SNAP – Questions and Answers on Student Exemptions

The Food and Nutrition Service (FNS) is clarifying student eligibility policy to help state agencies screen and certify eligible students and support work readiness for the Supplemental Nutrition Assistance Program (SNAP). Although students who are at risk of food insecurity may be eligible for SNAP, many are not participating in the program. A recent Government Accountability Office report estimated 3.3 million students were eligible for SNAP, but 67 percent reported not receiving benefits.

Individuals enrolled at least half time in an institution of higher education (IHE) are eligible for SNAP if they meet certain criteria (exemptions), provided at Section 6(e) of the Food and Nutrition Act of 2008 (the Act) and 7 CFR 273.5(b). FNS' Feb. 7, 2023, Institutions of Higher Education and Student Eligibility Rules memo clarified which individuals are considered enrolled in an IHE, and therefore subject to student eligibility rules. FNS understands there is confusion around student exemptions, and is issuing this memorandum to clarify several of these exemptions:

• The physically or mentally unfit exemption at Sec. 6(e)(2) of the Act and 7 CFR 273.5(b)(2);
• The work study exemption at Sec. 6(e)(4) of the Act and 7 CFR 273.5(b)(6);
• The exemption for individuals assigned to or placed in an IHE through certain employment and training programs outlined at Sec. 6(e)(3) of the Act and 7 CFR 273.5(b)(11); and
• The exemption for the work incentive or Job Opportunities and Basic Skills (JOBS) program under Title IV of the Social Security Act, or its successor program, at Sec.6(e)(7) of the Act and 7 CFR 273.5(b)(4).

The definition of a student covered in this memo and other SNAP memos is for SNAP eligibility purposes only.

Schools should determine who is a “student” for their own purposes, which may confer advantages such as access to a campus library or a student ID card.

State agencies with questions should contact their regional office representatives.

Sasha Gersten-Paal
Director
Program Development Division
Supplemental Nutrition Assistance Program

Attachment

• Questions and Answers