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FOOD AND NUTRITION SERVICES CERTIFICATION ELIGIBILITY REQUIREMENTS FNS 227 NON-CITIZEN REQUIREMENTS

19 Section 227 Change #1-2026 February 1, 2026 c. Veteran Dependent Child: Legally adopted or biological dependent child under 18, OR full-time student under 22, OR child dependent on veteran at death, OR disabled child 18+ if disabled before 18th birthday. 5. Lawfully Residing on 8/22/1996 and Age 65+: Individual was lawfully residing in U.S. on August 22, 1996 AND is currently age 65 or older. 6. Entered Before 8/22/1996 with Continuous Presence: Individual entered U.S. before August 22, 1996 and has maintained continuous presence until obtaining qualified immigrant status. E. Calculating the Five-Year Waiting Period Critical Rule (Dec. 9, 2025 USDA Q&A): The five-year waiting period runs from the date the individual obtained "qualified alien" status under pre-H.R. 1 law—NOT from the date of LPR adjustment. Example: An individual was paroled into the U.S. on January 1, 2022, and adjusted to LPR on June 1, 2025. The 5-year period began on January 1, 2022 (parolee status date), not June 1, 2025 (LPR date). This individual will have completed the 5year waiting period on January 1, 2027. How to Verify "Resident Since" Date: • Check the "Resident Since" date on the face of the I-551 (green card). • This date reflects when the individual first obtained qualified alien status, NOT the LPR adjustment date. • If the individual held multiple qualified statuses, use the earliest qualifying date. • If unclear, request additional documentation (I-94 arrival record, asylum grant letter, etc.) to establish the earliest qualifying date. F. LPRs Who Have Completed the Waiting Period Any LPR subject to the five-year waiting period (Section C) who has held qualified alien status for at least five years is eligible to participate in FNS, provided they meet all other eligibility requirements. Alternatively, any LPR who has earned or can be credited with 40 qualifying quarters of work is eligible regardless of how long they have held LPR or qualified alien status. See FNS 227.09 for 40 quarters calculation procedures. Proceed to FNS 227.07 Step 4: Verification of Non-Citizen Status