Olivia Arena and Nicole DuBois contributed to this post.

The Supplemental Nutrition Assistance Program (SNAP), also known food stamps, plays a critical role in the social safety net, helping approximately 39 million Americans put food on the table each month.

A landmark 2016 study on the initial roll-out of the food stamp program in the 1960s shows that children with access to the program had lower rates of obesity, heart disease, and diabetes as adults. And SNAP not only reduces food insecurity—it’s also an effective antipoverty tool.

Here are four trends we are monitoring in SNAP policy in 2019:

1. Potential for less flexibility for states to waive SNAP work requirements

The farm bill reauthorization debate in 2018 focused on a proposal to intensify SNAP’s work requirements. The proposal, which ultimately didn’t make it into the final bill, would have strengthened work requirements for parents of school-age children, requiring them to work at least 20 hours a week to maintain eligibility, and would have raised the age of able-bodied adults without dependents (ABAWDs) subject to work requirements and time limits from 49 to 59.

Upon signing the farm bill in December, however, the Trump administration signaled interest in efforts to tighten up so-called ABAWD waivers in 2019. On February 1, the US Department of Agriculture (USDA) published its proposal rule to revise the criteria by which states are granted permission to waive work requirements for ABAWDs. The public has 60 days to submit comments on the rule, which would not require congressional approval to be implemented.

Currently, ABAWDs can receive benefits for only three months within a 36-month period without having to work 20 hours a week to maintain their eligibility. But for those living in areas of high unemployment relative to the national unemployment rate or with a demonstrable lack of jobs, states can waive these requirements—either in specific areas that meet criteria for economic disadvantage or across the entire state. Granting waivers is not automatic but rather requires the USDA to approve waivers for which states apply.

This capacity to waive time limits augments SNAP’s ability to be an automatic stabilizer when the economy deteriorates (PDF), which was especially true during the 2008 recession.

In the first quarter of 2019, 7 states and territories had statewide waivers and 29 states had partial waivers (PDF). Some states, such as Kentucky and Arkansas, have lifted waivers mostly or completely, despite the fact that many areas could still qualify for them based on economic criteria. As a result, time limits for ABAWDs have been reinstated even in counties with persistently high unemployment rates, such as Magoffin County, Kentucky, where the unemployment rate was still 12 percent when the waiver was eliminated in May 2018.

In the proposed rule, states applying for ABAWD waivers for specific counties or across the state would have to show that these geographic areas have an absolute unemployment rate of 7 percent, as opposed to the current benchmark of 20 percent above the national average unemployment rate.

The concern likely to be raised during the comment period is the risk that new restrictions could hamstring SNAP’s ability to respond effectively to future recessions. The proposed rule also makes it harder for states to tailor requirements to local labor market conditions, which may be worse than statewide or national conditions.

2. Limited capacity of employment and training programs to serve new demand

By some estimates, more than 750,000 ABAWDs could lose SNAP benefits if the USDA proposal is implemented. If employment opportunities are not available for beneficiaries who must comply with work requirements, some may be able to fulfill it by participating in employment and training (E&T) services offered by state SNAP programs.

States are required to offer E&T services to SNAP participants, but studies show that E&T systems remain limited in their capacity to meet current need. Experts warn that because SNAP E&T already serves a small share of those who are subject to current work requirements (PDF), ABAWDs—particularly those with limited skills—who enter the system as a result of time limits being reinstated may not be served adequately.

A recent report from the Kentucky Center for Economic Policy highlighted this concern, concluding that the state’s E&T system is “inadequate to improve the lives of Kentuckians it is meant to serve.” In states seeking to implement Medicaid work requirements, such as Kentucky, the pressure on limited E&T capacity may increase if new requirements move forward.

3. State agendas to limit—or expand—access

SNAP is a federal entitlement program in which the federal government pays 100 percent of the benefit cost, but states and the federal government split costs to administer the program. In many cases, states pursue their own SNAP policies and requirements, sometimes through options available under current law, while other changes require the federal government’s approval.

In 2018, several states introduced legislation requiring the removal of or limiting applications for ABAWD waivers, and some states have pursued other measures—such as drug testing or extending disqualification periods—that could limit access to SNAP benefits for some participants. In 2018, the Wisconsin legislature approved a measure to expand the per week work requirement for parents of school-age children to 30 hours by October 2019.

On the other hand, last year, Ohio waived work requirements in 11 counties, including those that include Cleveland and Toledo. A study published shortly before Ohio’s decision showed that white people were more likely than black people to live in exempt counties.

4. Participation of immigrant families in SNAP and other nutrition assistance programs

The Trump administration’s public charge proposal would make it more difficult for noncitizens to obtain green cards or temporary visas if they have participated in safety net programs, have limited English proficiency, or don’t have incomes above 125 percent of the federal poverty level, among other personal characteristics.

While most noncitizens are ineligible for SNAP, noncitizen children, citizen children with noncitizen parents, lawful permanent residents older than 18 who have had their green cards for five years, and certain other immigrant households are eligible for SNAP benefits.

While the rule hasn’t been finalized, it—as well as broader anti-immigrant policies—has already had a chilling effect on immigrant participation in SNAP. Early analysis by Children’s Health Watch documented a 10 percent drop in SNAP enrollment among immigrant families in early 2018.

Policy experts and advocates will continue to monitor the effects public charge and other proposals have on immigrant families’ participation in SNAP and other vital nutrition assistance programs like the Special Supplemental Nutrition Program for Women, Infants, and Children, which is not included in the public charge proposal but has already experienced disenrollment by families with noncitizen members.