The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility

October 21, 2011 – February 25, 2022 R42054

The Supplemental Nutrition Assistance
February 25, 2022
Program (SNAP): Categorical Eligibility
Randy Alison Aussenberg
The Supplemental Nutrition Assistance Program (SNAP) provides benefits to low-
Specialist in Nutrition
income, eligible households on an electronic benefit transfer (EBT) card; benefits can
Assistance Policy
then be exchanged for foods at authorized retailers. SNAP reaches a large share of low-

income households, particularly so during the COVID-19 pandemic. In FY2021, a
Gene Falk
monthly average of 41.5 million persons in 21.6 million households participated in
Specialist in Social Policy
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 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.
As of January 2022, 44 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 a telephone hotline. There are varying
income eligibility thresholds within states that convey “broad-based” categorical eligibility, though no state may
have 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.
Neither the Agriculture Act of 2014 (“2014 Farm Bill,” P.L. 113-79) nor the Agriculture Improvement Act of 2018
(“2018 Farm Bill,” P.L. 115-334) made changes to SNAP categorical eligibility rules. House-passed versions of
both of these laws would have amended broad-based categorical eligibility.
On July 24, 2019, the Trump Administration published a proposed rule to amend the categorical eligibility
regulations, proposing to limit the TANF-funded benefits that may convey categorical eligibility. This rule was
never finalized, and the Biden Administration withdrew it June 10, 2021.

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Introduction
The Supplemental Nutrition Assistance Program (SNAP) provided food assistance to a monthly
average of 41.5 million persons in 21.6 million households in FY2021. Total benefit costs were
$107.6 billion in FY2021.1
This report discusses categorical eligibility and some of the issues raised by it. Categorical
eligibility is 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. Most of the controversy about SNAP categorical eligibility
focuses on “broad-based” categorical eligibility, stemming from the provision of SNAP law that
conveys eligibility based on a “TANF benefit,” as it was implemented by regulations promulgated
in 2000 by the Department of Agriculture.2 Under current law and regulation, it is a state option
to implement broad-based categorical eligibility for SNAP. As a result, potential changes to
curtail (or expand) categorical eligibility may impact some states more than others. This report
includes state-by-state information to assist in gauging these disparate impacts.
SNAP is typically reauthorized in an omnibus farm bill law, and neither of the last two farm bills
ultimately included changes to categorical eligibility rules. The Agriculture Act of 2014 (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 bill’s conference
agreement. The most recent farm bill, Agriculture Improvement Act of 2018 (“2018 Farm Bill,”
P.L. 115-334) made no changes to SNAP categorical eligibility rules. The House-passed version
of the bill would have made changes to limit but not eliminate broad-based categorical eligibility.
These changes were not included in the conference agreement. While the statute on categorical
eligibility has not changed in recent years, the Trump Administration proposed to limit categorical
eligibility via regulation, publishing on July 24, 2019, a proposed rule to do so.3 The proposed
rule was never finalized and, on June 10, 2021, the Biden Administration withdrew it.4 These
proposals are discussed further in the “Recent Proposals to Change Categorical Eligibility”
section.
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

1 USDA Food and Nutrition Service (FNS) data available at https://www.fns.usda.gov/pd/supplemental-nutrition-
assistance-program-snap (accessed February 15, 2022). The COVID-19 pandemic and federal SNAP policy responses
to the pandemic influenced SNAP participation and SNAP costs in FY2021. See CRS Report R46681, USDA Nutrition
Assistance Programs: Response to the COVID-19 Pandemic, by Randy Alison Aussenberg and Kara Clifford Billings.
2 The provision of SNAP law is found in Section 5(a) of the Food and Nutrition Act (codified at 7 U.S.C. §2014(a)),
and the regulations are found at 7 C.F.R. §273.2(j)
3 USDA, Food and Nutrition Service, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance
Program (SNAP),” 84 Federal Register 35570, July 24, 2019.
4 USDA, Food and Nutrition Service, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance
Program (SNAP); Withdrawal” 86 Federal Register 30795, June 10, 2021.
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The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility

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 disabled5 member must have monthly gross income (income before deductions)
below 130% of the federal poverty guidelines. In FY2022, for a household of three people, in the
48 contiguous states, DC, Guam, and the Virgin Islands, this monthly gross income limit is
$2,379.6
Additionally, the regular eligibility rules provide that a household must have liquid assets below a
specified level. Under federal rules in FY2022, a household’s liquid assets must also be below
$2,500, and below $3,750 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.7 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.8 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

5 “Elderly or disabled” is defined in Section 3(j) of the Food and Nutrition Act of 2008.
6 Current and past years’ income guidelines are available on the USDA-FNS website, at https://www.fns.usda.gov/
snap/allotment/COLA.
7 Section 5(a) of the Food and Nutrition Act of 2008 (codified at 7 U.S.C. §2014(a)).
8 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).
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persons are eligible for at least the minimum monthly benefit, set at $20 in the 48 contiguous
states and the District of Columbia for FY2022.
Early History
Special rules providing for expedited eligibility of cash assistance recipients date back to
amendments to the Food Stamp program enacted in 1971.9 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 1990.10 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.11 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:12
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.

9 Section 6 of P.L. 91-671.
10 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.
11 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.
12 Section 401(a) of the Social Security Act.
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States may expend TANF funds and associated state funds (called Maintenance of Effort or MOE
funds) in any manner “reasonably calculated”13 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.14 However, in FY2016
traditional cash welfare accounted for only 24% 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. Federal rules also do not require that
they be need-tested. Thus, these benefits and services are potentially available to a state’s entire
population.
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.15 The regulations require that states make categorically eligible for SNAP
 households in which all members receive or are authorized to receive16 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

13 Section 404(a)(1) of the Social Security Act.
14 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.
15 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.
16 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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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
 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 benefits from other specified means-tested programs.17 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 January 2022.
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
 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. 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.
 “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.
 “Broad-based” categorical eligibility. These states have expanded categorical
eligibility in ways that make most, if not all, households with low incomes in a

17 See 7 U.S.C. §2014(a).
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The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility

state categorically eligible for SNAP. States could make all low-income
households in a state—including those without children—eligible for a TANF-
funded 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 low-
income 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, 44 jurisdictions (41 states, the District of Columbia,
Guam, and the Virgin Islands) have broad-based categorical eligibility policies.
USDA currently does not have reliable information on the number of states that have opted to use
“narrow” categorical eligibility. However, they do track both the number of states and rules used
for states that have opted to use broad-based categorical eligibility. Figure 1 displays a map
showing the states that use broad-based categorical eligibility (shaded in blue).
Figure 1. States Opting for SNAP Broad-Based Categorical
Eligibility as of January 2022

Source: Congressional Research Service (CRS), based on data from the U.S. Department of Agriculture, as of
January 2022.
Note: Some states implement “narrow” categorical eligibility. Without a reliable data source for “narrow,” this
map only reflects those opting for broad-based categorical eligibility.
“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
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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
number must be funded with TANF or MOE dollars and thus must be directed at a TANF
purpose.18 The Department of Agriculture reports that, as of January 2022, 44 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 January 2022.
Of the 44 jurisdictions using broad-based categorical eligibility,
 42 make all family types eligible (New Hampshire and New York limit broad-
based categorical eligibility to certain household types);
 39 currently have no asset test. Note, though, currently in 16 of these
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 $3,500 for households of that type;
 5 states (Idaho, Indiana, Michigan, Nebraska, and Texas) apply an asset test for
all households); and
 36 have a gross income limit above 130% of the federal poverty guidelines.
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.19)
As an illustration, 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.

18 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.
19 Additionally, some states impose a net income test for at least some categories of applicants and recipients under
their broad-based categorical eligibility policies. See Elizabeth Laird and Carole Trippe, Programs Conferring
Categorical Eligibility for SNAP: State Policies and the Number and Characteristics of Households Affected,
Mathematica Policy Research, February 2014, p. 14.
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Table 1. SNAP Broad-Based Categorical Eligibility by State
Information as of January 2022, excludes states without broad-based categorical eligibility
Gross Income
Limit for
Households
Without an Elderly
or Disabled
Type of TANF
Member (% of
Households
Benefit or
federal poverty
State
Eligible
Servicea
Asset Rules
guidelines)b
Alabama
All
Brochure
No limit. Households
130%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Arizona
All
Referral on
No limit
185%
application
California
All
Pamphlet
No limit. Households
200%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Colorado
All
Notice on
No limit. Households
200%
application
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Connecticut
All
“Help for People in No limit
185%
Need” brochure
Delaware
All
Application refers
No limit
200%
to a pregnancy
prevention hotline
District of
All
Brochure
No limit
200%
Columbia
Florida
All
Notice
No limit. Households
200%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Georgia
All
TANF Community
No limit. Households
130%
Outreach Services
with an elderly or
brochure
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Guam
All
Brochure
No limit
165%
Hawaii
All
Brochure
No limit
200%
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Gross Income
Limit for
Households
Without an Elderly
or Disabled
Type of TANF
Member (% of
Households
Benefit or
federal poverty
State
Eligible
Servicea
Asset Rules
guidelines)b
Idaho
All
Flyer about referral $5,000
130%
service
Il inois
All
Guide to services
No limit. Households
165%
brochure
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Indiana
All
Brochure
$5,000
130%
Iowa
All
Notice of eligibility
No limit
160%
and brochure
Kentucky
All
Resource guide
No limit. Households
200%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Louisiana
All
Notice
No limit.
130%
Maine
All
Resource guide
No limit.
185%
Maryland
All
Referral to services No limit
200%
on application
Massachusetts
All
Brochure
No limit. Households
200%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Michigan
All
Language on
$15,000.
200%
application and
notice.
Minnesota
All
Domestic violence
No limit
165%
brochure
Montana
All
Brochure
No limit
200%
Nebraska
All
Pamphlet,
$25,000 for liquid assets
165%
statement on
notices and
applications
Nevada
All
Pregnancy
No limit
200%
prevention
information on
application
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Gross Income
Limit for
Households
Without an Elderly
or Disabled
Type of TANF
Member (% of
Households
Benefit or
federal poverty
State
Eligible
Servicea
Asset Rules
guidelines)b
New Hampshire
Households
Brochure
No limit
185%
with at least
one dependent
child “and a
specified
relative to that
child”
New Jersey
All
Brochure
No limit
185%
New Mexico
All
Brochure
No limit
165%
New York
Households
“Helping Hands”
No limit. Households
200% for households
with
brochure mailed
with an elderly or
with dependent care
dependent
yearly
disabled member with
expenses; or
care expenses;
incomes over 200% of
150% for households
or
poverty face a $3,500
with earned income
households
asset limit.
and no dependent
with earned
care expenses
income
North Carolina
All
Statement on
No limit
200%
application/recertifi
cation forms
North Dakota
All
Statement on
No limit
200%
application/recertifi
cation forms and
pamphlet
Ohio
All
Ohio Benefit Bank
No limit. Households
130%
information on
with an elderly or
approval notice
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Oklahoma
All
Certification notice No limit
130%
has 2-1-1 number
for information and
referral to
community
services
Oregon
All
Pamphlet
No limit
200%
Pennsylvania
All
Pamphlet
No limit. Households
160%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
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Gross Income
Limit for
Households
Without an Elderly
or Disabled
Type of TANF
Member (% of
Households
Benefit or
federal poverty
State
Eligible
Servicea
Asset Rules
guidelines)b
Rhode Island
All
Publication
No limit. Households
185%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
South Carolina
All
Pamphlet
No limit. Households
130%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Texas
All
Information about
$5,000 (excludes one
165%
various services
vehicle up to $15,000,
provided on the
includes excess vehicle
application
value).
Vermont
All
Notice with
No limit
185%
language on
website for
services
Virgin Islands
All
Brochure
No limit. Households
175%
with an elderly or
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Virginia
All
Brochure
No limit
200%
Washington
All
Information and
No limit
200%
Referral Services
provided on
approval letter
West Virginia
All
Information and
No limit. Households
200%
Referral Services
with an elderly or
program brochure
disabled member with
incomes over 200% of
poverty face a $3,500
asset limit.
Wisconsin
All
Job Net Services
No limit
200%
language on
approval and
change notices
Source: Prepared by the Congressional Research Service based on data from U.S. Department of Agriculture,
Food and Nutrition Service (FNS).
a. Type of TANF benefit or service is information col ected 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.
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b. Households with an elderly or disabled member do not have a gross income limit in SNAP.
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.20 Table 2 shows that in FY2019, a monthly average of 4.8% 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: FY2019
By household type
Households
Without an
Households
Elderly or
With an Elderly
Disabled
or Disabled
All SNAP

Member
Member
Households
100% of poverty or lower
84.7%
75.1%
80.1%
101% to 130% of poverty
10.5
16.4
13.4
131% of poverty and higher
4.8
8.5
6.6
Totals
100.0
100.0
100.0
Source: Congressional Research Service (CRS) tabulations of the FY2019 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 percentage of households without an elderly or disabled
member that have incomes above 130% of poverty by state.21 Note that tabulations in Table 2 and
Table 3 reflect states’ SNAP households under states’ broad-based categorical eligibility practices

20 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.
21 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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in place during FY2019. Some states’ current practices are different from their practices in
FY2019, so tabulations here do not necessarily reflect current state practices.
Table 3. Estimates of SNAP Households without an Elderly or Disabled Member
with Gross Incomes Over 130% of Poverty by State, FY2019
Percentage of All SNAP
Number of SNAP Households
Households Without an Elderly
Without an Elderly or Disabled
or Disabled Member and Gross
Member and Gross Income
Income 131% of Poverty or
State
131% of Poverty or Higher
Higher
Alabama
2,198
1.3%
Alaska
0
0.0
Arizona
8,493
3.7
Arkansas
0
0.0
California
79,891
5.7
Colorado
4,446
3.9
Connecticut
9,177
9.5
Delaware
2,889
9.1
District of Columbia
2,003
5.2
Florida
33,694
5.5
Georgia
539
0.1
Hawaii
533
1.4
Idaho
27
0.1
Il inois
13,283
2.7
Indiana
0
0.0
Iowa
7,009
8.1
Kansas
0
0.0
Kentucky
580
0.5
Louisiana
0
0.0
Maine
3,106
12.8
Maryland
15,064
9.2
Massachusetts
24,358
14.4
Michigan
26,009
9.6
Minnesota
6,691
6.4
Mississippi
677
0.6
Missouri
3,159
2.1
Montana
2,172
8.3
Nebraska
359
0.9
Nevada
9,111
7.1
New Hampshire
2,093
15.0
New Jersey
8,924
6.7
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Percentage of All SNAP
Number of SNAP Households
Households Without an Elderly
Without an Elderly or Disabled
or Disabled Member and Gross
Member and Gross Income
Income 131% of Poverty or
State
131% of Poverty or Higher
Higher
New Mexico
5,342
3.8
New York
44,438
7.9
North Carolina
22,725
6.9
North Dakota
834
7.0
Ohio
1,715
0.6
Oklahoma
0
0.0
Oregon
11,308
7.0
Pennsylvania
20,394
5.2
Rhode Island
3,638
10.7
South Carolina
267
0.2
South Dakota
124
0.6
Tennessee
0
0.0
Texas
43,143
5.2
Utah
196
0.4
Vermont
2,099
16.0
Virginia
0
0.0
Washington
20,600
9.2
West Virginia
4,308
6.2
Wisconsin
16,991
10.7
Wyoming
0
0.0
Guam
1,090
9.9
Virgin Islands
389
5.3
Total
466,084
4.8
Source: Congressional Research Service (CRS) tabulation of the FY2019 SNAP Quality Control data file.
Notes: 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.
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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Recent Proposals to Change Categorical Eligibility
2014 and 2018 Farm Bills
Neither of the last two farm bills ultimately included changes to categorical eligibility rules. The
enacted 2014 Farm Bill (P.L. 113-79) did not change categorical eligibility, although the House-
passed version would have eliminated broad-based categorical eligibility.22 Also, and more
recently, the enacted 2018 Farm Bill (P.L. 115-334) did not make changes, although the House-
passed bill proposed some. The 115th Congress House-passed policy is discussed further below.
The House-passed bill, the Agriculture and Nutrition Act of 2018 (H.R. 2, as passed June 21,
2018) would have made changes to limit but not eliminate broad-based categorical eligibility.
Debate during the House Committee on Agriculture’s April 18, 2018, markup was substantially
focused on the bill’s SNAP provisions, including the changes to categorical eligibility. The
Senate-passed bill, Agriculture Improvement Act of 2018 (H.R. 2, as passed June 28, 2018)
would not have made any changes to categorical eligibility.
Section 4006 of H.R. 2, as passed by the House, would have changed broad-based categorical
eligibility in a few ways. In states with broad-based options in place, some but not all households
would have been affected by this change. Under the proposal,
 to be categorically eligible, households would have had to receive SSI, state
general assistance, or “cash assistance or ongoing and substantial services”
through a state program funded by TANF; while these terms would be subject to
implementation, it was to be expected that a brochure may not meet this more
specific TANF-funded benefit;
 there would have been two gross income limits for broad-based categorical
eligibility:
1. households with an elderly or disabled member must be at or below 200% of
the federal poverty line,
2. households without an elderly or disabled member must be at or below 130%
of the federal poverty line;
 households meeting respective gross income limits and receiving a TANF-funded
benefit or other benefit that conveys categorical eligibility would not have had to
meet the law’s asset tests.
The Congressional Budget Office (CBO) estimated that the amendments to categorical eligibility
in the House committee’s reported bill would have reduced SNAP spending by $5.035 billion
dollars over 10 years (FY2019-FY2028).23 CBO also estimated that in an average year, about
400,000 households would have lost SNAP eligibility. As SNAP recipients are also eligible for
free school meals, CBO estimated that in an average year, 265,000 children would have lost
access to free meals.24 On the House floor, Section 4006 of the reported bill was amended by

22 For more information, see CRS Report R43332, SNAP and Related Nutrition Provisions of the 2014 Farm Bill (P.L.
113-79).
23 CBO, Agriculture and Nutrition Act of 2018, H.R. 2, May 2, 2018, p. 7, at https://www.cbo.gov/publication/53819.
Note that interactions with other policies in H.R. 2 may reduce the effect of this policy.
24 Ibid., pp. 13-14.
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H.Amdt. 606 to include a later implementation date, October 1, 2020, so the House-passed bill’s
cost and participation estimates could be different than those published for the reported bill.
Trump Administration’s Proposed Rule to Amend
Categorical Eligibility; Biden Administration’s Withdrawal
As discussed earlier, the current “broad-based” categorical eligibility state option is in part
created by USDA Food and Nutrition Service regulations finalized in 2000.25 In the Fall 2018
Unified Agenda, the Trump Administration indicated plans to change these regulations,26 and then
published a Notice of Proposed Rulemaking on July 24, 2019.27 The comment period ran through
September 23, 2019.
In short, the Administration proposed to limit those TANF-funded cash and non-cash benefits that
may generate categorical eligibility. If implemented, these changes would have been expected to
have the most effect on states that opted into broad-based categorical eligibility, particularly those
that have chosen higher income thresholds and no asset limits. However, the precise impact could
have depended on the federal TANF and state MOE financing and benefits decisions that states
make.
Like the farm bill proposals discussed above, the proposal would have left “traditional”
categorical eligibility in place. The rule did not propose to amend categorical eligibility for
Supplemental Security Income (SSI) households or General Assistance (GA) households.
The regulatory proposal was never finalized, and the Biden Administration withdrew the rule on
June 10, 2021. Further details about the proposal and withdrawal are described in the sections to
follow.
Summary of Proposed Rule
For SNAP categorical eligibility based on TANF, the proposed rule would have required cash and
non-cash benefits to be “ongoing and substantial,” limited non-cash benefits to certain types of
services, and in some respects revised the applicable income and resource limits that may apply to
the TANF-funded benefit. These changes are discussed further below.
Cash Assistance
In the case of TANF-funded cash assistance, to gain categorical eligibility all members of the
household would have had to have received or have been authorized to receive the cash
assistance. It would have been a requirement, not a state option, to convey this categorical
eligibility. The assistance would have to have been substantial and ongoing, which the proposed
rule defined as a minimum of $50 per month for a minimum of six months.28

25 7 C.F.R. §273.2(j)(2).
26 Office of Management and Budget, Unified Agenda of Federal Regulatory and Deregulatory Actions, Fall 2018,
“Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP),” RIN 0584-AE62, at
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201810&RIN=0584-AE62. The Unified Agenda is a
government-wide report published semiannually listing upcoming proposed and final rules that are currently underway
at federal agencies.
27 USDA, Food and Nutrition Service, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance
Program (SNAP),” 84 Federal Register 35570, July 24, 2019.
28 The proposed rule would also allow the U.S. Secretary of Health and Human Services to select a threshold higher
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Non-cash Benefits
In the case of TANF-funded non-cash benefits, they too would have had to have been substantial
and ongoing, which the proposed rule defined as valued at a minimum of $50 per month for a
minimum of six months. Further, the proposed rule specifies a limited list of non-cash benefits:
 subsidized employment for which the employer or a third party receives a
subsidy from TANF or other public funds to offset some or all of the wages and
costs of employing an individual;
 work supports, including transportation benefits or other allowances for work-
related expenses; and/or
 child care subsidies or vouchers.29
As shown earlier in Table 1, currently, broad-based categorical eligibility states are using TANF
or MOE funding to fund brochures and hotlines that then may convey categorical eligibility.
To gain categorical eligibility, under the proposed rule, (1) all members of the household would
have had to have received or be authorized to receive the benefit, or (2) one household member
would have had to have received or be authorized to receive the benefit if the state determines the
whole household benefits.
The state is required to convey categorical eligibility where the relevant TANF-funded benefits
are funded 50% or more by federal TANF or state MOE funds. It is a state option to convey
categorical eligibility for such benefits where the relevant TANF-funded benefits are funded less
than 50% by federal TANF or state MOE funds. The proposed rule would have required states to
notify FNS of all non-cash TANF benefits that confer categorical eligibility, regardless of the
share of TANF funding.
Applicable Income and Resource (Assets) Thresholds under the Proposed Rule
As discussed earlier in “What TANF Means for Categorical Eligibility,” current SNAP
regulations limit broad-based categorical eligibility to 200% FPL. This threshold applies for
TANF-funded benefits serving the TANF statute’s 3rd and 4th purposes, as these are purposes that
do not require targeting benefits to needy families with children.30 Under current regulations,
there does not have to be an asset limit associated with the TANF-funded benefit. As a result,
states using broad-based categorical eligibility have selected an associated income threshold
between 130% and 200% FPL, some have added a higher asset limit, but most states do not use
an asset limit at all.
The proposed rule would have removed the 200% FPL limit as well as any distinctions for
TANF’s statutory purposes. This presumably would have meant that the applicable income and
asset limits for households categorically eligible for SNAP via a TANF-benefit would be those
limits that the respective state sets for the TANF-funded benefit. It would have remained the case
that the household’s net income would have to be low enough to calculate for a benefit.

than $50 (“valued at a minimum of $50 per month or any minimum threshold determined by the Secretary of Health
and Human Services for Title IV-A programs, whichever is higher.”)
29 These types of non-cash benefits allowed for SNAP categorical eligibility are excerpted verbatim from the proposed
regulatory text, at 35581.
30 The 3rd purpose is to reduce the incidence of out-of-wedlock pregnancies. The 4th purpose is to promote the
formation and maintenance of two-parent families. Section 401(a) of the Social Security Act.
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Those households not receiving the proposal’s specified TANF-funded benefit would have been
subject to the income and asset limits set by SNAP law (see “Eligibility through Meeting Federal
Income and Resource Tests”).
USDA’s Estimate of Proposed Rule’s Impact
USDA released an extended Regulatory Impact Analysis (RIA) to accompany the proposed rule
that estimated how it may have impacted SNAP participation and federal spending.31 A summary
of the RIA is included in the Federal Register publication.
Primarily, the analysis used recent SNAP administrative data to determine the share of the
caseload currently categorically eligible through a non-cash TANF-funded benefit and then
estimated to what extent such households would be eligible under SNAP’s federal income and
resource tests. USDA supplemented its analysis with contracted research studies and certain U.S.
Census survey data.
USDA’s SNAP participation impact estimates included the following:
 Approximately 9.0% of currently participating SNAP households would have
lost eligibility for SNAP. In an estimate for FY2020, this would have been 1.7
million households, containing 3.1 million individuals. The numbers and rates of
households affected varied among household types.32
 Loss of eligibility would have been disproportionate among certain subgroups:
13.2% of households with elderly members, 12.5% of households with earnings,
and 10.1% of households without children.
 17.2 million households currently eligible under broad-based categorical
eligibility would still have been eligible for SNAP but would have undergone a
more burdensome application process.
In terms of federal spending, USDA estimated savings and costs associated with the policy
change. USDA forecasted a net federal savings of $9.4 billion over the five years from 2019 to
2023. This included (1) a reduction in federal spending for SNAP benefits of $10.543 billion, and
(2) an increase in federal spending for federal administrative costs of $1.157 billion. USDA
estimated that states’ spending for administrative costs would also have increased by $1.157
billion over the five years.
As far as state-by-state impacts, USDA’s estimates recognized that the proposed rule would have
been expected to affect only states that have opted into broad-based categorical eligibility, and
that it would disproportionately affect states that have more expansive categorical eligibility
policies (e.g., 200% FPL, no resource limit). USDA included some state-specific data in the
RIA.33
Children living in households that receive SNAP are automatically eligible for free school meals
(through the National School Lunch Program and School Breakfast Program) without filling out a
school meals application.34 While CBO analyses of past farm bill proposals to restrict broad-
based categorical eligibility in SNAP have often included estimates of children who would lose

31 The proposed rule’s full RIA is available at https://www.regulations.gov/document?D=FNS-2018-0037-0002.
32 Ibid., pp. 15-18.
33 Ibid., pp. 20-21.
34 See CRS Report R43783, School Meals Programs and Other USDA Child Nutrition Programs: A Primer for further
discussion of school meals eligibility.
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free meals eligibility, USDA’s RIA, published on July 24, 2019, did not include such an estimate.
On October 15, 2019, USDA subsequently released an “informational analysis” estimating the
impact of the proposed rule on children’s school meals eligibility.35 USDA estimated that 982,000
children would no longer have been automatically eligible for free meals via SNAP, but most
would still receive free meals, or be shifted to reduced-price meals, via a household income
application.36
Biden Administration’s Withdrawal of Proposed Rule
On June 10, 2021, the Biden Administration notified the public of its decision to withdraw the
proposed rule.37 The Administration noted that nearly 158,000 comments were received in the
proposed rule’s comment period and that they “came from a broad range of stakeholders and
generally opposed the proposed rule.”
The Administration determined that the proposed rule should not be finalized and that it is
withdrawing the rule. The notice stated that USDA “reaffirms its longstanding categorical
eligibility policy, codified in regulations at 7 C.F.R. §273.2(j).” In addition, the notice agrees with
certain critical comments—for example, one finding that the proposed revisions do not
sufficiently justify the lost eligibility or costs to states. The Administration further states that the
withdrawal “reaffirms the purpose of categorical eligibility to simplify the SNAP application
process for both SNAP state agencies and households.”

Author Information

Randy Alison Aussenberg
Gene Falk
Specialist in Nutrition Assistance Policy
Specialist in Social Policy

Acknowledgments
CRS Research Assistant Isaac Nicchitta assisted with updating this report.

35 Informational analysis available at https://www.regulations.gov/document?D=FNS-2018-0037-16046. On October
18, 2019, USDA published in the Federal Register, in light of the new analysis, a reopening of the proposed rule’s
comment period. Comments closed November 1, 2019.
36 Ibid., p. 3. Household income eligibility thresholds are below 130% of poverty for free meals and between 130% and
185% of poverty for reduced-price meals. USDA estimated that 445,000 (or 45%) would be income-eligible for free
meals by application, 497,000 (or 51%) would be income-eligible for reduced-price meals by application, and that
40,000 (or 4%) would lose eligibility for this assistance. USDA also noted that these may be high-end estimates, as
some theoretically affected students might continue to receive free meals based on their schools’ participation in the
Community Eligibility Provision (CEP).
37 USDA, Food and Nutrition Service, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance
Program (SNAP); Withdrawal” 86 Federal Register 30795, June 10, 2021.
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Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
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under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
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