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FOOD AND NUTRITION SERVICES CERTIFICATION ELIGIBILITY REQUIREMENTS FNS 227 NON-CITIZEN REQUIREMENTS
2 Section 227 Change #1-2026 February 1, 2026 COFA Migrants Citizens of Federated States of Micronesia, Republic of Marshall Islands, or Republic of Palau per PRWORA § 402(b)(2)(G) None -- eligible immediately
Statutory Authority: 7 U.S.C. § 2015(f)(2)(B) (LPRs); 7 U.S.C. § 2015(f)(2)(C) (Cuban and Haitian Entrants); 7 U.S.C. § 2015(f)(2)(D) (COFA Migrants).
Non-Citizen U.S. Nationals: Per USDA guidance, non-citizen U.S. nationals (primarily individuals from American Samoa, Swains Island, or the United States Minor Outlying Islands) are eligible immediately with no waiting period. See also FNS 225 for citizenship/national status requirements.
D. Categories No Longer Independently Eligible The following "qualified alien" categories under PRWORA (8 U.S.C. § 1641) are no longer independently eligible for FNS based on their status: • Refugees admitted under INA § 207 • Asylees granted asylum under INA § 208 • Individuals with deportation/removal withheld under INA § 243(h) or § 241(b)(3) • Conditional entrants under INA § 203(a)(7) • Parolees admitted under INA § 212(d)(5) for at least one year • Battered aliens under the Violence Against Women Act (VAWA) • Victims of severe forms of trafficking • Amerasian immigrants • Iraqi and Afghan Special Immigrants (SIVs) • Certain Afghan nationals granted parole between July 31, 2021 and September 30, 2023 • Certain Ukrainian nationals granted parole between February 24, 2022 and September 30, 2024 Pathway to Eligibility: Individuals in these categories may become eligible for FNS by adjusting status to Lawful Permanent Resident (LPR). Per 7 CFR 273.4(a)(6)(iv), "Each category of eligible alien status stands alone for purposes of determining eligibility." 7 CFR 273.4(a)(6)(iv). Eligibility is determined by current immigration status, not prior status.