Community Action and SNAP E&T:
A Flexible Approach to CAA Involvement
Integration with CAA programs
A CAA does not operate one program in isolation. Its unique role within the community demands that it offer programs and services to address the needs of its clients, which often include food, health, housing, early childhood learning, education, and employment. CAAs work to accomplish the goals of the federal CSBG Act to reduce poverty, revitalize low-income communities, and empower low-income families and individuals through, among other things, “the organization of a range of services related to the needs of low-income families and individuals” (42 U.S.C. § 9901(2)(B)). Successful CAAs integrate programs and processes as much as possible to create efficiencies and utilize resources, but also because they recognize that many low-income individuals face multiple barriers to self-sufficiency and stability. Thus, addressing client needs via a range of supportive services helps ensure that individuals have as many tools as possible to succeed. This whole-person perspective is also critical to developing the case management and referral systems CAAs must have in place to provide SNAP E&T. CAAs are familiar with these systems, given the federal CSBG Act requirement that CAAs provide the state with information to inform the state CSBG plan that includes “a description of how linkages will be developed to fill identified gaps in the services, through the provision of information, referrals, case management, and followup consultations” (42 U.S.C. § 9908(b)(3)(B)).
Federal regulations require state case management services for SNAP E&T participants “to guide the participant towards appropriate E&T components and activities based on the participant’s needs and interests, support the participant in the E&T program, and to provide activities and resources that help the participant achieve program goals.” 7 C.F.R. § 273.7(e)(1). The good news for CAAs is that many already utilize some form of case management system to help track and understand assistance received by clients and recognize eligibility for additional programs and services. This type of coordination is a key advantage that CAAs can offer. Consider how SNAP E&T may be integrated into these systems, because in many states, there is flexibility in how third-party partners meet the program’s case management requirement.
While some states use a shared case management system for SNAP E&T and allow third-party partners to access the system, others permit partners greater flexibility to manage cases using their own systems, provided that the system used meet minimum case management standards, including that they support participants as they progress through the program and that they do not impede an individual’s participation in the program. See USDA FNS’ SNAP Employment and Training Program: Training Toolkit. State provider handbooks and service contracts also detail specific case management requirements and features. CAAs should check with their states to determine their approach to SNAP E&T case management, what is required, and whether their current systems suffice.
Beyond the requirements, effective case management is essential for CAAs seeking to integrate SNAP E&T into existing programs and services. An effective system identifies needed services and helps facilitate client access to them. Consider how to integrate those with SNAP E&T. Does programmatic or administrative overlap exist? As discussed in Expense options, 50 percent funds allow third-party partners to scale up existing jobs programs by combining non-federal funds with SNAP E&T funds. Even if the program uses federal funds, a CAA might consider ways in which it could tap into the expertise created by that program for SNAP E&T. Program personnel could be effective educators or job trainers, or fiscal capacity might already be in place for the type of reimbursements associated with SNAP E&T. Remember, SNAP E&T participation impacts CAA staffing because SNAP E&T funding can support CAA staff who work directly with program participants, such as case managers, trainers, and coaches, as well as staff who administer the program, including those processing reimbursements and drafting invoices. For example, a case manager position normally funded by CSBG funds could be reallocated to be partially funded by SNAP E&T 100 percent funds for the time spent working on SNAP E&T case management. If this CAA only receives SNAP E&T 50/50 funds, remember that it would need to use other, non-federal funds (or CDBG funds) to cover 50 percent of the employee’s time spent working on SNAP E&T. CAAs must ensure that they possess the fiscal capacity to track and allocate staff costs appropriately when multiple awards are involved (see Expense options).
Referrals are another important area where a CAA’s experience may make integration of SNAP E&T into existing processes easier. States handle referrals, eligibility determinations, and assessments for SNAP E&T differently. Whereas some states choose to handle these aspects of the program at the state level as state agency referrals, others involve third-party partners in what are termed “reverse referrals”. Some states do both.
Reverse referral systems involve third-party partners such as CAAs, CBOs, or community colleges that conduct the entire referral process or elements of it. A CAA might, for example, participate in SNAP E&T by identifying among its clients who is eligible for and interested in the program, assessing alignment with available opportunities, or referring potential participants to an internal SNAP E&T program or to another CBO for services based on an assessment of individual needs. A CAA might also play a role in the enrollment process for SNAP E&T. American Jobs Centers, which some CAAs participate in (see X-factors: CAA considerations) sometimes also refer potential participants to a third-party partner such as a CAA. See USDA FNS’ Screening, Assessment, and Referral in E&T section of its SNAP E&T Program Toolkit at pp. 40-43.
As with case management, CAAs are well-versed in referrals and expected to use them to link services for clients under CSBG, and so opportunities exist for CAAs to add significant value in these areas of SNAP E&T. Since CAAs often serve as the entry point for clients to access other programs and services, adding a referral process for SNAP E&T may be a relatively easy way to open up another avenue to employment and training services. A CAA interested in the program should get clarity on the type of referral system in place in its state for SNAP E&T. If the state plan includes reverse referrals, the CAA could have the knowledge and experience to assist.
- USDA FNS, SNAP E&T Operations Handbook: A Step-By-Step Guide to Developing, Implementing, and Growing a SNAP E&T Program (2018)
- USDA FNS, SNAP E&T Program Toolkit (Revised 2021)
- American Public Human Services Association and SJI, SNAP E&T Provider Readiness Roadmap Part 1 (2022)
- USDA FNS, Survey of SNAP Employment and Training Case Management (2020)
This project has been funded at least in part with Federal funds from the U.S. Department of Agriculture. The contents of this publication do not necessarily reflect the view or policies of the U.S. Department of Agriculture, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.