Adult Student Eligibility for NA
 |
This section includes information about whether an adult student is eligible to participate in the Nutrition Assistance program.
This policy is effective for all eligibility determinations completed on or after 12/23/2024. For eligibility determinations completed before 12/23/2024 see the prior policy.
Policy
An applicant is considered an NA student when age 18 through 49 and enrolled at least half-time in an institution of higher education.
An NA student is considered enrolled in an institution of higher education when they meet one of the following criteria:
●In a business, technical, trade, or vocational school and in a course of study that normally requires a high school diploma or General Educational Development (GED) diploma.
●In a college or a university in a course of study working towards a degree.
An applicant is not considered enrolled in an institution of higher education when attending a special program or a course of study that does not require a high school or GED diploma. This may include participants attending any of the following:
●English as a Second Language (ESL) courses
●Adult basic education courses
●Literacy courses
●Community College
●Business School
●Technical School
●Trade School
●Vocational School
Participants who meet the definition of a student enrolled in an institution of higher education(g), are not eligible for NA benefits unless they meet all of the following:
●NA student work requirements or an NA student exemption.
●Not receiving the majority of their meals through mandatory or optional meal plans offered by the institution.
The NA student is considered enrolled during vacation, recess or between semesters or quarters provided the student intends to register for the next normal school term.
NOTE The student is not considered enrolled during vacation or recess when the student graduates, drops out, is expelled, is suspended, or does not intend to register for the next normal school term.
The school defines what is considered half-time. When the school has no official definition of half-time, the minimum number of full-time hours, as defined by the school, is divided by two to determine half-time.
See all of the following for NA student meal plans, work requirements, and exemptions:
NA Student Meal Plans
NA students who are receiving the majority of their meals (more than 50 percent of three meals daily) through mandatory or optional meal plans offered by the institution are not eligible for NA benefits
Meal plan structure may vary from institution to institution. The value of a meal plan may be counted by the number of meals, points, or dollars included. (See Example 5)
NA Student Employment
NA students who are employed and paid for at least 80 hours in a 30-day period are potentially eligible for NA benefits. It is not required that the student earn minimum wage.
Self-employed students must be employed for an average of 20 hours or more per week and receive earnings equal to the federal minimum wage(g).
NOTE Working for the landlord as payment for shelter expenses (In-kind income) is not considered employment when determining NA student eligibility.
NA Student Eligibility Work-study
NA students who are participating in a state or federally financed work-study program during the regular school year are potentially eligible for NA benefits. The student must be working at a job and receiving earnings or tuition credit for the work performed.
NOTE The criteria are met even when earnings from certain work-study programs are not counted for eligibility and income determination.
A student who is working in a hospital or student teaching is not considered as participating in a state or federally financed work-study. The student is receiving class credits, not earnings or tuition credit.
NA student eligibility based on work-study participation continues through vacations, breaks in the school year, and between semesters or quarters. The student is required to have been participating in the work-study during the school period before the break and must plan on continuing the work-study once classes resume.
NOTE NA students may contact the school for more information on work-study programs.
NA Student Employment and Training Programs
NA students are potentially eligible for NA benefits when assigned to, placed in, or self-admitted in an institution of higher education through one of the following:
●The Jobs Program. (See CA Work Programs for more information.)
●The Workforce Innovation and Opportunity Act (WIOA). (See WIOA for more information.)
●The Supplemental Nutrition Assistance Program Career Advancement Network (SNAP CAN). (See SNAP CAN for more information.)
NOTE A Career and Technical Education Program (g) in accordance with the Carl D. Perkins Career and Technical Education Act does not meet an exemption unless the program meets all of the following (See Example 4):
●Is designed to be completed in four years or less.
●Is completed at an institution of higher education.
●Requires a high school or GED diploma.
●Is not a special program such as ESL or GED classes.
●A Tribal employment and training program.
●Section 236 of the 1974 Trade Adjustment Act (TAA). TAA is made available to workers who lose jobs or hours of work due to increased imports.
●A similar employment and training program. The program must meet all of the following:
Offered by a state or local government.
For low-income households.
Provide at least one component similar to a component offered by SNAP CAN. (See SNAP CAN for more information.)
NA Student Participating in an On-The-Job Training Program
NA students who are participating in an on-the-job training program are potentially eligible for NA benefits during the training period. An NA student is participating in an on-the-job training program when all of the following occur:
●Hired and paid wages by an employer.
●Engaged in productive work and receiving training.
NOTE The student is only eligible for NA benefits during the time the student is being trained by the employer.
NA Student Exemptions
The participant may be an eligible student when they meet any of the following NA Student Exemptions:
●Age 17 or younger.
●Age 50 or older.
●Currently receiving any CA benefits.
●Unfit for Work. (See NA Work Requirement Exemptions for more information and policy.)
●The student is responsible for the care of a dependent child, based on one of the following caretaker exemptions:
The student is a single parent, enrolled full-time and responsible for the care of a dependent child aged 11 or younger, regardless of adequate childcare.
When adequate childcare is not available, and the child is aged 6 through 11. (See Example 1)
The child is age five or younger.
When the NA budgetary unit includes more than one child and more than one adult student responsible for the care of the children, every student is eligible for the caretaker exemption at a ratio of one student per eligible child. (See Example 2 and Example 3)
NA Student Exemption Adequate Childcare
Consider the availability of adequate childcare when an NA student is responsible for the care of a child aged 6 through 11. Adequate childcare allows the NA student to attend class and meet employment or work-study requirements.
Adequate childcare can be any of the following:
●Available - A participant aged 18 or older, other than the NA student, is suitable and able to provide the childcare.
●Unavailable - The participant states adequate childcare is unavailable due to one of the following:
Lack of public or private transportation to obtain childcare.
Lack of funds to pay a childcare provider.
NA Work Registration Requirements
When NA student eligibility criteria are met, the NA participant is exempt from NA work registration requirements. (See NA Work Requirement Exemptions for more information and policy.)
Verification
The participant has the primary responsibility for providing verification. (See Participant Responsibilities – Providing Verification for additional policy.)
Any of the following sources can be used to verify school attendance when requested:
●Correspondence from the school
●Registration form
●School records or school official's statements
●Current report card
●Scholarship boards/records
●Documents indicating placement into a Career and Technical Education Program.
●Participant's statement (allowed as a last resort)
Verification of participation in a meal plan may include, and is not limited to, any of the following:
●Completion of the Student Information Verification Notice (C013)
●Collateral Contact with the school
●Correspondence from the school
Verification of participation in work-study may include, and is not limited to, all of the following:
●Completion of the FAA-0060A form
●Collateral Contact to the school
●Correspondence from the school
●Paystubs that indicate the student is paid for work study hours
Verification of participation in an on-the-job training program may include, and is not limited to, all of the following:
●Collateral Contact or signed statement from the employer verifying participation in the program and the length of the training
●Any other verification that confirms the student’s participation in the program and the length of the training
When a participant is placed in an institution of higher education through an employment and training program, verification may include, and is not limited to, any of the following:
●Collateral Contact or signed statement from the employment and training program provider, verifying participation in the program
●Any other verification that confirms the student’s participation in the program
For verification that can be used for the unfit for work exemption, see NA Work Requirements.
Verification that adequate childcare is unavailable may include, and is not limited to, any of the following:
●Participant Statement verification, unless questionable(g).
●Screenshots confirming childcare distance or cost from the childcare provider’s website or the program’s application.
●Collateral Contact or a signed and dated statement from the childcare provider.
NOTE Provider documentation needs to contain the name, address, and telephone number of the provider.
Examples
1) All the following apply for Nutrition Assistance (NA):
●David (age 28/student/unemployed)
●Carol-spouse (age 26/student/unemployed)
●Frank-common child (age 8)
The budgetary unit includes two adult students and one child. Adequate childcare is not available for both adult students. David and Carol need to decide which one of them receives the caretaker exemption.
2) All of the following apply for Nutrition Assistance (NA):
●Richard (age 28/student/unemployed)
●Theresa-spouse (age 26/unemployed)
●Dick-common child (age 6)
●Jane-common child (age 3)
●Sally-common child (age 1)
Richard is eligible for the NA student caretaker exemption, even though Theresa is available for childcare. The reason Richard is eligible for the NA student caretaker exemption is that the household includes at least one child, age five or younger, per adult student.
3) All the following apply for Nutrition Assistance (NA):
●Richard (age 28/student/unemployed)
●Maria -spouse (age 26/student/unemployed)
●Dick-common child (age 5)
●Jane-common child (age 3)
Richard and Maria are both available to care for the children. However, both are eligible for the caretaker exemption because the household includes at least one child, age five or younger, per adult student.
4) Lois applies for NA benefits for herself, she is approved for NA and was screened as an appropriate candidate to participate in SNAP CAN. Lois is subject to ABAWD requirements and voluntarily contacts a SNAP CAN provider. Lois is referred to complete a Career and Technical Education Program by the SNAP CAN provider. She reports the change to FAA that she is now enrolled in a school for Cosmetology and can obtain her license in two years. A high school or GED diploma is required to enroll.
Lois is voluntarily participating, and complying, with the requirements of an employment and training program and provides the required verification. It is verified that the school is an institution of higher education. Since Lois has an ABAWD exemption and is an eligible NA Student, she continues to remain eligible for NA benefits.
Legal Authorities
7 CFR 273.5
7 CFR 273.5(a)
7 CFR 273.5(b)(1 through 11)
last revised 12/16/2024 effective 12/23/2024