USDA, ED Joint Guidance Aims to Expand SNAP Benefits to Students

The U.S. Department of Agriculture (USDA) and the Department of Education (ED) yesterday issued joint guidance to postsecondary institutions regarding temporarily expanded Supplemental Nutrition Assistance Program (SNAP) eligibility for students in need, better explaining which students may be eligible under these exemptions, what information students or state SNAP agencies may request from institutions of higher education (IHEs), and where IHEs can get more information.

Under regular SNAP rules, students enrolled at least half-time at an IHE are ineligible for SNAP unless they meet one of the program's exemptions. However, the Consolidated Appropriations Act of 2021 temporarily expanded SNAP eligibility to allow students who either:

• are eligible to participate in state or federally financed work study during the regular academic year, as determined by the IHE, or
• have an expected family contribution (EFC) of 0 in the current academic year.

As of Jan. 16, 2021, students who meet one of these two criteria may receive SNAP if they meet all other financial and nonfinancial SNAP eligibility criteria. The temporary exemptions will be in effect until 30 days after the COVID-19 public health emergency is lifted. According to the guidance, USDA’s Food and Nutrition Service (FNS) is encouraging state SNAP agencies to work with state departments of education to identify appropriate sources of verification and communicate the verification process to IHEs, as needed.

State SNAP agencies may contact IHEs to request verification of students’ eligibility for work study or EFC of 0. IHEs, when gaining prior written consent from the student, may provide a student’s Free Application for Federal Student Aid (FAFSA) data to a state or entity for the purposes of applying for or receiving state or federal means-tested benefits, which include SNAP benefits.

Other documents state SNAP agencies may use to verify student eligibility exemption criteria include:

• verification of eligibility to participate in a work study program may be found on the financial aid award letter provided to the student by the IHE, or in a letter from the IHE to the state at the request of the student;
• verification of an expected EFC of 0 may be found on a financial aid award letter or Student Aid Report, or in a letter from the IHE provided to the state at the request of the student; and
• students receiving the maximum federal Pell Grant have an EFC of 0, and 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 if they do not meet other student eligibility requirements.

The guidance also notes that under SNAP regular rules, only students who actually participate in state or federally financed work study are eligible. The new, temporary exemption expands SNAP eligibility to students who are eligible to participate in work study during the regular school year, without the requirement that they actually participate. Under this temporary exemption, the guidance explains that states may consider all students eligible if they are eligible for work study and attend an IHE that participates in a state or federal work study program. The IHE will determine whether a student is eligible to participate in a work study program.

There is a lot of coordination needed by various parties to reap the benefits of the temporary exemption. We hope that states and IHEs can work together to assist students struggling to cover basic expenses.

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