On Tuesday, April 2nd, the Trump administration closes a public comment period on proposed changes to the Supplemental Nutrition Assistance Program (SNAP, or food stamps) that could leave hundreds of thousands of unemployed and underemployed adults unable to meet their basic needs.
"The vast majority of SNAP recipients are children, the elderly, caregivers, or persons with disabilities."As we wrote in a previous blog, USDA Secretary Sonny Perdue surreptitiously announced the proposed rule via an after-hours, off-camera briefing in peak holiday season late last December. To be sure, the rule is nothing to be proud of. It would restrict states’ ability to waive time limits on SNAP benefits, meaning many adults across the country who are struggling to find work would lose their benefits after just three months.
If the Secretary’s hope was that the announcement would fly under the radar, it failed spectacularly. The public has responded (and how).
At the time this blog was published, nearly 30,000 comments from public health professionals, anti-hunger advocates, and other concerned citizens had been submitted to the federal register website.
There are many reasons the public has expressed opposition to the rule—and for many, it’s personal. Our top nine reasons for opposing the rule (and the evidence behind them) are below. Visit the federal register to view UCS’s comment in full, or use our model comment to submit your own before next week’s deadline.
Nine reasons why we oppose the proposed SNAP changes
1. Congress expressly defeated attempts to include such provisions in the recently authorized Farm Bill. The administration is using the regulatory process to directly subvert the will of Congress and the public.
The proposed rule changes mirror the legislative changes that were included in the House Farm Bill, which faced such fierce opposition from Congress, public health professionals, anti-hunger advocates, national organizations, and members of the general public that they were excluded from the final bipartisan bill. And just this week, a bipartisan group of 47 US Senators released a letter asking Secretary Perdue to reconsider the proposed changes. Circumventing Congress to unilaterally implement unpopular and unsubstantiated changes to SNAP through rule making is an ill-advised and short-sighted strategy that directly contradicts the expressed wishes and stated needs of many individuals, organizations, and elected officials.
2. There is no evidence that the proposed rule will increase participation in work. Research has not shown that stricter time limits for federal assistance programs encourage work, and further suggests that limiting access to basic needs may increase barriers to gainful employment.
The proposed rule asserts that stricter criteria for waivers “would encourage greater engagement in meaningful work activities and movement toward self-sufficiency among Able-Bodied Adults Without Dependents, thus reducing the need for nutrition assistance.” Yet a nonpartisan Congressional Research Service report on work requirements in federal programs concluded there is no research base for the effectiveness of work requirements for SNAP beneficiaries, and recent research has found that program participation actually increases the likelihood of employment and full-time work.
3. The proposed rule will likely increase food insecurity and have detrimental effects on public health for those who will lose program benefits.
Research shows that SNAP alleviates household food insecurity, which in turn can help to prevent the onset of chronic diseases and mental health issues. In 2017, SNAP lifted 3.4 million people out of poverty and reduced food insecurity by up to 30 percent. Consequently, the proposed rule may exacerbate health problems among able-bodied childless adults, making it harder, not easier, for them to find stable employment. Children who rely on adults not formally designated as caregivers may also suffer health consequences: young children’s participation in SNAP is linked to a higher likelihood of high school completion and lower rates of obesity and metabolic syndrome into adulthood.
4. The proposed rule would result in increased health care costs due to increased rates of food insecurity. Part of these costs would be paid by state and federal governments.
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Research has shown that adults who participate in SNAP tend to incur less medical costs than eligible non-participants, due in part to hospitalizations for diabetes complications. A 2017 study found that participants typically incur $1,400 less in total medical costs—meaning that the loss of benefits by 755,000 adults under the proposed rule would result in nearly $1.1 billion in additional medical costs. This amount, which will be paid in part by government in states with Medicaid expansion, is equal to the cost savings predicted by the administration under the proposed rule.
5. The proposed rule will likely harm local economies in communities across the country, including small and medium farms that receive revenue via the Food Insecurity Nutrition Incentive grant program.
When SNAP participants spend benefits at the store, it catalyzes a chain reaction of economic activity known as the “multiplier effect.” The standard USDA model estimates that, during a weak economy, $1 in SNAP spending generates about $1.80 in economic activity. This is what makes SNAP an important program during economic downturns—the influx of spending can help entire communities and industries recover more quickly from the fallout. But it also means that entire communities can feel the effects of cuts to the program, including farmers who rely on SNAP participants to purchase local produce, sometimes with the help of programs like the Food Insecurity Nutrition Incentive (FINI). In its first year, FINI programs generated almost $8 million in SNAP and incentive produce purchases at farmers markets in 27 states.
6. By setting a strict and arbitrary threshold for unemployment, the proposed rule fails to acknowledge the slow economic growth, persistent economic inequality and food insecurity facing some areas of the country.
The proposed rule would limit acceptable types of data states can use to request waivers and sets more stringent standards, imposing a 7 percent unemployment floor—even if local unemployment is considerably higher than the national average. Yet unemployment is only one measure of job availability and economic opportunity, and relying on unemployment data alone—particularly at the specified threshold—ignores critical considerations related to labor force participation, stagnant wages, and persistent food insecurity, despite national economic improvements. The new standards set by the proposed rule, which were provided without any science-based evidence, reject the reality that, in many places in America, it is still exceedingly difficult to find stable employment that pays a living wage.
7. The proposed rule would reduce states’ ability to make important decisions about how their populations can meet their basic needs.
Since 1996, every state except Delaware has needed to use waivers to halt time limits on SNAP, showing how essential it is to allow states the flexibility to help residents put food on the table when they fall on hard times. The proposed rule would remove this flexibility, making it harder for states to respond to economic downturn and to address the needs of unique communities. There are many counties with distinct economic conditions and challenges that will be exacerbated by the proposed rule. One such example is Murray County, Georgia, a rural area whose economy is driven by manufacturing and which overwhelming voted to put the current Administration into office. Though unemployment rate (6.8%) in Murray County is nearly three percentage points higher than the national average and the poverty rate is 34 percent higher than the national average, the county would no longer qualify for a waiver under the proposed rule. This is one of many counties across the country that will lose a critical lifeline for many of its low-income residents.
8. There is no substitute for SNAP. The emergency food system alone cannot provide additional food to meet the needs of those who will lose program benefits under the proposed rule.
Food banks play a critical role in alleviating food insecurity for individuals and families across the country, including those who don’t qualify for programs like SNAP. Nationally, more than one in four food-insecure individuals lives in a household that is unlikely to qualify for most food assistance programs. Feeding America, the nation’s largest domestic hunger-relief organization, provided 4.3 billion meals to millions of people facing hunger in 2018. Yet the reach and impact of meals provided by anti-hunger organizations is only a fraction of those provided through SNAP. It is estimated that for every single meal provided by the Feeding American nationwide network of food banks, SNAP provides 12 meals to families in need. Any cuts to SNAP will result in greater strain on these systems that are already unable to meet community needs.
9. Despite the outsized attention the administration has brought to this issue, the population of able-bodied adults without dependents is only a small fraction of Supplemental Nutrition Assistance Program participants.
The vast majority of SNAP recipients are children, the elderly, caregivers, or persons with disabilities. The population of unemployed and underemployed adults being targeted by the proposed rule makes up only 8.8 percent of all SNAP recipients, and the number of those unemployed at any given time makes up only 6.5 percent of all recipients. Furthermore, many adults classified as “able-bodied adults without dependents” may have unique circumstances that make finding work difficult, including veterans, homeless people, children who have aged out of foster care, and college students. This population may also include people who are not officially designated as caregivers, but are helping to care for children of friends or kin.
In one of the wealthiest countries in the world, the only thing more troubling than persistent hunger, poverty, and inequality is an unwillingness to do something about it. If Secretary Sonny’s motto is to “do right and feed everyone,” now seems like a good time to start.