FISCAL NOTE
Date Requested: February 12, 2025
Time Requested: 09:59 PM |
| Agency: |
Human Services, WV Department of |
|---|
| CBD Number: |
Version: |
Bill Number: |
Resolution Number: |
| 1087 |
Introduced |
SB249 |
|
|---|
| CBD Subject: |
Health |
|---|
|
FUND(S):
General and Federal
Sources of Revenue:
General Fund Federal Fund
Legislation creates:
Increases Existing Expenses
Fiscal Note Summary
Effect this measure will have on costs and revenues of state government.
The purpose of this bill is to expand the employment and training requirements necessary to receive SNAP benefits. The bill defines and expands exemptions. The bill clarifies the Secretary's duties when there is a lack of funding or inability to provide employment and training. Finally, the bill identifies when assignments to the employment and training program may not be suspended.
The Department estimates the fiscal impact related to this legislation to be $5,461,227 ($2,730,613 state) the first year and $3,471,227 ($1,735,613 state) upon full implementation.
Fiscal Note Detail
| Effect of Proposal |
Fiscal Year |
2025
Increase/Decrease
(use"-") |
2026
Increase/Decrease
(use"-") |
Fiscal Year
(Upon Full
Implementation) |
| 1. Estmated Total Cost |
0 |
5,461,227 |
3,471,227 |
| Personal Services |
0 |
3,356,227 |
3,356,227 |
| Current Expenses |
0 |
2,105,000 |
115,000 |
| Repairs and Alterations |
0 |
0 |
0 |
| Assets |
0 |
0 |
0 |
| Other |
0 |
0 |
0 |
| 2. Estimated Total Revenues |
0 |
0 |
0 |
Explanation of above estimates (including long-range effect):
An initial vendor estimate of systems costs for RAPIDS/PATH upgrades necessary to operate a mandatory E&T program totals $1.54M one time cost. A vendor estimate of year-one costs for federally-required client mass mailing totals $115k which includes development of new notices, etc. These costs would be 50% federal, 50% state. Future year mailing costs are unknown due to inability to accurately identify the impacted population.
The state received $629,008 in federal funding for the administration of the SNAP E&T program for FFY25. Annual funding is allocated by formula based on the state's prior-year population of federally-defined SNAP Work Registrants and federally-defined Able Bodied Adults Without Dependents (ABAWDs). The state's non-exempt ABAWD population has declined by nearly 15,535 since the post-pandemic return of ABAWD work requirements in June of 2023, so it is expected that future funding allocations for this program will be reduced from the current figure.
Release of the federal funding is contingent upon USDA approval of a SNAP E&T State Plan. See memorandum section for more information.
7 CFR 273.7(d)(4) mandates that states must reimburse participant expenses that are "reasonable and necessary" for a client's participation in a SNAP E&T program. These reimbursements are funded using 50% federal, 50% state dollars. 7 CFR 273.7(d)(4)(v) stipulates that clients whose monthly expenses for participation exceed the state cap must be exempted from participation; however, lack of state funding for reimbursement is not considered a legitimate reason for exempting a person from participation and would expose the State to a case error. It is difficult to determine the size of the impacted population, so this cost remains unquantified. Should the target population be expanded to include those with children in the household, costs to the child care subsidy system would grow exponentially.
A conservative estimate of staffing needs to handle the new eligibility functions created by this bill calls for a minimum of one new Family Support Supervisor to oversee the program in each county office (two new Family Support Supervisors in some counties). The Department is estimating that it would take 60 Family Support Supervisor positions. The average salary for the Supervisor is $47,406 (avg. salary) + $16,592 (35% benefits) = $63,998. In addition, two Health and Human Resource Specialists Senior are needed to provide quality control management evaluations, $53,836 (average salary) + $18,842 ( average benefits). Therefore, the total personal services cost is estimated to be $3,985,235 (less redirect $629,008) = $3,356,227. The estimated start-up costs of $450,000 for 60 employees ($7,500.00 x 60) would be a one-time cost. Start-up costs includes costs for computers, furniture and office supplies. In future years, these costs will be reduced.
The staffing costs are predicated on bringing case management staff in house (vs in grant agreements with the Regional Workforce Development Boards (WDBs)) in an attempt to mitigate an increase in SNAP error rates, as E&T will now be a function of eligibility. This would result in partially offseting the cost by shifting the administrative allocation for this program that is currently passed through to the WDBs for case management of participants in the State's current voluntary E&T program ($629,008).
Memorandum
The section of the bill that would create W.Va. Code §9-8-2a includes an age range of 18-59 to the ABAWD population. The federally-defined age range is 18-54. The bill also mirrors and refers to 7 CFR 273.7(b), which lays out exemptions from the federal Work Registration requirement, which are wholly different from the federal ABAWD work/education/training requirement exemptions found in 7 CFR § 273.24(c). This impedes determination of the impacted population and makes federal approval of a State Plan unlikely. It also means that implementation of a program based on this bill would expose the State to a significant increase in SNAP error rates, which carries the risk of millions of dollars in federal repayment.
The State's administrative allocation for this program is currently passed through almost entirely to the Regional Workforce Development Boards (WDBs) for case management of participants in the State's current voluntary E&T program. This funding would likely have to be repurposed toward Department costs, placing at risk an important source of funding to WV's Workforce Development system and 10 jobs at the WDBs that are currently wholly funded by this grant. This would also jeopardize the Department's ongoing efforts to ensure that our Workforce partners are co-enrolling all E&T participants in the WIOA-funded workforce programs for which they are also eligible.
The necessity of program restructuring to accommodate a statewide mandatory program would also likely mean limiting the program to a single Approved E&T Component, consisting of Supervised Job Search. This could jeopardize the future of the State's ability to reimburse third-party partners for paid employment and training that leads to skilled credentials, which represents the potential loss of approximately 107 participant jobs currently served across the State's existing E&T third party partners at Goodwill, Coalfield Development, WV Women Work, Blenko Glass, and Bridge Valley Community and Technical College.
Other states implementing mandatory E&T programs have seen drastic increases in their SNAP error rates. Error rates above the national average for 2 consecutive years place a state at risk of federal financial sanctions requiring potential repayment of federal funding. While WV's error rates are currently compliant, the administrative complexity of implementing new eligibility criteria under a mandatory program does expose the state to significant risk of repayment.
There is no alternate source of funding for the administration of the mandatory E&T program created by this bill. While a limited amount of TANF funding may in some cases be used to support participant reimbursement costs for certain eligible individuals for up to 4 months, it would not be applicable under any circumstances to the ABAWD population contemplated by this bill, as TANF funds can only be expended on families with dependent children.
The bill does reference ABAWD Pledge Funding, which the State does not currently receive. This funding, if received, would be a small portion of a $20M national pool that is allocated by formula to states that pledge to place ABAWDs at risk of losing their benefits into an activity that satisfies ABAWD work requirements. Supervised Job Search, likely the only E&T Component the State could feasibly include in a statewide mandatory program, is not an allowable activity for this purpose. The release of this funding is also contingent upon a federally approved State Plan for its use, and any state that fails to fulfill the pledge to place all at-risk ABAWDs in a qualifying activity may be disbarred from future receipt of this funding.
The bill stipulates that the Department will implement a mandatory program with no specified implementation date, meaning the State must submit a State Plan for implementation of a mandatory program that coincides with the state of the federal fiscal year in October 2025; however, the initial vendor estimate of required systems programming changes calls for 18-24 months to implement the necessary changes.
Person submitting Fiscal Note: Alex J. Mayer, MSA, PMP
Email Address: osafiscalnotes@wv.gov