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SNAP Cash Payment Pilot Projects and Work Supplementation or Support Programs Benefits

EO Guidance Document #
FNS-GD-2009-0043
FNS Document #
FD-091
Resource type
Policy Memos
Guidance Documents
Resource Materials
PDF Icon Policy Memo (270.32 KB)
DATE: June 29, 2009
POLICY MEMO: FD: 091 Commodity Supplemental Food Program (CSFP) and Nutrition The Emergency Food Assistance Program (TEFAP)
SUBJECT: Supplemental Nutrition Assistance Program Cash Payment Pilot Center Drive Projects (SNAP Pilot Projects) and Work Supplementation or Support Programs (SNAP Work Programs) Benefits

This memorandum clarifies how SNAP benefits should be treated in determining eligibility for CSFP and TEFAP when the benefits are provided through SNAP pilot projects or SNAP work programs.

SNAP Pilot Projects

Section 17(b)(1)(B)(vi) of the Food and Nutrition Act (FNA) authorizes SNAP pilot projects, which currently operate in Minnesota, Ohio, Oregon, Utah, and Vermont. SNAP benefits are issued to certified eligible recipients in the form of an "allotment." Through the pilot projects, SNAP allotments are issued as cash payments. Criteria for participation in the pilot projects include that all members of an eligible household must either be age 65 years or over or be entitled to supplemental security income benefits under title XVI of the Social Security Act. 

Per CSFP regulations at 7 CFR 247.9(b)(1)(i), women, infant, and children applicants who are certified as eligible to receive SNAP benefits automatically meet CSFP income eligibility requirements. Therefore, recipients of cash payments through SNAP pilot projects automatically meet CSFP income eligibility requirements, and states may not impose any additional income requirements when determining participant eligibility. However, applicants must still meet all other CSFP eligibility requirements, including categorical and residency requirements. 

For senior applicants age 60 years and over, eligibility for SNAP benefits does not create automatic income eligibility for CSFP. Senior applicants must separately meet CSFP income eligibility requirements in order to participate in the program. However, in accordance with section 8(b) of the FNA, SNAP benefits are "not considered income 'or resources for any purpose under any federal, state, or local laws...." Therefore, cash payments provided under the pilot projects must be excluded as income in determining eligibility for participation in CSFP. There are no resource limits in determining eligibility for CSFP. However, all other program eligibility requirements must also be met. 

In administering TEFAP, state agencies are responsible for establishing uniform statewide criteria for determining the eligibility of households to receive USDA foods for home consumption. For these households, TEFAP regulations at 7 CFR 251.5(b)(2) require states to include "income-based" eligibility standards. Income standards may, at the state's discretion, be met through participation in other existing federal, sate, or local food, health, or welfare programs for which eligibility is based on income. TEFAP regulations do not permit states to impose income limitations on households or individuals receiving prepared meals. 

Although state agencies establish income-based standards for households receiving TEFAP foods for home consumption, Section 8(b) of the FNA provides that SNAP benefits may not be considered income or resources for any purposes under federal, state, or local laws. Therefore, cash payments through SNAP pilot projects must be excluded as income in determining eligibility for participation in TEFAP. There are no resource limits in determining eligibility for TEFAP. However, all other state agency established program eligibility requirements must be met.

SNAP Work Programs

The FNA, at section 16 (b), authorizes SNAP work programs, through which SNAP benefits are "provided to an employer to be used for hiring and employing a public assistance recipient who was not employed by the employer at the time the public assistance recipient entered the program." Currently, only two states operate SNAP work programs: Arizona and Oregon. 

Per CSFP regulations at 7 CFR 247.9(b)(1)(i), women, infant, and children applicants who are certified as eligible to receive SNAP benefits automatically meet CSFP income eligibility requirements. Therefore, women, infants, and children certified as eligible to receive SNAP benefits, but who are participating in SNAP work programs rather than receiving SNAP benefits in the form of an electronic benefits transfer card, automatically meet CSFP income eligibility requirements. Under these circumstances, states may not impose any income requirements when determining CSFP eligibility. Applicants must still meet all other program eligibility requirements, including categorical and residency requirements. 

For senior applicants age 60 years and over, eligibility for SNAP benefits does not create automatic income eligibility for CSFP. Senior applicants must separately meet CSFP income eligibility requirements in order to participate in that program. However, in accordance with section 8(b) of the FNA, SNAP benefits are "not considered income or resources for any purpose under any federal, state, or local laws...." Therefore, the specific portion of SNAP benefits provided to a recipient through SNAP work programs must be excluded as income in determining eligibility for participation in CSFP. There are no resource limits in determining eligibility for CSFP. However, all other program eligibility requirements must be met.

In administering TEFAP, state agencies are responsible for establishing uniform statewide criteria for determining the eligibility of households to receive USDA foods for home consumption. For these households, TEFAP regulations at 7 CFR 251.5(b)(2) require states to include "income-based" eligibility standards. These income standards may, at the state's discretion, be met through participation in other existing federal, state or local food, health, or welfare programs for which eligibility is based on income, such as SNAP. TEFAP regulations do not permit states to impose income limitations on households or individuals receiving prepared meals. 

Because section 8(b) of the FNA states that SNAP benefits may not be considered income or resources for any purposes under federal, state, or local laws, the specific portion of SNAP benefits received by recipients through SNAP work programs must be excluded as income in determining eligibility for participation in TEFAP. There are no resource limitations in determining eligibility for TEFAP. However, in addition to income eligibility requirements, all other program eligibility requirements must be met. 

In those circumstances where a CSFP or TEFAP applicant is receiving benefits from SNAP pilot projects or SNAP work supplementation programs which should be excluded for income eligibility purposes, the applicant may refer to the SNAP approval notice, notice of change in benefits, or other documentation in order to determine the SNAP pilot projects or SNAP work programs benefit amount that should be excluded. Alternatively, applicants can contact their SNAP local office to inquire for the benefit amount. 

Cathie McCullough
Director
Food Distribution Division

06/29/2009

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.