The Online Resource for Massachusetts Poverty Law Advocates

36. Who must register for work and do job search, and who’s exempt?

Any member of your family who is age 16 to 60 and is not exempt must register, search for work, and accept any suitable job offer. This is called the SNAP Employment & Training (SNAP/ET) Program. 106 C.M.R. § 362.310. DTA will have you sign a work registration form where you agree to do certain activities and report your job search efforts.

Job search activities and reporting

After you register (by signing a DTA SNAP work registration form), you have two options:

  • You can make 18 job contacts within 60 days of signing the SNAP work registration form.  Job contacts can be done by phone, over the internet, or by mail; or
  • You can do a total of 24 hours of job search activities (which includes at least 5 job contacts) within 60 days. You can count as search activities the hours spent filling out applications, doing interviews, and/or going to a career center for job search. 106 C.M.R. §§ 362.310(D)(5), (E)(5).

DTA will give you a “Job Search Activity Log” on which to list either 18 job contacts or the hours you spent (and types of activities) to add up to 24 hours. See Appendix C. You need to start your job search within 30 days of when you register and finish it by day 60. Completion of the job search paperwork satisfies program requirements for the next 12 months. 106 C.M.R. § 362.310(E).

You also have the option of going to an employment and training program or career center to find out about other services. If DTA refers you to an SNAP/ET vendor for help with career or training skills, you have the choice whether or not you want to accept the referral. However, if you are offered a job during your job search or from a training program, you must take it unless you have a really good reason to refuse the job, and you cannot quit the job unless you have a really good reason. 106 C.M.R. § 362.310(D)(3), (6), (7) & (8)

Exemptions from the work registration/job search rules

The SNAP regulations provide for a wide range of exemptions from the job search and the SNAP/ET requirements. 106 C.M.R. § 362.310(B). You are exempt if you are:

  • physically or mentally "unfit" for work because you are receiving disability benefits such as SSI or EAEDC, or
  • physically or mentally "unfit" for work based on a statement from a nurse, doctor, psychologist, counselor, or social worker saying you cannot work on a short- or long-term basis or based on participation in vocational rehabilitation program, a mental health program, or a drug or alcohol treatment program, or
  • under 16 years old or over 59 years old, or
  • age 16 or 17 years old but not the head of household (whether or not going to school); or you are the head of household but are in a school or employment/training program at least half-time, or
  • more than three months pregnant, or
  • responsible for the care of a child under age six, even if that child is not part of your SNAP household, or
  • responsible for the care of an incapacitated person even if the incapacitated person does not live in your household, or
  • a TAFDC or EAEDC recipient complying with the cash assistance program work requirement, or
  • complying with SNAP/Work Program requirements for ABAWDs, or
  • receiving unemployment compensation or waiting for unemployment compensation and complying with the job search requirements of the unemployment office, or
  • participating in a drug or alcohol treatment program, or
  • working at least 30 hours a week or making at least $217.50 per week ($217.50 is 30 times the current federal minimum wage of $7.25/hour that went into effect July 24, 2009), or
  • a student enrolled in a program at least half-time. See Question 34 (What if I am a college student?) on which college students are considered eligible for SNAP.

If you do not comply with SNAP/ET work registration or job search rules after you apply and do not have “good cause,” you may be “sanctioned” and ineligible for benefits. See Question 38.

Work registration/job search sanctions

If DTA determines that you did not meet a work requirement without good cause, you will be ineligible for three (3) months for the first finding, six (6) months for the second finding, and twelve (12) months for the third finding. 106 C.M.R. § 367.800(E)(1). For the first two offenses, only the household member who does not comply loses benefits.

On the third offense, and if you are the "head of household," your whole household is ineligible for six months and you also lose your portion of benefits for 12 months. See 106 C.M.R. § 361.220 for a definition of who is the "head of household." Further, if you are sanctioned and have income, DTA will count all of your income to the rest of the household members while excluding you from the SNAP benefits paid to the household. See Question 49 (Do the SNAP rules count money I don't receive?).

Advocacy Reminders:

  • Work search requires only 18 job contacts within a 60-day period, or 24 hours worth of job search activities—not both. DTA workers should provide each SNAP/ET client with a “Job Search Activity Log” and help on how to fill it out and do work search activity, See Appendix C.
  • DTA has a one-page form you can bring to a medical provider to sign if you have a mental or physical impairment that makes it difficult for you to work. It can be signed by a wide range of medical providers, licensed social workers, counselors or directors of substance abuse or mental health programs. See Appendix C.
  • A 16- or 17-year-old who is a dependent in a SNAP household does not need to be in school or register for work search. The teen is exempt until he or she turns 18. 106 C.M.R. § 362.310(B)(11). But if the teen is the head of his/her SNAP household, he/she would need to register.
Additional Policy Guidance on Work Registration:
  • Employment and Training (E&T) are optional and SNAP clients cannot be sanctioned for failure to cooperate. Ops Memo 2012-12 (April 27, 2012).
  • Federal minimum wage increase effective July 24, 2009, impact on work rules. Field Operations (F.O.) Memo 2009-46 (Aug. 4, 2009).
  • ARRA rules suspend work/community service requirements for ABAWDs, but ABAWDs must still do job search activity. F.O. Memo 2009-33 (May 29, 2009).
  • Individuals residing in same household as child are exempt from work rules, even if child is not part of SNAP household. Transitions FYI (Apr. 2008).
  • Incapacitated person or child needing care does not need to live in same household for SNAP member to be exempt from work rules. F.O. Memo 2008-02 (Feb. 15, 2008).
  • Dependent less than 18 years old who drops out of school not required to do SNAP ET/job search. Rules only apply to head of household. Transitions Hotline Q&A (Aug. 2007).
  • DTA form to use for verification of medical "unfit" status. F.O. Memo 2004-22 (May 21, 2004).
  • Refugee attending training program exempt from work requirements. Transitions Hotline Q&A (Nov. 2001).