Project Bread SNAP Trainer: A Resource for Agencies
A curriculum for connecting low income families with healthy food
3: Understanding SNAP regulations
3.1 What do I need to know about SNAP regulations?Open
The SNAP regulations outline a clear and specific process. Let's start by reviewing some general guidelines.
Everyone has a right to apply
All applicants have a right to apply, even if they have applied in the past.
Applications must be submitted through the local Department of Transitional Assistance (DTA) office based on the city and/or ZIP code where the client lives. Click here to see the list of DTA offices.
There are five ways to apply:
- Over the phone - call Project Bread’s FoodSource Hotline to start an application over the phone, or have it sent through the mail.
- In person - click here to see the list of DTA offices
- By mail or fax - click here to download the application
- Online Click here for the Virtual Gateway (http://www.mass.gov/dta).
Applying in person at a local DTA office is not required.
The DTA requires an interview with the applicant.
Most of the time, it can be conducted over the phone. However, if your client prefers, s/he can request an in-person interview.
If the information on the application seems questionable, the DTA may require an in-person interview instead of a phone interview.
The DTA has 30 days to review and respond to the application. When the DTA approves the benefits, they will be retroactive to the date the DTA received your client's application.
3.2 Who is part of the SNAP household?Open
The DTA has a very specific definition of a household. Understanding that definition makes it easier for you to help your clients define their own household. To the DTA, a household is defined as people who live under one roof who purchase and prepare food together.
SNAP household regulations
The DTA defines a SNAP household as people who live under one roof who purchase and prepare food together. In practice, here is how it must be interpreted:
- An extended family that lives under one roof may or may not constitute multiple households. If they share food expenses, they must apply for benefits together in one application. If they do not share food expenses, they may be multiple, separate households;
- Sometimes more than one family lives under the same roof. If these different families do not share food expenses, then they can apply for SNAP benefits separately. Household members may go food shopping together, can cook together and can have occasional meals together, as long as they are not dependent on each other’s contribution to the food budget;
- Unrelated people who live under the same roof and buy and share food together are part of the same household.
For example, Theo and Kate are married and have a 2-year old and a 7-year old. They live in the same house and eat their meals together. They are a household of four.
When Kate's cousin, Briana, loses her job and needs a place to live with her 10-year old daughter and 9-year old son, Kate agrees to let them live in her finished basement. Briana and her children buy and make their own meals. They are a separate household of three.
According to the DTA's rules, living under the same roof alone doesn't make a household.
Kate and her cousin share a roof, but they don't buy and prepare meals together, so they aren't the same household. Being related is not the factor that defines a SNAP household according to the DTA.
According to the DTA there are now two separate households at the same address; each household may be eligible for SNAP benefits separately.
Exceptions to the rule
- Spouses who live together must apply together, even if they purchase, prepare, and eat separately;
- Children under the age of 22 who live with their parents must under all circumstances be included in the SNAP household;
For example, 20-year-old Anne, her boyfriend, and their baby live with Anne’s parents. Anne and her boyfriend work full time jobs and purchase and prepare their own meals, but because Anne is under 22 she cannot apply for SNAP on her own. If she applies, she must include her parents in her application. Or, if her parents apply, they must include Anne, the boyfriend, and the baby in their household SNAP application.
- Any child under the age of 18 (except for foster children), whether related or not, must be part of the same household as the responsible adult in the household. A child cannot apply for benefits separately from the adult in the household;
For example, 16-year-old Steve left home after a disagreement with his parents and is living with his friend’s family. He is not part of the foster care system. If his friend’s family applies for SNAP, they need to include Steve on the application.
- Foster children do not have to be included in the household. Your client can choose whether to include or exclude a foster child from the SNAP household. A foster child cannot apply for benefits as a separate household;
If your client includes the foster child in the household, the foster care stipend must be included as unearned income for the household.
- Non-citizen households sometimes include a mix of eligibility categories under one roof. Remember, under SNAP regulations, anyone under the same roof who shares food costs must be accounted for in the application. Be sure to read more about non-citizen households.
3.3 What documents will my clients need for verification?Open
Your clients need to provide documentation for each SNAP household member. This process is called verification.
Some verification documents are required, like ones that prove identity. Others are supplemental, like ones that show child care or rental expenses. Your clients can self-declare many eligibility factors. SNAP requires four types of documents for U.S. citizens and five for non-citizens.
Your clients must have this documentation:
- Proof of identity
- Proof that they live in Massachusetts
- Their social security numbers
- Proof of income for the past month. Please read our Income Guidelines document to learn more.
- If your clients are not U.S. citizens, they need to provide proof of their status. This can be their alien card or other immigration documents. For more information see Section 4.5 Tips for working with non-citizens.
Proof of identity
This can be any one of the following: driver’s license, passport, Social Security card, or birth certificate. This needs to be provided only by the primary applicant.
Proof that they live in Massachusetts
This can be any one of the following: driver’s license, utility bill, or tax forms.
Social security numbers
All applicants need to provide a social security number (SSN). They don't need to have the physical cards. If the head of household does not have a SSN and is applying for other household members, then that head of household is assigned a case number by DTA.
There are some supplemental documents that can help your clients obtain more benefits. These include documentation for expenses such as: housing expenses, utility expenses, childcare/adult day care expenses, and, in some limited cases, medical expenses.
- Your client may submit housing expenses
- Your clients may submit utility expensess
Utilities include heat, air conditioning, electricity, gas, and telephone. Documentation includes the bills from any or all of these utilities.
- Your clients may submit childcare, adult day care and child support payments
- Under some circumstances your clients may submit medical expenses
Applicants who can prove monthly unreimbursed medical expenses greater than $35 per month can apply a medical deduction when calculating SNAP benefits.
Medical deductions are applicable only to elders over the age of 59 and any person considered disabled under SNAP regulations.
For homeowners, this can include mortgage expenses, property taxes, and homeowner’s insurance. For renters, this can be any one of the following: current lease, rent receipt, a letter stating rental rates from the landlord, or a self-declared statement.
Child or adult day care expenses and child support payments
Expenses include both program fees and transportation costs. They can be self-declared as long as the amount is considered "reasonable".
For child support payments, your clients need to show the legal document ordering it, as well as proof of payment.
Your clients have the option of self-declaring their shelter and child or adult care expenses as long as the amount claimed is considered “reasonable” by DTA. Shelter expenses include housing and utilities.
Click here to download a copy of shelter or child or adult care self-declaration forms.
3.4 What alternative verification options can my clients use?Open
Your clients need to provide documentation to prove their household is eligible for SNAP benefits, but specific documents might vary depending on your client's particular circumstances. Learn more about options in verification.
Documents are one way of providing that proof - but may not be the only way. Some of the documents you read about in Section 3.3 provide the proof the DTA looks for, but there may be other options as well.
The DTA can't limit verification options
Regulations say that the DTA cannot ask for only one kind of verification. In other words, if your client's DTA caseworker does not accept one of the verification documents, that's not the end of the process. The caseworker must tell you what kind of proof your client needs and provide help getting it.
Sometimes the proof can be what is called self-declared. Self-declared means your client can make a signed and dated personal statement of fact, instead of providing supporting documentation. For example, the DTA allows your client to self-declare shelter and daycare costs. In some cases, the caseworker may require a written statement as proof for verification.
Click here to download a copy of shelter or child or adult care self-declaration forms.
Go to this link to see which proofs can be self declared.
Special cases for income verification
Most of the time, the DTA asks to see income from the past 30 days. However, there are special cases in which the DTA may ask for a different kind of proof. For example:
- If your client's weekly income varies, the DTA might ask for pay stubs from the past 8 weeks or more, so that the income can be averaged over time;
- Seasonal and school employees may need to show the DTA yearly income information;
- Self-employed clients will need to show recent tax filings or 3 months of business records;
- Rental income needs a supporting lease agreement or tenant statement.
3.5 What do the regulations say about income?Open
SNAP regulations define allowable income levels based on household size and composition. Let's look at these regulations.
SNAP benefits are based on household income, household composition, and household expenses. SNAP supplements a household's food budget. It fills the gap between what a household needs and what it has available to buy food.
The program figures out the size of the gap and the benefit level needed to fill it through a series of calculations.
The first thing you'll work with your client on is establishing his/her gross monthly income. The term gross income means all the earned and unearned income the household generates before any deductions are removed such as taxes or health insurance. In this case, earned income does not refer to the amount of your client’s paycheck, but the amount that the check would be before taxes and health insurance are taken out.
The gross income guidelines are different depending on your client’s household composition.
- Family, gross income - A family is a household with children under the age of 19. Gross family income is set at 200% of the federal poverty level, based on family size. This group is considered categorically eligible for SNAP and is not subject to asset limits.
- Over age 60 or disabled, gross income - There is no gross income guideline for households with disabled individuals or individuals who are 60 years of age or older. However, if their income is less than 200% of the federal poverty level, they meet the categorical eligibility criteria and are not subject to asset limits.
- No children, no elders, no disabled, gross income - Households that have no children, elders, or disabled individuals are referred to as Able Bodied Adults Without Dependents (ABAWD). This group's gross income eligibility is 130% of the federal poverty level, based on household size. If these households meet the income criteria for categorical eligibility, they are not subject to asset limits.
- Family or ABAWD with child support payments, gross income - Families and ABAWD that make court ordered child support payments can deduct these payments from their gross income before checking the appropriate eligibility guidelines (200% for families, 130% for ABAWD). In other words, you should look at what their income would be after the payments are made and consider this amount as their gross income when you check the SNAP income eligibility guidelines. However, when you prescreen these clients to assess their estimated benefit level, make sure to use their true gross income, ie their income before the payments are made.
The second thing you'll work with your client on is figuring out deductions and determining net income. The term net income means what your client has left after deducting a variety of allowable deductions.
- Allowed deductions include:
- Earned income deduction (20% of earned income)
- Standard deduction (based on family size)
- Medical deduction (out of pocket expenses over $35 for people age 60+ or disabled only)
- Dependent care deduction (program fees and transportation costs)
- Child support deduction (actual amount of court ordered child support)
- Excess shelter deduction (determined by formula)
- Homeless shelter deduction (alternative to excess shelter deduction for people who are homeless)
Assets are items of value owned by the client. In some cases their value must be calculated and cannot exceed certain limits, typically $3,250.
- Money that you have in cash or in a checking or savings account
- Real estate other than your home
SNAP does not count the following as assets:
- Your house and belongings
- A burial plot
- Up to $1500 in a pre-paid funeral home account
- Any asset that you cannot change into cash
- A car
There is no asset limit for low-income households that meet the categorical eligibility income guidelines. Remember, that's 200% of the federal poverty line for families and 130% of the federal poverty level for Able Bodied Adults Without Dependents.
Households with people age 60+ or disabled with income greater than 200% of the poverty level may still be eligible for SNAP, but because they are above the categorical eligibility criteria they have an asset limit of $3,250.
3.6 What education and employment regulations must be followed?Open
Households receiving SNAP benefits must comply with the SNAP Employment & Training Program (SNAP/ET) requirements. These requirements say that household members must look for work and accept any reasonable job offer. Let's learn more about what this means for your clients.
DTA requires SNAP households to comply with SNAP Employment & Training Program (SNAP/ET) regulations. This means that SNAP household members between the ages of 18 and 59 are required to register in the SNAP/ET program, search for employment, and accept any reasonable job offer.
If household members do not meet these requirements, it can result in loss of benefits for a period of time.
If the household provides its caseworker with a "good cause" verification, DTA may waive this requirement.
A good cause verification provides proof that there is an acceptable reason for not following SNAP/ET regulations. Examples of good cause reasons include:
- Lack of adequate child care
- A family crisis or emergency prevents working during work hours or complying with other SNAP/ET regulations
- The wage offered falls below federal or state minimum wage
- A strike or a lockout prevents work
- The job or offer, according to the client, discriminates based on age, sex, religion, race, ethnic origin or physical/mental handicap
- The work puts the client's health and safety at risk
- The work hours or employment type interfere with the client's religious observances or are inconsistent with the client's religious beliefs
- The commute time exceeds two hours per day or the walking distance, if walking is the only commute method available, exceeds two miles round trip
Exempt household members
Certain household members are exempt from the SNAP/ET regulations, including members who are:
- Under the age of 16 or over the age of 59
- Receiving or applying for unemployment and participating in a comparable work program
- Responsible for the care of a child under the age of six or of an incapacitated person (even if that child or incapacitated person does not live in the same household)
- Enrolled as a student (at least part-time)
- Employed and working a minimum of 30 hours per week
- More than three months pregnant
- Physically or mentally “unfit” for employment, including those whose illness is expected to last more than 30 days
Household members who are ill must once again meet program requirements after returning to health. Short term illness is not a permanent exemption.
106 CMR 362.300 contains complete rules and a list of exemptions.
3.7 What are the regulations for emergency SNAP benefits?Open
Some applicants are eligible for expedited benefits. Expedited benefits means that your client can go from a submitted application to approved benefits within 7 days. Learn more about expedited benefits.
To be eligible for expedited benefits your client must meet one of these three criteria:
- Income and money in the bank add up to less than the monthly housing expense
- Monthly income is less than $150 and money in the bank is less than $100
- The applicant is a migrant worker and money in the bank is less than $100
DTA uses "money in the bank" as a question to screen for expedited SNAP benefits, but it won't ask your client for proof of the bank balance.
If your client believes s/he is eligible for expedited benefits but doesn't get them, s/he has a right to a conference with a DTA supervisor.
If your client is applying for expedited benefits, s/he should file in person at the nearest DTA office that serves his/her ZIP code. If your client is unable to go in person, s/he should let the DTA caseworker know, during the phone interview, that s/he is eligible for the 7-day approval process.
3.8 What happens after my client applies for SNAP?Open
Great! You've helped your client gather all the needed documents and have submitted the materials to the DTA. Next comes the approval process. Let's learn a bit more about the regulations guiding this process.
Once your client submits the application and verification documents, the DTA has 30 days to complete the eligibility process. The process is clearly defined by SNAP regulations.
Once DTA has processed the application, conducted the interview, and received all the verification documentation, they determine your client’s eligibility and send an approval or denial letter.
Approval: When your client is approved s/he will receive a plastic card. This card is called an Electronic Benefits Transfer (EBT) card, and it works like a debit card. DTA electronically transfers benefits onto the card. DTA no longer uses paper coupons.
Your client may receive an EBT card in the mail right after submitting an application. However, until DTA processes and approves the application, the card won't have any benefit value on it. Once DTA approves the application, it will electronically "load" the card.
Denial: If DTA denies benefits because your client’s application was missing verification documents or proofs, your client has 30 days to submit the documents or proofs and ask the DTA to reopen the case.
If your client doesn’t respond to the DTA for more than 60 days, you will have to start the whole process all over from the beginning.
If DTA approves your client’s application, s/he will be certified to receive SNAP benefits for a certain number of months.
The length of the certification period is based on the stability of the household income. Most households are certified to receive benefits from 1-12 months. Elders and disabled individuals are usually certified for 12-24 months.
Your client will need to reapply or “recertify” at the end of this time period to continue receiving benefits.