.
The Supplemental Nutrition Assistance
Program (SNAP): Categorical Eligibility
Gene Falk
Specialist in Social Policy
Randy Alison Aussenberg
AnalystSpecialist in Nutrition Assistance Policy
JulyDecember 22, 2014
Congressional Research Service
7-5700
www.crs.gov
R42054
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Summary
The Supplemental Nutrition Assistance Program (SNAP) provides benefits to low-income,
eligible households on an electronic benefit transfer (EBT) card; benefits can then be exchanged
for foods at authorized retailers. SNAP reaches a large share of low-income households. In
FY2013FY2014, a monthly average of 47.646.5 million persons in 23.122.7 million households benefitted from
SNAP.
Federal SNAP law provides two basic pathways for financial eligibility to the program: (1)
meeting program-specific federal eligibility requirements; or (2) being automatically or
“categorically” eligible for SNAP based on being eligible for or receiving benefits from other
specified low-income assistance programs. Categorical eligibility eliminated the requirement that
households who already met financial eligibility rules in one specified low-income program go
through another financial eligibility determination in SNAP.
In its traditional form, categorical eligibility conveys SNAP eligibility based on household receipt
of cash assistance from Supplemental Security Income (SSI), the Temporary Assistance for
Needy Families (TANF) block grant, or state-run General Assistance (GA) programs. However,
since the 1996 welfare reform law, states have been able to expand categorical eligibility beyond
its traditional bounds. That law created TANF to replace the Aid to Families with Dependent
Children (AFDC) program, which was a traditional cash assistance program. TANF is a broadpurpose block grant that finances a wide range of social and human services. TANF gives states
flexibility in meeting its goals, resulting in a wide variation of benefits and services offered
among the states. SNAP allows states to convey categorical eligibility based on receipt of a TANF
“benefit,” not just TANF cash welfare. This provides states with the ability to convey categorical
eligibility based on a wide range of benefits and services. TANF benefits other than cash
assistance typically are available to a broader range of households and at higher levels of income
than are TANF cash assistance benefits.
As of July 21,December 2014, 4342 jurisdictions have implemented what the U.S. Department of Agriculture
Agriculture (USDA) has called “broad-based” categorical eligibility. These jurisdictions generally
make all
households with incomes below a state-determined income threshold eligible for SNAP.
States do
this by providing households with a low-cost TANF-funded benefit or service such as a brochure
brochure or referral to an “800” number telephone hotline. There are varying income eligibility thresholds
thresholds within states that convey “broad-based” categorical eligibility, though no state has a
gross income
limit above 200% of the federal poverty guidelines. In all but five of these
jurisdictions, there is
no asset test required for SNAP eligibility. Categorically eligible families
bypass the regular
SNAP asset limits. However, their net incomes (income after deductions for
expenses) must still
be low enough to qualify for a SNAP benefit. That is, it is possible to be
categorically eligible for
SNAP but have net income too high to actually receive a benefit. The
exception to this is one- or
two-person households that would still receive the minimum benefit.
The Agriculture Act of 2014 (the “2014 Farm Bill,” P.L. 113-79) made no changes to SNAP
categorical eligibility rules. The House-passed version of the bill that became the 2014 Farm Bill
would have eliminated broad-based categorical eligibility, but that change was not included in the
conference agreement on the bill.
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Contents
Introduction...................................................................................................................................... 1
Regular and Categorical Eligibility for SNAP................................................................................. 1
Eligibility through Meeting Federal Income and Resource Tests.............................................. 1
Categorical Eligibility ............................................................................................................... 2
Early History ....................................................................................................................... 2
The 1996 Welfare Law and TANF ...................................................................................... 3
What TANF Means for Categorical Eligibility ................................................................... 4
Traditional, Narrow, and Broad-Based Categorical Eligibility ........................................................ 5
Scope and Reach of Categorical Eligibility ............................................................................... 5
“Broad-Based” Categorical Eligibility Practices ....................................................................... 6
Incomes and Assets of SNAP Households..................................................................................... 12
Income ..................................................................................................................................... 12
Assets....................................................................................................................................... 15
Figures
Figure 1. Scope of SNAP Categorical Eligibility by State .............................................................. 6
Tables
Table 1. SNAP Broad-Based Categorical Eligibility by State ......................................................... 8
Table 2. Gross Incomes of SNAP Households Compared with Poverty: FY2011FY2012 ........................ 12
Table 3. Estimates of SNAP Households without An Elderly or Disabled Member with
Gross Incomes Over 130% of Poverty by State: FY2011FY2012 .......................................................... 13
Table A-1. Federal SNAP Monthly Income Eligibility Limits for FY2014FY2015................................... 16
Table A-2. Maximum Monthly Earnings a Family of Three May Have and Still Meet
Initial Eligibility for TANF Cash Assistance: July 2012 ............................................................ 16
Appendixes
Appendix........................................................................................................................................ 16
Contacts
Author Contact Information........................................................................................................... 18
Area of Expertise by Author .......................................................................................................... 18
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Introduction
The Supplemental Nutrition Assistance Program (SNAP) provided food assistance to a monthly
average of 47.746.5 million people in 23.122.7 million households in FY2013FY2014. Total benefit costs reached
$76.1were
$70.0 billion in FY2013. FY2014.
SNAP participation and costs have increased markedly sincefrom FY2007,
to FY2013, mostly as a result of
automatic and legislated responses to the recession.1
While much of the recent increase In FY2014, both participation and costs
declined from peak FY2013 levels. While much of the FY2007 to FY2013 increase in
participation and costs is attributable to the poor economy, recently states have beenstates during this period also
increasingly adoptingadopted more expansive “categorical eligibility” rules—a set of policies that make a
SNAP applicant eligible based on the applicant’s involvement with other low-income assistance
programs: benefits from the Temporary Assistance for Needy Families (TANF) block grant,
Supplemental Security Income (SSI), and state-financed General Assistance (GA) programs. This
report discusses categorical eligibility and some of the issues raised by it. It first describes the
three different types of categorical eligibility: traditional categorical eligibility conveyed through
receipt of need-based cash assistance, and the newer “narrow” and “broad-based” categorical
eligibilities conveyed via TANF “noncash” benefits. It also provides recent information on
current state practices with regard to categorical eligibility. Finally, the report discusses proposals
to restrict categorical eligibility.
The Agriculture Act of 2014 (the “2014 Farm Bill, P.L. 113-79) made no changes to SNAP
categorical eligibility rules. The House-passed version of the bill that became the 2014 Farm Bill
would have eliminated “narrow” and “broad-based categorical eligibility,” retaining only
“traditional” categorical eligibility for recipients of cash assistance. However, the House-passed
provision was not included in the conference agreement on the bill.
Regular and Categorical Eligibility for SNAP
Federal law provides the basic eligibility rules for SNAP. There are two basic pathways to gain
financial eligibility for SNAP: (1) having income and resources below specified levels set out in
federal SNAP law; and (2) being “categorically,” or automatically, eligible based on receiving
benefits from other specified low-income assistance programs.
Eligibility through Meeting Federal Income and Resource Tests
Under the regular federal rules, SNAP provides eligibility to households based on low income
and limited assets. Households must have net income (income after specified deductions) below
100% of the federal poverty guidelines. In addition, federal rules provide that households without
an elderly or disabled2 member must have gross income (income before deductions) below 130%
of the federal poverty guidelines (see Table A-1).
Additionally, the regular eligibility rules provide that a household must have liquid assets below a
specified level. Under federal rules in FY2014, a household’s liquid assets must also be below
1
See Congressional Budget Office, The Supplemental Nutrition Assistance Program, April 2012, http://www.cbo.gov/
sites/default/files/cbofiles/attachments/04-19-SNAP.pdf.
2
“Elderly or disabled” is defined in Section 3(j) of the Food and Nutrition Act of 2008.
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Additionally, the regular eligibility rules provide that a household must have liquid assets below a
specified level. Under federal rules in FY2015, a household’s liquid assets must also be below
$2,250$2,000, and below $3,250 in the case of households with an elderly or disabled member. The
value of the home is excluded from this “assets test,” as are certain other forms of assets (e.g.,
retirement and educational savings).
Further, a portion of the value of a household’s vehicles is not counted toward the asset limit (up
to $4,650 of the fair market value of a household’s vehicles). However, federal law gives states
the option to further exclude the value of vehicles from being counted toward the asset limit.
States may elect to use the exclusion applicable for TANF assistance in their SNAP program.
Under TANF, many states fully exclude the value of one vehicle. This option is distinct from
categorical eligibility.
Categorical Eligibility
Federal law also makes households in which all members are either eligible for or receive
benefits from TANF, Supplemental Security Income (SSI), or state-financed GA programs
categorically, or automatically, eligible for SNAP.3 These households, who have already gone
through eligibility determination for those programs, bypass the income and resource tests
discussed above and are deemed financially eligible.4 They then have their SNAP benefits
determined.
Categorically eligible households have their SNAP benefits determined under the same rules as
other households. A household’s SNAP benefit amount is based on the maximum benefit (which
varies by household size) and its net countable income after deductions for certain expenses.
While the household may be categorically eligible, its net income may be too high to actually
receive a SNAP benefit. The exception is that all eligible households consisting of one or two
persons are eligible for at least the minimum monthly benefit, set at $1516 in the 48 contiguous
states and the District of Columbia for the period November 1, 2013, to September 30, 2014FY2015.
Early History
Special rules providing for expedited eligibility of cash assistance recipients date back to
amendments to the Food Stamp program enacted in 1971.5 These rules were eliminated in the
rewrite of food stamp law enacted in 1977, but they were reinstated in phases during the early
1980s through 1990.6 Categorical eligibility was seen as advancing the goals of simplifying
administration, easing entry to the program for eligible households, emphasizing coordination
3
Section 5(a) of the Food and Nutrition Act of 2008.
Additionally, federal law also provides a separate rule for households where some, but not all, members receive
benefits from TANF or SSI. In such households, recipients of TANF or SSI benefits are deemed to have passed the
SNAP resource test. That is, the assets of household members who receive TANF, SSI, or GA are disregarded from the
household’s total resources when determining whether the household passes the asset test (Section 5(j) of the Food and
Nutrition Act of 2008).
5
Section 6 of P.L. 91-671.
6
The Omnibus Budget Reconciliation Act of 1982 (P.L. 97-253) provided that a household in which all members
received Aid to Families with Dependent Children (AFDC) cash assistance bypass the Food Stamp asset test (but not
the income eligibility test). The Food Security Act of 1985 (P.L. 99-198) provided that households in which all
members received AFDC or SSI would be automatically eligible for Food Stamps, bypassing both the income and asset
tests. P.L. 99-198 made this a temporary provision that would sunset at the end of FY1998. P.L. 100-435 eliminated the
sunset, making categorical eligibility a permanent feature of Food Stamp law. Categorical eligibility was extended to
recipients of state-run GA programs in 1990, enacted as part of P.L. 101-624.
4
(continued...)
4
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administration, easing entry to the program for eligible households, emphasizing coordination
among low-income assistance programs, and reducing the potential for errors in establishing
eligibility for benefits.7 The Food Security Act of 1985 conveyed categorical eligibility to all
households receiving cash aid from Aid to Families with Dependent Children (AFDC), SSI, or
state-run GA programs. These programs had their own income and resource tests (often more
stringent than food stamp tests), so subjecting a household to a separate set of income and
resource tests for food stamps could be seen as redundant and inefficient.
The 1996 Welfare Law and TANF
The current form of categorical eligibility resulted from the 1996 welfare reform law (the
Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193). That
law ended AFDC, replacing it with TANF. AFDC was a traditional cash assistance program.
Within some federal rules, states set AFDC eligibility and benefit amounts, but federal law
established it as a cash welfare program. AFDC eligibility rules were generally more restrictive
than those for food stamps, and most AFDC families also received a substantial food stamp
benefit.
TANF, on the other hand, is a broad-purpose block grant that gives states broad flexibility to
expend funds. The statutory purpose of TANF is to increase state flexibility to achieve four policy
goals:8
1. provide assistance to needy families so that children can be cared for in their own
homes or in the homes of their relatives;
2. end dependence by needy parents on government benefits through promoting
work, job preparation, and marriage;
3. reduce the incidence of out-of-wedlock pregnancies; and
4. promote the formation and maintenance of two-parent families.
States may expend TANF funds and associated state funds (called Maintenance of Effort or MOE
funds) in any manner “reasonably calculated”9 to achieve the TANF purpose, providing broad
authority for the types of activities that may be funded. These activities include the traditional
cash assistance programs—which convey traditional categorical eligibility.10 However, in FY2011FY2013
traditional cash welfare accounted for only 2928% of all expenditures from the TANF block grant
and MOE funds.
TANF funds a wide range of other benefits and services that seek to ameliorate the effects, or
address the root causes, of child poverty. TANF benefits and services to achieve the first two
goals of TANF (provide assistance, end dependence of needy parents on government benefits)
must be for needy families with children. These benefits or services are need-tested, though states
(...continued)
recipients of state-run GA programs in 1990, enacted as part of P.L. 101-624.
7
U.S. Congress, House Committee on Agriculture, report to accompany H.R. 2100, 99th Cong., 1st sess., September 13,
1985, H.Rept. 99-271, Part 1 (Washington: GPO, 1985), p. 142.
8
Section 401(a) of the Social Security Act.
9
Section 404(a)(1) of the Social Security Act.
10
In regulations promulgated after the 1996 welfare law, the Department of Health and Human Services (HHS) divided
TANF- and MOE-funded activities into two categories: (1) assistance, and (2) everything else. The regulations defined
assistance generally as representing the traditional cash assistance programs (“basic assistance”) and transportation or
child care aid for nonworking persons.
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TANF funds a wide range of other benefits and services that seek to ameliorate the effects, or
address the root causes, of child poverty. TANF benefits and services to achieve the first two
goals of TANF (provide assistance, end dependence of needy parents on government benefits)
must be for needy families with children. These benefits or services are need-tested, though states
determine their own income thresholds. These benefits are often available to families at higher
levels of income than is cash assistance, often a multiple of the federal poverty threshold, and
without an asset test.
Moreover, TANF services directed at the third and fourth goals shown above can be for any
person in a state; that is, TANF services to reduce out-of-wedlock pregnancies or promote twoparent families are not restricted to families with children. These benefits and services are
potentially available to a state’s entire population. Federal rules also do not require that they be
need-tested benefits and services.
What TANF Means for Categorical Eligibility
The 1996 welfare reform law did not substantively change SNAP law with respect to categorical
eligibility. Rather, it simply replaced the reference to AFDC with one to TANF in the section of
law that conveys categorical eligibility. As discussed above, TANF gives states much broader
authority than they had under AFDC to offer different types of benefits and services. This
expansion of authority under TANF had major implications for categorical eligibility, allowing
states to convey categorical eligibility based on receipt of a wide range of human services rather
than simply cash welfare.
U.S. Department of Agriculture (USDA) regulations issued in 2000 provide rules for which
noncash or in-kind TANF or MOE-funded benefits or services can be used to convey SNAP
categorical eligibility.11 The regulations require that states make categorically eligible for SNAP
•
households in which all members receive or are authorized to receive12 cash
assistance funded by TANF or MOE dollars; and
•
households in which all members receive or are authorized to receive noncash
aid funded at least 50% by TANF or MOE dollars.
The regulations imposed one restriction on states in conveying categorical eligibility: if the
TANF- or MOE-funded benefit or service was aimed at achieving TANF goals three (reducing
out-of-wedlock pregnancies) or four (promoting two-parent families), the state would have to
choose a program with an income limit of no more than 200% of the federal poverty guideline for
conveying categorical eligibility.
Additionally, subject to the 200% of poverty restriction discussed above, the regulations give
states the option of making categorically eligible for SNAP
•
households in which all members receive or are authorized to receive noncash
assistance funded less than 50% by TANF or MOE dollars; and
11
The regulations are at 7 C.F.R. 273.2(j). See discussion of the final rule at U.S. Department of Agriculture, Food and
Nutrition Service, “Food Stamp Program: Noncitizen Eligibility, and Certification Provisions of P.L. 104-193, as
Amended by Public Laws 104-208, 105-33, and 105-185,” 65 Federal Register 70159-70161, November 21, 2000.
12
The regulations also provide that a family is categorically eligible if they either receive a TANF- or MOE-funded
benefit or if they are “authorized” to receive such a benefit. “Authorized” to receive a benefit means that they have
been determined eligible and have been informed as such; they do not need to actually be receiving benefits.
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•
households in which all members receive or are authorized to receive noncash
assistance funded less than 50% by TANF or MOE dollars; and
•
households in which at least one member receives or is authorized to receive
noncash aid funded at least partially by TANF or MOE dollars, but the state
agency determines the whole household benefits from such noncash aid.
Traditional, Narrow, and Broad-Based
Categorical Eligibility
As discussed, in instances of categorical eligibility, SNAP applicants can be found eligible for
SNAP based on their receipt of benefit from other specified means-tested programs.13 At
minimum, households that receive Temporary Assistance for Needy Families (TANF) cash
assistance, Supplemental Security Income (SSI), or state-funded general assistance cash benefits
must be found categorically eligible for SNAP. However, the 1996 welfare reform law’s creation
of TANF as a broad-based block grant has allowed for a state option to include a long list of
benefits/services that can convey SNAP eligibility. This section discusses state choices in this
area as of July 21,December 2014.
Scope and Reach of Categorical Eligibility
The current status of SNAP categorical eligibility is the product of state choices. At minimum, a
state must implement “traditional” categorical eligibility, but some states allow additional
programs and benefits to convey categorical eligibility. The USDA has developed a typology of
state practices on categorical eligibility, categorizing states into three groups:
13
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•
Traditional categorical eligibility only. In its traditional form, a household
where all members receive need-tested cash aid from SSI, GA, or TANF is
automatically made eligible for SNAP as well. These households have already
met the income and (in general) resource test for cash aid. Note that states set
income and asset eligibility rules for TANF and GA (see Table A-2 for maximum
earnings possible for entry to TANF cash assistance in July 2012). SSI provides a
federal income floor based on federal rules for the needy who are aged, blind, or
disabled. However, states may supplement SSI with their own funds, leading to
state variation in SSI eligibility as well. Based on the most current information
available, only fivesix states currently convey only traditional categorical eligibility.
•
“Narrow” categorical eligibility. These states have expanded categorical
eligibility beyond just traditional categorical eligibility, but in a way to limit the
number of households made eligible for SNAP. These states convey categorical
eligibility through receipt of cash and certain TANF noncash benefits, such as
child care and counseling. Based on the most current information available, only
five states have “narrow” categorical eligibility policies.
•
“Broad-based” categorical eligibility. These states have expanded categorical
eligibility in ways that make most, if not all, households with low incomes in a
state categorically eligible for SNAP. States could make all low-income
households in a state—including those without children—eligible for a TANF-
See 7 U.S.C. 2014(a).
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See 7 U.S.C. 2014(a).
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state categorically eligible for SNAP. States could make all low-income
households in a state—including those without children—eligible for a TANFfunded service directed at either the reducing out-of-wedlock pregnancies or
promoting two-parent families goals of TANF. If a state opted to do so, any lowincome household (under 200% of poverty, per regulation) could either receive,
or be authorized to receive, such a TANF-funded service. Based on the currently
available information, 4039 states, the District of Columbia, Guam, and the Virgin
Islands have broad-based categorical eligibility policies.
Figure 1 displays a map categorizing states and territories by these three categories.
Figure 1. Scope of SNAP Categorical Eligibility by State
Source: Congressional Research Service (CRS), based on data from the U.S. Department of Agriculture, July 21,December
2014.
“Broad-Based” Categorical Eligibility Practices
Broad-based categorical eligibility is a policy that makes most households with incomes below a
certain threshold categorically eligible for SNAP. Typically, households are made categorically
eligible through receiving or being authorized to receive a minimal TANF- or MOE-funded
benefit or service, such as being given a brochure or being referred to a social services “800”
telephone number (see Table 1). Recalling the USDA regulation, the brochure or telephone
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number must be funded with TANF or MOE dollars and thus must be directed at a TANF
purpose.14
States have increasingly availed themselves of the option to use broad-based categorical
eligibility to expand and ease access to SNAP eligibility. The Department of Agriculture reports
that, as of July 21,December 2014 (the latest data available), 4342 jurisdictions operated broad-based
categorical eligibility to make most or all households in their state with whom the state welfare
office comes in contact SNAP eligible.
Table 1 shows the use of SNAP broad-based categorical eligibility by state as of July 21,December 2014.
Of the 4342 jurisdictions using broad-based categorical eligibility,
•
4140 make all family types eligible (New Hampshire restricted broad-based
categorical eligibility to families with children; New York restricted broad-based
categorical eligibility to households with dependent care expenses);
•
3837 currently have no asset test (Texas, Michigan, Nebraska, Idaho, and
Pennsylvania apply an asset test for all households. Note, though, currently in 11
jurisdictions, households with an elderly and disabled member with incomes in
excess of 200% of the federal poverty guidelines have to meet the regular SNAP
asset tests of $3,250 for households of that type); and
•
27 have a gross income limit above 130% of the federal poverty guidelines,
though some of the largest states (California; New York, for families without
dependent care expenses; and Illinois) retained the 130% gross income limit.
According to USDA policy and guidance, there is a general way that a state would administer
broad-based categorical eligibility for a SNAP applicant. The local SNAP office would collect
basic income information on the applicant; if the applicant’s income is below the limit specified,
then the state office would administer, or determine whether a member of the household was
authorized to receive, a relatively nominal TANF-funded benefit or service. Receipt of this TANF
benefit or service then constitutes SNAP eligibility through broad-based categorical eligibility.
(As discussed above, it is still possible to be categorically eligible but receive no benefit because
net income is too high.)
In the case of the District of Columbia, as shown in the table, if the applicant’s gross income is
below 200% of poverty, the applicant would then receive a particular brochure for a program that
is TANF-funded and would then be eligible for SNAP through the broad-based categorical
eligibility pathway.
14
For a discussion of state practices regarding “broad-based” categorical eligibility, see U.S. Government
Accountability Office, Supplemental Nutrition Assistance Program: Improved Oversight of State Eligibility Expansions
Needed, GAO-12-670, July 2012.
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Table 1. SNAP Broad-Based Categorical Eligibility by State
Information as of July 21,December 2014, Excludes States without Broad-Based Categorical Eligibility
Households
Eligible
State
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Type of TANF
Benefit or Servicea
Asset Rules
Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
poverty
guidelines)b
Alabama
All
Brochure
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
Arizona
All
Referral on application
No limit
185%
California
All
Pamphlet
No limit
200%
Colorado
All
Notice on application
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
Connecticut
All
“Help for People in
Need” brochure
No limit
185%
Delaware
All
Application refers to a
pregnancy prevention
hotline
No limit
200%
District of
Columbia
All
Brochure
No limit
200%
Florida
All
Notice
No limit
200%
Georgia
All
TANF Community
Outreach Services
brochure
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
Hawaii
All
Brochure
No limit
200%
Idaho
All
Flyer about referral
service
$5,000
130%
Illinois
All
Guide to services
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
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Households
Eligible
State
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Type of TANF
Benefit or Servicea
Asset Rules
Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
poverty
guidelines)b
Iowa
All
Notice of eligibility
No limit
160%
Kentucky
All
Resource guide
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
Louisiana
All
Information handout
No limit
130%
Maine
All
Resource guide
No limit
185%
Maryland
All
Referral to services on
application
No limit
200%
Massachusetts
All
Brochure
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
Michigan
All
Notice on application
$5,000. First vehicle
is excluded; other
vehicles with fair
market value over
$15,000 are
counted.
200%
Minnesota
All
Domestic violence
brochure
No limit
165%
Mississippi
All
Language on notice
No limit
130%
Montana
All
Brochure
No limit
200%
Nebraska
All
Pamphlet
$25,000 for liquid
assets
130%
Nevada
All
Pregnancy prevention
information on
application
No limit
200%
New Hampshire
Households with at
least one dependent
child
Brochure
No limit
185%
New Jersey
All
Brochure
No limit
185%
New Mexico
All
Brochure
No limit
165%
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200%. Households
without children
(aged 18 or
younger) or an
elderly or disabled
member have a
gross income limit
of 130%.
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The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
poverty
guidelines)b.
Households
Eligible
Type of TANF
Benefit or Servicea
New York
Households with
dependent care
expenses
Brochure mailed yearly
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
200%
North Carolina
All
Not specified
No limit
200%
North Dakota
All
Statement on
application/recertification
forms and pamphlet
No limit
200%
Ohio
All
Ohio Benefit Bank
information on approval
notice
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
Oklahoma
All
Certification notice has
website and 800 number
about marriage classes
No limit
130%
Oregon
All
Pamphlet
No limit
185%
Pennsylvania
All
Pamphlet
$5,500. Households
with an elderly or
disabled member
with incomes over
200% of poverty
face a $9,500 asset
limit.
160%
Rhode Island
All
Publication
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
185%
South Carolina
All
Pamphlet
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
130%
State
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Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
poverty
guidelines)b
Congressional Research Service
Asset Rules
10
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
Households
Eligible
State
Type of TANF
Benefit or Servicea
Asset Rules
Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
poverty
guidelines)b
Texas
All
Information about
various services provided
on the application
$5,000 (excludes
one vehicle and
includes excess
vehicle value).
165%
Vermont
All
Bookmark with
telephone number and
website for services
No limit
185%
Washington
All
Information and referral
services provided on
approval letter.
No limit
200%
West Virginia
All
Information and referral
services program
brochure
No limit
130%
Wisconsin
All
Job Net services
language on approval and
change notices
No limit
200%
Guam
All
Brochure
No limit
165%
Virgin Islands
All
Brochure
No limit.
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,250 asset limit.
175%
Source: Prepared by the Congressional Research Service based on data from U.S. Department of Agriculture,
Food and Nutrition Service (FNS).
c11173008
a.
Type of TANF benefit or service is information collected by the USDA, and this column utilizes USDA’s
terms. References to a notice or notice on application generally refers to an agency communication that an
applicant may be eligible for TANF or related benefit.
b.
Households with an elderly or disabled member do not have a gross income limit in SNAP.
Congressional Research Service
11
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
Incomes and Assets of SNAP Households
Income
Because broad-based categorical eligibility conveys SNAP to households with gross incomes as
high as 200% of poverty, there is concern that it could be unduly expanding the program.
However, broad-based categorical eligibility has not resulted in large numbers of households
receiving SNAP who have gross incomes, as measured using SNAP income counting rules,
exceeding 130% of poverty.15 Table 2 shows that in FY2011FY2012, a monthly average of 3.54.0% of all
households without an elderly or disabled member had incomes above 130% of poverty. (As
mentioned above, households with an elderly or disabled member are not subject to the 130% of
poverty gross income limit under regular federal eligibility rules.)
Table 2. Gross Incomes of SNAP Households Compared with Poverty: FY2011FY2012
By Household Type
Households without an
Elderly or Disabled
Member
Households with an
Elderly or Disabled
Member
All SNAP
Households
Below poverty
85.8%
77.74%
76.0%
82.90%
100% to 130% of
poverty
10.7
15.4
12.4
3.5
6.9
4.86
16.7
12.8
4.0
7.3
5.2
100.0
100.0
100.0
131% of poverty and
higher
Total
Source: Congressional Research Service (CRS) tabulations of the FY2011FY2012 SNAP Quality Control Data File.
Notes: Detail may not add to totals because of rounding. The information on the Quality Control Data File
sometimes fails to categorize a household with a disabled member. Therefore, some households classified in this
table as “without an elderly or disabled member” may in fact contain a disabled person.
Table 3 shows both the number and percent of households without an elderly or disabled member
that have incomes above 130% of poverty by state.16
Note that tabulations in Table 2 and Table 3
reflect states’ SNAP households under states’ broad-based categorical eligibility practices in place
15
This is based on data from the SNAP Quality Control Data files. These are administrative data, and the files include
monthly income data collected in determining SNAP eligibility and benefits. The data and the resulting analysis differ
in a number of ways from that of Census Bureau household survey income data of SNAP households. SNAP monthly
income data represents gross income as defined in SNAP law; this might exclude some income reported by households
in the Census survey. Moreover, SNAP eligibility and benefits are based on monthly income. The most widely reported
income data from Census household surveys examines annual income. Households may use the SNAP program in
particular months of economic need, which annual income data would not capture. There are also differences between
the SNAP and Census Bureau concepts of household and poverty thresholds.
16
Some states that have gross income limits of 130% of poverty report a small number of households without an
elderly or disabled member as having incomes above 130% of poverty. This is likely because of limitation on the
Quality Control Data File in identifying disabled individuals. The information on the Quality Control Data File
sometimes fails to categorize a household with a disabled member. Therefore, some households classified in this table
as “without an elderly or disabled member” may in fact contain a disabled person.
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Congressional Research Service
12
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
Table 3. Estimates of SNAP Households without An Elderly or Disabled Member
with Gross Incomes Over 130% of Poverty by State: FY2011
State
Alabama
Number of
Households
without an Elderly
or Disabled
Member and Gross
Income Over 130%
of Poverty
Percent of All
Households
without An
Elderly or
Disabled
Member and
with Gross
Incomes Over
130% of Poverty
0
0.0%
59
0.2
18,054
5.4
Arkansas
0
0.0
California
2,949
0.2
Colorado
228
0.2
Connecticut
8,537
7.5
Delaware
3,945
9.4
District of Columbia
1,853
3.7
38,872
3.7
0
0.0
1,077
2.3
Idaho
0
0.0
Illinois
1,353
0.2
0
0.0
3,985
3.4
99
0.1
Kentucky
551
0.3
Louisiana
976
0.4
8,574
12.2
Maryland
20,525
9.9
Massachusetts
19,468
9.2
Michigan
54,279
9.2
Minnesota
6,150
4.2
Mississippi
0
0.0
Alaska
Arizona
Florida
Georgia
Hawaii
Indiana
Iowa
Kansas
Maine
Congressional Research Service
13
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
State.
during FY2012. Some states’ current practices are different from their practices in FY2012, so
tabulations here do not necessarily reflect current state practices. For instance, California had a
gross income limit of 130% of poverty in place in FY2012, and in July 2014 raised the gross
income limit to 200% of poverty.
Table 3. Estimates of SNAP Households without An Elderly or Disabled Member
with Gross Incomes Over 130% of Poverty by State: FY2012
State
Alabama
Alaska
0
0.0%
225
0.8
22,429
6.4
156
0.1
Californiaa
6,781
0.4
Colorado
0
0.0
11,209
9.0
Delaware
4,869
10.1
District of Columbia
1,920
3.8
47,563
4.1
0
0.0
Hawaii
3,245
6.1
Idahoa
0
0.0
Illinois
2,442
0.4
341
0.1
9,341
7.4
126
0.1
Kentuckya
0
0.0
Louisianaa
674
0.3
7,621
11.3
15,438
6.9
Arizona
Arkansas
Connecticut
Florida
Georgia
Indiana
Iowa
Kansas
Maine
Maryland
c11173008
Number of
Households
without an Elderly
or Disabled
Member and Gross
Income Over 130%
of Poverty
Percent of All
Households
without An
Elderly or
Disabled
Member and
with Gross
Incomes Over
130% of Poverty
Missouri
1,609
0.6
Montana
1,756
4.7
0
0.0
Nevada
5,801
5.8
New Hampshire
3,486
12.7
New Jersey
12,900
6.0
New Mexico
4,324
3.5
New York
6,886
1.0
North Carolina
39,111
7.8
North Dakota
2,209
13.4
857
0.2
0
0.0
Oregon
29,954
10.3
Pennsylvania
26,068
6.4
Rhode Island
4,104
8.9
0
0.0
South Dakota
384
1.5
Tennessee
624
0.2
66,135
6.3
951
1.2
4,686
20.2
309
0.1
31,513
9.1
303
0.4
Wisconsin
32,667
14.0
Wyoming
0
0.0
Nebraska
Ohio
Oklahoma
South Carolina
Texas
Utah
Vermont
Virginia
Washington
West VirginiaCongressional Research Service
13
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
State
Massachusetts
21,400
9.8
Michigan
47,167
8.8
Minnesota
14,985
9.4
Mississippi
279
0.2
Missouri
438
0.2
Montana
2,508
7.0
172
0.4
Nevada
8,308
7.5
New Hampshire
2,784
9.8
New Jersey
13,615
6.1
New Mexico
4,943
3.8
New Yorka
18,597
2.4
North Carolina
46,132
9.1
North Dakota
1,998
12.3
Ohio
4,570
0.9
0
0.0
Oregon
43,209
14.1
Pennsylvaniaa
38,289
8.8
Rhode Island
4,977
10.6
0
0.0
479
1.7
0
0
59,001
5.6
401
0.5
4,680
18.2
445
0.2
Nebraskaa
Oklahoma
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
c11173008
Number of
Households
without an Elderly
or Disabled
Member and Gross
Income Over 130%
of Poverty
Percent of All
Households
without An
Elderly or
Disabled
Member and
with Gross
Incomes Over
130% of Poverty
Congressional Research Service
14
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
State
Guam
Virgin Islands
Total.
State
Washington
Number of
Households
without an Elderly
or Disabled
Member and Gross
Income Over 130%
of Poverty
Percent of All
Households
without An
Elderly or
Disabled
Member and
with Gross
Incomes Over
130% of Poverty
570
5.4
0
0.0
468,742
3.5
47,659
12.5
513
0.6
Wisconsin
32,926
13.0
Wyoming
0
0.0
700
6.0
0
0.0
555,554
3.5
West Virginia
Guama
Virgin Islandsa
Total
Source: Congressional Research Service (CRS) tabulation of the FY2011 SNAP Quality Control data file.
Note: Some states that have gross income limits of 130% of poverty report a small number of households
without an elderly or disabled member as having incomes above 130% of poverty. This is likely because of
limitation on the Quality Control Data File in identifying disabled individuals. The information on the Quality
Control Data File sometimes fails to categorize a household with a disabled member. Therefore, some
households classified in this table as “without an elderly or disabled member” may in fact contain a disabled
person.
a.
This state changed its Broad-Based Categorical Eligibility (BBCE) practices since FY2012, so tabulations here
should not be assumed to reflect the state’s current (as of December 2014) practices (displayed in Table
1).
Assets
As discussed above, broad-based categorical eligibility also eliminates the SNAP asset test in
many states. Since states that do not administer an asset test generally do not collect data on the
assets of SNAP households, it is not possible to determine the extent to which broad-based
categorical eligibility has resulted in households with assets above the usual SNAP limit
receiving benefits.
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Congressional Research Service
15
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
Appendix.
Table A-1. Federal SNAP Monthly Income Eligibility Limits for FY2014FY2015
Household Size
48 States
Alaska
Hawaii
Gross Monthly Income Limits (130% of the federal poverty guidelines)
1
$1,245265
$1,555580
$1,434454
2
1,681
2,100
1,934
3
2,116
2,645
2,435
4
2,552
3,190
2,935
5
2,987
3,735
3,436
6
3,423
4,280
3,936
7
3,858
4,825
4,437
8
4,294
5,369
4,937
436
545
501705
2,130
1,960
3
2,144
2,681
2,466
4
2,584
3,231
2,972
5
3,024
3,781
3,478
6
3,464
4,332
3,984
7
3,904
4,882
4,490
8
4,344
5,432
4,996
440
551
506
Each Additional Member
Net Monthly Income Limits (100% of the federal poverty guidelines)
1
$958973
$1,196215
$1,103119
2
1,293
1,615
1,488
3
1,628
2,035
1,873
4
1,963
2,454
2,258
5
2,298
2,873
2,643
6
2,633
3,292
3,028
7
2,968
3,711
3,413
8
3,303
4,130
3,798
335
420
385311
1,639
1,508
3
1,650
2,062
1,897
4
1,988
2,485
2,286
5
2,326
2,909
2,675
6
2,665
3,332
3,065
7
3,003
3,755
3,454
8
3,341
4,179
3,843
339
424
390
Each Additional Member
Source: U.S. Department of Agriculture, Food and Nutrition Service (FNS).
Table A-2. Maximum Monthly Earnings a Family of Three May Have and Still Meet
Initial Eligibility for TANF Cash Assistance: July 2012
Family Composed of One Parent and Two Children
State
Maximum Earnings for
Initial Eligibility
Percent of FY2012
Federal Poverty Level
Income
Alabama
$269
16.9%
Alaska
1,606
80.7
585
36.8
Arizona
c11173008
Maximum Earnings for
Initial Eligibility
Congressional Research Service
16
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
State
State
Maximum Earnings for
Initial Eligibility
Percent of FY2012
Federal Poverty Level
Income
Arkansas
279
17.5
California
1,258
79.1
Colorado
421
26.5
Connecticut
880
55.3
Delaware
428
26.9
D.C.
588
37.0
Florida
393
24.7
Georgia
514
32.3
1,740
95.1
Idaho
648
40.7
Illinois
796
50.0
Indiana
378
23.8
1,061
66.7
Kansas
519
32.6
Kentucky
908
57.1
Louisiana
359
22.6
1,023
64.3
Maryland
718
45.1
Massachusetts
708
44.5
Michigan
803
50.5
Minnesota
1,224
76.9
Mississippi
458
28.8
Missouri
557
35.0
Montana
753
47.4
Nebraska
923
58.0
1,448
91.0
New Hampshire
844
53.0
New Jersey
636
40.0
1,017
63.9
New York
860
54.1
North Carolina
681
42.8
1,169
73.5
Ohio
796
50.0
Oklahoma
824
51.8
Oregon
616
38.7
Hawaii
Iowa
Maine
Nevada
New Mexico
North Dakota
c11173008
Maximum Earnings for
Initial Eligibility
Congressional Research Service
17
The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility
.
Maximum Earnings for
Initial Eligibility
State
Percent of FY2012
Federal Poverty Level
Income
Pennsylvania
677
42.6
Rhode Island
1,277
80.3
South Carolina
1,428
89.8
782
49.2
1,315
82.7
Texas
401
25.2
Utah
668
42.0
1,053
66.2
Virginia
542
34.1
Washington
954
60.0
West Virginia
565
35.5
Wisconsin
NA
NA
Wyoming
801
50.4
South Dakota
Tennessee
Vermont
Source: Congressional Research Service based on data from the Urban Institute’s Welfare Rules Database
Notes: NA Families with earnings do not qualify for cash assistance in Wisconsin’s TANF program.
Author Contact Information
Gene Falk
Specialist in Social Policy
gfalk@crs.loc.gov, 7-7344
Randy Alison Aussenberg
AnalystSpecialist in Nutrition Assistance Policy
raussenberg@crs.loc.gov, 7-8641
Area of Expertise by Author
c11173008
Area of Expertise
Name
Phone
E-mail
TANF
Gene Falk
7-7344
gfalk@crs.loc.gov
SNAP
Randy Alison Aussenberg
7-8641
raussenberg@crs.loc.gov
Congressional Research Service
18