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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 Activities 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 Work Requirement include: ● In-Kind/Volunteer Work: When your client works for an individual or entity for goods or services (for something other than money) OR volunteers their time and/or labor for an entity, either for an event or on an ongoing basis. This is for in-kind/volunteer work where wages are not expected. ○ The Volunteer Verification Form must be completed by the organization or individual for whom the client is volunteering and then submitted by the client to the EF PO. The EF PO must store the completed form in the client’s case file. ● Paid Work: When your client works for an individual or entity for a wage or salary. ● Qualifying Work Program: When your client is participating in a qualifying work program other than SNAP E&T (Employment First) or Temporary Assistance for Needy Families (TANF), also known as Colorado Works (CW). Examples of a qualifying work program include: Last updated: July 9, 2026

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