This memorandum clarifies the use of third party payroll sources for SNAP certification policy and quality control purposes. The first two sections of this memorandum apply to certification policy and the section titled Quality Control Considerations provides details on how to treat verification from a third party payroll source for QC reviews.
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.