The Sisters of Notre Dame is an organization of Catholic women religious based in Ohio, Kentucky and California. Our organization pays very close attention to the Supplemental Nutrition Assistance Program (SNAP) because SNAP plays a critical role in addressing hunger and food insecurity in our community and is the first line of defense against hunger for the majority of our low-income clients. We care about the three-month time limit because this policy has cut off food assistance to so many in our community who are in need just because they are unable to find a reliable 20-hour-a-week job. Five hundred plus sisters have been actively engaged with persons who receive SNAP and know first hand the negative impact this change will have on these adults.
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 are able to 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. At least 500,000 low-income individuals nationwide lost SNAP in 2016 due to the time limit. This put their food security at risk. And, by time-limiting food assistance to this group, federal law has shifted the burden of providing food to these unemployed individuals from SNAP to local charities
While this request for comment appears to be open to suggestions on how to make the time limit less harsh via administrative action, we are concerned that the Administration seeks only to make the rule more draconian: to expand the scope of the cutoff and to eliminate the little flexibility states have to limit the damage of the rule. The Department’s stance on the time limit is not one that our organization shares. The Secretary of Agriculture has suggested that they need to “remove those waivers for able-bodied adults without dependents,” because “it’s become a lifestyle for some people.” USDA’s budget has proposed making the time limit harsher by repealing states’ flexibility to exempt certain individuals and most high unemployment areas from the time limit and exposing more people to this punitive policy. As a result, we are deeply concerned that this request for comment is part of an administrative effort to make the time limit even more harsh.
We strongly oppose any administrative action by USDA that would expose more people to this cutoff policy. Under the law, states have the flexibility to waive areas within the state that have experienced elevated unemployment. The rules governing areas’ eligibility for waivers have been in place for nearly 20 years and every state except Delaware has availed themselves of waivers at some point since the time limit became law. The waiver rules are reasonable, transparent, and manageable for states to operationalize. Any change that would restrict, impede, or add uncertainty to our state’s current ability to waive areas with elevated unemployment must not be pursued.
The request for comment also seems to suggest that potential improvements to other aspects of the time limit policy, such as individual exemption policy, would justify weakening states’ flexibility to waive the time limit in areas with elevated unemployment. This logic is unfounded. Our state’s current ability to exempt certain individuals from the rule is important, but is wholly insufficient and could never make up for having to apply the time limit in areas with elevated unemployment. And, the underfunded workforce system and SNAP employment and training programs are not designed or well suited to meet the job training requirements under this rule. Put simply, there is no justification for weakening current waiver rules and exposing more vulnerable people to this SNAP eligibility cutoff.
The only action we encourage USDA to take with respect to this time limit rule that impacts Able-Bodied Adults Without Dependents is to propose its elimination. Restoring SNAP’s ability to provide food assistance to impoverished unemployed people would be a powerful policy improvement that would reduce food insecurity among those seeking work.
Sister Mary Delores Gatliff, Toledo, OH
Sister Mary Ethel Parrott, Covington, KY
Sister Margaret Mary Gorman, Chardon, OH
Sister Mary Anncarla Costello, Thousand Oaks, CA