MR #18.06: Clarifying Student of Higher Education Eligibility Requirements for SNAP

Helping Families. Supporting Communities. Empowering Individuals.

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03/30/18

Summary

  • As a result of a policy clarification received from Food and Nutrition Service (FNS) this manual release is to provide guidance to FCRC staff with regard to the eligibility exemption requirements that a student of higher education must meet to qualify for SNAP participation.
  • Staff should review and discuss the student exemption requirements during the customer's interview to prevent improper denials of customers who may be eligible for an exemption, specifically those individuals who self-initiate enrollment into an employment and training program or are assigned or placed into an employment and training program, including a program under the Carl D. Perkins Career and Technical Education Improvement Act of 2006.

As a result of a policy clarification from Food and Nutrition Service (FNS), this manual release is being issued to stress the importance of reviewing the student exemptions with customers enrolled in a school of higher education to ensure that an accurate determination is made of student's eligibility for SNAP participation.

Definition of Student of Higher 

A customer is considered to be enrolled in an institution of higher education if enrolled in:

  • a business, technical, trade, or vocational school that normally requires a high school diploma or equivalency certificate for enrollment in the course of study; or
  • regular courses, including internet, mail, self-study or correspondence courses at a college or university that offers degree programs regardless of whether a high school diploma is required.

FCRC Action

When interviewing a student, staff are to explain the student eligibility requirements and discuss the student exemptions with the individual to prevent improper denials of students who may meet one of the exemptions, specifically those students who self-initiate enrollment, or are assigned to or placed into an employment and training program.

A customer who is assigned to or placed in an institution of higher education through compliance with the requirements of one of the programs identified below qualifies for the student exemption. A customer who self-initiates or voluntarily participates in one these employment and training programs and is placed in an institution of higher education through compliance with the requirements of the program qualifies for the student exemption.  The programs are:

  • A program under the Workforce Innovation and Opportunities Act (WIOA) of 2014;
  • A program under Section 236 of the Trade Act of 1974;
  • An employment and training program under the Food Stamp Act, such as a TANF Work and Training Program or SNAP Employment and Training Program;
  • An employment and training program for low income households that is operated by a State or local government, including a program under the Carl D. Perkins Career and Technical Education Improvement Act of 2006, administered by a community college that will lead to employment.

Carl D. Perkins Career and Technical Education Improvement Act of 2006

Community colleges offer degree programs and certificates that enhance the employability of an individual or that lead directly to employment.

Staff should determine if the individual is:

  • is attending the community college at least half-time; and
  • pursuing a career or technical education program under the Carl D. Perkins Career and Technical Education Improvement Act of 2006.

Under the Carl D. Perkins Career and Technical Education Improvement Act of 2006, a student identified by the community college as enrolled in a career or technical education program that leads directly to employment meets the requirement of an eligible student for SNAP. If the student meets both of the above eligibility criteria then the exemption has been met. The student must still meet all other SNAP eligibility requirements. Verification may be requested from the community college if the student does not have proof of their enrollment in a career and technical education program.

Student Exemptions

Below are the student exemptions. To be eligible to participate in SNAP, a student who is enrolled at least half time in an institution of higher education must meet at least one of the following exemption requirements:

  • Be under age 18 or age 50 or over.
  • Be physically or mentally unfit.
  • Be working in a paid job an average of 20 hours per week or, if self-employed, working an average of 20 hours per week and receiving weekly earnings at least equal to the Federal minimum wage multiplied by 20 hours.
  • At the time of application, be approved to participate in a State or federally funded work study program during the regular school term and the student must anticipate actually working during that time.
  • Be responsible for the care of a dependent household member under the age of 6 (only one adult may claim this exemption). When there is more than one adult in the home, the student must provide the majority of the child care to meet this requirement.
  • Be responsible for the care of a dependent household member age 6 through 11 and does not have adequate child care available to enable the student to attend class and work an average of 20 hours per week or take part in a work-study program. 
    • child care is adequate and the student is ineligible when the child(ren) is receiving child care at least 24 hours per week (time spent in school does not count as child care); or
    • there is someone in the SNAP unit  age 18 or older, other than the student, who is available to provide the care. A person who is physically or mentally impaired is not available to provide child care.
  • Be a single parent enrolled in a school of higher education and responsible for the care of a dependent child under the age of 12, regardless of the availability of adequate child care.
  • Receiving Temporary Assistance for Needy Families (TANF) under Title IV of the Social Security Act.
  • Be enrolled as a result of participation in the Job Opportunities and Basic Skills program under Title IV of the Social Security Act or its successor program.
  • Participating in an on-the-job training program. A person is considered to be participating in an on-the-job training program only during the period of time the person is being trained by the employer.
  • Self- initiates placement or is assigned to or placed in an institution of higher education through or in compliance with the requirements of one of the programs listed below:
    • A program under the Workforce Innovation and Opportunities Act (WIOA) of 2014;
    • A program under Section 236 of the Trade Act of 1974;
    • An employment and training program under the Food Stamp Act, such as a TANF Work and Training Program or SNAP Employment and Training Program;
    • An employment and training program for low-income households that is operated by a State or local government, including a program under the Carl D. Perkins Career and Technical Education Improvement Act of 2006, administered by a community college that will lead to employment. Some examples of career and technical programs offering certificate or a diploma that will lead to employment are data entry occupations, medical and health care careers, HVAC and refrigeration, hospitality and tourism management.

MEALS ON CAMPUS

This manual release also adds policy to the manual regarding student meal plans/meal tickets that have generated questions from FCRC staff. If more than half (50 percent) of the student's meals per day are provided by the institution, the student is not  eligible to participate in the SNAP. This includes students living on or off campus who buy a meal ticket from the institution. It does not matter if the purchase of the meal ticket is required or by choice.During the interview, staff should discuss with the student the number of meals the student anticipates eating/purchasing on campus and determine whether or not the number of meals purchased exceeds 50 percent of the three meals daily in any given month.

Manual Revisions

[signed copy on file]

James T. Dimas

Secretary, Illinois Department of Human Services

Forms Referenced: