Testimony of Joel Berg, CEO, Hunger Free America Hearing Before The New York City Council Committee on Committee on General Welfare


Testimony of Joel Berg, CEO, Hunger Free America

Hearing Before The New York City Council Committee on Committee on General Welfare

June 27, 2017

My name is Joel Berg, and I am the CEO at Hunger Free America. Formerly called the New York City Coalition Against Hunger, Hunger Free America changed its name in 2016 to better reflect the broad scope of our national work. This was also accompanied with intensifying our local efforts under the new name, Hunger Free New York City.

I want to thank Chairman Levin and the rest of the Committee for your work fighting on behalf of the most vulnerable New Yorkers, as well as for the opportunity to testify. Hunger Free Americans strongly supports  both Int. No. 855 and Int. No. 855-A to make it easier, less costly, and less bureaucratic for low-income New Yorkers to access safety net programs, many for which are federally-funded by underutilized.  I would like to thank Council Member Kallos for introducing these pioneering bill.

Background on Hunger in New York

Hunger is a significant problem in the United States, as 42 million Americans,[1] including 12 million children lived in households that struggles to afford enough food in 2015. Nearly 3 million New York State residents, including 1.4 million New York City residents, lived in such homes. [2] In 2013-2015, almost half of all food insecure households in New York City include at least one person working, approximately 424,307 residents. Forty-five percent of all food insecure adults in New York City were employed. Low-income communities face both income scarcity and time scarcity, compounding the challenges to overcome these barriers.

The top reasons for this food insecurity are low wages, too few jobs, the high costs of living, and an inadequate safety net programs. One key additional factor in under-participation in existing federal programs.

Background on the Opportunity Costs of Poverty

       Economists often apply the term “opportunity costs” to high and middle-income people, meaning that the time they spend on one task is time not available to perform other, potentially more valuable tasks. But social scientists rarely apply the concept to low-income people, acting as if their time is essentially worthless. Similar to a spouse who doesn’t count your food shopping, cooking, cleaning, child-rearing, accounting for family finances, shuttling family member to appointments, taking care of your sick parents, etc., etc. as work.     

Yet in addition to lacking money, low-income Americans frequently lack time. Just as many personal relationships collapse when people don’t have “quality time” with each other, a lack of time works mightily against the efforts of low-income people to have constructive relationships with their families and with the broader society.

Many low-income people work two or even three jobs. If they are unemployed, they spend a great deal of time looking for work. They often travel by public transportation, laboriously making one, or two, or three connections to shuttle between home, work, social service agencies, houses of worship, and grocery stores. If they work as a nanny for someone else’s children, because they themselves can’t afford to pay for childcare or babysitters, they also must take the extra time to care for their own kids. If they work as home health aides to assist someone else’s parents, because they can’t afford home health care themselves, they also must take the time to care for their own folks.  

While it’s true that government safety net programs help tens of million Americans avoid starvation, homelessness, and other outcomes even more dreadful than everyday poverty, it is also true that government anti-poverty aid is generally a major hassle to obtain and keep.  Congress, which creates the laws governing the programs, and most state and localities, which implement those laws, purposely make it extremely difficult to advertise these programs and enable families to access them. That’s why many low-income people are actually unaware of all the government benefits for which they are eligible, reducing the amount of help going to Americans in need by tens of billions of dollars every year.

Even if low-income people do know about available aid, the journey to receive it is usually long, onerous, and time-consuming. They need to go to one government office to apply for SNAP (Supplemental Nutrition Assistance benefits, formerly known as food stamps), a different government office to apply for housing assistance, a separate WIC (Women, Infants, and Children nutrition program) clinic to obtain WIC benefits, and a variety of other government offices to apply for other types of aid – sometimes traveling long distances by public transportation or on foot to get there, and then, once they’ve walked through the door, they are often forced to wait for hours at each office to be served. Even when people initially apply for benefits online, they often have to physically go to one or more government offices to follow-up. They need to bring piles of paperwork to each office, usually with slightly different combinations of documents every time. Making copies of the paperwork also takes time (and money). The lines in these offices can seem endless, and sometimes clients need to wait outside, for hours, in the worst kinds of weather.  If the office is especially backed up that day, or if the government case workers lost the previously-submitted paperwork, yet another visit on another day will be required, taking the same excruciating travel and waiting times. Many offices don’t have weekend or night hours, so if an applicant works, she or he will likely lose wages by applying for government help, since most low-income workers, unlike white-collar workers, often get no paid leave. Clients can try calling on the phone, but it’s rare for a human being to actually answer, and the voice mailboxes are often full.

And when a bureaucrat finally sees an applicant at an office, they will usually ask many of the same intrusive, detailed, lengthy questions about finances and personal situations as similar government workers did at the last three offices. It’s as if you have to explain to 12 different cousins at six different family get-togethers why your marriage fell apart and why you need to sleep on each of their couches for a night – while also having to hand over to each of them your complete tax records to prove why you are too broke to pay rent to them for that night of couch-surfing. In most places, families must even fill out additional forms, which their children must bring to school, to qualify their kids for free or reduced-price school meals.

To be sure, these government benefits provide a critical lifeline – and they often are the difference between a family eating and not eating and between them having a home or being homeless – but just because these programs are vital doesn’t mean they are perfect. Besides, more affluent Americans aren’t forced to jump through nearly as many hoops when they obtain far more expensive government aid, like farm subsidies or tax deductions for their vacation homes.

To obtain some form of help, low-income benefits applicants may also be required to attend job readiness classes, even if they have jobs are children at home. Such classes are often useless exercises in writing résumés for jobs that don’t require résumés or in obtaining training for jobs that don’t exist. Often these classes are worthless time sucks for attendees and exist to give large payouts to politically connected contractors.  If applicants quit the classes, they often lose benefits for themselves and their children. The system pits parents against their children, over and over again.

       Are you fed up? Are you tired yet? Well, if you live in poverty, your day has only begun.

Most poor folks, like all of us, also have to file tax returns with the IRS, sometimes paying a tax preparer handsomely to do so, even if the government owes them an EITC refund payment. A Progressive Policy Institute study found that in 2016, low-income workers paid an average of around $400 each to national tax preparation chains.[3]

       But wait, there’s more.

       Given that the United States has hundreds of thousands of nonprofit groups providing social services, it is nearly impossible for struggling people to determine which of those organizations provides services they need, whether the organization is conveniently located, and for which services they are eligible. If they do figure out that a nonprofit (or multiple nonprofits) could help, they will need to take the time to visit each one, where sometimes lines around the block ensure yet another seemingly endless wait, only to fill out even more paperwork, and go through yet more interviews.

       And since many government and nonprofit programs require frequent re-applications and re-certifications, a low-income person often has to jump through all these hoops every few months. In America, trying to get out of poverty can be a full-time job.

        Plus, it’s rare for the multiple government and nonprofit programs aimed at low-income people to work together in a coherent fashion to bolster families’ long-term self-sufficiency. Too often, these programs work at cross-purposes, so that obtaining one benefit might make a recipient ineligible for another. (The reverse is sometimes true, where getting one benefit makes a recipient automatically eligible for other benefits – but conservatives are trying to make that less common.) Sometimes a person can’t win for losing, such as when she or he finally gets a raise and then loses benefits because of it, and the amount of the raise is less than the value of benefits lost.  On the other hand, getting a job can make someone eligible for EITC payments, the value of which may exceeds the amount of benefits lost. But that’s a crap shoot too because it often depends upon household composition and a variety of other factors.

The Government/Nonprofit Social Services Status Quo

And that’s not all.

If low-income people don’t have a checking account or credit cards (and most don’t), they can’t pay bills by mail or online. Instead, they have to pay for everything in cash, spending money on extremely high fees at check cashing facilities that prey on residents of poor neighborhoods. And even then they aren’t done, because paying bills in cash often requires a visit to the phone company, the electric company, the landlord, and the gas company, where more long lines await the person who must pay their bills in person.

       Poor folks are less likely to have a washing machine in their homes or buildings, so more time must be spent at laundromats. There are neither doormen at their buildings, nor secured delivery spaces, so if they ever get a package, a trip to the post office is necessary – where they will inevitably find even more lines.

       For all Americans, including well-off ones, modern life is complex. There are always a zillion family, work, personal, community, religious, and civic obligations. With ever-shifting and complex options, it’s a challenge to effectively juggle them all and it can feel impossible to plan for the future. But affluent Americans are able to get professional help in sorting through their options and obligations, utilizing the best personal assistants, financial advisors, and modern technology that their money can buy.  Similarly, our government needs to get serious about helping low-income people clarify their options and simplify their lives.   

Putting HOPE into the Palm of Your Hand

       Technology has fundamentally revamped the lives of most Americans, usually for the better. Now it’s time for use digital technology – combined with policy improvements -- to simplify the lives and boost the long-term self-sufficiency of our lowest-income residents. That’s is why Hunger Free American has proposed that our federal, state, and local governments to create online HOPE (Health, Opportunity, and Personal Empowerment) accounts and action plans.

       Here’s how HOPE would work: The President and Congress would need to work together to enact a law that would authorize the federal Departments of Health and Human Services (HHS), House and Urban Development, (HUD),  Treasury,  and Agriculture (USDA) to work together -- and to form public/private partnerships with banks, credit unions, and technology companies – to  create HOPE accounts and action plans that combine improved technology, streamlined case management, and coordinated access to multiple to federal, state, city, and nonprofit programs that already exist. States and localities would initially be asked to participate in pilot projects implementing the accounts and plans, and, if they would, would be required over time to implement them universally.

One the accounts and plans are in place, workers could voluntarily choose to also have their paychecks deposited directly into the accounts, which would be held by private banks and credit unions that voluntarily chose to participate in the program. Families could also use the accounts to increase their savings, which would be matched by government and private sources, incorporating both IDAs and Kids Accounts. Job training and placement services would be modernized to connect real people with real jobs, and people could use the account app to easily locate and sign-up for such services online. All these efforts would work together in harmony to better give people in poverty the tools they need to take charge of their futures and to implement long-term plans to climb into – and stay in – the middle class. If Congress fails to pass authorizing legislation, the next President could achieve much of the above administratively. Also, if Washington fails to act fully or at all, states or localities could step up to the plate to enact similar programs on their own.

       The federal government, and/or states and localities SUCH AS New York, could issue open calls to allow a variety of banks and credit unions to compete to create such accounts, and they pick a number of the best proposals, thereby allowing low-income consumers with a choice of financial institutions to pick,  Once set up, HOPE accounts would enable families to use any smart phone, tablet, or computer to learn about the public and philanthropic programs for which they are eligible – including aid to improve health, nutrition, job training and placement, housing, income, etc. – and then apply for all of these programs at once from the convenience of their device. If supporting documents need to be submitted with the application, then families could take pictures of those documents and submit the pictures with the application. A surprising number of low-income people already have smart phones and/or home computers, not because they are luxuries, but because they are essential tools of learning and work in modern America. But families that don’t own a smart phone, tablet, or computer could be provided a basic one, along with a subsidized Wi-Fi/Internet access plan, and people uncomfortable with technology could go to a library, government office, or nonprofit agency to be walked through the system. For elderly and disabled shut-ins who can’t access the technology, government or nonprofit employees and/or AmeriCorps national service participants could make home visits to help. As noted previously, the AmeriCorps program should be expanded dramatically to aid these and other vital efforts.

To make it easier to access health care, HOPE accounts would also clearly specify medical benefits, and any out-of-pocket costs, for each of the health plans for which the users are eligible, and empower them to easily select the plan that works best for them.

The accounts would also enable working families to file for federal EITC refunds, and, in states and localities with their own supplemental EITC payments, to simultaneously file for those as well. Since the accounts will already have all the financial information needed to file for those payments, families could easily do so with this app, saving the time and money they would otherwise have to spend on third-party tax filing services.

While HOPE accounts are a new idea, the concept builds upon existing programs, such as the IDA program, and incorporates technological improvements in social services delivery that some forward-thinking states, cities, and counties are already implementing. For example, in New York City, the city government is already using updated technologies to allow families to apply online for multiple government benefits, through a portal called Access NYC (https://a069-access.nyc.gov), which allows users to pre-screen their eligibility for array of government programs, and, for some of the programs, to apply for them on line.   The city has even started a pilot project to allow people to apply for SNAP and cash assistance, but not other programs, by smart phone. But even in New York, the number of programs to which someone can actually apply online is limited, and applicants still must follow various procedures, on various timelines to access various programs, and still must visit or call multiple offices.

A Better Alternative: Online HOPE Accounts

Building on such innovations, but moving beyond them, HOPE accounts would enable families to rapidly apply for – and quickly learn if they are accepted into – all federal, state, and local government programs, as well as offer users information for wide variety of services provided by nonprofit groups. HOPE accounts would also include a calculator system to help families understand the financial impact of one program upon other programs.

All program benefit funds would go into the same system, with health care, food, housing, and other specific benefits accounted for separately from the cash. Overall funding for these programs would be maintained, or increased, and federal benefits that are now entitlements, such as SNAP and Medicaid, should continue to be entitlements, which people would still have a legal right to obtain. Families would also be encouraged to put their own cash savings into the accounts, which could then be matched. Any cash in the account set aside for education, job training, starting a business, or buying a home would be non-taxable. Sure, that’s a bit complicated, but still a heck of a lot easier for a family than figuring out all this out on their own. And if they still need help, some government and nonprofit social workers would still be available to guide them through the application and follow-up processes.

       The accounts would allow low-income families to easily access and monitor – in one central online account – the status, amounts, and recertification deadlines for all their benefits and savings. They could also use the accounts to pay all bills online, saving outrageous check cashing fees, and enormous amounts of time.

       The accounts could also include a budgeting function to give families real-time cash flow data and long-term financial planning data, including helping them to calculate how much they would lose in interest on credit cards versus how much they would gain in interest by saving more. The accounts would offer a calendar and scheduling function, enabling families to keep track of all job search, work, family, and school obligations, as well as any social service filing or appointment dates.[4]

Instead of a vast army of government and nonprofit caseworkers in charge of micromanaging the lives of low-income people, low-income adults would become, in effect, their own case managers. With this newfound power, people will be able spread their wings and take flight.

But to intrude on this love fest just as bit, I have to admit that these new apps and social service computer systems will be extraordinarily challenging to build and even more challenging to integrate with each other, especially given the current, antiquated condition of government social service computer systems, especially at the state level, and a unique system would need to be set up for each state.. These new system must combine ease of client access with very strict protections against fraud and theft, not easy considerations to balance. So the nation’s top tech leaders and companies would need to be challenged to work together with government to make this a reality. Dear Mr. Gates, Zuckerberg or Bezos: if you successfully accomplish this, we’ll add you to Mt. Rushmore – or if you prefer, we’ll carve a new monument on one of the Santa Cruz Mountains.[5]  Alternatively, the White House – with input from HHS, HUD, Treasury, and USDA – could sponsor a competition that would provide a monetary reward for the company (ies) that built the best app to fuse all these programs.

       It is also vital to stress that technological innovation alone won’t solve these problems – a wide variety of federal and state laws must change in order to ensure seamless interactions between varied social service programs.

Likely Objections from Both the Left and the Right

Some conservatives will no doubt fear that an approach like HOPE would make it easier for low-income people to get government assistance, thereby increasing dependency and government spending. But HOPE would reduce government bureaucracy and paperwork, and ensure that more of the money spent goes to helping families instead of bureaucracies, all of which are professed conservative goals.

Some conservatives believe that getting government help should be a difficult, shameful process, and making it less so would only increase dependency on government. But it’s inconsistent for the Right to argue for government to be less intrusive in the lives of most Americans but more intrusive in the lives of low-income Americans. Plus, by freeing up parents’ time to give them more ability to work, study, and spend time with their families, HOPE is “pro-family,” “pro-work,” and “pro-education” and thus would reduce long-term dependency.

Some liberals may also be wary because, at first blush, Hope accounts and action plans appear to be similar to the punitive contracts and safety net slashing block grant proposals advanced by Paul Ryan and other conservatives. But God is in the details, and, in reality, the HOPE accounts and actions plans would be 180 degrees different in both intention and implementation from conservative schemes. Yes, the delivery mechanism sounds similar, but we should not fixate too much on delivery mechanisms. After all, the Internet is a delivery mechanism that can deliver either text from the bible or pornography – it’s the content, not the delivery mechanism – that truly matters.  

The content of H.O.P.E is nearly the mirror opposite of the content of the Ryan plan. Ryan has used his anti-poverty plans as a cover for decimating existing government benefits for low-income families. In contrast, HOPE would provide anti-poverty benefits far above the current levels (out of new pots of money, not shifted from other antipoverty programs) so true self-sufficiency could be achieved. Unlike the Ryan and other GOP proposals that would replace existing federal programs, the HOPE accounts and plans would be in addition to existing government efforts. Unlike Ryan’s proposal, which assumes that his proposed opportunity grants can somehow succeed even if the rest of the safety net is slashed and the economy is still failing, this proposal assumes that HOPE accounts and plans can be effective in tandem with a strong safety net and the broad-based economic growth that creates jobs and raises wages. HOPE would also end the arbitrary benefit cliffs that kick in when families marginally increase their incomes as they struggle to enter – and remain in – the middle class. Ideally, the HOPE initiative would be funded robustly enough by the government and the philanthropic sectors so that all those ends could be achieved.

Liberals may also worry that HOPE might undercut public employees and their unions, which provide liberal candidates with vital troops, votes, and donations. Given the union-busting campaigns undertaken by Scott Walker, John Kasich, and other GOP governors, such concerns are understandable. So let me make it crystal clear that the HOPE proposal is based on the assumption that most public employees are dedicated, underpaid, and have a right to organize to defend their interests.  Some social workers would keep jobs similar to their existing ones, in order to answer questions about HOPE over the phone or from clients who still prefer face-to-face meetings. While HOPE would indeed eliminate most other government positions that are currently for handling paperwork and client interviews, this proposal recommends that employees holding those positions over time be transitioned into more useful functions such as training and placing low-income adults into living wage jobs, staffing universal pre-k programs, or aiding shut-in seniors. Public employees themselves would be happier if they spent less time filling out paperwork and more time directly aiding the public.

Some liberals worry that merely suggesting that government programs can be improved or that low-income Americans have personal responsibility for their own futures reinforces conservative messages, effectively giving “aid and comfort to the enemy.”  Some might argue more broadly that it’s inconsistent for anti-poverty advocates like Marianna Chilton and myself, to effusively praise safety net programs like SNAP, but also pointing out their significant flaws. Those arguments are also reasonable, but ultimately they are not convincing.  There’s nothing inconsistent in pointing out that programs significantly improve the lives of recipients but could help beneficiaries even more if they were modernized.  Just as even generally solid relationships can always be improved by both sides thoroughly addressing life realities (including painful realities), so too, social services can be further improved through an unflinching examination of their current defects.

       Some progressives might worry that funneling all anti-poverty funding into one program might it easier in the future for conservatives to cut them. Yet the recent trend of omnibus budget deals has already allowed conservatives to cut all anti-poverty programs at once with tools such as the sequestration process. Taking no action because you are afraid things could get even worse makes little sense. That’s sort of like when two people are in front of a firing squad, about to be executed, and one asks the other if they should ask for a cigarette, and the other responds: “Nah, I don’t want to make them mad.”

Taking the ostrich approach by ignoring both public concerns and real-life problems is a losing strategy, both substantively and politically. In contrast, FDR, the most successful progressive leader in US history, called for “bold, persistent, experimentation” because he understood that continually modernizing liberal programs was the best way to save them.

 The most effective political defense is an offense. The best way to push back against possible cuts is to fight for more funding, which is why progressives should be clear that that the HOPE system would need more money than the current system. 

In the end, though, the question that is most important is whether HOPE would make life better or worse – in both the short-term and the long-term – for the people the programs are intended to help. So let’s ask low-income Americans a basic question:

Should We Replace This … With This?

Given low-income Americans’ own frustrations with anti-poverty programs intended for their betterment the answer would likely to a resounding “yes."

Hunger Free America Strongly Supports Int. 0855 and 855 A

Hunger Free America Strongly Supports Int. 0855 and 855 as key steps towards implementing the HOPE idea. The requirement that HRA to pre-fill the application with any information they already have from the recipient’s original application and notify individual if they qualify for additional benefit will alleviate some of the time pressure of applying for benefits—both for case workers and program participants and move New York City towards a more comprehensive and effective safety net. We strongly support unifying the application process.

A recent qualitative study cited the need for improved application processing capacity and infrastructure as one of the 3 major themes emerged from interviews with SNAP outreach workers.[6] Long delays in processing time, complicated rules and involvement of the application process have been cited as sources of frustration from both the participants and the outreach organization.[7] A more streamlined application process through reduced wait times, simpler recertification, and increased use of electronic documentation would improve the application process. We believe this bill will increase SNAP enrollment by reducing barriers for new applicants and reducing burden on households that are recertifying.

Individuals should receive, if desired, all benefits for which they and their households are eligible. HRA providing the tools to simplify the process will avoid duplicative administrative costs and ensure the support for those in need. An econometric study estimated that SNAP caseloads increased by 6.2% in the year following implementation of automatically or “categorically” eligible for SNAP based on being eligible for or receiving benefits.[8] A simplified enrollment process has been shown to improve participation rates, and reduce the rate of in-person visits to the SNAP office for recertification. [9]

Short recertification periods make it more challenging for families to maintain their SNAP benefits because it may be difficult to maintain paperwork and travel to SNAP offices for transportation or work-related reasons.[10] An ERS-sponsored study found that in 2000, applicants who were ultimately approved for benefits spent an average of 6.1 hours on the process and were required to make an average of 2.4 trips to the SNAP office. Prior to welfare reform, applicants spent an average of 3.9 hours and 1.6 trips to be approved for participation.[11]

“Churning” occurs when SNAP participants leave the program and reenter less than 5 months later, causing additional costs to the program despite what is most likely no change in eligibility.[12] Eligible adults who work full time during nontraditional hours (i.e. nights and weekends) were more likely to participate in SNAP than those who work traditional daytime hours, and eligible adults with more than one job are even less likely to participate in SNAP. [13]

Households tended to exit SNAP during the recertification process due to application deficiencies, such as missed recertification, financial ineligibility, or incomplete information. Current practices continue to emphasize limiting fraud, despite the program having the lowest fraud rate in its history.[14] People’s needs during times of recession and long-term unemployment should outweigh this concern. To alleviate food access concerns, it is important that those who are eligible are encouraged and can easily participate in social services programs such as SNAP. Simplifying the application process is no silver bullet in light of other problems associated with SNAP, such as income cliffs for eligibility; however this initiative makes strides in the right direction to address the underutilization due to difficulty with continued eligibility recertification and lack of information. We thank the Committee again for the opportunity to testify and look forward to working with you to make sure all New Yorkers and Americans have access to adorable nutritious food.


[1] United States Department of Agriculture Economic Research Service. Household Food Security in the United States 2015. 2016. https://www.ers.usda.gov/webdocs/publications/79761/err-215.pdf?v=42636 

[2] Hunger Free America. “The State of the Working Hungry: Low Wages Chief Cause of Malnutrition.” New York City and State Hunger Report, 2016. https://www.hungerfreeamerica.org/sites/default/files/atoms/files/National%20Working%20Hunger%20Release%20November%202016_0.pdf

[3] Paul Weinstein Jr, and Bethany Patten, “The Price of Paying Taxes II:  How paid tax preparer fees are diminishing the Earned Income Tax Credit (EITC),” Progressive Policy Institute, April 2016, accessed June 10, 2016, http://www.progressivepolicy.org/wp-content/uploads/2016/04/2016.04-Weinstein_Patten_The-Price-of-Paying-Takes-II.pdf

[4] Careful security and privacy protections would need to be put in place, so that only the family, and not the government, nonprofit, or banking partners, would be able to see the or track private financial and appointment information.

[5] Dear environmentalists: just kidding about the Santa Cruz mountains part. Please don’t send protesters in rafts to surround my apartment.

[6] C. A. Pinard, F. M. W. Bertmann, C. Byker Shanks, D. J. Schober, T. M. Smith, L. C. Carpenter & A. L. Yaroch (2017) What Factors Influence SNAP Participation? Literature Reflecting Enrollment in Food Assistance Programs From a Social and Behavioral Science Perspective, Journal of Hunger & Environmental Nutrition, 12:2, 151-168. http://dx.doi.org/10.1080/19320248.2016.1146194

[7] Fricke, H. E., A. G. Hughes, D. J. Schober, C. A. Pinard, F. M. W. Bertmann, T. M. Smith, and A. L. Yaroch. “An Examination of Organizational and Statewide Needs to Increase Supplemental Nutrition Assistance Program (SNAP) Participation.” Journal of Hunger & Environmental Nutrition 10, no. 2 (April 2015): 271–83. http://www.tandfonline.com/doi/abs/10.1080/19320248.2015.1004217?journalCode=when20

[8] Andrews, Margaret, and David Smallwood. “What’s Behind the Rise in SNAP Participation?” Amber Waves. (March 1, 2012). United States Department of Agriculture (USDA), Economic Research service. Food & Nutrition Assistance. https://www.ers.usda.gov/amber-waves/2012/march/what-s-behind-the-rise-in-snap-participation/

[9] Ibid [2]

[10] Atasoy S, Mills BF, Parmeter CF. The dynamics of Food Stamp Program participation: a lagged dependent variable approach. Paper presented at: 2010 Annual Meeting; July 25–27, 2010; Denver, CO. http://econpapers.repec.org/paper/agsaaea10/60963.htm

[11] Ibid [4]

[12] Mabli J, Ohls JC. Supplemental Nutrition Assistance Program dynamics and employment transitions: the role of employment instability. Applied Economic Perspective Policy. 2012;34:187–213. https://doi.org/10.1093/aepp/ppr045

[13] McKernan SM. Employment Factors Influencing Food Stamp Program Participation. http://www.urban.org/publications/410800.html

[14] U.S. Department of Agriculture, Food and Nutrition Service. Supplemental Nutrition Assistance Program payment error rates FY2011. http://www.fns.usda.gov/snap/qc/pdfs/2011-rates.pdf