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Trump Administration's Attempts to Cut SNAP Through Regulations
The Supplemental Nutrition Assistance Program (SNAP) is the nation’s largest food assistance program. In 2019, the Trump Administration proposed three separate rules that, if implemented, would eliminate benefits for an estimated 3.7 million people.
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The Supplemental Nutrition Assistance Program (SNAP), formerly known as food stamps, is a federal program that helps low-income people buy food. The benefits average $256 per household every month, which breaks down to only $1.40 per person per meal, and are typically delivered monthly on Electronic Benefit Transfer, or EBT cards, that can be used in many grocery stores.
Last year, SNAP helped feed 38 million people across the country. More than 90 percent of SNAP households have incomes at or below the federal poverty guideline of $26,200 for a family of four. Almost half of recipients are children, and 21 percent are elderly adults or people with disabilities. Research shows that even meager SNAP benefits reduce poverty and improve health outcomes.
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Why is SNAP important right now?
From February through May, SNAP participation in states reporting caseloads increased by 17 percent as newly jobless people began applying for assistance; more than 6 million new people are projected to have participated in SNAP in those months. According to the Federal Reserve, almost 40 percent of households earning less than $40,000 a year lost their jobs in March. Food banks are trying to support people, but they are run by private charities and are not designed to meet the level of need we are seeing in the COVID-19 crisis.
SNAP is also an effective economic tool during recessions. Analysis has found that during times of economic downturn every SNAP dollar invested can generate between least $1.54 and $1.80 in economic stimulus. That means that SNAP can both make sure people have enough food and support a weakened economy.
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Rule One: Limits on Able Bodied Adults Without Dependents
Currently, SNAP includes restrictive work requirements. The rules limit a population defined as “Able Bodied Adults Without Dependents (ABAWDs)” from accessing SNAP benefits for more than three months in three years unless they can document at least 20 hours of work or approved job training per week.
In areas with high unemployment, states are able to have those work requirements waived, but a Trump Administration rule, proposed in early 2019, would have tightened the criteria for a waiver and stripped benefits from more than 700,000 adults. (Those estimates are from before the beginning of the COVID-19 pandemic, which continues to negatively impact economies across the country to varying degrees at different times as virus hotspots swell and recede.)
The rule was finalized in December of 2019, but stalled by legislation and legal challenges; despite the lawsuits brought by attorneys general in multiple states, rulings by a federal judge, and provisions in the Families First Coronavirus Act, the USDA made it clear they would continue to fight for its enactment.
On October 18, 2020, the rule was struck down in a summary judgement as “arbitrary and capricious.” The USDA has not yet commented on the ruling.
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Rule Two: Eliminating Categorical Eligibility
Eligibility requirements for SNAP, like income and asset limits, are determined on a federal level. Under a policy called “Broad-Based Categorical Eligibility,” households that receive any kind of benefit from the Temporary Assistance for Needy Families (TANF) program or a state “maintenance of effort,” which provide cash assistance and support services, are automatically “categorically eligible” for SNAP. That gives states flexibility to set higher gross income limits and allow for slightly higher levels of personal savings through those other programs, so that low-income households with high housing or child care expenses can receive the nutrition assistance they need as well. Those households must still submit an application and prove that they fulfill other SNAP eligibility rules (like a net income test and documentation requirements).
This rule ensures flexibility for states to help families avoid a drastic change in their benefits after a modest increase in their wages or savings, and creates streamlined processes for households to receive other benefits — for example, children who qualify for SNAP through Broad-Based Categorical Eligibility are also made automatically eligible for free school meals.
However, in July of 2019, the USDA proposed a change to Broad-Based Categorical Eligibility that would limit which TANF benefits make a household “categorically eligible” for SNAP — to qualify, a household would need to receive “substantial and ongoing” TANF benefits, defined as worth at least $50 for 6 months or longer.
The proposal would cut SNAP by $10.5 billion over five years and eliminate benefits for 3.1 million people. If the USDA’s proposed changes were implemented, more than a million children are at risk of losing SNAP benefits and almost a million would lose access to free school meals.
Although the comment period for the proposed rule has closed, the final rule has not been released or implemented. In late April, 22 state Attorneys General sent a letter to the USDA asking to suspend the rulemaking process around changes to BBCE, but no suspension has been announced yet.
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Rule Three: Capping the Standard Utility Allowance
To calculate eligibility for SNAP and the amount of benefits a household receives, the USDA estimates how much money that household has to spend by subtracting its monthly costs (like rent, medical equipment, and child care) from its total income to get a sense of how much money the family has left for food. To simplify these calculations, states have developed some “standard” costs rather than relying on individually reported costs from every SNAP applicant.
One of those standard costs is known as the Standard Utility Allowance, which is an average utility estimate for a household. Across states, the Standard Utility Allowance can range from $278 to $826 depending on household size and other factors. In general, the higher the Standard Utility Allowance, the less money a state estimates a household has left over for groceries after paying for utilities, and the more money they will receive in SNAP benefits.
In October 2019, the USDA announced a regulatory change that would standardize the formula for those calculations across every state and use a USDA-determined cap (at the 80th percentile of estimated costs to low-income households in the state) to decide how much in utility costs families can ultimately deduct from their incomes. This “small” technical change, however, has far-ranging impacts on the people who rely on SNAP. It would cut the program by $4.5 billion over five years and leave 7 million people with even fewer benefits than before.
This proposed rule has yet to be finalized or implemented, but advocates are pushing for emergency coronavirus response legislation to suspend all harmful rulemaking from USDA, including changes to the Standard Utility Allowance.
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Where Can I Learn More?
- For an analysis of the potential combined impacts if all three proposed rules were implemented: Estimated Effect of Recent Proposed Changes to SNAP Regulations, Laura Wheaton, The Urban Institute
- For a deeper look at what actions Congress can take to make SNAP work better during the COVID-19 crisis: Lawmakers Must Strengthen SNAP in Response to the Coronavirus Pandemic, Areeba Haider, Center for American Progress
- For a closer look at who would be harmed by more stringent work requirements: 6 Communities That Trump’s Latest SNAP Proposal Would Hurt Most, Donovan Hicks, Center for American Progress
- For an explainer on Broad Based Categorical Eligibility: SNAP’s “Broad-Based Categorical Eligibility” Supports Working Families and Those Saving for the Future, Dottie Rosenbaum, Center on Budget and Policy Priorities