Student Eligibility for the SNAP

This memo is in response to questions raised through Quality Control (QC) reviews related to student eligibility for SNAP benefits. Section 6(e) of the Food and Nutrition Act (the 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. These exemptions include students who are assigned to, or placed in, an institution of higher education through the SNAP Employment and Training (E&T) Program or an employment and training program for low-income persons operated by a state or local government. Under federal regulations, an acceptable local or state employment and training program must be at least equivalent to an acceptable SNAP E&T program component.

Each state decides who it will serve through its SNAP E&T Program and what services it will provide. Recently, several states have chosen to expand the role of the SNAP E&T Program to include educational activities at community colleges that have a direct link to employment. In addition, some states are using these E&T educational activities at community colleges to qualify students enrolled at least half-time for SNAP if, at the time of application, they are already enrolled in a SNAP E&T educational activity and all other eligibility requirements are met. The Food and Nutrition Service (FNS) has determined that this is acceptable within the language of the Act and federal regulations.

Please remind states that all SNAP E&T activities, including educational activities, must be approved through the state E&T plan. SNAP E&T educational activities are approvable to the extent that there is a direct link to employment. FNS will not pay for student educational expenses with SNAP E&T funds where these expenses are being met prior to SNAP participation.

Lizbeth Silbermann
Director
Program Development Division