Time Limits and Other Challenges Hinder Success of Kentucky’s SNAP E&T Program

By Ashley Spalding
January 16, 2019

Click here for a PDF of the report.

Executive Summary

Recent data shows more than 10,000 Kentuckians have lost SNAP (Supplemental Nutrition Assistance Program, formerly known as “food stamps”) as a result of new barriers to participation erected by the state. Lacking economic opportunity to become food secure without SNAP, individuals who have lost or are at risk of losing food assistance are falling through the cracks of the state’s inadequate SNAP Education and Training (E&T) program, which is meant to improve participants’ economic security in the long run — and in the short-term keeps them from losing food assistance. SNAP E&T in Kentucky has been expanded to coincide with the state’s roll-out of these barriers to food assistance – the county-by-county elimination of work requirement waivers for adults without disabilities or dependents. However, the program is inadequate to improve quality of life for the Kentuckians it is meant to serve. In addition to a lack of jobs with adequate wages in many counties that make training an insufficient response, SNAP E&T in Kentucky is difficult to access with few such training opportunities across the state, not targeted to good jobs and career pathways, and missing the support services needed to make the program successful at promoting upward mobility.

In this report, we first provide background information on SNAP E&T and the context for its expansion due to the Bevin administration’s voluntary expiration of time limits for nondisabled adults (ages 18 to 49) without dependents who receive SNAP benefits. The administration’s decision to expire time limit waivers removes nutrition assistance from SNAP participants who struggle to find adequate work, including as a result of living in economically distressed regions of our state, facing racial barriers to economic opportunity, or having a felony record, for instance. As a result of these and other factors, time limits have a long track record of failing to improve employment and economic outcomes.

Second, we show that Kentucky’s SNAP E&T program is an inadequate response to these many barriers facing Kentuckians newly subject to the time limits:

  • Employment opportunities are limited in many parts of the state, making training an insufficient response to time limits.
  • SNAP E&T training providers are few and there are numerous additional barriers to accessing E&T programs; for instance, many counties do not have a Kentucky Career Center offering E&T services including initial intake assessments for the program.
  • There is not enough focus on skills or career pathways to meaningful jobs, too much of a “work first” focus instead.
  • There are not enough supports to address the barriers many face to participation in E&T such as adequate transportation assistance. The loss of SNAP benefits due to time limits will make good, steady employment, not to mention overall health and well-being, harder. Removing nutrition assistance from Kentuckians with low incomes — many of whom already work but often in low-wage industries where hours are inconsistent — is antithetical to health, steady employment and productivity.

In total, Kentucky’s approach to SNAP runs the risk of driving people further into poverty, and further away from quality employment. The final section of this report makes policy recommendations to address concerns. The state should return to the practice of waiving time limits for SNAP in areas facing economic challenges and increase the quality and availability of E&T services and supports as part of a broader approach to reducing poverty in the state.

Context for SNAP E&T Expansion – Time Limit Waivers Expiring and Kentuckians Losing Food Assistance

SNAP E&T has been expanded in Kentucky to coincide with the expiration of time limit waivers across the state. Unfortunately, in addition to a lack of jobs in many parts of the state — particularly ones that pay adequately — SNAP recipients subject to the time limits (nondisabled adults without dependents) are more likely than others receiving food assistance to face many additional barriers to work. We have already seen more than 10,000 Kentuckians lose SNAP due to the time limits.1 This context is important for understanding the state’s expansion of SNAP E&T, which can help keep those subject to the time limit from losing benefits.

Kentucky’s voluntary expiration of time limit waivers

SNAP (formerly known as “food stamps”) is a federal program providing nutrition assistance – roughly $1.32 per meal per person in Kentucky – to about 580,000 Kentuckians with low incomes.2 The program requires that after receiving food assistance for three months, nondisabled adults without dependents must participate in a “work activity” (such as a job, school or training program including through E&T) for at least 20 hours a week. However, for decades, Kentucky has requested waivers of the requirement from the federal government for counties with long- and short-term economic challenges. But in October 2017, the state started phasing out these waivers.3 As a result, after three months of participation in SNAP, nondisabled adults without dependents now have their food assistance contingent upon participation in a “work activity” even in areas of the state where jobs are scarce. Since May 1, 2018 waivers from time limits remain in effect in just Kentucky eight Promise Zone counties in eastern Kentucky (discussed in more detail below).

Many Kentuckians losing food assistance

More than 68 percent of Kentucky’s SNAP participants are in families with children, more than 35 percent are in working families, and nearly 38 percent are in families with members who are elderly or have disabilities.4 While just about 1 in 10 receiving SNAP in January 2018 were nondisabled adults under the age of 50 without dependents, these approximately 64,000 Kentuckians face many barriers to employment including the state’s continued economic challenges that are worse in some areas than in others.5

According to national data, those subject to the time limits are extremely poor, tend to have limited education and may face barriers to work such as former involvement in the criminal justice system.6 About a quarter nationally have less than a high school education, and half have at most a high school diploma or GED credential. These SNAP participants are more likely than others receiving food assistance to lack basic job skills like reading, writing and basic mathematics.

As mentioned previously, we know that 10,000 Kentuckians so far have lost SNAP benefits for not meeting the “work activity” requirements — that’s approximately 1 in 5 people that became subject to the time limit.

Kentucky’s expansion of SNAP E&T

Established in 1985, SNAP E&T is a federal program states utilize to provide education and training to SNAP beneficiaries and more generally to support workforce development. Kentucky’s SNAP E&T program is set up to be an option for those subject to the time limit who may not be currently working enough to meet the requirement. Previously the state’s E&T program was very minimal as it was mandatory for (and only available to) those subject to the time limit — and, as noted, most areas of the state were exempt. However, the state has expanded E&T to coincide with the waiver expirations; as part of this expansion Kentucky’s E&T program is now considered to be “voluntary” for participants as it is an option for those subject to the time limits, and employment is at least theoretically another option to keep from losing benefits.7 The state has not committed to train all SNAP participants subject to the time limit, but has said by expanding the program it aims to provide more opportunity to receive these services for those at risk of losing benefits.

In nine counties (Bullitt, Campbell, Fayette, Henry, Jefferson, Oldham, Owen, Shelby and Spencer) the E&T program was also available to other SNAP recipients in 2018 — those not subject to time limits, including adults with dependents. The state is in the process of expanding E&T as an option to anyone in the state receiving SNAP.

To fund the expansion of SNAP E&T, Kentucky has relied in part on federal resources. Federal E&T funding is awarded to states in two different streams, the latter of which is the partial funding source for Kentucky’s recent expansion:

  • 100 percent funds (historically about $90 million a year across all states) that come entirely from federal dollars and do not require a state or local contribution. These funds do not stretch very far in providing education and training services to SNAP recipients.8
  • 50 percent reimbursement with federal dollars for eligible administrative costs and reimbursements for supports needed to help participants engage in services. Increasingly states are using this relatively new 50/50 match opportunity to provide training through partners such as community colleges and community-based organizations. Because the 100 percent funds are so limited, the 50/50 match enables more services to be offered to more SNAP participants.

In Kentucky, the 100 percent funds are utilized primarily by Kentucky Career Centers (KCCs) to provide SNAP participants with E&T assessment, case management and training activities such as job search and workfare (like an unpaid internship); and through the KCCs, SNAP participants can also be connected to a training program through Workforce Innovation and Opportunity Act (WIOA) funding. The 50/50 funds enable SNAP participants in Kentucky to enroll in additional E&T programs, including in a community college credential program.

Among the activities approved for state SNAP E&T programs are:

  • Job search.
  • Job search training.
  • Job retention services.
  • Workfare (similar to an unpaid internship, usually at a community organization).
  • Work experience.
  • Education and occupational training (including at a community college).
  • Self-employment training.
  • Enrollment in a federally-funded workforce training program.

A different type of SNAP E&T program — called “Paths 2 Promise” — is operating in the eight Promise Zone counties in eastern Kentucky where the time limit waivers are still in place: Bell, Clay, Harlan, Knox, Leslie, Letcher, Perry and Whitley. One of 10 SNAP E&T pilots in the nation funded by grants from the U.S. Department of Agriculture (USDA), Paths 2 Promise is designed to provide — and to test the impact of — expanded services for SNAP recipients such as team-based case management and intensive supportive services alongside education, training and subsidized employment. After the pilot ends in 2019, the work requirements are expected to go into effect in even these severely economically distressed counties.

SNAP E&T Is an Inadequate Response to Barriers Faced by Many Kentuckians Receiving SNAP

Kentucky’s SNAP E&T program is an inadequate response to time limits and the many barriers Kentuckians face to economic security. The state has too few jobs with adequate wages, and the E&T program has too few providers among other barriers to participation, is not focused enough on skills and provides inadequate supports for participants.

Too few jobs with adequate wages

While an expansion of SNAP E&T could provide important opportunities to Kentuckians needing food assistance, pairing it with SNAP time limits is counterproductive. SNAP recipients, especially those who face discrimination in the labor market and who live in economically distressed communities, may participate in E&T programs to get training and to keep their food assistance, but may still face a lack of employment options — and also hunger — once trainings are completed.

The economic challenges faced in many Kentucky communities are considerable and longstanding.9 For this reason, the time limits have never been in effect for all of Kentucky; in most of the years since 1998 when they were enacted nationally, a large number of Kentucky counties have been under a waiver because of a persistent lack of jobs. For 2018, there were 48 counties and 3 cities in Kentucky deemed Labor Surplus Areas, which made them “readily approvable” for such waivers by the USDA.10 In other words, while all Kentucky counties could potentially still qualify for waivers if the state made the case for it to the USDA, in 2018 48 counties were so challenged economically they officially had more people to work than they had jobs — and 40 of these counties now have time limits in place due to the state’s decision.11

Participants face numerous additional barriers to work

n top of the lack of good jobs, many SNAP E&T participants face additional employment impediments. A national survey of E&T participants by the USDA found 80 percent of participants reported facing at least one barrier to employment — including health issues, transportation issues, lack of education and caring for a family member with health issues.12 Approximately 28 percent reported 3 or more barriers. And 32 percent reported facing discrimination when they searched for jobs, including age (16.9 percent) race (11.5 percent) and gender (9 percent). Taking food assistance away because people cannot overcome barriers to employment will only worsen food and economic security and make it harder to get ahead.

While SNAP E&T can potentially increase education and skills, no matter how high-quality Kentucky’s E&T programs are, they will not create the jobs needed in distressed regions, eliminate race- and gender-based discrimination, or resolve individuals’ and families’ health issues. In fact, Kentuckians may become less healthy if forced to go without food assistance as a result of time limits.

Few training providers

Nine separate organizations agreed to be SNAP E&T 50/50 partners in Kentucky in 2018, which is a relatively small number given the large number of SNAP participants subject to the time limits and their geographic spread across the state. Participating organizations, listed in the table below, include two community colleges (Jefferson and Gateway), Kentucky Skills U (formerly known as “Kentucky Adult Education”) and five non-profit community-based organizations. However, just a few of these SNAP E&T programs were actually available to participants in 2018.

As shown in the table above, only a small number of SNAP recipients actually participated in one of the SNAP E&T programs offered through the 50/50 partners (as of July 2018). According to most of these partners, there have been many challenges with the program that have resulted in several having no participants at all and others reporting few referrals to their SNAP E&T program. In several cases, organizations have been confused about how to meet program requirements.13

Just four of the E&T programs listed in the table above were actually available to SNAP beneficiaries newly subject to the time limits in 2018: Opportunity for Work and Learning, Jefferson Community and Technical College, Gateway Community and Technical College, and Goodwill Industries of Kentucky.14 The reasons for this limited availability are varied, and E&T partners in some cases cited a lack of guidance and communication from the state. The resulting lack of programming is troublesome considering the important role the 50/50 partners can play in expanding access to training for those subject to the time limits (and therefore in keeping Kentuckians from losing SNAP benefits). While 50/50 partners are not the only providers of E&T training, these programs enable the state to serve more SNAP participants and offer a greater variety of training — and in some cases higher quality training.

Of the 112 counties with time limits currently in place, 14 had no E&T 50/50 partner opportunities in 2018 – and 7 of those are Labor Surplus Areas where jobs (another way to meet the work requirement) are scarce.15 Eighty counties had Goodwill Industries of Kentucky as the only operating E&T partner, and 34 of these were a Labor Surplus Area – problematic because Goodwill Industries focuses on relatively quickly placing participants in a job and fewer of these are available in Labor Surplus Areas.

KCCs can also provide SNAP E&T “work activities” including job readiness training, workfare and training (for instance, in a vocational program) through WIOA. It is unclear at this point how many E&T participants have received training through the KCCs and, as described below, there are also too few KCCs.16 At a recent Kentucky Workforce Innovation Board meeting, it was noted that around 1,200 individuals are currently enrolled in some type of WIOA-funded workforce credential program through the KCCs; however it was not indicated how many were SNAP E&T participants.

Notices about time limits and E&T option another barrier

Leading up to the expiration of waivers, SNAP recipients were sent a series of notices about the time limits expiring and the options available to those subject to the work requirements. One of these notices states that the E&T program is an option for meeting the requirements, which it describes as “a work program that includes work experience, skills training, job search and education to help you prepare for and obtain paid employment or a better job.” It also includes phone numbers for contacting a career coach to discuss this option.17

However, in the three other notices, SNAP E&T is either described in much less detail, or in more detail but using inaccessible language — and all three of these notices describe the need to register online before meeting with a career coach, which involves setting up an account with a username and login (see appendix for these notices). In addition to the lack of clarity in the documents themselves, the instructions about registering online (which could give the impression it is a requirement) may be a barrier to participation in SNAP E&T. Census data shows around 25 percent of adults receiving SNAP, who do not have a child in their household or a reported disability, do not have internet access at home.18

Too few KCC locations

The small number of KCCs providing E&T services – only 37 of the 112 counties subject to time limits have one in their county – is also likely a barrier to participation. While one KCC per county would be ideal – and this is close to what is provided to Paths 2 Promise participants – beginning in January 2017 the state closed many of its KCCs.19 KCCs provide initial screenings and placement in training programs (including with the 50/50 partners) and/or engagement in other “work activities,” so it is problematic that they are difficult to access for many SNAP beneficiaries. There is little public transportation outside of cities, making it even more difficult to access services for rural Kentuckians already facing economic insecurity and who are eligible for inadequate transportation reimbursements of just $25 a month.20 This lack of access is demonstrated in the map below.

In 75 counties (out of 112 counties with time limits currently in place), SNAP participants do not have a KCC in their county that offers E&T services.21 A SNAP participant can arrange to meet with a KCC staff member outside of a KCC, but these special arrangements are unlikely to provide the kind of robust assistance needed to address the need for services, especially as created by the time limits. (See appendix for information by county about KCC locations, E&T partner organizations, Labor Surplus Areas, number of adults subject to the time limit and the number of adults disenrolled due to the time limit.)

Not enough focus on skills

Training programs are far from equal. Some programs simply put participants to work doing job searches for low-wage employment or through workfare (unpaid work experience), while other programs provide the opportunity to gain skills and credentials that could lead to long-term employment at a decent job. Unfortunately Kentucky’s E&T program takes too much of a “work first” approach by emphasizing moving E&T participants into any type of employment rather than prioritizing education and training that can lead to a job with adequate wages and benefits.

A U.S. Census Bureau study found when former recipients of cash assistance subject to work requirements became employed, their ability “to advance out of entry-level, low wage employment has been quite limited,” even after years in the labor market.22 The only such programs that had some positive outcomes (those in Portland, Oregon and Riverside, California) were those that provided more intensive training and supports than merely requiring them to search for work or find a job; these programs also encouraged participants to hold out for higher quality work rather than simply taking the first position available even if it paid poorly.23

The design of Kentucky’s SNAP E&T program may frequently steer Kentuckians into low-wage jobs rather than support upward mobility through high-quality, skills-focused training. As noted previously, activities such as job search and workfare don’t typically lead to upward mobility, while educational programs can where jobs are available. In a USDA focus group with E&T participants, most reported being enrolled in independent job search and/or job search training, which they viewed as either ineffective or limited in capacity to help with obtaining the experience, skills, certificates or education needed to find work and achieve financial security: “For instance, focus group participants commonly reported that their E&T providers assisted clients in learning basic computer skills needed to find and apply for work online but generally did not offer software training or typing classes that would help them qualify or compete for administrative work.”24

Right now, Kentucky’s SNAP E&T program puts too much emphasis on workfare, which is not a skills-focused option.25 Based on the information in Kentucky’s SNAP E&T plan for 2018, just 35 percent ($98,800) of total E&T funds each month were anticipated to be spent on education (basic and vocational), while 54 percent ($152,750) would be spent on workfare and other work experience.26 Another 11 percent ($30,350) was slated for employment readiness training.

Though the training programs vary considerably, few of the E&T partners offer a high-quality credential that will result in much economic mobility:

  • Community college programs likely have some of the best employment outcomes, but few subject to the work requirement have access to such programs.
  • Goodwill Industries of Kentucky focuses on job readiness and placement, although they do attempt to take job quality into account with placement.27
  • And Brighton Center offers three strong career programs — in medical assisting, business and computer technologies, and health technology administration — that provide the opportunity to earn credentials and have good outcomes for participants. However, Brighton Center is still working on raising funds that will qualify for the 50/50 match; no E&T participants have yet participated in these programs.28

Inadequate supports

Participant supports are crucial to success in SNAP E&T programs. In the national USDA survey of E&T participants, 75 percent of respondents indicated that support services were very important to them, but only a small number reported having received those services.29

Kentucky’s E&T program provides very few supports. Participants receive a maximum of just $25 a month through the KCCs for transportation while they are in E&T. Furthermore, 50/50 E&T providers should be able to be reimbursed if they offer certain other supports such as the provision of work uniforms and high school equivalency (i.e., GED diploma) testing fees, but several E&T partners described a lack of clear communication from the state about how to make that happen.30 For SNAP participants with dependents (who are not subject to the time limits), the Child Care Assistance Program is another available support through the state; however, reimbursement rates are so low many providers do not accept the subsidy.31

Meanwhile, the supports being piloted in the Paths 2 Promise program in the eight Promise Zone counties have a lot of potential and show what is possible when supports are a significant priority. Coordinated team-based case management is provided by the Department for Community Based Services (DCBS), KCCs, Kentucky Skills U and the Kentucky Community and Technical College System. Supplemental wrap-around support services are also provided, including reimbursements for transportation (including up to $1,500 in vehicle repairs), child care, and mental health and addiction recovery counseling.32 While the approach being piloted is promising, it will still be difficult for some Kentuckians facing structural barriers to economic mobility to overcome them.

Loss of benefits will make meaningful employment (and overall well-being) harder

Taking away SNAP benefits from Kentuckians who face numerous barriers to jobs providing adequate wages will only make it harder to find good, steady work. Adequate nutrition plays a critical role in productivity, not to mention overall health and well-being.33

Modest Program Improvements Expected in 2019

Several changes to Kentucky’s SNAP E&T program are underway for 2019 that will hopefully lead to some increased participation and better employment outcomes for low-income Kentuckians. However, the proposed changes are not adequate to stem the tide of Kentuckians losing food assistance.

One important aspect of the plan for 2019 is an expansion of the program to SNAP recipients who are not subject to the time limit.34 Ideally this will enable greater participation, and with increased enrollment, additional partners may be recruited, thus also benefitting those subject to the time limit. A new online case management system called KEE SUITE is expected to facilitate better communication in 2019 among SNAP recipients, DCBS, KCCs and E&T 50/50 partner organizations.35 DCBS hopes that this system will enable SNAP beneficiaries and KCC case managers to better understand which programs are available and for E&T partners to get “reverse referrals.”36 Part of the robustness of Washington State’s SNAP E&T program — which is consistently cited by Kentucky DCBS as a model program — is due to reverse referrals; these occur when individuals participating, or interested in participating, in an education or training program are determined by a SNAP E&T partner to be a SNAP beneficiary — and therefore eligible for SNAP E&T. Reverse referrals connect the E&T program with SNAP participants who are already taking steps to gain education and skills.

In the long term, DCBS is interested in implementing a team-based management system like what is reportedly working well in the Paths 2 Promise program in eastern Kentucky — and this possibility is noted in the 2019 state SNAP E&T plan.37 The team would include DCBS, KCC staff, Kentucky Skills U and the community college system in order to best serve SNAP E&T participants.

Unfortunately, significant expansion of the number of 50/50 partners is not expected in 2019.38 However, several organizations listed as partners in 2018 that did not actually provide E&T services will be working to do so in 2019 (although one program does not plan to participate at all in 2019). The state E&T plan for 2019 also describes plans to consider proposals from for-profit entities and employers to provide training through E&T, which while providing additional needed partners could be an area for concern in terms of training and job quality.

Additionally, the share of total E&T funds the state anticipates to spend in 2019 on different types of training activities is still heavily weighted toward non-education activities. In fact, funds for education programs make up just 17 percent of anticipated E&T investments in training in 2019 — compared to 35 percent in 2018.39

Kentucky’s E&T Program Needs to Be More Skills-Focused with Robust Supports as Part of Broader Approach to Poverty Reduction

While SNAP E&T alone cannot address the many barriers to economic security faced by nondisabled adults without dependents, the program can make important contributions to broader anti-poverty efforts if changes are made. In addition to time limit waivers being reinstated and barriers to training opportunities being addressed, Kentucky’s E&T program needs to place more of an emphasis on high-quality training for good jobs across the state (which involves strengthening relationships with partners) and ensuring adequate participant supports are provided.

Reinstate time limit waivers

To fulfill the state E&T program’s potential, it is essential that waivers from time limits be reinstated across the commonwealth wherever it is possible. The threat of losing assistance due to time limits, especially given the economic challenges remaining in most Kentucky counties, is harmful and counterproductive.

Ensure access to education and training

The state’s SNAP E&T program needs to fully investigate barriers to participation such as the difficulty some face in getting to a KCC that offers these services and the limited number of 50/50 partners available. Expanding 50/50 E&T providers — such as to additional community colleges as described above — could help to increase access. Enabling participant intake for E&T programs to occur at locations outside of KCC may be another option; in Washington State’s E&T program, this empowerment of community colleges and community based organizations helps encourage program participation. Kentucky’s SNAP E&T program also needs to strengthen communications with current and potential 50/50 partners so that organizations can design training opportunities that meet the requirements of the program.

Focus on high-quality training

Kentucky’s SNAP E&T program should do more to provide high-quality training — what the National Skills Coalition considers to be a “skills-focused” program that can help low-income individuals advance beyond low-wage jobs.40

The National Skills Coalition has identified best practices for state SNAP E&T programs:41

  • Skill building is an integral part of the program’s vision.
  • A “third-party partnership model” is used to support skill-building; community colleges, community-based organizations, and others provide training services with non-federal funds, the costs of which are partially reimbursed using federal 50/50 funds.
  • Participant reimbursements are used to provide support services like transportation, books and supplies and child care.
  • Participation in SNAP E&T is voluntary and not required in order for SNAP participants to maintain eligibility for SNAP benefits.
  • Skill-building activities are accessible to SNAP participants in multiple parts of the state.

At the federal level, the National Skills Coalition has also commented against prematurely ‘pushing’ people into the labor market (and by extension, off public assistance) by restricting the use of SNAP time limit waivers.42 They recommend instead expanding support to states for policies “that ‘pull’ people into the labor market who are ready to participate.”

As described in a USDA report on best practices for SNAP E&T programs, states that emphasize high-quality training in their SNAP E&T programs, such as participation in postsecondary education programs, have a better likelihood of improving long-term employment and earnings for participants. In contrast, states that require participation in E&T and prioritize less robust training activities such as job search are less likely to have SNAP participants meaningfully improve their economic situations.43 While Kentucky’s E&T program is considered to be “voluntary” and does utilize the third-party partnership model, it has a long way to go to be a skills-focused program.

Washington State is an example of a state that has effectively leveraged SNAP E&T funds to provide high-quality training to a large number of voluntary participants.44 The program involves all of the state’s community and technical colleges as well as nearly 50 community-based organizations. High-quality vocational education is by far the most common SNAP E&T activity. Employment and wage outcomes for the program are promising; more than 60 percent of former participants are employed 2 and 4 quarters after leaving the program and the average wage continues to rise after completing services.45 It is important context that Washington State has continued to waive qualifying areas from SNAP time limits.

In order to increase the quality of training offered through Kentucky’s SNAP E&T program, the state needs to follow the example of Washington State by prioritizing high-quality vocational training rather than workfare. Opportunities for postsecondary education need to be expanded to additional community college campuses. Given the low rates of participation at the two Kentucky campuses currently participating, however, this would need to occur alongside other recommendations for the program including addressing barriers to participation. Adult education should also be fully available as an E&T activity; Kentucky Skills U recently completed two pilot adult education-focused E&T programs but does not currently have a contract to be a SNAP E&T provider.46

The state should also ensure any training provided by for-profit entities and employers is high-quality and that participating employers meet high-road standards such as no wage and hour violations, low rates of turnover and competitive pay and benefits (including paid sick leave and fair scheduling practices).47

Provide more robust supports

Kentucky’s SNAP E&T program also needs to make supports more robust and improve utilization by partners. The transportation benefit of $25 a month is too low. In addition, since some SNAP E&T partner organizations have expressed confusion regarding what qualifies for reimbursement and how to apply for these funds, the state should improve these communications with partners. And community colleges need support to expand student services to address student non-academic needs, especially those institutions participating in the E&T program.48

Washington State’s E&T program serves as a good model of 50/50 community-based organizations providing wrap-around services. This may be difficult to fully duplicate in Kentucky due to a low number of well-funded community-based organizations that could serve in this capacity; however, we should look to how Washington State’s community colleges successfully connect students to supports, including by working with other state or local agencies.

Make broader state policy changes

While access to E&T services and the quality of training provided are critical to improve outcomes for SNAP recipients, it is also important to acknowledge the limits of even high-quality training through SNAP E&T given the state’s job quality and labor market challenges.49

As Kentucky looks to SNAP E&T as an opportunity to develop our workforce and to equip Kentuckians with the tools they need to succeed, not only does SNAP E&T itself need improvement, but the state must take steps toward improved job quality. Efforts to provide education and training need to be accompanied by policies that increase wages, improve college affordability, support students with low incomes and increase access to felony expungement.50


Reinstating SNAP time limit waivers across the state and making improvements to the E&T program would do much to encourage economic security for Kentuckians with low incomes. Reducing barriers to SNAP means fewer Kentuckians go hungry, which can lead to better health — in addition to the economic benefits to the state from SNAP dollars circulating in local economies. And a SNAP E&T program with improved access, training quality and supports could go a long way toward increasing opportunities for state workforce development and economic mobility for Kentuckians receiving SNAP.

This report is a publication of the Kentucky Center for Economic Policy (KCEP), with support from the Working Poor Families Project. KCEP is a non-profit, non-partisan initiative that conducts research, analysis and education on important policy issues facing the Commonwealth. Launched in 2011, the Center is a project of the Mountain Association for Community Economic Development (MACED).


Appendix (click links for PDFs)

County-by-county look at SNAP E&T in Kentucky, including Labor Surplus Area status, closest Kentucky Career Center (KCC) location, whether there is a KCC in the county, whether there is a SNAP E&T 50/50 partner in the county, the number of adults subject to the time limit and the number of adults disenrolled from SNAP in 2018 due to the time limit.

E&T notices sent to those subject to work requirements:

  1. Dustin Pugel and Jason Dunn, ““Reinstated SNAP Time Limit Has Led to Thousands Without Food Assistance,” https://kypolicy.org/reinstated-snap-time-limit-has-led-to-thousands-without-food-assistance/.
  2. Pugel and Dunn, “Reinstated SNAP Time Limit Has Led to Thousands Without Food Assistance.”
  3. During the Great Recession and subsequent slow recovery, the 3-month time limit was waived across the entire country, including in all 120 counties in Kentucky. The state began to expire waivers in 2016, first in 8 and then a total of 20 counties by the end of 2017.
  4. Center on Budget and Policy Priorities, “Kentucky Supplemental Nutrition Assistance Program,” Dec. 3, 2018, https://www.cbpp.org/sites/default/files/atoms/files/snap_factsheet_kentucky.pdf.
  5. Kentucky Center for Economic Policy analysis of Cabinet for Health and Family Services data, January 2018.
  6. Ed Bolen, “Waivers Add Key State Flexibility to SNAP’s Three-Month Time Limit,” Center on Budget and Policy Priorities, Feb. 6, 2018, https://www.cbpp.org/research/food-assistance/waivers-add-key-state-flexibility-to-snaps-three-month-time-limit#_ftn18.
  7. Research on best practices for SNAP E&T programs indicates voluntary programs are preferable because participants get more out of training when they are genuinely interested. However, the tension between an officially voluntary program and its potentially compulsory nature in practice is demonstrated in responses to the USDA national survey of SNAP E&T participants. Respondents were asked if they were participating in the program because it was required to keep benefits (considered by the study to be mandatory) or if they volunteered to participate in SNAP E&T (considered by the study to be voluntary). The USDA report indicates there were “substantial differences between how SNAP E&T participants self-identified their participation and how the State defined participation in their program (mandatory or voluntary).” United States Department of Agriculture, “SNAP Employment and Training (E&T) Characteristics Study: Final Report,” October 2017, https://fns-prod.azureedge.net/sites/default/files/ops/SNAPEandTCharacteristics.pdf.
  8. United States Department of Agriculture, “SNAP E&T Operations Handbook,” January 2018, https://fns-prod.azureedge.net/sites/default/files/snap/S2S-Operations-Handbook.pdf.
  9. Nathan Joo and Elaine Waxman, “How Kentucky’s Economic Realities Pose a Challenge for Work Requirements,” Urban Institute, Aug. 9, 2018, https://www.urban.org/urban-wire/how-kentuckys-economic-realities-pose-challenge-work-requirements.
  10. Employment and Training Administration, “Labor Surplus Area Classification,” Federal Register, Oct. 2, 2017, https://www.federalregister.gov/documents/2017/10/02/2017-20977/labor-surplus-area-classification.
  11. The criteria to be deemed an Labor Surplus Area is an average annual unemployment rate during the previous two calendar years of 20 percent or more above the average annual civilian unemployment rate for all states during a 24-month period. Federal Register, “Labor Surplus Area Classification,” Oct. 2, 2017, https://www.federalregister.gov/documents/2017/10/02/2017-20977/labor-surplus-area-classification. For Fiscal Year 2019, two counties are no longer Labor Surplus Areas (LSAs) but six more are LSAs in 2019, which were not in 2018 – for a net change of four more LSAs. Ashley Spalding, “Growing Number of Kentucky Counties Have More Available Workers Than Jobs,” Kentucky Center for Economic Policy, Oct. 2, 2018, https://kypolicy.org/growing-number-of-kentucky-counties-have-more-available-workers-than-jobs/.
  12. United States Department of Agriculture, “SNAP Employment and Training (E&T) Characteristics Study.”
  13. 50/50 SNAP E&T partners, personal communication.
  14. While Goodwill Industries of Kentucky and the community colleges reported fewer than expected SNAP E&T referrals to their programs, other organizations described barriers that prevented them from serving any participants in 2018. Kentucky Alliance for Boys and Girls Club initially experienced difficultly coming to an agreement with the Department for Community Based Services (DCBS) as to who they would serve, and some other logistics are still being worked out, given the organization serves youth rather than adults. Employment Solutions had problems working out a curriculum with DCBS that would meet the requirements of SNAP E&T. And Brighton Center has three training programs with impressive outcomes for participants, but they don’t currently have funding sources that qualify for a match (although they are in the process of attempting to raise private funds for this purpose). On the other hand, close to the end of the 2018 federal fiscal year Kentucky Skills U was still in the very early stages of its two pilot programs.
  15. Kentucky Center for Economic Policy analysis of data from the Kentucky Cabinet for Health and Family Services, Kentucky SNAP E&T 50/50 partners and the U.S. Department of Labor. In addition to the 14 counties that had no 50/50 partners serving the county, an additional 2 had partners whose programs were not in effect in 2018.
  16. The Office of Employment & Training at the Education and Workforce Development Cabinet was contacted but did not provide this information.
  17. Kentucky Department for Community Based Services, Division of Family Support, “Notice from the Cabinet for Health and Family Services.” See appendix for actual notices.
  18. These are Kentuckians receiving SNAP, ages 18-49, who do not receive Supplemental Security Income (SSI), did not report a disability and reported no “own children” in the household. KCEP analysis of 2017 1-Year Sample, American Community Survey data for Kentucky.
  19. Daniel Desrochers, “State Pulling Workers Out of 31 Unemployment Offices Amid Major Cuts,” Jan. 10, 2017, Lexington Herald-Leader, https://www.kentucky.com/news/politics-government/article125733614.html.
  20. The most common barrier to accessing an E&T program identified by the USDA survey was transportation. United States Department of Agriculture, “SNAP Employment and Training (E&T) Characteristics Study.”
  21. Kentucky Center for Economic Policy analysis. Kentucky Career Center, “Office Locations,” https://kcc.ky.gov/Pages/Locations.aspx.
  22. Fredrik Anderson, Harry Holzer and Julia Lane, “Worker Advancement in the Low-Wage Labor Market: The Importance of Good Jobs,” U.S. Census Bureau, July 2003, ftp://ftp.census.gov/ces/tp/tp-2003-08.pdf.
  23. LaDonna Pavetti, “Work Requirements Don’t Cut Poverty, Evidence Shows,” Center on Budget and Policy Priorities, June 7, 2016, https://www.cbpp.org/research/poverty-and-inequality/work-requirements-dont-cut-poverty-evidence-shows
  24. United States Department of Agriculture, “SNAP Employment and Training (E&T) Characteristics Study.”
  25. Seattle Jobs Initiative, “SNAP E&T Advocates Guide,” November 2017, http://www.seattlejobsinitiative.com//www/wp-content/uploads/SNAP-ET-Advocates-Guide-and-Messaging-Tool.pdf.
  26. Kentucky Department for Community Based Services, “Kentucky SNAP Employment and Training Plan Federal Fiscal Year 2018,” Aug. 15, 2017.
  27. Goodwill Industries of Kentucky, personal communication.
  28. Brighton Center, personal communication.
  29. United States Department of Agriculture, “SNAP Employment and Training (E&T) Characteristics Study.”
  30. Kentucky SNAP E&T partner organizations, personal communication.
  31. Steve Magre, “Upgrading the Kentucky Child Care Program Would Pay Off for the State,” Courier-Journal, Dec. 22, 2017, https://www.courier-journal.com/story/opinion/contributors/2017/12/22/opinion-upgrading-kentucky-child-care-program-would-pay-off-state/964253001/.
  32. Joe Asher, “Paths to Promise: Program Available to Those Who Quality,” Harlan Daily Enterprise, June 1, 2018, https://www.harlandaily.com/2018/06/01/paths-to-promise-program-available-to-those-who-qualify/. United States Department of Agriculture, “Evaluation of SNAP Employment and Training Pilots: Fiscal Year 2017 Annual Report to Congress,” https://fns-prod.azureedge.net/sites/default/files/snap/SNAP-E-and-T-Report-Congress-FY2017.pdf.
  33. Steven Carlson and Brynne Keith-Jennings, “SNAP Is Linked with Improved Nutritional Outcomes and Lower Health Care Costs,” Center on Budget and Policy Priorities, Jan. 17, 2018, https://www.cbpp.org/research/food-assistance/snap-is-linked-with-improved-nutritional-outcomes-and-lower-health-care.
  34. Kentucky Department for Community Based Services, personal communication.
  35. The interface used by KCC case managers, E&T 50/50 partners and other staff is called “Business Connect.” The interface SNAP recipients use is called “Citizen Connect.”
  36. Kentucky Department for Community Based Services, “Kentucky SNAP Employment and Training Plan Federal Fiscal Year 2018.”
  37. Department for Community Based Services, personal communication.
  38. Kentucky Department for Community Based Services, “Kentucky SNAP Employment and Training Plan Federal Fiscal Year 2019.”
  39. Kentucky Center for Economic Policy analysis of Kentucky’s 2019 state SNAP E&T plan.
  40. Brooke DeRenzis, “Skills-Based SNAP Employment and Training Policy Toolkit,” National Skills Coalition, October 2016, https://www.nationalskillscoalition.org/resources/publications/file/SNAP-ET-Policy-Toolkit.pdf.
  41. DeRenzis, “Skills-Based SNAP Employment and Training Policy Toolkit.”
  42. National Skills Coalition, “Comments on Supplemental Nutrition Assistance Program: Requirements and Services for Able-Bodied Adults Without Dependents,” April 2018, https://www.nationalskillscoalition.org/documents/National-Skills-Coalition-comments-on-RIN-0584-AE57.pdf.
  43. United States Department of Agriculture, “SNAP Employment and Training (E&T) Best Practices Study: Final Report,” Nov. 22, 2016, https://www.fns.usda.gov/snap/snap-employment-and-training-et-best-practices-study-final-report.
  44. Kentucky Department for Community Based Services, “Kentucky SNAP Employment and Training Plan Federal Fiscal Year 2018,” Aug. 15, 2017.
  45. Washington State Department of Social and Health Services, “Expansion of the Basic Food Employment and Training Program (BFET),” Report to the Legislature, November 2017, https://app.leg.wa.gov/ReportsToTheLegislature/Home/GetPDF?fileName=Legislature%20Report_2017%20BFET%20Expansion_b2f117b8-f29f-4d25-8ab2-2387d00db455.pdf.
  46. Kentucky Skills U, personal communication.
  47. Ashley Spalding, “Workforce Development in Kentucky Should Encourage High-Road Jobs,” Feb. 12, 2018, https://kypolicy.org/workforce-development-kentucky-encourage-high-road-jobs/.
  48. Leslie Helmcamp, “Strengthening Student Success with Non-Academic Supports: The Role of State Policy,” Working Poor Families Project, Spring 2015, http://www.workingpoorfamilies.org//www/wp-content/uploads/2015/06/WPFP-Spring-2015-Brief.pdf.
  49. Jason Bailey, “State of Working Kentucky 2018,” Kentucky Center for Economic Policy, Aug. 28, 2018, https://kypolicy.org/the-state-of-working-kentucky-2018/.
  50. Kentucky Center for Economic Policy, “An Economic Agenda for a Thriving Commonwealth,” Aug. 22, 2018, https://kypolicy.org/economic-agenda/. Helmcamp, “Strengthening Student Success with Non-Academic Supports.”