The attached memorandum is Food Distribution Policy Memo FD-110, which clarifies requirements in crediting for, and use of, USDA donated foods in contracts with food service management companies, and provides guidance to ensure compliance with such requirements in the first and final years of such contracts.
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.
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.