Presentation on theme: "American Association of SNAP Directors"— Presentation transcript:
1 American Association of SNAP Directors The Return of the ABAWDAmerican Association of SNAP DirectorsSeptember 24, 2013Ed Bolen, Center on Budget and Policy PrioritiesDaniel Schroeder, University of Texas, AustinKathy Link, Utah Department of Workforce Services
2 FY 2006: Most states had partial waivers It might be good to also point out that not all of these were on the October-September schedule. These varied, from one town in RI, to almost all of the state in other states.
3 FY 2013: Most states have statewide waivers Most states eligible for statewide (3 were eligible but chose partial, 2 chose no waiver)
4 FY 2014: Most states still eligible for statewide Note that I didn’t indicate what they’re actually doing, but just what they’re eligible for. Based off of EUC.
5 FY 2015: Fewer states eligible for statewide Assuming states will be able to use a trigger notice from October-December 2013 to waive 2015, most states will still be eligible for statewide. AK and WV are close to dipping below the EUC threshold, so may not be eligible for partial. 4 others (KS, MT, HI, UT) have already dipped below and won’t be eligible for a statewide (unless their unemployment increases in the next few months).
6 FY 2016: Most states will need to request a partial waiver 3 states will probably be eligible for statewide, based on having unemployment rates above 20% above the national average for a 24-month period (CA, NV, RI). 2 others (NJ, NC) are close to that level, so may qualify. The others will need to request partial waivers.
7 Now is a good time to review ABAWD policy Bad news:The time limit causes hardship for many poor adultsIt’s extremely complicated; could mean extra work and errorsGood news:There’s more flexibility for states than often understood – now is the time to reassess options!
8 The Basics Who is an able-bodied adult without dependents? Between 18 and 50 years oldNot disabledNot raising dependent childrenNot otherwise exemptWhat 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, orAny combinationWhat happens if they don’t?Limited to 3 months of SNAP benefits in a thirty-six month period.How do they requalify?
9 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
10 Waiver Options Ways to qualify Flexibility Statewide or any area within a stateRecent 12 or 3 month average unemployment over 10 percentArea has been designated a Labor Surplus Area for current fiscal year by DOL24-month average unemployment rate 20 percent above national averageLow and declining employment to population ratioFlexibilityNot limited to Fiscal Year timelineTip: the Center can help your state prepare a waiver request!
11 Exemptions Under 18 or 50 years or older Parent of household member under 18Residing in household with member under 18PregnantDetermined by state to be unfit for workAlready exempt from SNAP work requirementsWorking an average of 20 hours per week
12 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 disabilityIs obviously mentally or physically unfit for workProvides a statement from a State-approved medical personnelIn contrast, SNAP general definition requires receipt of a government disability-related benefit.
13 State Definition of “unable to work” Several ways to qualifyReceive benefits, even temporaryObviously unfit3d party verificationSeveral options to verifyPhysicianPhysician’s assistantNurseNurse practitionerRep from doctor’s officePsychologistSocial workerOther medical personnel
14 Meeting the Work Requirement Who can be offered a training or work slot?What options are available?SNAP E&TWorkfareOther E&TWhat is the state’s capacityIdentify existing E&T programs capacity to serve childless adultsGeographical saturationAssess ability to expandTaking the pledge
15 SNAP E&T Can Help Provide Services 100% federal funds$99 million in FY 201250%-50% matching$240 million in FY 2012Pledge states$20 million each year (CO, DE, NY, SD, TX in 2012)Leveraging funds with community partners
16 E&T Options: 20 hours/week Education and TrainingBasic or vocational education, technical training, on-the-job training and up to half of required hours in job searchWorkforce Investment Act programsCan include job searchFunded by Department of LaborTrade ActTraining for workers who have lost or may lose jobsFunded by federal Department of Labor
17 Other Options: Hours Vary SNAP WorkfarePlacement at public and non-profit employersCan be voluntary with no disqualification for failure to complyNon-SNAP WorkfareOperated by non-SNAP government agencyCannot use 100% E&T funding (but may match)Work ExperiencePlacements at public and private (including for-profit) employersIncludes self-placement
18 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 individualsTarget specific geographic areas
19 Automating Exemptions Rule: Exemptions apply to all individuals in an area not covered by a waiverFirst, identify an ABAWDNext, screen for exemptionIf no exemption, then 12 month personal exemptionTracking
20 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 periodThe 3 months must be used consecutivelyThis must be trackedTell clients to flag to let you know when they are working and can qualify for benefits.
21 Tracking It All Systems must be able to track: 36 month clock for each individualMonths in which individual did not meet requirements or be exemptMonths of regained eligibilityJust to make this more complicatedCountable months need not be consecutiveMust track breaks in participationOnly full benefit months countSystem must be able to track use of individual exemptions
22 Implementing the ABAWD Three-Month Time Limit Kathy LinkUtah Department of Workforce ServicesSeptember 2013
23 Decision to Implement Statewide Executive Director made decision to implement the 3-month limit statewideDecision made in part due to anticipation that Utah would eventually no longer qualify for a statewide waiverDid not want to implement time limits at same time as ACANo increase in E&T budget to implement ABAWD time limitsDecision was made to automate E&T and shift staff to case manage ABAWDs
24 Planning ProcessPlanning began in March 2011 with implementation target date of October 1, 2012Workgroup formed consisting of:PolicySystemsOperationsPhase 1 Automate E&TStopped serving volunteers July 1, 2012 (now considered universal customers)Participate 3 months out of 12
25 Phase 1 (cont.) Phase 2 ABAWD Modeled SNAP E&T on Unemployment Insurance modelSend notice to mandatory participants with instructions to go onlineComplete online assessment to determine if job readyComplete workshops as assigned by assessmentResume writing, interviewing skills, social networking, etcJob searchPhase 2 ABAWDMost workers did not know ABAWD policyABAWD time limits not in new eligibility systemPulled out old ABAWD policy and current regulations
26 Policy and Program Decisions Pledge stateABAWD processAutomated referral made to employment counselor if 0, 1 or 2 months of ABAWD usedManual referral made to employment counselor by eligibility if all 3 months used so can begin participation immediatelyMeet with employment counselor before 4th monthFirst month of participation is job search and assignment to worksiteSecond month and ongoing participate 24 hours per month of worksite
27 Implemented incrementally ImplementationImplemented incrementallyAll new applications beginning October 1 had time limitOngoing cases time limit began at first recertification after September 2012Estimated 17,000 ABAWDs with ongoing cases. Approximately 2800 per month for first six monthsVery limited number of 15% exemptions so limited criteria for use
28 Technology New eligibility system (eREP) implemented summer 2010 ABAWD not in production in system when decision made to implement time limitsSystem changes were made in two phasesOctober 1 changes –clock started ticking, notices createdJanuary 1 changes-communicate with employment counseling system, ability to be both E&T and ABAWD
29 Two rounds of mandatory in-person training Training StaffTwo rounds of mandatory in-person trainingSeptember 2012 trained on who is an ABAWD, what are work requirements, who is exempt, ABAWD processes, how system changes will workDecember 2012 trained on additional systems changes and the more complicated situations including how to handle recipients who are both E&T and ABAWDQ&A’s sent out to staff
30 Outcomes E&T ABAWD 15% participate 78% of cases that close, close for non-participation22% of those who close have earnings within 6 months of closureABAWD12% participate82% of cases that close, close for non-participation16% of those who close have earnings within 6 months of closure
31 Checklist Policy options Program options Implementation Identify possible waiver optionsReview exemption policyUnfit for workVerificationUse of 15% exemptionsProgram optionsCapacity of state E&T programsPartnerships with other training programsImplementationDevelop tracking system and policyTraining for staffNotice and information to participants
32 Center on Budget and Policy Priorities Questions?Ed BolenCenter on Budget and Policy Priorities