This memo is in response to questions raised through Quality Control reviews related to student eligibility for SNAP benefits. Section 6(e) of the Food and Nutrition Act of 2008 and federal regulations at 7 CFR 273.5(a) prohibit students enrolled at least half-time in an institution of higher education from receiving SNAP benefits unless specific exemptions are met.
Some state agencies have adopted a version of simplified reporting for other programs, such as Medicaid and the Temporary Assistance for Needy Families Program, and are using multi-program report forms for the various programs, including SNAP.
This policy applies to all TANF-funded subsidized employment paid to SNAP clients or applicants in the form of wages, regardless of the source of TANF funding, including but not limited to funds available to states and Indian tribes through the Emergency Contingency Fund for state TANF programs.
This is a reminder of the statutory and regulatory requirements for categorical eligibility for the Child Nutrition Programs based on receipt of benefits from each state’s Temporary Assistance to Needy Families program. The Richard B. Russell National School Lunch Act restricts categorical eligibility to those TANF programs with standards that are comparable to or more restrictive than those in effect on June 1, 1995.
It has come to our attention that a number of states have begun using the emergency fund to develop and implement a wide range of subsidized employment efforts. In addition to the Emergency Fund program, subsidized employment may be funded under the regular TANF block grant or state Maintenance of Effort funds.