Aug 8 -- The Food and Nutrition Service, U.S. Department of Agriculture, invites the general public and other public agencies to comment to OMB on this proposed information collection for the Assessing Equity in Work Requirements and SNAP [Supplemental Nutrition Assistance Program] Employment & Training study. This is a new information collection request. This study informs the U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) about feasible options for assessing and monitoring equity in the administration of SNAP work requirements and SNAP Employment and Training (E&T) services. Written comments must be received on or before September 9, 2024.
Section 17 [7 U.S.C. 2026] (a)(1) of the Food and Nutrition Act of 2008, as amended, provides general legislative authority for the planned data collection. It authorizes the Secretary of Agriculture to enter into contracts with private institutions to undertake research that will help improve the administration and effectiveness of SNAP. FNS is conducting this study to identify data available from SNAP State agencies, their E&T provider partners, and other sources that can be used to develop measures to assess equity in the administration of SNAP work requirements and E&T services. The developed measures can be used to determine how and whether States are providing equitable access to SNAP through the administration of work requirements, achieving equitable participation in education and training opportunities through the SNAP E&T program, and adopting program option and discretionary policies and procedures that influence disparities.
This is a new Information Collection Request. The Food and Nutrition Act of 2008, as amended in 2014, provides the legislative authority for the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) to administer the Supplemental Nutrition Assistance Program (SNAP). Section 17 of the Food and Nutrition Act of 2008 provides FNS with the authority to conduct research to help improve the administration and effectiveness of SNAP.
Congress has amended Federal law to add provisions for SNAP participants focused on employment and work. SNAP participants aged 16–59 must meet certain general work requirements unless they are exempt or show good cause for being unable to work. Noncompliance with general work requirements may result in disqualification for any person from SNAP. SNAP participants aged 18–49 who do not have disabilities and live in households without dependents—referred to as able-bodied adults without dependents (ABAWDs)—are subject to a time limit on receipt of SNAP benefits. ABAWDs must be employed or participate in SNAP Employment and Training (E&T) activities for 80 hours a month or participate in workfare to maintain SNAP benefits for more than 3 months in a 36-month period. ABAWDs and other SNAP participants who are not exempt from work requirements can meet their work requirements by participating in a SNAP E&T program.
SNAP State agencies must operate a SNAP E&T program to help SNAP participants gain skills, training, or work experience. The SNAP E&T program is meant to increase participants’ ability to obtain regular employment and achieve economic self-sufficiency. While SNAP State agencies must offer a SNAP E&T program, they have flexibility in deciding whether some or all participants subject to general work requirements are required to participate or whether to exempt them from this requirement and offer a voluntary SNAP E&T program.
SNAP participants subject to SNAP work requirements and those who volunteer to participate in SNAP E&T represent a population often facing systemic barriers to employment opportunities, such as low educational attainment, less recent attachment to the labor force, and lack of transportation. The Federal Government made a commitment to ensure programs such as SNAP advance equity for all, including individuals who have been historically marginalized or underserved. President Biden’s January 20, 2021, Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government explains the need to address any barriers to equal opportunity caused by policies and programs to advance equity.
In alignment with the Executive Order, USDA FNS has contracted with Westat Insight to conduct a study identifying the data available from SNAP State agencies, their SNAP E&T provider partners, and other sources that can be used to develop measures to assess and monitor equity in the administration of SNAP work requirements and SNAP E&T services. The study includes a survey of all 53 SNAP State agencies, document review, and key informant interviews with individuals from 6 States. This Information Collection Request includes five data collection instruments: (1) Survey Instrument (attachment C); (2) SNAP State Agency Interview Protocol (attachment D); (3) SNAP Local Agency Interview Protocol (attachment E); (4) SNAP E&T Provider Interview Protocol (attachment F); and (5) Interested Parties Interview Protocol (attachment G).
The findings from this study will provide FNS with recommendations on how to assess and monitor equity in the administration of work requirements in SNAP and SNAP E&T programs. The information collected will be evaluated to identify the data available to assess equity in the application of policy or other instances where equity issues may arise, such as equitable access to SNAP through the administration of work requirements, equitable participation in education and training programs through SNAP E&T programs, or the influence of optional and discretionary policies and procedures on participant outcomes.
FNS has identified four objectives for this study:
1. Identify areas in the administration of work requirements in SNAP and in SNAP E&T program administration and access where equity issues could occur.
2. Identify and describe the data that could be used to assess access and outcomes in the areas identified in Objective 1.
3. Describe how State agencies address equity in administering work requirements in their SNAP and SNAP E&T programs.
4. Develop recommendations on how FNS should assess and measure equity in the administration of work requirements in SNAP and in SNAP E&T program administration and access.
FNS will use this information in considering plans to examine how and whether States are providing equitable access to SNAP through the administration of work requirements, achieving equitable participation in education and training opportunities through the SNAP E&T program, and adopting program option and discretionary policies and procedures that influence disparities. The study findings will be summarized in a report. FNS will post the final report with detailed findings in aggregate form on the FNS website. FNS may share public-use data files, which will not include any information that would compromise participant privacy, with other entities as requested. The research objectives of this study as defined by FNS and a description of the data collection are provided in attachment B, Research Objectives and Approach to Data Collection.
SNAP Work Requirements:
https://www.fns.usda.gov/snap/work-requirements
SNAP Employment and Training:
https://www.fns.usda.gov/snap-et
FNS submission to OMB:
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202406-0584-003 Click on IC List for questionnaire, View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting public comment:
https://www.federalregister.gov/d/2024-17584
For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at
https://www.aeaweb.org/content/file?id=5806