Annual Income in Shorter Period:
Due to the manner in which some households receive income, special certification procedures may be required. These households may include:
farmers and certain self-employed households, but not migrant or seasonal farm workers (see Self–Employment); and
Mandatory Income Averaging
If a client states s/he is are employed in a school department, you must send a VC-1 for a completed Request for School Employee Information form, along with corresponding documents, such as the contract or wages, as needed.
If the client returns a letter or any document from the school employer that represents information requested on the Request for School Employee Information Form, we must accept it. Return of the form itself is not required.
Teachers and other salaried school employees who derive their annual income in a period of time shorter than one year must have their income averaged over a twelve (12) month period if the following three conditions are met:
The school employee works under a renewable annual contract.
Contract Renewal - The renewal process may involve signing a new contract each year, automatic renewal, or as in cases of school tenure, rehire rights may be implied and thus preclude the use of a written contract altogether.
In some situations, a school employee may not have a contract that is updated every academic year. Certain clauses in a contract may allow for automatic extensions of the original terms of employment. If an employment contract contains such language, you must not disregard the verification because it is from a previous academic year.
Work-Non-Work Cycle - The fact that a contract is in effect for an entire year does not mean that the contract will stipulate work every month of the year. Rather, there may be certain predictable non-work periods or vacations, such as the summer break between school years.
The school employee has written reasonable assurance of employment for the upcoming academic year.
Reasonable Assurance –This is a written agreement from the school department/educational agency that offers reasonable assurance to the employee that they will be rehired for the upcoming academic year (fall and spring semester). The agreement confirms that the employee will be performing services in the same or similar capacity as the previous year.
The school employee is salaried and is not paid on an hourly basis.
Salaried Employee – The employee is guaranteed a base annual salary as part of his/her terms of employment. In some situations, a school employee may provide wage stubs with an hourly rate of pay. However, wage stubs alone may not be sufficient to determine whether he/she is a salaried or hourly employee.
Verification of Conditions
These conditions may be verified through a completed Request for School Employee Information form, or a letter from the school department/educational agency, or an employment contract. It is unnecessary to collect separate verifications for each condition. In certain situations a single document may be sufficient in verifying all three points.
If all three conditions apply, you must average the school employee’s salary over a 12-month period, even if his/her annual income is received in a period of time shorter than one year. You must average regardless of the school employee’s actual frequency of compensation. This calculation distributes the client’s earned income equally over a one year period.
Entering Earned Income of School Employees
If the school employee is subject to mandatory income averaging, you must enter the salary as an annual amount in the Earned Income page.
Continued Eligibility During Non-Work Periods
School employees subject to mandatory income averaging must not have their annualized income record zeroed out during non-work periods.
Nonexempt school employees must comply with General Work Requirements or ABAWD Work Program Requirements during the non-work season. See General SNAP Work Requirements Exemptions and ABAWD Work Program Exemptions
If a client reports no change in their earned income at Interim Report, continue to use the annualized income record.
In certain situations, non-work periods may coincide with the household’s Interim Reporting period. If the household reports no earned income at Interim Report, and the cause for the change is not clear, you must call the client to determine whether this decrease is due to job termination or a non-work period. If you are unable to reach the client via a telephone call, you must send a VC-1 for proof of the income change. You must not schedule an interview for clients during their IR period.
If the decrease in earned income is attributed to a non-work period, you must continue to use the annualized income record.
For additional guidance on Interim Reporting procedures, see (Simplified Reporting Interim Report).
You must rescreen the client against the conditions for mandatory income averaging at recertification. You may send a VC-1 for a new Request for School Employee Information form or an updated letter from the school department/educational agency.
If the Department has a self-renewing employment contract on file that contains reasonable assurance language and confirms that the school employee is salaried, then a request for additional employment information is unnecessary. The contract may be used to determine whether the client meets the conditions for mandatory income averaging. However, updated wage information must be collected to verify the client’s current annual income.
School Employees Not Subject to Mandatory Income Averaging
For school employees not subject to mandatory income averaging you must enter the client’s income based on his/her pay frequency.
If the client reports and verifies loss of income during a non-work period, you may adjust the household’s income record and recalculate SNAP benefits.
If subject to Simplified Reporting, the client is only required to report an increase in earned income if it puts him/her over the gross income limit for the household size. The school employee’s wages must be addressed in full at Interim Report or Recertification, whichever comes first.
Request for School Employee Information Form
This form may be provided to clients who work for a school department or educational agency. You must fill out section one and then forward the form to the client.
The client must sign section two and submit the form to his/her employer for completion.
The school representative must respond to the questions in section three and sign and date the form. The client must return the completed form to the DPC for processing. You must review this form to verify whether the school employee:
works under a renewable annual contract;
has reasonable assurance of employment for the upcoming academic year; and
is paid a base annual salary.
The client is subject to mandatory income averaging if Yes is checked for questions 1-3. You must enter the client’s salary (found on line 4 of the form) as an annual amount in the Earned Income page.
A No response for any question in section three will exclude the school employee from mandatory income averaging procedures. You must enter the client’s wage stubs in the Earned Income page based on his/her pay frequency.
The Request for School Employee Information form is a verification that may be used to verify the conditions for mandatory income averaging. Case managers cannot mandate the return of this specific form when other acceptable verifications are provided by the client.
Q1. Sally Mae is a full time elementary school teacher for Sharon Public Schools. She applied for SNAP benefits on July 1st and provided a letter from the school department. The letter verifies that Sally is a contracted school employee with a confirmed rehire date of September 1st. The letter also states that Sally is paid a salary of $24,000 between the months of September through June. Is Sally subject to mandatory income averaging?
A1. Yes. Sally is a school employee that meets all three conditions for mandatory income averaging. She works under a renewable annual contract, has reasonable assurance for employment for the upcoming academic year, and works as a salaried employee. Although she has no income at the moment, you must enter her salary as an annual amount in the Earned Income page. Sally will have $2,000 in gross monthly income counted against her SNAP calculation. This amount will be applied during work and non-work periods.
Q2. Danny Brown is a full-time cafeteria worker at Burncoat High School. He is employed by Sodexho, a private food services company contracted by Worcester Public Schools. He comes in to apply for SNAP benefits on October 1st and provides you with his employment contract and his last four weekly wage stubs. He is paid $11.00 per hour and works 40 hours per week. The contract verifies that Danny is guaranteed work each year between the months of September through June. The contract also explains that Danny is paid a salary of $22,880 per year. Is Danny subject to mandatory income averaging?
A2. No. Danny is not considered a school employee. He is not employed by a school department or educational agency. He works for a private company that operates dining services for a school. Although Danny appears to meet all the conditions for mandatory income averaging, he is not subject to this provision as a private employee. You must enter his last four weekly wage stubs to calculate his prospective income.
Q3. Emily Danes is a part-time school bus driver for Springfield Public Schools. She works under a renewable annual contract that stipulates a rehire date of September 5th each year. Emily is an on-call driver that fills in when other drivers call out. She is paid $15.00 per hour. Is Emily subject to mandatory income averaging?
A3. No. Although Emily is a school employee, she is not subject to mandatory income averaging. She works under a renewable annual contract, has reasonable assurance for employment for the academic year, but is not a salaried employee. You must enter her income based on her pay frequency.
Q5. Trisha McDonald is a contracted school employee for Greenfield Public Schools. She is hired by the school department every spring semester to work as a full time gym teacher and assistant tennis coach. Between the months of January through June she is paid a salary of $11,440 per year. At the end of the academic year, she receives a letter from the school department that offers reasonable assurance for employment for the upcoming spring semester. Trisha does not work for the school department during summer vacation or through the fall semester. Is Trisha subject to mandatory income averaging?
A5. No. Trisha meets two of the three conditions for mandatory income averaging. She works under a renewable annual contract and is paid an annual salary. However, she does not have reasonable assurance of employment for the full academic year. You must enter her income based on her pay frequency.
Q6. Bobby Wilson states that he is a full-time custodian for Saugus Public Schools. He provides you with his last 4 wage stubs. Bobby states that he does not work under a contract and is paid hourly. Is this information sufficient to disqualify Bobby from mandatory income averaging?
A6. No. You must send a VC-1 for a completed Request for School Employee Information form or a letter from the school department. We cannot determine whether to apply mandatory income averaging procedures from a self-declaration and wage stubs.
Q7. Maria Rosado is a full time teacher’s aide for Falmouth Public Schools. She applied for SNAP benefits on February 1st and provided a completed Request for School Employee Information form. The school representative checked off Yes to questions 1 and 2, but No to question 3. Based upon these responses, Maria was excluded from mandatory income averaging. Her case was approved and her wages entered based on her pay frequency. Maria was placed on 12-month Simplified Reporting. On July 3rd, Maria submitted her completed Interim Report. Her only reported change was for earned income. She indicated that she was last paid on June 30th and attached a letter from the school department. The letter stated that she had reasonable assurance for employment for the upcoming academic year, but would not be paid during the months of July and August. Is an interview required for this Interim Report?
A7. No, the reported information is not questionable and the income change was verified through a letter from the school department.
Q8. Should the case manager end Maria’s current earned income record?
A8. Yes, Maria is not subject to mandatory income averaging, her earned income record may be adjusted during non-work periods and SNAP benefits recalculated.
Q9. Should the case manager schedule a future action to follow up on this case in September when Maria starts working again?
A9. No, per Simplified Reporting rules Maria is only required to report an increase in earned income if it puts her over the gross income limit for the household size. If her wages remain below this limit, she is not required to verify this income until her recertification period in January.
Last Update: July 25, 2019