oversight

SNAP Employment and Training Pilot Projects

Published by the Department of Agriculture, Office of Inspector General on 2019-12-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

      United States Department of Agriculture




SNAP Employment and Training Pilot
Projects




Audit 27601-0004-22
December 2019
                                                OFFICE OF INSPECTOR GENERAL
SNAP Employment and Training Pilot Projects


Audit Report 27601-0004-22
OIG reviewed FNS’ controls over States’ E&T pilot projects to ensure their activities,
funds, and performance are properly monitored.



OBJECTIVE                        WHAT OIG FOUND
Our objective was to evaluate    The U.S. Department of Agriculture’s (USDA) Supplemental
FNS’ controls over States’       Nutrition Assistance Program (SNAP) is a critical safety
SNAP E&T pilot projects          net for many families and individuals in financial need.
ensuring activities, funds,      SNAP is the largest of USDA’s domestic nutrition assistance
and performance are properly     programs and is administered by the Food and Nutrition
monitored.                       Service (FNS). In accordance with the 2014 Farm Bill, FNS
                                 selected grant proposals from 10 State agencies to develop,
                                 implement, and evaluate innovative SNAP employment and
REVIEWED                         training (E&T) pilot projects intended to test and determine
We reviewed the FY 2013          the most effective ways to help SNAP recipients gain and
to FY 2017 expenditures of       retain employment—thereby reducing their need for public
the 10 States with SNAP          assistance.
E&T pilot projects, which
included a review of their       The 10 State agencies receiving E&T pilot program grants
pilot project activities from    were required to maintain the same level of funding in their
FYs 2015–2017. We visited        regular E&T programs as in fiscal year (FY) 2013 and to
the FNS national office          not replace this funding with Federal funding for the pilot
to review FNS’ internal          projects. However, the Office of Inspector General (OIG)
controls for administering,      found that 6 of the 10 States spent almost $38.7 million less
overseeing, and monitoring       on their regular programs from FYs 2015–2017 than their
the SNAP E&T pilot projects.     FY 2013 funding levels. FNS did not identify this issue
We also visited State            because it only reviewed States’ annual E&T plans—not
agencies responsible for the     the actual E&T expenditures. As a result, States may have
administration and oversight     replaced almost $27.6 million of State funds with Federal
of three non-statistically       funds.
selected SNAP E&T pilot
projects.                        FNS generally agreed with our recommendations, and we
                                 reached management decision on both recommendations.

RECOMMENDS
We recommend FNS require
States to substantiate
their reduced regular E&T
expenditures and seek
recovery of grant funds when
they are unable to do so.
                           United States Department of Agriculture
                                  Office of Inspector General
                                    Washington, D.C. 20250



DATE:          December 23, 2019

AUDIT
NUMBER:        27601-0004-22

TO:            Pamilyn Miller
               Administrator
               Food and Nutrition Service

ATTN:          Mark Porter
               Director
               Office of Internal Controls, Audits and Investigations

FROM:          Gil H. Harden
               Assistant Inspector General for Audit

SUBJECT:       SNAP Employment and Training Pilot Projects


This report presents the results of the subject review. Your written response to the official draft
is included in its entirety at the end of the report. We have incorporated excerpts from your
response, and the Office of Inspector General’s (OIG) position, into the relevant sections of the
report. Based on your written response, we are accepting management decision for both audit
recommendations in the report, and no further response to this office is necessary. Please follow
your internal agency procedures in forwarding final action correspondence to the Office of the
Chief Financial Officer (OCFO).

In accordance with Departmental Regulation 1720-1, final action needs to be taken within 1 year of
each management decision to prevent being listed in the Department’s annual Agency Financial
Report. For agencies other than the Office of the Chief Financial Officer (OCFO), please follow
your internal agency procedures in forwarding final action correspondence to OCFO.

We appreciate the courtesies and cooperation extended to us by members of your staff during our
audit fieldwork and subsequent discussions. This report contains publicly available information and
will be posted in its entirety to our website (http://www.usda.gov/oig) in the near future.
Table of Contents

Background and Objectives ................................................................................... 1
Finding 1: FNS Should Ensure Pilot Project States Maintain Funding
Efforts....................................................................................................................... 5
         Recommendation 1 ........................................................................................8
         Recommendation 2 ........................................................................................8
Scope and Methodology .......................................................................................... 9
Abbreviations ........................................................................................................ 12
Exhibit A: Summary of Monetary Results ........................................................ 13
Exhibit B: Audit Sites Visited ............................................................................. 14
Agency’s Response ................................................................................................ 15
Background and Objectives 
Background
The U.S. Department of Agriculture’s (USDA) nutrition assistance programs help provide
children and low-income Americans with access to a nutritious diet with emphasis on those
facing particular need due to unemployment, recession, disaster, age, or disability. The Food and
Nutrition Service (FNS) manages and administers these domestic nutrition assistance programs.

The Nation’s largest domestic nutrition assistance program, the Supplemental Nutrition
Assistance Program (SNAP), is a critical safety net for many families and individuals in financial
need. SNAP includes an employment and training (E&T) program to help recipients gain skills,
training, or experience that will increase their ability to obtain regular employment, with the
ultimate goal of becoming financially self-sufficient. SNAP E&T programs may assist
unemployed and underemployed participants in job searches, job skills training, education, work
experience, and provide support services like transportation and childcare to help reduce barriers
to employment and training.1

The Agricultural Act of 2014 (also known as the 2014 Farm Bill)2 authorized up to $200 million
for FNS to develop, implement, and evaluate up to 10 innovative SNAP E&T pilot projects, each
of which were to last no more than 3 years.3 As per the 2014 Farm Bill, the pilot projects should
be designed to develop and test methods for E&T programs and services to increase the
employment rate and incomes of SNAP recipients who are able to work (known as “work
registrants”), thereby reducing their need for public assistance. These pilot projects give USDA
and States the opportunity to build on existing SNAP E&T programs and test new strategies to
determine the most effective ways to help SNAP recipients gain and retain employment that
leads to self-sufficiency.

FNS developed a Request for Applications (RFA) for the SNAP E&T pilot projects based on
legislative requirements, the Secretary of Agriculture’s priorities, and consultation with other
Federal agencies involved in employment, training, and workforce development. FNS released
its RFA on August 25, 2014, and applications were due by November 24, 2014. In response,
FNS received 46 applications for SNAP E&T pilot projects from 35 States and the District of
Columbia. FNS convened an evaluation panel, consisting of three separate panels, of officials
from FNS, the U.S. Department of Labor, and U.S. Department of Education to consider the
merit of each grant application. Each panel shared the same panel chair and the same grant
officer (both FNS officials) and reviewed and scored about 15 proposals using the criteria


1
  “Unemployed” refers to an individual who is jobless, looking for a job, and available for work. “Underemployed”
refers to an individual who is working part-time, but desires full-time employment, or who is working in
employment not commensurate with the individual’s demonstrated education level.
2
    Agricultural Act of 2014, Pub. L. No. 113-79, 128 Stat. 649 (2014 Farm Bill).
3
  Section 4022 of the Agricultural Act of 2014, “Pilot Projects to Reduce Dependency and Increase Work
Requirements and Work Effort Under Supplemental Nutrition Assistance Program,” authorizes pilot projects that we
refer to as SNAP E&T pilot projects throughout this audit report.

                                                                          AUDIT REPORT 27601-0004-22            1
outlined in the RFA. Afterword, an evaluation contractor also provided a technical review of the
pilot project applications for FNS.

In March 2015, FNS awarded grants, ranging from $8.9 million to $22.3 million, to 10 States
through a competitive grants process, with the grants starting in April 2015. Collectively, the
selected projects tested a range of job-driven strategies, included a mix of urban and rural areas,
tested mandatory and voluntary programs,4 targetted a variety of work registrants,5 and reflected
a diversity of geographic areas (see Table 1, below).

Table 1: Overview of SNAP E&T Pilot Projects
                                                               Targeted
                                          Type of State                                                Award
      Grantee         Urban/Rural                                Pilot         FNS Region
                                          E&T Program                                                  Amount
                                                                Size(a)
    California       urban & rural       voluntary                 3,400 Western                       $12,166,778
    Delaware         urban & rural       voluntary                 5,292 Mid-Atlantic                  $18,765,069
    Georgia          urban               mandatory                 5,000 Southeast                     $15,011,438
                                         mandatory &
    Illinois         urban & rural                                 5,000 Midwest                       $21,857,568
                                         voluntary(b)
    Kansas           urban & rural       voluntary                 3,890 Mountain Plains               $13,509,167
    Kentucky         rural               voluntary                 4,000 Southeast                     $19,987,148
    Mississippi      urban & rural       mandatory                 4,950 Southeast                  $20,505,890(c)
    Vermont          rural               voluntary                 3,000 Northeast                      $8,959,379
    Virginia         urban & rural       voluntary                 5,386 Mid-Atlantic                  $22,329,952
    Washington       urban & rural       voluntary               5,088(d) Western                      $22,000,000

        (a) The targeted pilot size represents the total number of participants across the project’s treatment
            group (individuals who received pilot services) and control group (individuals that did not receive
            those services). For most State grantees, the number of participants was evenly split between
            these two groups.
        (b) Illinois’ State E&T program is mandatory in 15 counties and voluntary in 18 counties. The pilot
            project did not exclusively serve mandatory participants because regular SNAP E&T services are
            not offered in 18 out of 33 counties included in the pilot.
        (c) Mississippi’s E&T pilot project was initially funded at $20,505,890. The final award amount for
            Mississippi was $15,505,890, as surplus grant funds were identified and FNS recovered $5 million
            after advising the State to retain a portion of funds to support any final costs associated with the
            grant’s close out.
        (d) Washington revised its target pilot size from 14,000 to 5,088 participants in FY 2017.



4
  Mandatory programs require nonexempt work registrants to participate in assigned E&T program activities or face
disqualification from SNAP. Voluntary programs do not require participation, but offer individuals the opportunity
to participate in activities if they choose. Voluntary programs do not impose disqualifications from SNAP for
individuals failing to participate.
5
 The E&T pilot projects target work registrants who are either unemployed or underemployed, and many also target
subsets of this population who face significant barriers to employment, such as homelessness, criminal convictions,
substance abuse, long-term unemployment, and noncustodial parents.

2        AUDIT REPORT 27601-0004-22
SNAP E&T pilot projects operated as partnerships between FNS, State and local organizations,
and a contractor selected by FNS to conduct an independent evaluation of each pilot project. At
the State level, States voluntarily enter into cooperative agreements with the Federal government
to operate SNAP programs in exchange for program funds. In receiving an E&T pilot project
grant, each State agency assumed the overall responsibility for planning, implementing, and
operating its pilot project and must work closely with the evaluation contractor throughout the
duration of the cooperative agreement. State agencies were required to submit to FNS timely
quarterly progress and financial reports throughout the grant award period. The quarterly
progress report describeed the project’s progress, tasks completed, any problems encountered,
budget and costs, key activities planned for the next reporting period, and activities that may
require changes in the project’s schedule. The financial reports are submitted via Form SF-425
(Federal Financial Report).

At the Federal level, FNS’ Office of Employment and Training (OET) administers the E&T
program nationwide, provides technical assistance to State agencies, monitors the effectiveness
of States’ E&T programs, and increases collaboration with other Federal training programs.
OET monitored the E&T pilot projects to ensure they meet their intent and comply with program
rules and regulations. As part of this oversight, OET initially participated in bi-weekly phone
calls with the pilot States and the evaluation contractor and accompanied the evaluation team on
implementation site visits to the pilot projects. In addition, OET performed monitoring visits
from June 2016 to April 2017 to ensure each pilot project were complying with applicable laws
and regulations, requirements in the cooperative agreement and RFA, and the proposal included
in each State’s pilot project application. These evaluations included interviews, observations,
and case file reviews at the State agencies and their pilot project partners. OET also reviews
State agencies’ quarterly progress reports and financial reports (SF-425) for their pilot project
activities. Finally, OET acts as a liaison between the evaluation contractor and the State
agencies. FNS’ Grants Management Operations Branch is responsible for the financial
management of the pilot project grants and monitors the expenditures of the pilot projects
through the SF-425 financial reports.6

Lastly, the 2014 Farm Bill called for an independent, longitudinal evaluation of all pilot projects
to measure the effectiveness of the E&T programs and services on the ability of participants to
obtain and retain employment.7 FNS contracted with an evaluation contractor in December 2014
to conduct the required independent evaluation of the 10 SNAP E&T pilot projects. The
independent evaluation, which examines both the short-term and long-term impacts of the pilot
projects, will help USDA identify which approaches are most effective at helping SNAP
recipients find and keep work and reduce their reliance on food assistance. The evaluation


6
  The Grants Management Operations Branch, located within FNS’ Grants and Fiscal Policy Division, is responsible
for ensuring fair and open competition, and that proper controls are in place for all discretionary grant programs.
FNS’ Grants and Fiscal Policy Division is responsible for discretionary grants functions and grants management and
policy functions.
7
  The longitudinal evaluation will examine both the short-term results and long-term impacts of the pilot projects.
By comparing the outcomes of the pilot participants over time, the evaluation will measure the extent to which the
new SNAP E&T pilot services help more than the usual SNAP E&T services and determine whom the new services
help most. An interim report with short-term results of the pilot projects is scheduled for release in 2019 and a final
report with the long-term impacts of the pilot projects is scheduled for release in 2021.

                                                                          AUDIT REPORT 27601-0004-22                 3
contractor will prepare annual reports to Congress that provide details on the implementation
status of the pilots, activities of the evaluations, and early results (if available) of the process and
impact evaluations of each pilot project. Meaningful results of the pilot projects will not be
available until the evaluation is complete; the final report is scheduled for release in mid-2021.

The Agriculture Improvement Act of 2018 increased funding for SNAP E&T programs, from
$90 million to $103.9 million annually.8 As part of this funding increase, the Secretary of
Agriculture can reallocate any remaining available E&T program funds based on the results from
the independent evaluation of the pilot projects to those State agencies that have demonstrated
the most impact on the ability of participants to find and retain employment. 9 If the results of
the independent evaluation are not yet available, then the Secretary of Agriculture can base the
reallocation of funds on the information related to the performance of the E&T programs and
activities of the pilot projects.

Objectives
Our audit objective was to evaluate FNS’ controls over States’ SNAP E&T pilot projects
ensuring activities, funds, and performance are properly monitored.

We had no reportable findings for FNS’ controls over properly monitoring the activities and
performance of States’ SNAP E&T pilot projects. FNS used an evaluation contractor to monitor
the pilot projects for the independent evaluation. This contractor will report on both the short-
term and long-term outcomes of the pilot projects.




8
    Agriculture Improvement Act of 2018, Pub. L. No. 115-334 (2018 Farm Bill).
9
 The amount of remaining E&T program funds is determined based on the anticipated expenditures by State
agencies.

4        AUDIT REPORT 27601-0004-22
Finding 1: FNS Should Ensure Pilot Project States Maintain Funding Efforts
We found that 6 of the 10 States in the SNAP E&T pilot program spent almost $38.7 million less
from FYs 2015–2017 than their FY 2013 funding levels. FNS did not identify this issue because
it only reviewed States’ annual plans—not their actual E&T expenditures. As a result, these six
States may have replaced nearly as much as $27.6 million of the $38.7 million of State funds
with Federal pilot grant funds they were not entitled to spend in their existing E&T programs.

The 2014 Farm Bill requires States eligible to participate in an E&T pilot project to commit to
maintain at least the amount of State funding for regular E&T programs and services expended
for FY 2013 for each year of the pilot.10 In addition, State agencies could not shift the cost of
existing E&T programs and services to their pilot projects, as grant funds could only be used to
supplement or expand, not replace, non-Federal funds.11

Maintaining the FY 2013 level of E&T program funding was a priority for FNS while selecting
which pilot projects to fund. FNS issued an RFA, in August 2014, which required States to
include in their application a commitment to maintain at least the same level of State funding for
SNAP E&T programs and services that they expended in FY 2013. In fact, FNS rejected some
States’ highly-ranked project proposals because they did not include a commitment in their
applications to maintain their required FY 2013 funding levels. However, despite this important
requirement, we found that of the 10 SNAP E&T pilot projects, 6 States did not maintain at least
the same amount of State funds spent in FY 2013 for their E&T programs.12 Instead, the six
States collectively spent almost $38.7 million less of their own funds from FYs 2015–2017 than
their FY 2013 funding level (see Table 2, below).

Table 2: Overview of States’ E&T Program Expenditures compared to FY 2013 Spending
                                      Levels13

                          FY 2013            FY 2015            FY 2016           FY 2017        Total Regular
         State           Spending          Underspent         Underspent         Underspent        Program
                                                                                                 Underspending
                         (Baseline)           Funds              Funds              Funds
 California              $41,832,138         $5,962,140         $8,735,889         $8,596,467       $23,294,496
 Delaware                     $73,778            $28,700                  $0           $49,721          $78,421
 Illinois                $10,242,036         $2,409,578         $1,996,074         $1,879,812        $6,285,464
 Kansas                       $41,182                  $0           $29,549            $17,373          $46,922
 Vermont                   $4,958,023          $879,513         $2,787,368         $4,594,813        $8,261,694


10
     Agricultural Act of 2014, Pub. L. No. 113-79, 128 Stat. 649 § 4022 (2014 Farm Bill).
11
     Ibid.
12
   Four States (Georgia, Kentucky, Mississippi, and Washington) complied in meeting or exceeding the amount of
State dollars they spent for E&T programs in FY 2013 from FYs 2015–2017.
13
   The E&T program expenditures presented in Table 2 were reported on each State’s SF-425. This table lists those
six States that did not maintain their FY 2013 levels of E&T program funding. A $0 amount indicates that a State
spent more than its FY 2013 level in that fiscal year.

                                                                          AUDIT REPORT 27601-0004-22            5
 Virginia                $1,259,570          $204,933        $345,859     $164,561         $715,353
 Total                                     $9,484,864     $13,894,739   $15,302,747    $38,682,350

A State that does not abide by the requirements of the grant, such as the maintenance of effort
provision for pilot projects, may have all or part of the grant’s costs disallowed. 14 In comparing
the 10 States’ pilot grant awards to their related regular E&T program underspent funding levels,
we determined that 9 of 10 States were awarded pilot grant funds that exceeded the level of their
underspent funding. California is the only State participating in the E&T pilot projects where its
underspent amount is greater than the grant award amount. Since violators of the terms of the
pilot can only have those grant costs disallowed, maximum recovery would be limited to the
grant funds States received (see Table 3, below).

       Table 3: States’ Underspent Funds Compared to Award Amounts
                             Award           Underspent Funds
           Grantee                                                  Maximum Recovery
                             Amount           (FY 2015-2017)
         California          $12,166,778              $23,294,496            $12,166,778
         Delaware            $18,765,069                  $78,421                $78,421
         Georgia             $15,011,438                       $0                     $0
         Illinois            $21,857,568               $6,285,464             $6,285,464
         Kansas              $13,509,167                  $46,922                $46,922
         Kentucky            $19,987,148                       $0                     $0
         Mississippi         $20,505,890                       $0                     $0
         Vermont              $8,959,379               $8,261,694             $8,261,694
         Virginia            $22,329,952                 $715,353               $715,353
         Washington          $22,000,000                       $0                     $0
         Total                                        $38,682,350            $27,554,632




14
     2 C.F.R. § 200.338 Remedies for noncompliance.

6        AUDIT REPORT 27601-0004-22
FNS officials stated that the base year for measuring expenditures should begin in FY 2016 when
projects were fully operational—not FY 2015, when the States first received their funding. It
was the agency’s view that it was inappropriate to judge the projects when they were first
starting. Additionally, FNS officials said that the State expenditures should be measured as an
annual average over the duration of the grant, and not by each individual year. FNS stated since
the law was silent as to the method to be used, it was within FNS’ authority to select the year in
which the commitment to maintain effort started. FNS also stated that since Congress envisioned
this to be a multi-year pilot, FNS was not required to enforce the maintenance of effort
requirement each and every year, but rather across several years.

However, we maintain that it is appropriate to look at each individual year, starting with FY
2015, the first year grants were made. Since the intent of the requirement to maintain effort was
to disallow States to substitute Federal funding for State funding in the regular E&T program, the
requirement must apply in any year grants were made, including FY 2015. We also note that
subsequent to the enactment of the statute, FNS published its RFA in August 2014, which
required that States commit to maintain their FY 2013 funding levels on an annual basis. The
RFA stated, “[t]he Act requires that State agencies interested in applying must commit to
maintain at least the amount of State funding for SNAP E&T programs that they expended in
FY 2013 for each year of the pilot.” Since States applying for the program made a decision
based on this commitment to maintain funding at the FY 2013 levels, FNS needs to enforce such
requirement. Otherwise, States not accepted in the pilot program because of their uncertainty
about maintaining FY 2013 spending levels could challenge FNS’ grant decision. Thus, FNS
should obtain a justification and/or recover funds from those States that did not maintain
spending at the level required for each and every year the State received funding, including
FY 2015.

FNS officials also noted that State E&T programs and expenditures are fluid, which could affect
States’ ability to spend E&T funds or result in fewer expenditures than anticipated. For example,
States may have spent less on their E&T programs because of decreased program participation
due to enrolling participants in the pilot projects or improvements in the States’ unemployment
and economic conditions. While we acknowledge there may be legitimate reasons why States
could not maintain their required funding levels, we contend that FNS needs to ensure that States
annually maintained their FY 2013 funding levels or if not that there is a valid reason why this
did not occur. Instead of limiting its review to the States’ E&T plans and budgets, FNS should
expand its review to the SF-425s, which show States’ actual annual expenditures. If States did
not maintain their required FY 2013 funding levels in FYs 2015–2017, States should provide
justification to FNS.

Additionally, we found one instance where FNS took steps to enforce a State’s commitment to
maintain its FY 2013 funding level requirement. When reviewing one State’s E&T plan to
determine the State’s commitment, FNS identified that the State agency’s FY 2018 budget was
approximately 90 percent less than its FY 2013 funding level. Further, the State agency’s
FY 2017 regular SNAP E&T program expenditures had decreased significantly from its FY 2013
level. FNS notified the State agency that it was not in compliance with the requirement to
maintain its FY 2013 funding level and informed the agency that FNS may unilaterally terminate
the grant agreement or disallow up to 100 percent of the costs if the State failed to comply with


                                                            AUDIT REPORT 27601-0004-22          7
any term of the agreement.15 Had FNS reviewed the actual expenditures for this State in addition
to the plan’s budget, FNS would have discovered that in FY 2016, the State was also out of
compliance, as it had spent less than 60 percent of the required regular SNAP E&T program
amount. FNS fully resolved this matter when the State demonstrated that it was spending funds
for E&T costs but not seeking reimbursement from FNS due to a unique funding authority for
the State. We encourage FNS to apply these measures more consistently and to notify all State
agencies that do not maintain their required FY 2013 funding levels.

Recommendation 1

Require States to substantiate that the reductions in their regular E&T expenditures occurred for
reasons other than the receipt or expected receipt of their Federal pilot funds.

Agency Response
The Food and Nutrition Act, the Request for Applications, and the grant agreement signed by the
grantees, required States to commit to maintain at least as much State funding for SNAP E&T
programs and optional workfare as the State expended in FY 2013. USDA will review each
State’s expenditures over the period of performance of the grant and ask States to substantiate
that the reductions in expenditures in their regular E&T program occurred for reasons other than
the receipt or expected receipt of the Federal Pilot funds. The expected completion date is
March 31, 2020.

OIG Position
We accept management decision for this recommendation.

Recommendation 2

For any State unable to provide adequate substantiation for Recommendation 1, use agency
authorities under 2 C.F.R. § 200.338 and agency policies over grants to seek recovery of pilot
funds, as appropriate.

Agency Response
FNS will review the responses submitted by each State agency, carefully consider the
circumstances that resulted in the decreased expenditures, and determine next steps including
potential recovery of pilot funds, if appropriate. The expected completion date is June 30, 2020.

OIG Position
We accept management decision for this recommendation.

15
  The State agency, after meeting with FNS, provided a letter substantiating the reductions in regular employment
and training expenditures.

8     AUDIT REPORT 27601-0004-22
Scope and Methodology 
We conducted an audit of the SNAP E&T pilot projects. The scope of our audit work covered
the activities of the pilot projects from FYs 2013 through 2017. We conducted our audit work
from July 2018 through April 2019.

To accomplish our objective, we performed fieldwork at the FNS national office in Alexandria,
Virginia, in order review the agency’s internal controls for administering, overseeing, and
monitoring the SNAP E&T pilot projects. We also performed audit work at three
non-statistically selected SNAP E&T pilot projects, which included site visits to the State
agencies responsible for the administration and oversight of the States’ pilot projects and
selected partners and community organizations that provided services for the States’ pilot
projects.16

The SNAP E&T pilot projects from Georgia, Vermont, and Washington were non-statistically
selected based on such factors as geography, coverage within the States (Statewide or county
administered), service locations, target populations of SNAP participants, sample size, type of
State E&T program, and grant amount.17 We also selected pilot projects from States that neither
OIG nor the Government Accountability Office were visiting at the time of our fieldwork
selections as part of other ongoing SNAP audit work.

At the FNS national office, we:

       ·    Reviewed applicable laws, regulations, policies, and procedures regarding FNS’
            administration of the SNAP E&T pilot projects;

       ·    Determined FNS’ administrative and oversight responsibilities for the 10 pilot projects,
            the officials responsible for each pilot project, and the interaction with the State agencies
            and the independent evaluation contractor;

       ·    Determined the criteria, methodology, and ranking system FNS used to select the pilot
            projects;

       ·    Compared FNS’ methodology and ranking system with the selection criteria in the
            Agricultural Act of 2014 and the RFA;

       ·    Reviewed each State agency’s quarterly progress reports to determine FNS’ reporting
            requirements for State agencies to report on the progress of their pilot projects to both
            FNS and the evaluation contractor;

       ·    Evaluated how FNS verifies the performance data on the States agencies’ quarterly
            progress reports;

16
     For a list of sites visited, see Exhibit B.
17
  The selected pilot projects are referred to as SNAP Works 2.0 in Georgia, Jobs for Independence in Vermont, and
Resources to Initiate Successful Employment in Washington.

                                                                      AUDIT REPORT 27601-0004-22                9
     ·   Reviewed each State agency’s quarterly financial reports (SF-425) to determine FNS’
         requirements for State agencies to report their expenditures for the pilot projects and
         regular E&T activities;

     ·   Compared each State agency’s grant budget to the financial reports to determine if there
         were any significant variances;

     ·   Determined FNS’ process to evaluate the pilot projects to ensure the State agencies are
         meeting their project goals, which included a determination of how FNS uses
         management evaluations and the independent evaluation contractor in its oversight of the
         pilot projects; and

     ·   Interviewed the evaluation contractor officials to discuss the contractor's role in the
         independent evaluations of the pilot projects.

At the State agencies, we:

     ·   Interviewed officials responsible for the administration of the SNAP E&T program and
         pilot projects, identified partnerships with outside entities, identified the scope and
         characteristics of the pilot projects, and identified any reviews related to the States’
         SNAP E&T programs and pilot projects;

     ·   Determined if the State agencies submitted to FNS quarterly financial reports (SF-425)
         and progress reports and if the State agencies had any requirements for local agencies or
         partners to report on their progress and financial status of pilot project activities;

     ·   Reviewed the State agencies’ FY 2017 cost allocation plans and obtained States’
         approved plans of operations to ensure compliance with the cost allocation plans;

     ·   Determined and documented the controls for monitoring pilot project funds and for
         confirming State agencies’ maintainence of their FY 2013 SNAP E&T program funding
         levels;

     ·   Determined and documented whether the State agencies maintained their FY 2013
         funding levels for each year of their pilot projects and whether they used State funds or
         funds from other sources to administer the pilot projects;

     ·   Reviewed a non-statistical sample of State agencies’ administrative expense transactions
         and participant cost reimbursement expense transactions; and

     ·   Determined how performance data were collected and evaluated for States’ regular
         SNAP E&T programs and the pilot projects, documented the collaboration with the
         independent evaluation contractor for evaluating the States’ pilot projects, and
         determined how the State agencies monitored their partners’ performance and
         compliance.

10       AUDIT REPORT 27601-0004-22
During the course of our audit, we did not solely rely on any agency information systems. We
conducted limited verification of the data related to our objective by: (1) reviewing the data for
obvious errors and completeness by comparing the data to supporting documents we obtained
from the three States we visited, and (2) interviewing agency officials knowledgeable about the
data. We make no representation regarding the adequacy of any agency computer systems, or
the information generated from them because the fundamental processes related to the audit
objective did not rely on information systems or information technology.

We conducted this performance audit in accordance with Generally Accepted Government
Auditing Standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.




                                                            AUDIT REPORT 27601-0004-22          11
Abbreviations 
E&T........................................employment and training
FNS ........................................Food and Nutrition Service
FY ..........................................fiscal year
OET…………………………Office of Employment and Training
OIG ........................................Office of Inspector General
RFA…………………………Request for Applications
SNAP………………………..Supplemental Nutrition Assistance Program
USDA……………………….U.S. Department of Agriculture




12    AUDIT REPORT 27601-0004-22
Exhibit A:  Summary of Monetary Results 
Exhibit A summarizes the monetary results for our audit report by finding and recommendation
number.

Finding   Recommendation       Description                    Amount        Category
                               For any State unable to
                               adequately substantiate                      Questioned
   1               2           reductions in its regular      $27,554,632   Costs,
                               employment and training                      Recovery
                               expenditures, use agency                     Recommended
                               authorities and policies to
                               seek recovery of pilot grant
                               funds, as appropriate




                                                         AUDIT REPORT 27601-0004-22       13
Exhibit B:  Audit Sites Visited 
This exhibit shows the name and location of all sites visited during the audit, including the FNS
national office, State agencies, and State agency partners that provide oversight and services for
the SNAP E&T pilot projects in Georgia, Vermont, and Washington.

                     AUDIT SITE                                         LOCATION
FNS national office                                           Alexandria, VA
State Agency (Georgia):
Georgia Division of Family and Children Services              Atlanta, GA

Partners/Service Providers:
Georgia Department of Labor                                   Decatur, GA
DeKalb County Division of Family and Children Services        Decatur, GA
Gwinnett County Division of Family and Children               Lawrenceville, GA
Services
State Agency (Vermont):
Vermont Department for Children and Families                  Waterbury, VT

Partners/Service Providers:
Vermont Department of Labor (Burlington Resource              Burlington, VT
Center)
Vermont Department of Labor (Rutland Resource Center)         Rutland, VT
Vermont Division of Vocational Rehabilitation Employee        Rutland, VT
Assistance Program
Community College of Vermont                                  Winooski, VT
State Agency (Washington):
Washington Department of Social and Health Services           Olympia, WA

Partners/Service Providers:
Career Path Services                                          Federal Way, WA
North Seattle College                                         Seattle, WA
People for People                                             Yakima, WA




14     AUDIT REPORT 27601-0004-22
Agency’s Response 




                AGENCY’S
         RESPONSE TO AUDIT REPORT




                        AUDIT REPORT 27601-0004-22   15
United States
Department of    DATE:          December 9, 2019
Agriculture
                 AUDIT
                 NUMBER:        27601-0004-22
Food and
Nutrition
Service
                 TO:            Gil H. Harden
3101 Park                       Assistant Inspector General for Audit
Center Drive

Alexandria, VA   FROM:          Pamilyn Miller /s/
                                Administrator
22302-1500

                                Food and Nutrition Service

                 SUBJECT:       SNAP Employment and Training Pilot Projects

                 This letter responds to the official draft report for audit number 27601-0004-22, SNAP
                 Employment and Training (SNAP E&T) Pilot Projects. Specifically, the Food and
                 Nutrition Service (FNS) is responding to the two recommendations in the report.

                 OIG Recommendation 1:

                 Require States to substantiate that the reductions in the regular employment and
                 training expenditures occurred for reasons other than the receipt or expected receipt of
                 the Federal pilot funds.

                 FNS Response:

                 The Food and Nutrition Act (the Act), the Request for Applications, and the grant
                 agreement signed by the grantees, required States to commit to maintain at least as
                 much State funding for SNAP E&T programs and optional workfare as the State
                 expended in Fiscal Year (FY) 2013. USDA will review each State’s expenditures over
                 the period of performance of the grant and ask States to substantiate that the reductions
                 in expenditures in their regular E&T program occurred for reasons other than the
                 receipt or expected receipt of the Federal Pilot funds.

                 Estimated Completion Date:

                 March 31, 2020

                 OIG Recommendation 2:

                 For any State unable to provide adequate substantiation for Recommendation 1, use
                 agency authorities under 2 C.F.R. § 200.338 and agency policies over grants to seek
                 recovery of pilot funds, as appropriate.
Gil Harden
Page 2

FNS Response:

FNS will review the responses submitted by each State agency, carefully consider the
circumstances that resulted in the decreased expenditures, and determine next steps
including potential recovery of pilot funds, if appropriate.

Estimated Completion Date:

June 30, 2020




                            AN EQUAL OPPORTUNITY EMPLOYER
Learn more about USDA OIG
Visit our website: www.usda.gov/oig
Follow us on Twitter: @OIGUSDA

Report Suspected Wrongdoing in USDA Programs
OIG Hotline: www.usda.gov/oig/hotline.htm

Monday–Friday, 9:00 a.m.– 3:00 p.m. ET
In Washington, D.C. (202) 690-1622
Outside D.C. (800) 424-9121
TYY (Call Collect) (202) 690-1202

Bribery / Assault
(202) 720-7257 (24 hours)




In accordance with Federal civil rights law and U.S. Department of Agriculture             Relay Service at (800) 877-8339. Additionally, program information may be made
(USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and         available in languages other than English.
employees, and institutions participating in or administering USDA programs are
prohibited from discriminating based on race, color, national origin, religion, sex,       To file a program discrimination complaint, complete the USDA Program
gender identity (including gender expression), sexual orientation, disability, age,        Discrimination Complaint Form, AD-3027, found online at How to File a Program
marital status, family/parental status, income derived from a public                       Discrimination Complaint and at any USDA office or write a letter addressed to
assistance program, political beliefs, or reprisal or retaliation for prior civil rights   USDA and provide in the letter all of the information requested in the form. To
activity, in any program or activity conducted or funded by USDA (not all bases            request a copy of the complaint form, call (866) 632-9992. Submit your completed
apply to all programs). Remedies and complaint filing deadlines vary by                    form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the
program or incident.                                                                       Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington,
                                                                                           D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov.
Persons with disabilities who require alternative means of communication for
program information (e.g., braille, large print, audiotape, American Sign                  USDA is an equal opportunity provider, employer, and lender.
Language, etc.) should contact the responsible Agency or USDA’s TARGET
Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal               All photographs on the front and back covers are from USDA’s Flickr site and are in
                                                                                           the public domain. They do not depict any particular audit or investigation.