In 2019, the United States Department of Agriculture (USDA) proposed or finalized three rule changes to the Supplemental Nutrition Assistance Program (SNAP), also known as food stamps:
- Tightening the unemployment standards required for local waivers from time limits for Able-Bodied Adults Without Dependents (ABAWDs);
- Restricting Broad-Based Categorical Eligibility (BBCE), a streamlining option that helps working families and those saving for the future to qualify for SNAP; and
- Shifting the methodology for calculating the Standard Utility Allowance (SUA) that
many SNAP households receive as a deduction when calculating benefit allotments.
These changes to SNAP have the potential to withdraw close to $60 million in federal benefits from Colorado annually, and remove tens of thousands of Coloradans from SNAP, thereby limiting their ability to build a strong foundation for health and well-being.i
TIGHTENING CRITERIA FOR ABAWD TIME LIMIT WAIVERS – FINAL RULE RELEASE DEC. 4, 2019
ABAWDs between the ages of 18 and 49 who do not have dependents must meet a work requirement of 20 hours per week to receive more than three months of SNAP in a 36-month period. Traditionally, states have been able to waive this work requirement during periods of economic downturn. During the most recent recession, all states except one waived either all or a portion of their regions due to high unemployment. In 2011, every Colorado county except two waived the work requirement.ii
The new rule tightens the threshold for work requirement waivers: the change will require that these areas have an unemployment rate of at least six percent, as well as an unemployment rate at least 20 percent above the national average. In addition, states will no longer be able to combine certain geographies when seeking a waiver, which means cities like Washington D.C., Baltimore, and Detroit would no longer be exempted.
The final rule also includes a harmful change that was not in the proposed rule: it will eliminate extended unemployment benefits (EUB), which are triggered when unemployment rapidly rises, as a waiver criterion. This will limit states’ ability to quickly respond to sharp increases in unemployment based on recent unemployment data. The USDA estimates the new rule will cut off basic food assistance for nearly 700,000 of the nation’s poorest people.
Currently, about 800 Colorado ABAWDs living in rural areas with ongoing work requirement waivers would be affected. The larger concern, however, is that the decreased flexibility to waive work requirements would harm families with low incomes in times of economic downturn, when the SNAP is needed most.iii This final rule would weaken the program’s ability to dynamically respond to need during future recessions when millions more Americans need assistance.
RESTRICTING BBCE – PROPOSED RULE COMMENT PERIOD CLOSED NOV. 1, 2019
States may use BBCE as a way of combining Temporary Assistance for Needy Families (TANF) with SNAP in order to streamline program operations, increase SNAP gross income thresholds up to 200 percent of the federal poverty line (normally 130 percent) and increase the SNAP asset or resource test when determining eligibility ($2250 for most households).
Removing BBCE would cause harm to households if they work more hours, get a slight wage increase, or try to save money, thereby discouraging them from economic advancement. The Urban Institute determined that about nine percent of SNAP households would become ineligible for the program, and close to one million low-income students would lose their eligibility for Free and Reduced School Lunch, as a result.i The Colorado Department of Human Services (CDHS) estimates that 90,000 Coloradans annually would lose SNAP eligibility under this proposal, a third of whom are children, and a fifth of whom are older adults.iv
SHIFTING THE METHODOLOGY FOR THE SUA DEDUCTION – PROPOSED RULE COMMENT PERIOD CLOSED DEC. 2, 2019
States currently have the flexibility to set their SUA (the largest and most commonly used utility deduction in the program) based on state utility costs. The USDA has proposed standardizing the methodology for calculating this deduction nationally, thereby limiting states’ ability to use more current and accurate data sources and local knowledge when proposing SUAs for USDA approval.
The proposal would lower the deduction in most states, with up to seven million SNAP recipients seeing a reduction in their benefits, and approximately 8,000 households nationally completely losing program eligibility.v Colorado is one of the 29 states that would experience a benefit cut, with 40 percent of SNAP households experiencing benefit reductions amounting to more than $34 million total in decreased allotments annually.
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SOURCES
i Urban Institute. (2019). Estimated Effect of Recent Proposed Changes to SNAP Regulations. Retrieved from: https://www.urban.org/sites/default/files/publication/101368/estimated_effect_of_recent_proposed_changes_to_snap_regulations_1.pdf
ii The Center on Budget and Policy Priorities. (2019). States Have Requested Waivers from SNAP’s Time Limit in High Unemployment Areas for the Past Two Decades. Retrieved from: https://www.cbpp.org/research/food-assistance/states-have- requested-waivers-from-snaps-time-limit-in-high-unemployment
iii The Center on Budget and Policy Priorities. (2017). Watch SNAP Respond to the Economy, as Designed. Retrieved from: https:// www.cbpp.org/blog/interactives-watch-snap-respond-to-the-economy-as-designed
iv Hunger Free Colorado. (2019). Proposed SNAP Changes Plan to Take Food Stamps Away from More than 3 Million Americans. Retrieved from: https://blog.hungerfreecolorado.org/news/proposed-snap-changes-plan-to-take-food-stamps-away-from-more- than-3-million-americans/
v Hunger Free Colorado. (2019). The Latest Attack on SNAP: Standard Utility Allowance Rule Proposal. Retrieved from: https://blog.hungerfreecolorado.org/news/the-latest-attack-on-snap-standard-utility-allowance-rule-proposal/
iii The Center on Budget and Policy Priorities. (2017). Watch SNAP Respond to the Economy, as Designed. Retrieved from: https://www.cbpp.org/blog/interactives-watch-snap-respond-to-the-economy-as-designed
iv Hunger Free Colorado. (2019). Proposed SNAP Changes Plan to Take Food Stamps Away from More than 3 Million Americans. Retrieved from: https://blog.hungerfreecolorado.org/news/proposed-snap-changes-plan-to-take-food-stamps-away-from-more-than-3-million-americans/
v Hunger Free Colorado. (2019). The Latest Attack on SNAP: Standard Utility Allowance Rule Proposal. Retrieved from: https://blog.hungerfreecolorado.org/news/the-latest-attack-on-snap-standard-utility-allowance-rule-proposal/