This month, MS/MPH candidate Grace Flaherty takes a policy deep-dive into the winners, losers, and research behind the USDA’s proposed work requirements for SNAP participants.
Farm Bill reauthorization has come and gone, but the fight over work requirements in the Supplemental Nutrition Assistance Program (SNAP) lives on. The 2018 Farm Bill passed without any significant changes to work requirements in SNAP, but in February 2019 the United States Department of Agriculture (USDA) proposed a separate regulation that would impose stricter work requirements on Able-Bodied Adults Without Dependents, more commonly known as “ABAWDs.”
ABAWDs are defined by the Food and Nutrition Service (FNS) as single adults between the ages of 18 and 49 without children and who are not disabled. According to FNS estimates, 15 percent of all SNAP participants were ABAWDs in 2016.
Work requirements for ABAWDs participating in SNAP are not a new concept. Current federal regulations already require that ABAWDs work or participate in an employment program for at least 20 hours a week to continue to receive SNAP benefits for more than three months over a 36-month period.
Currently, many ABAWDs are exempt from this time limit rule because their states have demonstrated that the regional economy isn’t strong enough for them to reasonably find employment. For ABAWDs to be exempt, states need to show an unemployment rate above 10 percent or “lack of sufficient jobs.” As of April 2019, 36 states have been approved for statewide or partial ABAWD time limit waivers.
It’s this waiver system that the USDA’s proposed rule seeks to change. Taken at large, the rule makes waivers more difficult for states to obtain, which consequently exposes a broader population of ABAWDs to work requirements. When examined in detail, the rule is a bit more complicated. Wade with me, for just a moment, into the weeds of this regulation.
If finalized, the rule would:
- Eliminate statewide waivers – states would have to apply for partial waivers that cover smaller regions (counties stitched together into “labor market areas” as defined by the Department of Labor).
- Eliminate Labor Surplus Areas – Labor Surplus Areas (LSAs) are areas where unemployment is 20 percent above the national average. LSAs have traditionally been automatically eligible for SNAP work requirement waivers. The proposed rule would end this system.
- Increase waiver eligibility threshold – labor market areas would need an unemployment rate 7 percent (50 percent above the national average) or higher to qualify for waivers.
- Eliminate roll over exemptions – states will no longer be granted unlimited carryover of unused ABAWD time limit exemptions from year to year.
- Require that state governors review and approve all waivers.
- Limit waivers to one year instead of two.
The USDA estimates that the proposed rule will affect 775,000 ABAWDs (1.9 percent of the total SNAP population) by 2020, with 75 percent of the areas currently using waivers not being waived in the future.
Like any policy proposal, there are winners and losers behind the USDA’s proposed rule for ABAWDs. If the rule is finalized, congressional Republicans will be able to declare a political victory that they missed in the 2018 Farm Bill with the added benefit that the proposed rule doesn’t require legislative approval. The rule is also a win for The Heritage Foundation – a conservative think tank and the leading champion of “labor market areas.”
Employment and training corporations also stand to gain from the proposed rule. My home state of Wisconsin expanded its work requirements independently in 2015, and the corporation hired to manage the expanded employment and training program gleaned a sizable payment from the contract. Ultimately, the contract cost twice as much as state officials predicted and the corporation is under investigation for several civil rights violations.
Whether ABAWDs will benefit from the proposed rule depends on whom you ask. Proponents of work requirements argue that if the government requires ABAWDs to actively find employment, they will reach self-sufficiency more quickly and no longer rely on SNAP benefits. Critics hold that work requirements are ineffective at lifting individuals out of poverty and contribute to food insecurity by kicking vulnerable individuals off SNAP.
But what does research say about work requirements? First, it’s important to acknowledge that many SNAP recipients are already working. More than half (58 percent) of working-age, non-disabled SNAP households are employed while receiving benefits. Additionally, a significant decrease in ABAWD participation in SNAP from 2015 (4.21 million) to 2017 (2.99 million) suggests that ABAWDs are leaving SNAP on their own accord, without stricter work requirements.
Regarding the effects of work requirements on employment, a Center for Budget Policy Priorities analysis of work requirements in welfare programs found that although work requirements lead to modest employment increases, these gains decrease with time and do not increase stable employment in most cases.
Furthermore, research shows that individuals subject to work requirements rarely receive pay high enough to move them off assistance and out of poverty. In Wisconsin, the average wage for those who found employment under expanded work requirements was $13.43 an hour, for an average of 36 hours per week, which amounts to an income insufficient to move the individual off of SNAP.
The USDA’s proposed rule was opened to public comment and received a deluge of over 82,000 responses primarily from anti-hunger and public health advocates. It’s unclear when the USDA plans to release the final rule, but regardless of the outcome, the debate over the proper role of employment and training in federal food programs will undoubtedly continue.
Grace Flaherty is an MS/MPH candidate at the Tufts Friedman School and Tufts Public Health Program, studying how federal policy influences the national food environment and health outcomes. In her spare time, you can find Grace experimenting in the kitchen and searching for the best spots to watch live music in Boston (send tips to firstname.lastname@example.org).