SNAP E&T Training Workbook JULY 2014

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1 SNAP E&T Training Workbook JULY 2014

2 Introduction This SNAP E&T Workbook is intended to assist states in planning, designing and implementing expanded SNAP E&T programs. It is based upon best practices derived from Washington State s successful SNAP E&T program, Basic Food Employment & Training (BFET) program, as well as the general knowledge/expertise of the Seattle Jobs Initiative-based consulting team in designing and operating workforce development and related programs targeting low-income and low-skill populations. The Workbook is not intended to be exhaustive, but to provide key things for states to consider. How the Workbook is Organized The SNAP E&T Workbook is organized in sections that are generally ordered to reflect how states might proceed through the planning and implementation process for their expanded SNAP E&T programs. Sections are categorized as either part of PLANNING & DEVELOPMENT or OPERATIONS of SNAP E&T programs. Reference materials (many of which were created for BFET) are listed when available to enhance the information provided in the sections. Sections: Attached Reference Materials: PLANNING & DEVELOPMENT A. Understanding SNAP E&T Options National Skills Coalition Guide to SNAP E&T B. Organizing a Planning Team & Process C. Defining Your Program Objectives & Services D. Mapping and Building on Your Current Resources E. Developing a Strategic Plan & State E&T Plan Washington State SNAP E&T Plan, Budget Template F. Sustainability: Political Support/Program Funding 1

3 Sections: Attached Reference Materials: OPERATIONS G. System of Participant Referral BFET Handbook, BFET Individual Employment Plans H. System of Participant Eligibility & Invoicing BFET Eligibility/Billing Rosters, BFET Match Certification Form, BFET Student Eligibility Form I. Key State Functions & Staffing J. SNAP E&T Services through Community Colleges Information for New WA College BFET Providers, BFET Community College Start-Up Budget K. SNAP E&T Services through Community Agencies L. Identifying & Integrating Third-Party Providers BFET Capacity Checklist, BFET Letter of Intent Form (DSHS), BFET Community College Notice of Intent Form, Sample CBO Contract Statement of Work M. Building a System for Data Tracking & Analysis 2

4 PLANNING & DEVELOPMENT A. Understanding SNAP E&T Options A clear first step in planning to develop an expanded SNAP E&T program is to become familiar with the federal rules governing the program, understanding its objectives and the types of activities that are or are not allowable. In addition, a review of the federal government s new Omni Circular (which includes the former A-122) will be helpful in understanding federal costing principles relevant to SNAP E&T. Some important features of SNAP E&T to consider: Flexibility in Program Design SNAP E&T s flexibility provides states an opportunity to design robust employment and training services that best meet the needs of their SNAP populations/workforce development priorities. States should consider programs that offer both skills and supports to participants. States decide whether participation is mandatory or voluntary. Voluntary programs mean more motivated participants; less administrative burden on service providers. Complement other programs fill gaps in services of other workforce programs (WIA, TANF). Multiple Funding Streams 100 percent funds (currently $90 million) allocated to states by formula; may be used for all facets of SNAP E&T programs (planning, operations, administration and direct services) except for direct reimbursement of participant expenses. 50 percent reimbursement ( uncapped ) may be used for all facets of SNAP E&T programs, covering expenses above and beyond what is covered by 100 percent funds, as well as direct reimbursement of participant expenses related to program participation. Third-Party Match Models The state is leveraging match for SNAP E&T 50 percent reimbursement via thirdparties such as colleges and community agencies that are contracted by the state to provide SNAP E&T services. State may use 100 percent and/or 50 percent SNAP E&T funds to pay for contracted services (utilizing 100 percent funds to also meet its program administrative costs). 3

5 PLANNING & DEVELOPMENT Resources: National Skills Coalition Guide to SNAP E&T, Attached FNS SNAP E&T Toolkit, accessible at Farm Bill of 2014 [see Title IV], accessible at 113hr2642enr.pdf OMB Omni-Circular, accessible at 4

6 PLANNING & DEVELOPMENT B. Organizing a Planning Team & Process A collaborative planning process is key to developing a third-party match SNAP E&T program The state as well as potential service providers should be involved in program design State should avoid directive approach focus on equal partnership toward common goals Sets the stage for ongoing collaboration, continuous improvement after implementation Potential key partners in the planning process State agency that operates SNAP/SNAP E&T, including representatives from HQ and local service areas: 1. Policy and program staff 2. Fiscal, contracting, data and IT systems staff Other state agencies that are involved in workforce development and data collection, e.g.: 1. Workforce agency or board 2. Community college system/postsecondary education system 3. Employment security Leaders from individual community colleges and community-based organizations, particularly those likely to be initial SNAP E&T providers Other community leaders and potential project funders (such as United Way) Utilize funding, volunteerism and self-interest to incent participation in planning process BFET example: Planning Group met weekly for several months to complete project plan 5

7 PLANNING & DEVELOPMENT B. Organizing a Planning Team & Process (continued) In Washington State, the planning and development of the BFET pilot utilized a Planning Group built from an existing, multi-agency volunteer group focused on employment and training strategies for low-income individuals: 6

8 PLANNING & DEVELOPMENT C. Defining Your Program Objectives & Services Once a planning group has been organized, its first priority might be to begin work to broadly define the parameters of the SNAP E&T program to be developed. Consider starting small and developing a pilot focused on serving a specific geography with a high level of need. What are your broader goals for participants (outcomes)? Emphasis on skills development vs. immediate attachment to labor market (job search/workfare) Where will your program fall on continuum of purely employment and training services vs. inclusion of intensive social/support services (determines who you will serve/partners) Specific outcomes: skills/credential attainment; employment; wages; job retention; people move off of SNAP; etc. How will SNAP E&T fit into state s current overall workforce development priorities? State strategies to increase postsecondary attainment rates/grow skilled workforce State labor market needs/sector strategies Who will be served? Voluntary vs. mandatory Specific populations (e.g., those not well served by other employment and training programs; ready to work in unsupported employment; etc.) Specific geographies Target numbers Types of services offered Vocational education Other job skills training Job readiness/job search 7

9 PLANNING & DEVELOPMENT Types of services offered, cont d Basic skills/esl Support services (e.g., transportation, childcare, case management, career navigation/ coaching) Service delivery partners State agencies Community colleges Community-based organizations Workforce intermediaries 8

10 PLANNING & DEVELOPMENT D. Mapping and Building on Your Current Resources Once the planning group answers fundamental questions about program objectives and services of its SNAP E&T program, it can begin to map out the resources that currently exist in the state or service area that can serve as the foundation upon which the program can be built. This might include examination of: the state s current workforce development system, including gaps in services; existing effective employment and training programs and support services; existing effective program partnerships in service delivery; existing systems and staff resources that can be repurposed. This research is more feasible if it is limited to a specific geography that will be the initial focus of a SNAP E&T pilot. Map existing effective employment and training/support services Community colleges and community-based workforce providers/intermediaries Effective partnerships (e.g., college community agency, state service provider) Federal programs WIA one-stop system, TANF, etc. Identify gaps in services Populations or geographies not being well-served by existing workforce/postsecondary systems Types of services that are lacking (e.g., skills training, support services) What do WIA, TANF, and other major workforce programs do and NOT do well? Consider ways SNAP E&T can fill gaps in complementary way; create seamless transitions Identify existing systems and resources available to the state for SNAP E&T Client databases and other systems at state that can be repurposed Staff that can be repurposed (unless/until new dedicated staff can be put in place) Identify existing data resources that can be utilized for SNAP E&T SNAP agency data Employment Security/Department of Labor-funded entity (UI wage data) Community college system data (tracking persistence, credits, credential attainment) Unique data systems housed at potential services providers Map out potential matching resources for SNAP E&T reimbursement 9

11 PLANNING & DEVELOPMENT E. Developing a Business/ Strategic Plan & State SNAP E&T Plan A state s planning effort can culminate in the creation of a SNAP E&T business/strategic plan that sets out the overall purpose of the program, short and long-term goals and objectives, staffing roles and responsibilities, services to be offered, budget, etc. The elements captured in the business plan can be utilized as the basis for the state s initial SNAP E&T plan for its expanded program submitted to FNS. The importance of a business/strategic plan Ensures the SNAP E&T pilot partnership and senior leadership of the state SNAP E&T agency have a solid foundation for the program and plan for continuous improvement and expansion Key components of a SNAP E&T business/strategic plan Clear identification of program purpose what is the problem that the new services are targeted to resolve? Definition of program goals and objectives, including general participant outcomes sought The roles and responsibilities for the state agency and program partners (providers) Identification of the initial administrative resources required (of both the state agency and partners) to effectively manage the program The outcome evaluation process that will be used or commitment to develop one to define and measure program success, report on return on investment, and make improvements Performance milestones Definition of the participant engagement process and flow, as well as the supporting MIS that will be utilized Partnership organizational chart The initial planned service levels for the first year of the program, by service component The eligible potential match sources and budget for each initial program provider Commitment to and process for utilizing an honest broker model 10

12 PLANNING & DEVELOPMENT Crafting the state SNAP E&T plan from the business/strategic plan Business/strategic plan should identify core service levels and budget information required in state plan that reflects the expanded SNAP E&T program Add new components to be offered to the state plan, such as Vocational Education, Basic Education Communicate regularly with FNS regional SNAP E&T staff in process of developing plan to be certain all required elements are covered Plan must include budget by service component, summary statewide budget, as well as detailed budget spreadsheet for each of the program providers Set up process to collect necessary information from service providers (services to be offered, target population, number to be served, and detailed budgets). This forms basis of both state plan as well as individual contracts with providers. Resources: Washington State SNAP E&T Plan, Attached BFET Budget Template, Attached 11

13 PLANNING & DEVELOPMENT F. Sustainability: Political Support/ Program Funding Ultimately, any major expansion of a state s SNAP E&T program as well at its long-term sustainability requires political support and solid funding base of local (non-federal) funds. Cultivate champions for your SNAP E&T program to ensure initial and continued commitment of necessary state resources (staffing, funding) and to advocate for SNAP E&T on a federal level City and County leaders, State legislators, Governor s office, higher education and workforce committees Senior staff within the state s SNAP/SNAP E&T agency Major philanthropists, community college and community agency leaders, policy advocates Solid participant/outcomes data and client stories are critical to drive program support at the state and federal levels Long-term sustainability of expanded SNAP E&T program necessitates moving to a program primarily funded by reimbursement funds Pilot funds and 100 percent funds are limited, so states should move to identify current (and potentially build new) local match in order to grow and sustain their SNAP E&T programs SNAP E&T reimbursement can incent local funders to invest in workforce programs Programs supported by local match have additional benefit of spurring collaboration and coalition-building in support of SNAP E&T everyone has skin in the game. 12

14 G. System of Participant Referral Where will participants in your SNAP E&T program come from? In a third-party match model, the state may take responsibility for referring prospective participants to the appropriate contracted service provider(s); or, in a more decentralized model (such as Washington s BFET) contracted agencies themselves are charged with referring prospective participants into the program. Some things to consider with regard to participant referral include: Integrate state s workforce and social services systems as referral points to create more seamless transitions for prospective participants WIA one-stop system may serve as point of referral for those more appropriate for SNAP E&T TANF may serve as point of referral (individuals exhausting TANF, as well as diversion or positive prevention from TANF) SNAP agency front-line staff should be trained in SNAP E&T program and menu of providers, and serve as point of referral SNAP E&T administrators can create and disseminate resources/outreach materials and offer intra- and inter-agency as well as community training to facilitate referral SNAP E&T service providers should assess prospective participants prior to referral Most participants in third-party match models will come through doors of service providers (community colleges, community-based organizations) Contracted providers should assess participants up front to ensure appropriateness of referral into their own SNAP E&T services, as well as cross-referral Providers should not be doing 100 percent self-referral Set up a system of cross-referral whereby providers, after assessing prospective participants, may seamlessly refer individuals to other SNAP E&T providers offering more appropriate services Reverse referral model used by BFET program has advantages (and some challenges) Not difficult to find more than enough referrals through this model (potentially more than can be served by SNAP E&T) 13

15 Limits burden on state, and providers are already doing this work Individuals coming through doors of providers are typically already a good match for services Giving up control of referral means states must take extra caution to ensure program eligibility Resources: BFET Handbook, Attached College and CBO Individual Employment Plans, Attached 14

16 H. System of Participant Eligibility & Invoicing A key component of an expanded SNAP E&T program is ensuring there is an effective and accurate eligibility verification process in place. The state agency in coordination with partner providers, jointly share responsibility for verifying that 100 percent of participants are eligible for services being provided and being billed for reimbursement. Systems of participant eligibility/invoicing for third-party match SNAP E&T models Variety of possible models for the eligibility and billing processes BFET employs combination of reverse referral (contracted providers initially identify potential participants) with referrals from state agency and other community/ workforce partners BFET utilizes centralized team of state agency staff to verify eligibility at enrollment and when services are being billed An alternative model: state agency verifies eligibility up front and makes referrals to providers At billing, need process for state agency to review and approve participant rosters to ensure payment is made only for those eligible when services were provided. Key considerations/concerns in developing a participant eligibility/invoicing system Whatever process utilized should be developed collaboratively and clearly understood by the state agency and service providers (training can be provided) Eligibility and participant monitoring process requires significant staff resources for both the state and service providers Put a system in place to ensure matching resources are non-federal (e.g. certification of eligible match that puts onus on service providers) To address federal student eligibility rules, must be process for approving SNAP benefits for college students who are enrolled at least half-time in Basic Education or Vocational Education and not employed a minimum of 20 hours per week. Onsite contract monitoring process can be utilized by state to review providers compliance and accuracy within system of participant eligibility and invoicing Work to streamline this system as much as possible while still maintaining accuracy; while difficult, this can be facilitated by state implementing ideas/recommendations from providers 15

17 Utilize opportunity to build from state s current participant tracking systems Most states already have instituted participant tracking and reporting systems for their TANF welfare to work programs that can be repurposed/streamlined for SNAP E&T Involve your state s IT staff early and often A shared system supports effective coordination of services, communication between partners, participation/monitoring reports, and the UI cross-match process for outcomes reporting Resources: Sample BFET Eligibility and Billing Rosters, Attached Sample BFET Match Certification Form, Attached Sample BFET Student Eligibility Form, Attached 16

18 H. System for Participant Eligibility & Invoicing (continued) The following depicts participant flow for Washington s BFET program, in terms of enrollment, maintenance (activity tracking) and invoicing. 17

19 I. Key State Functions & Staffing The following describes the different functions a state SNAP/SNAP E&T agency might play in administering an expanded SNAP E&T program, and where these functions might reside: State program management/oversight functions Developing state SNAP E&T plan annually (includes collecting needed information from providers, making any necessary amendments) Working and communicating with FNS on behalf of state and providers (includes mandatory reporting to FNS FNS 583 repot and quarterly outcomes) Contracting service providers (includes contract monitoring, program and fiscal) Developing and executing process to identify and to bring on board new providers Strategic planning (setting overall SNAP E&T program goals, ensuring integration into state workforce, social services and postsecondary education goals) Managing federal SNAP E&T funds, reviewing contractor invoices and submitting for payment Program outreach, technical assistance and training (for prospective new providers, internal frontline staff, other systems such as WIA one-stops) Data collection and analysis, including coordination with other state agencies that collect data Advocacy for the program within state government Reports provided to stakeholders that can include the state legislature Local state agency functions Assessment/referral of participants to contracted providers (in more centralized models) Working directly with contractors to manage eligibility and invoicing process (Section H) Possible onsite services assisting service providers, including training and convening Community outreach and promotion around SNAP E&T 18

20 Some points on staffing SNAP E&T programs Consider how to re-purpose current staff initially to cover needed functions in pilot stage With program growth, 100 percent SNAP E&T funds can cover costs of new staff (still may need to advocate for legislative/agency approval to increase FTEs prepare your case) Staffing levels necessary can be reduced somewhat through: 1. Subcontracting to intermediaries through the potential use of umbrella contracts (state community college systems, workforce intermediaries, possibly organizations like United Ways) reduces contracts, contract monitoring, invoices 2. Allowing service providers access to state participant tracking MIS 3. Employing call center model centralizing local state agency functions 19

21 I. Key State Functions & Staffing (continued) The following org chart demonstrates the administrative structure for Washington s BFET program: Note: Eligibility and invoice roster approval process involves providers and DSHS CSO; DSHS HQ receives and reviews invoices and approves for payment 20

22 J. SNAP E&T Services through Community Colleges How SNAP E&T funds may be utilized by community colleges: Staff to administer the program and directly support SNAP E&T students Tuition, fees (100 percent and/or 50 percent funds), books, supplies (50 percent funds only) Bridge funding support students for 1-2 quarters while lining up other sources of aid (Pell) College-based support services May not be used for full cost of instruction only covers what non-snap E&T student pays College-based programs which can be supported by SNAP E&T Basic education, ESL and Vocational ESL, other bridge programs Professional/technical programs (shorter-term preferred by FNS; up to two-years accepted) Not for transfer students College-based support services that can be supported by SNAP E&T Coaching/counseling/college and career navigation support Transportation and childcare Textbooks, supplies (considered support services) College staffing potentially needed to run SNAP E&T Staff to work directly to support SNAP E&T students (coaching, navigation, etc.) Administrative staff to work with state on SNAP E&T eligibility and invoicing Administrative staff to identify, apply, monitor matching fund sources 21

23 Potential funding sources colleges might use as match Any state-based funding available to colleges for students, such as grants for lowincome students and worker-retraining funds College foundation funds and tuition set-asides Identifying stable and consistent funding sources is important Potential challenges/recommendations for the colleges Staffing to administer the program is significant Challenge to identify/track multiple sources of match for students Running out of match sources before academic year is over Recommend involving Business Office, Financial Aid Office, Student Services along with Workforce Education Department in designing/administering program Resources: Information for New College BFET Providers, Attached College BFET Program Start-Up Budget, Attached 22

24 K. SNAP E&T Services through Community Agencies How SNAP E&T funds may be utilized by community-based organizations: Staff to administer the program and directly support SNAP E&T participants (e.g. case managers, career navigators, coaches, trainers) Costs for training-related tuition and fees (100 percent and/or 50 percent funds), books, supplies (50 percent funds only) Support services Community-based organization programs which can be supported by SNAP E&T Basic Skills, and ESL training Job Search and Job Readiness training Vocational/Sector-based skills training short-term to longer-term (shorter-term preferred by FNS; up to two years accepted) Case management/career and college navigation; support services Mixed participant programs as well as SNAP E&T-only programs Community-based organization support services that can be supported by SNAP E&T Transportation and childcare Textbooks, supplies Housing (in some circumstances) Community-based organization staffing potentially needed to run SNAP E&T Staff to work directly to support SNAP E&T participants Administrative staff to work with state on SNAP E&T eligibility and invoicing Finance staff experienced in cost allocation systems 23

25 Potential funding sources community-based organizations might use as match Any non-federal funding, including: 1. State or local government funding 2. Private contributions: foundation or corporate grants, individual donations 3. Social enterprise revenues Ensure that federal sources are not hidden in other grants being utilized as match Potential challenges/recommendations for community-based organizations Cost allocation systems/federal dollars can be daunting access fiscal expertise Eligibility and invoicing processes can be staff intensive Need liquidity to pay for full SNAP E&T services while waiting for 50% reimbursement Technical assistance from state/other providers important when starting out 24

26 L. Identifying & Integrating Third-Party Providers In running a third-party match SNAP E&T model, states must identify partners that provide appropriate services and are additive to their overall SNAP E&T strategies. Once identified, states must have a process for contracting providers and monitoring their performance. Because SNAP E&T is complex, states should also consider what support they can provide to on-board newly-contracted providers. Processes for identifying potential providers To attract prospective providers: outreach, information, word-of-mouth (peers) Consider providers that meet service gaps (by geography, population, type of service) Consider state s administrative capacity to add new providers Evaluating potential providers Service capacity: do they provide appropriate/effective services to target population? Data recording/reporting capacity: can they track participation eligibility, meet data reqs? Financial capacity: do they have appropriate match funding, sufficient cash flow, cost allocation system, and ability to meet financial audit requirements? Consider tools (e.g., capacity checklist ) for prospective organizations to self-evaluate Consider formal process for evaluation by state prior to contracting Contracting and monitoring of providers State may contract directly with providers and/or through intermediaries Contracts should include: 1. Detailed description of services to be provided 2. Target population and anticipated number to be served 3. Anticipated participant outcomes 4. Budget that describes matching funds Site visits and other contract monitoring processes should be put in place 25

27 On-boarding support for new providers Tools, training and technical assistance from state are critical Set up a system of peer support Consider using 100 percent funds to provide start-up resources Resources: BFET Partner Agency Capacity Checklist, Attached BFET Letter of Interest template, Attached Community College Notice of Intent Form, Attached Sample CBO Contract Statement of Work, Attached 26

28 M. Building a System for Data Tracking & Analysis Integrating a system of data-collection into a SNAP E&T program is critical not only to provide internal information to the state and its partners that can lead to continuous improvement but to demonstrate tangible results that may be needed politically to support the program s continuation. Why data is so important/fns requirements in new Farm Bill The 2014 Farm Bill now requires data reporting from states on their SNAP E&T programs Building political support/justification for SNAP E&T in your state and at federal level Continuous improvement Types of data to collect Skills attainment data 1. College enrollment 2. Basic skills/esl attainment 3. College credit attainment 4. Credential attainment Employment data 1. Entered employment (e.g. at 6 months, 1-year, 2-years, etc.) 2. Job retention (e.g. at similar intervals) 3. Wage and wage advancement 4. Employed in field for which training was received Continued SNAP usage (and/or other public benefits) Where to find the data Providers can be required to keep/report data as part of contract obligations State-level community college/workforce development agencies Employment security/department of Labor-funded state agency for UI wage match data 27

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