April 10, 2019

Fresh evidence of economic flaws underlying the Trump Administration’s proposed Supplemental Nutrition Assistance Program (SNAP) rule was provided in a testimony given by The Hamilton Project Director Jay Shambaugh at a recent House Agriculture Subcommittee hearing.

The proposed rule would undermine states’ flexibility to secure SNAP time-limit waivers for certain unemployed and underemployed adults who can’t obtain, maintain, and document sufficient weekly work hours in areas with insufficient jobs. The United States Department of Agriculture (USDA) itself estimates that the rule would eliminate access to SNAP for 755,000 Americans.

Shambaugh’s testimony provides insights that can help inform comments submitted in opposition to the rule by the new Wednesday, April 10, 2019, deadline. Highlights from the testimony are below.

“Research shows that SNAP is a highly effective program. It also shows that work requirements keep people out of the SNAP program but have little or no impact on work.”

“The USDA’s Notice of Proposed Rulemaking and its Regulatory Impact Analysis are correct that the changes will reduce SNAP participation, but provide no evidence that the changes would increase employment.”

“In research that I have conducted with my Brookings colleague Lauren Bauer, which has been provided to the committee, we find that 75 percent of ABAWDs are labor force participants. Over one-third of those in the labor force would satisfy the work requirements at some points but not at others over a two-year window, almost as many as would consistently satisfy them. Of those who generally work but sometimes do not, the majority don’t work due to ‘work-related reasons.’ That is, they lost a job or couldn’t get enough hours.”

“Our analysis shows that the rule would have reduced waiver eligibility early in the Great Recession. For example, in 2008, the State of Ohio was granted a work requirement waiver for the entire state for two years. By the proposed rule, Ohio could not apply for a statewide waiver, the 20 percent rule they used would be compromised by an excessively high unemployment rate floor, and the extended time period granted based on evidence of dire economic conditions would be denied. Our submitted analysis shows the proposal takes a waiver system that is already too slow to respond to an economic downturn and makes it even worse.”

“There are better ways to encourage work within the SNAP program, such as adjusting the earnings disregard, expanding wrap-around services, and improving training and placement. There are also better ways to improve waiver eligibility, such as automatically granting waivers in the event that Congress authorizes Emergency Unemployment Compensation.”

Take a minute to submit a comment to oppose the Administration’s proposed rule today.