On Tuesday, President Trump signed an executive order calling for a review of the nation’s federal safety net, with the stated aim of “moving people into the workforce and out of poverty.” This is almost certainly thinly veiled code language for additional work requirements in programs that serve millions of low-income individuals and families, including Medicaid and the Supplemental Nutrition Assistance Program (SNAP).
There are a number of inaccuracies and logic flaws contained in the text, but chief among them are these:
Falsehood 1: The federal safety net is causing poverty.
The order states, “Many of the programs designed to help families have instead delayed economic independence, perpetuated poverty, and weakened family bonds.”
It is a grim truth that poverty has a strong grip on too many communities in this country. But poverty is not created by social support programs, nor is it perpetuated by the people who use them. Persistent poverty is far more likely a product of the complex structural inequities embedded in our everyday lives—income inequality, for example, and institutional racism and discrimination. And until we address and remedy these underlying factors, it is essential that we have a strong federal safety net to fall back on.
Falsehood 2: Working-age adults have become dependent on programs like SNAP.
The US Department of Agriculture (USDA) counters this notion with its own data. The populations who might depend on the program for longer periods of time include children, the elderly, and those with disabilities; together, these groups make up about two thirds of all SNAP participants. The population of SNAP participants who are classified as able-bodied adults without dependents (ABAWDs) and are required to work make up just a small fraction—only two percent—of all those who stay on SNAP for a period of eight years or longer.
Yet there is every indication that ABAWDs will be the target of more stringent work requirements in the months to come. A recent USDA federal register notice asked for public input on “innovative ideas to promote work and self-sufficiency” among the ABAWD population. Here’s what we offered.
April 9, 2018
The Union of Concerned Scientists
Re: Document No. FNS-2018-03752: Supplemental Nutrition Assistance Program: Requirements and Services for Able-Bodied Adults Without Dependents; Advance Notice of Proposed Rulemaking
We submit this comment to the US Department of Agriculture (USDA) to express broad opposition to policy and programmatic changes that would further limit SNAP eligibility for able-bodied adults without dependents (ABAWDs). While we appreciate USDA efforts to address food insecurity and provide adequate opportunities for employment and training among low-income populations, any proposals which would remove participants from the program—either through more stringent work requirements, further restrictions on eligibility, or other means—would fail to accomplish either, and may in fact contribute to worsening economic hardship among low-income individuals while imposing undue administrative burden and cost on state and federal agencies.
Our opposition to the aforementioned policy and programmatic changes is grounded in the following:
The work requirements in place for ABAWDs are already extensive.
In addition to meeting general work requirements for SNAP participation, ABAWDs are subject to a second set of time-limited work requirements. These dictate that an ABAWD must work or participate in a work program for at least 80 hours per month, or will face benefit termination after a period of three months, renewable after three years. Data from the Bureau of Labor Statistics show that for many, securing a job within three months is an unattainable goal: last year, nearly 40 percent of those able to work and looking for jobs in the general population were unable to find work within 15 weeks, while nearly 25 percent were unable to find work within 27 weeks.[1]
The population of unemployed ABAWDs is a small fraction of SNAP participants.
The vast majority of SNAP recipients are children, the elderly, caregivers, or persons with disabilities. The ABAWD population makes up a small fraction of all SNAP recipients, and many are already working or looking for work. Fewer than 8.8 percent of all SNAP participants are classified as ABAWDs, and the number of unemployed ABAWDs at any given time constitutes only 6.5 percent of all program participants.[2] It should be noted that the population of unemployed ABAWDs is not stagnant, but shifts depending on need: research shows that among SNAP households with at least one non-disabled, working-age adult, eight in 10 participants were employed in the year before or after receiving benefits, meaning SNAP is providing effective temporary assistance during periods of economic difficulty.[3] Many of the policy changes addressed in the federal register notice, including new review processes, certification processes, and reporting requirements, would incur administrative burdens and costs with little demonstrable benefit for low-income populations, and may in fact detract from the efficacy of the program.
Bolstering employment and training programs will do little to counter the root causes of poverty and food insecurity—particularly when other public assistance programs are at risk.
Employment and training (E&T) programs can provide a path to self-sufficiency if evidence-based and adequately funded. Currently, there is wide variation among state E&T programs, with varying efficacy, and limited full federal funding available to states.[4] Until there is consistent implementation of effective and scalable models for job training across states—accompanied by a strong government commitment to invest in such models—we cannot rely on E&T programs alone to keep low-income populations employed and out of poverty. This is particularly important at a time when numerous other public assistance programs serving low-income populations are at risk.
We appreciate the opportunity to provide comments on the manner in which the USDA intends to pursue its stated goals of addressing food insecurity and providing adequate opportunities for employment and training among low-income populations. However, the questions posed by the agency suggest that forthcoming policy proposals will do more harm than good. Any policy changes to SNAP resulting in removal of individuals from the program—including more stringent work requirements or restricted eligibility among the ABAWD population—present serious risks to the health, well-being, and economic vitality of the individuals and communities served by this program.
Thank you for your consideration.
[1] Bureau of Labor Statistics. 2018. Table A-12: Unemployed persons by duration of employment. Washington, DC: US Department of Labor. Online at www.bls.gov/news.release/empsit.t12.htm, accessed March 2, 2018.
[2] Food and Nutrition Services (FNS). 2016. Characteristics of able-bodied adults without dependents. Washington, DC: US Department of Agriculture. Online at https://fns-prod.azureedge.net/sites/default/files/snap/nondisabled-adults.pdf, accessed March 2, 2018.
[3] Council of Economic Advisers (CEA). 2015. Long-term benefits of the Supplemental Nutrition Assistance Program. Washington, DC: Executive Office of the President of the United States.
[4] Food and Nutrition Services (FNS). 2016. Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) Best Practices Study: Final Report. Washington, DC: US Department of Agriculture. Online at https://fns-prod.azureedge.net/sites/default/files/ops/SNAPEandTBestPractices.pdf, accessed March 8, 2018.
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