Verification of Exemption

California elects not to require verification of exemptions for the student eligibility rule. Client statement that a student is exempt from the student eligibility rule on the application, during the interview, periodic report, recertification, or during the certification period is sufficient evidence that the student is exempt from the student eligibility rule.

Only one exemption is needed to qualify a student for CalFresh. The EW must document all exemptions being claimed in the case record. If the student loses an exemption, the EW must assess whether the student meets the criteria for another exemption before taking adverse action.

Important: While the student exemption is no longer a mandatory verification, income must be verified to determine the household's income eligibility for CalFresh.

EWs must only require verification that a student meets an exemption from the student eligibility rule when:

Information provided by the household is questionable; or
A student’s physical or mental unfitness claim is not evident to the EW.

Questionable Exemption

If an exemption is questionable, EW must follow the previous guidance for verifying student eligibility exemptions, including those listed in this section. Below are examples of questionable information for purposes of establishing an exemption from the student eligibility rule. This list is not intended to be exhaustive.

Criteria Exempting the Student	Examples of Questionable Information
Employed for an average of 20 hours per week or a total of 80 hours per month	The student does not have monthly gross income totaling the state minimum wage (or federal minimum wage if self-employed) multiplied by 80 hours, or wage stubs provided for income verification show the student working less than the required threshold
Parental control for a child under age 6	Another parent has claimed this exemption as the primary person responsible for the care of the child
Parental control for a child under age 12 without adequate childcare	Another parent has claimed this exemption as the primary person responsible for the care of the child, or the child has adequate childcare
Single parent responsible for a child under age 12	There are two of the child’s natural, adoptive, or step-parents in the same CalFresh household as the child
Part of a CFET program	The County does not have a record of the student participating in CFET
Program to increase employability	The program the student mentions is not on the LPIE listed on the CDSS website
Receipt of TANF-funded benefits like CalGrant A/B	The student provides a complete list of financial aid awarded as part of income verification, and Cal Grant A or B is not listed.
Approved for work study and anticipates working (only applicable after the Temporary Eligible for Work Study exemption ends	The student states they do not expect to accept a work study job offer
Temporary: Eligible for work study	The student provides an income verification document that indicates the student is not eligible for work study

The EW must document in the case record what exemption is being claimed. If a student’s statement that they meet an exemption from the student eligibility rule is questionable and verification is requested, the reason must be adequately documented in the case record as to why the information was deemed questionable, and that verification was requested.

The following are suggested verifications for specific programs if questionable:

Approved for State or Federal Work Study

This exemption is partially based on a student being approved for work study for the current term, as defined by the institution of higher education. Acceptable verification of approval for work study may include a work study award letter from financial aid, but it is not limited to this.

Receipt of Cal Grant A or B

Verification of receipt of a Cal Grant A or B may include but is not limited to, a copy of a student’s California Aid Report, which is an award letter provided by the California Student Aid Commission and/or a printout of award confirmation from a student’s college or university web grants account.

For purposes of verifying whether a Cal Grant A or B recipient meets two of the three TANF Cal Grant eligibility requirements outlined, including currently unmarried and 25 years of age or younger, the EW may reference existing case information.
To verify whether the student meets the third requirement, parental and/or student income of $50,000 a year or less, counties should reference the student’s California Aid Report (provided by the student), which includes information regarding parental and/or student income at the time the student was deemed eligible for the Cal Grant A or B.

Participation in a Program to Increase Employability

Verification of participation in a program to increase employability may include, but is not limited to, a formal document showing participation in one of the programs listed above or a printout from a student’s college or university web-based account indicating participation in such a program.

Local Programs that Increase Employability (LPIEs) Approved by the State

AB 396, signed into law on October 4, 2021, requires all CCC and CSU campus-based programs that meet LPIE requirements to submit an application to the CDSS on or before September 1, 2022, and requests UC programs to do the same. SB 609, signed into law on October 6, 2021, requires CDSS to include Adult Education and CTE programs in the List of Approved LPIEs.

Process for Identifying LPIEs

Counties will no longer participate in identifying or approving campus-based LPIEs. Colleges must identify and submit their LPIE programs that contain the equivalent of an E&T component. The CHC, a CalFresh outreach prime contractor out of Chico State University, will assist campuses in identifying and submitting LPIEs.

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: https://www.cdss.ca.gov/inforesources/CalFresh-resource-center/policy.

The list is accessible from Program Bureau/CF Reference Materials/EW Resources/CF Student Eligibility: List of Approved Local Programs that Increase Employability.

General Programs Identified

In addition to individual LPIE program identification, the CCCs, CSUs, and UCs have identified two general programs that meet the LPIE criteria. Students from all campuses may participate in one or both of the general programs below.

Campus Employment Program: Students employed by their campus or a recognized auxiliary organization are considered to be participating in a Campus Employment Program. For LPIE purposes, an auxiliary organization must be overseen by the CCC, CSU, or UC and must serve the institution of higher education. Students enrolled in this program do not need to work an average of 20 hours per week or 80 hours per month to meet the criteria for an exemption to the student eligibility rule, as LPIEs do not have a minimum hour requirement.
Research and Teaching Assistantship Program: Students hired for a research or teaching assistant position, whether paid or unpaid or part of a training program, are considered to be participating in a Research and Teaching Assistantship Program.

Based on available student data, students may be notified by their campus of their enrollment in one of the above programs.

Removal of LPIEs at Private Institutions

Federal regulation requires that an LPIE be operated by a state or local government. Due to this requirement, previously approved programs that are not operated by a CCC, CSU, or UC are removed from the List of Approved LPIEs effective September 1, 2022.

Students receiving CalFresh due to being enrolled in a private school LPIE must remain exempt from the student eligibility rule for the length of the certification period. Student eligibility status must be reassessed during the student’s next recertification. At that time, the EW must evaluate the student’s circumstances to determine if they meet another exemption before determining whether the student is ineligible.

Verification of LPIE

To the greatest extent possible, students enrolled in an LPIE will be notified by their campus that they meet the criteria for an exemption from the student eligibility rule. 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. 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.