Who is subject to student eligibility criteria?
A student between the ages of 18 and 49 who is enrolled at least half time in one of the following:
an institution of post-secondary education
a vocational or technical school
a program that provides for completion of a high school diploma or the equivalent
a school for the physically or mentally disabled
An institution of post-secondary education is any public or private educational institution that admits persons who are beyond the age of 16 or normally requires a high school diploma or equivalency certificate for enrollment. The institution must be legally authorized to provide an educational program beyond secondary education or to provide a training program that will prepare students for gainful employment.
Institutions of post-secondary education include but are not limited to:
Who is not subject to student eligibility criteria?
The student definition does not apply to persons who are:
under age 18 or age 50 or older
attending high school
participating in a training program provided by an employer
enrolled in schools and training programs that are not institutions of higher education
enrolled for the exclusive purpose of obtaining training in English as a Second Language (ESL), provided that the courses are not taken for credit as part of a total program
attending school less than half-time
physically or mentally unfit for employment
Student Eligibility Requirements
All students must be issued a Verification Checklist (VC-1) requesting completion of an EDUC-1. The VC-1 must also request a CCE-1 if a student attends a school that operates a Perkins IV program (identified below).
To be eligible for SNAP, a student must meet at least one of the following requirements. The student must:
for a minimum of 20 hours per week averaged monthly and be paid for such employment (verify with pay stubs or employee letter) or
if self-employed, be employed for a minimum of 20 hours per week averaged monthly and receive weekly earnings at least equal to the federal minimum wage multiplied by 20 hours (verify with current income and expense records)
participate during the school year in a federally or state-funded work-study program (verify with EDUC-1 form)
Massachusetts does not operate a state-funded work-study program.
be responsible for the care of a dependent household member under the age of six
be responsible for the care of a dependent household member who has reached the age of six but is under the age of 12 for whom adequate child care is not available to enable the student to attend school and work a minimum of 20 hours per week, or participate in a work-study program during the regular school year (self-declaration acceptable unless questionable)
be receiving TAFDC
be in receipt of the MASSGrant (verify with EDUC-1)
be assigned to or placed in an institution of higher learning through:
o a program under the Workforce Innovation and Opportunity Act (WIOA)
o a program under Section 236 of the Trade Act of 1974
If a client indicates that s/he is placed in a training program, you must explore whether the program falls is part of the JTPA or Trade Act of 1974. If you are not sure if the program qualifies, please email the Procedural Mailbox.
an employment and training program under the Food and Nutrition Act, or
a SNAP Path to Work Program employment and training program
under the Carl D. Perkins Career and Technical Education Improvement
Act of 2006 (Perkins IV), or in a course of study that would lead
Participation in a Perkins IV program is verified by the CCE-1.. Perkins IV institutions in Massachusetts are listed below.
be a single parent enrolled full-time in an institution of higher education and responsible for the care of a dependent child under the age of 12 regardless of the availability of adequate child care
To be exempt from the ABAWD Work Program Requirement as a student at least half-time, the Education page must reflect an active start date and an anticipated graduation date that is in the future.
The income and assets of an ineligible student must not be included in eligibility determinations.
To remove an ineligible student from the SNAP household, you must:
go to the AU Composition Results Page
click the AU Member tab
select the ineligible student
select Reason Category: Program Rules
select Reason: In School Beyond Secondary Level
If the student resides on-campus and more than 2 out of 3 daily meals are provided, s/he must be removed for the Reason: Institutionalized, including Incarceration. This will generate a notice that states, “you and/or a household member do not meet the program's rules because you are a resident of a facility that provides the majority of your meals.”
A student’s status does not change when the school is not in session, provided the student is enrolled for the next regular session. The enrollment status of a student begins on the first day of the school term of the institution and continues through:
normal periods of class attendance
semester breaks, and
vacation unless the student:
is expelled; or
If a student who was previously ineligible becomes eligible by meeting the student status rules, s/he may be able to receive SNAP benefits.
If a student who was previously ineligible becomes eligible during a period in which the student is continuously enrolled, for example during the summer, s/he may receive SNAP benefits.
A student who receives a MassGrant or meets one of the exemptions of the student status rules is ineligible if the student is currently boarding at school and receiving two out of three meals daily.
Please refer to examples provided at the end of the page.
A student is not subject to continuous enrollment rules if s/he enrolls for the first time and the start date is in the future.
Financial aid offices award work-study funds as part of a financial aid package. If a student accepts the package, these funds are distributed to the employer to pay the student in the form of work-study wages. If a student is unwilling or unable to participate in work-study, s/he will not derive eligibility through work-study. The student must be approved for work-study and anticipate actually working. The exemption does not continue between terms when there is a break of one month or more unless the student is participating in work-study during the break.
Verifying Work-Study During Breaks
If a student who derives eligibility through work-study has a break from school greater than one month and is at application, Interim Report, or Recertification, you must request wages or documentation from the school proving current participation in a work-study program. This is an exception to normal work-study eligibility and continuous enrollment clauses.
Work-study wages are not countable in the SNAP benefit calculation. Request of work-study wages is only required to verify current work-study participation during breaks.
Student Eligibility Forms
Educational Income and Expense form (EDUC-1)
This form must be provided to all clients who meet the student definition. The student completes the first part of the form. The financial aid office completes the second part of the form. You must review this form to verify:
that the client is required to meet student eligibility requirements because s/he is enrolled ½ time or more;
whether the student receives a MASSGrant;
whether the student participates in federal work-study (Massachusetts does not operate a state-funded work study program at this time);
whether the student has living expenses covered by a non-federal funding source;
You must enter the total amount in 8C as Education Assistance in the Other Income page. The number of months in the academic year must be entered in the Number of E/T months field so BEACON can calculate the monthly income accurately.
whether the student lives on campus
o if yes, whether 2 out of 3 daily meals are provided by a meal plan, making the student ineligible for SNAP.
Community College Enrollment form (CCE-1)
This form must be provided to students in a Perkins IV program. You must review this form to confirm that the client:
is required to meet student eligibility requirements because s/he is enrolled ½ time or more; and
is eligible because his/her Course of Study or Major is a career or technical education that will lead to employment.
This form does not apply to clients participating in a training program through SNAP Path to Work or attending a four-year college
Educational Loans, Grants, Scholarships, and Reimbursements
Certain sources of student income are excluded for SNAP purposes. For a list of excluded income, see 106 CMR 363.230(D).
Nonfederal reimbursements or allowances provided to the student for past or future expenses are excluded from income to the extent that they do not exceed the actual expense and do not represent a gain or benefit to the student. For a list of excluded reimbursements, see 106 CMR 363.230(F).
Financial aid offices complete the EDUC-1 to identify any portion of educational income/reimbursement that is countable for SNAP purposes.
Allowances for room and board are considered a gain or benefit and must be counted as income. Financial aid offices will verify this on question 8C of the EDUC-1.
The Carl D. Perkins Career and Technical Education Improvement Act of 2006
The following institutions operate eligible Perkins IV programs. You must send a VC-1with an EDUC-1 and a CCE-1 to students attending these schools.
Massachusetts Community Colleges
Berkshire Community College
Bristol Community College
Bunker Hill Community College
Cape Cod Community College
Holyoke Community College
Greenfield Community College
MassBay Community College
Massasoit Community College
Middlesex Community College
Mt. Wachusett Community College
North Shore Community College
Northern Essex Community College
Quinsigamond Community College
Roxbury CC Community College
Springfield Tech. Community College
Students may establish Massachusetts residency and attend an out-of-state community college near their home. These students must also be given a CCE-1.
Quasi-State Perkins IV Eligible
Benjamin Franklin Institute of Technology
Regional Vocational Technical Perkins IV Schools
The following schools are high schools that offer Perkins IV post-secondary programs. Students enrolled in these programs must have a high school diploma or HiSET. Students who attend these schools for a high school curriculum are not held to the student eligibility requirements.
Assabet Valley Regional Vocational Technical
Blackstone Valley Regional Vocational Technical
Blue Hills Regional Vocational Technical
Greater Fall River Regional Vocational Technical (Diman Regional Voc.)
Greater Lowell Regional Vocational Technical
Montachusett Regional Vocational Technical (Monty Tech)
Northern Berkshire Regional Vocational Technical (McCann Tech)
Shawsheen Valley Regional Vocational Technical
Southeastern Regional Vocational Technical (Southeastern Technical Institute)
Southern Worcester County Regional Vocational Technical (BayPath Regional)
Tri-County Regional Vocational Technical
Upper Cape Cod Regional Vocational Technical
Many schools disburse Perkins loans, but these are different than Perkins IV programs. If a client indicates that their institution participates in a Perkins IV program but it is not on this list, please contact the Procedural Mailbox.
Q1. If I interview a student and s/he verbally states that s/he does not meet any of the student eligibility criteria, should I still send the student eligibility forms?
A1. Yes. We must have verification before we can deny a client as an ineligible student so s/he understands the reason for denial.
Q2. Dante was previously a student and reported during an interview that he is not in school anymore and does not plan to return. How do I verify this?
A2. You do not need any further verification that the client is no longer enrolled. The client’s verbal statement is sufficient. If you suspect that the client is lying, for instance, if s/he was recently denied as an ineligible student, you may submit a fraud referral.
Q3. Lauren lives in Massachusetts but attends a community college in Connecticut that is not on the CCE-1 form. Is a CCE-1 required?
A3. If the client attends an out-of-state community college, but is resident of Massachusetts, you must send him/her a VC-1 with an EDUC-1 and CCE-1. If the client attends a technical school that is not on the list from the Department of Education (above), please contact the Procedural Mailbox to determine whether that school operates a Perkins IV program.
Q4. I received an EDUC-1 indicating Jackie attends school for the fall semester, from September through December. Question 8A lists $15,000 and 8C lists $2,000. Is any of this money countable? How do I enter it in BEACON?
A4. The amount reported on 8C is considered countable income. You must enter the amount on 8C in the unearned income page as Educational Income. In the Number of E/T months field, you must enter 4 because the client is only enrolled for the Fall semester (September, October, November, and December). The Number of E/T months field makes sure that the countable income is divided appropriately.
Q5. Hui attends a school that is not on the Perkins IV program list and does not have college or university in its name. Is she considered a student? Does she need to meet student eligibility requirements?
A5. In these instances, you should research the institution to see if it requires a high school diploma or equivalency certificate for enrollment. This information is typically on the institution’s website. If there is no such requirement, s/he does not need to meet student eligibility requirements.
Q6. Luigi attends Bridgewater State University. He is a junior and has a scanned EDUC-1 on file that is good through May 2017. Luigi’s certification period is from October 4, 2016-October 3, 2017. It is now April and his Interim Report is due. Do I need to issue a VC-1 with an EDUC-1?
A6. No. Although there is only one month left for the period the EDUC-1 covers, the EDUC-1 is considered current because the client is within the academic year at this point. Another EDUC-1 is not required at this time because the one on file covers the period through May 2017. However, if the EDUC-1 on file covered through December 2016, then a new EDUC-1 would be required.
Q7. If a student enrolled in school for the first time or s/he has formally withdrawn, and the semester has not started, are student eligibility forms required?
A7. No. The client is not considered a student until the semester begins unless s/he is considered a continuously enrolled student. In this example, the client has not been matriculated yet and is therefore not held to student eligibility requirements.
Q8. Bran is due to recertify in July and falls under the continuous enrollment clause because he is going into his junior year of college without any gaps in formal enrollment. I sent a VC-1 with an EDUC-1 but he called to say that the financial aid office has not completed award packages for the upcoming academic year yet. Should I let the case close or should I process it?
A8. In this instance, you should review student eligibility based on the previous academic year. If the client previously met student eligibility criteria, you should process the case maintaining the same eligibility reason. A detailed narrative must be left and an EDUC-1 will be required at the next reporting period.
If there was countable educational income reported on the previous EDUC-1, you should continue to use the same amount and advise the client that if the amount may be adjusted if it decreases, but does not need to report an increase until the next Interim Report/Recertification unless it puts the household over the gross income limit for its size.
Q9. Scott applied in January and provided an EDUC-1 that verified work-study. He anticipated participating in work-study over the spring semester. It is now June and Scott does not meet any other student eligibility criteria. He states that he is participating in work-study over the summer. Is verification required?
A9. In this instance, yes because verification of work-study participation is required during breaks longer than one month. This is contrary to other rules about continuous enrollment and anticipated participation. Scott must be sent a VC-1 for verification of work-study income.
Q10. Stephanie submitted an old version of the EDUC-1 form. Can I accept an old EDUC-1 or do I need to send the new version?
A10. You must accept old versions of the EDUC-1.
Q11. Drew is an ineligible college student as he does not meet any eligibility requirement for a college student. He is now off for the summer and plans to continue college in the Fall. Nothing has changed in his case. Can Drew be considered an eligible college student?
A11. Drew would still be considered an ineligible college student even in the summer as he still does not meet the student status rules.
Q12. Andrea was disqualified from SNAP during the school year because she was receiving a majority of her meals at school. However, she was considered an eligible college student as she received the MASSGrant. She is now off for the summer and moved back home with her parents. Can Andrea be considered an eligible college student?
A12. Since she is not boarding at this time, Andrea can now be considered an eligible college student as she is receiving the MASSGrant. You must not go in at the end of the summer and remove her or mark her as an ineligible college student based on Simplified Reporting rules. The next reporting period will adjust her eligibility status.
Q13. Jamie is at her recertification period in June. During the recertification interview, she states that she applied and was accepted at Berkshire Community College and will start in the Fall Semester. After the interview, she submits her completed EDUC-1 and CCE forms. After reviewing the forms, I notice she is not an eligible college student. Would continuous enrollment rules apply?
A13. No. Since Jamie’s start date is in the future, you cannot apply continuous enrollment rules. She is eligible for SNAP if otherwise eligible, as we will not apply the student rules until she starts school. At her next reporting period, you must review the forms and mark her as an ineligible college student if she still does not meet any eligibility requirements at that time.
Other Income Introduction
Students Policy and Procedures