Q. Why is the Administration for Children and Families (ACF) including Supplemental Nutrition Assistance Program (SNAP) benefits in Head Start eligibility criteria at this time?
A. President Biden’s Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government requires federal agencies to reduce the challenge of navigating multiple eligibility processes and support better alignment and coordination across federal public benefit programs. ACF is expanding its interpretation of public assistance because the current, narrow interpretation does not capture many families who are already eligible for Head Start programs. The majority of households with young children who receive SNAP benefits have incomes below 100% of poverty. Currently, these families must document their income eligibility for both SNAP and Head Start programs, which can cause unnecessary burden to both families and Head Start grant recipients. Reducing this administrative burden to qualify for multiple federal services will allow programs to reach more families in need.
Q. Will this make higher income children eligible for Head Start programs?
A. Head Start programs can consider SNAP recipients categorically eligible for their programs. Though WIC has a higher income threshold for eligibility than the Head Start program, a majority of SNAP recipients are already eligible for Head Start programs based on their income level. While there are some households who receive SNAP benefits with incomes higher than 130% of the federal poverty level, data shows that number is relatively small. The inclusion of SNAP benefits as public assistance will expand the pool of eligible participants in Head Start programs for these households. However, programs are required to continue to enroll and serve the most vulnerable in their communities based on their selection criteria.
Q. Why does this Information Memorandum (IM) add SNAP public assistance for Head Start categorical eligibility and not the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) assistance?
A. The sole purpose of IM 22-03 is to make clear that programs can consider SNAP as “public assistance” for purposes of determining Head Start eligibility. While the SNAP income-based eligibility threshold of 130% of federal poverty guideline is slightly higher than income-based Head Start eligibility, the inclusion of SNAP as public assistance is unlikely to substantially expand the number of Head Start participants with incomes exceeding 100% of poverty.
The WIC income eligibility level is up to 185% of the federal poverty guideline, which is higher than the income-based eligibility for the Head Start program and SNAP. Furthermore, the number of households receiving SNAP with both children under 5 and above the 130% of federal poverty guideline is much smaller than the similar group receiving WIC benefits. Based on data available, an estimated 150,000 households receiving SNAP with children under 5 had incomes above 130% of the federal poverty guideline compared to an estimated 900,000 children under 5 participating in WIC with household incomes above 130%.
Q. Do programs need Regional Office approval to consider SNAP benefits as public assistance?
A. No, programs do not need approval to include SNAP benefits in the interpretation of public assistance. Programs must continue to prioritize those most in need for enrollment and adhere to selection criteria and program policies and procedures that are based on community needs according to 45 CFR §1302.13.
Q. When does the IM take effect?
A. This IM goes into effect immediately. Programs can move forward in updating their program policies and procedures on eligibility determinations to enroll or add to wait lists children in households receiving SNAP benefits.
Q. How should programs verify families receive SNAP benefits?
A. To verify a family’s receipt of SNAP benefits as potential eligibility for the Head Start program, staff need to examine and maintain a copy of documentation from the state, local, or tribal public assistance agency as required in 45 CFR §1302.12(i)(2). For example, a family could present a copy of notice of approval, other documentation of eligibility or benefits from the SNAP agency, or an Electronic Benefit Transfer (EBT) card with SNAP ID number to be eligible for Head Start services.
Q. How should programs record SNAP eligibility determinations in program files?
A. Head Start grant recipients must maintain an eligibility determination record for each participant in the program, as required in 45 CFR §1302.12(k). Each record should indicate whether a child was deemed eligible through SNAP, income, or another category. Programs maintain copies of documentation used to verify eligibility in each child’s file as part of the required eligibility determination record.
Q. Will this ACF guidance allow programs to enroll more children?
A. No, including SNAP benefits as public assistance for Head Start eligibility determinations will not increase a program’s funded enrollment. However, it may allow programs to find additional eligible families to add to their waitlist or fill any vacant slots.
Q. Do Pandemic Electronic Benefit Transfer (P-EBT) benefits count for Head Start categorical eligibility?
A. No, P-EBT will not count as public assistance for Head Start categorical eligibility. P-EBT was established by the Families First Coronavirus Response Act (FFCRA) as part of the U.S. government response to the COVID-19 pandemic. P-EBT provides benefits to children who would have received free or reduced-price school meals if not for COVID-19-related school closures or reductions in school hours or attendance. Receipt of P-EBT will not qualify as categorical eligibility for Head Start services.
Q. Will families receiving benefits from programs in lieu of SNAP, specifically the Nutrition Assistance Program (NAP) and the Food Distribution Program on Indian Reservations (FDPIR), be considered categorically eligible for Head Start services?
Q. Are the income guidelines for the Supplemental Nutrition Assistance Program (SNAP) higher than that of Head Start programs?
A. Eligibility for or receipt of SNAP makes a family categorically eligible for Head Start services. If a family is categorically eligible, they do not need to have their income verified. Therefore, it doesn’t matter if the family’s income is equal to, below, or above the poverty line.
Q. If families receiving SNAP are eligible for Head Start services, is it the case that Head Start eligibility allows a family to be eligible for SNAP?
A. No. Families eligible for Head Start services must apply for SNAP benefits separately. It is likely most Head Start-eligible families are also eligible for SNAP.
Q. Which families are categorically eligible for Head Start services?
A. There are certain categories of eligibility where income verification is not required. If a family’s circumstances include any of the following, the verification process does not need to include a family’s income.
- Eligible for or receiving the following public assistance:
- Temporary Assistance for Needy Families (TANF)
- Supplemental Security Income (SSI)
- Supplemental Nutrition Assistance Program (SNAP)
- Experiencing homelessness
- In foster care
Q. Are categorically eligible families guaranteed placement in a Head Start program?
A. No. Eligible applicants are not guaranteed enrollment in a program. Children in in foster care, experiencing homelessness, or receiving TANF, SSI, or SNAP benefits are categorically eligible for Head Start services. Programs then use their selection criteria to prioritize families most in need for enrollment.
Q. If a family is SNAP-eligible but does not receive benefits, how can a Head Start program show that they are eligible for SNAP? Is the only recourse for a Head Start program to use a letter from a government entity stating that the family is eligible?
A. As stated in IM 22-03, a program would need to examine and maintain a copy of documentation from the state, local, or tribal public assistance agency to verify SNAP receipt or potential eligibility, as required in 45 CFR §1302.12(i)(2). For example, a family could present a copy of notice of approval, other documentation of eligibility or benefits from the SNAP agency, or an Electronic Benefit Transfer card with SNAP ID number to become categorically eligible for Head Start services.
Q. Can a family provide a self-attestation that they are eligible for SNAP?
A. No, a family cannot provide self-attestation that they are eligible for SNAP. Self-attestation is only appropriate verification for a family documenting no income or experiencing homelessness.
Q. When will the eligibility verification form be updated and will it include SNAP?
A. The updated Head Start eligibility verification form now includes SNAP and is available on the Early Childhood Learning and Knowledge Center (ECLKC) website.
Q. Are SNAP eligibility guidelines the same across the country?
A. States have flexibility in setting state SNAP guidelines, but Head Start programs will consider all SNAP recipients eligible for services regardless of where they live.
Q. How do we award points if families are on SNAP?
A. Families on SNAP are categorically eligible for Head Start services. Programs generally award points in their selection process to prioritize eligible applicants for enrollment. Each program develops their own selection criteria based on community needs.
Q. If a family is slightly over income but receives SNAP benefits, would we then consider them categorically eligible or over income?
A. If a family receives SNAP, they are categorically eligible through public assistance. As such, a program would not need to verify the family’s income, so they would not be considered over-income.
Q. Will the SNAP offices across the nation be alerted that recipients are also eligible for Head Start services? May the SNAP offices directly refer age- and SNAP-eligible children to the Head Start program?
A. Yes. The Administration for Children and Families has worked closely with the U.S. Department of Agriculture Food and Nutrition Service SNAP federal office and is planning events to ensure that SNAP offices are aware of the Head Start eligibility policy and can refer families to the Head Start program.
Q. Do we need to know the amount of SNAP benefit?
A. No. Eligibility for or receipt of SNAP would deem a family eligible for Head Start services, regardless of the amount of SNAP benefits received.
Last Updated: May 9, 2022