April 1, 2019

As reflected in the President’s FY (fiscal year) 2020 budget, the Trump Administration routinely fails to recognize the critical role the nation’s safety net plays in the lives of low-income people and families. The latest threat to the safety net is the Administration’s proposed Supplemental Nutrition Assistance Program (SNAP) rule, which would time limit SNAP benefits for certain underemployed and unemployed SNAP recipients who can’t obtain, maintain, and document sufficient weekly work hours.

If implemented, the proposed rule would jeopardize access to nutrition assistance for 755,000 Americans, threatening to further fuel rates of poverty and hunger, harm local economies, and negatively impact the health and employment of affected people.

Kali Grant, Senior Policy Associate for the Georgetown Center on Poverty and Inequality’s (GCPI) Economic Security & Opportunity Initiative, explains why action must be taken to oppose the proposed rule now.

How does SNAP impact the economic well-being of low-income individuals and families?

Research makes it clear that SNAP provides a foundation that can help support work for millions of people and their families in the U.S. For example, for just an average of $1.40 per person per meal, SNAP provides individuals and their families vital nutrition assistance, which has positive long-term, intergenerational effects on employment and earnings for children in participating families. Taking away food assistance from low-paid individuals and their families only magnifies hardship and intensifies obstacles to maintaining or finding employment.

Can you explain how the Trump Administration’s proposed SNAP rule differs from current federal law?

Under current federal law, there are already harsh time limits that restrict SNAP participation for working-age adults without minors to just three months out of every three years if they are unable to obtain, maintain, and document at least 20 hours of work each week. Due to this policy, hundreds of thousands of under- and unemployed workers are currently unable to access food assistance when they need it most.

The proposed SNAP rule would amplify the effects of the existing time limits by applying them to more workers and jobseekers. Because the proposed rule does not consider the realities of the low-wage labor market, low-paid workers eligible for SNAP could lose eligibility because of job-based factors outside of their control (e.g., unpredictable and volatile work schedules and pay, or challenges with juggling multiple jobs).

The proposed rule would also eliminate states’ ability to apply for waivers to temporarily lift the time limits in areas with high unemployment, which would dramatically undercut a state’s options for helping struggling residents put food on the table.

The United States Department of Agriculture (USDA) has stated that the proposed SNAP rule is meant to align with the Administration’s focus on fostering “self-sufficiency” and ensuring that those who can work do work. Does the proposed SNAP rule make any false assumptions about SNAP recipients and work?

Yes — what this proposed rule fails to understand is that the majority of working-age SNAP participants without a work-limiting disability already work or want to work. In fact, workers usually only rely on SNAP to help make ends meet while weathering temporary spells of un- or underemployment; periods of involuntary fluctuations in pay, work hours, and schedules; or involuntary part-time status — all common features of the low-wage labor market that are typically beyond a worker’s control. The rigidity and harshness of the proposed SNAP rule is made all the more stark when you consider how much flexibility the low-wage labor market demands of its workers, whether through the imposition of fluctuating schedules, work hours, or pay.

Also, GCPI’s research shows that taking away food or other basic supports from people who can’t meet burdensome documentation requirements is more likely to penalize those already working than to raise employment or earnings.

What are barriers to adequate employment that the proposed SNAP rule ignores?

In addition to the proposed SNAP rule ignoring the realities of today’s low-wage labor market, it also fails to address the obstacles standing between workers and quality, stable, and secure employment.

Specifically, the rule ignores the structural and systemic barriers low-paid workers and jobseekers face, including the unavailability of full-time work and the instability of many low-wage jobs; labor market discrimination based on a worker’s race/ethnicity or origin, disability or serious health condition, or previous involvement with the criminal justice system; and other challenges that can arise from or would be exacerbated by not being paid a living wage. These challenges include caregiving responsibilities and other family obligations, and limited economic and social resources (e.g., transportation and housing). For these reasons and more, the proposed rule is inequitable, as it would disproportionately harm people already facing barriers to financial security, including children, people with disabilities, workers of color, caregivers, and older adults.

Your Unworkable & Unwise working paper notes that proposals that take away basic assistance from people who can’t obtain, maintain, and document sufficient work hours are ill-informed, ineffective, inefficient, and inequitable. What are some policy options alternative to the proposed SNAP rule that would increase economic security among SNAP participants?

Rather than use already limited state resources to implement and enforce the Administration’s harsh and counterproductive proposed SNAP rule, states should instead invest in proven strategies for increasing economic security and opportunity for low-income individuals and families. Such strategies include:

  • Expanding and bolstering access to SNAP, raising the minimum wage, and strengthening other supports for low-income individuals and families, such as Medicaid, housing assistance, and Temporary Assistance for Needy Families (TANF);
  • Strengthening family stability, including by modernizing Unemployment Insurance and establishing a Jobseeker’s Allowance, establishing paid leave and fair and predictable schedules, and reforming the criminal justice system; and
  • Empowering workers by investing in job preparation and creation programs, such as subsidized and public employment; expanding child care assistance; and boosting the Earned Income Tax Credit (EITC).

How can individuals and organizations take action against the proposed rule?

The proposed rule is currently being subject to a public comment period, so individuals and organizations can submit comments in opposition to the rule using available comment platforms, comment templates, and other resources. The last day to submit comments is April 2, 2019, so after submitting your own comment, encourage your partners and those in your grassroots networks to submit their own!

Are there other looming threats to SNAP, or the nation’s safety net in general, that we should be concerned with?

Yes! It’s important to recognize that the Administration’s proposed SNAP rule is part of a broader, concerted strategy to undermine, gatekeep, and shrink our system of foundational supports. That’s why it can feel a bit like a whack-a-mole situation — things keep popping up at different levels of government. While new policies and proposals that emerge may all look different on the surface, they all share the same underlying goal: to take away food, health care, housing, and other basic necessities from low-income people and their families.

Take a stand against the proposed SNAP rule today.