The federal Food and Nutrition Service recently proposed a rule that would limit the amount of time that an able-bodied adult without dependents can receive Supplemental Nutrition Assistance Program (SNAP) benefits to 3 months in a 36-month period, unless the individual meets certain work requirements. Recognizing the negative impact of such a policy on low-income families, local economies, and farmers—without increasing employment or earnings—NYSHealth submitted the following comments urging that the rule not be implemented:
March 29, 2019
Certification Policy Branch
SNAP Program Development Division
Food and Nutrition Service, USDA
3101 Park Center Drive
Alexandria, VA 22302
RE: Proposed Rule: Supplemental Nutrition Assistance Program (SNAP): Requirements for Able-Bodied Adults without Dependents RIN 0584-AE57
To Whom it May Concern:
The New York State Health Foundation (NYSHealth) appreciates the opportunity to respond to the proposed rule to limit the amount of time an able-bodied adult without dependents (ABAWD) can receive Supplemental Nutrition Assistance Program (SNAP) benefits to 3 months in a 36-month period, unless the individual meets certain work requirements. Such a policy would harm low-income families, local economies, and farmers without increasing employment or earnings, and we urge that the rule not be implemented.
NYSHealth is a private, charitable foundation that works to improve the health of all New Yorkers, especially the most vulnerable. One of our key programs supports healthier communities in part by expanding access to affordable nutritious foods. For example, we invest in nutrition incentive programs such as the Double Up Food Bucks program, which provides matching funds for SNAP recipients to stretch their SNAP dollars to purchase more fresh fruits and vegetables. In New York City, we support GrowNYC, the first farmers market program in the nation to integrate SNAP into its markets. Our experience with this work has provided us with in-depth knowledge of the critical role that SNAP plays in addressing hunger and food insecurity for low-income New Yorkers.
Enacting stricter work requirements for ABAWDs would harm already vulnerable individuals by denying them food benefits at a time when they most need it. Moreover, the policy would be largely ineffective. Research demonstrates that such policies do not result in increased employment or earnings., While most ABAWDs are already employed, many of the jobs they hold are low wage, unpredictable, and may be less than the required 20 hours a week. The proposed three-month time limit for receiving SNAP benefits punishes these workers even as they do their best to support themselves.
The USDA estimates that the proposed rule with its stricter work requirements would result in 755,000 individuals nationally no longer being eligible for SNAP. This would significantly increase the financial burden on already strapped states, cities, and local charities to allocate scarce resources to provide food assistance to individuals whose SNAP eligibility would be eliminated.
The negative repercussions would also be felt by local economies and farmers. According to the Center on Budget and Policy Priorities, in fiscal year 2017, SNAP participants redeemed approximately $63 billion in SNAP benefits for food purchases, supporting retailers of every size. The USDA Economic Research Service has estimated that each $1 in SNAP benefits generates $1.79 in economic activity. With the proposed rule, the USDA estimates a net reduction of $15 billion in spending on SNAP benefits over 10 years. With the stricter requirements resulting in fewer SNAP beneficiaries, the adverse economic impact to food growers and procurers would be felt across the nation.
The proposed rule would also make it harder for areas with low unemployment rates to qualify for waivers that allow ABAWDs to participate in SNAP for longer than 3 months in a 36-month time period. A 7% unemployment rate floor is proposed as a condition under which states and municipalities could apply for a waiver. According to the CUNY Urban Food Policy Institute, this would have a negative impact on various states, including New York, where 37 of 62 counties, 6 cities, and 2 sets of community districts are currently covered by waivers; “with a 7% floor, 90% of ABAWDs would live in areas without waivers.”
Congress recently concluded a review and reauthorization of SNAP in the 2018 Farm Bill and did not recommend the changes proposed by the Administration. The rules governing areas’ eligibility for waivers have been in place for nearly 20 years, and have proven to be reasonable, transparent, and manageable for states to operationalize. This proposed rule would be disruptive and dangerous by shifting financial responsibility for addressing food insecurity to states, without giving states what has been their historical autonomy to tailor SNAP program requirements in a manner that corresponds to the needs of their residents.
By the Administration’s own calculations, the proposed rule would take food away from 755,000 low-income Americans, cutting food benefits by $15 billion over 10 years. The Administration does not provide estimates on improvements in health or employment among the affected population. But it is a well-documented fact that food insecurity is a predictor of higher health care costs and worse health outcomes., SNAP is a lifeline for millions of Americans. If their benefits are taken away, they could be put in the dangerous, untenable position of having to choose between paying for food, medicine, housing, or transportation.
For these reasons, we oppose the proposed rule, which would severely harm the health of many communities, negatively impact local economies and farmers, and unfairly shift increased responsibility for financing a basic human need—access to food—to those who can least afford it.
 Pavetti, LaDonna, “Work Requirements Don’t Cut Poverty, Evidence Shows,” Center on Budget and Policy Priorities, updated June 7, 2016, https://www.cbpp.org/research/poverty-and-inequality/work-requirements-dont-cut-poverty-evidence-shows.
 Hotz, Joseph; Imbens, Guido; and Klerman, Jacob, “The Long-Term Gains from GAIN: A Re-Analysis of the Impacts of the California GAIN Program,” November 2000, https://www.nber.org/papers/w8007.pdf.
 Bolen, Ed, “Trump’s Expected SNAP Change Would Target Jobless Workers,” Center on Budget Policy and Priorities, updated December 19, 2018, https://www.cbpp.org/blog/trumps-expected-snap-change-would-target-jobless-workers.
 Food and Nutrition Service, USDA, Proposed Rule Document, Supplemental Nutrition Assistance Program: Requirements for Able Bodied Adults Without Dependents, updated February 1, 2019, https://www.regulations.gov/document?D=FNS-2018-0004-5999.
 Wolkomir, Elizabeth, “SNAP Boosts Retailers and Local Economies,” Center on Budget Policy and Priorities, updated April 6, 2018, https://www.cbpp.org/research/food-assistance/snap-boosts-retailers-and-local-economies.
 Blinder, Alan S. and Zandi, Mark, “The Financial Crisis: Lessons for the Next One,” Center on Budget and Policy Priorities, October 15, 2015, https://www.cbpp.org/research/economy/the-financial-crisis-lessons-for-the-next-one.
 Poppendieck, Janet, “Proposed Rule Would Remove 775,000 People from SNAP Rolls, CUNY Urban Food Policy Institute, updated February 24, 2019, http://www.cunyurbanfoodpolicy.org/news/2019/2/21/new-proposed-rule-would-remove-755000-people-from-snap-rolls.
 Tarasuk, V., Cheng, J., de Oliveira, D., Dachner, N., Gundersen, C., & Kurdyak, P. (2015). Association between household food insecurity and annual health care costs. Canadian Medical Association Journal, 187 (14), E429-436.
 Berkowitz, S. A., Basu, S., Meigs, J. B., & Seligman, H. (2017). Food insecurity and health expenditures in the United States, 2011-2013. Health Services Research, 53(3), 1600-1620.