Exhibit F - FFY2026 EF Program Operator Handbook.pdf

Colorado Employment First

FFY2026 Program Operator Handbook

State of Colorado, Department of Human Services

SNAP Employment and Training

Last updated: March 5, 2026

This handbook is a living document and is subject to change throughout the 2026

Federal Fiscal Year.

Table of Contents

Acronyms 1

Summary of Employment First 3

Use of Program Operator Handbook 4

State Employment First Team Directory 4

Program Resources 4

Employment First Funding 4

Employment First Allocation Methodology 6

Employment First Partnerships 7

Partnership with Local SNAP Eligibility Teams 7

Who Is an EF Client? 7

Able-Bodied Adults without Dependents (ABAWDs) 8

Recruitment and Engagement 8

Screening and Referrals to Employment First 9

Provider Determinations (PD) 11

Employment First Program Enrollment 13

Case Management 13

Supportive Payments (Participant Reimbursements) 16

Employment First Job Retention 19

Activity Hour Data Entry 19

Employment First Activities 21

Billing Procedures 24

1575 Sherman St., Denver, CO 80203 P 303.866.5700 cdhs.colorado.gov

Jared Polis, Governor | Michelle Barnes, Executive Director

Third-Party Partner Billing Procedures 26

Colorado Benefits Management System (CBMS) 27

Client Files 28

Record Retention 28

Program Oversight Procedures 28

Forms and Resources 29

Acronyms

Below is a list of common acronyms.

Acronym Term

ABAWD Able-Bodied Adult Without Dependents

CBMS Colorado Benefits Management System

CCCAP Colorado Child Care Assistance Program

CDHE Colorado Department of Higher Education

CDHS Colorado Department of Human Services (this acronym is for the Colorado State

Department of Human Services, not the County Human Services Departments)

CDLE Colorado Department of Labor and Employment

CFMS County Financial Management System

CFR Code of Federal Regulations

CUBS Colorado Unemployment Benefits System

CWDC Colorado Workforce Development Council

DHS Department of Human Services (this acronym is for County Human Services

Departments, not the Colorado State Department of Human Services)

DVR Department of Vocational Rehabilitation

DEWS Division of Economic and Workforce Support

EF Employment First

EF PO Employment First Program Operator (includes county human services departments and Third-Party Partners)

E&T Employment and Training

EW Eligibility Worker

FAFSA Free Application for Federal Student Aid

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FDPIR Food Distribution Program on Indian Reservation

FEAD Food and Energy Assistance Division (the CDHS Division that supervises

Colorado’s SNAP program)

FFY Federal Fiscal Year

FNS Food and Nutrition Services

GA General Assistance

ISP Individualized Service Plan

ITO Indian Tribal Organization

LMI Labor Market Information

LOE Level of Effort

MCJ My Colorado Journey

ME Management Evaluation

NOA Notice of Action

NOAA Notice of Adverse Action

OIT Office of Information Technology

OJT On-the-Job Training

PR Participant Reimbursement

PD Provider Determination

RMWDA Rocky Mountain Workforce Development Council

SJS Supervised Job Search

SNAP Supplemental Nutrition Assistance Program

SOW Statement of Work

SUIT Southern Ute Indian Tribe

TANF Temporary Assistance for Needy Families

TPP Third-Party Partner

UMUT Ute Mountain Ute Tribe

USDA United States Department of Agriculture

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USDOL United States Department of Labor

WF Workfare

WIOA Workforce Innovation and Opportunity Act

WBL Work-based Learning

WDP Workforce Development Program

Summary of Employment First

Federal regulations governing the Supplemental Nutrition and Assistance Program

(SNAP) require that all states provide employment and training services to SNAP recipients.

Employment First (EF), Colorado’s SNAP Employment and Training Program, helps

SNAP applicants and recipients in Colorado connect to meaningful employment and succeed in the pursuit of economic well-being.

EF is a State-supervised, county-administered program. Federal regulations, State statutes, and State rules provide the administrative code of operation for all human service programs in the State, including EF. The Colorado statute outlines the county administration of human services programs and the parameters of State-supervision and county administration (Title 26, C.R.S.).

The State Board of Human Services promulgates the regulations for the EF program;

additional guidance is provided through policy, training, and technical assistance.

The EF program is voluntary; there are no mandatory participation requirements.

However, federal regulations require some Able-Bodied Adults without Dependents

(ABAWD) SNAP recipients to register for work and participate in approved activities to maintain their SNAP eligibility. ABAWD SNAP recipients can meet the participation requirement through EF’s approved employment and training activities.

Colorado county DHS and TPPs are required to submit a plan for program operation to

CDHS for review and approval on an annual basis, as outlined in 10 CCR 2506-1 Rule

Manual Volume 4.312.1. Plans must adhere to all applicable rules and regulations

(such as providing case management and at least one E&T component) and, within those parameters, may be locally tailored based on resources, community needs, and available community partnerships. County DHS and TPP plans are consolidated into a unified EF State plan. County DHS and TPPs are referenced as EF POs when policy and sections within this handbook apply to both County DHS and TPP operators. EF POs receive face-to-face training that provides detailed instructions and examples of common and rare case actions.

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Use of Program Operator Handbook

The EF Program Operator Handbook details a standard set of policies and guidelines for delivering and documenting EF program services and expenses. This handbook does not cover every situation or scenario that a provider may encounter in their day-to-day case management activities. This handbook is updated annually, or as needed.

State Employment First Team Directory

Rebecca Balu Administrator of Strategic

Partnerships rebecca.balu@state.co.us

Meryl Perlman SNAP E&T Supervisor meryl.perlman@state.co.us

Ashley Caldwell Strategic Partnership

Advisor ashley.caldwell@state.co.us

Brad Smith E&T Program Lead bradley.d.smith@state.co.us

Kasey Strube E&T Program Coordinator kasey.strube@state.co.us

Jessica Johnson E&T Program Coordinator jessica.johnson@state.co.us

Isabella “Bella”

Colletti

Partner Liaison isabella.colletti@state.co.us

Teri Hardy Partner Liaison teri.hardy@state.co.us

Shenshakea

"Shakea" Sanders

Public and Private

Partnership Administrator shenshakea.sanders@state.co.us

Program Resources

EF POs, community partners, and clients may learn more about Colorado’s EF program on our website.

The EF program partner data dashboards are designed to highlight the important impact of EF POs’ work each year. They track how program activities help clients build skills, complete training, earn certificates, and secure lasting employment.

Monthly case management data is also included, giving EF POs a clear view of how their program is progressing in meeting key requirements.

General EF program questions can be sent to the DEWS policy inbox at:

CDHS_DEWS_Policy_Inbox@state.co.us

Employment First Funding

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The EF budget consists of four funding streams, each unique in what it can be used for and when it should be expended. Beginning in July each year, Colorado begins to receive federal allocations to operate the EF Program and passes a majority of the funding to EF POs. In addition to federal funding, Colorado’s Long Bill appropriates

$187,834 for State Program Administration of the EF program and $78,435 for reimbursements (80/20).

Please note, time spent assisting clients in applying or reapplying for SNAP benefits is not allowable with SNAP E&T funds and cannot be reimbursed.

Funding Stream Funding Source Begin Date End Date

100% Administrative funding Federal October 2025 September 2026

50/50 Administrative

Reimbursement funding

Federal/EF PO October 2025 September 2026

50/50 Participant

Reimbursement funding

Federal/EF PO October 2025 September 2026

80/20 Participant

Reimbursement funding

Federal/State/

EF PO

July 2025 June 2026

Allowable Expenditures by Funding Stream

1. 100% Administrative

100% Administrative funding can be spent during the FFY (October -

September). The funding stream consists of federal funds only. 100%

Administrative funds are allocated to county human services departments based on the number of work registrants. While not required, it is strongly suggested that counties spend these funds first.

100% Administrative funding can be spent on any allowable purpose in the operation of the EF program, including:

● EF program marketing

● Staffing and overall planning, implementation, and operations

● Direct program expenses, such as:

○ Case management services

○ Administrative functions, such as working on reports and attending training

2. 50/50 Administrative Reimbursement

50/50 Administrative Reimbursement funding can be spent during the FFY

(October - September). The funding stream comprises 50 percent federal funds and 50 percent EF PO funds.

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50/50 Administrative Reimbursement funding can be spent on any allowable purpose in the operation of the EF program, including:

● EF program marketing

● Staffing and overall planning, implementation, and operations

● Direct program expenses, such as:

o Case management services o Administrative functions, such as working on reports and attending training

3. 50/50 Participant Reimbursement

50/50 Participant Reimbursement can be spent during the FFY (October -

September). The funding stream comprises 50 percent federal funds and 50 percent EF PO funds.

50/50 Participant Reimbursement funds can be spent on participant expenses that are reasonable, necessary, and directly related to participation in employment and training activities (also known as supportive payments).

Please reference the Supportive Payments section of this handbook for allowable participant reimbursement expenses.

4. 80/20 Participant Reimbursement

80/20 participant reimbursement funding is available from July to June every year. These participant reimbursement funds are allocated to county human services departments to help partially cover the cost of reimbursing EF clients for necessary expenses tied to program participation. The naming convention of "80/20" represents 50% federal dollars ($130,725), 30% State dollars

($78,435), and 20% county dollars ($52,290).

Employment First Allocation Methodology

Colorado allocates EF funding using different approaches for county human services departments and TPPs.

Historically, Colorado allocated EF funding only to county human services departments. These allocations were based primarily on each county’s number of

SNAP work registrants, and counties directly provided employment and training services to eligible SNAP applicants and recipients.

In 2019, Colorado expanded its EF funding model to include non-county service providers. Through a competitive bidding process, Colorado began awarding 50/50

Administrative reimbursement funding and 50/50 Participant Reimbursement funding to qualified non-profit, for-profit, and private organizations. These entities, referred to as Third-Party Partners (TPPs), provide employment and training services or have

Last updated: March 5, 2026 6 the capacity to do so in coordination with counties. TPPs enhance service delivery by expanding capacity and helping engage additional eligible SNAP work registrants.

For FFY2026, Colorado will continue to allocate EF funding to county human services departments based on the number of SNAP work registrants and the budgets submitted through the annual EF PO Plan. Counties may receive 100% Administrative funding, 50/50 Administrative funding, 50/50 Participant Reimbursement funding, and

80/20 funding.

TPPs will continue to receive 50/50 Administrative funding and 50/50 Participant

Reimbursement funding EF funding through the budgets submitted with annual EF PO plans and, when appropriate, the competitive bid process.

Employment First Partnerships

The EF program funds 16 county DHS and 22 TPPs that generate local partnerships among workforce centers, community colleges, foundations, employers, etc. The focus of each partnership is to enhance wrap-around services and increase the employability upskilling of EF clients.

Partnership with Local SNAP Eligibility Teams

EF POs are required to develop and maintain working relationships with county SNAP eligibility teams. This can be accomplished informally through email, phone calls, or in-person meetings. However, the communication between the EF PO and the county

SNAP eligibility team must be documented through detailed case comments in CBMS

(date of the communication, communication method, and the result of the communication).

Required communication that must be documented in CBMS includes screening and referrals, regain, and provider determination actions.

Who Is an EF Client?

An EF client is a SNAP applicant or recipient who has been screened by a SNAP eligibility technician to participate in the program, has an active program plan, is enrolled in a program activity, and has been offered supportive payments. An EF client may or may not be subject to the SNAP work requirement. Individuals who are exempt from the SNAP work requirement may still participate in EF if they fall within the populations served by an EF PO.

Colorado’s EF program prioritizes serving Able-Bodied Adults without Dependents

(ABAWDs). However, EF clients may include other priority populations such as single parents, veterans, and individuals experiencing homelessness.

To be enrolled and remain engaged in the program, EF clients must be able to participate in program activities for a minimum of 12 hours per month, engage in

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Able-Bodied Adults without Dependents (ABAWDs)

ABAWDs have a work requirement that requires them to engage in an approved work program (current federally-approved work programs are the Workforce Innovation and

Opportunity Act [WIOA], Veteran Employment and Training programs, and Employment

First), work, volunteer, or attend training or school for at least 80 hours a month to receive SNAP benefits. When ABAWDs do not meet their 80-hour work requirement in a month, they may accrue a countable month. When an ABAWD accrues three countable months, they may no longer be eligible for SNAP in a three-year period. As such, ABAWDs must be prioritized in EF recruitment efforts, case management services, and hour/activity tracking in CBMS. This supports ABAWDs in meeting their work requirement and supports ABAWDs' success in the EF program.

EF POs must communicate with SNAP eligibility teams when they become aware of any changes affecting an ABAWD’s work requirement or of ABAWD countable months.

If an ABAWD does not meet their work requirement but has a reason for not doing so, such as a potential exemption to the work requirement, the EF PO must refer the

ABAWD to the SNAP eligibility team to be rescreened.

Recruitment and Engagement

EF POs are responsible for recruiting and engaging SNAP applicants/recipients and providing training and employment opportunities. EF POs need to provide a summary of EF services available and ensure clients are offered reasonable and necessary supportive payments. EF services and supportive payments must be marketed during all SNAP eligibility interviews. EF POs should effectively develop internal processes to market EF services and supportive payments. EF POs may use the promotional flier template provided by CDHS and are responsible for amending and maintaining the

“For more information” section of the promotional flyer. The “For more information” section of the promotional flyer will contain the EF PO logo, EF PO’s contact information, and other relevant information (such as upcoming job fairs and new supportive payments) so SNAP applicants/recipients can contact the EF program to engage with the services offered. (See SNAP and Employment First Roles and

Responsibilities: Memo April 2023)

EF POs must establish an effective follow-up process when a client is referred to EF and communicate to SNAP eligibility teams when a SNAP applicant/client enrolls in the EF program. EF POs are required to develop and maintain working relationships with county SNAP eligibility teams. This can be accomplished informally through email, phone calls, or in-person meetings. However, the communication between the

EF PO and the county SNAP eligibility team must be documented through a detailed case comment in CBMS (date of the communication, communication method, and the result of the communication).

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Time spent assisting clients in applying or reapplying for SNAP benefits is not allowable with SNAP E&T funds and cannot be reimbursed.

In addition to the promotional flyer, EF POs may develop additional recruitment and engagement strategies for general recruitment efforts and recruitment efforts for targeted populations, including but not limited to: ABAWDs, individuals experiencing homelessness, single parents, veterans, students, returning citizens, etc. EF recruitment and engagement strategies may include:

● Building community partnerships and sharing the EF POs promotional flyer at agencies such as:

○ Libraries

○ Technical schools

○ Community colleges

○ Family resource centers

○ Food banks

○ Emergency shelters

○ Community-based organizations

○ Workforce centers

● Developing internal referral processes between EF POs and eligibility teams to ensure successful referrals.

Television and Radio broadcasting for the EF program is prohibited and cannot be reimbursed.

Screening and Referrals to Employment First

To ensure consistent implementation of EF services statewide, SNAP eligibility workers and EF POs follow a defined screening and referral process, beginning with the screening conducted by SNAP eligibility workers.

For an effective screening and referral process, EF POs must regularly provide a summary of the services and supportive payments available for SNAP applicants/recipients to all county human services departments in which the EF PO operates.

Screening. Screening is the process used by a SNAP eligibility worker to determine whether an individual should be referred to EF. A SNAP eligibility worker screens for

EF by confirming the following criteria:

1. Age Requirement: 16–17 years old and the head of household, or 18–64 years old.

2. Program Availability: An EF program is operating in the individual’s county of residence.

3. Willing and Able to Participate: The individual is able and willing to participate in EF services after program expectations and client responsibilities are explained.

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Referral. When one or more of the above three screening criteria are met, county

SNAP eligibility workers complete a referral to one or more EF POs. Clients who are not interested in EF services can elect to engage with an EF PO at a later date without having to be rescreened by SNAP eligibility.

Screening and Referral Roles and Responsibilities. The county SNAP eligibility team and EF POs each have their own responsibilities when it comes to screening and referrals.

SNAP eligibility workers are responsible for:

● Conducting EF screening.

● Determining whether the individual meets EF referral criteria.

● Informing individuals of:

○ The purpose of the EF program

○ Available EF activities

○ Allowable supportive payments

○ Program expectations and client responsibilities

● Entering CBMS case comments to document screening and referral actions.

○ The case comment(s) must include two key program actions:

■ 1. The client was screened for the EF program.

■ 2. The client's choice of whether or not to participate in EF.

● If the client would like to participate in EF, document the referral to the appropriate EF PO in case comments.

● If the client is unsure, document in case comments and provide the client with EF resources available in the county in which they receive SNAP benefits.

● If the client declines to participate in EF, document in case comments.

EF POs are responsible for:

● Verifying in CBMS comments that the client was screened by SNAP eligibility using the EF screening criteria before enrolling a client into EF.

● Taking action on referrals within 10 business days of receipt.

○ Action includes contacting the referred individual to schedule an orientation or initial appointment in order to initiate EF services.

● Providing program orientation and explaining:

○ Program mission

○ Available activities

○ Allowable supportive payments

○ Program expectations and client responsibilities

● Regularly providing county human services departments with a summary of available EF services and supportive payments.

● Updating the client’s EF Program Status on the Employment First Plan page in

CBMS.

● Entering CBMS case comments to document all actions and communication related to EF referrals.

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○ All attempts to contact a referred client, including those where the EF

PO is unable to reach the client, must be documented in CBMS case comments.

Reverse Referral. At times, a client may meet with an EF PO without first applying for or currently receiving SNAP. In these cases, the EF PO must notify the client over the phone, in person, or in writing that the client must be directed to SNAP eligibility in order to apply for SNAP and be screened for EF. The EF PO has 10 business days to direct the client to a SNAP eligibility team. This is known as a Reverse Referral.

Once the client has applied for SNAP and is screened and referred to EF by a SNAP eligibility team, the EF PO must check CBMS case comments to verify the client has been screened for EF. After these required steps have occurred, the EF PO will follow the regular process of accepting a referral.

Screening and Referral Documentation. EF POs and SNAP eligibility workers are required to enter CBMS case comments to document all steps in the screening and referral process, including all communication.

When an eligibility worker refers a client to EF and the client connects with the EF

PO, the EF PO updates the client’s EF program status to “EF - Referred” and documents a CBMS case comment.

If an EF PO accepts the referral and the client successfully enrolls in EF, the EF PO updates the client’s program status to “EF - Enrolled.” However, if the client chooses not to participate in EF, the EF PO keeps the program status as “EF - Referred” and changes the radio button (“Active EF Participant”) to “No.” Reference the EF Data

Entry Desk Aid and the Employment First Referral Status Memo for more details.

Finally, the screening and referral process includes multiple steps that, when executed properly, ensure that SNAP and Employment First funding streams are used at different stages of the process. To ensure this occurs, please note that EF POs are not responsible for:

1. Determining exemptions for EF clients, including ABAWDs.

2. Application of discretionary or federal waiver exemptions.

3. Entering or correcting accrued ABAWD countable months.

4. Providing clients with SNAP work requirement rights and responsibilities information.

Provider Determinations (PD)

A SNAP applicant/recipient may receive a provider determination (PD) when the EF

PO does not offer the activity or service in which the individual was referred to. For example, an individual is interested in obtaining a CDL license, but the EF PO only offers training in the healthcare industry.

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The EF PO is responsible for maintaining a working relationship with county SNAP eligibility teams to communicate when a SNAP applicant/recipient receives a PD. The

EF PO must inform the County SNAP eligibility team of the PD through a phone call, email, or other written communication (such as a form). The EF PO must enter a CBMS case comment when a PD occurs, including when and how the PD was communicated to the SNAP eligibility team.

Shared responsibilities of the SNAP eligibility team and EF PO:

● Develop and document shared business and communication processes to ensure timely and efficient communication when a PD is made.

County SNAP eligibility team responsibilities:

● Notify the client of the PD within 10 calendar days of receiving notification from the EF PO. This can be accomplished through a phone call attempt or a written notification with contact information for the client to call the county

DHS for further information.

● In instances where the county SNAP eligibility worker cannot obtain the reason for the PD, the worker will continue to act on the PD based on information that they received from the EF PO.

● Inform ABAWDs that:

○ Countable months will not accrue as a direct result of the PD.

○ The ABAWD will not accrue a countable month for the time during which the ABAWD did not receive communication of the PD from the county

SNAP eligibility worker.

● Explain that ABAWDs are still subject to accrue countable months in the month following the PD, and will be ineligible once they have received three countable months within the 36-month period if they are not exempt, do not live in a waived area, or are not meeting work requirements.

● Take one of the following actions that is most suitable for a client with a PD as soon as possible, but no later than the date of the client’s next recertification:

(1) Refer the client to an appropriate EF program;

● Before making this referral, county SNAP eligibility workers must rescreen the individual and reassess for any exemptions.

(2) Refer the client to an appropriate workforce partnership if available;

● Before making this referral, county SNAP eligibility workers must provide information about workforce partnerships (including EF

POs and private community employers/organizations) to assist the client in making an informed decision about whether to participate in the workforce partnership voluntarily.

(3) Reassess all possible exemptions for the client, including but not limited to the physical and mental fitness of the client; or

● Before making this referral, county SNAP eligibility workers must rescreen the individual and reassess for any exemptions.

(4) Coordinate, to the maximum extent practicable, with other Federal, State, or local workforce or assistance programs to identify work opportunities or assistance for the client.

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● If this option is selected, county SNAP eligibility workers must not require the client to participate in the EF program.

EF PO responsibilities:

● Update CBMS within 10 calendar days of notifying eligibility of the PD.

● Close open activities in CBMS, provide a detailed case comment on the PD reason, and change the program status to “EF-Provider Determination”.

● Put forth the best effort to work with the client to consider engaging in other program activities, updating the Individualized Service Plan (ISP), or exploring other supportive payment options that may assist the client before making a

PD.

○ These efforts; discussions; and any updates to the ISP, program activities, and/or supportive payments must be documented thoroughly in CBMS.

Employment First Program Enrollment

SNAP applicants/recipients will be considered enrolled in EF once a referral has been documented in CBMS by SNAP eligibility, received from the EF PO, and the following steps have been taken:

● The client and EF PO complete a comprehensive employability assessment.

● The client and EF PO develop an ISP based on the results of the comprehensive employability assessment, and the results are entered into CBMS.

● The client and EF PO agree that the client is able to participate in an EF activity (see Employment First Activities section for more details), and the activity is reflected on the ISP and entered into CBMS.

● The client is enrolled in case management and at least one allowable EF activity. Clients must participate in at least 12 hours per month across all activities and case management to meet the Level of Effort (LOE) program requirement.

● The EF PO offers or issues the client a reasonable and necessary supportive payment for the client to access the program.

Case Management

EF POs must provide at least one hour of case management services per month to all

EF participants, including comprehensive employability assessments, ISPs, progress monitoring, coordination with service providers, and reassessments. EF PO workers must meet with clients individually or in a group setting. This can occur in person, virtually, over the phone, or via email. All case management hours must be documented on the Attendance tab in CBMS.

CBMS must be used as the system of record for all case management services and documentation. All forms of case management, screening and referral, enrollment, attendance hours, and communication with the client must be documented in CBMS within 14 days of service delivery, and no later than the 6th of the following month.

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Time spent in case management services can be rounded up to one hour (or more if applicable). For example, if an EF PO worker and client had a scheduled appointment for an hour but only met for 45 minutes to update an ISP, the EF PO worker may round up and document one hour of case management in CBMS.

Case comments must document all program activities, including how the client was introduced or onboarded to the program. EF POs are also required to retain supporting documentation in a client’s case file, including but not limited to the following:

● A signed copy of the comprehensive employability assessment (client and EF PO worker signature, verbal acknowledgment, or electronic confirmation documented in case comments).

● A signed copy of the ISP (client and EF PO worker signature, verbal acknowledgment, or electronic confirmation documented in case comments).

● Any documentation that supports why the client is placed in an EF program activity.

Comprehensive employability assessments must be conducted at the initial case management appointment and at least once every 365 days. The comprehensive assessment must also be signed by both the client and EF PO worker and be retained in the client’s case file. The comprehensive employability assessment must assess at least one of the following:

● applied academic skills

● interpersonal skills

● critical thinking skills

● communication skills

● challenges to access employment

Please refer to your organization’s approved EF PO Plan for the comprehensive employability assessment approved for use during this program year. If the EF PO does not have an approved employability assessment, they may use the State’s

Employment First Employability Assessment or the Spanish Employment First

Employability Assessment.

Individualized Service Plans are individualized to the client, developed in partnership (in-person or virtually) between the client and EF PO worker, updated at least once every 120 days, and must be retained in the client’s case file and added to the client's “My Story” page in CBMS. ISPs must include:

● Measurable, specific short-term and long-term goals that focus on employment, training, and/or education.

● Allowable EF activities that align with short-term and long-term goals.

● Specific client and EF PO worker action items during the 120-day period of the

ISP.

● Signatures (physical signature, verbal acknowledgment from the client and EF

PO worker with a corresponding case comment, or electronic confirmation such as an email) from both the client and EF PO worker.

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● Coordination with and referrals to other employment and training service providers, when applicable, and can include:

○ Referrals to WIOA, Vocational Rehabilitation, Veteran Services, or any other Title I Employment and Training programs.

○ Referrals to community colleges or any other Title II Education program.

○ Education of and referral to appropriate community resources (e.g., food banks, clothing providers, mental health providers, housing providers, etc.).

○ Collaboration with community partners through periodic meetings and communication.

ISPs must be updated at least every 120 days or when the client’s goals or planned activities change.

Progress monitoring check-ins must include a case comment, even if the progress monitoring check-in is an attempt to follow up with the client. Progress monitoring case comments must be documented in CBMS at least once a month (monthly meetings held virtually or in-person, phone calls, correspondence via email, or attempted contacts to re-engage a client).

A detailed case comment must include:

● The date that the communication, attempted contact, or meeting/action

(referral, outreach, ISP, progress monitoring, coordination with other service providers, supportive payments, and job retention service) was conducted.

● A summary of the case management meeting; client's progress in the EF activities in which they are enrolled; and any goals, barriers, and challenges completed/identified for the EF client.

● Resources (approved volunteer sites, clothing, informational flyers) provided or offered during the case management meeting.

● Supportive payments offered (and if they were issued or denied) during the case management meeting, including why the supportive payment was reasonable and necessary to participate in the program (see the

Supportive Payments section for more details).

● Any referrals made to other service providers during the case management meeting on behalf of the client. Examples include:

○ Community resources, higher education, or public transportation.

● Next steps, including but not limited to: the next appointment date and time for the EF PO worker and the EF client to meet, and any new objectives/goals for the worker and client.

Below is a blank case comment template that encompasses all required aspects of a detailed progress monitoring case comment, which EF PO workers may find useful:

1. Date of Meeting:

2. Summary (Activity Progress/Goals/Barriers):

3. Resources Provided (Clothing, Flyers, etc.):

4. Supportive Payments Offered/Issued/Denied (and Reasoning):

5. Referrals to Other Service Providers:

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6. Next Steps (Next Appt., and New Objectives/Goals):

A progress monitoring case comment, even if the progress monitoring is an attempt to follow up with the client, must be documented in CBMS at least once a month.

Unsuccessful attempts to engage clients may indicate the client is no longer interested in the program. In these cases, EF POs must conduct and document in case comments at least two follow-up attempts (through email, phone, or written notification) for at least 60 days before ending a client’s EF plan with the

“EF-Declined Program Service” Program Status for EF-Enrolled clients who have stopped engaging. EF POs can document one hour of case management services for unsuccessful contact attempts.

Supportive Payments (Participant Reimbursements)

EF POs are required to offer to pay for or reimburse SNAP applicants/recipients for all expenses that are reasonable, necessary, and directly related to participation in the

EF program and in finding employment. Federal regulations refer to these expenses as participant reimbursements, but the EF program calls them supportive payments.

These payments are program-funded and can be issued to clients before the initial EF meeting so that the client may begin engaging in program services.

The EF program authorizes the use of multiple types of supportive payments to assist clients in overcoming barriers to employment, such as transportation assistance, rental assistance, tuition, course fees, and work clothing. These supportive payments are identified in each year’s State SNAP Employment and Training Plan and reflected in each EF PO’s annually approved EF PO Plan. EF POs may only offer supportive payments listed in their approved EF PO Plan, and all supportive payments paid for in the FFY must be issued in the same FFY.

Client Notification Requirements. Clients must be informed that supportive payments are available to help them engage and succeed in the EF program and in finding employment. This information must be communicated at multiple points throughout participation, including:

● During the SNAP eligibility and redetermination appointment with eligibility workers.

● At the initial EF case management appointment or program orientation.

● During all ongoing EF program meetings and progress monitoring check-ins.

EF POs must also ensure that clients understand:

● The types of supportive payments that may be available.

● The purpose of the payment is to support participation and employment goals.

● That clients may be required to provide supporting documentation to verify that the supportive payment was spent as intended (receipt, rental agreement, etc.)

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Reasonable and Necessary Supportive Payments. An allowable supportive payment is considered "reasonable and necessary" if it's the kind of expense a prudent person in similar circumstances would spend and is directly related to the client’s participation in the EF program. That is:

● It directly supports the client's ability to participate in EF activities reflected in their ISP.

● It is what someone would normally pay in the same situation.

● The cost is in line with similar program expenses.

● It is an allowable expense reflected in the EF PO's annual plan and EF State

Plan.

● It is not an ongoing expense, but instead, is used to help a client stabilize and engage in EF and is reasonable and necessary to participate in the program.

All issued supportive payments must have a case comment explaining how the supportive payment is reasonable and necessary for the individual to participate in the EF program.

If you are not sure if a requested supportive payment is reasonable and necessary, please contact your Partner Liaison to discuss the request prior to issuing the payment.

Supportive Payment Documentation. Documentation must clearly demonstrate the supportive payment’s purpose and direct link to the client’s EF activity or employment goal.

Documentation must also include:

● the client's name

● type of payment

● amount of the payment to whom the service was paid

● receipt of the payment

● date that the supportive payment was provided, and, if applicable, date that the supportive payment was paid.

EF POs must record all documentation information, including method of disbursement, in CBMS case comments and on the CBMS (Inside or Outside) Supportive

Payments screen to ensure accurate tracking of expenditures within the EF program.

● Inside Supportive Payments tab: For payments issued to a client’s EBT card.

● Outside Supportive Payments tab: For payments issued outside of a client’s EBT card.

EF POs must also retain documentation of receipt, such as client acknowledgment in case comments, vendor invoice, or proof of purchase, to verify that the supportive payment was provided and received.

● If using a receipt form to document that the client received the supportive payment, the receipt form should:

○ Be signed by both the client and the staff member of the organization

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○ Include the client's 1B number

○ Include the type of supportive payment provided and its value/cost

● For supportive payments issued on an EBT card, a verbal confirmation from the client with a case comment meets the requirement of documentation.

See the Supportive Payment Documentation Examples (Resource T) for more information.

Allowable Supportive Payment Disbursement Methods. Supportive payments may be issued using any of the following allowable disbursement methods:

Documented on CBMS Inside

Supportive Payments tab

Documented on CBMS Outside

Supportive Payments tab

● Client’s EBT card ● Gift cards (e.g., for transportation, work clothing, or supplies)

● Vouchers redeemable for specific goods or services

● Direct payment to vendors (e.g., employers, landlords, or training providers)

EF POs must ensure that all disbursement methods align with their internal fiscal procedures. If an EF PO needs to use an alternative disbursement method that is not listed above, please contact your Partner Liaison for approval.

Supportive Payment Limits. Supportive payment costs must not exceed the maximum amount established in each EF PO’s approved EF PO Plan. These limits ensure consistency, fiscal accountability, and alignment with the funding available to each EF

PO.

If a supportive payment exceeds the cost limit listed in the EF PO Plan, it must receive prior written approval from the EF PO Director or Designee before the payment is issued. Documentation of this approval must be maintained in the client’s case file and fiscal records.

Missing Verification or Receipts. Verification that a client received a supportive payment is considered “missing” when a monetary value is exchanged for goods and/or services and a receipt or acknowledgment was requested but failed to be returned. If a client fails to submit a receipt, EF POs must document the attempts in

CBMS case comments to encourage the client to return the receipt or acknowledge receipt of the supportive payment.

Incentives and Stipends. Incentives and stipends are not allowable expenditures under the EF program. This means that EF POs cannot issue payments to clients as a reward for completing an activity, internship, or training component.

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Employment First Job Retention

EF POs must offer job retention services to clients who secure employment (a new job or promotion within their existing job) after enrolling and participating in the EF program. Job retention services are available even after a client's SNAP case has closed due to income.

Please note, there are times when an individual is leaving SNAP due to a failure to comply with the general work requirement or an intentional program violation. In these instances, the client cannot receive job retention services, even if they secured employment after enrolling and participating in EF.

Job retention services include job coaching and assistance that support resolving any barriers that may affect employment. Clients may also receive supportive payments for necessary expenses directly related to job retention, such as clothing required for work, job-related equipment or tools, transportation, and childcare.

Clients enrolled in the Job Retention activity are required to complete a minimum of one hour per month in job retention services and one hour per month in case management to meet the LOE program requirement. This specific LOE is only applicable to clients enrolled in the Job Retention activity.

EF POs are expected to make a good-faith effort to offer at least 30 days of job retention services to eligible clients. This includes informing clients about the 30-day minimum requirement, opening a Job Retention activity in CBMS, and developing a

Job Retention ISP in CBMS that extends for at least 30 days.

Note: There is no limit to the number of times an individual may receive job retention services, as long as the individual has re-enrolled and participated with the

EF Program before obtaining new employment.

For a visual aid with information on determining when a client can receive job retention services, for how long, and how to navigate this in CBMS, see the Job

Retention Decision Tree (Resource R).

Activity Hour Data Entry

EF POs must track and enter all activity hours completed by clients into CBMS.

Activity hours must be entered by the 6th of each month for the previous month.

Level of Effort. All EF clients are required to complete a minimum of 12 hours per month, which must be tracked and entered in the CBMS Attendance screen, in case management and at least one EF allowable activity. This requirement is referred to as

Level of Effort (LOE). All EF clients, including ABAWDs, are required to meet this

12-hour LOE each month.

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During a client’s first month in the EF program, the EF PO must support the client in working toward the LOE requirement. By the second month and beyond, the EF PO must ensure that the client is meeting the LOE.

Moreover, the LOE hour minimum is adjusted for clients enrolled in the Job Retention activity. These clients must complete at least one hour per month in job retention services and one hour per month in case management.

When a client cannot meet the LOE, EF POs must document in CBMS case comments the challenges faced by the client that led to them being unable to complete this EF program requirement. Any exceptions for not meeting the LOE should be rare and only considered for extenuating circumstances.

SNAP ABAWD Work Requirement. ABAWDs can maintain their SNAP benefits by working, training, or volunteering for at least 80 hours per month. This can include paid work, unpaid work (volunteering), participation in Colorado’s Employment First program, or participation in another employment and training program.

The hours from the LOE requirement of at least 12 hours per month in case management and at least one EF allowable activity count toward the SNAP ABAWD work requirement.

● For example, in one month, if a client completes one hour of case management, 11 hours of Adult Basic Education, and 68 hours of part-time job, then this client has met both the 12-hour LOE and 80-hour SNAP ABAWD work requirement.

When an ABAWD is meeting their work requirement through a combination of EF activities and their own work efforts outside of EF, EF POs must open an Activity for

Work Requirement in CBMS, along with any existing allowable EF activities in which the ABAWD is participating. EF POs are responsible for entering attendance hours for

Activities for Work Requirement whenever a client is an ABAWD.

Activities for the SNAP ABAWD Work Requirement include:

● Full-Time Job: When your client is working for an individual or entity in exchange for a wage or salary, for 30 hours or more per week, in either long-term employment or temporary employment.

● Part-Time Job: When your client is working for an individual or entity in exchange for a wage or salary, for less than 30 hours per week, in either long-term employment or temporary employment.

● Temporary Job: When your client is either:

○ Working for an individual or entity in exchange for goods or services (for something other than money);

○ Working for an individual or entity without the exchange of a wage, salary, goods, or services; or

○ Volunteering their time and/or labor for an entity, either for an event or on an ongoing basis

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● WIOA: When your client is participating in the WIOA program or Veteran

Program.

11/9 Rule. All EF activities count toward the SNAP ABAWD Work Requirement.

Supervised Job Search (SJS) may be included as part of those hours, as long as it makes up less than half of the 80 required hours in a month. This is known as the 11/9

Rule.

What to Do When SNAP ABAWD Work Requirement Hours are Incomplete. At times, an ABAWD client may be unable to meet their 80-hour work requirement, whether it is from an extenuating circumstance or the client failed to complete or submit hours to their EF PO worker during the month. EF POs must notify the client and document this in a CBMS case comment.

An example of an appropriate CBMS case comment is: “Client was unable to meet their 80-hour SNAP ABAWD Work Requirement for the month of February due to losing access to transportation. Notified the client via email that these hours are incomplete for the month.”

Why It Is Important to Report Work Requirement Hours. Failure to enter hours by the 6th of the month can put an ABAWD client at risk of losing their SNAP benefits. If any extenuating circumstances prevent activity hour entry by the 6th of the month, EF POs must communicate with the appropriate county’s SNAP eligibility team immediately and then document in CBMS case comments. EF POs must document any late data entry or when a client does not report activity hours in a timely manner.

Employment First Activities

All EF clients must be enrolled in case management and at least one allowable EF activity, which are defined below.

1. Case Management

a. Meet with clients (individually or in a group setting) as they engage in the EF program. This can occur in person, virtually, over the phone, or via email. All EF clients must receive at least one hour per month of case management. These services include comprehensive employability assessments conducted at least annually, ISPs updated at least once every 120 days, monthly progress monitoring, and coordination with and referrals to other service providers.

b. Please note that case management alone is not considered an allowable

EF activity. EF clients must be enrolled in both case management and an allowable EF activity.

2. Adult Basic Education

a. Pre-GED basic skills education for clients who test between 5.5 and

8.5-grade level to increase skill level and attain a GED. Homework may also be assigned and counted for participation hours.

3. Career and/or Technical Education (CTE) and…