This page describes the rules for the Supplemental Nutrition Assistance Program (SNAP). It is part of the report The State of State Choices: A national landscape analysis of postsecondary eligibility restrictions and opportunities in SNAP, CCDF, and TANF. Click here to return to the main page or continue reading below.

Introduction and Background on Students and SNAP

On college campuses across the country, rates of student food insecurity and hunger have remained high and consistent for years, disrupting the educational aspirations of millions of students. However, not all students experience food insecurity equally. According to The Hope Center survey, 39% of students at two-year institutions and 29% at four-year institutions experience food insecurity, with even higher rates among Black, Indigenous, LGBTQ, parenting students, and other systemically marginalized groups.^[1] At Historically Black Colleges and Universities (HBCUs), 46% of students experienced food insecurity, compared to 32% of students at other minority-serving institutions (MSIs).^[2]

Students holding multiple systemically marginalized identities, including first-generation college students or students facing economic challenges, often find themselves navigating outdated public benefit rules that perpetuate the assumption that a majority of students  come from White, middle-income homes and are supported by their parents through their college journey.^[3] In many instances, the groups most likely to experience food insecurity also face other forms of basic needs insecurity as well.

Unfortunately, these students and families must often navigate a confusing patchwork system of financial aid, emergency aid, and public benefits. These programs—when they are available and accessible—can help reduce the risk that families go hungry. Students may stop out of school because they cannot afford healthy and balanced meals.

The Supplemental Nutrition Assistance Program (SNAP)—the nation’s largest anti-hunger program—helps families afford adequate food, improves health outcomes, and reduces poverty.^[4];[5] For eligible students, increased access to public benefits like SNAP is associated with an increase in retention and college completion.^[6] However, despite the fact that states hold some flexibility in how they interpret the SNAP rules, few states have taken action to improve access to food subsidies for students as a way to alleviate campus food insecurity.^[7]

SNAP Eligibility

Everyone who applies for SNAP must meet stringent criteria that include income, assets, household, and immigration status requirements. Eligibility is then assessed by determining if a household qualifies for an exemption or if they must meet SNAP’s work requirements to receive food assistance. The SNAP program has six statutorily mandated data matches that are required as part of the SNAP certification process and has one of the most rigorous payment accuracy systems. Despite extensive guardrails, many college students find themselves excluded from the program due to outdated and confusing restrictions that the Government Accountability Office (GAO) found were among the most confusing and hardest to administer in the entire SNAP program.^[8]

To meet the income and asset eligibility requirements of SNAP, most households must earn at or below 130% of the federal poverty guidelines and their assets must be at or below $2,750.^[9] Households may be categorically eligible for SNAP based on being eligible for or receiving benefits from other specified assistance programs.^[10] A SNAP household is normally a group of people who live together, buy food, and prepare meals together. Some people who live together, such as spouses and most children under age 22, are included in the same household, even if they purchase and prepare meals separately.

SNAP participants are also subject to work requirements unless they qualify for an exemption.^[11] Most people (non-exempt individuals) are subjected to one or both of SNAP’s work requirements and must participate in a list of approved activities for a minimum number of hours each month (known as “activity requirements”). Hours spent in a college class or doing homework do not count toward the work or activity requirements. Further, people who are deemed students must meet an additional set of criteria to receive SNAP.

SNAP enrollment eligibility is also based on enrollment intensity. Generally, a student enrolled less than half-time must meet the aforementioned activity requirements. Students who are enrolled half-time or more (and who also meet income, household, and citizenship requirements) must meet separate—and onerous—eligibility criteria set by federal law. ^[12] These eligibility restrictions have contributed to the common misunderstanding that most students attending college are ineligible for SNAP.

However, students enrolled at least half-time (as determined by the institution of higher education) can qualify by meeting one of the following criteria:

1. Age 17 or younger, or age 50 or older, or
2. Physically or mentally unfit, or
3. Receiving Temporary Assistance for Needy Families (TANF) cash assistance, or
4. Enrolled in a TANF Job Opportunities and Basic Skills program, or
5. Caring for a dependent child under the age of 6, or
6. Caring for a child aged 6 to 11 and lacking the adequate child care to attend school and work 20 hours a week or participate in work-study, or
7. Single parent enrolled full-time and caring for a dependent child age 12 or under, or
8. Working 20 hours a week averaged over a month, quarter, trimester or semester, or
9. Participating in a state or federally funded work-study program during the school year, or
10. Participating in an on-the-job training program, or
11. Assigned to, placed in, or self-placed in one of the following employment and training programs in an institution of higher education including:
    • A Trade Adjustment Assistance Program under Section 236 of the Trade Act of 1974.
    • A program under Workforce Innovation and Opportunity Act of 2014 (formerly the Job Training Partnership Act);
    • An employment and training program that meets the definition of a Carl D. Perkins Career & Technical program designed to be completed in no more than four years, or that is limited to remedial, basic adult education, literacy, or English as a second language.
    • An employment and training program that meets the equivalent criteria as determined by the state agency where at least one component is equivalent to a SNAP employment and training program operated by a state or local government.

While these exemptions are overly complicated, they do provide a pathway for some students to get SNAP. The rules result from outdated perspectives about who students are or who they should be. Some policymakers erroneously assume that all students have parents with incomes that will cover their living expenses or live in residence halls with meal plans. Deficit-based narratives about people of color and people with low incomes have also fueled work-first policies that emphasize low-wage work over education.

A student who is taking classes is making an investment in their financial future, engaging in an activity that holds more value to the student and society, yet SNAP eligibility rules don’t count education among approved activities. We know that many students with low incomes work because they need to make ends meet, yet more work is correlated with less successful higher education outcomes.

Due to confusing eligibility rules and a lack of outreach to students,^[13] college students have a low SNAP take-up rate even if they are income-eligible and food insecure. The rates of SNAP use among students are much lower than the general population. According to a Government Accountability Office (GAO) report in 2018, just 43% of students who were potentially eligible for SNAP and at risk of food insecurity were enrolled in SNAP.^[14] They also found that just 31% of college students overall who meet SNAP income limits reported receiving benefits.¹⁵ In comparison, 82% of all eligible participants across the total population of adults received SNAP nationwide in 2019.^[16]

According to the most recent Hope Center data, only 24% of students at two-year institutions, and just 11% of students at four-year institutions, who experienced basic needs insecurity received SNAP benefits.^[17] In other words, between 76% and 89% of students who reported not having enough to eat were not receiving any federal food assistance to help with that urgent problem. SNAP’s eligibility restrictions uniquely fail to support students and hinder their ability to advance through postsecondary education.

The inability of students to access SNAP benefits is also increasingly problematic because the average age of college students has increased, and more students are also caring for a dependent child.^[18] These students often need far more in the way of financial and basic needs supports than those who attend college immediately after high school and can rely on family or other resources.

SNAP State Flexibility

SNAP, once known as “food stamps,” was created in 1964 through the Food Stamp Act and has become an essential program for families with low incomes across the U.S. Because SNAP is a means-tested entitlement program, the number of people eligible for the program increases when economic circumstances result in lower incomes and increased hardship. In the early part of the COVID-19 pandemic, enrollment in SNAP increased. In February 2020, almost 19 million households participated in SNAP. By May 2022, a little over 21.5 million households were enrolled.^[23]Through three rounds of relief bills in 2020 and 2021, Congress responded to rising food insecurity and economic uncertainty by temporarily maximizing SNAP benefits, waiving certain eligibility rules, adding new criteria for student eligibility, and suspending time limits.^[24] These pandemic-era changes allowed a greater number of students to qualify and stay enrolled in SNAP.

While SNAP benefits are completely funded by the federal government, the costs of administration are shared with states. States have considerable flexibility to administer their SNAP program based on their needs. This flexibility allows states to use discretion in implementing or interpreting certain program requirements that can impact how all people, including students, access the program.

For example, over the years, a variety of states have adopted what is called “broad-based” categorical eligibility (BBCE) to improve access to SNAP. While households in all states can be categorically eligible for SNAP if they qualify for and receive certain other means-tested benefits such as TANF cash assistance, BBCE allows states to additionally raise the gross income limit for SNAP as well as adopt less restrictive asset tests by allowing qualification through state-determined TANF non-cash benefits and services.^[25] Income and asset eligibility are usually two of the most restrictive tests in general federal eligibility. As of February 2022, there are 41 states, plus the District of Columbia, that utilize BBCE.^[26] The following nine states do not allow BBCE: Alaska, Arkansas, Kansas, Mississippi, Missouri, South Dakota, Tennessee, Utah, and Wyoming. BBCE is discussed in more detail below.

Under a federal law known as the Personal Responsibility and Work Opportunity Act of 1996 (PRWORA), an applicant’s immigration status also factors into SNAP eligibility. Undocumented and Deferred Action for Childhood Arrivals (DACA) individuals are not eligible for SNAP, and lawfully present immigrants must meet additional eligibility requirements.^[27] However, states can provide food assistance to qualified immigrants who are ineligible for federal benefits with their own state-funded programs. Currently, six states, including California, Connecticut, Illinois, Maine, Minnesota, and Washington, provide food assistance to certain noncitizens who were ineligible for SNAP benefits, although program eligibility varies by state.^[28]

Once participants meet the above criteria, SNAP participants are required to register for work, participate in SNAP Employment and Training or workfare^[29] if assigned, take a suitable job if offered and not voluntarily quit a job or reduce work hours below 30 a week without good reason, unless exempt.^{[30]; [31]} Adults aged 18 to 50 without children in the home  (although older adults will soon see new limits).^[32]

Students attending an institution of higher education more than half time are exempt from this time limit, but students less than half time without a dependent would be subject to the three-month limit unless they meet the 20-hour work requirement. Additionally, states with high unemployment may temporarily waive the time limit.

These requirements are meant to encourage work and move participants off benefits as soon as possible. However, they stem from a long legacy of racist assumptions about people on welfare programs,^[33] perpetuate the idea that certain groups are undeserving of public support, and promote the stereotype that people need to be coerced to work.^[34] Research shows that work requirements also fail to increase employment and income, rendering these rules ineffective and counterproductive.^[35]

State-by-State Student Rules in SNAP

As mentioned, states have discretion in how they determine eligibility for SNAP, and how they administer certain eligibility rules like work requirements and exemptions based on work-study and employment and training programs (SNAP E&T). Yet this information is often not readily available to students who may be experiencing food insecurity. Federal resources often point students toward a confusing maze of state websites that can make eligibility difficult to decipher.

Through a systematic scan of state-by-state policy manuals, we have identified state rules for students pursuing higher education more than half-time.^[36] These state rules are listed in as illustrated in the state-by-state map below. By looking across states, we can examine which states are expanding access and eligibility to their fullest potential, which states could go further, and how best to inform outreach strategies to students who may be eligible for SNAP but are not currently receiving benefits. The state manuals gave insight into four main flexibilities:

• how income or asset limits are used for all participants;
• how a student’s work hours are calculated or averaged to meet the 20-hour per week work requirement;
• how a state interprets work-study requirements; and
• how a state defines programs as comparable to SNAP E&T, particularly for programs that meet the definition of Carl D. Perkins Career and Technical Education Act^[37] (CTE) or that increase students’ employability.

In these four areas and others, states have the authority to make a difference in a students’ ability to access and receive SNAP benefits long-term. In the state-by-state map below, we highlight how states are using these flexibilities, including states that are utilizing broad-based categorical eligibility, states that allow for more flexible work hour determinations, states that define work-study participation more broadly, and states that reduce those impacted by work requirements by streamlining the process of determining which programs are comparable to a SNAP E&T program component.

Means-Testing: Broad-Based Categorical Eligibility (BBCE)

BBCE allows states to increase the income limits that allow certain households to qualify for SNAP up to 200% of the federal poverty guidelines (sometimes referred to as “federal poverty level”). Of the states that allow BBCE, 19 states expanded the gross income limit to 200% of federal poverty guidelines, while nine states kept their gross income artificially limited at 130% of federal poverty. The regular federal gross income limit can abruptly cut participants off benefits when their income reaches 130% of federal poverty, creating an economic “cliff effect” and throwing low-income families further into economic hardship. For a family of three in 2024, 130% of the federal poverty guidelines translates to just $25,820 annually or $2,152 monthly in most states,^[38] meaning those earning more than this are at-risk of being ineligible for vital food assistance.

Additionally, under BBCE, states have the authority to eliminate any “asset limit” for SNAP by using the asset limit of the TANF benefit or service. Currently, 36 states plus the District of Columbia have eliminated asset limits. By having no asset limit, families are allowed to build savings to better protect themselves from emergencies and support themselves in the long run without worrying about being disqualified for SNAP. While using BBCE and eliminating asset tests could benefit all SNAP participants, this would also expand access for students and their families who are balancing the combined costs of higher education and their basic needs.

Counting Student Work Hours

Under federal rules, a student must generally work 20 hours a week on top of their studies to maintain SNAP eligibility unless they meet one of the other narrow exemptions. This work threshold may seem straightforward, but each state has the authority to determine the timeframe on which students' work hours are counted—for example, whether the average of 20 hours is counted by month or academic term.^[39]

There are many reasons why students may need to reduce work hours in a given week—from family responsibilities, illness, an intense academic period, unexpected emergencies, or because their employer cuts their hours. Federal rules say “the State agency may choose to determine compliance with this requirement by calculating whether the student worked an average of 20 hours per week over the period of a month, quarter, trimester or semester.” Still, there remains confusion and ambiguity for students who may need to reduce their work hours in a given week. States have flexibility in how they “average” student work to meet the 20-hour threshold. They should use the broadest possible timeframe to average work hours in order to ensure students do not lose benefits.

After examining each state’s administration manual, 28 states currently average work hours across the month. By averaging by month, students are allowed some flexibility in how many hours they can work each week as long as they meet the 80-hour requirement by the end of the month. A student who falls behind 20 hours in one week due to extra academic responsibilities, illness, or caring for family can make up those hours another week without losing SNAP benefits. Wisconsin is the only state that clearly allows students to average work hours across a semester due to contractual and fluctuating employment.

Unfortunately, 22 states plus the District of Columbia are not explicit in how work hours were averaged and indicate only that students need to work 20 hours “per week,” potentially creating confusion or fear if a student needs to reduce work. Ohio and Maryland—the most restrictive states—explicitly state that averaging across a month is not allowed.

States need to stipulate policies that allow students to average their hours across a month or more (ideally, an academic term), as student’s work schedules can fluctuate frequently, as well as course loads and unforeseeable emergencies may arise.

Work-Study Flexibility

When analyzing work-study, federal regulations state that “the student must be approved for work-study at the time of application for SNAP benefits, the work-study must be approved for the school term, and the student must anticipate actually working during that time.”^[40] However, states have flexibility in how they interpret the words in this definition, because federal work-study rules do not define either “approved” or “anticipation.” Neither words appear in the Higher Education Act of 1965.

Even when a school has adequate funding for work-study, eligible positions on or near campus may be tough to come by. For example, students might be eligible for state or federal work-study, have received an amount for this assistance in their financial aid offer, and still await a placement. CRRSAA temporarily expanded and clarified this exemption by allowing all students who are eligible for state or federal work-study to bypass the work requirement. However, state flexibility in administering definitions are key now that the public health emergency (and this flexibility) has expired.

Prior to CRRSAA, California was the leading state to utilize federal flexibility to interpret what it means to be “approved” and “anticipating participation” in work-study for students to be exempted from the SNAP work requirement. Colleges in California are permitted to determine whether they deem a student to be “approved” for work-study at the college level. If a student plans to participate in the work-study program once a position or funds are made available, the student qualifies for the exemption. They will not be penalized if work has not yet started. Their manual explains, “… a student shall be deemed to be ‘anticipating participation’ in work-study until he or she receives notices from the institution of higher education that he or she has been denied participation in work-study,” and further, that “a work-study job assignment which has not yet begun or is not yet available does not prevent the student from meeting the criteria for this exemption.”^[41] This is especially helpful for students awaiting work-study placement during a term when there are fewer positions, such as a summer term when campuses are not operating at full capacity. Further, if a California student is approved for work-study and a position does not open, the student is not penalized for that term.

A total of 9 states have implemented some flexibility within the work-study rule. For example, Oregon no longer requires students to present a start date or other information about their work-study employment to determine eligibility. They state that a student would need to be awarded work-study and “anticipate starting a position in the school term” to be considered eligible.^[42] Additionally, Washington updated their state manual in 2019 to clarify that if a student foresees and expects to be assigned to a work-study job, they are eligible, even if the job is not yet available or has not yet begun. In six states (Arkansas, Maryland, Ohio, Mississippi, Montana, and South Dakota) state manuals also give some indication of possible flexibility. For instance, Arkansas allows students to remain eligible even if they stopped working because funding ran out. Others emphasize that a student anticipating participation should not be penalized if a work-study assignment does not materialize or has not started yet, unless they gave wrong or misleading information. Guidance for other states was not found.

Programs that Increase Employability

All students enrolled in programs that are determined by the state to be “comparable” to a SNAP E&T program component are exempt from the work requirement. Federal rule states that this includes “an employment and training program for low-income households that is operated by a State or local government where one or more of the components of such program is at least equivalent to an acceptable SNAP employment and training program component as specified in § 273.7(e)(1).”^[43] Some states have streamlined the process of determining which programs are comparable to the SNAP E&T component and thereby expanded the pool of students who can be exempted from onerous work requirements to get SNAP. To simplify their process, these states use the Carl D. Perkins Career and Technical Education Act (“Perkins Act”) definition of “career and technical education.”^[44] State agencies can determine what courses or programs meet the career and technical education criteria (a program does not need to be receiving Perkins funding^[45]) or increase employability.

In 2010, Massachusetts set an example for this provision and determined that a community college may identify a student enrolled in a career and technical education program or other courses that lead directly to employment as meeting this student eligibility exemption.^{[46]; [47]} Massachusetts determined that colleges can independently determine if a student’s program is likely to increase employability for the student and therefore whether the student is eligible for the SNAP E&T exemption. Following in Massachusetts’ footsteps, more states began to adopt a version of this practice. Guidance or information on how they implement this rule was found for 13 states.

Four states (New York, Oregon, Pennsylvania, and Wisconsin) have issued policy guidance or memoranda explaining how their community college students in career and technical education programs can qualify for benefits.^[48]Additionally, Illinois, Louisiana, Michigan, Minnesota, and Virginia used their state manual to briefly highlight eligibility for students participating in career and technical programs and point to their verification form that can be used by the college to determine student eligibility. On the other hand, two states do not include information in their state manual, but their state website gives some guidance. New Jersey states that approved career and technical education programs at community colleges are eligible. Maine specifies most certificate and associate degree programs at their community colleges fit the definition under the Perkins Act. Information was not found for other states.

Out of the states identified above, Pennsylvania is an example of a state that has “determined that most courses of study at Pennsylvania’s 14 community colleges are comparable to a SNAP E&T activity and improve employability.”^[49]Given that food insecurity impacts community college students at higher rates than students at four-year colleges,^[50]allowing a greater number of community college students in career and technical education programs to qualify for SNAP can be an effective strategy for reducing food insecurity.

Other states have also identified a larger number of programs that are likely to increase employability under the SNAP E&T exemption – not just career and technical education and community colleges. For example, Oregon updated their policy in 2019 to include college students in 4-year universities who are participating in a program that has a direct link to employment. Staff must have meaningful conversations with students about their careers and articulate how their educational aspirations will lead to employment.^[51] Additionally, California’s AB 396 now requires all colleges and universities to identify and submit “state-approved local educational programs that increase employability” to the State Department of Social Services, which can expect many more programs to be considered than before.^[52]

References for the state-by-state map can be found here.

SNAP Recommendations for State Policymakers

It is time for state policymakers to act to expand SNAP eligibility for college students across the country to address food insecurity. An increasing number of college campuses and states are coming up with innovative solutions to address campus hunger (i.e. “Hunger-Free Campus” laws^[81]), yet restrictive SNAP eligibility is impeding these efforts and doing a disservice to students by limiting access to SNAP.

While data have established the severity of food insecurity among college campuses, many states are still not maximizing student eligibility. States should work to expand eligibility requirements by:

• Implementing Broad-Based Categorical Eligibility. Although the majority of states are already implementing BBCE, there are still nine states (Alaska, Arkansas, Kansas, Mississippi, Missouri, South Dakota, Tennessee, Utah, and Wyoming) not using BBCE. Utilizing BBCE can help alleviate restrictive administrative rules for eligible low-income households.
• Averaging work hours across a semester. Although federal eligibility allows it, Wisconsin is currently the only state that explicitly mentions they allow the averaging of work hours across a semester.^[82] This allows for a bigger window for students to meet the 20-hour-a-week requirement. The 25 states that only mention the weekly 20-hour requirement without further detail, or otherwise fail to provide information on how work hours are calculated, should better communicate how students can average hours across a month or more. This would help illustrate that a student won’t be at risk of losing benefits if they fall below 20 hours one week, as long as they make up those hours in other weeks.
• Interpreting work-study eligibility: California’s interpretations of “approved” for and “anticipating participation” in state or federal work-study serves as an example of ways states can provide more access to SNAP for eligible students with low incomes. California students can bypass SNAP work requirements even if their work-study job has not yet started or been assigned yet. More states should follow in California’s footsteps.
• Supporting a greater number of career and technical education and employability programs. States have the flexibility to designate qualifiable programs operated by a state or local government that have an equivalent component to SNAP E&T to best support low-income households. Many states have identified career and technical programs that lead to employment, as defined by the Perkins Act, as eligible programs. Some states have taken it further by expanding the definition and identifying most community college programs as improving employment and, therefore eligible under this provision. More states should follow in the footsteps of Massachusetts, Pennsylvania, and other states to support a growing number of students who may not have qualified for benefits otherwise.