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July 28 -- The Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) invites the public to comment by September 27, 2021 on its proposed information collection regarding Assessing Supplemental Nutrition Assistance Program (SNAP) Participants' Fitness for Work.
 
This is a new collection for: (1) Documenting the policies and guidelines used for making fitness for work determinations by all 53 State Agencies, which include the States, the District of Columbia, the U.S. Virgin Islands, and Guam; (2) describing the process State Agencies use for making fitness for work determinations; (3) determining any general patterns and trends in fitness for work and good cause determinations within and across four case study States; and (4) determining how closely caseworkers follow the States' fitness for work and good cause determination policies and requirements and the challenges they face in applying the policy in four case study States.

The Food and Nutrition Act of 2008 requires that Supplemental Nutritional Assistance Program (SNAP) participants between the ages 16 and 59 to meet certain work requirements, unless they are exempt or show good cause as to why they cannot work. Whether a participant is required to meet these work requirements is based upon a SNAP eligibility worker (caseworker) making a determination whether an individual is exempt from these work requirements, including a determination whether the individual is physically or mentally unfit for work. The U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) offers general guidance and States develop their own policies and procedures with little input from FNS. States are given a great degree of latitude in making determinations regarding unfitness for work exemptions.   

FNS has contracted with MEF Associates and its subcontractor, Mathematica, to conduct a study to better understand how States determine whether individuals are exempted from work requirements or have good cause for not meeting work requirements due to a physical or mental limitation. By surveying all 53 State SNAP Agencies, which include the States, the District of Columbia, the U.S. Virgin Islands, and Guam, and conducting in-depth case studies of four States, this study will provide FNS with valuable insights into how States develop and implement policies and procedures for making fitness for work determinations. This information can help FNS assess States' needs for technical assistance around fitness for work issues and identify lessons learned to share across all State SNAP Agencies.  

Survey: After survey recruitment, FNS anticipates 100 percent participation from the State government Agencies. We will reach out to 53 State or territory SNAP directors to complete a survey and anticipate that all these SNAP directors will agree to participate in the survey. Each SNAP director may designate up to three staff to complete sections of the survey, accounting for an additional 159 State or territory staff participating as respondents (212 survey respondents total). This is the highest possible number of survey respondents; FNS expects fewer to participate in the survey.

Case Studies: FNS will reach out to a maximum of six States Agencies to participate in in-depth case studies and expects four to participate. The case studies will involve semi-structured interviews with program administrators and staff of State SNAP agencies, local offices, and businesses or other agencies that provide SNAP E&T services. After recruiting the four state SNAP agencies, FNS expects two selected local SNAP agencies and two local SNAP E&T providers to participate in each State. The case studies will also include observations of staff-participant interactions during eligibility interviews. The eligibility interviews that will be observed will not be recorded and no personally identifiable information will be recorded during the observations. FNS expects that approximately 25 percent of individuals/households invited to participate will choose not to participate and oversampled to account for nonresponse.

Respondent groups identified for the survey and case studies include the following:

State Agency SNAP Directors (53 survey respondents, 0 survey nonrespondents, 4 case study recruitment respondents, 2 case study recruitment nonrespondents, 4 case study interview respondents, and 0 case study nonrespondents).
State Agency SNAP policy staff (159 survey respondents, 24 case study interview respondents, and 0 survey or case study nonrespondents).
Local SNAP office administrator (8 case study respondents and 0 case study nonrespondents).
Local SNAP office supervisor (8 case study respondents and 0 case study nonrespondents).
Local SNAP office frontline staff (64 case study interview respondents and 0 case study interview nonrespondents, 8 case study one-on-one observation participants, 0 case study observation nonparticipants).
Business—SNAP E&T provider administrators from business or other for profit agencies (4 case study interview respondents and 0 case study interview nonrespondents).
Business—SNAP E&T provider supervisors from business or other for profit agencies (4 case study interview respondents and 0 case study interview nonrespondents).
Business—SNAP E&T provider frontline staff from business or other for profit agencies (32 case study interview respondents and 0 case study interview nonrespondents).
Business—SNAP E&T provider administrators from not for profit agencies (4 case study interview respondents and 0 case study interview nonrespondents).
Business—SNAP E&T provider supervisors from not for profit agencies (4 case study interview respondents and 0 case study interview nonrespondents).
Business—SNAP E&T provider frontline staff from not for profit agencies (32 case study interview respondents and 0 case study interview nonrespondents).
Individual/household—SNAP applicants (24 case study one-on-one observation participants, 6 case study one-on-one observation nonrespondents).
 
FR notice inviting public comment, with instructions: https://www.federalregister.gov/documents/2021/07/28/2021-15912/agency-information-collection-activities-assessing-supplemental-nutrition-assistance-program-snap
Draft information collection instruments: https://www.dropbox.com/sh/0tw3dxab8fl5vop/AACJWK4-ovmd9BXF8xGSOcPza?dl=0

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