Community Action and SNAP E&T:

A Flexible Approach to CAA Involvement

Laws and regulations

While the way a SNAP E&T program is designed and implemented is largely state-specific, any CAA that participates in the program must be aware of and comply with the federal laws and regulations that govern the program. Many of these requirements will be incorporated into the state-level requirements imposed on third-party partners by state authorities. CAAs should be sure to read through SNAP E&T grant agreements or contracts (see Learn: grantees vs. contractors) and consult with an attorney to be clear on the legal obligations applicable to the CAA.

The following list includes key federal statutes and regulations that third-party partners should be familiar with and may need to reference for SNAP E&T.

Food Security Act of 1985
This legislation established the requirement that state agencies implement SNAP E&T programs.

SNAP Act, 7 U.S. Code Chapter 51
This chapter of the U.S. Code contains the federal statutes that pertain to the SNAP program. Within this chapter are statutory provisions that govern the SNAP E&T program, including but not limited to 7 U.S.C. § 2015, 7 U.S.C. § 2020, and 7 U.S.C. § 2025.

SNAP Work Provision Rules, 7 Code of Federal Regulations § 273.7
The Code of Federal Regulations contains the SNAP Work provisions, which are the federal rules that implement sections of the Food Security Act and subsequent statutes applicable to SNAP E&T. The rules govern the SNAP E&T program, including work requirements for program participants along with state agency responsibilities, grant allocations, use of funds, participant reimbursements, case management, and program administration.

SNAP Eligibility Rules, 7 Code of Federal Regulations Part 273 Subpart D
The Code of Federal Regulations contains federal rules related to eligibility for SNAP benefits.

Agricultural Improvement Act of 2018 (2018 Farm Bill)  
The 2018 Farm Bill made several, notable changes to the existing SNAP E&T program that are relevant to third-party participants. These included requirements that state SNAP E&T agencies consult with the state workforce development board or employers in the state when developing annual E&T state plans, that case management be provided to all SNAP E&T participants, and that programs include components addressing job retention and supervised job searches. USDA FNS implemented these changes through its March 2021 Final Rule, Employment and Training Opportunities in SNAP, which includes the resulting federal regulations (see 7 C.F.R. § 273.7). In March 2021, USDA FNS also released Final Rule: Employment and Training Opportunities in SNAP – Questions and Answers, with additional information and guidance about the changes.

Civil rights laws and regulations
SNAP E&T programs may not discriminate against those eligible to participate in SNAP E&T programs or SNAP E&T participants. USDA’s FNS houses a Civil Rights Division dedicated to ensuring that programs funded by USDA comply with federal requirements that prohibit discrimination based on race, color, national origin, age, sex, religious creed, disability and political beliefs. Third-party partners should ensure that they understand the civil rights requirements associated with SNAP E&T programs. Many of these will be included in grant agreements or contracts with the state. An overview of civil rights requirements related to SNAP E&T can be found on the USDA FNS website, SNAP E&T Guidance on Civil Rights Requirements.

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 C.F.R. Part 200
Fiscal responsibilities and cost allowability for all SNAP E&T funding are governed by the Uniform Guidance, which was adopted and supplemented by Department of Agriculture rules (2 C.F.R. Part 400). Further fiscal requirements are located in the SNAP program rules (7 C.F.R. §§ 271 through 285).

 

Additional Resources: 

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.