On Thursday, President Trump signed the 2018 farm bill, closing a contentious chapter in this congressional cycle. In the months leading up the bill’s signing, House and Senate leaders wrangled over work requirements in the Supplemental Nutrition Assistance Program (SNAP).

The final bill does not include the House version’s proposal of stronger work requirements for parents of school-age children or able-bodied adults without dependents (ABAWDs) up to age 59, which were strongly supported by the administration.

The Urban Institute’s analysis of the House version found that, over the course of a year, 9.8 million SNAP participants potentially subject to the work requirements would have at least one month in which they did not meet them. But 52 percent of those participants would meet the requirements in another month—evidence that SNAP participants often have unstable work, a reality of many low-wage jobs. 

These findings echo other research on work patterns of able-bodied adults without dependents. A recent study found that 75 percent of households with childless adults were working within a year of receiving SNAP.   

Although the administration did not achieve stiffer work requirements through legislation, it signaled this week its intent to pursue stricter work requirements for adult SNAP recipients without dependents through regulatory changes (PDF), which do not require congressional approval. The proposed regulation will have a 60-day public comment period.

How the administration’s proposal could limit access to SNAP

The proposed rule change would restrict states’ ability to waive existing SNAP time limits and work requirements for SNAP participants with ABAWD status. Currently, these individuals are required to work at least 20 hours a week to continue receiving SNAP and are eligible for only 3 months of benefits in a 36-month period if they do not meet the requirement.

States can request to waive these time limits in geographic areas based on specified economic conditions, including where the unemployment rate has been higher than 10 percent over the past 12 months or where it has been 20 percent higher than the national average over a 24-month period.  

Four states and the District of Columbia (PDF) have waivers in effect for the entire state. Twenty-nine states waive ABAWD work requirements in certain counties.

The proposed rule change would restrict state waiver applications to areas with an unemployment rate of 7 percent or higher, regardless of whether the local unemployment rate is 20 percent higher than the national average.

In a statement, the administration expressed concern that with a national unemployment rate of 4 percent, certain areas with current waivers have sufficient job opportunities to support those seeking work. The administration is also seeking to reduce exemptions that states have used to address challenges for particular workers or areas.

The proposed rule change could limit states’ flexibility to tailor policies to the barriers they observe in local labor markets, especially when unemployment rates are rising rapidly but the multimonth average rate has not yet crossed a high threshold. 

Investment in meaningful education and training could lead to well-paying work

A primary concern about work requirements is the tension between putting the onus on people who may have limited skills or other barriers to work and providing adequate supports to work, such as education and training, to reduce those barriers.

Historically, the farm bill’s education and training activities—known as SNAP Employment and Training (E&T)—have prioritized low-intensity supports such as job search assistance, rarely investing in significant employment and training efforts or ensuring that all geographic areas and participants can be adequately served. States are not required to guarantee an E&T slot for each SNAP participant who must meet the work requirement, and most states do not do so.  

Recognizing the need to strengthen SNAP E&T, the 2014 farm bill authorized the US Department of Agriculture to award grants ranging from $8.9 to $22.3 million to test E&T strategies in 10 states that might produce better outcomes. A final evaluation report examining those outcomes is due in 2021.

In the meantime, although the 2018 farm bill does include new focus on education and training, with an emphasis on learning from the ongoing pilots (PDF), a deep investment in meaningful job training resources does not appear to be on the horizon.

The administration’s next major opportunity to address SNAP will come when it announces its fiscal year 2020 budget plan. The administration’s prior budgets have proposed deep cuts to SNAP, and to date, it has not prioritized meaningful investment in job creation and training that could boost employment and earnings among low-wage workers in the long term.

For now, SNAP continues to be a critical support for many low-wage workers, who often rely on the program during spells of unstable employment. The 2018 farm bill reinforced that message, but it remains to be seen whether the proposed regulatory change will reduce access to SNAP for many of the country’s most vulnerable workers.