colift

What counts as SNAP volunteer hours, and our authority for it

Federal law, the California verification standard, and the New York verification standard each allow unpaid volunteer work to count toward the SNAP/ABAWD work requirement. This article cites each one. Claims are graded:

  • Direct authority Regulation, statute, or official guidance says so.
  • Analogical Related law or precedent supports it.
  • Unaddressed-but-defensible No on-point authority either way.

The federal hook

Direct authority Under federal SNAP regulations, the ABAWD work requirement can be met by "working," and "working" is defined to include unpaid work verified under the state's standard.

7 CFR §273.24(a)(2): “7 CFR §273.24(a)(2): "Working… includes: (i) Work in exchange for money; (ii) Work in exchange for goods or services ('in kind' work); or (iii) Unpaid work, verified under standards established by the State agency."”

Source: 7 CFR §273.24 (Cornell LII).

That is the federal foundation. Unpaid volunteer work counts when the state has a verification standard for it. California and New York both do.

California: the CalFresh work-hours verification form

Direct authority California's standard is in All-County Letter (ACL) 25-34 (May 14, 2025) and the CalFresh ABAWD Volunteer Work Hours Verification Form (rev. 5/25).

Key facts about the form:

  • Section 2 is signed by "a representative of the organization where the person volunteers."
  • The form has no penalty-of-perjury jurat.
  • The signer is not required to have observed the work.
  • The county may, as an alternative, accept the verbal statement of an authorized representative.

Sources: California verification form (CDSS); Santa Clara County handbook.

New York: Monthly ABAWD Volunteer Participation Record

Direct authority New York counts volunteer/community service toward the work requirement, with hours documented on the Monthly ABAWD Volunteer Participation Record and signed by the host nonprofit. Unlike California's flat 80-hour standard, New York values volunteer hours at SNAP allotment ÷ minimum wage, which is typically a much smaller monthly number. In NYC, documentation flows through ACCESS HRA.

Sources: NY OTDA SNAP Work Requirements; NYC ACCESS HRA.

Who qualifies as a verifying organization

Direct authority Federal and state frameworks recognize 501(c)(3) and 501(c)(4) nonprofits, government agencies, schools, and food banks as qualifying organizations. There is no state pre-approval list. A fresh IRS determination letter satisfies the category.

colift is a 501(c)(3) and meets the criteria.

What this means in practice

The federal regulation opens the door. The state supplies the verification standard. colift is a qualifying organization that signs the form based on its platform records.

The follow-on question, whether remote and online volunteering specifically counts, is covered in the next article.

Not legal advice. Citations as of publication.