ABAWD SNAP directors presentation 10-13

The Return of the ABAWD
American Association of SNAP Directors
September 24, 2013
Ed Bolen, Center on Budget and Policy Priorities
Daniel Schroeder, University of Texas, Austin
Kathy Link, Utah Department of Workforce Services
FY 2006: Most states had partial waivers
FY 2006 Waivers
No waiver (5)
Statewide (7)
Partial (39)
FY 2013: Most states have statewide waivers
FY 2013 Waiver Status
No waiver (not eligible) (1)
Partial (eligible for state) (3)
Statewide (40)
Partial waiver (3)
None (eligible for state) (2)
None (eligible for partial) (2)
FY 2014: Most states still eligible for statewide
FY 2014 Waiver Eligibility
No waiver (not eligible) (3)
Statewide (41)
Eligible for partial (7)
FY 2015: Fewer states eligible for statewide
FY 2015 Waiver Eligibility
Probably eligible for statewide (35)
Probably eligible for partial (14)
Eligible for at least partial (2)
FY 2016: Most states will need to request a
partial waiver
FY 2016 Waiver Eligibility
Likely eligible for statewide (3)
May be eligible for partial (46)
May be eligible for statewide (2)
Now is a good time to review ABAWD policy
Bad news:
• The time limit causes hardship for many poor adults
• It’s extremely complicated; could mean extra work
and errors
Good news:
• There’s more flexibility for states than often
understood – now is the time to reassess options!
The Basics
• Who is an able-bodied adult without dependents?
Between 18 and 50 years old
Not disabled
Not raising dependent children
Not otherwise exempt
• What must ABAWDs do?
Work for an average of 20 hours per week,
participate in a qualifying work activity for an average of 20 hours per week,
participate in workfare, or
Any combination
• What happens if they don’t?
– Limited to 3 months of SNAP benefits in a thirty-six month period.
• How do they requalify?
Developing a Plan of Action
What areas can your state still waive?
Who is and is not subject to ABAWD requirements?
Who will the state individually exempt?
Who will be offered qualified training (and what
activities qualify)?
• How do you track all this?
• Training
Waiver Options
• Ways to qualify
– Statewide or any area within a state
– Recent 12 or 3 month average unemployment over 10 percent
– Area has been designated a Labor Surplus Area for current fiscal year
by DOL
– 24-month average unemployment rate 20 percent above national
– Low and declining employment to population ratio
• Flexibility
– Not limited to Fiscal Year timeline
• Tip: the Center can help your state prepare a waiver request!
• Under 18 or 50 years or older
Parent of household member under 18
Residing in household with member under 18
Determined by state to be unfit for work
Already exempt from SNAP work requirements
Working an average of 20 hours per week
Flexibility with Exemptions
• ABAWD definition of disabled: “determined by the State
agency to be medically certified as physically or mentally unfit
for employment”
– Receiving temporary or permanent disability, including private
– Is obviously mentally or physically unfit for work
– Provides a statement from a State-approved medical personnel
• In contrast, SNAP general definition requires receipt of a
government disability-related benefit.
State Definition of “unable to work”
Several ways to qualify
Receive benefits, even
Obviously unfit
3d party verification
Several options to verify
Physician’s assistant
Nurse practitioner
Rep from doctor’s office
Social worker
Other medical personnel
Meeting the Work Requirement
• Who can be offered a training or work slot?
• What options are available?
– Workfare
– Other E&T
• What is the state’s capacity
– Identify existing E&T programs capacity to serve childless adults
– Geographical saturation
– Assess ability to expand
• Taking the pledge
SNAP E&T Can Help Provide Services
• 100% federal funds
– $99 million in FY 2012
• 50%-50% matching
– $240 million in FY 2012
• Pledge states
– $20 million each year (CO, DE, NY, SD, TX in 2012)
• Leveraging funds with community partners
E&T Options: 20 hours/week
• Education and Training
– Basic or vocational education, technical training, on-the-job training
and up to half of required hours in job search
• Workforce Investment Act programs
– Can include job search
– Funded by Department of Labor
• Trade Act
– Training for workers who have lost or may lose jobs
– Can include job search
– Funded by federal Department of Labor
Other Options: Hours Vary
• SNAP Workfare
– Placement at public and non-profit employers
– Can be voluntary with no disqualification for failure to comply
• Non-SNAP Workfare
– Operated by non-SNAP government agency
– Cannot use 100% E&T funding (but may match)
• Work Experience
– Placements at public and private (including for-profit) employers
– Includes self-placement
The Individual or “15 percent” Exemption
• Exemptions equal to 15 percent of the State’s ABAWD
caseload subject to the time limit.
• Each exemption extends eligibility to one person for one
month (case months). Yes, this is confusing.
• Developing an exemption policy:
– Check what’s in the bank (or what you owe)
– Extend the time limit by adding months to all affected individuals
– Target specific geographic areas
Automating Exemptions
Rule: Exemptions apply to all
individuals in an area not
covered by a waiver
• First, identify an ABAWD
• Next, screen for exemption
• If no exemption, then 12 month
personal exemption
• Tracking
Regaining Eligibility
• How?
– By working for 30 days, meeting an exemption or when the
36 month period ends.
• The tricky part: An ABAWD who regains eligibility but
then does not meet the work requirement can
receive an additional 3 months of benefits.
– Only once in a 3-year period
– The 3 months must be used consecutively
– This must be tracked
Tracking It All
• Systems must be able to track:
– 36 month clock for each individual
– Months in which individual did not meet requirements or be exempt
– Months of regained eligibility
• Just to make this more complicated
– Countable months need not be consecutive
– Must track breaks in participation
– Only full benefit months count
• System must be able to track use of individual exemptions
Implementing the ABAWD Three-Month
Time Limit
Kathy Link
Utah Department of Workforce Services
September 2013
Decision to Implement Statewide
• Executive Director made decision to implement the
3-month limit statewide
– Decision made in part due to anticipation that Utah would
eventually no longer qualify for a statewide waiver
– Did not want to implement time limits at same time as ACA
• No increase in E&T budget to implement ABAWD
time limits
• Decision was made to automate E&T and shift staff
to case manage ABAWDs
Planning Process
• Planning began in March 2011 with implementation target
date of October 1, 2012
• Workgroup formed consisting of:
– Policy
– Systems
– Operations
• Phase 1 Automate E&T
– Stopped serving volunteers July 1, 2012 (now considered universal
– Participate 3 months out of 12
• Phase 1 (cont.)
– Modeled SNAP E&T on Unemployment Insurance model
• Send notice to mandatory participants with instructions to go
• Complete online assessment to determine if job ready
• Complete workshops as assigned by assessment
– Resume writing, interviewing skills, social networking, etc
• Job search
• Phase 2 ABAWD
– Most workers did not know ABAWD policy
– ABAWD time limits not in new eligibility system
– Pulled out old ABAWD policy and current regulations
Policy and Program Decisions
• Pledge state
• ABAWD process
– Automated referral made to employment counselor if 0, 1 or 2 months
of ABAWD used
– Manual referral made to employment counselor by eligibility if all 3
months used so can begin participation immediately
– Meet with employment counselor before 4th month
– First month of participation is job search and assignment to worksite
– Second month and ongoing participate 24 hours per month of
• Implemented incrementally
– All new applications beginning October 1 had time
– Ongoing cases time limit began at first
recertification after September 2012
• Estimated 17,000 ABAWDs with ongoing cases.
Approximately 2800 per month for first six months
– Very limited number of 15% exemptions so limited
criteria for use
 New eligibility system (eREP) implemented summer
 ABAWD not in production in system when decision
made to implement time limits
 System changes were made in two phases
o October 1 changes –clock started ticking, notices created
o January 1 changes-communicate with employment
counseling system, ability to be both E&T and ABAWD
Training Staff
• Two rounds of mandatory in-person training
– September 2012 trained on who is an ABAWD, what are
work requirements, who is exempt, ABAWD processes, how
system changes will work
– December 2012 trained on additional systems changes
and the more complicated situations including how to
handle recipients who are both E&T and ABAWD
• Q&A’s sent out to staff
• E&T
– 15% participate
– 78% of cases that close, close for non-participation
– 22% of those who close have earnings within 6 months of
– 12% participate
– 82% of cases that close, close for non-participation
– 16% of those who close have earnings within 6 months of
• Policy options
• Identify possible waiver options
• Review exemption policy
– Unfit for work
– Verification
• Use of 15% exemptions
• Program options
• Capacity of state E&T programs
• Partnerships with other training programs
• Implementation
• Develop tracking system and policy
• Training for staff
• Notice and information to participants
Ed Bolen
Center on Budget and Policy Priorities
[email protected]

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