Benefits eligibility for citizens of freely associated states

Effective March 9, 2024, citizens of the Compact of Free Association states of Micronesia, Palau, and the Marshall Islands are eligible for federal Supplemental Nutrition Assistance Program benefits (CalFresh in California).  This population is not subject to a waiting period and is immediately eligible for benefits.

State agencies must verify the immigration status of this population using the Systematic Alien Verification for Entitlements (SAVE) system.

Members of this population who applied for Supplemental Nutrition Assistance Program benefits on or after March 9, 2024 and were denied may reapply to be determined eligible from the date of reapplication.  In addition, people who applied and were denied can request a hearing within 90 days of the denial[1] and if the Administrative Law Judge determines that the household was eligible at the time of application, benefits can be issued retroactive to the date of application.

As a best practice, states should track members of this population who were denied benefits on or after March 9, 2024 and do outreach to encourage them to reapply or request a hearing.

Citizens of the Compact of Free Association states of American Samoa and the Northern Mariana Islands remain ineligible for Supplemental Nutrition Assistance Program benefits.   (FNS Memo, July 12, 2024.)

The California Department of Social Services has now issued a policy that mirrors the FNS memo except that when the date of denial is within 30 days, counties must reopen the application and process it in accordance with the new rules.  (ACL 24-61, August 21, 2024.)

NOTE:  Citizens of the Compact of Free Association states of Micronesia, Palau, and the Marshall Islands are now also eligible for Medicaid.  (P.L. 118-42, Section 209(f)(1).)

[1] In California, that 90 day deadline can be extended to 180 days for good cause, and the 90 time limit does not begin to run if the denial notice does not meet legal requirements.