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 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.

A 2021 study by the Urban Institute found 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 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.

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, "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.