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Implementing a Mini–Simplified Food Stamp Program to Replace Food Stamp Work Requirements with TANF Work Requirements

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SUBJECT: Questions and Answers on Implementing a Mini–Simplified Food Stamp Program to Replace Food Stamp Work Requirements with TANF Work Requirements
TO: Food Stamp Program Directors
All Regions

Attached for immediate distribution to your respective state agencies are questions and answers on implementing a mini–Simplified Food Stamp Program (mini–SFSP) to replace Food Stamp Program (FSP) work requirements with those under the Temporary Assistance for Needy Families (TANF) Program.

On June 29, 2006, the Department of Health and Human Services (DHHS) issued regulations that define the activities that are countable toward TANF work participation rate requirements. Since the minimum wage protections of the Fair Labor Standards Act (FLSA) apply to TANF recipients, state agencies cannot require recipients to participate in unpaid “work” activities, i.e., community service or work experience, at an hourly rate less than minimum wage. However, many state agencies will not be able to offer unpaid work activities for a sufficient number of hours to meet the TANF 20–hour core activity requirement. The rule addresses this situation by allowing state agencies to “deem” any family that participates for the maximum hours allowed under the minimum wage requirements of the FLSA as having satisfied the required number of hours in core activities. The maximum hours permissible under the FLSA must be based on both the value of the TANF assistance unit’s benefits and the household’s food stamp benefits.

Although the preamble to the TANF regulation indicated that state agencies need to implement a FSP workfare program and conform TANF and FSP exemption policies under a mini–SFSP, we have determined that this is not necessary. By aligning FSP and TANF work requirements in a mini–SFSP, TANF work experience or community service programs can serve in place of the FSP workfare program.

The attached questions and answers will clarify the most important aspects of the mini–SFSP. In addition, for state agencies that desire to pursue this alternative, we have attached a notification letter template that simplifies mini–SFSP implementation.

Arthur T. Foley
Program Development Division


Page updated: April 17, 2023

The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.