MR #21.07: COVID 19 - New Temporary Student of Higher Education Exemptions January 2021 through June 2021

Illinois Department of Human Services Logo

03/01/2021

Summary

  • Under regular Supplemental Nutrition Assistance Program (SNAP) rules, students enrolled at least half-time in an institution of higher education are ineligible for SNAP unless they meet one of the student exemptions. The Consolidated Appropriations Act 2021 signed on December 27, 2020, temporarily adds the following two exemptions to help more students qualify for SNAP
    1. have an expected family contribution (EFC) of $0 in the current school year; or
    2. are eligible to participate (as determined by the school) in a state or federal work study program during the regular school year. This exemption differs from the existing work study exemption which requires a student to be eligible for a state of federal work study program and be anticipating that he or she will be working during the school year. The existing exemption requires that jobs be available for the student to anticipate working during the school year. The new temporary exemption only requires that the student be eligible to participate and does not require that a job be available for the student to work.
  • The new temporary exemptions do not impact any other student exemptions. All current student eligibility exemptions remain in effect. A student who does not meet one of the existing student exemptions may still qualify for SNAP if a temporary exemption is met. Students must still meet all other SNAP financial and non-financial criteria to be eligible for benefits.
  • Determine for initial applications and recertifications received on or after January 16, 2021 and when any household reports a change during the certification period that would potentially add a new eligible member to the household whether a student meets an exemptions, including the two new temporary exemptions.
  • Prior to certifying, verify the temporary exemption if any statement made by the student is questionable and would impact eligibility.
  • The new temporary exemptions are in effect until 30 days after the COVID-19 public health emergency is lifted. Staff will be notified when the COVID-19 public health emergency ends.
  • The Consolidated Appropriations Act, 2021 was signed into Federal law on December 27, 2020 . Division N, Title VII, Subtitle A, Section 702(e) of the Act temporarily expands student eligibility at Section 6(e) of the Food and Nutrition Act of 2008. The Act temporarily provides for two additional exemptions for students enrolled in a school of higher education. The new temporary exemptions do not impact any other student exemptions. All current student eligibility exemptions remain in effect. Students must meet all other financial and non-financial criteria to be eligible for benefits.
  • The two new temporary exemptions are in effect until 30 days after the COVID-19 public health emergency is lifted. Staff will be notified when the COVID-19 public health emergency ends.

Eligibility Determination

Determine for initial applications and recertifications received on or after January 16, 2021 and when any household reports a change during the certification period that would potentially add a new eligible member to the household whether a student meets an exemption, including the two new temporary exemptions.

Existing State/Federal Work Study Exemption

Under regular SNAP rules, only students who are eligible for a state or federal work study program and are anticipating that he or she will be working during the school year are eligible for the work study exemption. The existing exemption requires that jobs be available for the student to anticipate working.

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. Mr. B meets the special student eligibility requirements for the school term. 

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 under regular SNAP rules.

Temporary State/Federal Work Study Exemption

  • The new temporary exemption extends SNAP eligibility to students who are eligible to participate in work study during the regular school year, but without the requirement of anticipating being able to work. This may be due to circumstances beyond the student's control, such as no jobs available or loss of a job due to COVID-19.
  • The institution of higher education makes the determination as to whether a student is eligible to participate in a work study program. Verification should be obtained from the school if the student does not have proof.
  • Continue to exempt students under the existing student 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.
  • Allow the new 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. 
  • Because IES will not be modified to include the two temporary exemptions, 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 students who meet the temporary work study exemption. In Case Comments, document the work study 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 of $0

  • This exemption allows students of higher education to qualify for SNAP if they have an Expected Family Contribution (EFC) of $0 in the current regular 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.
  • In IES, use the exemption, enrolled in a work study program or works more than 20 hours per week, when allowing the $0 EFC exemption. Document in Case Comments that the student met the $0 EFC exemption. Students who receive the maximum Pell grant have a $0 EFC. 
  • In the 2020-21 award year, the maximum Pell grants are:
    • $3,172 per semester for students enrolled full-time,
    • $2,379 per semester for students enrolled three-quarter-time, and
    • $1,586 per semester for students enrolled half-time.
  • 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. However, not all students with an EFC of $0 receive a Pell grant.
  • The EFC of $0 must be for the current school year, as defined by the institution of higher education, in which the individual is enrolled. Request verification from the school if the student does not have proof.

Example 1: Ms. O is a full-time college student. Her financial aid award letter shows that she received a Pell grant $3,172. Ms. O 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. 0 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

  • There will not be any system updates to IES for the new temporary exemptions. Use the current exemption in IES, enrolled in a work study program or works more than 20 hours per week, when allowing the work study exemption and when allowing the $0 EFC exemption as the work study exemption for students who meet a temporary exemption.
  • Follow the instructions below for the work around procedure.
 IES Screens IES Questions Action Verification
Complete Gatepost Question Is there a SNAP unit member (age 18-49 potentially subject to the SNAP Work Requirements? Answer YES
Complete 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.
Individual has met the work requirement Answer NO.
Complete the Education Detail Page Highest Level of Education Completed Select Some College, Not Graduated Select Verification Source
Enrollment Status In the drop down, select the appropriate status (full or part-time),

H.S. diploma required?

Leave Blank
Type of Educational Institution In the drop down, select the appropriate institution.
School Name Enter the appropriate Name
Enrolled in a Training Program Answer NO
Enrolled in a work study program or works more than 20 hours per week. Answer YES
Individual education plan approved? Answer NO
Will the curriculum lead to a high school diploma or GED? Leave Blank
Able to work? Answer YES

If NO. Verification.

Leave Blank.
Childcare available? Answer NO

Manual Revisions

PM 03-04-03-b
WAG 03-04-03-b

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms referenced: