05/30/23
Summary
- Due to the ending of the Public Health Emergency (PHE), certain waivers approved by Food and Nutrition Service (FNS) are also ending. Section 702(e) of the Consolidated Appropriations Act, 2021 (CAA) authorized two temporary exemptions that allowed students of higher education who did not meet regular student exemptions to qualify for SNAP benefits during the COVID-19 pandemic.
- These exemptions are being phased out in this manual release as set forth by FNS guidelines. Family Community Resource Centers (FCRCs) do not have discretion to end the temporary student exemptions earlier or later than the timeframes outlined in this manual release.
- A student who files or has a pending initial application by 06/09/2023 and does not meet a regular student exemption must still have their eligibility for a temporary student exemption determined.
- For an initial application filed on 06/10/2023 and after, a student must meet a regular student exemption and all other eligibility requirements to qualify for SNAP.
- A student who is currently active for SNAP and was determined eligible under a temporary student exemption retains this exemption until their next REDE.
- A temporary exemption may still be allowed for students who file a REDE application by 06/30/2023 or have a REDE pending as of this date.
- Beginning with SNAP REDEs filed 07/01/2023 and after, a student must be eligible for a regular student exemption and meet all other eligibility requirements to qualify for SNAP.
- As the temporary student exemptions expire, FCRC staff must make every attempt to screen students for all regular student exemptions in PM 03-04-03-b A student who was previously certified with one of the temporary exemptions may continue to be eligible for SNAP if they qualify under a different exemption. These changes apply to students of higher education applying for SNAP benefit on their own and students living in a SNAP household with other members.
- Workers now have access to answer the question, Individual receives 1/2 meals from organization?, on the Living Arrangement - Details Page. This question should be answered regardless of whether the student is living on or off campus and meeting a student exemption. It does not matter if the purchase of the meal ticket is required or by choice.
- A new denial/cancellation reason is created for use with Notice of Decision (IL444-360c): Individual receives 50% or more of meals through a meal plan at your school of higher education.
Temporary Student Exemptions
- Section 702(e)(2) of the Consolidated Appropriations Act, 2021 (CAA) created two temporary exemptions for students in response to the COVID-19 Federal Public Health Emergency (PHE). The two temporary exemptions apply to students who meet either of the following:
- The student is eligible to participate in a State or Federally financed work study program during the regular school year, as determined by the institution of higher education; or
- The student has an expected family contribution (EFC) of $0 in the current academic year.
Regular State or Federal Work Study Exemption
- The temporary exemption for students eligible to participate in a State or Federal Work Study did not require that jobs be available for the student to be anticipating to work during the school year.
- 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. A student filing an initial application on or after 06/10/2023 and students filing a REDE effective 07/01/2023 and after, must be anticipating to work because there are jobs available.
Transition Process to Regular Student Exemptions
Family Community Resource Centers (FCRCs) do not have discretion to end the temporary student exemptions earlier or later than the timeframes outlined in this manual release.
Initial Applications/Pending Applications
Eligibility for a temporary student exemption is based on the application filing date and not when the application is processed.
Initial Applications filed or Pending by 06/09/2023
For initial SNAP applications filed by 06/09/2023 or pending as of this date, the FCRC will continue to determine if a student who is not eligible under 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, all students of higher education must meet a regular student exemption to be eligible for SNAP. FCRCs cannot use a temporary exemption for students who file an initial application on 06/10/2023 or after and do not qualify for SNAP under regular student exemptions.
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.
Example 2: JT is applying for SNAP on 06/10/2023 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 meets the special student eligibility requirements 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). REDEs filed effective 07/01/2023 are the first REDEs to be affected by this change. 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 requirement 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.
REDEs Applications filed by 06/30/2023
A temporary exemption may still be allowed for a student who files a REDE application by 06/30/2023. If eligible for a temporary exemption and all other eligibility requirements are met, the student is approved for SNAP. At the following REDE, the student must meet a regular student exemption.
Example: J filed a REDE application on 06/25/2023. He is a full-time student but does not meet a regular student exemption. Because J filed his application before 07/01/2023, 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 the case for one year. At J's next REDE, a temporary exemption cannot be allowed.
REDEs 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 receive SNAP.
Example: OB files a REDE application on 07/01/2023. 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 07/01/2023 and after. OB does not qualify for SNAP. His REDE is denied because he does not meet any of the special student eligibility requirements.
IES Work Around for Temporary Exemptions
Because IES was not modified to include the two 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 temporary work study exemption. In Case Comments, document the exemption the student was allowed, whichever is applicable.
Meal Plan Policy Update
This manual also includes an update to policy regarding students with meal plans.
Students who receive the majority of their meals (50 percent or more of three meals daily) through either a mandatory or optional meal plan are considered residents of an institution (PM 04-05-04) and are ineligible for 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.
Students who meet one of the student exemptions and do not receive the majority of their meals from a meal plan are not residents of an institution and may be eligible for SNAP, if they meet all other eligibility requirements.
The Living Arrangement - Details Page in IES has been modified to allow workers to access the question, Individual receives 1/2 meals from organization?, regardless of whether the student is living on or off campus.
A new denial reason has been created to display on Notice of Decision (IL444-360c) for students who are ineligible due to receiving the majority of their meals through a meal plan.
Manual Revisions
[signed copy on file]
Grace B. Hou
Secretary, Illinois Department of Human Services
Forms referenced:
IL444-360c
