FATL 379 (Supplemental Food Assistance Nutrition Program Employment and Training (SNAP E&T) Requirements)
Food Assistance Transmittal Letter No. 379
June 21, 2017
TO: All Food Assistance Manual Holders
FROM: Cynthia C. Dungey, Director
SUBJECT: Supplemental Food Assistance Nutrition Program Employment and Training (SNAP E&T) Requirements

In accordance with section 106.03 of the Ohio Revised Code (ORC), each state agency is required to review each of its rules in the Ohio Administrative Code a minimum of once every five years. The intent of the review is to ensure that Administrative Code rules are clearly written and that program requirements are accurate, up-to-date and clearly expressed. To the extent possible, unnecessary paperwork will be eliminated, local agencies will be given increased flexibility, and any adverse impact on businesses will be eliminated or reduced. As a result of the review, the agency may amend the rule; rescind the rule; or continue the rule without amendment.

In addition to the rules subject to five year rule review, the Office of Family Assistance (OFA) is proposing both substantive and non-substantive changes to Ohio's mandatory employment and training program due to a recent management evaluation by the US Department of Agriculture, Food and Nutrition Service (FNS).

The rule has been subject to a review by the Joint Committee on Agency Rule Review (JCARR). The rules will become effective on 7/01/2017.

Chapter 2000 Application Process

5101:4-2-07"Food Assistance: Initial Interview Process”

The rule describes the process for conducting the initial eligibility interview in the supplemental nutrition assistance program (SNAP). OFA amended this rule. Changes to the rule include:

  • Clarified the rights and responsibilities that must be explained during the eligibility interview.
  • Clarified that the county agency must determine if each member of the household is required to register for work.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

Chapter 3000 Non Financial Eligibility Standards

5101:4-3-09"Food Assistance: Ohio Works First Assistance Groups"

The rule describes the actions a county agency must take on SNAP benefits when a member of an assistance group in which all members are receiving Ohio works first (OWF) is sanctioned or disqualified from the OWF program for failing a requirement in the OWF program. OFA amended this rule. Changes to the rule include:

  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-11"Food Assistance: Work Registration and Exemptions."

The rule describes the process for determining which SNAP recipients are subject to work registration requirements. OFA amended this rule. Changes to the rule include:

  • Clarified the requirements of an individual required to register for work.
  • Revised the process for determining an individual to be physically or mentally unfit for employment to align with the process for able-bodied adults without dependents.
  • Clarified that the county agency must ensure that work registrants received verbal notification of their rights and responsibilities.
  • Added the requirement that each mandatory work registrant be provided with information about services available through the OhioMeansJobs website (OhioMeansJobs.com) and/or the closest OhioMeansJobs center.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T.”
  • Other non-substantive changes for clarity.

5101:4-3-11.1"Food Assistance: Work Registration Requirements."

The rule describes the work registration requirements of a work registered individual and the consequences for failing to meet the requirements. OFA amended this rule. Changes to the rule include:

  • The title of the rule has been revised from “Food Assistance: Employment and Training Requirements” to “Food Assistance: Work Registration Requirements.”
  • Modified who is subject to the SNAP E&T requirements described in rule 5101:4-3-29. Specifically, only ABAWDs are required to participate in E&T. ABAWDs who reside in a county where the ABAWD work requirement has been waived must still participate in SNAP E&T. All work registered individuals will receive information and the opportunity to participate in OhioMeansJobs.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-11.2"Food Assistance: Work Registration Sanctions and Compliance."

The rule describes the work registration requirements of a work registered individual and the consequences for failing to meet the requirements. OFA amended this rule. Changes to the rule include:

  • The title of the rule has been revised from “Food Assistance: Employment and Training Program Sanctions and Compliance” to “Food Assistance: Work Registration Sanctions and Compliance.”
  • Clarified that sanctions apply to all work registration requirements, which is not limited to (but includes) SNAP E&T requirements.
  • Clarified that the penalty for voluntarily quitting a job or reducing work hours is described in rule 5101:4-3-19.
  • Revised paragraph (D) to align with the requirements found in 7 CFR 273.7(f)(7) which holds that the failure to comply with an unemployment or Ohio Works First requirement is equivalent to failing a SNAP work registration requirement. No determination by the county agency is required; and removed paragraph (D)(4) as it is redundant to paragraph (D)(3).
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-19"Food Assistance: Voluntary Quit and Reduction of Work Effort."

The rule describes the penalty for work registered individuals who voluntarily quit employment or reduce work hours. OFA amended this rule. Changes to the rule include:

  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-20"Food Assistance: Able-Bodied Adults without Dependents."

The rule describes the process for determining who is an able-bodied adult without dependents (ABAWD); the work registration, SNAP E&T and work requirements applicable to ABAWDs; and the ABAWD time-limit. Because the change to the requirements are so extensive, OFA rescinded the rule and adopted this new rule with the same rule number. Changes from the existing rule include:

  • Clarified the requirements for determining who is an ABAWD.
  • Clarified that ABAWDs are subject to work registration requirements; SNAP E&T requirements; and the ABAWD work requirement.
  • Clarified the way that ABAWDs may meet the work requirement.
  • Removed the language describing how ABAWDs may regain eligibility after reaching the time-limit and moved it to new proposed rule 5101:4-3-20.1.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP) ", and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-20.1"Food Assistance: Regaining Eligibility."

The rule describes the process for ABAWDs who have reached the ABAWD time-limit to regain SNAP eligibility. OFA moved this information from paragraphs (G) and (H) of existing rule 5101:4-3-20 into a new proposed rule. Changes from the existing language include:

  • Clarified the requirements necessary to regain eligibility.
  • Clarified requirements for calculating the SNAP benefit amount when an ABAWD regains eligibility.
  • Clarified the eligibility criteria for receiving three additional months of eligibility for an ABAWD that has regained eligibility.
  • Removed the language describing how ABAWDs may regain eligibility after reaching the time-limit and moved it to new proposed rule 5101:4-3-20.1.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-29"Food Assistance Employment and Training: Appraisal"

The rule describes the process for appraising individuals required to participate in SNAP E&T. OFA amended this rule. Changes to the rule include:

  • Added a requirement for required SNAP E&T participants to sign the employability plan developed in accordance with this rule. This change is necessary to ensure that participants are aware of their SNAP E&T assignments and obligations.
  • Clarified that the county agency must ensure that work registrants received notification of their rights and responsibilities. Added a requirement that the appraisal be conducted within thirty days of authorization of benefits. Participation in SNAP E&T is a condition of eligibility for required SNAP E&T participants and ensuring that the appraisal is conducted in a timely manner is a recommendation of FNS.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-30"Food Assistance Employment and Training Program"

The rule describes the process for appraising individuals required to participate in SNAP E&T. OFA amended this rule. Changes to the rule include:

  • Clarified that only ABAWDs (including those in waived counties) are required to participate in SNAP E&T.
  • Added a requirement for required SNAP E&T participants to sign the employability plan. This change is necessary to ensure that participants are aware of their SNAP E&T assignments and obligations.
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-31"Food Assistance Employment and Training: Required Hours"

The rule describes the process for appraising individuals required to participate in SNAP E&T. OFA amended this rule. Changes to the rule include:

  • Revised the minimum number of hours to align with the minimum hourly requirements described in 7 CFR 273.7(e)(1).
  • The term "food assistance" was replaced with "Supplemental Nutrition Assistance Program (SNAP)"; and the term "employment and training" was replaced with "SNAP E&T."
  • Other non-substantive changes for clarity.

5101:4-3-37"Food Assistance Employment and Training: Job Development"

The rule describes the former SNAP E&T job development activity. OFA rescinded this rule, as it is no longer an approved component of Ohio's SNAP E&T plan.