Urging Comment on Proposed SNAP Regulations

SNAP (The Supplemental Nutrition Assistance Program), formerly food stamps, is part of the Farm Bill which was passed on December 12. Congress rejected a version of the bill which would have imposed strict work requirements on SNAP recipients. But President Trump and the US Department of Agriculture propose to sidestep Congress’s approval through Executive Action: A new regulation would limit some of the states’ traditional ability to determine when employment in certain areas is so insufficient that the existing rules imposed on “able bodied without dependents” SNAP recipients (to work at least 20 hours or be in job train-ing) should be waived. The rationale for limiting this waiver ability is that it would increase “self-sufficiency” in a time of generally high employment.

But analysis by the Brookings Institute indicates that this will harm many who are unable to find work or prove they have met the requirement. As many as 3/4s of able-bodied adults without dependents (ABAWDs) are in the labor force but in jobs with few hours, or undergo frequent job changes or spells of unemployment. Some are hindered by poor health but have not qualified as “disabled.” The results of the regulation could well increase poverty, and deepen racial disparity. The Justice Committee believes the regulations should be opposed. They bring harm to vulnerable persons and play on the stereotype of the “lazy poor.”

There is a 60-day period of PUBLIC COMMENT on this proposal. This period will end on April 2. You are encouraged to participate. Go to federalregister.gov. Find “Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults Without Dependents” then click on “Submit a Formal Comment.” You will find more information and a comment box to fill in. Afterword there a number of spaces for information, but note that the only required spaces are for your name. Then submit. Here is one sample comment:

I deeply oppose the proposed regulations to stiffen requirements for SNAP recipients. The ability to deter-mine when rates of unemployment and lack of sufficient jobs in an area call for a waiver of existing work and job training requirements should be left to states. This has been the long-standing, bipartisan process. The great majority of ABAWD's receiving SNAP who can work are in the labor force, but subject to minimal hours, job changes, low compensation etc. Others receiving SNAP have health issues that hinder employment but have not qualified for disability. The result of these proposed regulations will drive more persons into poverty, increase racial disparity, and be counter-productive. As a resident of Cape Cod, I know what a struggle it is for persons who are able to obtain seasonal employment for periods of a year but require nutritional assistance in the remaining months. These proposed regulations should not be implemented.

For questions or comments, see Rod MacDonald

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