On February 1, the Trump Administration proposed a rule that would restrict states’ flexibility to provide nutrition assistance to people who struggle to put food on the table. In effect, this rule will eliminate Supplemental Nutrition Assistance Program (SNAP) benefits for 755,000 unemployed and underemployed adults and amount to $15 billion in SNAP cuts over 10 years. The proposed rule would have a devastating impact on women and families who rely on SNAP for basic food assistance while they are working or between jobs. Regardless of negative stereotypes, taking away food assistance will not help people find and maintain work.
In December, Congress passed the 2018 Farm Bill, rejecting these same changes to SNAP. Members of Congress rightly saw that these changes to the SNAP program were punitive and contrary to the aims of the program. This new rule is an attempt to circumvent the will of Congress on food policy.
The recent 35-day government shutdown revealed the economic vulnerability of middle-class Americans and the vital importance of a federal nutrition safety net. In recent weeks, thousands of federal workers turned to the charitable food sector to meet their basic needs. Despite dozens of food pantries springing up and holding special events in unusual locations, thousands of hard-working Americans still could not put food on the table. The charitable food sector is not equipped to respond to the scope of food insecurity in the United States—and the shutdown only highlights the critical need for SNAP.
The proposed rule is currently open for public comment until April 2, 2019. You have the right to submit a comment to the USDA letting them know that this rule is bad for workers and a bad way to make public policy. Make sure to prepare your comment and then visit the federal register comments page.
Sample letter –
To Whom it May Concern:
[PERSONALIZE BELOW. DELETE THESE INSTRUCTIONS AND ADD YOUR OWN WORDS BELOW or this message will not be registered.]
I am writing to comment in opposition to USDA’s Proposed Rulemaking on SNAP requirements and services for Able-Bodied Adults Without Dependents (ABAWDs).
As a Presbyterian Christian, I believe that all people should have access to food, regardless of their income. I further believe in the dignity of work and the value of standing up for those working to lift themselves out of poverty in the United States. I am opposed to this rule because…
[ADD YOUR OWN WORDS.]
SNAP plays a critical role in addressing hunger and food insecurity in our community. It is the first line of defense against hunger for low-income residents. Based on USDA Economic Research Service analysis, it is estimated that each $1 in federal SNAP benefits generates $1.79 in economic activity. Those dollars help many food retailers operating on thin margins to remain in business; something that improves food access for all residents.
Federal law limits SNAP eligibility for childless unemployed and underemployed adults age 18-50 (except for those who are exempt) to just three months out of every three years unless they can obtain and maintain an average of 20 hours a week of employment. This rule is harsh and unfair. It harms vulnerable people by denying them food benefits at a time when they most need it and it does not result in increased employment and earnings. By time-limiting food assistance to this group, federal law has shifted the burden of providing food to these unemployed individuals from SNAP to states, cities, and local charities.
I strongly oppose the proposed rule that would expose even more people to the arbitrary food cutoff policy by limiting state flexibility regarding area waivers and individual exemptions. 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 ten years. The Administration does not estimate any improvements in health or employment among the affected population.
The Administration proposed rule seeks to ignore the intent of Congress, which just concluded a review and reauthorization of SNAP in the 2018 Farm Bill and did not make the proposed changes. The rules governing areas’ eligibility for waivers and individual exemptions have been in place for nearly 20 years. In that time, the waiver rules have proven to be reasonable, transparent, and manageable for states to operationalize.
As a person of faith, I strongly oppose the proposed rule that would expose even more people to the arbitrary SNAP food cutoff policy and harm our community.
The Department of Agriculture (USDA) has proposed a Supplemental Nutrition Assistance Program (SNAP) rule that would put time limits on food benefits for unemployed and underemployed people who can’t document a designated number of weekly work hours or job training. People who cannot meet the documentation requirement would lose SNAP eligibility after three months regardless of how hard they are trying to find work or advance job skills.
Experience teaches us that lifting oneself out of poverty is both dignified and hard work. Time limits complicate, rather than facilitate that goal. The proposed rule would adversely impact neighbors:
- Stringing together minimum-wage, part-time jobs may not put healthy food on the table. A job training course holds more promise for a living wage, but taking time to pursue it could jeopardize vital SNAP support and the health and welfare of the individuals who qualify for food assistance.
- Available work can come with significant stability challenges, such as schedules being posted weekly with varied hours and shifts, putting continuing education options and better job searches out of reach. SNAP time limits push those struggling to find this balance deeper into a cycle of insecurity.
- Rural realities can hamper efforts to move out of poverty. Available work may not match up with transportation options and commute distances. Time limits may deprive a hungry person of modest SNAP benefits that would help them focus on their future and not their next meal.
Additional Talking Points–
- By USDA’s own estimate, the proposed rule change would result in 755,000 people losing access to life-saving nutrition benefits.
- This proposal is out of touch with the reality of struggling Americans. Taking food away from unemployed and underemployed workers won’t help them find work faster.
- The proposed rule change completely ignores the realities of people who work inconsistent hours, lack access to transportation, live in areas where the economy has been slow to recover, or are unable to access employment and training programs—all of whom could fail to meet the harsh time limits imposed on SNAP recipients.
- If this proposed rule change goes through, more people will go hungry. Religious congregations and charitable organizations cannot make up the difference. National nutrition programs provide more than 10 times more food assistance than private charity.
- This new attack against SNAP is an attempt to circumvent congressional intent as laid out in the recently-passed bipartisan Farm Bill reauthorization. Instead of rulemaking that jeopardizes food assistance, USDA should focus on implementing the 2018 Farm Bill provisions that will help Americans get back to work.
- The recent 35-day government shutdown illustrated the economic vulnerability of middle-class Americans and the vital importance of our federal nutrition safety net—the charitable food sector is in no way equipped to respond to the scope of food insecurity in America.
Reasons to Oppose the Rule:
- Circumvents Congress, which rejected these changes when it enacted the 2018 Farm Bill.
- Causes serious harm to individuals who cannot afford to lose benefits on which they rely for daily bread.
- Does not improve the health outcomes or employment outlook of those impacted by the proposed rule.
- Harms grocery retailers and agricultural producers by reducing the amount of SNAP dollars available to spur local economic activity.