Comments on Proposed Changes to Limit SNAP Eligibility

The federal Food and Nutrition Service recently proposed a rule that would limit the amount of time that an able-bodied adult without dependents can receive Supplemental Nutrition Assistance Program (SNAP) benefits to 3 months in a 36-month period, unless the individual meets certain work requirements. Recognizing the negative impact of such a policy on low-income families, local economies, and farmers—without increasing employment or earnings—NYHealth submitted the following comments urging that the rule not be implemented: 

March 29, 2019

Certification Policy Branch
SNAP Program Development Division
Food and Nutrition Service, USDA
3101 Park Center Drive
Alexandria, VA 22302

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

To Whom it May Concern:

The New York Health Foundation (NYHealth) appreciates the opportunity to respond to the proposed rule to limit the amount of time an able-bodied adult without dependents (ABAWD) can receive Supplemental Nutrition Assistance Program (SNAP) benefits to 3 months in a 36-month period, unless the individual meets certain work requirements. Such a policy would harm low-income families, local economies, and farmers without increasing employment or earnings, and we urge that the rule not be implemented.

NYHealth is a private, charitable foundation that works to improve the health of all New Yorkers, especially the most vulnerable. One of our key programs supports healthier communities in part by expanding access to affordable nutritious foods. For example, we invest in nutrition incentive programs such as the Double Up Food Bucks program, which provides matching funds for SNAP recipients to stretch their SNAP dollars to purchase more fresh fruits and vegetables. In New York City, we support GrowNYC, the first farmers market program in the nation to integrate SNAP into its markets. Our experience with this work has provided us with in-depth knowledge of the critical role that SNAP plays in addressing hunger and food insecurity for low-income New Yorkers.

Enacting stricter work requirements for ABAWDs would harm already vulnerable individuals by denying them food benefits at a time when they most need it. Moreover, the policy would be largely ineffective. Research demonstrates that such policies do not result in increased employment or earnings.[1],[2] While most ABAWDs are already employed, many of the jobs they hold are low wage, unpredictable, and may be less than the required 20 hours a week. The proposed three-month time limit for receiving SNAP benefits punishes these workers even as they do their best to support themselves.[3]

The USDA estimates that the proposed rule with its stricter work requirements would result in 755,000 individuals nationally no longer being eligible for SNAP.[4] This would significantly increase the financial burden on already strapped states, cities, and local charities to allocate scarce resources to provide food assistance to individuals whose SNAP eligibility would be eliminated.

The negative repercussions would also be felt by local economies and farmers. According to the Center on Budget and Policy Priorities, in fiscal year 2017, SNAP participants redeemed approximately $63 billion in SNAP benefits for food purchases, supporting retailers of every size.[5] The USDA Economic Research Service has estimated that each $1 in SNAP benefits generates $1.79 in economic activity.[6] With the proposed rule, the USDA estimates a net reduction of $15 billion in spending on SNAP benefits over 10 years. With the stricter requirements resulting in fewer SNAP beneficiaries, the adverse economic impact to food growers and procurers would be felt across the nation.

The proposed rule would also make it harder for areas with low unemployment rates to qualify for waivers that allow ABAWDs to participate in SNAP for longer than 3 months in a 36-month time period. A 7% unemployment rate floor is proposed as a condition under which states and municipalities could apply for a waiver. According to the CUNY Urban Food Policy Institute, this would have a negative impact on various states, including New York, where 37 of 62 counties, 6 cities, and 2 sets of community districts are currently covered by waivers; “with a 7% floor, 90% of ABAWDs would live in areas without waivers.”[7]

Congress recently concluded a review and reauthorization of SNAP in the 2018 Farm Bill and did not recommend the changes proposed by the Administration. The rules governing areas’ eligibility for waivers have been in place for nearly 20 years, and have proven to be reasonable, transparent, and manageable for states to operationalize. This proposed rule would be disruptive and dangerous by shifting financial responsibility for addressing food insecurity to states, without giving states what has been their historical autonomy to tailor SNAP program requirements in a manner that corresponds to the needs of their residents.

By the Administration’s own calculations, the proposed rule would take food away from 755,000 low-income Americans, cutting food benefits by $15 billion over 10 years. The Administration does not provide estimates on improvements in health or employment among the affected population. But it is a well-documented fact that food insecurity is a predictor of higher health care costs and worse health outcomes.[8],[9] SNAP is a lifeline for millions of Americans. If their benefits are taken away, they could be put in the dangerous, untenable position of having to choose between paying for food, medicine, housing, or transportation.

For these reasons, we oppose the proposed rule, which would severely harm the health of many communities, negatively impact local economies and farmers, and unfairly shift increased responsibility for financing a basic human need—access to food—to those who can least afford it.

[1] Pavetti, LaDonna, “Work Requirements Don’t Cut Poverty, Evidence Shows,” Center on Budget and Policy Priorities, updated June 7, 2016,

[2] Hotz, Joseph; Imbens, Guido; and Klerman, Jacob, “The Long-Term Gains from GAIN: A Re-Analysis of the Impacts of the California GAIN Program,” November 2000,

[3] Bolen, Ed, “Trump’s Expected SNAP Change Would Target Jobless Workers,” Center on Budget Policy and Priorities, updated December 19, 2018,

[4] Food and Nutrition Service, USDA, Proposed Rule Document, Supplemental Nutrition Assistance Program: Requirements for Able Bodied Adults Without Dependents, updated February 1, 2019,

[5] Wolkomir, Elizabeth, “SNAP Boosts Retailers and Local Economies,” Center on Budget Policy and Priorities, updated April 6, 2018,

[6] Blinder, Alan S. and Zandi, Mark, “The Financial Crisis: Lessons for the Next One,” Center on Budget and Policy Priorities, October 15, 2015,

[7] Poppendieck, Janet, “Proposed Rule Would Remove 775,000 People from SNAP Rolls, CUNY Urban Food Policy Institute, updated February 24, 2019,

[8] Tarasuk, V., Cheng, J., de Oliveira, D., Dachner, N., Gundersen, C., & Kurdyak, P. (2015). Association between household food insecurity and annual health care costs. Canadian Medical Association Journal, 187 (14), E429-436.

[9] Berkowitz, S. A., Basu, S., Meigs, J. B., & Seligman, H. (2017). Food insecurity and health expenditures in the United States, 2011-2013. Health Services Research, 53(3), 1600-1620.

Veterans on Campus Are Overlooked and Underserved

When Congress passed the post-9/11 GI Bill in 2008, it opened the doors to college for thousands of deserving veterans.

The funding covers tuition, housing, books, and other expenses for a four-year education. Between 2009 and 2013, the number of returning veterans on college campuses grew from 500,000 to 1 million, and the number continues to grow. But access to higher education is no guarantee of success. These students need more than financial aid.

Returning veterans face a unique set of challenges, and American universities are often ill equipped to serve them.

The “invisible wounds of war” are well known, and can have a significant impact on the college experience. While most veterans return home and adjust to civilian life without major difficulties, veterans who have suffered trauma have trouble adjusting to campus life and may have difficulty sleeping and concentrating. This puts student veterans at higher risk for dropping out of institutions that fail to provide them with support.

The mental health challenges of the transition period from the military to college are serious. Difficulty adjusting also puts student veterans at greater risk for self-harm: 46% of young veterans in college have thought about suicide, compared with 6% of their collegiate peers, according to the American Psychological Association.

Imagine you are a returning veteran. You have spent recent years in a highly structured environment, taught to follow orders and encouraged to show strength at all times. You may be conditioned to believe that reporting mental health challenges would have a negative impact on your future. Would you ask for help, even if you need it?

The adjustment can take a heavy toll. Most colleges have extensive mental health and wellness services, and yet, military veterans have trouble finding support they trust on campus. Many campus health and wellness providers have spent years developing successful marketing programs to reach traditional students. They promote their expertise with academic stress, eating disorders, alcohol misuse, and similar challenges. Veterans dealing with PTSD can feel like fish out of water in that environment. They need counselors who can spark confidence by communicating that they understand the particular challenges veterans face.

College campuses are not unique in this way. A recent study found a glaring need to increase health care professionals’ ability to provide culturally competent care to vets. It is particularly important to address this issue on close-knit college campuses; if a student veteran has a negative experience with a health provider, news of that experience will spread through veteran peer groups, and could inhibit other veterans from seeking treatment.

In partnership with the State University of New York (SUNY) at New Paltz, the New York Health Foundation has invested in an innovative program with the potential to change the way colleges serve veterans. SUNY New Paltz has developed a training program that builds the cultural competency of health care providers on campuses throughout the SUNY system. The one-day workshop enables campus health and wellness staff, as well as other staff who have regular contact with veterans, to enhance their understanding of and empathy for military culture. It is based on the Star Behavioral Health Providers curriculum, an evidence-based training program that has been evaluated and shown to be highly effective.

SUNY New Paltz has already conducted workshops on 15 SUNY campuses across New York State. The response has been positive, with attendees reporting that they expect to change the way they work with veterans.

This program is showing great promise and could be a model not only for helping returning veterans succeed in college, but also for using college as an opportunity to provide vital mental health services. SUNY is now considering expanding the program to reach staff on all of its campuses. This bodes well for the 33,000 veterans in college across New York State. More important, it is a model for schools seeking to improve care for veterans across the country. Most important of all, it is a call to action to address the needs of the veterans who have proudly served our country by making campuses the supportive environments they need to thrive.

By David Sandman, President and CEO, New York Health Foundation
Published in Medium on March 18, 2019