Community Action and SNAP E&T:
A Flexible Approach to CAA Involvement
Learn to distinguish between grantee and contractor relationships
States administer SNAP E&T programs and services offered by CAAs through grant agreements and contracts. The method varies by state and depends on each state’s preferred type of relationship with a third-party partner. Prior to entering into any SNAP E&T arrangement, a CAA should understand the type of agreement that governs the relationship with the state, as the duties and obligations of subgrantees differ from those of contractors.
Generally speaking, under a grant agreement, a grantor awards funds to a grant recipient, who agrees to use those funds in furtherance of a programmatic purpose. The recipient must use the funds received for the agreed-upon aim and according to the terms and conditions that govern the agreement, including any applicable laws related to allowable uses of funds, eligibility for benefits and services, reporting, and more. The grant recipient’s performance will be measured in relation to whether objectives of the award were met. Grants are awarded through a competitive application process.
When a CAA contracts with the federal or state government as a vendor, it does so to provide the government with goods or services for the government’s benefit. Contractors typically provide similar goods and services to many different purchasers, and what they provide is usually within their normal business operations. Contracts are awarded through a procurement process, which specifies the type of rate/price quote or bid proposal required for the good or service needed. Often, the goods and services provided are ancillary to the operation of the government program for which they are provided. While government contractors do not have to typically comply with programmatic requirements in the same way that grantees do (unless, for example, the contractor is involved in program service delivery), they are required to comply with requirements specifically applicable to government contracts.
Since each state takes its own approach to SNAP E&T agreements with third-party partners, a CAA should understand the type of agreement it is signing. Though CAAs are generally grantees (rather than contractors) with respect to federal funding streams such as CSBG, LIHEAP, Head Start, and Weatherization, states may sometimes issue contracts for services, rather than grants, for their SNAP E&T program. See the Uniform Guidance’s guidance on making subrecipient and contractor determinations, 2 C.F.R. § 200.331. This means a CAA must look at its state’s SNAP E&T plan and, more importantly, understand the obligations it is taking on pursuant to its agreement with the state to participate in the SNAP E&T program. Because the term “contract” is often used generically in both “contractor” and “grantee” relationships, a CAA should not assume that it is a contractor simply because it has a “contract” with the state to provide SNAP E&T services. When in doubt, a CAA should consult with an attorney licensed to practice law in its state to clarify the type of arrangement to be created, and what it obligates the organization to do.
Interested to see what a SNAP E&T grant agreement looks like? A redacted grant agreement between a state and CAA can be accessed here.
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.