	Introduction

The Supplemental Nutrition Assistance Program (SNAP) provided food assistance to a monthly average of 40.3 million persons in 20.1 million households in FY2018. While much of the FY2007 to FY2013 increase in participation and costs was attributable to the poor economy, states during this period also increasingly adopted more expansive "categorical eligibility" rules—a set of policies that make a SNAP applicant eligible based on the applicant's involvement with other low-income assistance programs: benefits from the Temporary Assistance for Needy Families (TANF) block grant, Supplemental Security Income (SSI), and state-financed General Assistance (GA) programs. The Agriculture Act of 2014 (2014 Farm Bill, P.L. 113-79 ) made no changes to SNAP categorical eligibility rules. The House-passed version of the bill that became the 2014 Farm Bill would have eliminated "narrow" and "broad-based categorical eligibility," retaining only "traditional" categorical eligibility for recipients of cash assistance. However, the House-passed provision was not included in the bill's conference agreement. The most recent farm bill, Agriculture Improvement Act of 2018 ("2018 Farm Bill," P.L. 115-334 ) made no changes to SNAP categorical eligibility rules. The House-passed version of the bill would have made changes to limit but not eliminate broad-based categorical eligibility. These changes were not included in the conference agreement. There are two basic pathways to gain financial eligibility for SNAP: (1) having income and resources below specified levels set out in federal SNAP law; and (2) being "categorically," or automatically, eligible based on receiving benefits from other specified low-income assistance programs. They then have their SNAP benefits determined. A household's SNAP benefit amount is based on the maximum benefit (which varies by household size) and its net countable income after deductions for certain expenses. The Food Security Act of 1985 conveyed categorical eligibility to all households receiving cash aid from Aid to Families with Dependent Children (AFDC), SSI, or state-run GA programs. That law ended AFDC, replacing it with TANF. AFDC was a traditional cash assistance program. This expansion of authority under TANF had major implications for categorical eligibility, allowing states to convey categorical eligibility based on receipt of a wide range of human services rather than simply cash welfare. However, the 1996 welfare reform law's creation of TANF as a broad-based block grant has allowed for a state option to include a long list of benefits/services that can convey SNAP eligibility. This section discusses state choices in this area as of October 2018. These states have expanded categorical eligibility beyond just traditional categorical eligibility, but in a way to limit the number of households made eligible for SNAP. "Broad-Based" Categorical Eligibility Practices

Broad-based categorical eligibility is a policy that makes most households with incomes below a certain threshold categorically eligible for SNAP. Typically, households are made categorically eligible through receiving or being authorized to receive a minimal TANF- or MOE-funded benefit or service, such as being given a brochure or being referred to a social services "800" telephone number (see Table 1 ). Note, though, currently in 13 of these jurisdictions, households with an elderly and disabled member with incomes in excess of 200% of the federal poverty guidelines have to meet the regular SNAP asset tests of $3,500 for households of that type); 6 states (Idaho, Indiana, Maine, Michigan, Nebraska, and Texas) apply an asset test for all households); and 33 have a gross income limit above 130% of the federal poverty guidelines. (As discussed above, it is still possible to be categorically eligible but receive no benefit because net income is too high. ) In the Fall 2018 Unified Agenda, the Administration stated that it plans to publish a proposed rule "pertaining to categorically eligible TANF households by limiting categorical eligibility to households that receive cash TANF or other substantial assistance from TANF." As of the date of this report, the proposed rule has not yet been published.
The Supplemental Nutrition Assistance Program (SNAP) provides benefits to low-income, eligible households on an electronic benefit transfer (EBT) card; benefits can then be exchanged for foods at authorized retailers. SNAP reaches a large share of low-income households. In FY2018, a monthly average of 40.3 million persons in 20.1 million households participated in SNAP.
Federal SNAP law provides two basic pathways for financial eligibility to the program: (1) meeting program-specific federal eligibility requirements; or (2) being automatically or "categorically" eligible for SNAP based on being eligible for or receiving benefits from other specified low-income assistance programs. Categorical eligibility eliminated the requirement that households who already met financial eligibility rules in one specified low-income program go through another financial eligibility determination in SNAP.
In its traditional form, categorical eligibility conveys SNAP eligibility based on household receipt of cash assistance from Supplemental Security Income (SSI), the Temporary Assistance for Needy Families (TANF) block grant, or state-run General Assistance (GA) programs. However, since the 1996 welfare reform law, states have been able to expand categorical eligibility beyond its traditional bounds. That law created TANF to replace the Aid to Families with Dependent Children (AFDC) program, which was a traditional cash assistance program. TANF is a broad-purpose block grant that finances a wide range of social and human services. TANF gives states flexibility in meeting its goals, resulting in a wide variation of benefits and services offered among the states. SNAP allows states to convey categorical eligibility based on receipt of a TANF "benefit," not just TANF cash welfare. This provides states with the ability to convey categorical eligibility based on a wide range of benefits and services. TANF benefits other than cash assistance typically are available to a broader range of households and at higher levels of income than are TANF cash assistance benefits.
As of October 2018, 43 jurisdictions have implemented what the U.S. Department of Agriculture (USDA) has called "broad-based" categorical eligibility. These jurisdictions generally make all households with incomes below a state-determined income threshold eligible for SNAP. States do this by providing households with a low-cost TANF-funded benefit or service such as a brochure or referral to a telephone hotline. There are varying income eligibility thresholds within states that convey "broad-based" categorical eligibility, though no state has a gross income limit above 200% of the federal poverty guidelines. In all but six of these jurisdictions, there is no asset test required for SNAP eligibility. Categorically eligible families bypass the regular SNAP asset limits. However, their net incomes (income after deductions for expenses) must still be low enough to qualify for a SNAP benefit. That is, it is possible to be categorically eligible for SNAP but have net income too high to actually receive a benefit. The exception to this is one- or two-person households that would still receive the minimum benefit.
Neither the Agriculture Act of 2014 ("2014 Farm Bill," P.L. 113-79) nor the Agriculture Improvement Act of 2018 ("2018 Farm Bill," P.L. 115-334) made changes to SNAP categorical eligibility rules. In the 113th Congress, the House-passed version of the 2014 law would have eliminated broad-based categorical eligibility, but that change was not included in the conference agreement. In the 115th Congress, the House-passed version of the 2018 law would have made changes to limit but not eliminate broad-based categorical eligibility; these changes were not included in the conference agreement.
In the Fall 2018 Unified Agenda, the Trump Administration included plans to publish a proposed rule that would amend SNAP categorical eligibility rules. As of the date this report, this proposed rule has not yet been published.