Collaborative Statement on Proposed Eligibility Limits for SNAP Enrollment

April 2, 2019
Certification Policy Branch
Program Development Division
Food and Nutrition Service, USDA
3101 Park Center Drive
Alexandria, Virginia 22302

RE: Proposed Rule: Supplemental Nutrition Assistance Program (SNAP): Requirements for Able-
Bodied Adults without Dependents RIN 0584-AE57

To the Certification Policy Branch:

As supporters of the Colorado Blueprint to End Hunger, we appreciate the opportunity to provide comments on the Department of Agriculture’s (USDA) proposed rulemaking regarding requirements for Able-Bodied Adults Without Dependents (ABAWDs) in the Supplemental Nutrition Assistance Program (SNAP).1 Given the vulnerability of the ABAWD population, the removal of state discretion and flexibility, and the negative economic impact of the rule, we encourage the Department not to move forward with this proposal.

The Colorado Blueprint to End Hunger is a multi-year plan to end hunger for all residents of the state. The Blueprint was developed by individuals and organizations from across Colorado who are working on or experiencing hunger in their own homes and communities. Key elements of the plan include efforts to maximize enrollment and participation of income-eligible Coloradans in SNAP and other federal food assistance programs and increasing the number of Coloradans who can access the nutritious food they need through community-based organizations.2

Nearly one in eleven (9.2%) Coloradans struggle to put food on the table, including many able-bodied, working adults who may be struggling due to a job loss, lack of available full-time hours, or minimum-wage pay.3 In 2016, an estimated 41,000 SNAP enrollees in Colorado fell into the ABAWD category, making them subject to the harsh time limit on benefits under existing law.4 Most ABAWDs who can work do so; however, the Colorado Department of Human Services has observed that this population faces significant challenges in finding and maintaining employment, such as: (1) lack of a high school diploma or its equivalent; (2) no significant/relevant work history; (3) felony convictions; (4) substance abuse; (5) mental and physical health problems; (6) housing problems; and (7) transportation problems.5

A recent analysis by Mathematica Policy Research reveals that a greater share of ABAWD SNAP participants live in poverty nationally compared to other SNAP participants, and often at a deeper level of poverty – at or below 50 percent of the federal poverty guideline.6 Additionally, nearly 44 percent of ABAWDs are either under the age of 21 or over the age of 40. This group includes young adults that have recently transitioned out of foster care, veterans, and those facing homelessness.

SNAP is not only a boost to ABAWDs and other low-income households but benefits the U.S. economy by generating between $1.22 and $1.79 in economic activity for every SNAP dollar spent.7 Based on this multiplier effect, the Center for American Progress estimates that this proposed rule could shrink U.S. gross domestic product (GDP) by nearly $18.3 billion, resulting in a loss of 178,000 jobs.8 This estimate is based on the Department’s own assumptions that the rule would eliminate 755,000 ABAWDs from the program and shrink spending by $15 billion over ten years.

When the ABAWD time limit was put in place, Congress granted states two waiver authorities to exempt these vulnerable individuals from the loss of benefits. Geographic waivers and 15 percent individual caseload exemptions – recently lowered to 12 percent – allow states the flexibility needed to assist residents living in areas with a lack of job opportunities or those facing the challenging individual circumstances discussed above. Congress recently reaffirmed its commitment to these state flexibilities when it rejected similar changes proposed during the reauthorization of the 2018 Farm Bill.

Prior to proposing this rule, USDA Secretary Sonny Perdue indicated that the Department did not have thenauthority to reject or alter state ABAWD waiver requests without a statutory change made by Congress.9 The finalization of this rule would go against congressional intent and represent an Administrative overreach. We urge the Department not to finalize the rule.

We thank you for your consideration of our comments. If you have any questions, please contact Alexis Weightman, Senior Policy Officer at the Colorado Health Foundation, at aweightman@coloradohealth.org
or 303-953-3600.

Sincerely,
Mark Kling and Teva Sienicki
Co-chairs, Colorado Blueprint to End Hunger
Governing Council
Abarrotes Bondadosa
Colorado Center on Law and Policy
Colorado Children’s Campaign
Colorado Department of Public Health and
Environment

Denver Alliance for Street Health Response
Denver Food Rescue
Hunger Free Colorado
Metro Caring
Share Our Strength
The Colorado Health Foundation
Weld Food Bank