Congress Made 3 Million College Students Newly Eligible for SNAP Food Aid. Here’s What Must Come Next

Low-income college students trying to access public benefits such as the Supplemental Nutrition Assistance Program (SNAP) are often in for a rude awakening: once they enroll in college, they become ineligible. In the COVID-19 pandemic and beyond, removing barriers to benefits such as SNAP is essential not only to ensure that college students are fed, but also to create more affordable and equitable pathways to and through college. Thankfully, in its December relief package, Congress amended the restrictions on students’ eligibility for SNAP to make participation easier for an estimated 3 million low-income college students for the duration of the COVID-19 public health emergency.

This valuable change could deliver as much as $700 million per month in food-purchasing assistance to low-income students, at a time when such support is needed more than ever—but only if there is swift action at the federal, state, and institutional level to maximize the impact of this change.

The Program’s New Reach

During the COVID-19 public health emergency, SNAP participants in nearly all states receive the maximum monthly benefit, and the latest relief package provides an automatic increase of 15 percent for all participants: in most states, a student enrolled as a one-person household receives $235 per month, equivalent to $2,820 per year.¹ Though the program is intended only to supplement a participant’s own grocery budget, not cover it entirely, it should still play a key role in addressing the epidemic of student hunger that has likely worsened under the COVID-19 pandemic. Receiving SNAP also frees up students’ limited funds for other essential needs, such as housing and tuition.

Because of legislative decisions made by Congress forty years ago that still await much-needed revision, college students enrolled at least half-time may not receive SNAP benefits unless they hold a qualifying exemption: for short, this is known as the “SNAP student eligibility rule.” Some students hold an exemption to the student eligibility rule through their participation in work-study, their course of study, or a qualifying role as a caregiver for a dependent child. However, many low-income college students can only qualify for SNAP if they work twenty or more hours per week.² During the COVID-19 pandemic, this has become an especially untenable demand for students who cannot find enough hours of work, have caregiving responsibilities due to COVID-19, or for any number of health reasons do not want to risk exposure to the virus through a frontline job.

Congress carved out new pathways to SNAP access for a large number of low-income students in its December relief package. Under Section 702(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the general ban on students’ participation in SNAP will not apply to students eligible to participate in federal or state work-study programs (even if they don’t anticipate holding a job) or students with an Expected Family Contribution (EFC) of $0, a change that will last for the duration of the federal public health emergency.

The provision for zero-EFC students alone enables as many as 3 million low-income students who could not previously qualify for SNAP to now do so—roughly 2.5 million undergraduates and nearly 500,000 graduate students.

Using national survey data, I estimate that the provision for zero-EFC students alone enables as many as 3 million low-income students who could not previously qualify for SNAP to now do so—roughly 2.5 million undergraduates and nearly 500,000 graduate students. If these students all applied and satisfied other prerequisites, then they could claim as much as $700 million in monthly benefits during the pandemic.³

However, this money will never reach newly eligible students if they do not know about it. Many students do not understand the SNAP eligibility system, and research shows that clear information and assistance play critical roles in SNAP benefit up-take. At the same time, key implementation decisions by the federal Food and Nutrition Service (FNS), the Department of Education, and the state agencies that oversee SNAP will determine how easy or difficult it is for students to obtain these benefits. To ensure that eligible low-income students take up this critical resource, there are certain steps that these federal agencies, state agencies, and institutions of higher education should take.

What the Federal Government Should Do

• Provide eligible students the documentation they need. The relief package passed by Congress requires the Department of Education and FNS to inform Free Application for Federal Student Aid (FAFSA) filers and current college students about this new provision. When sending this notification to zero-EFC students, these agencies should include individualized documents that will verify eligibility for the exemption during students’ applications to their state SNAP agencies, such as students’ Student Aid Reports. These agencies should also emphasize in their communications to FAFSA filers that college administrators can use professional judgement in cases where students’ financial situations have changed.⁴
• Communicate to students the size of their potential benefit. The CRRSAA makes FAFSA data available to the U.S. Department of Agriculture (USDA) for the purpose of informing low-income students about available aid through SNAP.⁵ The USDA can use the information provided by students’ FAFSAs to determine the likely size of each FAFSA applicant’s SNAP household, as well as their state of residence: as a result, communications with FAFSA filers about the new provision can include the message “Based on your household size of X, you may qualify for up to $Y in monthly SNAP benefits during the COVID-19 pandemic,” where Y is contingent on whether the student’s state of residence is implementing emergency allotments under the Families First Coronavirus Response Act. Looking toward the long-term, the USDA and Department of Education can explore the feasibility of personalized estimates of SNAP eligibility and monthly benefits using FAFSA data.
• Exempt students from having to recertify. The new provision⁶ applies to students eligible to participate in work-study “during the regular school year” and students with an EFC of $0 “in the current academic year.” Based on this language, it does not appear that students must recertify their eligibility for the new exemptions by completing the FAFSA again when the new academic year begins. Research indicates that the administrative burden of recertification decreases the rate of participation. To ensure that states do not needlessly require students to recertify, FNS can advise states to treat a student who is exempt once as exempt for the duration of the COVID-19 federal emergency.⁷
• Advise states to allow the work-study exemption to continue through school breaks. Under current regulations, a student remains subject to the student eligibility rule during scheduled breaks, such as summer break.⁸ However, the work-study exemption under federal regulations⁹ typically only applies during the terms for which the student would be participating in work-study, which would generally not include the summer break. FNS can advise states that the new work-study provision under the relief bill should endure through the summer following the first term for which a student has been approved for work-study.
• Advise states to interpret eligibility for work-study in the broadest sense. The rule change does not say explicitly how a student’s eligibility to participate in the federal work-study program should be determined. Under flexibilities provided by the CARES Act during the COVID-19 public health emergency, colleges may reallocate the federal portion of their work-study funds elsewhere and are not required to contribute their share of program costs: at some colleges, no students are currently receiving federal work-study. Meanwhile, it would be operationally difficult and cause delays if colleges had to manually determine which students would be receiving federal work-study were it not for the pandemic. To implement this rule change efficiently and fairly, FNS should advise states to accept any student as eligible to participate in work-study so long as their college confirms that the student meets the federal requirements for the program (meaning they are eligible to participate in Title IV programs generally and have demonstrated financial need). This subset of students will include some who will not ultimately pass their state’s SNAP income and/or asset thresholds, so colleges should be intentional in communicating that there are additional prerequisites for SNAP enrollment beyond holding the exemption.

Update: On February 2, FNS released a “Frequently Asked Questions” document that affirms that institutions shall determine whether a student is eligible for a federal or state work-study program. It does not address whether meeting the eligibility requirements for the federal work-study program is sufficient for the exemption, though it requires that the exemption be verified by a student’s financial aid award letter (unless such letter has been lost). FNS should clarify whether a student who was not offered federal work-study in their award letter—but who meets the federal requirements for work-study participation—is eligible for this exemption.

What State Agencies Should Do

• Explain SNAP student eligibility rules in plain terms on state agency website. When students receive notification from the Department of Education and FNS that they may qualify under this new provision, they are likely to turn to their state agencies for information. Unfortunately, many state agencies overseeing SNAP still do not have a devoted page explaining the rules around student eligibility: only five have such a page on their agency websites.¹⁰ This is a relatively easy yet important first step, and states publishing this information for the first time can model their pages off those in Oregon, New Jersey, Massachusetts, or California, adjusted to reflect states’ particular policies and procedures.
• Inform state-funded work-study students about SNAP eligibility. Some states, including Pennsylvania and Minnesota, have their own state-funded work-study programs. The new SNAP provision applies to students eligible for not only federal work-study, but state-funded work-study programs as well, meaning these states’ SNAP agencies should coordinate with those overseeing state work-study programs to inform eligible students that they should consider applying.

What Colleges Should Do

• Encourage students to complete the FAFSA. This exemption will not benefit students who have not completed a FAFSA.¹¹ According to my analysis of national survey data, roughly 490,000 students who could likely enroll in SNAP thanks to the new provision for zero-EFC students must first complete the FAFSA to do so.¹² Colleges should encourage all students to complete a FAFSA if they have not already and offer assistance with the form. In particular, those students that a college can identify as potentially low-income should be encouraged to complete the FAFSA, such as students who have signed into a campus food pantry and students who applied for CARES Act emergency aid (where applicable).¹³ Because technology access is a key factor in FAFSA completion, and technology resources such as public libraries may not be available in a student’s community during the pandemic, colleges should think about how they can support FAFSA completion for students without printers, scanners, or internet access in their own homes.
• Provide assistance to students applying for SNAP. Research indicates that assistance applying for SNAP leads to more uptake than information alone.¹⁴ Colleges should aim to have designated staff trained to help students applying for SNAP, a goal already advanced by Hunger-Free Campus legislation in California and New Jersey. When a student is notified by their college about SNAP eligibility, they should receive the contact information of a college staff member who can assist them. If a college cannot designate a staff member as such, they should provide the contact information for the local county welfare office or a local nonprofit organization that provides assistance with SNAP applications.
• Include new SNAP eligibility information across assistance programs. The CRRSAA also allocates over $6 billion in emergency grants for colleges to distribute to students. When colleges notify students about emergency grants, they should provide information about SNAP eligibility. This is yet another opportunity to target specific language at students who are zero-EFC or eligible for work-study.

Next Steps for Students’ SNAP Access

Maximizing the impact of Congress’s new law for student eligibility is an important step to reduce student hunger during the pandemic. In addition, the Biden administration can consider going even further for college students by approving states’ requests to simply waive the ban on students’ participation in SNAP entirely for the duration of the pandemic; the Trump administration at the USDA denied these requests last April. Approving them would mean millions of low-income students would no longer need to obtain an exemption from the ban and their eligibility would be determined by their finances and other prerequisites alone, the same as any other person.

It is especially true in a pandemic—but it is also true generally—that students’ access to food and financial security should not be limited by an eligibility system that errs on the side of restricting benefits for genuinely needful students. For its part, Congress should consider linking student eligibility to EFC permanently and should reexamine whether the student eligibility rule is serving the country’s goals for higher education and food access. Meanwhile, states should look for opportunities to clear barriers to participation, which can benefit students and non-students alike. This includes approving postsecondary programs such that they convey an exemption to participating students, raising income and asset thresholds for categorical eligibility,¹⁵ ensuring applications and interviews can be completed online or by phone without an in-person interview, and enabling SNAP participants to buy groceries through online orders at a range of retailers.

Thanks to Congress, there is forward momentum toward greater access to SNAP benefits for college students. Agencies and institutions should move quickly to ensure that newly eligible students apply for and obtain these benefits, while remembering that only long-term changes to federal policy will create the lasting changes students need.

Acknowledgements

Thanks to Carrie Welton and Abigail Seldin for their helpful feedback and suggestions, and to Karen McCarthy for background information.

1. Not all students enroll as a one-person household, especially if they have children. However, someone who buys groceries and prepares meals by and for themselves would apply as a one-person household, regardless of how many people they cohabitate with.
2. The full list of exemptions under federal regulations can be found at 7 CFR 273.5(b).
3. This analysis uses the National Postsecondary Student Aid Survey (NPSAS) from 2015–16 and enrollment data from the Integrated Postsecondary Education Data System (IPEDS) reflecting 2018–19 to estimate the number of students who (1) are enrolled at least half-time and a U.S. citizen, (2) are not eligible for any of the exemptions for which data is available in NPSAS (see list below), and (3) have an EFC of $0. Other than status as a $0 EFC student, the exemptions used in the analysis are employment for twenty or more hours per week, being under the age of 18 or over the age of 49, holding a work-study job, or being a student-parent. This does not exhaust the list of exemptions provided under federal law, so this analysis should be treated as back-of-the-envelope estimates. The methodology of this analysis is available by request.
4. It may also be helpful for agencies to note in these communications that unemployment compensation, the primary source of income for many Americans in the past year, is not counted as income for the purposes of evaluating SNAP eligibility. See Section 702(d) of the Coronavirus Response and Relief Supplemental Appropriations Act.
5. Sec. 485E(c)(2)(A)(iv).
6. Section 702(e).
7. For example, California’s Department of Social Services has stated that recertification will not be necessary until the end of the public health emergency; see their all-county letter, “Calfresh Student Eligibility: COVID-19 Relief Package,” January 22, 2021, https://www.cdss.ca.gov/Portals/9/Additional-Resources/Letters-and-Notices/ACLs/2021/21-11.pdf.
8. 7 CFR 273.5(c).
9. 7 CFR 273.5(b)(6).
10. The list of states whose SNAP agencies who have pages on their websites detailing the rules for college students’ eligibility (not including state policy manuals, regulatory codes, or administrative codes) is as follows: California, Massachusetts, New Jersey, Oregon, and South Dakota. Vermont appears to have a page that was made collaboratively between the state human services agency and a nonprofit. Louisiana, Maine, Maryland, Michigan, Nevada, New York have pages that provide a relatively thorough explanation of their policies for college students or one of the possible exemptions, though these pages are not dedicated specifically to college students and may only focus on one aspect of the policy. In this review, short mentions that students are generally ineligible without an explanation of exceptions were not counted.
11. Although expected family contribution can be estimated using other forms, such as an institution’s own application for aid or the CSS Profile, the language of Section 702(e) suggests that zero-EFC status must be assessed through the federal needs analysis via a FAFSA submission. Meanwhile, federal work-study eligibility is assessed by institutions using the FAFSA, like all other federal aid.
12. See footnote 3 for explanation of this analysis.
13. Colleges had discretion about how to distribute these grants to students. Some colleges allowed students to request aid through an application system, and others delivered all the aid automatically based on EFC.
14. In one experimental study, elderly individuals in Pennsylvania either received (1) nothing, i.e. the control group; (2) two postcards with information about SNAP; and (3) two postcards with information about SNAP and the phone number of a specialist who would help individuals understand their eligibility and walk them through the application. Nine months after the treatment, 6 percent of subjects in the control group had enrolled in SNAP, 11 percent in the “information only” group had enrolled, and 18 percent in the “information plus assistance” group had enrolled. See Amy Finkelstein and Matthew J. Notowidigdo, “Take-up and targeting: Experimental evidence from SNAP,” Quarterly Journal of Economics 134, no. 3 (August 2019): 1505–56, https://academic.oup.com/qje/article-abstract/134/3/1505/5484907.
15. Since 2011, California has not used an asset test, and in 2019 Michigan increased its asset limit from $5,000 to $15,000. This good policy in general, and especially in a pandemic and especially for college students. People should feel comfortable building savings without fear of losing their food benefits, especially in such a volatile job market.

Tags: snap benefits, college students, covid-19, higher education