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    "title": "Food Stamps [2]",
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    "ocrText": "27\n1.\nWorkfare\nRecipients may receive food stamps beyond three months if they are participating in either\na food stamp workfare program or a \"comparable\" state or local workfare program. Unlike most\nemployment and training components, workfare slots need not require 20 hours per week of\nactivity to allow participants to receive food stamps without regard to the three-month limit.\nUSDA policy guidance to the states confirms that workfare for single individuals \"imposes a\nmuch lower hourly obligation than 20 hours per week.\"87\nThe number of hours a recipient is required to work in a month under a food stamp\nworkfare program is determined by dividing his or her food stamp benefit level by a wage rate,\ntypically the minimum wage. 88 In food stamp workfare, the federal minimum wage is used unless\nan applicable state minimum wage is higher. Assuming no applicable state minimum wage, a\nsingle person receiving the maximum food stamp allotment of $120 per month would have to\nwork 25 hours - or about three full days - per month. Recipients eligible for smaller allotments,\nand those in areas where higher minimum wages apply, would be required to work fewer hours.\nFurthermore, because the legislation does not require that state and local workfare programs\nfollow the formula for food stamp workfare, state and local governments could allow recipients to\nwork off their benefits at a rate somewhat higher than the applicable minimum wage.⁹\n877 U.S.C. §§ 2015(o)(2)(C) and (5)(A)(iii), as added by Pub. L. 104-193, § 824(a). USDA's August 26, 1996,\nimplementing memo to states failed to note this distinction, but subsequent USDA communications have confirmed\nthat the applicability of the usual formula for determining the hours of obligation in workfare. Memo of Arthur T.\nFoley, Director, Program Development Division, Food Stamp Program, FCS, USDA, p. 8 (November 12, 1996);\nMemo from Arthur T. Foley (November 7, 1996).\nAlthough food stamp workfare is likely to be the most common program with less than 20 hours per week\nof activity that states will offer to allow recipients to continue receiving food stamps beyond the three-month limit,\nit is not the only such option available to states. In two other instances, programs that states can support with food\nstamp E&T funds can confer exemptions on recipients without requiring 20 hours per week of activity. As\ndiscussed above in sections V(A) and VI(B)(2), half-time enrollment in an education or training program will\nrender a recipient exempt from the time limit even though it is not technically considered a \"work slot\" under the\ntime limit provision. Similarly, enrollment in a bona fide substance abuse confers an exemption without regard to\nthe number of hours of treatment provided. See section V(A) above.\n887 U.S.C. § 2029(a)(1); 7 C.F.R. § 273.22(e)(2).\n⁸⁹Food stamp workfare is described in section 20 of the Food Stamp Act (7 U.S.C. § 2029). The requirement that\nthe number of hours of obligation be determined by dividing the recipient's benefit amount by the minimum wage\nis found at 7 U.S.C. § 2029(a).\nThe law does not define what it means by \"a comparable program established by a State or political subdivision\nof a State.\" See 7 U.S.C. §§ 2015(o)(2)(C) and (5)(A)(iii), as added by Pub. L. 104-193, § 824(a). It is difficult,\nhowever, to see how the use of a modestly different wage rate for the work performed would make the program not\n\"comparable\" to food stamp workfare. A state or local government might, for example, choose to calculate a\nrecipient's hours of obligation based on the prevailing wage for the type of work being performed, rather than on\nthe minimum wage."
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