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Student Eligibility Exemptions
For a student to be eligible to participate in CalFresh, the student must meet at least one of the following exemptions on the initial or recertification interview date. Once eligibility for an exemption has been established, the exemption will apply through the certification period, except for the exemptions based on work hours and work study, or if the individual reports a change in their student status.
Reminder: Per the CalFresh definition of a student, any person enrolled less than half-time is not considered a student and is, therefore, not subject to the student eligibility rule.
CalFresh Student Exemption Checklist (CF 6177)
The “CalFresh Student Exemption Screening Form” must be used to determine if a student exemption applies to a student in the household. EWs can collect the information during an interactive initial and RC interview or complete the form with the client when adding a student. EWs must review the selected items to determine if the student qualifies for an exemption and if verification is needed.
Exemption from the Student Eligibility Rule
Students who meet one of the following exemptions may be eligible for CalFresh if they meet all other eligibility criteria.
Age
A student who is age 17 or younger or age 50 or older.
Disabled
Students who receive disability-based income, such as Social Security Disability, Supplemental Security Income (SSI), Veterans’ Disability, Worker’s Compensation, or other disability-based income meet the definition of being physically or mentally unfit to work. The disability must be expected to last more than 30 days.
Physically or Mentally Unfit to Work
If an individual has a temporary or permanent illness, disability, condition, or life circumstance that reduces or affects their ability to work, they are considered medically certified as physically or mentally unfit to work. This means that the physical or mental condition must make the individual unfit to work an average of 20 hours per week on an ongoing basis, and it is not limited to being unfit to work at all.
Students who do not receive disability-based income but cannot work due to a physical or mental condition must verify the inability to work from a third-party source if the student’s unfitness is not apparent. Like ABAWD time limit rules, indicators of apparent unfitness to work include but are not limited to homelessness, struggling with drugs or alcohol, and having experienced domestic violence. If unfitness is not apparent, verification is required, and a client statement or affidavit will not suffice.
Verification can be provided by a medical professional, including but not limited to a physician, nurse, psychologist, or psychiatrist. Other professionals who are not medical professionals but assist clients in case management or other services, such as a Behavioral Health Case Manager or Regional Center Case Manager, may also provide verification.
When third-party verification is unavailable, worker observation noted in the case record can also be used for verification. When possible, the EW attempts to assist the client in obtaining verification for this exemption.
Paid Work/Employment
Students in the following situations are eligible for CalFresh based on working 20 hours per week or an average of 80 hours per month or being self-employed.
- Officially employed, but the first day of work begins later in the month or the following month provided that employment is expected to be 20 hours per week.
- Working an average of 20 hours per week (at least 80 hours per month, but not evenly spaced out through the month).
- Work stops for two weeks or less during school vacations, provided the student remains employed.
- If self-employed, working an average of 20 hours per week or an average of 80 hours per month and receiving weekly earnings at least equal to the Federal minimum wage multiplied by 20 hours weekly.
A student provides their most recent pay stubs showing they work 19 hours per week. Even though the student does not work 20 hours per week, they do work more than an average of 80 hours or more each month. The student is eligible for the paid work exemption.
Average hours: 19 hours per week X 4.33* = 82.77 hours per month.
A student provides their previous month’s pay stubs showing they work 16 hours per week. This student does not work an average of 20 hours per week and does not maintain an average of at least 80 hours per month, so the student is not eligible for the paid work exemption.
Average hours: 16 hours per week X 52 weeks per year* = 832 hours per year / 12 months = 69.33 hours per month.
*Note: The 4.33 multiplier is used to account for the varying lengths of months over the year when calculating average monthly hours. Students must maintain an average of at least 80 hours each month to be eligible for the paid work exemption, even if they work a total of 80 hours in a single month.
Students in the following situations do NOT meet the employment student eligibility criterion.
- Paid with in-kind benefits (such as free housing, utilities, food, or clothing) instead of cash.
- Student teaching or other employment where no pay is received.
- There is no work from June through August; the student will return to work in September. (There is no student eligibility from June through August, but the student would be eligible from September through May.)
Reported Changes to Work Hours
A change in student work hours is not required to be reported mid-period. If the student does not report a change in work hours during the certification period, the student meets the criteria for an exemption from the student eligibility rule through the length of the certification period.
If a student reports a change in income mid-period and the change in income is verified, the EW must reassess the student's continuing CalFresh eligibility. If the student no longer meets the exemption criteria based on work hours, the EW must determine whether the student qualifies for another exemption or is no longer eligible for CalFresh.
If the student reports a change in work hours in their SAR 7, the Eligibility Worker (EW) must determine if the change in work hours averages 20 hours per week or an average of 80 hours per month in order to continue applying for the exemption. If the change in work hours does not average 20 hours per week or an average of 80 hours per month, the EW must then determine whether the student meets the criteria for another exemption from the student eligibility rule or whether the student is no longer eligible for CalFresh.
Work Study
A student is eligible for the work-study exemption if they have been approved, awarded, or accepted for state—or federally financed work study for the current school term (as defined by the institution) and anticipate working during the term.
This exemption is partially based on a student being approved for state or federally-financed work study for the current term, as defined by the institution of higher education. If questionable, acceptable verification of approval for work study may include a work-study award letter from financial aid.
If questionable, acceptable verification of work-study approval may include but is not limited to, a work-study approval or award letter from the financial aid department.
Length of Exemption
This exemption begins the month the school term starts or the month work study is approved, whichever is later. It continues until the end of the month the school term ends or it becomes known that the student refused a work study assignment.
The exemption shall not continue between terms when there is a whole month or longer break unless the student participates in work study during the break. Otherwise, during the break, the student must meet one of the other student eligibility criteria to maintain eligible student status. However, a break or end-of-work study is not a mandatory mid-period report. Therefore, assessment of whether a student is participating in a work-study to determine whether the individual is an eligible student may only be initiated at the periodic report (SAR 7) and recertification.
However, if the household voluntarily reports mid-period that the student will have a break in their work-study for longer than a month and the report is verified, then the EW must act on the reported information. The student is no longer exempt based on work-study; therefore, the EW must reassess whether the student meets other criteria for another exemption before determining continuing eligibility.
A student is eligible based on being approved for work-study and anticipating working during the school term, which began in September. In November, during the RC, the student advised that he was offered a work-study assignment but turned it down. At that point, the student no longer qualifies for the work-study exemption. Unless he meets one of the other student eligibility criteria, he is no longer an eligible student.
A student is eligible based upon being approved for work study and anticipating working during the school year. The school term ends May 26. The student's intent is to return to school in the fall. The new school year begins on August 21. Since there is a break of a full month, unless the student is participating in work-study during the break, he/she must meet one of the other student eligibility criteria to maintain eligible student status during the break.
Anticipating Work
The AB 214 codifies that, to determine CalFresh student eligibility, a student shall be considered “anticipating participation” in work study if “he or she can reasonably expect or foresee being assigned a work study job, and a student shall be deemed to be ‘anticipating participation’ in work study until he or she receives notices from the institution of higher education that he or she has been denied participation in work study.”
The fact that a work study job assignment has not yet begun or is unavailable does not disqualify the student from receiving the exemption. A student can reasonably anticipate being offered a work study job assignment until they receive notice of denial.
Work Study Verification Form
Below is a sample copy of the Work Study Verification Form provided by individual higher education institutions.
Receipt of Temporary Assistance for Needy Families (TANF) Funded Benefit
A Student receiving a TANF-funded (cash or non-cash) benefit meets the criteria for the student eligibility rule. This includes:
- California Work Opportunity and Responsibility to Kids (CalWORKs),
- Tribal TANF,
- TANF-Funded Cal Grant A or B, and
- Any other program funded with the TANF block grant under Title IV of the Social Security Act.
Note: Any student participating in a job training program due to TANF participation is exempt from the student eligibility rule.
CalWORKs Recipient
An applicant for CalWORKs is not considered to be a recipient. A student who begins to actually receive CalWORKs meets the “Student Eligibility Criteria” effective the first of the following month.
Receipt of Cal Grant A or B
Each year, the State allocates TANF funds to the California Student Aid Commission (CSAC) to issue Cal Grants to low-income college students who meet the TANF eligibility requirements. CSAC determines whether a student is eligible to receive a Cal Grant. CSAC offers Cal Grant A, Gal Grant B, and Cal Grant C; however, only Cal Grant A and B are TANF-funded.
Students without qualifying citizenship status may be approved for a Cal Grant A or B but will not receive TANF funding for the Cal Grant. Therefore, their receipt of the Cal Grant does not qualify them for an exemption from the student eligibility rule.
Therefore, only receipt of Cal Grant A or B can be used to determine that a student meets the criteria for an exemption from the student eligibility rule. Cal Grant B Access and Cal Grant C are not TANF-funded. Therefore, receipt of Cal Grant B Access and Cal Grant C cannot be used to determine that a student meets the criteria for an exemption from the student eligibility rule.
The following Cal Grant recipients meet the student exemption rule:
- Students attending a four-year college or university, including CSU, UC, or private institutions, receive a TANF-funded Cal Grant A or B.
- Students participating in the pilot program for a Baccalaureate (BA) Degree at a California Community College that offers BA degrees and receive a TANF-funded Cal Grant A or B.
Verification Letter
CSAC provides recipients of a TANF-funded Cal Grant A or B written notification regarding their potential eligibility for CalFresh. This written notification verifies that a student receives a TANF-funded Cal Grant A or B. The written notification, which has taken the form of an electronic or paper letter sent directly to the student, is provided by CSAC once the TANF-funded Cal Grant A or B has been awarded and paid. If the student’s attestation of receipt of a TANF-funded Cal Grant A or B is questionable, the EW may request verification. Written notification from CSAC can verify that a student has received a TANF-funded Cal Grant A or B.
It cannot be assumed that every student receiving a Cal Grant A or B has received a TANF-funded Cal Grant A or B. CSAC will not provide the written notification if a student's Cal Grant A or B is not TANF-funded. Therefore, if a student who has been awarded and paid a Cal Grant A or B does not receive written notification from CSAC regarding their potential eligibility for CalFresh, it may be that the student is not receiving a TANF-funded Cal Grant A or B.
If a student loses the written notification confirming receipt of a TANF-funded Cal Grant A or B, the student may request a replacement directly from CSAC.
When a student is approved for a TANF-funded Cal Grant A or B, the award is for one year at a time for up to four years. Generally, a Cal Grant is awarded for up to four years as long as the student continues to meet the need requirements and meet satisfactory academic progress on campus. The school distributes funding, and students receive the funding by term. If the student only attends one term, they will only receive funding for one term. However, once eligibility for the exemption has been established, the exemption will apply through the certification period.
The CSAC Cal Grant letter is acceptable for a full year as it is only issued once per year. If the new Cal Grant cycle has not yet been issued for the current school year, the County must accept a student’s receipt of a TANF-funded Cal Grant from the previous academic school year as meeting the criteria for the Cal Grant exemption.
Since CSAC has already determined that the student has met the TANF eligibility requirements by awarding the TANF-funded Cal Grant, the student satisfies this student exemption as long as the award letter is provided to the county. The county should retain a copy of the award letter as it verifies receipt of a TANF-funded Cal Grant A or B.
CalGrant A/B Award Letter
Below is a sample copy of the TANF-funded Cal Grant A or B award letter provided by CSAC.
Parental Control for A child Under Age Six
A student who exerts parental control over a dependent household member under the age of six meets the criteria for exemption from the student eligibility rule.
Only one adult can claim the exemption as the primary person responsible for caring for a dependent child under six. However, if there is more than one child under age six, the EW must explore why one of the parents cannot care for both children or why each parent is “responsible” for each child.
Parental Control for A Child Under Age Twelve Without Adequate Child Care
Availability of child care shall be determined on a case-by-case basis. Situations where adequate childcare services are not available include the following:
- Child care hours offered by the daycare provider do not coincide with the student's employment hours or potential employment hours or
- The distance between the student's home, school, place of employment, and child care prevents the student from meeting their school or employment schedule or
- The institution of higher education provides child care to the children of students only while the student is attending class, and no other child care is available or
- In addition to all of the above factors, an adult member in the home is either unable or unwilling to provide child care.
Only one parent can claim the exemption as the primary person responsible for caring for a dependent child who has reached age six but is under age twelve, and adequate childcare services are unavailable. If there is more than one child under age twelve, the EW must explore why one of the parents cannot care for both children or why each parent is “responsible” for each child.
A student mother with a ten-year-old son has no child care for him. They live with the boy's grandmother, who is a household member, but she refuses to babysit for the boy. There is a child care center ten miles away that would take him, but it is in the opposite direction from the college attended by the student mother and would add an hour to her daily commute routine. Suitable child care is considered unavailable.
Single Parent Responsible for Child Under Twelve
A student enrolled full-time in an institution of higher education and who is a single parent responsible for caring for a dependent child under age 12 meets the criteria for an exemption from the student eligibility rule.
This exemption applies when only one of the child’s natural, adoptive, or stepparents is in the same CalFresh household as the child, regardless of marital status. If none of the natural, adoptive, or stepparents is in the same CalFresh household as the child, another full-time student in the same CalFresh household as the child may qualify for this exemption if they have parental control over the child and their spouse is not part of the CalFresh household.
Attending School as Part of an Employment and Training Program
A student who is assigned to, or placed in, an institution of higher education through or in compliance with one of the requirements listed below meets the criteria for an exemption from the student eligibility rule:
a) Workforce Innovation Opportunity Act (WIOA)
b) CalFresh Employment and Training (CalFresh E&T) Program
c) Programs under Section 236 of the Trade Act of 1974
d) State or local government E&T programs for individuals with low income, determined by the
The county is to be providing at least one of the components listed below:
- Job retention,
- Job search,
- Job search training,
- Work experience,
- Workfare,
- Vocational training,
- Self-employment training,
- On-the-job-training, or
- Education.
Self-initiated placements during the period of time the person is enrolled in one of the E&T programs as specified in the list above must be considered to be in compliance with the requirements of the program in which the person is enrolled, provided that the program has a component for enrollment in an institution of higher education and that program accepts the placement.
Workforce Innovation and Opportunity Act
The Workforce Innovation and Opportunity Act (WIOA) reauthorized and amended the Workforce Investment Act (WIA) of 1998, which superseded the Job Training Partnership Act (JTPA). WIOA-funded activities promote increased employment, job retention, earnings, and occupational skills improvement by participants. Therefore, a student enrolled in a WIOA activity meets the criteria for an exemption from the student eligibility rule.
Note: The Department of Rehabilitation (DOR) receives federal funding under the Rehabilitation Act, as amended by the WIOA. The vocational rehabilitation program is Title IV of the WIOA and is part of the California Unified Strategic Workforce Development Plan under 34 CFR 361.125. All individuals receiving or participating in DOR services are, therefore, participating in a WIOA employment and training program. A student enrolled in a WIOA activity is considered eligible for CalFresh if all other eligibility conditions are satisfied.
Participation in a Local Program to Increase Employability (LPIE)
Participation in a state or local program that increases employability (LPIE) exempts students from the student eligibility rule. A student meets the criteria for an exemption from the student eligibility rule if the student’s attendance can be described as part of a program to increase the student’s employability. To be defined as a program to increase employability, a student must participate in a program that assists in gaining the skills, training, work, or experience to increase the student’s ability to obtain regular employment. This includes programs for low-income students operated by a state or local government, where one or more of the program's components are equivalent to an E&T component.
Process for Identifying LPIEs
Colleges or other educational partners should identify and submit their LPIE programs equivalent to an E&T component. The Center for Healthy Communities (CHC), a CalFresh outreach prime contractor at Chico State University, helps campuses identify and submit LPIEs to the state.
The California Department of Social Services (CDSS) confirms and tracks approvals. On the first of each month, CDSS updates the List of Approved LPIEs on the CDSS website. Both undergraduate and graduate students can qualify under this exemption. Once approved, counties must consider student participation in the program as qualifying the student for an exemption from the CalFresh student eligibility rule.
CDSS updates the List of Approved LPIEs on the CDSS website on the first of each month.
For the updated list, EWs must refer to the CDSS Student Resources CalFresh Student Eligibility: List of Approved LPIEs website at: CalFresh Student Eligibility: List of Approved LPIEs.
The list is accessible from Program Bureau/CF Reference Materials/EW Resources/CF Student Eligibility: List of Approved Local Programs that Increase Employability.
Note: If a student resides in one county but commutes to another county where they are enrolled in an approved LPIE, the student is exempt from the student eligibility rule.
Verification of LPIE
If a student states, verbally or in writing, that they are enrolled in one of the programs listed on the List of Approved LPIEs, that is sufficient information for the County to exempt the student unless it is questionable. If the information provided by a student is questionable, acceptable verification can include but is not limited to a transcript, an email from an instructor, or verbal affirmation from a campus official. Additionally, targeted outreach emails from campuses to LPIE enrollees are acceptable verification. Typically, students enrolled in an LPIE will be notified by their campus that they meet the criteria for an exemption to the student eligibility rule. If a program does not appear on the Approved LPIE List, the county must explore if the student is enrolled in another LPIE or meets the criteria for another exemption before determining the student to be ineligible.
LPIE Notification Letter
Below is a sample copy of the LPIE notification letter provided by individual higher education institutions.
Does Not Expect to be Enrolled Next Term
A student who does not expect to be enrolled in the next school term due to the student graduating, suspension or expulsion, dropping out, or not intending to register for the next normal school term (excluding summer school) is not subject to the student eligibility rule.
If a student applies in February but states they plan to graduate in June, then the student is not subject to the student eligibility rule.
Students who apply in March but do not plan to return to school in the fall are not subject to the student eligibility rule.
Tracking Student Exemptions
Only one exemption is needed to qualify a student for CalFresh. The Eligibility Worker (EW) must record all exemptions claimed in the case file. If a student loses an exemption, the EW must determine if the student meets the criteria for another exemption before taking any negative action.
The County must track all applicable student exemptions. The County may track a student’s exemption using the various drop-down menu items in the Demographics, Income, and School detail pages in the California Statewide Automated Welfare System (CalSAWS), which indicates the student’s exemption status as it relates to the student eligibility rule.
The table below lists the student exemptions provided on the CalFresh Student Exemption Screening Form and the CalSAWS location for each exemption.
| Exemption | Exemption Location in CalSAWS |
| Enrolled less than half-time | School Attendance Enrollment detail page |
| Taking only non-credit courses | School Attendance select Vocational as the institution type |
| Age 17 or younger | Individual Demographic Detail page |
| Age 50 or older | Individual Demographic Detail page |
| Approved for work-study (even if a work-study job has not yet begun or is not available), anticipates working, and has not refused a work-study assignment | Income Detail page for students reflects Work Study income ($0 entry may be used when the assignment is not active) |
| Received a TANF-funded Cal Grant A or B in the last 12 months | Income Detail page |
| Working an average of 20 hours per week or an average of 80 hours per month | Employment detail page |
| Disabled |
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| Physically or mentally unable to work | Medical Condition detail page |
| Does not expect to be enrolled next term | School Attendance Enrollment detail page reflects that the student is not currently enrolled. |
| Responsible for the care of a household member under the age of 6 | Individual Demographic detail page shows the Date of Birth field reflecting a child under age 6 who is indicated on the Relationship detail page to be under the care of the student |
| Responsible for the care of a household member under the age of 12 without adequate childcare |
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| A single parent responsible for the care of a household member under the age of 12 | The individual Demographic detail page shows the Date of Birth field reflecting a child under age 12 who is indicated on the Relationship Detail page to be under the care of the student and a second parent is not in the household as indicated by the Relationship Detail page |
| Receiving CalWORKs or Tribal TANF |
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| Participating in CalFresh E&T | CFET Program block in Active Status |
| Enrolled in a WIOA | School Attendance Detail page |
| Enrolled in an On-the-job training program | School Attendance Detail page |
| Enrolled in an Approved LPIE | School Attendance Detail page |
Summary Chart
The following chart summarizes the student exemption criteria. For detailed policies, refer to the individual exemption sections above.
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CRITERIA |
ADDITIONAL INFORMATION OR RESTRICTIONS |
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Employed at least 20 hours per week/Average of 80 hours per month |
Must receive pay for employment. |
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Self-employed at least 20 hours per week/Average of 80 hours per month |
Must earn at least the equivalent of federal minimum wage times 20 hours per week. |
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State or Federally-financed Financed Work Study participant |
Be APPROVED for state or federally-financed Work Study for the current school term, as defined by the institution, and ANTICIPATE working during the term. |
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Workforce Innovation and Opportunity Act (WIOA) |
Participating in activities approved under WIOA, including vocational rehabilitation programs offered by the Department of Rehabilitation (DOR). |
| Disabled | Receive disability-based income, such as Social Security Disability, SSI, Veterans' Disability, Worker's Compensation, or other disability-based income. The disability must be expected to last more than 30 days. |
| Physically or Mentally Unfit to Work |
Students who do not receive disability-based income but are unable to work due to a physical or mental condition. A temporary or permanent illness, disability, condition, or life circumstance that reduces or affects their ability to work. The physical or mental condition must make the student unfit to work an average of 20 hours per week on an ongoing basis and is not limited to being unfit to work at all. |
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Exerting Parental Control over a Dependent HH Member who is under the age of six |
The assertion of parental control is only met if the student provides most of the child care for children under age 6. Only one parent can claim this exemption as the primarily responsible person for a dependent child. However, if there is more than one child under the age of six, the EW must explore why the primary parent cannot care for more than one child or why both parents are responsible for the children under six. |
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Exerting Parental Control over a Dependent HH member age six through Twelve and Adequate Child Care Services are unavailable. |
Adequate childcare services are not available to enable the student to attend class, work 20 hours per week, or participate in a state or federally-financed work study program during the regular school year.
Only one parent can claim the exemption as the primary person responsible for caring for a dependent child who has reached age six but is under age twelve, and adequate childcare services are unavailable. However, if there is more than one child under age twelve, the EW must explore why one of the parents is unable to care for all the children or why both parents are “responsible” for the children. |
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Enrolled full-time in an institution of Higher Education and a Single Parent responsible for the care of a child under age 12. |
This provision applies when only one of the child’s(ren’s) natural, adoptive, or step-parents, regardless of marital status, is in the same CalFresh household (CalFresh HH) as the child(ren). If no natural, adoptive, or step-parent is in the same CalFresh HH as the child, another full-time student in the same CalFresh HH as the child may qualify for eligible student status if they have parental control over the child and are not living with their spouse. |
| Single Parent Responsible for Children Under 12. |
A student enrolled full-time in an institution of higher education and is a single parent responsible for the care of a dependent child under age 12. This exemption applies only when the parent is the child's natural, adoptive, or step-parent, regardless of marital status, and is in the same CalFresh household as the child. If no natural, adoptive, or stepparent is in the same CalFresh household as the child, another full-time student in the same CF HH may qualify for this exemption if the student has parental control over the child and is not living with their spouse. |
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Recipients of TANF Funded Benefit |
This includes CalWORKs, Tribal TANF, TANF-Funded CalGrant A or B, and any other programs funded with the TANF block grant. It cannot be an RCA recipient. |
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Assigned or Placed in an Institution of Higher Education through or in Compliance with one of the Programs on the right |
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| Local Programs that Increase Employability (LPIE) |
List of Approved LPIEs website at: https://www.cdss.ca.gov/inforesources/CalFresh-resource-center/policy. |
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