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The Supplemental Nutrition Assistance
Program: Categorical Eligibility
Gene Falk
Specialist in Social Policy
Randy Alison Aussenberg
Analyst in Social Policy
October 21, 2011
Congressional Research Service
7-5700
www.crs.gov
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CRS Report for Congress
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epared for Members and Committees of Congress
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
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 April
2011, there were 45 million persons in 21 million households benefitting from SNAP.
Federal SNAP law provides two basic pathways for financial eligibility to the program: (1)
meeting 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 through the 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 broad-
purpose 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.
In total, 43 jurisdictions have implemented what the U.S. Department of 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 or
referral to an “800” number telephone hotline. There are varying income eligibility 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 three 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.
During the decade of the 2000s, there were a number of proposals to restrict categorical eligibility
based on receipt of TANF benefits. These proposals would have limited TANF-based categorical
assistance to households receiving TANF-funded cash assistance. The proposal was made by the
Bush Administration in its farm bill proposals and several budget submissions. It passed the
House in a budget reconciliation bill in 2005 (H.R. 4241, 109th Congress) but was not part of that
year’s final reconciliation package, the Deficit Reduction Act of 2005 (P.L. 109-171).
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
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
State Practices in Providing “Broad-Based” Categorical Eligibility ......................................... 6
Is it Possible to Determine How Many Families Are SNAP Eligible Solely Because of
Categorical Eligibility?............................................................................................................... 11
Proposals to Restrict Categorical Eligibility.................................................................................. 12
Figures
Figure 1. Scope of SNAP Categorical Eligibility by State: 2010 .................................................... 6
Tables
Table 1. SNAP Broad-Based Categorical Eligibility by State ......................................................... 7
Table A-1. Federal SNAP Monthly Income Eligibility Limits for FY2011................................... 13
Table A-2. Maximum Monthly Earnings a TANF Cash Assistance Applicant Can Receive
and Still Meet Initial Eligibility for Benefits: July 2009 ............................................................ 14
Appendixes
Appendix........................................................................................................................................ 13
Contacts
Author Contact Information........................................................................................................... 15
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
Introduction
The Supplemental Nutrition Assistance Program (SNAP) provided food assistance to 44.2 million
people in 21 million households in April 2011. The Congressional Budget Office (CBO) projects
SNAP outlays of $78 billion in FY2011. SNAP participation and costs have increased markedly
since FY2007, mostly as a result of automatic and legislated responses to the recession. CBO also
projects that under current law, SNAP benefits will peak at $80 billion in FY2012 before falling
beginning in FY2013, as they project the economy to improve.
While much of the recent increase is attributable to the poor economy, recently states have been
increasingly adopting 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 past
proposals to restrict TANF-based categorical eligibility.
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 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 disabled1 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 FY2011, a household’s liquid assets must also be below
$2,000, and below $3,000 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
1 “Elderly or disabled” is defined in Section 3(j) of the Food and Nutrition Act of 2008.
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
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 separate 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), and state-financed GA programs
categorically, or automatically, eligible for SNAP.2 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.3 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 benefits 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 $16 in the 48 contiguous
states and the District of Columbia in FY2011.
Early History
Special rules providing for expedited eligibility of cash assistance recipients date back to
amendments to the Food Stamp program enacted in 1971.4 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 1990.5 Categorical eligibility was seen as advancing the goals of simplifying
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.6 The Food Security Act of 1985 conveyed categorical eligibility to all
households receiving cash aid from Aid to Families with Dependent Children (AFDC), SSI, and
state-run GA programs. These programs had their own income and resource tests (often more
2 Section 5(a) of the Food and Nutrition Act of 2008.
3 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).
4 Section 6 of P.L. 91-671.
5 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.
6 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.
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
stringent than food stamp tests), so subjecting a household to a separate set of income and
resource tests for food stamps was seen as redundant and inefficient.
The 1996 Welfare Law and TANF
The current form of categorical eligibility results 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:7
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”8 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.9 However, in FY2009
traditional cash welfare accounted for only 28% 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
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 two-
parent families are not restricted to families with children. These benefits and services are
7 Section 401(a) of the Social Security Act.
8 Section 404(a)(1) of the Social Security Act.
9 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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The Supplemental Nutrition Assistance Program: Categorical Eligibility
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.10 The regulations require that states make categorically eligible for SNAP
• households in which all members receive or are authorized to receive11 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.
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
• 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 whether the whole household benefits from such noncash aid.
The regulations imposed one restriction on states in conveying categorical eligibility: if the
TANF- or MOE-funded benefit or service was aimed at achieving 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.
10 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.
11 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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The Supplemental Nutrition Assistance Program: Categorical Eligibility
Traditional, Narrow, and Broad-Based Categorical
Eligibility
Giving states the option to make households in which at least one member receives TANF
noncash aid categorically eligible for SNAP provides them with considerable flexibility. Many
TANF-funded human services (e.g., child care, counseling, brochures) may actually be provided
only to one or some members of a household. This has led to varied practices by states on what
types of TANF noncash assistance are used to convey categorical eligibility beyond that provided
through receipt of cash assistance.
Scope and Reach of Categorical Eligibility
The USDA has developed a typology of state practices regarding categorical eligibility,
categorizing states into three groups:
• 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 2009). 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 five 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 to make most, if not all, households with low incomes in a
state categorically eligible for SNAP. Based on the currently available
information, 40 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.
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Figure 1. Scope of SNAP Categorical Eligibility by State: 2010
Source: Congressional Research Service (CRS), based on data from the U.S. Department of Agriculture.
State Practices in Providing “Broad-Based” Categorical Eligibility
Broad-based categorical eligibility is a policy that makes most households with incomes below a
certain amount 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). The brochure or telephone number must be funded with TANF
or MOE dollars and thus must be directed at a TANF purpose.
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 October 4, 2011 (the latest data available), 43 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.
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Table 1 shows the use of SNAP broad-based categorical eligibility by state as of October 4, 2011.
Of the 43 jurisdictions using broad-based categorical eligibility,
• 42 make all family types eligible (New Hampshire restricted broad-based
categorical eligibility to families with children);
• 40 have no asset test (Texas, Michigan, and Nebraska apply an asset test for all
households), though, in 12 jurisdictions, households with an elderly and disabled
member with incomes in excess of 200% of the federal poverty guidelines had to
meet the regular SNAP asset tests of $3,000 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, 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 the relatively nominal benefit or service. Receipt of this
TANF 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.
Table 1. SNAP Broad-Based Categorical Eligibility by State
Information as of October 4, 2011
Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
Households
Type of TANF
poverty
State
Eligible
Benefit or Servicea
Asset Rules
guidelines)b
Alabama
All
Brochure
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Arizona
All
Referral on application
No limit
185%
California All
Pamphlet
No
limit
130%
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Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
Households
Type of TANF
poverty
State
Eligible
Benefit or Servicea Asset
Rules guidelines)b
Colorado
All
Notice on application
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Connecticut
All
“Help for People in
No limit
185%
Need” brochure
Delaware
All
Application refers to a
No limit
200%
pregnancy prevention
hotline
District of
All Brochure
No
limit 200%
Columbia
Florida
All
Notice
No limit
200%
Georgia All
TANF
Community
No limit.
130%
Outreach Services
Households with an
brochure
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Guam All
Brochure
No
limit
165%
Hawaii All
Brochure
No
limit
200%
Idaho
All
Flyer about referral
No limit
130%
service
Illinois
All
Guide to services
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Iowa
All
Notice of eligibility
No limit
160%
Kentucky
All
Resource guide
No limit
130%
Louisiana
Al
Information handout
No limit
130%
Maine
All
Resource guide
No limit
185%
Maryland
All
Referral to services on
No limit
200%
application
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Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
Households
Type of TANF
poverty
State
Eligible
Benefit or Servicea Asset
Rules guidelines)b
Massachusetts All
Brochure
No
limit.
200%. Households
Households with an
without children
elderly or disabled
(aged 18 or
member with
younger) or an
incomes over 200%
elderly or disabled
of poverty face a
member have a
$3,000 asset limit.
gross income limit
of 130%.
Michigan
All
Notice on application
$5,00012 200%
Minnesota All
Domestic
violence No limit
165%
brochure
Mississippi
Al
Language on notice
No limit
130%
Montana All
Brochure
No
limit
200%
Nebraska
Al
Pamphlet
$25,000 for liquid
200%
assets
Nevada Al
Pregnancy
prevention
No limit
200%
information on
application
New Hampshire
Households with at
Brochure No
limit
185%
least one dependent
child
New Mexico
All
Brochure
No limit
165%
New Jersey
All
Brochure
No limit
185%
New York
All
Brochure mailed yearly
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
North Carolina
All
Not specified
No limit
200%
North Dakota
All
Statement on
No limit
200%
application/recertification
forms and pamphlet
12 Michigan added an asset test of $5,000, effective October 1, 2011. Vehicle value over $15,000 will be counted
toward the asset limit.
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Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
Households
Type of TANF
poverty
State
Eligible
Benefit or Servicea Asset
Rules guidelines)b
Ohio
All
Ohio Benefit Bank
No limit.
130%
information on approval
Households with an
notice
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Oklahoma
All
Certification notice has
No limit
130%
website and 800 number
about marriage classes
Oregon All
Pamphlet
No
limit
185%
Pennsylvania All
Pamphlet
No
limit.
160%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Rhode Island
All
Publication
No limit.
185%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
South Carolina
All
Pamphlet
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Texas All
Information
about
Asset limit of
165%
various services provided $5,000 (excludes
on the application
one vehicle and
includes excess
vehicle value).
Vermont All
Bookmark
with No limit
185%
telephone number and
website for services
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Gross Income
Limit for
Households
Without an
Elderly or
Disabled Member
(% of federal
Households
Type of TANF
poverty
State
Eligible
Benefit or Servicea Asset
Rules guidelines)b
Virgin Islands
All
Brochure
No limit.
130%
Households with an
elderly or disabled
member with
incomes over 200%
of poverty face a
$3,000 asset limit.
Washington Households
eligible
Information and referral
No limit
200%
for TANF services.
services provided on
approval letter.
West Virginia
All
Information and referral
No limit
130%
services program
brochure
Wisconsin
Al
Job net services language
No limit
200%
on approval and change
notices
Source: U.S. Department of Agriculture, Food and Nutrition Service (FNS).
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 general y refers to an agency communication on
otherwise 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.
Is it Possible to Determine How Many Families Are
SNAP Eligible Solely Because of Categorical
Eligibility?
Given the available data collected through SNAP, it is not possible to determine the number of
families who are eligible for benefits solely because of categorical eligibility. The major reason
for this is that asset information is not collected for families who are categorically eligible. Thus,
it cannot be said how many categorically eligible households had countable assets above the
$2,000 or $3,000 threshold.
SNAP data can be used to determine how many families have incomes above either the 130% of
the poverty threshold for gross income or 100% of the poverty threshold for net income limit. In
FY2009 (the latest year for which SNAP data are available), only 2.3% of all SNAP households,
totaling 320,000 households, had incomes above these limits.13
13 Congressional Research Service (CRS) tabulations of the FY2009 SNAP Quality Control Data File.
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
These 320,000 households disproportionately represent households with children who have
earnings and households with elderly and disabled members receiving the SNAP minimum
benefit. Some general characteristics of these 320,000 households are
• 45% were households with children that were also households with earnings
(compared with 20% of all SNAP households having children and earnings);
• 30% were households with an elderly or disabled member receiving the SNAP
minimum benefit (compared with 3% of all SNAP households having elderly and
disabled members receiving the minimum benefit); and
• 25% were other types of households.
Proposals to Restrict Categorical Eligibility
During the decade of the 2000s, there were a number of proposals to restrict categorical eligibility
to families based on TANF benefits and services. The George W. Bush Administration proposed
limiting TANF-based categorical eligibility to receipt of cash assistance as part of its farm bill
proposals in 2002 and 2007, as well as its budget proposals for FY2006 through FY2008. Such a
proposal passed the House in a budget reconciliation bill in 2005 (H.R. 4241, 109th Congress).
This provision was not part of the final reconciliation package, the Deficit Reduction Act of 2005
(P.L. 109-171).
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Appendix.
Table A-1. Federal SNAP Monthly Income Eligibility Limits for FY2011
Household Size
48 States
Alaska
Hawaii
Gross Monthly Income Limits (130% of the federal poverty guidelines)
1
$1,174
$1,466
$1,350
2
1,579
1,973
1,816
3
1,984
2,480
2,282
4
2,389
2,987
2,748
5
2,794
3,494
3,214
6
3,200
4,001
3,679
7
3,605
4,508
4,145
8
4,010
5,015
4,611
Each Additional Member
406
507
466
Net Monthly Income Limits (100% of the federal poverty guidelines)
1
903
1,128
$1,039
2
1,215
1,518
1,397
3
1,526
1,908
1,755
4
1,838
2,298
2,114
5
2,150
2,688
2,472
6
2,461
3,078
2,830
7
2,773
3,468
3,189
8
3,085
3,858
3,547
Each Additional Member
312
390
359
Source: U.S. Department of Agriculture, Food and Nutrition Service (FNS).
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
Table A-2. Maximum Monthly Earnings a TANF Cash Assistance Applicant Can
Receive and Still Meet Initial Eligibility for Benefits: July 2009
Maximum Monthly Earnings an
Applicant can Receive and Still
As a Percent of the Federal
State
Be Eligible for Assistance
Poverty Guidelines for 2009
Alabama $269
17.6%
Alaska 1,554
81.5
Arizona 585
38.3
Arkansas 279
18.3
California 1,187
77.8
Colorado 511
33.5
Connecticut 858
56.2
Delaware 428
28.1
D.C. 588
38.5
Florida 393
25.8
Georgia 514
33.7
Hawai 1,802
102.7
Idaho 648
42.5
Illinois
522 34.2
Indiana 378
24.8
Iowa 1,061
69.6
Kansas 519
34.0
Kentucky 908
59.5
Louisiana 360
23.6
Maine 1,023
67.0
Maryland 718
47.0
Massachusetts 708
46.4
Michigan 815
53.4
Minnesota 1,108
72.6
Mississippi 458
30.0
Missouri 557
36.5
Montana 811
53.1
Nebraska 886
58.1
Nevada 1,430
93.7
New Hampshire
844
55.3
New Jersey
636
41.7
New Mexico
1,056
69.2
New York
811
53.2
North Carolina
681
44.6
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The Supplemental Nutrition Assistance Program: Categorical Eligibility
Maximum Monthly Earnings an
Applicant can Receive and Still
As a Percent of the Federal
State
Be Eligible for Assistance
Poverty Guidelines for 2009
North Dakota
1,252
82.1
Ohio 980
64.2
Oklahoma 824
54.0
Oregon 616
40.4
Pennsylvania 493
32.3
Rhode Island
1,277
83.7
South Carolina
733
48.0
South Dakota
762
49.9
Tennessee 1,315
86.2
Texas 401
26.3
Utah 668
43.8
Vermont 1,052
68.9
Virginia 727
47.6
Washington 1,122
73.5
West Virginia
565
37.0
Wisconsina NA
NA
Wyoming 745
48.8
Source: Congressional Research Service (CRS), based on data from the Urban Institute’s Welfare Rules
Database, except Virginia’s eligibility limit is from the Virginia Department of Social Services.
a. In Wisconsin, families with earnings are ineligible for cash assistance.
Author Contact Information
Gene Falk
Randy Alison Aussenberg
Specialist in Social Policy
Analyst in Social Policy
gfalk@crs.loc.gov, 7-7344
raussenberg@crs.loc.gov, 7-8641
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