By: Rachel Cahill & Sofia Charlot
Executive Summary
The Supplemental Nutrition Assistance Program (SNAP) is the nation’s first and best line of defense against hunger. 100% federally-funded SNAP benefits help 1.4 million low-income Ohioans afford nutritious food and support Ohio’s broader food economy.[i] SNAP’s lesser-known sister program – the SNAP Employment and Training (E&T)program – helps unemployed and underemployed SNAP participants gain skills, training and work experience to “increase their ability to obtain regular employment that leads to economic self-sufficiency.”[ii] All states are required to operate a SNAP E&T program, but due to limited federal funding, states have discretion in how the program operates and who it serves.
In its 2024-2025 biennial budget, the Ohio Legislature directed the Ohio Department of Job and Family Services (ODJFS), which oversees SNAP in Ohio, to “redesign” the SNAP E&T program to “ensure that the new program meets the needs of employers in this state.”[iii] This legislative directive presented a tremendous opportunity for Ohio to:
- Examine how the current SNAP E&T program does (or does not) live up to the program’s core goals of increasing the employment and self-sustaining wages of SNAP participants; and
- Incorporate stakeholder feedback and national best practices to create a high-quality SNAP E&T program that is more responsive to participant and employer needs.
The SNAP program is one way, but not the only way, for SNAP recipients to meet existing federal work requirements.
In response to this legislative directive, ODJFS convened a SNAP E&T Redesign Workgroup in August 2023.[iv] The Center for Community Solutions take part in this important workgroup, alongside approximately 40 other stakeholders representing County Departments of Job and Family Services, workforce boards and providers, members of the business community, and legal aid providers. Community Solutions was specifically invited to share SNAP E&T best practices from across the country for consideration by the workgroup. After presenting this research to the workgroup in September 2023, Community Solutions decided to publish this paper to share lessons learned with all interested Ohioans to ensure the next generation of Ohio’s SNAP E&T program provides high-quality services and supports to job seekers and employers alike.
Key findings and recommendations for the SNAP E&T redesign process:
- Ohio’s current SNAP E&T program does not meet the program’s goals of increasing employment and earnings among participants and is under corrective action for not meeting federal requirements.
- Ohio’s current mandatory SNAP E&T program creates wasteful bureaucracy and limits the amount of funding available for counties to invest in quality employment and training opportunities for SNAP recipients. In Federal Fiscal Year 2022, Ohio budgeted just $120 per participant per year on average, with 73% of those funds being spent on bureaucracy instead of employment and training services.
- Mandatory SNAP E&T programs with high sanction rates, like Ohio, have worse employment and earnings outcomes for participants than non-mandatory programs. Regardless of whether or not a state runs a mandatory SNAP E&T program, SNAP recipients are still subject to federal work requirements.
- Best practice research confirms that SNAP E&T programs should be designed to be one way – but not the only way – for SNAP recipients to meet existing federal work requirements. This model offers more flexibility to counties and participants alike and will improve the likelihood of success. SNAP E&T programs in Tennessee, West Virginia, Wisconsin, and Virginia are models that Ohio can follow.
- A rigorously evaluated, 10-state pilot of SNAP E&T programs identified best practices that Ohio can adopt to increase the employment and earnings of SNAP participants, including expanding community college partnerships, providing intensive case management from skilled staff, and planning robust outreach and recruitment efforts.
- Ohio’s successful Benefits Bridge Pilot Program should be expanded statewide to support working Ohioans in all 88 counties maintain self-sustaining employment.
- To determine whether Ohio’s SNAP E&T redesign effort is ultimately successful, Community Solutions encourages ODJFS to commit to a transparent evaluation process and continuous improvement principles to instill public confidence in the program. Doing so would ensure that current and future state and federal investments in Ohio’s SNAP E&T program are an effective use of taxpayer resources.
Ohio's successful Benefit Bridge Pilot Program should be expanded to support working Ohioans in all 88 counties in maintaining self-sustaining employment.
Introduction
The Supplemental Nutrition Assistance Program (SNAP) is the bedrock of all anti-hunger programs in the United States. SNAP provides basic nutrition assistance to almost 42 million low-income Americans, including 1.4 million Ohioans.[v] SNAP benefits are modest – just $6.11per person per day, on average – but are critically-important to the health and well-being of Ohio families and communities.[vi] The vast majority of SNAP participants in Ohio are children, older adults (age60+), individuals with disabilities, and low-wage working parents.[vii] SNAP is an important contributor to Ohio’s economy, with $3 billion in federal funding for groceries flowing through Ohio’s retailer sector each year, creating $4.7 billion in economic activity that fuels employment opportunities throughout Ohio, including in some of the most disadvantaged areas of the state.[viii]
Because federal funding is so limited, states decide how SNAP E&T programs operate and who the program serves.
A lesser-known component of SNAP is the SNAP Employment and Training program -known as “SNAP E&T.” Congress established this program to help unemployed and underemployed SNAP participants gain skills, training, and work experience, and to “increase their ability to obtain regular employment that leads to economic self-sufficiency.”[ix] All states must run a SNAP E&T program, alongside the SNAP program.[x] Unlike other job training programs that with funding and oversight from the U.S. Department of Labor, SNAP E&T is overseen by the U.S. Department of Agriculture (USDA). States get very limited dedicated (100%) federal funding from the USDA to run this program, with additional reimbursement (50%) funds available to help cover state and county costs. Because federal funding is so limited, States decide how SNAP E&T programs operate and who the program serves. States generally do not have enough resources to serve all working-age SNAP recipients through SNAP E&T, so they often identify a target population and/or geographic area where SNAP E&T resources can be concentrated.[xi]
The intersection between SNAP’s federal work requirements and SNAP E&T
A commonly misunderstood area of federal SNAP policy is “work requirements.” At the federal level, SNAP has two distinct sets of work requirements:
- General work requirement (also called “work registration” requirement)
- Work requirements and time limits for Able-Bodied Adults Without Dependents (ABAWDs)
The general work requirement applies to SNAP recipients aged 16-59 who are physically and mentally able to work, not already employed for at least 30 hours per week, and not meeting an exemption.[xii] SNAP recipients subject to the general work requirement must register for work, accept an appropriate job if offered, and not voluntarily quit a job or reduce work hours below 30 hours without good cause.[xiii]
A subset of individuals who are subject to the general work requirement, known as Able-Bodied Adults without Dependents (ABAWDs), must meet additional work requirements. ABAWDs are work registrants between the ages of 18 and 52 who are not veterans, pregnant or living with children under the age of 18, former foster youth (up to age 24), or experiencing homelessness.[xiv] ABAWDs can only receive SNAP for three months out of every three years unless they report working or participating in training for 80 or more hours per month.
Able-Bodied Adults Without Dependents can only receive SNAP for three months out of every three years unless they report working or participating in training for 80 or more hours per month.
Participation in a SNAP E&T program is one of several ways that individuals subject to SNAP’s 3-month time limit can meet their work requirements. Most states design their SNAP E&T programs to serve ABAWDs who need education and training to secure self-sustaining employment, but they do not mandate participation. Instead, these states - like Tennessee and West Virginia – promote their high-quality SNAP E&T programs as one way, but not the only way, for an ABAWD to follow federal work requirements and avoid hitting the three-month time limit.[xv]
By contrast, a small minority of states, including Ohio, have SNAP E&T programs that functionally run as a third work requirement, on top of existing federal work requirements and time limits (see Figure 1).[xvi] In these states, some or all individuals subject to the general work requirement are also required to take part in an assigned work or training activity, even if they already have a job and are complying with other work requirements. Individuals who do not participate in their mandatory SNAP E&T assignment without claiming good cause can have their SNAP benefits sanctioned.
Figure 1: SNAP Recipients Subject to Federal and State Work Requirements by age
Ohio’s SNAP Employment and Training Program
Ohio is one of just eight states that currently requires certain SNAP recipients to participate in the SNAP E&T program, in addition to following federal work requirements.[xvii] For Federal Fiscal Year 2024 (October 1, 2023 – September 30, 2024), the SNAP E&T program in Ohio is required for ABAWDs.
For several years, Ohio’s SNAP E&T program has been under scrutiny from the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) for not complying with federal regulations. In three successive Management Evaluations in Cuyahoga, Hamilton, and Franklin Counties, FNS alerted ODJFS of their concerns with Ohio’s compliance with federal requirements. Table 1 summarizes a subset of these findings that required corrective action plans.[xviii]
Table 1. Subset of FNS Findings Requiring Corrective Action
In a warning letter addressed to the Ohio Department of Job and Family Services, FNS expressed concern that “SNAP recipients in Ohio are being required to participate in E&T as a condition of eligibility without being properly screened, without adequate supports, and at risk of failure to comply, there by being disqualified from the E&T program and from the SNAP program overall.” The letter stated that federal funding for Ohio’s SNAP E&T program would be withheld if significant reforms were not enacted.[xix] In response to this letter, ODJFS issued Food Assistance Change Transmittal (FACT) 96, effective July 1, 2023.[xx] FACT 96 requires county agencies to use a new SNAP E&T screening tool, pre-sanction checklist, and other methods of reporting to ensure SNAP recipients are not improperly sanctioned due to non-participation in Ohio’s SNAP E&T program.
SNAP recipients in Ohio are being required to participate in E&T as a condition of eligibility without being properly screened, without adequate supports, and at risk of failure to comply, there by being disqualified from the E&T program and from the SNAP program overall.
In addition to improper screening and sanction practices, FNS is concerned about the overall quality of Ohio’s E&T program. For example, in Fiscal Year 2022, just 4% of SNAP E&T participants in Ohio completed an education, training, on-the-job training, or work experience component.[xxi] Additionally, less than one-third of participants were employed in the 2nd or 4th quarters after completion of SNAP E&T in Ohio. The median wage, two quarters after program competition, was just $2,228 (see Figure 2).
Figure 2: A State-Level Comparison of Ohio’s SNAP E&T Annual Outcomes in FFY22 (USDA-FNS)
Legislative Directive to Redesign of Ohio’s SNAP E&T Program
During these elevated concerns about the long standing weaknesses of Ohio’s SNAP E&T program, the Ohio Legislature included language in its 2024-2025 biennial budget (House Bill 33) directing ODJFS to “redesign the [SNAP] employment and training program” and “ensure that the new program meets the needs of employers in this state.”[xxii]
To comply with this legislative mandate, ODJFS did the following:
- Commissioned a SNAP E&T Study: ODJFS partnered with Deloitte to conduct a “current state” analysis of SNAP E&T in Ohio in Fall 2023. The study consisted of reviewing and analyzing four years’ worth of SNAP E&T data, as well as surveying and interviewing county JFS agencies about their SNAP E&T policies, practices, and pain points.
- Formed an Executive Committee: The Executive Committee “meets periodically to hear from shareholders, advocacy groups, employer representatives and the public, and to receive updates from the workgroup.”
- Convened SNAP E&T Redesign Workgroup: The workgroup consists of “county agencies SNAP E&T representatives, workforce board representatives, state SNAP E&T, TANF and WIOA policy subject matter experts, the business community, and advocates.”[xxiii]
Executive Committee and Workgroup members joined a kick-off meeting on August 16, 2023. The Workgroup has been meeting twice per week since the kick-off meeting, including two in-person meetings during Fall 2023. The Executive Committee also meets regularly. ODJFS must report the results of the SNAP E&T Redesign effort to the Ohio legislature by July 1,2024.
Ohio budgeted for just $120 per participant per year on average for SNAP E&T in FFY22.
Understanding the Root Causes of Ohio’s SNAP E&T Program Challenges
The inferior quality of Ohio’s SNAP E&T program - as shown by low employment and earnings outcomes for SNAP E&T participants - are the result of two interwoven factors: (1) Ohio’s operating model and (2) budget constraints.
By operating its SNAP E&T program under a mandatory model, Ohio’s 88 County Departments of Job and Family Services must schedule, appraise, serve and, when necessary, sanction approximately 100,000 ABAWDs each year, most of whom have complex barriers to work. [xxiv] To do this, Counties must dedicate most or all their annual SNAP E&T budget to compliance tracking, rather than high-quality employment and training services. For example, in Federal Fiscal Year 2022 (FFY22), 73% of programmatic funding went to attempting to enroll and/or sanction individuals, while only 27% of funding supported program activities (see Figure 3).
Figure 3: Average Monthly E&T Costs in Federal fiscal year 2022 (ODJFS)
In FFY (Federal Fiscal Year) 2022, there were 100,600 ABAWDs in Ohio who were required to participate in SNAP E&T. The total statewide budget available to serve these individuals was just over $12 million, including $7.7 million in federal funding and $4.3 million in county and state funding. This means Ohio budgeted for just $120 per participant, per year on average for SNAP E&T in FFY22. As detailed in the next section of this paper in Table 3, none of the National SNAP E&T Pilots had costs even close to that low, with the least expensive pilot (Georgia) costing $2,029 per person.
To better understand how these budget constraints show up at the county level, the authors selected a sample of small, medium, and metro counties and reviewed their SNAP E&T plans for Federal Fiscal Year 2024 (FFY24). Table 2 shows a high-level summary of SNAP E&T costs and program components, by county. This data shows how limited the SNAP E&T opportunities are in some counties due to constrained budgets and a lack of contracted employment and training providers.
Figure 4: Ohio counties represented in Table 2
The only two SNAP E&T components offered statewide are Supervised Job Search and the Work Experience Program (known federally as Workfare). These are considered non-education components and are generally not expected to help SNAP participants skill up into higher paying, more sustainable jobs. Projected statewide participation and costs for these components are:
- For Supervised Job Search: 27,313 individuals (~27% of ABAWDs), at a cost of $4.44 million.
- For Work Experience Program (Workfare): 37,396 individuals (~37% of ABAWDs), at a cost of $6.1 million.[xxv]
Of the 10 counties studied for this paper, the only other common part was Basic Skills Instruction (e.g., GED classes), offered in 78 of 88 counties in Ohio. Projected statewide participation in FFY24 is 3,592 participants at a total cost of $583,954.[xxvi]
The other commonly offered SNAP E&T components in the studied counties are:
- Career and Technical Education Programs (8 of 10 counties), which includes Ohio’s Community College Acceleration Program (discussed in more detail later in this paper). Projected statewide participation is 6,907 (~7% of ABAWDs) for a total cost of $1,122,989.
- Job Readiness Program (9 of 10 counties), which includes “soft skills training” designed to expand an individual’s employability potential (interview skills, workplace etiquette, etc.) Projected statewide participation is 15,747 (~16% of ABAWDs) for a total cost of $2,560,414.
- English Language Acquisition (7 of 10 counties), to help English language learners achieve competence in reading, writing, speaking and comprehension. This component is offered in just 35 of Ohio’s 88 counties, with projected participation of 1,381 for a total cost of $224,598.[xxvii]
Low funding levels mean most counties cannot offer the high-quality E&T programs that would help SNAP recipients achieve employment stability and higher wages.
The total amount of funding allocated to SNAP E&T services varies widely across the state, including in the counties selected for closer study, and these investments are not necessarily proportional to the number of SNAP participants or ABAWDs in the county. For example, Lucas County has about 100,000 less residents than Montgomery County and 10,000 fewer SNAP recipients, yet its total SNAP E&T operating budget is $1,000,000 more than Montgomery County’s budget.[xxviii] Low funding levels mean most counties cannot offer the high-quality E&T programs that would help SNAP recipients achieve employment stability and higher wages.
Third-party partnerships with E&T providers are the most common way that counties can increase the range of SNAP E&T program components available to residents. Six of 10 counties studied engage third-party partners, such as Center for Employment Opportunities (CEO), Towards Employment, and Community Colleges, with contracted budgets ranging from $23,750 in Licking County to $1.1 million Cuyahoga County.[xxix] If more Ohio counties were able to invest their limited E&T funds in high-quality third-party partnerships rather than compliance activities associated with a mandatory E&T program, many more Ohio residents could benefit from these opportunities.
Table 2: Ohio County SNAP E&T Plans for Federal Fiscal Year 2024
In addition to the deep analysis of current practices and pain points underway, the Ohio Department of Job and Family Services should consider national best practices from SNAP E&T programs across the country as part of the redesign process. There is a significant body of research on what does work well in SNAP E&T, including recently published findings from a major SNAP E&T study funded by Congress through the 2014 Farm Bill, described below.
Best Practices from Rigorously Evaluated SNAP E&T Pilots in Ten States
The bipartisan Agricultural Appropriations Act of 2014 (aka 2014 Farm Bill) authorized $200 million for 10 SNAP Employment and Training(E&T) pilots. Like those of the Ohio Legislature, the goals of the 10 SNAP E&T pilots were to “test innovative strategies to increase employment and reduce the need for SNAP among SNAP E&T program participants.”[xxx] Ohio can learn from recent pilots designed to rigorously evaluate new approaches to connecting SNAP participants to high-quality employment and training opportunities. There is broad bipartisan agreement that the SNAP E&T program should increase employment and earnings and decrease the need for SNAP participation – the question is how.
Ohio can learn from recent pilots designed to rigorously evaluate new approaches to connecting SNAP participants to high-quality employment and training opportunities.
At the direction of Congress, FNS issued grants to 10 states to fund pilot SNAP E&T programs in March 2015. Pilot implementation began between January and April 2016, with all pilot services ending by April 2019. Pilots studied over 44,000 SNAP participants across the ten states who were assigned into treatment and control groups. FNS contracted with Mathematica, Inc. to conduct a rigorous evaluation, with the most recent findings published in July 2023.[xxxi] Evaluators collected implementation data, administrative service use data, unemployment insurance wage records, cost data, and 12- and 36-month follow-up survey data from treatment and control group members. Over a 2-year follow-up period, pilot evaluators tracked earnings, employment outcomes, and SNAP participation.[xxxii]
Pilot Designs
States tested a variety of SNAP E&T models, including mandatory and voluntary participation; urban, rural, and suburban program designs; and statewide, county, and locality-operated programs. Pilots offered a wide range of service components, including services aligned with Workforce Innovation and Opportunity Act (WIOA) programs, a range of supportive and wraparound services, and various levels of case management intensity.[xxxiii] Pilots served an average of 4,500 participants per state and total costs of the pilots varied widely. For example, in Georgia, the total cost was $6.8 million while in Washington State, the total cost was $23.3 million.[xxxiv]
An important finding from the pilots is that increased employment did not mean that pilot participants saw increased earnings.
Some pilots were marginally successful, but others were not. Between treatment and control groups, earnings increased in three states–California, Mississippi, and Virginia–by $1,600 to$4,000. Employment rates increased by four to six percentage points in five pilot states–California, Illinois, Kansas, Kentucky, and Vermont. An important finding from the pilots is that increased employment did not mean that pilot participants saw increased earnings. The only pilot that showed both increased employment and earnings was California’s SNAP E&T program.[xxxv] See Tables 3 and 4 for a high-level summary of each pilot.
Table 3: Summary of SNAP E&T Pilots – Model, Size, Cost, and Final Outcomes[xxxvi]
Evaluators identified the following key findings across all pilots[xxxvii]
- Service design matters. Too many hand-offs, upfront requirements, and lengthy waiting periods for employment, education, or training opportunities reduced participation.
- Paid work-based learning was among the most effective components but was challenging to implement. Jobs with career advancement were hard to name.
- SNAP agencies must take ownership of their E&T programs and provide oversight to ensure proper implementation of policy and procedures by partners and providers.
- Recruiting SNAP participants into E&T programs requires a multifaceted approach.
- Community colleges are important SNAP E&T providers, but waiting periods are an issue.
Table 4: Summary of SNAP E&T Pilots – Target Population, Activities, and Completion Rates[xxxviii]
Findings from Mandatory SNAP E&T Pilots
Evaluators dedicated further analysis to the three mandatory E&T pilot programs in Georgia, Mississippi, and Illinois. In addition to comparing the outcomes of treatment and control groups, evaluators also compared outcomes for sanctioned and non-sanctioned participants to understand the consequences of sanctions on both individuals and the labor market.[xxxix]
In the three mandatory E&T pilots, 19% to 24% of individuals were sanctioned and lost SNAP benefits. Sanctioned individuals ultimately had lower earnings, lower employment, and lower SNAP participation than those not sanctioned. Individuals sanctioned during the first year of enrollment were earning $1,300 to $2,100 less than their counterparts in year two (See Figure 4). Sanctioned individuals were also 5-6% less likely to be employed (See Figure 5). Like Ohio, Mandatory E&T pilot states also struggled to follow federal requirements for proper screening, referral, and good cause processes.[xl]
Figure 4: Earnings Outcomes from Mandatory E&T Pilots (Reproduced from FNS Brief)[xli]
Figure 5: Employment Outcomes from Mandatory E&T Pilots (Reproduced from FNS Brief)[xlii]
Disproportionate impact of sanctions on individuals facing structural barriers in the workforce
Poor outcomes in Mandatory E&T pilots disproportionately impacted individuals facing structural barriers in the workforce. In Mississippi, sanctioned individuals were more likely to be Black, male, and not have a high school diploma or equivalent. In Illinois, Black and male individuals were more likely to be sanctioned in the first year. SNAP participants without a high school diploma or equivalent were more likely to be sanctioned in Georgia.[xliii]
Excessive sanctions make it harder for SNAP E&T participants to enter an already inequitable economic landscape. In 2022, Black, Indigenous, Latino(a), and other People of Color were unemployed at a rate higher than the national average, and even higher than their white counterparts.[xliv] In a 2019 study of racial and ethnic disparities in wealth, the US Federal Reserve found that white households had eight times more wealth than Black households and five times that of Latino(a) households. Labor statistics also show that individuals who have less than a high school diploma or equivalent have the lowest earnings outcomes and the highest unemployment rate across all levels of educational attainment.[xlv] Sanctions worsen these same negative outcomes by restricting access to SNAP and increasing food insecurity. Evaluation findings suggest E&T sanctions do not improve outcomes; they merely disconnect food insecure individuals from access to critical food and nutrition.
Ultimately, mandatory E&T programs with high sanction rates fail to meet the core purpose of the program – to increase education and skill attainment and boost labor market participation.
Promising Strategies from SNAP E&T Pilots and National Best Practices
A broad review of SNAP E&T best practices from the 10 SNAP E&T pilots, as well as FNS’ SNAP to Skills Institute, shows there are several promising strategies that Ohio can explore through the redesign process to improve program outcomes.[xlvi]
Effective Case Management
Across most pilots, staff found that the SNAP E&T population needed more case management than the staff at workforce agencies or other providers were accustomed to providing.
Ohio County JFS Directors report similar issues with having qualified staff with sufficient time to provide intensive case management. Implementing intensive case management required finding staff with expertise in naming and addressing the types of barriers SNAP E&T participants experience. Intensive case management was time consuming, and staff did not always feel they had time to provide the level of case management needed, especially in pilots where case managers took on a variety of more roles, such as recruitment, intake, and assessments.[xlvii]
Intensive case management also requires a shift in the staff's traditional approach to working with individuals in SNAP E&T, from a focus on compliance to customer service. While no one approach will necessarily meet the unique needs of each unemployed or underemployed SNAP participant, providing qualified staff with the skills to conduct comprehensive assessments of individual needs and offer individualized services and support is vital. Ohio has important experience implementing intensive case management in counties taking part in the Benefits Bridge Pilot Program, which could be expanded statewide.[xlviii]
Work-Based Learning
Work-based learning was among the most effective components in the SNAP E&T pilots. Work-based learning involves hands-on experience in a work setting, often at an employer’s business. Pilot evaluations found that work-based learning led to longer engagement in SNAP E&T, higher employment, and higher earnings. They also found that work-based learning programs were most effective when combined with other services and supports. Pilot programs in Illinois, Kentucky, Mississippi, and Vermont offered work-based learning as a major component of SNAP E&T.[xlix] Pilot states learned that the selection of work-based learning opportunities needs to be driven by both employer and participant needs.[l]
While proven most effective, work-based learning was challenging to implement because jobs with career advancement were hard to identify and subsidies were not enough to incentivize employer participation. In California, for example, some employers reported that their need for entry-level candidates was so great that subsidies did not incentivize them to hire pilot participants.[li] The highest priority for employers was identifying candidates who could reliably arrive at work on time and could handle challenging working conditions (e.g., graveyard shifts, lifting requirements, and part-time or seasonal schedules). Notably, this sentiment was echoed by Ohio employers who took part in an Employer Focus Group as part of the E&T Redesign Workgroup in Fall 2023.
Outreach and Recruitment
Program evaluations revealed that SNAP E&T pilots without specific outreach plans or recruiting experience struggled. Because of the robust services offered through the pilots, many grantees initially thought they would not need to do much recruitment, and some did not develop detailed outreach plans or approaches before the pilot began. However, once they enrolled individuals into the pilot, most grantees had to add resources or change their approach to meet goals.[lii] States that run mandatory SNAP E&T programs rarely have experience with outreach and recruitment strategies, because participants must attend. The SNAP E&T pilots demonstrate that the most successful SNAP E&T programs enjoy high levels of engagement because they (1) offer quality programming, (2) effectively communicate with potential participants about the services available, and (3) attract individuals who are ready and able to participate in education and training programs that will increase their long-term employment and earning potential. States that run mandatory SNAP E&T programs rarely have experience with outreach and recruitment strategies, because participants must attend. The SNAP E&T pilots demonstrate that the most successful SNAP E&T programs enjoy high levels of engagement because they (1) offer quality programming, (2) effectively communicate with potential participants about the services available, and (3) attract individuals who are ready and able to participate in education and training programs that will increase their long-term employment and earning potential.
Successful SNAP E&T programs enjoy high levels of engagement because they offer quality programming, effectively communicate with potential participants about the services available, and attract individuals who are ready and able to participate in education and training p
Community College Partnerships
Community colleges were important partners in many SNAP E&T pilots, most often providing occupational skills training (described below). Community colleges reach adverse population and have the organizational infrastructure and administrative resources to effectively administer robust SNAP E&T programs. Community colleges are also well-positioned to leverage SNAP E&T’s 50/50 funding model that encourages third-party partnerships.[liii] Ohio has begun partnering with community colleges, including Clark State Community College, Columbus State Community College, Lorain County Community College, and Northwest State Community College, and could explore expanding to more campuses in the next few years.[liv]
The SNAP E&T pilots also surfaced some watch outs for community college partnerships. For example, waiting periods (e.g., until a new semester begins) can be particularly problematic for SNAP recipients who are subject to work requirements and time limits. In Mississippi, which operated a Mandatory E&T program, staff noted that those who were waiting for classes to begin were often placed in “filler activities or did busy work,” which neither the staff nor participants felt was beneficial. By comparison, in Virginia, the community colleges offered online, self-paced trainings on digital literacy, soft skills, and job readiness training that people could take while waiting for classes to begin. SNAP E&T pilot evaluators also found aptitude tests and outstanding community college debt as barriers to enrollment for some SNAP E&T participants.[lv]
Occupational Skills Training
In occupational skills training programs, SNAP E&T pilots sought to align short-term training with specific employers' needs in the area, such as in construction, manufacturing, food preparation and service, nursing and medical professions, and commercial truck driving. Programs are often offered through community colleges and non-profits (such as Goodwill, YMCA and Food Banks) and last from a few weeks to a few months. Across all pilots, 22% of E&T participants started occupational skills training with two-thirds completing their training.
Results from occupational skills training in the SNAP E&T pilots were mixed. Credential attainment was much lower than the rate of training participation and completing multiple occupational skills training activities was common. Many individuals who completed training did not find employment after completing training. Despite taking longer to find work, earnings did increase for those who became employed after training.[lvi]
Ohio’s Community College Acceleration Program (CCAP) provides occupational skills training in the FY24 SNAP E&T program, with estimated enrollment of 6,900 participants across four participating community colleges.[lvii]
It will be important for ODJFS to evaluate outcomes for these participants to determine whether this strategy should be expanded in future years as part of are designed SNAP E&T program.
Recommendations for Ohio
Community Solutions applauds the Ohio Department of Job and Family Services (ODJFS) for embracing the Ohio Legislature’s directive to redesign the SNAP Employment and Training (E&T) Program to better meet the needs of employers and help individuals gain economic independence through increased employment and earnings. ODJFS’ current investments in a thorough SNAP E&T Study, an intensive, participatory SNAP E&T Redesign Workgroup, and an Executive Committee all have the potential to pay lasting dividends.
This participatory stakeholder engagement process – rooted in human-centered design – gives Ohio the best possible chance of achieving a meaningful redesign that has buy-in from a wide range of stakeholders.
As part of its commitment to full participation in the SNAP E&T Redesign Workgroup, Community Solutions will continue to share findings from this paper and future research, as well as make connections to other key community stakeholders across Ohio.
Summary of key findings and recommendations for the SNAP E&T redesign process:
- Ohio’s current mandatory SNAP E&T program creates wasteful bureaucracy and limits the amount of funding available for counties to invest in quality employment and training opportunities for SNAP recipients, including those with existing federal work requirements.
- Mandatory SNAP E&T programs with high sanction rates, like Ohio, have worse employment and earnings outcomes for participants than non-mandatory programs.
- SNAP E&T programs should be one way – but not the only way – for SNAP recipients to meet existing federal work requirements. Non-mandatory programs offer more flexibility to counties, participants, and employers alike and will improve the likelihood of success. SNAP E&T programs in Tennessee, West Virginia, and Wisconsin are models that Ohio can follow.
- As part of a redesigned SNAP E&T program, Ohio could invest more funding into expanding its community college partnerships, providing intensive case management from skilled staff, and planning robust outreach and recruitment efforts.
- Ohio’s successful Benefits Bridge Pilot Program should be expanded statewide to support working Ohioans in all 88 counties maintain self-sustaining employment.
- To determine whether Ohio’s SNAP E&T redesign effort is ultimately successful, Community Solutions encourages ODJFS to commit to a transparent evaluation process to ensure public confidence in current and future state and federal investments in Ohio’s SNAP E&T program.
Sources
[i] Food and Nutrition Service, U.S. Department of Agriculture, Supplemental Nutrition Assistance Program: Number of Persons Participating, 2023. https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-persons-11.pdf
[ii] SNAP to Skills, Food and Nutrition Service, U.S. Department of Agriculture, What is SNAP E&T? https://snaptoskills.fns.usda.gov/about-snap-skills/what-is-snap-et#:~:text=SNAP%20Employment%20and%20Training%20%28SNAP%20E%26T%29%20can%20help,%24300%20million%20annually%20by%20USDA%20to%20administer%20them
[iii] The Ohio House Legislature 135th General Assembly, Amended Substitute House Bill Number 33, 2023. https://search-prod.lis.state.oh.us/solarapi/v1/general_assembly_135/bills/hb33/EN/06/hb33_06_EN?format=pdf
[iv] Ohio Department of Job and Family Services, Ohio Fiscal Year 2024 State Employment & Training Plan, 2023. https://jfs.ohio.gov/static/PRC/FFY2024StateETPlan.pdf
[v] Food and Nutrition Service, U.S. Department of Agriculture, Supplemental Nutrition Assistance Program: Number of Persons Participating, 2023. https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-persons-11.pdf
[vi] Hall, Lauren, Nchako, Catlin, A Closer Look at Who Benefits from SNAP: State-by-State Fact Sheets, 2023. https://www.cbpp.org/research/a-closer-look-at-who-benefits-from-snap-state-by-state-fact-sheets#Ohio
[vii] Food and Nutrition Service, U.S. Department of Agriculture, Characteristics of SNAP Households: FY 2020 and Early Months of the COVID-19 Pandemic: Characteristics of SNAP Households, 2022. https://www.fns.usda.gov/snap/characteristics-snap-households-fy-2020-and-early-months-covid-19-pandemic-characteristics
[viii] Ohio Department of Job and Family Services, Caseload Summary Statistics Report, August 2023. https://jfs.ohio.gov/static/PRC/CaseloadSummaryReportAugust2023.pdf; Economic Research Service, U.S. Department of Agriculture, Economic Linkages Supplemental Nutrition Assistance Program (SNAP) Linkages with the General Economy, 2021. https://www.ers.usda.gov/topics/food-nutrition-assistance/supplemental-nutrition-assistance-program-snap/economic-linkages/
[ix] SNAP to Skills, Food and Nutrition Service, U.S. Department of Agriculture, What is SNAP E&T? https://snaptoskills.fns.usda.gov/about-snap-skills/what-is-snap-et#:~:text=SNAP%20Employment%20and%20Training%20%28SNAP%20E%26T%29%20can%20help,%24300%20million%20annually%20by%20USDA%20to%20administer%20them
[x] Food and Nutrition Service, U.S. Department of Agriculture, A Short History of SNAP, 2023. https://www.fns.usda.gov/snap/short-history-snap#:~:text=The%20Food%20Stamp%20Act%20of%201985%20also%20outlined%20the%20financial,the%20cost%20of%20participant%20reimbursements
[xi]The Tennessee Senate Legislature 113th General Assembly, Tennessee Senate Bill 778, 2023. https://legiscan.com/TN/supplement/SB0778/id/319973
[xii]The 30-hour per week requirement can also be satisfied by earning wages that are at equal to 30 hours multiplied by Ohio’s minimum wage. Exemptions from the general work requirement include meeting work requirements for another program(TANF, UI), caring for a child under age 6 or incapacitated person, participating in an alcohol or drug treatment program, or enrolled in school or training at least half-time.
[xiii]Food and Nutrition Service, U.S. Department of Agriculture, Supplemental Nutrition Assistance Program (SNAP)
SNAP Work Requirements, 2023.https://www.fns.usda.gov/snap/work-requirements
[xiv]The list of individuals exempted from ABAWD time limits changed on October 1, 2023, with implementation of new provisions from the Fiscal Responsibility Act of 2023.
[xv]Website for Tennessee’s Department of Labor & Workforce Development’s SNAP Employment & Training Program; Website for West Virginia’s Bureau for Family Assistance’s Employment & Training Program
[xvi] According to October 2023 SNAP State Options Report, only 8 states operate Mandatory SNAP E&T programs: Florida, Idaho, Kansas, New York, Ohio, South Dakota, Texas, and Utah. Benvie, et al., Supplementary Nutrition Assistance Program State Options Report, 2023. https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-15th-state-options-report-october23.pdf
[xvii] Food and Nutrition Service, U.S. Department of Agriculture, 2023. SNAP State Options Report, 15th Edition. https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-15th-state-options-report-october23.pdf
[xviii] Open findings from the Management Evaluation Report for Franklin County Able-Bodied Adults Without Dependents and Employment & Training by Food and Nutrition Service, U.S. Department of Agriculture, in February 2023.
[xix] Letter to ODJFS Director Damschroder on May 18, 2023 from Vista Fletcher, FNS Regional Administrator
[xx] Ohio Department of Job and Family Services, Food Assistance Change Transmittal (FACT) No. 96, 2023. https://emanuals.jfs.ohio.gov/CashFoodAssist/FACM/FACT/FACT-96.stm
[xxi]Note that Ohio submitted revised data in July2023 showing a 13% completion rate, which is still far below Ohio’s regional peers. The second lowest completion rate in the Midwest was 40%.
[xxii] The Ohio House Legislature 135th General Assembly, Amended Substitute House Bill 33, 2023. https://search-prod.lis.state.oh.us/solarapi/v1/general_assembly_135/bills/hb33/EN/06/hb33_06_EN?format=pdf
[xxiii] Ohio Department of Job and Family Services, FFY2024SNAP Employment and Training (E&T) State Plan, 2023, 18. https://jfs.ohio.gov/static/PRC/FFY2024StateETPlan.pdf
[xxiv]Ohio Department of Job and Family Services, FFY2024 SNAP Employment and Training (E&T) State Plan,51.
[xxv]Ohio Department of Job and Family Services, SNAP Employment and Training (E&T) County Plans, 2023, 71-77. https://jfs.ohio.gov/cash-food-and-refugee-assistance/food-assistance/food-programs/snap-supplemental-nutrition-assistance-program/snap-employment-and-training-plan/snap-employment-and-training-plan
[xxvi]Ohio Department of Job and Family Services, SNAP Employment and Training (E&T) County Plans, 79-81.
[xxvii]Ohio Department of Job and Family Services, SNAP Employment and Training (E&T) County Plans, 82-91.
[xxviii]United States Census Bureau, QuickFacts,2023. https://www.census.gov/quickfacts/fact/table/montgomerycountyohio,lucascountyohio/PST045222; Ohio Department of Job and Family Services, 2024 County SNAP Employment and Training Plan for Lucas County,2023, 22. https://jfs.ohio.gov/static/ofam/LucasCountyFFY2024SNAPETPlan.pdf;Ohio Department of Job and Family Services, 2024 County SNAP Employment andTraining Plan for Montgomery County, 2023, 26. https://jfs.ohio.gov/static/ofam/MontgomeryCountyFFY2024SNAPETPlan.pdf
[xxix]Ohio Department of Job and Family Services, 2024 County SNAP Employment and Training Plan for Licking County, 2023, 28-30. https://jfs.ohio.gov/static/ofam/LickingCountyFFY2024SNAPETPlan.pdf;Ohio Department of Job and Family Services, 2024 County SNAP Employment andTraining Plan for Cuyahoga County, 2023, 31. https://jfs.ohio.gov/static/ofam/CuyahogaCountyFFY2024SNAPETPlan.pdf
[xxx] Food and Nutrition Service, U.S. Department of Agriculture, SNAP E&T Pilots Summary of Key Findings and Considerations,2023, 1. https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-et-pilot-findings-july23.pdf
[xxxi] Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Final Summary Report, 2023, viii. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-ET-FinalReport.pdf
[xxxii] Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Evaluation of USDA’s Supplemental Nutrition Assistance Program (SNAP)Employment and Training Pilots: Final Summary Report (Summary), 2022. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-ET-FinalReport-Summary.pdf
[xxxiii] Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Final Summary Report.
[xxxiv] Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Final Summary Report, 51.
[xxxv] Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Evaluation of USDA’s Supplemental Nutrition Assistance Program (SNAP)Employment and Training Pilots: Final Summary Report (Summary), 2.
[xxxvi]Food and Nutrition Service, U.S. Department of Agriculture, Final Summary Report, p. XX, 10-12, 51.
[xxxvii] Food and Nutrition Service, U.S. Department of Agriculture, SNAP E&T Pilots Summary of Key Findings and Considerations.
[xxxviii]Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Final Summary Report, Appendix C.
[xxxix]Food and Nutrition Service, U.S. Department of Agriculture, Sanctions in SNAP E&T Mandatory Programs: Lessons from the SNAP E&T Pilots, 2022. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-E-and-T-Lessons-Sanctions-Brief.pdf
[xl] Food and Nutrition Service, U.S. Department of Agriculture, Sanctions in SNAP E&T Mandatory Programs: Lessons from the SNAP E&T Pilots, 2-4.
[xli]Food and Nutrition Service, U.S. Department of Agriculture, Sanctions in SNAP E&T Mandatory Programs: Lessons from the SNAP E&T Pilots, 4.
[xlii] Food and Nutrition Service, U.S. Department of Agriculture, Sanctions in SNAP E&T Mandatory Programs: Lessons from the SNAP E&T Pilots, 4.
[xliii] Food and Nutrition Service, U.S. Department of Agriculture, Sanctions in SNAP E&T Mandatory Programs: Lessons from the SNAP E&T Pilots, 3.
[xliv] U.S. Bureau Of Labor Statistics, Labor force characteristics by race and ethnicity, 2022, 2023. https://www.bls.gov/opub/reports/race-and-ethnicity/2022/home.htm
[xlv] U.S. Bureau Of Labor Statistics, Education pays,2021, 2022. https://www.bls.gov/careeroutlook/2022/data-on-display/education-pays.htm
[xlvi]U.S. Department of Agriculture SNAP to Skills Institute webpage.
[xlvii]Food and Nutrition Service, U.S. Department of Agriculture, Expanding Opportunities and Reducing Barriers to Work: Final Summary Report, 23.
[xlviii] Ohio Department of Job and Family Services, Fiscal Administrative Procedure Letter No. 92, 2021. https://emanuals.jfs.ohio.gov/LocalAdmin/FAPM/FAPL/FAPL-92.stm
[xlix] Food and Nutrition Service, U.S. Department of Agriculture, Implementing the SNAP E&T Pilots: Challenges Encountered and Lessons Learned, 2021. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-ET_Issue-Brief_Lessons-Learned.pdf
[l] In Kentucky, when a Case Manager asked participants where they would like to work if they could, one said she'd tried to get hired at the local hospital for years. After completing her work-based learning hours, she was hired full-time in an unsubsidized role.
[li] Food and Nutrition Service, U.S. Department of Agriculture, Implementing the SNAP E&T Pilots: Challenges Encountered and Lessons Learned.
[lii] Food and Nutrition Service, U.S. Department of Agriculture, Implementing the SNAP E&T Pilots: Challenges Encountered and Lessons Learned.
[liii] Seattle Jobs Initiative (SJI), SNAP E&T Opportunities for Alignment with WIOA, 2016. https://www.seattlejobsinitiative.com/wp-content/uploads/SNAP_ET_WIOA_Alignment.pdf.
[liv] Ohio Department of Job and Family Services, FFY2024 SNAP Employment and Training (E&T) State Plan, 110-120.
[lv] Food and Nutrition Service, U.S. Department of Agriculture, Considerations for Providing SNAP E&T Through Community Colleges: Lessons from SNAP E&T Pilots, 2022, 3-4. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-ET-CommColleges-Brief.pdf
[lvi] Food and Nutrition Service, U.S. Department of Agriculture, Finding Work after Occupational Skills Training: Employment Patterns from the SNAP E&T Pilots, 2022, 4. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-E-and-T-Lessons-FindingWork-Brief.pdf
[lvii] Coccia, A. Children’s Defense Fund Ohio. Successful Community College Acceleration Program should be expanded through FY22/23budget, April 2, 2021. https://cdfohio.org/cdf_oh_blog/successful-community-college-acceleration-program-should-be-expanded-through-the-fy22-23-budget/
