When do assets count?

We are in the process of updating the SNAP Advocacy Guide, so some of the information is no longer current.  In the meantime, you can read or download a pdf of the 2022 guide from www.masslegalservices.org/FoodStampSNAPAdvocacyGuide

Produced by Patricia Baker and Victoria Negus, Massachusetts Law Reform Institute
Reviewed January 2020

There is no asset requirement for most SNAP households. The majority of states have elected a federal option, known as “categorical eligibility,” which allows states to eliminate the SNAP asset test for most households. 106 C.M.R.§§363.110 and 365.180.


In 2019 the Trump Administration proposed a rule change that would impact the rules about assets and SNAP. As of January 2020, no rules have changed and there continues to be no asset test for the vast majority of SNAP households in Massachusetts. Contact MLRI for more information. 


There are four situations when DTA will ask about your assets:

  • Expedited benefits: If you need SNAP benefits quickly, you may qualify if you have less than $150 in countable income and less than $100 in liquid assets (cash on hand, money in the bank), or if your shelter costs exceed your income and liquid assets. 106 C.M.R. § 363.100. See When am I eligible for expedited (emergency) benefits? about expedited SNAP.
  • Elder/disabled households with gross income above 200% FPL: If you are age 60 or older or disabled and your gross income exceeds this level, DTA will ask about assets. Your assets must be below $3,500. Assets include bank accounts, stocks, bonds, real estate other than your home, etc. Assets do not include tax-deferred retirement or education accounts, your home or land it sits upon, a car or other excluded items. See 106 C.M.R.§363.130 for a full list of which assets are counted and 106 C.M.R §363.140 for a list of non-countable assets.
  • Income you earn from assets: Any income you receive from an asset does count as income, including interest earned on savings and dividends you receive. 106 C.M.R. § 363.220(B)(5). If interest is paid quarterly or annually, DTA will average it out over the three, or twelve, months. 106 C.M.R. §364.340. DTA may ask for bank statements, tax filings or other proof of the amount of interest or dividends you receive.
  • If you or a household member is disqualified due to an intentional program violation (fraud) per 106C.M.R.§367.800.These households must have less than $2,250 in assets.
    • Under federal rules, DTA cannot count assets if a household member is disqualified under the ABAWD work rules. Contact MLRI if DTA asks about assets and you are not part of the above 4 situations. 7 C.F.R. §273.2(j)(2)(vii).

DTA Online Guide Sections:SNAP > Eligibility Requirements > Assets > SNAP Asset Guidelines

Additional Guidance
  • Pension or retirement savings account withdrawals that are more frequent than one time withdrawals are likely countable as unearned income. Withdrawals from savings accounts are non- countable income. Interest income is countable. Hotline Q&A (Feb 2014)
  • Instructions on how to explain to elders and other households why interest income and other income from assets count (e.g., annuities, dividends, pension payments); verification of dividend payment or assets can include tax returns; requirement to assist with verifications. Transitions Hotline Q&A (May 2009
  • Cash-in of life insurance policy treated as asset to the extent household subject to asset test (not cat el). Transitions Hotline Q&A #2 (Feb. 2013).

Show DTA Policy Guidance

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