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 an institution of higher education.

An institution of higher education is any public or private nonprofit educational institution that admits persons that have 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.

For SNAP eligibility purposes, students are considered enrolled in an institution of higher education if they are enrolled in:

Types of schools considered institutions of higher education include but are not limited to:

 

Who is not subject to student eligibility criteria?

SNAP student eligibility rules do not apply to persons who are:

 

Student Eligibility Requirements

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

o  an employment and training program under the Food and Nutrition Act, or

o  a SNAP Path to Work Program employment and training program

 

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.  

 

Community College Students

If a student is enrolled at a community college or at a post-secondary program at a vocational/technical school, this means they are enrolled in an eligible career and technical education  (CTE) program under the Carl D. Perkins Career and Technical Education Improvement Act of 2006 (Perkins IV) or in a program of study that would lead to employment. The student can provide either a telephonic or written self-declaration of the community college they are enrolled at. The school must be entered in BEACON and no additional verification is needed, unless questionable.

Massachusetts Community Colleges

Note

Students may establish Massachusetts residency and attend an out-of-state community college near their home.

Students who attend an out-of-state community college meet student status under the Perkins IV eligible program exemption.

 

Quasi-State Schools

Students meet the student exemption of being enrolled in a CTE program under Perkins IV or in a program of study that would lead to employment regardless if they are enrolled in a 2 or 4 year degree program at these schools:

 

Regional Vocational Technical Schools

 

Note

Students enrolled in post-secondary programs at these vocational/technical schools must have a high school diploma or HiSET, so therefore, are considered enrolled in an institution of higher education and meet the student exemption to be eligible for SNAP.

Students who attend these schools for a high school curriculum are not held to the student eligibility requirements (i.e., not considered enrolled in an institution of higher education).

 

Four Year College/University Students

If a client indicates they are a student at a four-year college or university, the student must meet at least one of the student eligibility criteria outlined above.

 

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, they 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, they may receive SNAP benefits.

Important

A student is not subject to continuous enrollment rules if the student 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, the student 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 Student Eligibility

Students can provide a telephonic or written self-declaration of the school they are attending and the student eligibility criteria they are claiming, unless the student eligibility criterion is required to be verified with documentary evidence, such as earned income. No further verification of student eligibility is required, unless questionable.

Example 1: Terry is applying for SNAP for themself and has reported that they are attending UMass Dartmouth and is a recipient of a MassGrant.  Terry telephonically signs that they are receiving a MassGrant.  They are an eligible college student, and no additional verification is needed as it is not considered questionable.

Example 2: Jovanny is reapplying for SNAP for themself and has reported that they are attending Amherst College and is participating in Work Study.  However, you reviewed Jovanny’s case, and noticed that Jovanny was recently denied SNAP two weeks prior as an ineligible college student because they voluntarily provided their Financial Aid Award Letter which did not indicate that they met any student eligibility criteria, including being eligible for Work Study.  You must disposition the auto populated Financial Aid and School Enrollment verification item and create a mandatory User-Entered Additional Verification item for student eligibility as their financial aid award of work study is now considered questionable and documentary evidence is required.  

Example 3: Rachael is applying for SNAP for themself and has reported that they are attending Boston University and is working at Target for an average of 20 hours per week.  Rachael is considered an eligible college student based on working an average of 20 hours per week; however, verification of their wages is mandatory as the income is also countable for the purposes of SNAP eligibility.  A mandatory VC-1 must be sent for the wages.

Important

If a student is working on-campus and the employment is not tied to any financial aid award, the wages are considered countable earned income.

 

Conversation With a Household Member About Student Eligibility

When a client indicates that they or a household member is a college student, you must ask them to indicate the name of the college they attend.  If this is not a community college, you must continue to screen for student eligibility. You must start with eligibility requirements that are based on household circumstances.

 

Eligibility Based on Household Circumstances

This is likely to be information we would have in BEACON.

  • are they receiving TAFDC and/or enrolled in a TAFDC Pathways to Work program,

  • is there a child in the household under 6 years old,

  • are they responsible for the care of a dependent household member who is between the ages of 6 and 12 for whom adequate childcare is not available to enable the student to attend school and work a minimum of 20 hours per week,

  • are they 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 childcare,

  • are they working an average of 20 hours per week, or

  • are they federally certified as disabled?

If the student does not meet student eligibility criteria based on being enrolled in a community college or for any of the household circumstances mentioned above, you must ask the student if they:

  • have received any documentation such as their financial aid award letter, an email/letter from the Department of Education, or Student Aid Report (SAR) stating they have been awarded a MassGrant.

  • are unable to work due to being physically or mentally unfit

    • Questions to ask the student if they state they are physically/mentally unfit for employment but are not federally disabled:

      1. Are you in receipt of temporary or permanent disability benefits from a government or private source?

Important

If the client indicates they are in receipt of benefits, proof of income is required for SNAP eligibility, unless the Department can verify the income through data sources.

 

  1. Has your physician or licensed/certified psychologist deemed you physically or mentally unfit for employment?

  2. Do you participate in a Massachusetts Rehabilitation Commission program or other Massachusetts approved vocational rehabilitation programs?
    *If YES to any of the above questions, the client can telephonically self-declare they meet student eligibility criteria based on being physically/mentally unfit for employment.

  • participate during the school year in a federally or state-funded work-study program

  • are participating in an on-the-job training program. A person is considered to be participating in an on-the-job training program only during the period of time the person is being trained by the employer,

  • are enrolled in an employment and training program subject to the condition that the course or program of study is limited to remedial courses, basic adult education, literacy, or English as a Second Language (ESL),

  • have been assigned to or placed in an institution of higher education through:

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

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

    • an employment and training program under the Food and Nutrition Act, or

    • a SNAP Path to Work Program employment and training program

Questions to ask the student if they state they are enrolled in an employment/training program (except for SNAP Path to Work, as that can be verified with the SNAP E&T unit):

  1. Do you receive any part of your training program through an institution of higher education such as a trade/vocational tech school, college, or university?

    • If NO, client is not considered a student and is not subject to SNAP student eligibility criteria.

  2. Did a MassHire Career Center, the Department of Unemployment Assistance (DUA), or another government agency help you enroll in your training program?

  3. Are you participating in a training program or receiving training at no cost?
    *If YES to all three questions, the student’s training program meets student eligibility, and it is not considered questionable.  If the student answers NO to questions 2 and/or 3, the eligibility of their training program is considered questionable, and verification must be requested.

Note: For some of these student eligibility items, a parent/guardian (or any head of household that is not the student) completing the interview may not readily know.  If you sense that this is the case, you must issue a VC-1 requesting proof of student eligibility.  If the student or head of household contacts the Department and states the student exemption and it is not questionable, you must verify the student exemption via telephonic self-declaration.  You must not request further verification.

If student eligibility is not already a part of the case record (i.e., child under 6 or wages with a minimum of 20 hours per week) the client can provide a telephonic or written self-declaration to verify student information, (i.e., the name of their school, how they are meeting the student eligibility requirement, and when applicable, total meals included in their meal plan). Staff must complete a detailed narrative capturing the information the client telephonically verifies.

Important:  A student can attest to the name of their school, student eligibility reason, and their meal plan status (if applicable) all in one telephonic signature.

 

Documentary Evidence is Required When Student Eligibility is Considered Questionable

In most cases, proof of student eligibility can be self-declared. However, there may be certain situations where student eligibility is questionable, such as a client indicating student status based on a MassGrant, but previous financial aid documentation voluntarily provided from the same academic year does not verify this particular eligibility factor.

In these instances, documentary evidence is required.  Below are ways students can verify their student eligibility, and instances when student eligibility is considered questionable.

 

Student Exemption

Examples of When Student Eligibility is Considered Questionable

Verification

Receives MassGrant

There is previous documentary evidence on file from the current academic year that does not indicate MassGrant

Client previously applied within the same academic year and stated they did not meet any student eligibility criteria and now stating they do meet student eligibility by receipt of MassGrant

Financial Aid Award letter

Participating in Work Study

There is previous documentary evidence on file from the current academic year that does not indicate Work Study

Client previously applied within the same academic year and stated they did not meet any student eligibility criteria and now stating they do meet student eligibility by receipt of Work Study

Financial Aid Award letter or pay stubs

Participating in an on-the-job training program

Client states they are not currently working

Letter from the employer

Enrolled in an employment and training program provided that the course or program of study is limited to remedial courses, basic adult education, literacy, or English as a Second Language (ESL)

Client is unsure of the type of training program they are in

Letter from the program the client attends

Placed in an employment and training program through the Workforce Innovation and Opportunity Act (WIOA)

Client indicates that they have to pay out of pocket for the training

The client is unsure if the training is affiliated with the MassHire Career Center or other government agency

Letter from the institution or MassHire Career Center

Placed in an employment and training program through Trade Adjustment Assistance (TAA)

Client indicates that they have to pay out of pocket for the training.

The client is unsure if the training is affiliated with the Department of Unemployment Assistance (DUA) or the MassHire Career Center

Letter from MassHire Career Center

Letter from the Department of Unemployment Assistance (DUA) confirming that the client is approved for TAA training

Mentally or physically unfit for employment

Client is currently working or has recent work history

In receipt of temporary or permanent disability benefits from a government or private source

Note: Verification of benefits needed as this is also considered countable income for SNAP eligibility

Proof of participation in a Massachusetts Rehabilitation Commission program or other Massachusetts approved vocational rehabilitation programs

Letter from the student’s physician/certified psychologist stating the student is physically or mentally unfit for employment

 

Meal Plan

Verifying whether a student has a meal plan is another aspect that is related to student eligibility but pertinent only to students who reside and attend 4-year colleges or universities.

The goal is to determine whether or not the student receives a majority of meals through their meal plan. If a client reports that there is a college student in their SNAP household, staff must ask if the student has a meal plan that covers at least 2 out of their 3 daily meals or 14 or more meals per week.

You must verify whether the student has a meal plan by asking:

“Do you have a meal plan that provides at least two out of three of your daily meals or 14 or more meals per week?”

The client can provide a self-declaration verifying their meal plan, unless questionable.

 

Note

A student can attest to the name of their school, student eligibility reason, and their meal plan status in one telephonic signature.

 

Remember

Staff must not deny a client simply because the client participates in a meal plan at an institution of higher education. Instead, staff must determine the scope of an applicant’s meal plan to determine eligibility.

 

Verifying a Meal Plan When it is Considered Questionable

If the student response is considered questionable (such as, but not limited to the student indicating that they live on campus full-time but state they do not have a full-time meal plan or no meal plan at all), actual proof of the meal plan status is required.  This can be verified by sending a mandatory VC-1 requesting a copy of the student bill or any other document the student can provide that shows whether they have a meal plan for the current academic year.

If the student is having difficulty obtaining verification, assist the student by instituting collateral contact. It will be easier to make this call with the student on the other line so that the staff at the school understands that the student permits them to provide this information to DTA.

If verification is received that at least 2 out of 3 daily meals are provided or the meal plan accounts for 14 or more meals, the student must be denied 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.”

If the student indicates that they receive a meal plan that covers the majority of their meals, the student is not eligible for SNAP even if they meet one or more student eligibility criteria.

 

Important

A student attending community college or living off-campus is not boarding at school so you must not explore verification of meal plan for such students.

 

 

How to Request Proof of Student Eligibility and/or Status of a Meal Plan When it is Considered Questionable

When staff enter the student’s education information in BEACON, an auto populated verification for the EDUC-1 and CCE forms will populate. Despite this configuration in BEACON, the Department is no longer using the EDUC-1 or CCE forms. Staff will need to disposition the auto populated verification items to prevent the VC-1 from erroneously going out.  Staff will then need to create a User-Entered mandatory verification request. The steps below outline this process.  

  1. To disposition the auto populated Financial Aid and School Enrollment verification item, you must select Other in the Verification Details page and write Mandatory Verification of Student Eligibility Requested in the Other comment section. This will verify the item so that the EDUC-1 information will not be printed on the VC-1.

  2. To disposition the auto populated Community College Enrollment verification item, you must select Other in the Verification Details page and write Mandatory Verification of Student Eligibility Requested in the Other comment section. This will verify the item so that the CCE information will not be printed on the VC-1.

  3. To request verification of student eligibility, you must create a User-Entered Additional Verification as mandatory and in the Details field, enter Student Eligibility.

  4. The below VC-1 Document(s) of evidence section must be copied and pasted in its entirety as students may not exactly know what type of student exemption they may meet.  However, the VC-1 language will not be able to fit in one Document(s) of evidence row due to character count limits.  You must space out the VC-1 language by adding additional rows, as indicated in the Document(s) of evidence language below (Step 5). For more information, please see Utilizing Additional Rows in the User Entered Additional Verification Element.

  1. Annotate the Document(s) of Evidence section:

{+ Add Row}

“You told us that you or someone in your household is a college student.  You can call and tell us if the student meets an eligibility reason below or send us any documentation verifying that the student:

{+ Add Row}

{+ Add Row}

{+ Add Row}

 

Meal Plan

  1. To request verification of a meal plan, you must create a User-Entered Additional Verification as mandatory and in the Details field, enter Meal Plan.

  2. Annotate the Document(s) of Evidence section with:

“You told us you are a college student that has a meal plan.  Please provide a copy of your meal plan.”

 

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 two out of three of their daily meals are provided through a meal plan, the client 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.”

 

 

Educational Loans, Grants, Scholarships, and Reimbursements

Educational income is not countable for any DTA program.  When a client indicates that they are a student, you must not inquire or request verification of any type of educational income such as grants, scholarships, assistantships, and fellowships.  This includes educational grants, scholarships, and educational stipends awarded by a college, a nonprofit organization or private company.

Note

If the client has a campus job that is not funded through work study or any type of financial aid, this income is countable as regular wages.

 

Student Examples

Q1. Dante (he/him) 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?

A1. 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 the client was recently denied as an ineligible student, you may submit a fraud referral.

 

Q2. Hui (they/them) attends a school that is not on the list of community colleges or vocational/technical schools that have eligible programs under Perkins IV or programs that would lead to employment. Is the client considered a student? Does the client need to meet student eligibility requirements?

A2. In these instances, you are to research the institution or program to see if it requires a high school diploma or equivalency certificate for enrollment. This information is typically on the institution’s website. If a high school diploma or equivalency certificate is required for enrollment, Hui must meet student eligibility requirements. If there is no such requirement, Hui does not need to meet student eligibility requirements.

 

Q3. If a student enrolled in school for the first time or has formally withdrawn, and the semester has not started, does student eligibility need to be explored?

A3. No. The client is not considered a student until the semester begins unless the client 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.

 

Q4. Bran (they/them) is due to recertify in July and falls under the continuous enrollment clause because the client is going into their junior year of college without any gaps in formal enrollment. Bran states that they will not know what their financial aid package will be, as they have not completed award packages for the upcoming academic year yet. Should I let the case close or should I process it?

A4. In this instance, you must review student eligibility based on the previous academic year. If the client previously met student eligibility criteria, you are to process the case maintaining the same eligibility reason. A detailed narrative must be left and student eligibility will be explored at the next reporting period.

 

Q5. Drew (he/they) is an ineligible college student as they do not meet any eligibility requirement for a college student. Drew is now off for the summer and plans to continue college in the Fall. Nothing has changed on the case. Can Drew be considered an eligible college student?

A5. Drew would still be considered an ineligible college student even in the summer as they still do not meet the student status rules.

 

Q6. Andrea (she/her) was disqualified from SNAP during the school year because she was receiving a majority of their meals at school. However, Andrea was considered an eligible college student as she received the MASSGrant. Andrea is now off for the summer and moved back home with their parents. Can Andrea be considered an eligible college student?

A6. Since the client is not boarding at this time, Andrea can now be considered an eligible college student as they are receiving the MassGrant. You must not go in at the end of the summer and remove the client or mark the client as Institutionalized based on Simplified Reporting rules. The next reporting period will adjust the client’s eligibility status.

 

Q7. Jamie (they/them) is at their recertification period in June. During the recertification interview, Jamie states that they applied and was accepted at Tufts University and will start in the Fall Semester. During the interview, I notice she is not an eligible college student based on the interview. Would continuous enrollment rules apply?

A7. No. Since Jamie’s start date is in the future, you cannot apply continuous enrollment rules. The client is eligible for SNAP if otherwise eligible, as we will not apply the student rules until school starts. At the next reporting period, you must review student eligibility and mark Jamie as an ineligible college student if Jamie still does not meet any eligibility requirements at that time.

 

Q8. William (he/him), 24, is applying for SNAP. During the application interview, William states that he is a student attending Boston University and works approximately 22 hours per week for a local business. William supplies his wage stubs for the previous four weeks. The wage stubs indicate:

When reviewing William’s verifications, I notice that the wage stubs do not show the hours worked per week but do provide William’s hourly rate of $15.00 per hour. Am I able to determine the number of hours worked for student eligibility purposes with information provided?

A8. Yes. To determine the number of hours worked, you must perform the following calculations:

Based on this calculation, William meets the student eligibility criteria as William is paid for a minimum of 20 hours per week, averaged monthly.

 

Q9. Sarah (she/her), 20, is applying for SNAP. During the application interview, Sarah states that she is a commuting, full-time student at UMass Amherst, and works approximately 25 hours per week. Sarah supplies wage stubs for the previous four weeks. The wage stubs indicate:

When reviewing Sarah’s verifications, I notice that the wage stubs do not show either the hours worked per week nor Sarah’s hourly rate. Am I able to determine the number of hours worked for student eligibility purposes with information provided?

A9. No. Since the hourly rate is not provided, you must take Sarah’s telephonic self-declaration of the number of hours they work to determine student eligibility. However, if the hourly rate is less than the minimum wage amount Sarah reports, this would be considered questionable, and actual proof of Sarah’s hours worked must be provided.

 

Q10: Zion (they/them) is a graduate student at Tufts University.  They indicate that they participate in an assistantship and works an average of 20 hours per week.  Zion does not meet any other student eligibility criteria.  Is Zion an eligible student?  Do I count the assistantship income, and does it need to be verified?

A10: Zion is not an eligible college student as the assistantship is considered noncountable educational income, and therefore cannot be used for meeting student eligibility criteria by working 20 hours per week.

Note

Students may establish Massachusetts residency and attend an out-of-state community college near their home.

 

Q11:  Soleil (she/they) is 19 years old and is a college student.  They are applying with their parents as they all live together and purchase and prepare food together.  Soleil’s mother, Ivana, is completing a telephonic SNAP application and indicates that Soleil is a college student at a four-year university.  When I review the student eligibility criteria, Ivana is not sure if Soleil meets any of the exemptions.  What should I do?

A11:  Since Ivana does not know if Soleil meets college student eligibility, you must issue a mandatory VC-1 for Student Eligibility.  You must tell Ivana that they can contact the Department and complete a telephonic self-declaration or provide any of the verifications listed on the VC-1.

 

Q12: Jeremiah(he/him) is applying for SNAP and indicates he is a college student.  Jeremiah meets student eligibility as he is participating in Work Study.  During the interview, Jeremiah states that he is receiving a scholarship from their local Credit Union to go towards school expenses.  Do I count the income from the local Credit Union?  Does Jeremiah need to verify this income?

A12:  No, Jeremiah does not need to verify the scholarship from the local Credit Union, as all educational income, including scholarships and grants received from entities outside of the college or university is also noncountable income for all DTA programs.

 

Q13: Nala (she/her) applies for SNAP for herself.  Nala indicates that she receives the MassGrant and reside on campus full-time in the student apartments, and only has a part-time meal plan that covers one meal a day on weekdays, as Nala has a full kitchen in her apartment. Is Nala eligible for SNAP?

A13: Yes, Nala is eligible for SNAP as they meet student eligibility criteria by being in receipt of the MassGrant.  Additionally, Nala has a meal plan that only covers one meal per day on weekdays, which is less than 50 percent or more meals covered per day.  Therefore, Nala is eligible for SNAP.

 

Q14: Jodie (they/them) applies for SNAP for themself.  Jodie indicates that they attend Quincy College and are enrolled in the Bachelor of Science, Business Management program.  Since Quincy College is a quasi-state school, does Jodie qualify as an eligible student based on their program and attendance at Quincy College?

A14: Yes.  Since Quincy College offers eligible CTE programs under Perkins IV or programs that would lead to employment, Jodie is considered an eligible college student by being enrolled at Quincy College regardless of the type of degree Jodie is enrolled in.

 

Earned Income Policy and Procedures

Other Income Introduction

Students Policy and Procedures

 

 

  Last Update:  June 22, 2023