Maintaining SNAP Benefits and Recertification

Employment & Training (E&T)

SNAP has an employment and training component. Unless they are exempt, adults must participate in some type of work or training activity to receive SNAP. However, there are many people who are exempt and have no further obligation to participate in work activities. A SNAP participant is exempt if they are:

  • under age 16 or age 60 and over
  • age 16 or 17 and not the head of the household
  • attending high school, training, or college on at least a half-time basis (Note: College students between the ages of 18 and 49 must meet the student eligibility criteria listed—see the Eligibility Rules section.)
  • working at least 30 hours/week or earning weekly pay of at least 30 times the hourly federal minimum wage
  • a migrant or seasonal farm worker under contract to begin work within the next 30 days
  • meeting TANF work requirements
  • receiving unemployment benefits
  • participating in a drug or alcohol treatment program
  • taking care of a child under six or an incapacitated person (can apply to multiple adults in a household if there are multiple children and different adult caretakers for each child)
  • jointly applying for SNAP and SSI and awaiting an SSI eligibility determination
  • physically or mentally unable to work (less documentation is required than for being disabled—generally doctor’s or other health care provider certification is sufficient)

E&T Requirements for Non-Exempt SNAP Recipients

Non-exempt SNAP recipients must comply with the SNAP office’s work requirements. This usually involves:

  • attending an evaluation appointment at the SNAP office’s employment office,
  • providing information about education and work history, and then
  • participating in an assigned work program. Work programs typically include:
    • work experience program (WEP),
    • supervised job search, 
    • “job clubs,” 
    • GED programs, and, occasionally,
    • training or other educational activities. 

Complying with Work Requirements

Individuals who must comply with work requirements cannot be required by their SNAP office to spend more than 120 hours per month participating in employment and training activities. This includes:

  • financial literacy or personal finance instruction, including career advice, credit counseling, using savings/checking accounts, cash management techniques
  • supervised job search
  • job skills training and educational work activities directly related to employment and training
  • job readiness classes
  • paid work
  • Subsidized employment and apprenticeships (including: internships, customized training, transitional jobs, on the job training as defined under WIOA)
  • vocational education
  • WEP
  • any work the individual is doing for something other than money (such as free housing or meals)

If a participant fails to comply with work requirements, voluntarily quits a job without good cause, or fails to meet cash assistance work requirements, they can be sanctioned, or made ineligible to participate for a period of time. The sanction disqualifies only the individual, not the whole household.

If other people in the household are still eligible, the SNAP case will stay open and the sanctioned person should request to be restored to the case at the end of the sanction period. If there are no other eligible participating household members, the sanctioned person will have to reapply for benefits the month before the sanction ends to receive SNAP benefits again.

Read more about Complying with a WEP Assignment.

Note: If the SNAP office does not assign a work activity, the participant is still eligible to receive SNAP.

E&T Requirements for SNAP Offices

SNAP offices are required to:

  1. Coordinate their SNAP E&T components and services with available community resources, including job training and related employment services available through the local Workforce Innovation and Opportunity Act (WIOA) partners.
  2. Coordinate with NYS Career Center System partners to align and improve access to local employment, training and supportive services, thus ensuring SNAP recipients benefit from the Career Center System’s full array of services.
  3. Inform SNAP applicants and recipients about their work requirements and available employment and training services.
  4. Provide case management services to qualified SNAP recipients.
  5. Determine if an individual is a good fit for an E&T component. This is called a provider determination.
  6. Determine if a participant has good cause for failure to comply with a mandatory E&T requirement.

Requirements 3 – 6 are discussed in detail below.

Informing SNAP Applicants and Recipients About Their Work Requirements

If a household being approved or recertified for SNAP includes members subject to work requirements, that household must be provided with a written notice and oral explanation describing the work requirements those individuals must follow.

The written notice must contain all pertinent information relating to each applicable work requirement, including:

  • An explanation;
  • Which individuals are subject to which requirements;
  • A listing of exemptions;
  • An explanation of the process to request an exemption (including contact information for the local SNAP office);
  • Rights and responsibilities;
  • How to comply and maintain SNAP benefits;
  • Dates by which each individual must take actions to remain in compliance;
  • Consequences for failure to comply; and
  • Explanation of the process for requesting good cause, including a list of examples of good cause circumstances (including contact information for the local SNAP office).

If an individual is a mandatory E&T participant, the written notice must explain:

  • The individual’s right to receive reimbursement for allowable expenses related to participation in E&T; and
  • The SNAP office’s responsibility to excuse a participant from mandatory SNAP E&T participation if the allowable expenses exceed what the office can reimburse.

To view these notices see LDSS-5193 and LDSS-5193A.

Advising Households of Available Employment and Training Services

At recertification, SNAP offices must advise adult SNAP recipients in households without elderly or disabled members and with no earned income of the availability of employment and training services within the district or region. This is not limited to SNAP E&T and should include E&T opportunities provided by:

  • Local career centers
  • Community-based organizations
  • Local education providers

To meet this rule, SNAP offices must, at minimum, provide a list of available employment and training services electronically (on a website or in an email) or in printed form.

Examples of printed materials include but are not limited to:

  • Flyer explaining local career center offerings
  • Brochures on adult education and training resources
  • Contact information for local community organizations that provide employment and training services.

Mandatory Case Management

Due to a new provision, SNAP recipients placed into a mandatory E&T assignment must receive case management services and be assigned to at least one E&T work activity component.

The purpose of case management services is to:

  • Guide participants toward appropriate E&T components and activities based on the participant’s needs and interests,
  • Support the participant in the E&T program, and
  • Provide activities and resources that help the participant achieve program goals.

Case management services include:

  • Completion of an employability assessment,
  • Development of an employment plan,
  • Monitoring the progress of the individual in the assigned SNAP E&T activity component, and
  • Coordination with service providers.

SNAP offices have flexibility to provide case management services in the way that best meets the needs of the participant and the capacity of the district or provider. This includes:

  • Offering case management services remotely,
  • Delivering services through virtual tools like web applications, and
  • In-person services.

Note: Under this regulation, SNAP offices must pay for or reimburse SNAP participants for expenses that are necessary, reasonable, and directly related to participation in the E&T program. If a SNAP office is unable to provide a participant with reimbursements, then the individual is excused from mandatory participation in the SNAP E&T and would not be subject to a SNAP sanction for failure to comply with the assigned SNAP E&T activity.

Good Cause for Failure to Participate When There Is No Appropriate/Available Opening in SNAP E&T

In situations when there is not an appropriate and/or available opening for a mandatory E&T participant in the district’s E&T program, the SNAP office must determine that the participant has good cause for failure to comply with the mandatory E&T requirement.

Good cause for a lack of an appropriate or available opening in an E&T program ends when the SNAP office identifies an appropriate and available opening and informs the participant.

Provider Determinations and Referral Process

Local SNAP E&T providers are responsible for determining if an individual is a good fit for a particular E&T component; this is called a provider determination.

SNAP E&T providers have flexibility to set the criteria used to make a provider determination and may use any information available to make the determination. The processes below apply to both mandatory and voluntary E&T participants:

Before making a referral to an E&T provider, the SNAP office must:

  • Work with the provider to understand the skills and qualifications needed for E&T participants to be successful, and
  • Thoroughly screen individuals prior to referral, to help ensure a good fit with the E&T component.

If a SNAP E&T provider finds someone is not a good fit they must:

  • Notify the SNAP office within 10 days of making the determination,
  • Give the reason for the determination, and
  • Include input on the appropriate next step.

If a SNAP office receives a provider determination they must:

  • Notify the named E&T participant within 10 days of receiving the determination, either verbally or in writing. The notice must include:
    • An explanation of what a “provider determination” is,
    • The next steps the district will take as a result of the determination, and
    • Contact information for the SNAP office.
  • The participant must be notified that they are not being sanctioned as a result of the provider determination.

SNAP offices must document the provider determination and the notification in the individual’s case record and take the most suitable action from the two choices below by the participant’s next recertification:

1. Refer the individual to an appropriate E&T program component:

a. Perform an assessment to determine an appropriate E&T program component;

b. Provide case management services along with at least one E&T work activity component.

2. Re-assess the participant’s physical and mental fitness:

a. Perform a reassessment and screen for any other exemptions from the work requirement;

b. If determined to be mentally or physically unfit, the participant must be found exempt from the work requirement;

c. If determined to be physically and mentally fit and not otherwise exempt from the general work requirements, the SNAP office must follow the process described above.

Complying with a WEP Assignment

Reference Documents

If an individual is currently volunteering at a public or non-profit organization, including faith-based organizations, public schools, food pantries, and local churches, those activities may count as a qualified work activity under this provision.

To calculate the number of hours that an individual would be required to complete each month, divide the amount of the SNAP benefit by the number of adult SNAP recipients in the household. Then divide by the minimum wage that is in effect for the area of the state in which the household is located:

2023 2024
New York City $15.00 $16.00
Long Island & Westchester $15.00 $16.00
Rest of state $14.20 $15.00

Please see Labor.ny.gov for additional information.

Example: a SNAP household in Albany County consisting of two adults receives $516 in SNAP benefits each month. To determine the number of hours needed each month under a WEP assignment or an approved volunteer activity for each adult, divide the full SNAP benefit by two adults and then divide the result by the state minimum wage:

$516 ÷

2 =

$258 ÷

$14.20

= 18

SNAP Benefit

Adults

Min. wage (2023) for Albany County

Hours required for each adult (rounded)

Those volunteering who do not meet the required number of hours may use their volunteer hours as hours of work in combination with any other qualifying work activities, for a total of at least 80 hours per month.

Reference Documents

Voluntary Quit

The voluntary quit rule was instituted to prevent people from deliberately making themselves poor so they can get SNAP benefits. The rule disqualifies such people from receiving SNAP benefits for a specified length of time, called a sanction period, of one month and until the individual complies. This rule often comes into play when someone quits their job for some other reason, such as a decision to relocate, and immediately applies for SNAP.

SNAP offices frequently question the reasons for leaving a job. All the applicant has to show is that there was some valid reason, to prove good cause and satisfy the rule.

Applicants who were fired are never assumed to have left their job so that they could obtain SNAP benefits—it does not matter why they were fired. The NYS Temporary Assistance and SNAP Employment Policy Manual states that “provoked discharge” termination situations, in which employees cause themselves to be fired, are not subject to a voluntary quit disqualification.

Those without a valid reason for quitting their job may or may not be subject to a voluntary quit sanction. Many people are exempt from the voluntary quit rule. The duration of the sanction is based on the circumstances of the individual client. See the SNAP Employment and Training Desk Guide for more on the voluntary quit rules.

Work Sanctions, Intentional Program Violations

People who do not comply with work requirements, or who are found to have committed an Intentional Program Violation (IPV), will be removed from the household’s SNAP case for a period specified by the SNAP office. The duration of the sanction is based on the circumstances of the individual client.

The SNAP Employment and Training Desk Guide has a summary of SNAP employment and training rules.

Able-Bodied Adults Without Dependents (ABAWD)

ABAWD Time Limit Rule Suspended in NYS

The federal Able Bodied Adults Without Dependents (ABAWD) time limit rule places a limit on how long unemployed, non-disabled, childless adults, ages 18 to 52, are eligible to participate in SNAP. Those considered “ABAWDs” may only receive SNAP benefits for a total of three full months in the 36-month period, unless they live in a waived area, meet an exemption, or are already meeting work requirements.

FNS has approved OTDA’s request to waive the ABAWD time limit rule in all areas of the state through February 28, 2025.

The Fiscal Responsibility Act of 2023 raised the age limit for those subject to the time limit rules from 49 to 54. This change will be rolled in over time. On October 1, 2023, the age of those subject to the ABAWD time limit increased to age 52. On October 1, 2024, the age of those subject to the ABAWD time limit will increase to age 54.

SNAP recipients who are newly determined to fall under the ABAWD time limit rule will be sent a notice about this determination. Those letters are not a notice of a requirement to work or take any action. They are merely to let the SNAP recipient know that they fall under the criteria for the ABAWD time limit rules, which are currently suspended.

Learn more

Recertification and Reporting Requirements

A household is only authorized eligible for SNAP benefits for a specified, limited period of time, called the certification period. At the end of that period, the SNAP case is automatically closed unless the LDSS/case examiner authorizes a new certification period.

6-month certification period:

  • Households with income that changes frequently

12-month certification period:

  • Most households with income
  • Households with no income
  • Homebound individuals
  • Group home residents receiving SSI/SSD
  • People who are homeless

36-month certification period:

  • Elderly Simplified Application Program (ESAP) households, where all members are a senior or disabled and there is no earned income
  • NYS Combined Application Project (NYSCAP) households—SSI recipients with live-alone status who receive SNAP automatically

48-month certification period:

  • NYS Nutrition Improvement Project (NYSNIP) households (sunsets December 1, 2024)—SSI recipients with live-alone status who receive SNAP automatically

Before the end of the certification period, the household will receive a recertification packet with documents to be submitted and information on their recertification interview. If the household does not send back the updated recertification packet and complete an interview in the time frame designated, the case will close at the end of the certification period.

Telephone Recertification

During the recertification process, existing SNAP participants must complete an additional interview to determine continued eligibility. The interview can be by phone, or the participant can request to have it in person. Households should return their completed recertification application as soon as possible. The SNAP office will not make contact or go through with the scheduled interview if the household has not sent in their signed recertification form.

The interview time is included with the recertification packet, however, the SNAP office may attempt to call up to three times to try to complete the interview before the scheduled date.

In New York City, SNAP households can call 1-800-SNAPNOW to access an on-demand telephone recertification interview without needing a scheduled interview time.

If the household sends in their recertification form, but the SNAP office cannot reach them for their interview, a “notice of missed interview” will be mailed. This notice advises the household to contact the SNAP office immediately to reschedule their interview if they wish to have their recertification application processed. See Notice of Missed Interview.

Changes Between Certification Periods

Reference Documents

In addition to participating in the recertification process, SNAP households must follow detailed reporting rules.

Any failure to report required information may result in an overpayment. The SNAP office will try to recoup the overpayment from future benefits or through a claims process, which can result in the overpaid amount being taken from tax refunds.

Reporting Rules

Households with Six-Month Reporting Rules:

The only thing these households must report during the six-month period is:

  • Change in income that causes the household to be over 130% of the Federal Poverty Level. If this happens, they must report it immediately.

Households with Certification Periods Longer than Six Months:

  • Will receive a change report form to be filled out at the six-month point of their SNAP certification; the change report form is mailed at the end of the fifth month of certification;
  • Should complete the form and return it to the local SNAP office to continue receiving benefits.

These households must do the following under reporting rules:

  • Return the six-month report form;
  • Report any change in household income above 130% of poverty.

These households do not have to report any other changes in circumstances until their next SNAP recertification interview.

Households that Are 10-Day Reporters:

Some households are required to report almost all changes in household information by the tenth day of the month following the month of the change.

Ten-day reporting households include:

  • Households with unearned income where all the adults are elderly or disabled
  • Group home residents receiving SSI/SSD
  • Households with no income
  • Migrant workers
  • Homeless households
  • Households with a certification period of less than four months

These households do not have to report certain changes in between certification periods. For example, it is not necessary for elderly households to inform the SNAP office when their Social Security benefits increase each January, as long as the increase is less than $50 per month.

04-INF-25 is a helpful source of information on reporting rules.

Reference Documents

Case Reactivation Waiver

This waiver enables SNAP offices to reinstate SNAP benefits during the certification period, for households that reestablish their eligibility.

Households can accomplish that by:

  • Reporting and verifying any change in circumstances, and/or
  • Complying with an unfulfilled program requirement within 30 days of the date their SNAP case was closed.

Households that reestablish their eligibility in such a manner are not required to file a new SNAP application or to complete an eligibility interview.

A common situation where case reactivation is used: a household’s SNAP case is closed for failure to submit or complete a periodic report, but the household then provides the needed information.

How Households Can Be Reinstated Under the Case Reactivation Waiver
Affected households must do the following within 30 days of their case closing:

  • Report and verify all changes in circumstances that have occurred,
  • Provide any outstanding information that may be missing, and
  • Continue to meet SNAP eligibility rules.

Upstate Counties: households should have at least three full months remaining in their certification period following the date of fulfilling all the above requirements for reactivation.

NYC: households should have at least four full months remaining in their certification period following the date of fulfilling all the above requirements for reactivation.

These time frames are necessary due to the requirements districts must follow for generating timely recertification notices and scheduling and completing recertification interviews.

OTDA reserves the right to permit exceptions to that last requirement and permit reactivation during the last three or four months of the certification period if case circumstances merit the exception.

When the Case Reactivation Waiver Cannot Be Used
Case reactivations are not re-applications for SNAP. Therefore:

  • Consideration for expedited processing is not part of the reactivation process;
  • Households that provide missing information or comply with eligibility requirements 30 days or more after their SNAP certification end date must file a new SNAP application.

This waiver does not apply to households that have not complied with SNAP E&T activities resulting in their SNAP case closing. An individual whose SNAP case has been closed because of a SNAP E&T sanction must serve the minimum durational sanction in addition to complying with the SNAP E&T requirements as assigned by the SNAP office, unless the individual provides documentation that shows that they have become exempt from SNAP work requirements.

Reference Documents

Transitional Benefits

Reference Documents

Most households that leave TANF are now automatically eligible for transitional SNAP benefits, called the Transitional Benefits Alternative (TBA).

Households that are eligible for TBA:

  • Newly employed households
  • SNAP households with children who leave TANF or Safety Net Assistance (SNA). For more information on this policy change see 09-ADM-22.

Households that are not eligible for TBA:

  • Temporary assistance households without children who leave SNA. Note: These households may be eligible for regular SNAP benefits.
  • Households that miss their TANF/SNAP recertification interview.
  • Households that have their SNAP case closed due to a violation.

At the time the TANF case is closed, if a household is eligible for TBA, the caseworker will:

  • Authorize TBA for five months—even if a household had less than five months left in its SNAP certification period.
  • Freeze the TBA benefit at the SNAP benefit level issued prior to the TANF case closing, but the Family Assistance is no longer counted as income. There is no income “cap” for TBA; even households with gross incomes above 130% of poverty are eligible.

The household is not obligated to report any change in income, resources, or household composition during the TBA period.

Before the TBA period expires, households are sent a recertification notice to allow them to certify for ongoing SNAP benefits.

To “unfreeze” the SNAP benefits during the five-month TBA period—for example, if a household’s income dramatically decreases or a new member joins the household—the household would have to undergo early recertification.

Reference Documents