SNAP - Clarification of Policies Barriers Facing Homeless Youth
|DATE:||May 17, 2013|
|SUBJECT:||SNAP- Clarification of Policies Barriers Facing Homeless Youth|
|TO:||All Regional Directors
Supplemental Nutrition Assistance Program
This memorandum provides policy clarification that will help to ensure that eligible homeless youth can access the Supplemental Nutrition Assistance Program (SNAP).
The Food and Nutrition Service (FNS) recognizes the unique circumstances faced by homeless youth, and other homeless persons, in need of food assistance. FNS is committed to reducing barriers and improving program information in order to help eligible vulnerable populations, including homeless youths, obtain the food they need for good health.
As provided by the Food and Nutrition Act, as amended, at Section 3(m), homeless individuals are defined as follows:
"Homeless individual'' means-
(1) an individual who lacks a fixed and regular nighttime residence; or
(2) an individual who has a primary nighttime residence that is-
( A) a supervised publicly or privately operated shelter (including a welfare hotel or congregate shelter) designed to provide temporary living accommodations;
(B) an institution that provides a temporary residence for individuals intended to be institutionalized;
(C) a temporary accommodation for not more than 90 days in the residence of another individual; or
(D) a public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.
Based on reports from FNS regional offices and non-governmental and community based partners, FNS has identified common policy misconceptions relevant to homeless youth applying for SNAP. This memo is provided to clarify some of these misconceptions. States should contact their regional offices if there are questions regarding eligibility for SNAP.
Photographic identification. It is a common misconception that an official photographic identification is needed to apply for SNAP. SNAP is flexible in what documents are required to verify an applicant's identity. As provided by SNAP regulations at 7 CFR 273.2(f)(l)(vii):
Examples of acceptable documentary evidence which the applicant may provide include, but are not limited to, a driver's license, a work or school ID, an ID for health benefits or for another assistance or social services program, a voter registration card, wage stubs, or a birth certificate. Any documents which reasonably establish the applicant's identity must be accepted, and no requirement for a specific type of document, such as a birth certificate, may be imposed.
Therefore, a state agency is not limited to accepting a driver's license or other form of photo I.D.; a work or school identification card, or even a collateral contact such as a shelter worker or employer may suffice.
Permanent address. Another common misconception is that applicants must have a permanent address in order to apply for SNAP. There is no requirement for a permanent address in order to be eligible for SNAP. Moreover, homeless households are specifically exempted from the requirement to verify residency. SNAP regulations provide that verification of residency "should be accomplished to the extent possible" and provides flexibility regarding what documents may be used to verify residency. As provided by 7 CFR 273.2(f)(l)(vi):
Residency. The residency requirements of§ 273.3 shall be verified except in unusual cases (such as homeless households, some migrant farmworker households, or households newly arrived in a project area) where verification of residency cannot reasonably be accomplished. Verification of residency should be accomplished to the extent possible in conjunction with the verification of other information such as, but not limited to, rent and mortgage payments, utility expenses, and identity. If verification cannot be accomplished in conjunction with the verification of other information, then the state agency shall use a collateral contact or other readily available documentary evidence. Documents used to verify other factors of eligibility should normally suffice to verify residency as well. Any documents or collateral contact which reasonably establish the applicant's residency must be accepted and no requirement for a specific type of verification may be imposed. No durational residency requirement shall be established.
These provisions specifically provide flexibility for homeless households who may not have a fixed or regular nighttime residence or may be seeking some form of temporary accommodation. Depending on the household's circumstances, homeless persons may choose to use the address of an authorized representative, a shelter, or the SNAP local office as a place to receive mail from SNAP.
Age requirement. There is a misconception in SNAP that there is an age requirement. While this is the standard in most cases, youth who are not living with their parents are not required to apply as part of their parent's household.
As provided by regulations at 273.1 (a), an individual must apply as a household with the other people he or she lives with if they customarily purchase and prepare food together. In addition, a person under 22 years of age who is living with his or her parents must apply as part of the same household regardless of whether or not they purchase and prepare food together.
However, regulations at 273.l(b) provide policy which may apply to cases in which a homeless youth is temporarily seeking accommodation in the residence of another individual. This policy provides that a child under "parental control" must apply as part of the same household as the adult, defining parental control as follows:
A child (other than a foster child) under 18 years of age who lives with and is under the parental control of a household member other than his or her parent. A child must be considered to be under parental control for purposes of this provision if he or she is financially or otherwise dependent on a member of the household, unless state law defines such a person as an adult.
While some homeless youth may fall under parental control of a non-parent household member, other homeless youth may not. Anyone who, under SNAP policy, is considered an individual living alone should be afforded the opportunity to apply as a one person household.
FNS stands ready to work with state agencies and will provide any policy support needed to ensure that those who are eligible to participate are able to do so. Please note that, "Questions and Answers about SNAP for Homeless Persons" is available on the FNS website at the following address: http://www.fns.usda.gov/SNAP/outreach/pdfs/Homeless QA.pdf. It is important to ensure the food security of this vulnerable population as they transition to stable living situations.
Program Development Division
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.