program unless the state demonstrates to USDA that consultation with private employers or
employer organizations would be more effective or efficient (7 U.S.C. § 2015(d)(4)(A)(i)).
Mandatory and Voluntary Programs
Federal law requires certain SNAP enrollees to comply with work requirements. These “work
registrants” are required to participate in SNAP E&T programs unless the state exempts them.
States have broad authority to exempt work registrants from the requirement to participate in SNAP
E&T programs. A state may do so for various reasons, including a lack of appropriate or available
spot in the E&T program or a work registrant’s pregnancy, homelessness, lack of proficiency in
English, or geographic location. Exempt work registrants or other SNAP enrollees may participate in
SNAP E&T programs voluntarily. If a state requires a work registrant to participate in SNAP E&T, the
work registrant may be sanctioned or lose SNAP benefits for failing to participate.
Alternatively, states may exempt all work registrants from the requirement to participate, essentially
administering an entirely voluntary E&T program.
Federal regulations require state SNAP agencies to screen and refer SNAP applicants for E&T
programs (whether voluntary or mandatory) as part of a SNAP eligibility determination (7 C.F.R. §
271.2 & 7 C.F.R. § 273.7(c)(2)).
Funding
The USDA allocates federal funds as “100% funds” among the 53 state SNAP agencies according
to a formula based on the number of work registrants and ABAWDs in the state or territory
(approximately $103.9 million total in 2022). States that pledge to provide E&T activities to every
ABAWD may receive additional funds (“pledge funds,” approximately $20 million total in 2022).
(ABAWDs are subject to a time limit on benefits based on compliance with additional work
requirements.) Amounts for these federal funds are set in federal statute ($123.9 million total (7
U.S.C. § 2025(h)(1)(A) & (E))).
States may also identify nonfederal funds to support E&T programs. The USDA will reimburse states
for 50% of these expenditures (“50% funds”). These nonfederal funds may be state funds,
appropriated by the state, or other nonfederal funds. These funds may be used for administrative
costs or “participant reimbursements.” State SNAP agencies are required to pay for or reimburse
E&T applicants and participants for all expenses reasonably necessary and directly related to
participation in an E&T program (e.g., dependent care, transportation, books, or training materials).
These “participant reimbursements” may not be paid for with federal funds; these must be paid for
through 50% funds (7 C.F.R. § 273.7(d)(4)). USDA estimates amounts for these 50% funds based
on (1) last year’s spending, (2) projected inflation, and (3) consultation with the state program.