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Column 1DescriptionAdministering EntityImpacted?Risk - Difficult to get back or to cover with cashProgram DetailsProtections Mechanisms Identified / UsedPilot Waiver / Protection HistoryClear pathway for protection?Considerations / Actions for benefit counseling
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Children's Health Insurance Program (CHIP) Provides health coverage to children in families with low to moderate incomes.Typically the State Department of Human Services, sometimes the State Health DepartmentNo?NoneEach state has the option to cover its CHIP population within its Medicaid program, design and structure a separate CHIP program, or establish a combination program using both options. Using CHIP funding, states can opt to provide coverage for pregnant women and/or services through the “unborn child” coverage option.

For information about your State's program, visit: https://www.nashp.org/all-states-chip-fact-sheets

CHIP programs located under a State's Medicaid program use MAGI (Modified Adjusted Gross Income) to calculate household income. These programs have no risk as non-taxable income (gifts) & resources are not counted as part of the eligibility determination. **This assumes that the pilot has structured their GI payments as gifts according to the IRS gift definition. Any income that is reported on taxes will be counted for MAGI programs.

*Note - In the States, CHIP is under MAGI methodologies for calculation; however this may not be true everywhere and depend on how the State sets up the program.
Guidance on Medicaid, Medicare, CHIP waivers during COVID-19 and natural disasters - here
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Earned Income Tax Credit (EITC) & Child Tax Credit (CTC)Refundable tax credit given for
low-income individuals and
families with children during tax
filing who earned low or moderate
income in a given year.
YesLow- Given DCA is usually targeted towards low-income households, it’s unlikely it will push households over the limit for EITC or CTC.

- There is potential value of counting GI as earned income which is that potential earned income tax credit (EITC) may increase more substantially than the increase in tax on the GI income, a double benefit for recipients. This is most likely impactful amongst those with multiple dependents, versus single recipients, and where other benefits tied to income are not lost (offsetting the gains) - and those eligible for EITC.
“Gifts” below 17k/year are not taxable income. EITC uses federal taxable income in their means-testing.“Gifts” below 17k/year are not taxable income. EITC uses federal taxable income in their means-testing.
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Federal Pell GrantsProvides need-based grants to low-income undergraduate and certain post-baccalaureate students to promote access to postsecondary education.Department of EducationUnknown- Must denote waivers for both a student or a parent receiving unearned income.
- Losing other benefits linked to FAFSA could reduce or eliminate Pell/Federal Aid. Gift aid should not be counted within adjusted gross income for FAFSA but could have indirect effects if caused to lose other benefits.
- Tied to Medicaid, SNAP, & SSI eligibility for “zero expected financial contribution”
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Free & Reduced school lunch programProvides free and reduced school lunches to children from low-income families.State Department of Human ServicesYesModerateChildren from families with incomes at or below 130% of the poverty level, and children in families receiving TANF or SNAP benefits are eligible for free lunches. Children in families whose income is between 130% and 185% of the poverty level are eligible for reduced price lunches.See SNAP protection mechanism outlined below.
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General AssistanceProvides cash and other services for eligible persons.Depends on state - could be state agency or could be local governmentYesHighNot all states offer General Assistance. The income and resource limits for eligibility can vary. The program typically considers unearned income when determining eligibility and payment amount. Individuals may be required to exhaust other possible sources of income/benefits before receiving GA.
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Head Start / Early Head StartPromotes the school readiness of infants, toddlers, and preschool-aged children from low-income families. Services are provided in a variety of settings including centers, family child care, and children’s own home.U.S. Dept. of Health and Human Services; The Administration for Children and FamiliesYesMixedHead Start funding flows directly from the federal government to local grantees and grantees determine whether children are eligible for services based on their family income or other circumstances in accordance with federal requirements.

Eligibility for Head Start / Early Head Start is determined at point of program intake. Head Start eligibility continues for two years and Early Head Start eligibility lasts while a child or pregnant woman is participating in the program. Income eligibility is only redetermined when a child transitions from Early Head Start to Head Start. Therefore, additional income received while participating in the program will not affect program eligibility.
As to whether payments received during the year would affect initial eligibility, first note that under certain circumstances, Head Start / Early Head Start eligibility can be determined without regard to an income determination. Specifically, children are eligible for participation if their families’ incomes are below the poverty line, or in the following circumstances:
- Their families are eligible for public assistance, or
- They are in foster care, or
- They are homeless.
Thus, if families are eligible for public assistance in the state, they could qualify for Head Start / Early Head Start even if the study’s payments increase the family’s income level above the federal poverty line.

If an income determination is needed, the question that would need to be determined is whether these payments fall within the definition of income that must be included for Head Start purposes. The Head Start Program follows the Internal Revenue Service’s (IRS) definition of income. Thus, if the IRS counts the study’s cash payments as income, then Early Head Start and Head Start programs would have to take the additional income into consideration when determining a child’s eligibility if it was received BEFORE their participation in Head Start or while transitioning from Early Head Start to Head Start. Note that there is no asset test for purposes of Head Start or Early Head Start.
For all programs for which it is up to the State to define income and determine whether to impose an asset limit, it is important to note that whether the exclusion of income or assets above set limit(s) is determined by executive or legislative action is a matter of state, not federal law, so it may vary across the study states.
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Low Income Home Energy Assistance Program (LIHEAP)Assistance to low-income families to pay the costs of home energy consumption. States have discretion regarding directing funds to different priorities.Typically the State Department of Human ServicesYesLowMust meet income limits based on household size. Income thresholds can be determined by the State but must be capped at either 150% of the Federal Poverty Guideline or 60% of State Median Income (or a combination of these depending on household size). Gross income is used as basis for eligibility.
Cash gifts are considered countable income. States have discretion to implement categorical eligibility for some groups, such as SNAP, TANF, SSI recipients, etc.
Typically applications are only open for certain periods of the year. Payments are issued directly to vendors providing the service.
State has discretion with income limits; could choose to exclude GI income depending on how their LIHEAP plan is set up. Some states publish their plan on their LIHEAP program page.

If no action by the State, pilot participants who are over the income limit wait could apply for their next grant once their GI payments have been completed. Individuals who remain categorically eligible can apply during participation in the pilot.
- PA DHS agreed to exclude GI payments from LIHEAP applications.

- Helpful FAQ from HHS: States have discretion for categorical eligibility with Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Food Stamps, or certain needs-tested veteran benefits.
- “The statute does not define what items or sources of funds are to be counted as income. It is up to the state to determine what it will or will not count as income. As a general rule, states treat Social Security benefits as income for purposes of determining eligibility for LIHEAP assistance. Since some Federal program benefits cannot be counted as income, grantees may need to check with those programs when determining what to count as income.”
If DHS agrees to exclude GI payments, share that there will be no impact to participants.

If DHS does not agree to exclude GI payments, show participants the income limits and suggest that they wait to apply for their next grant until after their GI payments have been completed if these will put them over the income threshold. Individuals who remain categorically eligible can apply during participation in the pilot.
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Low-Income Household Water Assistance Program (LIHWAP)Helps residents pay their water and wastewater bills. States have discretion regarding directing funds to different priorities.
Typically the State Department of Human ServicesYesLowMust meet income limits based on household size. Income thresholds can be determined by the State but must be capped at either 150% of the Federal Poverty Guideline or 60% of State Median Income (or a combination of these depending on household size). Gross income is used as basis for eligibility. Cash gifts are considered countable income. States have discretion to implement categorical eligibility for some groups, such as SNAP, TANF, SSI recipients, etc.
Typically applications are only open for certain periods of the year. Payments are issued directly to vendors providing the service.
State has discretion with income limits; could choose to exclude GI income depending on how their LIHWAP plan is set up. Some states publish their plan on their LIHWAP program page.

If no action by the State, pilot participants who are over the income limit wait could apply for their next grant once their GI payments have been completed. Individuals who remain categorically eligible can apply during participation in the pilot.
- PA DHS agreed to exclude GI payments from LIHEAP applications.If DHS agrees to exclude GI payments, share that there will be no impact to participants.

If DHS does not exclude GI payments: Show participants the income limits and suggest that they wait to apply for their next grant until after their GI payments have been completed if these will put them over the income threshold. Individuals who remain categorically eligible can apply during participation in the pilot.
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MedicaidMedicaid is a program that helps pay for medical services for low-income individuals. State and federal money is used to pay for services.Typically the State Department of Human Services, sometimes the State Health DepartmentMixedMixedIncome limits and the manner in which countable income is determined (i.e. income calculation methodology) vary by eligibility groups. Resource limits vary by eligibility groups.

No Risk: Individuals who qualify for Medicaid through a MAGI (Modified Adjusted Gross Income) program have no risk as non-taxable income (gifts) & resources are not counted as part of the eligibility determination. **This assumes that the pilot has structured their GI payments as gifts according to the IRS gift definition. Any income that is reported on taxes will be counted for MAGI programs.

High Risk/Impacted: Aged, Blind, Disabled (ABD) Groups. Most unearned income is counted & resources are counted as part of eligibility determination. If considered to be countable unearned income, GI will count as income in the month of receipt. Any GI retained after month of receipt will be considered a resource.
*typically these programs include SSI recipients, Medicare Savings Programs, Long Term Services & Supports (including home and community based waivers and nursing homes).
To protect individuals in Medicaid programs using a MAGI based calculation, the pilot must be structured to meet the IRS gift definition. Any income that is reportable on taxes will be counted for MAGI programs (ex income that is listed on a 1099).

States may have discretion to amend their State Plans to include protections for AABD groups (this is called a SPA or "State Plan Amendment").

Due to the COVID-19 Public Health Emergency (PHE), individuals cannot be removed from Medicaid coverage, even if they are no longer eligible. This protection will end on March 31, 2023. When the PHE ends, States may contact individuals to review their eligibility for continued coverage.
- PA pursued a SPA to protect ABD groups, but ended up finding another mechanism to do so without having to go through a SPA (they did not share what that mechanism was!)

- HealthFirst Colorado: Exemption - MAGI: 26 U.S.C. 36B(d)(2)(B); 42 CFR 435.603(e) and 435.603(d)(3) that funds that are classified as a charitable “Gift” are Non-taxable income not counted in determining Medicaid/CHIP MAGI-based income.

- HealthFirst Colorado: Exemption - Non-MAGI: Exempt this income type (unearned income) as assistance from another agency, based on 8.100.5.F.6.j&y and Non-MAGI following the most closely related financial assistance program 42 CFR 435.601 (b)(2)

- Guidance on Medicaid, Medicare, CHIP waivers during COVID-19 and natural disasters - here
-Identify through which group the individual is eligible for Medicaid to determine next steps.
-If in a MAGI group, advise individual that they should not report GI payments on their taxes. Confirm with your State whether individuals should list non taxable income on their application/renewal paperwork with Medicaid.
-If in a non-MAGI (ABD) group, advise that GI payments will count as income in determining eligibility.
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MedicareFree or low cost health insurance for the elderly. The plan covers people age 65 or older, younger ones with disabilities, and patients with end-stage renal disease.Centers for Medicare and Medicaid Services (CMS)YesLow- May not be necessary to include because Medicare Parts B (insurance) and D (prescription drugs) are means-tested with increased premiums for those who cross relevant income thresholds. These thresholds are, however, quite high ($88,000 for an individual taxpayer, $176,000 for a married couple filing jointly) so as a practical matter pilot participants in the typical GI pilot will not be affected.
- 1135 waiver
- Guidance on Medicaid, Medicare, CHIP waivers during COVID-19 and natural disasters - here
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Section 8:
Public Housing &
Housing Choice Vouchers
Provides housing and rental assistance to low-income families.Local Public Housing Authority; your pilot service area may include more than one.YesHighEligibility based on adjusted gross annual income. The family's income may not exceed 50% of the median income for the county or metropolitan area in which the family chooses to live in order to qualify. In general, earned and unearned income for all family members is considered when calculating annual income, including "regular contributions and gifts". Income from assets/resources is also included in the calculation. Income is assessed annually after initial eligibility.
The housing voucher family must pay 30%-40% of its monthly adjusted gross income for rent and utilities

NOTE: Long wait lists are common - could take a long time to get back on benefits if they are lost (some waitlists could be closed or have a multi-year wait).
PHAs participating in HUD's Moving to Work Demonstration can exclude GI payments by amending their MTW plan.

PHAs can use Additional Deductions (also known as Permissive Deductions) 24 §CFR 5.611(b) to exclude GI payments from eligiblity & rent determinations for public housing, the Housing Choice Voucher (HCV) and the Section 8 moderate rehabilitation programs (including the moderate rehabilitation Single-Room Occupancy (SRO) program).

Depending on the length of the pilot, some PHAs may be able to use Nonrecurring Income 24 §CFR 5.609 (b)(24) to exclude GIY payments from eligibility and rent determinations for Public Housing and Housing Choice Voucher beneficiaries. Nonrecurring income includes "Direct Federal or State payments intended for economic stimulus or recovery" which may be relevant for publicly funded pilots, particularly those funded through the American Rescue Plan Act (ARPA).
*Please see column H for details about the effective date of this provision.


PHAs can submit a request to HUD headquarters for a waiver under the General Waiver Authority 4 CFR § 5.110. Waiver requests under §5.110 are considered on a case by case basis for good cause. Using this mechanism, PHAs would need to individually request a waiver of an applicable regulation. So far, HUD has only approved GI exclusions for the Housing Voucher program under this mechanism and has required the PHA to implement a Permissive Deduction for Public Housing beneficiaries.

Some in our community have taken this approach: Whenever the relevant sections of HOTMA (Housing Opportunity Through Modernization Act of 2016) are implemented, "permissive deductions" for research-related cash transfer pilots will also be available for section 8. As a last resort, pilots may want to discuss with local PHA(s) the possibility of doing off-cycle income verification (i.e., move this up from whenever it would be next to occur just before the pilot starts). If income increases (via a gift) during the period until the next verification, ostensibly the resident should report it, but it shouldn't cause rent to go up. Oakland folks came to an agreement in principle on this approach with their PHA, but didn't need to use it.

Others have had a more complicated experience: the understanding is that new income needs to be reported between certification periods, which would trigger a recalculation of the rent payment. HUD put out some ideas of not requiring reports of changes in income between recertification periods to help people build their assets and take advantage of pay raises but that it is not currently allowed.
You can find out if your PHA is participating in the MTW demonstration here.
MTW PHAs using this mechanism include: Cambridge Housing Authority (MA); Oakland Housing Authority (CA); Housing Authority for City of Baltimore (MD) and Philadelphia Housing Authority (PA).

Additional/Permissive Deductions: 24 §CFR 5.611(b)
The City of Providence adopted Permissive Deductions to protect Public Housing recipients for its GI program. The Abundant Birth Project used a combination of Permissive Deductions and the General Waiver Authority to protect both Public Housing and Housing Voucher Recipients. See Protecting Benefits in Guaranteed Income Pilots report, pages 30-33:

The Temporary Income Exclusion 24 CFR § 5.609(c)(9) was previously used by some Housing Authorities to exclude GI payments from eligibility and rent calculations. A recently passed HUD rule updated this regulation. It is now an exclusion for Nonreccuring Income 24 CFR § 5.609(c)(24) which is defined as "Income that will not be repeated in the coming year based on information provided by the family." This new non-recurring income provision has yet to be tested.
**Please note that the effective date for the above mentioned HUD rule will be established upon publication of the final rule in the Federal Register. We anticipate this to happen soon.
Additional Deductions and/or the nonrecurring income regulation should cover most participants in pilots. However, the Housing Authority has to agree to implement Additional Deductions and the applicability of the nonrecurring income exclusion depends on the length of the pilot and the Housing Authority's interpretation of the definition of "nonrecurring".If no protections are implemented: Identify the Area Median Income (AMI) for each of the target housing areas to inform participants of the income limits for eligibility. Inform participants of their reporting requirements and that their rent will likely increase if they remain eligible for the benefit. People typically pay 30% of their monthly adjusted income for rent & utilities.
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Social Security
Retirement
Retirement income payable to adults at least 61 years and 9 months oldSocial SecurityNoNoneEligibility is based on previous contributions to Social Security.Not ApplicableConfirm individual is not receiving SSI under the Aged category to supplement retirement income (dual beneficiary).
Beneficiary can check this on their "mysocialsecurity" account.
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Social Security - Supplemental Security Income (SSI)Assistance to children and adults with disabilities who have low income and resources; also payable to adults at least 65 years old without disabilities who meet financial criteria (aged category).Social Security AdministrationYesHighGI payment is considered a gift (unearned income) and counts against eligibility and payment amount. SSI payments will be reduced $1 for every $1 received in GI. Individuals with other income in addition to GI could lose eligibility for SSI. This program also has a $2,000 resource limit.
Losing SSI can also impact categorical eligibility for other benefits, such as Medicaid and SNAP.
This benefit is typically difficult for people to attain and requires a new application and lengthy evaluation process to resume after pilot activities end. No net benefit for participants unless using a protection mechanism as SSI is reduced $1 for $1 with GI.
*Please note that the above program details refer to adults receiving SSI. The rules regarding SSI for children are different, but take into account parental income and resources.
- SSI working group exploring possibilities, to include Disaster Assistance, Assistance Based on Need, ICAP demonstration projects with SSA.
- Most pilots so far have gone the "informed choice" route, which means that most SSI recipients opt out at benefits counseling stage due to impact on SSI.
In general - Little precedent if any, highly restrictive for eligibility.

Chicago Resilient Communities Cash Assistance Pilot achieved a GI income and resource exclusion through the Disaster Assistance Mechanism. In November 2022 additional pilots that had ARPA funding also received an exclusion through this mechanism. See Here. **Advocates are still clarifying the criteria pilots must meet to be approved under this mechanism.

Humanity Forward Foundation & the University of Pennsylvania signed a cooperative agreement with Social Security in Feb 2023 for a pilot in Philadelphia, which will include a waiver of GI income for SSI recipients and applicants as part of a demonstration project. GI income saved will not count as a resource for 3 years.
No, still in development.Inform participants of the $1 for $1 deduction in their SSI payment and the possibility of losing eligibility for SSI.

Participants should do a cost analysis of how much they will lose in SSI and then make a decision whether or not to move forward.
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Social Security Disability Income (SSDI)Payments to adults who can’t work at SGA level due to a disability. Based on work history and payment into SSA system via taxes.Social SecurityNoNoneEligibility is based on previous contributions to Social Security and inability to work at SGA level. Unearned income and resources not considered in eligibility determination.Not Applicable-Confirm individual is not receiving SSI to supplement SSDI income (dual beneficiary). Beneficiary can check this on their "mysocialsecurity" account.
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Subsidized Child CareProvides a subsidy to help low-income families pay their child care fees. State and Federally funded; county administered.YesModerateThe Child Care and Development Block Grant Act, 42 U.S.C. 9858 et seq., does not define “income” or “assets” for purposes of CCDBG eligibility. In addition, the Office of Child Care has not regulated as to how states should define income and there is no assets test required by Federal law for the Child Care Development Fund (CCDF). While it is possible for states to create an assets test, as they have discretion to add additional eligibility requirements provided that they are not discriminatory, very few states have them. Accordingly, states are free to determine that the payments described above can be excluded from their definition of income and from any assets test that the state elects to apply.

Income eligibility limits for this program vary between States. Often the income thresholds for this program are higher than for other benefits such as TANF and SNAP. Check your State government website for updated information on income thresholds. Some programs require families to contribute towards the cost of their child care in the form of copays. If the State does not exclude GI payments from household income calculations, some households may become ineligible for the program, or may be required to pay a (higher) copay. Some States have waitlists which could cause challenges for families who lose this benefit as a result of GI payments and have to reapply after the pilot ends.
*Note: It is possible (though likely rare) to work with a county that is willing to backfill the cost of subsidized child care such that folks won't lose this benefit if they are getting GI (as a matter of policy) - San Francisco is an example. Maybe not worth mentioning if it seems unlikely many other places would take this approach, but we were able to get the city ageny (Children Youth and their Families?) to draft a one pager explaining this protection to any pilot participants. It was less rock solid/clear that this would apply to people first applying for a subsidy during the GI Pilot, but I was also told that would be the case.

States are required to submit plans, every two years, containing policies for administering their programs (including their definition of income for eligibility purposes). However, plans can be amended at any time. States have 60 days following the effective date of a change in their program to submit a plan amendment. Thus, a state could make a change and request a plan amendment approval subsequently. Nonetheless, the specificity of the information provided in each state’s Child Care Development Fund (CCDF) Plan varies. For a resource that describes each state’s policies in more detail, please see: https://ccdf.urban.org/
- In Illinois, a bill was passed that directed their DHS to exclude income for the purposes of determining child care eligibility. SB1735 (in our 101st GA) – now public act 101-0415.

- Massachusetts included an exemption for GI pilots in their regulations: https://www.mass.gov/doc/eecs-financial-assistance-policy-guide-february-1-2022/download
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Supplemental Nutrition Assistance Program (SNAP)Assists low-income households get the food they need to prevent hunger and malnutrition.State Department of Human ServicesYesModerateRecurring gifts that exceed $30 per quarter are counted as Unearned Income in eligibility determination. Monthly SNAP benefit will likely decrease and eligibility for SNAP may be compromised depending on other household income. This program also has resource limits that participants should be aware of if they plan to save money from the pilot.

Broad Based Categorical Eligibility (BBCE): all members of the household must be receiving a Temporary Assistance for Needy Families (TANF) funded service, Supplemental Security Income (SSI), or general assistance. These households do not need to meet the resource limits or gross or net income requirements. Note: In some states the TANF funded service is a brochure or a referral. BBCE allows states to eliminate asset limits and confer eligibility to SNAP for families with gross incomes up to 200% of FPL. Eligibility criteria differ by state.

If the pilot can't get a waiver, reinstating SNAP benefits doesn't appear to be too difficult; may not require a new application if benefits were closed prior to the end of the certification period. Losing SNAP eligibility may also impact eligibility for Free School Lunch program (although may still qualify for reduced school lunch, see below).
There is a well established mechanism used by multiple pilots, but the State has to be willing to implement. This mechanism is connected to the TANF exclusion of GI income. This method is currently limited to privately funded GI pilots or pilots with co-mingled public/private funds.

USDA COLA 2023 Memo Link

SNAP Protection Mechanism: 7 CFR 273.9(c)(19) At the State agency's option, any types of income that the State agency excludes when determining eligibility or benefits for TANF cash assistance as defined by 45 CFR 260.31(a)(1) and (a)(2), or medical assistance under Section 1931 of the SSA...the State agency must exclude for SNAP purposes the same amount of income it excludes for TANF or Medicaid purposes. A State agency that chooses to exclude income under this paragraph (c)(19) must specify in its TANF state plan of operation that it has selected this option and provide a description of the resources that are being excluded.
- The Families First Coronavirus Response Act granted new and temporary SNAP waivers by legislation, giving states flexibility; FNS state-by-state waivers here; and 1135 waivers;

- Implementing reg at 7 CFR 273.9(c)(19) using TANF as a backdoor to reach a GI exclusion from SNAP is the current most common strategy in demonstration projects (not just GI) because FNS does not grant many native income exclusions or options for waiver request - Method currently limited to privately funded GI pilots. Multiple pilots have implemented SNAP protections using this mechanism.
Yes, but the mechanism mostly commonly used only applies to pilots using private funding.Participant does a cost analysis of how much they will lose in SNAP and then decide whether they will move forward or not.
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Temporary Assistance for Needy Families (TANF)Time limited benefit that assists pregnant women and families with children when the parents or other responsible relatives cannot provide for the family's basic needsTypically the State Department of Human Services but 10 states have county administered programsYesModerateImpacted: Individuals must have very low income and limited assets to be eligible (actual limits can vary among States); Individuals must report all income from all sources when determining eligibility, including unearned income/gifts. Urban Institutes Welfare Rules Database may be a good starting place to better understand TANF eligibility criteria in your state- https://wrd.urban.org/wrd/query/query.cfm
Other family members may be relying on this income in addition to GI recipient. TANF also may confer eligibility to other important benefits such as child care, transportation subsidies, employment and training assistance, etc. and other cash assistance programs.
- States have wide latitude to exclude GI payments from eligibility and benefit amount determinations under federal TANF statutes given the structure of the block grant. However, the State has to have the desire to do so.- Multiple pilots have successfully excluded GI payments from eligibility and benefit amount determination for the TANF program.
- Colorado has secured waivers when there was a research component of the cash program included.
Yes in States/administrations that are supportive of GI pilots.Compare the amount of the GI payment to your State's maximum TANF payment (based on household size) to assess whether the family will be financially better off with the pilot payment. Assess impact on overall household as well as TANF related benefits such as child care assistance, transportation subsidies, employment and training assistance, etc. Also of note, SNAP benefits decrease with an increase in TANF cash assistance. (And relatedly, the mechanism available to protect SNAP benefits for GI pilots is via an exclusion of GI cash for the purposes of determining TANF eligibility and benefit levels.)

As this benefit is typically only available for a limited number of months (up to 60 months depending on state), participants may want to consider pausing benefits while participating in the pilot and resuming benefits afterwards if the GI payments will render them ineligible.

For Colorado (Colorado Works), Request letter from your community-based organization to be printed or emailed from AidKit for your records for any reporting requirements to your case worker in TANF (pulled from Denver Basic Income Project matrix).
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UnemploymentProvides temporary income support to individuals who have lost their job through no fault of their own or are working less than their typical full-time hours. Individuals receive money for a limited time to help meet expenses while they seek new employment.Department of Labor, Workforce or Economic Security - full list of state departments here.NoNoneNo risk: eligibility based on work history in the state, participation in employment search requirements, and reason for leaving past employment.No action neededNone
*Note: It may be worth discussing, as a best practice (if not essential), getting local partners to help with a one-pager/quick reference explaining why this (or other benefits) are protected. Hopefully this can come through trusted/expert voices - in the Bay Area, a coalition of groups worked to get Legal Aid at Work to provide a one-pager on unemployment, plus maybe paid disability.
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Women, Infant, and Children (WIC)Provides nutrition services, breastfeeding support, health care and social service referrals, and healthy foods for low-income
mothers, infants, and children up to five years old who are at nutritional risk.
State Department of Human Services or Health DepartmentYesModerateGI payment is considered a gift which is considered income in eligibility determination. Income threshold is 185% of FPL based on household size (including unborn children). Annual gross income is used to determine eligibility.Limited - this has been a challenging benefit to protect.- In Colorado, adjunctive eligibility is in place under 7 CFR 246.7(d)(2), WIC Policy Memo 94-28 for those who qualify for TANF, SNAP FDPIR, and Medicaid (including Health First Colorado Limited/Emergency Medicaid, Transitional Medicaid). Thus protecting those benefits may provide a path to protecting WIC.
- See precedent for WIC (currently limited to GI pilots funded via private dollars)
Encourage participant to check the FPL guide for 2022 to see if they will continue to qualify based on their benefit recertification date.
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