Exhibit D - THIRD-PARTY PARTNERSHIP STATEMENT OF WORK

1. PROJECT OVERVIEW

1.1. In Colorado, the Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) program, known as Employment First (EF), promotes long-term self-sufficiency and independence by preparing SNAP clients for meaningful employment through work-related education and training activities. The EF program is administered in Colorado counties at local county human/social services offices and through organizations around the state, known as Third-Party Partners.

1.2. The Colorado Department of Human Services (CDHS) (the “Department”) is contracting with __________ (the Program Operator) to enter into a Third-Party Partnership (TPP), in which the Program Operator will provide specialized services that increase employment readiness, increase employment outcomes, offer assistance and guidance in reskilling, upskilling, new skilling, and obtaining certificates and credentials that strengthen the employability of eligible SNAP clients.

1.3. Eligible SNAP clients are individuals ages 16 and over who have applied for or receive food assistance benefits through the State of Colorado’s SNAP program.

1.4. This partnership will leverage existing expertise in the community and build upon already established employment and training-focused agencies that work with SNAP clients and assist the hardest-to-serve individuals to become economically self-sufficient.

2. TERM OF PROJECT

2.1. The Program Operator under this contract shall complete the terms of the project no later than September 30, 2026.

3. GENERAL REQUIREMENTS

3.1. The Program Operator shall perform all work under all applicable federal and State statutes, regulations, and rules, including but not limited to provisions from the 2 CFR 200, 2 CFR 400, 7 CFR 271-285, 2018 Agricultural Improvement Act, SNAP E&T Toolkit, Colorado’s SNAP Employment and Training State Plan, Colorado’s Section 20 Optional Workfare Plan, and the EF Program Operator Handbook as now and hereafter amended, and the requirements described in this Statement of Work and the Department-approved EF Program Operator Plan.

3.2. The Department will provide the Program Operator the current version of the EF Program Operator Handbook at the annual Employment First Kick-Off Meeting. The Program Operator must adhere to the requirements outlined in the most current version of the EF Program Operator Handbook throughout the program year. An example of the EF Program Operator Handbook has been included (Exhibit #).

3.3. The Program Operator shall work closely and collaboratively with the Department, discuss suggestions or issues as issues occur, and incorporate guidance from the Department while performing the work described within this Statement of Work, the EF Program Operator Plan, and the EF Program Operator Handbook.

3.4. The Program Operator shall incorporate any policies deemed necessary and created for the CDHS EF TPP program by the Department. These policies include but are not limited to Case Management, Fraud, and Supportive Services.

3.5. The Program Operator shall coordinate and prioritize all work to ensure all performance requirements (see Section 6.0) are fulfilled by their deadlines.

3.6. The Program Operator shall employ an internal quality control process to ensure that all deliverables are complete, accurate, easy to understand, and of high quality. The Program Operator shall participate in the review and revision process until the Department provides written acceptance of the deliverable.

3.7. The Program Operator shall retain all supporting documentation for all deliverables for four years (including the current contract period).

3.8. The Program Operator must provide copies of any supporting documentation to the Department upon request of the Department and without charge within three business days of the request.

3.9. The Program Operator shall notify the Department of any changes to their organization or operations.

3.10. The Program Operator must sustain program services with their non-federal funding sources.

4. DIRECT SERVICES

4.1. The Program Operator shall provide case management services, participant reimbursements, and at least one component to SNAP clients, in alignment with the costs, activity details, maximum limits, and method of disbursement from the Department-approved EF Program Operator Plan, and the FNS-approved Employment First State Plan, to receive reimbursement for these direct services.

4.1.1. Case Management Services - refer to Section 5.0 of the SOW and the Program Operator Handbook for further details and requirements regarding case management services.

4.1.2. Participant Reimbursement - refer to the Department-approved EF Program Operator Plan and the EF Program Operator Handbook for further details regarding participant reimbursements. The Program Operator may seek reimbursement on additional components (not listed in their Department-approved EF Program Operator Plan) AFTER written approval from both the Department and USDA Federal Nutrition Services (FNS).

4.1.3. Components - refer to the Department-approved EF Program Operator Plan and the EF Program Operator Handbook for further details regarding which components are reimbursable to the Program Operator. The Program Operator may seek reimbursement on additional components (not listed in their Department-approved EF Program Operator Plan) AFTER written approval from both the Department and USDA Federal Nutrition Services (FNS).

4.1.4. Any changes or adjustments to your Program Operator Plan will require approval from the Department, and an update to the Colorado SNAP Employment and Training State Plan for Food and Nutrition Services approval.

5. CASE MANAGEMENT REQUIREMENTS

5.1. The Program Operator must provide case management services to all EF clients. Case management services must include the following:

5.1.1. A comprehensive employability assessment. The comprehensive employability assessment is to be completed at the initial case management appointment and at least once a year (ongoing employability assessments are recommended). A Department-approved comprehensive employability assessment is provided on the Employment First website. The Program Operator may use their own comprehensive employability assessment with written approval from the Department.

5.1.2. Individualized service plans (ISP). ISPs are to be individualized to the client, developed in partnership between a client and case manager, and updated/revisited at every case management appointment. A new ISP must be developed once every 120 days. A Department-approved ISP is provided on the Employment First website. The Program Operator may use their own ISP with written approval from the Department.

5.1.3. Progress monitoring through case comments (attempted contact and contact with the client). Progress monitoring through case comments are to be completed at least once a month. Refer to the Employment First Data Entry Desk Aid for further details on what should be included in a good, high-quality, and detailed case comment.

5.1.4. Coordination with and referrals to other employment and training service providers, when applicable (must be developed and revisited when the individualized service plan is developed).

5.1.5. The Program Operator must conduct follow-up attempts (through email, phone, or written notification) for at least 60 days before closing the client’s case (i.e. Plan, Activities and Case Comment) when the client has stopped engaging in program services.

5.2. Documentation for all case management services and activities must be retained in the client’s physical program file and the Colorado Benefits Management System (CBMS), as outlined in the EF Program Operator Handbook.

5.3. All forms of case management services, communication, and activities must be entered into CBMS within 14 days of service delivery, and no later than the 6th of the following month, as outlined in the EF Program Operator Handbook.

5.4. Refer to the EF Program Operator Handbook for further details on case management services and expectations.

6. PERFORMANCE REQUIREMENTS

6.1. Data Entry and CBMS Access

6.1.1. The Program Operator shall use CBMS for all reporting of programmatic activity. These programmatic activities include, but are not limited to:

1. verifying client EF program eligibility

2. client activities

3. client attendance hours

4. client participant reimbursements

5. client employment and credential outcomes

6. client case comments

6.1.2. Failure to report all programmatic activity for clients in CBMS by the 6th of each month (for services rendered in the previous month) could result in delayed approval of logs, delayed or denial of invoice payment, and denial of a contract extension for the next program year.

6.1.3. The Program Operator shall use CBMS reports to manage the data entry workload, ensure data entry completion by the 6th of each month (for services rendered in the previous month), and determine the number of SNAP clients and services that the Program Operator can request reimbursement for each month. These reports include, but are not limited to:

1. ‘TPP Caseload Report-Interim’ report

2. ‘TPP Caseload Report-Final’ report

3. Other CBMS reports recommended by the Department

6.1.4. The Program Operator will identify at least one staff member who will need CBMS access for all reporting of programmatic activity. The identified staff are to follow the CBMS Access processes outlined in the EF Program Operator Handbook. After access to CBMS is granted, staff are to attend an initial EF CBMS data entry training provided by the Department.

6.1.5. The Program Operator will inform the Department within one business day whenever there are staff changes which impact if the staff should have access to CBMS any longer.

6.1.6. If the Program Operator is unable to use or access CBMS for a reason that is approved by the Department, the Program Operator shall work with the Department to ensure all TPP reporting requirements are met through an alternative method, including but not limited to a Participant Log.

6.2. Invoices and Supporting Documentation

6.2.1. The Program Operator shall accurately report their non-federal contribution to the program every month on the provided invoice and ledger templates.

6.2.2. The Program Operator shall submit supporting documentation, as prescribed by the Department, on a monthly basis via encrypted email, as outlined in the EF Program Operator Handbook.

1. Invoices, ledgers, and required supporting documentation are due by the 15th of each month (for services rendered in the previous month), unless otherwise requested by the Department.

2. Note: Due to the CDHS Accounting timeline, the June invoice is due by June 30th.

6.2.3. If the above days do not fall on a business day, invoices, ledgers, and supporting documentation will be due on the next business day.

6.2.4. If the Program Operator does not plan to submit an invoice, they must inform the Department in writing by the 15th of the month.

6.2.5. If the Program Operator needs an extension to submit their monthly Invoice, they must seek written approval from the Department prior to their submission deadline.

6.2.6. If the Department does not receive the Program Operator’s invoice within 30 days of the invoice’s due date, the Program Operator may forfeit their reimbursement at the Department’s discretion.

6.2.7. Failure to submit Invoices, ledgers, and the required supporting documentation timely, or request for extensions timely, could result in delayed or denial of invoice payment, and denial of a contract extension for the next program year.

6.3. Administrative Holdback Percentage

6.3.1. To help cover state-level oversight and program management, the Department keeps a small percentage of a Third-Party Partner’s federal reimbursement. The percentage held back is based on how much the partner is getting in federal reimbursement—not their total budget. For example, if a Third-Party Partner has a $1,000,000 budget for Employment First and is getting $500,000 in federal reimbursement, they fall into the 1% holdback category. "The Contractor shall remit the full holdback percentage as specified in the approved program budget (“Holdback”). The Holdback obligation applies to all applicable payments made under this Agreement during the program year, regardless of whether the Holdback percentage was established, modified, or implemented through an amendment at any time during the program year. Any holdback amounts not previously collected shall remain due and payable and may be deducted from future payments. See the table below for details.

6.4. Budget, Budget Amendments, and Performance-Based Allocations

6.4.1. The Program Operator’s initial budget allocation at the beginning of the program year (i.e. October 1) will be a portion of the agreed-upon budget amount from the EF PO Plan. Remaining budget allocations, based on performance, are tentatively scheduled for:

1. January-February

2. April-May

3. July-August

6.4.2. Performance Timeframe Table:

6.4.3. Program Operator may receive remaining budget allocations based on the following performance indicators outlined in the Program Operator Plan:

1. Budget spend-down

2. Clients served

3. Percentage of activities closed with Completed/Unable To Complete outcomes

4. No outstanding findings from Case File Oversight (i.e. findings not closed within 30 days of issuance), and

5. No outstanding Management Evaluations (i.e. findings not closed within 90 days of issuance).

6.4.4. The Department reserves the discretion to reduce or add funding to the existing contract via a contract amendment at any point during the contract period, based on program oversight findings and monitoring.

6.4.5. Any budget modifications, which may include an increase in the average cost/participant, adjusting or moving expenses from one line item to another (ex: Admin to PRM), must be submitted by email and approved by the Department before any changes or adjustments are made to the budget.

6.4.6. Any budget adjustments greater than 10% shift across line items (ex: Admin to PRM) will require the Department’s SNAP E&T Management approval and a contract amendment.

6.4.7. The Program Operator shall provide the Department with an estimate of potential unspent funds for the remainder of the federal fiscal year by April 15, unless otherwise requested by the Department.

6.4.8. EF Program Operators are responsible for budgeting themselves appropriately to ensure the funding lasts through the fiscal year so that they can continue to provide services through the contract term.

6.4.9. Failure to submit invoices and supporting documentation in a timely manner, or to request extensions in a timely manner, could result in invoice payment, and denial of a contract extension for the next program year.

6.5. Quarterly Success Stories

6.5.1. The Program Operator shall provide success stories to the Department at least quarterly:

1. Quarter 1 (October-December) Success Story is due January 31, unless otherwise requested by the Department.

2. Quarter 2 (January-March) Success Story is due April 30, unless otherwise requested by the Department.

3. Quarter 3 (April-June) Success Story is due July 31, unless otherwise requested by the Department.

4. Quarter 4 (July-September) Success Story is due October 31, unless otherwise requested by the Department.

6.5.2. If the above dates do not fall on a business day, the success story will be due on the previous business day.

6.5.3. A Department-approved success story template is provided on the Employment First website. The Program Operator may use their own success story template with written approval from the Department.

6.5.4. Failure to submit quarterly success stories timely to the Department could result in denial of a contract extension for the next program year.

6.6. EF Program Operator Plans and Request For Proposal (RFP)

6.6.1. As a condition of a contract extension, the Program Operator shall provide an updated EF Program Operator Plan, or RFP application, between late spring and mid-summer, as part of the contract extension/renewal process for the next federal fiscal year. Deadlines and expectations for these documents will be communicated with the Program Operator by the Department 60-90 days in advance of the submission deadline.

6.6.2. If the Department does not receive an updated EF Program Operator Plan (or RFP application), or the Department cannot approve the Program Operator’s submitted plan by their internal procurement timeline, the Department will not be able to offer a contract extension for the new federal fiscal year; the Program Operator’s current contract will expire as of the listed Current Contract Expiration Date.

6.6.3. EF Program Operators must adhere to the program design and costs outlined in their approved EF Program Operator Plan (or RFP application).

6.6.4. Contract extensions will occur via a contract amendment and will include an updated budget, Statement of Work, and Exhibits for the new federal fiscal year. Contract extensions are not to exceed three years from the original Contract Performance Beginning Date.

6.6.5. The Program Operator may not be both an Employment First Program Operator (directly funded through the State procurement process) and a Regional-Operated Employment First Program Operator (funded through county/ies Employment First allocation), unless otherwise approved by the Department through the EF Program Operator Plan process.

6.7. Department-led Training and Program Meetings

6.7.1. The Program Operator must have direct service staff in attendance at the Employment First Kick-Off Meeting. This annual training is held at the start of the program year and discusses various topics, including but not limited to: program goals, governance structure, fiscal and budget information, billing process, program design and requirements.

6.7.2. The Program Operator must have at least one staff member in attendance at additional department-led training and program meetings. This may include, but is not limited to:

1. Employment First group training and group technical assistance meetings

2. Employment First Quarterly Forums

3. Department-led Phone-Ins

4. Department-led special projects and initiatives (when appropriate)

6.7.3. If the Program Operator is unsure if or when their staff should attend a department-led training and program meeting, they are to seek guidance from the Program Administrator.

7. OVERSIGHT, MONITORING AND AUDITS

7.1. Oversight: The Department will conduct random spot-checks on CBMS and physical client files and supporting documentation for completion and accuracy throughout the program year. Failure to complete data entry in CBMS, provide supporting documentation, or provide physical client files may result in delayed invoice approval or denial of reimbursement expenses.

7.2. Monitoring: The Department will conduct a Management Evaluation for all program operators contracted with the Department. The Department will conduct the management evaluations either virtually or in person. The management evaluation will include a sample review of SNAP recipients’ files. A report summarizing the management evaluation will be sent to the Program Operator within 14 days following the management evaluation.

7.3. Audit: The Program Operator shall adhere to any additional State and Federal audits that are deemed necessary by the Department.

7.4. The Department will conduct a fiscal review, file reviews, and interviews with the Program Operator and staff as needed in all other contract years.

7.5. The Department will inspect the Program Operator's records to ensure compliance regarding the performance and terms of this Statement of Work, the Department-approved Employment First Program Operator Plan, and the FNS-approved Employment First State Plan as available on the CDHS website.

7.6. The program operator must address or close out Oversight, Management Evaluations, or Audit findings. Unresolved findings may result in denial of a contract extension for the next program year.

8. HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA)

8.1. Federal law and regulations governing the privacy of certain health information require a business associate contract between the Department and the Program Operator. 45 C.F.R. § 164.504(E). Attached hereto and incorporated herein by reference and agreed to by the parties is a HIPAA Business Associate Addendum for HIPAA compliance. Terms of the Addendum shall be considered binding upon the execution of this contract and shall remain in effect during the term of the contract, including any extensions, please refer to (Exhibit #).

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