To determine whether an individual meets an exemption from time-limited benefits, first the CAO must determine whether they are outside the PEER age range or live in a geographically waived area. eCIS will assign an eligibility status code based on the address and date of birth.
|
Status Code |
Name |
Use Case |
|
NM |
Non-Eligible Member |
An individual that is not included in the SNAP household. This includes, but is not limited to, a PEER who is ineligible for SNAP because they have exhausted their three months of time-limited benefits and are not exempt, meeting the work requirement, or living in a geographically waived area. |
|
EM |
Eligible Member |
An individual who is under age 18 or age 65 or older and thus is not subject to time-limited benefits. |
|
EW |
Eligible Waived Adult |
An individual who is between age 18 and 64 but resides in a geographically waived area and thus is not subject to time-limited benefits. |
|
EB |
Eligible Non-Waived Adult |
An individual who is between age 18 and 64 who is subject to time-limited benefits unless exempt or meeting the federal PEER work requirement. |
The CAO must assign individuals a SNAP Qualification code (Qual Code) in eCIS to indicate whether they are exempt from the PEER time limit, meeting the federal work requirement, or neither.
The CAO must assign the first applicable Qual Code in the list below:
| Qual Code | Exempt? |
|
Description | Use Case | |
| 22 | Yes | N/A | Resides in a SNAP household with a child under age 14 |
A child under 14 lives in the same SNAP household as the individual. |
|
| 02 | Yes | N/A | Disabled or receives federal or state disability. |
Individual receives Social Security Disability, SSI, VA Disability (10% or higher rating), disability-related MA for which they are certified by the state MRT, an employer disability pension, or any other temporary or permanent disability benefit issued by a governmental or private source; or NOTE: Veteran’s disability must be for the veteran themselves, not a survivor. The exemption applies for both pensions and disability payments and is only applicable for SNAP PEER purposes. Individual is participating in a substance use disorder (SUD) program |
|
| 03 | Yes | N/A | Meets federal E&T exemption codes 04, 12, 14, 17, 20, or 21 |
See: Chapter 535.3. |
|
| 04 | Yes | N/A | Pregnant |
Individual is pregnant (any trimester). |
|
| 10 | Yes | N/A | Unable to work as determined by DHS |
Assign Qual. Code 10 without requiring additional verification if:
Assign Qual Code 10 if:
NOTE: This can include, but is not limited to situations where an individual is suffering from addiction, but not regularly participating in a treatment program.
|
|
| 15 | Yes | N/A | Federally Recognized Native American |
Individual is a federally recognized:
“Urban Indian”;
“California Indian”
|
|
| 05 | No | Yes | Working at least 20 hours a week averaged monthly |
|
|
| 06 | No | Yes | Participating in an E&T approved activity except job search/prep (20 hours/week) |
Individual is meeting the work requirement through participation in a work program, or through a combination of work and a work program. See: Chapter 536.22 NOTE: Individuals meeting the work requirement by participating in the E&T community service activity using the special workfare hourly requirement are assigned Qual Code 07. |
|
| 07 | No | Yes | Participating in a workfare program |
Individual is meeting the work requirement by participating in the E&T community service activity using the special workfare hourly requirement. See: Chapter 536.22. |
|
| 16 | Yes* | No* | Expedited SNAP Pending Exemption or Work Verification |
Individual reported they are federally exempt or meeting the work requirement at application and are eligible for Expedited SNAP, but verification is pending. NOTE: Cannot be assigned if the applicant’s PEER Clock is already at 3. *NOTE: Individuals with Qual Code 16 are treated as exempt for the period covered by the expedited SNAP NCE.
|
|
| 09 | Yes | No | Meets state E&T exemption codes 15, 16, or 19. |
See: Chapter 535.3 |
|
| 11 | No* | No | PEER time limit expiration appeal |
Individual appeals the closure of benefits due to the PEER time limit and elects to keep receiving benefits pending the outcome of the appeal.
If the individual withdraws or loses their appeal, the CAO shall establish an overpayment for any full calendar months of benefits received in excess of the third countable month.
*NOTE: Qual Code 11 is not an exemption, however benefits will continue while the Qual Code is open.
|
|
| 20 | No | No | Does not meet an exemption or work requirement |
Individual who is not meeting the work requirement and to whom no exemption applies. |
|
| 21 | No | No* | Regained eligibility as designated in SNAP HB Section 536.25 |
Individual met the work requirement at some point after exhausting their initial three countable months but is no longer meeting the work requirement. May only be used once per fixed three-year period to authorize three additional countable months of benefits. See: Chapter 536.25 *NOTE: Qual Code 21 is used when an individual previously met the work requirements but is not currently meeting the work requirements. |
As long as an individual is exempt from or meeting PEER requirements, receipt of SNAP benefits is not limited to three months.
Examples:
A residence contains a mother and her children under age 14 who do not receive SNAP benefits. The mother’s 24-year-old brother moves in with the family. The brother applies and is found eligible for SNAP as a separate household due to buying and preparing meals separately. The brother does not meet the PEER exemption, because his sister’s children are not members of his SNAP household. He is subject to the three-month time limit.
A father applies for SNAP benefits for himself and his 13-year-old child in May for that month. The mother has custody of the same child during the school year and receives SNAP benefits in another county. The father has custody during the summer months. The father is claiming an exemption based on the age of the child. Because the child is already active with one parent in another SNAP household, the father cannot claim an exemption for himself. The father does not meet a PEER exemption and is subject to the three-month time limit.
A 30-year-old single woman applies for SNAP benefits. She states she is pregnant. This information is not questionable, so no verification is needed. This woman meets a PEER exemption based on her pregnancy and is not subject to the three-month PEER time limit.
NOTE: Additional examples for each exemption are available in the SNAP Work Requirements Desk Guide.
Screening PEERs
At application and renewal, the CAO must screen for and narrate all exemptions an individual meets, as well as if the individual meets the work requirement (see: Chapter 536.22). This ensures an individual is not incorrectly subjected to the PEER time limit resulting in the applicant losing their SNAP Benefits.
CAOs may optionally utilize the narrative generation tool in the SNAP Work Requirements Desk Guide to assist with this screening and narrative.
As part of the screening process, the CAO must provide a comprehensive verbal explanation of all applicable work rules to households which appear to include at least one work registrant (see: Chapter 535.3) and/or PEER.
The CAO must verbally explain the following to the household:
In addition, eCIS will centrally mail a consolidated written notice of work requirements (PA 772, PA 772.1, or PA 772.2) to each applicable household each time benefits are newly authorized or renewed.
Losing or Gaining an Exemption during the Certification Period
If an exempt PEER loses their federal exemption during the certification period, they are not required to report the loss of the exemption until renewal. If the individual reports the loss of exemption during the certification period, the CAO will narrate this information and allow the SNAP recipient to keep their current exemption code until renewal. The CAO will then re-screen the SNAP recipient for all possible exemptions at renewal. At renewal, the CAO must not retroactively add months to the PEER clock or otherwise backdate the PEER clock to the date the exemption was lost.
NOTE: Non-exempt SNAP recipients who stop meeting the work requirements during the certification period are required to report that they stopped meeting requirements by the 10th day of the month following the month of change. Since this is a reportable change, the CAO must take action to start the PEER Clock at the time the change is reported, unless the recipient is also exempt.
A non-exempt PEER may report to the CAO that they have become exempt or started meeting the work requirement at any time. For newly reported exemptions, the CAO will stop the PEER clock effective starting the calendar month that the individual reported and (if necessary) verified the exemption. For individuals who newly report meeting the work requirement, the CAO will also retroactively remove countable months for any previous months for which work requirement compliance is verified.
NOTE: For exemptions or work participation reported after the issuance deadline date for a calendar month, the CAO will manually remove a month from the PEER clock for the month in which the report occurred (see: Chapter 536.11).
Verification of Exemptions
Most federal exemptions do not require verification from the CAO unless questionable. This applies to all federal exemptions except Disability (Qual Code 2), where verification must be requested if not available electronically, and Unable to Work (Qual Code 10), where verification must be requested if not available electronically and the inability to work is not obvious to the CAO.
For all other exemptions, the CAO will accept the individual’s statement unless questionable. If the individual’s statement is questionable, the CAO will review the eCIS case record and electronic data sources for previous verification prior to requiring the individual provide documentary verification.
The CAO may refer to the SNAP Work Requirements Desk Guide for examples of verification that may be accepted.
Employment and PEER status
For a PEER who is working in paid employment, the CAO must first verify the individual’s wages. If the recipient is earning wages greater than or equal to 30 times the federal minimum wage per week ($217.50), they are exempt from both work registration and the PEER time limit (ETP Code 17 and Qual Code 3).
If the PEER is earning wages less than $217.50 per week, the CAO must verify hours. In many but not all cases, hours may be reflected on the paystubs or other wage verification already provided by the individual. If the individual is working 30 or more hours per week, they are exempt from both work registration and the PEER time limit (ETP Code 17 and Qual Code 3). If the individual is working 20-29 hours per week and earning less than 30 times the minimum wage ($217.50), they are meeting the PEER work requirement (Qual Code 5).
Students and PEER status
Eligible students (see: Chapter 514.2) enrolled at least half-time in any recognized school, training program, or institution of higher education are exempt from work registration (ETP 20) and thus also exempt from the PEER time limit (Qual Code 3).
The exemption ends at the first SNAP application or renewal after a student’s graduation, suspension, expulsion, dropping out, or not intending to register at least half-time for the next normal school term. A student who was enrolled at least half-time during the spring term and intends to enroll at least half-time for the fall term continues to be exempt during summer vacation (see: Chapter 514.22).
Students enrolled less than half-time should be reviewed to determine if they meet any other PEER exemptions. Students who do not meet an exemption from the time limit should be encouraged to volunteer to participate in the SNAP E&T program through the KEYS or KEYS Expansion program, if appropriate (see: Chapter 535.1). Students who participate in SNAP E&T can count their class time and reasonable study time toward the 20 hour per week PEER work requirement (Qual Code 6). The CAO must advise students that volunteering to participate in SNAP E&T is one way to meet the work requirement.
Individuals living in geographically waived areas are exempt from the time limit for receipt of SNAP benefits. Waiver requests are submitted by the Bureau of Policy and the Bureau of Employment Programs and are subject to approval by the U.S. Department of Agriculture, Food and Nutrition Service (FNS). FNS may waive the time limit and work requirements for an area if it has been determined that the area has an unemployment rate of over 10 percent.
NOTE: When an individual resides in a geographically waived area, receipt of SNAP benefits is not limited to three months.
As of October 2025, no areas in Pennsylvania have an unemployment rate of over 10 percent. Therefore, no areas are currently waived. Appendix A contains the listing of previously geographical areas waived by FNS and the date the area became unwaived.
A PEER is meeting the federal work requirement if the individual meets one of the following:
NOTE: Participation in a job search or a job readiness and job preparation activity does not qualify as a primary activity but participation in these activities of up to 10 hours per week may be combined with participation in a different activity to meet an individual’s participation requirement.
As long as an individual meets the work requirement, the individual does not incur countable months and receipt of SNAP benefits is not limited to three months.
If an individual would have worked or participated in a work program an average of 20 hours per week (or if a household would have participated in community service for the required hours) but missed some work for good cause, the individual should be considered to have met the work requirement if the absence from work, the work program, or the community service placement is temporary and the individual retains his or her job. Good cause shall include, but is not limited to the following:
Circumstances outside the individual's control
Temporary illness or illness of another household member requiring the presence of the individual
NOTE: If the temporary illness is expected to last for more than one month, the CAO should review the individual for an unable to work exemption (Qual Code 10) or a caregiver exemption (Qual Code 3).
A household emergency
Transportation issues
Hours affected by an employer or program closing for a holiday or a break of no more than one month
Temporary closures of an employer or program due to inclement weather, emergencies, or government shutdowns
Each state is allotted PEER exemptions equal to 8 percent of the state’s SNAP caseload that is ineligible because of the PEER time limit. These "discretionary exemptions” (sometimes also referred to as “8% exemptions”) allow the state to extend SNAP eligibility to PEERs who would otherwise be ineligible because of the three-month time limit. See: Appendix B for a list of the current discretionary exemptions.
Regaining Ongoing Eligibility
PEERs who have exhausted their three countable months may regain ongoing eligibility at any time by:
7 CFR §§ 273.24(d)(1)(i)–(d)(1)(iii)
There is no limit to the number of times an individual may regain ongoing eligibility.
The CAO will assign the appropriate SNAP Qual Code to these individuals, depending on how they are (or will be) exempt or meet the work requirement (e.g., Qual Code 5 if the individual is meeting the work requirement through employment).
Individuals who are already meeting the work requirement may verify they have regained eligibility by providing paystubs or similar documentation showing they have met the work requirement in the most recent 30 days. The CAO may consider this as proof the individual will continue to meet the work requirement unless the CAO has other information that the individual will no longer meet the work requirement moving forward.
Individuals who have not yet met the work requirement but will do so within 30 days must provide verification as follows:
The CAO will advise the individual that they are required to report if they fail to actually meet the work requirement in the following 30 days, as well as if they stop meeting the work requirement at any point in the future.
If the individual does not meet the work requirement in the first 30 days after being re-opened, the CAO will close the case (or remove the individual from the household) and process an overpayment for the month the individual did not comply.
Exception: If an individual is referred to E&T and participates to some extent in the next 30 days, but does not meet the work requirement, the contractor will term the individual. The CAO will follow the process for provider determinations in OPS 23-08-04 and will not process an overpayment.
If the individual meets the work requirement in the first 30 days after being re-opened but later stops meeting the work requirement and does not meet any exemption, the CAO will review to determine if the individual regained eligibility on a one-time basis (see below).
Examples:
Regaining Eligibility on a One-Time Basis
A PEER who uses all three of their countable months, then starts meeting the PEER work requirement, but subsequently stops meeting the work requirement may be eligible for an additional three consecutive months of SNAP eligibility.
This additional three-month eligibility period:
Is coded as an EB-21
Cannot be used before the three countable months are exhausted (EB-20)
Is only available once within the three-year period
Must be used consecutively and issued as an NCE
NOTE: When reviewing an application for EB-21, the CAO must consider all months between the month the PEER used their last month of EB-20 and the month of application. If the PEER verifies that they met the work requirement in any such 30-day period (whether or not they were receiving SNAP at the time), they are eligible to regain eligibility under EB-21.
A PEER receives three months of time-limited benefits in March, April, and May. The benefits stop effective May 31 due to the time limit. On June 2, the PEER starts a new job and works 80 hours during the first two weeks in June. The job ends on June 16. On June 20, the PEER applies for SNAP and verifies the full 80 hours worked. If all SNAP eligibility factors are met, an additional three consecutive months of SNAP benefits (EB-21) may be authorized because the PEER worked 80 hours within a 30-day period but has since stopped meeting PEER requirements. This individual would be authorized as an EB-21 for the period from June 20 through September 30.
A PEER receives three months of time-limited benefits in March, April, and May. Benefits are stopped effective May 31 due to the time limit. The individual worked 40 hours per week from June 14 through August 1 and was laid off but found ineligible for unemployment compensation. The individual reapplies for SNAP on January 15 of the following year and is now unemployed. If all SNAP eligibility factors are met, an additional three consecutive months of SNAP benefits (EB-21) may be authorized because the PEER worked 80 hours within a 30 day-period, but has since stopped meeting PEER requirements. This individual would be authorized as an EB-21 for the period from January 15 through April 30.
Updated February 12, 2026, replacing January 6, 2026