woman with no children

• Lives in a non-waived area

• Applied for SNAP and claimed that she has a mental disability that prevents her from working. The disability is not obvious.

• Given a PA 1921 to have completed by her physician but has yet to return it to the CAO.

• Does Janice meet any ABAWD exemptions?

19

ABAWD Exemption Example 3

No. Janice does not meet any other ABAWD exemptions, and she has not yet provided certification of her disability.

Non-Work Activities to meet 20 hour/week req.

• Advanced degree (college) classes

• Skill/Vocational training classes

• English-as-a-Second Language (ESL) classes

• Adult Basic Education (ABE)/ Literacy classes

• GED/High school remediation classes

• Work experience/vocational experience

• Programs through Career Links (WIOA programs)

• Community service/ workfare (see next slide)

Activities that can meet 20 hours/week requirement (alone or in combination):

20

Community Service/Workfare

• By volunteering with a non-profit or government site, an ABAWD can qualify by working off their SNAP grant.

• Instead of 20 hours/week, the required hours are just the monthly SNAP grant amount divided by the minimum wage ($7.25/hour).• E.g., $194 (maximum grant for 1) / $7.25 = 26 hours / month

• Non-profits and government sites must sign a Community Service Agency Agreement.

• Non-profits will be doing ABAWDs a big service by offering volunteer slots!

21

What if an ABAWD works fewer than 20 hours/week?

• If the job is scheduled for 20 hours a week but the ABAWD misses a few hours through no fault of their own (e.g., holidays, sickness, transportation breakdown), they should report this to the CAO. They can then be reviewed for GOOD CAUSE by the caseworker and continue to qualify for SNAP.

• If the regularly scheduled hours are less than 20 hours/week, the ABAWD must do other permitted activities – such a volunteering or training -- to get up to 20 hours a week. Job search can count for up to 10 hours/week.

22

Planning so ABAWDs Do Not Lose SNAP

In Allegheny County (Pittsburgh area), Just Harvest is working with 211 of Southwestern PA to establish a network of non-profits where ABAWDs may be able to complete their work or volunteer hours requirement.

They are:

• Building a list of non-profits partners

• Educating them about the issue

• Most importantly, explaining how they can help

23

Connecting ABAWDs to Critical Information – Model 1: Using 211

On or about March 1, ABAWDs will be able to call 211 and phone representatives will:

• Use the non-profit partners list to connect them to work or community service opportunities near them

• Provide information about supportive services or special allowances they can request from DHS to assist them with getting to their community service site

This service will be particularly useful for ABAWD’s with limited to no computer knowledge or access

24

Just Harvest is also working with non-profit partners to list volunteer opportunities online at:

www.volunteermatch.org

- or -

www.justharvest.org

25

Connecting ABAWDs to Critical Information –Model 2: Using Volunteermatch

In Allegheny County, ABAWDs will be able to:

• Enter their information online

• Be matched with a community service site

The goal is to have this online service available by February 1.

Regaining SNAP After a Cutoff

• Can always reapply and get SNAP back if:• Become exempt

• Move to an area with a geographic waiver

• Meet the 20 hour/week work requirement (or work off the SNAP through community service)

• Even if don’t otherwise qualify, can get another 3 months of SNAP if:• In any 30-day period since last

got SNAP, have: • worked 80 hours, or

• participated in a training program for 80 hours.

• New 3-year period for all ABAWDs will start 1/1/18.

26

Additional Information & Updates

Today’s webinar has been recorded and will soon be posted, see:

www.clsphila.org/ABAWDs

– OR –www.hungercoalition.org/ABAWDs

New information and updates will be posted to both websites as soon as it becomes available.

CLS has additional materials posted, including:

• ABAWD Client flyer

• ABAWD Service Provider Handout

• Draft versions of forms clients will need (final versions will be posted once approved)

27

Questions?