Grocery store.

How Restrictions on SNAP Harm Health

By Molly Prothero

One of President Biden’s earliest actions in office was to sign an executive order asking Congress and the US Department of Agriculture (USDA) to expand the Supplemental Nutritional Assistance Program (SNAP).

President Biden proposed that Congress extend the 15% SNAP benefit increase, originally passed in late December. Biden’s executive order also directed the USDA to issue new guidance documents enabling states to increase SNAP allotments in emergency situations and update the Thrifty Food Plan, the basis for determining SNAP benefits, to better reflect the cost of a nutritious diet today.

President Biden’s actions stand in sharp contrast to Trump, who sought to limit the reach of SNAP benefits during his time in office. In December 2019, Trump’s USDA issued a final rule restricting SNAP eligibility for unemployed adults without dependents.

Prior to the rule, states had the option to waive the three-month time limitation on SNAP benefits for able-bodied adults without dependents who were neither working nor enrolled in an education or training program. While the waiver was designed with areas with high unemployment rates in mind, counties with unemployment as low as 2.5% were utilizing the waiver option, allowing unemployed adults to receive SNAP benefits for longer than three months out of three years. The Trump Administration argued that restricting the waiver’s usage would ensure that individuals who could work were incentivized to do so, and save $5.5 billion in costs over five years.

However, by doubling down on work requirements for individuals without disabilities or dependents, the proposal would have rendered nearly 700,000 unemployed individuals ineligible for the program.

After several States challenged the rule, the District Court of D.C. struck it down in October. The Chief District Judge found that the rule was arbitrary and capricious — USDA had failed to address the large-scale impact of the change, which was further highlighted by skyrocketing unemployment rates during the coronavirus pandemic and the addition of more than 6 million individuals to SNAP.

And research shows that the impacts of such a policy change can be profound.  While SNAP benefits are meager, on average providing $1.40 per meal per person, research institutes such as the Center on Budget and Policy Priorities (CBPP) have found that the SNAP program provides an important buffer against food insecurity, which increases the likelihood of adverse health outcomes and is linked to higher health care costs. SNAP participants report better health outcomes than people living with low income who do not receive SNAP. According to CBPP, children’s food insecurity fell by about a third among families that received SNAP benefits for six months.

Of course, many restrictions on SNAP target only individuals without dependents, such as the Trump Administration’s final rule. Advocates for restrictions on the program often point to the benefits of employment, including for health. But many of the people receiving SNAP already are employed. Restrictions on the basis of employment for able-bodied adults appear to create additional barriers with little positive impact.

Intertwined with stated goals of promoting employment and economic independence is often the question of desert.

In the USDA’s 2019 promulgation of its final rule restricting SNAP, it stated, “Federal programs should empower individuals to seek employment and achieve economic independence, while reserving public assistance programs for those who are truly in need.” Attaching the goal of promoting economic independence to food access, something so pivotal to health, is dangerous and harmful.

First, the majority of SNAP beneficiaries do not fall into the bucket of able-bodied, without dependents, and living in areas with low unemployment rates. Nearly two-thirds of SNAP recipients are children, the elderly, or people living with disabilities. Hurdles to eligibility can render these individuals, who still qualify on paper even under a limited definition of “truly in need,” unable to access the benefits they ought to receive. As such, targeting policies to encourage economic independence for a minority of SNAP recipients too often results in mass disenfranchisement, harming the very people that the policy purports to help. This in turn impacts health, and may lead to greater long-term costs to taxpayers than the SNAP program itself.

Second, even those individuals who the government has in mind as able-bodied and capable of working are put in harm’s way by restrictions that levy access to food as incentive to employment. The coronavirus pandemic has highlighted how quickly circumstances can change. But even absent the extreme of COVID-19, individuals without disabilities or dependents should not face the prospect of limited food if unable to find employment or begin an educational program within three months.

Biden’s steps on SNAP are needed, especially as the coronavirus pandemic continues. Concerns about promoting economic independence cannot be tied to one of the most foundational of life’s necessities: access to food. Going forward, when a presidential administration wants to incentivize economic independence it should do so with carrots, not sticks, and focus on building benefits policies that promote health first.


Molly Prothero is a 3L at Harvard Law School and Executive Director of Harvard Legal Aid Bureau.

The Petrie-Flom Center Staff

The Petrie-Flom Center staff often posts updates, announcements, and guests posts on behalf of others.

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