SNAP Work Requirements and Participation in Office of Refugee Resettlement Training Programs

Policy Letter 16-08

Publication Date: July 15, 2016

July 14, 2016

SUBJECT: Refugee Training Programs

TO: All Program Directors / Food Stamp Programs

The purpose of this memorandum is to clarify that refugee training programs approved, funded, or operated by the Office of Refugee Resettlement, Administration for Children and Families, Department of Health and Human Services, are Federally recognized training programs. In accordance with sections  6 (d) (2) (C) and 6 (o) (3) (D) of  the Food Stamp Act of 1977, as amended, participants in these programs at least half time are exempt from Food Stamp Program work requirements and time limits.

On February 21, 1997, this office issued policy guidance concerning individuals in refugee training programs. That guidance established that able-bodied adults without dependents (ABAWDs) participating in a recognized refugee training program at least half time are exempt from the ABAWD time limit. Such participants are not exempt as refugees per se, but as students enrolled half time in a recognized training program.

What is considered a “recognized” program is not specifically defined by law or regulation.  However, the legislative history of the Food Stamp Act shows that Congress intended that any school or program recognized by a Federal agency is considered recognized for the purpose of establishing exemptions from the work requirement (Page 157 of the House Report on the Food Stamp Act of 1977 (Report No. 95-464), dated June 24, 1977). Programs approved, funded, or operated by the Office of Refugee Resettlement are clearly "recognized" by a Federal agency within this context. We hope this clarification is useful. If you have any questions please contact Gini Gerbasi at (703) 305-2764.

Arthur T. Foley
Program Development Division

SUBJECT: SNAP Work Requirements and Participation in Office of Refugee Resettlement Training Programs

TO: Regional Directors
       Supplemental Nutrition Assistance Program All Regions

       State Refugee Coordinators
       National Voluntary Agencies
       Other Interested Parties

The Food and Nutrition Service (FNS) issued the attached 1997 policy memo explaining that individuals enrolled at least half-time in a training program approved , funded, or operated by the Office of Refugee Resettlement (ORR) are exempt from both the general Supplemental Nutrition Assistance Program (SNAP) work requirements and therefore also the time limit for able-bodied adults without dependents (ABA WDs). FNS is reissuing the 1997 memorandum to affirm that this policy still stands, provided that these individuals are otherwise eligible for SNAP. FNS and ORR encourage State SNAP agencies and ORR agencies to freely collaborate and coordinate on individual cases in order to allow State SNAP agencies to verify the applicability of this exemption in SNAP eligibility determinations.

This guidance is being provided because FNS has recently received questions from State agencies on how to consider participation in an ORR training program in relation to SNAP work requirements.

Please share this guidance with your respective SNAP State agencies and ORR agencies.  State SNAP agencies may contact their respective FNS Regional Office with any questions and for technical assistance. FNS Regional Offices should contact Jessica Dziengowski at with any questions concerning this memorandum.

Lizbeth Silbermann
Program Development Division
Supplemental Nutrition Assistance Program

Robert Carey
Office of Refugee Resettlement

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