Students

 

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 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:

 

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:

Note

When a client’s wage stubs or other earned income verification does not include the number of hours worked, but includes the client’s hourly rate, staff may calculate the number of hours worked. See Entering Number of Hours Worked When Not Available and refer to Student Examples provided at the end of this page.

 

 

Note

Massachusetts does not operate a state-funded work-study program.

 

o  a program under the Workforce Innovation and Opportunity Act (WIOA)

o    a program under Section 236 of the Trade Act of 1974

 

Important

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.

 

Participation in a Perkins IV program is verified by the CCE-1.. Perkins IV institutions in Massachusetts are listed below.

 

Important

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.  

 

Ineligible Students
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:

  1. go to the AU Composition Results Page

  2. click the AU Member tab

  3. select the ineligible student

  4. select Reason Category: Program Rules

  5. select Reason: In School Beyond Secondary Level

 

 

Note

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.”

 

Continuous Enrollment

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:

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.

 

Important

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.  

 

Work-study

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.

 

Note

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:

 

Important

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.

 

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:

 

Important

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.

 

 

Important

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

 

 

Note

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

 

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. 

 

 

Important

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.

 

Student Examples

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. 

 

 

Note

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.

 

Q14. William, 24, is applying for SNAP. During the application interview, he states that he is a student attending Boston University and that he works approximately 22 hours per week for a local business. In addition to his completed EDUC-1 form, William supplies his wage stubs for the previous four weeks. The wage stubs indicate:

When reviewing William’s verifications, the case manager notices that the wage stubs do not show the hours worked per week but do provide William’s hourly rate of $14.00 per hour. Is the case manager able to determine the number of hours worked for Student eligibility purposes with information provided?

A14. Yes. To determine the number of hours worked, the case manager handling William’s case performs the following calculations:

Based on this calculation, the FAW determines that William meets the Student eligible criteria as he is paid for a minimum of 20 hours per week, averaged monthly. 

Q15. Sarah, 20, is applying for SNAP. During her application interview, she states that she is a commuting, full-time student at UMASS Amherst and that she works approximately 25 hours per week. In addition to her EDUC-1, Sarah supplies her wage stubs for the previous four weeks. The wage stubs indicate:

When reviewing Sarah’s verifications, the case manager notices that the wage stubs do not show either the hours worked per week nor Sarah’s hourly rate. Is the case manager able to determine the number of hours worked for Student eligibility purposes with information provided?

A15: No, because the hourly rate is not provided, the case manager cannot calculate hours worked. Additionally, since Sarah meets the Student definition and is claiming eligibility through working for a minimum of 20 hours per week averaged monthly, a mandatory VC-1 must be sent requesting verification of hours or hourly rate. 

 

 

Earned Income Policy and Procedures

Other Income Introduction

Students Policy and Procedures

 

 

  Last Update:  January 9, 2020