536.3 Certification Periods For PEERs

PEERs will be assigned a certification period based on their exemption and meeting work requirement status, how many months of benefits they’ve already used, and whether they have countable income.

NOTE: Households which would normally be assigned a three-month certification period or receive a one- or two-month NCE which ends in the final month of the three-year period (e.g., December 2026) will receive a certification period that ends in the third month of the subsequent three-year period (e.g., March 31, 2027).

At renewal, the CAO must rescreen all PEERs to determine if they had a change in circumstances that may result in their time-limited benefit eligibility status changing. Such changes would include meeting any exemptions, meeting work requirements, or moving to a waived area. See: Chapter 536.2.

Mixed PEER/non-PEER households may have a certification period end date that does not align with the PEER’s third countable month of eligibility.  In this case, the CAO will receive an ABWD 233 alert after the issuance deadline date for the second countable month of benefits for the PEER member.  The CAO must attempt to reach out to the household to determine whether the PEER now meets an exemption or the work requirement, as well as whether the PEER is responsible for or paying for the household’s shelter costs.  Based on the results of this outreach, the CAO must either update the PEER’s ETP and Qual Code or enter an exclusion code for the PEER member(s) after the issuance deadline date for the third countable month of benefits.

536.31 Reporting Requirements for PEER-Only Households

PEERs who are not exempt, meeting work requirement, or waived

PEER-only households assigned a three-month certification period will not be enrolled in semi-annual reporting (SAR).  Therefore, they will have different reporting requirements than those households enrolled in SAR.  A PEER-only household is considered a change-reporting household.  These households must report the following:

• Any change in the wage rate or salary; or
• A change in full-time or part-time employment status; or
• Their work hours fall below 80 per month or an average of 20 hours weekly.

These households must report these changes by the 10^th day of the month following the month of the change.  Households must be informed of this reporting requirement at the time of application interview.  Reporting requirement language has also been added to the eligibility notices.

SNAP recipients who are exempt, meeting work requirements, and/or waived

Households assigned a six- or twelve-month certification period because all members are exempt from, meeting, or waived from the PEER work requirement will be enrolled in semi-annual reporting (SAR).  They will be required to report the following:

• When income exceeds 130 percent FPIGs.
• When a non-exempt individual’s work hours fall below 80 hours per month.

These households must report these changes by the 10^th day of the month following the month of change.

However, these households are not required to report the loss of a federal exemption during the certification period.  This is only required to be reported at renewal.

If an individual reports losing a federal exemption during their 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.

NOTE: This policy also applies to SNAP recipients who, at the time of their most recent application or renewal, were working 30 or more hours per week or earning at least 30 times the minimum wage per week ($217.50 per week), since these recipients are considered exempt (ETP 17/Qual Code 3).

When a non-exempt PEER or a PEER receiving a discretionary exemption reports that they have gained a federal exemption during their certification period, the CAO must apply the exemption starting in the month the individual reports the new exemption or (if the exemption was questionable) the date the exemption is verified.  In some instances, this might require a retroactive adjustment to remove the month the exemption was reported in from the individual’s PEER clock (see: Chapter 536.11).

536.32 Reporting Requirements Mixed PEER Households

A mixed PEER/non-PEER household will be enrolled in SAR.  They will be required to report the following:

• When income exceeds 130 percent

• When the PEER's work hours fall below 80 hours per month.

NOTE:  These households must report changes by the 10^th day following the month of change.

Households must be informed of this reporting requirement at the time of application interview. 

536.33 Verification

Meeting the Work Requirement

The CAO must verify the work hours of individuals who are subject to the SNAP time-limits and who are satisfying the work requirement by working or participating in SNAP E&T, a Workforce Innovation and Opportunity Act program (WIOA), a Trade Adjustment Assistance Act program (TAA), a program of employment and training for veterans operated by the Department of Labor or the Department of Veteran Affairs, or community service.

7 CFR § 273.24(b)(6)

7 CFR §273.2(f)(1)(xiv)(A)

PEERs who are working must verify they are meeting the hourly requirement at application and recertification.  The CAO must first determine whether the verification shows that the individual is exempt due to receiving wages of 30 times the minimum wage or more per week ($217.50 per week).  If not, the CAO must then determine whether the verification shows that the individual is meeting the work requirement due to working 20 or more hours per week.

PEERs participating in a SNAP E&T program must be referred to a SNAP E&T contractor (see: Chapter 535, Appendix B), who will track their hours monthly in the Commonwealth Workforce Development System (CWDS), which will synchronize with the Activity Tracking Screen in eCIS.  PEERs participating in a community service program may also optionally choose to be referred to a SNAP E&T contractor to track their hours.  PEERs may verify their participation in community service to the contractor by submitting the PA 1938.

PEERs participating in other eligible work programs (e.g., WIOA, TAA) must verify their hours with the CAO at application and renewal. The PA 1895 may be used to verify the employment and training activities.

PEERs participating in a community service program who elect not to participate through a SNAP E&T contractor should be enrolled in a CAO-Directed Project (SA) on the Project Enrollment Screen in eCIS.  The PEER may verify their participation by submitting the PA 1938 to the CAO. The CAO must enter these hours on the Activity Tracking Screen in eCIS.

The PA 1938, Community Service Volunteer Verification Form, is valid verification of the PEER’s participation in community service until the earliest of:

• The Expected End Date of Service listed on the form;
• The date the organization coordinating the community service reaches out to the CAO or E&T contractor to report that the PEER has discontinued participation in community service; or
• Six months from the date the form is signed.

PEERs who stop participating in an E&T program receive a provider determination (see OPS 23-08-04).  Individuals are not subject to the PEER time limit during the calendar month in which the CAO receives the ASAP 156 alert.  However, the PEER will begin incurring countable months starting the next full calendar month unless they meet the work requirements, live in a waived area, or are otherwise exempt. 

Countable Months

The CAO must verify at application, for individuals subject to the time limits, the number of countable months an individual has used in another state if there is an indication that the individual participated in another state.  The CAO may accept another state agency’s statement as to the number of countable months an individual has used in that state and when.  The CAO may utilize the National Directory of Contacts to reach out to other states to request this verification.

It is not sufficient for the CAO to request the number of countable months benefits were received in the other state.  The CAO must request which actual months benefits were received in the other state.  This ensures the CAO will be able to accurately count the months used within Pennsylvania’s current three-year period.

Example:

Cindy, a non-exempt PEER, applies for SNAP on October 1, 2025 and is found not entitled to expedited SNAP.  During her interview, she reveals that she recently moved from Alabama to Pennsylvania and closed out her Alabama case record. The CAO obtains an email address for Alabama DHR from the National Directory of Contacts and requests verification that Cindy’s case record has closed and how many countable “ABAWD” months she has used.  Alabama DHR responds that, while Cindy has not received time-limited SNAP benefits during Alabama’s current three-year period of 1/1/25 – 12/31/27, she did receive three months of time-limited SNAP in November and December of 2023 and January of 2024. Since Pennsylvania’s three-year period is from 1/1/24 – 12/31/26, Cindy has used one countable month (January 2024).  The CAO submits a ServiceNow ticket to manually increase Cindy’s PEER clock from 0 to 1, then processes a two-month NCE for October and November 2025.

7 CFR §273.2(f)(1)(xiv)(B)

Reissued January 6, 2026