E. Categorical Eligibility for SNAP
|Release 64C: Effective February 1, 2012|
QC Hot Tip
To ensure categorical eligibility for all households, establish categorical eligibility based on 185 percent of FPL, and give the Information and Referrals for Low-Income Households (DHS 3400) at each certification and recertification.
Categorical Eligibility the Easy Way
Categorical eligibility for SNAP can be very easy. It is simply developing a habit for every certification or recertification action.
To establish categorical eligibility:
- Check financial group (SNAP C.5) countable income against the 185 percent FPL standard. * (SNAP E.1)
- Give the group a copy of the DHS 3400.
Code the Cat El field on FSMIS "C."
Do not count any resources. When the filing group is coded as categorically eligible, FSMIS will skip the countable and adjusted income tests and issue at least $16 to eligible benefit groups (SNAP C.7) of one or two persons and the calculated amount to groups of three or greater. (SNAP F.25)
Remember to check the income limit whenever the group reports changes during certification.
* Exception: Cases in TANF Transition are categorically eligible even if over 185 percent.
People are not categorically eligible if:
- At or over 185 percent FPL.
- The head of household is currently serving an OFSET disqualification (SNAP D.20).
- Anyone in the filing group is currently serving an IPV penalty (GP C.5).
Code the Cat El field on FSMIS "N."
Count the resources of the OFSET disqualified head of household and anyone serving an IPV disqualification. Code on FSMIS in Tot Res.
FSMIS will run the countable and adjusted income tests - and the resource test - on the case to determine financial eligibility unless the filing group contains someone meeting the SNAP definition of elderly or disabled.
The term "Categorical Eligibility" is a misnomer. Categorical eligibility (GP A.12) does not mean that the household or person is automatically eligible for SNAP. What categorical eligibility means is that certain eligibility factors do not apply to the SNAP case when all individuals in the filing group (SNAP C.2) are categorically eligible for SNAP.
A SNAP filing group is considered categorically eligible for the entire month when, at any time during the month, all of its members receive or have been determined eligible to receive any combination of benefits or services from the following programs:
Financial Group Size
|Each additional person||+611|
|Note:||For NC1s, the 185 percent FPL test is done on total gross income before proration.
If using self-employment income with allowable costs, count the gross SEC less 50 percent for the costs for the 185 percent test. If there are no allowable costs, count the gross SEN for the 185 percent test.
Eligibility for medical assistance (EXT, MAA, MAF, OHP, etc.) does not make the household categorically eligible for SNAP.
Remember to document on TRACS or ACCESS if the household is not categorically eligible.
All members of the filing group for ERDC, Housing Stabilization or TA-DVS services are considered to be receiving the benefit or service because they receive a benefit from the payment to the head of household or other adult in the home. In addition, the income and resources of all filing group members are considered in determining a family's eligibility. Therefore, all members of the other programs' filing group are categorically eligible for SNAP.
F SEE CATEGORICAL ELIGIBILITY EXAMPLES #1 THRU #8 (SNAP E.8 - EXAMPLES).
A person is not considered categorically eligible if they are disqualified from receiving SNAP due to serving a SNAP program IPV (GP C.5) or if the head of household is disqualified for failure to comply with OFSET (SNAP D.20) requirements. In addition, categorical eligibility does not end SNAP disqualification. When one of these persons cannot be categorically eligible, the case must not be coded as categorically eligible on the computer.
F SEE CATEGORICAL ELIGIBILITY EXAMPLES (SNAP E.8 - EXAMPLES).
Households determined categorically eligible due to household income less than 185 percent of FPL and the receipt of the pamphlet on TANF information and referral services are categorically eligible for the entire certification period unless an OFSET (SNAP D.20) or IPV (GP C.5) disqualification is applied or a change in circumstances is reported indicating the income exceeds 185 percent of FPL (SNAP E.1).
If categorical eligibility is based on eligibility for specific programs and the eligibility for that program ends, categorical eligibility does not continue. Review and determine if categorical eligibility exists another way, such as, household under 185 percent of FPL.
Remember to change the categorical eligibility coding in the CAT EL field from "Y" or "C" to "N" when categorical eligibility ends. The household may move from one related program to another. For example, a TANF family may gain employment and begin to receive ERDC. When there is a change from one program to another, determine categorical eligibility based on the new program. In the example of a TANF family moving to ERDC, the CAT EL coding should change from "Y" to "C."
Former TANF families who ended TANF due to employment are eligible for Transition services for 12 months after their TANF ends. Housing Stabilization is approved for a 12-month period in which the household may continue to receive benefits as needed. TA-DVS is approved for a three-month period in which the household may continue to receive TA-DVS benefits as needed. Therefore, the households receiving benefits or services from these programs are considered categorically eligible for the full three-month or 12-month period.
In creating categorical eligibility for SNAP, Congress assumed that certain eligibility factors were met in the program that made the individual categorically eligible. Therefore, if they are verified in the other program, they are verified for SNAP also. The eligibility factors that are assumed met and not used in determining SNAP eligibility for categorically eligible individuals are: SSN (SNAP D.6), resources (SNAP F.3), and the sponsored alien (NC A.4) information. Workers are required to look at SSN and sponsored alien information if they have not been verified in the categorical program. However, workers are not required to look at resources beyond verifying the income the household is getting from those resources.
In addition to not looking at these eligibility factors, a categorically eligible SNAP household with income above the countable and adjusted income limits can still be eligible for SNAP because there is no comparison of income to the countable (SNAP F.2) or adjusted (SNAP F.27) income limits. Categorically eligible clients are not assumed eligible for SNAP; they must meet all of the other program requirements.
Categorical eligibility is an important determination because less information must be verified when determining eligibility for SNAP. The biggest plus to workers is that there is no need to look at resources, including vehicles, owned by categorically eligible persons. There is also a big impact on some clients. The greatest impact will be felt by many clients who have income that exceeds the SNAP countable income limit. Due to categorical eligibility, clients may be eligible for SNAP when their income or resources exceed the federal SNAP standards.
|Note:||These eligibility factors must still be verified for the other programs, if those programs require verification of the factors. Although residency is not verified, the members of the benefit group (SNAP C.7) must be considered Oregon residents. All persons applying for SNAP must provide their SSN, however, it is not verified at application. The BENDEX match will verify the number.|
Determine SNAP eligibility and benefit amounts for all categorically eligible households. This means all of the nonfinancial and financial eligibility factors other than SSN, Oregon residency, and resources must be explored. These eligibility factors include household composition (who must be included in the SNAP filing group (SNAP C.2)), student status (SNAP D.3) (is a student eligible) and citizen/alien status (SNAP D.5) (if a noncitizen meets the eligibility criteria for SNAP). Those individuals who are mandatory for OFSET (SNAP D.11) must still comply with the work requirements. Verify (SNAP B.11) and determine what income is countable and the amount to be used in the benefits computations. Also determine eligibility for the various deductions (dependent care (SNAP F.18), shelter (SNAP F.21), utility (SNAP F.22), medical (SNAP F.19), and child support payment (SNAP F.20)). In addition, categorical eligibility does not end SNAP disqualifications.
For categorically eligible SNAP benefit groups (SNAP C.7), a benefit calculation is done solely to determine the amount of benefits. If the income of the benefit group is over the payment standard (SNAP F.24), they may receive no benefits in the initial month due to a proration (SNAP F.27). However, they will receive $16 in benefits for ongoing months when there are one or two persons in the benefit group. Benefit groups of three or more persons will receive the calculated amount only (see SNAP F.25). When a benefit group is eligible for zero dollars, they will remain coded as eligible on FCAS. This is so they can continue to be eligible for OTAP, school lunch programs, etc.
Ineligible noncitizens may be categorically eligible when the other members of the household are receiving ERDC or some TANF-related benefits and the ineligible noncitizen is a member of the filing group for that other program. This does not mean the ineligible noncitizen becomes eligible for SNAP benefits. It means their resources are not used and the household income is not compared to the countable and adjusted income limits.
When a group contains some members who meet categorical eligibility criteria and others who do not, exclude the resources of those who meet the criteria. Do this even if the resources are jointly owned by those who meet categorical eligibility criteria and those who do not. Determine eligibility based on the resources of the person(s) who are not categorically eligible. When one member of the group is not categorically eligible, the case must be coded "NA" with an "N" code in the CAT EL field. Therefore, the household must have resources and income within the resource and income limits to qualify for SNAP.
F SEE CATEGORICAL ELIGIBILITY EXAMPLES #9 AND #10 (SNAP E.8 - EXAMPLES).
Categorical eligibility is an important determination because less information must be verified when determining eligibility for SNAP. The biggest plus to workers is that there is no need to look at resources, including vehicles, owned by categorically eligible persons. There is also a big impact on some clients. The greatest impact will be felt by many clients who have income that exceeds the SNAP countable income limit. Due to categorical eligibility, clients may now be eligible for SNAP when their income or resources exceed the SNAP standards. In addition, families eligible for SNAP may also be eligible for other programs (WIC, OTAP, etc.).
F SEE MP WG #10 FOR INFORMATION ON OTAP AND LINK UP AMERICA.
F SEE MP WG #16 FOR INFORMATION ON SCHOOL LUNCH AND CHILD CARE FOOD PROGRAMS.
For the case to be categorically eligible, each person in the SNAP filing group must be determined eligible for or receiving services or benefits from one of the following programs. If part of the SNAP filing group is receiving benefits from one program but another member of the SNAP filing group is not eligible to receive benefits from any of these program benefits, the household is not categorically eligible for SNAP.
|Program||CMS Coding/Identification||Program Time Frames||Who is Included|
|EA||Open program E2 case on CMS and an ET resource code.||30-day program.||The adult and children in the EA household are considered to receive EA benefits.|
|ERDC||Open program M5 case on CMS.||As long as eligible for ERDC.||The adult and children in the M5 financial group are considered to receive ERDC benefits.|
|GA||Open program 5 case on CMS.||As long as eligible for GA.||All persons in the GA program financial group.|
|Housing Stabilization through Housing and Community Services||Not coded on CMS.
There may be narration in TRACS. If the client states they received Housing Stabilization, contact the community action agency to determine the start date of the program.
May receive one or several payments during that year. Categorically eligible for the entire year.
|All persons in the household are considered to receive the Housing Stabilization benefits.|
|Countable Income under 185% of FPL and received information and referral pamphlet||None||Length of SNAP certification period unless income exceeds 185% FPL.||All persons in the financial group.|
|Pre-TANF||Open program 2, M5 or P2 on CMS, ASM case descriptor, ASM need code with the month the family entered the program.||45-day program.||All persons in the Pre-TANF program financial group.|
|Post-TANF||Open 2, M5 or P2 on CMS, PDF case descriptor and resource codes of PT1 or PT2.||Up to 12 months.||All persons in the Post-TANF financial group.|
|SSI||Open program 4, D4 (disabled), 3, B3 (blind) or 1, A1 (aged) case on CMS. Code the SSI case descriptor and SSI and SIP N/R codes. Code ESB if not zero. May be verified through BEIN or letter from the Social Security Administration.||As long as the Social Security Administration finds eligible for SSI.||Any individual receiving SSI benefits or determined eligible for SSI under 1619(a) or (b) of the Social Security Act.|
|TANF and Tribal TANF||Open program 2 or 82 case on CMS.||As long as eligible for TANF.||All persons in the TANF financial group.|
|TA-DVS||Any open case on CMS with a DVS need/resource code and the start month.||90-day program.||The adult and children in the DVS household are considered to receive TA-DVS benefits.|
|TANF JOBS Plus||Open program 2 case on CMS, with a PLS case descriptor and PLS resource code with the starting month.||As long as eligible for JOBS Plus up to 6 months.||All persons in the TANF JOBS Plus financial group.|
|TANF Transition retention and wage enhancement services||Pending, open or closed program 2, M5 or P2 case on CMS.
||Transition is for 12 months after TANF closes.
Retention and wage enhancement services do not require previous receipt of TANF.
|All persons in the TANF-related financial group are considered to receive
Transition Services for at least 12 months.
All persons in the TANF-related financial group are considered to receive retention and wage enhancement services in the month of receipt only.
|Note:||Remember, eligibility for medical program benefits does not make a person categorically eligible for SNAP.|
F SEE CATEGORICAL ELIGIBILITY EXAMPLES (SNAP E.8 - EXAMPLES).
|Example 1:||A couple and their 20-year-old son are applying for SNAP together. They have income below 185 percent of FPL. They receive the TANF information and referral pamphlet Resource Guide for Low-Income Households (DHS 3400). This family is categorically eligible the length of the certification period unless the family income exceeds 185 percent of FPL.|
|Example 2:||A client is getting SSI and living in a Group Care home. He is categorically eligible for SNAP. The CAT EL field should have a "Y" and the CATEG field must be "PA." SSI income must be coded. The CMS case number for medical and person letter should be coded with the person.|
|Example 3:||A client is receiving SSI. Her two children are receiving TANF (Program 2). They are categorically eligible for SNAP. The CAT EL field should have a "Y" and the CATEG field must be "PA" and each person has a CMS case and person letter listed.|
|Example 4:||A client and her three children are receiving ERDC. They are categorically eligible for SNAP. The CAT EL field should have a "C" and the CATEG field should be "NA" and each person should have a CMS case and person letter listed.|
|Example 5:||A client and his child are not receiving TANF cash benefits because they are eligible for less than $10. They are receiving MAA. They are categorically eligible for SNAP because they are eligible for TANF (Program 2) even though they are not receiving cash benefits. The CAT EL field should have a "Y" and the CATEG field must be "PA" and each person has a CMS case and person letter listed.|
|Example 6:||A family lost their eligibility for TANF when the client got a job. This family is now eligible for one year of Post-TANF benefits. Therefore, this family is categorically eligible for one year. The CAT EL field should have a "C" and the CATEG field should be "NA" and each person should have a CMS case and person letter listed.|
|Example 7:||An ineligible noncitizen is receiving TANF (Program 2) for a child. Her income and resources were used to determine eligibility for TANF and she is ineligible for TANF solely due to citizenship/alien status. This family is categorically eligible for SNAP. This means that even though the noncitizen is not eligible for SNAP, their resources are not considered when determining SNAP eligibility for the rest of the household. It also means that the computer will not look at the countable or adjusted income limits. The CAT EL field should have a "C" and the CATEG field should be "NA" and each person should have a CMS case and person letter listed.|
|Example 8:||A 20-year-old client and her child are receiving TANF. They live with the client's mother. Her mother is not receiving any program benefits. The daughter is under the age of 22; therefore, she is required to apply for SNAP with her mother. The combined household income exceeds 185 percent of FPL. The 20-year-old and her child are categorically eligible but the mother is not categorically eligible. The SNAP filing group is not categorically eligible for SNAP. Code the CAT EL field with an "N" and the CATEG field must be "NA." If the FCAS message is over income, close or deny the case.|
|Example 9:||A 52-year-old grandmother is receiving TANF (Program 2) for her two grandchildren. She is not receiving any program benefits for herself. She is not categorically eligible for SNAP because her income in combination with the children's exceeds 185 percent of FPL. Close or deny the case and code the CAT EL field with an "N" and the CATEG field must be "NA."|
|Example 10:||A client and her child (age 14) have been receiving SNAP. Their household income is below 185 percent of FPL. The client quit her job without good cause and is disqualified due to noncooperation with OFSET. The client is not categorically eligible for SNAP because of the OFSET disqualification. To be categorically eligible she must meet the OFSET work requirements and have her needs restored to the SNAP case. The CAT EL field should have an "N" and the CATEG field must be "NA."|