Aiming to foster widespread prosperity in the twenty-first century economy, Michigan has set a goal for three out of every five adult residents to have obtained a postsecondary credential by the end of the decade.1 To meet this goal, the state must overcome the legacy of state funding reductions that have spanned a generation and contributed to the doubling of tuition costs at state schools over the past twenty years.2 Michigan must close the gap between the college costs students face and their means to pay them, and the state should leave no stone unturned to deliver available money to its students.

Efforts such as Governor Whitmer’s statewide FAFSA Challenge shine a worthy spotlight on the Pell Grant, an essential resource that too often goes unclaimed by eligible students.3 There are also an estimated 50,000 or more Michigan students who leave their Tuition Incentive Program (TIP) benefits on the table every year by not applying.4 However, to meet the state’s goal, resources outside traditional financial aid must be leveraged as well. In particular, the state can take actions—both immediate and long-term—to promote college students’ enrollment in the state’s Food Assistance Program (FAP).

Through FAP, Michigan administers federal benefits under Supplemental Nutrition Assistance Program (SNAP), the nation’s largest and most essential anti-hunger tool. Formerly known as food stamps, the program delivers monthly benefits up to $204 per person to help its 40 million participants cover a portion of their food budget, of whom 1.25 million live in Michigan.5 Under temporary provisions passed by Congress, Michigan has raised all participating households to their maximum allotment through the end of the COVID-19 public health emergency, and the monthly maximum has been increased by 15 percent through June 30, 2021.6 As a result, any student approved as a one-person household would receive monthly benefits of at least $204 during the pandemic and potentially as much as $235. Though the state covers half of FAP’s administrative costs, all monthly benefits are fully funded by the federal government. Maximizing federal dollars through programs such as FAP would deliver a dependable lifeline to the more than three out of every ten students7 experiencing food insecurity and hunger, as well as additional students at risk.8

However, it will take direct interventions by the Michigan Department of Health and Human Services (MDHHS) and the state’s postsecondary institutions to get this money into students’ hands. This report estimates that, from 2015 to 2019, roughly four out of every five FAP-eligible Michigan college students were not receiving benefits. While this low participation rate reveals the informational and administrative barriers students must overcome to enroll, it also signals how much aid is waiting to be claimed by Michigan students: between $13 million and $24 million dollars unclaimed every month, for an annual total exceeding $150 million.

This report provides an overview of the federal and state rules on college students’ eligibility for FAP, highlighting the windows of opportunity to increase eligibility and deliver targeted information for students. It then offers a strategy of immediate and long-term actions to increase enrollment during the remainder of the pandemic and beyond.

Federal and State Policies Governing FAP Eligibility

Since the late 1970s, Congress has embedded in the SNAP program special rules for college students’ eligibility, originally out of concern that affluent college students receiving financial assistance from their families would be misidentified as low-income under the program’s measures of monthly income.9 Under this set of rules—called the “SNAP student eligibility rule” for short—all college students enrolled at least half-time are ineligible for SNAP benefits unless they can demonstrate an exemption.10 Qualifying exemptions include working for pay for twenty hours per week, receiving work-study benefits, and meeting certain student-parent qualifications, among several others. Once a student has proven that they have an exemption, they still must meet program standards for gross income, assets, citizenship, and other prerequisites.

The federal regulations governing SNAP include an exemption for those who participate in postsecondary programs at public institutions of higher education that improve employability for low-income students.11 States have discretion to interpret the scope of this exemption, and in spring 2020, MDHHS announced a policy change that broadly approves career and technical education (CTE) programs under the Perkins Act to convey this exemption to participating students. According to a press release from MDHHS,12 this change applies to roughly 88,000 students across more than 3,600 programs, or 31 percent of students at the thirty-two Michigan institutions that receive Perkins Act funding, all but four of which are community colleges.13 MDHHS estimates that 16,000 of these students also have the income eligibility to qualify for FAP benefits.14

Atop this important change, more Michigan students were recently made newly exempt from the student rule through temporary provisions in the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) in December. Under these provisions, students with an Expected Family Contribution (EFC) of $0 are exempt until shortly after the end of the COVID-19 federal public health emergency, as are students whose colleges deem them eligible to participate in federal work-study (FWS).15 The exemption for $0-EFC students alone makes an estimated 3 million students newly eligible for SNAP nationwide,16 and MDHHS estimates that the temporary provisions together make 200,000 more Michigan students eligible.17

This complex system offers various pathways to eligibility, which is a double-edged sword for students and the state’s postsecondary leaders. Many students are eligible for FAP benefits, but they may not know that they are eligible.18 Compounding this issue, students typically do not know how much they would receive from FAP before they apply, and they may not know how to apply.19 Factors such as social stigma can also pose barriers when FAP usage is not normalized among a college’s students.

Participation in SNAP among eligible college students nationwide is estimated to be as low as one out of every five, and Michigan is no exception.

As a result, participation in SNAP among eligible college students nationwide is estimated to be as low as one out of every five, and Michigan is no exception.20 According to The Century Foundation’s analysis of Census Bureau survey data from 2015 to 2019, at least 104,000 Michigan college students did not receive FAP benefits despite data suggesting that they are eligible.21 Only 22,000 students who were likely to be eligible for SNAP reported their household as receiving FAP benefits, for a participation rate of about 17 percent. Compared to Michigan college students overall, students who received FAP were more likely to be older or female, twice as likely to be a parent, more than three times as likely to identify as Black, and six times as likely to be on Medicaid.22

Map 1 below shows the regional distribution of these 104,000 students who would likely begin receiving benefits if they applied. Most regions have at least a few thousand such students, though the Detroit and Grand Rapids regions combine for a majority.

Map 1

Based on a pre-pandemic average monthly SNAP benefit of $125 per person, these 104,000 students leave roughly $13 million in FAP benefits on the table every month. If instead the maximum for a one-person household under temporary rules passed by Congress were applied, this total would rise to $24 million in benefits every month of the COVID-19 pandemic. Even these high totals of unclaimed benefits are likely underestimates: these figures do not capture students made newly eligible thanks to enrollment in CTE programs or the temporary exemptions passed by Congress in December, nor do they include the effect of certain exemptions that are not well-represented in the American Community Survey.23

Drawing down all available FAP benefits for college students would be the dollar-for-dollar equivalent of more than doubling Michigan state financial aid for students.

Theoretically, drawing down all available FAP benefits for college students would be the dollar-for-dollar equivalent of more than doubling Michigan state financial aid for students.24 However, hardly a fraction of this amount will be gained without an ambitious, coordinated effort to inform and support eligible students as they apply. The following recommendations will outline immediate steps the state can take to seize upon a confluence of opportunities for FAP enrollment during the pandemic, followed by longer-term changes to policy and practice that would build the lasting infrastructure for strong FAP participation among eligible students.

Immediate State Actions

In the short term, Michigan can pursue a range of actions that would have immediate positive impacts on students’ access to much-needed aid.

Continue direct outreach to $0-EFC and federal-work-study-eligible students.

Earlier this semester, institutions in Michigan such as Oakland University and Henry Ford College started informing students about the temporary exemptions passed by Congress and encouraged students to contact their local FAP office to learn about their eligibility.25 The Governor’s Office and MDHHS have also been using their platforms to announce this opportunity.26

To supplement these efforts, MDHHS should partner with the Michigan Department of Treasury to email all $0-EFC students about their temporary exemption and what this means for their potential FAP eligibility.27 Michigan students’ FAFSA data are held by the Department of Treasury, enabling this targeted outreach.

Although Congress’s temporary exemptions are determined using financial aid information for the current academic year, students who qualify under this exemption will be able to claim the exemption until thirty days after the federal COVID-19 public health emergency declaration is lifted.28 Returning college students next academic year should remain a target for outreach even if they have not previously enrolled in FAP.

Include FAP in future and ongoing information campaigns about financial assistance for college.

Michigan’s Fiscal Year 2021 budget act calls on the Michigan Department of Treasury to “launch an aggressive campaign” to provide information about state financial aid to high school students, and to “provide an online informational resource for prospective and current student loan borrowers” that contains links to state and federal financial aid programs.29 In both of these cases, the department should include information about FAP eligibility and the FAP application process alongside information about traditional financial aid for college. In addition to encouraging students to apply, this may help to reduce possible stigma associated with using FAP benefits when the program is presented alongside sought-after programs such as the Michigan Competitive Scholarship.

For a current high school senior, it may make sense to wait to apply for FAP benefits in college until an exemption like federal work–study takes effect or if they anticipate leaving home for college. For the purposes of these information campaigns, the Department of Treasury could enable voluntary signups for reminders: high school students who provide their phone numbers or email addresses would receive reminders and information about FAP delivered by text message or email in the fall.

Approve more employment-and-training-equivalent programs.

The federal regulations governing SNAP student eligibility allow for state agencies to approve postsecondary programs that they consider to be equivalent to SNAP employment and training (SNAP E&T). This enables students who participate in these programs to claim an exemption.30 Last year, Michigan used this flexibility to broadly approve all CTE programs under the Perkins Act. This is a promising avenue for increasing FAP participation, enabling simple messaging: once programs are approved, colleges can perform targeted outreach to participating students and provide documentation that verifies the exemption.

MDHHS can add to this list by identifying additional programs that satisfy the necessary criteria, including those at the twelve public universities not covered under the Perkins CTE rule. Programs must be for low-income students at a public institution and have an E&T-like component such as an internship, job search training, or a direct link to improving employability. These do not necessarily need to be academic degree or certificate programs: for example, California has approved its student success programs for former foster youth and economically disadvantaged students.31

MDHHS should consider approving the following programs, though this list is not exhaustive:

Once any of these programs is approved, MDHHS should work with administrators overseeing these programs to ensure that they have the necessary information to assist participating students to enroll in FAP. A searchable list of approved programs should also be published on the MDHHS website for students, campus staff, and county caseworkers to reference, including the individual CTE programs approved (or an indicator, such as Classification of Instructional Programs codes).

Conduct targeted outreach to Michigan Reconnect and Futures for Frontliners participants.

The populations targeted by Michigan’s newest free tuition programs happen to be groups that are more likely than others to already qualify for an exemption. According to Census Bureau data, college students who are 25 years old or older who do not yet have a degree—the population served by Michigan Reconnect—are 21 percent more likely than the average student to have an exemption by way of their status as a parent, working twenty or more hours per week, or being age 50 or older.34 Futures for Frontliners recipients may also be similarly likely to claim an exemption if they applied.

Though the agency cannot guarantee eligibility before these students apply for FAP, MDHHS and the state Department of Treasury can send general information about FAP to these students using the contact information provided on the FAFSA and refer these students to local resources for assistance with the FAP application.

Long-Term State Actions

In addition to the short-term actions listed above, there are longer-term steps that Michigan can take that would greatly improve students’ access to much-needed aid.

Establish Hunger-Free Campus designations and state funding.

Experimental research has found that offering information about SNAP and direct assistance with applications can triple the likelihood that someone receives SNAP, and that offering both information and assistance outperforms information alone.35 Direct assistance with FAP is not currently widespread on all Michigan campuses: according to a group of Michigan campus food pantry managers, the FAP information and outreach that students receive can range from referrals to local MDHHS caseworkers, to pamphlets and flyers to—in some cases—no known FAP outreach at all.36

FAP information and outreach that students receive can range from referrals to local MDHHS caseworkers, to pamphlets and flyers to—in some cases—no known FAP outreach at all.

Seeking to increase SNAP participation among students and improve students’ food security, legislatures in three states (California, Maryland, and New Jersey) have now enacted laws that name as a “hunger-free campus” any public institution that designates a staff member to provide information about SNAP to students and to assist them with the application process.37 Other requirements include establishing campus food pantries and programs for meal swipe donations, though the exact policy varies by state. The Michigan legislature can pass similar legislation to adopt this model, as the Michigan League for Public Policy has recommended.38

California initially funded its initiative with $7.5 million, and New Jersey has allocated $1 million per year. State funding for this initiative would require investment, but it would likely have a multiplier effect: the staff members whose FAP outreach is remitted by the state would bring federal dollars into the state by way of newly claimed benefits, which would generate new activity in the state economy and local economies around campuses.39 For any Hunger-Free Campus initiative, the investment should be large enough to rise to meet the challenge. Given the low FAP participation rate, the size of the FAP-eligible population, and the multiple goals of the legislation, several million dollars per year would likely be a lower-bound cost estimate for Michigan.

Given that upwards of three out of every ten surveyed students report experiencing food insecurity during the pandemic,40 the Hunger-Free Campus initiative deserves consideration for a portion of the $5.6 billion allocated to the Michigan government under the American Rescue Plan Act to combat the economic toll of COVID-19.41 This would be in line with the spirit of the act’s flexible allocations to states and localities to allow for innovative and creative approaches to economic recovery.42

Pursue federal reimbursement for campus-based outreach.

If Michigan establishes funding for campus-based FAP outreach, it can then receive 50 percent federal reimbursement of outreach expenditures under the Food Stamp Act of 2008. This 50 percent reimbursement is available for activities that “inform low-income households about the availability, eligibility requirements, application procedures, and benefits” of the program.43 MDHHS can include campus outreach in its state SNAP Outreach Plan and make postsecondary institutions or community organizations subcontractors whose expenses are reimbursed.

If Michigan establishes funding for campus-based FAP outreach, it can then receive 50 percent federal reimbursement of outreach expenditures under the Food Stamp Act of 2008.

This federal reimbursement is a little-known yet valuable untapped resource. In California, more than forty campuses’ SNAP outreach activities are coordinated by the Center for Healthy Communities at Chico State University, a contractor whose expenses are eligible for this reimbursement. This appears to be the first such use of federal reimbursement to promote SNAP awareness on college campuses,44 but Michigan can start when it submits its next SNAP Outreach Plan to the U.S. Department of Agriculture. For instance, if the legislature determines it can budget $3 million per year in state resources for campus-based outreach, then it should instead invest $6 million per year and apply for federal reimbursement. All it must do is file the right paperwork (and adhere to federal rules).

Provide state funding for public benefits coordinators at campuses.

As the state develops a strategy to connect low-income students with FAP, it should consider expanding this strategy to other public benefits. Fortunately for Michigan students, MDHHS has developed one of the nation’s more modern public benefit application systems, MI Bridges. Applicants apply to FAP online, and if the user elects to do so, MI Bridges combines their application for FAP with the state’s applications to Medicaid, WIC, cash assistance, child care, and emergency relief.

In a similar spirit, Governor Whitmer’s fiscal year 2022 budget proposal includes a $6 million provision for wraparound services for Michigan Reconnect and Futures for Frontliners recipients.45 Benefit managers under this funding could then help students apply for MI Bridges benefits such as FAP, as well as provide other resources such as federal aid application assistance, financial counseling, and tax preparation. Evidence suggests that this “single stop” model for student financial assistance can have positive effects on student persistence, student performance, and credit accumulation.46 The legislature should enact this smart investment and consider expanding the resource to more students, including those at public universities.

Key Actions for Institutions

In addition to the actions that the state government can pursue, there are steps that individual colleges and universities can take to increase students’ access to much-needed aid.

Become MI Bridges Navigation Partners.

MDHHS provides free online training every two to three weeks whereby community members can become trained in the MI Bridges application system47 to assist applicants.

Currently, just eleven of the state’s forty-six public colleges and universities are Navigation Partners with staff trained in the MI Bridges system. As a result, only one out of every four Michigan students is enrolled at a campus with staff who are trained in MI Bridges as a Navigation Partner, according to 2018–19 enrollment data.48

Virtually all components of a FAP outreach strategy are made easier if institutions have staff members trained as Navigation Partners.49 Once they do, outreach messaging can direct students to a specific office on campus for assistance with the application, rather than an off-campus resource. These staff would also have access to information on their students’ cases (if the student provides consent) and data on the cash value of benefits they have helped students obtain, a useful measure of impact and effectiveness.

Integrate FAP outreach and/or enrollment into the matriculation process for students in programs that convey an exemption.

Although MDHHS has broadly approved CTE programs such that they convey an exemption to participating students, MDHHS will not know in real time which students are participating in CTE programs before they apply for FAP. It is incumbent on institutions to perform targeted outreach to these students to inform them of their potential FAP eligibility. Providing students with an email or letter when they enroll in a qualifying CTE course is one way to communicate the exemption to students. In addition, research has found that providing food pantry clients with a SNAP application and submitting it on their behalf can lead to greater participation.50 In the context of the MI Bridges online application, this could mean a college hosts a FAP enrollment workshop within the first two weeks of the semester and encourages CTE students to attend.

Automate outreach and information.

As this report has detailed, 104,000 Michigan students who are not participating in FAP would likely receive benefits if they applied, even before taking into account new exemptions enacted over the past year. Helping such a large number of students overcome informational barriers is a significant undertaking.

Automated information and outreach can complement in-person assistance by enabling students to screen themselves for likely eligibility. For example, a college can add to its online student portal a questionnaire that asks how many hours per week the student works, what program they are in,51 whether they have a disability that precludes them from work, and other questions that would enable the form to identify a qualifying exemption. If the student’s response indicates an exemption, then the form can provide to the student the list of next steps for applying for FAP and the best point of contact on or near campus. Even better, a campus staff member can then reach out to the student directly to offer assistance and send reminders about their potential FAP eligibility.

The use of such SNAP interest forms by colleges is not widespread, but there are promising examples. For instance, Fresno State University in California has implemented a pre-screening tool on its student portal for two years, finding that it greatly increased the number of SNAP applications submitted by students.52

This is a low-cost intervention with strong upside, though it is important to remember that countless surveys are ignored by college students every day, even those that advertise potential monetary benefits. Online screening should only be one element of a multi-pronged approach.

The Essential Role of Food Pantries and Emergency Aid

Amid the opportunities described above, Michigan’s higher education policymaking leadership should remember key limitations of FAP as a resource for college students’ food security. First, the program does not provide immediate access to food for a new applicant. An application may take weeks to submit and fully process, and hunger does not wait for paperwork. And unfortunately, existing federal law still leaves gaps where some genuinely low-income students who would otherwise qualify, but for lack of an exemption still do not qualify—even some students who work as many as nineteen hours per week. Financially vulnerable students without the right citizenship credentials cannot qualify, no matter how much they work.53

An application may take weeks to submit and fully process, and hunger does not wait for paperwork.

For these reasons, food pantries and emergency aid will both remain essential for campus food security, regardless of advancements in state policy for students’ access to FAP. The Hunger-Free Campus model as enacted in other states provides funding for campus food pantries, and other states have begun supplementing federal emergency aid for college students with state emergency aid.54 The state should take an active, additive role in providing funding for these services. If it does not, these needs will instead be met through institutional funds that may be derived from student charges.

Looking Forward

Michigan has long been a leader in postsecondary educational quality and has been a trailblazing state in the movement for tuition-free college. Missing from these accomplishments, however, is a sustainable solution to the high non-tuition costs that too often pose the greatest barriers to student enrollment and success.55 These same barriers have only risen over the past year, and a surge of COVID-19 infections in recent weeks has given Michigan a harrowing reminder: even as the vaccine rollout continues, the pandemic that has deepened long-standing inequities will continue to be with us for many more months. Low-income college students are among the groups who feel this stress most acutely, putting their postsecondary trajectories at risk.

The good news is that there is money to be claimed, and implementing all of the above recommendations would make Michigan a leader in promoting SNAP access for college students. While taking the steps detailed here to increase FAP enrollment would not alter the fundamental challenges in state funding declines and equity in college costs, it would still mark a significant step forward toward Michigan’s college affordability and completion goals. Furthermore, these goals can be reached at low cost to the state, with the opportunity to seize on $24 million per month in unclaimed benefits while federal emergency allotments are in place. Now as much as ever, Michigan’s leaders should take up the task of helping their students get the critical benefits to which they are entitled.

Acknowledgements: The author thanks Cody Impton for assisting with background research; Jen Mishory for feedback on drafts of this report; Bob Murphy, Erica Orians, Colby Cesaro, and Peter Ruark for reviewing a draft of this report; and Ashley Burnside and Anna Almanza for sharing insights during the research process.


  1. Chad Livengood, “State of the State: Whitmer calls for 60% higher ed goal by 2030,” Crain’s Detroit, February 12, 2019,
  2. Peter Granville, Kevin Miller, and Jen Mishory, “Michigan’s College Affordability Crisis,” The Century Foundation, September 6, 2019,
  3. The Governor’s Office estimates that in 2019 roughly 25,000 Pell-eligible Michigan students did not complete the FAFSA, leading to $100 million in unclaimed Pell grant dollars. See Lori Higgins, “Whitmer takes steps to make sure $100 million in federal student aid to Michigan students doesn’t go unspent again,” Chalkbeat Detroit, December 2, 2019,
  4. Catherine Brown, Jen Mishory, and Peter Granville, “Michigan’s Tuition Incentive Program: A Model for National Need-Based Financial Aid,” The Century Foundation, February 16, 2021,
  5. “SNAP Benefit Increase Takes Effect,” U.S. Department of Agriculture Food and Nutrition Service, October 1, 2020,; “SNAP Data Tables,” U.S. Department of Agriculture Food and Nutrition Service, n.d., accessed April 2021,
  6. “Additional food assistance for 350,000 Michigan families approved in response to COVID-19 emergency; SNAP work requirements also temporarily waived,” State of Michigan, March 2020,,9753,7-406-98158-523398–,00.html; “Ranking Member Stabenow Leads Bipartisan Effort to Secure Increases in Food Assistance, Support for Farmers in Final COVID-19 Package,” United States Senate Committee on Agriculture, Nutrition, and Forestry, December 20, 2021,
  7. “#RealCollege 2021: Basic Needs Insecurity During the Ongoing Pandemic,” The Hope Center for College, Community, and Justice, March 31, 2021,
  8. Peter Ruark, “Studying in the shadow of the Coronavirus: Addressing college students’ basic needs insecurity—during the pandemic and after,” Michigan League for Public Policy, August 2020,
  9. Elizabeth Lower-Basch and Helly Lee, “SNAP Policy Brief: College Student Eligibility,” The Center on Law and Social Policy, June 2014,
  10. The federal regulations are located at 7 CFR 273.5.
  11. See 7 CFR 273.5(b)(11)(iv).
  12. “MDHHS and LEO partner to help low-income college students enrolled in career and technical education programs to receive food assistance,” State of Michigan, May 5, 2020,,4669,7-192-29942_34762-528136–,00.html.
  13. At these thirty-two institutions, there was headcount enrollment of 284,996 in 2018–19, according to the Integrated Postsecondary Education Data System (IPEDS).
  14. Author’s personal correspondence with MDHHS staff, April 2021.
  15. “SNAP Student Provisions in the Consolidated Appropriations Act 2021—Questions and Answers,” U.S. Department of Agriculture Food and Nutrition Service, February 2, 2021, The policy also exempts those who are eligible for a state work-study program, but Michigan does not have a state work-study program.
  16. Peter Granville, “Congress Made 3 Million College Students Newly Eligible for SNAP Food Aid. Here’s What Must Come Next,” The Century Foundation, February 2, 2021,
  17. Bob Wheaton, “Gov. Whitmer announces expansion of food assistance to many low-income students who are attending college; As state recovers from pandemic, temporary measure allows Michiganders to stay in school while also getting help buying food,” State of Michigan, March 31, 2021,,9753,7-406-98163-555830–,00.html.
  18. The state’s particular policy history around FAP access for students may cause misconceptions. Prior to 2011, any college student with a plan for completing a degree was approved by the state and exempted from the student rule. The administration of Governor Snyder reversed this policy, rescinding eligibility from college students where the state had discretion, causing roughly 30,000 students who were receiving FAP benefits to lose eligibility. According to an advocate at the Food Bank Council of Michigan, the 2011 decision has led to a misconception in the state that no students are eligible or that very few are (personal correspondence, November 2020). See Peter Luke, “Most Michigan college students will be ineligible for Bridge Card food assistance,” Bridge Magazine, February 2011,
  19. When the Government Accountability Office conducted a study of students’ food security in 2018, students and campus staff alike reported little understanding of SNAP eligibility policies or misconceptions about eligibility. See “Food Insecurity: Better Information Could Help Eligible College Students Access Federal Food Assistance Benefits,” Government Accountability Office, December 2018, Similarly, the Hope Center’s national survey of college students in fall 2020 found that two of the three leading reasons for why students did not access campus basic needs supports were “I do not think I am eligible” and “I do not know how to apply.” See “#RealCollege 2021: Basic Needs Insecurity During the Ongoing Pandemic,” The Hope Center for College, Community, and Justice, March 31, 2021,
  20. Tom Allison, “Rethinking SNAP Benefits for College Students,” Young Invincibles, February 2018,
  21. Author’s analysis of 2015–19 5-year Public Use Microdata Sample (PUMS) dataset for Michigan. Students were counted as eligible if their incomes were under 200 percent of the federal poverty limit (FPL), were U.S. citizens, and could claim an exemption through either their hours worked per week, their status as a parent, and/or their age (under 18 or over 49). This is not an exhaustive list of all possible exemptions, so the report’s results are likely underestimates. Importantly, 200 percent FPL gross income qualifies for categorical eligibility in Michigan. See “The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility,” Congressional Research Service, updated October 2019, Assets are also a factor in categorical eligibility, but assets cannot be readily estimated using the PUMS dataset. Students who live in college dormitories were counted as ineligible, as students who live on campus and receive at least half of their meals through a meal plan are ineligible for SNAP. See “SNAP for College Students: An Overview,” The Center for Law and Social Policy, n.d., accessed March 2021, Note that the use of citizenship as an eligibility variable is a simple proxy for a more complex rule: some noncitizens such as green card holders can potentially receive SNAP benefits. Note, as well, that the exemption for student-parents is more complex than can be estimated using the PUMS dataset (for example, access to affordable daycare and enrollment intensity play a role) so we use the indicator of whether the student has children as a simplified proxy. Counties were divided into regions using a categorization used by the Governor’s Office last spring. See Derick Hutchinson, “Here’s how all 83 Michigan counties are divided into regions in Gov. Whitmer’s reopening plan,” Click On Detroit, May 2020,
  22. Author’s analysis of ACS data (see prior footnote).
  23. Examples of such exemptions include work-study participation, TANF receipt, participation in an approved program such as a CTE program or a WIOA program, and having a disability. The full list of exemptions under federal regulations is located at 7 CFR 273.5(b).
  24. For comparison, the Michigan Department of Treasury distributed about $139 million in state financial aid to college students last year. Note, however, that $123 million of this amount is reallocated from the state’s Temporary Aid for Needy Families (TANF) block grant.
  25. “Students encouraged to check their eligibility for SNAP benefits,” Oakland University, March 8, 2021, “SNAP extends food stamp eligibility for students during pandemic,” Henry Ford College, March 9, 2021,
  26. Bob Wheaton, “Gov. Whitmer announces expansion of food assistance to many low-income students who are attending college; As state recovers from pandemic, temporary measure allows Michiganders to stay in school while also getting help buying food,” State of Michigan, March 31, 2021,,9753,7-406-98163-555830–,00.html.
  27. Institutions determine who is eligible for the federal work–study program, so the state cannot perform corresponding outreach for eligible students.
  28. “SNAP Student Provisions in the Consolidated Appropriations Act 2021—Questions and Answers,” U.S. Department of Agriculture Food and Nutrition Service, February 2, 2021,
  29. Sections 259-260 of Public Act 165 of 2020:
  30. See 7 CFR 273.5(b)(11)(iv).
  31. For a list of the student success programs California has approved, see parts 5 and 6 of “All County Letter 20-08, the CalFresh Student Eligibility Handbook,” California Department of Social Services, February 12, 2020,
  32. The five public universities that host the McNair Scholars Program in FY 2020 are Central Michigan University, Eastern Michigan University, Grand Valley State University, Northern Michigan University, and Wayne State University. Siena Heights University, a private university in Adrian, MI, also hosts the program. See “Ronald E. McNair Postbaccalaureate Achievement Program: Awards,” U.S. Department of Education,
  33. The list of programs is as follows: Central Michigan University, Fostering Success Central program,; Eastern Michigan University, Mentorship, Access, and Guidance in College (MAGIC) program,; Ferris State University, Johnson Scholars program,; Grand Valley State University, Fostering Laker Success program,; Saginaw Valley State University, Fostering an Academic Successful Transition (FAST) program,; University of Michigan–Ann Arbor, Blavin Scholars program,; University of Michigan–Flint, Mpowering My Success program,; Wayne State University, CHAMPS program,; and Western Michigan University, Seita Scholars program, Only formal programs were counted. Merely having a resource center or staff member supporting former foster youth would be unlikely to qualify under federal regulations. Financial aid for former foster youth, without any additional services or support, would also be unlikely to qualify. Summer programs for high school students in foster care were not counted.
  34. Author’s analysis of American Community Survey 2019 1-year Public Use Microdata Sample, nationwide sample. The report finds that 63.6 percent of all college students qualify for one of the described exemptions, whereas 77.1 percent of all college students who are age 25 or older and have no degree qualify for one of the described exemptions. Therefore, the latter group is 13.5 percentage points more likely to qualify for one of these exemptions, or 21.2 percent (relative).
  35. 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,
  36. Author’s personal correspondence with food pantry managers at eight Michigan public institutions, December 2020.
  37. See “Hunger Free Campus Bill,” Swipe Out Hunger, n.d., accessed March 2021,
  38. Peter Ruark, “Studying in the shadow of the Coronavirus: Addressing college students’ basic needs insecurity—during the pandemic and after,” Michigan League for Public Policy, August 2020,
  39. Patrick Canning and Rosanna Mentzer Morrison, “Quantifying the Impact of SNAP Benefits on the U.S. Economy and Jobs,” U.S. Department of Agriculture Economic Research Service, July 2019,
  40. “#RealCollege 2021: Basic Needs Insecurity During the Ongoing Pandemic,” The Hope Center for College, Community, and Justice, March 31, 2021,
  41. “State and Local Allocation Estimates: American Rescue Plan Act of 2021,” National Conference of State Legislatures, March 8, 2021,
  42. Mark Muro, Eli Byerly Duke, and Joseph Parilla, “The American Rescue Plan’s secret ingredient? Flexible state and local aid,” The Brookings Institution, April 2, 2021,
  43. The 50 percent reimbursement is codified in 7 U.S.C. 2025. Information about reimbursable activities is found at 7 U.S.C. 2020(e)(1)(A).
  44. Both the author and a representative of the Center for Healthy Communities were unable to identify another university system in the nation coordinating campus-based SNAP outreach and receiving federal reimbursement.
  45. See page 256 of the “FY 2022–2023 Executive Recommendation, General Omnibus Budget Bill,” State of Michigan,
  46. Jing Zhu, Susanne Harnett, and Michael Scuello, “Single Stop Final Impact and Implementation Report,” Metis Associates, September 2018,
  47. These eleven institutions are Eastern Michigan University, University of Michigan-Ann Arbor, Bay College, Delta College, Glen Oaks Community College, Grand Rapids Community College, Macomb Community College, Mid Michigan College, Mott Community College, North Central Michigan College, and West Shore Community College. The author searched the MI Bridges online lookup tool for each public institution in Michigan based on the institution’s street address, available at The author also compared this list with a list of approved community colleges provided to the Michigan Community College Association (MCCA) by MDHHS, shared with the author by MCCA. If an institution appeared in either list, it was included here.
  48. Headcount enrollment data from the Integrated Postsecondary Education Data System (IPEDS). The exact figure is 26.4 percent of students at public institutions are enrolled at a campus that is a designated Navigation Partner.
  49. Institutions can also be MI Bridges Access Partners, which agree to display promotional materials and provide technology for completing MI Bridges applications, and/or MI Bridges Referral Partners, which agree to offer their services to MI Bridges users. For the purposes of making FAP application assistance maximally accessible to students, designation as a MI Bridges Navigation Partner appears to be ideal. See “MI Bridges Levels of Engagement,” Michigan Department of Health and Human Services, n.d., accessed April 2021,,5885,7-339-71551_82637_82639-450651–,00.html.
  50. James Mabli, “Supplemental Nutrition Assistance Program Participation and Local Program Outreach and Eligibility Services,” Research in Agricultural and Applied Economics 44, no. 3 (December 2015): 291–314,
  51. Their program could then be cross-checked with a list of CTE programs approved for an exemption.
  52. Author’s personal correspondence with Fresno State University food security coordinator, February 2020.
  53. This includes the estimated 9,000 undoucmented students attending Michigan colleges and most of the state’s estimated 31,000 international students. See Miriam Feldblum, Steven Hubbard, Andrew Lim, Christian Penichet-Paul, and Hanna Siegel, “Undocumented Students in Higher Education: How Many Students are in U.S. Colleges and Universities, and Who Are They?” New American Economy, April 2020,; and “International Students in the United States,” Migration Policy Institute, January 2021,
  54. For example, California’s fall 2020 budget allocated $15 million in emergency aid for undocumented students at the state’s public institutions. See Phil Ting, “Floor Report, 2020–21 State Budget,” California Assembly Budget Committee, October 2020, 56, See also “Student COVID-19 Emergency Fund,” Illinois Board of Higher Education, n.d., accessed April 2021,
  55. While institutional aid fills in gaps for many public university students, this depends on tuition revenue and high sticker price.