WAG 03-04-03-b: Eligible Students of Higher Education

PM 03-04-03-b

Follow the steps below to determine if a student meets the special student eligibility requirements:

Determination of Special Student of Higher Education Exemptions	Student Eligibility  Requirement Questions	Response to Questions/    Action to Take
Step 1:	Is student enrolled in a school of higher education halftime or more? PM 03-04-03-a "Definition of Student of Higher Education."	If Yes, go to Step 2 If No, the person's status as a student does not affect their eligibility for SNAP. Determine eligibility using their income/assets and include them in the SNAP unit
Step 2:	Are more than half (50 percent) of the student's meals per day provided by the institution of higher education?	If Yes, the student is not eligible to participate in SNAP, regardless of meeting a student exemption. 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. If No, go to Step 3.
Step 3:	Does the student meet one of the special student eligibility requirements? PM 03-04-03-b "Eligible Students of Higher Education."	If Yes, the person's status as a student does not affect their eligibility for SNAP. Determine eligibility using their income/assets and include them in the SNAP unit. If No, the student is a non-SNAP unit member PM 04-05-06 "Non-SNAP Unit Members."  Do not include them in the SNAP unit and do not count their income/assets. PM 05-04-01 "Income and Assets."

The following information further clarifies the special student eligibility requirements:

Work in a Paid Job

The student must work in a paid job an average of 20 hours per week. If self-employed, work an average of 20 hours per week and receive weekly earnings at least equal to the federal minimum wage multiplied by 20 hours (see WAG 25-06-08);

Example: Ms. S works 10 hours the first week in February. The following week she works 30 hours. The third week, Ms. S is only able to work 15 hours. She then works 25 hours the last week of the month. Ms. S meets the student eligibility requirement of working an average of 20 hours per week.

Approved for Work Study and Anticipates Working

The student must be approved to participate in a state or federal work-study program at the time he/she applies for SNAP benefits and the work study must be approved for the school term and the student must anticipate actually working during that time;

Example 1: Mr. B, a full-time student at a local college, applied for SNAP 01/10/21. He has been approved to work in a state work-study program that will begin January 21st per his statement. Mr. B meets the special student eligibility requirements for the school term. No special verification is required.

Example 2: Ms. Q, a full-time student, takes internet courses from DuPage College. She is approved for a federal work-study program, but the school has no slots available. She does not meet the special student eligibility requirements.

Eligible to Participate in Work Study

A student who does not meet the existing work study exemption above can still qualify for SNAP if eligible to participate in a state or federal work study program (as determined and verified by the school) at the time he/she applies for SNAP benefits.

Exempt students under the existing student work study exemption who are meeting the requirement by working in a state or federal work study program or who are anticipating working during the school year because there are jobs available.

COVID-19 Temporary Student Exemptions

Due to the ending of the public health emergency, the two temporary student exemptions are being phased out. See temporary exemptions, initial application and REDE processing procedures below.

Eligibility for Temporary Exemption

Eligibility for a temporary student exemption is based on the application filing date and not when the application is processed.

Eligibility for a temporary exemption should be determined when a student does not meet a regular student exemption and has filed or has a pending:

Initial Applications filed or Pending by 06/09/2023

For initial SNAP applications filed by 06/09/2023 or pending as of this date, determine if a student who does not meet a regular student exemption qualifies for a temporary student exemption.

Initial Applications filed on 06/10/2023 & After

Effective with initial applications filed on 06/10/2023 and after, determine student eligibility using only regular student exemptions. All students who file an initial application on 06/10/2023 and after must meet a regular student exemption to be eligible for SNAP.

Example1: Mr. B, a full-time student at a local college, files an initial SNAP application on 06/10/2023. He has been approved to work in a state work-study program that will begin 06/25/2023. Mr. B meets the special student eligibility requirements for the school term. Verification is not needed, unless questionable.

Example 2: JT is applying for SNAP on 06/11/2023 and is a full-time student at Olsen Community College. He has been approved to work in a state work study program during the school term but does not currently have a job. JT states during the interview that there are job slots available and he anticipates getting one of the jobs during the school term. JT meet the special student eligibility requirement for the school term. Verification is not needed, unless questionable.

Example 3: Ms. Q files an initial SNAP application on 06/10/2023. She is a full-time student, and takes internet courses from DuPage College. She is approved for a federal work-study program, but the school has no slots available. She does not meet the special student eligibility requirements under regular SNAP rules. FNS guidelines do not allow a temporary exemption to be granted for initial applications filed on 06/10/2023 and after.

Active Cases with Students

• All students who are currently active for SNAP and were determined eligible for benefits using one of the temporary student exemptions retain their exemption until the next redetermination (REDE). No action should be taken to change the student's temporary status during the certification period or at the interim Mid-Point Report.
• If an active SNAP household reports during the certification period that a member has enrolled in a school of higher education, determine if the student meets student eligibility requirements using the regular exemptions only. Do not allow a temporary exemption.

REDE Applications

The FCRC must base eligibility for the temporary student exemptions on the REDE application date and not the date of processing.

REDE Applications filed by 06/30/2023

For REDEs filed by 06/30/2023 or in pending status as of this date, the FCRC will continue to determine eligibility for a temporary exemption when the student does not qualify for a regular student exemption.

Example: J filed a REDE application on June 25, 2023. He is a full-time student but does not meet a regular student exemption. Because J filed his application before July 1, 2023, the HSC reviews his eligibility for a temporary exemption. The HSC determines that J qualifies for the Expected Family Contribution of $0 in the current academic year exemption. J qualifies for SNAP if all other eligibility requirements are met. If eligible, the HSC uses the work around that was created for the temporary exemption in IES and certifies case for one year. At J's next REDE, a temporary exemption cannot be allowed.

REDE Applications filed Effective 07/01/2023 & After

Effective with REDEs filed 07/01/2023, the FCRCs must determine student eligibility using only regular student exemptions. The student must meet a regular student exemption and all other eligibility requirements to received SNAP.

Example: OB files a REDE application on July 1, 2023. He was previously approved for SNAP because he met a temporary student exemption. The HSC reviews OB's eligibility now and he does not meet a regular student exemption. FNS guidelines do not allow a temporary exemption to be granted for REDE applications filed effective July 1, 2023 and after. OB does not qualify for SNAP. His REDE is denied because he does not meet any of the special student eligibility requirements.

Household Member Becomes Student During Certification Period

Effective 07/01/2023, if an active SNAP household reports during the certification period that a member has enrolled in a school of higher education, determine if the student meets student eligibility requirements using the regular exemptions only. Do not allow a temporary exemption.

Temporary Work Study Exemption

Allow a temporary work study exemption to students who are eligible to participate in a state or federal work study program but are not anticipating working because they have not secured a job. The FCRC must base eligibility for this temporary student exemption on the application date and not the date of processing.

No special verification is needed, unless the student's statement is questionable.

Case Comments

Documentation in Case Comments is important. Use the current exemption in IES, enrolled in a work study program or works more than 20 hours per week, for the temporary exemption. In Case Comments, document the exemption that the student was allowed, whichever is applicable.

Example: Ms. J states she is eligible to participate in a state or federal work study program. There are no jobs available. The HSC determines Ms. J meets all other eligibility requirements for SNAP. The HSC completes the Education Detail Screen in IES and documents in Case Comments that Ms. J met the new temporary work study exemption for SNAP.

Expected Family Contribution (EFC)

The FCRC must base eligibility for this temporary student exemption on the application date and not the date of processing.

The student has an Expected Family Contribution (EFC) of $0 in the current school year. The EFC is an index number that college financial aid staff use to determine how much financial aid a person qualifies for at their school.

Verification of the Pell grant amount may be found on the financial aid award letter and may be used as verification that a student has an EFC of $0, if questionable. The EFC of $0 must be for the current academic year, as defined by the institution of higher education, in which the individual is enrolled. Request verification if the student's statement is questionable.

Example 1: Ms. B is a full-time college student. Her financial aid award letter shows that she received a Pell grant and has a $0 EFC. Ms. B meets the student exemption. The HSC determines Ms. B meets all other eligibility requirements for SNAP. The HSC completes the Education Detail Screen in IES and documents in Case Comments that Ms. B meets the $0 EFC exemption for SNAP.

Example 2: Ms. Z is a full-time student at Morrison University. She did not receive a Pell grant but was awarded a full 4-year volleyball scholarship. Ms. Z has a copy of her financial aid award letter at the interview which shows that she has a $0 contribution from her parents. Ms. Z meets the $0 EFC student exemption. The HSC determines Ms. J meets all other eligibility requirements for SNAP. The HSC completes the Education Detail Screen in IES and documents in Case Comments that Ms. Z meets $0 EFC exemption for SNAP. No special verification is needed unless the student's statement is questionable

IES Work Around for Temporary Exemptions

Use the current exemption in IES, enrolled in a work study program or works more than 20 hours per week, for students who meet the new temporary work study exemption or the new $0  Expected Family Contribution (EFC) exemption. In Case Comments, document the work study exemption that the student was allowed, whichever is applicable.

Complete IES Screens	IES Questions	Action	Verification
Gatepost Question	Is there a SNAP unit member (age 18-49 potentially subject to the SNAP Work Requirements?	Answer YES.
SNAP Work Requirements - Details Screen	Is individual fit to work or fit to participate in Employment & Training activities at least 20 hours per week?	Answer YES.
SNAP Work Requirements - Details Screen	Individual has met the work requirement	Answer NO.
Education Detail Page	Highest Level of Education Completed	In the drop down select: Some College, Not Graduated	Select Verification Source
Education Detail Page	Enrollment Status	In the drop down, select the appropriate status (full or part-time),	H.S. diploma required? Leave Blank
Education Detail Page	Type of Educational Institution	In the drop down, select the appropriate institution.
Education Detail Page	School Name	Enter the appropriate Name
Education Detail Page	Enrolled in a Training Program	Answer NO
Education Detail Page	Enrolled in a work study program or works more than 20 hours per week.	Answer YES
Education Detail Page	Individual education plan approved?	Answer Unknown
Education Detail Page	Will the curriculum lead to a high school diploma or GED?	Leave Blank
Education Detail Page	Able to work?	Answer YES
Education Detail Page	Childcare available?	Answer NO

Responsible for Care of a Child

• Responsible for the care of a unit member under age 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 child care to meet this requirement.

  • Example: Mr. W is a full-time student attending college. Mrs. W is unemployed and is at home during the day with their year-old daughter. Since Mrs. W provides the majority of childcare, Mr. W does not meet the requirement and is considered an ineligible student.

Career and Technical Program

• Perkins Career and Technical Education Program
  • • Determine if the student is attending the community college at least half-time, and
    • is pursuing a career or technical education program under the Carl D. Perkins Career and Technical Education Improvement Act that will lead to employment. 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.
  • Example: Mr. G lives alone and is applying for SNAP. During the interview, Mr. G states he is a full-time student enrolled in the Heating, Ventilation, Air Conditioning and Refrigeration certificate program at Lincoln Land Community College. This is a career and technical education program that is supported in part by the Perkins Act. Mr. G provides his enrollment documentation. Upon completion of the coursework Mr. G will be eligible for certification to enter into the workforce. Mr. G is eligible to participate in SNAP if all other eligibility requirements are met.

The following two criteria require special verification:

Physical or Mental Impairment

• If physical or mental impairment is not evident, ask the person to provide a physician's statement verifying the condition, or proof of the receipt of permanent or temporary disability benefits. 
• Lack of adequate childcare for unit member age 6 - 11 (PM 03-04-03-b).

  Determine if there is a lack of adequate childcare based on information provided by the unit. If the client claims that an adult living in the home is incapacitated and cannot provide care, ask for written proof of the incapacity.

  • Example 1: The SNAP unit consists of Mr. J, his 21 year-old son T, and 8 year-old daughter K. Mr. J is a half-time student. He states he is unable to work because he is responsible for the care of his daughter. His son receives Social Security disability. Do not consider T as available in the home to provide childcare. Mr. J meets the requirement.
  • The requirement may also be allowed when another adult in the home is not incapacitated, but is not available to provide the care.
  • Example 2: Mrs. D, her spouse and their 7 year-old daughter are applying for SNAP. Mrs. D is a full-time student and attends classes during the day. Her spouse is employed full-time and attends classes 3 nights a week. Ms. D cannot go to school and meet the requirement of working an average of 20 hours per week because childcare is not available in the home. Exempt Mrs. D for "responsible for the care of a dependent unit member age 6 through 11" since childcare is not adequate to allow her to meet both requirements.

Meals on Campus

During the interview, the worker must discuss the number of meals the student will receive through a meal plan to determine if the majority of the meals are being provided though the meal plan (21 total weekly meals).

Answer the question, Individual receives 1/2 meals from organization?, the Living Arrangement - Details Page, regardless of whether the student is living on or off campus.

For students who are ineligible due the majority of their meals being provided through a meal plan, Notice of Decision (IL444-360c) is sent with the denial reason: Individual receives more than 50% of meals through a school meal plan at your school of higher education.

Example1: J is enrolled full-time at Marion University. He lives on campus in a dorm and has a meal plan for breakfast and lunch every weekday. This is equivalent to 10 meals per week. He is not considered resident of an institution because 10 meals per week is less than the majority of 21 total weekly meals. If J meets student eligibility and all other eligibility requirements, he qualifies to receive SNAP.

Example 2: K is enrolled full time at Oakland University and lives on campus in a dorm. K is required to purchase a meal plan that includes 21 meals per week. K doesn't like the food offered and applies for SNAP stating that although she pays for a meal plan, she doesn't eat the food. K has more than 50% of her meals paid for, even though she chooses not to use her meal plan, and therefore is not eligible to receive SNAP. She is considered a resident of institution that provides meals as part of its normal service.

Level of Pay Plans 

The following levels of pay plans may also be used to determine if the majority of meals are being provided with the assumption that students are receiving less than 50 percent of their meals from the meal plans at Level 1 or Level 2.  Students whose meals plans are Level 3, Level 4, Level 5, or  Unlimited Plans are receiving more than 50 percent of their meals from the institution.

• Unlimited Plan:  Designed for 3 meals a day plus snacks (highest cost).
• Level 4 Plan:    Designed for 3 meals a day (high cost).
• Level 3 Plan:    Designed for 2 meals every day (moderate cost).
• Level 2 Plan:   Designed for about 2 meals a day on weekdays (lower cost).
• Level 1 Plan:    Designed for light snacks (lowest cost).

Dormitory Costs (without meals)

Workers should only allow dormitory costs paid by an eligible student as a shelter expense deduction if the dormitory costs are solely for shelter and does not include meal fees as part of the costs.

During the interview:

1. If an eligible student is claiming dormitory costs as a shelter expense deduction:
   • The worker must discuss the circumstances of the student's living arrangement and meal source to determine the amount of the expense and whether a fee for meals is included in the costs and how the student paid the expense.
   • The worker must document the details of the discussion in Case Comments and upload any verification, if needed  to the Electronic Case Record (ECR).
2. Only request verification if it cannot be determined if the student pays for their own dormitory costs and/or if meals are included in the costs. A student may provide their dormitory/meal plan contract or proof from their school or from any other source that verifies that information that is needed.
3. If dormitory costs are allowed, complete the IES screens to allow the deduction in the SNAP calculation.