Editor’s note: This report was updated on October 30, 2020 to account for an adjustment to calculations of the CalFresh student participation rate. 

The COVID-19 pandemic and recession have supercharged the economic anxiety that California’s college students have long faced, further elevating student hunger as an urgent public policy challenge.With many California institutions likely to face up to a full academic year in which learning is predominantly remote and campuses are largely closed, prior hunger interventions such as food pantries and meal swipe donations are less capable of reaching students in need.1 Furthermore, a plan to link the Cal Grant to the full cost of attendance,2 including food and other basic needs, is facing budgetary barriers3 while the state navigates the COVID-19 public health crisis, record-high budget deficits,4 and another year of historic wildfires. Amidst these challenges, leveraging existing federal resources to battle student hunger is more important than ever.

CalFresh, the state’s Supplemental Nutrition Assistance Program (SNAP), would be well-suited to reduce student hunger if it were broadly accessible to students in need of it. However, a complex set of federal eligibility requirements bars many low-income students from accessing the program unless they work twenty hours per week or are eligible for another exemption to this rule. The Trump administration’s Food and Nutritional Services (FNS) has rejected requests from California and other states to waive this college student eligibility rule during the pandemic,5 and Congress has not moved to approve legislation that would provide students relief from this rule.6 Many of the students who need food assistance the most do not participate, often because they cannot find the twenty hours per week of work required of them, because their courseload leaves them without the time to work twenty hours per week, or because they don’t know whether they are eligible.

This report argues that the California state law and guidance addressing this challenge could be changed to better meet the goals of the SNAP program, provide more low-income students with CalFresh eligibility, and enable the delivery of simple messages about program eligibility to students.

This report argues that the California state law and guidance addressing this challenge could be changed to better meet the goals of the SNAP program, provide more low-income students with CalFresh eligibility, and enable the delivery of simple messages about program eligibility to students. California can adopt practices already utilized by other states to allow more community college programs to convey CalFresh access to their students, and it can restructure (even without increasing) the state’s use of Temporary Assistance for Needy Families (TANF) block grant dollars within the financial aid system to deliver access to more low-income students.

This report analyzes both what we know about student hunger in the state and efforts to date to address these challenges. It then offers state policymakers and advocates a menu of actionable pathways to sizably increase and streamline student access to CalFresh, even in the absence of federal action. While these changes are not designed to provide a comprehensive solution to food insecurity, any of them could help diminish the cresting wave of financial hardships that students are experiencing.

The Prevalence of Student Hunger in California

Even before the COVID-19 pandemic, college student hunger in the United States had reached “epidemic” proportions,7 and research suggested that food insecurity is even more prevalent among California’s college students than among the nation’s college students overall. Major surveys over the past five years find undergraduate food insecurity8 rates of 44 percent at the University of California (UC) system,9 42 percent at the California State University (CSU) system,10 and 50 percent at the California community colleges (CCCs).11 In these surveys, members of historically underrepresented groups tend to report food insecurity more often, such as nearly 2 in 3 respondents who were Black first-generation students at the CSU.

These rates were unacceptably high before the COVID-19 pandemic,12 and they are likely higher now. A national survey of students’ basic needs conducted by the Hope Center in late April and early May13 showed food insecurity up 2 percentage points at two-year colleges and up 5 percentage points at four-year colleges compared to aggregate results from comparable national surveys over the past five years.14

The available evidence suggests that the financial impact of the pandemic on college students can hardly be overstated. In a survey conducted by the California Student Aid Commission (CSAC) in late May, college students in California reported that 70 percent had lost some or all of their sources of income since the pandemic began, and the percentage of respondents with “a lot” of concern about paying for housing and food more than quadrupled compared to before the pandemic began.15

Recent Efforts to Combat California Students’ Food Insecurity

Over at least the past decade, student activists in California have called for greater assistance paying for food while enrolled in college, leading to new guidance by state agencies.16 Thanks to this activism and advocacy, California began implementing a greater set of federal pathways to student eligibility starting in 2014.17

In recent budgets, the state has made investments to connect students with food resources. In fiscal year 2017–18, the state enacted “Hunger-Free Campus” legislation18 that delivered $2.5 million to each of the public segments to develop programs for the sharing of unused meal swipes in campus dining halls, to create campus food pantries, and to establish on-campus staff specifically to help students enroll in CalFresh.19 In fiscal year 2019–20, the state made targeted investments in students’ food and housing, totaling $15 million each at the UC and CSU, plus another $4 million in student basic needs programs at the CCCs.20

This budget year, as a result of the COVID-19 pandemic, California faced an unprecedented shortfall of an estimated $54 billion that has constrained the state’s ability to further advance its prior campus hunger efforts.21 State policymakers did make some important investments in basic needs, though none were exclusively targeted at food assistance for students. The enacted fiscal year 2020–21 budget provides $120 million to the CCCs to support basic needs, including food insecurity, as well as for learning loss and COVID-19 response; it is unknown yet how much of this will be allocated towards food aid or how colleges will deliver food assistance using the funds.22 The budget also provides institutions flexibility to repurpose certain educational funding to now support food pantries,23 and the state made general increases in funding for emergency food assistance, though not targeted at college students per se.24

These are positive steps, and they demonstrate that the state’s leaders have continued to prioritize students’ food security within a wide landscape of financial and health-related emergencies. However, more needs to be done, and there remains uncertainty about the extent to which campus closures will affect campus-based food assistance programs, which have been central to the state’s recent investments.

CalFresh emerges as a compelling avenue for increasing food assistance for students: as a federal benefit, the program is not contingent on state funding beyond the state’s and counties’ share of administrative costs, and students need not visit their campus in person to receive the benefit.

Given these fiscal and logistical constraints, CalFresh emerges as a compelling avenue for increasing food assistance for students: as a federal benefit, the program is not contingent on state funding beyond the state’s and counties’ share of administrative costs, and students need not visit their campus in person to receive the benefit.

A single student in the CalFresh program can receive up to $204 per month in CalFresh benefits25 in the form of regular deposits onto an EBT card, eligible for use at grocery stores and online grocery purchases from Amazon and Walmart.26 The monthly amount is a function of income and household size, and most participating households’ income from all sources must be below 200 percent of the federal poverty level to be potentially eligible for CalFresh.27 (Exceptions are made when a member of the household is disabled or homeless.) Household expenses for child care, child support, housing, medical costs, and utilities are also considered within certain parameters.

While CalFresh benefits are intended to only fill in a portion of a student’s food budget, they reduce risk of food insecurity and the need for students to work burdensome hours to pay their bills. However, complex eligibility structures in federal law and regulation place important constraints on what California policymakers can do to expand access.

Federal SNAP Regulations on Student Eligibility

Title 7, Section 273.5 of the Code of Federal Regulations (CFR) establishes that college students enrolled at least half-time may not receive SNAP benefits unless they work for pay for at least twenty hours per week or meet at least one of ten other exemptions.28 Collectively, Section 273.5 is referred to as the “student rule,” or the “student work rule,” since it generally functions as a work requirement.

Enacted by the Food and Agriculture Act of 1977,29 the student rule appears to have been designed primarily to block SNAP access from upper-class college students, who are likely to receive significant financial help from family while enrolled; the program’s standard measures of income could portray these students as lower-income than they actually are.30 However, high financial support from parents is not the norm among today’s students. According to survey data from 2015–16, a majority of in-state California students—52 percent—are financially independent.31 Of those who are classified as dependent students, 25 percent receive no support from their parents towards college expenses, and 28 percent of dependent students receive between $1 and $1,500 per year from their parents.32

California, among other states, has petitioned FNS to waive the student rule for the duration of the pandemic, but FNS has denied these requests.33

How Many Eligible California Students Participate in CalFresh?

According to a 2016 U.S. Department of Agriculture (USDA) report, California has an overall SNAP participation rate of about 72 percent among those who are eligible, the fifth-lowest rate among the states.34 The participation rate among eligible college students may be lower: an exploratory analysis by the federal Government Accountability Office estimated that, nationally, 57 percent of potentially eligible low-income college students with risk factors for food insecurity did not participate in SNAP.35 A national analysis by Young Invincibles estimated that only 22 percent of SNAP-eligible college students in California received benefits in 2015.36

The California Department of Social Services (CDSS) recently shared research findings from a work group that was convened as a result of state legislation to compile statewide data on CalFresh participation among college students.37 The work group reports that the average number of California college students receiving CalFresh benefits throughout 2018–19 was 127,360. Using data provided by the three public systems in the state, the report provides estimates of total students who may be eligible, which suggest the participation rate could be between 18 percent and 30 percent. However, the institutions do not collect data on several exemptions, such as working twenty hours per week, and information about students at private institutions was not available.

Seeking to fill in these data gaps using Education Department and Census Bureau data (in a methodology detailed in Appendix A), I estimate that about 105,000 undergraduates at public institutions received CalFresh benefits in 2018–19, less than 15 percent of an estimated 750,000  who are subject to the student rule yet appear to have an exemption and meet other requirements for participation. Across public and private institutions, eligible California undergraduates leave an estimated $100 million in CalFresh benefits unclaimed every month. 38

Figure 1
Estimated participation rate in CalFresh among those who are subject to the student rule and appear eligible
Public undergraduates Between 12.7% and 15.3%
Private undergraduates Between 6.2% and 8.3%
Californians overall About 70%39
Note: calculating the number of CalFresh-eligible graduate students is beyond the scope of our analysis.

To be sure, these rates represent approximations based on incomplete data: for example, in-state students are used as a proxy for all students for some variables. See Appendix A for the full list of assumptions.

Remembering that 40-plus percent of surveyed students report food insecurity, it appears from these estimates that a large share of students genuinely suffer from hunger but do not participate in CalFresh, even if they are eligible. This underscores significant challenges around awareness and communications: prior research has found that confusing information about eligibility, difficulty reaching CalFresh staff, and fear of submitting wrong information pose obstacles to completed CalFresh applications, even for those who are not subject to the student rule.40 Another factor may be that many college students are young and not experienced with subjects like deductible expenses and the federal poverty limit, and for them applications that center such terms may appear daunting.

While colleges can be valuable vectors for messaging about CalFresh, they do not have available all the information that goes into whether or not a student will be eligible. Identifying (or creating) opportunities where colleges can inform students of their likely eligibility may motivate more students to access and claim the benefits to which they are entitled.

A Key Limitation

Before discussing CalFresh as a policy intervention for student hunger, a major limitation to remember is that undocumented students cannot access the program. According to a major study of CSU students, Dreamers and DACA respondents had higher rates of food insecurity than the sample overall. The $15 million in emergency financial aid for undocumented students, approved by the governor and legislature in June,41 makes important progress towards meeting these students’ needs, given their exclusion from the federal government’s major social safety net program and the Education Department’s rule to exclude them from CARES Act emergency aid.42,43

The Student Work Rule and Local Programs that Increase Employability

Though the SNAP program features a work requirement, it allows for unemployed individuals to remain enrolled in the program while participating in employment and training (E&T) programs to improve their work prospects. Many CalFresh recipients participate in E&T programs hosted by the state or their county, but the federal regulations also allow a student to qualify for the exemption if they receive equivalent training from an institution of higher education.44 If approved by CDSS, it is considered a qualifying local program that increases employability (dubbed “LPIE” in this report). One way to qualify as a LPIE is for a postsecondary program to be intended for low-income students45 and contain at least one of a list of components typically offered by CalFresh E&T programs.46

One such component is demonstrated if the program “improve[s] basic skills or otherwise improve[s] employability.”47 In other states, this language has been applied to include most community college programs, since community colleges generally serve low-income students and improve basic skills or employability. Massachusetts, for example, allows each community college to make its own determination about which of its own programs make participants more employable.48

Relative to states like Massachusetts, California is more restrictive and sees far fewer programs qualify: only 130 postsecondary programs are approved as LPIEs.49 There are over 9,000 educational programs hosted by CCCs in the College Scorecard database, yet only 82 of these programs are approved as LPIEs.50

An analysis of relevant federal regulations can be found in Appendix B. This analysis finds that CDSS can take steps to remove restrictions when assessing whether community college programs holistically improve employability and satisfy the requirements of a LPIE. If implemented, this would lead to many more programs qualifying. Students in those programs could then be given the simple message, “We know you’re exempt from the student rule, so you should apply for CalFresh.” (Those students would then, of course, still need to meet the income requirements.)

The state could use one of the following frameworks to evaluate community college programs’ qualifications as LPIEs. To our knowledge, FNS has not yet weighed in on this approach. 

Option 1: Allow All CCC Certificate and Degree Programs to Qualify

To gain approval as a LPIE and thus convey an exemption on participants, a program must improve employability. Which programs and courses of study at the CCCs do, in fact, improve employability? Research indicates that both associate’s degrees and certificates increase the likelihood and stability of employment, with the return on associate’s degrees in particular continuing to rise even ten years after degree attainment.51 A dataset compiled by the CCC Chancellor’s Office (CCCCO) on students’ wages before and after their programs shows that, of the roughly 300 CCC programs included, two-thirds showed a median gain of at least 25 percent in annual wages from two years before students entered the program to two years after they completed it; about half show a median wage increase of 40 percent or more.52

While conventional wisdom says that the greatest employment gains come from degrees in STEM and CTE fields, data from the CCCs point to a large number of fields of study in the arts, humanities, and social sciences with above-average rates of employment for students six months after leaving their program.53 One reason why the conventional wisdom is not borne out by the data is that the skills students gain in their program are often applied to a number of occupations, even those not in the same field as the coursework: for example, one analysis finds that sales and marketing rank in the top five jobs held by language/philosophy majors, social science majors, communications majors, and business majors alike.54<sup>,</sup>55

Option 2: High Demand Fields

A narrower approach would be to apply this exemption only to those community college programs whose graduates can measurably expect the greatest employment prospects. Pennsylvania state officials maintain lists of “high-priority occupations” (HPOs) by region, and the state allows nearby community college programs specializing in those fields to qualify as LPIEs.56

In a similar manner, California could identify the occupations that are in most need of educated workers in the future and approve associated community college programs as LPIEs.57 Supporting students who are being educated in these fields, which provide wages that can support families, is one of the surest ways to accomplish the SNAP program’s goal that recipients not need public assistance in the future.58

Option 3: Letting Colleges Decide

Another option is to let colleges decide which of their programs improve employability. In Massachusetts, colleges sign verification forms on behalf of students when the student is enrolled in a program that they consider to improve employability.59 While implementing such a system in California would require training for community college administrators, it would allow for those most familiar with individual programs to make these determinations.

The Student Work Rule and TANF-Funded Financial Aid

The CalFresh program’s student rule and income restrictions make it difficult for students to understand whether they are eligible. Where the state can combine income data and exemption data, it can send clear messages to low-income students who are likely to obtain benefits if they apply. TANF-funded financial aid is one such opportunity to send these messages: a student is exempt from the student work rule if they receive a TANF-funded benefit, and a student financial aid award that is funded by TANF qualifies the recipient for this exemption.60 By changing the state’s budgeting decisions for TANF allocations for financial aid, more low-income students could receive TANF-funded financial aid and thus be exempt from the student rule.

The Cal Grant is California’s primary need-based financial aid program, serving more than 400,000 students last year with an annual budget of about $2.5 billion.61 Since fiscal year 2013–14,62 the Cal Grant A/B program has received funding from California’s TANF block grant, roughly $435 million in the current fiscal year applied to the tuition portion of qualifying Cal Grants.63 According to data provided by the California Student Aid Commission (CSAC), 121,885 Cal Grants were funded by TANF in 2018–19.64

A student receives a TANF-funded Cal Grant only if they meet certain criteria: they must be age 25 or younger, unmarried, and have income under $50,000.65 These criteria were established by a work group to target this TANF funding at the students with the most need, and to link the funding allocation to the third stated purpose of TANF, to prevent out-of-wedlock pregnancies.66 The data on these student attributes is provided to CSAC through the student’s FAFSA, and CSAC then makes the determination of whether a student’s Cal Grant will be TANF-funded. CSAC then sends letters to these award recipients, encouraging them to apply for CalFresh.67

Enabling more students to be exempt from the student rule by increasing the number of TANF-funded financial aid awards would both increase the number of students eligible for CalFresh and enable direct messaging from CSAC about those students’ exemption from the student rule. The section of this report that follows describes a number of potential policy actions that would accomplish this.

It is important to note that federal TANF regulators and policymakers have grown increasingly critical of TANF funds being used for the educational expenses of Americans with incomes above the poverty line or who don’t have children. The following section does not recommend increasing the TANF funding for financial aid in California. Rather, it considers ways to distribute the existing funding differently to better meet the intended purpose of this funding stream and of the exemptions provided by Congress.68 With each policy option included here, there is an opportunity to establish income limits.

To be sure, increasing the number of students who receive a TANF-funded financial aid award while maintaining a constant level of TANF funding—thus leading to fewer TANF dollars in each individual award—can be done in a way that will not impact whether or not any of the individual awards provides the exemption from the SNAP student rule.69 The following proposals can be achieved using the current levels of TANF funding, without a need for an increase. (Appendix C explains how this can be achieved using current funding levels.)

Option 1: Adjusting Eligibility Criteria for the TANF-Funded Cal Grant

As previously described, a student’s Cal Grant is TANF-funded if the student is 25 years or younger and unmarried with income of $50,000 or less. These eligibility rules were established due to state regulation, and they could thus be revised by the state.

The criteria were selected to connect this use of TANF to the program’s third stated purpose, to prevent out-of-wedlock pregnancies.70 While unmarried status is implied by “out-of-wedlock” and the income limit ensures that the funding reaches low-income students, it does not appear necessary for an age limit of 25 years old to be included.

According to data from CSAC, increasing the age limit on TANF-funded Cal Grants from 25 to 35 would increase the number of students receiving these grants by 10,389, or about 8.5 percent, based on 2018–19 data. Alternatively, removing the age limit entirely would increase the number of TANF-funded grants by 12,709, or 10.4 percent.

Option 2: Restructuring Funding Streams of the California College Promise Grant (with Income Limit)

The California College Promise Grant is a longstanding program at the California community colleges, known until recently as the Board of Governors fee waiver: the program waives enrollment fees for nearly one million qualifying students per year. Like the Cal Grant, the Promise Grant is funded by state appropriations dollars, and a portion of the annual TANF allocation made for Cal Grants could be directed to support low-income recipients of the Promise Grant in the annual budget.

In 2018–19, 931,396 students received the Promise Grant.71 A subset of Promise Grant recipients could receive TANF-funded awards based on income, in a similar manner as the TANF-funded Cal Grants have income restrictions.72


While California should be proud of the strides it is taking to address college student hunger, CalFresh participation among students remains stubbornly low, likely arising from the complexity of the application process and entrenched federal law. While much of this difficulty could be eliminated if Congress revises the student rule, and it could be temporarily diminished if FNS approves California’s request to waive the student rule during the pandemic, none of this seems imminent. Until that time comes, the best approach may be to expand CalFresh eligibility in such a way that enables colleges to send clear messages about eligibility to students, breaking through the complexity of the system.

This report has offered a survey of the current state and federal context for student hunger in California and the use of CalFresh to address this epidemic; it then explored several California-specific policy actions that could increase the number of California college students who are eligible for CalFresh. Increasing college students’ access to CalFresh would bring down the cost of attendance at a crucial time. The new enrollment of 10,000 college students in CalFresh, for example, would yield roughly $15 million in federally-funded assistance for those students per twelve months.73 All the state must do is make small changes to process and procedure.

Appendix A: Estimating the CalFresh Participation Rate

Appendix B: Regulatory Framework for Proposal to Broadly Approve CCC Programs for the Employment & Training Program Exemption

Appendix C: Maximizing the Impact of California’s TANF Dollars Allocated to Financial Aid Programs


The author thanks Jen Mishory and Andy Stettner for guidance, feedback, and initial research. The author thanks Cassandra Wagner and colleagues at the California Department of Social Services, and Melissa Bardo and colleagues at the California Student Aid Commission, for confirming facts with the author. The author thanks Jessica Bartholow of the Western Center for Law and Poverty and Lindsay Ahlman and Laura Szabo-Kubitz of The Institute for College Access and Success for their peer reviews.


  1. After beginning the fall 2020 semester with predominantly online learning, the California State University system recently announced plans to continue online learning through the spring 2021 semester. Ashley A. Smith, “CSU Chancellor announces 23 campuses to remain virtual for spring term,” EdSource, September 10, 2020, https://edsource.org/2020/csu-chancellor-announces-23-campuses-to-remain-virtual-for-spring-term/639954
  2. “Cal Grant Modernization: A Vision for the Future,” California Student Aid Commission, March 2020, https://www.csac.ca.gov/sites/main/files/file-attachments/cal_grant_modernization_report_legislature.pdf?1583522224
  3. Staff members from the California Student Aid Commission told the author in September 2020 that the legislature is seeking budget-neutral proposals to phase in Cal Grant modernization, and the Commission is in discussion about what such a phase-in could look like. The modernization proposal approved by the California Student Aid Commission in early March would have provided for low- and middle-income students’ food costs, and it would have required about $1.09 billion in net new spending by the state.
  4. John Myers, “Coronavirus plunges California into worst budget deficit in state history,” Los Angeles Times, May 7, 2020, https://www.latimes.com/california/story/2020-05-07/coronavirus-california-worst-budget-deficit-state-history
  5. Jessica Shahin, “SNAP – Denial of Certain Requests to Adjust SNAP Regulations,” EO Guidance Document #FNS-GD-2020-0034, Food and Nutrition Service, U.S. Department of Agriculture, April 10, 2020, https://www.fns.usda.gov/snap/covid-19/denial-certain-state-requests
  6. These bills are H.R. 4297, the Enhance Access to SNAP (EATS) Act of 2019, and H.R. 6565, the Emergency EATS Act. The former would permanently remove the student rule, and the latter would suspend it during the COVID-19 public health crisis.
  7. Caitlin Dewey, “The hidden crisis on college campuses: Many students don’t have enough to eat,” Washington Post, April 3, 2018, https://www.washingtonpost.com/news/wonk/wp/2018/04/03/the-hidden-crisis-on-college-campuses-36-percent-of-students-dont-have-enough-to-eat/
  8. Food insecurity is measured using criteria established by the USDA, with “low” and “very low” rates of food security representing food insecurity. These criteria are found in the U.S. Adult Food Security Survey Module by the USDA’s Economic Research Service.
  9. In a 2016 survey conducted by the University of California (UC) system, 44 percent of UC undergraduates reported food insecurity, above the national average for four-year college students. Rates exceeded 50 percent among financially independent students and lower-income dependent students. See “Global Food Initiative: Food and Housing Security at the University of California,” University of California Global Food Initiative, December 2017, https://www.ucop.edu/global-food-initiative/_files/food-housing-security.pdf
    The national food insecurity rate among four-year college students is roughly 33 percent: see Christine Baker-Smith, Vanessa Coca, Sara Goldrick-Rab, Elizabeth Looker, Brianna Richardson, and Tiffani Williams, “#RealCollege 2020: Five Years of Evidence on Campus Basic Needs Insecurity,” Philadelphia, PA: The Hope Center for College, Community, and Justice, revised February 2020, https://hope4college.com/wp-content/uploads/2020/02/2019_RealCollege_Survey_Report.pdf
  10. In a 2017 survey conducted by the California State University (CSU) system, about 42.4 percent of CSU undergraduates reported food insecurity. The report by the CSU does not list the food insecurity rate for undergraduates; I estimated this 42.4 percent figure based on the system-wide rate and the rate for graduate students, which is cited in the report, in combination with enrollment data by student level from IPEDS.
    Rashida Crutchfield and Jennifer Maguire, “Study of Student Basic Needs,” Long Beach, CA: California State University Office of the Chancellor, January 2018, https://www2.calstate.edu/impact-of-the-csu/student-success/basic-needs-initiative/Documents/BasicNeedsStudy_phaseII_withAccessibilityComments.pdf
  11. In surveys of students conducted by the Hope Center at 57 CCCs in 2016 and 2018, 50 percent of respondents reported food insecurity over the prior thirty days, greater than the estimated national rate of food insecurity at two-year colleges, 42 percent. See:
    Sara Goldrick-Rab, Christine Baker-Smith, Vanessa Coca, and Elizabeth Looker, “California Community Colleges #RealCollege Survey,” Philadelphia, PA: The Hope Center for College, Community, and Justice, March 2019, https://hope4college.com/wp-content/uploads/2019/03/RealCollege-CCCCO-Report.pdf
    Christine Baker-Smith, Vanessa Coca, Sara Goldrick-Rab, Elizabeth Looker, Brianna Richardson, and Tiffani Williams, “#RealCollege 2020: Five Years of Evidence on Campus Basic Needs Insecurity,” Philadelphia, PA: The Hope Center for College, Community, and Justice, revised February 2020, https://hope4college.com/wp-content/uploads/2020/02/2019_RealCollege_Survey_Report.pdf
  12. The research on hunger at California’s private colleges is not as thoroughly explored and is thus not detailed here.
  13. Sara Goldrick-Rab, Vanessa Coca, Gregory Kienzl, Carrie R. Welton, Sonja Dahl, and Sarah Magnelia, “#RealCollege During the Pandemic: New Evidence on Basic Needs Insecurity and Student Well-Being,” Philadelphia, PA: The Hope Center for College, Community, and Justice, June 2020, https://hope4college.com/wp-content/uploads/2020/06/Hopecenter_RealCollegeDuringthePandemic.pdf
  14. Christine Baker-Smith, Vanessa Coca, Sara Goldrick-Rab, Elizabeth Looker, Brianna Richardson, and Tiffani Williams, “#RealCollege 2020: Five Years of Evidence on Campus Basic Needs Insecurity,” Philadelphia, PA: The Hope Center for College, Community, and Justice, revised February 2020, https://hope4college.com/wp-content/uploads/2020/02/2019_RealCollege_Survey_Report.pdf
  15. “Spring 2020 COVID-19 Student Survey Results,” California Student Aid Commission and California Education Lab, July 2020, https://www.csac.ca.gov/sites/main/files/file-attachments/spring_2020_covid19_student_survey_results_presentation.pdf?1594172639
  16. Thanks to the efforts of student leaders, in 2012 the first policy to improve students’ access to CalFresh was enacted by the state CalFresh Bureau within the California Department of Social Services (CDSS), allowing counties to count average hours worked at regular report intervals rather than on a weekly basis. In 2014, AB 1930 directed CDSS to identify any existing exemptions under federal law that California had yet to provide to students through a work group involving student groups, college sectors, legal services, financial aid providers, and anti-hunger advocates.
  17. Jessica Bartholow, “Addressing College Student Hunger in California: A Whitepaper Detailing Efforts to Date,” The Western Center for Law and Poverty, February 2020, https://wclp.org/wp-content/uploads/2020/02/CollegeHungerWhitePaper_Feb2020_Final.pdf
  18. SB 85, the budget trailer bill for education, included language that originated in AB 453, introduced by Assembly Member Limón. See “SB 85,” California Senate Committee on Budget and Fiscal Review, chaptered June 2017, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB85
  19. Tenille Metti, “Gov. Brown Signs CA State Budget: Approves $7.5 Million for ‘Hunger-Free College Campuses,’” Los Angeles, CA: Swipe Out Hunger, June 27, 2017, https://www.swipehunger.org/gov-brown-signs-ca-state-budget-approves-7-5-million-for-hunger-free-college-campuses/
  20. “2019-20 State Budget: Education,” California eBudget, pages 52, 87, and 103, accessed August 26, 2020, http://ebudget.ca.gov/2019-20/pdf/Enacted/GovernorsBudget/6000.pdf .In addition to the aforementioned investments, the state has sought to improve information about CalFresh student eligibility: the 2019–20 budget bill directed CDSS to convene a group to estimate the number of students who are eligible for CalFresh, and in 2020 California became the first state to publish a college student guide for SNAP benefits.
  21. Kevin Yamamura, “California faces $54B budget deficit,” Politico, May 7, 2020, https://www.politico.com/states/california/story/2020/05/07/california-faces-54b-budget-deficit-1282926.
  22. “2020-21 Enacted Budget: Board of Governors of the California Community Colleges,” California eBudget, page 2, accessed August 25, 2020, http://ebudget.ca.gov/2020-21/pdf/Enacted/GovernorsBudget/6000/6870.pdf
  23. The budget also allows for institutions to allocate some of the $475-million Student Equity and Achievement Program (SEAP) to fund food pantry expenses, but it is unknown yet how much these expenses will total. “2020-21 Enacted Budget: Board of Governors of the California Community Colleges,” California eBudget, page 2, accessed August 25, 2020, http://ebudget.ca.gov/2020-21/pdf/Enacted/GovernorsBudget/6000/6870.pdf
    The budget also requires that institutions participating in SEAP establish on-campus food pantries. Phil Ting, “Floor Report of the 2020-21 Budget,” California State Assembly, page 119, revised July 1, 2020, https://abgt.assembly.ca.gov/sites/abgt.assembly.ca.gov/files/Floor%20Report%20of%20the%202020-21%20Budget%20-%20%20%28updated%20as%20of%20July%201%29.pdf
  24. To address food needs in the general population in the wake of the pandemic, the budget makes a $50 million increase in funding for the Emergency Food Assistance Program. “2019-20 State Budget: Health and Human Services,” California eBudget, page 173, accessed August 26, 2020, http://ebudget.ca.gov/2020-21/pdf/Enacted/GovernorsBudget/4000.pdf
  25. Household size for SNAP is based on the number of people the recipient buys groceries with and prepares meals with, not necessarily whom they cohabitate with or who is in their tax household. Most students who don’t live with family would apply as a household of one.
  26. CalFresh recipients who are elderly, disabled, or homeless can use their EBT card for food at authorized restaurants through the Restaurant Meals Program. Although the vast majority of students are currently ineligible for the Restaurant Meals Program, AB 612 of 2019 allows for students to pay for on-campus dining at CCCs using CalFresh as part of the Restaurant Meals Program, effective February 2021: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB612
  27. Some households may have income above 200 percent FPL and qualify, and a household with income under 200 percent FPL may not qualify if they have few expenses.
  28. 7 CFR Section 273.5, Federal Register, accessed August 1, 2020, https://www.ecfr.gov/cgi-bin/text-idx?SID=fc2e885c93c52ec7655faa143835750d&mc=true&node=pt7.4.273&rgn=div5
  29. “A Short History of SNAP,” Food and Nutritional Services, Washington, D.C.: U.S. Department of Agriculture, n.d., accessed August 26, 2020, https://www.fns.usda.gov/snap/short-history-snap#1977
  30. “Food Insecurity: Better Information Could Help Eligible College Students Access Federal Food Assistance Benefits,” Washington, DC: Government Accountability Office, December 2018, https://www.gao.gov/assets/700/696254.pdf
  31. Author’s analysis using the National Postsecondary Student Aid Survey. “2015-16 NPSAS Undergraduate Survey,” Washington, D.C.: National Center for Education Statistics, accessed May 2020.
  32. Ibid.
  33. Jessica Shahin, “Denial of Certain Requests to Adjust SNAP Regulations,” Washington, D.C.: Food and Nutritional Services, April 10, 2020, https://www.fns.usda.gov/snap/covid-19/denial-certain-state-requests
  34. Karen Cunnyngham, “Reaching Those in Need: Estimates of the State Supplemental Nutrition Assistance Program Participation Rates in 2016,” United States Department of Agriculture, March 2019, https://fns-prod.azureedge.net/sites/default/files/ops/Reaching2016.pdf
  35. “Food Insecurity: Better Information Could Help Eligible College Students Access Federal Food Assistance Benefits,” Washington, D.C.: Government Accountability Office, December 2018, https://www.gao.gov/assets/700/696254.pdf
  36. Tom Allison, “Rethinking SNAP Benefits for College Students,” Washington, D.C.: Young Invincibles, February 2018, https://younginvincibles.org/wp-content/uploads/2018/02/Rethinking_SNAP_benefits.pdf
  37. “SB 77 CalFresh Student Data Report,” California Department of Social Services, June 2020, https://www.cdss.ca.gov/inforesources/information-resources/family-engagement-and-empowerment-reports
  38. The question of how to measure the total number of CalFresh eligible college students is being explored by researchers at UC Berkeley in collaboration with CDSS.
  39. Anna Gorman and Harriet Rowan, “Why Millions Of Californians Eligible For Food Stamps Don’t Get Them,” National Public Radio, May 1, 2018, https://www.npr.org/sections/thesalt/2018/05/01/606422692/why-millions-of-californians-eligible-for-food-stamps-dont-get-them
  40. San Francisco-Marin Food Bank, “Findings from the CalFresh Application Experience Survey,” September 25, 2015, https://www.sfmfoodbank.org/wp-content/uploads/2020/02/Report-CalFresh-Application-Experience-Study-2015.pdf
  41. Phil Ting, Floor Report of the 2020-21 Budget, California State Assembly, updated July 1, 2020, https://abgt.assembly.ca.gov/sites/abgt.assembly.ca.gov/files/Floor%20Report%20of%20the%202020-21%20Budget%20-%20%20%28updated%20as%20of%20July%201%29.pdf
  42. Peter Granville, “DeVos’s Emergency Aid Rule Contradicts Congress’s Intent, Harming Vulnerable Students,” New York, NY: The Century Foundation, July 22, 2020, https://tcf.org/content/commentary/devoss-emergency-aid-rule-contradicts-congresss-intent-harming-vulnerable-students/ ,
  43. While there has been a growing call to better serve immigrants with an undocumented status in California’s public benefits programs, which has generated some legislative interest so far, it has only resulted in several failed pieces of California legislation.
  44. 7 CFR §273.5(b)(11)
  45. The exact phrasing in the federal regulations is that the program must be “for low-income households,” which is ambiguous. The CalFresh Student Eligibility Handbook uses the phrase “intended for low-income students,” so the phrase is used here as well.
  46. A program must also be operated by a state or local government, which is true of community colleges. See Appendix B for a full discussion.
  47. 7 CFR §273.7(e)(1)(vi). The regulations state that this is satisfied by basic literacy programs, high school equivalency programs, and English as a Second Language programs, but that this is not an exhaustive list.
  48. John Augeri, “Field Operations Memo 2010-28,” Massachusetts Department of Transitional Assistance, June 1, 2010, https://www.masslegalservices.org/system/files/library/2010-28.pdf
  49. Eleven CCCs, three CSU campuses and five UC campuses have programs that are approved. The full dataset is found on the CDSS website for CalFresh policy resource for college students, under “CalFresh Student Eligibility: Approved Programs to Increase Employability.”
  50. “College Scorecard: Most Recent Data by Field of Study,” Washington, D.C.: U.S. Department of Education, accessed August 26, 2020, https://collegescorecard.ed.gov/data/
  51. Veronica Minaya and Judith Scott-Clayton, “Labor Market Trajectories for Community College Graduates: New Evidence Spanning the Great Recession,” The Center for Analysis of Postsecondary Education and Employment,” April 2017, https://ccrc.tc.columbia.edu/media/k2/attachments/labor-market-trajectories-community-college-graduates-R1.pdf
  52. The Salary Surfer tool only provides wage data for those who graduated from their programs and did not transfer to another institution, including bachelor’s degree programs. The dataset is available at https://salarysurfer.cccco.edu/SalarySurfer.aspx
  53. My analysis of 2017–18 data from the California Community Colleges Chancellor’s Office Partnership for Achieving Student Success (Cal-PASS Plus) finds that rates of employment one year after leaving a CCC program are above-average for at least eighteen fields of study in the arts, humanities, and social sciences, as organized by the 4-digit TOP codes: https://www.calpassplus.org/LaunchBoard/Community-College-Pipeline.aspx
  54. Clare Coffey, Rob Sentz, and Yustina Saleh, “Degrees at Work: Examining the serendipitous outcomes of diverse degrees,” Moscow, ID: EMSI Economic Modeling, August 2019, https://www.economicmodeling.com/wp-content/uploads/2019/08/Emsi_Degrees-at-Work_Full-Report-1.pdf ,
  55. Presuming that we define “program” as a degree program or a certificate program, then the question remains whether to grant the exemption to CCC students who have not declared a major and who arguably have not yet entered a program. Fortunately, the CCC system has long been examining how to ensure incoming students quickly get on a path to college completion and employment, and the system is currently implementing a framework called Guided Pathways to do so. Among other interventions, Guided Pathways establishes “meta-majors” grouping together programs promoting similar skill sets and career outcomes. Once Guided Pathways is fully implemented, incoming students will be encouraged to declare a meta-major even if they are still deciding between particular programs, and the state could consider meta-majors sufficient for the purposes of this exemption.

    When it comes to students who lack a declared major, we likely don’t need to worry about students enrolling in a very small number of courses per semester—such as someone taking one-off courses to gain individual skills—because they would be enrolled less than half-time and would not be counted as a student for the purposes of SNAP.

  56. For each region in the state, the Pennsylvania Department of Labor & Industry identifies a number of occupations with high regional demand, up to 112 occupations in the region with the most HPOs. See Inez Titus, “Operations Memorandum #18-03-04,” Harrisburg, PA: Pennsylvania Department of Human Services, March 19, 2018, http://services.dpw.state.pa.us/oimpolicymanuals/snap/c_271849.pdf.
  57. The California Economic Development Department appears to have maintained a list of high-demand occupations as recently as 2018: https://www.labormarketinfo.edd.ca.gov/LMID/Occupations_in_Demand.html. In addition, CSAC has published a list of 30 occupations for the purposes of granting priority to Cal Grant C applicants in fields associated with strong job prospects: https://www.csac.ca.gov/sites/main/files/file-attachments/cal_grant_c_priority_occupational_list_0.pdf.
  58. Moreover, this framework justifies E&T approval for associate’s degree programs that are intended to help students progress to a bachelor’s degree and beyond. In 16 out of Pennsylvania’s 22 workforce development regions, at least 10 percent of high-priority occupations require a bachelor’s degree or higher, in some regions more than 20 percent. Source: Author’s analysis of HPO lists for the year beginning August 1, 2020 and ending July 31, 2021: “2020 HPO lists,” Center for Workforce Information and Analysis, Harrisburg, PA: Pennsylvania Department of Labor and Industry, accessed August 26, 2020, https://www.workstats.dli.pa.gov/Products/HPOs/Pages/default.aspx
  59. John Augeri, “Field Operations Memo 2010-28,” Massachusetts Department of Transitional Assistance, June 1, 2020, https://www.masslegalservices.org/system/files/library/2010-28.pdf. The relevant regulation is located at 106 CMR 362.410(F)(3).
    Oregon also exercises the “program to improve employability” provision, but there is no verification form originating with the college, and the burden falls on students to inform their county SNAP officer that they are enrolled in a program that improves employability. A benefit of this approach is that it removes the intermediate step of receiving a signed form from the student’s college. However, if access to the exemption is expanded in California then students are likely to hear about it from their colleges; by starting with a signed verification form, colleges can help students navigate the complicated process of gaining CalFresh approval.
  60. Todd R. Bland, “All County Letter No. 17-05,” Sacramento, CA: California Department of Social Services, February 14, 2017, https://www.cdss.ca.gov/Portals/9/ACL/2017/17-05.pdf?ver=2017-02-15-111331-970.
  61. “2019-20 Cal Grant Offered Awardees,” Sacramento, CA: California Student Aid Commission, n.d., accessed August 27, 2020, https://www.csac.ca.gov/sites/main/files/file-attachments/2019-20_cal_grant_program_offered_awardees.pdf?1578529234
  62. “2012-13 Enacted Budget: Higher Education,” California eBudget, accessed August 26, 2020, http://ebudget.ca.gov/2012-13-EN/pdf/Enacted/BudgetSummary/HigherEducation.pdf
  63. This represents a $600 million decrease from fiscal year 2020–21, prompted by increased demand for CalWORKs cash assistance amid the pandemic.
    “California State Budget 2020-21,” California eBudget, accessed August 26, 2020, http://ebudget.ca.gov/2020-21/pdf/Enacted/BudgetSummary/FullBudgetSummary.pdf.
  64. The TANF allocation for Cal Grants in 2018-19 was $1,087,730,000. It does not appear that the amount of TANF funding per award affects the award’s ability to exempt the recipient from the student rule, since the 54 percent reduction in TANF funding from 2019–20 to 2020–21 has no bearing on the exemption. (It is debatable whether $10 per award would justify calling the award “TANF-funded,” but several thousand dollars per award clearly suffices.)
    “2018-19 Enacted Budget: California Student Aid Commission,” California eBudget, accessed August 28, 2020, http://ebudget.ca.gov/2018-19/pdf/Enacted/GovernorsBudget/6000/6980.pdf.
  65. Todd R. Bland, “All County Letter No. 17-05,” Sacramento, CA: California Department of Social Services, February 14, 2017, https://www.cdss.ca.gov/Portals/9/ACL/2017/17-05.pdf?ver=2017-02-15-111331-970.
  66. Some documents also cite the second stated purpose of TANF as a justification for this use of funding. See Mac Taylor, “The 2018-19 Budget: Analysis of the Health and Human Services Budget,” Sacramento, CA: Legislative Analyst’s Office, February 16, 2018, page 31, https://lao.ca.gov/reports/2018/3757/2018-19-HHS-Analysis-021618.pdf.
  67. AB 214 of 2017 required that this letter be sent.
  68. Note as well that the author explored approaches that would have funded Cal Grant access awards with TANF dollars. However, the particular treatment of cash assistance under federal TANF policy would have had unintended negative consequences for students if they received TANF-funded access awards, so those approaches have not been included here
  69. Recall that, this fiscal year, budget changes cut the TANF allocation to the Cal Grant program by 54 percent. CSAC has confirmed with the author that the Commission is keeping the number of TANF-funded Cal Grants the same. This means there are roughly 54 percent fewer TANF dollars in each individual TANF-funded Cal Grant, but these awards still qualify the student for the exemption.
  70. See the agenda for April 19, 2012 meeting of the California Senate Subcommittee on Budget and Fiscal Review, page 9, https://sbud.senate.ca.gov/sites/sbud.senate.ca.gov/files/SUB1/April19CSACdoc.pdf.
  71. Source: CCCCO Data Mart, total Promise Grants excluding AB 19 students.
  72. At least 96.5 percent of Promise Grant recipients in 2018–19 qualified either by certifying their income with their community college or submitting a FAFSA, so the CCC system has sufficient data to establish thresholds based on income for the vast majority of Promise Grant recipients.

    There are four “methods” by which a student may qualify for the Promise Grant. In 2018–19, 25,836 students certified eligibility through public benefit receipt, including TANF, SSI, and general assistance (this is called Method A); 484,354 students certified their eligibility through income (this is called Method B); 451,747 students certified their eligibility by demonstrating financial need through the FAFSA or CADAA (this is called Method C); and 6,804 students certified eligibility as a homeless youth, child of a deceased law enforcement officer or firefighter, child of a deceased or disabled veteran, and/or other identifications (this is called Method D). Those who applied for the Promise Grant another way, such as through their status as the child of a deceased veteran, could be encouraged to submit information to assess whether they meet the needed criteria.

    This proposal was introduced for the first time in SB 1082 of 2019. According to advocates, it was also discussed in pre-hearing budget meetings. However, due to the COVID-19 public health epidemic, this bill or budget request did not proceed to a hearing.

    In 2018-19, the CCCs issued $757 million in Promise Grants. Recall that the 2020–21 TANF allocation to Cal Grants is about $500 million. This means only some fraction of the Promise Grant could be TANF-funded, unless some rationing were used through income. However, the use of TANF in the Cal Grant program demonstrates that an award partially funded through TANF still qualifies for the exemption.

  73. This figure reflects the average monthly benefit of $125 received by college students nationwide, estimated by Young Invincibles. Tom Allison, “Rethinking SNAP Benefits for College Students,” Washington, D.C.: Young Invincibles, February 2018, https://younginvincibles.org/wp-content/uploads/2018/02/Rethinking_SNAP_benefits.pdf