The U.S. Department of Agriculture (USDA) issued several proposals in 2019 to implement major policy changes to the Supplemental Nutrition Assistance Program (SNAP). The following three rules, one of which has been recently finalized, that have been issued over the past year would significantly reduce benefits and limit eligibility for millions of households – many of them with seniors and caregivers – who rely on the program.
- Work Requirements for Able-Bodied Adults Without Dependents
- Revision of Broad-Based Categorical Eligibility
- Standardization of State Heating and Cooling Standard Utility Allowances
Several of the proposed changes included in the rules have previously been considered by Congress and were rejected in the most recent reauthorization of the Farm Bill. The Agriculture Improvement Act of 2018 (P.L. 115-334) passed with broad bipartisan support in the House and Senate – indicating strong support for maintaining current policies pertaining to SNAP. Members of the general public and advocates have also shown overwhelming opposition to these rules, collectively generating hundreds of thousands of public comments in opposition.
Millions of seniors, their family members, and caregivers count on receiving modest monthly SNAP benefits to be able to afford the food that their household needs. These efforts to deny or decrease benefits will result in harmful effects to the health, wellbeing and financial security of millions of low-income seniors, and, if implemented, the rules may have negative implications for local senior nutrition programs that help senior clients and their families receive the nutrition and social services and support they critically need.
Read more about the individual rules, how they will affect older adults, and our efforts to oppose them in the subsections below.
Work Requirements for Able-Bodied Adults Without Dependents
The first of the proposed rules was released by USDA in February 2019 and would implement stricter work requirements for individuals between the ages of 18-49, or able-bodied adults without dependents (ABAWDs), to be eligible to receive their monthly household SNAP benefits.
The rule would make it more difficult for states to receive waivers that exempt the requirements for ABAWDs in certain geographic areas experiencing high rates of unemployment. The final rule includes an even more restrictive provision than originally proposed, that limits the kind of data that states can use to qualify for work requirement waivers, making it more challenging states to be able to waive the requirements in the event of future economic downturn or rapidly rising unemployment. As a result, an estimated 700,000 SNAP beneficiaries are no longer be expected to meet the work requirements under this rule and will therefore lose eligibility in FY 2020 alone. Additionally, spending on SNAP will be reduced by an estimated $5.5 billion over the course of the next five years.
On December 4, the rule was finalized and published to the Federal Register and is set to take effect on April 1, 2020 – unless it is challenged in court, which is likely.
Though this rule doesn’t directly impact seniors receiving SNAP benefits at this time, it would have significant impact on seniors’ families and caregivers while also creating barriers for healthy aging among younger individuals who rely on SNAP. Meals on Wheels America submitted a public comment on the proposed rule in April about the impact this rule would have for older adults and the harms it would have to healthy aging for individuals regardless of age. We will continue to keep you updated on developments of this final rule as it is implemented and/or challenged through litigation.
Revision of Broad-Based Categorical Eligibility
In July 2019, the USDA submitted a its second proposed rule to restrict eligibility for SNAP benefits by making changes to a policy known as Broad-Based Categorical Eligibility (BBCE).
The current policy gives states the flexibility to establish higher asset and income limits for SNAP eligibility by aligning them with the eligibility rules for Temporary Assistance for Needy Families (TANF) benefits. Currently, 43 states use BBCE to reduce administrative paperwork and grant TANF benefit recipients automatic, or “categorical,” eligibility for SNAP – even if their gross income or assets exceed thresholds in the SNAP eligibility test. Under the proposed rule, the Administration would restrict BBCE by limiting the TANF benefits that may generate categorical eligibility. Specifically, for certain TANF benefits to qualify a household or individual for SNAP under BBCE, the benefits must have a minimum value of $50 and have been received for at least six months.
The USDA estimates that nine percent of households (3.1 million individuals) receiving SNAP would no longer be eligible and would lose benefits that help them afford nutritious food under this rule. Seniors and their families would be disproportionately affected as over 13 percent of SNAP households with elderly individuals would become ineligible for SNAP through this policy change.
Meals on Wheels America submitted comments on the impact of this rule on the older adult population. The USDA must review and respond to over 75,000 comments that were submitted before issuing a final decision on the rule.
Standardization of State Heating and Cooling Standard Utility Allowances
The USDA released a third proposed rule in October that would greatly reduce the monthly benefits for households participating in SNAP. The rule would eliminate existing state flexibility to set Standard Utility Allowances (SUA) – a deduction related to household utility expenses that is used when determining an individual or household’s monthly SNAP benefits.
Under current policies, monthly household utility expenses – like heating and cooling – are factors used to determine the amount of SNAP benefits a household is eligible to receive. States are allowed to establish their own calculation methods for the SUA, which helps account for the large variation in geographies and average utility costs across the country.
Under the proposed rule, USDA would now calculate and impose a SUA for each state based on standard criteria from surveys, removing state flexibly, and in many states, reducing the amount of SNAP benefits for which households qualify, even in those geographies with high utility expenses. The USDA estimates that overall SNAP benefits will be reduced by $4.5 million over five years with 19% of households – 7.2 million individuals – expected to have reduced monthly benefit amounts, by an average of $31. Among those 3.4 million households with reduced benefits, 20% of them will be households with one or more seniors. Furthermore, this rule will disproportionately affect households with older adults in colder geographies where the costs of heating and other utilities are greater.
Meals on Wheels America submitted comments on the impact of this rule on seniors. The period for submitting public comments ended December 2, and now the USDA must review and respond to over the 100,000 comments that were submitted before issuing a final decision on the rule.
For more information about these proposed SNAP regulations, reference these additional resources: