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NYS Office of Temporary and Disability Assistance- TA and SNAP Employment Policy Manual

Section 385.11 – Page 17 Rev. 3/2022 SNAP E&T sanction would be imposed consistent with 18 NYCRR §385.12. SNAP benefits for the remainder of the SNAP household must be determined. Q.4 Does the SNAP conciliation process apply to non-exempt SNAP recipients who are subject to SNAP work requirements who are concurrently receiving TA benefits? A.4 Yes, because in New York State individuals receiving both TA and SNAP benefits are mandatory participants for SNAP employment and training assignments. Therefore, when a TA/SNAP recipient is assigned to a work assignment, failure to comply results in a TA sanction and a SNAP sanction unless the individual is exempt from SNAP work requirements. SNAP work registrants who also receive TA benefits and fail to comply with a concurrent TA/SNAP work requirement must be offered the opportunity to demonstrate compliance to avoid the SNAP sanction. The same procedure must be followed for individuals receiving TA and receiving SNAP benefits on a SNAP-Mix case. For example:

A non-exempt work registrant individual who is receiving TA and receiving SNAP on a SNAP-Mix case is considered a mandatory participant for SNAP employment and training assignments. The non-exempt work registrant would be subject to the TA and SNAP work requirements and would be issued a joint TA/SNAP conciliation notice. However, if it is determined that the individual willfully and without good cause failed to comply with the assigned work requirement and the individual does not demonstrate compliance with a SNAP work activity to the satisfaction of the district, the worker outside of NYC would need to issue separate Notices of Intent to impose a TA employment sanction on the TA case and a SNAP E&T sanction on the SNAP-Mix case. Separate notices are required outside of NYC because the TA and the SNAP benefits are issued through separate case numbers. TA and SNAP benefits for the same household are generally issued on the same suffix in NYC, except for multi suffix cases. For a household greater than one (and is not a multi- suffix), the worker at the NYC HRA Job Center would enter the information on the Client Notices System (CNS) to generate the sanction notice and complete the transaction on WMS to implement both the TA and SNAP sanction. For single individual households, the worker at the NYC HRA Job Center would enter the information on the Client Notice System (CNS) and complete the transaction on WMS to send the Notice of Intent and implement the TA sanction and then process a separate determination for SNAP benefits. If the individual does not document good cause or an exemption from SNAP work requirements and does not timely demonstrate compliance with an assigned SNAP work activity to avoid the SNAP sanction the separate determination may be used to generate the Notice of Adverse Action to impose the SNAP sanction consistent with 18 NYCRR 385.12. Q.5 Can districts extend the opportunity to avoid a SNAP sanction by demonstrating program compliance to individuals who are subject to sanction for failure to comply with TA employment requirements?