MR #23.09: Are Dormitory Costs Paid by Eligible Students of Higher Education an Allowable Shelter Expense for SNAP?

02/10/2023

Summary

• This manual release is being issued to inform Family Community Resource Centers (FCRCs) of a recent policy clarification from Food and Nutrition Service (FNS) on allowing dormitory costs as an allowable shelter expense for students of higher education.  
• Dormitory costs that do not include meals and are paid by eligible students of higher education may be considered as shelter expenses for the SNAP excess shelter deduction and for consideration of expedited SNAP service. Verification is not needed unless it is questionable that the student is paying their own dormitory costs and if meals are included.
• The two temporary student exemptions allowed during the COVID-19 public health emergency continues until further notice. FCRCs will be notified when the temporary exemptions end.
• This manual release also includes a correction to an unrelated PM page (PM 02-08-03-c). 

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A policy clarification has been received from Food and Nutrition Service (FNS) on allowing dormitory costs paid by eligible students of higher education as an allowable shelter expense for Supplemental Nutrition Assistance Program (SNAP) benefits. The Bureau of Policy Development (BPD) sought guidance to this question as a result of a Family Community Resource Center (FCRC) inquiry.

Students of Higher Education

Residents of an Institution

• Students of higher education residing in a dormitory are considered residents of an institution (PM 04-05-04) if 50% or more of their meals are provided by the school and are not eligible for SNAP.
• 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.

Dormitory Costs Without Meals

• An eligible student of higher education who pays for their own dormitory costs may claim the expense as a deduction for SNAP if the dormitory costs are solely for shelter and does not include meal fees as part of the costs.
• Allow the expense at initial application and redetermination (REDE). The expense may also be allowed when determining expedited service. Treat the expense as a reported change if reported by the SNAP household during the certification period.
• Dormitory costs are usually paid up-front in a one-time payment for the semester or quarter. If paid as a one-time payment, the charges may be considered continual charges and can be prorated accordingly.
• It is important that a thorough interview be conducted with the SNAP household to discuss the living and meal arrangement a student has with the school.
• If the expense is claimed as a deduction, workers should determine the amount of the dormitory costs and whether a fee for meals is included in the costs and how the student paid the expense.
• Verification is not needed unless it is questionable that a student is paying their own dormitory costs and if meals are separate from the cost. Worker should not routinely request verification. If it becomes necessary to verify, the student may provide their dormitory/meal contract, proof from the school, or any other verification that shows proof of their dormitory/meal arrangement
• Document the details of the discussion in Case Comments and upload any verification to the Electronic Case Record (ECR).

Complete IES Screens

In IES, complete the:

• Education Details Screen
• On the Living Arrangement/Domicile - Details Screen:
  • Select Living Arrangement Type:  Dormitory/Education Housing.
  • Answer (No) to Individual receives 1/2 meals from organization?
• On the Question - Shelter/Utility Deduction Screen:
  • Answer (Yes) to Does the household have shelter expenses? 
• On the Shelter Expense Details Page complete:
  • Status Occupancy - Select Occupied
  •  Expense type - Select Home Rent
  • Expense frequency - Select annually (unless student has a different payment plan with the school).
  • Amount - Enter the amount based on the frequency of pay.
  • Verification- Select client statement, unless questionable and proof was requested.
• Review the Shelter Expense Screen to ensure accuracy of the information and document the details of the case in Case Comments.

Miscellaneous Manual Page Correction

This manual release also includes a correction to an unrelated PM page. PM 02-08-03-c. Corrects and revises this section to clarify that if the SNAP household's monthly expenses exceed their monthly income and resources financial management must be explained before expedited benefits are issued but does not need to be verified.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced: