With respect to states, we have already seen the real-world impact of similar policies taking effect. Kentucky reinstated work-related time limits in SNAP for ABAWDs living in most counties in the state (after having reinstated these limits in seven more economically prosperous counties during 2016). A recent analysis8 from the Urban Institute finds that:
- After Kentucky reinstated stricter work requirements on ABAWDs on SNAP, the number of those individuals receiving SNAP benefits declined by 30 percent between January 2017 and September 2018, far outstripping the decline of 12 percent in the overall SNAP caseload.
- Between January 2017 and September 2018, 13,122 able-bodied adults without dependents that had been participating in SNAP have been disenrolled from the program because they reached the three-month time limit, which comprised approximately 20 to 22 percent of the state’s overall number of participants during that timeframe.
- Comparing disenrollment from SNAP between economically similar counties with and without work-related time limits in Kentucky, the analysis finds that the size of ABAWD SNAP caseload declined much more in counties where the stricter work-related time limits were reinstated, even though they had nearly identical caseload trends prior to the policy change. The differences were dramatic with a 44 percent decline between January 2017 and September 2018 in the counties after reinstated time limits versus only a 2 percent decline in the eight counties that continue to have waivers in place.
SNAP helps people meet their nutritional needs and mitigates financial hardships, enabling people to seek work, education, and/or training. However, as the Kentucky examples illustrates, stricter work requirements for programs such as SNAP can have the opposite of the intended effect to promote more and better employment among participants.
To put it simply, stricter work requirements do not create jobs; given the irregularities typically associated with low-wage work, even those working may not always be able to meet these requirements. Moreover, SNAP already promotes work by not reducing benefits for each dollar earned, allowing participants to own cars for commuting purposes, and providing existing employment and training programs.9
The participants affected by this rule face substantial barriers to work, including limited education and skills, significant health issues that don't qualify as disabilities, or care responsibilities for which they aren't granted exemptions. Moreover, people of color in these groups face discrimination in the labor market. SNAP’s current Employment and Training programs may not be able to meet the greater needs if the rule is implemented with no corresponding increase in education, training or certification.10
Finally, even those who are able to comply with more burdensome work requirements may have significant difficulties documenting that compliance.11 Particularly for participants with temporary jobs or irregular work schedules, regularly tracking work hours can be difficult and time-consuming, with even minor errors having the potential to imperil receipt of benefits. These challenges can be compounded when participants lack access to technology or the Internet. Similar administrative burdens would fall on state agency staff who are required to document or certify that compliance, which in turn can lessen their available time to ensure receipt of proper benefits for participants.
The Proposed Rule’s Impact on Children
Nearly half of all SNAP participants are children, who need nutritious food to grow, learn, and thrive. Research shows that access to nutritious food helps children’s brain development,12 improves their school performance,13 has long-term health benefits,14 and establishes healthy eating habits that can last a lifetime.15 In households with children, participation in SNAP for six months has been linked to a reduction in food insecurity.16 In 2017, SNAP benefits helped 1.5 million children out of poverty.17
While the rule would exempt adults who have dependent children under the age of 18, it does not consider the complex and inter-dependent financial arrangements that low-income families often employ to make ends meet.18 Following are several examples of how the proposed rule could negatively impact children.
Non-Custodial Adults: Parents who do not have custody of their children (non-custodial parents) often still pay child support and other expenses related to the care of their children, and depend on SNAP and other forms of assistance. Under tightened waiver rules this population would be at risk for losing benefits, compromising their ability to provide for their children.19
Extended Family Members: Depending on the family support structure, some children rely on extended family members to provide food, financial and childcare support. Low income families often make ends meet through the accommodation of resources from other family members, and would be the first to suffer should family members in these networks lose SNAP benefits.20
Opioid Crisis: The growing opioid epidemic has resulted, in part, in more than 2.5 million children being raised by grandparents or other relatives.21 Adults caring for children whose parents are struggling may find it difficult to receive an exemption from strict time limits and may lose their SNAP benefits, putting children at risk for food insecurity and poverty.22
Should these types of examples come to fruition, the consequences for affected children could be severe.
Even with the important safety net SNAP provides, nearly 13 million children suffer from food insecurity across the country.23 In 2017, one in six children lived in a household that had uncertain access to enough healthy food. The negative consequences of experiencing food insecurity, especially for children, are significant. Food insecure children are:
- Almost twice as likely to have fair or poor health and about one-third more likely to be hospitalized since birth;24
- Four percent more likely to show symptoms of anxiety and depression,25 and;
- Nearly 10 percent more likely to display hyperactivity.26
Any reforms to SNAP should be driven by analysis of impacts on access, equity, cost and program outcomes including food security, financial security and diet quality.
In applying this standard of review to the proposed rule, we see no compelling health, economic, or equity rationale for moving forward. Again, we believe wholeheartedly in the dignity of work and the value—both economic and personal—of meaningful employment. However, the proposed rule would push the affected participants further away from that goal. As such, we urge the Department to discontinue this approach and find a better path forward.