I am Joel Berg, Chief Executive Officer of Hunger Free America, a nationwide direct service and advocacy organization based in New York City. This comment is being submitted on behalf of our organization and those across the nation who struggle with putting enough food on the table for themselves and their families.
According to President Trump’s own administration, the proposed rule: Supplemental Nutrition Assistance Program (SNAP): Requirements for Able-Bodied Adults without Dependents RIN 0584-AE57, could take up to $15 billion worth of food away from up to 755,000 of the most vulnerable low-income Americans over the next ten years.
This rule, if enacted, would deny food for people who are temporarily unemployed, hampering their ability to find productive work. It would, ironically, force unemployed people to halt their job search to go to government offices to attest that they are looking for work. It will increase hunger while doing nothing to increase employment.
In 2017, according to USDA, 40 million Americans, (a population larger than the combined populations of Texas and West Virginia), suffered from food insecurity, unable to always afford a sufficient supply of food. Hunger Free America’s analysis of USDA data found that 14.76 million American adults in 2015-2017 were working for income but still lived in households that were food insecure. While food insecurity across the country overall – as well as food insecurity among working people – would be far higher if SNAP did not exist, we believe that the single most important goal for improving SNAP should be to expand and strengthen it so that it helps virtually eliminate food insecurity and hunger in America.
It is vital to note that the SNAP program is already incredibly effective in enabling work outside the home. According to the Center for Budget and Policy Priorities, 90 percent of SNAP households with children had at least one parent working for income the year before and the year after getting SNAP and nearly 75 percent of adults who participate in SNAP in a typical month work either that month or within a year of that month of participation.
As is the case with unemployment insurance, people pay for SNAP with their tax dollars when they are working, and, if they are temporarily unemployed, they then receive back (in the form of benefits) a bit of what they have previously paid into the system.
Moreover, the vast majority of Americans who rely on SNAP are children, older Americans, people with disabilities, and working people. Only about 7 percent of SNAP recipients are classified as Able Bodied Adults Without Dependents (ABAWDS) who are not currently working. Many people who are in this category are veterans, some of whom have undiagnosed post-traumatic stress disorders.
So we note the great irony that, rather than focusing on ending food insecurity for the 40 million Americans who suffer from it, the Trump Administration is hyper-focused on taking food away from the seven percent of the caseload that are ABAWDs.
USDA concedes that while the proposed changes “have the potential for disparately impacting certain protected groups due to factors affecting rates of employment of these groups, [it] find[s] that implementation of mitigation strategies and monitoring by the Civil Rights Division of FNS will lessen these impacts.” But they give no explanation of what those “mitigation strategies and monitoring” will entail, so there is no way to know how those potential disparate impacts could, in fact, be mitigated.
The best way for the executive and legislative branches to slash U.S. food insecurity and increase paid employment is to create more jobs and ensure that these jobs pay a living wage. But for the foreseeable future in the U.S., there will not be enough living wage jobs. Additionally, increased wages alone will not end hunger for most children, older Americans, people with disabilities, or people looking for work. Moreover, we believe no American of any age or status should go hungry.
Some people judge the success of anti-poverty programs solely on whether the use of those programs goes down over time. Such a limited metric makes little sense and is tantamount to judging the success of a hospital solely by how many people leave the hospital, without differentiating between how many people leave the hospital cured, equally ill, or dead. A reduction in the SNAP caseload should only be considered a success if it corresponds to a reduction in food insecurity and hunger in America. That principle should apply to a reduction in the ABAWD caseload as well, which should only be judged successful if hunger decreases among the ABAWD population.
Limiting ABAWD waivers – especially without adding a penny for job creation or wage hikes -- would increase hunger and fail to increase employment. It would be the wrong solution to the wrong problem. Such a change would be based on the false assumption that low-income Americans don’t want to work, so they need to be forced to do so. Yet the vast majority of low-income adults – including SNAP participants – are regular workers. Most proposals to limit ABAWD waivers do not include an extra penny for job creation, job training, or job creation. Trying to place more people in employment without spending more money on employment would be as ineffective as trying to solve drought without more water. Eliminating waivers won’t create jobs; doing so would mostly increase bureaucracy and paperwork by forcing SNAP participants to take time out of their jobs or their job searches to report to a SNAP agency that they are working or looking for work, and then force states and counties to record and report those activities. Furthermore, under the Trump Administration, USDA has repeatedly said it wants to increase the flexibility that states have to administer SNAP; it is wholly inconsistent to then reduce flexibility that states now have to aid SNAP participants. The executive and legislative branches should work together to eliminate special ABAWD requirements entirely and use the administrative funds saved to support concrete job creation activities.