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CBO's Claim on SNAP Work Requirements Is Highly Suspect

Advocates question whether new enrollees will pour into the food
assistance program, given bureaucratic barriers and no additional
resources for caseworkers and agencies.

 

Jon Elswick/AP Photo

By Luke Goldstein

**** The Fiscal Responsibility Act (FRA), which passed
the House yesterday, makes several changes to the Supplemental Nutrition
Assistance Program (SNAP, sometimes known as food stamps). The changes
would deliver Republicans a long-sought policy goal to extend one of the
program's two work requirements, which will now be imposed on older,
able-bodied, childless adults aged 50 to 54. But President Biden is
selling his caucus on the idea that he actually outfoxed Republicans on
the deal, by pointing to exemptions from this work requirement granted
to three vulnerable populations: homeless individuals, veterans, and
young people recently out of foster care.

On Tuesday, the Congressional Budget Office sided
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with Biden's version of the argument. CBO estimates that the deal on
the whole would actually raise SNAP participation by 78,000, leading to
a slight increase (about $2.1 billion over ten years) in spending. This
has triggered gloating by Democratic partisans, who believe the
right-wing effort to deny food to impoverished people has been
neutralized.

In the near term, the CBO score may cause more upheaval among
Republicans intent on slashing funding on social programs. But it's
also a misleading evaluation of how SNAP is administered, according to
anti-hunger organizations that handle outreach to the program's users.

These organizations question many of the theoretical assumptions made by
CBO in scoring the food aid provisions, which fail to take into account
the reality of implementing these new policies. They instead argue that
the work requirements on older Americans will lead to the largest
restrictions on SNAP since welfare reform in 1996, while the exemptions
fail to account for long-standing barriers to including disadvantaged
populations in SNAP. Without additional funding for the withered
administrative capacity at state and local agencies, many of these
groups will likely not be able to participate.

"We have far more certainty about what the impacts will be of the
punitive measure in the bill than we do about the potential exemptions,"
said Ellen Vollinger, the SNAP program director at the Food Research and
Action Center.

The able-bodied work requirement creates a time limit for nutrition
assistance of a maximum of three months over a three-year period for
those who do not qualify. Research has shown that this policy is a crude
tool that mostly kicks people off SNAP rather than promoting greater
labor market participation. In other words, SNAP isn't designed to be
a jobs program.

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A 2021 study by the Urban Institute found
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that time limits, since their reinstatement in 2016 after a temporary
freeze during the Great Recession, did not lead to any increase in job
employment among SNAP participants. Instead, work requirements strand
low-income people, who would otherwise qualify based on their income
levels, from accessing the program.

That happens often because people fail to receive proper information
about the exact details of the work requirements, or even when they do
meet the minimum work hours, they may face challenges in procuring pay
stubs to prove their eligibility based on their line of work. Older
people, the group targeted by this new set of work requirements, also
have a harder time finding work to meet the 80 hour/month minimum
imposed by the 1996 welfare reform. On net, work requirements lower SNAP
enrollment numbers for this age cohort and force older people to go
hungry.

The exemptions for certain populations, the purported concession for
accepting work requirements in the FRA, rest on shakier ground. Rep. Jim
McGovern (D-MA) thus far has been one of the more outspoken progressives
against accepting the exemptions as sufficient victories. In an
interview with Politico
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on Tuesday, he blasted the deal, saying, "This is a food benefit. So
moving the deck chairs around and saying, you get food, but you
don't-that's not a very convincing argument to me."

Though anti-hunger advocates welcome the exemptions, they don't see it
as a justifiable trade-off. And they don't believe it will increase
SNAP enrollment without the government making additional resources
available.

The three groups that would receive exemptions from work requirements
are seen by the advocacy community as the most difficult to identify at
the population level and get assistance from outreach services. Though
the challenge is especially pronounced for homeless individuals, many of
the same burdens apply for veterans or people in foster care, since both
groups often have a higher chance of losing housing. At a basic level,
food assistance and homelessness organizations don't even have an
exact estimation of how many people are unhoused, a number which many
believe is far underestimated by official city-level data.

The Maryland Hunger Solutions organization has primarily faced a
technological burden to get these groups included in SNAP. To get signed
up for many social services such as SNAP, many cities have required
access to a mobile device or a computer since the start of the pandemic,
when a lot of administration moved online.

"Most of the people we deal with who are in these categories, especially
unhoused, just have very limited access to those digital devices, which
dissuades them from getting enrolled for SNAP," said JD Robinson, the
program coordinator for SNAP at MD Hunger. To succeed in implementing
the new SNAP exemption policy, MD Hunger would encourage greater funding
to expand digital access.

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Even once anti-hunger groups are able to get homeless people set up with
caseworkers, there are further institutional barriers in the next steps
to keep them enrolled. While a mailing address isn't required, it's
encouraged for SNAP beneficiaries to have one to receive notices for
additional forms from caseworkers or program changes, which frequently
occur. That of course makes it harder for homeless people or young
people out of foster care without stable housing.

Advocates also pointed to past struggles that food aid organizations
have faced to communicate policy changes to homeless people and other
groups. Even if the exemption goes through, it takes extensive efforts
just to inform people who have previously been kicked off SNAP that they
can now reapply.

"We're worried just about getting people into the front door, even if
other restrictions have been lifted," said Victoria Negus, a policy
advocate at the Massachusetts Law Reform Institute.

Exceptions to rules rather than changing the rules themselves can create
greater administrative challenges for typically understaffed caseworkers
and agencies. One clear example is the difficulty to enforce the work
requirement exemption for the disabled, who make up a sizable chunk of
SNAP users. Many people who could qualify due to either mental or
physical disabilities don't have physician assessments to verify a
disability for the SNAP paperwork. In that case, many aren't able to
find work and meet the requirements.

Exemptions are not always clear-cut, as Andrew Cheyne, the manager of
public policy at GRACE and End Child Poverty, explained to the

**Prospect**. They depend on exact definitions set by the USDA for state
agencies to carry out and create bureaucratic subcategories and further
burdens of proof. Being homeless, for example, can mean either they have
unstable housing, they sleep on the street, or they're temporarily
living in a shelter. Without further guidance, caseworkers have to make
assessments on a case-by-case basis, which can cause ambiguity.

Rep. Pramila Jayapal (D-WA), chair of the Congressional Progressive
Caucus, also noted on a conference call on Tuesday that exempted
individuals would have to go through "more bureaucratic red tape" in
order to qualify.

This problem has already played out for the "chronically homeless," a
nebulous rule on the books which is supposed to let people off the hook
for work requirements as they're deemed unfit for employment. In other
words, many people experiencing chronic homelessness, including
veterans, are already supposed to be exempt from the able-bodied work
requirement in SNAP. As Sharon Parrott with the Center on Budget and
Policy Priorities explained
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"the need for a special category exposes the failures of the current
exemption system."

Some exemptions may be better than nothing. But the CBO score
shouldn't be taken at face value as any indicator of what the true
limitations will be for actually implementing new SNAP policy changes.

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