The Workforce Innovation and Opportunity Act (WIOA) is the main federal law for workforce development. It funds a network of American Job Centers where eligible adults, dislocated workers, and youth can get: • Career services – skills and interest assessments, job search help, labor market information, résumé and interview help, career counseling, and referrals to other services. • Training services – occupational skills training, on‑the‑job training, apprenticeships, and other work‑based learning to prepare for in‑demand jobs. • Supportive services – help with things like transportation, childcare, uniforms/tools, or test fees so people can participate in training and keep jobs. Services are delivered mainly through state and local workforce boards and partner agencies at one‑stop centers.
The MOU is an interagency agreement between USDA and DOL; it does not itself change statute or directly impose new legal duties on states beyond existing SNAP and WIOA law. Instead, it commits the two federal departments to: • Develop shared strategies to connect SNAP participants with WIOA employment and training. • Issue joint guidance clarifying when SNAP recipients who join WIOA programs count as “participants” for meeting SNAP work requirements. • Encourage states to use existing flexibilities (including WIOA waivers) to align SNAP E&T and WIOA services. • Provide coordinated technical assistance and jointly review WIOA Combined State Plans that include SNAP E&T. State SNAP and workforce agencies remain legally bound by the underlying SNAP and WIOA statutes and regulations; the MOU shapes how USDA and DOL will interpret, coordinate, and support those programs, rather than creating new enforceable obligations on states.
Based on the MOU and current federal materials, SNAP recipients are not universally required to enroll in WIOA programs to meet SNAP work requirements. Key points: • The MOU says USDA and DOL will issue guidance “clarifying that SNAP recipients must engage as a ‘participant’” if they choose to fulfill SNAP work requirements through a WIOA program; this defines how WIOA participation counts, not a blanket mandate to use WIOA. • SNAP work requirements can still be met through work, SNAP Employment & Training (E&T), other approved work programs, or workfare, consistent with existing ABAWD and general work rules. • States could encourage or route more SNAP recipients into WIOA, but nothing in the publicly available MOU language requires every work‑required SNAP recipient to enroll in WIOA specifically. So WIOA is one qualifying pathway among several, not a compulsory channel for all SNAP recipients.
Under the agreement, states are expected to adjust how their SNAP and workforce systems coordinate, not to create an entirely new program. Anticipated changes include: • Stronger referral and data‑sharing pipelines so SNAP recipients are routinely connected to WIOA career and training services through American Job Centers. • Redesigning SNAP Employment & Training (E&T) to use WIOA‑funded services more, and to structure SNAP E&T components so they look like, or plug into, WIOA activities (e.g., co‑enrolling clients in both programs). • Using allowed flexibilities and waiver requests under WIOA to better align eligibility rules, service models, and performance measures across SNAP E&T and WIOA. • Incorporating SNAP E&T into their WIOA Combined State Plans, which may change how states plan and report on SNAP E&T strategies. These are policy and administrative expectations driven by USDA/DOL guidance and technical assistance rather than explicit new statutory mandates.
WIOA Combined State Plans are multi‑year strategic plans that states can submit to meet WIOA planning requirements for core programs plus certain partner programs—one option is to include the SNAP Employment & Training (E&T) plan as part of that combined plan. • Instead of filing a separate SNAP E&T plan, a state can embed its SNAP E&T strategy and required elements into the WIOA Combined State Plan, subject to both DOL and USDA approval. • The MOU says DOL and USDA will “coordinate the review of WIOA Combined State Plans that include SNAP employment and training, including communication regarding the submission and approval of such plans.” In practice, that means: – USDA’s Food and Nutrition Service and DOL’s Employment and Training Administration review those sections together; and – They try to align feedback and approval timelines so states get one coordinated set of comments rather than conflicting federal directions. Coordination does not change the formal approval standards in law, but it influences how smoothly and quickly states can get combined plans approved.
Publicly available documents do not show specific hard deadlines inside the MOU for: • When USDA and DOL must issue the promised joint guidance; • When joint technical assistance must begin; or • New submission dates for state plans beyond existing WIOA/SNAP planning calendars. Instead, the MOU describes ongoing commitments (“will develop,” “will issue guidance,” “will coordinate”) layered on top of existing statutory and regulatory timelines—for example, the regular four‑year WIOA State Plan and SNAP E&T plan cycles and amendment windows. Without access to the full, text‑searchable MOU from USDA/DOL, no more precise timeline can be confirmed.
The statement about requiring work‑capable individuals to “work, train, or volunteer for at least 80 hours per month” refers to the updated federal work requirement for able‑bodied adults without dependents (ABAWDs) on SNAP. As of late 2025: • Many childless adults ages roughly 18–54 must document at least 80 hours per month of paid work, participation in a qualifying work or training program (such as SNAP E&T or another approved program), or volunteering/workfare to keep SNAP for more than three months in a three‑year period. • USDA’s official guidance explains you can meet the ABAWD work requirement by: working 80 hours/month; being in a work or training program 80 hours/month (including SNAP E&T or another federal, state, or local program); combining work and program hours to total 80; or meeting workfare hours assigned. • States still must apply exemptions written into law (e.g., people who are pregnant, have a disability, have a child under 18 in their SNAP household, are homeless, are veterans, or meet other exception criteria). The MOU links this 80‑hour rule to WIOA by clarifying that if an ABAWD uses a WIOA program to meet the requirement, they must be a formal WIOA “participant” with recorded hours, so their activity can count toward the 80‑hour monthly minimum.