by Kyle Winterboer*
As students return to in-person school, it is an important time to revisit the issue of food insecurity across America’s educational system. Particularly in Higher Education, recent studies suggest student food insecurity levels had reached as high as 38% in Spring 2020 and 5.8 of every 10 students experienced some form of basic needs insecurity. These rates have dramatically increased throughout the duration of the pandemic because students sent home for lock-down no longer had access to the already limited forms of support available in person on campuses.
A common tool used to fight food insecurity is the Supplemental Nutrition Assistance Program (SNAP). Despite its successes in reducing hunger and the economic benefits the program introduces to stimulate local economies, SNAP has many limitations and needs reform to better address food insecurity. One such limitation is that policy makers have long denied students access to SNAP. While the past decade has brought some expansions to grant students access, significant barriers remain. Barriers include restrictive student eligibility criteria and mixed messaging that leaves students misinformed of their eligibility. This policy failure leaves students hungry, many of whom would otherwise be eligible for aid if they were not pursuing higher education.
To show the real human impacts of these policy failings, journalist Alejandra Salgado details student stories in an article that appeared in CalMatters and was shared by Civil Eats: Colleges Rush to Sign Students Up for Food Aid, as Pandemic Rules Make More Eligible | Civil Eats
To provide additional context to the policies described in Salgado’s reporting, the below contains insights from Resnick Center Research Assistant Kyle Winterboer in this policy area. This research comes from his time with the student led research advocacy group “unBox”, the assistance of the UCLA CalFresh Initiative, his own application process amidst the pandemic, and from his time implementing a little known policy solution across UCLA departments to better support students in their SNAP applications.
The Resnick Center thanks the unBox Project and the UCLA CalFresh Initiative for readily sharing information for this report, and their continued dedication to the mission of ensuring equitable access to food for all.
Student Barriers to SNAP Overview:
In Pre-Covid times, students across the country applying for SNAP had to meet additional requirements beyond the standard SNAP income and resource eligibility requirements. Student specific requirements included stipulations that they maintain 20 hours of work per week, with minimal exceptions. (See CA Student Eligibility Example.) These exceptions vary depending on the state, and even on the local level as county social service departments vary in how they grant exemptions. These additional student requirements are incongruent with the demanding nature of acquiring a higher educational degree, and make students choose between focusing on school or working to eat or feed their own families. This was difficult enough in normal times, not to mention during a global health emergency.
At the onset of the pandemic, these additional student requirements led to a policy bottleneck which left students locked out from accessing their crucial benefits. With the declaration of the federal health emergency and lock down orders in the spring of 2020, federal work requirements for standard SNAP recipients were removed on July 1, 2020, to accommodate stay at home orders. While this was widely beneficial and removed the minimum hour work requirements for standard SNAP recipients, those requirements were not removed from the student eligibility criteria. Due to this oversight, students wanting to access benefits needed to continue working 20 hours a week in the middle of a global pandemic.
As lockdowns rolled out across the country, the failure to remove the work requirement impacted new applicants as well as students who were already receiving these benefits. Newly unemployed students already enrolled in SNAP faced uncertainty whether their unemployed status would impact their benefits. Meanwhile, new student applicants unable to find work were being denied as they could not meet the still required 20 hour student work requirements. This observation was based on my own application process, as well as those of my peers. Upon being denied services, students became unable to afford basic necessities, and in some cases had to drop out of school to feed their families. Based on UCLA student testimonials, some unemployed students reported dropping out of school, reapplying for SNAP, and subsequently being admitted to receive benefits. The only barrier restricting their access had been the student eligibility requirements.
The policy bottleneck remained until January 14, 2021, when the passage of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) temporarily lifted the student eligibility work requirement. Student applicants who met the criteria expected of standard applicants now could apply without having to meet the additional work criteria. The CRRSAA lowered significant barriers and greatly opened student eligibility to a record number of students. After its passage, an estimated 2 in 5 higher education students were now eligible to apply for SNAP benefits. While the Act has temporarily solved the bottleneck, without further legislation the progress will be undone, and students will once again be stripped of their benefits.
Policy Solutions: To prevent the undoing of newly granted student SNAP access at the end of the pandemic, there are legislative solutions being proposed and immediate actions academic institutions can take.
The Enhanced Access To SNAP (EATS) Act:
If passed, this Act will effectively make the temporary CRRSAA extensions permanent and allow students to continue to access SNAP after the federal health emergency designation’s expiration. It will do so by federally recognizing the pursuit of a higher education as fulfilling standard SNAP work requirements. Such a policy change will put students on equal footing with standard applicants, including on income and resource requirement levels. The action will also remove the variabilities of student eligibility across different states and simplify applications.
EATS Act Congressional Overview:
Introduced to the US House of Representatives on 3/16/2021, the bill will “amend the Food and Nutrition Act of 2008 to treat attendance at an institution of higher education the same as work for the purpose of determining eligibility to participate in the supplemental nutrition assistance program.” The bill is sponsored by Rep. Gomez, Jimmy (D-CA-34) and currently has 79 cosponsors. It was initially referred to the House Committee on Agriculture, and then the Subcommittee on Nutrition, Oversight, and Department Operations on 5/13/2021. Recently it was also introduced to the Senate as S.2515 by Sen. Gillibrand, Kirsten (D-NY) on 7/28/2021 and assigned to the Senate Agriculture, Nutrition, and Forestry Committee.
(Track the House Bill here: All Info – H.R.1919 – 117th Congress (2021-2022): EATS Act of 2021 | Congress.gov | Library of Congress and Senate Bill here: S.2515 – 117th Congress (2021-2022): EATS Act of 2021 | Congress.gov | Library of Congress)
What Schools Can Do Right Now:
Buildout Basic Needs programs:
Going forward, schools can invest in their basic needs programs to better support students facing difficulties. Examples of services provided include food through campus meal vouchers, food pantries, emergency housing assistance funds, and campus staff dedicated to help students applying for governmental assistance services. By having staff dedicated to servicing student needs, campuses can provide direct assistance while gaining a better understanding of what difficulties their students are facing.
At UCLA, the “CalFresh Initiative” serves as a successful model of providing assistance to students during SNAP applications. The Initiative is part of UCLA’s Basic Needs Office and offers weekly virtual office hours and one-on-one application appointments. Their website also contains detailed lists and instructional videos to walk students through the necessary application steps. During these sessions, their staff walk students through the nuances of applications and identify errors that may delay students being admitted. After the application is ready, students submit their forms virtually with CalFresh (California’s SNAP Program) at their local CA Dept of Social Services (CDSS) County Office.
Despite the efforts of on campus programs, not nearly as many students are applying as are eligible for SNAP. This is due to mixed messaging, stigmas surrounding governmental assistance programs, and previous denials which can lead students to give up on applying for SNAP assistance. One way to overcome these barriers is through targeted messaging campaigns. Universities can partner efforts with financial aid and registrar offices to identify eligible students. Then the university can work to standardize the required SNAP paperwork and send out the required documentation in mass to those groups. This helps lower barriers by limiting the amount of paperwork requests students need to make of their academic institutions should they decide to apply to SNAP.
Enroll Degree Programs Into Exemption Designation:
“Local Program That Increases Employability”
If the EATS Act or further legislation is not passed, students will find themselves having to once again meet restrictive student requirements that are incongruous with their higher education goals. To prepare for the worst case of CRRSAA expiring without the EATS Act or further legislation, individual degree programs can apply to the CA Dept of Social Services (CDSS) for a special exemption called “Local Program that increases employability” (henceforth referred to as LPIE).
With this exemption, so long as a degree program contains a job training component or internship as part of their curriculum, enrolled students are eligible to be exempt from the student requirements of SNAP and are instead vetted by standard applicant criteria. This particularly benefits programs such as Med schools, J.D. Programs, Social Welfare, Teaching Credentials, Research Labs, and any other program that is able to prove to CDSS that their students undergo some type of internship component.
For the first 10 months of the pandemic before the passage of CRRSAA, this departmental exemption was one of the few ways for students to avoid the work requirement. It was a vastly underutilized exemption that most academic programs had been unaware of. Before the pandemic, the only two programs at UCLA that had been accepted by CDSS were the UCLA School of Law’s J.D. program and the Medical Education Program of the David Geffen School of Medicine. The nursing and dentistry program luckily were admitted right as the pandemic temporarily shut down the facilities processing these requests. Due to the shutdowns, other interested departments had to wait months for approval; while students beholden to the work requirements had to choose between school, eating, or working in unsafe environments. Notably, thanks to on-campus messaging and student activism, 23 UCLA programs have now been approved by CDSS.
Basic Needs programs can help identify potential eligible degree programs across their campuses and then help each individual department apply with CDSS. Unfortunately, a more streamlined process is not available; each degree program interested must apply individually. This has led to an uneven and slow utilization of the exemption across the state with many schools being left behind. A more equitable application of the program would include CDSS streamlining implementation across the state. Despite these barriers, in the meantime the exemption offers a meaningful way to offer students benefits and universities should continue applying to support as many students as possible.
Interested programs can enroll by contacting the California Department of Social Services. The application can be found at Draft ACL WIOA EOPS (2).docx (ca.gov)
Behind the numbers:
Despite the LPIE designation existing since 2017, implementation remains sparse. On CDSS’s publicly available excel sheet (linked below), as of 9/9/21 only around 50 California campuses across the entire have at least one program that has enrolled in the designation. Keep in mind that designation only benefits that individual degree program, not the entire campus. Delving further into the data, only 260 individual programs have successfully been approved, compared to the thousands of potentially eligible degree programs across the state. Of those 260 approved programs, only 62 were enrolled before the March 2020 pandemic lockdowns. In line with the program’s ability to protect students from unsafe work requirements in the pandemic, a notable 198 programs have been approved since April 2020.
Find Out if Your Program is Recognized by CDSS Here:
To find out which programs have been approved, an excel sheet is available and updated every few months on the CDSS website. To access it, click this link, Policy Guidance (ca.gov), scroll down to the title Student Resources, and click “CalFresh Student Eligibility: Approved Programs to Increase Employability” Alternatively, use this direct Excel link: (https://www.cdss.ca.gov/Portals/9/CalFresh/Students/External-Student-Program-List.xlsx) This is the same sheet local case workers reference when admitting students.
Note to Student Applicants: when applying, to ensure your case worker sees your degree program on the excel sheet, UCLA CalFresh Initiative recommends submitting a screen shot of your program highlighted on the list, as part of your application’s verification documents.
For J.D. programs, UCLA, USC, UC Irvine, UC Berkeley, and UC Davis Law Schools have been approved by CDSS. Additional programs may have escaped the Resnick Center’s search given variations in the excel sheet’s data and new programs currently being processed, so readers are encouraged to look for their own program of interest and proceed from there.
Even if you believe your program is enrolled, you may want to double check your program’s information to ensure it appears correctly. It is very easy to miss programs on the document given mistakes of data entry that occurred during the pandemic transition. For example, USC’s Law School does not show up on the document in the same space as other USC programs, leading students to be denied if a case worker doesn’t notice the discrepancy. This is because it is mislabeled as being in Sacramento. The Resnick Center has reached out to CDSS and USC to alert them of this discrepancy.
Note to law schools: if your program is listed for the J.D. program, this convers only the J.D. track, not the Master of Law, certificates, or doctorates. Each of those individual degrees require approval and a separate application to CDSS. Some law schools on the Excel Sheet do appear to have enrolled additional programs beyond the J.D. track.
Should any readers have further questions about the LPIE exemption, they are encouraged to contact their school’s basic needs program and the CA Depart of Social Services to go through the registration process.
CalFresh Application Resources:
Californians can apply to CalFresh online at GetCalFresh.org:
You may contact your local Department of Social Services office should you have questions or wish to submit a paper application. For more information visit the CDSS’s website or call the Benefits Helpline.
- CA Dept. Social Services Website: https://www.cdss.ca.gov/inforesources/calfresh
- CalFresh Benefits Helpline: 1-(877)-847-3663
UCLA Students can use UCLA’s CalFresh Initiative: Applying | UCLA Basic Needs
Students are encouraged to schedule an appointment during the office’s weekly office hours to ensure all application material is accounted for and ensure proper processing once the application is submitted to CDSS through getcalfresh.org. Temporary Closure Notice: Office Hours and appointments are unavailable the week of Sept. 13th to prepare for Fall quarter and will resume Sept. 20th. Students can still access resources on the website including a prerecorded video walk-through and lists of verification document requirements.
Departmental Application for “Local Program That Increases Employability” Interested departments are suggested to coordinate with their school’s basic needs program and to contact the CA Depart of Social Services to go through the registration process.
The application can be found at Draft ACL WIOA EOPS (2).docx (ca.gov)
*Kyle is a research assistant with the Resnick Center, and a Master of Public Policy candidate at the UCLA Luskin School of Public Affairs, focused on sustainability and food systems. He is also a member of UCLA’s Graduate Food Studies Program and the National Science Foundation’s INFEWS research traineeship program.