[House Hearing, 118 Congress]
[From the U.S. Government Publishing Office]
INNOVATION, EMPLOYMENT, INTEGRITY,
AND HEALTH: OPPORTUNITIES FOR
MODERNIZATION IN TITLE IV
=======================================================================
HEARING
BEFORE THE
COMMITTEE ON AGRICULTURE
HOUSE OF REPRESENTATIVES
ONE HUNDRED EIGHTEENTH CONGRESS
FIRST SESSION
__________
JUNE 7, 2023
__________
Serial No. 118-14
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]
Printed for the use of the Committee on Agriculture
agriculture.house.gov
__________
U.S. GOVERNMENT PUBLISHING OFFICE
53-146 PDF WASHINGTON : 2023
COMMITTEE ON AGRICULTURE
GLENN THOMPSON, Pennsylvania, Chairman
FRANK D. LUCAS, Oklahoma DAVID SCOTT, Georgia, Ranking
AUSTIN SCOTT, Georgia, Vice Minority Member
Chairman JIM COSTA, California
ERIC A. ``RICK'' CRAWFORD, Arkansas JAMES P. McGOVERN, Massachusetts
SCOTT DesJARLAIS, Tennessee ALMA S. ADAMS, North Carolina
DOUG LaMALFA, California ABIGAIL DAVIS SPANBERGER, Virginia
DAVID ROUZER, North Carolina JAHANA HAYES, Connecticut
TRENT KELLY, Mississippi SHONTEL M. BROWN, Ohio
DON BACON, Nebraska SHARICE DAVIDS, Kansas
MIKE BOST, Illinois ELISSA SLOTKIN, Michigan
DUSTY JOHNSON, South Dakota YADIRA CARAVEO, Colorado
JAMES R. BAIRD, Indiana ANDREA SALINAS, Oregon
TRACEY MANN, Kansas MARIE GLUESENKAMP PEREZ,
RANDY FEENSTRA, Iowa Washington
MARY E. MILLER, Illinois DONALD G. DAVIS, North Carolina,
BARRY MOORE, Alabama Vice Ranking Minority Member
KAT CAMMACK, Florida JILL N. TOKUDA, Hawaii
BRAD FINSTAD, Minnesota NIKKI BUDZINSKI, Illinois
JOHN W. ROSE, Tennessee ERIC SORENSEN, Illinois
RONNY JACKSON, Texas GABE VASQUEZ, New Mexico
MARCUS J. MOLINARO, New York JASMINE CROCKETT, Texas
MONICA De La CRUZ, Texas JONATHAN L. JACKSON, Illinois
NICHOLAS A. LANGWORTHY, New York GREG CASAR, Texas
JOHN S. DUARTE, California CHELLIE PINGREE, Maine
ZACHARY NUNN, Iowa SALUD O. CARBAJAL, California
MARK ALFORD, Missouri ANGIE CRAIG, Minnesota
DERRICK VAN ORDEN, Wisconsin DARREN SOTO, Florida
LORI CHAVEZ-DeREMER, Oregon SANFORD D. BISHOP, Jr., Georgia
MAX L. MILLER, Ohio
______
Parish Braden, Staff Director
Anne Simmons, Minority Staff Director
(ii)
C O N T E N T S
----------
Page
Carbajal, Hon. Salud O., a Representative in Congress from
California; on behalf of Stephanie Johnson, RDN, Vice
President, Government Relations, National Grocers Association,
submitted letter............................................... 230
Davis, Hon. Donald G., a Representative in Congress from North
Carolina; on behalf of MAZON: A Jewish Response to Hunger,
submitted statement............................................ 227
DesJarlais, Hon. Scott, a Representative in Congress from
Tennessee, submitted website snapshot.......................... 196
McGovern, Hon. James P. a Representative in Congress from
Massachusetts:
Submitted news release....................................... 199
Submitted resolution......................................... 201
Salinas, Hon. Andrea, a Representative in Congress from Oregon;
on behalf of Marc Egan, Director of Government Relations,
National Education Association, submitted letter............... 226
Scott, Hon. David, a Representative in Congress from Georgia,
opening statement.............................................. 4
Submitted letters on behalf of:
Pham, Hoa, Deputy Secretary, Office of Income
Maintenance, Pennsylvania Department of Human Services. 197
Academy of Nutrition and Dietetics, et al................ 198
Spanberger, Hon. Abigail Davis, a Representative in Congress from
Virginia:
Submitted report............................................. 203
Submitted statute excerpt.................................... 219
Thompson, Hon. Glenn, a Representative in Congress from
Pennsylvania, opening statement................................ 1
Prepared statement........................................... 3
Submitted articles........................................... 115
Submitted Federal Register Rule.............................. 149
Submitted press release...................................... 166
Submitted reports............................................ 168
Witnesses
Brown, Tikki, Assistant Commissioner, Children and Family
Services Administration, Minnesota Department of Human
Services, Minneapolis, MN...................................... 6
Prepared statement........................................... 7
Submitted question........................................... 247
Stover, Ph.D., Patrick J., Director, Institute for Advancing
Health Through Agriculture, Texas A&M University, College
Station, TX.................................................... 13
Prepared statement........................................... 15
Supplementary material....................................... 232
Submitted questions.......................................... 248
Hodel, Eric E., Chief Executive Officer, Midwest Food Bank,
Normal, IL..................................................... 20
Prepared statement........................................... 22
Royal, Dawn, Member, Board of Directors and past President,
United Council on Welfare Fraud, Greybull, WY.................. 23
Prepared statement........................................... 24
Supplementary material....................................... 232
Rachidi, Ph.D., Angela K., Research Fellow in Poverty Studies,
American Enterprise Institute, Washington, D.C................. 37
Prepared statement........................................... 39
Submitted question........................................... 251
INNOVATION, EMPLOYMENT, INTEGRITY,
AND HEALTH: OPPORTUNITIES FOR
MODERNIZATION IN TITLE IV
----------
WEDNESDAY, JUNE 7, 2023
House of Representatives,
Committee on Agriculture,
Washington, D.C.
The Committee met, pursuant to call, at 10:03 a.m., in Room
1300 of the Longworth House Office Building, Hon. Glenn
Thompson [Chairman of the Committee] presiding.
Members present: Representatives Thompson, Austin Scott of
Georgia, DesJarlais, LaMalfa, Rouzer, Bacon, Bost, Johnson,
Baird, Mann, Feenstra, Miller of Illinois, Moore, Finstad,
Rose, Jackson of Texas, Molinaro, De La Cruz, Langworthy,
Duarte, Nunn, Alford, Van Orden, Chavez-DeRemer, Miller of
Ohio, David Scott of Georgia, Costa, McGovern, Adams,
Spanberger, Hayes, Brown, Davids of Kansas, Slotkin, Caraveo,
Salinas, Perez, Davis of North Carolina, Tokuda, Budzinski,
Sorensen, Vasquez, Crockett, Jackson of Illinois, Casar,
Pingree, Carbajal, Soto, and Bishop.
Staff present: Caleb Crosswhite, Halee Fisher, Jennifer
Tiller, Erin Wilson, John Konya, Kate Fink, Amar Nair, Ashley
Smith, Michael Stein, Katherine Stewart, Elaine Zhang, and Dana
Sandman.
OPENING STATEMENT OF HON. GLENN THOMPSON, A REPRESENTATIVE IN
CONGRESS FROM PENNSYLVANIA
The Chairman. Okay, good morning, everyone. Good morning,
and welcome to this hearing. Before I gavel in, I ask a good
friend and colleague from North Carolina, if he would just
offer a blessing over our proceedings today, and then we will
gavel in after that. Mr. Davis?
Mr. Davis of North Carolina. Thank you so much, Mr.
Chairman. Let us pray. O Holy One, we come before you now, and
we are just so thankful for this opportunity for this day. We
are thankful for the opportunity to talk about agriculture. As
we prepare to proceed today, be with our Chairman, our Ranking
Member, all of the Committee Members, our witnesses, and all
those gathered today. Allow us insight into your wisdom. It is
these things we pray, amen.
The Chairman. Amen. Thank you, sir. The Committee will come
to order. Welcome, and thank you for joining today's hearing
entitled, Innovation, Employment, Integrity, and Health:
Opportunities for Modernization in Title IV. After brief
opening remarks, Members will receive testimony from our
witnesses today, and then the hearing will be open to
questions.
Good morning once again, and welcome to this morning's
hearing on the nutrition title of the farm bill, and thank you
to our witnesses for sharing their time, their expertise, and
their vision.
Last week the Supplemental Nutrition Assistance Program, or
SNAP, became a significant focus of the debt ceiling
negotiations, which laid bare the strong emotions and opinions
across the political spectrum. But, when one in four Americans
participate in at least one of the U.S. Department of
Agriculture's 15 food and nutrition assistant programs over the
course of a typical year, it is time to redefine success.
Now, I believe we can all agree, albeit through different
lenses, there exists an opportunity to advance meaningful
legislation that moves people forward while meeting their
dietary and their financial needs. However, I am firm in my
belief that smart policies do not equal indiscriminate
expansion of these programs. I have also been involved in
shaping Federal domestic nutrition policy through my work on
the House Committee on Agriculture and the Committee on
Education and the Workforce. Now, I value these programs,
advocate for them, and understand there is room for
improvement. My goal is preservation for those truly in need,
and recognize that sometimes our neighbors in need require a
helping hand. With the farm bill set to expire, we as
policymakers can build on the success of the 2018 Farm Bill,
and find opportunities to foster self-sufficiency, promote
health, explore innovation, and ensure taxpayer resources are
used most effectively.
First, we must continuously explore how to serve eligible
recipients through innovation and flexibility. If the pandemic
has taught us one thing, it is there is no one way to serve
families in need. Midwest Food Bank has found a way to immerse
itself deep into Appalachia, and I look forward to hearing more
about how they, and we, can meet people more efficiently where
they are, whether in urban or rural communities.
Second, we must think about the best ways to guide
recipients to independence through employment, and the role
that career and technical education plays in that transition.
Let us move from states going out of their way to keep
employable individuals idle and disengaged, and spend more time
fostering connections with employers and education providers.
Dr. Rachidi has studied this extensively for decades, and her
testimony is integral to how we should think about an
expectation of productivity, and its outcomes on health and
communities.
As an aside, in talking to organizations that provide case
management, placement, and retention services, I am encouraged
to hear clients over the age of 50 report more employment than
those under 50, report incomes on an average of $500 more per
month than their younger peers, and hold employment longer, as
``older Americans'' can still contribute to the labor force and
our communities, and should not be thought of as
``incapacible'', or incapable, or hopeless.
Third, we cannot deny program integrity has been
compromised. As policymakers at the Federal level, we must
ensure USDA returns and--to and maintains the virtues of our
domestic nutrition safety net, but our constituents also have a
role here. From maintaining vigilance at checkout to lessen the
chances of skimming, to small businesses taking a chance on a
recipient, we can all come together to restore and sustain
accountability to the taxpayers footing the 10 year, $1.2
trillion cost of these programs. The United Council on Welfare
Fraud provides compelling reasons for these reforms, and more.
And last, and perhaps most importantly, the promotion of
healthy eating. Employment, healthcare costs, military
readiness, education, and general longevity highly depend on
the foods that we consume. With the right resources, research,
modernized programming, and technology, and appropriate and
effective Federal dietary policy, USDA, states, and local
communities are uniquely positioned to improve the nutrition of
millions of households. Dr. Stover will share his experiences,
but most importantly, his vision to bring about a healthier
America.
The nutrition program in the farm bill shows the world how
we as a nation take care of one another. And if we can put
politics aside to have honest dialogue, promote pragmatic
policymaking, and commit to good governance, we can move
mountains for those in need.
[The prepared statement of Mr. Thompson follows:]
Prepared Statement of Hon. Glenn Thompson, a Representative in Congress
from Pennsylvania
Good morning, and welcome to this morning's hearing on the
nutrition title of the farm bill.
Thank you to our witnesses for sharing their time, expertise, and
vision.
Last week, the Supplemental Nutrition Assistance Program, or SNAP,
became a significant focus of the debt ceiling negotiations, which laid
bare the strong emotions and opinions across the political spectrum.
But when one in four Americans participate in at least one of the U.S.
Department of Agriculture's 15 food and nutrition assistance programs
over the course of a typical year, it is time to redefine success.
I believe we can all agree, albeit through different lenses, there
exists an opportunity to advance meaningful legislation that moves
people forward while meeting their dietary and financial needs.
However, I am firm in my belief that smart policies do not equal
indiscriminate expansion of these programs. I've long been involved in
shaping Federal domestic nutrition policy through my work on the House
Committee on Agriculture and the Committee on Education and the
Workforce. I value these programs, advocate for them, and understand
there is room for improvement.
My goal is preservation for those truly in need, a recognition that
sometimes our neighbors in need require a helping hand.
With the farm bill set to expire, we as policymakers can build on
the success of the 2018 Farm Bill, and find opportunities to foster
self-sufficiency, promote health, explore innovation, and ensure
taxpayer resources are used most effectively.
First, we must continuously explore how to serve eligible
recipients through innovation and flexibility. If the pandemic has
taught us one thing, it is there is no one way to serve families in
need. Midwest Food Bank has found a way to immerse itself deep into
Appalachia, and I look forward to hearing more about how they--and we--
can meet people more efficiently where they are, whether in urban or
rural communities.
Second, we must think about the best ways to guide recipients to
independence through employment, and the role career and technical
education plays in that transition. Let's move from states going out of
their way to keep employable individuals idle and disengaged, and spend
more time fostering connections with employers and education providers.
Dr. Rachidi has studied this extensively for decades, and her testimony
is integral to how we should think about an expectation of productivity
and its outcomes on health and communities.
As an aside, in talking to organizations that provide case
management, placement, and retention services, I am encouraged to hear
clients over the age of 50 report more employment than those under 50,
report incomes on average of $500 more per month than their younger
peers, and hold employment longer. Us `older Americans' can still
contribute to the labor force and our communities and should not be
thought of as incapable or hopeless.
Third, we cannot deny program integrity has been compromised. As
policymakers at the Federal level, we must ensure USDA returns to and
maintains the virtues of our domestic nutrition safety net. But our
constituents also have a role here. From maintaining vigilance at the
checkout to lessen the chances of skimming to a small business taking a
chance on a recipient, we can all come together to restore and sustain
accountability to the taxpayers footing the 10 year, $1.2 trillion cost
of these programs. The United Council on Welfare Fraud provides
compelling reasons for these reforms, and more.
And last, and perhaps most importantly, the promotion of healthy
eating. Employment, healthcare costs, military readiness, education,
and general longevity highly depend on the foods we consume. With the
right resources, research, modernized programming and technology, and
appropriate and effective Federal dietary policy, USDA, states, and
local communities are uniquely positioned to improve the nutrition of
millions of households. Dr. Stover will share his experiences, but most
importantly, his vision to bring about a healthier America.
The nutrition programs in the farm bill show the world how we as a
nation take care of one another. And if we can put politics aside to
have honest dialogue, promote pragmatic policymaking, and commit to
good governance, we can move mountains for those in need.
With that, I welcome the esteemed Ranking Member from Georgia for
any opening remarks he would like to make.
The Chairman. And with that, I am pleased to recognize and
welcome the esteemed Ranking Member from Georgia for any
opening remarks that he would like to make.
OPENING STATEMENT OF HON. DAVID SCOTT, A REPRESENTATIVE IN
CONGRESS FROM GEORGIA
Mr. David Scott of Georgia. Thank you very much, Mr.
Chairman. Let me say this at the outset. My Democratic
colleagues and I have said, and we will continue to say, we
stand united against any efforts to take food away from
children, families, or any vulnerable American in this farm
bill, or any legislation. We stand united. Because we can also
surely find areas that we can work together, and in a
bipartisan way. I know, Chairman Thompson, your priorities are
innovation, employment, integrity, and health opportunities.
Well, we Democrats--excuse me. We Democrats care about these
issues too, and we can work with you in a bipartisan way.
Innovation, for example. We can use innovation to improve
program access, improve application and processing time. On
employment, we can provide additional support to help
participants get and retain jobs. And we also need to take the
time to look at the impact of artificial intelligence. Let me
tell you that artificial intelligence is moving rapidly, and
replacing many jobs that lower income people once had an
opportunity to do. I was eating at a restaurant in Atlanta, and
it was a robot that brought my menu, and a robot that brought
the food. Now, those were jobs that once were had.
We need to look at AI. We need to also examine the rapid
move in technology that are making many jobs beginning--that
lower-income people once had no longer are there. We have to
provide support, like transportation--that is one of your
initiatives--childcare assistance, which research has shown
time and time again does more to encourage employment than any
punitive time limits. And we can now assure that education,
something critical to job readiness--and as I said, with the
movement in technology, education becomes even more an
environment.
One of your goals is on integrity. We can combat EBT
skimming so no one can lose their benefits because of a
fraudulent action. You mentioned on health. We can incentivize
healthy eating and improve SNAP nutrition education. Incentives
work. Look at GusNIP, the program's great impact on fruit and
vegetable incentives. And also, I want to say a big thank you
to President Biden's leadership, because the recent debt limit
agreement included a new exemption from the time limits for our
precious military veterans, for homeless people, and for
children of the foster care movement. And I, unfortunately,
remain deeply disappointed that the debt limit agreement
included a harmful SNAP provision that puts food assistance at
risk for 700,000 of our older senior citizens. We need to work
on that.
And I just want to reiterate that we Democrats stand united
against any efforts to take food away from veterans, from
children, or any families that are vulnerable in America. We
are too big of a country, we are too great a country, to let
anybody go hungry who needs help. We need to provide proper and
humane food assistance to our precious American citizens who
are in need. Thank you.
The Chairman. I thank the gentleman. The chair would
request that other Members submit their opening statements for
the record so witnesses may begin testimony, to ensure that
there is ample time for questions.
Our first witness today is Ms. Tikki Brown, who is the
Assistant Commissioner for Children and Family Services at the
Minnesota Department of Human Services. Our next witness is Dr.
Patrick Stover, who is the Director of the Institute for
Advancing Health Through Agriculture. To introduce our third
witness today, I am pleased to yield to the gentleman from
Illinois, Mr. Sorensen.
Mr. Sorensen. Thank you, Mr. Chairman. I am very happy
today to be able to introduce a guest from my state, Mr. Eric
Hodel. Mr. Hodel is the CEO of the Midwest Food Bank, which
operates in my home district, and serves as a lifeline for
constituents in Peoria, Morton, and Bloomington-Normal. Midwest
Food Bank currently distributes $34 million worth of food to
over 2,200 nonprofit organizations each month, with 12
locations in Illinois, Arizona, Florida, Georgia, Indiana,
Texas, Pennsylvania, New England, East Africa, and Haiti. Mr.
Hodel, I am proud of your work in Illinois 17. Thank you for
your testimony, your time, and, Mr. Chairman, for the ability
to introduce him. Thank you.
The Chairman. Well, I thank the gentleman from Illinois.
Our fourth witness today is Ms. Dawn Royal, who is the Director
and past President of the United Council on Welfare Fraud. And
our fifth, and final, witness today is Dr. Angela Rachidi, who
is a Senior Fellow and Rowe Scholar at the American Enterprise
Institute. Thank you to all of our impressive witnesses for
joining us today. We are now going to proceed to your
testimony. You will each have 5 minutes. The timer in front of
you will count down to zero, at which point your time has
expired. Ms. Brown, please begin when you are ready.
STATEMENT OF TIKKI BROWN, ASSISTANT COMMISSIONER, CHILDREN AND
FAMILY SERVICES ADMINISTRATION,
MINNESOTA DEPARTMENT OF HUMAN SERVICES,
MINNEAPOLIS, MN
Ms. Brown. All right. Thank you, Chairman Thompson, Ranking
Member Scott, and Members of the Committee for the invitation
to testify before the House Agriculture Committee. I am Tikki
Brown, Assistant Commissioner of Children and Family Services
at the Minnesota Department of Human Services. With more than
20 years of state government experience, including serving as
Minnesota State's SNAP Director for 4 years, I am pleased to
share Minnesota's perspective with all of you today.
First, I would like to thank the Committee for its work to
provide states with SNAP emergency allotments, quality control
flexibility and waivers, and additional flexible administrative
dollars to manage the pandemic response activities. Combined
with the careful use of waivers, these resources allowed
Minnesota to seamlessly deliver critical services, while
ensuring a payment error rate below the national average.
We took many lessons from our pandemic efforts, including
the need to improve program access. Those improvements include
MN Benefits, an online application for public assistant
benefits which moves from the paper-based application to a
mobile-friendly online version, reducing completion time from 1
hour down to 13 minutes. Seventeen stores now participate in
online grocery shopping, which has been an important option for
rural residents, seniors, and participants with disabilities.
Contacting SNAP recipients via text messages ensures that
they are aware of important changes in their SNAP benefits. It
improves communications with workers, and we are able to
collect recipient feedback. Minnesota is rapidly expanding
texting capacity and has found texting to be a reliable and
impactful tool for communication with participants.
The last several years have emphasized both the strength
and the fragility of people. We understand many of our program
participants hope they never have to rely on SNAP. However, a
personal crisis, a job loss, or a global pandemic shakes the
very foundation, which results in a need to ask for help.
We know SNAP is paramount in the health and well-being of
program participants. Referenced in my written testimony is a
recent study conducted by the Minnesota Department of Human
Services and John Hopkins University, which found healthcare
costs decreased by an average of $99 per day when people have
access to SNAP. And as you know, the majority of SNAP
participants are children, so it will come as no surprise to
hear additional studies conducted by my department found
parents describe the toll a lack of food takes on mental
health. These parents also sadly share their own stories of
choices they made to go without food for the sake of their
children.
In our social safety net, many fibers are required to
support the most vulnerable. Transportation, housing,
healthcare, childcare, livable wages. Our participants' lives
are complex, and they have complex needs. Alignment across
programs is critical, and our SNAP policies require attention
to the barriers participants face.
This is most evident when we look at inequities in
Minnesota's labor market. Our unemployment rate is less than
three percent, and yet unemployment rates for our populations
of color and American Indians are significantly higher, and
many struggle to enter the workforce. Policies around time
limits must consider the unequal impact on race and ethnicities
in different communities.
As we look to the future of SNAP, Minnesota is excited to
continue its efforts with Tribal Nations by expanding their
ability to provide benefit eligibility to their members. We
will continue to increase the number of diverse organizations
providing employment and training services and continue to
improve our technological capacity through pilot projects like
our upcoming, FNS funded, Rapid Cycle Evaluation Texting
Project to boost participation in SNAP employment and training.
We also have challenges to overcome. As an 87 county and
three Tribe administered state, our county and Tribal partners
are burdened by staff turnover, workforce shortages, and an
increased caseload, and high number of applications. Some
counties have a turnover rate in the 50 percent range. In order
to compensate, experienced staff worked an unprecedented number
of overtime hours, doubling expenses in 2021.
System complexity creates an additional challenge.
Intricate and interrelated programs result in public assistance
systems with complex and rigid timelines. These systems require
a careful allocation of staff resources and expertise to avoid
case closure and unnecessary churn. And flexibility remains
key. Minnesota's recently approved SNAP interview waivers which
gives counties and Tribes flexibility to work with participants
on the information needed to reduce burden, rather than follow
a more rigid interview process.
In closing, we are committed to the critical role of SNAP.
It has been a privilege to meet the needs of participants
during such a challenging time in our nation's history. We must
continue to do so in this time of recovery. Thank you.
[The prepared statement of Ms. Brown follows:]
Prepared Statement of Tikki Brown, Assistant Commissioner, Children and
Family Services Administration, Minnesota Department of Human
Services, Minneapolis, MN
Thank you, Chairman Thompson, Ranking Member Scott, and Committee
Members for the invitation to join you today before the House
Agriculture Committee on ``Innovation, Employment, Integrity, and
Health: Opportunities for Modernization in Title IV.'' I am Tikki
Brown, Assistant Commissioner for Children and Family Services at the
Minnesota Department of Human Services. With more than 20 years of
state government experience, including serving as Minnesota's state
SNAP Director for several years, I am pleased to share the state
perspective with all of you.
The purpose of the Supplemental Nutrition Assistance Program (SNAP)
is to ``promote the general welfare and to safeguard the health and
well-being of the nation's population by raising the levels of
nutrition among low-income households. Congress finds that the limited
food purchasing power of low-income households contributes to hunger
and malnutrition among members of such households. Congress further
finds that increased utilization of food in establishing and
maintaining adequate national levels of nutrition will promote the
distribution in a beneficial manner of the nation's agricultural
abundance and will strengthen the nation's agricultural economy, as
well as result in more orderly marketing and distribution of foods. To
alleviate such hunger and malnutrition, a supplemental nutrition
assistance program is herein authorized which will permit low-income
households to obtain a more nutritious diet through normal channels of
trade by increasing food purchasing power for all eligible households
who apply for participation.''
SNAP has a long and successful history of providing temporary help
to reduce food insecurity, lift people out of poverty, help families
achieve self-sufficiency and reduce health disparities.\1\ For nearly
60 years, the Federal Government and states have worked together to
make these goals a reality by focusing on four primary areas:
---------------------------------------------------------------------------
\1\ Robert Wood Johnson Foundation. SNAP Supports Children and
Families (https://www.rwjf.org/en/insights/our-research/2018/09/snap-
supports-children-and-families.html), September 2018.
1. Ensuring people have reliable access to food, reducing
---------------------------------------------------------------------------
deprivation and improving health.
2. Incentivizing people to work to meet national and local labor
needs and support opportunities for financial stability and
growth.
3. Serving people well by being good stewards of public funds.
4. Prioritizing and balancing the portion of program funds required
to administer these programs by responding to evolving
needs through human and technological innovation.
I hope to offer insight into how SNAP operates in Minnesota under
the framework of these four goals and provide information as current
and future legislation is considered.
Ensuring people have reliable access to food reduces deprivation and
improves health
SNAP is a critical lifeline for approximately 440,000 people in
Minnesota. The program supports families with children, seniors, and
people with disabilities--these groups make up \2/3\ of all SNAP
recipients in Minnesota.
More than \1/3\ of SNAP recipients are children (another 30%
are parents or adults caring for children in their homes.)
Another \1/4\ are either seniors or adults with a
disability.
Seniors make up 14% of recipients.
People with disabilities represent 11% of recipients.\2\
---------------------------------------------------------------------------
\2\ Minnesota Department of Human Services SNAP data, 2021.
While many people work hard directing resources and efforts to
address hunger and nutrition challenges, more than \1/3\ of Minnesotans
report not having consistent, reliable access to enough food. There is
compelling evidence that shows systems struggle to ensure everyone has
enough to eat in Minnesota and across the country, especially for
people of color and Native people. In 2020, Black, Hispanic and Latino
Minnesotans reported food insecurity at more than double the rate of
white residents (85% of Black residents, and 70% of Hispanic residents,
compared to 32% of white residents.) Fifty-two percent of Asian
American residents and 55% of people of other races also reported some
degree of food insecurity.\3\
---------------------------------------------------------------------------
\3\ Wilder Foundation, New Food Insecurity Data Highlight
Minnesota's Continuing Disparities and the Need for Multi-Sector
Solutions (https://www.wilder.org/articles/new-food-insecurity-data-
highlight-minnesotas-continuing-disparities-and-need-multi-sector),
2020.
---------------------------------------------------------------------------
Minnesota had a record number of food shelf visits in 2022--more
than 5.5 million visits. That is 1.7 million more visits than the
previous record set in 2020. The increase was largely due to the rise
in food prices.\4\ In 2022, food-at-home (grocery store or supermarket
food purchases) prices increased by 11.4%.\5\ Food shelf use continued
to rise, even with the distribution of Emergency SNAP supplements and
the SNAP benefit increase in the Thrifty Food Plan.
---------------------------------------------------------------------------
\4\ Hunger Solutions Minnesota (https://www.hungersolutions.org/
data-posts/2022-food-shelf-visits-hit-record-high-up-almost-2-million-
visits-over-previous-year/), 2022.
\5\ Economic Research Service, U.S. Department of Agriculture. Food
Price Outlook (https://www.ers.usda.gov/data-products/food-price-
outlook/summary-findings/), 2023.
---------------------------------------------------------------------------
In 2020, the Minnesota Department of Human Services published a
report uplifting the voices and experiences of those living in deep
poverty that provided groundbreaking insight on the importance of
economic stability. During interviews conducted with parents living in
poverty, many shared they had received SNAP at some point in their
lives. They reported that it was very valuable in helping them access
food, especially healthy food, and worry less about whether they would
be able to feed their family. A recipient named Alison shared how
making sure children have enough to eat is their main concern.
``It helps me from worrying or trying to figure out how to feed my
kids. It doesn't matter the situation, my kids come first. I will give
them the last of whatever it is so that they're satisfied. You're not
fighting and worrying about, `how am I gonna support my kids?' '' \6\
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\6\ Minnesota Department of Human Services. Improving the Health of
People Living in Deep Poverty (https://edocs.dhs.state.mn.us/lfserver/
Public/DHS-8061-ENG), December 2020.
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SNAP helps to offset health care costs for vulnerable adults.
A study conducted by our agency and published in a Johns
Hopkins University public health journal found that health care
costs were lower for adults without a disability or dependents
when they had access to SNAP benefits.\7\
---------------------------------------------------------------------------
\7\ Journal of Health Care for the Poor and Underserved.
Supplemental Nutrition Assistance Program Participation is Associated
with Lower Health Care Spending among Working Age Adults without
Dependents (https://muse.jhu.edu/article/854362), May 2022.
Annual health care costs decreased by an average of $99 for
every month someone otherwise subject to time limits continued
---------------------------------------------------------------------------
to receive SNAP benefits.
The study highlights an alarmingly high burden of various chronic
diseases in people who are subject to time limits. Among the people
subject to time limits:
At least one in three have significant chronic health
problems that are likely to interfere with stable employment.
These conditions include chronic obstructive pulmonary disorder
(COPD), chronic renal failure, or heart disease that included a
heart attack or required hospitalization.
40 percent have a severe mental illness.
Although these conditions should exempt these individuals
from the time limit, the complexity of the work rules and
requirements for verification frequently result in the loss of
SNAP benefits.
For every month someone is denied food benefits because of time
limits, they have fewer resources for food and public expenditures on
their health care increase. After losing food assistance, people are
hospitalized, end up in emergency rooms and need more outpatient care.
Denying unhealthy people access to food makes them sicker. As might be
expected, there is an even greater reduction in monthly health care
expenditures for people who were homeless ($152.40), had a chronic
mental health condition ($206.10) or had a chronic physical disease
($193.20) when they are able to receive food benefits.
Incentivizing people to work to meet the national and local labor needs
and support opportunities for financial stability and growth
SNAP supports working families--more than \1/2\ of parents with
children receiving SNAP in Minnesota are working.\8\ Most adult
Minnesotans who receive SNAP work but earn wages too low for their
household to afford adequate food. The people turning to SNAP are low-
wage workers in retail, hospitality, food service, health care and
temporary agencies. These jobs are subject to inconsistent work
schedules, high turnover, and few benefits. Though, in Minnesota, jobs
are plentiful, significant skills gaps continue to limit employment for
many workers, particularly in rural areas.
---------------------------------------------------------------------------
\8\ Minnesota Department of Human Services. Characteristics of
People and Cases on the Supplemental Nutrition Assistance Program
(https://edocs.dhs.state.mn.us/lfserver/Public/DHS-5182N-ENG), August
2022.
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According to an independent study featured on the U.S. Department
of Agriculture website, there is no evidence that SNAP time limits
increase employment or annual earnings.\9\ A more effective way to
increase employment among SNAP recipients is to raise the earned income
disregard that is applied to wages and earnings for a household. SNAP
currently disregards 20% of earnings. This is out of step with other
Federal programs, like Supplemental Security Income, which disregards
the first $65 of earnings and then the remaining 50% in a month.
Increasing the earned income disregard would help to incentivize work
among SNAP recipients by reducing the effects of the benefits cliff,
allowing recipients to maintain SNAP benefits as they earn more income.
In Minnesota, about 60,000 households receiving SNAP could benefit from
this policy change. Families with children and households composed
solely of working-aged adults without a documented disability or
children in the home would be the most likely to benefit. Minnesota's
unemployment rate currently stands at 2.8% and the state ranks seventh
in seasonally adjusted labor force participation. Those individuals
still on the sidelines in Minnesota's labor force typically face
significant barriers to work that are not easily addressed.
---------------------------------------------------------------------------
\9\ Urban Institute. The Impact of SNAP Able-Bodied Adults without
Dependents Time Limit Reinstatement in Nine States (https://
www.fns.usda.gov/snap/impact-snap-able-bodied-adults-without-
dependents-abawd-time-limit-reinstatement-nine), June 2021.
Significant racial inequities exist, and the economic strain
caused by the COVID-19 pandemic impacted populations of color
and American Indians more significantly. The number of workers
who have applied for Unemployment Insurance benefits as a share
of the labor force varies widely by race and ethnicity: Blacks
(42.2%) and American Indians (35.9%) have the highest number of
Unemployment Insurance applications as a share of total labor
force size, which is at least in part because of the industries
in which they are employed. A large number of American Indians
are employed in accommodation and food services, many of which
were temporarily closed. Likewise, a high share of Black or
African Americans in Minnesota work in the health care industry
and other customer-facing industries like retail trade and
personal services, which have all been severely impacted by
pandemic containment measures.\10\
---------------------------------------------------------------------------
\10\ https://mn.gov/deed/assets/
061020_MN_disparities_final_tcm1045-435939.pdf.
As the economy moves into recovery, employment trends
indicate certain demographic groups were slower to return to
work or didn't return at all. Individuals aged 55 and above
were among the groups most likely to leave the workforce,
suggesting that the pandemic has pushed more of them to retire.
Other categories who are struggling to reenter are Black
workers, workers with a disability and workers with lower
levels of educational attainment.\11\
---------------------------------------------------------------------------
\11\ https://mn.gov/deed/newscenter/publications/trends/march-2023/
reemployment.jsp.
Time limits for SNAP are burdensome to implement, racially
inequitable and ineffective in helping people move into employment or
out of poverty. Time limits also apply to individuals who live in rural
areas and do not have reliable access to transportation. These
individuals want to work, but their circumstances make finding and
keeping steady work challenging. SNAP time limits increase these
challenges. When Minnesota lost a statewide waiver from the time limit
in 2013, 45,000 time-limited adults without dependents lost SNAP
benefits; we ask for support from USDA to prevent a similar outcome in
2023.\12\
---------------------------------------------------------------------------
\12\ Kollannoor-Samuel, Grace, et al. ``Supplemental Nutrition
Assistance Program Participation is Associated with Lower Health Care
Spending Among Working Age Adults Without Dependents.'' Journal of
Healthcare for the Poor and Underserved. 33.2. May 2022. 738.
---------------------------------------------------------------------------
Even though for most low-wage workers who participate in SNAP it is
a critical work support, for some people, including college students
and participants in work experience programs, SNAP's rigid rules can
interfere with their advancement.
For college students, working to better their education and
training prevents access to food even when their income qualifies for
SNAP. College students, many of whom are working as much as they are
able while also trying to complete training as quickly as possible,
face antiquated and complex additional eligibility rules. Take for
example, Alex, a nursing student, who was required to complete the
program in one academic year per the program requirements. This means
Alex was taking 18 credits a semester as well as the additional
clinical hour, which are a rotating schedule of shifts. Alex was unable
to work outside of the rigorous academic requirements as well as the
unpredictable clinic schedule. Alex was 24, therefore required to use
her parent's income for her FAFSA, which placed her over income for
additional grants. Despite having no additional resources, Alex was
also ineligible for SNAP because she didn't meet student exemption
criteria. Unable to access the resources she needed to stay healthy and
focused on her degree, Alex dropped out of the LPN program.
In addition, the student eligibility rules prevent students from
applying for SNAP even when it is desperately needed and make it more
difficult for eligibility workers to accurately assess eligibility.
This jeopardizes their ability to complete these trainings. As a
result, in 2018 37% of Minnesota state college students working hard to
increase their earnings in the long-term reported feeling food-
insecure. This can create a vicious cycle, with food insecurity
discouraging the student from earning a degree.
Supports exist within the program to help SNAP recipients increase
their income. Minnesota's SNAP Employment and Training program has
expanded significantly over the past 5 years and is working to improve
outcomes and service quality. But SNAP Employment and Training is
under-funded and administratively burdensome to both providers and SNAP
recipients. For example, very limited direct allocation funds for the
program cannot be used for one of the most evidence-backed program
components--support services--and the 50% funding model is limited by
SNAP Employment and Training program rules that discourage braided
funding (effectively paying for 50% of services while expecting
adherence to extensive Federal program guidelines). Most critically,
SNAP's rigid income calculations make the best-evidenced activities
within SNAP Employment and Training largely ineffective.
Research shows that paid and structured work experience is among
the most effective approaches to lifting SNAP recipients out of poverty
[Best Practices in SNAP E&T Programs 2016-2020: Final Report, USDA, p.
25]. But for many, particularly single adults without dependents, the
income they earn in these programs makes them immediately ineligible
for the very program they need for sustainable wage gain. Once they
fall out of the training program, they often end up income eligible for
SNAP again. Excluding income earned through a training or education
program from SNAP income calculations would have a minimal impact on
SNAP benefit receipt in the short term and has the potential to make a
hugely positive impact on these individuals' benefit receipt in the
long-term.
Time limited SNAP recipients
In Minnesota, American Indian and Black or African American
recipients are significantly over-represented in the time limited group
of recipients for many of the reasons, including those shared above.
This over-representation means that the Federal mandates and policy
decisions disproportionately affect these recipients, limiting their
food benefits and further exacerbating health disparities due to food
insecurity.
Federal regulations allow states to seek waivers of time limits for
areas within the state with an unemployment rate over 10% or a lack of
sufficient jobs. Prior to the statewide waiver of time limits initiated
by the public health emergency, Minnesota sought and received time-
limit waivers for certain counties and most Tribal Nations. However, a
2017 analysis found that although African American, Asian American and
Hispanic/Latino adults experienced high unemployment in Minnesota's
labor market, very few SNAP enrollees from these racial and ethnic
groups were served in counties that received a waiver. American Indian
SNAP recipients have historically made up a significant portion of the
population in waivered areas because the time limit waiver has covered
Tribal Nations in Minnesota due to continuous high unemployment rates
in these communities. Minnesota is exploring options to seek waivers
for areas that lack sufficient jobs, even in the context of
historically low statewide unemployment rates.
June 2022 administrative data shows that of 27,594 time-
limited recipients, 24% showed significant challenges in
accessing housing and were homeless. Having an address, a
reliable phone and means of transportation are basic
requirements for employment.
Many SNAP recipients subject to time limits face serious
health issues and housing barriers not related to the
unemployment rate. However, Federal SNAP policies rely on
individual SNAP recipients to identify whether they have
conditions that might exempt them from the time limits. There
are not adequate resources or systems to ensure that people
with serious health conditions are not subject to time limits.
Serve people well by being good stewards of public funds
We must maintain public trust, be aware of and responsive to
threats to the program, and ensure we review and adjust our policy and
practices accordingly.
As administrators of the program, there is a critical need to
maintain and update our systems, policies and practices, especially
with regard to technology. External criminal forces are nimble and
target vulnerable populations. Elderly SNAP recipients are a target,
with fewer technology resources and knowledge to detect phishing and
other scams. Without adequate funding to implement changes, such as
adding chip technology to EBT cards, or, moving to tap-to-pay options,
to better protect public dollars, we will continue to be at a
disadvantage and coming from behind, rather than proactively addressing
needs per the evolving marketplace.
Program Integrity
Program integrity is a critical component of maintaining public
confidence. States, counties and Tribes all have a role to ensure
benefits are provided accurately. Program integrity tools, like The
Work Number, help avoid errors related to household wages. We look
forward to the outcome of USDA's work to expand access to wage data
through third-party verification
Minnesota used ARPA funds to build a tool for counties and Tribes
to use to conduct case audits. Ongoing, systematic case audits are a
fundamental tool to ensure integrity in the SNAP program and reduce
errors. In addition, our weekly virtual policy and procedural update
meetings during the pandemic contributed to an error rate under the
national average.
Innovations
We thank Congress for support of funding for pandemic EBT to ensure
children had enough to eat during summer breaks, emergency SNAP
benefits to boost basic SNAP benefits, and additional flexible
administrative dollars for states to manage pandemic response
activities.
With additional administrative funding, Minnesota was able to hire
temporary SNAP staff to communicate program and policy changes
efficiently and effectively to counties and Tribes during the chaotic,
uncertain and ever-changing pandemic landscape. We created better
learning tools for the virtual environment, stood up pandemic EBT and
emergency SNAP programs, and piloted a contact center with interactive
voice technology to allow people to receive answers to basic questions
without the need for human intervention. This funding, coupled with the
careful use of waivers, allowed Minnesota to seamlessly deliver
critical service while ensuring a payment error rate below the national
average.
We are proud of the work that states undertook to provide necessary
benefits to people in need. And, given the heroic efforts of state,
county and Tribal staff to provide excellent customer service who are
now managing to the workforce shortage, staff are dealing with the
aftereffects. While change is a given in human services, the speed of
change and the ongoing adjustments is wearing on staff at all levels.
Local public sector employment in Minnesota has not recovered since the
initial pandemic decline and is currently experiencing the fifth
steepest percent decline in public sector employment compared to pre-
pandemic levels.\13\ Eligibility workers are essential and highly
skilled. They navigate multiple complex systems and timelines with
applicants whose lives and needs are equally complex.
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\13\ Minnesota already ranked ninth lowest public sector employment
among states pre-pandemic. Senf, Dave. Minnesota Public Sector
Employment Recovery from the Pandemic Recession. Minnesota Economic
Trends, March 2023, DEED.
---------------------------------------------------------------------------
Simplification is key
SNAP policies and procedures are complex and eligibility workers
are typically responsible for learning and applying rules for multiple
assistance programs. The more complex the policies and procedures, the
more it costs to administer the program--including training staff,
writing training, technical and informational materials, updating
systems, conducting quality audits and reviews and correcting benefit
calculation errors.
Simplifying the benefit administration system with more automation
offers the potential for great savings. Given the current labor issues
in this field all states are facing, a simpler policy will go a long
way to ensure SNAP households receive the right amount of benefits at
the right time.
While we are grateful for the grant opportunities currently
provided by USDA, the flexible administrative ARPA dollars provided
during the pandemic taught us how valuable it is for all states to have
access to funds to test new technologies.
Prioritizing and balancing the portion of program funds that are
required to administer these programs by responding to evolving
needs through human and technological innovation
Over the last several years, Minnesota has prioritized partnerships
with 11 federally recognized Tribal Nations to administer SNAP and
other health and human service programs. Working closely with Tribal
officials and providing support through state legislatively directed
resources, the planning and implementation of human service delivery
programs by Tribal Nations has resulted in three Tribal Nations
determining SNAP eligibility and one administering a SNAP Employment
and Training program. These three Tribes work in partnership with local
units of government and successfully provide services to their members,
both on and off reservation.
Supporting these efforts is Minnesota Executive Order 19-24; and
now state law 10-65; affirming the Government-to-Government
Relationship between the State of Minnesota and Minnesota Tribal
Nations: Providing for Consultation, Coordination, and Cooperation.
This Executive Order states in part: The State of Minnesota and the
Minnesota Tribal Nations significantly benefit from working together,
learning from one another, and partnering when possible. Meaningful and
timely consultation between the State of Minnesota and the Minnesota
Tribal Nations will facilitate better understanding and informed
decision making by allowing for collaboration on matters of mutual
interest and help to establish mutually respectful and beneficial
relationships between the state and Minnesota Tribal Nations.
Good government programs require both an adequacy of resources to
provide a structure of support and the flexibility to adjust and
address state-specific needs and trends.
MN benefits
We are grateful for the ability to partner with nonprofits such as
Code for America to create better access points for SNAP participants
through a new MNbenefits portal. Before MNbenefits was implemented, it
took applicants over an hour on average to complete a paper
application. Using the portal, the average time to complete an
application online has held steady at around 13 minutes.
As one recent applicant described it, the new portal makes it
``very easy to complete the application. Major improvement from how it
used to be.''
On the opposite end of the spectrum, ``David's'' experience was
quite different. Facing homelessness during the winter months and
unable to secure transportation to the post office to retrieve his
mail, he missed a notice with instructions on how to renew his SNAP
benefits. When his cell phone was disconnected for non-payment, county
workers could not reach him by phone, resulting in the closure of his
SNAP benefits.
Minnesota, like most states, struggles to balance easy access to
the program with our ability to keep up with the demand given existing
labor issues and the need for further automation and quicker
verification tools and methods. Additional funds similar to the
``Process and Innovation Technology Grant--PTIG'' would go a long way
to streamline and automate resulting in better service and cost
savings.
In conclusion
The nation's support of SNAP is more critical now than ever before.
Fresh from a devastating pandemic, recipients need the program now,
more than ever. By maintaining supports, the farm bill provides an
opportunity for lawmakers to support an individual's trajectory out of
poverty. Acknowledging and responding to the correlation between long-
term access to food and healthcare costs can mitigate detrimental
policy impacts.
SNAP has served the American people well, and exactly as it was
designed to do. Reaching more recipients in times of need, and less
when the economic realities of the population served are improved.
State agencies and eligibility workers have completed an immense amount
of work, through incredibly difficult times. They too need recovery and
support as they move to address new challenges.
Employment is critical, and lawmakers' acknowledgment of the
volatile nature and realities of low wage workers will ensure that SNAP
policies take into consideration the real barriers people face while
maintaining the most basic of all human needs, access to food.
Minnesota and national research highlight the disproportionate
impact of time limits, barriers to employment, of poverty and hunger on
American Indian and Black populations. An equity lens should be
considered for any policy adjustments in the farm bill to minimize
unintended impacts.
And finally, lawmakers should consider focusing on improving
technological supports, supporting state flexibilities and smoothing
the benefit cliff through adjustments to the earned income disregard.
Thank you again for the opportunity to join you today to share this
important information about SNAP and the experiences of those who rely
on this critical program.
The Chairman. Thank you, Ms. Brown. Now pleased to
recognize Dr. Stover. Dr. Stover, please begin when you are
ready.
STATEMENT OF PATRICK J. STOVER, Ph.D., DIRECTOR,
INSTITUTE FOR ADVANCING HEALTH THROUGH
AGRICULTURE, TEXAS A&M UNIVERSITY, COLLEGE
STATION, TX
Dr. Stover. Chairman Thompson, Ranking Member Scott, and
Members of the Committee, thank you for the opportunity to
testify before you today. My name is Dr. Patrick Stover, and I
serve as Director of the Institute for Advancing Health Through
Agriculture at Texas A&M. I oversee a unique research institute
that aligns agriculture as to the solution to skyrocketing
rates of diet-related chronic diseases that are driving
unsustainable healthcare costs and making both young and adult
Americans sick. Today I will provide my perspective on the
state of agriculture and food, and its connection to hunger and
human health, as well as the enormous challenges we face. But
more importantly, I will emphasize the opportunities to
reimagine the role of agriculture in transforming our lives.
First, for some context, Norman Borlaug won the Nobel Peace
Prize for sparking the Green Revolution by transforming global
food systems to be abundant and affordable, which dramatically
reduced hunger. Today we face a growing crisis of diet-related
chronic disease, which costs the U.S. economy over $1 trillion
annually, and affects half of adults. We need to build upon
Borlaug's legacy by expanding our mission, from using food to
eliminate hunger, to using food to become healthier. This can
only be achieved by innovating throughout the entire food
supply chain, not by merely focusing on agenda-driven
preferences and opinions, and around what some proclaim to be
healthy foods.
Today hunger and food insecurity still exist, but not
because of insufficient food production. On the other hand,
American diets are responsible for billions of dollars in
healthcare costs. We must expand the goal of agriculture to
include both hunger and health. We know that chronic diseases
are disproportionate in rural, and other underserved,
underrepresented, and low-resource populations, while the
associated healthcare costs are shared by everyone. We all have
a stake in finding solutions. We need to work together, and
everyone needs a seat at the table.
I am grateful for the new investments from Congress and the
State of Texas that has enabled us to launch the Institute for
Advancing Health Through Agriculture, which is focused on
advancing research that connects production agriculture and
human health. Our focus is on bridging the gap between
precision nutrition and the land-grant university agriculture
research complex that is the envy of the world. We are
addressing the most pressing problems facing our nation and the
world. I would like to highlight three initiatives that we are
undertaking to make agriculture the solution to human health.
First, we are now collaborating with the Chicago Council on
Global Affairs, with experts nationally, to identify priorities
and related barriers to make agriculture the solution to human
health. We will make recommendations on actions we can take
now, and what actions are aspirational, and require more study.
Second, we have launched the Agriculture Food and Nutrition
Scientific Evidence Center. We must have confidence in the
quality of scientific evidence that serves as the foundation
for our policies, practices, guidance, and programs in the
agriculture and food space. We must ensure we have science-
informed policy, and not policy-informed science. The newly
created evidence center, located in downtown Fort Worth, is
conducting state of the art scientific evidence synthesis to
provide decision-makers with objective analysis on what the
current science says regarding any proposed change in policy,
practice, or guidance.
Third, we have launched a major maternal diet and child
health study. Science has revealed that the risk for diet-
related chronic disease begins very early in fetal development
and is influenced by diet. We are launching a major study to
understand the role and contribution of maternal diet during
pregnancy to lifelong risk of chronic disease in both mothers
and their children.
In conclusion, we must align agriculture with human health.
Diet-related chronic disease places a huge financial burden on
individuals, the healthcare system, the American economy, and
are crippling the quality of life for many Americans. While
historic efforts to eliminate hunger and food insecurity
continue to be important, hunger cannot be considered in the
absence of health. To put it bluntly, this disconnect between
food and health threatens agriculture, the food supply, the
health of our society. Fortunately, agriculture is uniquely
positioned to be the solution.
With that, thank you again for this opportunity to testify,
and I look forward to your questions.
[The prepared statement of Dr. Stover follows:]
Prepared Statement of Patrick J. Stover, Ph.D., Director, Institute for
Advancing Health Through Agriculture, Texas A&M University, College
Station, TX
Introduction
Chairman Thompson, Ranking Member Scott, and Members of the
Committee, thank you for the opportunity to testify before you today
and elaborate on the crucial intersection of agriculture, food,
nutrition, and human health. My name is Dr. Patrick Stover, and I serve
as Director of the Institute for Advancing Health Through Agriculture
in The Texas A&M University System. I oversee a unique research
institute that conducts research and rigorous scientific evidence
synthesis seeking to better align Agriculture, Food and Nutrition as
the solution to the skyrocketing rates of diet-related chronic diseases
that are driving unsustainable health care costs and making both young
and adult Americans sick. Medical costs associated with diet-related
diabetes alone are more than $180 billion annually, more than the
budgets of most Federal agencies.
I previously served as Vice Chancellor and Dean of Texas A&M
AgriLife, where I oversaw the agricultural and life sciences academic
and research programs across the Texas A&M System, one of the largest,
top ranked and most comprehensive agriculture programs in the country,
encompassing 5,000 people and a $400 million budget. Texas A&M research
programs span the entire agriculture value chain, from food production
and farm inputs all the way to consumer behavior and human nutrition.
Prior to that role, I served as director of the Division of Nutritional
Sciences at Cornell University, one of the largest and top ranked
academic nutrition programs in the United States. In this position, I
worked with the World Health Organization (WHO) to establish a
successful summer training program to train experts in evidence-based
nutrition policy. Additionally, I have consulted for the Centers for
Disease Control and Prevention, WHO, and the U.S. Food and Drug
Administration on a variety of nutritional topics such as food
fortification, nutrition policy and related research gaps. I have been
an expert member, organizer and/or a report reviewer for several
National Academies of Sciences, Engineering and Medicine (NASEM)
initiatives including but not limited to: ``Guiding Principles for
Developing Dietary Reference Intakes Based on Chronic Disease''; \1\
``A Framework for Assessing the Effects of the Food System''; \2\
``Redesigning the Process for Establishing the Dietary Guidelines for
Americans''; \3\ and ``Examining Special Nutritional Requirements in
Disease States: Proceedings of a Workshop''.\4\ I am an elected member
of the National Academy of Sciences (NAS) and currently serve in a
leadership position as NAS Agriculture Section Chair.
---------------------------------------------------------------------------
\1\ https://www.nap.edu/catalog/24828/guiding-principles-for-
developing-dietary-reference-intakes-based-on-chronic-disease.
\2\ https://www.nap.edu/catalog/18846/a-framework-for-assessing-
effects-of-the-food-system.
\3\ https://www.nap.edu/catalog/24883/redesigning-the-process-for-
establishing-the-dietary-guidelines-for-americans.
\4\ https://www.nap.edu/read/25164/chapter/1.
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My research program specializes in deciphering the connections
among human genetics, dietary folic acid, and birth defect prevention,
notably spina bifida. I was part of a global team who advanced the
fortification of folic acid into the food supply, which has been one of
the greatest public health successes in using food as medicine, based
on rigorous clinical trial data, and saving health care costs. Spina
bifida, a debilitating birth defect, is now rare thanks to changes in
food policy. My research in this area led to the Presidential Early
Career Award for Scientists and Engineers awarded by President Bill
Clinton, the highest honor bestowed by the U.S. Government on
outstanding scientists and engineers beginning their independent
careers. I have served two terms on the NASEM Food and Nutrition Board,
which oversees the academies' nutrition portfolio including the
establishment of the Dietary Reference Intakes. I am a Fellow of the
American Association for the Advancement of Science (AAAS) and former
President of the American Society for Nutrition (ASN). As ASN
President, I led a major initiative to understand and address public
trust in nutrition science. Last month, I was selected by the U.S.
Department of Agriculture (USDA) Agricultural Research Service (ARS) as
the 2023 W.O. Atwater Lecturer, which recognizes ``scientists who have
made unique contributions toward improving the diet and nutrition of
people around the world.''
Today, I want to provide my perspective on the state of
agriculture, the food system, and its connection to hunger, nutrition,
and human health. I will give some context and urgency related to the
enormous challenges and barriers we face, but more importantly,
emphasize the opportunities to reimagine the role of food and
agriculture as the solution in transforming our lives, the economy, and
our health. Finally, I will update you on efforts we are leading to
position agriculture and our nation's food supply as the solution to
the diet-related chronic disease epidemic.
Chronic Diseases Manifest at the Interface Between the Consumer and the
Food Environment They Experience
As we are all aware, the food we eat is in large part responsible
for billions in healthcare costs attributable to diet-related diseases.
The burden of chronic disease and associated costs are disproportionate
in minority, rural, and other underserved, low resource populations,\5\
while the associated health care costs are shared by everyone--we all
have a stake in finding solutions. The overall obesity prevalence among
U.S. adults is 42.4%, driven by a disproportionate prevalence in
African American (49.6%), Hispanic (44.8%), and Native American (48.1%)
adults.\6\ Food insecurity follows a similar pattern.\7\ There are two
primary and interacting drivers that underpin diet-related chronic
disease: (1) the food environment that consumers experience and (2)
individual consumer choices and health behaviors. The rising and
unprecedented health care costs directly due to diets can only be
addressed through a focused national effort that advances the spectrum
of research, policy and practice that better aligns the food
environment and individual consumer choices with human health outcomes.
Both the food environment and consumer behavior need to be addressed
together through sound policy grounded in high quality scientific
evidence, which is largely lacking at this time.
---------------------------------------------------------------------------
\5\ RAND Health Care. Landscape of Area-Level Deprivation Measures
and Other Approaches to Account for Social Risk and Social Determinants
of Health in Health Care Payments. September 2022.
\6\ National Center for Health Statistics. Summary Health
Statistics: National Health Interview Survey, 2018. (https://
ftp.cdc.gov/pub/Health_Statistics/NCHS/NHIS/SHS/2018_SHS_Table_
A-15.pdf).
\7\ Coleman-Jensen A., Rabbitt M., Gregory C., Anita Singh A.
Household Food Security in the United States in 2021, ERR-309. U.S.
Department of Agriculture, Economic Research Service; September 2022;
Jernigan V.B.B., Huyser K.R., Valdes J., Simonds V.W. Food insecurity
among American Indians and Alaska Natives: a national profile using the
Current Population Survey--Food Security Supplement. Journal of Hunger
and Environmental Nutrition 2017; 12(1): 1-10. (In eng.). DOI: 10.1080/
19320248.2016.1227750.
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The Food Environment That Consumers Experience
The agricultural system and food environment we all experience
today has its origins in the post WWII era, where there was a consensus
that food was a human right, and that hunger was unacceptable in the
United States and globally. A food system and economic model was
developed to ensure that hunger (lack of calories), and hidden hunger
(lack of essential nutrients) would be rare and not due to insufficient
food production to prevent nutritional deficiencies. Technology was
brought to bear to achieve this goal. In 1970, Norman Borlaug won a
Nobel Peace Prize for developing disease-resistant wheat plants, which
sparked the Green Revolution. Borlaug leveraged science and technology
to increase agricultural efficiency, generating more food production
from the land. His legacy is the race to feed the world and eliminate
hunger. A long-time Distinguish Professor of International Agriculture
at Texas A&M University, his scientific and humanitarian achievements
are legendary.
These efforts led to the creation of a national food system that is
abundant, affordable, nutrient fortified and high in caloric density,
as hunger results from a deficit in calories. While this system has
proved successful in achieving its intended mission, one of the biggest
challenges we face today is the unintended consequence of obesity and
other chronic health conditions. Diet-related chronic diseases cost the
U.S. economy well over $1 trillion annually and affect 50% of adults.
In Texas alone, obesity costs businesses $11 billion per year, and that
is expected to reach $30 billion by 2030. We need to build upon
Borlaug's legacy in a revolutionary new way, expanding our mission from
simply using food to eliminate hunger and under-nutrition to also using
food to become healthier. This necessarily involves innovating
throughout the food supply chain and not merely focusing on what some
deem to be ``healthy foods.''
But, urbanization, underinvestment in agricultural research, gaps
in knowledge, the shifting landscape of dietary guidance leading to a
deficit in public trust all contribute to the growing disconnect
between people and their knowledge of food production and the role of
agriculture in human, environmental and economic health. This
disconnect threatens the very system that puts food on their plate--
agriculture.
Consumer Choice, Agency and Health Behaviors
The role of the consumer is equally important to achieving chronic
disease reduction through food. When the purpose of food and diets is
to avoid nutritional deficiencies, population-based approaches to
agriculture, food and nutrition programs, policies and guidance are
possible because most healthy individuals respond the same in the food-
deficiency relationship. When chronic disease reduction is the
expectation of the food environment, people respond differently to
dietary exposures. I served as chair of an invited expert workshop to
advise the National Institutes of Health on a major initiative in
``Precision Nutrition''. As former NIH Director Francis Collins has
stated, one-size does not fit all in the diet-chronic disease
relationship. This awareness resulted in the National Institutes of
Health focusing on understanding the complex role that dietary
exposures play in chronic disease, and its variability among
individuals, primarily through the Nutrition for Precision Health (NPH)
initiative which is expected to facilitate actionable dietary advice to
reduce chronic diseases.
Hence, as a nation we must focus on addressing both the food
environment that consumers experience as well as increasing the
individual consumer's ability to support informed and positive food
choices, which is fundamental to achieving chronic disease reduction
through food. The ability to make healthy food choices includes a
person's knowledge, ability, skills, and resources to make decisions
about the consumption of healthy foods based on their goals,
preferences, culture, and values. While advancing the precision
nutrition research agenda and related technologies is key to informing
Americans of the dietary practices and foods that best support their
health, there are also actionable steps we can take now. For example,
there is unacceptable variability in the delivery, rigor,
effectiveness, and impact evaluation our nutrition education programs
that support national food assistance programs, including EFNEP and
SNAP-Ed. Immediate attention should be paid to understanding and
maximizing the best practices that lead to positive health behaviors
and disease reduction across these education programs, including common
standards for effectiveness evaluation.
Building Public Trust in Nutrition
A 2019 report from the Pew Research Center, and a publication from
the American Society for Nutrition, which I co-authored, indicated
trust gaps between the public and nutrition research scientists. The
science of nutrition is still in its infancy and today is rife with
misunderstanding that leaves consumers confused. Inconclusive, emerging
research on the nutrition needs of individual persons, which has led to
flip-flopping dietary recommendations over time, has bred distrust in
the science around the food we eat and the way that food is made.
That's why another piece to this puzzle is public trust. That is,
everyone engaged in research, practice and policy must work even harder
to ensure scientific rigor is our highest priority, especially research
that underpins our food intake recommendations. We can only earn that
trust by not fearing where the science takes us, by being transparent
about the state of knowledge and the certainty of our recommendations,
and by respecting the tight linkages between cultures and their food
systems.
The Texas A&M Institute for Advancing Health Through Agriculture (IHA)
and the Agriculture, Food and Nutrition Evidence Center (AFNEC)
The divide between agricultural production and the contemporary
expectations of agricultural systems--transitioning from hunger to
human health--amounts to one of the greatest challenges facing our
society. However, agriculture is positioned uniquely to be the
solution--to lead the world in bridging this divide, supporting human
health in a way that is both environmentally and economically
sustainable. As a research accelerator, the new Texas A&M Institute for
Advancing Health Through Agriculture (IHA) is the world's first
research institute to bring together precision nutrition and responsive
agriculture research, linking food production to human consumption, to
improve public health and lower health care costs. The IHA will also
advance research to help agricultural producers and consumers harness
big data, artificial intelligence and machine learning to produce food
that improves public health.
The IHA includes a USDA-ARS program called ``A Systems Approach to
Responsive Agriculture.'' We define ``responsive agriculture'' as
approaches that increase both the quantity of food produced (to
eliminate hunger) and the quality of food produced in that it supports
human health in a way that is both environmentally and economically
sustainable. The program will work with other land-grant universities
and USDA-ARS centers to bring big data, state-of-the-art sensors and
computational systems approaches to responsive agriculture and
precision nutrition. IHA has a strong emphasis on minority food systems
and health and respects the importance of all cultures and their
connection to food. We have entered a full collaboration with The Texas
A&M University System member Prairie View A&M University, an 1890
institution, which includes three post-docs for collaborative projects.
Below, I highlight three example research and convening initiatives
that the IHA is undertaking to make agriculture and food the solution
to human health:
(1) Task Force on Developing a National Roadmap for Responsive
Agriculture Solutions
Over the course of the next 18 months, the IHA is collaborating
with the Chicago Council on Global Affairs' Center on Global Food and
Agriculture (the Council) by convening committees to set priorities for
supporting human health through food and agriculture. These priorities
will focus on the concept of responsive agriculture, which is an
agriculture-system and food environment that consumers experience that
supports human health through nutrition while ensuring the system is
environmentally and economically sustainable for future generations.
The three domains of responsive agriculture are: chronic disease
reduction, agricultural ecosystems and agriculture-food value chain,
and nutrition equity. To catalyze a system of responsive agriculture,
the IHA, with project management support from the Council, has convened
a Task Force on Developing a National Roadmap for Responsive
Agriculture Solutions and three committees. The task force will oversee
the work of the committees and provide an initial framework to help
guide the work of the committees. The composition of the committees
includes leading experts in human health, agriculture, food, and
economics with knowledge of biological and/or social/behavioral
research, scientific evidence, policy, applied health and agricultural
technologies as well as food and agriculture related industry
representatives. This is an inclusive initiative that involves
stakeholders throughout the entire food and agriculture value chain--
everyone must have a seat at the table and be engaged in conversations
to address these grand challenges at the nexus of agriculture, food
systems, nutrition, and health.
Achieving human health though food will require greater precision
in dietary guidance as ``one size does not fit all'' in the diet-
disease relationship. Hence it is essential that we maintain a highly
diversified agriculture production system to meet the different dietary
needs of our diverse population. Agriculture is vital to these efforts.
We cannot solve these problems without working collaboratively with
production agriculture.
(2) Agriculture, Food and Nutrition Scientific Evidence Center
To have confidence that our investments and interventions in the
food system and human nutrition, whether a new policy action or
recommendation, achieves the intended outcome, we must have confidence
in the quality of the scientific evidence that serves as the
foundation. There are major efforts underway to improve the rigor and
reproducibility of agriculture and nutrition research. Furthermore,
over the past 2 decades, nutrition has been moving from an approach of
convening a group of experts to advise on policies and practices, to a
two-tiered ``evidence-informed'' approach that considers and evaluates
the totality of the scientific literature and data by agnostic
methodologists or data experts, followed by the convening of experts.
These advances are focused on removing the many biases we all have
based on individual preferences and values around food choice when
evaluating scientific data, but there is still much work to be done as
discussed in more detail below.
The Texas A&M Agriculture, Food and Nutrition Scientific Evidence
Center located in downtown Fort Worth is conducting state-of-the-art
scientific evidence synthesis studies to address pressing public issues
where agriculture, food and health intersect. This one-of-a-kind
evidence center is a place where policymakers can ask questions related
to connections among food, agriculture, the environment and the
economy, and research specialists will gather and combine existing data
on any topic pertaining to diet and health or economic and
environmental policy by performing rigorous systematic reviews. And
then, they will interpret the data for a non-science audience. The
center is an objective source of comprehensive scientific information
for decision-makers, akin to evidence centers in the medical science
domain.
(3) Maternal Diet and Child Health
Studies of the Dutch Famine of World War II revealed that maternal
diet during pregnancy has strong and persistent effects on offspring
health that persist through the lifespan, including risk for
cardiovascular disease, diabetes, and obesity. In Texas, health and
nutrition for mothers and their children is in a state of crisis, which
ultimately negatively impacts all Americans. The 2021 March of Dimes
Report Card, which provides a comprehensive overview of the health of
moms and babies across the U.S. and grades states' performance on
mother and infant health, gave Texas a ``D'' grade. We believe it
doesn't have to be this way. Texas has one of the nation's highest
rates of poor birth outcomes (pre-term birth rate of 10.8% statewide,
14.6% for African American Women in Texas), and one in nine babies are
born too soon in Texas. The maternal mortality rate in Texas is 34.5
deaths per 100,000 births, which is higher than the U.S. rate at 17.4
deaths per 100,000 births (highest among developed nations) and higher
than Cuba, Mexico, and Uzbekistan. Texas ranks highest among the U.S.
states and territories in childhood obesity with 20.3% of children ages
10-17 considered obese.
To address these challenges of maternal and child health, and high
rates of chronic disease, the IHA is launching a major study to
understand the role and contribution of maternal diet during pregnancy
to chronic disease. There are three popular and distinct food
traditions in Texas: African American, Hispanic and European. Our food
preferences are one of the many things that make our state one of the
most culturally diverse. The United States is a melting pot of people
with various ethnicities and heritages, and the current menu landscape
at all types of restaurants and food-service operations certainly
reflects that. Food is not just a part of culture; it can define
culture. However, it is important to note that food traditions such as
those we have in Texas and in many parts of the country provide
different nutritional benefits, as well as challenges to consumers. We
must work within the cultural contexts of these food traditions to
improve maternal and child health, starting at pregnancy. We must use
certain science to work within these cultural contexts to improve lives
through food systems and avoid the temptation to simply ``tell people
what to eat.''
The IHA is deploying mobile health units to perform this community-
based scientific research that seeks to understand the connection
between food systems and maternal health (i.e., precision nutrition)
and improve health habits in urban and underserved communities,
populations that are not normally accessible to university-based
research. These ``labs on wheels'' will house tools like body
composition scanners, biometric recorders and blood pressure monitors
and may partner with local farmers markets to deliver healthy food to
residents. Equipped with information about healthy living, the mobile
health units will also generate research data by surveying citizens
about their current food habits. For many Texans, they will be the
IHA's first touchpoint to connect food and health in underserved
communities.
Conclusion
While historic efforts to eliminate hunger and food insecurity were
important and well-intentioned, hunger cannot be considered in the
absence of agriculture and health. We need to develop a systems
approach to connecting agriculture, food, environment, economic and
human health.
The costs of the current situation are hard to overstate. Diet-
related chronic diseases place a huge financial burden on individuals,
the health care system, and the American economy as a whole--as well as
a heavy toll on life expectancy and quality of life. Our society needs
help improving health outcomes and re-establishing trust in the science
of nutrition and all of agriculture. Again, in achieving this goal, we
must ensure our practices across the entire food and agriculture value
chain are environmentally and economically sustainable for future
generations.
Fortunately, there are solutions on the horizon. Achieving those
improvements requires that the bridge between producers and consumers
be rebuilt and no longer fragmented. It also requires that policies and
practices must be informed by the best available science, and that
nutrition and food needs must be based on people's specific biology and
physiology, cultural preferences, transparency regarding scientific
certainty and current health needs as they change over a lifetime. And,
finally, it requires us to bolster citizen education to bring consumers
along with the evolving field to earn their trust, ultimately allowing
them to make the best decisions for themselves--benefitting the whole
population in the aggregate.
It is also critical to restore trust across the entire food value
chain, from producers to consumers. To meet these critical expectations
of the food system, all actors and players in the food system must have
a seat at the table to ensure collaboration and cooperation, while
keeping rigorous and transparent science and the goals of eliminating
hunger while advancing human, environmental and economic health, as
paramount.
The White House recently proposed an $8 billion Federal and private
partnership to implement program and policy initiatives referred to as
``Food is Medicine'' (FIM), to reduce the prevalence of chronic
diseases. At this time, reducing hunger and chronic disease through
food policies and programs that are evidence-based and therefore
achievable will require first filling fundamental knowledge gaps
through a nutrition research agenda that builds a deeper understanding
of the diet-disease relationship. In the case of folic acid
fortification for birth defect prevention, there was a strong evidence
base to ensure the likelihood of success. For other FIM initiatives,
our policies, programs and practices cannot get ahead of the science if
they are to be successful.
Thank you for the opportunity to testify. I look forward to your
questions.
The Chairman. Dr. Stover, thank you so much. I am now
pleased to recognize Mr. Hodel, please begin your testimony
whenever you are ready.
STATEMENT OF ERIC E. HODEL, CHIEF EXECUTIVE OFFICER, MIDWEST
FOOD BANK, NORMAL, IL
Mr. Hodel. Chairman Thompson, Ranking Member Scott, and
Members of the Committee, good morning, and thank you for the
invitation to participate in today's hearing. My name is Eric
Hodel, and I serve Midwest Food Bank as the Chief Executive
Officer. I am honored to have a seat at the table today.
Midwest Food Bank was founded by a farmer 20 years ago. I too
was raised on a farm, and continue to manage a 1,400 acre grain
and livestock farm, in addition to my responsibilities at
Midwest Food Bank. I come today understanding the impacts of
agriculture policy as both a producer and servant to the food-
insecure. Thanks in advance for the important work and policies
the Agriculture Committee supports through the USDA.
Food insecurity is real. It is besieging our urban and
rural poor, grandparents on Social Security caring for
grandchildren, struggling single parents, and the
underemployed. Every day Midwest Food Bank rescues food that
would otherwise be discarded and effectively distributes it to
our nonprofit agencies and food recipients. My ask today for
the Committee on Agriculture is simple, continue providing
programs and support that are open and inclusive for all food
banks to help put food on the table for the nearly 35 million
Americans who live in food-insecure households. I am prayerful
today's testimonies and discussion from all of us will provide
innovative ideas needed to change the trend line of food
insecurity.
After 2 decades of sustainable growth, our values and
missions remain steadfast. In 2022 Midwest Food Bank
distributed $415 million of food, including family disaster
relief boxes. We have ten locations across the U.S., 55 full
time employees, and 99.5 of every dollar is spent on program
services. Our business model is simple. We receive donations of
food, financial support, and volunteer efforts. With these
three inputs, we deliver four programs, distributing food to
nonprofit agencies, disaster relief, Tender Mercy Nutritional
Meal, and weekend feeding program for school-age children. We
serve small- to very-large-agencies, knowing that each have a
role to play in providing food access. We do not collect
payment from our agencies for food provided to them. This
allows our agencies' operational costs to not be burdened, and
their local impact to go further.
Some of our agencies will partner with their local grocery
store, and team together to purchase or receive donated food
items to help supplement the MFB donated food. It is a
collaborative and community team effort to fight hunger and
serve food to individuals and families. We believe change
occurs in the community, and our hope is to serve our food
recipients for a season, not for a lifetime.
We celebrated the downward trend in food rates of food
insecurity across our nation in the decade leading up to 2022,
and then unexpectedly the pandemic catapulted more families
into a state of food insecurity. Our combination of food
distribution and disaster relief equipped us for this
challenging season. The USDA Farmers to Families Food Box was a
valuable resource for Midwest Food Bank. We distributed over
two million USDA Farmers to Families Food Boxes, and we
appreciate and applaud the USDA for the quick program
execution. The program injected nutrition directly into the
emergency food system.
``Never waste a crisis'' is a leadership motto I firmly
believe and follow, and so at Midwest Food Bank we have taken
the learnings from the Farmers to Families Food Boxes and
improved our availability in our disaster relief boxes. We now
provide our boxes for humanitarian agencies to deliver. We have
also teamed with corporations to study data on the high poverty
countries and counties in the United States. And thanks to
their financial support to purchase food items, our volunteers
assemble the Family Food Boxes, and an agency in location
provides delivery service of these food boxes to homes. Nearly
1,000 food boxes, representing 15,000 meals, are delivered each
week into eastern Kentucky. Future projects and plannings for
expansion in Mississippi and Louisiana are underway, based on
data.
Additionally, we have started a pilot program with a
logistics company to keep Family Food Boxes in inventory to
help support the super rural communities. Their drivers will
have access to shelf stable food boxes to take out with them on
delivery routes, and they can determine and share appropriately
with those people battling food insecurity. As I mentioned,
Midwest Food Bank has ten main warehouses distributing food
into 23 states. As we continue to grow, USDA's TEFAP is an
option we would explore, and look for an opportunity to provide
staple food options in addition to the industry rescued food.
We request an open bid process for all food banks to have an
opportunity to apply.
Moving forward, we will continue to pursue four
opportunities, mission focus, nutrition, collaboration, and
community partnerships. In closing, we ask the Committee on
Agriculture to commit to an equitable policy that channel
government resources to independent food banks to meet program
requirements. Relieving hunger and malnutrition is a complex
challenge requiring a multifaceted solution. We ask for your
continued effort to bring community-centric programs to the
table. Together we will provide food to families in need as we
serve and support the communities across America with
innovation and nimble execution.
[The prepared statement of Mr. Hodel follows:]
Prepared Statement of Eric E. Hodel, Chief Executive Officer, Midwest
Food Bank, Normal, IL
Good morning and thank you for the invitation to participate in
today's hearing. My name is Eric Hodel, and I serve Midwest Food Bank
as the Chief Executive Officer. I am honored to have a seat at the
table today.
Midwest Food Bank was founded by a farmer 20 years ago. I too was
raised on a farm and continue to manage a 1,400 acre grain and
livestock farm in addition to my responsibilities at Midwest Food Bank.
I come today understanding the impacts of agriculture policy as both a
producer and a servant to the food-insecure. Thanks in advance for the
important work and policies the Agriculture Committee supports through
the USDA.
Food insecurity is real. It is besieging our urban and rural poor,
grandparents on social security caring for grandchildren, struggling
single parents, and the underemployed. Everyday Midwest Food Bank
rescues food that would otherwise be discarded and efficiently
distributes it to nonprofit agencies and food recipients. My ask today
for the Committee on Agriculture is simple: Continue providing programs
and support that are open and inclusive for all food banks to help put
food on the table for the nearly 35 million Americans who live in food-
insecure households. I am prayerful today's testimonies and discussion
from all of us will provide the innovative ideas needed to change the
trend line of food insecurity.
After 2 decades of sustainable growth, our values and mission
remain steadfast. In 2022, Midwest Food Bank distributed $415M in food,
including family food disaster relief boxes. We have ten locations
across the U.S. spanning from Connecticut to Arizona. We have 55 full-
time employees, and 99.5 of every dollar spent is for program
services.
Our business model is simple: We receive donations of food,
financial support, and volunteer efforts. With these three inputs, we
deliver four programs: (1) Distributing food to nonprofit agencies, (2)
providing Disaster Relief support, (3) producing Tender Mercies
nutritional rice & beans meal and (4) weekend feeding program for
school aged children.
We serve small- to very-large-agencies knowing they each have a
role to play in providing food access. We do not collect payment from
our agencies for food provided to them. This allows our agency's
operational cost to not be burdened and their local impact to go
further. Some of our agencies will partner with their local grocery
store and team together to purchase or receive donated food items to
help supplement the MFB donated food. It's a collaborative and
community team effort to fight hunger and serve food to individuals and
families. We believe change occurs in the community. Our hope is to
serve our food recipients for a season, not for a lifetime.
We celebrated the downward trend in rates of food insecurity across
our nation in the decade leading up to 2020. And then, unexpectedly,
the pandemic catapulted more families into a state of food insecurity.
Our combination of food distribution to nonprofits and Disaster Relief
equipped us to promptly serve during this challenging season. The USDA
Farmers to Families Food Box Program was a valuable resource for
Midwest Food Bank. We distributed over two million USDA Farmers to
Families Food boxes. We appreciate and applaud the USDA for the quick
program execution from concept to delivered boxes. The program injected
nutrition directly into the emergency food system--while supporting
farmers and producers.
``Never waste a crisis'' is a leadership motto I firmly believe and
follow. And so, at Midwest Food Bank we have taken the learning from
the [Farmers] to Families Food boxes and improved the availability of
our Disaster Relief boxes. We now provide our boxes for humanitarian
and agencies to deliver. We have also teamed with corporations to study
data on the high poverty counties and pockets in the U.S. And thanks to
their financial support to purchased food items, our volunteers
assemble the family food boxes and an agency in location provides
delivery service of these food boxes to homes. Nearly 1,000 food boxes
representing 15,000 meals are delivered each week into eastern
Kentucky. And future projects are in the planning stages for
Mississippi and Louisiana. Additionally, we have started a pilot
program with a logistics company to keep family food boxes in inventory
to support the super rural communities. Their drivers will have access
to shelf stable food boxes to take out with them on delivery routes and
they can determine and share appropriately with those people battling
food insecurity.
As mentioned earlier, Midwest Food Bank has ten main warehouses
distributing food into 23 states. As we continue to sustainably grow,
USDA's The Emergency Food Assistance Program, commonly known as TEFAP,
is an option we are exploring and looking for as an opportunity to
provide staple food options, in addition to the industry rescued food.
We request an open bid process for all food banks to have an
opportunity to apply.
Moving forward, Midwest Food Bank will continue to pursue four
opportunities:
Mission Focus--Serving our agencies with a focus on
efficiency and excellence.
Nutrition--Increasing the nutrition of food distributed,
procured through multiple channels.
Collaboration and sponsorship--Build relationships with
industry (food and other) to provide financial support,
volunteers, in-kind services, and rescue food for re-use in the
food bank network.
Community Partnerships--Strengthening our partnerships with
community leaders and agencies to advance holistic programing
for those we serve.
In closing, we ask the Committee on Agriculture to commit to
equitable policies that channel government resources to independent
food banks able to meet program requirements. Alleviating hunger and
malnutrition is a complex challenge requiring a multi-faceted solution.
We ask that you continue to bring efficient, community-centric programs
to the table for collaboration. Together we will provide food to
families in need as we serve and support communities across America
with innovation and nimble execution.
The Chairman. Mr. Hodel, thank you very much. Ms. Royal,
please begin when you are ready.
STATEMENT OF DAWN ROYAL, MEMBER, BOARD OF
DIRECTORS AND PAST PRESIDENT, UNITED COUNCIL ON WELFARE FRAUD,
GREYBULL, WY
Ms. Royal. Chairman Thompson, Ranking Member Scott, Members
of the Committee, thank you for the opportunity to address you
today. My name is Dawn Royal. I am a current Director and two-
term past President of the United Council on Welfare Fraud,
commonly referred to by its acronym, UCOWF. The United Council
on Welfare Fraud is a national professional organization
dedicated to protecting the integrity of our nation's public
assistance programs. We are the only national organization
singularly focused on the detection, prevention, and
prosecution of welfare fraud. UCOWF has over 1,000 members
throughout the country, who will proudly celebrate UCOWF's 50
year history this year at its annual training conference.
While I have always been aware of SNAP and its predecessor
the Food Stamp Program, I didn't learn the importance of the
program until I became an investigator 15 years ago. I think we
all agree that the United States cannot claim to be the most
powerful country in the world if our citizens are hungry. On
this point, there can be no debate. The importance of a strong
nutrition assistance program cannot be overstated. I volunteer
my time to promote UCOWF's mission, and I am intensely proud of
my job as a Certified Welfare Fraud Investigator. My day-to-day
duties are investigating allegations of fraud. I am on the
front line. And I am here to talk today about current real-
world fraud in SNAP that happens every day.
My days are seldom dull, not only because of the volume of
cases I work through, but also because I don't work with hunch
or suspicion. I have to find facts and evidence to prove, or
disprove, fraud in--allegations of fraud and misuse. As an
example, I worked a case where a man submitted several
applications over several years where he repeatedly claimed his
only source of income was a nominal amount from Social Security
Disability, and yet he reported in a rented home in an area
with one of the highest costs of living in the country.
After my extensive investigation I was able to prove
multiple false statements, including the applicant was not a
resident of my state, and that he and his family lived in a
bordering state in a home he owned, as well as his nine cars,
motorcycles, and a sailboat. The Defendant pleaded guilty to a
felony, and paid over $28,000 of restitution, and a single
payment he presented at his sentencing hearing.
Members of this Committee, it is investigators through this
country who diligently work every day to detect, prevent, and
prosecute fraud that keep SNAP strong. We identify and bring
those who take unlawful advantage of the program into the light
and hold them accountable for their actions.
There are simple measures that we can discuss today that
can be included in the farm bill that will give immediate and
substantial assistance to the fight of the ever-increasing
occurrences of fraud that have become rampant in the program.
First, additional funding, such as increasing retention amounts
and mandating retention money be used for the prevention,
detection, and prosecution of fraud. Second, access to
technology, including immediately implementing the National
Accuracy Clearinghouse. And third, updates to antiquated
policies, including geographical controls on EBT purchases.
Thank you for giving me the opportunity to provide you with
our views, and what we in UCOWF see as simple measures that
will make significant strides in reducing fraud and abuse in
this vital safety net program. We also sincerely appreciate the
opportunity to further discuss the outstanding work
investigators do every day, and what you can do to help their
efforts to promote and protect the integrity of the
Supplemental Nutrition Assistance Program, so when America's
vulnerable citizens need help, there is a strong and fair
program standing ready.
[The prepared statement of Ms. Royal follows:]
Prepared Statement of Dawn Royal, Member, Board of Directors and Past
President, United Council on Welfare Fraud, Greybull, WY
Program Integrity for the Supplemental Nutrition Assistance Program
Chairman Thompson, Ranking Member Scott, Members of the Committee,
thank you for the opportunity to address you today. My name is Dawn
Royal, I am a member of the United Council on Welfare Fraud, commonly
referred to by its acronym, UCOWF. I am honored by the invitation to
discuss the devastating problem of fraud that plagues the Supplemental
Nutrition Assistance Program (SNAP) and advocate for simple changes in
the farm bill that would substantially strengthen integrity.
The United Council on Welfare Fraud (UCOWF) is a non-partisan
national professional organization dedicated to defending against the
erosion of integrity in our nation's public assistance programs. We are
the only national organization singularly focused on the detection,
prevention, and prosecution of welfare fraud. We provide annual
training on program integrity best practices, fraud trends, and the
only professional certification in our field. Our membership spans
state, county, and Territory SNAP agencies and is comprised of over
1,000 program administrators, analysts, Inspectors General,
investigators--both sworn and non-sworn--claims overpayment
specialists, and quality control auditors.
I have served two terms as UCOWF's President, and currently co-
Chair our Intergovernmental Committee which collaborates and educates
the public, agency, and government leadership on welfare fraud. While I
volunteer my time to promote UCOWF's vision, I work full-time as a
state Certified Welfare Fraud Investigator. My day-to-day duties are
investigating allegations of fraud, I am on the front line, and I am
here today to talk about current, real-world fraud impacting SNAP every
day. My subject matter expertise is the product of personal experience
conducting numerous investigations, face to face discussions with other
investigators and the analysis of data from the unique perspective of
protecting the SNAP program feeding our most needy members of society
while safeguarding our nation's taxpayer resources.
The United Council on Welfare Fraud has the steadfast belief that
the United States cannot claim to be most powerful country in the world
if its citizens are hungry. On this point, there can be no debate; the
importance of a strong nutrition assistance program cannot be
overstated.
Members of this Committee, it is the investigators throughout this
country, who diligently work every day to detect, prevent and prosecute
fraud that keeps SNAP strong. We identify and bring those who take
unlawful advantage of the program into the light and hold them
accountable for their actions. Unfortunately, we are overrun by those
who leverage the compassion of the American taxpayers and steal the
dollars allocated to this program with impunity.
Our nation's public assistance fraud investigators are roundly
under-funded and insufficiently staffed to address the volume of
suspected fraud; and most days, we know we are fighting an unwinnable
battle. Not only do we face ever changing fraud schemes, but we often
are crippled by antiquated regulations and agency bureaucracy.
Fraud in SNAP
SNAP fraud occurs in three ways:
Eligibility Fraud--Eligibility fraud is when an applicant
provides false or incomplete information to obtain SNAP
benefits for which they are ineligible. This occurs in both
recipients and retailers. In SNAP, recipient eligibility fraud
is the responsibility of the state and county program integrity
staff, and violations result in disqualifications--one year for
the first offender.\1\ When someone does receive SNAP in two or
more states in the same month or in two or more households
within the same state, it is referred to as dual
participation.\2\
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\1\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-F/section-273.16.
\2\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-272/section-272.4#p-272.4(e).
The Burden of Proof in administrative disqualification hearings
is set a Clear and Convincing, a higher threshold than any
other government assistance program.\3\ In fact, it's easier to
arrest a suspected violator with Probable Cause than it is to
administratively prosecute. Retailer program eligibility is the
responsibility of the United States Department of Agriculture
(USDA) Food and Nutrition Service (FNS) national office.
Retailer violations exceeding $250,000 fall under the
jurisdiction of the USDA Inspector General.
---------------------------------------------------------------------------
\3\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-F/section-273.16#p-273.16(e)(6).
Identity Fraud--The food assistance program, much like tax-
refund fraud and unemployment insurance fraud exposed during
the Pandemic Health Emergency, is targeted by both domestic and
international fraudsters. With data breaches and the growing
global modernization of foreign states and the proliferation of
stolen Personal Identification Information (PII), SNAP now
stands alone as the largest Federal program with antiquated or
non-existent anti-fraud measures. Unfortunately, these identity
theft attacks occur in both recipient and retailers. This
includes synthetic identity fraud, skimming of Electronic
Benefit Transaction (EBT), and account takeover--which results
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in the loss of benefits for real legitimate SNAP recipients.
Trafficking--The exchange of SNAP benefits for anything
other than eligible food items is referred to as trafficking.
The most common example of this is when a recipient exchanges
SNAP benefits for cash at a dishonest retailer. UCOWF members
have also seen benefits trafficked for rent, firearms,
narcotics, and human trafficking--and while those incidents may
be uncommon, no instances are acceptable. Despite this form of
fraud resulting from a quid-pro-quo transaction, retailers can
be removed with a Preponderance of the Evidence. Even though it
is the same incident, antiquated rules require the much higher
Clear and Convincing evidential burden for recipients.\4\
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\4\ https://crsreports.congress.gov/product/pdf/R/R45147 2018
Congressional Research Service report: ``Errors and Fraud in the
Supplemental Nutrition Assistance Program'', pp. 37-38:
``Retailer and recipient trafficking proceedings have different
burdens of proof; therefore, gov-
ernments will not necessarily prevail in both cases with the same
evidence. Accepting SNAP
benefits as a form of payment is not an entitlement for retailers. To
disqualify a SNAP retailer
for a violation of SNAP rules, USDA-FNS must only meet a lower-level
burden of proof--the
`preponderance of the evidence' standard. Receiving SNAP benefits is
an entitlement for eligible
individuals. To disqualify a SNAP recipient for fraud, a state agency
must meet a higher-level
burden of proof--the `clear and convincing evidence' standard. This
means that evidence
deemed sufficient to prove retailer trafficking may not be sufficient
to prove recipient traf-
ficking. Indeed, over 84% of the USDA-FNS retailer trafficking cases
that resulted in a perma-
nent disqualification in FY 2016 relied primarily on an analysis of
suspicious transaction pat-
terns based on Anti-fraud Locator using EBT Retailer Transactions
(ALERT) system data.
These EBT transaction data, on their own, are not generally
considered sufficient grounds for
the disqualification of SNAP recipients. For this reason, state
agencies often have difficulty dis-
qualifying recipients whose EBT cards were used in transactions
flagged as trafficking by
ALERT transaction data analysis, absent other evidence of recipient
trafficking.''
UCOWF contends that recipient trafficking fraud should not be an
entitlement and should use the preponderance standard as other
entitlement programs.
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Common Sense Modernization of Regulations Are Needed
There are simple measures that can be included in the farm bill
that will give immediate and substantial assistance to fight the ever-
increasing occurrences of fraud that have become epidemic in the
program. Specifically, some measures or provisions include:
Increased Retention Amounts with Mandated Use
No incentives currently exist for SNAP agencies to detect and
prevent fraud at the front-end.\5\ Current incentives only exist in the
inefficient recovery of overpayments, also known as ``pay and chase.''
States retain either 20% (Inadvertent Household Errors/Unproven Fraud)
or 35% (Intentional Program Violation/fraud proven at administrative or
criminal proceedings). Prior farm bills reduced this amount from 50%
retained share of recoveries.\6\ Unfortunately, there are no mandates
that require agencies reinvest their state share of recoveries into
program integrity; and few do.
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\5\ 2014 GAO report: Despite the U.S. Government Accountability
Office recommendations for FNS to explore ways that Federal incentives
can better support cost effective state anti-fraud activities nearly a
decade ago, nothing has changed. See https://www.gao.gov/products/gao-
14-641.
\6\ Historically, the state retention rates have changed several
times. Prior to October 1, 1990, IPV retention was 50%. Afterwards and
until September 30, 1995, the rate was reduced to 25%. The rate was
changed back to 50% until January 1, 2001, when the 35% rate was
established. Some states reinvest the retained percentage of
collections into their integrity programs; however, FNS does not
provide guidance or mandates for states to do so. This results in the
recoveries (state revenue) being diverted to pay for competing
priorities and not reinvested back into program integrity initiatives,
similar to guidance on the use of SNAP QC performance bonuses (Section
4021).
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The August 2014 GAO report suggested that increasing this retention
rate and restricting the use of retained funds to state agency anti-
fraud activities could significantly enhance efforts to combat
recipient trafficking, noting that the strategy ``may result in a net
savings for SNAP if increased collections in payment recoveries
outweigh the increased amount states receive in retentions.'' \7\ A
decade later, nothing has changed.
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\7\ https://www.gao.gov/assets/gao-14-641.pdf p. 15.
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Grant Opportunities
FNS spends 0.005% of appropriations on anti-fraud efforts. One
twentieth of one percent. States are forced to carry the burden of
protecting Federal assets/taxpayer monies with a 50% administration
reimbursement rate. SNAP-Ed receives more money, half a billion
dollars, at 100% Federal funding; yet state program integrity efforts
receive no earmarks and require 50/50 state matching. While states can
qualify for any number of annual performance bonuses totaling $48
million, no such incentive award is issued for stopping or preventing
fraud, waste, and abuse.\8\ States, reluctant to invest their limited
resources to protect Federal taxpayer resources, are put at a
significant disadvantage when compared to other assistance programs.
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\8\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-275/subpart-G/section-275.24#p-275.24(a)(1).
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The only grant program providing funds to states to combat fraud is
the SNAP Fraud Framework Grant, established by Section 4029 of the 2014
Farm Bill--which awards up to $750,000 to a single state out of the
total $5M appropriated.\9\ However, not all appropriations are
distributed, and no grants were published or awarded in 2016 and
2017.\10\ This grant expires at the end of this Federal fiscal
year.\11\
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\9\ The SNAP Fraud Framework contains FNS guidance on best
practices for states to follow for program integrity activities. The
Framework was released in 2018. Despite intentions it would exist as a
living document, it has never been updated.
\10\ https://crsreports.congress.gov/product/pdf/R/R45147.
\11\ https://www.fns.usda.gov/grant/snap-fraud-framework-
implementation.
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Fraud Data and Rates
The question of how much fraud is a topic of much discussion and
debate. FNS contends fraud rates of less than 1% and holds the program
as a model of Federal excellence. Anyone, including the public, can
clearly see the numbers don't add up. It is a matter of debate even
amongst UCOWF members across the nation with rates ranging from 8% to
40% of all households currently enrolled. One thing is clear--the fraud
rate varies from County to County, state to state . . . but the numbers
being bantered about by USDA FNS amount to nothing short of
gaslighting.
A simple internet search for `SNAP fraud' will reveal dozens of
news stories with real examples. Last week in Michigan, three
individuals were arrested in connection with stealing EBT benefits from
8,000 SNAP households from across the nation, mostly in California, and
spending the benefits in Detroit Sam's Club stores. While FNS monitors
EBT transactions for fraud, they do not monitor large supermarkets,
such as Sam's Club. The number of stolen benefits was said to be $4
million--but the actual amount is reportedly much higher.\12\
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\12\ https://www.msn.com/en-us/news/us/michigan-catches-4m-of-food-
stamp-fraud-mum-on-fraud-scope/ar-AA1c4rX7.
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The issue is compounded by the mandatory quarterly reporting by
state SNAP agencies in the FNS 366b (fraud reporting) and FNS 209
(claims recovery) reports. Simply put, the numbers are wrong. I am
reticent to say this is intentional as USDA FNS does not publicly post
this information online, and it takes months to get a FOIA response.
This Committee can observe this issue for themselves by comparing the
county and state submitted data to the FNS State Activity reports,
which are grossly inaccurate as a simple review can attest.
According to the fiscal year 2020 FNS State Activity Report,
California established almost 269,000 overpayment claims, but only 52
for fraud (note: California has a reported 5,245,040 persons on
SNAP).\13\ However, contrast this with the 366b report submitted to FNS
showing 28,407 cases of eligibility fraud that resulted in reduced or
denied benefits.\14\ 2,279 were submitted for criminal prosecution or
administrative disqualification equal to $2.55 million in eligibility
fraud claims. Yet California only established 52 fraud claims? That
does not add up, and there is a clear disconnect between the data
collected by states and reported by FNS. Using flawed data results in
flawed statistics--such as claims of only .01%. This alone demands
Congressional oversight inquiries and USDA OIG investigations.
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\13\ https://fns-prod.azureedge.us/sites/default/files/resource-
files/FY20-state-activity-report.pdf.
\14\ UCOWF Freedom of Information Act request to FNS for FFY2020.
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The states themselves know the numbers are much higher.
Commonwealth of Pennsylvania's Inspector General ``told lawmakers
during a recent budget hearing that the agency uncovered a 40% fraud
rate among public assistance beneficiaries--primarily in the
Supplemental Nutritional Assistance Program.'' \15\
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\15\ https://www.bradfordera.com/news/key-pa-budget-negotiator-
hopes-for-welfare-fraud-compromise/article_560351bf-6e3e-5beb-8177-
18282b864774.html.
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Florida Medicaid and Public Assistance Fraud Task Force
commissioned an independent study in 2012 on SNAP eligibility fraud in
the state--omitting identity theft and trafficking--and found 7.5% of
SNAP households were fraudulent. At today's enrollment, this s
translates to 129,243 investigations. At current staffing levels, this
amounts to 2,585 cases per investigator--a workload that would take
Florida 51 years to complete.
More Investigative Oversight Staffing
Nearly all state and county SNAP agencies are facing a shortage of
eligibility workers currently focused on Unwinding and a backlog of
certifications since the PHE ended. However, the worker shortage has
hit the hardest in program integrity. Current antiquated regulations
only require fraud detection units when an ``area'' exceeds 5,000
households--no standard in the amount of Program Integrity staff is
defined--and the ``area'' can include the entire state.\16\
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\16\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-272/section-272.4#p-272.4(g).
---------------------------------------------------------------------------
Staffing varies at the state level and is grossly deficient--some
states only have a single fraud investigator. Fraud rates may appear
low--but only because states lack staff and resources to address fraud
prior to issuance. GAO has reported on this in a 2016 report--and while
recipient rolls and program expenditures have drastically increased
over the past 20 years, there have been few increases to staff
dedicated in protecting SNAP.\17\ FNS must mandate a minimum ratio of
Investigators to SNAP households.
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\17\ https://www.gao.gov/assets/gao-16-719t.pdf.
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National Accuracy Clearinghouse
Several southern states tested the concept of data sharing through
the ``buddy state'' model as early as 2008 as a result of lessons
learned operating D-SNAP programs following Hurricane Katrina. The
establishment of the Partnership Fund for Program Integrity Innovation
by the Office of Management and Budget (OMB) in 2010 created the
opportunity for funding a more comprehensive solution.
The following year, OMB awarded the USDA FNS $2.5 million with the
goal of reducing improper payments that occur due to dual participation
in SNAP. This grant funded the development of a searchable database--
the National Accuracy Clearinghouse (NAC)--to support near real-time
sharing of eligibility information. Subsequently, Mississippi was
awarded the funding to lead the project on behalf of a consortium of
contiguous states (also including Alabama, Florida, Georgia, and
Louisiana, and most recently, Missouri).
A 2015 independent evaluation of NAC was provided to Congress
showing success and the return on investment and cost savings to the
program.\18\ The NAC found that dual participation across the five
states was quite rare affecting roughly 0.1 percent of SNAP
participants. However, the establishment of NAC did prevent dual
participation, and the evaluation provided insights into best practices
for states to use the data match most effectively. The CBO estimated
that this provision will reduce SNAP spending by $576 million from 2019
to 2028.\19\
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\18\ https://fns-prod.azureedge.us/sites/default/files/resource-
files/nac-pilot-evaluation.pdf.
\19\ https://www.ers.usda.gov/agriculture-improvement-act-of-2018-
highlights-and-implications/nutrition/.
---------------------------------------------------------------------------
In a 2018 press release, USDA wrote about the NAC stating, ``The
NAC Strengthens SNAP integrity through the nationwide expansion of an
interstate data match to prevent household receipt of benefits from
more than one state and by requiring states to provide USDA with
greater access to SNAP records for inspection and audit.''
Subsequently, the 2018 Farm Bill required FNS to expand the NAC
nationally to prevent duplicate simultaneous benefit issuance to the
same individual in more than one state.
The 2018 Farm Bill mandated all states be actively participating in
the NAC by December 31, 2021. Unfortunately, in 2021, FNS unilaterally
decided to ignore Congress' directive by directing the Government
Services Administration (GSA) 18F unit to construct a new and unproven
pilot. This decision has delayed the implementation of this essential
tool until 2027, a delay of more than 6 years costing the taxpayers an
estimated $2.5 billion when adjusted for inflation and increases due to
the Thrifty Food Plan.\20\
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\20\ The 2015 NAC Pilot report to Congress estimated up to $193.4
million in annual savings. The Interim Final Rule cites a lower figure,
the average of $114 million. The savings in the 2015 NAC Pilot report
to Congress range from $53.8m to $193.4m, averaging $114m. Adjusted for
inflation, the figures are then $67.8m, $243.7m, and $143.6m,
respectively.
Adjusted for inflation and increases to SNAP allotments through the
Thrifty Food Plan, anticipated annual savings are currently up to
$309.5 million per year. It can therefore be concluded that the
decision to delay the roll-out of the farm bill mandate for the new and
unproven NAC Pilot has cost the SNAP program approximately $1.85
billion (or $2.5b adjusted for inflation at current rates). The
Congressional Budget Office reported an estimated 10 year cost estimate
savings (outlays) of $588 million; however, CBO did not factor in the
decision to create a second NAC pilot or FNS' benefit increases via the
Thrifty Food Plan.
---------------------------------------------------------------------------
We find this delay irresponsible, and the reasoning provided is
ludicrous. This invaluable tool to end duplicate participation,
established by Congress and signed into law, was ignored without
adequate reasoning or replacement. We find the timeline created by FNS
to deliver the version of the NAC they requested to be developed by GSA
18F to be a wholly unacceptable waste of resources.
FNS issued an Interim Final Rule (IFR) on the newly commissioned
NAC on October 3, 2022.\21\ The IFR references to technology do not
take into considerations the improvements in technology, matching, and
security implemented in the original NAC pilot since 2015. The original
NAC pilot resolved matching data models currently impeding the 18F
technology as described in Department updates to Congress (such as
special characters, hyphens, etc.) and omits any referential data
checks to ensure proper matching to identifiable individuals.
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\21\ https://www.fns.usda.gov/snap/nac.
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The Congressional inclusion of the NAC expansion and mandate was
based entirely on the successful NAC Pilot and impressive return on
investment savings. The ``new'' NAC ignores lessons learned, and
contradicts best practices realized by states administering disaster
(D-SNAP) programs. In fact, the lead state (Mississippi) in the NAC
pilot was not even consulted. Further, the current 5 year roll-out of
the proposed 18F NAC ignores the intent and establishment of the
Partnership Fund for Program Integrity Innovation by the Obama
Administration's Office of Management and Budget in 2010.
A copy of the United Council on Welfare Fraud's response to the NAC
Interim Final Rule is attached to the end of this testimony.
Identity Verification
Identity fraud, synthetic identity fraud, and account takeover are
impacting all states. Our UCOWF conversations with states confirm the
issue not being a one-off individual state or county SNAP agency
problem. The issue has been demonstrated across all public assistance
programs and exposed more broadly during the pandemic. SNAP is one of
the last government assistance programs that does not conduct remote
identity verifications.
One State Unemployment Insurance agency found up to 500,000 bot
attacks originating from transnational fraud rings in just 1 month. Why
would identity thieves target SNAP? Well, there are several reasons.
First, there are no controls in place. Despite Federal law
requiring state agencies to verify an applicant's identity and other
critical information prior to certifying the household to participate
in SNAP, FNS issued a memorandum in 2019 giving states the option to
use identity authentication tools. However, FNS provided over-
burdensome conditions and mandated that applicants can opt-out of
online identity checks.\22\ The justification is due to an
interpretation that regulations only require a name, address, and
signature--regulations that go back to the creation of the food stamp
program.\23\
---------------------------------------------------------------------------
\22\ https://www.fns.usda.gov/snap/identity-authentication-pilot-
projects.
\23\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273#p-273.2(b)(1)(v).
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So [John Doe, homeless, and an `X'] is all that is required to
apply for SNAP. No date of birth. No Social Security Number (SSN). No
identification or driver's license number. This creates an
administrative burden to states, creates churn and delays issuance of
benefits, and as we know firsthand, provides fraudsters an open door to
access the system.
Yet eligibility requirements are clear.
``The state agency shall require that a household
participating or applying for participation in SNAP provide the
state agency with the social security number (SSN) of each
household member or apply for one before certification. If
individuals have more than one number, all numbers shall be
required. The state agency shall explain to applicants and
participants that refusal or failure without good cause to
provide an SSN will result in disqualification of the
individual for whom an SSN is not obtained.'' \24\
---------------------------------------------------------------------------
\24\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-C/section-273.6#p-273.6(a).
FNS publicly provides this information to the public on their
website.\25\
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\25\ https://www.fns.usda.gov/snap/facts.
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Requiring the SSN on the application is commonsense and does not
impose an additional condition of eligibility. Modernization of the
regulations demand that this be addressed. Failing to include the SSN
has a broader impact to program integrity and introduces waste, fraud,
and abuse into the program. For example, anyone receiving Social
Security Income in California is ineligible for SNAP--SSI payments have
been specifically increased to include the value of SNAP.\26\ However,
California does not require SSNs to apply or be certified for SNAP,
making cross-program data checks extremely difficult--if they are done
at all.
---------------------------------------------------------------------------
\26\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-G#p-273.20(a).
---------------------------------------------------------------------------
But that single, mandatory eligibility requirement does not just
impact California. Without SSNs, you cannot efficiently conduct
mandatory data matches against the Electronic Disqualified Recipient
System (eDRS, to check for disqualified and ineligible recipients),\27\
the Social Security Administration Death Master File (DMF), or the
Income Eligibility and Verification System (IEVS).\28\
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\27\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-A/section-273.2#p-273.2(f)(11).
\28\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-272/section-272.8#p-272.8(a).
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Further, states cannot do duplicate participation checks under
current regulations, which state:
``Each state agency shall establish a system to assure that
no individual participates more than once in a month, in more
than one jurisdiction, or in more than one household within the
state in SNAP. To identify such individuals, the system shall
use names and social security numbers at a minimum, and other
identifiers such as birth dates or addresses as appropriate.
[emphasis added]'' \29\
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\29\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-272/section-272.4#p-272.4(e).
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Without addressing these shortcomings, UCOWF fears that fraud will
become the face of this program--not the assistance it provides for the
overwhelming majority of law-abiding eligible recipients. Mandating
identity verification that does not require opt-out, can be done in a
way that aligns with best industry standards and provides benefits to
eligible recipients more quickly, ensures program integrity, and
increases access to the program with reduced administrative burden in
identification requirements. We eagerly await modernization in
application requirements.
Second, the lack of identity verification tools is impacted by
antiquated eligibility systems--state systems that lack modular human-
centered design. The Urban Institute researched state modernization
projects and the use of the $1.15 billion in additional SNAP
administrative funding to help state agencies address these antiquated
systems. Program Integrity was one of the authorized use cases to
access these funds. 7 States listed Program Integrity initiatives in
their use of funds (CT, MI, NE, NM, PA, UT, WA).\30\
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\30\ https://www.urban.org/projects/exploring-states-snap-
modernization-projects.
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FNS defines Program Integrity as, ``Improving stewardship of
Federal money by reducing recipient fraud, reducing retailer fraud,
ensuring accurate eligibility determinations, and reducing improper
payments.'' UCOWF believes accurate eligibility determinations is
primarily an administrative function--doing your job correctly.
Reviewing the use of ARPA funds, only two states had legitimate anti-
fraud initiatives--Pennsylvania (resources for the Inspector General)
and Utah (asset testing/verification).
Third, SNAP is a target for identity thieves due to the siloing and
restrictions on recipient data sharing. Regulations, which still exist
in a pre-9/11 condition, spell out the strict sharing of information of
SNAP household information.\31\ You cannot share information with law
enforcement for exigent circumstances, including the preservation of
life. Nor can you conduct data matches with the National Center for
Missing and Exploited Children to locate kids currently in the system.
And we've all heard about the stories of SNAP funds going to
terrorists, who refer to the program as the ``Jihadist's Allowance.''
\32\
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\31\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-272/section-272.1#p-272.1(c).
\32\ ``EBTerrorism: How Fraud Ridden SNAP Funds Terror, Fails at
Enforcement and Wastes Taxpayer Money'' (https://thedrilldown.com/wp-
content/uploads/2018/10/2018_GAI_SNAP_
FRAUD_TERROR.pdf).
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There are no prohibitions against anyone on the terrorist watch
list or no-fly list receiving SNAP--and Homeland Security is prohibited
from accessing recipient information. Had this not been the case, the
government would have been able to obtain information on the 9/11
hijackers--but that never happened. Addressing data sharing in today's
world climate provides a safer nation, and efforts to combat this can
only be viewed as anti-American. Common sense reform can balance the
protection of personal information against any shortcomings.
Physical and digital identity verifications that go beyond
knowledge-based authentication questions are private sector best
practices. While we strongly encourage and endorse stronger program
integrity guidelines, we are reticent as it relates to facial
recognition technology and the potential bias that currently exists in
the technology. Asset verifications, wage and employment verifications,
and incarceration checks are readily available. Many states are
introducing state legislation to fill the lack of Federal efforts.\33\
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\33\ https://legiscan.com/IA/bill/SF494/2023.
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Use of both digital and physical identity referential data allows
state agencies to quickly identify risky applications (such as
originating from foreign countries) as well as quickly identifying
known-GOOD applicants. Effective identity authentication reduces the
time to get benefits to eligible applicants, resulting in lower
administrative costs.
``EBT Skimming''
Recent news articles related to fraud within public assistance
programs (SNAP, TANF, WIC) have focused on ``EBT Skimming.'' Both FNS/
ACF and individual SNAP/TANF agencies have issued numerous client
education materials aimed at informing genuine needy clients as to how
to spot a card skimmer. Yet the epidemic continues, and it goes much
farther than fake devices placed on a credit card point-of-sale device
to capture EBT card numbers and PINs. Skimmers have historically and
predominately been found on ATM and gas pumps targeting credit and
debit cards. Recently, this trend has expanded to large supermarkets
and big box stores; unfortunately, FNS does not monitor transactions
for fraud at these retailers. And while guidance has been issued on
replacing stolen benefits, nothing is being done to prevent it.\34\
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\34\ https://www.fns.usda.gov/snap/replacement-snap-benefits-
consolidated-appropriations-act-2023.
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SNAP recipients are having their benefits stolen and drained by
fraudsters who gain access to the account in what is commonly referred
to as ``Account Take-Over'' Account Take-Over (ATO) has been an issue
for decades; anyone who has had funds suddenly drained from a debit
card knows this. Credit card companies notify clients of suspicious
transactions and monitor oversea purchases. Card skimming devices are
but one tool in the arsenal of fraudsters looking to make an easy buck.
But now it's hitting the most vulnerable in society. Texas recently has
directed recipients to change their PIN regularly and to freeze/
unfreeze their card to prevent ATOs.\35\ California, long struggling
with the issue, even provided numbers related to the depth of this
problem: $84 million in anticipated 2023 losses just for TANF in
CalWorks.\36\
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\35\ https://www.kxan.com/news/texas/hhsc-warns-of-increased-
reports-of-snap-tanf-recipients-being-targets-of-fraud/.
\36\ https://calmatters.org/california-divide/2023/01/calfresh-
calworks-thefts/.
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Call Centers remain the number one target of opportunity for
identity thieves as they can hide behind the anonymity of (spoofed)
phone numbers to social engineer and scam call takers. Due to high call
volumes, staff shortfalls, and the expense it takes to identify
callers, operators continue to fall back on Name, DOB, SSN, and a
validating question (address, name of a child on account, etc.).
Unfortunately, every identity fraudster has this information on hand.
Call centers remain a major vulnerability where clients (and
fraudsters) can change account information, change addresses, order new
cards, or offset PINs. Improving call center identity solutions and a
federally mandated standard for states and EBT vendors is sorely
needed.
Customer Service Portals have been critical to providing enhanced
access to recipients to check balances, reset PINs, get balance
inquiries, or confirm when benefits will be loaded onto a card. Online
portals lack sufficient safeguards that can confirm the person
accessing the portal is the client. Interactive Voice Response phone
systems (IVRs) commonly only require the last four digits of an SSN, a
DOB, and sometimes a case number to access client accounts or to
determine benefit balances. Few states check the phone number in the
IVR, but no (known) state agencies check for spoofed numbers, Voice
Over Internet Protocols (VOIPs), or SIM swaps.
Online identity verification still presents the best opportunity to
prevent synthetic identities in the U.S. banking system (estimated at
five million) and to verify legitimate recipients accessing or applying
for benefits. It remains the best method to stop EBT skimming/ATO.
Additional methods of ATO impacting the SNAP program include card
tumbling, third party apps that claim to provide additional coupons or
assistance, common PIN numbers, cloned point-of-sale (POS) devices, and
bot attacks. Bot Attacks are on the rise as the unemployment insurance
industry discovered during the PHE. International fraud rings, criminal
groups and state sponsored terror groups were responsible for massive
bot attacks, whether it is only several hundred a day, or millions as
some states discovered.
Without safeguards, automated bot scripts slamming states and
county application sites are creating massive backlogs in requests for
information, referrals to call centers, and delays in receiving
benefits. And worse, the bot attacks are combining the tactics above
and create a fail-proof way of ATOs. Every state with an online
customer service portal or application must have bot-detection tools.
To our knowledge, none do--all must rely upon EBT vendors for
assistance.
Instead of relying upon a hungry, marginalized SNAP recipient being
responsible to change their PINS monthly, freezing their PIN, or opting
to prohibit out of state transactions,\37\ Congress must demand FNS
enact measures to stop ATO. A common-sense start would be for states to
turn off Out of State (OOS) transactions and allow recipients to change
it if circumstances require it. Two free refills only encourage
otherwise legitimate households to traffic (or empty) their accounts
and then falsely claim they were victimized.
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\37\ https://fns-prod.azureedge.us/sites/default/files/resource-
files/ebt-card-skimming-prevention.pdf.
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This crime of opportunity is made even more attractive to
fraudsters when you consider SNAP High Balances. UCOWF is aware of EBT
balances exceeding $15,000 in every state.
Retailer Fraud
Retailer integrity is a known issue, and UCOWF is not here to
criticize FNS for its handling of the retailer process, nor on the USDA
Office of Inspector General's gross understaffing issues. However,
modernization of SNAP requires an overhaul of the retailer integrity
processes currently in place. This isn't new--a 2019 GAO report found
as much as $4.7 billion in retailer trafficking fraud (back when SNAP
expenditures were $64 billion per year).\38\
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\38\ https://www.gao.gov/products/gao-19-167.
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FNS lacks the authority to do any effective business integrity/
oversight of SNAP retailers. The most recent retailer trafficking data
showed 18-20% of all small businesses trafficked SNAP. Some of these
businesses are represented by lobbying firms pushing for hot food
allowances. Effective oversight of the 250,000 SNAP approved retailers
is sorely needed, particularly as they expand approved businesses to
sell benefits online.
While we addressed the lack of SSN mandates in recipients, the
problem is far worse with retailers. In a January 2017 USDA OIG report,
3,394 stores were found to have deceased owners and 193 retailers
approved using PII for minors (under 18 years old). FNS addressed this
barrier, stating, ``FNS recognizes the value in conducting a DMF match
on an on-going basis. As such, should FNS be granted future authority
to use SSN for matching purposes, FNS will match to the SSA DMF using
SSN on an on-going basis.'' \39\ To date, FNS does not verify retailer
submitted SSNs nor match against the SSA DMF due to this statutory
restriction. Fixing this would require modification to the Social
Security Act.\40\
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\39\ https://usdaoig.oversight.gov/sites/default/files/reports/
2023-06/27901-0002-13.pdf.
\40\ Section 205(c)(2)(C)(iii)(I) of the Social Security Act
(codified at 42 U.S.C. 405(c)(2)(C)(iii)(I) and implemented at 7 CFR
278.1(q)(3)).
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States are given no input on retailers operating in their own
state. FNS does not check to see if a business is even licensed (and
paying taxes), if they have been debarred from other programs (such as
state lottery), or if the business owner has criminal background and/or
active arrest warrants at the local/state level. One of my UCOWF
colleagues refers to FNS retailer oversight as ``dumping their trash on
our lawns and then complaining about the smell.'' But he's correct in
that the failure to provide effective and efficient Federal oversight
on retailers shifts the burden on states to chase after every person
who committed fraud and abuse against SNAP rules.
Either allow states input on who can operate as a SNAP retailer in
their jurisdiction or give FNS the authority to do what is required.
Conversely, if modifications of the Social Security Act prove too
cumbersome to give FNS the needed authority, at least require advance
notice and time for the states to conduct appropriate reviews. This is
not a new issue--a July 2013 USDA OIG report repeated an earlier
recommendation to perform background checks, and FNS agreed to initiate
rulemaking to require applicants to provide a ``self-initiated''
background check. This never occurred--however, if it did, it would
only be another self-attested verification by the retailer applicant.
Today, retailers can submit forged/Photoshopped information to meet
requirements, yet FNS lacks authority to conduct any meaningful
oversight.\41\
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\41\ https://crsreports.congress.gov/product/pdf/R/R45147/6, page
54.
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Better retailer controls would reduce recipient fraud. Failure to
address retailer integrity has a massive impact on states. An
independent survey of 76 state and county SNAP agencies found that it
costs up to $4.40 for every dollar of SNAP fraud.\42\ It's time FNS
cleaned up this mess.
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\42\ https://risk.lexisnexis.com/insights-resources/research/true-
cost-of-fraud-study-for-snap.
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Conflicting Regulation Language
There are specific regulations that continue to frustrate
investigators' efforts and have required FNS to issue clarification
memos. Unfortunately, the clarification memos create confusion between
states and FNS Regional Offices, and UCOWF has been asked by members to
address several of these here.
Regulations state, ``Except as provided under paragraph (B)(1)(iii)
of this section, an individual found to have made a fraudulent
statement or representation with respect to the identity or place of
residence of the individual in order to receive multiple SNAP benefits
simultaneously shall be ineligible to participate in the Program for a
period of 10 years.'' \43\
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\43\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-F/section-273.16#p-273.16(b)(5).
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FNS guidance in Attachment 13 to Policy Letter 13-02 states, ``The
real issue is whether or not the client fraudulently represented their
situation or if they made an innocent mistake. If it is a mistake with
no intent to commit fraud and they thought their case file in the first
state was closed, then there is no penalty. If they fraudulently
represented their circumstances by claiming two addresses in order to
get benefits in two places, then it is duplicate participation, and the
penalty is 10 years. It does not matter that the names and addresses
are not correct when the intent is to collect two benefit payments
(duplicate participation). The 1 year penalty is not a factor in this
situation.''
The clarification is not uniformly used; and in fact, as part of an
integrity audit, one regional office demanded a state reduce the 10
year penalty issued in the Administrative Disqualification Hearing
decision to a 1 year penalty.
Regulations define claims against households and state; ``A
recipient claim is an amount owed because benefits that are overpaid,''
and, ``This claim is a Federal debt subject to this and other
regulations governing Federal debts . . . The state agency must
establish and collect any claim by following these regulations.'' \44\
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\44\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273/subpart-F/section-273.18#p-273.18(a).
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In conflict with these two regulations, FNS issued Attachment 4 to
Policy Letter 89-03 that dictates, ``Categorical eligibility is based
on a household receiving or being authorized to receive AFDC or
Supplemental Security Income payments. The household's eligibility for
these payments is not relevant for food stamp purposes. Therefore,
since the household was correctly determined to be categorically
eligible based on receipt of AFDC, there is no over issuance for food
stamp purposes and no claim is established.''
The FNS policy guidance directly conflicts with regulations and has
contributed to confusion and weakened program integrity.
In Summary
Investigators detect, prevent, and prosecute fraud so taxpayers do
not lose faith in this critical program. It is an ugly truth, that if
there is a source of money or benefits, people will try to steal it. It
is the dedication of every welfare fraud investigator, working on
behalf of the taxpayers, that provides the backbone of SNAP and
continually upholds program integrity.
The United Council on Welfare Fraud can only do so much. SNAP
integrity is under-funded, understaffed, and widely ignored. We
adamantly disagree with USDA FNS' unbending 15 year assertion that the
fraud rate in SNAP is less than 1%. The above information references
the wide-ranging attacks that continue to hit SNAP at all flanks; and
yet, with all the different fraud schemes that continue to erode SNAP,
USDA FNS perpetuates the message that SNAP is the only Federal program
with a negligible fraud rate.
States need funding for additional personnel to adequately staff
fraud units at all levels. States need funding to access and leverage
technology to confront the sophisticated fraudsters who victimize
recipients. We need common sense regulations that prevent fraud and
work towards its elimination instead of continually frustrating
investigations with antiquated rules and incongruent application.
Deficiencies in program integrity have been a long-standing issue not
addressed in past farm bills and largely ignored by the USDA. We cannot
afford to continue to kick the can 4 more years down the road. On
behalf of the front-line workers across the nation and on behalf of the
United Council on Welfare Fraud, I implore you to fix these issues now.
We appreciate the opportunity to address these issues and the
invitation to appear before Congress today.
Thank you.
Additional Antiquated Regulations Requiring Farm Bill Modernization
UCOWF members from across the nation have shared concerns about
outdated regulations. We are sharing these issues and suggested
remedies:
Recipients are permitted to refuse to cooperate with an
administrative fraud investigation. Yet, failure to cooperate
with a Quality Control review will result in recipients being
removed from the SNAP program. Subjects refusing to participate
in administrative fraud investigations or respond to questions
should be removed from the program. https://www.ecfr.gov/
current/title-7/subtitle-B/chapter-II/subchapter-C/part-275/
subpart-C/#p-275.12(g)(1)(ii). The same issue extends to
administrative hearings. https://www.ecfr.gov/current/title-7/
subtitle-B/chapter-II/subchapter-C/part-273/subpart-F/section-
273.16#p-273.16(e)(2)(iii)
Recipients are given Miranda Rights, even in non-custodial
administrative investigations. Miranda, as the Supreme Court
has ruled, is for criminal interviews and interrogations of
persons in law enforcement custody or control. https://
www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-
C/part-273/subpart-F/section-273.16#p-273.16(f)(1)(ii)(B)
Third Party Processors are enabling fraudulent activity.
Collusion between dishonest retailers and TPPs have been
documented by the USDA OIG. Due to past farm bills, FNS no
longer bears any responsibility for oversight of the TPPs and
Point of Sale (POS) devices. That responsibility is given to
the retailer. As such, TPP POS devices do not transmit
geolocation data. FNS cannot reliably determine the physical
location of devices involved in SNAP transactions and balance
inquiries--they are anywhere in the world. Congress is
encouraged to address this as states can no longer say benefits
are being used in the location FNS has approved, including
globally.
``SNAP-authorized retailers need to conduct their own research
and due diligence when selecting a TPP and should review
the cost of leasing or purchasing equipment and services to
make the best choice for their business.'' https://fns-
prod.azureedge.us/sites/default/files/resource-files/SNAP-
EBT-TPP-Information.pdf
Fraudulent Retailers are not added to the Federal System for
Award Management website by FNS for debarment despite
Presidential Executive Order 12549 and 7 U.S. Code 2209(j). See
2 CFR 180, 2 CFR 417, and https://www.fns.usda.gov/snap/
retailer-sanctions-debarment-disqualified-firms.
Retailers removed from the program are not added to the
electronic disqualified recipient system (eDRS). Business
owners should be disqualified from being a recipient for a
period for violating SNAP rules, same as a recipient.
There are no regulations prohibiting a retail owner from
receiving personal SNAP benefits and spending them in their own
stores.
Retailers should be immediately suspended when
administrative or criminal activity is alleged, like the
Medicaid program. Fraud is not an entitlement for businesses.
Disaster SNAP guidelines have not been updated in nearly a
decade (2014), are woefully outdated in policy and practice,
and should be codified in Federal regulations.
Self-attestation is the general rule when it comes to
verifying eligibility criteria and should be reviewed for
consistency and relevance in a modernized SNAP program.
FNS currently prohibits states to automatically deny an
applicant when they self-declare information that makes them
ineligible. For example, if an applicant declares their monthly
income is higher than the limit, states must contact the
applicant to verify/ double-check that the information provided
by the applicant is in fact true before denying the
application. This is an unnecessary workload for state
eligibility staff and is expensive to notice applicants who
have already self-declared themselves ineligible.
FNS must mandate that states protect online application and
public portals are safeguarded from bot-attacks.
FNS has information on all individuals who have been
disqualified from the food assistance program in the Electronic
Disqualified Recipient System (eDRS), and they share this data
with all states; however, FNS does not allow states to act on
the information. States are required to double check with the
state where the disqualification originated and verify the data
to determine that all processes were completed correctly in the
originating state. As states are required to upload accurate
disqualification data, this is an unnecessary administrative
burden for eligibility staff who spend time researching and
attempting to communicate with other state staff to reverify
the data--yet FNS accepts this data without question. FNS
places a huge burden on states to scrub this data, but they
accept it at face value from states. eDRS data should be
considered Verified Upon Receipt, and any clients who feel it
is not accurate still have Due Process procedures in Fair
Hearing requests.
FNS does not allow states to close a SNAP case or
application when they receive undeliverable returned mail
unless the state chooses to act on all changes reported to the
state. It's an all or nothing policy. Once approved, clients no
longer must report most household circumstances unless it
adversely affected their benefit eligibility--they were
approved and frozen for a 6 month certification at a set
benefit amount. Not having to report an address change, even to
another state, is included in that policy but should be
addressed as a stand-alone regulation. Failure to report an
address change does not adversely affect a benefit amount;
recipients should be required to report their residency since
states are seriously challenged in their ability to remain in
contact with its recipients/clients. The policy also leads to
fraud and over-payments when recipients receive benefits in
more than one state at a time. Additionally, FNS does not allow
the state to use Post Office information to determine (in)valid
addresses. FNS requires the state to send correspondence to
applicants/recipients to known bad addresses that ultimately
get returned--a waste of postage and state administrative
resources.
Eligibility staff receive numerous data exchanges on a
daily, weekly, and monthly frequency. Many data exchanges are
not verified upon receipt and many times contain outdated
information, i.e., Prisoner Information exchanges. The 2014
Farm Bill requires states to check the National Directory of
New Hires (NDNH) before approval which also has a cost; states
must pay $30,000 per year or more for this marginally
beneficial data. The information received from the NDNH is
often no longer relevant to the recipient's current
circumstances and/or is discovered in the interview. The
requirement for staff to process these data exchange does not
have a beneficial impact on the recipient/applicant's case, has
a direct cost to the state by invoice, and costs the state's
precious staff time to research without any realization of
return.
United Council on Welfare Fraud Comments on NAC Interim Final Rule
December 2, 2022
Chief Maribelle Balbes,
State Administration Branch,
Program Accountability and Administration Division,
Food & Nutrition Service, USDA,
Alexandria, VA
Dear Chief Maribelle Balbes:
The United Council on Welfare Fraud (UCOWF) appreciates the
opportunity to comment on the USDA Food and Nutrition Service
(Department) second's posted Interim Final Rule (IFR) on the National
Accuracy Clearinghouse (NAC) (Federal Register Vol. 87, No. 190, dated
October 3, 2022).
UCOWF is a national professional organization of investigators,
administrators and claims and recovery specialists who are on the
frontlines combating welfare fraud in our public assistance programs.
Our members come from across the country at the local, county and state
agency level who work every day to protect the integrity of these
critical programs and safeguard taxpayer resources. In addition to
reinforcing public confidence and ensuring benefits are not diverted
from our society's neediest citizens, we strive to bring a cohesive
voice to these efforts and share best practices in the prevention,
detection and prosecution of welfare fraud.
It is with a clear goal of enhanced program integrity that UCOWF
shares the following comments and concerns on the 28-page IFR.
1. The intent of the Agriculture Act of 2018 (``farm bill'')
creation of the NAC has been ignored. The delays in
implementing the NAC, as directed by the farm bill, result
in significant waste by the Department.
2. The proposed IFR limits administrative flexibility granted to
state agencies, fails to consider best practices currently
in place, and conflicts with existing laws and regulations.
First, the intent of the 2018 Farm Bill duplicate participation
mandate to the Department to implement the original NAC pilot program
has been ignored and position the elimination of duplicate
participation as a new initiative. Instead, the Department created
justifications that codify legal interpretations of existing
regulations into this IFR.
The ``new'' NAC currently under production amounts to ``recreating
the wheel'' and delays the mandate of full nationwide implementation by
6 years (from 2021 to 2027). These delays by the Department will result
in unacceptable waste, considering:
The savings in the original NAC Pilot report to Congress
range from $53.8m to $193.4m, averaging $114m.\1\
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\1\ https://www.fns.usda.gov/snap/nac-evaluation-final-report
National Accuracy Clearinghouse Evaluation, Final Report (Oct. 2015).
See also the Congressional Budget Office 10 year cost estimate savings
(outlays) of $588 million referenced by the Center on Budget and Policy
Priorities, https://www.cbpp.org/sites/default/files/atoms/files/6-11-
18fa.pdf. Adjusted for inflation using the savings based on 2014 data,
$1 in 2014 costs $1.26 in 2022. Numbers are then $67.8, $243.7m, and
$143.6m, respectfully. https://www.usinflationcalculator.com/.
Adjusted for inflation and increases to SNAP allotments
through the Thrifty Food Plan, anticipated annual savings are
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currently up to $309.5 million per year.
It can therefore be concluded that the decision to delay the roll-
out of the farm bill mandate for this new and unproven NAC totals
approximately $1.85 billion. Adjusting for compounding inflation at
current rates brings the total outlay waste from this decision and IFR
to an approximately forecasted $2.5 billion by FY 2028.
The 2018 Farm Bill did not intend for the Department to introduce
waste or to ``start over.'' \2\
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\2\ https://www.congress.gov/congressional-report/117th-congress/
senate-report/34/1 S. Rept. 117-3421 November 2022, p. 106, states:
``The Committee continues to support the implementation of the
National Accuracy Clearing-
house (NAC). The Committee directs the Department to move forward
with the NAC to prevent
duplicative issuance of SNAP benefits and improve program integrity.
When the USDA imple-
ments and expands the NAC, the Committee urges the Department to
allow states to use a
blended workforce including contractors and subcontractors that have
the capability to use
complex match technology with multiple data elements and administer a
robust appeals proc-
ess to ensure individuals are not automatically removed from
receiving benefits.''
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Section 4011 of the 2018 Farm Bill require the IFR ``incorporate
best practices and lessons learned from the pilot program.'' The IFR
fails at this requirement. The IFR references to the original NAC pilot
do not take into considerations improvements in technology made to
security, workflows, or matching that have been implemented since the
2015 report to Congress.\3\ Further, recommendations from the original
pilot were ignored and neither the lead state (Mississippi) nor
technological experts involved in the original NAC pilot were utilized
or consulted as recommended to Congress.\4\
\3\ National Accuracy Clearinghouse Evaluation, Final Report (Oct.
2015).
\4\ Ibid., page 6.
``The five NAC pilot states have implemented the tool in
significantly differently ways and have realized different
levels of success. Those that have achieved superior outcomes
provide a set of best practices that should be considered as
use of the NAC continues in the current states and as expansion
beyond the pilot is explored. Furthermore, the pilot states
have learned lessons that should be heeded by any state--
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current or future--intending to use the NAC.''
The IFR conflicts with current regulations and codifies legal
interpretation more appropriate in Department guidance memorandums.
The language and justifications for rule modifications and
creation in this IFR apply to Simplified Reporting (SR) and
assume all states will choose SR as a state administrative
option.
The original waiver used by the original NAC pilot was only
necessary due to FNS legal interpretation that the state-to-
state dual participation checks are not Verified Upon
Receipt.\5\ The proposed IFR and workflows attempt to consider
a duplicate application ``unclear information.'' Instead, this
IFR would best be constructed to address deficiencies in the SR
flexibilities.
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\5\ The IFR states, ``The existing regulations prevent states from
contact with the acting on NAC data matches before their next scheduled
household, so states participating in the NAC pilot operate under an
administrative waiver ( 272.3(c); 17(b)(1) of the Food and Nutrition
Act of 2008).''
Current regulations 272.4(e) already address state
monitoring of duplicate participation, which data can be used,
and that monitoring can be done at times determined by the
state agency. Proposed modifications to Rule that further
reduce state flexibility and best practices are improper. This
IFR also ignores questions on nearly all state agency SNAP
applications that specifically asks the applicant if they are
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currently receiving SNAP benefits.
Identity information is provided by the household. Legal
interpretation that considers state to state duplicate
participation checks as verified information (verified upon
receipt) should be considered, making the majority of this IFR
unnecessary.
The IFR concerns with technical security in sharing or
sending applicant provided SSN information can be resolved
without the creation of this IFR and conflict with other FNS
practices (such as sending and storing PII in eDRS, information
transmitted to EBT vendors, matches with Treasury Offset
Program, the CMS Federally Facilitated Marketplace (Medicaid
Hub), SSA Prisoner and Death Master File exchanges, as well as
other public assistance program best practices (ex.
Unemployment Insurance Integrity Data Hub).
This IFR contains references to a current regulation that
does not exist; see 273.12(c)(9).
Finally, the administrative burden to state agencies do not address
the ``Big Bang'' or address state agencies currently implementing
duplicate participation checks under the NAC pilot.
For the above referenced concerns, the UCOWF feels these proposed
regulations should be withdrawn and the Department reconsider their
decision on rolling out what can only be viewed as another (unproven)
pilot.
Sincerely,
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Andrew Petitt, President,
United Council on Welfare Fraud.
The Chairman. Ms. Royal, thank you so much. And now we will
proceed, and--Dr. Rachidi, please begin when you are ready.
STATEMENT OF ANGELA K. RACHIDI, Ph.D., RESEARCH
FELLOW IN POVERTY STUDIES, AMERICAN ENTERPRISE
INSTITUTE, WASHINGTON, D.C.
Dr. Rachidi. Thank you. Chairman Thompson, Ranking Member
Scott, and Members of the Committee, thank you for the
opportunity to testify today on this important issue. My name
is Angela Rachidi, and I am a Senior Fellow on Poverty and
Opportunity at the American Enterprise Institute. I am also a
former Deputy Commissioner for the New York City Department of
Social Services, where, for over a decade, I oversaw the
agency's policy research and evaluation, including of SNAP. As
this Committee considers a farm bill for 2023, I wanted to
highlight two key issues as it relates to SNAP, employment and
health.
In the course of my research, three key themes have
emerged. First, consistent and sustained employment is one of
the most crucial ingredients for reducing poverty and
increasing upward mobility. Second, poor health is one of the
largest barriers to employment for low-income Americans. And
third, SNAP's lack of dietary guidelines often leaves its
recipients in poor health, limiting their ability to work and
escape poverty.
Let me begin by first acknowledging the ways in which the
recently enacted Fiscal Responsibility Act of 2023 (Pub. L.
118-5) has improved the employment prospects of SNAP
recipients. The Act strengthened SNAP's work requirements by
extending them to more working-age adults. It also added, as a
new stated purpose to the program, to help SNAP recipients find
employment. But Congress can do more.
SNAP should be helping people find employment, not
discouraging it. Employment offers financial and non-financial
benefits to individuals and the broader economy. As last
month's jobs report showed, the U.S. continues to see strong
job growth and low unemployment rates, but businesses continue
to struggle to find workers. Safety net programs such as SNAP
should support the broader economy by encouraging, not
discouraging, work.
Yet, SNAP participants have very low employment rates. In a
recent report my AEI colleague, Thomas O'Rourke, and I found
that the employment to population ratio among non-disabled SNAP
participants without children, what we typically think of as
ABAWDs, has hovered between 15 and 30 percent since at least
1996. Our research also found that the composition of SNAP has
shifted toward the childless. For example, in 1996, the share
of prime age SNAP household heads with children outnumbered
those without children three to one, but today the ratio is 1.8
to 1. During this same time, SNAP expenditures have increased
five-fold in real dollars.
A longitudinal look at employment rates among ABAWDs paints
an equally concerning picture. Based on my research, using
longitudinal data from the State of Wisconsin, I found that
quarterly employment rates among ABAWDs were consistently below
40 percent, even though \2/3\ of them had employment at some
point in the year. This raises concerns about the ability of
SNAP to support consistent and stable employment. Congress can
help fix this problem by further strengthening SNAP's work
requirements, including tightening the rules for waivers of
ABAWD work rules and evaluating work requirements in other
populations.
The second point I want to make relates to nutrition and
health. SNAP participants display very concerning health
outcomes. In a recent analysis of national health data, I found
that, in 2018, 65 percent of older SNAP adults had ever been
diagnosed with diet-related disease, and 42 percent were obese,
rates much higher than other groups of Americans not receiving
SNAP. SNAP contributes to these problems because it contains no
nutritional standards, and the data show that SNAP participants
spend a large amount of their benefits on non-nutritious foods,
such as sugary beverages and prepared desserts, which obviously
contribute to poor health.
There is bipartisan support to strengthen the nutrition
aspects of SNAP. Congress can do this in the farm bill. They
should make improving diet quality a core SNAP objective,
require the USDA to measure diet quality among SNAP households,
and track and publish the foods purchased with SNAP benefits.
Congress should also establish nutrition standards in SNAP,
similar to those in other Federal nutrition assistance
programs. Congress should also impose common sense restrictions
on SNAP purchases, disallowing purchases of sugary beverages,
as the National Commission on Hunger recommended doing in 2015.
To close, part of SNAP's stated purpose reads: ``The
intention to raise levels of nutrition among low-income
households.'' The new added purpose is to assist low-income
adults in obtaining employment and increasing their earnings.
My testimony today clearly shows that SNAP is falling short in
meeting its purpose as it relates to nutrition and employment.
However, Congress has an opportunity to fix its shortcomings
through the farm bill. Thank you, and I look forward to
answering your questions.
[The prepared statement of Dr. Rachidi follows:]
Prepared Statement of Angela K. Rachidi, Ph.D., Research Fellow in
Poverty Studies, American Enterprise Institute, Washington, D.C.
The Supplemental Nutrition Assistance Program: Toward Better Employment
and Health Outcomes
Chairman Thompson, Ranking Member Scott, and Members of the
Agriculture Committee. Thank you for the opportunity to testify on this
important issue. My name is Angela Rachidi and I am a Senior Fellow on
poverty and opportunity at the American Enterprise Institute, where I
have spent the past several years researching policies aimed at
reducing poverty and increasing employment for low-income families.
Before I joined AEI, I was a Deputy Commissioner for the New York City
Department of Social Services, where for more than a decade I oversaw
the agency's policy research, including evaluating the Supplemental
Nutrition Assistance Program, or SNAP.
As this Committee considers a farm bill for 2023, I wanted to
highlight two key issues as it relates to SNAP: employment and health.
I have spent much of my career researching the Federal Government's
safety net programs and identifying policies aimed at helping low-
income families achieve the type of opportunity and social mobility
that every American deserves. In the course of my research, three key
themes have emerged. First, consistent and sustained employment is one
of the most crucial ingredients for reducing poverty and increasing
upward mobility, along with family structure. Second, poor health is
one of the largest barriers to employment for low-income Americans.
Third, SNAP's lack of dietary guidelines often leaves its recipients in
poor health, preventing them from working and escaping poverty.
Let me begin by acknowledging the ways in which the recently
enacted Fiscal Responsibility Act of 2023 has improved the employment
prospects of SNAP recipients. The Act strengthened SNAP's work
requirements by extending the work expectation to more working-age
adults. It also added as a new stated purpose the program: ``To assist
low-income adults in obtaining employment and increasing their
earnings.'' If SNAP is to accomplish its core goal of supporting
Americans in their path out of poverty, emphasizing the importance of
employment is an integral first step.
Employment must be a clear goal of SNAP for two reasons. First,
employment provides the only realistic path for low-income households
to escape poverty and move up the income ladder. As we learned from
welfare reform in 1996, when government assistance programs add an
employment expectation, benefit recipients respond by going to work and
improving their well-being. Second, low levels of labor force
participation and high numbers of job openings suggest that there are
ample jobs for all Americans. The latest jobs report showed strong job
growth and the national unemployment rate remains below four percent.
However, it also showed a labor force participation rate far below
levels from a decade ago as older Americans have exited the labor force
and prime-age workers have failed to pick up the slack.\1\ The
implication is that the U.S. labor market needs more workers; and
safety net programs such as SNAP must encourage, not discourage, labor
force participation.
---------------------------------------------------------------------------
\1\ Jeffrey Sparshott, ``Behind Rise in Unemployment, Job Market Is
Really Strong,'' Wall Street Journal, June 2, 2023, https://
www.wsj.com/articles/mixed-signals-in-u-s-jobs-report-a57b18f
d?mod=economy_more_pos1.
---------------------------------------------------------------------------
Despite the benefits of employment to individuals and the broader
economy, work-capable SNAP participants have very low employment rates,
partly because SNAP disincentivizes work, as research has shown.\2\ In
a recent report, Thomas O'Rourke and I analyzed SNAP Quality Control
data to document the employment rate among different groups of adult
SNAP participants. We found that the employment-to-population ratio
among non-disabled SNAP participants without dependents--often called
ABAWDs--has hovered between 15 and 30 percent over time.
---------------------------------------------------------------------------
\2\ Hilary Williamson Hoynes and Diane Whitmore Schazenbach, ``Work
Incentives and the Food Stamp Program,'' (working paper, National
Bureau of Economic Research, Cambridge, MA, July 2010), https://
www.nber.org/papers/w16198.
---------------------------------------------------------------------------
In the very strong labor market of 2019 (the most recent year of
data), 30 percent of non-disabled SNAP participants without dependents
between age 18-49--the ABAWD population--worked while receiving SNAP;
among non-disabled, childless 50-64 year olds receiving SNAP, only 24
percent worked.\3\ A 2018 report by the Council of Economic Advisors
analyzed household survey data and found that a slightly higher share
of SNAP participants worked while receiving SNAP, but even their
analysis suggested that 50 percent or fewer worked. The discrepancies
between administrative data and survey data can either be due to
misreporting on surveys or a failure on the part of participants to
disclose earnings to SNAP agencies.\4\ Either way, employment levels
remain very low among non-disabled SNAP participants without children.
---------------------------------------------------------------------------
\3\ Angela Rachidi and Thomas O'Rourke, ``Promoting Mobility
Through SNAP: Toward Better Health and Employment Outcomes,'' American
Enterprise Institute, May 1, 2023, https://www.aei.org/research-
products/report/promoting-mobility-through-snap-toward-better-health-
and-employment-outcomes/.
\4\ The Council of Economic Advisors, ``Expanding Work Requirements
in Non-cash welfare Programs,'' July 2018, https://
trumpwhitehouse.archives.gov/wp-content/uploads/2018/07/Expanding-Work-
Requirements-in-Non-Cash-Welfare-Programs.pdf.
---------------------------------------------------------------------------
Figure 1. Percentage of Non-disabled SNAP Recipients Employed by Group,
1996-2019
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: ``Promoting Mobility Through SNAP: Toward Better
Health and Employment Outcomes,'' American Enterprise
Institute, May 1, 2023.
We might be less concerned about very low employment rates among
prime-age, work-capable SNAP recipients if their share of SNAP
expenditures were shrinking over time. But our research also found that
the share of SNAP adults who are capable of work--meaning childless,
non-disabled recipients--has grown over time. For example, in 1996, the
share of SNAP household heads age 18-49 with children outnumbered those
without children three to one, but by 2019, the ratio was 1.8 adults
with children to every one household head without children. During this
same time, SNAP expenditures have increased five-fold in real dollars
due to higher participation and larger per-person benefits.\5\
---------------------------------------------------------------------------
\5\ United States Department of Agriculture, Food and Nutrition
Service, SNAP Monthly and Annual Participation and Costs historical
data, https://www.fns.usda.gov/pd/supplemental-nutrition-assistance-
program-snap.
---------------------------------------------------------------------------
Figure 2. SNAP Composition by Age, Disability, and Parental Status
Among Household Heads, 1996-2019
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: ``Promoting Mobility Through SNAP: Toward Better
Health and Employment Outcomes,'' American Enterprise
Institute, May 1, 2023.
Granted, limited employment is part of the reason participants
receive SNAP in the first place, but a longitudinal look at employment
rates among non-disabled SNAP participants paints an equally concerning
picture. While it is true that most non-disabled SNAP participants move
in and out of employment, at any given point in time, their employment
rates are very low relative to the general population. In years when
unemployment rates are at historical lows (such as now) and employers
cannot find enough workers, such low employment rates are difficult to
explain.
Based on my own research using longitudinal SNAP administrative
data from Wisconsin, I found that quarterly employment rates among
ABAWDs were low across time. I explored a cohort of ABAWDs receiving
SNAP during a 6 month period in 2014 and 2015, and found that the
quarterly employment rate was consistently below 40 percent and
declined over the course of the next year (Figure 3). Although 70
percent of this cohort had employment in at least one quarter in 2015,
their employment was inconsistent and not sustained, raising concerns
about their ability to escape poverty and achieve upward mobility over
the long-term. To the extent that SNAP contributed to these low average
work rates, policymakers should enact reforms that strengthen
recipients' attachment to the labor force.
Figure 3. ABAWD Employment Rate in Wisconsin, 2014-2015
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: Authors calculations using Wisconsin administrative
data on ABAWD SNAP receipt and employment using wage reporting
data.
SNAP could be doing more to help these participants seek and find
stable employment. Establishing employment as a program purpose in the
recent debt limit bill is a positive development. But work requirements
can also play a role, as long as states implement them properly. This
approach has proven to work in other contexts, such as TANF, and
Federal policy should ensure that states encourage SNAP participants to
work insofar as they are able, rather than providing unconditional
transfer payments. For these reasons, Congress should further
strengthen existing work requirements by tightening the criteria by
which states can waive work requirements, and by conducting evaluations
to test the effectiveness of work requirements on new populations.
The second point I want to make relates to nutrition and health.
Through my research, I have documented extremely concerning health
outcomes among SNAP participants, which regrettably are worse for SNAP
participants than income-eligible non-participants and higher income
adults. For example, I found that in 2018 (the most recent year of
data), 65 percent of SNAP adults age 50-64 had ever been diagnosed with
diet-related disease, and 42 percent were obese. Compared to other
groups of Americans not receiving SNAP--both high- and low-income--SNAP
recipients exhibited much worse health outcomes.
Research shows that diet-related disease, such as diabetes and
heart disease, can have severely negative outcomes for individuals,
such as limited mobility, limited work productivity, mental health
problems, and reduced quality of life. A stated goal of SNAP is to help
low-income households afford a nutritious diet, to promote good health.
Yet, SNAP has no nutritional standards and the data show that SNAP
participants spend a large share of benefits on non-nutritious foods,
such as sugary beverages and prepared desserts.\6\ Our nation's largest
nutrition assistance program, which transfers over $100 billion per
year to low-income households, is well positioned to encourage
healthier eating among low-income populations, laying the foundation
for upward mobility.\7\
---------------------------------------------------------------------------
\6\ United States Department of Agriculture, Food and Nutrition
Service, ``Foods Typically Purchased by Supplemental Nutrition
Assistance Program (SNAP) Households,'' Nov 2016, https://
www.fns.usda.gov/snap/foods-typically-purchased-supplemental-nutrition-
assistance-program-snap-households.
\7\ Jerold Mande and Grace Flaherty. 2023. ``Supplemental Nutrition
Assistance Program as a health intervention,'' Current Opinion in
Pediatrics 35, no. 1 (February), 33-38.
---------------------------------------------------------------------------
There is bipartisan, bicameral support to improve SNAP's approach
to nutrition and diet quality, and there are incremental steps that
Congress can take as part of a farm bill. Congress should make
improving diet quality a core SNAP objective, while requiring the USDA
to measure diet quality among SNAP households as an accountability
metric. Congress should also require the USDA to regularly track and
publish the dietary quality of foods purchased with SNAP benefits.
Finally, Congress should establish nutrition standards in SNAP, similar
to those in other Federal nutrition programs such as the National
School Lunch Program and WIC.\8\ As a part of these standards, Congress
should impose common sense restrictions on SNAP purchases, disallowing
recipients from using benefits to purchase sugary beverages, as the
National Commission on Hunger recommended in 2015,\9\ as well as other
foods with limited nutritional value.
---------------------------------------------------------------------------
\8\ Angela Rachidi, ``A 21st-Century SNAP: Considerations for the
2023 Farm Bill,'' American Enterprise Institute, February 23, 2023,
https://www.aei.org/research-products/report/a-21st-century-snap-
considerations-for-the-2023-farm-bill/.
\9\ National Commission on Hunger, ``Freedom From Hunger: An
Achievable Goal for the United States of America,'' 2015, https://
cybercemetery.unt.edu/archive/hungercommission/20151217000051/http://
hungercommission.rti.org/.
---------------------------------------------------------------------------
Conclusion
In closing, I want to restate the purpose of SNAP as legislated in
the 2008 Farm Bill and the recent Fiscal Responsibility Act of 2023.
The first purpose states: ``It is declared to be the policy of
Congress, in order to promote the general welfare, to safeguard the
health and well-being of the nation's population by raising levels of
nutrition among low-income households.'' The Fiscal Responsibility Act
of 2023 added at the end of the paragraph: ``That program includes as a
purpose to assist low-income adults in obtaining employment and
increasing their earnings.''
The data I have presented today clearly shows that SNAP is falling
short in meeting the stated purpose of SNAP by Congress. However,
Congress has an opportunity through the farm bill to enact reforms.
Thank you and I look forward to answering your questions.
The Chairman. Dr. Rachidi, thank you so much for your
testimony, and thank you all for your important testimony
today. At this time Members will be recognized for questions in
order of seniority, alternating between Majority and Minority
Members, and in order of arrival for those who joined after the
hearing convened. You will be recognized for 5 minutes each in
order to allow us to get to as many questions as possible.
And before I recognize myself, I would ask unanimous
consent to submit for the record a June 6 Forbes article about
a job placement company that has been successfully connecting
recipients of public assistance to employment for nearly 4
decades entitled, Work Requirements? The Ongoing Lessons Of
`America Works'.\1\ Without objection, that will be considered
submitted for the record, and I will recognize myself for 5
minutes of questions.
---------------------------------------------------------------------------
\1\ Editor's note: the article referred to is located on p. 121.
---------------------------------------------------------------------------
As I mentioned in my opening statement, the four principles
that guide me as we look to address the nutrition title include
innovation and technology, employment and education, integrity
and accountability, and health and well-being. There are
multiple programs within the Title IV, including SNAP, TEFAP,
and the Commodity Supplemental Food Program, each of which can
benefit from some level of refinement. Mr. Hodel and Dr.
Stover, can each of you provide one or two examples of where
some fine tuning can change our overall trajectory across
spending impact and outcomes?
Mr. Hodel. Thank you. In terms of fine tuning, I like the
concept of innovation, and I like the idea of starting--
thinking big, starting small, and so that is what we have done
at Midwest Food Bank, is looking at areas and pockets that are
underserved, even through our agencies. And so, I think
providing support through food purchase options, and also
providing support just through the support of the food banks to
allow them to work with the agencies that are on the ground
that know the food recipients the best, partner with
corporations, and partner with the food banks.
The example I would use is what we are doing in the
Appalachians and eastern Kentucky. We are working with
corporations to purchase food, we are utilizing our volunteers
as the workforce to package that food, and then an agency that
is in location to distribute the food.
Dr. Stover. Mr. Chairman, if you look at the food system we
have today, it was engineered to address the endpoint of hunger
and food security. So, all of the policies that we have, all of
the programs that we have, all of the economic incentives we
have are focused on that goal of limiting hunger and food
insecurity. Now, because of the unintended consequence of
rising healthcare costs due to the diets that we consume, there
is a movement to shift to include health with hunger. To do
that, I am not sure that incremental changes will achieve that
goal. If we are going to change the goal to include health, we
need to re-think back across the entire agriculture value
chain, look at our incentives, look at our policies, look at
our programs, look at innovations to achieve that goal. I think
it may be time to rip the Band-Aid off.
The Chairman. Well, thanks to both of you. Ms. Royal and
Dr. Rachidi, your testimonies speak to issues plaguing SNAP
from skimming and burdensome regulations to labor force
participation, and where nutrition programs lack accountability
to the taxpayer. How do you break the logjam when talking about
nutrition programs, and how do we create lasting change that
results in more substantive outcomes?
Dr. Rachidi. Thank you for the question. I mean, I agree
with Dr. Stover that when the food stamp program was first
established, there was a problem of malnutrition and hunger to
the extent that we do not see anymore today, fortunately, and
that is a testament to SNAP. But what we have seen is this very
large shift in diet quality among Americans, and I believe that
SNAP has contributed to the declining diet quality.
So, if we think about SNAP as a program that has
effectively addressed food insecurity in this country, it
certainly has contributed to other problems, the main one being
poor diet quality and poor health among low-income Americans,
and the other being limited employment due to the disincentives
that are built into the program. So, I would somewhat agree
that we do kind of need to shift our thinking of what the
program's purpose is, and it needs to be both around addressing
food insecurity, but also ensuring that families have the
employment and have the health that they need to live thriving
lives.
The Chairman. Thank you. Ms. Royal?
Ms. Royal. While I also agree the program needs to be re-
examined, I think we also need to stop ignoring the fact that
fraud exists in the program. So, for the 15 years that I have
been aware of it, FNS continues to hold to the statistic that
fraud occurs in less than one percent of SNAP, and I just find
that statistic unreasonable. We do need to address integrity.
We do need to make sure that the program does stay strong so it
can be utilized by the families that need it.
If we take a--I think a more reasonable look at the fraud
rate, it is still a small percentage, and I agree with that.
The majority of applications that we receive contain honest
information and are submitted by people who need access to the
program. And by all means, we should make sure that they
receive it. But we also, again, cannot ignore the false
applications that come in with the false statements, with the
intentional acts to take benefits from the program that someone
is not eligible to receive.
The Chairman. Thank you, Ms. Royal. My time has expired. I
now recognize the Ranking Member for 5 minutes.
Mr. David Scott of Georgia. Ms. Brown, we have some
startling information and statistics that I want to express to
you and see if you can help us with. More than 80 percent of
SNAP households included a child, an elderly adult, or a person
with a disability; 42 percent of all SNAP participants were
children; ten percent--I am sorry, 16 percent--of SNAP
participants were elderly.
And then USDA also found that veterans had a 7.4 percent
greater risk of food insecurity than the general population.
And veterans are characterized as having a 7.4 percent higher
rate of living in food-insecure households. So those three
groups, our veterans, our children, and seniors--and, I might
add, our seniors, basically lower-income seniors, are now our
most threatened group.
Ms. Brown. Yes.
Mr. David Scott of Georgia. What are we doing to try to get
our hands underneath these three groups to help them become
food-secure? Sixty percent, for example, of our veterans who
are eligible for food assistance don't get it. What can we do
to improve this situation with our children, our seniors, and
our veterans?
Ms. Brown. Thank you, and I agree with the statistics that
you shared. I will start with the children. When we look,
indeed, children are the majority of the majority of the
population that are receiving SNAP and parents in poverty
Mr. David Scott of Georgia. Yes.
Ms. Brown. When they speak about the difficulties that they
have, speak to a number of concerns about the difficulties that
they face, and, as I spoke about earlier, often go without food
so that their children can go with food. And having SNAP
Outreach, for example, really focus in on these populations
makes a really big difference in--and creating understanding
about the availability of the program ensuring that folks
understand this is a program that is here for help when people
need it. People do not--again, people do not want to be on
SNAP, but it is here and available for people when they need
it.
When we think about our senior population, we know that
seniors, when they receive food benefits, can stay in their
homes longer. It is so beneficial for them to receive a stable
source of food. Their medication works much better. Students do
better in school. We know all of the benefits that food
requires in order for the health of our population to do so
much better.
Mr. David Scott of Georgia. And let me ask you this, if I
may. I mentioned in my opening remarks about the impact of
artificial intelligence, and our rapidly increasing technology,
and I am concerned that we are not addressing that in a proper
way, because many of these job opportunities are disappearing.
Artificial intelligence are doing many of these jobs, and they
are being pictured to do even more of the types of jobs that
lower-income people, people who really need SNAP--what more can
we do? I am trying to get an interest here in Congress to
explore this. And not only that, jobs now require being able to
handle technology, in terms of how they address their work. And
if we are not careful, we are going to become servants of the
machine that was created to serve us.
Ms. Brown. Yes. Absolutely. There are a number of ways we
can work with that. Our employment and training programs, for
instance, really need to address the capacity for our
populations in poverty to be able to go to school and learn
these skills and technologies for this new growing technology
force. Additionally, we need to address the student policies to
ensure that students can go to school to learn this new way of
working so that they then can receive a job and move their way
out of poverty. So those two areas, SNAP employment and
training, strengthening, and then also reform our student
policies, would both be beneficial.
Mr. David Scott of Georgia. Thank you for your courtesy,
Mr. Chairman.
The Chairman. Sure.
I thank the gentleman. Before I introduce--or recognize our
next Member, I do ask unanimous consent to submit for the
record a June 2 Wall Street Journal piece that shows how, by
ignoring work, we are not serving low-income communities well
entitled, Work Requirements and Lost Lessons of 1996.\2\
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\2\ Editor's note: the article referred to is located on p. 146.
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Mr. David Scott of Georgia. Yes.
The Chairman. So, without objection, I now recognize the
other gentleman from Georgia, Mr. Austin Scott, for 5 minutes.
Mr. Austin Scott of Georgia. Thank you, Mr. Chairman, and I
absolutely support the work requirements that we have sought to
add. I do want to make it clear, just so everybody understands,
the change is from 49 to 54. We are not talking about senior
citizens. We are talking about 49 to 54. I don't know anybody
who thinks that age 54 is a senior citizen. It is not only
important for them to go to work for their health, but I would
remind everybody that what you earn over the course of your
time, over the course of your lifetime, gets calculated into
your Social Security benefits. So, if you go from 49 to 54
without working, you are going to have reduced Social Security
benefits the rest of your life. Certainly, less than you would
have if you had worked.
But I want to focus on what Dr. Rachidi and Dr. Stover--
both of you mentioned health. And I will tell you, it bothers
me--as a parent, I walk in the grocery store, I see things that
I buy for my family that can't be bought with SNAP benefits,
and I think if we could have an honest discussion about the
food that we are eating and allowing to purchased, that maybe
we could accomplish a couple of things together, instead of
simply criticizing each other.
But if you look at the list of things that can be
purchased, fruits and vegetables, that is good. Expensive, but
good. Meat, poultry, and fish, that is good. Breads and
cereals, that is good. Other foods, such as snack foods. I am
not sure that is good. I am not saying people shouldn't be able
to buy a pack of crackers, but if we are honest, some of the
stuff that is being bought with SNAP benefits is leading to the
health challenges that you are talking about.
If you go to what households cannot buy, and I am reading
from the USDA website, foods that are hot at the point of sale.
So, my family literally purchases a rotisserie chicken probably
every week. Probably every week. It is good, it is simple, it
is nutritious, and yet people can't use SNAP benefits to
purchase a rotisserie chicken. I mean, can you explain to me
why we won't allow people to buy a rotisserie chicken with
their SNAP benefits, either of you? Why it makes any logical
sense?
Dr. Rachidi. Well, I will just say--I mean, the original
purpose of the food stamp program was for people to purchase
groceries for preparation at home. And so, if you think about--
at the time the food stamp program started, the idea of
rotisserie chicken----
Mr. Austin Scott of Georgia. I am talking about today.
Look, I am sorry, ma'am, respectfully, I have 5 minutes.
Dr. Rachidi. Okay.
Mr. Austin Scott of Georgia. It just defies logic that we
won't allow a rotisserie chicken to be----
Dr. Rachidi. The cost to prepare the rotisserie chickens
are baked into the cost of that product, which is not the
intention of SNAP, which is to purchase groceries for
preparation at home.
Mr. Austin Scott of Georgia. It doesn't cost much more than
an uncooked chicken.
Dr. Stover. I am not going to offer an opinion, but what I
will say is that we should----
Mr. Austin Scott of Georgia. Okay. All right.
Dr. Stover.--if we are going to have health as an outcome,
we need to look at all opportunities to achieve health, and
balance that individual liberty versus the outcome we are
interested in.
Mr. Austin Scott of Georgia. What baffles me with the whole
system--my school nutrition people--we micromanage everything
that our school nutrition people can serve our kids, as if that
is the problem with their health. Whether it be the type of
milk they can drink, or putting salt on asparagus or broccoli
that they serve them at lunch. We micromanage everything that
is done in the school cafeteria in the name of health, and yet
we do nothing with regard to what we allow people to buy SNAP
benefits with.
So, Dr. Stover, I am going to come to you real quick. You
said production agriculture is the key to human health. I think
that the titles of the farm bill are inherently tied together.
The more production ag we have, the cheaper our food supply is
in this country. But I would like for you just to walk the
Committee through, real quick, the types of innovations you
reference, and how they are tangible to human health.
Dr. Stover. Certainly. There are many opportunities. If you
look at the Green Revolution, and the technologies that were
brought to bear in breeding, and in processing, et cetera, to
create an abundant food supply to reduce hunger, they were
incredibly successful. We need to use the same sorts of
technologies. We have CRISPR, we have other innovations across
the food system where we can increase both the quantity and the
quality of the food that we produce that will promote health.
We just need the will to do it. We need to look at barriers
like regulation, like will, et cetera. But we have the tools
and technology to make the food system anything we want it to
be. We just have to decide what we want.
Mr. Austin Scott of Georgia. Mr. Chairman, my time has
expired. I do think, if we did this right, we would certainly
into account health with regard to hunger, and the amount of
money, and where we spend it. With that, I yield back.
The Chairman. I thank the gentleman. I am now pleased to
recognize the gentleman from Massachusetts, Mr. McGovern, for 5
minutes.
Mr. McGovern. Thank you.
Well, thank you, Mr. Chairman. I want to thank everybody
here for their testimony, which, by the way, I read, as well as
listened to you here today. Some of it has been helpful. Quite
frankly, some of it has not been so helpful. Ms. Royal and Dr.
Rachidi, I have some strong disagreements with some of the
things you have said. By the way, I would say to those who are
saying we should require SNAP recipients to have healthier
diets, maybe one of the things we can do is expand the benefit.
You try having a healthy diet on an average about $6 per person
per day. It is awfully hard. So, the benefit is inadequate, and
maybe we ought to be talking about expanding GusNIP as a way to
deal with that.
The Speaker of the House the other day said, and I quote,
he ``wants to get more cuts to SNAP.'' He wants to continue his
crusade to impose more work requirements, and more hurdles for
people to jump through. We have people on this Committee who
have bills that would actually increase the age of work
requirements and expand who would have to comply with them. And
the Republican cuts that were in the debt ceiling bill, in my
opinion, were nothing more than throwing literally hundreds of
thousands of people off the benefit.
And they didn't get all they wanted, because President
Biden stopped them from passing the worst version of their
bill--so now they want to use the farm bill as an excuse to
kick even more people off the benefit. So, the Freedom Caucus
has all kinds of red lines that they are drawing that we all
have to supposedly adhere to. Well, I have a red line too. You
cut SNAP, you make more people in this country hungry, then we
are against this farm bill. We will fight against this farm
bill, plain and simple.
And, Ms. Royal, I actually read your testimony, and your
presentation here was much toned down from the testimony that
you provided here today, and I would like to go through line by
line to rebut some of the points that you were trying to make,
but I don't have all day, I only have 5 minutes. But one of the
things that you say--in your written testimony--you imply that
the overall fraud rate--and you use Pennsylvania as an
example--it sounded like 40 percent. That is just not true. You
are cherry picking numbers to make it sound like fraud is
rampant when it only represents a fraction of cases.
Your testimony says that FNS only monitors EBT transactions
for fraud, not for large retailers. Again, wrong. FNS monitors
all retailers in a variety of ways, including undercover
investigations, and monitoring online transactions for
suspicious activity. So, I kind of went through that. I did my
research. I have a document here that refutes a lot of what you
have said, but we don't have but we don't have all day, so let
me just formally correct the record on one thing in your
written testimony.
Ms. Royal, your testimony also gives the impression that
people can apply and gets lots of benefits, including SNAP,
with just their name, address, and a signature. Ms. Brown, help
me correct the record on this. I mean, can you walk through
everything people have to submit, in addition to the interview,
verification, and intensive quality control checks at the back-
end?
Ms. Brown. Thank you, Representative. Indeed, the process
for application and review through our eligibility workers is
quite extensive, so I will begin to list some of the
verifications. So first a client must meet and talk to an
eligibility worker, and they share information that is then
verified. And that includes first, the identity of the
applicant, and that can be through a driver's license, that can
be through a birth certificate, and then it is a Social
Security Number. All applicants must provide a Social Security
Number. We have an automated interface in our system that
matches against the Social Security Administration to verify
that number. If that number is not verified, the case is
closed.
We also ask non-citizen applicants about--if they don't
have a Social Security Number, proof that they have applied for
one, so there is a process for that. Applicants must share
their proof of income, both earned and unearned, they must
submit pay stubs. They share their wage detail printout from
their employers. If they have been terminated, they share
documents that show their termination, the last day paid, any
documents that show any type of income requirement.
They also share immigration status. We match against the
Systematic Alien Verification for Entitlements Program to
ensure that immigration status is verified. We verify residents
of the state. We verify shelter, what are the shelter costs? We
verify, if they are a student, what are the costs of financial
aid information? If they are working, we verify the number of
hours that they are working, the number of counted months used
in other states. And then we go through some of the deductions
that they may have, whether that is medical expenses, shelter
expenses, child support payments. And then once application is
proved, then we go through the quality control process, which
is a detailed interview with the household.
Mr. McGovern. Boy, that sounds like more than a name,
address, and a signature. Thank you very much. I just want to
say, we are going to fight like hell against any cuts to this
program that will increase hunger in this country. This is the
wrong way for us to proceed. Thank you. I yield back.
The Chairman. The gentleman yields back. Before I recognize
our next speaker, Mr. DesJarlais, I am seeking unanimous
consent to submit for the record a 2022 LexisNexis Risk
Solutions True Cost of FraudTM Study.\3\ Without
objection, that is submitted, and I am now pleased to recognize
Mr. DesJarlais from Tennessee for 5 minutes.
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\3\ Editor's note: the report referred to is located on p. 186.
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Mr. DesJarlais. I thank the Chairman. And I find it
interesting, when we have SNAP hearings or nutrition hearings,
they always seem to devolve into a partisan exercise when all
of us on this Committee want to prevent food insecurity, and we
just have to find responsible ways to manage it, and that is
what a lot of this is about.
Ms. Royal, your testimony opines on the rates of fraud in
SNAP, an estimate which can range from eight percent to 40
percent. As you know, the Department is set to release their
error rate accommodation of overpayments and underpayments on
June 30. What error rate is the Council anticipating?
Ms. Royal. There is a significant distinguishing factor
between the error rate and a fraud rate. They are independent.
Again, I am a fraud investigator. But I will say that--I mean,
certainly we keep track of--I am aware of the error rate, and I
do keep track of that. And I also--I am very concerned that it
is going to exceed the numbers in 2019, which were in excess of
seven percent.
Mr. DesJarlais. Okay.
Ms. Royal. Again, fraud rate has to do with false
statements, the number of false statements that are encountered
in the program. The error rate has to do with the accuracy that
states issue benefits.
Mr. DesJarlais. Okay. You speak in your testimony about the
importance of integrity in our nation's public assistance
programs. One concern of mine has the number of non-citizens
who are receiving benefits. You may be aware that there are 13
categories outlining eligibility requirements for benefits with
no waiting period, and this includes qualified alien children
under 18 years of age, and asylees under Section 8 of the
Immigration and Nationality Act.
I firmly believe SNAP was intended to temporarily serve
American families, giving them the leg up they need to be self-
sufficient, and SNAP is already projected to cost more than
$1.2 trillion over the next 2 years. And with the crisis we
have seen at the southern border, with literally millions of
undocumented citizens coming in, I don't think the program can
continue to keep up, considering that there are literally
millions of children that qualify for SNAP based on these
standards, and also the fact that almost everyone coming across
the border is seeking asylum. Do you have any ideas about how
do we maintain the program integrity when it comes to non-
citizens?
Ms. Royal. Critical element that we need is identity
verification at the front-end, so when somebody submits an
application we have the ability, again, to verify that the
person is who they say that they are. Certainly, benefits can
be issued with a name, address, and signature. Verification is
required to continue benefits, but the name, address, signature
is the requirement on the initial benefit. Having technology
available at the beginning to leverage that verification
process, to leverage all of the facets of eligibility, would be
a game-changing opportunity for the fight for integrity.
Mr. DesJarlais. Ms. Royal, I am certain you are aware the
National Accuracy Clearinghouse, as written in the 2018 Farm
Bill, has yet to be implemented due to a variety of Executive
Branch antics. At this point we are looking at another 5 years
before the NAC is fully implemented, and I am not convinced it
will resemble anything like the policymakers' design. Do you
have any thoughts on this?
Ms. Royal. That was a devastating blow to SNAP integrity.
The National Accuracy Clearinghouse just provided an
opportunity for states to discover where there is an individual
receiving benefits in more than one state at one time. That
isn't always an intentional error. Somebody can cross state
lines and inadvertently forget to close their previous case,
submit an application. That does happen. And the NAC would have
been able to give us--would have given us the tool to identify
that. Unfortunately, it is also an opportunity for people to
steal from the program. People do submit applications across
state lines with the intentional act to receive dual benefits.
That also--the NAC would have been able to help us identify
those intentional acts as well.
The delay, again, was devastating to integrity. Having the
new NAC, if you will, developed, and able to roll out in the
next 5 years, at the end of 2027, can cost the taxpayers
billions of dollars.
Mr. DesJarlais. Okay. Well, thank you all for being here
today. My time is about to expire. Mr. Chairman, I yield back.
Mr. Austin Scott of Georgia [presiding.] The chair now
recognizes Ms. Adams of North Carolina for 5 minutes.
Ms. Adams. Thank you, Mr. Chairman, and thank you all for
your testimony. I just keep hearing all this fearmongering. It
is just wrong. Undocumented individuals are not eligible for
SNAP, and no American citizen is being denied SNAP because a
permanent resident received benefits. And no one in this
country should go hungry because they can't afford food,
period. I strongly believe that, and that is why I am still
furious that Speaker McCarthy and House Republicans held the
American economy hostage to make our lowest-income Americans
pay the price by taking food off their tables for their tax
breaks for the richest one percent. It is kind of like Robin
Hood in reverse. We are taking food from the poorest of the
poor, we are blaming them for the debt, and we are asking
nothing of the richest of the rich.
Now, poor folk are not responsible for our debt, and you
shouldn't be punished because you are poor. So, when I heard
that my colleagues, including the Speaker, are going to push to
take food assistance away from more vulnerable Americans in the
upcoming farm bill, we are just not going to have that. No
more. No more PPP, punishing poor people. There are more than
2,000 references in the Bible that speak to how we treat the
poor, and so what is being proposed, that is not the way. That
is not what it says.
Our Ranking Member has previously stated taking food away
from people is un-Christian. Well, so is all the misinformation
and the conspiracy about SNAP. Leviticus 19 and 11 reminds us
``Do not steal, do not lie,'' and so I am not going to support
any farm bill or any other legislation that will take food away
from low-income households, which are really underpaid
households. And we continue to talk about getting to work for
$7.25 an hour? You can't survive on $7.25.
Cuts to SNAP harm our nation's most vulnerable, including
children, and families, and older Americans, and disabled
people. In 2020 almost 31,000 households in my district
depended on SNAP to put food on their tables every month. We
have a food insecurity issue in North Carolina, and in other
places, so soon many low-income Americans will lose out on
critical food assistance, because of the reinstatement of
SNAP's punitive, insensitive, 3 month time limit on benefits
for people who can't find work, but who need to eat, so where
is the compassion, folks?
Taking away SNAP doesn't help anyone find work. It just
makes them go hungry. Our SNAP recipients who can work do work,
and some people, like elderly people, are being forced to work
in our economy. I have heard stories about people in my
district taking low wage jobs when they should be enjoying
retirement, for example, and some of them can't even stand up
at work. Greeting people coming into the store. Many of these
folks that we are trying to punish here get SNAP benefits
because they don't earn enough. The money runs out, the food
runs out, before the month runs out. Working hard is not enough
if you don't make enough: $7.25, you can't survive, and all of
my colleagues here know it.
And then when we talk about what you are getting, $6 a day,
$2.41? I mean, come on. Are you going to be able to eat a
decent meal for $2.41 a meal? That is absolutely ridiculous.
Ms. Brown, how is Minnesota preparing to reinstate the time
limit and the expansion from 50 to 54 years old? And by the
way, I got my AARP card at 50, so some people do consider you
to be a senior then. So what burden does the time limit place
on program administrators and recipients, and what do you think
the ultimate impact will be?
Ms. Brown. Thank you, Representative. The time limit--so as
we are thinking about reinstating the time limits, we are
working through a number of processes. We are ensuring that our
trainers, our workers, are fully trained and are aware of the
rules and regulations they need to apply on people. We are
working with recipients to ensure that they are aware of what
they need to do to keep up to speed with the changing
regulation. We are ensuring that our websites have information
about other resources that they can access. So, we know this
will be an additional burden on our food banks and our food
shelf system, which is already seeing record numbers. So, we
are preparing in a lot of ways, with our emergency food system,
to ensure that folks are ready to respond to the number of
folks that will no longer be available.
We also are working to ensure that we can apply for a
waiver that will allow us to take into consideration the
unemployment rates. So, we know, and as I shared earlier, that
our unemployment rate in Minnesota is very low. But when we
start to look at the racial divides, we see that African
American and American Indian populations are disproportionately
impacted, and so this time limit will disproportionately impact
those populations----
Ms. Adams. Thank you very much, ma'am. My time is up. We
are not going to allow this. I want my colleagues to know that.
Let us keep SNAP, let us keep people eating. We must feed
folks. Working hard is not enough if you don't make enough.
Mr. Austin Scott of Georgia. Thank you. The chair asks
unanimous consent to submit for the record May 31 FOXBusiness
article referencing April surge in job openings, Job Openings
Unexpectedly Surge in April to the Highest Level in 3
Months.\4\ Hearing no objections, it is submitted. I now
recognize Mr. LaMalfa for 5 minutes.
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\4\ Editor's note: the article referred to is located on p. 124.
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Mr. LaMalfa. Thank you, Mr. Chairman. We keep hearing we
are not going to allow this or that. Well, all we are looking
for here is a program that is being run with accuracy and
integrity for the folks that have the real need that are
receiving it, and that's also appropriate to have course
corrections with any Federal program during its time of
existence. So, I'm tired of these accusations.
So, Ms. Royals--Ms. Royal, I wanted to clarify something
that was said earlier as well, is that--are not asylum seekers
and any person under 18 years old able to receive SNAP benefits
in this country? The--as non-citizens? Anybody else on the
panel that want to weigh in on that? Ms. Royal, is that
something you are aware of?
Ms. Royal. It is not something I am comfortable in
responding to. Again, I am an--or a--an integrity investigator,
and I don't issue benefits.
Mr. LaMalfa. Okay. How about Ms. Rachidi? Dr. Rachidi?
Dr. Rachidi. I do not believe the 5 year ban on non-citizen
applies to asylees--asylums.
Mr. LaMalfa. Sorry?
Dr. Rachidi. So, there is a 5 year ban on non-citizens,
that they can't receive SNAP benefits. I do not believe that
applies to those that are seeking asylum.
Mr. LaMalfa. It does not apply to asylum? How about under
18 years old?
Dr. Rachidi. And children as well, right.
Mr. LaMalfa. Yes. So, we do have people that are not here
legally that are receiving SNAP benefits, or they are not
citizens receiving SNAP benefits?
Dr. Rachidi. Well, I--right. I mean, I think they are here
legally if they are seeking asylum, but, yes.
Mr. LaMalfa. Well, asylum is one thing, but my--people
under 18 that have gotten here are receiving SNAP benefits,
right?
Dr. Rachidi. To your point, yes.
Mr. LaMalfa. Okay. Thank you. So, Dr. Stover, we are
hearing about the gap in income, and how far that goes on
receiving nutritious food, healthier food, healthier choices.
So, would increasing the dollar amount of the benefits, would
that lead to healthier choices, do you believe, and do you have
any data that would support that?
Dr. Stover. There are data in this area. What I would say
to that is if one is interested in increasing the SNAP benefit
for health outcome, one would look at the available data to do
an impact analysis, and look over time what has increasing SNAP
done to affect hunger and food insecurity, what could
increasing the SNAP benefit do to then improve health outcomes
and lower healthcare costs? But that is the type of data that
we need so we can have science-informed and data-driven
policies.
While I am not answering that question directly because I
am not familiar with the totality of the literature, this is
the value of having an evidence-based approach to setting
policy, so that one can be certain about outcomes, or more
certain about outcomes.
Mr. LaMalfa. So, in all the existence of the SNAP Program,
we don't really have data that has been gathered yet that the
increased dollar amount per user of the program would lead to
healthier food choices in their diet?
Dr. Stover. Some of those data are available, and we can
make those available to you, but I don't have those in my
fingertips.
[The information referred to is located on p. 232.]
Mr. LaMalfa. Do you have a conclusion, from what you know
of that data, that would say, yes, it is--seems true, or
inconclusive? What do you think about the data you have seen?
Dr. Stover. I am not aware of any meta analyses, or any
type of research synthesis that has been done to look at the
totality of the literature. There are some studies that show
effects, there are some studies that show other effects, but I
am not aware of someone who has systematically combined all of
the data to answer your specific question. But I agree with you
that that is what is needed in the entire food and agriculture
space.
Mr. LaMalfa. More data, or higher benefits?
Dr. Stover. More data, and combination of the data. Taken--
looking at the existing data and combining it in a way that is
statistically appropriate so that you can get the answer you
are seeking so you can make an informed decision.
Mr. LaMalfa. So, in all these years we don't have this kind
of data that is being gathered, so we--I got--got more to do on
data gathering, so--all right. The--so the concept that has
been advanced today is that more money would mean healthier
choices. We don't really have proof of that?
Dr. Stover. Literature that would----
Mr. LaMalfa. Okay. All right. All right. Do you have an
idea of what we could do to incentivize healthier choices,
whether it is more dollars, or any other method? And we have
just a little time, please.
Dr. Stover. Again, the food system we have is focused on
lowering rates of hunger and food insecurity. If you change the
endpoint to health, then all of your incentives should be
around health, not around the food itself.
Mr. LaMalfa. Okay. Thank you.
Mr. Austin Scott of Georgia. The gentleman's time has
expired. I ask to submit for the record a February 2023 article
on how SNAP can be strengthened to be a health intervention.\5\
Without objection, so ordered. Mrs. Hayes, from Connecticut,
you are recognized for 5 minutes.
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\5\ Editor's note: the Current Opinion Pediatrics article referred
to entitled, Supplemental Nutrition Assistance Program as a health
intervention, is located on p. 115.
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Mrs. Hayes. Thank you, and thank you for holding this
hearing. Much of our work this year is going to be around the
farm bill, and we have heard a lot about how the farm bill
impacts farmers and rural communities. While every Member of
Congress may not represent a rural community, I remind you that
every single one of us represents people who eat. And with the
farm bill being our biggest undertaking, I will once again
express my disappointment that 80 percent of the farm bill
falls under the Nutrition Title, and this is the first and only
hearing we are having on this topic.
You are all right, hunger should not be a political issue.
But when we came to the table to negotiate on the debt ceiling,
what my Republican colleagues asked for was increases to our
military budget, which has been increased year after year, even
though the DOD has failed five consecutive waste, fraud, and
abuse audits, and they are unable to account of over 60 percent
of their $3.5 trillion in assets.
But SNAP is where we want to look to make cuts. Their
obsession with cutting food assistance is just jarring. I
remind you one more time, $6 per person per day. That is not
the cause of our enormous budget deficits. And highlighting
one-off instances of fraud as indicative of the larger program
is just wrong. Ms. Royal, I hope that you arrest every single
person who is committing fraud in the SNAP Program because they
too are stealing from the people who need it most. Every one of
us supports investigating those cases of fraud, which are few
and far between, and not what is being reported today.
SNAP is one of the largest anti-hunger, anti-poverty
initiatives in this nation. More than 42 million Americans
depend on SNAP each month, including 15.3 million children;
108,000 of those children live in my state. And when we want to
talk about data--I listened very carefully to some of the data
that Dr. Rachidi introduced--Federal data shows that four out
of five households in the program have at least one family
member working, so the majority of people who are collecting
benefits are working.
As an educator, I saw poverty firsthand. Hungry kids don't
learn, and hunger and poverty are a significant driver to poor
learning outcomes, and many families are unable to purchase or
access the food their children need to reach their full
potential. I am going to go through all of this, and then I am
going to give you some time, Ms. Tikki Brown, to respond. I
want you to talk about the effects hunger has on learning, and
how these can be lifelong and cyclical, and what barriers
children have to accessing SNAP. And then my other question--I
just want you to have enough time to speak--is about incentive
programs like GusNIP, and how they help SNAP recipients
purchase fruits and vegetables, and support local farmers.
We heard a lot about people's choices. Their choices are
not because they don't have restrictions or guidelines in SNAP.
Many low-income, urban, and rural communities frequently have
low access to healthy food or retail options. If there is no
grocery store around you, and you are buying your meals from a
bodega, and you are homeless, and don't have access to hot
foods, you buy what is available. So, it is flawed to think
that people are just making the choice, from everything there,
to only buy snacks.
So, my second question that I would like for you to
address, Ms. Brown, is how programs like GusNIP can help
connect people in low access communities to farmers, farmers'
markets, and healthy food options. So those two things. Thank
you.
Ms. Brown. Thank you, Representative. So, to your first
question, absolutely, children who go to school hungry, who
live in households with a lack of access to food, often suffer
with an inability to concentrate at school. They fall behind
academically. They are more likely to miss school because of
illnesses. It impacts health, right? And we see those impacts
throughout a person's life often, as well. So, prevention is
key here, and ensuring that children have enough food from an
early age, and throughout their growth cycle.
To your second question around incentives, it is incredibly
important. In Minnesota we have been able to pay with state
dollars, through our legislature, a Market Bucks Program, and
that incentivizes SNAP recipients by doubling their SNAP
dollars at the farmers' market. It creates more access to
fruits and vegetables. It helps rural farmers' markets and
agriculture producers. It is a--it is an absolutely wonderful
program, and people enjoy it.
So, we have to think about, when we are talking about SNAP
participants, it is a supplemental program. It is $110 per
month in our state, and it does not cover every single expense.
And so when we look at what people are buying, we have to
consider all of the options. Thank you.
Mrs. Hayes. Thank you. With that, I yield back.
Mr. Austin Scott of Georgia. Thank you. The chair now
recognizes Mr. Bost for 5 minutes.
Mr. Bost. Thank you, Mr. Chairman. My colleagues from the
other side of the aisle did a couple things here. First off,
one said that we only had one hearing, but while they were in
the Majority, they only had two on this. You know that? But
since 2015 we have had 39 on this particular subject. One of my
colleagues, also on the other side of the aisle, gave testimony
that one of our witnesses has failed to--blew apart, and
complained about her testimony, and--but failed allow--to allow
her to respond, and I would like to give Ms. Royal, if she can,
to respond about her testimony and why it is accurate.
Ms. Royal. The accusation was that it requires more than
name, address, and signature to submit an application. And, to
make the clarification, that is what is required to receive an
application. Now, verification is required of the different
things that--among the different things that Ms. Brown
described, and that verification--the burden of that falls on
the agency to do that.
So, somebody comes in, essentially John Doe, homeless, and
puts an X on the application, it needs to be processed, and
benefits are likely going to be issued for that first month. I
will clarify again, we will need to get clarifying information,
according to the regulations, including Social Security Number,
and additional eligibility requirements. But I will hold fast
to that statement as true and accurate.
Mr. Bost. Thank you very much. Mr. Hodel, we are spending
more taxpayer dollars on nutrition support than ever before,
yet the rate of food insecurity still hovers around ten
percent. Where is innovation lacking, and where do you see
opportunities--where do they lie for new ways to invest--these
programs so they show results, and decrease the rates of food
insecurity? If any other witnesses would like to add, to do
that, I would like that as well.
Mr. Hodel. Thank you representative. Yes, innovation, you
go to any corporation--that is the buzzword, but it is elusive.
Innovation starts with ideas, and ideas start with people. And
the secret sauce in the Midwest Food Bank is our volunteers. We
have 30,000 volunteers that come in and out of our facilities
every year, and we highly leverage our volunteers in a variety
of roles, and so that is where--that is what sparks our ideas
for innovation. So, we are blessed at Midwest Food Bank to have
a variety of talents--they are coming--they are retirees, they
are still employed, they are mothers that are looking to kind
of fill their day, but they all bring different life
experiences, they all bring different education to Midwest Food
Bank, and that sparks ideas.
And so, from those ideas, then we move quickly. We
experiment, we determine what works, and we just grow from
there. And so, I would say that that innovation of how do we
use companies that have logistics companies, and we utilize
their freight lanes? How are they distributing family food
boxes for us? Where are we working with the retail market and
the grocery industry has changed rapidly, and so we have to
pivot quickly to rescue food. And so, all of those ideas and
connections, to make sure that we are casting a broad net, we
are rescuing food across the country, we are bringing it in,
and a lot of times using other resources. Companies that have
trucking companies that are willing to give back, and support
philanthropically to what Midwest Food Bank does.
One other example of innovation is we have a local junior
college that they train their CDL drivers at our facility. We
have a large parking lot, and so we get food moved around by
that junior college while they are achieving their CDL
certification.
Mr. Bost. Wonderful. Anyone else?
Dr. Rachidi. Can I just add real quickly that there is a
disconnect between food insecurity rates and SNAP expenditures?
And we have seen that even more so in recent years. Since 2019
over $40 billion more dollars in SNAP has gone out to
households in real dollars. Benefits were increased in 2021 by
25 percent, and we have not really seen food insecurity rates
move very much.
Mr. Bost. All right.
Dr. Stover. I would just like to add that I really
appreciate the innovation that we have seen here with the
Midwest Food Bank. As was said, rates of hunger and food
insecurity, other than the pandemic, have been pretty much
stagnant. And the issue is not food production, it is access,
and dealing with the access issue was absolutely critical. At
the same time, we have also seen, amongst that population,
rapid increases in obesity and diet-related chronic disease.
And so, it is access, but we also need to have a think about
the issue of the chronic diseases in that population.
Mr. Bost. Thank you very much to all of you for your
answers. Let me be very, very clear here. No Republican wants
to see people go hungry. We want to make sure a program works.
But the difference is we want to make sure that it works
wisely, that it works wisely, and we are spending the money
accurately. And my time has expired, but I think, if you want
me to, I can go on a long time explaining why it is that the
program itself has a lot of problems. With that, Mr. Chairman,
I yield back.
Mr. Austin Scott of Georgia. To clarify, in the first 6
months of the 117th what--that--this Committee had two meetings
on production agriculture, and so far we have had one on
production agriculture--so that is--I know there is some
accusations going back and forth, but it is--anyway. And----
Mr. McGovern. Yes, Mr. Chair? Chairman?
Mr. Austin Scott of Georgia. Yes, sir?
Mr. McGovern. I want to ask unanimous consent to insert in
the record an article entitled, `City slickers' receiving
federal farm subsidies soared under Trump,\6\ and it basically
is about a GAO study that found that roughly \1/4\ of farm
subsidy recipients do not contribute personal labor to farms.
They live in urban areas like New York City and Chicago. So, we
want to hear about integrity of programs cracking under fraud,
maybe we ought to do a hearing on this, rather than rather than
beating up on poor people.
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\6\ Editor's note: the Environmental Working Group's news release
is located on p. 199.
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Mr. Austin Scott of Georgia. That is so ordered. We can't
make a speech on it. We are going to allow you to submit it for
the record. All right. Ms. Brown from Ohio, 5 minutes.
Ms. Brown of Ohio. Thank you so much. As we open with
prayer, I am reminded of Proverbs 14:31, ``Whoever oppresses a
poor man insults his maker, but he who is generous to the needy
honors him.'' Last Congress we held seven hearings on
nutrition, so I want to set the record straight on that. I also
want to set the record straight as it relates to illegals, or
aliens, that are getting SNAP. this is, again, pure
fearmongering, and wrong on many levels.
One, undocumented individuals are not eligible for SNAP.
Two, SNAP benefits are available to all who qualify, and no
American citizen is being denied SNAP because a permanent
resident received benefits. More than 96 percent of SNAP
participants are U.S. citizens. Of the four percent who are
not, less than one percent are refugees, and three percent are
lawful permanent residents, and other eligible non-citizens,
like asylees. And they are only eligible once they have been
granted asylum, not while their applications are pending. The
only exception is for Cuban and Haitian nationals. So, I just,
again, want to set the record straight.
As it relates to incentivizing nutrition, nutrition
incentives are definitely a benefit, and we can talk about
programs like GusNIP, which are far more effective and
productive, and I am happy to discuss how we can work together
to expand that program. Because in my district, almost 25
percent of households, which--nearly one in four depend on SNAP
to put food on their tables. Statewide, in my state, 1.3
million Ohioans receive food assistance through SNAP. In an
average month this number includes 530,000 children, 200,000
individuals with disabilities, and 163,000 seniors, however you
want to define them.
One of the most vulnerable food-insecure populations in my
district, and indeed across the nation, are people facing
homelessness. Even though most, if not all, of these people are
SNAP eligible, our homeless population has lower SNAP
enrollment rates than any other groups due to administrative
and logistical barriers like inconsistent transportation, and
lack of access to food storage and preparation, Ms. Royal. They
also face obstacles to employment, such as a consistent
address, and access to a phone, e-mail, or traditional mail.
That is why I remain outraged that the Republicans demanded
more older Americans be subject to SNAP's harsh time limits on
benefits as part of the debt limit agreement. I was pleased,
though, that President Biden was able to negotiate a new
exemption for individuals experiencing homelessness through
2030. Leaving people hungry will not help our economy, it will
not create jobs, or balance the budget. But despite these
claims, this is what my Republican colleagues seem to believe.
So, Ms. Brown--no relation, I don't think--as things
currently stand, pre-implementation of the new exemption, how
do work requirements impact homeless individuals, and what are
some of the barriers unhoused populations face to achieve
steady work?
Ms. Brown. Thank you, Representative. So currently in our
state, we do use an exemption with our homeless population. We
call it a Homeless Plus. So, if somebody is lacking in a fixed
or regular nighttime residence, plus they are lacking access to
a shower or laundry facilities, they can achieve some
exemption. So, we have made some progress on that front. What
we have found, in speaking to the population, is that they find
it very difficult to interview for jobs, and people, in fact,
will not interview with them if they do not have access to a
shower, or have access to laundry facilities.
I also want to just make the comment that some homeless
individuals do work, and they also face many, many barriers.
When people are homeless, they often have to check into a
homeless shelter at a certain time of the night, or even during
the day, and that does impede their ability to work, and to go
to interviews. And so there are a number of barriers that
homeless individuals face that prevent them from achieving long
lasting work, and that is why SNAP is so important, to ensure
that they have the ability to have food so that they then can
stabilize.
Ms. Brown of Ohio. Two questions. Do you think the
exemption will help more unhoused individuals qualify, and stay
qualified, for SNAP, and if so, should we consider making this
a permanent exemption?
Ms. Brown. I think it is a great opportunity for folks. I
believe that it will allow folks to stay on the program longer,
to stabilize.
Ms. Brown of Ohio. Thank you. So, I want to be clear, as we
begin serious consideration of the upcoming farm bill, I will
not support taking food assistance away from low-income
households, period. And with that, Mr. Chairman, I yield back
the balance of my time.
Mr. Austin Scott of Georgia. Mr. Moore for 5 minutes.
Mr. Moore. Thank you, Mr. Chairman. I appreciate the
witnesses being here today. Four out of every $5 in the farm
bill goes to nutrition, as it stands today, and that worries
me. I would like to take this opportunity to remind my friends
across the aisle that this farm bill is not a nutrition bill,
and that there is more to be discussed than just SNAP
programming.
Do I think hungry people should go no--a--I mean do I think
people should go hungry? No, absolutely not. But I do think we
need to make sure the program that is consuming more than 85
percent of the farm bill's budget needs to ensure--and needs to
be administered in a way that serves the taxpayers, and for
those receiving those benefits. I want to make sure that we
are--we talk about integrity and innovation in this hearing
session, and so--one of the things I want to ask, Ms. Royal--I
don't know if you have been tracking the Federal welfare
program reforms in the new debt ceiling negotiations. How do
you expect other provisions in the debt ceiling package to
increase program transparency and integrity?
Ms. Royal. I am not aware of elements in the new debt
ceiling package that are going to affect integrity. Again,
integrity has to do with intentional false statements that
people make in order to become eligible, and the focus, again,
on pursuing fraud in that program, I would say, is confined to
that area.
Mr. Moore. I grew up on a farm and worked in industry
before I actually came to Congress, and I could certainly
appreciate the value of a hard day's work. The SNAP Program has
education and training requirements included in its eligibility
standards. Dr. Rachidi, can you speak to the value of
incorporating education and training opportunities into SNAP
eligibility standards, and have these requirements shown a
return to the workforce and self-sufficiency?
Dr. Rachidi. Well, the SNAP Employment and Training Program
is largely voluntary in most states. There are a few that have
mandatory for ABAWDs, but for the most part, it is voluntary.
The funding is also fairly limited. There is a state match that
is required, so really this program is pretty small. And the
evidence that we have on the programs, again, that is people
already motivated to participate. Because it is voluntary, they
participate.
The evidence that we have is that these programs are
actually not very effective at increasing employment on
average. And so, I think there is a lot of work that could be
done, because in employment and training is a key component,
and the program could be stronger in that area.
Mr. Moore. Dr. Rachidi, I don't think there is a government
program in the world as good as a job, and I think people
earning and working in any--I think that was shown even with
the Clinton work requirements, when they came out with those
under Bill Clinton, that once people got in the workforce, they
stayed in the workforce, and it actually improved their
standard of living.
And so, I think that is something we should all encourage
and want to see. I don't think that programs should be--they
are safety net programs, but they should not be spiderwebs. I
don't think people should get trapped in those programs. I
think our job is to lift people out of poverty, and then create
opportunity for those folks. And so, Dr. Brown--I mean, Ms.
Brown--I am not trying to promote you to Ph.D. here--quick
question. You said something a while ago about people applying,
maybe, for benefits that maybe are non-citizens. And do you
know if asylee seekers--or--if they are--the people who are
seeking asylum instantly are approved for benefits?
Ms. Brown. Thank you, Representative. Asylee seekers do not
receive benefits. Once they receive asylum, then they would be
eligible.
Mr. Moore. Do you know how quickly that process happens
normally, when they apply for asylum?
Ms. Brown. I unfortunately do not.
Mr. Moore. Okay. I went--in Yuma, Arizona--I went to a
hearing down there a few weeks ago, and we were actually
interviewing some law enforcement officers and people down
along the border in Yuma, and one of the things that concerned
me was--the Sheriff told me they--instantly, when those people
cross the border, they are granted a Notice to Appear in court,
and they are given benefits, taxpayer benefits.
And so, my concern was--we know of five million people now
that have had encounters on the southern borders, but one of
the things is they are throwing their IDs down before they get
there. So, we have tons south of the U.S. border, and people
are claiming to be unaccompanied minors, but they are above the
age of 18. And so, my concern, for the American people, that we
want the people that are most vulnerable, that we talk about
the vulnerable populations in this country. My concern is if we
continue to just process five million people every 24 months at
the U.S. southern border, that at some point the people on our
assistance programs will push out the most needy Americans.
And that is a concern for me, because when they told me
instantly they got a cell phone, and then they got a Notice to
Appear in court, and many cases they got benefits of up to $800
a month, and that is concerning for me, because I am afraid
some of that might be SNAP benefits that we could be using for
Americans. So, I just wondered if you might have any access or
idea of how quickly they are approved, and how are we
verifying, because you said something I felt was interesting, a
proof of application for a Social Security Number. Could you
elaborate on--never mind, I am----
Mr. Austin Scott of Georgia. Ms. Brown, could you be very
fast with that? We are out of time.
Mr. Moore. Real quick, Ms. Brown, please?
Ms. Brown. We do have a number of verifications that ensure
that Social Security Number, you cannot receive benefits
without a Social Security Number.
Mr. Austin Scott of Georgia. Okay. All right. Time has
expired. Before we go to Ms. Davids for 5 minutes, Mr. Finstad,
we are coming to you next. Ms. Davids, 5 minutes.
Ms. Davids of Kansas. Good morning. Being in Congress can
be hard sometimes, because it is kind of heartbreaking to spend
so much time trying to get here, to have arguments that include
sometimes--while focusing on trying to make sure that we have
integrity in a system, or that we are taking care of American
citizens, that we sometimes end up seeing the dehumanization of
people.
And, as someone who, like, grew up poor, and has managed
to--through education, through help from a lot of different
people and organizations, to have conversations taking place
that essentially start with a premise of laziness, or a lack of
desire to do something like get an education, or get a job--
because people who aren't able to feed their kids are not
sitting at home trying to figure out how to avoid getting a
job.
And I just really hope that we can, like, have
conversations where we are not acting like people who want to
feed their kids, or even bring their kids here so they can
work, and have access to better lives, are trying to do
something negative.
I have notes. So as our Committee engages in serious
discussions about the upcoming farm bill--no, I am having an
on-the-fly moment. Good, that was the break I needed.
As we begin to engage in serious discussions about the
upcoming farm bill, I do want to emphasize that I am--I am
personally committed to ensure that we pass a farm bill that
both supports our farmers and producers, and also protects food
security for America's households: low-income households, rural
communities, our veterans, children, families, seniors. And
beyond its immediate impacts on food security, SNAP is a
critical economic driver, especially in rural communities. In
Kansas, where I live, an average of $21 million in SNAP
assistance was issued each month in the Fiscal Year 2020.
The utilization of SNAP is an investment in our
communities. By helping low-income families afford food, and
ensuring that farmers, processors, distributors, and retailers
are also able to be supported. As of 2020, we had about 2,000
food retailers accepting SNAP in Kansas. And a nationwide study
by the National Grocers' Association found that in 2020 SNAP
was responsible for more than 200,000 U.S. grocery jobs,
earning wages totaling more than $6.7 billion. I know that
USDA's Economic Research Service has also found that during
economic downturns, $1 utilized in SNAP generates more than
$1.50 in economic activity.
And I had questions that I wanted to ask, but the last
thing I want to say, just speaking to this, is I have lived in
a rural community where it took 35 minutes to get to a grocery
store that often couldn't sell meat because they kept getting
cited by regulators. And the next closest place was a Dollar
General, and that was 48 minutes. And the next closest place
was a Super Walmart that was 90 minutes from the town I lived
in.
And I just know that, like, when we are making these
policies, none of us knows every single person's experience,
but all of us should be trying to figure out how we make sure
that people can eat, have jobs, feel secure, and not be
dehumanized. And I think we can do all of that together. I will
yield back.
Mr. Austin Scott of Georgia. The chair now recognizes Mr.
Finstad for 5 minutes.
Mr. Finstad. Thank you, Mr. Chairman, and thank you,
Ranking Member Scott for holding this important hearing today,
and thank you to all of our witnesses for being here. And I
will just start my comments out by maybe acknowledging what I
have heard a little bit from the folks on the other side of the
aisle here, and I will just simply say I hear you. And one
party in this country doesn't own compassion, and one party in
this country doesn't own the willingness to give the shirt off
your back for your neighbors that are in need. I think that
that is something that we all can agree that we can work
together on, and that we can hold as a common value.
And I will just say that we can also--we can do that, but
we can also talk about serious things like program integrity,
and making sure that we are getting the best bang for the buck,
that the taxpayers' dollars are going to those most vulnerable
people. That should be something, again, that we, on both sides
of the aisle, could agree on. So, I think there is some common
ground here, and it is so important that we keep this
conversation going, and we keep the bipartisan nature of a farm
bill coalition intact, because it is going to take that to get
this done.
In 2001 we spent $17 billion on SNAP. This year SNAP is
projected to cost taxpayers $124 billion, an increase of over
700 percent. Meanwhile, food insecurity in this country has
remained largely unchanged. So, I think that is some data that
is important for us to know, that it is not because of a lack
of investment. We have definitely put our money where our mouth
is in this country.
So, as we explore the conversation in regards to program
integrity, and trying to make sure that we understand, are we
getting the dollars to those that are in the most need, couple
things that come into mind that I need to--maybe just to better
understand. So, I will start with Ms. Royal. Americans in rural
communities I represent, again, like I have said, would clearly
give the shirt off their back to help a neighbor in need. And,
really, our southern Minnesota philosophy is, we are all about
giving folks and hand up, not just a handout. How do we help
people get to that next level of life, and we are willing to do
it.
So, in your testimony today you referenced the rates of
fraud in SNAP, but you also mentioned a little bit about the
error rate. And I just want to maybe have you give us a quick
view of what is error rate versus fraud. If you could do that,
Ms. Royal?
Ms. Royal. Error rate comes from quality control reviews
that are mandated and done by each state, and it checks the
accuracy of benefits that are issued by the state. The fraud
rate is the amount of fraud that occurs in the program. The
error rate is calculated and reported, but the fraud rate is
really difficult to put your finger on, because there are so
many different elements that make up that rate.
So, states do report quarterly on our fraud, but they use a
form--it is the 366B form. It is antiquated, it is inaccurate.
It provides just a--not even a snapshot, but an excerpt of
information that states have to deal with in regards to fraud.
Mr. Finstad. Thank you for that. And, I am a simple farmer
from southern Minnesota. Error rate, fraud rate, to me, it all
is dollars that aren't going to where we said we want them to
go, and that is to help the most vulnerable people in this
country, whether it is error rate or fraud rate. And I think it
is something that we have to--again, this is bipartisan, it
should be a bipartisan concern, and an issue, and if we are
focused on getting dollars to the most vulnerable, this is a
way to make sure we can get more money to the most vulnerable.
So, I appreciate you helping me understand that a little bit
better.
Dr. Rachidi, in your testimony you reflected on waivers,
something that has long seen strong support from one side, and
intense opposition from the other side. While I am sure there
will be further debate on this, I would like to take a step
back and talk about the role of the states. This is an
administered program by the states, and it is such an important
part of this.
So this Administration reissued an Obama era guidance that
reiterated the importance of states screening recipients for
the able-bodied adult work requirements. When a state is
waived, recipients lose a touchpoint, one that could have
connected them to other services or other supports well beyond
work. Would you share your thoughts on this issue, Dr. Rachidi?
Dr. Rachidi. Yes. Thank you for the question. And I think
this is an important point, because the problem with SNAP
related to employment is not related to the individuals. The
problem is related to the program, and the way the program is
set up. I interacted with hundreds of SNAP participants
throughout my tenure as Deputy Commissioner in New York City.
The vast majority of them want to work, but they are frustrated
that this program holds them back. And so, by waiving work
requirements, it is exactly what you said. They are--you are
removing a touchpoint.
I don't think it is at all compassionate to send government
checks to households that leaves them jobless, and in poor
health, and not have a touchpoint with a government worker who
is trying to help them. And I think that the approach of
ignoring the issues in the households, and just sending them
checks in the name of reducing hunger is not the right
approach.
Mr. Austin Scott of Georgia. The gentleman's time has
expired. I seek unanimous consent to enter into the record 7
CFR 1400, a regulation promulgated by Secretary Vilsack in 2015
\7\ regarding--actively engaged in farming requirements. This
regulation requires that any producer receiving farm program
payments to make a significant contribution of active personal
labor and management and have a share of the risk on the farm
operation. This regulation ensures that no one gets assistance
unless they have significant involvement in the operation of
the farm. That said, I now recognize Ms. Caraveo of Colorado
for 5 minutes.
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\7\ Editor's note: the Federal Register final rule entitled,
Payment Limitation and Payment Eligibility; Actively Engaged in
Farming, is located on p. 149.
---------------------------------------------------------------------------
Ms. Caraveo. Thank you, Mr. Chairman, and I would like to
thank Chairman Thompson and Ranking Member Scott for hosting
today's incredibly important hearing on nutrition and thank you
for--the panel for being here and sharing your testimony. I am
a pediatrician, and as a pediatrician, I am very passionate,
passionate about the health----
Mr. Austin Scott of Georgia. Keep that then you.
Ms. Caraveo.--and well-being of our nation's children. When
we talk about the front lines, I have been on the front lines
of taking care of children's medical needs for the last 15
years, while dealing with their food insecurity, and being able
to do little as a pediatrician, other than tell them that there
is a supplemental program to help them with their hunger needs.
That is why I will not support any changes in the farm bill
that will take food away from low-income households which would
harm our nation's children and families, including the ones
that I saw in clinic every single day. I am deeply concerned
about the proposals being pushed by Republicans that would put
food assistance for more than four million children, and three
million parents, grandparents, and other caretakers at risk.
Let us take a step back and talk about why this is so
important. Many people do not know that 42 percent of SNAP
participants are children. That is 15.3 million children in the
country, and in my home State of Colorado alone, nearly 180,000
kids who participate in SNAP each month. Now, I understand that
my colleagues on the other side of the aisle have said that
they don't want to put anybody at risk at--hunger, in
particular children, but when we make cuts to programs, they
affect the kids that I see in clinic every single day.
Now, about 80 children a week is what I saw in clinic every
single week. About \2/3\ of those kids were on Medicaid, and
therefore a good portion of them were on SNAP. So let us round
that out, and say about 50 kids a week, every single week, who
I saw who relied on this benefit to make sure that they did not
go into hunger. When we talk about cuts, we are talking about
pediatricians having serious conversations with families about
hunger. I stop and think, which of those 50 kids, which of
those 50 families, would I have to stop and say, ``Sorry, you
don't get these benefits anymore''?
Should it be the family of four kids who are now being
raised by their grandparents because their parents have been
victims to the opioid crisis, and now these parents, instead of
thinking of retirement, are focusing on how am I going to feed
these kids? Thank God for SNAP. Should it be the single parent
who is trying to balance childcare, having a job or two, and
still not making ends meet, and therefore says, thank God for
SNAP. At least my kids are going to be fed every single day.
Should it be the nuclear family that we think is doing
everything right, yet is still living below the poverty line,
and says, thank God for SNAP. At least I have $6 extra per kid
per day to put something on the table.
Now, people don't always think of pediatricians having to
have these difficult conversations, but they do think of us
talking about the science, so let us talk about science.
Research shows that not having enough resources to meet
children's basic needs leads to a host of negative outcomes
throughout a child's life, including poor health and lower
educational achievement.
There are tons of issues, really, around children's health,
whether it is including the risk of obesity, high blood
pressure, heart disease and diabetes in adulthood that come
from hunger and food instability, but is addressed by SNAP.
But, Ms. Brown, what I would like to hear from you is--and I
talk about the families that I have seen in clinic, and how
SNAP impacts them. Can you tell me more about the families that
you have seen with children? How would additional investments
in SNAP make this program even more effective and impactful on
the health of kids in your state and mine?
Ms. Brown. Thank you very much for the question. We hear
from families who talk about the mental health toll on
themselves and on their children. We know that it--with
research that we have from Chapin Hall out of Chicago--they
talk about the connection between family stability and food
security helping mitigate child protection cases. So, we know
there are connections to other programs and other negative
impacts on children, on families. We hear from families that
are very excited to have a little bit of food, to buy bananas
and milk. That is the number--those are the top two things that
our retailers tell us that families on SNAP buy. So those small
things make a really big difference in people's lives.
I also just want to make a quick note that we have heard a
little bit about food insecurity rates have not decreased,
despite all of the extra funding being brought into the
program. That is exactly what it is supposed to do. With all
the extra funding being put in, food insecurity rates did not
decrease, they stayed the same. That is exactly what SNAP is
supposed to do.
Ms. Caraveo. I thank you so much for those comments, and I
just urge my colleagues to think about, when you make cuts,
which of those 50 children would you choose to cut benefits
from? Thank you.
Mr. Austin Scott of Georgia. The chair now recognize Mr.
Bacon for 5 minutes.
Mr. Bacon. Thank you, Mr. Austin. Thanks for all of our
panelists being here today. The evidence is very clear. The
majority of Americans think able-bodied adults without children
should have to work, or seek work, or get the training to get a
job. And it is not even close. I mean, we had a poll just a
month ago from Axios saying \2/3\ of American support work
requirements, to include half of all Democrats. A poll a month
before that from the Center of Excellence poll showed 74
percent of Americans support work requirements, to include the
majority of Democrats.
So, again, we are talking about able-bodied adults without
children. And we have record low unemployment, we have a record
of number people trying to hire, and we have lots of
opportunities for folks to get the skills and the training they
need to get these jobs. This is very important to America's
economy and our economic growth.
My first question is to Dr. Rachidi. We hear from those--
and this is in the previous Congress--that those that have been
on SNAP, there is a point where they earn one more dollar, that
they could lose hundreds of dollars of benefits. We call it the
Cliff Effect. And sometimes this is a disincentive for full
time work or promotions. I would like to get your opinion on
this, as--I mean, we have heard experts in this Committee say
this, but I am curious to get your perception and your
feedback.
Dr. Rachidi. Yes, it is a great question. Benefit cliffs,
or we also call it marginal effective tax rates, because it
actually kind of phases out over time, is an issue, and if you
talk to state administrators, or state groups who work with
SNAP participants, it really is one of the number one issues,
because it does disincentivize employment because people feel
that they can't increase their work effort or increase hours
because they will lose some of their benefits.
One way to counteract that is to phase out the benefits
more slowly. SNAP currently is phased out, but there are some
additional things that could be done to try to smooth that
benefit decrease as earnings increase.
Mr. Bacon. We would sure like to have your expertise so we
could do this better, because we want to incentivize
promotions, full time work, but to ask someone that is in a
lower-income area to say, okay, if I get this promotion, am I
actually going backwards, it is not advantageous, and I know we
could do better. And I think with that I will just--I will
yield back the balance of my time. I appreciate you all being
here today.
Mr. Austin Scott of Georgia. The chair now recognizes Ms.
Gluesenkamp Perez for 5 minutes.
Ms. Perez. Good luck with that one. Thank you. Thank you,
Mr. Chairman.
Mr. Austin Scott of Georgia. That is about as good as a
Georgia boy could do.
Ms. Perez. I would just like to contextualize my
perspective today. I was raised in the church, I am a proud
Christian, and Matthew 25:35 says, ``For I was poor''--``For I
was hungry, and you gave me food. I was thirsty, and you gave
me something to drink. Brothers and sisters, whoever''--
``whatever you did for the least of these, you did for me.''
And I believe that Christians have a mandate to feed the poor,
and this is a mandate that is not just for the benefit of the
hungry, but is also a benefit to our own--it is a reflection of
our own morality. And it is a reflection of us submitting to
God's will to eschew greed and take care of people.
So, reducing hunger is a mandate of Christian scripture. It
has also been a goal of the Federal Government for decades.
And, I am not a legislator by training, I fix cars, so I had to
do some research on SNAP, and I think it actually is a really
elegant bill. The original 1964 SNAP bill (Pub. L. 88-525, The
Food Stamp Act of 1964) has three parts to it, reducing hunger,
supporting agricultural markets, and increasing the nutritional
quality of the American diet. And SNAP is certainly one of the
best tools we have for reducing poverty.
But rural communities like mine are actually 23 percent
more likely to be enrolled in SNAP than their urban
counterparts: 45,000 families in my district in southwest
Washington rely on SNAP. And let me tell you something that is
very deeply concerning to me. Right now, every dollar that
Americans spend on food, only 14.5 make it back to the farm:
14.5 of every dollar spent on food makes it back to the farm.
And I don't think it is a coincidence by any stretch of the
imagination that we are seeing more rural dependence on SNAP
benefits at the same time that we are seeing a lowering of the
dollars that make it back to the farms, these rural
agricultural producers.
So, my question is how do we circle this economy? How do we
use SNAP to feed back in to supporting rural agriculture as we
are supporting these families who are experiencing hunger? So,
Ms. Brown, my question is to you. How can we get more of these
dollars back into our agricultural producers?
Ms. Brown. Thank you for the question. Certainly, incentive
programs, such as the Market Bucks Program, or other similar
farmers' market programs are a really good option for that. I
think any way that we can help incentivize both health and
nutrition, but encourage folks to use SNAP and, whether it is--
in our state it is state legislative dollars that help match
that, that is a great benefit to our rural farmers' markets. I
speak about that all the time.
I also just wanted to thank you for your work on cars.
Transportation is a big issue in rural communities as well, and
I just wanted to acknowledge that as well, that--the comments
about the distance to grocery stores are--is absolutely
critically important.
Ms. Perez. Thank you so much. And could you elaborate on
your testimony about the support SNAP provides to workers in
rural areas in Minnesota?
Ms. Brown. Certainly. So especially--I--well, it was
mentioned a little bit earlier about retailers, and the jobs
that help with the grocers, but we have heard directly from
grocers that say, without SNAP benefits coming into the
community, the local grocery store would close. And so all of
that spreads into the community. Every single dollar that SNAP
utilizes frees up extra dollars. So, if you are in a household,
and you, for instance, need to pay for your children's shoes,
school supplies, if you have SNAP benefits, that frees up extra
dollars, which then goes into your local economy.
Ms. Perez. Thank you so much. Thank you to all of our
witnesses.
Ms. Brown. Thank you.
Ms. Perez. I yield back.
The Chairman [presiding.] I thank the gentlelady from
yielding back. And, before I recognize Mr. Baird for 5 minutes
of questioning, I just request unanimous consent to submit for
the record a recent Department of Justice release that is
related to SNAP fraud.\8\ And, it is from March 2, 2023. And,
without objection, the article will be submitted. And now
recognize Mr. Baird for 5 minutes.
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\8\ Editor's note: the U.S. Attorney's Office, Central District of
California press release entitled, 15 Arrested in Law Enforcement
Operation Targeting Fraudulent Withdrawal of Benefits Designated for
Low-Income Families, is located on p. 166.
---------------------------------------------------------------------------
Mr. Baird. Thank you, Mr. Chairman, and Ranking Member, and
for all you witnesses to be here, got a research background. I
have been in production agriculture all my life. The
interesting thing to me that I want to get your comments on
here in a minute is the--our ability--the technology that is
advancing agriculture--production agriculture--I mean, the kind
of crops that we can raise today, and the quality, and the
ability to use CRISPR techniques, and really define the
genetics of what we produce.
So, my question is, and I am going to start with Dr.
Stover, you indicated that production agriculture could really
contribute to human health, and I really want to emphasize
that, because I think we could do things in production
agriculture that really would contribute to human health, and I
would just like your thoughts on that.
Dr. Stover. There is absolutely no question about that, and
I just want to go back to a point that was made about the
amount of food income that actually--or food purchasing that
goes back--the dollars that go back to the farmer is really
small. And, again, that is because we have an agriculture
system that is built around reducing hunger to make food in
abundance so that it is as affordable as possible.
We have the--in that model we have this externality, if you
will, of really high healthcare costs, so that is where the
money is in agriculture. It is in the healthcare sector,
because of diet quality. And so how do we reimagine a food
supply that both addresses hunger and addresses health? And as
you mentioned, we have so many tools today that we can make the
food supply whatever we want it to be. We can use CRISPR, we
can use genetics, genomics to change micronutrient composition.
We can play with caloric density. There are so many things we
can do, but we have to incentivize that in a way that
production agriculture will adopt these because the model they
are in now, margins are very low because of that endpoint of
keeping hunger as low as possible.
And so, this can be done. We need a different economic
model, and we have to somehow bring together healthcare
economics and ag economics to make this work, because otherwise
we are going to continue to lose a lot of our precious farmland
to more profitable purposes, like solar panels.
Mr. Baird. I couldn't agree with you more, so I would like
to continue on with--conversation with you, but do any of the
other witnesses have thoughts about--in that area? I am talking
about the nutrition that we can create in production
agriculture. And I am not sure very many people are aware of
that, but we can alter the kinds of grains, as he just
mentioned, so I would like for us to put some emphasis in that
area, because it is important to production agriculture, and,
as he mentioned, it is important to save the farmers and
ranchers. So if anyone else has a comment, I would appreciate
it.
Mr. Hodel. Yes, I will just comment a little bit, and maybe
just from the data standpoint of what we found in eastern
Kentucky. So, we have sent Family Food boxes there with
chicken, potatoes, mini oranges, milk, butter, apples, and
juice boxes. And I guess the comment would be is--food
recipients, they absolutely desire and seek nutrition. Like,
they are not avoiding it, they are not trying to use their
dollars elsewhere. If they have a choice, nutrition is
absolutely high on their list.
We surveyed them, and they said 81 percent were very
satisfied, and 84--with what they received in the boxes. And
then we also asked them about health, and 84 percent responded
and--saying it was very healthy. And so we gave--we got
confirmation that those that are in rural, remote areas that
are receiving nutritious food boxes with produce, and dairy,
and meat are extremely grateful, and thankful to have that
nutrition brought to their doorstep.
Mr. Baird. Absolutely. Any other? I have one more question.
Midwest Food Bank, I am really impressed with your----
The Chairman. Your microphone, I think your microphone is
off.
Mr. Baird. Thanks, Mr. Chairman. I need all the help I can
get in this day and age. Anyway, I don't know how much time I
am getting into, but, Mr. Hodel, I am impressed with the
Midwest Food Bank. You are doing that without any government
help and assistance, so my question really is how are you able
to do that? I mean--and how does that work? Quickly. We have 22
seconds.
Mr. Hodel. Yes.
So our model, again, built around volunteers, and so we
keep a very low staff, a very low period cost structure. We
seek private donations. We work with corporations, small
businesses, large businesses, churches. So, we are very
thankful for the donated dollars that come help support our
operation. It costs about $2 million to run one of our
locations, and we distribute about $60 million of food back
into that community.
Mr. Baird. Fantastic. I thank you very much, and I yield
back, Mr. Chairman.
The Chairman. The gentleman yields back. I now recognize
the gentleman from North Carolina, Mr. Davis, for 5 minutes.
Mr. Davis of North Carolina. Thank you so much, Mr.
Chairman, and to the Ranking Member for having us together
today. There is an issue that remains close to my heart, and
that is veterans--our veterans. Those soldiers, sailors,
Marines, airmen, who have worn the uniform in service to our
country. Research shows that food insecurity particularly
impacts veterans who have recently left military service with
lower final salaries, and those who had lived in rural or low-
income areas with limited access to food. USDA recently found
that working age veterans face 7.4 times more significant risk
of food insecurity than the general population, and about \1/3\
of all working age disabled veterans are food-insecure.
Food insecurity is a critical issue in eastern North
Carolina, rural America, and across the country. North
Carolina's First Congressional District alone is the home of
over 46,000 veterans, and in North Carolina veterans are nearly
twice as likely to have a disability than non-veterans, with 30
percent of the state's veterans reporting a disability in 2019.
The Supplemental Nutrition Assistance Program serves as a
safety net for many veterans. On average, about 1.2 million
veteran households participate annually. Unfortunately, far too
many eligible veterans do not participate in the program. A
recent CDC survey (National Health Interview Survey) found that
nearly 60 percent of eligible veterans do not participate. The
recent debt limit agreement had a critical new exemption from
SNAP's time limit on benefits for veterans, which should help
ensure more veterans can access SNAP's essential food
assistance.
I would like to be clear that my support for legislation
that helps Americans, and those in particular: children,
families, seniors, and, yes indeed, our veterans. So, I would
like to direct just a couple questions to Ms. Brown. How do you
think the new time limit exemption will help veterans?
Ms. Brown. Thank you, Representative. I am excited about
this prioritization towards veterans. In our state right now,
we actually do not know how many veterans are currently on the
SNAP Program. It is not a code that we have in our system. So,
with this prioritization, this will encourage additional
partnerships with Veterans' Affairs, and other like-minded
groups, and will allow us to track and prioritize this
population.
We do know that many veterans have high unemployment rates
for their spouses. There is some stigma associated with
applying for the SNAP Program, so, again, this partnership, and
I think coordinated with SNAP outreach, will really focus in on
this population.
Mr. Davis of North Carolina. Okay. And then my follow-up
question here, what other policies should Congress consider to
reach and address the needs of America's heroes, our veterans?
Ms. Brown. Thank you. In addition to increasing SNAP
outreach, I wonder about categorical eligibility, identifying
veterans, and making some type of policy impact so that they
are eligible for the program, depending on their status. I
think that would reach the population that we are trying to
reach and will encourage more participants to apply for the
program.
I will say, in Minnesota, while we haven't tracked it on
the SNAP side of things, it has been a big focus effort on the
homeless side, and they, in fact, are eliminating veteran
homelessness, so we have a lot of good lessons to learn there.
Mr. Davis of North Carolina. Okay. Thank you so much. And,
Mr. Chairman, I would conclude today by saying to those who are
present, and have served, thank you for your service to our
country. And as we continue to do our work here, let us
continue to fight for those who fought for us. I yield back.
The Chairman. Thank you. Mr. Davis, would you yield?
Mr. Davis of North Carolina. Yes.
The Chairman. A little bit of follow-up on the question he
asked. What President Biden insisted we put into the debt
ceiling with regard to the three groups are there, homeless,
veterans and, quite frankly, those children, they are aging out
of foster care. Is it helpful, the fact that under--the
provisions that the President insists to be in there? These
folks are not going to be eligible for SNAP education and
career and technical education benefits that other individuals
up to age 54 would be.
Ms. Brown. So, I think your question is: they won't be
eligible for SNAP education with this, and career----
The Chairman. That is correct.
Ms. Brown. Right.
The Chairman. Because they are automatically going to be
waived from those work--job opportunities.
Ms. Brown. Right.
The Chairman. And we will talk offline.
Ms. Brown. Sure.
The Chairman. His time has expired, and I try to be a good
example, so--thank you. I am pleased to recognize, for 5
minutes, the gentleman from Iowa, Mr. Feenstra.
Mr. Feenstra. Thank you, Chairman Thompson, and Ranking
Member Scott, and thank you for our panel today. I greatly
appreciate what you are doing. I have read your testimonies,
and they are very impressive. With more than 80 percent of the
expected cost of the farm bill going toward nutrition programs,
Title IV is very important to us. It is--and I am glad we are
holding this hearing just to discuss it.
I heard Jerome Powell, the Head of the Federal Reserve,
talk probably about 6 weeks ago, and he said the reason we have
pretty significant inflation right now is because of
employment, meaning that we have ten million jobs available,
and we only have two million people unemployed. And the cause
for the inflation is that, obviously, work--the workforce is in
demand, high demand. So, you have businesses looking for
workers, then they have to pay more, and--which is causing
inflation. So, this is my concern.
Dr. Rachidi, sorry, I didn't mean to mess up your name
there--you outlined that, in 2019, 30 percent of the able-
bodied adults without dependents between the ages of 18 to 49
worked while receiving SNAP, meaning about 70 percent of the
recipients did not work at the time. Now, I really don't want
to go into that, but what I do want to go into is how can we
use SNAP, right? How can we use--and work together
collaboratively to connect those unemployed workers with
employers begging for workers, and causing this inflation? Can
you reflect on that, or have any ideas on that?
Dr. Rachidi. Sure. So, my experience working within SNAP in
New York City, I certainly found that work requirements can be
useful in the sense that they introduce the conversation about
employment with SNAP participants. And I think that that
crucial touchpoint, with individuals who obviously are
experiencing temporary financial insecurity, coming in--
employment should be one of the main parts of the conversation,
and how to help that individual achieve, escape poverty and
achieve upward mobility.
So, I think it is crucial to bring in employment. And then,
having that discussion about employment, combined with the work
requirement, will ensure that those individuals are looking for
work, and can meet the needs of the broader labor market.
Mr. Feenstra. Yes, I appreciate that. And I just think--and
I am trying to--this is a positive moment, I think that we have
this stress on our economy right now, and how do we work
collaboratively to incentivize, and we want to bring people out
of poverty. That has got to be our number one goal. How do we
do that, how do we create that? And I think we have a wonderful
opportunity to do that here.
Dr. Rachidi, I have another question. According to the
National Skills Coalition, in 2018, 52 percent of jobs require
education that falls between high school diploma and a 4 year
degree, but only 43 percent of workers have the skills. So,
what we are saying here is that 43 percent of society do not
have the skills or ability for the jobs that are required.
Again--and you sort of noted this--is there a way that we can
create training programs within SNAP to encourage
apprenticeships or trade schools? Can we--again, I am not
looking for partnerships here. I am looking for anything to
help bring people to the next level, and get them jobs, and get
them out of poverty.
Dr. Rachidi. I think there definitely are opportunities to
do that through SNAP education and training. Part of the
problem, though, is there is a lot of SNAP education and
training dollars that are spent on programs that are not
effective.
Mr. Feenstra. Yes.
Dr. Rachidi. And so, if we could discontinue funding for
programs that are not effective, and move it to programs that
are effective, like partnerships with community college, that
actually ensure SNAP participants get a credential, and can get
a sustainable job, that would be a positive--in the positive
direction, and discontinue programs that are really proven to
be ineffective.
Mr. Feenstra. Yes. Thank you. Thank you for those comments.
Ms. Royal, in your testimony you mentioned that the Food and
Nutrition Service reports fraud rates within SNAP are less than
one percent, which is wonderful, but your organization has
estimated fraud rates range from eight to 40 percent of
households currently enrolled. That is quite an extreme change.
I am just wondering, could FNS be addressing these issues of
fraud today, and why are they not currently prioritizing this?
To me, this is sort of a moment that we need to look at and
say, okay, we need to be effective with our dollars, and are we
truly doing that?
Ms. Royal. I would love FNS to take more of a look at
fraud. I think that would be fantastic. Asking why they don't,
I mean, that has been a topic of discussions that I have had
for a very long time. The SNAP budget spends \1/20\ of 1
percent on fraud detection, prevention, and prosecution.
Mr. Feenstra. Yes.
Ms. Royal. Again, they hold to that one percent fraud rate,
but even with the one percent fraud rate, \1/20\ of 1 percent
doesn't seem to even address that.
Mr. Feenstra. I think you answered my question for me.
Absolutely. Thank you, Ms. Royal. And I yield back, Mr.
Chairman.
Mr. Finstad [presiding.] Thank you. All right. We will go
over to Ms. Tokuda for 5 minutes.
Ms. Tokuda. Thank you, Mr. Chairman, Ranking Member. Upon
coming to Congress, I wanted to join the Agriculture Committee
because I saw a great opportunity and hope in the 2023 Farm
Bill. It was a chance to support our agricultural producers,
increase our food security, strengthen our economy, feed our
people.
So, you can imagine my anger and disgust as I have watched
the farm bill become weaponized by House Republicans, including
Speaker McCarthy, as a way to literally take food out of the
mouths of our older Americans. In fact, Members of this
Committee have put out proposals that would cut SNAP benefits
and put at risk many of the adults that we have in our
communities. As many as two million older adults would be at
risk of losing their SNAP benefits.
I want to focus on something that is close to my heart as
well, senior hunger. Older Americans are among our country's
most food-insecure populations. We should be making it easier,
not harder, for them to access food assistance. Rates of food
insecurity among older Americans remains higher than pre-Great
Recession levels. A study by Feeding America found that in
2021, and you know it has only gotten worse, approximately 5.5
million seniors were food-insecure, with 2.1 million seniors
having very-low-food security.
Let me put it in simpler terms. Our seniors, our
grandparents, our elderly neighbors, our retirees, they go to
sleep hungry. They wake up hungry. On a fixed income, they are
forced to choose between food and medicine, a roof over their
head. One of my constituents on the big island, over in Hawaii,
he was kicked off of SNAP because of a $7 increase in his
Social Security benefit as a result of this year's COLA
increase: $7. That can't even buy you a dozen eggs in Hawaii.
That left this senior with zero SNAP support.
Significantly cutting funding for SNAP will result in
millions of low-income adults losing their food assistance,
including seniors, children, families, people with
disabilities. Penny wise, pound foolish. The consequences of
these cuts are far more devastating than any proposed budgetary
savings. I will not support legislation that takes food away
from low-income households.
In my home State of Hawaii, 30,000 older adults participate
in SNAP each month, and this is just half of the total number
of seniors in Hawaii who are eligible to participate in the
program. Last month, while I was visiting many of our SNAP
processing centers throughout our islands, I heard countless
stories from family members and SNAP workers of seniors who are
not on SNAP, but they could be, and they should be.
Too many seniors in Hawaii, and across our country, are not
accessing SNAP benefits because they have difficulties
navigating the application system, we heard a little bit about
it today, or don't want to apply because they feel that they
would be taking limited funding away from other families in
need. And while that is admirable, it is a false choice. Let us
be clear, that is a false choice. Seniors should not be in put
in a position to either choose between feeding themselves or
their communities.
This issue isn't unique in my state. In 2020 it is
estimated five million older Americans who qualified to receive
SNAP were not enrolled in the program. This means close to
three out of every five seniors eligible for SNAP is missing
out on critical nutrition assistance that can provide them not
only with food, but the means, the greater means, to lift
themselves and their loved ones out of poverty. So, again, let
me put it in very simple terms. Millions of elderly Americans,
our seniors, our grandparents, our retirees, our neighbors,
they are going to bed hungry. They wake up hungry.
Ms. Brown, why is SNAP participation among eligible older
Americans so low, and how can we improve access to SNAP to
ensure the program reaches those Americans in greatest need?
How about demonstration projects, like the Elderly Simplified
Application Project, that helps increase SNAP participation, or
ease the application process for older adults? And are we
taking into consideration access issues in our rural and remote
communities? We heard about it today, language barriers,
something that is an issue with my constituents, and broadband
access, and our seniors' ability to navigate even simple online
or telephonic platforms. I would love your thoughts on that.
Ms. Brown. Sure. Thank you. Certainly, we support any
simplified application process for seniors. We recognize and
hear some of the same stories that you have heard from seniors
that are reluctant to apply for SNAP because they are worried
about taking away from somebody else. I will say that in
Minnesota, when we lifted our asset tests--so I think asset
flexibilities are incredibly important that was the number one
reason why seniors were not applying for SNAP.
Ms. Tokuda. Yes.
Ms. Brown. And when we lifted that asset test, we were able
to see a SNAP increase from a rate of 25 percent to 58 percent
for our senior population. So that is a significant option. I
think also looking at medical deductions. Expanding some of the
medical deductions that could be utilized would also benefit
our senior population.
Ms. Tokuda. Thank you very much. I know I am out of time.
Those are all things we really need to take into consideration.
Senior hunger is real, my colleagues, and we have to do more to
make sure they can access SNAP. I yield back.
Mr. Finstad. Thank you. I now recognize the gentlewoman
from Texas, Ms. De La Cruz, for 5 minutes.
Ms. De La Cruz. Thank you so much, Mr. Chairman. I think we
can all agree that integrity and accountability are important
when it comes to SNAP and other benefits, whether it is fraud,
criminal activity, or state activity, or state issues that
cause this type of fraud or criminal activity, we all want to
understand why and how we can do better. We want to make sure
that it is mitigated.
Ms. Royal, I am going to address this question to you. Can
you flesh out some of your ideas to help mitigate some of these
issues?
Ms. Royal. Sure. Identity verification on the front-end of
an application would be very, very important. I discussed, very
briefly----
Ms. De La Cruz. And, can you please expand on that? Because
we heard that they do have to show their Social Security card.
What do you mean by identity verification specifically?
Ms. Royal. The ability to leverage technology to verify
that when somebody presents themself, that they are actually
who they say they are. That their Social Security Number
belongs to them. That they are eligible to receive benefits,
meeting all of the different criteria. That they are not
receiving benefits in duplicate states at one time. To verify
that members that the--they have listed in their household
exist. To verify, perhaps, people who are not listed on the
application do live in the household. So having--being able to
leverage technology to help that verification process would be
very significant.
I mentioned increasing the retention amount. It seems to be
a really simple way to do that. So, in previous years, the
retention amount from the dollars that states recovered from
overpaid benefits was 50 percent. That has been reduced down to
30 percent in fraud--or 35 percent in fraud claims. But
increasing that back up to 50 percent would provide the funding
that would allow states to purchase and be able to access that
type of technology.
Tying that money--making sure that those retention dollars
are mandated to be used for the prevention, detection, and
prosecution of fraud. In many states that retention money goes
into the General Fund, and is used elsewhere, so the benefits--
or the fraud units don't have the benefit of that money.
Ms. De La Cruz. So let me ask you something. Right now, as
it stands, can we--does the system allow for you to check with
multiple states to see if there are benefits, or is it just at
the word of the beneficiary of these programs?
Ms. Royal. We don't have a way to check. So, there are
states that still utilize or still have access to the original
NAC project. I believe there are six. So, the rest of the
states, we have to rely on that self-declaration in an
application that a recipient has received benefits in another
state. And when they provide that information, then the issuing
state can contact the previous state and make sure that,
again--isn't a problem.
But it is also a problem when people intentionally omit the
answer to that because they want to receive benefits in
multiple states. And then our hands are tied. We don't have a
mechanism to find that type of false statement.
Ms. De La Cruz. So, as I am hearing, it is really just a
self-declaration? That is the only way to find out if someone
is receiving benefits in multiple states?
Ms. Royal. For the most part, yes, that is correct.
Ms. De La Cruz. Typically, people who are intentionally
trying to take advantage of the situation won't self-declare
that I imagine. Moving forward, these retention dollars, you
said that it was reduced from 50 percent to 30 percent. When
was that reduced?
Ms. Royal. 35 percent----
Ms. De La Cruz. Or 35 percent.
Ms. Royal. It is in footnotes in our written testimony. I
don't recall the specific year.
Ms. De La Cruz. Yes.
Ms. Royal. But, again, not only was it reduced, but there
are no mandates of how the money is used.
Ms. De La Cruz. Okay. So, what I am hearing is increase it
back up to the 50 percent, but also giving mandates as to where
that money is used once it is recovered?
Ms. Royal. Right. And I think it is really important to say
that 50 percent has to do with fraud claims. So, the state does
the fraud investigation, they prove that fraud has occurred, a
false statement has occurred. They establish the claim, they
collect that claim, and then the money that they collect, they
split with USDA. So, again, we are recommending that we have a
50/50 split, and that there is a mandate that the $50--or the
50 percent that we recover be used for the prevention,
detection, and prosecution of fraud.
Ms. De La Cruz. Thank you very much. With that, I yield
back.
Mr. Finstad. Thank you. I now recognize the gentlewoman
from Illinois, Ms. Budzinski, for 5 minutes.
Ms. Budzinski. Thank you, Mr. Chairman, and thank you,
Ranking Member, and thank you to the panelists for being here
today. Before I start with some questions, I thought it would
be important for my colleagues and the panelists to hear a few
stories from my constituents who rely on the support that SNAP
provides. And, really, I think you will hear I am amplifying
what my colleague, Congresswoman Tokuda, really eloquently
stated around the importance for seniors and older Americans to
SNAP benefits. And so, I am going to highlight a few of my
constituents that are older Americans, and their stories, and
that importance of the SNAP benefit.
Kathy, a 66 year old from Decatur, Illinois, lives on a
fixed income of only $1,088 a month. She gets $98 a month from
SNAP and pays around $100 on food each month. As someone living
with diabetes, Kathy shared with me that a lot of the high-carb
foods offered at local food banks send her blood sugar through
the roof. She uses her SNAP benefits to buy fresh fruits and
vegetables that help her to stay healthy, and that SNAP
benefits, she said, are a matter of life and death for her.
James, a 66 year old from Urbana, Illinois, shared that the
$55 a month that he receives in SNAP benefits barely help him
get by. He told my office that: ``If I didn't have SNAP, I
would starve.'' And Don, a 56 year old from east St. Louis,
told us that he doesn't know what he would do without the $100
he receives each month through SNAP. It is the only way that he
can put food on his table. These are the stories of my
constituents, as I mentioned, who depend on SNAP, each of them
over the age of 50 years old.
Nationally, SNAP serves about 5.3 million households with
elderly individuals each month. That is nearly 30 percent of
all SNAP households. In my home State of Illinois, about
240,000 older adults receive food assistance each month from
SNAP. Far too many of our nation's seniors struggle with food
insecurity each month, and this crisis is even more dire for
older adults living with disabilities.
In 2021, older adults with disabilities had food insecurity
rates more than three times as high as those without
disabilities. Even among those who are food-insecure, seniors
with disabilities are more than two times as likely to be food-
insecure, and are three times as likely to be very-food-
insecure than seniors without disabilities.
SNAP is a lifeline for seniors and older adults, helping to
address food insecurity, and improve the quality of life for
its participants. SNAP participation has been linked to lower
healthcare costs, including lower Medicaid and Medicare costs.
A study of 60,000 low-income seniors recently found that SNAP
participants are 23 percent less likely to enter a nursing
home, and four percent less likely to be hospitalized in the
year after receiving SNAP than non-participants. And that is
why I will not support any policies that result in food being
taken away from Kathy, James, Don, and the many other older
adults in my district who depend on SNAP to put food on their
tables for their families.
And so, in the remaining moments--time that I have, I did
want to ask Ms. Brown--you elaborated a little bit--
Congresswoman Tokuda, my colleague, had asked you about
specifically what we can be doing to break down barriers for
seniors to access, and I know you mentioned simplifying the
application process. I was actually also going to highlight the
medical deduction. But are there any other ideas that you might
offer to us to help us make sure that seniors, some of our most
vulnerable population, get access to SNAP benefits?
Ms. Brown. I think the important thing in this
conversation--and I appreciate all the stories, because they
are exactly, like I said, what we hear from participants every
single day--is that participants have an extremely complex
life. Now, one participant, when you speak to one, right, it
doesn't explain all the SNAP participation across the board,
and so, as we think about all of the flexibilities that are
important for families, and for seniors, and for disabled
individuals, it is important to think about the barriers that
they face, and ensure that we have policies that allow for
flexibilities to really serve those that need it.
Ms. Budzinski. Great. I will yield back my time. Thank you.
Mr. Finstad. Thank you. I now recognize the gentleman from
California, Mr. Duarte, for 5 minutes.
Mr. Duarte. Thank you, Mr. Chairman. I would like to talk
more broadly about abundance and access implications of our
farm policy. We have a lot biofuels, a lot of acres of farming,
a lot of farming resource, a lot of food resources going into
biofuels, a lot of restrictions on animal protein systems. We
can see Europe we are shutting down whole industries of dairy
and swine. I am from California. I represent a district that
is--we looked at it--the 18th highest poverty level in America.
It is a rural farm district. I am a farmer by background.
And so, I am very interested, particularly if--Dr. Stover
and Dr. Rachidi, what do you see as the broader implications of
our farm policy in general? We had the EPA Director, Mr. Regan,
in here a few weeks ago, mentioned biofuels 32 times. We
counted them. And I just think the implications for that, in
terms of typing up our food production resources to produce
biofuels, because of what I believe are sentimental reasons, is
really going to come down hard on working families and their
food access, especially when it comes to producing protein that
diversifies their diets.
And I am very concerned that this might be the first
generation in America that is actually moving our diet away
from additional produce, and protein, and diverse nutrition on
the dinner plate, towards a higher starch-based diet, which we
all share concerns of--health concerns with. I don't think we
can bioengineer our way around that. So, I will start with you,
Dr. Stover, and then I would like to go to Angela Rachidi.
Dr. Stover. When we use food to promote health and prevent
chronic disease, which is a major initiative that was started
at NIH by former NIH Director Francis Collins, what we
recognize is that in the diet/health relationship, one size
does not fit all. So, when hunger is the outcome, everyone
responds the same. When you have a health outcome, and you want
to use food as the solution to healthcare costs, people respond
differently to foods. This relates to our past history as
humans, where human populations emerged all over the world.
Those that survived and thrived adapted to local food systems.
This is why you see hemochromatosis in Scandinavia, et cetera.
We need a highly diversified food system to meet the
nutrient needs of all individuals. If we want to use food and
agriculture to promote health, we have to understand that
better. But in the meantime, we need a highly diversified food
system, and we need to put health first.
Mr. Duarte. Are we displacing our highly diversified food
system with commodity crops, farm policy, and biofuels?
Dr. Stover. And I would agree with that statement. I think
that that is driven by the incentives. We have to look at the
incentives that we have that farmers and ranchers are
businesspeople. They are going to make decisions based on the
business. If we want to use agriculture for health, we have to
get the incentives right?
Mr. Duarte. Dr. Rachidi? Thank you.
Dr. Rachidi. Yes, I would also agree with that, and I will
just say--I mean, you mentioned that you worry that we are
moving towards this diet of highly starch--I mean, we are
already there, right? Like, we--we have seen that happen, and
it is having devastating consequences on health for
individuals, but it is also hurting farmers because it is
changing production, it is changing how they farm, and it is
also hurting the Earth, to your point.
So, I completely agree with Dr. Stover that we need just
kind of a wholesale look at our food system, and certainly
incentives and disincentives that are put into the farm bill
play a big role in that.
Mr. Duarte. Thank you. I am also concerned that our green
energy, our movement towards biofuels, our movement away from
carbon energy, is limiting opportunity for the American working
family, that lower-income working families are having their
opportunities greatly limited because we can't power the grid.
We know that other economies that are growing faster than
ours have emerging middle and upper classes that are competing
with our working families for the produce, and protein, and
dietary diversity that we produce. I mean, not in California.
This is a global food system. In a global food system, the most
desired foods will go to who--those who can pay the most for
them. And do you share any concern that our--disadvantaging our
economic growth through certain green energy policies,
primarily, is hurting our working families, and indirectly
hurting their diet options?
Dr. Stover. So, my comment to that is we need to support
agriculture in all of its forms for reasons of innovation, and
to meet the needs of local communities. And so, in my mind,
this is more of a local governance, local economy effect,
where--what type of an agriculture system do you need for a
given nation, for a given state, that is going to best support
the goals of that individual state?
Mr. Duarte. Thank you. I think it is time for me to yield
back.
Mr. Finstad. Thank you. I now recognize the gentleman from
Illinois, Mr. Sorensen, for 5 minutes.
Mr. Sorensen. Thank you, Mr. Chairman. Like many other
Members up here, SNAP has served as an essential safety net for
my constituents, and boosts income for the agriculture
industry. That is why I do not support changes to SNAP that
will take away food from older Americans, children, families,
veterans, people with disabilities, in the farm bill or
otherwise. Cutting benefits would also harm our nation's
farmers, who are supported by programs like SNAP and incentives
within it.
More than 21 percent of households in my district in
western Illinois participate in SNAP. These are neighbors of
mine. They are children, they are veterans, senior citizens.
They are disabled, folks who are struggling, or just folks who
are down on their luck. It is our responsibility in Congress to
help people, not take the help away. And, unfortunately, many
eligible Americans don't even enroll in SNAP. And the U.S.
Census Bureau has found that one in six eligible Americans did
not participate in the program, and I believe that that is an
area where SNAP needs innovation, it needs modernization.
And so my question, I will start with you, Ms. Brown. Based
on your experience in Minnesota, what are some of the obstacles
that people face when they sign up for SNAP, and how have these
barriers affected your team's ability to be efficient with the
program?
Ms. Brown. Thank you for the question. Certainly,
technology has been a big conversation today, and I think
technology has not--we have not had a modern system across all
of our nation, and we have not been able to keep up, right,
with other technologies. And so certainly access is a barrier,
as folks try to apply for the program. Understanding that SNAP
is available to them is also a problem. And we face stigma
across the nation as well, and so, depending how the
conversation goes, right, folks may feel shame, and feel that
this isn't a program that they should be applying for when, in
fact, we do want folks to apply, and to be on the program to
stabilize, and move their way to economic self-sufficiency.
Mr. Sorensen. Do you believe that the need is greater today
than it was yesterday?
Ms. Brown. Absolutely. We are in a recovery period from the
pandemic, and folks that have experienced poverty and have been
through the pandemic need a longer on-ramp to reach self-
sufficiency and stability.
Mr. Sorensen. Thank you for that. Mr. Hodel, thank you for
your testimony, and for your commitment to our home State of
Illinois, and we share the same Congressional district. Your
testimony notes that your business model relies on donations
for food, financial support, volunteer efforts. Are we meeting
the need of our kids, of our seniors, disabled, and veterans in
need?
Mr. Hodel. Yes, I believe so, and the reason is we
distribute our food without discrimination, and we are very
inclusive, and very broad with our agencies. So, we are in the
wholesale space. We are not providing food to the food
recipient. That is why we work with our agencies. In Illinois
we have 550 agencies that are distributing food. I think that
is key.
As you talk about food access, those soup kitchens, those
churches, those local pantries in every town, they know their
community best. And so, what we do at Midwest Food Bank is we
make it very easy for them to come and receive food from us at
no cost, and then they go back and serve their communities. And
so, I believe they know their community the best, and they are
well positioned to serve and reach those outlying areas, as
well as--you mentioned the students, as well as the seniors and
veterans.
Mr. Sorensen. What do I say to the single mother in East
Moline, Illinois that works 25 to 30 hours of her day just to
be able to afford the childcare, and then she can't afford to
go to the Jewel--the grocery store at the end of the day--or at
the end of the week to be able to feed her kids?
Mr. Hodel. Yes, so for--I mean, she has a lot on her plate.
Like, I have done a poverty simulation, and she is getting kids
to childcare, she is trying to get to her job, she is trying to
get to different health appointments, and a lot of time she is
maybe using public transportation. I think your message to her
would be reach out in your community. Look for support. The
government has some programs that will help you, such as SNAP,
but it is an and. It is not an or.
So, to that single mother, you have SNAP, and you have food
pantries, and you have local organizations that want to help
support the community. I would encourage her to reach out and
look for support in her community.
Mr. Sorensen. I will ask the same question that I asked of
Ms. Brown. Do you feel that the need is greater today than it
was before? Do you agree with her on that?
Mr. Hodel. Yes. What we are seeing is the food insecurity
need is greater. You have reduced subsidies from the
government, and you have inflation. And it is really
inflationary driven, the--what dollars it takes now to fill a
gas a tank, or to pay your rent. It--we are definitely seeing
kind of an increase.
At the same time, our goal is to serve them for a season,
so we have definitely tried to increase our resources to be
able to serve this increased kind of spike, or inflection. But
our hope is that, through policies, and just through general
economics, that it will cycle out.
Mr. Sorensen. I agree with you, the need is increasing
today, which makes me question why anyone would want to make
cuts. I yield back.
Mr. Finstad. I now recognize the gentlewoman from Illinois,
Ms. Miller, for 5 minutes.
Mrs. Miller of Illinois. Thank you. Ms. Royal, I know you
have already talked about the National Accuracy Clearinghouse,
but can you speak on some of the differences, and how the
Clearinghouse was supposed to be implemented, and what the USDA
has done instead?
Ms. Royal. Thank you. The 2018 Farm Bill mandated the NAC--
the National Accuracy Clearinghouse to be utilized by all
states by December 31, 2021. In late 2021, as I said before,
that rug was ripped out from under us. So, there was a
determination made that personal identifiable information was
not being securely maintained in the current working NAC
project, and so a project--a new NAC was offered to be created
using GSA-18F to create this--the new NAC.
Several problems along with that, one being they didn't
even talk to the states that were currently using the original
NAC pilot, to use their best practices, the lessons that they
had learned while the pilot was being active.
Mrs. Miller of Illinois. Yes.
Ms. Royal. The other thing, too, is the new rollout is
2027. We have delayed it for a substantial amount of time. So
now we don't have anything to use until 2027.
Mrs. Miller of Illinois. So, since a clearinghouse has yet
to be implemented, then what do--how do states know if an
individual or a household is receiving multiple benefits in
multiple states?
Ms. Royal. We don't know. We don't have a database to make
that connection.
Mrs. Miller of Illinois. Do you believe this process is
effective for preventing duplication of SNAP benefits from
multiple states?
Ms. Royal. Yes, and there have been many reports indicating
that it has been very successful.
Mrs. Miller of Illinois. Well, thank you. I hope we get
this implemented ASAP, and I yield the remainder of my time to
Congressman DesJarlais.
Mr. DesJarlais. I thank the gentlelady. I ask the Chairman
to enter into the record a document from USDA Food and
Nutrition Services on SNAP policy for non-citizen eligibility.
And what it will do is clarify some of the questioning from
myself and Representative LaMalfa to Dr. Rachidi and Ms. Royal.
We had asked about eligibility for non-citizens under 18 and
asylees under Section 8208 of the Immigration and Nationality
Act. From USDA, it states, ``Non-citizens eligible with no
waiting period,'' and I think you said there was a 5 year
waiting period.
There are several in this category, but the two we focused
on were qualified alien children under 18 years old, and
asylees under Section 208 of the Immigration and Nationality
Act. So, I would ask unanimous consent to introduce this into
the record.\9\
---------------------------------------------------------------------------
\9\ Editor's note: the website snapshot of the USDA FNS page
entitled, SNAP Policy on Non-Citizen Eligibility, is located on p. 196.
---------------------------------------------------------------------------
Mr. Finstad. So moved.
Mr. DesJarlais. And so, I am not doing this to be
argumentative, but we are really trying to understand, with the
large number of immigrants that are coming into this country,
as we prepare to write the farm bill that already has 42
million participants, we could literally be looking at several
million new SNAP recipients, and we need to be prepared for
that. So that is why we bring up this question, and then--just
looking for clarification. And would either of you like to
comment?
Dr. Rachidi. No. Just I think what--my statement was that
that 5 year time limit did not apply to them.
Mr. DesJarlais. Well, I am sorry. I thought you said that
there was a 5 year waiting period.
Dr. Rachidi. Yes. No, sorry. Sorry if that was
misunderstood.
Mr. DesJarlais. I did misunderstand. Anyone else? Okay. I
yield back the remainder of my time.
Mr. Finstad. All right. I now recognize the gentleman from
New Mexico, Mr. Vasquez, for 5 minutes.
Mr. Vasquez. Thank you, Mr. Chairman, and I appreciate our
witnesses being here to discuss the nutrition title, and the
critical importance of SNAP. In today's hearing, I have heard
SNAP being talked about from different perspectives. We have
heard the words fraud, criminal activity, waste, identity
theft, prosecution. We have also heard compassion, our American
duty, health and opportunity, strengthening the middle class,
and our Christian duty, and our Christian values. Think that
says a lot about the value, and the different approaches that
we, as legislators, take to this very important program that,
in many cases, is the way to improve the lives of Americans.
Now, SNAP is not just a program that protects families from
hunger. In my district, I know that it is one of the most
important stepping stones to help lift families out of poverty.
This program helps people get ahead by helping to cover
critical food costs so that they can focus on the things that
many of my colleagues have talked about today, like vocational
training, finding a job, education, and eventually reaching the
middle class. I know one thing for sure, hungry people can't
work. Hungry kids can't learn. Hungry families can't raise
their children. And a hungry nation cannot prosper.
In New Mexico I served on the board of Casa De Peregrinos,
an emergency food bank in the City of Las Cruces, and I saw
firsthand the many reasons why kids and families need food
assistance. Losing a job, getting sick, divorce, and family
separation, situations that many Americans are going through
today. And I specifically chose to serve on the Agriculture
Committee to defend SNAP because it is that vital lifeline for
my constituents.
Now, last week myself, and many others who voted for the
debt limit bill, made it clear that we wouldn't accept changes
to this critical program, and we were proud to have this be a
bipartisan vote to expand SNAP benefits to veterans and to the
unhoused. But some of my colleagues are also aiming to cut the
program, and making a conscious decision that would directly
hurt the poor and working families, and I don't think we should
let that happen.
Mr. Hodel, as the CEO of a large food bank, what kind of
anti-poverty impact have you seen emergency food assistance
have on individuals who are served by both yourself and the
clients that you serve?
Mr. Hodel. Yes, thank you very much for the question. The
anti-poverty impact--I guess I would just go back to what we
hear from our agencies, when we visit our agencies, when we are
there for a loadout with their food recipients. We hear
stories, and we hear testimonies of individuals that went
through a hard patch in life, and they were blessed by
receiving food from their local soup kitchen, or their food
pantry. And they are super kind, to be able to translate that
back, and also thank Midwest Food Bank for providing that food
during that season.
And so, we get examples of individuals that are in New York
City, and they receive food after a difficult breakup, and they
are raising two children, and it is that food that has kind of
gotten them through a season to then get their education and
get jobs. And so, sometimes we take our groups out, and we are
able to bring those food recipients from the past in to share
their story to the people that we are trying to encourage to
support the work that Midwest Food Bank is doing. So, I would
say it is through kind of testimony and feedback that we get
through our agencies.
Mr. Vasquez. Thank you, Mr. Hodel, I appreciate that, and I
have heard many of those stories personally, serving in an
emergency food bank in the past, and how important these
oftentimes short-term solutions for families that are down on
their luck, how important having that food in their household
is for their kids, and also for their mental well-being.
In New Mexico, 12 percent of households are already food-
insecure, more than the national average. And Casa Del
Peregrinos, the CEO, who I just talked to recently, told me
that they are continuing to see an influx of new clients at the
rural pantries that have all echoed the problems my rural
constituents are facing, the cost of inflation, the cost of
gas, the cost of groceries that are much too high, and this
disproportionately impact people in underserved rural areas
harder than cities.
Now, one of the reasons that I think we are seeing an
increase in recipients of SNAP and other benefits is because of
the growing wealth inequality in this country. The less money
that people have in their pockets, although they may be
employed, although they may be working those minimum wage jobs
that we want Americans to take, it still doesn't stretch far
enough to pay utilities, to pay insurance, God forbid somebody
gets sick.
And so, I think some of the solutions behind why folks need
food assistance, and need to enroll in a program like SNAP, has
to do with the power of reducing wealth inequality in this
country, which is a discussion we can, and will, continue to
have, I am sure, in other committees, and in Congress. I yield
back.
Mr. Alford [presiding.] The gentleman's time has expired.
The chair now recognizes the gentleman from Texas, Mr.
Jackson.
Mr. Jackson of Texas. Thank you, Mr. Chairman. Thank you to
the witnesses for coming today. I appreciate you being here.
These nutrition programs are meant to be a hand up for the
neediest Americans, yet time and time again we see cases of
criminal organizations skimming and then trafficking SNAP
benefits from the true individuals that these programs are
intended to help. Just last week three people in Michigan were
arrested for stealing more than $4 million from people more
than 2,000 miles away, in California. Mr. Chairman, could I
please submit for the record the article from the Washington
Examiner entitled, Michigan Catches $4 Million of Food Stamp
Fraud; Mum on the Fraud Scope?
[The article referred to is located on p. 137.]
Mr. Alford. Without objection.
Mr. Jackson of Texas. Thank you. Ms. Royal, in your
testimony you mentioned how SNAP benefits are a target for
identity thieves due to siloing and restriction on recipient
data sharing. Could you please share with us how we could
address these data sharing deficiencies to help combat these
criminal organizations?
Ms. Royal. Sure. We just need a readjustment of the
regulation, or a reevaluation of the regulation. SNAP is one of
the few Federal programs left that has the limitations and
restrictions in it to share information, so a reevaluation of
that, reconsidering the opportunities that states would have to
provide that critical information to law enforcement and other
agencies.
Mr. Jackson of Texas. Thank you. Recently USDA released a
request for applications for their Supplemental Nutrition
Assistance Program Fraud Frame Implementation Grant Program.
This program is expected to award nine different applicants
with up to $750,000 to proactively detect fraud beginning in--
at the application process and continuing throughout the
recipient's time in SNAP. Projects eligible for this grant
include efforts to detect potential fraud at the time of
application.
Ms. Royal, in your testimony you mention that no date of
birth, no Social Security Number, identification, or driver's
license is needed to access the system. Without these
identification requirements, I am not sure how any of these
grant award winners will be able to detect potential fraud at
the time of application. Ms. Royal, could you explain how
requiring a Social Security Number on SNAP applications would
help to limit fraud and abuse, while not imposing an additional
condition of eligibility?
Ms. Royal. We use the Social Security in many different
mandated ways. If somebody is disqualified in the program,
states are required to enter that information into a national
database, and we do that with name, date of birth, and Social
Security Number. And that is important. When somebody is
disqualified, depending on whether it is the first, second, or
third offense, or specific types of trafficking, depends on
what the penalty is. And so, for instance, if somebody is
disqualified in Missouri, they come later, commit an
intentional program violation in Wyoming, it would be important
for me to have that information to make sure that I request the
specific--or the accurate penalty. So, we use it for eDRS.
We use it for death match certification. Again, the Social
Security Number is such a critical element to the different
types. Asset verification. I mean, there is certainly a long
list, as was provided in our written testimony.
Mr. Jackson of Texas. Thank you, ma'am. That helps a lot.
Dr. Stover, change of subject just a little bit. In your
testimony you state that the new Texas A&M Institute for
Advancing Health Through Agriculture in the world's--is the
first research institute to bring together precision nutrition
and responsive agriculture research. I know you mentioned this
also in your opening statement a little bit. This links food
production to human consumption, thereby improving public
health, and lowering healthcare cost. This is just the latest
example of some of the impressive work being done at Texas A&M,
and at the Texas A&M University system.
Dr. Stover, I know you mentioned this briefly, but could
you please expand on how the work you are doing at IHA could be
used to develop a more realistic and usable dietary guideline?
Dr. Stover. Certainly. We have established, in Fort Worth,
the world's first agriculture food and nutrition evidence
center. In the medical field, there is no controversy whether
aspirin is good for you or bad for you. There are accepted
methodologies to look at the totality of the data, to combine
that data, and then to say what the answer is, whether it is,
where there is a question about a policy, a practice, a
guideline, and to say how strong the data is, how confident you
can be in the science to make a decision that you know will be
effective. Policy, or program, what have you.
We do not have that in food, agriculture, and nutrition, so
we have partnered with international consortia, the World
Health Organization, FAO to begin to get set standards of
evidence and methodological rigor into how we combine data, how
we analyze data, how we present that data to decisionmakers
like yourself so that you have the ability to consider what the
scientific evidence is, and how strong it is, so you can be
more certain in the decisions you make.
Mr. Jackson of Texas. Thank you, sir, I appreciate it. My
time is up. I yield back. Thank you.
Mr. Alford. Thank you. And we go from Jackson of Texas to
Jackson of Illinois.
Mr. Jackson of Illinois. Hey, hey. Thank you, Mr. Chairman.
Thank you, Ranking Member Scott. It was 59 years ago the
Reverend Martin Luther King said that he had the audacity to
believe that people everywhere can have three meals a day for
their bodies, education and culture for their minds, and
dignity, equality, and freedom for their spirits. Such a belief
shouldn't be an audacious thought. Ensuring no American goes
hungry should not be controversial. That is why I will not
support any bill that further tries to reduce food assistance
and benefits to low-income households.
Cuts to SNAP harms our nation's most vulnerable, including
children, families, older Americans, and those with
disabilities. Just 59 years ago those powerful quotes were
shared, and here we are, 59 years later, looking at 42 million
Americans, including 15 million children, five million seniors,
and a million two of veterans, that are needing this
Supplemental Nutrition Assistance Program.
I am deeply concerned that, instead of addressing our
nation's persistent food insecurity, some people would like to
suggest we should police the purchase of SNAP recipients. And
it was in that same season in 1968 when Reverend Martin Luther
King had the same thought, and his last moral mission was to
declare a war on poverty. And now it seems as if we are
engaging in a war on the poor.
Restriction schemes that stigmatize program participants
who are equally as capable of picking what foods they want to
eat as each and every one of us, and would result in massive
administrative burdens for USDA and retailers, ultimately
increasing program costs, and making SNAP incredibly difficult
to operate. When we start policing these food programs
unnecessarily, it will run up the administrative costs. Right
now, SNAP is an incredible example of a partnership that
operates within the free market, allowing recipients to
purchase the foods that they determine will serve their
families best.
I would like to direct my comment, or if you will, my
question. To Ms. Brown. Ms. Brown, in light of--if there were
increased restrictions placed on the policing of this food, how
will that affect the retailers and families?
Ms. Brown. Thank you for the question. Retailers would need
to completely overhaul their system. They are not equipped
right now to separate out different types of food to meet any
type of restrictions, so it would be a massive load for our
retailers to manage. I also want to point out, as we think
about restrictions on food for SNAP participants, USDA has a
program, SNAP-Education, that provides education, focuses on
families with a limited budget, and focuses on physical
activity. This program exactly meets the needs of folks worried
about the health choices that SNAP recipients are making.
Mr. Jackson of Illinois. Let me ask you, if there were more
benefits, if we raised the eligibility and increased the
benefit lowered the eligibility and raised the benefit, how
would that improve health in our nation?
Ms. Brown. So anytime, so, again, supplemental. The program
is Supplemental Nutrition Assistance Program, so $110 in
benefits are received per person per month. That is not enough
to meet anybody's food needs. And so, by raising the SNAP
benefit, it will decrease health costs. All of our studies in
our state, as we have looked at the costs on health, and the
ongoing impacts of poverty on all of our systems, indicate that
more benefits will decrease health costs.
Mr. Jackson of Illinois. My last question, these numbers
move around. People are saying food insecurity. I take it that
means hunger?
Ms. Brown. That is true.
Mr. Jackson of Illinois. Okay. Hunger. I would prefer to
use that term.
Ms. Brown. That is right.
Mr. Jackson of Illinois. And then you are talking about
$110 a month in benefits. We have heard of $2 per meal per
participant, $6 a day. Can you explain the discrepancy?
Ms. Brown. So, it would depend per state. So the $110 per
month is specific for my state, and so it really depends on the
variety of folks that you have that are participating in the
program. So, you may see some variance in the dollar amounts,
but bottom line is it is not enough to--in any way, the per
month or the per day isn't enough to feed people.
Mr. Jackson of Illinois. So, it can go from $3 per day in
your state to as high as $6 a day for a participant in another
state, correct?
Ms. Brown. It could, correct.
Mr. Jackson of Illinois. Thank you very much. I thank each
of the panelists for your participation, and willingness to
come forward. I yield back my time, Mr. Chairman.
Mr. Alford. Thank you, Mr. Jackson. The chair now
recognizes himself for 5 minutes.
The relationship between the farm bill titles is symbiotic.
It all works together to accomplish these goals that I think my
fellow Committee Members and I can all agree on. Number one, to
make sure our farmers and ranchers have reliable access to risk
management programs to ensure that they can feed, fuel, and
clothe the world. Number two, to make sure our nation is fed.
And number three, to make sure we are good stewards of God's
creation.
These goals are all dependent on each other. Without our
hardworking farmers and ranchers we can't feed our nation, and
SNAP recipients are part of the market. If we can't feed our
nation, we cannot be productive citizens. We don't have the
healthy workforce we need, and our economy and society will
suffer. And if we are not good stewards of God's creation
through conservation and good farming and ranching policies, we
will not be able to efficiently grow the food needed to feed
our nation and the world.
Twelve percent of this year's farm bill will go to
agricultural production programs. Five percent will go to
conservation programs; 81 percent this year will go to SNAP.
Since 2015, this Committee has had 39 hearings on Supplemental
Nutritional Programs. We care. We all care in this room. This
should not be a Republican issue, this is should not be a
Democratic issue. This is an American issue. And using harmful,
and misleading, and inflammatory rhetoric is neither productive
nor helpful in us all doing the right thing.
There is no reason that an able-bodied American with no
dependents should not be either looking for a job, working,
volunteering, or being part of a job training or search
program. There is no reason that farmers and ranchers should
not have the risk management programs they need to succeed. But
there is also no reason that a nation as great as ours should
let citizens who are truly struggling to find their next meal
and feed their family go hungry.
I believe firmly that we must return nutrition to SNAP. We
must make sure we limit the fraud and abuse in the system. We
must ensure that we are not enabling able-bodied citizens and
making them dependent on the government, but instead bolstering
them for success and self-worth. SNAP should be a life vest,
not a lifestyle. But most importantly, we must all tell the
truth, and cut the harmful rhetoric designed to stoke fear,
anger, and divisiveness in America.
With that, I want to get to our questions. This one is for
the panel. How long is the average recipient on SNAP? Does
anyone know? Yes, ma'am?
Ms. Brown. In our state, depending on the population, we
see it range from 24 months to 72 months on average.
Mr. Alford. How do we make sure that this does not become a
lifestyle, Doctor? How do we make sure that SNAP does not
become a lifestyle, and it is a life vest for Americans?
Dr. Rachidi. Is that question to me?
Mr. Alford. Yes.
Dr. Rachidi. Well, I think having an employment component
in SNAP, making employment a big part of SNAP, that is intended
to be a temporary program, and employment really is the path
out of poverty. I think sending that message is a crucial one.
Mr. Alford. In your testimony you talk about the positive
outcomes consistent and sustained employment has on families.
What does that do for the psyche, having a job, even
volunteering? What does that do for a recipient to help move
them in the direction forward?
Dr. Rachidi. Well, there is a very large literature on the
nine financial benefits of work. It improves mental health,
improves physical health, it builds social capital, it builds
connection to the community, it has positive effects on
children. So, yes, there is a very large literature that
employment not only helps the financial security of a
household, but it helps all sorts of other things as well.
Mr. Alford. Mr. Hodel, we are spending more taxpayer
dollars on nutrition support than ever before, yet the rate of
food insecurity still hovers about ten percent. Where is
innovation lacking, and where do opportunities lie for new ways
to invest in these programs?
Mr. Hodel. You--great question, thank you. I think, again,
across the supply chain. In the food bank business we are in
the supply chain business, and so I think innovation, all the
way from working with retailers, food manufacturers,
distributors, transportation, warehousing--and so, again, that
is where we have tried to be creative in getting multiple
sources, and then multiple channels to get the food moved to
our different food banks. And then, also, on the----
Mr. Alford. Thank you, sir. To be fair, my time has
expired. I appreciate everyone on the panel. Next let us go to
Congresswoman Pingree.
Ms. Pingree. Sorry. Equipment. Thank you very much, Mr.
Chairman, and thank you to the panel. I appreciate all the time
you have put in today, and I feel very privileged to have had a
chance to listen to so much of the testimony. I just want to
emphasize the thing that always strikes me, having worked on
this issue for many years. We are in the wealthiest country in
the nation. We spend hours arguing whether or not people
deserve food. That is why we are here again today. This was the
argument that held up the debt limit. We are now talking about
doing even more in the farm bill, and I am fully opposed to
doing any more in this farm bill that would restrict people's
access to healthy foods.
I represent a very small rural state, one of the most rural
states in the nation of only 1.3 million people, yet 23,000
people--23,000 households are on SNAP in my district every
month. Statewide we have 145,000 members, including more than
46,000 children who need access from SNAP. It is critical,
given the fact that Maine has the highest rate of childhood
food insecurity in New England.
We are talking about ways to cut SNAP, but it is becoming
even more of a lifeline as families feel the impact of
inflation and higher food costs, which disproportionately
affect those people with lower incomes. The share of American
adults who reported being in a worse financial position in 2022
than during the previous year rose to 35 percent, with
inflation being the financial burden cited by most respondents,
according to the Federal Reserve.
Now, again, we are talking about constraining this program.
We are talking about trying to require more people to be
working, and acting as if it is the constraint of the program.
The fact is, there are not enough childcare slots for people.
There isn't adequate housing. There isn't always adequate
transportation in rural areas. Those are all constraints on
working, and we treat it as if it is somehow the product of
SNAP.
I hear my constituents talk about these concerns every day,
food, gas, housing, and how that contributes to their inability
to buy food. And we also talk as if we have forgotten that the
situation that was, I grant you, getting better, it has been
getting worse since we had the pandemic. Supply chain
shortages, the war with Russian and Ukraine, all things that
have driven up food prices and made it that much more difficult
to provide a healthy meal for $2 a meal, $6 a day, as we have
been talking about.
And I appreciate the testimony. Dr. Rachidi, you talked a
lot about the constraints of SNAP for people's ability to get a
job, but I disagree. I believe it is outside factors that makes
it very difficult. It is also not people's bad choices,
necessarily, on what they put in front of their food. I agree
people need more healthy food, but it is very hard to provide
food on $6 a day per person. A gallon of milk is nearly $5.
We want to see people eating more fresh fruits, fresh
vegetables, healthy proteins, which is why we should be talking
more today about the GusNIP program, about produce
prescriptions, about all things that we could do to get more
healthy food on the table.
The other thing that I find really distressing about today
is we are talking about making more cuts, more restrictions.
Well, when 170,000 Mainers lost SNAP emergency allotments in
March, $17 million a month was drained from our state's
economy, and taken away from hungry families. We have already
made severe cuts. People are already reeling from what we have
done, and now we want to talk about doing more?
We also are going to talk about the impact that it has on
our rural economies. During economic downturns, every $1 in new
SNAP benefits generates $1.50 in economic activity. And we have
heard people talking about how difficult it is, in a rural
community, to get access to healthy food, and how important
that return is to our community.
I recently met with Good Shepherd, one of our state's
largest food bank--our state's largest food bank. They are
sending me photos of empty pantry shelves. USDA trucks carrying
900 cases of milk to Good Shepherd pantry partners used to take
48 hours to distribute. That is what they told me. Now the
demand is so high that offloading cases takes under 3 hours.
Preble Street Food Security Hub in south Portland is seeing 100
percent increase in demand from March 2023 back to 2022. They
are providing 800 boxes a month, compared to 400 in March of
2022 and previous months.
Clearly, I am going to use up all of my time ranting about
this, but the fact is we are here today to talk about making
more cuts, to making it more restrictive, to making it more
difficult, and I can't say it enough, this is the wealthiest
country in the world. We have plenty of policy to worry about.
We have plenty to debate. But it should not be whether or not
people can put food on the table. I yield back.
Mr. Alford. Thank you. The gentlelady's time has expired.
We now go to Mr. Nunn of Iowa.
Mr. Nunn. Thank you, Chairman Alford, and the gentleman
from Missouri. I am privileged to be here with so many
Midwesterners. And, Mr. Hodel, I would like to begin with you,
because you have really been feeding and caring for so many in
the heartland, which we are incredibly grateful, in my home
State of Iowa, to see what you do both in our urban areas, our
suburban areas, but particularly across my 21 rural counties
that are in desperate need of just the leadership that you are
providing in this space.
One of the things I want to highlight here is that I think
we all agree, we very much want to be able to care for folks.
This is one of the reasons the farm bill is so important. I
want to focus in here on The Emergency Food Assistance Program,
TEFAP. In FY 2022 $1.17 billion were allocated to this, and a
majority of it goes to Feeding America, a government-backed
organization. They do some really great work.
But for your organization, you operate with a very small
budget, and distribute more than $400 million in food without
any of this help. I would like to hear some of the really
incredible efficiencies you have led, and some of the
innovation you talked about, and maybe we on the Federal side
here need to replicate what the food bank is doing.
Mr. Hodel. Well, thank you for the question, and the
compliment. It is an honor to serve Iowa, as well as our other
states. Again, I go back to, our founder started this 20 years
ago with really the mission of--we need to serve our
communities. And there have been some Bible references today,
which I appreciate, but the Bible does call us and reminds us
that the poor will always be with us.
Mr. Nunn. That is right.
Mr. Hodel. And so, one of the things is--I stepped into
this job 6 years ago that I had to kind of think about and
learn is, like, we are probably not going to eliminate this,
but we need to figure out how do we best solve. And, again, it
is for a season. The poor will always be with us, and I don't
think there ever will be a--not a need for food banks, or not a
need for programs.
The innovation side of it, again, I go--I point back to our
model. We have really focused on a business model of high
efficiency. A period cost walks in on two feet every day, and
so we are very cognizant about the leadership and the staff
that we have at each location. Each one of our food banks I
talked about runs about a $2 million operational budget. There
are five staff members. And any--I love going and walking
somebody through our warehouse, and I will give a tour of what
we are doing, and we will run into 50, 60, 70 people, and I
remind that group that we are with that five of these people
that you just saw are staff members, the rest are volunteers.
So part of that model is core volunteers. We are blessed
with people that retire at 50, 55, 60, and they are still
capable mind. And some choose to go to the gym to work out,
other choose to come to Midwest Food Bank and to give of their
time, and to lift boxes.
Mr. Nunn. Also work out.
Mr. Hodel. And so that core volunteer is a key model for
us, and I think that helps our efficiency, kind of helps our
leverage. And what we have been able to do is build a model
that works, and then scale it as we have gone to different
locations. So, we very much know that Illinois is Illinois, and
Texas is Texas, and Arizona is Arizona.
People ask us why we are called Midwest Food Bank. It is
because our founder, again, 20 years ago, was trying to think
big, and didn't call it McLean County, or didn't call it the
Central Illinois Food Bank. He says, we will call it Midwest,
because we surely won't outgrow that. And so, God had different
plans for the organization, but I think our core volunteers,
our volunteer model, as well as just--again, the culture of--
we--we will say yes, and then we will figure it out.
Mr. Nunn. Mr. Hodel--well, compliments, and I think--please
continue to share those best practices with us not only across
the country, for the volunteers who do it, but for the Federal
agencies that could really use you, as a template on how to do
this right.
Very quickly, Dr. Rachidi, I want to talk about our nation
experiencing an alarming increase in diet-related diseases
among children. I have six kiddos, two of them are foster kids.
They went through a long process of really needing that hand up
that was just talked about, but also the ability to survive on
this in a healthy way. How can we in Congress remain focused on
enhancing the nutritional and educational aspects of healthier
eating habits in the upcoming farm bill?
Dr. Rachidi. I think that is a good question, and you are
correct that the diet-related disease among children, diabetes,
obesity, is actually a larger problem than hunger. Less than
one percent of children have very-low-food insecurity; 20
percent have obesity. So, I think that that should be the
priority in the farm bill, is how do we get healthier food into
the mouths of children?
Federal Government does that through the National School
Lunch Program, places very restrictive restrictions on what can
be served in schools. I think they should take--maybe not quite
to that extreme, but a similar approach with SNAP in ensuring
that the program actually supports nutrition, and does not
allow unhealthy products to be purchased through the program.
Mr. Nunn. Dr. Rachidi, thank you so much. Thanks to the
panel today, and I yield back my time.
Mr. Alford. Thank you. The chair now recognizes Mr. Casar
of Texas.
Mr. Casar. Thank you. Today we are discussing SNAP,
otherwise known as food stamps. I had some remarks planned, but
now I feel like I have to change what I was going to say,
because I just have to disagree with the gentleman chairing the
meeting who said he wanted SNAP to be a life vest, not a
lifestyle, implying that people could be living large on their
food stamp benefits. To be clear, SNAP provides people $2 a
meal, overwhelmingly to kids, working people, and seniors. You
aren't living some kind of extravagant lifestyle on the few
bucks you get to buy groceries.
If my Republican colleagues want to talk about wasteful
government welfare that lets people live large, then we should
be talking about tax breaks for yachts. We should be talking
about the multitrillion dollar Trump tax scam that
overwhelmingly benefits the richest .1 percent of 1 percent,
and the biggest corporations.
We have been told that folks on my side of the aisle have
been using potentially inflammatory rhetoric, but this is
personal. We are talking about families that are working really
hard, and just need a few extra bucks to eat. We are talking
about families in my district in San Antonio that are working
part time. They are also taking care of aging parents and their
kids. Maybe they can't get to that 20 hours a week worth of
work, and they could lose the little benefit that they get,
that they pay for in their taxes.
Speaking of things being inflammatory, I still think it is
inexcusable that the entire nation's debt ceiling, a threat of
default, part of those negotiations that we never should have
been having over whether America should default or not, were
about some 53 and 54 year olds having a harder time getting
those $2 a meal. I personally believe that that is what is
inflammatory.
But we don't have to be in that divisive place. Instead, we
should listen to our food banks, and to our social service
providers that help every single day, who are asking us to make
it easier for folks to get this benefit, be able to get a meal,
and be able to get to work and provide for themselves and for
their families.
In my own district I am hearing from small farmers who are
struggling in drought conditions to get by, but these Federal
food assistance programs help them make sure they get their
food to market, make sure they get their food to folks who need
it the most, and help keep them afloat. I hear even from big
retailers, like, H.E.B., one of this company's biggest private
company--one of this country's biggest private companies,
asking and pushing to protect these basic nutrition benefits
that we know help farmers, help retailers, and help those
families.
And so, Ms. Brown, if you could talk just a little bit
about what it is that we can do to reduce the governmental
paperwork that folks have to get through when they truly do
qualify for the program, how we can find savings on our end,
but ultimately benefit those folks that the SNAP Program
intended to benefit in the first place?
Ms. Brown. Thank you for the question. I am a big fan of
simplification, right? We have a lot of bureaucracy that we
deal with, policies and procedures, and so any ways that we can
simplify some of the requirements, make it easier for
participants, make it easier for states to administer the
program, I think overall is a win.
I will give you an example of a time-limited SNAP recipient
who didn't have access to reliable transportation, lived in a
rural community, and wasn't able to get to the employment and
training provider, and there weren't enough jobs in his
community. And so, he was unable to meet the work requirement
because of circumstances outside of his control, and will only
receive 3 months of benefit. I don't think that is the intent
of the program. We need to be able to feed people, and meet
their nutritional requirements, while taking into consideration
some of the barriers that they face.
And so, one example that would be really beneficial is to
exempt training income. We have a lot of folks that want to
provide training, and build up people, and if they give them
income as an incentive, that counts against them, and it
reduces their SNAP benefit, or eliminates it altogether. So,
there are a number of ways we can simplify the program, and
make it easier for it all to work.
Mr. Casar. Thank you so much. As we begin moving forward on
the farm bill, I look forward to supporting a bill that feeds
more families, that supports more of our farmers, and I won't
support legislation that takes food away from those low-income
households. Thank you.
Ms. Brown. Thank you.
Mr. Casar. I yield back.
Mr. Alford. Thank you, sir. The chair now recognizes the
Cheese King from Wisconsin, Mr. Derrick Van Orden.
Mr. Van Orden. Thank you very much, Mr. Chairman. I was
raised in abject rural poverty by a single mother, and we were
on food stamps. To answer the question that you are thinking
about right now, they were not written on papyrus. I am not
quite that old. I had subsidized lunches. I had government
cheese. I was being shot at, literally, as a Navy SEAL in
combat, and my wife and I used WIC to help feed our children.
Mr. Molinaro from New York shares a similar story.
So, I will not sit here and be lectured by people who have
not walked the walk that I have. I will not. I volunteered to
be on the SNAP Committee because I think these programs are
incredibly important, and to say that Republicans are trying to
snatch bread out of people's mouths is inflammatory, it is
disingenuous, and it is not helpful. And I am going to call a
truce after I do this.
It took less than a second for me to find a job in Sparta,
Wisconsin, an entry level position that paid $14.07 an hour.
The $7.25 is ridiculous. So, I am going to ask my colleagues to
stop it, and I will also, okay? Enough. Let us work for the
American people and not try to legislate by sound bites.
Inappropriate.
Ma'am, Dr. Rachidi, I am not sure that I agree with you
dictating what people should be eating. I just don't. I think
it is inappropriate. We are trying to get whole food, or whole
milk back into schools, and the reason it is not there is
because it was removed by a previous Administration, so I am
not a fan of the government dictating to people what they can
and cannot eat.
They say that we already provide microwavable foods to
folks. Well, guess what? When I was growing up, we were too
poor to have a microwave. I could take you to places in
Baltimore right now, or within a mile and a half of this room,
and they don't have a microwave because they can't afford it.
Or they are latchkey kids, and they don't know how to prepare
food. So, I don't want to mandate what people can and cannot
eat. I think that is inappropriate. I do agree with the rest of
the stuff you are saying, but--just so you know.
Ms. Brown, are you aware that last September it was
revealed that Feeding Our Future, a Minnesota-based nonprofit,
allegedly exploited USDA child nutrition programs to defraud
the American taxpayers of over $250 million intended to feed
hungry children during COVID-19.
Ms. Brown. I am aware. That was with the Department of
Education, not the Department of Human----
Mr. Van Orden. Yes. I understand. Similar program. So can
you admit that fraud does exist in these programs?
Ms. Brown. Well, absolutely.
Mr. Van Orden. Okay.
Ms. Brown. I think there are bad actors----
Mr. Van Orden. Right on. Everywhere, right. So, we can't
legislate by exception, correct?
Ms. Brown. Say that again?
Mr. Van Orden. We can't legislate by exception.
Ms. Brown. Well, absolutely.
Mr. Van Orden. All right. And G.T. Thompson says that he
really wants these programs to be a hand up, not a handout. Do
you agree with that?
Ms. Brown. A hand up, not a handout?
Mr. Van Orden. Yes.
Ms. Brown. I believe that the SNAP benefit is incredibly
beneficial to people.
Mr. Van Orden. Yes. I am 100 percent with you. So, with
that in mind, how many people have been raised out of poverty
that have used your programs?
Ms. Brown. I don't have any of the stats in front of me,
but we can certainly send that to you afterward. I know that
there are numerous studies that indicate childhood poverty has
been reduced by the receipt of SNAP.
Mr. Van Orden. Okay. Well, I would like to see those
numbers, because I am a Member of Congress now because of these
programs. I take this very, very seriously. Mr. Hodel, I would
posit the reason that your programs are so incredibly
successful is specifically because you do not receive any
government funding. Do you concur?
Mr. Hodel. That has been our business model, and it has
been part of our success.
Mr. Van Orden. Okay. So out of all the things we have
talked about, all these incredibly important programs, we have
one example here where your ROI is--blows it out of the water.
So, you are involving the community in a Godly fashion to help
our fellow citizens, our neighbors, in a way that is incredibly
productive, and it has zero involvement with the Federal
Government?
Mr. Hodel. Yes sir, and I will just--we do have some
involvement with the government.
Mr. Van Orden. Is that correct?
Mr. Hodel. When you say zero--for example, we received
Farmers to Families Food Boxes. So I just want to acknowledge
that that was a government program benefit to us.
Mr. Van Orden. Okay. Right on.
So you have minimal involvement with the Federal
Government?
Mr. Hodel. Very, very minimal.
Mr. Van Orden. Okay. Well, I am very proud of you. And I do
appreciate the Christian sentiment by my brothers and sisters
here on the Committee. I too am a Christian, and, you are
right, the poor will always be with us, but that doesn't mean
we don't try helping them on a daily basis, so thank you very
much for your work, everybody. With that, I yield back.
Mr. Hodel. Thank you, sir.
Mr. Alford. Thank you. I now recognize the gentleman out of
California, Mr. Carbajal, for 5 minutes of questions.
Mr. Carbajal. Thank you, Mr. Chairman. Last week's debt
ceiling vote saved our country from a catastrophic default. As
a result of that negotiated deal, additional work requirements
were placed on SNAP. I want to make it clear I am not inclined
to support any farm bill that will take food away from low-
income households. I will not support a farm bill that does
that.
Cuts to SNAP harm our nation's most vulnerable, including
children, families, older Americans, and people with
disabilities. As someone whose family depended on SNAP when I
was young, it is disconcerting to hear the over-obsession by
some who have--about the specifics about what low-income
Americans buy and eat. Wanting to monitor the specific
nutrition intake choice of families who are food-insecure is
demeaning, demoralizing, and unfounded.
Studies have shown that SNAP recipients purchase
essentially the same foods at the same rates as other
Americans. It is always those with the least who we are most
obsessed with, taking their autonomy away, and wanting the most
government intrusion into their lives. Nutrition and healthy
eating are challenges that we are all struggling with.
Regardless of class and income, we should all eat more
nutritiously.
But those with the least are also the least able to afford
fresh produce, and other times intensive healthy foods that
take a lot of energy and know-how to cook. I, for one, am a
terrible cook. Again, we all share the goal to promote good
nutrition and nutrition education.
While we already do that, there is definitely room to do
even more. So let us focus on ensuring we are accomplishing
that goal, and work together to support expanding and improving
GusNIP, which helps low-income families afford nutritious food,
and SNAP-Education, which teaches families about nutrition, and
how to cook nutritious foods they might be intimidated by
because they have never bought them before.
Ms. Brown, as someone involved in the administration of
SNAP, can you speak to the incredible burden restricting SNAP
purchases would have on states and recipients?
Ms. Brown. Thank you for the question. Absolutely.
Restricting any benefit, and any of the food choices that folks
are able to make, would be incredibly burdensome not only for
retailers, but also for recipients themselves. We have worked
really hard over the years to reduce stigma in the program. The
EBT card actually helps with that. We don't have the paper
coupon, the stamps, that make it really visible. The EBT card
looks exactly like a credit card, and so folks don't feel
ashamed to utilize the benefit when they need it the most.
Restricting foods would require separation on the grocery cart.
It would very much signal to folks around them that this is a
SNAP recipient and can only buy certain foods.
Mr. Carbajal. Thank you. Studies that track the impact of
SNAP on the physical health of recipients find that
participation in the program is linked with positive improved
nutritious outcomes, lower healthcare costs, and improved
current and long-term health. However, prior to 2021 Thrifty
Food Plan re-evaluation, the Urban Institute found that SNAP
did not cover the cost of low-income meal in 96 percent of U.S.
counties, with both urban and rural counties seeing the highest
disparities, and USDA's Economic Research Service estimated
that 49.7 percent of SNAP households were food-insecure in
2019. Ms. Brown, do you think that the 2021 Thrifty Food Plan
re-evaluation, and the resulting benefit increases, are
furthering SNAP's positive impact on the health and well-being
of its beneficiaries?
Ms. Brown. I absolutely do. It was long overdue, and we are
really excited to see some of those increased benefits show up
with our participants. I also will note that inflation has
greatly increased, and we need to balance benefits, and
continue to work on the Thrifty Food Plan to keep up with the
market prices.
Mr. Carbajal. Thank you. Mr. Chairman, I yield back.
Mr. Miller of Ohio [presiding.] Thank you. The chair now
recognizes himself for 5 minutes of questions. Thank you for
holding this important hearing as we seek to provide long-term
economic and nutritional security to those challenged in our
nation. It is my fundamental belief that everyone deserves the
chance to shape a stronger future for themselves and their
families. At the same time, we must provide access to the long-
term tools to address food insecurity, and ultimately build a
better life for those in need.
First, I would like to call attention to the important work
of the Ohio Association of Food Banks, including the Greater
Cleveland Food Bank, and Feeding Medina County, through public
partnerships with 3,600 hunger relief organizations across my
state. Last year the Greater Cleveland Food Bank provided 10.8
million pounds of food to families in need, including 94,000
children. Similarly, the Feeding Medina County Food Bank, among
other efforts, must--helped must--needs of underserved older
citizens across the region.
The agricultural community also plays a key role in
addressing hunger, including in my state, through the
Agricultural Clearance Program, providing wholesome food to
families struggling with food insecurity, while enabling a
meaningful outlet for farm goods. As a nation, we owe it to
these individuals to identify policies aimed at helping low-
income families achieve the type of opportunity that every
American deserves.
By providing greater access to workforce training,
education, employment placement, and job retention services, we
can empower individuals to build a foundation for a stable,
productive life for themselves, and a road map to achieve a
long-term goal of self-sufficiency. That is why I was proud to
co-lead Training and Nutrition Stability Act, H.R. 3087, with
Committee Members Alma Adams and Mark Molinaro, along with
Adriano Espaillat, to ensure those in workforce training
programs are able to maintain access to nutrition benefits
while completing employment training programs to bolster
economic security.
Our bipartisan bill would ensure job seekers and programs
authorized under the Workforce Innovation and Opportunity Act,
and the Supplemental Nutrition Assistance Employment and
Training and Vocational Rehabilitation Programs, may leverage
job-driven training programs' dollars and maintain them
nutrition benefits, leading to long-term employment and
economic stability.
Toward this end, I would like to recognize the work of
training facilities across the country, including the Center
for Employment Opportunities, operating in the State of Ohio,
as well as Pennsylvania, Georgia, and many other regions
through bold innovation, helping underserved access employment
opportunities through on-site workplace training, jobs
placement retention, enabling pathways to long-term sustainable
career opportunities.
Participants, like Mr. Rice in my district, demonstrate
that SNAP E&T can work. After gaining work-based learning on a
transitional job through local partnerships with employers to
provide work experience and training to challenge participants,
he learned skills, was hired full time, and he is now building
a foundation for the future.
Dr. Rachidi, you note in your testimony SNAP must
accomplish its core goal of supporting Americans in their path
out of poverty. Can you please share your perspective on the
critical nature of providing access to job training, including
the importance of provisions within the Training and Nutrition
Stability Act, to allow those in critical Federal workforce
training programs to maintain food security and engage in
employment training to assist individuals toward long-term
security?
Dr. Rachidi. Thank you for the question. I do think
employment training is a crucial component of SNAP. In New York
City, when I was there, we ran a very robust employment and
training program. Part of the problem, though, is there are
many employment training programs in SNAP that are not very
robust and not very effective. So, I think that while there is
a role, the Federal Government could do a better job in holding
those programs accountable for achieving results that actually
do help people get employment and put them on a path towards
upward mobility.
Mr. Miller of Ohio. Thank you. Mr. Hodel, in your testimony
you stated alleviating hunger and malnutrition is a complex
challenge requiring a multifaceted solution. How can Congress
best enable and leverage public-private partnerships to meet
the needs of underserved citizens, and what is the most
effective role for the agricultural community to play in
getting wholesome goods from the farm to those in need, and
what barriers do you see in meeting these challenges ahead?
Mr. Hodel. Yes, thank you. Great question. Again, I think
about it as a mathematical equation. It is an and, right? We
have individuals that are purchasing food, and they get food
from the food banks, and they have SNAP. And I think what are
the best programs to figure out the total equation?
I would strongly endorse Farmers to Families Food Boxes.
The exception, or the difference, I would say, is utilize the
food bank to do the packaging. When you think about the
Agriculture Committee, to be able to support farmers, and have
a market, an additional channel for them to have to sell their
goods, get that to a food bank that has a cooler and the
freezer capacity. We can package it with our volunteers, and
then get it out to our agencies. I think that would be a
tremendous solution to add to the portfolio of solutions that
you offer.
Mr. Miller of Ohio. Thank you, sir, and I yield back. I now
would like to recognize Mr. Costa out of California for 5
minutes of questions.
Mr. Costa. Thank you very much, and Members of the
Committee, I know it has been a long hearing, but I think it
has been an important one. I want to concur with the Ranking
Member, Mr. Scott, and his opening comments. I think that we do
have a consensus among Members here on our side about the--I
don't know if it is the oath that physicians take, that--thou
shall do no harm.
Clearly--my district has the largest percentage of SNAP
recipients in California, and Congressman Valadao has a similar
high number. There are a lot of contrasts between significant
wealth and significant poverty, and a lot of our folks are
among the working poor. They are seasonal, working not only in
the fields, some of the hardest working people you ever meet in
your life, but also--and we--I think the highest minimum wage
law in the country.
But yet, with seasonal employment, family of four or five,
oftentimes that is not enough nutrition to feed a family. And
so I think that we need to be very careful when we make
generalizations, in terms of what changes or reforms. And this
is my fourth farm bill reauthorization, this issue comes up
every reauthorization, in terms of how do we best provide food
to the safety net. Because the farm bill is a safety net. It is
a safety net for American agriculture, and it is a safety net
for those who are socially and economically challenged in our
country. and that is the way I look at the farm bill.
So, under the category of thou shall do no harm, Ms. Royal,
you talked about issues of experience in New York. How would
you describe your view of the application of food stamps and--
or SNAP benefits, Women, and Infants, and Children in
California, and the distribution, and how we have done that,
with the state's own efforts?
Ms. Royal. As it applies to integrity? Could you repeat the
question? I am not sure. I am not sure how----
Mr. Costa. How would you rate the program in our
application and distribution of SNAP in California?
Ms. Royal. I can't answer the question.
Mr. Costa. Okay. Well, that is fine. Ms. Brown, do you have
any perspective on the California efforts?
Ms. Brown. Unfortunately, my only familiarity with
California, in terms of their recent efforts, are around their
success with online benefit applications, since we modeled
something similar. And so, in terms of their ability to access,
and create access to benefits, that is more of what I am
familiar with.
Mr. Costa. And how would you describe that? As being
successful?
Ms. Brown. Very successful. I think using technology, with
some strong support, and having the ability to increase our
access points for folks that are disabled, rural communities
unable to reach transportation, is incredibly beneficial.
Mr. Costa. I mean, this is a subset of that point you just
made, but I have learned that convenience stores--a lot of our
poor communities, that convenience store, it is not really a
grocery store, is where they can pick up groceries. I am told
that you can use a SNAP card or check for food that is in the
freezer as you take it out, but if you take items that are
heated, that you can't use that. is that correct?
Ms. Brown. That is correct.
Mr. Costa. Don't you think that is something we should
change? I mean, that makes no sense. You are in a convenience
store, you are hungry, you are coming--lunch, or working, and
you can't buy the chicken, or the other kinds of food that is
heated there? I mean, if you are lucky, they even have a
microwave, and you can buy it in the cold freezer, the burrito
or something, and then you pay for it with your SNAP credit,
and then you heat it in the microwave. But that is something we
could change here in the farm bill, don't you think?
Ms. Brown. That is something you can change. I will also
say it impacts our homeless population, who often doesn't have
opportunity to cook in a hotel room or in a shelter, and so
greater opportunities are----
Mr. Costa. Well, I would hope that is something we get
bipartisan support. It doesn't seem to me that--having left--I
mean, we are already agreeing that they can use the SNAP
benefit in a convenience store, but we are saying if it is
heated, you can't use it, and if it is not, you can. Makes no
sense.
My time has expired. There are going to be other things we
need to work on. But I think that, as the Ranking Member said,
we ought to find bipartisanship, as we have in the past, to
produce a farm bill this year, and I will continue to work with
everyone. Thank you.
Mr. Miller of Ohio. Thank you. I now would like to
recognize Mr. Molinaro out of New York for 5 minutes of
questions.
Mr. Molinaro. Thank you, Mr. Chairman, and thank you all
for spending the day with us. Obviously, this title is not only
significant, many times it causes a bit of controversy and
contention. I have been here for much of today's testimony. I
want to frame my questions--although I do want to acknowledge,
Ms. Brown, Minnesota's work to broaden access to SNAP, and
those touchpoints that you referred to. Also, by the way, use
of technology to reach to communities that are often untouched.
And it is--I only offer that in this--as a way of framing
what I hope will be a question at some point in my comments. I
spent the last 12 years as a county executive in the State of
New York. We are responsible for the delivery of food stamps,
TANF, Medicaid services. That is--while the Federal Government
says this is a state responsibility, which it is--and I would
remind my colleagues, Republican and Democratic, that we
empower states to administer these programs, and there is no
prohibition from the Federal Government to use other state
supports or Federal supports to create the connection necessary
to provide access, for instance, to those dealing with housing
insecurity.
There is no prohibition a state can't provide laundry care.
There is no prohibition a state can't provide wraparound mental
health supports. There is no prohibition that the states can't
engage in the kind of extra supports necessary as a supplement
to SNAP. In fact, that is what we empower states to do. And
states like Minnesota, and to some degree, I would acknowledge,
New York have attempted to do this.
However, I can tell you, over the 12 years I administered
SNAP and social services in my county, I saw a culture change.
Historically, Dr. Rachidi, as you know, and you testify,
historically, states were encouraged by the Federal Government
with a very firm mission statement. Use SNAP as a tool to help
people get to their own degree of independence.
I am going to pause here and say what my colleagues from
New York have often heard me say, I grew up on food stamps. My
mother was undiagnosed with depression. I thought every mom
slept until eleven o'clock, and I thought every kid got a free
lunch at school. But my mom worked hard--don't tell the unhired
IRS agent, she probably worked off the books a bit--and we got
back on our feet. I am grateful for the support structure. But
when we moved--when we started to move into self-sufficiency,
the agency was encouraged to help people find work. And it
wasn't--it--we wouldn't--didn't leave people to simply navigate
a massive labyrinth of bureaucracy.
But quite frankly, what the Federal Government has done,
and this very dialogue has devolved to is how much more money
should we or should we not spend? Or let us demonize or not
demonize a particular group or individuals. The truth of the
matter is we have a robust system. We just don't effectively
use it. And we haven't empowered states, and encouraged states,
and incentivized states to truly engage in the kind of support
necessary to help people find their way to their defined
independence.
My mother is independent now, diagnosed with depression,
gets the services and support she deserves. My daughter
receives Medicaid services, is an individual with disabilities.
I understand the challenges. But allowing this debate to simply
devolve into how much more or how much less we are going to
spend is just foolhardy, because ultimately, the mission
statement, to use the term I think Mr. Doar used some time
ago--a week ago, the mission statement of agencies
administering SNAP has changed from helping people to
processing people, and states like New York have taken enormous
amounts of Federal taxpayer money to simply support
bureaucracy, and instead leave people to feel worthless as they
are dehumanized in a system that doesn't care too much about
them. You might, Ms. Brown, our staff might, I am certain. My
social service agents did, but the system didn't.
Dr. Rachidi, I just want to return to this concept of the
mission statement. I was very grateful, authored the one
sentence, I think it is a paragraph in the Fiscal
Responsibility Act of 2023 (Pub. L. 118-5), that talks to
changing, or re-establishing that commitment to finding work
for people. My question is simply, can you speak to the value
of pointing state agencies in that direction? And that likely
will be my only question.
Dr. Rachidi. Yes, I think there is tremendous value in it,
because, as you mentioned, over the past at least 15, 20 years
of my career, I have also seen the shift away from employment.
And part of that is because states are very good at processing
checks, but they are less good at engaging participants, and
helping them find a path into employment.
So, I think by the Federal Government making it a clear
purpose of SNAP to help people find employment, I think it not
only sends a message, but it also allows the Federal Government
to hold states accountable for achieving that goal.
Mr. Molinaro. I am--I have 10 seconds for one last
question. What state spends more than New York on social
service, Medicaid, and SNAP? Which state is that?
Dr. Rachidi. Maybe California, but I don't think there are
many. I think it is probably New York.
Mr. Molinaro. It is New York. Spends the most on Medicaid,
TANF, and SNAP combined, and yet we still trap people in a
bureaucracy that is dehumanizing.
Mr. Miller of Ohio. Thank you. I would now like to
recognize Ms. Crockett out of Texas for 5 minutes of questions.
Ms. Crockett. Thank you, Mr. Chairman, and thank you to all
the witnesses today for your time. Let me be clear, my
colleagues and I stand united against efforts to take food away
from veterans, children, families, or any vulnerable American
in the farm bill, or in any other legislation. Any cuts to
these lifesaving benefits would disproportionately affect the
folks who make up the majority of my district, which is Black
and Latino Americans. Any cuts would be borne most severely by
these same communities, which are significantly more likely to
go hungry due to years of systemic disinvestment.
In 2021 Black seniors were nearly four times as likely, and
Latino seniors were three times as likely, to experience food
insecurity. That is why SNAP is so important to the 100,000
seniors in my district, which is over 40 percent African
American, and over \1/3\ Latino.
Statewide, SNAP is critical to more than 3.2 million Texans
who depend on it to put food on their tables each month. And
let me pause here. I haven't been here for the entire hearing,
but we do know we are talking about $6 a day. I just want to
make sure that those at home recognize that we are not talking
about a lot of money. I know that there was a lot of talk about
how much money.
And as we recently had our conversations as it relates to
the debt ceiling, there was an increase in defense, and so we
decided that we were going to cut $6 a day. I don't know how
you balance any budget whatsoever off of that, but I did need
to interject that we felt like that was really where all the
fat was, with trying to feed hungry people in this country to
the tune of $6 a day, and I can't buy a sandwich for $6, but
nevertheless--this includes close to 400,000 elderly adults,
and over 1.8 million children.
In my district, over 45,000 households used SNAP in 2021.
That is 16 percent of the households in my district. But what
is most concerning is that only 36 percent of SNAP eligible
seniors actually participate in the program, far below the
national average of about 50 percent. So instead of talking
about kicking people off the program, we should be focused on
improving SNAP accessibility.
In my home State of Texas, seniors are losing access to, or
sometimes never even receiving, these crucial benefits due to
difficulties they face in accessing the internet, navigating
complicated applications, and dealing with onerous
recertifications, even though their income hasn't changed. But
we aren't doing anything about that. Instead of pursuing made-
up problems with policies we know don't work, like time
limiting benefits, we should be working on how to modernize
SNAP to solve the problems of our constituents that they are
actually facing. In fact, I have another plug right here.
I had an opportunity to visit with a number of the food
banks in my district that have talked about how we have
modernized in this country. I use Uber Eats all the time.
People use DoorDash, they use all of these different things,
and so there are--I know DoorDash was actually one of those
companies who had agreed to deliver boxes of food to seniors,
but, because of the bureaucracy and the paperwork, if they
weren't there to physically sign for the food, then the
DoorDash delivery could not leave the food for them, because
they can't go about kind of just doing it on an app, like many
of us in this country do. So, it is time for us to catch up
with the times.
Ms. Brown, I was incredibly interested to read your
testimony about Minnesota's benefits application portal, which
has improved application times from over an hour on the
previous paper version to about 13 minutes on average. Can you
tell us more about the process for developing and launching MN
Benefits?
Ms. Brown. Yes, I can. Thank you for the question. So, we
partnered with Code for America, who was able to provide
resources to us free of charge, and they worked with our IT
systems to really look at what are the necessary questions we
were asking, and how could we utilize technology to really
streamline the process behind the scenes, and not on the backs
of the individuals who are applying for the program.
And so, with that, we have had incredible success. People
are incredibly happy with the length of time that they can go
through the application. And, furthermore, they can do it at
all hours of the day. In the traditional model, if you are open
from 8:00 to 5:00, if you work different hours, it was really
difficult for people to get to the social service office, so--
--
Ms. Crockett. And speaking of working, just to be clear,
currently SNAP does have work requirements, isn't that correct?
Ms. Brown. That is correct.
Ms. Crockett. Thank you so much.
Mr. Miller of Ohio. Thank you. I would now like to
recognize the gentleman out of New York, Mr. Langworthy, for 5
minutes of questions.
Mr. Langworthy. Thank you, Mr. Chairman, and Ranking Member
Scott. Dr. Stover, as you know, farmers and ranchers have the
opportunity to work alongside the retail community through
programs such as GusNIP. These programs are a win for local
businesses and farmers. In New York State alone more than
100,000 families have utilized the program. Over 5.2 million
pounds of produce have been sold, and the economic impact on
farmers in our communities has totaled more than $8.3 million.
Constituents receiving benefits in my district are able to
increase the number of fruits and vegetables being consumed
through these incentives at certain retailers. What role do you
believe incentive programs play in supporting the health of
SNAP participants?
Dr. Stover. I believe both education and incentive programs
are absolutely essential. The intersection of health--if you
want food to promote health in the population, it is an
intersection of the food environment, the food that is
available, and then the ability of the consumer to make the
healthful choice. And we need to work on both of those. And
that is a very innovative program, and we have to make sure
that we get the food environment right, and that we have agency
within individuals, the ability, the knowledge to make the
right choices.
Mr. Langworthy. Dr. Rachidi, I would like to open this
question up to you as well.
Dr. Rachidi. I do think incentives play a role, but I do
think we have to be clear about the evidence around GusNIP. It
did marginally include vegetable purchases, but it was fairly
small. So, if we are thinking about the problem of diet
quality, an incentive program like GusNIP, while useful, is not
really going to be a game changer.
I will add there were some comments about restrictions. I
agree. I don't necessarily like telling people what they should
eat or what they should not eat. I just believe that a taxpayer
funded program like SNAP, billions of dollars of Federal
dollars, taxpayers should not be subsidizing poor diet and poor
health. So, I think there is a role for incentives, and I think
there is a role for restrictions.
Mr. Langworthy. Thank you. Ms. Royal, no one has been
immune to skimming, but it is particularly bothersome when a
household in need falls victim to criminal activity. Now, while
some Congressional action has been taken in the Consolidated
Appropriations Act of 2023 (Pub. L. 117-328), it may have
simply provided a roadmap for bad actors. Ms. Royal, from a
national perspective, can you tell me more about skimming, and
how we as policymakers can stop it?
Ms. Royal. Skimming is an attack on benefits. It is a way
to use technology to recover information, and then use that
information to drain SNAP accounts. Waste prevented--a lot of
the skimming instances also arise from recipients using the
simple password, the 1234, the 111, again those sequential
passwords. Making sure, putting in mandates that we can't use
1234. And I realize that that comes with complications, but
when we are talking about draining an EBT card versus
complications in requirements on PIN numbers, it seems to be an
easy trade.
Mr. Langworthy. Very good. Thank you. Switching over to
food waste, Mr. Hodel, across the U.S., almost 40 percent of
our food is wasted. That is 130 billion meals, worth almost
$408 billion. I, and a lot of my colleagues, are concerned
about the costs of addressing hunger. Can you talk a little bit
more about how food banks like yours work with grocery stores
and other sources to capture food that might otherwise go to
waste, and where can we work to do more of that?
Mr. Hodel. Yes. So thank you for the question. Again, we
have a procurement director, we have logistics folks that--they
are very tied in. And we know when a grocery store especially,
or a supermarket, or a distribution center has food that is in
excess, they need to get it out of there. So that is one of our
driving forces, is--we have a fleet of trucks, we have drivers,
we have access to trucking companies across the country so that
we can quickly remove that from their business. They are trying
to run a business, and we are able to quickly capture, and
rescue that, and bring it in to our facilities.
We have invested heavily in our facilities with freezers
and coolers so that we can bring that in. And then we have a
variety of distribution models. So not all agencies are created
equal. We have small to large, we have local versus more
distant. So, again, we have different distribution models so
that when we get something in, that we can quickly turn it out
to those agencies, that they can get it to their food
recipients.
I think an incentive, or a promotion, is carbon credits,
because we think about how much are we rescuing that is not
going to a landfill. And then how do we reward and incentivize
those companies, and give them credit for the reduction in
carbon.
Mr. Langworthy. Thank you very much for the testimony from
all the witnesses, and, Mr. Chairman, I yield back.
The Chairman [presiding.] I thank the gentleman. Before I
recognize our next Member, I just want to ask unanimous consent
to submit for the record an article, May 31 Reuters article
\10\ on the number of job openings, including industries like
healthcare, transportation, logistics, and utilities. Without
objection, we will enter that into the record.
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\10\ Editor's note: the article entitled, US labor market remains
resilient as job openings climb, layoffs drop, is located on p. 133.
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Now I am pleased to recognize the gentlelady from Oregon,
the mother of a recent high school graduate on Friday,
congratulations to you and Amelia.
Ms. Salinas. Thank you.
The Chairman. I now recognize Ms. Salinas for 5 minutes.
Ms. Salinas. Well, thank you, Mr. Chairman. Thank you for
your kind words. I want to start by saying, I actually agree
with my colleagues in the Majority. I think we need to
encourage opportunity, and I think we need to do that with all
of our government programs. Sadly, that is where it ends.
So nearly 17 percent of households in my district depend on
SNAP to put food on their tables, each month, and that is about
one in six families in Oregon's Sixth District. But I am
particularly concerned about a certain population, and that is
those who attend community college, so our community college
students.
I want to again thank the Chairman Thompson and
Congresswoman Lori Chavez-DeRemer, who both serve on this
Committee. We were down in Albany, and out in the State of
Oregon this past Friday, and we were at Linn-Benton Community
College, were we heard that the average student is 27 years
old, and about \1/3\ of all those are parents.
And so, we are talking about non-traditional students, many
with dependents, trying to piece together work, caring for
kids, going to school, and yes, putting food on the table. And
a recent study from Johns Hopkins found that food-insecure
students were more than 40 percent less likely to graduate from
college, and more than 60 percent less likely to earn a
graduate or professional degree.
Despite the importance of nutrition to student success, and
what I would consider increased opportunity, recent surveys
estimate that as many as 30 to 40 percent of college students
are impacted by food insecurity. And, unfortunately, SNAP's
strict eligibility rules for students enrolled at least half
time make it difficult for many to get the help that they need.
And supporting food assistance for college students is an
investment in opportunity, and in human potential.
And I have my own personal story around this. It was really
difficult. My parents could not pay for college. I worked so
many jobs. I think I worked 70 hours a week. Sometimes I was
full time, sometimes I was part time, but they were able to
help me put food on my table. And I know a lot of kids these
days, and non-traditional students, just cannot. So, I believe
strongly that we need to make it possible for the millions of
students that want to follow in a similar path to mine who--we
need to enable them to make those ends meet while pursuing that
education.
So, Ms. Brown, how accessible is SNAP to students enrolled
half time or more, and what barriers do people who are already
participating in SNAP face when they try to enroll in higher
education to further their work prospects?
Ms. Brown. Thank you for raising this important issue. One
in five college students are parents. And, adding onto some of
those stats that you shared, we believe that student policies
need to be modernized. When the program policies were put in
place, the traditional college student looked much different
than what it looks like today.
So, during the pandemic, the COVID provisions that were
passed were incredibly helpful. We heard from college students
all across the state how grateful they were for that. So, what
that did is it loosened the student eligibility criteria, which
allowed for work study placement to occur. And what we have in
Minnesota is that some college students that are eligible for
work study are unable to get a work study placement simply
because there aren't enough.
Ms. Salinas. Right.
Ms. Brown. And so that is a particular barrier that is
incredibly important to really solve. We also are interested in
seeing a blanket exemption for all income-eligible students if
they are enrolled in a 2 year community college or a technical
college program, again, with the idea of boosting up and
removing barriers for student populations.
Ms. Salinas. Thank you. And then, also, just in my last
minute, I would like to ask about the mechanism SNAP has in
place to address the benefits cliff families might face if they
are able to increase their earnings to the point where they are
no longer eligible for SNAP. So, Ms. Brown, can you speak to
how utilizing broad-based categorical eligibility, or BBCE,
impacts SNAP recipients in your state, and then what kind of
benefit cliff, if any, do they face when they become ineligible
for SNAP?
Ms. Brown. Yes. Thank you so much. So, the broad-based
categorical eligibility does allow households to save for the
future. That is the number one piece, and it really does soften
that benefit cliff. So, we want people, in order to be
successful, and not turn on and off the program, to really be
stable when they leave the program. And so, if we can soften
the benefit cliff, and utilize all the exceptions and the
flexibilities states can employ, then we will have a much more
stable population, and people more successful.
Ms. Salinas. Thank you. And more opportunities ahead. I
mean, it really does go to show that we do need some safety
nets there, so thank you. Thank you again to you, Mr. Chairman,
to coming to our great State of Oregon to hear the needs of our
state, and I yield back.
The Chairman. It was a pleasure. Thank you for the
hospitality. Before I recognize the gentleman from Tennessee, I
do want to make a unanimous consent request to submit for the
record a May 23 Wall Street Journal opinion,\11\ where the
author lays bare how public policy has made unemployment too
attractive for some healthy adults. Without objection, so
submitted. I am now pleased to recognize the gentleman from
Tennessee, Mr. Rose, for 5 minutes.
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\11\ Editor's note: the article entitled, Make Welfare Reform Part
of the Debt-Ceiling Deal, is located on p. 140.
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Mr. Rose. Thank you, Chairman Thompson and Ranking Member
Scott, for holding the hearing, and thank you to our witnesses
for your time today. I know you have lots of things you could
be doing, and we appreciate you being here with us. I want to
begin with Ms. Royal. As a member of the United Council on
Welfare Fraud, do you believe that welfare fraud is a
victimless crime?
Ms. Royal. Absolutely not. The victims are the taxpayers,
and the victim is the program itself.
Mr. Rose. And thank you for that. You anticipated my
follow-up question, so I will move on, then, and thanks for
that clarity. Mr. Hodel, your testimony mentions weekly
deliveries to eastern Kentucky, with future projects for
Mississippi and Louisiana, and a mention of a pilot program to
support the super rural communities. Knowing these are high
poverty areas, how do you succeed in getting food to these
communities in need?
Mr. Hodel. It is teamwork. We are using data analytics to
look at the high poverty countries--or counties, sorry, and
districts, and then teaming with corporations that have a
philanthropic element. Obviously more and more I would say
companies are looking for their proof to be able to show their
employees that they are giving back, and they are caring about
communities across the country.
Two different programs, but one is procuring food,
packaging basically family food boxes. One is shelf stable, and
one is perishable. And then utilizing logistics companies, and
they truck the food from our location down to eastern
Tennessee, and then utilizing a local agency to do the
distribution.
And actually, of the 944,000 households that we dropped
off, or the agency dropped off and delivered, only seven missed
the delivery. So we have had really good response to be able to
take a family food box to a house. Many times they don't have a
door, or don't have windows, and they are clearly in need. So
that is teamwork, kind of across the supply chain, with
corporations, and companies, and agencies.
Mr. Rose. Thank you. And to serve these areas for a season,
and not a lifetime, are there--and I think I just said that
backwards, for a lifetime, and not just a season, are there
opportunities for collaboration with employers, career and
technical education providers, and other service providers to
give these families the support that they need to move from
poverty to true independence?
Mr. Hodel. Absolutely. Yes, we talked about junior
colleges, and the one thing I would add is we actually have a
lot of food pantries in junior colleges. And they are able to
put those food pantries in place because we don't charge for
our food, so it is an opportunity for a college student to come
get food. But I do think companies, employers--we will see
where manufacturing companies, trucking companies, they will
reach out to Midwest Food Bank, and they will have an activity.
They will do a food packaging drive at their facility to drive
awareness about Midwest Food Bank, but they also know, then,
that it is a support system for the community. And there are
probably some employees at those locations that, based on their
situation, maybe have to use the food pantry at times.
So, again, I think it is community collaboration, but
primary, secondary, post-secondary education, and training, and
connections with the local employers in the area I think is
really, really key.
Mr. Rose. Thank you. I completely agree, and would just
stress the old adage of give a man a fish, you feed him for a
day, teach a man to fish, you have fed him for a lifetime.
And--came up through the FFA Program, and appreciated the
important lessons there of teaching people how to feed
themselves, and grow the food to feed themselves, so I embrace
everything you just said.
Mr. Hodel, one photo from a once a month distribution was
used repeatedly throughout the pandemic to demonstrate need.
While it suggested demand, it also suggested logistical
failure. What has your experience been? Have you seen dramatic
lines? If not, how have you supplied your demand with
efficiency?
Mr. Hodel. Yes. We actually saw the opposite. So during the
pandemic--and I am familiar with the photo, but we actually
more fine tuned our supply chain and our planning of our
agencies to pick up, because we needed--we had to kind of space
people out. And so we were, again, with integrity, trying to
make sure we were respectful of their time, so we kind of
dialed in our schedule to make it really clear that--we need
you to come at this time to pick up your food, and we had it
kind of pre-packaged and ready for our volunteers to load their
vehicles.
So, our experience was just, again, making sure that we
dialed in our planning and our logistics to be respectful of
our agency so they did not have to wait.
Mr. Rose. Thank you. Mr. Chairman, I yield back.
The Chairman. Thank the gentleman. Before I recognize the
young lady from Virginia for 5 minutes, I just would request
unanimous consent to submit for the record a May 24 Wall Street
Journal \12\ article that articulates how desperate states are
to keep people idle through waivers. Without objection, I am
now pleased to recognize the gentlelady from Virginia, Ms.
Spanberger, for 5 minutes.
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\12\ Editor' note: the article entitled, Fixing the Food-Stamp Work
Requirement Loopholes, is located on p. 143.
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Ms. Spanberger. Thank you very much, Mr. Chairman, and
thank you to our witnesses for being with us. There have been a
number of conversations and questions posed throughout this
hearing, some directly related to the topic, and some not.
There was a question posed of Ms. Brown about the time it takes
for an asylum process to go through, an application. The answer
to the question--though, Ms. Brown, given your specialty and
expertise was probably misdirected at you--is 4.3 years. And
so, individuals who may eventually become eligible for SNAP
benefits, once they are approved, it is an average of 4.3
years, with some taking more than a decade. And, Mr. Chairman,
I ask unanimous consent to put this document into the record
substantiating that.\13\
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\13\ Editor' note: the TRAC Immigration report entitled, A Sober
Assessment of the Growing U.S. Asylum Backlog, is located on p. 203.
---------------------------------------------------------------------------
The Chairman. Without objection.
Ms. Spanberger. Thank you. There were also questions
related to work requirements, and in the question was a little
bit of an implication, that, in fact, work requirements are not
in place, and that they are not currently supported. Work
requirements are in place, and so I submit for the record--or I
ask unanimous consent to submit for the record the statute
related to existing work requirements, which do indeed already
exist for many SNAP requirements.\14\
---------------------------------------------------------------------------
\14\ Editor' note: the excerpt from 7 U.S.C., 2015. Eligibility
disqualifications, is located on p. 219.
---------------------------------------------------------------------------
The Chairman. Without objection.
Ms. Spanberger. Thank you. There was a question related to
veterans, and how removing some of the requirements related to
hurdles that might be in place for veterans to get SNAP
benefits, whether that would hurt veterans, because they
wouldn't be required to take education and training programs.
So, Ms. Brown, directed at you, while those requirements are
not in place, thanks to the Fiscal Responsibility Act, for
veterans who choose to participate, that option is still on the
table, is it not?
Ms. Brown. That is correct.
Ms. Spanberger. So, we are not disadvantaging veterans by
removing a hurdle for them to have access to affordable food,
is that correct?
Ms. Brown. Correct.
Ms. Spanberger. There are, though, substantial challenges
with some of the state-run program for education and training,
that that is another matter. Is that also correct?
Ms. Brown. That is correct.
Ms. Spanberger. Thank you. There was a comment about the
fact that an individual on the Committee went out and just
found a $14 paying job. I would just like to state for the
record that the Federal minimum wage continues to be $7.25, and
a tip wage worker, it is $2.13. If any of my colleagues want to
join some of us in raising that to a $14 level, I welcome them
to do so.
Related to the Farmers to Families Food Box Program,
notably I think there was--in the immediacy of the pandemic,
this program showed some strength, though notably a $39 million
contract went to an event planning company out of Texas. There
is story after story of abuses of the program.
And so, when we are moving forward trying to find programs,
and ways to leverage Federal dollars to help people and help
communities, my attention is drawn to my state, the
Commonwealth of Virginia, where agriculture is our number one
private industry, and what I see in my district is the fact
that local farmers are able to participate in programs such as
community food projects. The GusNIP Program is incredibly
helpful in helping leverage SNAP dollars. And, in fact, the
Regional Food Business Centers are something that I do hope
this Committee will codify when we move forward with this farm
bill, because they have been so incredibly helpful to the
people that I serve.
And, with that, I want to just speak to another population
that continues to face food insecurity, and those are active-
duty servicemembers. In the Commonwealth of Virginia, we have
the second highest population of active-duty servicemembers,
second to California, and in Virginia's Seventh District, I am
proud to represent so many of them. My colleagues have spoken
about veterans who also face food security challenges.
A 2020 survey found that nearly \1/5\ of active-duty
military families in Virginia say they can't reliably afford
food. The survey also found that lower ranked servicemembers,
those who considered suicide, and those who were experiencing
loneliness were more likely to experience food insecurity.
These stories, these experiences, are not rare or unique to
Virginia.
According to the U.S. Department of Defense, 24 percent of
active-duty servicemembers experience food insecurity at some
point over the course of 1 year. That is almost one in four,
and even our colleagues here today have spoken of availing
themselves of food security programs while they were active-
duty servicemembers.
During my career I spent many years working to keep our
country safe from a wide variety of threats, and I can tell you
hunger among our military families is a national security
issue. It is unacceptable that military families struggle to
put food on the table in the richest, most powerful country in
the world. Those who defend our nation do not deserve to go
hungry.
And while the conversation today has included some
programmatic improvements that we could make to our food
security program, some improvements to education and training,
to the administration of the program, encouraging access to
healthy foods, simplifying programs, and, of course,
eliminating fraud, I also want to join my colleagues in saying
that I refuse to accept senseless changes to SNAP that would
harm our nation's servicemembers, veterans, and any other
vulnerable Americans by taking food away from them in the 2023
Farm Bill or any other way. Thank you, I yield back.
The Chairman. The gentlelady did that very nicely, getting
it in under the wire. I didn't think you lived that far north
to be able to speak that fast. That was really good. Before I
recognize Mr. Johnson, want to ask unanimous consent to submit
for the record a May 17, 2023 Wall Street Journal \15\ article
regarding the sensible reforms in the Fiscal Responsibility
Act. Without objection, so submitted. And now recognize the
gentleman from South Dakota, Mr. Johnson, for 5 minutes.
---------------------------------------------------------------------------
\15\ Editor's note: the article entitled, The GOP Can Win on Work
Requirements and Welfare, is located on p. 138.
---------------------------------------------------------------------------
Mr. Johnson. Dr. Rachidi, your testimony references the
relative lower health outcomes for SNAP recipients, which I
think is, of course, concerning to all of us. I assume that
health is highly correlated to employment, and so then I wonder
if SNAP recipients would have correlatingly lower work
outcomes. Is my assumption right, and then, if so, what do we
do about that to make sure that people are healthier, more
productive, happier? We have talked about some programmatic
improvements, but what are we missing?
Dr. Rachidi. Yes, thank you for the question. This is
actually one of my main concerns about SNAP, because SNAP
obviously draws to the program just an unhealthier population,
because that is likely why they can't work, which is why they
are low-income, which is why they need SNAP. So, it does draw
an unhealthy population somewhat by design.
But the problem with SNAP is that once that unhealthy
population comes to SNAP for help, SNAP actually contributes to
poor health by reducing diet quality, and also disincentivizes
work, which we know leads to further deterioration of health.
So, in the reverse, really SNAP should be looking at those with
poor health as an opportunity to improve their health and make
them more employable, so that they can, in the end, escape
poverty.
Mr. Johnson. So, I do not have it in front of me, but there
was a Federal Reserve report a number of years ago that I
reviewed that indicated--that talked--that did time studies on
work capable individuals who were not working. And you--not
surprising that there was a big difference between the way that
unemployed women spent their time versus unemployed men.
Unemployed women are so often the custodial parent. They were
spending huge chunks of their day on care for dependents. With
the young work capable men, that was less the case.
And the time study result, as I remember, was early on they
were spending a fair amount of time trying to be work ready and
look for work. If they didn't get a job relatively quickly, how
they spent their time changed dramatically. And they began to
spend more time on television, on a smartphone, on other
entertainment devices, and that there was a corresponding
precipitous drop in their mental health.
Does that sound about right? Is that consistent with other
research you have analyzed, and any other observations you
would have about what sounds like, frankly, a serious problem
for the behavioral health of Americans generally?
Dr. Rachidi. It is, and it is exactly correct. So, Nick
Eberstadt, who is a scholar at AEI, has done work on time use
surveys, and documented that--especially among men, those were
prime age and not working, they spend their time mostly in
front of screens. And then we have the literature to suggest
the longer people are out of the labor market, their health
deteriorates even more, and even mental health issues.
So, you can imagine a population that is becoming further
depressed because they are not working, spending a lot of time
on screens it is just contributing to the problem rather than
trying to help them.
Mr. Johnson. And I would--I think both sides of the dais--
and by the way, I think we all know this Committee is generally
far more common ground seeking than many of the food fight
committees in Washington, and that is one of the reasons that I
am so proud to serve here. I do think sometimes the rhetoric
many of us can use about this issue can be a barrier.
I do think everybody in here ultimately shares the same
desire, which is how do we allow people to live happier, more
productive, healthier lives. We may have tactical disagreements
about the best way to do that, but I do observe that we all
accept that, to get stronger in athletics, you can't just jog
at a comfortable pace, that growth comes outside of one's
comfort zone. And, of course, that is true for a high school
cross-country runner, but it is also true for each of us, in
our personal relationships, in our professional relationships.
And I know that every human being I have met is more--is
better positioned to grow outside of that comfort zone if there
is some--if there is accountability. If there are--not just
accountability, but some supports, right? And ultimately,
looking forward, we do know that work requirements can play a
role there. We know that job training programs can play role
there. We know that job seeking supports, including childcare,
plays a role as well.
And so, I would just thank you for the research that you
and your colleagues have done, because ultimately, we cannot
afford to have the kind of precipitous decline in physical
health and mental health that the research you are discussing
describes. Thanks so much. I yield back.
The Chairman. The gentleman yields back. Before I
recognize--good friend from Florida, I would just unanimous
consent to submit for the record Dr. Rachidi's May 2023 report,
Perspective on Opportunity: Promoting Mobility Through SNAP:
Toward Better Health and Employment Outcomes. Without
objection, the article is submitted, and now pleased to
recognize the gentleman from Florida, Congressman Soto, for 5
minutes.
[The report referred to is located on p. 168.]
Mr. Soto. Thank you, Mr. Chairman, and thanks for coming to
Florida for the listening tour just a few weeks ago. It has
been said often on this Committee, by both sides of the aisle,
that we live in the most powerful, most prosperous nation in
the history of the world, and that no American family should go
hungry. We also have incredible farmers. The American farmer is
the most productive in the world as well, which helps give us
this blessed bounty.
I want to go through some of the facts about SNAP. First,
SNAP is effective. It serves over 42 million Americans. SNAP is
also a critical program for our local agriculture. I have
spoken to many ranchers, and growers, and farmers in my
district who work with our state, and with the Federal
Government to help provide the food for the SNAP program. SNAP
has modest benefits. The average benefits are $2 per person per
meal, $6 per day. As I have mentioned that to some of my
constituents, a lot of folks have been shocked about that
number. And, last, SNAP also helps our most vulnerable
Americans: 80 percent of the program are children, the
disabled, seniors. We also have a lot of veterans who are able
to get SNAP benefits, as my colleague, Representative
Spanberger, mentioned so well.
I talked to some of our local nonprofits, like Osceola
Council on Aging in my district about persons with disabilities
in my district who are receiving SNAP, and they talked about a
gentleman named Herman who is a constituent of mine in central
Florida. He is a senior who lives alone with diabetes, suffers
from heart problems, uses a walker. His food stamps have
already been cut from $150 to $50. If there were further cuts,
he will be in an increasingly worse situation. Right now, he
tries to make things work by working with other charities, and
churches, and the like, and we applaud the work they do, but
the funding and the food there is not consistent.
We know that a household containing an adult with
disability is estimated to require 28 percent more income to
maintain the same standard of living as a similar household.
SNAP can serve as a vital lifeline for Americans in this
situation. In Florida, more than 288,000 non-senior adults with
disabilities participate in SNAP each month. Nationally, in
2020, 22 percent of SNAP households, over four million
households, included non-elderly adults and children with
disabilities. That is why I feel strongly about these programs,
and I hear it from my constituents every day.
Ms. Brown, how can we improve SNAP benefits to ensure
Americans living with disabilities like Herman can afford
healthy, nutritious food? Because $50 doesn't seem like a lot
of money each week. And are there ways we can adjust--excuse
me, monthly, forgive me. And are there ways we can adjust
things like SNAP work requirements and medical deductions to
ensure low-income disabled individuals have better food
assistance?
Ms. Brown. Yes. Thank you for the question, and thank you
for the example of the constituent. I think that is an
important example, because it shows the conditions that your
constituent has as a result of SNAP, but they are utilizing
SNAP to help, despite all the of the conditions that they are
dealing with. And I think there have been a few statements made
that are really ignoring the conditions that folks have as they
are entering into SNAP, and SNAP is not causing those
conditions, so I want to make that point. I also just have to
make another point that when we look at a point in time, a data
point, that does not--that--it does not serve as well to make
broad characterizations of a population.
So, to your point about folks that we can improve access,
and encourage disabled folks, absolutely. Increased review of
the medical deductions will absolutely benefit that population,
and encourage more to apply, and to receive benefits, and
hopefully stabilize. We have to really be understanding of the
myriad of conditions and problems that our folks have, and that
is exactly why SNAP is here.
Mr. Soto. Well, thank you so much, Ms. Brown. Constituents
like Herman, a disabled senior, who already had his benefits
cut from $150 to $50 a month--I can't imagine any family, let
alone a constituent suffering from disabilities to be able to
really live on that, so--think these are types of stories we
have to keep in mind as we are looking at protecting SNAP here
in the farm bill. And I yield back.
The Chairman. Thank the gentleman. Before I recognize the
Ranking Member here for closing comments, I just would like to
submit for the record a May 30 Wall Street Journal \16\ article
on restoring a culture of work and safety net programs. Without
objection, consider the article submitted. And now pleased to
recognize, for any closing comments that he would like to make,
the gentleman from Georgia.
---------------------------------------------------------------------------
\16\ Editor's note: the article entitled, The GOP's Progress on
Work and Welfare, is located on p. 144.
---------------------------------------------------------------------------
Mr. David Scott of Georgia. Well, thank you, Mr. Chairman.
And I want to thank our panelists for a very engaging,
informative, and heartfelt presentation. We are dealing here
with fine points. What has been missed here is that--this issue
of work, as if Democrats don't have work requirements. We do,
up to 49 years of age. Under the bill that President Biden has
just signed, the work requirements are 5 more years. So it is
minor.
But why do we feel--we have an opportunity here to really
get to the heart of the matter. Let me just share with you why
I oppose moving from the 49 years of age that we have the work
requirements. You would hear from our Republican friends as if
Democrats don't support work requirements. We do. But we have a
reason for putting it at the age where it is least hurtful for
the very people we are trying to help.
Let me share with you these astounding figures so that I
think you will agree that 49 years is sufficient, and once you
get beyond that, you create an amazing amount of hurt to the
very people that you are trying to help: 82 percent of SNAP
households include a child, an elderly adult, a person with
disability. That is in 82 percent of every household. And 42
percent of all of the SNAP participants are children. It is the
children in the households. It is the grandparents, it is the
parents, that have to provide food from their qualifications
for the food stamps.
That age is so important, and that is why we Democrats feel
strongly in holding this age at this pattern. We are not
against people going out--able-bodied going to work. Work is
not just there when you have this type of constituency in each
household. Who is going to take care of those children, the
disability, the people who are in these homes that SNAP is
giving the attention to? That is what is at issue here. And I
am hoping that our Republican friends will see the
justification to don't add more difficulties onto our SNAP
recipients than what we have now.
And y'all's testimony proves this very point, that we are
set, and with--the SNAP requirements of work where they are,
are there for a purpose. It is not these additional 5 years we
have to be concerned about. We are there to help these
children. We are here to help the disabled. And when you throw
in our veterans, who are living in food-insecure households at
a rate of 7.4 percent greater than the general population, that
is why we have the work requirements where they are.
That is the only difference we have. And you have heard
similar commentaries from each side. There is a compassion
here. Now we all just hope, and we pray, that our Republican
friends will want this to be a bipartisan bill. But there is no
way that we Democrats can turn our backs on where we are right
now. All we are asking for is to keep it where it is. And you
all have testified as to why. Thank you, Mr. Chairman.
The Chairman. Well, I thank the gentleman. I want to thank
our witnesses. This panel has been unmatched, in terms of your
expertise, and your dedication to basically what we are talking
about under the nutrition title, and I just greatly appreciate
it. Thank you to our Members. We had tremendous participation
and turnout. And thank you to our staff, all of our staff, for
helping to make this hearing so successful.
There are a couple truisms out there in this space. Farmers
feed, and nutrition matters. And so that is why I am very proud
to have Title IV, the nutrition title, in the farm bill. I
think it is an essential part of the farm bill. And under the
SNAP Program, the fact that the national average is $248 a
month, the national average is a little over $8 a day.
Now, that is the national average. There are some
differences based on the states' administrations. I want to
compare that over $8 a month for SNAP recipients to the fact
that the national average for expenditure for non-SNAP on a
daily basis is $12 a day. And that is why we call it
Supplemental Nutritional Assistance Program. It is not the full
amount, supplemental, but it is--the differences is pretty
close.
Now, as we continue our work for the 2023 Farm Bill, I hope
it will keep a principled approach. Those principles were in
the title of this hearing, and, quite frankly, has been in any
discussion that I have led, or have been a part of, not just in
this hearing room, but, quite frankly, all across the country,
and probably about 40 states over the past 2 years and 5
months, as we have done a listening--farm listening session to
take input on all 12 titles of the farm bill, including Title
IV, the nutrition title. That is innovation and flexibility,
food and financial security--or independence, food and
financial independence, program integrity, and healthy eating.
By focusing on principle, we can mute the politics that can be
so divisive. I think we have an obligation to do that.
As we look at SNAP, and I know that it can be very
controversial, but it is important for people to understand
that, in terms of--I don't use the word work requirements. I
use the word job opportunities: almost \1/4\ of all SNAP
recipients today are working. They are the working poor. They
are working one and two jobs or more, minimum wage, no
benefits, and they are not getting any further ahead, and they
are struggling.
And they qualify financially for SNAP, and they don't--I
mean, they fulfill that 20 hours a week work requirements, but
it is important people--to clarify that that requirement, as
has been in law for a very long time, is 20 hours of work, or
20 hours of volunteer time. Or, quite frankly, I think one of
the best ways is engagement in SNAP employment and career and
technical education. Helping people reach a new rung on the
ladder of opportunity. So I look forward to our continued
discussion on where areas for improvement exist.
And so, with that, under the Rules of the Committee, the
record of today's hearing will remain open for 10 calendar days
to receive additional material and supplementary written
responses from witnesses to any question posed by a Member.
This hearing of the Committee on Agriculture is adjourned.
[Whereupon, at 2:43 p.m., the Committee was adjourned.]
[Material submitted for inclusion in the record follows:]
Submitted Articles by Hon. Glenn Thompson, a Representative in Congress
from Pennsylvania
Article 1
[https://journals.lww.com/co-pediatrics/Fulltext/2023/02000/
Supplemental_Nutri
tion_Assistance_Program_as_a.8.aspx]
Supplemental Nutrition Assistance Program as a health intervention
Current Opinion in Pediatrics
Jerold Mande a and Grace Flaherty b
---------------------------------------------------------------------------
\a\ Harvard T.H. Chan School of Public Health.
\b\ Bailit Health Purchasing, Needham, Massachusetts, USA.
Correspondence to Jerold Mande, Harvard T.H. Chan School of Public
Health, 655 Huntington Avenue, Boston, MA 02115, USA.
Tel: +1 617 850 2578; e-mail: jmande@hsph.harvard.edu
Curr. Opin. Pediatr. 2023, 35: 33-38, DOI:10.1097/
MOP.0000000000001192.
This is an open access article distributed under the terms of the
Creative Commons Attribution--Non Commercial--No Derivatives License
4.0 (CCBY-NC-ND), where it is permissible to download and share the
work provided it is properly cited. The work cannot be changed in any
way or used commercially without permission from the journal.
------------------------------------------------------------------------
-------------------------------------------------------------------------
Purpose of review
In 2020, obesity prevalence among U.S. children reached 19.7%,
impacting about 14.7 million children and adolescents. Food insecurity
among children is also a public health concern but has largely
decreased or remained stable over the past decade, reaching 6.2% of
U.S. households with children in 2021. Given food insecurity and
obesity's interconnected nature and their negative consequences on
children's health, it is of interest to assess the Supplemental
Nutrition Assistance Program's (SNAP's) impact on childhood food
security, dietary quality, disease risk, and health outcomes.
Recent findings
Evidence suggests that SNAP participants, including children,
struggle to meet key dietary guidelines and perform poorly on key
health indicators when compared with income-eligible and higher income
non-participants. Children participating in SNAP were more likely to
have elevated disease risk and consume more sugar-sweetened beverages
(SSBs), more high-fat dairy, and more processed meats than income-
eligible non-participants. However, research suggests that Federal food
assistance programs with more stringent nutrition standards--the
Special Supplemental Nutrition Program for Women, Infants and Children
(WIC) and the National School Lunch Program (NSLP) and School Breakfast
Program (SBP)--improve dietary quality, increase birth weight and
gestation periods, and reduce childhood obesity, infant mortality and
healthcare costs.
Summary
After reviewing the evidence on SNAP's impacts on food insecurity,
dietary quality, and health as well as research on the health impacts
of other more successful Federal food assistance programs, we provide
three policy recommendations to strengthen SNAP's effectiveness as a
health intervention for children and families.
Keywords
diet quality, food insecurity, health intervention, nutrition
assistance, Supplemental Nutrition Assistance Program
------------------------------------------------------------------------
Introduction
Obesity and diet-related disease are a growing public health crisis
for both adults and children, with significant disparities by race and
ethnicity. Childhood food insecurity is also a public health concern
and is closely tied to diet-related disease and overall child health.
The Supplemental Nutrition Assistance Program (SNAP) is the largest
Federal food assistance program and is of interest for its potential to
further alleviate food insecurity among children while also improving
health outcomes.
Burden Of Obesity, Diet-Related Disease, and Food Insecurity
From 2017 to 2020, for children aged 2 to 19 years, the prevalence
of obesity in the United States was 19.7% and impacted about 14.7
million children and adolescents.[1D] Obesity
prevalence was 26.2% among Hispanic children, 24.8% among non- Hispanic
black children, 16.6% among non-Hispanic white children, and 9% among
non-Hispanic Asian children.[2] Obesity increases a child's
risk for adverse diet-related health conditions, including type 2
diabetes, cardiovascular disease, and certain cancers.[3]
Among adults, from 2017 to 2020, obesity prevalence was 41.9%, a record
high.[3] Obesity prevalence was 49.9% among non-Hispanic
black adults, 45.6% among Hispanic adults, 41.4% among non-Hispanic
white adults and 16.1% among non-Hispanic Asian adults.[3]
In 2017-2018, 93.2% of adults had less-than-optimal metabolic
health.[4D] Diet-related chronic diseases are
among the leading causes of death in the United States, and research
during the coronavirus 19 (COVID-19) pandemic showed that diet-related
chronic diseases were associated with higher risk of COVID-19 infection
and \2/3\ of COVID-19 hospitalizations.[2, 5D]
------------------------------------------------------------------------
-------------------------------------------------------------------------
Key Points
Childhood obesity and diet-related disease are growing
public health concerns. Childhood food insecurity is also an
important public health concern but has been decreasing over the
past decade, thanks in large part to Federal policy efforts.
Research suggests that the Supplemental Nutrition
Assistance Program (SNAP) has positive impacts on child health by
reducing food insecurity and providing economic benefits to
families, but SNAP participants are still struggling more than
income-eligible and higher income non-participants to meet key
dietary guidelines.
Research on other Federal food assistance programs suggests
that making diet quality a SNAP core objective, applying more
stringent nutrition standards to SNAP authorized retailers, and
pairing incentives for purchasing fruits and vegetables with
restrictions on unhealthy foods and beverages would improve
participants dietary patterns and metabolic health.
------------------------------------------------------------------------
Food insecurity and very-low-food insecurity among households with
children decreased from 2020 to 2021. Food-insecure households, as
defined by USDA, are those that had difficulty at some time during the
year providing enough food for all members because of a lack of
resources.[6] Very-low-food insecurity is a more severe
range of food insecurity, wherein the food intake of some household-
members was reduced, and normal eating patterns was disrupted at times
during the year because of limited resources.[6] In 2021,
6.2% of households with children were food-insecure (compared with 7.5%
in 2020) and 0.7% had very-low-food security (compared with 0.8% in
2020).[7D, 8D] Food insecurity is
associated with a host of short-term and long-term health consequences
for children, including infant mortality, fetal epigenetic changes,
suboptimal development and function, increased hospitalizations and
healthcare use, disrupted or under use of prescribed medications,
poorer-management of chronic diseases and poor diet
quality.[9-19]
Supplemental Nutrition Assistance Program Background
SNAP is a Federal program with the potential to impact childhood
food insecurity, obesity, and diet-related disease simultaneously. SNAP
provides food-purchasing assistance to low-income Americans. SNAP is
the largest Federal food assistance program, serving 41.5 million
people in fiscal year (FY) 2022 at an expenditure of $140
billion.[20] The most recent data on SNAP household
characteristics found that in FY 2019, 41% of participating SNAP
households included children.[21] The United States
Department of Agriculture (USDA) pays the full cost of SNAP benefits
and shares half of the administration costs with states, which operate
SNAP. To be eligible to receive SNAP benefits, an individual or
household must have a gross income of less than 130% of the Federal
poverty standard, net income less than 100% of the Federal poverty
standard, and assets must fall below certain limits.[22]
Households deemed eligible for SNAP benefits receive an electronic
benefit card (EBT), which is loaded with benefits monthly. Households
may use EBT cards at an authorized retailer, of which there are more
than 247,000.[23] SNAP participants may use EBT benefits to
purchase food and allowable beverages but may not be used to purchase
alcoholic beverages, tobacco, paper goods, and other non-food
items.[24] Heated and hot prepared foods are not considered
staple foods and are also not eligible for purchase, except in some
areas under certain circumstances.[25] On average, SNAP
participants received an estimated $217.88 per month per person in
regular SNAP benefits in FY 2021.[26] Each household's
monthly benefit amount is based on the household's net income, so that
if a household's net income after deductions is zero, the household
receives the maximum SNAP benefit, and the benefit reduction rate is
30% (meaning the monthly benefit is reduced by 30 for each dollar of
net income).[27] During the COVID-19 pandemic, Congress
provided all SNAP recipients the maximum benefit. The maximum SNAP
benefit is tied to the cost of the USDA's Thrifty Food Plan (TFP), a
diet plan intended to provide adequate nutrition consistent with the
Dietary Guidelines for Americans, and which was updated in 2021 as
directed by Congress, increasing SNAP benefits by
21%.[28, 29]
Supplemental Nutrition Assistance Program's Impact on Child Health
Research suggests that SNAP has positive impacts on health by
reducing food insecurity and lifting individuals out of poverty.
Research has shown that SNAP meets its goal of reducing hunger and food
insecurity among participants, including
children.[30, 31DD] Participation in SNAP has
been shown to reduce the incidence of low-birth weight among newborns
by 7% for whites and 5-11% for blacks.[32] Research on the
relationship between SNAP purchasing power and children's health and
health care utilization found that a 10% increase in SNAP purchasing
power increases the likelihood a child had a preventive check-in in the
past year by 8.1%, increases the likelihood that children had any
doctor's visit in the past 12 months by 3.4%, and is associated with a
22% reduction in the number of school days missed because of
illness.[33] Research has shown that children receiving SNAP
are less likely than low-income non-participants to be in fair or poor
health or underweight, and their families are less likely to make
tradeoffs between paying for health care and paying for other basic
health needs, like food, housing, heating, and
electricity.[34, 35] Reductions and cut offs in SNAP
benefits because of increased income have also been associated with
poorer child health.[36]
Supplemental Nutrition Assistance and Diet Quality
Although SNAP effectively alleviates food insecurity for children
in terms of caloric, macronutrient, and micronutrient intake, SNAP
participants are still struggling more than income-eligible and higher
income nonparticipants to meet key dietary guidelines.
The average USDA Healthy Eating Index (HEI) score among Americans
is 58 (out of a possible 100), suggesting that the majority of
Americans have suboptimal diets.[37] However, while other
USDA food assistance programs, such as the Special Supplemental
Nutrition Program for Women, Infants and Children (WIC) and the
National School Lunch Program (NSLP) and School Breakfast Program
(SBP), significantly improve diet quality, research suggests that SNAP
does not.
The National Health and Nutrition Examination Survey (NHANES) has
frequently been used to assess Americans' dietary quality and health,
including by income and SNAP participation status. A study using 2011-
2016 NHANES data found that, on average, SNAP participants had lower
total HEI scores than income-eligible and higher income nonparticipants
(55, 57, and 60 points, respectively).[38DD] SNAP
participants scored lower for total fruits, whole fruits, total
vegetables, and added sugar components.[38DD]
Adults participating in SNAP had a higher prevalence of obesity than
matched income-eligible nonparticipants (44 versus
38%).[38DD] Children participating in SNAP had a
higher prevalence of elevated blood pressure compared with higher
income non-participant children (9 versus
7%).[38DD] In terms of disease risk, a higher
percentage of SNAP participants than either income-eligible or higher
income nonparticipants had very high or extremely high-disease risk (31
versus 27%, and 26 and 11% versus 8 and 7%,
respectively).[38DD]
A study of 1999-2008 NHANES data found that children who received
SNAP benefits had substandard diets, consuming 43% more SSBs, 47% more
high-fat dairy, and 44% more processed meats than income-eligible
nonparticipants.[39]
A study of 1999-2014 NHANES data found that between 2003 and 2014,
SNAP participants had less improvements in diet quality using American
Heart Association (AHA) diet scores than both income-eligible
nonparticipants and higher income individuals.[40]
Disparities in diet quality persisted for most foods and nutrients and
worsened for processed meats, added sugars and nuts and
seeds.[40]
In addition to NHANES, sales data have also been used to assess
foods purchased using SNAP benefits. Sales data obtained from a large
supermarket chain in the northeastern United States from April 2012 to
April 2014 revealed that customer transactions paid at least partially
with SNAP benefits included lower spending on fruits, vegetables, and
poultry, and higher spending on SSBs, red meat, and convenience foods
than transactions that did not involve SNAP.[41] A USDA
study assessed the content of SNAP purchases in 2011 from a leading
retailer and found that soft drinks were the number one purchase in
terms of share of expenditures by SNAP households and the number two
purchase by non-SNAP households.[42]
Lessons Learned From Other Federal Feeding Programs
In contrast to SNAP, other USDA feeding programs targeting children
perform better with respect to diet quality. The NSLP, SBP, the Child
and Adult Care Food Program, and the WIC Program all apply nutrition
standards based on the Dietary Guidelines for Americans.
The Healthy Hunger-Free Kids Act (HHFKA) in 2010 established
stronger nutrition standards for the NSLP and SBP, which significantly
improved dietary quality. Specifically, the HHFKA regulations required
schools to increase the amount of fruits and vegetables served and
limit starchy vegetables; serve only low-fat or fat-free milk; and
serve more whole grains.[43] The HHFKA also established
standards for food and beverage products sold in schools outside of the
breakfast and lunch programs, which eliminated most sugary beverages
and reduced the sugar and calorie content of food products for
sale.[44] Following the changes, the USDA found that the
nutritional quality of NSLP lunches increased significantly between
school year 2009-2010 and school year 2014-
2015.[45DD] Evaluations found that students
consumed more fruit, vegetables, whole grains, and fewer starch
vegetables than before the HHFKA, without contributing to increases in
food waste or reductions in program
participation.[45DD, 46] The mean total HEI-2010
score for NSLP lunches increased 41%--from 57.9 to 81.5 out of a
possible 100.[45DD]
Unlike SNAP, which does not limit food or nonalcoholic beverage
purchases, WIC purchases are limited to different food packages for
different groups of participants. Research has shown that WIC lowers
Medicaid costs for participating women, and WIC participation is
associated with longer gestation periods, higher birth weight, and
lower infant mortality.[47, 48] The WIC food packages were
revised in 2009 to align with the Dietary Guidelines for Americans more
closely and to introduce incentives for the purchase of fruits and
vegetables, which research showed was associated with a 17.5 and 27.8%
increase in fresh and frozen vegetable purchases (respectively) and a
28.6% increase in fresh fruit purchases.[49] The Centers for
Disease Control and Prevention (CDC) and the USDA analyzed WIC data
from 56 states and territories from 2010 and 2018 and found that 31 WIC
agencies reported significant declines in obesity among children aged
2-4 years.[50] Between 2010 and 2018, overall obesity
prevalence among WIC participants aged 2-4 years decreased from 15.9 to
14.4%.[50]
Policy Interventions To Improve Health Outcomes for Supplemental
Nutrition Assistance Program Participants
There are three evidence-based policy changes that lawmakers should
consider, and that pediatricians could support, to strengthen SNAP's
effectiveness as a health intervention for children and families, build
on the successes of WIC, CACFP and the NSLP and SBP, and help ensure
that every child reaches the age of 18 at a healthy weight. First,
policymakers should make diet quality a core SNAP objective and define
and report on nutrition security. SNAP's current core objectives (food
security and fiscal integrity) should be continued and supplemented
with an additional, Congressionally mandated focus on diet quality and
healthy nutrition. Adding a diet quality component to SNAP's current
core objectives could be accomplished through the next farm bill (the
omnibus, multiyear law that governs U.S. agricultural and food
programs), an Executive Order, or a voluntary internal policy change at
USDA. Once this core objective is in place, the USDA Economic Research
Service (ERS) should include nutrition security in its annual reporting
of U.S. food security. Nutrition security should be defined using an
evidence-based metric such as USDA's HEI (e.g., nutrition-security
defined as HEI of 80 or higher, nutrition-insecurity at HEI between 80
and 60, and very-low-nutrition security defined as HEI below 60). In
addition, the USDA should report on any policy changes that have been
made to improve diet quality and nutrition, the impact of USDA policies
on diet quality and healthy eating, and any additional authorities that
the USDA has identified it needs in order to improve diet quality,
nutrition, and healthy eating.
Second, policymakers should strengthen requirements for SNAP-
authorized retailers to promote healthier retail food environments,
especially for large retailers such as Walmart, Kroger, and Amazon.
SNAP-authorized retailers are currently required to either stock three
units of three different varieties for each staple food category
(vegetables or fruits; dairy products; meat, poultry, or fish; breads
or cereals) on a continuous basis or a store must have more than 50% of
its total gross retail sales from the sale of staple
foods.[44] Despite these requirements, research shows that
SNAP authorized retailers offer comparatively fewer fresh fruits and
vegetables, whole-grain foods and low-fat dairy products in lower
income communities than retailers in higher income
communities.[51-55] SNAP retailers should be prohibited from
in-store (brick and mortar and on-line) marketing of unhealthy foods
such as sugar-sweetened beverages (SSBs) (e.g., endcap displays and
favored placement, including for online purchases).
Third, policymakers should support healthy purchases in SNAP by
pairing incentives for purchasing fruits, vegetables, and other healthy
foods with restrictions on unhealthy foods and sweetened beverages.
Today, soft drinks are top commodity typically purchased by SNAP
households.[42] Evidence suggests that restricting SSB
purchases in SNAP could reduce the calories consumed from SSBs by 15%
and reduce negative health consequences including obesity prevalence
and diabetes.[56] A separate study of the impact of
restricting SSBs on children's health found that if SSBs were
substituted with fruit juice and milk, the restriction would be
expected to reduce obesity prevalence among SNAP participants by 6.2
percentage points.[57DD] A randomized controlled
trial found that pairing incentives for purchasing more fruits and
vegetables with restrictions on the purchase of less nutritious foods
(e.g., SSBs, sweet baked goods, candies) improved diet quality, reduced
consumptions of SSBs and sweets, and increased fruit intake compared
with individuals who made purchases with no restrictions or
incentives.[58]
A survey of public attitudes towards policies to improve the
nutritional impact of SNAP, including SNAP participants, found that 82%
of respondents supported providing additional benefits to SNAP
participants that can only be used on healthful foods, 69% of
respondents supported removing SNAP benefits for SSBs, and of the 46%
of respondents who initially opposed removing SSBs, 45% supported
removing SNAP benefits for SSBs if the policy also included additional
benefits to purchase healthful foods.[59]
Multiple-expert, nonpartisan bodies have supported one or more of
these recommendations, including the National Commission on Hunger; the
Bipartisan Policy Center; Healthy Eating Research; and the Report of
the 50th Anniversary of the White House Conference on Food, Nutrition,
and Health.[60-63] They also build on the recommendations of
the Dietary Guidelines for Americans; the CDC; the National Academy of
Medicine; and the WHO.[64-67]
How Pediatricians Can Leverage These Learnings
Pediatricians can act to improve SNAP's efficacy as a health
intervention by urging the American Academy of Pediatrics (AAP) to
advocate for the three aforementioned policy recommendations in its
legislative priorities. They can also advocate individually and with
their local colleagues to their Senator & Representative to make these
changes in the 2023 Farm Bill. Pediatricians can become involved with
their state SNAP-Education (SNAP-Ed) program (SNAP-Ed is USDA's largest
nutrition-education and obesity-prevention program) and seek to have
our three recommendations implemented at the state level using SNAP-Ed
funds.
Conclusion
SNAP has demonstrated its benefit as an economic support for
children and families to reduce food insecurity and allow for greater
spending on other vital expenditures, such as healthcare. However,
research suggests that there is an opportunity to improve its efficacy
as a health intervention for children and families, in line with other
Federal food assistance programs.
Acknowledgements
Nourish Science (https://nourishscience.org/) for funding writing
and open access.
Financial support and sponsorship
None.
Conflicts of interest
There are no conflicts of interest.
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Papers of particular interest, published within the annual period of
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Article 2
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[https://www.forbes.com/sites/michaelbernick/2023/06/06/work-
requirements-the-ongoing-lessons-of-america-works/?sh=1ba5b7bb5765]
Work Requirements? The Ongoing Lessons Of `America Works'
Michael Bernick,\1\ Contributor
---------------------------------------------------------------------------
\1\ https://www.forbes.com/sites/michaelbernick/.
Jun. 6, 2023, 09:40 a.m. EDT
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
``Are there no workhouses?'', Scrooge asks the two men
soliciting donations for the poor. Today, critics of work
requirements compare these requirements to the workhouses of
the past. But the truth is much different.
Merchant's House Museum
(Work requirements for government benefit recipients emerged
as a major issue in the debt ceiling negotiations, and will be
a major issue going forward. It's time to listen to those who
know best the impact of these requirements: former benefit
recipients and the community groups that have assisted them.)
In the recent debt ceiling negotiations, work requirements for TANF
(welfare) recipients and SNAP (food stamp) recipients became one the
most contentious items. Democratic legislators denounced these
requirements as ``cruel'', ``heartless'', and ``senseless'', and vowed
to continue to oppose them.
One need not romanticize or oversell the 1996 Federal welfare
reforms and current work requirements to recognize the value that work
requirements have come to play over the past twenty-five years. These
work requirements have changed the culture and practice of welfare
offices in better assisting welfare recipients into employment. This
point is made repeatedly by those who should know best: former welfare
recipients and the workforce groups that have assisted them. Let's
listen to one of the major nationwide workforce groups involved today
in implementing work requirements.
Since its founding in 1984 by Peter Cove and Lee Bowes, America
Works has provided job preparation, placement and retention for
unemployed welfare recipients, ex-offenders, workers with disabilities,
the homeless and veterans. Over the years, it has grown to one of the
largest such agencies in the nation, with offices in 27 cities, serving
nearly 40,000 clients per year.
``What we do in job placement is not rocket science,'' notes
America Works Chief Operating Officer David Aguado. That's true.
America Works has always been about doing the basics most effectively.
It has fine-tuned training, placement and retention processes over the
years, and its growth has been driven by results. It provides
individualized services of assessment, placement, on-going support
following placement, and on-going skills upgrading for mobility. It has
a library of over 1,000 in-person and virtual training curricula, and
ties with both major national employers and local employers in each of
its service areas.
In the early years of America Works, Cove and Bowles helped spread
the ``strengths-based'' model for employment. Whereas others in the
welfare and social work systems looked at welfare recipients and saw
mainly weaknesses and dysfunction, America Works emphasized the
strengths that these persons brought to the job market. Whereas others
talked of why welfare recipients were not ready for employment, America
Works embraced direct job placement, and an advancement process of ``a
job, a better job, a career.''
As Bowes recalls, work requirements significantly improved the
employment prospects of welfare recipients, especially after the
Federal welfare reform of 1996. They did so in two important ways.
First, work requirements changed the culture of welfare offices. After
welfare reform, welfare offices developed from a culture of benefit-
distribution, suspicion, and paperwork to one of employment and action.
Bowes explains:
``When we began in the 1980s, welfare caseworkers were only
telling clients ways to increase benefits. With welfare reform
the culture changed to an employment focus. Though caseworkers
initially felt threatened that they would lose their jobs, they
came to find their new roles much more gratifying.''
Second, work requirements helped move forward a portion of the
welfare population who had become stuck in their lives--due to
depression or inability to identify resources, or a hundred other
different reasons. The work requirements helped them to get
``unstuck''.
``At the beginning people were so afraid because many
believed no one would ever hire them. As they saw their friends
get jobs and keep jobs their motivation increased. I remember
one woman who saw a neighbor, walking down the city streets,
dressed at 8 in the morning. She was told that her neighbor
obtained a job and here's where you should go to get a job.
Word of mouth and the efforts on the government totally
transformed the nature of the lives of those on public
assistance.''
Today, America Works collaborates in job placement with social
services departments and local workforce boards throughout the nation,
including in Fresno County, California. Blake Konczal, the Executive
Director of the Fresno Regional Workforce Development Board, has been
active in the public workforce system since the 1990s. In Fresno
County, the years since the welfare reform of 1996 have resulted in a
heightened job placement orientation at the social services department,
and partnership with the workforce board. Additional supports and
supportive services have accompanied the work requirements, to aid the
transition of TANF recipients into jobs. Konczal explains:
``Welfare reform in 1996 and the work requirements brought
new and logical partnerships between local workforce boards and
social service offices. Logical in that we had a common goal of
assisting public welfare recipients into unsubsidized
employment. Welfare offices came to see themselves in a new
way, as job placement agents. This was of immense benefit to
the entire workforce system and more importantly to our common
(and now employed) clients.''
America Works provides employment preparation and job search
assistance as part of the County's Job Readiness program (JobWISE).\2\
Nuvia Varela, the program manager for America Works in Fresno, adds:
---------------------------------------------------------------------------
\2\ https://www.youtube.com/watch?v=jhZ5bOdvpOg.
``It can be challenging for many of our participants to find
and keep a job due to coping with many obstacles such as
substance abuse, domestic violence, child support, or mental
health issues. JobWISE allows us to meet the needs of the
participant and assist them in achieving financial independence
---------------------------------------------------------------------------
in our community.''
Marsha Netus, Vice President and Regional Director of America Works
in the Baltimore-Washington D.C. area, has been involved in placement
efforts for TANF recipients and also ex-offenders since the late 1990s.
Today, one of her main projects is a bail diversion initiative for non-
violent offenders in Baltimore, that incorporates strong work
requirements. She highlights the structure that work requirements have
provided for ex-offenders as well as TANF recipients:
``Individuals not accustomed to a formalized system like a
basic work schedule often struggle adapting into employment.
Getting a job is not the issue; learning to sustain a routine
can be daunting for those reentering into the workplace. A
formalized system like work requirements can be the stepping
stone for this training.''
Netus further notes that in practice welfare departments make wide
allowance for recipients who have significant mental or physical health
illnesses or other serious impediments to employment. These recipients
are exempted from work requirements. There remains wide discretion in
the program administration, that is utilized by individual case
managers.
``America Works is not oblivious to the challenges that
affect families into complying with regulations. We pride our
ourselves in fostering relationships that provide comprehensive
services for those transitioning into employment. Our
collaboration with local agencies ensure customers have the
adequate support for success. There are cases where exemptions
may be the best course of action, and provisions are already
available to support them.''
America Works is only one of hundreds of workforce providers
throughout the nation that daily interact with benefit recipients. I
urge critics of work requirements to talk to these providers as well as
former recipients of TANF, food stamps or bail diversion programs.
No one in the workforce system regards the work requirements as the
full answer. Other policies remain to be developed, particularly
policies that can improve low wage jobs for all workers.\3\ But the
work requirements are one element in an effective workforce system.
---------------------------------------------------------------------------
\3\ https://www.forbes.com/sites/michaelbernick/2023/05/16/hell-to-
pay-michael-lind-on-a-true-good-jobs-strategy/?sh=5b7d22bb4d16.
---------------------------------------------------------------------------
Meanwhile, America Works itself evolves with the evolving job
market, updating training curricula, adding new programs for workers
with disabilities as well as refugees, introducing a Fellows program
for aspiring workforce professionals. Cove and Bowles continue to be at
the center of America Works, not at all beaten down, even after nearly
a half century of battling the social welfare and political
establishments.
Article 3
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.foxbusiness.com/economy/job-openings-unexpectedly-surge-
april-highest-level-months]
May 31, 2023 11:57 a.m. EDT
Job openings unexpectedly surge in April to highest level in 3 months
Job vacancies surge above 10M, keeping pressure on the Federal Reserve
By Megan Henney,\1\ FOXBusiness \2\
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\1\ https://foxbusiness.com/person/h/megan-henney.
\2\ https://www.foxbusiness.com/.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Probability for July rate cut falls on strong jobs data \3\
---------------------------------------------------------------------------
\3\ https://www.foxbusiness.com/video/6326849329112.
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NewEdge Wealth chief investment officer Cameron Dawson discusses
seasonal stretch as investors eye the Presidential cycle for stock
guidance on 'Making Money with Charles Payne.'
U.S. job openings unexpectedly jumped in April to the highest level
in 3 months, keeping pressure on Federal Reserve policymakers as they
try to cool the economy with an aggressive interest-rate hike campaign.
The Labor Department said Wednesday that there were 10.1 million
job openings in April, an increase from the upwardly revised 9.75
million openings reported in the previous month. Economists surveyed by
Refinitiv expected a reading of 9.38 million.
It marked a major increase from March, when the government reported
an upwardly revised 9.75 million number of available jobs.\4\
---------------------------------------------------------------------------
\4\ https://foxbusiness.com/category/jobs.
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Job openings remain historically high: Before the COVID-19 pandemic
\5\ began in early 2020, the highest on record was 7.6 million. There
are roughly 1.7 jobs per unemployed American.
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\5\ https://www.foxbusiness.com/category/coronavirus.
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The Housing Recession Isn't Over Yet \6\
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\6\ https://foxbusiness.com/economy/housing-recession-isnt-over-
yet.
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A general view shows construction workers standing before the
Manhattan skyline and Empire State Building in New York City on
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Jan. 24, 2023. (Ed Jones/AFP via Getty Images/Getty Images).
The Federal Reserve \7\ closely watches these figures as it tries
to gauge labor market tightness and wrestle inflation under control.
The higher-than-expected figure indicates that demand for employees
still far outpaces the supply of available workers.
---------------------------------------------------------------------------
\7\ https://foxbusiness.com/category/the-fed.
---------------------------------------------------------------------------
The central bank has responded to the inflation crisis and the
extremely tight labor market by raising interest rates at the fastest
pace in decades. Officials have so far approved ten straight rate hikes
and have signaled that another increase is on the table at their June
meeting following a slew of surprisingly hot economic data.
The latest jobs data could give policymakers more space to hike
again.
Traders are now pricing in a 66.3% chance of another quarter-
percentage-point increase during the Fed's June 13-14 meeting--a
significant rise from just 1 day ago, when 36.4% projected another
hike, according to the CME Group's FedWatch tool.
Majority Of Workers Regret Quitting During `Great Resignation' \8\
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\8\ https://foxbusiness.com/economy/majority-workers-regret-
quitting-during-great-resignation.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
A ``Now Hiring'' sign is seen outside a job fair at a
Schneider Electric manufacturing facility in Hopkins, South
Carolina, on Jan. 18, 2023. (Micah Green/Bloomberg via Getty
---------------------------------------------------------------------------
Images/Getty Images)
``Not only did today's job openings number came in much stronger
than expected at 10.1 million, last month's number was revised
higher,'' said Mike Loewengart, head of model portfolio construction at
Morgan Stanley Global Investment Office. ``Friday's jobs report may
tell a different tale, but this is just one more sign the labor market
is still hot and raises the pressure on the Fed to raise interest rates
further this year.''
The number of Americans quitting their jobs, meanwhile, was mostly
unchanged at 3.8 million, or roughly 2.4% of the workforce, indicating
that workers remain confident they can leave their jobs and find
employment elsewhere.
Switching jobs has been a windfall for many workers over the past
year: Roughly 49% of job-switchers saw their real hourly wage increase
faster than inflation last year, compared with just 42% of workers who
stayed in the same job, according to recent Atlanta Fed data.\9\
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\9\ https://foxbusiness.com/economy/americans-switching-jobs-still-
seeing-huge-pay-gains.
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Article 4
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[https://nypost.com/2023/06/10/the-political-battle-over-food-stamps-
and-welfare-programs/]
The political battle over food stamps and welfare programs
By Peter Cove \1\ and Jason Turner \1\
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\1\ https://nypost.com/2023/06/10/the-political-battle-over-food-
stamps-and-welfare-programs/.
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June 10, 2023 4:00 p.m.
Updated \1\
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The debt-ceiling deal from earlier this month thrust the
issue of work requirements for welfare and food stamps back
into the spotlight. During the Giuliani Administrations,
programs were devised to help support such requirements--but
they've mostly been disbanded.
Shutterstock.
The furious Beltway debate over raising the national debt ceiling
earlier this month mostly hinged on just a few Federal programs, with
Republicans aiming to score political points for cutting spending and
Democrats committed to preserving entitlements at all costs.
One issue featured in the debate inspired superheated rhetoric from
both sides of the political spectrum: food stamps.
The nation's largest welfare program has grown dramatically since
2000: from 17 million to 41 million \2\ recipients, even though
unemployment has dropped from 4% to 3.4% during the same period. Today
in the prime working-age years of 18-49 only 28% of singles without
dependents and 50% of adults \3\ with school age children are working.
Why is that?
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\2\ https://fns-prod.azureedge.us/sites/default/files/resource-
files/SNAPsummary-5.pdf.
\3\ https://www.bls.gov/data/.
---------------------------------------------------------------------------
Currently, few food stamp recipients are required to either work or
look for work as a condition of receiving benefits. Over the past
decade, the work-based welfare reforms which were so successful in the
1990s have been mostly dismantled. Which is why the debt ceiling's most
significant provision may be a renewed focus on compulsory employment
for older recipients of food stamps,\4\ which are officially known as
SNAP (Supplemental Nutrition Assistance Program).
---------------------------------------------------------------------------
\4\ https://www.nytimes.com/2023/05/29/us/politics/debt-limit-deal-
food-stamps.html.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
While some older Americans may now be forced to work to
receive food stamps under the debt deal, veterans will be
exempt from such rules.
Getty Images.
Food stamp benefits are associated with a host of chronic diet-
related conditions, such as hypertension, obesity, diabetes and heart
disease. The diseases exist among some 30% of adults \5\ receiving
benefits, and are only exacerbated by idleness and non-work.
---------------------------------------------------------------------------
\5\ https://www.aei.org/wp-content/uploads/2023/04/Promoting-
Mobility-Through-SNAP.pdf
?x91208.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Under the debt-limit deal, some Americans 54 and under will be
compelled to work in order to receive foods stamps; previously the cut-
off age was 49. But the deal also exempts from work employment
obligations those who need it most: homeless folks with drug addictions
who would benefit from structured workdays while they recover;
unemployed veterans who have shown themselves able-bodied enough to
defend the country; and foster-care children turning 18 and about to be
launched into adulthood and self-care.
These three populations are among the most in need of work and
income. Yet progressives treat them as if no-strings-attached coddling
is actually in their best interests.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
During the tenure of former Mayor Rudy Giuliani, mandates
were initiated to compel folks receiving food stamps and
welfare to also secure employment. By the end of his tenure,
42% of welfare recipients were in the labor force, up from 16%
before he took office.
Getty Images.
In the 1990s, Mayor Rudy Giuliani declared he wanted all welfare
recipients to go to work. But not all welfare recipients want to work.
So the Giuliani Administration developed a welfare system in which work
obligations were applied to applicants of all capabilities--which we
called ``universal work engagement.''
Three work tiers were created, starting with unsubsidized private
work. During the 6 week application process, every applicant was
obligated to participate in a formalized job search overseen by the
City's welfare agency. The vast majority of applicants went right to
work on their own once they knew that benefits would not otherwise be
forthcoming.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
The next tier was the Work Experience Program (or WEP)--city
``workfare'' jobs. At its peak, over 4,000 recipients served New York
by working in the parks, maintaining city streets and answering phones
in city offices, all in exchange for temporary assistance.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Homeless folks will also be exempt from work mandates even
though they are among the most in need of steady employment.
Getty Images.
Last, for those who claimed a health condition, the new system did
not just accept a ``doctor's note.'' New York's welfare agency hired
its own physicians, who performed a rigorous, independent health review
of each applicant. Most were found capable of work and were required to
do so. Only 17% of those claiming health problems were deemed likely to
qualify for Federal disability.
The Giuliani reforms did not stop there. The mayor also ended the
usual practice of awarding guaranteed contracts to private agencies
which ``help'' recipients find work. Instead, he only paid these
nonprofit and for-profit agencies each time they placed a recipient in
a job. Bonuses were awarded for the newly employed who remained in
their jobs. Unsurprisingly, many of those private agencies ended their
partnerships with City Hall or went bankrupt.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Food stamps are the nation's largest welfare program with
some 41 million recipients nationwide.
Shutterstock.
Other organizations such as America Works, thrived in the new
environment, viewing work not as a four-letter-word, but as a vital
weapon in the war on poverty. As we chronicled in our recent
documentary, Gotham: The Fall and Rise of New York,\6\ welfare rolls in
New York City dropped from 1.2 million to an astounding 300,000 in just
over a decade.
---------------------------------------------------------------------------
\6\ https://gothammovie.com/.
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Two years into Mayor Giuliani's term in 1996 the census bureau
found that of New York's single mothers without a high school education
only 16% were working. By 2001, Giuliani's last year 42% were in the
labor force.\7\
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\7\ https://smhttp-ssl-58547.nexcesscdn.net/nycss/images/uploads/
pubs/MotherWork.Sept20
02.pdf.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Decades ago, thousands of New Yorkers were involved in
``workfare'' programs which helped them secure employment while
they received aid. The program was criticized and protested by
some progressive groups.
Boycott Workfare.
About \1/3\ of young adult food stamp recipients report feeling
hopeless or worthless. Work requirements for welfare benefits are not
cruel and unusual; rather those required to work typically thrive both
during and after participation in mandatory employment programs.
Article 5
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.reuters.com/markets/us/us-job-openings-unexpectedly-rise-
april-2023-05-31/]
US labor market remains resilient as job openings climb, layoffs drop
By Lucia Mutikani \1\
---------------------------------------------------------------------------
\1\ https://www.reuters.com/authors/lucia-mutikani/.
May 31, 20235:12 PM EDT Updated 21 days ago
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Job openings increase 358,000 to 10.1 million in April
Layoffs drop 264,000; voluntary quits decrease 49,000
Washington, May 31 (Reuters)--U.S. job openings unexpectedly rose
in April and data for the prior month was revised higher, pointing to
persistent strength in the labor market that could compel the Federal
Reserve to raise interest rates again in June.
The Job Openings and Labor Turnover Survey, or JOLTS report, from
the Labor Department on Wednesday also showed layoffs declined
significantly last month. There were 1.8 job openings for every
unemployed person in April, up from 1.7 in March, and well above the
1.0-1.2 range that is considered consistent with a jobs market that is
not generating too much inflation.
The report added to data this month, including consumer spending,
in suggesting that the economy regained speed at the start of the
second quarter.
Demand has remained resilient despite 500 basis points worth of
interest rate increases from the Fed since March 2022, when the U.S.
central bank embarked on its fastest monetary policy tightening
campaign since the 1980s to tame inflation. The flow of strong data has
diminished expectations that the Fed could pause further rate increases
next month.
``This is not what the Fed was hoping to see,'' said Priscilla
Thiagamoorthy, a senior economist at BMO Capital Markets in Toronto.
Job openings, a measure of labor demand, increased by 358,000 to
10.1 million on the last day of April. Data for March was revised
higher to show 9.75 million job openings instead of the previously
reported 9.59 million. The April data ended three straight monthly
decreases in job vacancies. Economists polled by Reuters had forecast
9.375 million job openings.
The increase in job vacancies was led by retail trade, where there
were an additional 209,000 openings. There were 185,000 more job
openings in healthcare and social assistance, while vacancies jumped by
154,000 in the transportation, warehousing, and utilities sector.
Notable increases were also reported in construction as well as finance
and insurance industries.
But job openings declined in durable goods manufacturing, which has
seen demand for goods slowing as higher interest rates increase the
cost of credit. Spending is also shifting back to services.
Job openings surged in the West and Midwest. They rose moderately
in the South, but fell in the Northeast.
Businesses with one to nine employees and those with 250 to 999
workers accounted for last month's rise in job vacancies. Companies
with 10 to 49 workers reported a sharp drop.
The job openings rate rose to 6.1% from 5.9% in March.
The Fed's ``Beige Book'' \2\ report on Wednesday described the
labor market as having ``continued to be strong'' in May, ``with
contacts reporting difficulty finding workers across a wide range of
skill levels and industries.''
---------------------------------------------------------------------------
\2\ https://www.reuters.com/markets/us/us-economy-little-changed-
recent-weeks-outlook-deteriorated-fed-survey-2023-05-31/.
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But it also noted that contacts across districts reported that
``the labor market had cooled some, highlighting easier hiring in
construction, transportation and finance.''
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
A 7-Eleven convenience store has a sign in the window reading
``Now Hiring'' in Cambridge, Massachusetts, U.S., July 8, 2022.
Reuters/Brian Snyder
Stocks on Wall Street were trading lower. The dollar rose against a
basket of currencies. U.S. Treasury prices rose.
JOLTS: U.S. Labor Market Churn
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: Refinitiv Datastream--Reuters graphic/Stephen Culp
31/05/2023.
Fewer Resignations
Minutes of the Fed's May 2-3 policy meeting,\3\ which were
published last week, showed policymakers ``generally agreed'' the need
for further rate hikes ``had become less certain.''
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\3\ https://www.reuters.com/markets/us/fed-agreed-may-need-more-
rate-hikes-was-less-certain-meeting-minutes-show-2023-05-24/.
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Some economists are, however, skeptical that the JOLTS report is
offering a clear read of the labor market.
According to Goldman Sachs economist Ronnie Walker, a low response
rate to the survey, which has reduced the sample size, could be
boosting the JOLTS data, noting that some alternative measures of job
openings from LinkUp and ZipRecruiter, have declined sharply in the
past year.
But Walker also acknowledged that some of the alternative measures
of job openings could be downwardly biased, as their samples could be
skewed toward companies which are more likely to have an online
presence and have cut job openings sharply.
``As a result, we suspect that the `true' level of job openings
lies somewhere in the middle of the range implied by JOLTS and
alternative measures of job openings,'' Walker said.
The JOLTS report showed layoffs fell 264,000 to 1.6 million,
consistent with the very low levels of weekly unemployment claims data.
Layoffs decreased by 113,000 in construction, another sector hard hit
by the Fed's rate hikes.
There were also notable declines in information, leisure and
hospitality as well as healthcare and social assistance.
Despite the strong demand for labor, workers are growing less
confident, leading to fewer resignations. The quits rate, viewed as a
measure of labor market confidence, fell to 2.4% from 2.5% in March.
That aligns with a Conference Board \4\ survey on Tuesday that
showed the share of people viewing jobs as ``plentiful'' dropped in May
to the lowest level since April 2021.
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\4\ https://www.reuters.com/markets/us/us-consumer-confidence-dips-
may-survey-2023-05-30/.
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Resignations declined in the professional and business services,
healthcare and social assistance categories as well as in durable goods
manufacturing. They dropped in the Northeast and South. There were
modest increases in the West and Midwest.
``This suggests that the labor market is slackening, despite the
reported increase in job openings, and that workers are increasingly
sheltering in place in their jobs as better alternatives become less
available,'' said Julia Pollak, chief economist at ZipRecruiter.
Reporting by Lucia Mutikani; Editing by Andrea Ricci and Paul
Simao.
Article 6
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[https://www.washingtonexaminer.com/news/michigan-catches-4m-of-food-
stamp-fraud-mum-on-fraud-scope]
Michigan catches $4M of food stamp fraud; mum on fraud scope
By Scott McClallen\1\D The Center Square
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\1\ https://www.washingtonexaminer.com/news/michigan-catches-4m-of-
food-stamp-fraud-mum-on-fraud-scope
June 03, 2023 08:45 a.m.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
(The Center Square)--Standing in the checkout lines or in virtual
lines at Sam's Clubs in metro Detroit, criminals are spending
government benefits stolen from people more than 2,000 miles away in
California.
On May 24, three people--Travis Newby, 39, of Detroit, Derriun
Williams, 23, of Detroit, and Vanessa Williams, 47, of Highland Park--
were arrested and arraigned on felony charges.
The three are charged in connection to $4 million of interstate
food stamp fraud wherein they allegedly obtained electronic benefit
card data from 8,000 cardholders mostly residing in California.
The trio allegedly reproduced EBT cards in Michigan and then spent
funds on fraudulent purchases from metro Detroit Sam's Club stores.
The amount of SNAP fraud known by Michigan is unclear. The Center
Square's record request seeking that number from The Michigan
Department of Health and Human Services has been pending for 2 months.
That request was approved but hasn't been fulfilled as of Wednesday,
May 31.
The state health department plans to fight SNAP fraud by blocking
common PINS, restricting card functionality in high-fraud areas, and
giving more access to a fraud interface system, according to documents
obtained through the Freedom of Information Act.
MDHHS submitted a plan to reduce SNAP fraud to the United States
Department of Agriculture's Food and Nutrition Services, which doesn't
appear to be approved yet.
Haywood Talcove, the CEO of LexisNexis Risk Solutions' Government
Group, which provides fraud prevention tools to 26 state unemployment
programs and the 50 top U.S. banks, told The Center Square that state
government should take additional steps to prevent fraud.
``The needed resources to investigate each of these claims is
significant, it goes well beyond a signature and requires access to
third-party tools, law enforcement databases, etc.,'' Talcove wrote in
an email. ``These investigations many of which will center around
criminal groups need to be conducted by trained law enforcement
personal with arrest authority.''
Talcove recommended Michigan eliminate SNAP card functionality
outside of the state. He suggested state government file police reports
to help investigators crack organized criminal groups.
``Their report is like moving deck chairs around the Titanic--it
does nothing to prevent fraud, it does nothing help the food-insecure
whose benefits are stolen and it hasn't even been approved by USDA,''
Talcove wrote in an email.
The Federal Government must approve Michigan's plan before the
state can enact solutions to save taxpayer money.
For example, Ohio submitted its plan to reduce SNAP fraud in late
February. USDA didn't approve the plan until May, which will be enacted
in late July, according to documents obtained by The Center Square.
Michigan's plan included restricting EBT usage in areas of high
fraud, which Talcove said does nothing to stop identity fraudsters from
stealing SNAP benefits from vulnerable citizens.
``Worse, it only creates a barrier to access for legitimate SNAP
recipients, especially those living in `high fraud' areas,'' Talcove
wrote. ``Worse yet, this policy can disproportionately impact
minorities. This goes against common sense administration.''
Nessel says more arrests are expected as Michigan works with seven
other retailers to investigate millions of dollars of taxpayer fraud.
Article 7
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[https://www.wsj.com/articles/house-republicans-welfare-work-
requirements-debt-ceiling-negotiations-pete-aguilar-democrats-1ebc862d]
The GOP Can Win on Work Requirements and Welfare
The details show how reasonable the House debt-ceiling
proposals are.
By The Editorial Board \1\
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\1\ https://www.wsj.com/news/author/editorial-board.
Updated May 17, 2023 7:00 p.m. ET
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Photo: Will Oliver/EPA/Shutterstock.
House Republicans are holding firm as they negotiate a deal with
President Biden to raise the debt ceiling--a small miracle for the
GOP--and one sticking point is work requirements in welfare. Democrats
are digging in, calling the rules this week a ``nonstarter,'' but the
attacks are false, and the GOP has the high ground on the merits and
the politics.
The House GOP's Limit, Save, Grow Act that passed this spring
stiffens work requirements in programs such as food stamps and
Medicaid. The Supplemental Nutrition Assistance Program currently
stipulates 20 hours per week of work or training for able-bodied adults
under age 50 without children. Those who don't comply can only receive
benefits for 3 months out of every 36.
House Republicans want to raise the age requirement to 55. The bill
would also crack down on states that water down the requirements with
exemptions. Decide for yourself if a part-time work program aimed at
able-bodied men without children at home constitutes taking ``food out
of the mouths of kids,'' as House Democrat Pete Aguilar said in a
Tuesday press conference.
Then there's the cash benefit Temporary Assistance for Needy
Families (TANF). As a condition of Federal funding, states are supposed
to engage at least half of families in some type of work, including
training or job hunting. But only six states hit the 50% target in
2021, according to the House Ways and Means Committee,\2\ and 34 had a
0% effective rate.
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\2\ https://waysandmeans.house.gov/wp-content/uploads/2023/04/
Restoring-Work-Requirements-in-TANF_one-pager55.pdf.
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Why? For one, states can claim a ``credit'' against the work target
if they reduce their caseload relative to the welfare year 2005, and
most do. Republicans would update the year to 2022 so states can't
exploit this provision based on antiquated data. What radicals.
States can also pay away the work requirement by spending more of
their own money on the program, which the GOP wants to end. Most
egregious: Some states goose their stats by sending $10 or $20 TANF
checks to food-stamp recipients who work, and then counting them in
their calculations. The term for this is scam, and offenders include
California \3\ and Oregon.
---------------------------------------------------------------------------
\3\ https://www.aei.org/opportunity-social-mobility/is-president-
biden-about-to-triangulate-democrats-on-welfare-work-requirements/.
---------------------------------------------------------------------------
The GOP's boldest proposal is to introduce a work requirement in
Medicaid. This is also not an obligation to hold a full-time job, and
it doesn't apply to anyone caring for dependent children or an ailing
relative, or to pregnant women, or to anyone who is in treatment for
substance abuse, among other exemptions.
The biggest budget savings from the GOP work proposals would come
from Medicaid, with the Congressional Budget Office estimating $109
billion in reduced spending over 10 years. States could still pick up
the tab for those on Medicaid who refuse to work, and CBO predicts that
many would.
President Biden acknowledged on Saturday that he has supported work
requirements in the past, most notably Bill Clinton's 1996 welfare
reform. He said Medicaid is ``a different story'' as a healthcare
program, but then why not agree on food stamps? The next day the
President's Twitter account claimed the GOP proposal would put a
million older adults at risk of ``going hungry.'' \4\
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\4\ https://twitter.com/POTUS/status/1658217034075742241.
---------------------------------------------------------------------------
Republicans didn't extend work requirements to parents, even to
those with children in school for more than 20 hours a week, and the
lesson is that such concessions don't stop Democratic attacks. But now
Republicans can hold firm, and even if Mr. Biden won't agree on
Medicaid they can bank the incremental wins and build on the progress
later.
``They're coming for the children. They're coming for the poor.
They're coming for the sick, the elderly and the disabled,'' Democrat
John Lewis wailed on the House floor in the 1995. He was wrong about
that 1996 welfare reform, which included a work requirement and has
been an engine for upward mobility. By one analysis, single-parent
household poverty fell more than 60% between 1995 and 2016.\5\
---------------------------------------------------------------------------
\5\ https://www.cato.org/research-briefs-economic-policy/change-
poverty-1995-2016-among-single-parent-families.
---------------------------------------------------------------------------
Democrats have slowly reversed much of the 1996 reform in recent
years. This is one reason so many prime-age Americans are now out of
the labor force, which hurts the economy and social cohesion.
Republicans can win this debate, if they can explain that welfare
should be a temporary hand up, not a permanent sinecure in return for
doing nothing.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Wonder Land: The attorneys general of 19 states have sent a
letter to JPMorgan Chase, accusing it of discrimination against
conservative religious groups. The bank denies it. The business
of America should become business again, not politics. Images:
Zuma Press/Bloomberg News Composite: Mark Kelly.
Copyright 2023 Dow Jones & Company,
Inc. All Rights Reserved.
Appeared in the May 18, 2023, print edition as 'The GOP Can
Win on Work and Welfare'.
Article 8
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.wsj.com/articles/make-welfare-reform-part-of-the-debt-
ceiling-deal-mccarthy-biden-1996-98bf6afb]
Opinion \1\ Upward Mobility \2\
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\1\ https://www.wsj.com/news/opinion?mod=breadcrumb.
\2\ https://www.wsj.com/news/types/upward-mobility?mod=breadcrumb.
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Make Welfare Reform Part of the Debt-Ceiling Deal
The Clinton-era law added work requirements, but politicians
since have chipped away at them.
By Jason L. Riley \3\
---------------------------------------------------------------------------
\3\ https://www.wsj.com/news/author/jason-l-riley.
May 23, 2023 6:14 p.m. ET
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
A supermarket displays stickers indicating they accept food
stamps in West New York, N.J. Photo: Seth Wenig/Associated
Press.
Work requirements for healthy welfare recipients make sense to most
Americans. But in Washington those are fighting words, and they have
become a welcome point of contention in the debate over raising the
nation's debt ceiling.
House Speaker Kevin McCarthy surprised the White House and much of
the political press last month when he brought together his Republican
caucus to pass a bill that raises the debt limit. President Biden had
reasoned that GOP infighting would doom any chance of that happening
and that Democrats ultimately would be able to lift the debt ceiling
without significant policy reform. That gambit failed, and now the
pressure is on the President to compromise on a final deal. Democrats
performed better than expected in last year's midterm elections, but
they still lost control of the House.
Worse for Democrats, the House bill imposes or expands work rules
for able-bodied people who receive benefits from Federal programs.
Medicaid recipients without dependents would have to work or volunteer
for 80 hours a month. States would be limited in their ability to grant
waivers that bypass work requirements for those on food stamps. Asking
something of people on the dole is perfectly rational, but liberals in
Washington have long prioritized making the poor comfortable over
helping them out of poverty. These days, weaning people off welfare by
encouraging them to be more productive is an afterthought on the
political left.
House Democratic leader Hakeem Jeffries spoke for many in his party
when he told CNBC that the proposed work rules are ``entirely
unreasonable.'' The remark was entirely predictable. In the late 1980s
and early 1990s, welfare dependence grew by a third as people figured
out that they could receive more in public benefits than they could
earn in the labor force. When Bill Clinton joined forces with a
Republican Congress in 1996 to pass a welfare-reform bill that included
work mandates, party leaders from Ted Kennedy to Pat Moynihan and Dick
Gephardt predicted social carnage. Yet by the end of the decade, the
welfare rolls had fallen by more than 50% nationwide. Poverty rates
among blacks and female-headed households--groups with
disproportionately high welfare-use rates--also plunged.
Since then, lawmakers have chipped away at those reforms, usually
in the wake of an economic downturn. Under Democratic and Republican
Administrations, unemployment insurance has been expanded and work
requirements have been suspended. The public is assured that the
changes will be temporary, but they seldom are. Most politicians can't
resist using government largess to win over voters, and it's easy to
demonize the few who do resist. Nevertheless, this is a good fight for
Republicans to wage and the right time to wage it. That we have
millions more jobs available today than we have people looking for work
is a strong indication that these programs have become too generous.
The unemployment rate has reached historic lows, and wages have
been rising, including among historically marginalized groups. A
headline in Friday's Journal read ``Job Market for Black Workers Is
Best Ever.'' Black unemployment was a record low 4.7% in April, and the
number of blacks in the labor force today is some 1.1 million higher
than it was before the pandemic. ``Black workers have long been at the
bottom of the ladder in terms of wages and job security,'' the story
noted. ``But the confluence of strong demand for labor and demographic
shifts in the country over the past few years, when many older white
workers retired, benefited Black Americans.'' If now isn't the time to
rethink qualifications and requirements for public assistance, when is?
Too many healthy adults are opting out of work because public
policy has made unemployment too attractive. As Mr. McCarthy has noted,
Joe Biden \4\ once understood this. As a senator, he was among the
Democrats who supported the 1996 welfare reform. These days, the White
House is claiming that work requirements for food stamps would result
in mass starvation. Given that it's hard to enter a business
establishment these days without seeing a help-wanted sign, that could
be a tough sell for Democrats.
---------------------------------------------------------------------------
\4\ https://www.wsj.com/topics/person/joe-biden.
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Republicans say the reforms will help cut costs, and a
Congressional Budget Office analysis predicted savings of more than
$100 billion over 10 years. Republican lawmakers might have more
credibility with voters if they had been equally concerned about
excessive spending when Donald Trump \5\ was President, but Mr.
McCarthy is right to assume that most people don't want their tax
dollars being used by the government to subsidize laziness. I once saw
a bumper sticker that read ``Work harder: Millions of welfare
recipients are depending on you.'' So are a lot of liberals in
Washington.
---------------------------------------------------------------------------
\5\ https://www.wsj.com/topics/person/donald-trump.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Wonder Land: A beside-the-point President is the best thing
that has ever happened to the progressive centralization
project. But its success in 2024 depends on whether Republicans
back Trump or not. Images: Warner Bros/Kobal/Shutterstock/AP/
Zuma Press Composite: Mark Kelly.
Copyright 2023 Dow Jones & Company,
Inc. All Rights Reserved.
Appeared in the May 24, 2023, print edition as 'Make Welfare
Reform Part of the Debt-Ceiling Deal'.
Article 9
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.wsj.com/articles/debt-ceiling-negotiations-food-stamps-
work-requirements-welfare-foundation-for-government-accountability-
b04159f0]
Fixing the Food-Stamp Work Requirement Loopholes
New evidence shows how states let recipients skirt even part-
time work.
By The Editorial Board \1\
---------------------------------------------------------------------------
\1\ https://www.wsj.com/news/author/editorial-board.
Updated May 24, 2023 6:46 p.m. ET
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Photo: Daniel Acker/Bloomberg News.
Work requirements, even minimal ones, are a sticking point in the
debt-ceiling talks, and it's worth adding a dose of reality to the
political histrionics.
The Supplemental Nutrition Assistance Program, or food stamps, now
requires able-bodied adults ages under 50 without dependent children to
work or train 20 hours a week. Hold a part-time job or benefits expire
after 3 months. The House GOP debt-ceiling bill would raise the working
age to all of 55. States can currently exempt a certain number of
recipients, and the bill would also crack down on carrying these carve-
outs from year to year.
Democrats say the current work rules are tough enough, but what
they don't say is how much regulators have watered down what Congress
passed in the 1996 welfare reform. Take the waiver process for food
stamps. States can ask the feds to waive work requirements in areas
with high unemployment.
New research \2\ from the Foundation for Government Accountability
(FGA) shows how states have abused that privilege. Roughly half of
states are waiving requirements. States rely on antiquated data,
including figures from [COVID]-19 lockdowns, to claim that it's tough
to find a job. States also lump disparate geographic areas into a
single region to drive up jobless figures.
---------------------------------------------------------------------------
\2\ https://thefga.org/research/waivers-gone-wild-food-stamp-
loopholes.
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FGA found that, of 800 counties nationwide where work is waived,
only 20 have unemployment rates above the 10% threshold prescribed by
the waiver process. FGA says there are four million able-bodied adults
without dependents on food stamps, and three in four don't work at all.
Less than 3% work full-time.
The GOP's bill also imposes work requirements on Medicaid, which
would account for $109 billion of the $120 billion in savings from the
GOP work provisions, according to the Congressional Budget Office. The
savings are so large because the health entitlement covers so many
prime-age men out of the labor force. If Democrats can't abide work in
return for free healthcare, they should at least be willing to fix the
work loopholes in food stamps.
President Biden in 1996 said the U.S. needs a ``culture of self-
sufficiency and personal responsibility.'' Time for that guy to make an
appearance and cut a debt-ceiling deal.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Wonder Land: A beside-the-point President is the best thing
that has ever happened to the progressive centralization
project. But its success in 2024 depends on whether Republicans
back Trump or not. Images: Warner Bros/Kobal/Shutterstock/AP/
Zuma Press Composite: Mark Kelly.
Copyright 2023 Dow Jones & Company,
Inc. All Rights Reserved.
Appeared in the May 25, 2023, print edition as 'Fixing the
Food-Stamp Work Loopholes'.
Article 10
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.wsj.com/articles/debt-ceiling-deal-work-requirements-
welfare-gop-kevin-mccarthy-2dcd6029]
The GOP's Progress on Work and Welfare
The debt-ceiling deal is a step toward restoring a culture of
work.
By The Editorial Board \1\
---------------------------------------------------------------------------
\1\ https://www.wsj.com/news/author/editorial-board.
May 30, 2023 6:42 p.m. ET
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
President Joe Biden shakes hands with House Speaker Kevin
McCarthy on Feb. 7. Photo: Pool/Via Reuters.
Some Republicans aren't enthused about the debt-ceiling deal that
Speaker Kevin McCarthy brokered with President Biden--not enough
spending cuts, too few policy concessions. But one reason the deal is
worth passing: The provisions on work and welfare are incremental
progress the GOP can build on.
The Fiscal Responsibility Act makes several changes to social
safety net programs, notably food stamps. The Supplemental Nutrition
Assistance Program imposes a 3 month limit on able-bodied adults under
age 50 without dependent children--unless they work or train 20 hours a
week.
That rule was suspended during the interminable [COVID] emergency,
and spending on the program exploded to $114 billion in 2021 from $60
billion in 2019. Of four million Americans on food stamps ages 18 to 60
without a disability or children at home, fewer than 30% are in a
household with earnings. The House bill would raise the working age to
54.
States can exempt 12% of their rolls from the requirement, which
the House bill reduces to 8%. The bill also cracks down on stockpiling
these exemptions year to year. Yet another way states water down the
requirements: states can apply to suspend the rules in areas where jobs
are hard to find, and they have gerrymandered regions to goose
unemployment data.
Arizona has a statewide waiver even as the state has about 1.5 open
jobs for every person looking. Minnesota relied on data as old as
September 2020 to justify its request, according to the Foundation for
Government Accountability.\2\ The House bill forces the Agriculture
Department to publish state waiver requests and data, and the hope is
that such scrutiny can shame states into better behavior.
---------------------------------------------------------------------------
\2\ https://thefga.org/research/waivers-gone-wild/.
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The changes are similarly sensible in cash assistance known as
Temporary Assistance for Needy Families (TANF). States are supposed to
have 50% of families working. Yet states can claim a ``credit'' if they
reduce their cases compared with 2005. The House bill updates that
baseline year to 2015.
The House bill also slays an embarrassment known as the ``small
checks scheme.'' To meet the TANF work requirement, states could find
food-stamp beneficiaries who are working and mail them a $10 or $20
check. Voila! Another person is classified as working under TANF.
One mistake in the debt deal is that the food-stamp work
requirement exempts veterans and the homeless. These Americans could
perhaps most benefit from the dignity and stability of work. Ditto for
parents of children attending school, whom Republicans exempted in
their initial proposal. Some of the food-stamp provisions expire in
2030.
Still, the GOP has won improvements, and making the food-stamp work
rules permanent can be a priority for the farm bill this year.
Republicans could also flesh out their proposal to require work in
Medicaid, which Democrats refused to allow.
The left has managed over many years to water down the 1996
bipartisan welfare reform, so small improvements matter. The House bill
emphasizes that one purpose of food stamps is to help Americans find
jobs and boost their earnings. That will reinforce local administrators
trying to make welfare programs more than a check-writing exercise.
A major difference between the two political parties these days is
that most Democrats favor a culture of dependency. The GOP's task,
which is popular with voters, is to rebuild a culture of work. The
debt-ceiling bill starts to do that, which is one reason to support it.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Journal Editorial Report: Can anyone cut into Trump's big
polling lead? Images: AP/Reuters Composite: Mark Kelly.
Copyright 2023 Dow Jones & Company,
Inc. All Rights Reserved.
Appeared in the May 31, 2023, print edition as 'The GOP's
Progress on Work and Welfare'.
Article 11
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.wsj.com/articles/lost-lessons-of-the-1996-welfare-reform-
robert-doar-aei-work-requirements-snap-food-stamps-medicare-5bdd598e]
Opinion \1\ The Weekend Interview \2\
---------------------------------------------------------------------------
\1\ https://www.wsj.com/news/opinion?mod=breadcrumb.
\2\ https://www.wsj.com/news/types/the-saturday-
interview?mod=breadcrumb.
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Work Requirements and the Lost Lessons of 1996
The left fought to stop welfare reform and failed. Now they
want us to forget the law's success. But Robert Doar remembers.
By Kate Bachelder Odell \3\
---------------------------------------------------------------------------
\3\ https://www.wsj.com/news/author/kate-bachelder-odell.
June 2, 2023 6:16 p.m. ET
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Editor's note: the above video is retained in Committee file.
Wonder Land: The country is drifting right and opposition
conservatives better not miss the turn. Images: AP/AFP/Getty
Images/Zuma Press Composite: Mark Kelly. Washington.
No sooner did House Republicans and President Biden reach a debt-
ceiling deal than the histrionics began. One magazine writer accused
lawmakers of ``selling out some of America's poorest and most
vulnerable families.'' She was referring to the bill's provision that
will require some Americans to work in exchange for welfare benefits.
Rep. Ayanna Pressley (D., Mass.), said the bill \4\ ``takes food away
from hungry people.''
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\4\ https://twitter.com/RepPressley/status/1664087239515668480.
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The rhetoric is familiar. Opponents of the 1996 Personal
Responsibility and Work Opportunity Act raised similar alarms, but that
bill passed with bipartisan support, Bill Clinton signed it, and for a
time nearly everybody recognized it as a success. But the Democratic
Party has moved to the left and forgotten the policy lessons of welfare
reform.
Robert Doar remembers. Mr. Doar, 62, is President of the American
Enterprise Institute, but earlier in his career he ran safety-net
programs in New York, with stints in both state and city offices. He
spent 7 years running social services for Mayor Michael Bloomberg,
overseeing everything from cash benefits and Medicaid to food stamps.
Mr. Doar is unequivocal: Work matters, and when paired with public
assistance it's a powerful ``path out of poverty,'' a phrase he deploys
more than once in our conversation at his Washington office.
In New York City, around the time of welfare reform in 1996, Mr.
Doar says, ``the number of men, women and children on cash welfare was
1.1 million, in a city of less than eight million.'' Yet ``over a long
period of time, in multiple Administrations,'' that figure plummeted to
about 360,000, even as the city's population grew. How? By ``applying a
consistent policy focused on work.''
New York ``transformed a system that was entirely focused on
signing people up for benefits and enrolling them, and helping them
become dependent on government aid and not work, to a system that
wanted to help them get into work.'' Offices called ``income
maintenance centers'' were recast as ``job centers,'' and ``eligibility
workers'' restyled as ``job opportunity specialists.''
``We sent notices to people who didn't comply with certain
requirements that their benefits were at risk, and they complied by
going to work,'' Mr. Doar says. This wasn't a harsh order to report to
the salt mines. Government provided daycare for families with preschool
children.
``The labor-force participation rate in New York City and around
the country went from roughly 50% or less for never-married single
mothers to roughly 65% or 70%,'' Mr. Doar says. ``That is enormous
change in behavior. That was good. It gave them the dignity of work. It
gave them structure and a schedule. It gave them earnings.''
Some of his AEI colleagues have found in research that, since the
1996 welfare reform, poverty in single-parent households has dropped by
more than 60%.\5\ Yet the ``focus on work has been eroded,'' Mr. Doar
says. The current debate in Washington doesn't even involve parents,
notwithstanding the evidence that they and their children are better
off when someone in the house is working.
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\5\ https://www.cato.org/research-briefs-economic-policy/change-
poverty-1995-2016-among-single-parent-families.
---------------------------------------------------------------------------
Take food stamps, whose work rules were adjusted by Congress's
debt-ceiling bill. In theory, the Supplemental Nutrition Assistance
Program already requires adults without kids at home to work or train
for 20 hours a week: Hold down a part-time job or benefits expire in 3
months. It doesn't apply to those with disabilities, among other
exemptions.
Yet these requirements are nonexistent in practice. States can
exempt a percentage of beneficiaries right off the bat. They can then
apply for waivers based on dubious data suggesting that jobs are hard
to find--and these waivers are in effect even as a labor shortage
leaves employers desperate for more workers. ``Look at the history of
the Great Depression,'' Mr. Doar says. ``People were out of work, and
the solution was jobs. And now we have jobs available, and people
aren't taking them, but we're giving people assistance. And I think
that makes Americans uncomfortable.''
States have little incentive to behave differently. SNAP ``is 100%
Federal money,'' Mr. Doar notes. States are enrolling residents,
``sucking down the Federal money'' and funneling it to local grocery
stores. ``The problem with that is that you're not serving well the
low-income population in your community.''
One rejoinder from the left is that those on food stamps are
working. ``Many, many people do have earnings and receive these
benefits,'' Mr. Doar acknowledges. But then why fight a requirement?
``Whenever anybody says, `These individuals you're trying to impose
this work requirement on--they're working two jobs,' I want to say,
`Well, if they're working two jobs, then they're not going to be
affected by these changes.' ''
Some Americans on food stamps report ``no earnings--zero,'' Mr.
Doar says, forming a circle with his index finger and thumb. AEI
research published last month \6\ looked at able-bodied adults 18 to 49
without children at home. Only about \1/4\ worked while receiving food
stamps, and the low figure couldn't be explained away by caring for
relatives or other such obligations.
---------------------------------------------------------------------------
\6\ https://www.aei.org/wp-content/uploads/2023/04/Promoting-
Mobility-Through-SNAP.pdf
?x91208.
---------------------------------------------------------------------------
``We should ask what's going on, and let's address it,'' Mr. Doar
says. ``It's not one program. It's a combination of programs.'' More
Americans, particularly prime working-age men, are cobbling together
benefits from a constellation of benefits--from food stamps and housing
subsidies to Medicaid and disability.
The debt deal's provisions are modest. The bill Congress passed
this week would raise the maximum age at which the food-stamp work
requirement applies to 54 from 49. Some Republicans were disappointed
the bill didn't go further and revolted when the Congressional Budget
Office said the work requirements wouldn't save money. Mr. Doar argues
that work requirements aren't about ``savings'' anyway, but ``helping
people get to a healthier, stronger, more positive life'' even if they
still need government benefits while they work.
But the reason for the bad CBO score is new carve-outs from work
for veterans and the homeless. ``That was a mistake,'' Mr. Doar says.
The homeless can benefit from the stability and dignity of work.
``People on the street who you see--and your heart goes out to them--
they are recipients of public assistance,'' often in programs that
don't require work. Programs such as disability aid have ``financed
their situation without actually helping them.'' As for veterans, they
are often caricatured as traumatized or incapacitated--a stereotype
perpetrated by endless movies about deranged Vietnam vets. Most
veterans are more capable, not less, for their years in uniform.
Yet while Mr. Doar says the new work requirements aren't
``transformative,'' he points out a sleeper provision that hasn't
attracted much attention. The bill enshrines helping low-income
Americans find employment and increasing their earnings as a purpose of
food stamps, an update to the program's ``mission statement'' that will
let reform-minded states focus more on work. He suggests the Federal
Government could offer bonuses to states that boost their work-
participation rates--a ripe idea for Republicans, who can build on
their incremental progress in negotiations over the farm bill this
year.
Even the bill's limited work provisions were a tough sell for
President Biden, although he voted for welfare reform as a senator in
1996. The bipartisan consensus on work has devolved into ``truly a
party divide,'' Mr. Doar says. Democrats largely view welfare programs
as universal entitlements. One example is the brawl over the child tax
credit, which Democrats temporarily transformed into a cash allowance
as part of the [COVID]-19 emergency. Democrats aspired to make that
change permanent, ``sneaking through a real retrenchment'' against the
1996 welfare reform, Mr. Doar says.
The argument on the left is that work requirements merely punish
children for the failures of their parents. Better to deposit cash
every month. Yet unconditional money can leave children stuck in
suffering far beyond what a check can heal--such as a parent with
untreated mental illness or addiction. ``Sending a check from
Washington with no human connection'' allows struggling families ``to
remain in the shadows,'' Mr. Doar says, or in ``houses with the
curtains drawn.'' On this issue, West Virginia Sen. Joe Manchin was
``the only real ally'' among Democrats. His opposition helped scuttle a
permanent cash allowance for parents.
Mr. Doar's view is popular with the public. A May opinion poll \7\
showed roughly \2/3\ of Americans, including \1/2\ of Democrats,
support work requirements on food stamps and Medicaid. That support
holds in other surveys across income and racial demographics. In April
an advisory ballot referendum asked Wisconsin voters whether they
support work requirements on welfare. It won with nearly 80% of the
vote. And Mr. Doar notes that in the 2020 primaries, Mr. Biden
``handily'' outperformed Bernie Sanders and Elizabeth Warren among
black voters. He says one reason may be those senators' ``welfare
entitlement perspective.''
---------------------------------------------------------------------------
\7\ https://www.axios.com/2023/05/18/axios-ipsos-poll-work-
requirements-medicaid-snap.
---------------------------------------------------------------------------
One Republican seizing this political high ground is Sen. Tim
Scott. ``If you're able-bodied, you work,'' Mr. Scott promised in his
2024 Presidential campaign announcement, crediting his mother for
offering an example of hard work. But Republicans are sometimes cowed
by the accusations that they're heartless.
Mr. Doar suggests that the progressive resistance to work reflects
a dim view of low-income Americans: ``They're saying that those seeking
assistance aren't capable of working, aren't capable of stepping up and
fulfilling some form of responsibility and moving toward self-
sufficiency. And what we found in welfare reform is--actually, they are
capable. And when you ask these families to make some commitment to
employment,'' then ``they'll do it. And they can do it.''
Republicans can also explain to voters that these rules aim to fix
a broken bureaucracy--to put pressure ``on the agency to make a better
and more concerted effort to help someone get a job,'' he says. Those
receiving benefits are responding to bad incentives in government. ``If
the message is, `Don't worry about it. Here's your card. See you in a
year,' they'll take the card, and you won't see them for a year, and
you won't have really helped them.''
One important misconception is that poverty is uniquely awful in
America compared with, say, Europe. Such comparisons tend to ``isolate
one program'' or fail to count a bevy of refundable tax credit for low-
income Americans.
``The sad part of the popular impression is that the official
poverty measure doesn't count all the benefits we provide,'' Mr. Doar
says. A 2019 paper by economist Bruce Meyer of AEI and the University
of Chicago and James Sullivan of Notre Dame found that taking better
account of benefits and increased consumption power reduced poverty \8\
from the official rate of about 12%--barely changed since the 1970s--to
less than 3%.
---------------------------------------------------------------------------
\8\ https://www.aei.org/research-products/speech/poverty-in-
america-before-and-after-covid-19/.
---------------------------------------------------------------------------
``I think we really are''--Mr. Doar searches for the right word--
``plagued by this failure to recognize that we have made progress on
these issues, and that we are a good and generous country to people who
struggle.''
That hesitancy to acknowledge success crosses partisan and
ideological lines. On parts of the left, ``they think if we say we've
made great progress on reducing poverty, which we have, then we won't
be able to justify further investments. We have to paint a dark, bad
picture because that's what justifies more spending.'' For some on the
right, declaring success ``would mean that government actually could do
something well over time.''
Mrs. Odell is a member of the Journal's editorial board.
______
Submitted Federal Register Rule by Hon. Glenn Thompson, a
Representative in Congress from Pennsylvania
[https://www.govinfo.gov/content/pkg/FR-2015-12-16/pdf/2015-31532.pdf]
Federal Register
Vol. 80, No. 241, Wednesday, December 16, 2015, 78119-78130
Rules and Regulations
Department of Agriculture
Commodity Credit Corporation
7 CFR Part 1400
RIN 0560-AI31
Payment Limitation and Payment Eligibility; Actively Engaged in Farming
Agency: Commodity Credit Corporation, USDA.
Action: Final rule.
Summary: This rule changes the requirements for a person to be
considered actively engaged in farming for the purpose of payment
eligibility for certain Farm Service Agency (FSA) and Commodity Credit
Corporation (CCC) programs. Specifically, this rule amends and
clarifies the requirements for a significant contribution of active
personal management to a farming operation. These changes are required
by the Agricultural Act of 2014 (the 2014 Farm Bill). The provisions of
this rule do not apply to persons or entities comprised entirely of
family members. The rule does not change the existing regulations as
they relate to contributions of land, capital, equipment, or labor, or
the existing regulations related to landowners with a risk in the crop
or to spouses. This rule will apply to eligibility for payments earned
for the 2016 crop or program year for farming operations with only 2016
spring planted crops, and to eligibility for payments for the 2017 and
subsequent crop or program years for all farming operations (those with
either spring or fall planted crops).
Dates: This rule is effective December 16, 2015.
For Further Information Contact: James Baxa; Telephone: (202) 720-
7641. Persons with disabilities who require alternative means for
communication should contact the USDA Target Center at (202) 720-2600
(voice).
Supplementary Information:
Overview
CCC programs managed by FSA, specifically the Market Loan Gains
(MLG) and Loan Deficiency Payments (LDP) associated with the Marketing
Assistance Loan (MAL) Program, the Agriculture Risk Coverage (ARC)
Program, and the Price Loss Coverage (PLC) Program, require that a
person or legal entity be ``actively engaged in farming'' as a
condition of eligibility for payments. As specified in 7 CFR part 1400,
a person or legal entity must contribute: (1) Land, capital, or
equipment; and (2) active personal labor, active personal management,
or a combination of active personal labor and active personal
management to be considered ``actively engaged in farming'' for the
purposes of payment eligibility.
Section 1604 of the 2014 Farm Bill (Pub. L. 113-79) requires the
Secretary of Agriculture to define in regulations what constitutes a
``significant contribution of active personal management'' for the
purpose of payment eligibility. CCC published a proposed rule in the
Federal Register on March 26, 2015, (80 FR 15916-15921) to implement
the changes required by the 2014 Farm Bill. CCC received 95 comments on
the proposed rule. The comments and responses are discussed later in
this document. No major changes are being made in response to comments,
because FSA has determined that the comments support the definitions
and requirements for ``actively engaged in farming'' specified in the
proposed rule and support limiting eligibility for farm payments. Also,
there was no consensus amongst the comments for any alternative payment
eligibility provisions that would address the 2014 Farm Bill
requirements. FSA has made minor changes from the proposed rule in this
final rule to respond to commenters' requests for clarifications of
certain provisions.
As specified in the proposed rule, this final rule amends 7 CFR
part 1400 to define what constitutes a significant contribution of
active personal management and to revise the requirements for active
personal management contributions. The 2014 Farm Bill also directed the
Secretary to consider the establishment of limits on the number of
persons per farming operation who may be considered actively engaged in
farming based on a significant contribution of active personal
management. Based on this directive, a limit was established in the
proposed rule and this final rule therefore amends 7 CFR part 1400 to
set a limit on the number of persons per farming operation who may
qualify as actively engaged in farming based on a significant
contribution of active personal management, or a combination of active
personal management and active personal labor. The new requirements and
definitions are specified in a new subpart G to 7 CFR part 1400.
Exceptions for Entities Comprised Solely of Family Members
As required by the 2014 Farm Bill, the provisions of this rule do
not apply to farming operations comprised solely of family members.
This rule does not revise the definition of ``family member.'' As
specified in 7 CFR 1400.3, a family member is ``a person to whom
another member in the farming operation is related as a lineal
ancestor, lineal descendant, sibling, spouse, or otherwise by
marriage.'' This definition is consistent with 7 U.S.C. 1308, which is
the authority for the definition. FSA handbooks further clarify that
eligible family members include: Great grandparent, grandparent,
parent, child, including legally adopted children and stepchildren,
grandchild, great grandchild, or a spouse or sibling of family members.
In 7 CFR 1400.208, there are existing provisions for family members
to be considered actively engaged in farming by making a significant
contribution of active personal labor, or active personal management,
or a combination thereof, to a farming operation comprised of a
majority of family members, without making a contribution of land,
equipment, or capital. The new subpart G does not change these
provisions.
Existing Provisions and Exceptions for Actively Engaged Requirements
That Are Not Changed
As specified in the current regulations, there are exceptions to
the requirement that a person must contribute labor or management to be
considered actively engaged in farming. These exceptions for certain
landowners and for spouses are not changed with this rule.
Specifically, a person or legal entity that is a landowner who makes a
significant contribution of owned land to the farming operation and
receives rent or income for such use of the land based on the land's
production or the operation's operating results, and who therefore
shares a financial risk in the crop (profit or loss is based on value
of crop and not from a fixed rent amount) is considered to be actively
engaged. A landowner who meets that requirement of sharing financial
risk in the crop is not required to contribute labor or management to
be considered actively engaged in farming. If one spouse, or an estate
of a deceased spouse, is considered to be actively engaged in farming
the other spouse is considered to be actively engaged without making a
separate, additional contribution of management or labor. The spouse
exemption as specified in the current regulations applies regardless of
whether the other spouse has qualified as actively engaged through a
contribution of management or labor or as a landowner sharing risk in
the crop.
The final rule specifies how persons and legal entities comprised
of non-family members may be determined eligible for payments, based on
a contribution of active personal management made by persons with a
direct or indirect interest in the farming operation. Payments made to
persons or legal entities are attributed to persons as specified in 7
CFR 1400.105 and the methods for attribution remain unchanged with this
rule.
Additional Requirements for Certain Nonfamily General Partnerships and
Joint Ventures
The revised definition of what constitutes a significant
contribution of active personal management in this rule apply only to
certain nonfamily farming operations seeking to have more than one
person qualify as actively engaged in farming by providing a
significant contribution of active personal management. Such person is
referred to as a ``farm manager'' for the purposes of this rule. This
rule only applies to farming operations structured as general
partnerships or joint ventures that seek to qualify more than one farm
manager. The existing requirements that farming operations supply
information to FSA county committees (COC) on each member's
contribution or expected contribution of labor or management related to
actively engaged determinations remain unchanged and continue to apply.
However, each of the members of farming operations subject to this
final rule that are determined to be actively engaged in farming by
their contribution of active personal management, or the contribution
of the combination of active personal labor and active personal
management, will also be required to keep and provide a management log.
For most farming operations that are legal entities, such as
corporations and limited liability companies, adding an additional
member to the entity does not affect the number of payment limits
available; it simply increases the number of members that can share a
single $125,000 payment limit, should such a limit be reached. But for
general partnerships and joint ventures, adding another member to the
operation can provide the availability of an additional $125,000
payment limit if the new member meets the other eligibility
requirements, including being determined as actively engaged in
farming. This potential for a farming operation being able to qualify
for multiple payment limits provides an opportunity to add members and
to have those members claim actively engaged in farming status, each
with an additional and separate payment limitation, especially for
farming operations earning annual program payments in an amount close
to or in excess of the payment limitation.
For this reason, several additional requirements now apply to
nonfamily farming operations seeking to qualify more than one farm
manager. Specifically, in addition to the existing requirements that
farming operations must provide information to FSA on how each of their
members qualify as actively engaged based on a contribution of labor,
management, land, capital, and equipment, a limit is placed on the
number of members of a farming operation that can be qualified as a
farm manager. Also, an additional recordkeeping requirement now applies
for each member of such farming operations contributing any active
personal management. These additional requirements also apply to
individuals requesting to qualify with a combination of labor and
management if their farming operation is seeking to have more than one
farm manager (combinations of labor and management can qualify as
actively engaged in farming).
Number of Farm Managers That May Qualify As Actively Engaged
This rule restricts the number of farm managers to one person per
farming operation, with exceptions. Nonfamily farming operations
seeking only one member to qualify as actively engaged in farming with
only a significant contribution of management or a combination of labor
and management (one farm manager) are not subject to the new
requirements of 7 CFR part 1400 subpart G. They are still, however,
subject to the existing requirements of being actively engaged, as they
were prior to this rule. In other words, such operations will continue
to be subject to the existing regulations in subparts A and C of 7 CFR
part 1400 that specify the requirements to be considered actively
engaged in farming.
Any farming operation seeking two or three farm managers must meet
the requirements of subpart G for all farm managers in the farming
operation, including documenting that each of the two (or three)
individuals are actively engaged in farming by their contribution of
active personal management (or a combination of labor and management)
by the maintenance of the records or logs discussed below for all the
members in the farming operation. If one person of the farming
operation meets the requirements for being actively engaged in farming
by making a contribution of active personal management, and that
farming operation seeks to qualify an additional farm manager, the
farming operation must meet the requirements that it is a large
operation or a complex operation as specified in this rule. To qualify
a total of three farm managers, the operation is required to meet the
requirements specified in this rule for both size and complexity. In
other words, a very large farm operation that is not complex (for
example, one growing a single crop) may only qualify for two farm
managers, not three. Under no circumstances is a farming operation
allowed to qualify more than a total of three persons as farm managers.
The default standard for what constitutes a large farming operation
is an operation with crops on more than 2,500 acres (planted or
prevented planted) or honey or wool with more than 10,000 hives or
3,500 ewes, respectively. The acreage standard is based on an analysis
of responses to the Agricultural Resource Management Survey (ARMS)
conducted by the USDA Economic Research Service and National
Agricultural Statistics Service. The results of that survey indicate
that on average, farms producing eligible commodities that required
more than one full time manager equivalent (2,040 hours of management)
had a size of 2,527 acres. (See http://www.ers.usda.gov/data-products/
arms-farm-financial-and-crop-production-practices.
aspx for more information on the survey.) The size standards for honey
and wool did not have comparable survey information available. The
honey standard for the number of hives is based on the beekeepers
participating in 2011 through 2012 Emergency Assistance for Livestock,
Honey Bees, and Farm-Raised Fish that met or exceeded the payment
limit. These large operations averaged 10,323 hives. The standard
established for sheep was based on industry analysis that showed that
operations with 1,500 through 2,000 ewes could be full time. The 3,500
ewes standard is approximately double that threshold. Each State FSA
committee (STC) has authority to modify these size standards for their
state based on the STC's determination of the relative size of farming
operations in the state by up to 15 percent (that is plus or minus 375
acres, 1,500 hives, or 525 ewes). In other words, the standard in a
particular state may range from 2,125 acres to 2,875 acres; 8,500 to
11,500 hives; or 2,975 to 4,025 ewes. Any deviation from the state
level standards may only be granted on a case by case basis by the FSA
Deputy Administrator for Farm Programs (DAFP).
If a farming operation seeks an additional farm manager based on
the complexity of the operation, such operation must make a request to
the FSA state committee that demonstrates complexity by addressing the
factors established in this rule. The complexity factors specified in
this rule take into account the diversity of the operation including
the number of agricultural commodities produced; whether irrigation is
used; the types of agricultural crops produced such as field,
vegetable, or orchard crops; the geographical area in which an
operation farms and produces agricultural commodities; alternative
marketing channels (that is, fresh, wholesale, farmers market, or
organic); and other aspects about the farming operation such as the
production of livestock, types of livestock, and the various livestock
products produced and marketed annually. The addition of a second or
third farm manager to be considered actively engaged in farming must be
approved by the STC, and is subject to review by DAFP. The final review
and concurrence by DAFP is intended to ensure consistency and fairness
on a national level.
Records on the Performance of Management Activities
As specified in this final rule, if a farming operation seeks to
qualify more than one farm manager as actively engaged in farming, then
all persons that provide any management to the farming operation are
required to maintain contemporaneous records or activity logs of their
management activities, including the management activities that may not
qualify as active personal management under this rule. Specifically,
activity logs must include information about the hours of management
performed for the farming operation. While the recordkeeping
requirements under this rule are similar to the current provisions at 7
CFR 1400.203 and 1400.204 in which contributions must be identifiable
and documentable, and separate and distinct from the contributions of
other members, these additional records or logs must also include the
location of where the management activity was performed (either on-site
or remote) and the time expended or duration of the management activity
performed. These records and logs must be made available if requested
by the appropriate FSA reviewing authority. If a person or member
initially determined as actively engaged in farming by a represented
contribution of active personal management to the farming operation
fails to provide these management activity records within a reasonable
amount on time, usually 30 days, the represented contribution of active
personal management will be disregarded and the person's eligibility
for payments will be re-determined.
Section 1604 of the farm bill requires USDA to ensure that any
additional paperwork required by this rule be limited only to persons
in farming operations who would be subject to this rule. As described
above, the additional recording and recordkeeping requirements of this
rule only apply to persons in farming operations that seek to qualify
more than one farm manager as actively engaged in farming.
New Definition of Significant Contribution of Active Personal
Management
The existing definition of a ``significant contribution'' in 7 CFR
1400.3 specifies that for active personal management, a significant
contribution includes ``activities that are critical to the
profitability of the farming operation,'' but that definition does not
specify what specific types of activities are included, whether these
activities need to be direct actions and not passive activities, and to
what level or quantity such activities must be performed to achieve a
level of significance.
This final rule specifies a new definition of ``significant
contribution of active personal management'' that applies only to non-
family farming operations that seek to qualify more than one person as
a farm manager. Similar to the existing requirements in 7 CFR 1400.3
for a substantial amount of active personal labor, the new definition
for a significant contribution of active personal management requires
an annual contribution of 500 hours of management, or at least 25
percent of the total management required for that operation. This final
rule also adds a new, more specific definition for ``active personal
management'' that includes a list of critical management activities
that qualify as a significant contribution if such activities are
annually performed to either of the minimum levels established (500
hours or 25 percent of the total management hours required for the
operation on an annual basis).
The new definition changes what constitutes ``active personal
management'' only for farm managers in nonfamily farming operations
seeking to qualify two or three farm managers. The requirements for
such farm managers clarify that eligible management activities are
critical actions performed under one or more of the following
categories:
Capital, land, and safety-net programs: Arrange financing,
manage capital, acquire equipment, negotiate land acquisition
and leases, and manage insurance or USDA program participation;
Labor: Hire and manage labor; and
Agronomics and Marketing: Decide which crop(s) to plant,
purchase inputs, manage crops, price crops, and market crops or
futures.
The management activities described place emphasis on actions taken
or performed by the person directly for the benefit and success of the
farming operation. Passive management activities such as attendance of
board meetings or conference calls, or watching commodity markets or
input markets (without making trades), are not considered as making a
significant contribution of active personal management. Only critical
actions as specified in the new definition of ``active personal
management'' are counted towards the required hourly threshold for a
significant contribution of active personal management.
As required by the 2014 Farm Bill, the new definition and
requirements in the final rule take into account the size and
complexity of farming operations across all parts of the country. The
final rule also takes into consideration all of the actions of the
farming operation associated with the financing; crop selection and
planting decisions; land acquisitions and retention of the land assets
for an extended period of time; risk management and crop insurance
decisions; purchases of inputs and services; utilization of the most
efficient field practices; and prudent marketing decisions.
Furthermore, this new definition takes into account advancements in
farming, communication, and marketing technologies that producers must
avail themselves to remain competitive and economically viable
operations in today's farming world.
Eligible management activities include the activities required for
the farming operation as a whole, not just activities for the programs
to which the ``actively engaged in farming'' requirement applies. For
example, if a farming operation is participating in ARC or PLC and
using grain produced under those programs to feed dairy cattle, those
management activities with respect to the dairy component of the
operation can be considered for eligibility purposes to qualify a farm
manager. Similarly, if a farming operation receives MLG or LDPs on some
crops, but not on others, all the management activities for all the
crops are considered for eligibility purposes.
The final rule clarifies that the significant contribution of a
person's active management may be used only to qualify one person or
legal entity in a farming operation as meeting the requirements of
being actively engaged in farming. For example, if members of a joint
operation are entities, one person's contribution will only count
toward qualifying one of the entities (and not any other entity to
which the person belongs), as actively engaged in farming.
Summary of Comments Received and FSA Responses
The 60 day comment period on the proposed rule ended May 26, 2015.
CCC received 95 comments on the proposed rule. Comments were received
from individual farmers, members of the public, slow food and
sustainable agriculture groups, environmental groups, rural advocacy
groups, the USDA Office of the Inspector General, an FSA employee, and
groups representing farmers and growers. Most of the comments supported
the idea of restricting eligibility for farm payments, but many of
those supportive comments also suggested additional restrictions on
eligibility. The rest of the comments, primarily from groups
representing farmers and growers, did not support restricting
eligibility for farm payments based on active contribution of
management, or suggested that additional persons be made eligible for
payment.
Many of the suggestions to further restrict farm program payments
were out of scope or exceed FSA's authority. For example, some
commenters objected to the family member operation exemption that is
required by the 2014 Farm Bill. The suggestion of one payment limit per
farm, no exceptions, would eliminate the spouse exemption for actively
engaged in farming, which FSA does not have authority to change. Other
suggestions were good ideas that are already addressed by existing
regulations. For example, the attribution rules already specified in 7
CFR part 1400 prevent one person from earning multiple payment
limitations based on their participation in multiple farming
enterprises.
The following discussion summarizes the issues raised by
commenters, and FSA's responses to those comments as reflected in this
rule:
Family Members and Family Farm Exemptions
Comment: The new requirements on the contribution of active
personal management should be applied to all farming operations
including family operations as a matter of clarity and equity.
Response: Section 1604(c) of the 2014 Farm Bill specifically states
that any revisions to the actively engaged in farming provisions will
not apply to farming operations comprised entirely of family members.
Therefore, no change to the rule is made in response to this comment.
Comment: The definition of family member should be extended an
additional generation to great great grandchildren.
Response: If such a familial relationship of great great
grandparent and great great grandchild is represented between members
in the same farming operation, who are both currently members at the
same time of such farming operation, this would fall under the existing
definition of family member because the great great grandchild is a
lineal descendant of the great great grandparent and would therefore be
recognized as such by the FSA reviewing authority. No revision to the
rule or handbooks is needed to accommodate five generations within the
same farming operation in the application of this rule.
Comment: FSA should interpret the definition of family member to
include cousins, nieces, nephews, aunts, and uncles. While not lineal
descendants, an extended family relationship exists between such
individuals that many times are involved in the same farming
operations.
Response: The existing definition of family member in 7 U.S.C. 1308
is centered on the term lineal descendant. FSA does not have authority
to revise the current definition of family member in 7 CFR part 1400
and therefore, cousin, niece, nephew, aunt, and uncle will not be
included or considered to be included as a family member under the
current definition. No change is made to the definition of ``family
member.''
Comment: The changing legal landscape regarding definitions of
marriage, and the effect, if any, it has on the related definitions
within the rule, should be considered for this rule.
Response: The text in 7 CFR part 1400 refers only to ``spouse'' and
has no reference to husbands or wives. No revisions to the regulations
are necessary to address the issue of marriage equality.
Comment: Given the importance now placed on family members for
operations to meet specific payment eligibility requirements,
clarification is needed regarding the continuity of a farming
operation's eligibility and the immediate consequences of unplanned
events such as death, incapacitation, or forced retirement of a family
member that otherwise negates this family relationship amongst all
members. (For example, a grandparent retires from the operation, and
one of the grandchildren remaining is a cousin but not a lineal
descendent or sibling of any other remaining members.) Furthermore, FSA
should consider a ``grandfather clause'' for existing members of a
family farming operation (non-lineal descendants) that have succeeded
former members due to death or retirement of a parent or grandparent.
Response: Current regulation and FSA policy as specified in the
handbooks provide that if an individual is determined to be actively
engaged in farming and is otherwise eligible to receive program
benefits subsequently dies or becomes incapacitated and is no longer
able to make contributions to the farming operation, that person is
considered to be actively engaged in farming and eligible for the
duration of the program year. Consistent with this policy, eligibility
determinations for a farming operation and its members for a specific
program year, and that are dependent upon the family member exemption,
will remain effective for the entire program year regardless of when
the death, disability, or incapacitation of a family member occurred
during the same program year. Then, for the following program year, new
determinations for payment eligibility and payment limitation purposes
will be made by FSA based on the representations made by the farming
operation, and its members, and applicable rules in effect at that
time.
Regarding ``grandfathering'' existing members of a farming
operation, as noted above, the eligibility of a particular person or
operation is effective for a program year. No other accommodations for
additional years will be adopted or allowed based on the historical
relationship of an operation's former members, because we do not have
the authority to do so. The definition of ``family member'' as
specified in 7 U.S.C. 1308 specifies that a family member is one to
whom ``a member in the farming operation is related as lineal ancestor,
lineal descendant, sibling, spouse, or otherwise by marriage.'' The
plain language meaning of the authority is that a family member is one
who is currently related to another member of the farming operation,
and does not include a historical relationship for one who was related
to someone who was formerly in the farming operation. Therefore, no
change to the rule is made in response to this comment.
Implementation Timing
Comment: If the rule is making the changes in requirements for
certain producers' eligibility effective for the 2016 crop year, we
will have only a few months to potentially reorganize a farm operation
to come into compliance. The effective date for the implementation of
all changes to the actively engaged in farming provisions should be
postponed until at least the 2017 crop year.
Response: There is no requirement that a farm operation needs to be
reorganized to come into compliance with the rule changes; the rule
changes how many payment limitations the farming operation may qualify
for based on managers' activities and the size and complexity of the
farming operation. We have considered the implementation timing and
made a change in the in response to this comment and will make the rule
effective for the 2016 crop year for producers who only have spring
planted covered crops and loan commodity crops and effective for the
2017 crop year for producers who have both spring and fall planted
covered crops and loan commodity crops.
Definitions
Comment: Although we are in agreement to FSA's new definition of
active person management and the categories of management activities,
FSA should include all of the management activities found in the Joint
Explanatory Statement of the Committee of Conference (commonly referred
to as the Managers' Report) on the 2014 Farm Bill.
Response: FSA handbook instructions will be revised to include a
list of all eligible management activities. The rule specifies the
categories, and the handbook provides more details, so the categories
are applied consistently. Therefore, no change to the rule is made in
response to this comment.
Comment: The phrase ``critical to the profitability of a farming
operation'' used in the description of a significant contribution of
active person management should be defined in the final rule.
Response: The proposed rule outlined the three specific categories
of management activities that will be considered as a contribution of
active personal management and used in determining whether the person
or member has made a significant contribution of active personal
management. Although not explicitly stated, it must be understood that
to be successful in farming, the timing of those management activities
is critical and the failure to make a management decision or failing to
take a management action, may make a difference in a farming operation
remaining viable. So unless those specific management activities are
timely completed by the person or member of a farming operation, the
person or member will not only be considered to not meet the
requirements to be determined actively engaged in farming, but also
that such a failure of the person or member to timely perform the
specified management activities would adversely affect the viability
and continued existence of the farming operation itself. Therefore, we
believe that the term critical is being used in the normal dictionary
definition and an additional regulatory definition is not necessary.
Comment: Rather than 500 hours or at least 25 percent of the total
management needed for the farming operation, the new measurable
standard for management should be increased to 1,000 hours or 50
percent, equal to the existing labor contribution requirement.
Response: Various proposals and concepts were considered in the
development of this rule, including a minimum level of interest a
person must hold in a farming operation before the person could qualify
as actively engaged in farming with only an active personal management
contribution, a weighted ranking of critical activities performed,
Internal Revenue Service tax code requirements for a person to be
considered a material participant in a business to claim a percentage
of profit or loss from the business for personal income tax purposes,
ARMS data of average size farming operations, and a higher hourly
threshold, such the current hourly standard for active personal labor.
The 500 hour or 25 percent standard was chosen because the ARMS found
that generally in a farming operation, at least twice the amount of
hours is devoted to labor activities as compared to the performance of
actual management activities. Therefore, we are not making a change in
the regulation in response to this comment.
Comment: A numerical standard is not suitable to be applied at all
to the performance of management activities.
Response: The Managers' Report on the 2014 Farm Bill specifically
directed the Secretary in implementing Section 1604 to develop clear
and objective standards that can easily be measured and accounted for
by members of the farming operation. In the absence of a consensus on
an alternative standard for measuring a management contribution, the
numerical standard from the proposed rule was adopted in the final
rule. A numerical standard meets the requirements for being clear and
objective, as well as easily measured and accounted for. Therefore, we
are not making a change in the regulation.
Comment: An equitable, measurable standard of significance should
be one that combines both labor and management contributions due to the
difficulty at times of deciding whether an activity or action is labor
or management.
Response: We have revised the rule in response to this comment to
address the issue of a combined significant contribution of management
and labor for farming operations that are subject to the new Subpart G.
The existing regulations in 1400.3(b)(4) specify how such a combined
significant contribution can meet the requirements of actively engaged
in farming for operations that are not subject to new subpart G, where
the activity is primarily labor or primarily management. This rule
specifies a new measurable standard for a significant contribution of
the combination of active personal labor and active personal management
to a farming operation that is subject to subpart G that takes into
account the reality of most farming operations where a person or member
contributes not just labor or just management, but contributes a
combination of both.
The new standard for a contribution of the combination of active
personal labor and active personal management balances these realities
and establishes a minimum hourly requirement based on the existing
hourly standard for a significant contribution of active personal labor
of 1,000 hours and the new hourly standard adopted for a significant
contribution of active personal management of 500 hours. However, the
threshold for a significant contribution of combined labor and
management is based on the proportionate share of the person's or
member's combined contribution of both labor and management activities
performed. Accordingly, under a combination of labor and management,
the labor contribution is counted towards the existing 1,000 hours
threshold for labor, and the management contribution is counted towards
the 500 hours threshold for management. Because the rule establishes a
combined limit for the combination of both labor and management, the
minimum contribution amounts for each component are less than their
individual limits if such determination would be made based on their
sole contribution of labor (1000 hours) or management (500 hours) alone
and the contributions under the combination are weighted to the
activity that is greatest.
There are five total hourly thresholds for a significant
contribution of the combination of labor and management, based on a
prorated combination of each type of contribution. For example, a
combined contribution where the majority of the contribution is
management is measured against a 550 total hour threshold that is
weighted towards the 500 hour standard for management, whereas a
combined contribution where the majority of the contribution is labor
is measured against a 950 total hour threshold that is weighted toward
the 1,000 hours required for a significant contribution of labor.
The following table specifies the hourly thresholds for the
combined contribution of active personal labor and active personal
management based on the proportionate share of both labor and
management activities reported.
Combination of Active Personal Labor and Active Personal Management
Minimum Requirement for a Significant Contribution
[In hours]
------------------------------------------------------------------------
Meets the minimum
Management contribution Labor contribution in threshold for
in hours hours significant
contribution, in hours
------------------------------------------------------------------------
475 75 550
450 100 550
425 225 650
400 250 650
375 375 750
350 400 750
325 425 750
300 550 850
275 575 850
250 600 850
225 625 850
200 650 850
175 675 850
150 800 950
125 825 950
100 850 950
75 875 950
50 900 950
25 925 950
------------------------------------------------------------------------
Under these weighted thresholds, two contributions of the same
total contributed number of hours could have a different result, as it
will depend upon how many hours of such total contribution are
management and how many are labor. For example, a total combined
contribution of 650 hours consisting of 250 hours of management and 400
hours of labor would not qualify as a significant contribution, whereas
a total combined contribution of 650 hours consisting of 400 hours of
management and 250 hours of labor would qualify as a significant
contribution.
This standard will apply to each person that a farming operation
requests to qualify as actively engaged in farming by making a
significant contribution of the combination of labor and management,
rather than only a significant contribution of management.
This rule treats a combination of labor and management as a subset
of the manager requirements. This new provision to clarify a combined
significant contribution does not change the limit of three farm
managers. As part of an entity seeking more than one payment limit for
management, those farm managers qualifying because of a combination of
labor and management are also covered by the new definition and
recordkeeping requirements. In no case may more than three persons per
farming operation qualify as actively engaged in farming based on a
contribution of active personal management or a combination of labor
and management activities.
Comment: Section 1604 of the 2014 Farm Bill prohibits FSA from
making changes or revisions to any of the existing regulations other
than for the contribution of active personal management.
Response: That is correct, and this rule does not change the
measurable standard for the significant contribution of active personal
labor, which remains at 1,000 hours or 50 percent of the labor required
for the operation. The statute is clear and this rule changes the
regulations only for a contribution of active personal management,
including for a significant contribution of combined labor and
management. The regulations that apply solely to a contribution of
labor have not changed.
Restrictions on Active Personal Management Contributions
Comment: No restriction should be placed on the number of persons
that a farming operation is allowed to qualify as actively engaged in
farming with the significant contribution of management and no labor.
Response: Section 1604 of the 2014 Farm Bill directs the Secretary
to consider placing limits on the number of persons in a farming
operation that may qualify as actively engaged in farming by only
contributing management. Having no restriction would not address
Section 1604. We considered various options while developing the
proposed rule. As explained in the proposed rule, one option considered
was a strict limit of one farm manager; however, we determined that it
was reasonable to provide an option for a second and third farm manager
in specific circumstances. The adoption of this restriction or limit
addresses the 2014 Farm Bill provision while providing flexibility for
large or complex operations. Therefore, no change to the rule is made
in response to this comment.
Comment: There should be only one additional manager, period, the
same as included in the House and Senate farm bills. The total payment
limit for a farm should be decoupled from the number of managers by
setting a strict limit of one manager.
Related comment: A non-family farm operation should not be allowed
to exceed two eligible managers under any scenario.
Response: Consideration was given to allowing only one manager, or
two managers, per non-family farming operation for all circumstances.
However, the 2014 Farm Bill contained requirements that consideration
be given to other factors such as operation size and operation
complexity. The decision was made to allow up to a total of three
managers, but only with documentation of the need for the additional
managers, based on both operation size and complexity. Therefore, no
change to the rule is made in response to these comments.
Comment: Restricting the number of managers completely negates the
new definition of active personal management, and the removal of this
restriction would provide flexibility for operations to adjust to the
new management requirements and lessen the impact of implementation.
Response: The new limit of one farm manager with exceptions for up
to three farm managers is flexible and recognizes that many diverse
farming operations and farming practices are in existence today and may
require multiple persons in farm management roles. Therefore, no change
to the rule is made in response to this comment.
Comment: The standards for the allowance of additional managing
members based in the operation's size and complexity are a recipe for
abuse, permissiveness, and inconsistent application by COCs and STCs.
Response: All COC and STC recommendations for variances to the
established standards for operation size and complexity, and all
approvals of requests for additional managing members in a farming
operation, are subject to approval and concurrence by DAFP before
implementation. In addition, there will be no instances in which more
than three farm managers per operation will be allowed by DAFP.
Therefore, no change to the rule is made in response to this comment.
Comment: The new restriction of one contribution qualifies only one
person or member in the farming operation is unreasonable because for
liability or other purposes, a non-family manager may need to spread
his or her management contributions over more than one entity or member
to make all of them eligible for payment.
Response: In this rule, one person's contribution of active
personal management or a combination of management and labor can only
qualify only one person or one legal entity as actively engaged. Aside
from the spousal provision for actively engaged in farming that allows
one spouse's actions to be used to qualify the other spouse as actively
engaged, we have no statutory authority to permit the contributions of
one person to qualify additional persons and legal entities that
represent multiple payment limitations in the same farming operation.
Furthermore, without this restriction, the tracking and measurement of
actual contributions of labor or management being made to a farming
operation would be difficult, if not elusive, to determine to any
measurable level or degree of risk. Therefore, we are not making a
change in the regulation.
Recordkeeping Requirements
Comment: The requirement to keep a written log of the performance
of management activities should be eliminated on the premise that such
records would be overly burdensome to the members, disruptive to the
workflow, and too expensive for an operation to maintain.
Response: With the implementation of a measurable standard for the
contribution of active personal management in hours or percentage of
total hours expended in the farming operation, a written record or log
of the performance of management activities is required from all
members. These records are essential to enable county and State FSA
committees to determine whether or not a significant contribution of
specific management activities was performed to at least the minimum
level necessary to qualify as a significant contribution as defined.
Furthermore, the implementation of a measurable standard is meaningless
in the absence of actual documentation to verify that the minimum level
of the standard established has been met by the person who represents
as meeting the standard. The new recordkeeping requirements apply only
to joint operations and legal entities comprised of non-family members
that are seeking to qualify more than one farm manager. Therefore, we
are not making a change in the regulation.
Comment: The 2014 Farm Bill had a provision that FSA develop and
implement a plan to monitor compliance reviews to ensure producers'
compliance to the provisions of part 1400. Why was that not
specifically in the rule?
Response: This requirement was already met prior to the
implementation of the 2014 Farm Bill. FSA implemented an automated
tracking system to record compliance review results and to monitor
completion of compliance reviews in 2012. Review results and progress
on the completion of compliance reviews for the 2009 through 2013
program years are currently being tracked. The United States Government
Accountability Office (GAO) used FSA's tracking system in completion of
the most recent audit of payment eligibility and payment limitation
provisions (GAO 13-781, ``Farm Programs: Changes Are Needed to
Eligibility Requirements for Being Actively Involved in Farming,''
September 2013). The current regulations in 7 CFR 1400.2(h) already
specify that compliance reviews of farming operations and corresponding
documentation may be conducted at any time.
To address this comment and further clarify the compliance review
process, this final rule adds a new provision to 7 CFR 1400.2 to
specify that the Deputy Administrator will periodically monitor the
status of completion of the assigned compliance reviews, and take any
actions deemed appropriate to ensure the timely completion of the
reviews for payment eligibility and payment limitation compliance
purposes.
General Comments
Comment: This rule removes certain flexibilities to where many farm
families will become less sustainable to the point that they may lose
their ability to participate in farm programs.
Response: It is unclear how limiting the number of persons who may
qualify for payment based solely on management will in any way reduce
the sustainability of family farms. Furthermore, family farming
operations are exempt from this rule. Therefore, no change to the rule
is made in response to this comment.
Comment: Farm policy must seriously address the aging farmer crisis
and effective payment caps are one tool USDA has to address this issue.
Response: Payment limits have been in place since the 1970s, and
are not changed with this rule. The eligibility requirements for the
receipt of farm program payments have been made more restrictive with
each successive legislation to date. FSA does not have authority to
modify the current payment limitations below what is specified in the
2014 Farm Bill. We have outreach programs that target beginning
farmers, and many of our programs have special provisions, such as fee
waivers, to encourage beginning farmers.
Comment: Lax payment limits allow big farms to outbid beginning
farmers for land and leases. Limit or restrict the issuance of program
payments to new and small farm operators only.
Response: FSA does not have authority to implement such a
restriction. However, the average Adjusted Gross Income (AGI)
provisions first implemented under the Farm Security and Rural
Investment Act of 2002 (Pub. L. 107-171, generally referred to as the
2002 Farm Bill) and that remain, as amended by subsequent legislation,
do restrict the payment eligibility of recipients with incomes above
the specified AGI levels. As specified in 7 CFR 1400, persons with an
AGI above the limit are not eligible for payments or benefits under ARC
and PLC, price support programs including MAL and LDP, the Conservation
Reserve Program, the Noninsured Crop Disaster Assistance Program, most
FSA disaster assistance programs, and some conservation programs
operated by the Natural Resources Conservation Service. Therefore, no
change to the rule is made in response to this comment.
Comment: Require any operation that reorganizes to qualify for the
family farm exemption to wait 5 years following the effective date of
this rule to qualify for the exemption.
Response: The 2014 Farm Bill does not authorize such a provision.
The 2014 Farm Bill requires that this rule not apply to any farming
operation comprised entirely of family members, and with no such
waiting period. Therefore, no change to the rule is made in response to
this comment.
Comment: FSA's failure to evaluate the effects of this proposal on
the environment would violate the National Environmental Policy Act
(NEPA, 42 U.S.C. 4321-4347), current FSA regulations, and would be
arbitrary, capricious, an abuse of discretion, and contrary to the law
under the Administrative Procedure Act (5 U.S.C. 553).
Response: FSA has evaluated the effects of this proposal and
determined that this final rule does not constitute a major Federal
action that would significantly affect the quality of the human
environment, individually or cumulatively. Therefore, FSA will not
prepare an environmental assessment or environmental impact statement
for this regulatory action.
Effective Date
The Administrative Procedure Act (5 U.S.C. 553) provides generally
that before rules are issued by government agencies, the rule is
required to be published in the Federal Register, and the required
publication of a substantive rule is to be not less than 30 days before
its effective date. One of the exceptions is when the agency finds good
cause for not delaying the effective date. Subsection 1601(c)(2) of the
2014 Farm Bill makes this final rule exempt from notice and comment.
Therefore, using the administrative procedure provisions in 5 U.S.C.
553, FSA finds that there is good cause for making this rule effective
less than 30 days after publication in the Federal Register. This rule
allows FSA to make the changes to the actively engaged regulations in
time for the new 2016 program year. Therefore, this final rule is
effective when published in the Federal Register.
Executive Orders 12866 and 13563
Executive Order 12866, ``Regulatory Planning and Review,'' and
Executive Order 13563, ``Improving Regulation and Regulatory Review,''
direct agencies to assess all costs and benefits of available
regulatory alternatives and, if regulation is necessary, to select
regulatory approaches that maximize net benefits (including potential
economic, environmental, public health and safety effects, distributive
impacts, and equity). Executive Order 13563 emphasizes the importance
of quantifying both costs and benefits, of reducing costs, of
harmonizing rules, and of promoting flexibility.
The Office of Management and Budget (OMB) designated this rule as
significant under Executive Order 12866, ``Regulatory Planning and
Review,'' and therefore, OMB has reviewed this rule. The costs and
benefits of this final rule are summarized below. The full cost benefit
analysis is available on regulations.gov.
Summary of Economic Impacts
About 3,200 joint operations could lose eligibility for around $106
million in total crop year 2016 to 2018 benefits from the PLC, ARC, and
MAL Programs. The largest savings, around $38 million, are projected
for both the 2016 and 2017 crops (note that the exemption for
operations with fall plantings ends with the 2016 crops). Savings are
projected to decline to around $29 million for the 2018 crop if prices
improve, and in that case, producers would be eligible for lower
benefits from the MAL, LDP, ARC, and PLC Programs, independent of the
requirements of this rule. These savings can also be viewed as a cost
of this rule for producers. This rule does not change the payment limit
per person, which is a joint $125,000 for the applicable programs. As
specified in the current regulations, the payment limits apply to
general partnerships and joint ventures (collectively referred to as
joint operations) based on the number of eligible partners in the joint
operation; each partner may qualify the joint operation for a payment
of up to $125,000. In other words, each person in the joint operation
who loses eligibility due to this rule will lose eligibility for up to
$125,000 in payments for the joint operation.
Other types of entities (such as corporations and limited liability
companies) that share a single payment limit of $125,000, regardless of
their number of owners, would not have their payments reduced by this
rule. Each owner must contribute management or labor to the operation
to qualify the operation to receive the member's share of the single
payment limit.
No entities comprised solely of family members will be impacted by
this rule.
If commodity prices are sufficiently high that few producers are
eligible for any benefits, the costs of this rule to producers (and
savings to USDA) would be less, possibly even zero. That is, if very
few joint operations were to earn farm program payments due to high
commodity prices, limiting eligibility on the basis of management
contributions would not have much impact. Government costs for
implementing this rule are expected to be minimal ($0.4 million). The
applicable joint operations' opportunity costs associated with keeping
management logs over the course of each year are expected to be about
$7 million, but that amount could decline over time as managers
standardize their recordkeeping.
Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601-612), as amended by
the Small Business Regulatory Enforcement Fairness Act of 1996
(SBREFA), generally requires an agency to prepare a regulatory analysis
of any rule whenever an agency is required by APA or any other law to
publish a rule, unless the agency certifies that the rule will not have
a significant economic impact on a substantial number of small
entities. This final rule will not have a significant impact on a
substantial number of small entities. The farming operations of small
entities generally do not have multiple members that contribute only
active personal management to meet the requirements of actively engaged
in farming.
Environmental Review
The environmental impacts of this final rule have been considered
in a manner consistent with the provisions of NEPA, the regulations of
the Council on Environmental Quality (40 CFR parts 1500-1508), and the
FSA regulations for compliance with NEPA (7 CFR part 799). The
Agricultural Act of 2014 (the 2014 Farm Bill) requires that USDA
publish a regulation to specifically define a ``significant
contribution of active personal management'' for the purposes of
determining payment eligibility. This regulation clarifies the
activities that qualify as active personal management and the
recordkeeping requirements to document eligible management activities.
This rule is making a mandatory administrative clarification. As such,
FSA has determined that this final rule does not constitute a major
Federal action that would significantly affect the quality of the human
environment, individually or cumulatively. Therefore, FSA will not
prepare an environmental assessment or environmental impact statement
for this regulatory action.
Executive Order 12372
Executive Order 12372, ``Intergovernmental Review of Federal
Programs,'' requires consultation with state and local officials that
would be directly affected by proposed Federal financial assistance.
The objectives of the Executive Order are to foster an
intergovernmental partnership and a strengthened Federalism, by relying
on state and local processes for state and local government
coordination and review of proposed Federal financial assistance and
direct Federal development. For reasons specified in the final rule
related notice regarding 7 CFR part 3015, subpart V (48 FR 29115, June
24, 1983), the programs and activities in this rule are excluded from
the scope of Executive Order 12372.
Executive Order 12988
This final rule has been reviewed under Executive Order 12988,
``Civil Justice Reform.'' This rule will not preempt state or local
laws, regulations, or policies unless they represent an irreconcilable
conflict with this rule. This rule will not have retroactive effect.
Before any judicial actions may be brought regarding the provisions of
this rule, the administrative appeal provisions of 7 CFR parts 11 and
780 are to be exhausted.
Executive Order 13132
This final rule has been reviewed under Executive Order 13132,
``Federalism.'' The policies contained in this rule would not have any
substantial direct effect on states, on the relationship between the
Federal Government and the states, or on the distribution of power and
responsibilities among the various levels of government, except as
required by law. Nor would this rule impose substantial direct
compliance costs on state and local governments. Therefore consultation
with the states is not required.
Executive Order 13175
This final rule has been reviewed in accordance with the
requirements of Executive Order 13175, ``Consultation and Coordination
with Indian Tribal Governments.'' Executive Order 13175 requires
Federal agencies to consult and coordinate with Tribes on a government-
to-government basis on policies that have Tribal implications,
including regulations, legislative comments or proposed legislation,
and other policy statements or actions that have substantial direct
effects on one or more Indian Tribes, on the relationship between the
Federal Government and Indian Tribes or on the distribution of power
and responsibilities between the Federal Government and Indian Tribes.
FSA has assessed the impact of this final rule on Indian Tribes and
determined that this rule would not, to our knowledge, have Tribal
implications that require Tribal consultation under Executive Order
13175. If a Tribe requests consultation, FSA will work with the USDA
Office of Tribal Relations to ensure meaningful consultation is
provided where changes, additions, and modifications identified in this
rule are not expressly mandated by the 2014 Farm Bill.
Unfunded Mandates
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA, Pub. L.
104-4) requires Federal agencies to assess the effects of their
regulatory actions on state, local, and Tribal governments or the
private sector. Agencies generally must prepare a written statement,
including cost benefits analysis, for proposed and final rules with
Federal mandates that may result in expenditures of $100 million or
more in any 1 year for state, local or Tribal governments, in the
aggregate, or to the private sector. UMRA generally requires agencies
to consider alternatives and adopt the more cost effective or least
burdensome alternative that achieves the objectives of the rule. This
final rule contains no Federal mandates, as defined in Title II of
UMRA, for state, local and Tribal governments or the private sector.
Therefore, this rule is not subject to the requirements of sections 202
and 205 of UMRA.
Federal Domestic Assistance Programs
The title and number of the programs in the Catalog of Federal
Domestic Assistance to which this rules applies are: 10.051 Commodity
Loans and Loan Deficiency Payments; 10.112 Price Loss Coverage; and
10.113 Agriculture Risk Coverage.
Paperwork Reduction Act
The regulations in this final rule are exempt from requirements of
the Paperwork Reduction Act (44 U.S.C. Chapter 35), as specified in
Section 1601(c)(2)(B) of the 2014 Farm Bill, which provides that these
regulations be promulgated and administered without regard to the
Paperwork Reduction Act. Section 1604 of the farm bill requires us to
ensure that any additional paperwork required by this rule be limited
only to persons who are subject to this rule. The additional recording
and recordkeeping requirements of this final rule will only apply to
persons who are claiming eligibility for payments based on a
significant contribution of active personal management or a combination
of labor and management to the farming operation.
E-Government Act Compliance
FSA is committed to complying with the E-Government Act, to promote
the use of the Internet and other information technologies to provide
increased opportunities for citizen access to government information
and services, and for other purposes.
List of Subjects in 7 CFR Part 1400
Agriculture, Loan programs--agriculture, Conservation, Price
support programs.
For the reasons discussed above, CCC amends 7 CFR part 1400 as
follows:
Part 1400--Payment Limitation and Payment Eligibility
u 1. The authority citation for part 1400 continues to read as
follows:
Authority: 7 U.S.C. 1308, 1308-1, 1308-2, 1308-3, 1308-3a,
1308-4, and 1308-5.
1400.1 [Amended]
u 2. In 1400.1(a)(8), remove the words ``C and D'' and add the
words ``C, D, and G'' in their place.
u 3. Amend 1400.2 by adding paragraph (i) to read as follows:
1400.2 Administration
* * * * *
(i) The Deputy Administrator will periodically monitor the
status of completion of assigned compliance reviews and take
any actions deemed appropriate to ensure timely completion of
reviews for payment eligibility and payment limitation
compliance purposes.
u 4. Add subpart G to read as follows:
Subpart G--Additional Payment Eligibility Provisions for Joint
Operations and Legal Entities Comprised of Non-Family Members
or Partners, Stockholders, or Persons With an Ownership
Interest in the Farming Operation
Sec.
1400.600 Applicability.
1400.601 Definitions.
1400.602 Restrictions on active personal management
contributions.
1400.603 Recordkeeping requirements.
Subpart G--Additional Payment Eligibility Provisions for Joint
Operations and Legal Entities Comprised of Non-Family Members
or Partners, Stockholders, or Persons With an Ownership
Interest in the Farming Operation
1400.600 Applicability.
(a) This subpart is applicable to all of the programs as
specified in 1400.1 and any other programs as specified in
individual program regulations.
(b) The requirements of this subpart will apply to farming
operations for FSA program payment eligibility and limitation
purposes as specified in subparts B and C of this part.
(c) The requirements of this subpart do not apply to farming
operations specified in paragraph (b) of this section if
either:
(1) All persons who are partners, stockholders, or
persons with an ownership interest in the farming
operation or of any entity that is a member of the
farming operation are family members as defined in
1400.3; or
(2) The farming operation is seeking to qualify only
one person as making a significant contribution of
active personal management, or a significant
contribution of the combination of active personal
labor and active personal management, for the purposes
of qualifying only one person or entity as actively
engaged in farming.
1400.601 Definitions.
(a) The terms defined in 1400.3 are applicable to this
subpart and all documents issued in accordance with this part,
except as otherwise provided in this section.
(b) The following definitions are also applicable to this
subpart:
Active personal management means personally providing
and participating in management activities considered
critical to the profitability of the farming operation
and performed under one or more of the following
categories:
(i) Capital, which includes:
(A) Arranging financing and managing
capital;
(B) Acquiring equipment;
(C) Acquiring land and negotiating
leases;
(D) Managing insurance; and
(E) Managing participation in USDA
programs;
(ii) Labor, which includes hiring and
managing of hired labor; and
(iii) Agronomics and marketing, which
includes:
(A) Selecting crops and making
planting decisions;
(B) Acquiring and purchasing crop
inputs;
(C) Managing crops (that is, whatever
managerial decisions are needed with
respect to keeping the growing crops
living and healthy-soil fertility and
fertilization, weed control, insect
control, irrigation if applicable) and
making harvest decisions; and
(D) Pricing and marketing of crop
production.
Significant contribution of active personal
management means active personal management activities
performed by a person, with a direct or indirect
ownership interest in the farming operation, on a
regular, continuous, and substantial basis to the
farming operation, and meets at least one of the
following to be considered significant:
(i) Performs at least 25 percent of the total
management hours required for the farming
operation on an annual basis; or
(ii) Performs at least 500 hours of
management annually for the farming operation.
Significant contribution of the combination of active
personal labor and active personal management means a
contribution of a combination of active personal labor
and active personal management that:
(i) Is critical to the profitability of the
farming operation;
(ii) Is performed on a regular, continuous,
and substantial basis; and
(iii) Meets the following required number of
hours:
Combination of Active Personal Labor and Active Personal Management
Minimum Requirement for a Significant Contribution
[In hours]
------------------------------------------------------------------------
Meets the minimum
Management contribution Labor contribution in threshold for
in hours hours significant
contribution, in hours
------------------------------------------------------------------------
475 75 550
450 100 550
425 225 650
400 250 650
375 375 750
350 400 750
325 425 750
300 550 850
275 575 850
250 600 850
225 625 850
200 650 850
175 675 850
150 800 950
125 825 950
100 850 950
75 875 950
50 900 950
25 925 950
------------------------------------------------------------------------
1400.602 Restrictions on active personal management contributions.
(a) If a farming operation includes any non-family members as
specified under the provisions of 1400.201(b)(2) and (3) and
the farming operation is seeking to qualify more than one
person as providing a significant contribution of active
personal management, or a significant contribution of the
combination of active personal labor and active personal
management, then:
(1) Each such person must maintain contemporaneous
records or logs as specified in 1400.603; and
(2) Subject to paragraph (b) of this section, if the
farming operation seeks not more than one additional
person to qualify as providing a significant
contribution of active personal management, or a
significant contribution of the combination of active
personal labor and active personal management, because
the operation is large, then the operation may qualify
for one such additional person if the farming
operation:
(i) Produces and markets crops on 2,500 acres
or more of cropland;
(ii) Produces honey with more than 10,000
hives; or
(iii) Produces wool with more than 3,500
ewes; and
(3) If the farming operation seeks not more than one
additional person to qualify as providing a significant
contribution of active personal management, or a
significant contribution of the combination of active
personal labor and active personal management, because
the operation is complex, then the operation may
qualify for one such additional person if the farming
operation is determined by the FSA state committee as
complex after considering the factors described in
paragraphs (a)(3)(i) and (ii) of this section. Any
determination that a farming operation is complex by an
FSA state committee must be reviewed and DAFP must
concur with such determination for it to be
implemented. To demonstrate complexity, the farming
operation will be required to provide information to
the FSA state committee on the following:
(i) Number and type of livestock, crops, or
other agricultural products produced and
marketing channels used; and
(ii) Geographical area covered.
(b) FSA state committees may adjust the limitations described
in paragraph (a)(2) of this section up or down by not more than
15 percent if the FSA state committee determines that the
relative size of farming operations in the state justify making
a modification of either or both of these limitations. If the
FSA state committee seeks to make a larger adjustment, then
DAFP will review and may approve such request.
(c) If a farming operation seeks to qualify a total of three
persons as providing a significant contribution of active
personal management, or a significant contribution of the
combination of active personal labor and active personal
management, then the farming operation must demonstrate both
size and complexity as specified in paragraph (a) of this
section.
(d) In no case may more than three persons in the same
farming operation qualify as providing a significant
contribution of active personal management, or a significant
contribution of the combination of active personal labor and
active personal management, as defined by this subpart.
(e) A person's contribution of active personal management, or
the contribution of the combination of active personal labor
and active personal management, to a farming operation
specified in 1400.601(b) will only qualify one member of that
farming operation as actively engaged in farming as defined in
this part. Other individual persons in the same farming
operation are not precluded from making management
contributions, except that such contributions will not be
recognized as meeting the requirements of being a significant
contribution of active personal management.
1400.603 Recordkeeping requirements.
(a) Any farming operation requesting that more than one
person qualify as making a significant contribution of active
personal management, or a significant contribution of the
combination of active personal labor and active personal
management, must maintain contemporaneous records or activity
logs for all persons that make any contribution of any
management to a farming operation under this subpart that must
include, but are not limited to, the following:
(1) Location where the management activity was
performed; and
(2) Time expended and duration of the management
activity performed.
(b) To qualify as providing a significant contribution of
active personal management each person covered by this subpart
must:
(1) Maintain these records and supporting business
documentation; and
(2) If requested, timely make these records available
for review by the appropriate FSA reviewing authority.
(c) If a person fails to meet the requirement of paragraphs
(a) and (b) of this section, then both of the following will
apply:
(1) The person's contribution of active personal
management as represented to the farming operation for
payment eligibility purposes will be disregarded; and
(2) The person's payment eligibility will be re-
determined for the applicable program year.
Val Dolcini,
Executive Vice President, Commodity Credit Corporation, and
Administrator, Farm Service Agency.
[FR Doc. 2015-31532 Filed 12-15-15; 8:45 a.m.]
BILLING CODE 3410-05-P
______
Submitted Press Release by Hon. Glenn Thompson, a Representative in
Congress from Pennsylvania
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.justice.gov/usao-cdca/pr/15-arrested-law-enforcement-
operation-targeting-fraudulent-withdrawal-benefits]
Press Release
15 Arrested in Law Enforcement Operation Targeting Fraudulent
Withdrawal of Benefits Designated for Low-Income Families
Thursday, March 2, 2023
For Immediate Release
U.S. Attorney's Office, Central District of California
Los Angeles--``Operation Urban Justice,'' a large-scale law
enforcement operation this week, has resulted in the arrest of 15
individuals who allegedly used information from ``skimmed'' electronic
benefit transfer (EBT) cards to make unauthorized withdrawals of funds
that had been disbursed to low-income individuals, the Justice
Department announced today.
More than 300 law enforcement officers early Wednesday morning
began monitoring about 20 ATM locations across the Los Angeles area and
identified individuals who were making multiple cash withdrawals with
cards encoded with information that had been stolen from cards used by
the California Department of Social Services to provide CalFresh and
CalWORKs benefits to qualified recipients.
Authorities made arrests after determining that the suspects at the
ATMs were not entitled to access funds that had been deposited into
beneficiary's accounts. At this time, Federal prosecutors have filed
five criminal complaints charging defendants with the use of
unauthorized access devices (the cards used to make the cash
withdrawals) or possession of 15 or more unauthorized access devices,
and they are expected to file additional cases later today and
tomorrow. The defendants arrested, many of them Romanian nationals, are
expected to begin making initial appearances this afternoon in United
States District Court.
The Los Angeles Police Department started the investigation into
the fraudulent withdrawal of benefits in August 2022, and the United
States Secret Service soon after joined ``Operation Urban Justice'' as
a joint partner.
A number of law enforcement agencies are providing significant
support, which included participating in Wednesday's takedown,
including U.S. Customs and Border Protection, Homeland Security
Investigations, U.S. Immigration and Customs Enforcement, the Glendale
Police Department, the Los Angeles County Sheriff's Department, the
California Department of Social Services, the United States Department
of Agriculture's Office of Inspector General, and the Romanian Brigade
for Combatting Criminal Organizations (which is part of the Romanian
National Police).
Documents filed in Federal court outline how the California
Department of Social Services has identified more than $38.9 million in
funds stolen from victims' EBT cards. This fraud has targeted CalWORKs
and CalFresh (previously known as ``food stamps''), both of which are
intended to help low-income beneficiaries purchase food and provide for
basic needs.
The investigation has revealed that the fraudulent withdrawal of
these benefits is done with ``cloned'' cards, which are debit cards,
gift cards or other devices with magnetic strips that have been encoded
with information from legitimate EBT cards. Court documents allege that
at least some of those involved in the fraudulent withdrawals obtained
stolen EBT card information from ``skimming'' devices that were
installed on ATM machines.
``By stealing public benefits using counterfeit EBT cards, the
defendant in these cases plundered the accounts of some of our
community's poorest residents--people who need these benefits to
survive,'' said United States Attorney Martin Estrada. ``These actions
are part of a larger assault on the EBT system, one which has caused
tens of millions of dollars in losses. Working with our law enforcement
partners who have devoted untold resources to combating this issue, my
Office will continue to do everything in our power to stop criminals
from victimizing people in our community, especially those who are most
vulnerable.''
``Today's successful operation demonstrates how a sophisticated and
extensive criminal scheme can be disrupted and dismantled by a team of
law enforcement professionals who approach their investigation with an
even greater degree of cooperation,'' said James Huse, Special Agent in
Charge with the Los Angeles Field Office of the United States Secret
Service. ``The results of this investigation are a testament to strong
partnerships across the law enforcement community. Our efforts today
serve to protect the Electronic Benefits Transfer system and ensure
that public funds reach those who need them without delay or
distress.''
``On March 1, 2023, the Los Angeles Police Department's Commercial
Crimes Division partnered with the United States Secret Service and
other Federal law enforcement agencies to conduct a collaborative
enforcement operation targeting the State of California's Electronic
Benefits Transfer (EBT) fraud issue with losses in the tens of millions
of dollars,'' said Los Angeles Police Chief Michel Moore. ``The
operation involved numerous Los Angeles Police Department personnel and
resulted in the recovery of 429 cloned state issued EBT cards, $129,000
in U.S. currency unlawfully drawn from ATM machines at several Southern
California banking institutions, as well as resulting in the arrests of
11 Romanian national individuals for EBT access card fraud with losses
totaling over $1,000--a Federal felony. All of the individual cases
will be filed by the United States Department of Justice (USDOJ),
United States Attorney's Office (USAO) for Federal prosecution.''
On February 2, as part of Operation Urban Justice, three additional
defendants were arrested after they allegedly withdrew funds from ATM
machines in Hollywood and Tarzana with cloned EBT cards. All three were
subsequently named in Federal indictments that charge them with bank
fraud (which carries a statutory maximum penalty of 30 years in Federal
prison), aggravated identity theft, unlawful use of unauthorized access
devices and possession of 15 or more unauthorized access devices.
Criminal complaints and indictments contain allegations that a
defendant has committed a crime. Every defendant is presumed innocent
until and unless proven guilty beyond a reasonable doubt.
The United States Secret Service and the Los Angeles Police
Department are investigating these matters.
Assistant United States Attorneys Nisha Chandran and Joshua O.
Mausner of the General Crimes Section are prosecuting these cases.
Substantial assistance was provided by the following Assistant United
States Attorneys, all from the General Crimes Section: Laura A.
Alexander, Jeremy K. Beecher, Haoxiaohan H. Cai, Declan T. Conroy,
Alexander S. Gorin, David C. Lachman, Kelly L. Larocque, Jena A.
MacCabe, Angela C. Makabali, Sonya A. Nevarez, Daniel H. Weiner, and
David W. Williams.
Contact: Ciaran McEvoy, Public Information Officer,
ciaran.mcevoy@usdoj.gov, (213) 894-4465.
Updated March 2, 2023.
______
Submitted Reports by Hon. Glenn Thompson, a Representative in Congress
from Pennsylvania
Report 1
[https://www.aei.org/research-products/report/promoting-mobility-
through-snap-toward-better-health-and-employment-outcomes/]
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Perspectives on Opportunity
Promoting Mobility Through SNAP: Toward Better Health and Employment
Outcomes
By Angela Rachidi and Thomas O'Rourke, [American Enterprise Institute
for Public Policy Research]
May 2023
The Supplemental Nutrition Assistance Program (SNAP) is among
the nation's largest safety-net programs, helping low-income
households afford food, improve nutrition, and support
employment. As program expenditures continue to grow, assessing
SNAP from the perspective of employment and health outcomes is
crucial. We analyze administrative and survey data to document
trends in employment and health outcomes for adult SNAP
recipients from 1996 to 2019. We find the fastest-growing
groups of the adult caseload suffer from low employment levels
and poor health outcomes. These results suggest that program
reforms should focus on not only reducing hunger but also
improving employment and nutrition.
The Supplemental Nutrition Assistance Program (or SNAP, formerly
called the Food Stamp Program) provides food benefits to 40 million
Americans each month at a total cost of over $110 billion in 2022 (USDA
2023b). One of SNAP's primary goals is to reduce hunger and
malnutrition by helping low-income households afford food. However, the
program's purpose goes beyond simply providing resources for food. It
also aims to help families escape poverty by encouraging proper
nutrition and stable, gainful employment.
A growing body of research shows that SNAP's design can work
against these goals by discouraging employment and contributing to poor
diet (Hoynes and Schanzenbach 2012; East 2018; Andreyeva, Tripp, and
Schwartz 2015; Mande and Flaherty 2023). Unlike other Federal food
assistance programs, SNAP has no nutritional standards, allowing
participants to purchase any food or beverage product intended for
consumption, except alcohol. As a result, data show that sizable
portions of SNAP dollars purchase non-nutritious foods, such as sugary
beverages and ultra-processed foods, which can lead to poor health
(USDA 2016).
Additionally, SNAP's work requirements have a limited scope, with
the most stringent work requirements applying only to age 18-49 able-
bodied adults without dependents (ABAWDs). Over the past several years,
states have exploited exceptions in the law to waive these work
requirements, resulting in many ABAWDs not subject to a work
requirement at all. Moreover, research suggests that SNAP benefits can
disincentivize work among some low-income families, reducing the
prospects of upward mobility.
Although previous research has investigated SNAP's health and
employment effects, we know little about trends in employment and
health outcomes for adult SNAP participants over time. To document
trends in SNAP participants' health and employment outcomes over the
past 2 decades, we analyzed data from the U.S. Department of
Agriculture's (USDA) Quality Control (QC) dataset to explore changes in
the composition and employment levels of the SNAP adult caseload from
1996 to 2019 and health data from the National Health Interview Survey
(NHIS).
SNAP QC data compile demographic and economic information on a
representative sample of SNAP households from all 50 states, collected
to determine SNAP eligibility. The NHIS is a household survey conducted
yearly by the Centers for Disease Control and Prevention asking
respondents a variety of health- and employment-related questions,
including whether anyone in the household receives SNAP. Both datasets
are cross-sectional, meaning the results reflect the SNAP caseload at
points in time, not necessarily the same individuals over time. For our
analyses, we grouped SNAP adults by age and parent status, stemming
from how SNAP policy is currently structured.\1\
---------------------------------------------------------------------------
\1\ For example, non-parent adults age 18-49 are subject to work
requirements, so for our analyses, we use the same age range.
---------------------------------------------------------------------------
Our results show that adult SNAP recipients have had especially
poor health and employment levels over the past 2 decades. We found
that the average age of adults receiving SNAP has risen substantially
over time and that these adults were more likely than ever to be
childless. Older and childless adults displayed the lowest employment
levels of all recipients consistently across years. Additionally, we
documented high rates of physical and mental health issues among all
groups of SNAP adults, especially when compared to other groups of U.S.
adults. Making matters worse, these health and employment challenges
are affecting a greater number of low-income Americans as SNAP
caseloads have grown over time. Our findings raise serious concerns
about the employment and health status of SNAP adults and the program's
potential contribution to these alarming statistics.
In the sections that follow, we first describe SNAP's history,
including the evolution of policies related to employment and
nutrition. Next, we document SNAP's caseload and expenditure growth
since 1996, along with changes to the composition of the SNAP caseload
by age and parent profiles. In the third section, we review employment
levels for the SNAP caseload by age and parent profiles using SNAP QC
data. In the fourth section, we review health outcomes using data from
the NHIS, also according to age and parent profiles. We conclude with
key takeaways for policymakers as they consider SNAP reforms.
Program History
The Food Stamp Program began in the 1930s as a small effort to
match excess commodities from farmers with hungry families, offering
disadvantaged Americans an essential social service throughout the
Great Depression. The modern-day SNAP--retitled from the Food Stamp
Program in 2008--has roots in this early program but long ago shifted
its purpose away from redistributing excess commodities to reducing
poverty. Upon signing the Food Stamp Act of 1964, President Lyndon B.
Johnson signaled this shift, saying, ``As a permanent program, the food
stamp plan will be one of our most valuable weapons for the war on
poverty'' (Johnson 1964).
Several additional legislative efforts in the following decade
further transformed the program into its current form. Notably,
President Richard Nixon set a goal in 1969 to end hunger in America
(Nixon 1969), and Congress responded by mandating that states offer the
Food Stamp Program nationwide by 1974, which began a period of
exceptional program growth.
The language used in the 1964 Food Stamp Act outlined the core
goals of the program, which remain in place today: ``It is hereby
declared to be the policy of Congress, in order to promote the general
welfare . . . to safeguard the health and well-being of the nation's
population by raising levels of nutrition among low-income
households.'' \2\ The program's goals were not limited to the vision of
``reducing hunger and malnutrition''; they also included promoting more
nutritious diets among low-income Americans and supporting domestic
agriculture. In the 1977 Food Stamp Act, Congress attributed ``limited
purchasing power'' as a factor leading ``to hunger and malnutrition in
the U.S.'' and authorized food stamps to ``permit low-income households
to obtain a more nutritious diet through normal channels of trade by
increasing food purchasing power for all eligible households who apply
for participation.'' \3\
---------------------------------------------------------------------------
\2\ Food Stamp Act of 1964, Pub. L. No. 88-525; and Food and
Nutrition Act of 2008, Pub. L. No. 88-525.
\3\ Food Stamp Act of 1977, Pub. L. No. 88-525.
---------------------------------------------------------------------------
Consistent with Congress's motivation to promote nutrition (while
also supporting domestic agriculture), SNAP has always been an in-kind
benefit that recipients can use only for food and beverages, making it
different from other safety-net programs that offer direct cash
assistance, such as cash welfare. Efforts to restrict benefit use even
further--such as excluding items with no nutritional value--invited
intense debate throughout the 1970s that continues today, but Congress
has never restricted benefit use beyond a few goods, such as alcohol
and tobacco products (NRC 2013).
Another common theme across legislative efforts over the years has
involved employment. Policymakers have long debated what, if any, work
expectations the program should place on recipients (NRC 2013).
Proponents of work requirements argue that able-bodied Americans should
work insofar as they are able, whereas opponents argue that work
requirements effectively penalize the most disadvantaged Americans. In
early legislation, participants had to register for work, and by 1977,
certain participants were required to search for a job. Later, as part
of welfare reforms in 1996, Congress required ABAWDs age 18-49 to work
(USDA 2018).
This brief program history frames how researchers and policymakers
tend to think about SNAP's goals and effectiveness. Reducing hunger and
food insecurity (defined as ``not having access to sufficient food, or
food of an adequate quality, to meet one's basic needs'') has always
been the most prominent program goal (USDA 2023a). For this reason, the
USDA has tracked food insecurity rates since 1996 and has used these
trends to assess SNAP's performance. This research generally shows that
SNAP reduces food insecurity in the short term. But given SNAP's
negative effects on employment and health--both necessary for upward
mobility and self-sufficiency-- questions remain over whether SNAP
effectively reduces food insecurity in the long run.\4\ Although the
government does not routinely assess nutrition outcomes or employment,
a body of research suggests that SNAP reduces employment and
contributes to poor diet (Hoynes and Schanzenbach 2012; East 2018;
Andreyeva, Tripp, and Schwartz 2015; Mande and Flaherty 2023).
---------------------------------------------------------------------------
\4\ One study examined increases in SNAP benefits stemming from the
2009 American Recovery and Reinvestment Act (ARRA) and found that it
decreased food insecurity by 2.2 percentage points (Nord and Prell
2011). However, another study using a different data source found that
the ARRA SNAP expansions did not affect food insecurity rates for
youth, nor did higher benefits result in healthier diets (Hudak,
Racine, and Schulkind 2021). Yet another study using an even different
data source and methodology found that SNAP participation lowered food
insecurity for households after receiving 6 months of benefits but did
not affect very low food security (i.e., a proxy for hunger) among some
subgroups (USDA 2013). Moreover, it is difficult to ignore the reality
that despite the exceptional growth in SNAP participation, food
insecurity rates have held relatively steady over the past 2 decades,
only fluctuating with the business cycle.
---------------------------------------------------------------------------
SNAP Growth and Demographic Changes
SNAP participation and costs have grown tremendously over the past
2 decades. The percentage of the U.S. population participating in SNAP
increased from 7.1 percent in 1980 to 14.9 percent at its peak in 2013
after the Great Recession. Even with pre-pandemic unemployment rates at
record lows, one in ten Americans received SNAP in 2019 (Crouse 2022).
Increases in the costs of the program have tracked closely with
increases in participation. From 2000 to 2019, SNAP's annual costs grew
from $23 billion to $57 billion (in 2021 dollars) (USDA 2023b).\5\
During the pandemic, a number of measures increased SNAP spending on a
per-person basis, resulting in a near doubling of costs from 2019 to
2022 (Figure 1). Given these benefit increases, the Congressional
Budget Office projects that total costs will top $110 billion annually
through 2033 (CBO 2023).
---------------------------------------------------------------------------
\5\ SNAP costs were adjusted using the Consumer Price Index for All
Urban Consumers.
---------------------------------------------------------------------------
The growth of SNAP is the result of a confluence of changes to both
policy and economic conditions starting in the mid-to-late 2000s
(Rachidi 2021). First, changes to the program's administration from
paper coupons to electronic benefits occurred in the early 2000s, as
did the reinstatement of eligibility for some immigrants. Second, the
economic distress the Great Recession caused increased the number of
low-income Americans eligible for SNAP. Additionally, the 2008 Farm
Bill changed the program title, adding the term ``nutrition'' among
other things and liberalizing some operational program components.
Altogether, these economic and policy changes reduced program stigma
and extended its reach.
Figure 1. SNAP Participation and Costs, 2000-22
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Costs were adjusted for inflation using the Consumer
Price Index for All Urban Consumers.
Source: USDA (2023b).
Perhaps the most consequential effects on SNAP participation during
this time, however, involved three important policy changes. First, in
response to the Great Recession, the American Rescue and Recovery Act
of 2009 waived the ABAWD time limit nationwide from April 2009 through
September 2010, and many states continued to request waivers in
subsequent years, citing a struggling economy and limited labor market
prospects for recipients. However, even as the economy recovered and
the labor market grew stronger, many states were slow to reinstate the
ABAWD time limit, often exploiting loopholes in the law (USDA 2019).
Secondly, many states eliminated SNAP's asset test during this
time, which the law allowed but states increasingly opted to do after
the Great Recession (Sykes 2017). Lastly, when the pandemic hit in
2020, SNAP participation increased due to rising levels of economic
hardship and pandemic-related emergency measures, such as delaying
recertification requirements, issuing emergency allotments, and
suspending the ABAWD work requirement. SNAP also ignored the value of
over $1 trillion in Federal pandemic stimulus checks, tax credits, and
unemployment bonuses in determining claimant eligibility, further
driving caseload increases (Weidinger 2023). Because the Federal public
health emergency remained in effect well into 2023, SNAP caseloads have
remained stubbornly high, even though economic conditions have
improved.
Despite SNAP's rising caseloads over the past 2 decades, such
growth has not been uniform across demographic groups. We used SNAP QC
data to categorize SNAP household heads into mutually exclusive groups
by parent status, age, and disability status. For our purposes, non-
disabled individuals include those who were not receiving Federal
disability assistance.
As displayed in Figure 2, the composition of SNAP household heads
has changed considerably over the past 2 decades. The average age of
household heads has become substantially older, and those household
heads have become much more likely to be childless, evidenced by an
increasing share of adults age 50-64 and a decreasing share of parents
age 18-49. In 1996, adults age 50-64 accounted for only 12.6 percent of
all household heads, but by 2019, this group's share had more than
doubled, accounting for over a quarter of all SNAP household heads
(27.6 percent). Much of the growth of this group is attributable to
nondisabled adults age 50-64, which has nearly tripled from five
percent of heads of households in 1996 to 13 percent in 2019.
Figure 2. SNAP Composition by Age, Disability, and Parental Status
Among Household Heads, 1996-2019
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: See SNAP QC (n.d.) for a definition of ``disability.''
Although the data stop identifying individuals with disability
at age 59, we construct a similar measure of disability for
those age 60-64. We use age 49 as a cutoff for adults because
this is the upper age limit at which ABAWD work requirements
apply. Percentages reflect the share of household heads, not
all recipients.
Source: SNAP QC (n.d.) for individual years 1996-2019.
In contrast, the group of SNAP household heads witnessing the most
dramatic declines in caseload share were non-disabled parents age 18-
49, falling from 53.5 percent in 1996 to 33 percent by 2019. Childless
household heads age 18-49 fluctuated over time but remained a similar
share in 2019 as in 1996. As a result, among household heads age 18-49,
the share with children outnumbered those without children three to one
in 1996, but by 2019, the ratio was 1.8 to 1. The other groups shown in
Figure 2 fluctuated over time but did not change as dramatically from
1996 to 2019.
Notably, when Congress passed the ABAWD work requirement as part of
welfare reform in 1996, ABAWDs constituted 11.2 percent of SNAP
household heads, whereas non-disabled 50 to 64 year olds accounted for
4.9 percent. After 2 decades, non-disabled 50 to 64 year olds now
constitute a greater share of SNAP household heads than ABAWDs (13.3
and 12 percent, respectively) despite the much larger age span for
ABAWDs, raising concerns over the rising recipiency of older, non-
disabled SNAP household heads.
In some ways, the growing share of older SNAP recipients simply
reflects broader demographic trends observed throughout the entire U.S.
As baby boomers age into retirement and fewer younger Americans have
children, the country has become progressively older over time--
evidenced by an increase in the median age by 3.4 years since 2000 and
fertility falling below the replacement rate (Census Bureau 2022).
While these population-wide shifts likely play a role in dictating
SNAP trends, they certainly are not large enough to explain such
dramatic changes in the composition of the SNAP caseload. As a share of
the entire poor population (according to the Official Poverty Measure),
50 to 64 year olds have grown from 15 percent in 1997 to 22 percent in
2019. But among adults receiving SNAP, 50 to 64 year olds grew from 14
percent to 28 percent over the same period.\6\ Policy changes--
including the waiving of work requirements and asset tests--have almost
certainly affected who did and did not receive SNAP benefits over the
past 2 decades.
---------------------------------------------------------------------------
\6\ Authors' calculations using the Current Population Survey. The
``poor population'' includes those who are below 125 of the Federal
poverty line.
---------------------------------------------------------------------------
Figure 3. Percentage of SNAP Recipients Employed by Group, 1996-2019
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Parents of ``older'' children are parents who only have
children age 5 or above. Parents of ``younger'' children are
those who have any children younger than age 5.
Source: SNAP QC (n.d.) for individual years 1996-2019.
The analyses of caseload data show that the SNAP caseload of today
does not resemble the caseload of previous decades. Around the time of
welfare reform, parents with children headed the majority of SNAP
households, yet today less than 40 percent fall into this category.
Rising recipiency among older and childless adults calls attention to
their employment and health outcomes, along with SNAP's contribution to
their challenges.
Employment and SNAP
When examining employment levels, we maintained the same age groups
as in Figure 2, but we disaggregated 18 to 49 year old parents by the
age of their children to reflect their differing caretaking
responsibilities and attachment to the labor force. We also excluded
the oldest cohort of recipients (age 65 and older) from the analysis,
given that many Americans of this age are retired.
As displayed in Figure 3, in the most recent years of data,
slightly less than \1/2\ of SNAP parents age 18-49, regardless of the
children's age, worked while receiving SNAP, a rate that has increased
modestly over time.\7\ Older household heads age 50-64 (with or without
dependents) experienced the lowest employment levels consistently
across time, with 13 percent reporting employment while receiving SNAP
in 2019, marginally higher than in 1996.\8\
---------------------------------------------------------------------------
\7\ For definitions of ``older'' and ``younger'' children, see
Appendix A.
\8\ In the most recent year of data, only 11.4 percent of SNAP
household heads age 50-64 had a dependent in the household.
---------------------------------------------------------------------------
Moreover, only about one in five household heads age 18-49 without
dependents reported employment while receiving SNAP in 2019, also
marginally better over time. Employment levels for SNAP parents have
increased steadily over time. However, the gains have been small, and
overall employment levels remain low.
One reason for such low employment levels was due to a high
incidence of disability. Undeniably, disabilities and work limitations
can majorly inhibit stable and gainful employment, and SNAP receipt
often goes hand in hand with disability benefits. For example, one of
the nation's largest disability programs, Supplemental Security Income
(SSI), makes SSI individuals living alone (or with other SSI
recipients) categorically eligible for SNAP (Trenkamp and Wiseman
2007). Figure 4 shows that, among SNAP recipients, disabilities were
more common among adults age 18-49 without dependents and adults age
50-64 than they were for parents, which partly explains the low
employment levels observed in Figure 3.
Older and childless SNAP household heads were much more likely to
be disabled than younger SNAP adults with children were--and presumably
less able to work. However, even when considering the employment levels
for non-disabled SNAP adults, employment rates remained remarkably low.
As Figure 5 shows, while employment levels have risen over time, still
only about \1/4\ of non-disabled adults age 18-49 without dependents
and household heads age 50-64 worked while receiving SNAP (27.8 percent
and 24.1 percent, respectively) in 2019.
Figure 4. Percentage of SNAP Recipients Who Receive Disability
Assistance by Group
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: The rates of disability are pooled across the most
recent 3 years of data, 2017-19. Disability rates for each
groups do not vary substantially across time.
Source: SNAP QC (n.d.) for individual years 2017-19.
Figure 5. Percentage of non-disabled SNAP Recipients Employed by Group,
1996-2019
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Source: SNAP QC (n.d.) for individual years 1996-2019.
Figure 6. Percentage of SNAP Recipients Who Are Either Disabled,
Employed, or Engaged in Caretaking
Panel A. Among 18 to 49 Year Old Panel B. Among 50 to 64 Year Olds,
Non-parents, 2003-19 2003-19
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: See Appendix A for a description of calculations for
each category. We begin the series in 2003 rather than 1996
because, for 50 to 64 year olds, our method for identifying
disabled 60 to 64 year olds is not consistent with the data
provided in previous years.
Source: SNAP QC (n.d.) for individual years 2003-19.
Because SNAP targets low-income households (and employment offers a
substantial source of income), it is unsurprising that SNAP adults
generally have low levels of employment. But these data raise the
question of why so many non-disabled, childless adults remain without
employment, especially in years when nationwide unemployment rates were
low and job opportunities were plentiful.
To gain a fuller understanding of the factors that could be
contributing to low employment rates--especially among SNAP recipients
age 18-49 without dependents and those age 50-64--we accounted for the
share of each group that was either disabled, already employed, or had
caretaking responsibilities. As Figure 6 Panels A and B show, a sizable
share of household heads age 18-49 without dependents and household
heads age 50-64 were not disabled, did not have caretaking
responsibilities, and lacked employment.\9\ This leaves major shares of
these groups' status while receiving SNAP unexplained.
---------------------------------------------------------------------------
\9\ We used a generous definition of caretaking, to include if they
had (1) a child below age 18 residing in their SNAP-defined household,
(2) an elderly person age 65 or older in their household, or (3) anyone
in their household who was disabled.
---------------------------------------------------------------------------
In sum, our findings suggest that the fastest-growing groups of
SNAP household heads had low levels of employment across much of the
past 3 decades. Even after accounting for a variety of factors that
might explain these low levels of employment, we found that a large
share of these SNAP recipients were not working, caretaking, or
disabled.
Health and SNAP
Employment and health are interdependent, but it can be difficult
to disentangle cause and effect. Poor health might cause unemployment,
but not working might also cause deteriorating health (Hussam, et al.
2021). SNAP's status as a nutrition benefit that provides income
support offers a unique opportunity to promote both health and
employment, potentially spurring a cycle of healthy living and stable
employment among low-income adults. However, the health status of SNAP
adults suggests that the program falls well short of promoting good
health.
To analyze health outcomes among SNAP adults, we used data from the
NHIS--a nationally representative health survey. We explored physical
and mental health outcomes for SNAP adults based on parent and age
status from 1997 to 2018. We also compared their outcomes to two groups
of adults not receiving SNAP: low-income non-recipients and high-income
non-recipients.\10\
---------------------------------------------------------------------------
\10\ Specifically, we define ``low-income non-recipients'' as those
who are below 125 percent of the Federal poverty line but do not
receive SNAP. And we define ``high-income non-recipients'' as those who
are above 125 percent of the poverty line and do not receive SNAP.
---------------------------------------------------------------------------
Figure 7. Percentage of Unexplained with Self-Reported Work Limitation,
1997-2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: The unexplained are SNAP recipients who are non-
disabled, not working, and have no caretaking responsibilities.
A work limitation is defined as any physical, mental, or
emotional problem that prevents the respondent from working or
limits the kind or amount of work that the respondent is able
to undertake.
Source: NHIS (n.d.) for individual years 1997-2018.
First, we explored self-reported health limitations for the
``unexplained'' SNAP adults identified in Figure 6. As displayed in
Figure 7, a large share (between 50 and 60 percent across time) of the
50 to 64 year old unexplained group reported a health-related work
limitation, which changed only slightly over time. A smaller percentage
of unexplained adults age 18-49 without dependents reported a work
limitation, suggesting that something other than a health issue was
driving low employment within this group. This suggests that a large
share of the nonworking 50 to 64 year old group had a health issue that
limited their employment, while health issues explained a smaller share
of employment problems for those age 18-49.
Next, we explored physical and mental health outcomes among all
adults receiving SNAP to understand the health issues facing the SNAP
population as a whole. As shown in Figure 8, across age and parent
profiles, SNAP adults reported high rates of ever having a diet-related
disease (including diagnosed with diabetes, heart disease, stroke, or
hypertension) (CDC 2022)--especially recipients age 50-64. Between 60
to 70 percent of this group reported ever having a diet-related disease
over the past 2 decades; even among SNAP parents of young children,
almost 20 percent reported ever having a diet-related disease in 2018.
Figure 9 displays how, for each age and parent profile, ever having
a diet-related disease was much more common among SNAP recipients
compared to low- and high-income non-recipients (non-recipients below
125 percent of the Federal poverty line and non-recipients above 125
percent of the poverty line, respectively). For example, 65 percent of
50 to 64 year old SNAP recipients reported having at least one diet-
related disease, whereas only 44 percent of similarly aged high-income
non-recipients and 57 percent of low-income non-recipients reported
having a diet-related disease. That diet-related disease was much more
common among SNAP recipients than other low-income adults suggests that
SNAP serves a particularly unhealthy population.
Figure 8. Percentage of SNAP Adults with Diet-Related Disease, 1997-
2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are 3 year running averages. Diet-related
disease is defined as ever being diagnosed with diabetes, non-
congenital heart disease, stroke, or hypertension.
Source: NHIS (n.d.) for individual years 1997-2018.
Figure 9. Diet-Related Disease by SNAP Status and Age and Parent
Profiles, 2014-18
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Diet-related disease is defined as ever being diagnosed
with diabetes, non-congenital heart disease, stroke, or
hypertension. The figure reflects pooled averages of diet-
related disease from 2014 to 2018. All differences between SNAP
recipients and the two comparison groups are statistically
significant at the 0.05 level.
Source: NHIS (n.d.) for individual years 2014-18.
Figure 10. Percentage of SNAP Recipients with Obesity, 1997-2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are 3 year running averages. Obesity is defined
as having a body mass index of 30 or greater.
Source: NHIS (n.d.) for individual years 1997-2018.
We observed the same pattern for obesity rates. Like U.S. adults
broadly, rates of obesity among adults receiving SNAP have increased
over the past 2 decades. As shown in Figure 10, among SNAP adults age
18-49 with children and SNAP adults age 50-64, obesity rates at the
time of the survey increased from approximately 30 percent in the late
1990s to around 40 percent by 2018. But the group of household heads
experiencing the most rapid rise in obesity has been adults age 18-49
without dependents, whose rate has grown from 22 percent to 34 percent,
a 55 percent increase.
Although obesity plagues U.S. adults of all socioeconomic statuses,
SNAP adults were much more likely to be obese than were low-income non-
recipients and high-income non-recipients, suggesting again that there
is something uniquely substandard about the health status of adults
receiving SNAP. As Figure 11 displays, over \1/3\ (34 percent) of SNAP
adults age 18-49 without dependents were obese, while only 20 percent
of low-income non-recipients and 23 percent of high-income non-
recipients were obese.
Unsurprisingly, given SNAP recipients' high rates of diet-related
disease and obesity, a relatively large percentage of SNAP adults,
especially those age 50-64, rated their health as fair or poor at the
time of the survey. As Figure 12 shows, this trend improved over time
for the oldest cohort of SNAP recipients, but still \1/2\ reported fair
or poor health by 2018. Consistent with the other health measures, SNAP
adults also reported fair or poor health at higher rates than non-
recipients did, as shown in Figure 13.
Many of the health problems facing low-income Americans--and SNAP
recipients in particular--are not merely physical. Figure 14 presents
the share of SNAP adults who reported feeling either ``hopeless'' or
``worthless'' in the 30 days preceding the survey. We focused on these
two indicators because research has shown these to be two of the
strongest predictors of severe mental health issues (Shand, et al.
2015). For SNAP adults age 50-64, these mental health issues subsided
slightly over time as more people in this age category joined SNAP, but
still 35 percent reported these feelings in 2018--a higher percentage
than any other group. Like other health measures, SNAP adults reported
higher rates than non-recipients did, as shown in Figure 15.
Figure 11. Obesity by SNAP Status and Age and Parent Profiles, 2014-18
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are averages across the past 5 years of data
(2014-18). All differences between SNAP recipients and the two
comparison groups are statistically significant at the 0.05
level.
Source: NHIS (n.d.) for individual years 2014-18.
Figure 12. Percentage of SNAP Recipients That Rate Their Health Status
as Fair or Poor, 1997-2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are 3 year running averages. Fair and poor
health status are the two lowest self-assessments on a five-
point Likert scale, ranging from ``poor'' to ``excellent.''
Source: NHIS (n.d.) for individual years 1997-2018.
Figure 13. Fair or Poor Health Status by SNAP Status and Age and Parent
Profiles, 2014-18
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are averages across the past 5 years of data
(2014-18). All differences between SNAP recipients and the two
comparison groups are statistically significant at the 0.05
level.
Source: NHIS (n.d.) for individual years 2014-18.
Figure 14. Percentage of SNAP Recipients Who Report Feeling Hopeless or
Worthless in the Past Month, 1997-2018
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are 3 year running averages.
Source: NHIS (n.d.) for individual years 1997-2018.
Figure 15. Feelings of Hopelessness or Worthlessness by SNAP Status and
Age and Parent Profiles, 2014-18
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Note: Results are averages across the past 5 years of data
(2014-18). All differences between SNAP recipients and the two
comparison groups are statistically significant at the 0.05
level.
Source: NHIS (n.d.) for individual years 2014-18.
Altogether, these data show that physical and mental health
problems were common among adults receiving SNAP and likely contributed
to their relatively low employment levels over the past 2 decades.
These data also raise questions about the degree to which SNAP might be
exacerbating health issues among low-income adults by contributing to
poor nutrition and discouraging employment. It is cause for concern
that almost 70 percent of SNAP adults age 50-64 reported ever having a
diet-related disease, and 40 percent reported feeling ``hopeless'' or
``worthless'' in recent years.
Whether SNAP causes poor health or attracts people with already
poor health remains up for debate. However, the persistently high rates
of health problems among adults receiving SNAP--along with enduring
gaps between recipients and non-recipients--suggest that SNAP is
falling short on leading participants toward good health and may even
make matters worse by supporting non-nutritious diets for millions of
disadvantaged adults.
Conclusion
SNAP is one of the nation's largest safety-net programs,
transferring more than $100 billion per year to low-income households.
Although research shows that SNAP may reduce food insecurity in the
short run, our results document low employment levels and poor--and, in
the case of disease and obesity rates, worsening--health status,
raising questions about the program's long-term effectiveness.
Specifically, we find that two of the fastest-growing groups of SNAP
recipients--50 to 64 year olds and adults age 18-49 without
dependents--face the worst health and employment outcomes.
Approximately \1/2\ of household heads age 50-64 and \1/3\ of
adults age 18-49 without dependents were disabled while receiving SNAP.
However, even when we exclude disabled recipients from our
calculations, employment levels remained low. In 2019, at a time of
historically low unemployment in the U.S. economy, only 28 percent of
ABAWD household heads worked while receiving SNAP, and only 24 percent
of non-disabled 50 to 64 year olds worked. Further, we found that
caretaking responsibilities played a limited role in depressing labor
force participation among these groups. We found that three in ten SNAP
household heads age 50-64 and 43 percent of those age 18-49 without
dependents were not working and were neither caretaking nor disabled.
In other words, their inability to work remains unexplained.
One reason we discovered for a large share of unexplained SNAP
adults was poor health that did not rise to the level of disability,
according to data from the NHIS. Alarmingly, more than \2/3\ of
unexplained 50 to 64 year olds reported a health problem that limited
their ability to work. However, our analyses also found that these
health problems were not limited to unexplained recipients. SNAP adults
consistently reported high rates of diet-related disease and obesity
and viewed their health poorly. When compared to the rest of U.S.
adults--both low-income and high-income non-recipients--SNAP recipients
consistently reported higher rates of physical and mental health
problems.
These findings reveal a concerning picture of SNAP. One of SNAP's
main goals is to improve nutrition for low-income households by giving
them additional resources to afford a healthy diet. And proper
nutrition is a crucial ingredient to helping people be healthy so that
they can work and escape poverty. Put simply, the poor employment and
health outcomes associated with SNAP adults suggest that the program is
failing in both regards.
Some might argue that SNAP benefit levels are insufficient for
households to afford a healthy diet, requiring that SNAP participants
purchase unhealthy food because they cannot afford to eat an
appropriate diet. However, little evidence exists to support this
contention when properly scrutinized. Contrary to conventional wisdom,
research shows that when measured properly (per nutrient or per
serving, for example), healthy foods actually cost less than unhealthy
foods (Carlson and Frazao 2012; Savoie-Roskos and Durward n.d.). In
fact, research suggests that people who eat ultra-processed foods
(common in SNAP participant diets) on average consume 500 more calories
per day than those who eat diets full of unprocessed foods such as
fruits and vegetables (Hall, et al. 2019).
Additionally, over the long run, diets full of ultra-processed
foods have substantial secondary costs, such as high medical costs and
employment disruptions due to poor health (Savoie-Roskos and Durward
n.d.). Collectively, this shows that unhealthy diets like those common
among SNAP participants are likely more costly in the short run and
definitely more costly in the long run than are healthy diets rich in
minimally processed foods.
SNAP is due for reauthorization in 2023 as part of the farm bill,
and policymakers must act to address the myriad health and employment
challenges facing SNAP recipients. With the proper reforms,
policymakers can maintain SNAP as a vital income support while also
addressing the alarmingly low employment rates and poor health outcomes
of its participants. The first priority must be to place commonsense
nutritional standards on SNAP, similar to those that already apply to
other Federal food assistance programs such as the National School
Lunch Program and the Special Supplemental Nutrition Program for Women,
Infants, and Children. This can start with excluding sugary beverages
from the list of eligible food items for purchase with SNAP benefits.
The next priority must be to strengthen existing work requirements for
ABAWDs and extend the positive aspects of work requirements to other
SNAP populations (Rachidi 2023).
Acknowledgments
Special thanks to Antonia Bleser for her research and writing
assistance and to Matt Weidinger for his review and comments.
About the Authors
Angela Rachidi is a senior fellow and Rowe Scholar with AEI's
Center on Opportunity and Social Mobility, where she studies government
policies and programs aimed at helping low-income Americans.
Thomas O'Rourke is a research assistant with AEI's Center on
Opportunity and Social Mobility, where he supports research on social
capital and economic mobility.
About AEI's Center on Opportunity and Social Mobility
The Center on Opportunity and Social Mobility, directed by Scott
Winship, conducts rigorous research and develops evidence-based
policies aimed at expanding opportunity in America by reducing
entrenched poverty, increasing upward mobility, and rebuilding social
capital.
About AEI's Perspectives on Opportunity
AEI's Perspectives on Opportunity is a policy report series
published by the Center on Opportunity and Social Mobility (COSM).
Contributions to this series include empirical and theoretical analysis
of issues related to opportunity in the United States and evidence-
based policy proposals to expand opportunity, promote upward mobility,
and strengthen social capital. COSM Deputy Director Kevin Corinth is
the editor of Perspectives on Opportunity.
Appendix A. Data and Methods
For all original analyses in this report, we primarily rely on two
different data sources. The first is the U.S. Department of
Agriculture's (USDA) Supplemental Nutrition Assistance Program (SNAP)
Quality Control (QC) data, an administrative dataset containing tens of
thousands of observations each year. The second data source we use is
the National Health Interview Survey (NHIS), which is a yearly study
that has been conducted since 1963, asking a representative sample of
Americans about a variety of health and employment outcomes.
In this appendix, we give a detailed account of each dataset,
including any methodological decisions that we made in cleaning and
preparing the data for our analyses. We then go through a series of
terms that we use throughout the report, clearly articulating our
definition of each term within each dataset. We begin with the NHIS.
National Health Interview Survey
The NHIS, conducted yearly by the Centers for Disease Control and
Prevention, asks respondents a variety of different health- and
employment-related questions. Beginning in 2019, the survey underwent a
significant redesign, which makes comparability with prior years
difficult. However, the survey was conducted using consistent methods
from 1997 to 2018, making it an optimal source for examining yearly
trends in health outcomes for various populations. The sample sizes are
sufficiently large to break out by SNAP recipiency, age, and parental
status.
We extracted our sample of NHIS variables from the University of
Minnesota's Integrated Public Use Microdata Series. Our subset of
variables includes a standard set of demographic and income variables,
a variety of variables asking respondents about their physical and
mental health status, and household-level indicators of SNAP receipt.
SNAP QC Data
As part of SNAP's administration, the program implemented a quality
control system to ensure that SNAP recipients are receiving the proper
amount of benefits given their income and household size. A random
sample of households is selected each year to participate in a quality
control review, in which a SNAP caseworker meets face-to-face with the
randomly selected household. Throughout this review, caseworkers ask
recipients a variety of questions about their employment, income,
household size, and participation in other government programs.
Each year, the USDA publishes anonymized data collected through
this process in the form of SNAP QC data. Because these data are
collected directly by the USDA and administered face-to-face, it is
viewed as the authoritative data source on SNAP receipt. However, due
to a variety of different coding discrepancies and survey methodologies
over the past 2 decades, the data are difficult to compare across time.
In certain years, the administrators of SNAP QC data warn those
using the data about potential coding errors or inconsistencies. On
some variables, SNAP QC data recommend either against using a given
variable--evidence that the variable was coded so inconsistently that
it is totally unreliable--or that users take caution when using a
variable. Although we never used any variable that the SNAP QC data
recommend against using, we did, in some cases, use variables for which
the QC data recommended caution. In each case we did so, we detailed
what measures we took to ensure that our data were accurate.
We also dropped some observations from the data. Most notably, we
dropped those who were deemed ineligible for SNAP as a result of the
review process. These observations are households that, as a result of
being reviewed, no longer qualify for SNAP and lose their SNAP
benefits. After 2002, QC data administrators dropped these observations
from the sample before releasing the public use data. Before 2002,
there were usually only a few hundred such observations that we
dropped. Additionally, we dropped households for which there was no
identifying information--such as head of household status or
employment--again, resulting in a negligible number of observations
dropped per year.
We now turn to our definitions of each term that we employ
throughout the report, highlighting any important methodological
decisions that we made and any definitional discrepancies between our
two data sources.
Disability
The NHIS data have asked respondents about their disability status
every year from 1997 to 2018. We define an individual as disabled if
they report receiving Supplemental Security Income (SSI) or Social
Security Disability Insurance (SSDI). The NHIS asked respondents four
questions about whether they receive SSI or SSDI, and if they answered
in the affirmative in any of those questions, then they are categorized
as disabled. Conversely, we refer to any respondent who did not receive
SSI or SSDI as non-disabled.
The SNAP QC data, on the other hand, define disability slightly
differently. From 2012 onward, SNAP QC defines ``non-elderly
individuals identified as disabled using receipt of SSI or a
combination of hours worked, work registration status, receipt of
Social Security, veterans' benefits, or workers' compensation, and/or
unit medical expense deduction.'' For the full list of criteria used by
the QC data to identify disability, refer to Appendix B in SNAP QC
data's technical documentation (Cornquist, Lauffer, and Vigil 2020).
Curiously, from 2007 to 2011, SNAP QC data documentation does not
include individual-level disability identifiers, but the data files
available for download include consistent measures of individual-level
disability identifiers. After performing a series of checks, it appears
that SNAP QC retroactively coded disability for these years just as
they did from 2012 onward. From 2003 to 2006, however, the data files
do not have individual-level disability information, so we
reconstructed SNAP QC's measure of disability, replicating their
methods with the given information. From 1996 to 2002, SNAP measured
disability in a nearly identical manner, using information from a
similar combination of programs.
Importantly, SNAP QC data identify disability only among the
nonelderly population--therefore excluding those age 60 and older.
Because we are interested in the employment trends of those between age
50 and 64, we create individual-level disability identifiers for heads
of households between age 60 and 64. If an individual between age 60
and 64 receives SSI or veterans' benefits, then we also count them as
disabled. And if an individual is age 60 or 61 and receives Social
Security, then we count them as disabled. Our justification for the
latter is that SNAP QC data do not uniquely identify SSDI receipt, so
we assume that all Social Security recipients age 60 and 61 are
receiving SSDI. Despite our relatively simple measure of disability for
those age 60 to 64, our analyses show that disability rates for this
group are similar to external sources of data and are consistent with
disability incidence for those below 60.
However, because of methodological differences in how the QC
collected data on disability before 2003, we are unable to consistently
measure disability for those 60 and older before 2003. Therefore, our
analyses of the unexplained (Figure 6, Panels A and B) only extend back
to 2003.
With the SNAP QC data, we also define anyone not meeting any of the
above criteria as ``non-disabled.'' Although the NHIS and SNAP QC data
employ slightly different definitions of ``disability,'' we contend
that these differences do not affect any of our conclusions. We also
never use the two different definitions interchangeably--using the NHIS
definition of disability when referring to health outcomes and using
the QC definition of disability when referring to demographic changes
or employment outcomes.
Employment and Labor Force Participation
The NHIS asks respondents about their employment status and gives
them five possible responses: (1) working for pay at a job, (2) working
without pay at a job, (3) with job but not at work, (4) unemployed, or
(5) not in the labor force. We define anyone who responds one, two,
three, or four as a part of the labor force and define anyone who
responds one, two, or three as employed.
In most years, the SNAP QC data recommend caution when using their
employment variables, because there are often inconsistencies between
their two employment variables and between them and other income
variables. Because the sample sizes in the SNAP QC data are large (and
without information on whether inconsistencies were more or less likely
among the employed), we took a conservative approach when navigating
these potential data issues, dropping all observations for which we
witnessed significant inconsistencies between these variables.
Specifically, we dropped all observations that do not have
employment data. We also dropped any observation for which one
employment variable indicated that the observation was employed and the
other employment variable indicated that they were not employed. We did
not drop any observation based on inconsistencies between employment
status and income, as we were only interested in trends in employment,
not income.
After dropping these observations, we define any observation as
employed if they claim to be working for at least 1 hour per week. And
we define any observation as being in the labor force if they are
employed or actively looking for work.
Head of Household
When examining demographic or employment changes using the QC data,
we are only interested in trends among adults. Although the share of
children on SNAP has been growing over time, the scope of this report
was to review the health and employment outcomes of adults on SNAP.
Specifically, our focus on health and employment outcomes motivated us
to narrow our focus to adults.
We conducted several tests to ensure that the heads of SNAP
households were representative of all adults receiving SNAP, and our
results were not sensitive to such changes.
The Unexplained
Using the SNAP QC data, we define the unexplained as an individual
between age 50 and 64 who is not employed, not disabled, and not
caretaking. See above for our definitions of employment and disability.
We define an individual as caretaking if they have (1) a child
below age 18 residing in their SNAP-defined household, (2) an elderly
person age 65 or older in their household, or (3) anyone in their
household who is disabled.
We also progressively account for disability, employment, and
caretaking, meaning that we first count the overall share of the given
group of recipients who are disabled. Then, among those who are non-
disabled, we account for the share who are employed. Then, among those
who are non-disabled and unemployed, we account for the share who are
caretaking. The remainder--those not disabled, unemployed, and not
caretaking, are the unexplained. Therefore, the shares reflected in
Figure 6 are not meant to be representative of the overall disability,
employment, and caretaking responsibilities in each group.
We also replicated the unexplained in the NHIS data. For this, we
use the NHIS definition of disability and employment. (See above.) And
because the NHIS does not allow us to identify individuals who have
caretaking responsibilities for elderly or disabled household members,
an individual has caretaking responsibilities only if they have a child
in the household under age 18.
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program-snap-households.
___. 2013. ``Measuring the Effect of Supplemental Nutrition
Assistance Program on Food Security.'' August. https://fns-
prod.azureedge.us/sites/default/files/Measuring2013.pdf.
Weidinger, Matt. 2023. ``Unemployment Is Low, Welfare High. What
Gives?'' Wall Street Journal. March 20. https://www.aei.org/op-eds/
unemployment-is-low-welfare-high-what-gives..
Robert Doar, President; Scott Winship, Director of the AEI
Center on Opportunity and Social Mobility; Kevin Corinth,
Editor, Perspectives on Opportunity.
The American Enterprise Institute (AEI) is a nonpartisan,
nonprofit, 501(c)(3) educational organization and does not take
institutional positions on any issues. The views expressed here
are those of the author(s).
2023 by the American Enterprise
Institute for Public Policy Research. All rights reserved.
Report 2
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[https://risk.lexisnexis.com/-/media/files/government/case%20study/
lnrs%20true
%20cost%20of%20fraud_snap%20report%20pdf.pdf]
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2020 LexisNexis' Risk Solutions
True Cost of FraudTM Study for Supplemental [Nutrition]
Assistance Program (SNAP)_Mobile and Web Channels Drive Bot and
Fraud Attacks
Overview
Background and Objectives
LexisNexis' Risk Solutions conducted a research study
that can drive government segment revenue growth via thought
leadership, particularly in the Social Services area with the
Supplemental Nutrition Assistance Program (SNAP) as an initial target.
This True Cost of FraudTM Study for SNAP serves as a model
framework by informing the level and impact of fraud on SNAP agencies,
including the challenges, volume, and cost, as well as the resources
that agencies utilize to detect and prevent fraud.
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Fraud Definitions:
Account takeover by unauthorized persons
Fraudulent transactions due to identity fraud, SNAP benefits
are exchanged for cash (trafficking--generally involving two
parties--typically a household and a SNAP retailer)
A household intentionally lies to the state to qualify for
benefits or to get more benefits than they are supposed to
receive
The LexisNexis Fraud MultiplierTM cost:
Estimates the total amount of loss a firm incurs based on
the actual dollar value of a fraudulent transaction
Methodology
LexisNexis' Risk Solutions partnered with KS&R, a global
market research firm, to collect the survey responses for this research
study.
Data was collected on line and by phone in August 2022 with
a total of 74 completions in the United States.
Respondents included mostly senior executives responsible
for fraud mitigation and decisions with SNAP.
------------------------------------------------------------------------
Type Region
------------------------------------------------------------------------
County State NERO MARO SERO MWRO MPRO SWRO WRO
------------------------------------------------------------------------
49 25 15 9 9 18 12 4 7
------------------------------------------------------------------------
States: Alaska, Arizona, Connecticut, Delaware, Florida,
Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas,
Kentucky, Louisiana, Maryland, Massachusetts, Michigan,
Montana, Pennsylvania, South Carolina, Texas, Utah, Vermont,
Virgin Islands, Washington, D.C.
Counties from the ten states (California, Colorado,
Minnesota, New York, New Jersey, North Carolina, North Dakota,
Ohio, Virginia, Wisconsin) that delegate to the county level:
Alameda, Albany, Anoka, Arapahoe, Arlington, Bergen, Boulder,
Bronx, Buncombe, Burleigh, Burlington, Butte, Cass, Clermont,
Cuyahoga, Dakota, Dane, Denver, Douglas, Durham, El Paso,
Fairfax, Grand Forks, Hamilton, Hennepin, Henrico, Hudson,
Kenosha, Kings, Milwaukee, Morris, Onondaga, Onslow, Pender,
Ramsey, Richmond, San Bernardino, San Francisco, Somerset, St.
Louis, Suffolk, Summit, Wake, Ward, Warren, Williams
Significant Differences
Statistical significance is determined by a set level of confidence
sought in an estimate. Results are considered statistically significant
if the observed difference is large based on sample size(s) and
confidence level. This means the observed difference in the estimates
is extreme enough to conclude with confidence (usually 90% or 95%) that
the results would not have occurred by chance and a real difference
between them exists. For this study with 74 completions at the total
level, the sampling error is +/- 11.4% in order to highlight two
findings as statistically different.
Directional significance, commonly referred to as practical
significance, on the other hand, is when the magnitude of the
difference is large enough to be meaningful given the situation, though
not statistically different.
Comparing the two, note that statistical significance relates to
existence of a difference, while directional significance refers to the
meaningfulness/magnitude of a difference. No statistical test can
determine directional significance, as it varies greatly depending on
the area of study, issue at hand, etc., and instead, must be decided
upon by those using the results. When reporting on directional
significance, it is often helpful, especially when dealing with
extremely large/small base sizes, to set a predetermined threshold
agreed upon in collaboration with the client and apply to all results.
A finite population correction may be applied to the margin of
error when the sample size is at least 5% of the overall population.
While this is the case for the total sample relative to the number of
states and counties as we achieved just shy of 10%, the difference in
significance testing outcomes for reporting is minimal. In an effort to
simplify reporting and explanation for publication, the finite
population correction is ignored.
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Summary of Key Findings
#1: Digital transactions channels, particularly mobile devices and
apps, are contributing to the cost of fraud across SNAP
agencies.
Every $1 value of lost benefits through fraud actually costs
SNAP agencies $3.72 based on additional costs related to
labor and administrative activities. The cost of fraud is
higher for agencies that have more mobile channel
applications.
#2: Inadvertent household errors (IHEs) and suspicious cases not
worked because of limited resources represent the majority
of SNAP fraud losses. Malicious bots and the mobile channel
are influencing this.
Identity-related fraud represents over half of fraud losses.
The mobile channel continues to be a challenge, with
agencies that have an above average volume of mobile
transactions also reporting a higher number of fraud
attacks per month.
#3: Verifying household composition, identifying malicious bots,
address verification, and identity verification are among a
number of challenges SNAP agencies have with online and
mobile channel applications.
Verifying identities is directionally more of a challenge with
mobile channel applications compared to those via online.
#4: There is limited use of best-practice fraud mitigation methods
involving a multi-layered solution approach and the
integration of fraud solutions with cybersecurity and
digital customer experience operations.
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Key Findings 1
Every $1 value of lost benefits through fraud actually costs SNAP
agencies $3.72 based on additional costs related to labor and
administrative activities. The cost of fraud is higher for agencies
that have more mobile channel applications.
While in-person is the single largest channel for SNAP
application submissions and Electronic Benefits Transfer (EBT)
card use, the on line and mobile channels contribute to the
cost of fraud.
The volume of applications through the mobile channel is
still emerging, though fraudsters have increased their focus on
mobile devices and mobile apps during the past 12 months.
Distribution of Direct Fraud Costs
For every $1 value of benefits lost through fraud, it
actually costs SNAP agencies $3.72.
This is based on the LexisNexis Fraud Multiplier, which
demonstrates that the cost of fraud is more than just the lost value,
but also additional costs.
Agencies that have an above average level of applications through
the mobile channel have a higher cost of fraud ($4.40), with nearly
half of costs related to internal labor.
Distribution of Direct Fraud Costs
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Survey Q5E: Adding to 100%, what percentage do each of the
following direct fraud costs account for your total SNAP fraud
losses during the past year?
Distribution of SNAP Applications and Fraud Across Channels
In-person is the single largest channel for submitting SNAP
applications, though online applications represent just over
\1/4\ of these transactions and account for a similar level of
SNAP fraud while mobile channel fraud is growing.
Mobile channel submissions are limited but are likely to grow given
the increased use of mobile transactions in the larger market. Mobile
apps account for the majority of submissions and fraud through this
channel, with 61% of agencies that allow these types of transactions
saying that fraud has increased through them during the past 12 months.
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Survey Q1: Please indicate the percentage of SNAP
applications submitted over the past 12 months across each of
the following channels used by your agency.
Survey Q3: You indicated that approximately [INSERT# FROM
Q1_4] % of your agency's total number of SNAP applications
during the past 12 months were submitted through a mobile
device. Of that [INSERT # FROM Q1_4] %, what is the
distribution of applications through the following:
Survey Q8: Adding to 100%, please indicate the percent of
fraud costs generated through each of the following channels
currently used for SNAP applications (as a percentage of total
annual fraud losses).
Survey Q11: For SNAP applications conducted through a mobile
device or mobile app, what percentage do the following account
for applications fraud?
Survey Q11B: Has fraud with applications through mobile
devices or mobile apps increased, decreased or stayed during
the past 12 months?
Distribution of EBT Card Transactions and Fraud Across Channels
In-person is also the single largest channel used for
Electronic Benefits Transfer (EBT) transactions, though online
and mobile use contributes to EBT card fraud just as much as
in-person use.
Distribution of Electronic Benefits Transfer (EBT) Card Transactions
and Fraud Costs Across Channels in the Past 12 Months
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Survey Q4: Please distribute 100 points to indicate the
approximate percentage that total transactions/purchases during
the past 12 months were completed through the following
methods.
Survey Q9: Adding to 100%, please indicate the distribution
of fraud across the following types of EBT card transactions
during the past 12 months.
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Key Findings 2
Inadvertent household errors (IHEs) and suspicious cases not worked
because of limited resources represent the majority of SNAP fraud.
Malicious bots and the mobile channel are influencing this.
SNAP agencies that experience an above average (>38%)
distribution of fraud losses due to IHEs have a higher cost of
fraud compared to the overall average.
Identity-related fraud represents over half of fraud losses.
The mobile channel continues to be a challenge, with
agencies that have an above average volume of mobile
transactions also reporting a higher number of fraud attacks
per month. They are also more likely to have indicated an
increase in bot attacks during the past 12 months.
Distribution of SNAP Fraud Losses
A majority of SNAP application fraud losses are either
suspicious cases not worked on given lack of resources or
inadvertent household errors (IHEs) that have not been formally
designated as an intentional program violation but could be
provable or reasonably be assumed as fraud.
EBT card-related fraud losses are distributed similarly across
various factors, including card not present, counterfeit or doctored
cards and stolen/card theft. SNAP agencies that experience an above
average (>38%) distribution of fraud losses due to IHEs have a higher
cost of fraud compared to the overall average.
Distribution of SNAP/Electronic Benefits Transfer (EBT) Card Fraud
Losses
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Survey Q5C: Adding to 100%, what percentage do each of the
following account for your total SNAP fraud losses during the
past year?
Survey Q1O: For fraud losses related to EBT transactions/
purchases, please indicate the distribution across the
following types of card fraud.
Identity-related fraud accounts for over half of SNAP fraud
losses. Automated malicious bot attacks have increased.
As shown later, the rise of malicious bot attacks is a driver of
identity verification challenges for roughly half when assessing the
risk of on line and mobile channel applications. Directionally, those
with an above average volume of applications through the mobile channel
are even more likely to indicate an increase in bot attacks from last
year.
Distribution of SNAP Fraud Losses by Activity and Fraud Type
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Survey Q6: Approximately, how much of your fraud losses would
you attribute to each of the following types of fraud?
Survey Q15A: In a typical month, what percent of your
transactions are determined to be malicious automated bot
attacks?
Survey Q15B: How does this compare to the same time last
year? Would you say the percent of monthly automated malicious
bot attacks has:
Median Volume of Fraudulent Applications
SNAP agencies that have a higher, above average volume of
applications submitted through the mobile channel are dealing
with more fraud attacks per month, including those that are
unworked due to limited resources.
Median Volume of Fraudulent Applications per Month
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Survey Q13: In a typical month, approximately how many
fraudulent applications are prevented at the front-end by your
agency?
Survey Q14: In a typical month, approximately how many
fraudulent applications are unworked/not prosecuted at your
agency?
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Key Findings 3
Verifying household composition, identifying malicious bots,
address verification, and identity verification a re among a number of
challenges SNAP agencies have with on line and mobile channel
applications.
Verifying identities is directionally more of a challenge
with mobile channel applications compared to those via online.
Those experiencing increased bot attacks are directionally
more likely to rank verification of household composition as an
on line and mobile channel challenge.
Top Online and Mobile Applications Fraud Challenges
There are many similar fraud detection challenges between
online and mobile channel applications, including identifying
malicious bot attacks. Verifying applicants' identity is
directionally more challenging with mobile channel
applications.
Those experiencing increased bot attacks are directionally more
likely to rank verification of household composition as an on line and
mobile channel challenge.
Top Online and Mobile Channel Applications Fraud Challenges
(% Ranked in Top 3)
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Survey Q12A: Please rank the top 3 challenges related to
fraud when the application process is submitted online through
your agency's website (via a PC).
Survey Q12B: Please rank the top 3 challenges related to
fraud when the application process is submitted through a
mobile device or mobile app.
Top Factors Challenging Customer Identity Verification
Confirming location of applicant, the rise of synthetic
identities, malicious bot attacks and the need for real-time
data are challenges with identity verification.
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* No segment analysis because of small sample size.
Survey Q12C: Please rank the top 3 factors that make customer
identity verification a challenge when SNAP applications are
submitted through your agency website (via a PC).
Survey Q12D: Please rank the top 3 factors that make customer
identity verification a challenge when SNAP applications are
submitted a mobile device or mobile app.
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Key Findings 4
There is limited use of best-practice fraud mitigation methods
involving a multi-layered solution approach and the integration of
fraud solutions with cybersecurity and digital customer experience
operations.
Few agencies have fully implemented the USDA Food and
Nutrition Service (FNS) SNAP Fraud Framework, though over half
have partially done so.
FNS SNAP Fraud Framework, though over half have partially
done so.
The use of fraud mitigation solutions is limited,
particularly those that assess digital identity attributes to
address challenges with on line and mobile channel fraud
detection challenges.
FNS SNAP Fraud Framework and Other Best Practice Approaches
Many agencies are still in the process of implementing the
SNAP Fraud Framework, though agencies are moving towards this.
Half of participating agencies have integrated their
cybersecurity operations with their fraud prevention efforts.
Fewer have fully integrated their digital/customer experience with
fraud prevention efforts as a majority are less than extremely focused
on minimizing friction. Those that are extremely focused on minimizing
customer friction are more likely to have implemented these best
practice approaches.
FNS SNAP Fraud Framework and Other Best Practices Implementation
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Survey Q16A: Has your agency implemented recommendations from
the FNS SNAP Fraud Framework?
Survey Q16B: Does your agency have plans to implement the FNS
SNAP Fraud Framework during the next 12-18 months?
Survey Q18: To what degree has your agency integrated its
cybersecurity operations with its fraud prevention efforts?
Survey Q19: Approximately, what is your agency's typical rate
of churn (i.e., the number of clients that are denied and
reapply within the same eligibility period)?
Survey Q19B: To what degree is your agency focused on
minimizing customer friction when a SNAP application is
completed online (via a PC) or through a mobile device or
mobile app?
Survey Q20: To what degree has your agency integrated its
digital/customer experience operations with its fraud
prevention efforts?
Providers Helping to Detect and Mitigate SNAP Fraud
An Electronic Disqualified Recipient System (eDRS) is
mentioned by many participating agencies as a source of fraud
detection information. The National Accuracy Clearinghouse and
National Directory of New Hires (NDNH) are similarly mentioned.
Fewer have fully integrated their digital/customer experience with
fraud prevention efforts as a majority are less than extremely focused
on minimizing friction. Those that are extremely focused on minimizing
customer friction are more likely to have implemented these best
practice approaches.
Sourcing Information from Providers to Detect and Mitigate SNAP Fraud
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Survey Q17B: Does your agency participate in/source
information from any of the following in order to detect and
mitigate SNAP fraud?
Fraud Prevention Solutions Cost
The amount of budget dedicated to the detection and
mitigation of fraud is 2% on average, with nearly half of
participating agencies expecting this to increase next year by
an average of 6%.
Fraud Prevention Solutions Budget
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Survey Q5D: Approximately, what percent of your annual budget
is dedicated to the detection and prevention of fraud?
Survey Q5F: Do you expect the amount you spend on fraud
prevention solutions to increase, remain the same, or decrease
in the next year?
Fraud Prevention Solution Use
Overall, there is limited use of digital identity solutions
that specifically support fraud detection in the online and
mobile channels.
These types of solutions are designed to assess both individual and
device risks (E-mail Risk Verification, Geolocation, Device ID,
Biometrics and Behavioral Biometrics) and risk of the transaction
(Real-Time Fraud Detection), which provide fast, seamless, and ``behind
the scenes'' fraud detection that reduces customer efforts and delays
while more effectively distinguishing synthetic identities and
malicious bots.
Fraud Prevention Solutions Budget & Use
In other LexisNexis' Risk Solutions True
Cost of FraudTM studies, findings have shown
that organizations which use a multi-layered solutions
approach involving both traditional and digital
identity verification solutions along with integrating
cybersecurity and the digital customer experience with
these solutions experience a lower cost of fraud and
greater effectiveness at detecting and mitigating
fraud.
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Survey Q17: Which solutions does your agency currently use to
detect and mitigate fraud associated with SNAP applications/
eligibility, account login and/or trafficking of benefits?
For more information, please visit https://
risk.lexisnexis.com/GovFraud or call 1-888-216-3544
About LexisNexis Risk Solutions
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is a leader in providing essential information that helps
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trademarks of RELX Inc. Copyright 2022
LexisNexis Risk Solutions.
______
Submitted Website Snapshot by Hon. Scott DesJarlais, a Representative
in Congress from Tennessee
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[https://www.fns.usda.gov/snap/eligibility/citizen/non-citizen-policy]
Supplemental Nutrition Assistance Program (SNAP)
SNAP Policy on Non-Citizen Eligibility
Only U.S. citizens and certain lawfully-present non-citizens may
receive SNAP benefits. Non-citizens who are eligible based on their
immigration status must also meet other SNAP eligibility requirements
such as income and resource limits.
Non-citizens eligible with no waiting period
The following non-citizens are eligible with no waiting period:
Qualified alien children under 18 years old
Refugees admitted under section 207 of INA (includes victims
of severe forms of trafficking)
Victims of Trafficking under the Trafficking Victims
Protection Act of 2000
Asylees under Section 208 of the Immigration and Nationality
Act (INA)
Deportation withheld under 243(h) or 241(b)(3) of INA
Amerasian immigrants under 584 of the Foreign Operations,
Export Financing and Related Programs Appropriations Act
Cuban or Haitian entrants as defined in 501(e) of the
Refugee Education Assistance Act of 1980
Iraqi and Afghan special immigrants under Section 101(a)(27)
of the INA
Certain American Indians born abroad
Members of Hmong or Highland Laotian Tribes, legally living
in the U.S., that helped the U.S. military during the Vietnam
era, and their spouses or surviving spouses and unmarried
dependent children
Elderly individuals born on or before August 22nd, 1931 and
who lawfully resided in the U.S. on August 22nd, 1996
Lawful Permanent Residents in the U.S. who are receiving
government payments for disability or blindness
Lawful Permanent Residents with a military connection
(veteran, on active duty, or spouse or child of a veteran or
active duty service member)
Qualified aliens eligible after a waiting period
A qualified alien is a non-citizen with a certain immigration
status defined under the Personal Responsibility and Work Opportunity
Reconciliation Act (PRWORA).
A qualified alien who does not belong to one of the non-citizen
groups listed above can be considered for SNAP benefits after a waiting
period if the person is:
A Lawful Permanent Resident (LPR) who has earned, or can be
credited with, 40 quarters of work, or
Is an alien in one of the following groups who has been in
qualified status for 5 years:
Paroled for at least 1 year under section 212(d)(5) of
INA
Granted conditional entry under 203(a)(7) of INA in
effect prior to April 1, 1980
Battered spouse, child or parent with a petition
pending under 204(a)(1)(A) or (B) or 244(a)(3) of INA
09/04/2013
______
Submitted Letters by Hon. David Scott, a Representative in Congress
from Georgia
Letter 1
on behalf of hoa pham, deputy secretary, office of income maintenance,
pennsylvania department of human services
June 15, 2023
Committee on Agriculture,
U.S. House of Representatives,
Washington, D.C.
Dear Representatives:
Thank you to the U.S. House Committee on Agriculture for organizing
the June 7, 2023 hearing, ``Innovation, Employment, Integrity, and
Health: Opportunities for Modernization in Title IV.'' On behalf of the
Pennsylvania Department of Human Services, I am submitting this
statement for the record.
The Pennsylvania Department of Human Services (PA DHS) administers
the Supplemental Nutritional Assistance Program (SNAP) for over 1.9
million food-insecure individuals across the Commonwealth. We are proud
of the important work we have done to create vital access to nutrition.
At the same time, we take seriously our responsibility to steward
taxpayer funds, and have in place a robust array of program integrity
measures to ensure public funds are directed to people in need, and
only people in need. First, DHS prioritizes fraud prevention: we
regularly review twelve state and Federal databases to verify ongoing
eligibility for our programs. Second, DHS works closely with the Office
of State Inspector General (OSIG) to target, investigate, and defer
trafficking of SNAP benefits. Indeed, OSIG conducts investigations
specifically into suspected fraud cases most of which are referred
directly from DHS.
PA DHS would like to submit for the record that the testimony
offered by Ms. Dawn Royal, Director and Past President of United
Council on Welfare Fraud during the June 7, 2023 House Committee on
Agriculture's Hearing ``Innovation, Employment, Integrity, and Health:
Opportunities for Modernization in Title IV,'' and specifically the
citation of Commonwealth of Pennsylvania's Inspector General ``told
lawmakers during a recent budget hearing that the agency uncovered a
40% fraud rate among public assistance beneficiaries--primarily in the
Supplemental Nutritional Assistance Program'' is not a direct quote,
and was offered by Ms. Royal outside of the context in which OSIG
described in its testimony. The reality is that 40% of OSIG's field
investigations--most of which occur when DHS refers suspected fraud to
OSIG--result in fraud findings. This is a wholly different statement
than 40% of Pennsylvania's public beneficiaries commit fraud. Ms.
Royal's testimony provided in the hearing is an untrue
mischaracterization that at best, belies PA DHS and OSIG's diligent
work to prevent and deter fraud, and at worst, risks making dangerous
decisions on false grounds to minimize support for vulnerable families.
PA DHS appreciates the opportunity to submit this statement for the
record, and we are happy to provide additional information about our
fraud monitoring and OSIG's investigations as it would be helpful. We
look forward to ongoing discussion to strengthen and modernize the SNAP
program in ways that support food-insecure households.
Sincerely,
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Hoa Pham,
Deputy Secretary, Office of Income Maintenance,
Pennsylvania Department of Human Services.
Letter 2
on behalf of academy of nutrition and dietetics, et al.
June 5, 2023
Hon. Debbie Stabenow, Hon. Glenn Thompson,
Chair, Chairman,
Senate Agriculture, Nutrition, and House Agriculture Committee;
Forestry Committee;
Hon. John Boozman, Hon. David Scott,
Ranking Minority Member, Ranking Member,
Senate Agriculture, Nutrition, and House Agriculture Committee;
Forestry Committee;
Dear Chairwoman Stabenow, Ranking Member Boozman, Chairman
Thompson, and Ranking Member Scott:
As Congress considers the 2023 Farm Bill, the undersigned
organizations write in strong support for maintaining the ability of
individuals to choose the groceries they feel are best for their
families rather than items decided by the government within the
Supplemental Nutrition Assistance Program (SNAP).
SNAP provides households with resources to supplement their overall
food budgets to meet basic needs in a manner that allows them to
address allergy or dietary needs as well as budgetary or medical
challenges.
Dividing SNAP food items into a complex system of variable,
government-administered state-specific lists from among the 40,000
items in a grocery store would be confusing to customers and retailers
and would increase the cost of administering the program for retailers
that accept SNAP benefits. This would particularly burden smaller
retailers in key rural and urban markets.
To create and maintain a government-approved list of foods that
would be SNAP eligible and those that would not be, stores would need
to manage the data and determination of eligibility of the more than
20,000 new food and beverage items introduced each year, requiring them
to program any updates into computer systems to ensure compliance.
Store associates would have to attempt to explain the restrictions to
customers leading to confusion. Managing a SNAP-eligible foods list
would be an unending task that would have to be staffed and maintained,
and communicated to retailers, customers, and manufacturers on a real-
time basis.
Defining foods as ``in'' or ``out'' based on some type of
undetermined government definition of ``healthy'' means picking winners
and losers for families simply trying to feed their families. USDA has
rejected state requests over a number of years to restrict purchases of
types of foods within SNAP because of the additional program complexity
and costs. Additionally, Federal dietary guidance applies to a total
diet, not individual foods.
Furthermore, most customers paying with SNAP benefits are
supplementing those food purchases with another form of tender--cash,
WIC, TANF or debit card. In those instances, any restrictions could be
complicated for store personnel based on the location of the item on
the conveyor belt and which form of payment is accessed first in the
order, simply complicating and slowing the transactions for both
customers and retailers.
The data is clear that SNAP already improves diet-related health
outcomes. If the Federal Government were to put in place a single list
of eligible products or ineligible products, it would be easier for
those rules to change from state-to-state, county-to-county or
Administration-to-Administration--deepening the complexity. Since its
inception as a program, there have been several attempts to impose a
wide variety of restrictions including those on certain dairy foods,
frozen foods, imported foods, meats, seafood, cake mixes, snack foods,
and carbonated or sugar-sweetened beverages.
We should not lose ground on the efficiencies that have been added
to SNAP and the dignity it provides to SNAP recipients. Much of the
stigma that used to be attached to participation in SNAP stemmed from
the visibility participants received when redeeming paper ``food
stamp'' coupons in a supermarket line. Implementation of EBT technology
and online SNAP have enhanced the dignity experienced by SNAP customers
along with the efficiencies of administration. Implementing
restrictions is a step backwards, reducing both the efficiencies of the
program and the dignity of SNAP customers, most of whom are
experiencing a short-term need, and are already struggling to feed
their families.
As you consider the upcoming farm bill, we encourage you to
maintain the long-held policy position that recipients should be
allowed to buy the foods their families need without following a
government-issued list.
Sincerely,
Academy of Nutrition and Dietetics National Confectioners Association
Alliance to End Hunger National Council of Farmer
Cooperatives
American Bakers Association National Grocers Association
American Beverage Association National Milk Producers Federation
American Frozen Food Institute National Pork Producers Council
Can Manufacturers Institute National Retail Federation
Congressional Hunger Center National Turkey Federation
Consumer Brands Association North America Millers' Association
Corn Refiners Association North American Meat Institute
Feeding America Share Our Strength
Food Research & Action Center SNAC International
FMI--the Food Industry Association United Food and Commercial Workers
National Association of Convenience
Stores
CC:
The Honorable Chuck Schumer, Majority Leader, U.S. Senate
The Honorable Mitch McConnell, Minority Leader, U.S. Senate
The Honorable Kevin McCarthy, Speaker, U.S. House
The Honorable Hakeem Jeffries, Minority Leader, U.S. House
______
Submitted News Release by Hon. James P. McGovern, a Representative in
Congress from Massachusetts
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://www.ewg.org/news-insights/news/2023/03/city-slickers-
receiving-federal-farm-subsidies-soared-under-trump]
By Jared Hayes \1\ (EWG), Eve Devens \2\ (EWG)
---------------------------------------------------------------------------
\1\ https://www.ewg.org/news-insights/our-experts/jared-hayes.
\2\ https://www.ewg.org/who-we-are/our-team/eve-devens.
March 9, 2023
`City slickers' receiving Federal farm subsidies soared under Trump
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
From coast to coast, almost 29,000 people in the 50 largest U.S.
cities had received a combined $555 million in farm subsidies as of
2021, as the payments soared during the Trump Administration.
The surge in Department of Agriculture farm subsidy recipients in
these cities was mostly due to payouts from two Trump-era disaster
programs--the Market Facilitation Program and the Coronavirus Food
Assistance Program, an Environmental Working Group Analysis finds.
In Chicago, Los Angeles, New York and other major cities, between
1995 and 2021, exactly 28,831 people got subsidies totaling just under
$555 million. That's a significant increase over the number of
recipients and value of subsidies just a few years ago.
In 2018, an EWG analysis identified \3\ 19,832 ``city slickers''--
urban dwellers--in the nation's largest cities who had received $109
million in farm subsidies as of 2017. Those figures also represented an
increase over previous years--EWG found that 17,836 people living in
the 50 biggest U.S. cities got $63 million in farm subsidies in 2015
and 2016.
---------------------------------------------------------------------------
\3\ https://www.ewg.org/news-insights/news/2018/11/nearly-20000-
city-slickers-received-farm-subsidies-2017.
---------------------------------------------------------------------------
The size of payments to city slickers and the amount of recipients
has increased significantly in the years since 2017. Since then, the
average payment has increased, from just over $3,000 going to just over
16,000 people, up to its highest in 2020, when average payments reached
nearly $22,000 going to more than 20,000 people.
Farm subsidy recipients must be ``actively engaged'' \4\ in
farming. But under current law, urban residents can and do get farm
subsidies even if they do not live or work on a farm.
---------------------------------------------------------------------------
\4\ https://fas.org/sgp/crs/misc/R44656.pdf.
---------------------------------------------------------------------------
The Government Accountability Office in 2018 found \5\ that roughly
\1/4\ of farm subsidy recipients do not contribute personal labor to
farms.
---------------------------------------------------------------------------
\5\ https://www.gao.gov/assets/700/691864.pdf.
---------------------------------------------------------------------------
By contrast, anti-hunger assistance programs are subject to much
stricter income and asset tests,\6\ so people living on low income stay
eligible for Supplemental Nutrition Assistance Program benefits for
only 12 months,\7\ on average.
---------------------------------------------------------------------------
\6\ https://www.cbpp.org/research/food-assistance/a-quick-guide-to-
snap-eligibility-and-benefits.
\7\ https://www.cbpp.org/research/testimony-of-robert-greenstein-
president-center-on-budget-and-policy-priorities-before-1.
---------------------------------------------------------------------------
Rather than closing loopholes \8\ that allow city slickers to
receive farm subsidies, the 2018 Farm Bill created new subsidy
loopholes by allowing a farmer's cousins, nieces and nephews to receive
payments, whether they live or work on a farm or not.
---------------------------------------------------------------------------
\8\ https://www.ewg.org/agmag/2018/05/23andme-farm-bill#.WwGKy1Mvx-
U.
Table: Farm subsidies rose during Trump Administration for people in 50
largest U.S. cities
------------------------------------------------------------------------
City Recipients Total
------------------------------------------------------------------------
Albuquerque, N.M. 468 $5,771,058.69
Arlington, Texas 429 $3,640,827.72
Atlanta 351 $3,147,202.18
Austin, Texas 1,287 $15,537,323.24
Bakersfield, Calif. 474 $61,044,895.85
Baltimore, Md. 43 $1,000,288.84
Boston 25 $837,805.07
Charlotte, N.C. 210 $2,621,918.84
Chicago 526 $6,324,579.32
Colorado Springs, Colo. 589 $6,582,394.43
Columbus, Ohio 321 $4,411,185.39
Dallas 1,318 $17,172,774.93
Denver 975 $10,657,980.86
Detroit 40 $290,485.73
El Paso, Texas 209 $5,984,905.26
Fort Worth, Texas 865 $17,215,142.34
Fresno, Calif. 1,266 $97,680,950.65
Houston 1,992 $21,181,654.30
Indianapolis 731 $9,109,378.78
Jacksonville, Fla. 202 $1,883,606.30
Kansas City, Mo. 1,337 $14,189,115.33
Las Vegas 253 $4,350,693.56
Long Beach, Calif. 76 $1,703,985.70
Los Angeles 223 $9,490,534.54
Louisville, Ky. 467 $3,736,138.60
Memphis, Tenn. 999 $14,482,809.39
Mesa, Ariz. 321 $8,240,067.71
Miami 403 $25,711,196.50
Milwaukee 114 $1,236,818.69
Minneapolis 720 $10,908,305.55
Nashville, Tenn. 440 $3,732,030.10
New York 191 $2,733,103.60
Oakland, Calif. 81 $770,859.82
Oklahoma City 1,267 $13,826,522.53
Omaha, Neb. 1,602 $26,807,446.88
Philadelphia 39 $922,061.15
Phoenix 436 $13,268,156.76
Portland, Ore. 450 $5,127,831.47
Raleigh, N.C. 249 $3,813,354.85
Sacramento, Calif. 227 $7,490,124.81
San Antonio 1,078 $16,900,412.28
San Diego 315 $3,494,921.68
San Francisco 202 $3,498,127.90
San Jose, Calif. 192 $5,321,126.13
Seattle 465 $5,014,325.01
Tucson, Ariz. 430 $6,565,064.45
Tulsa, Okla. 719 $9,312,075.32
Virginia Beach, Va. 173 $4,043,436.94
Washington, D.C. 165 $2,141,955.14
Wichita, Kan. 2,876 $34,052,859.60
---------------------------------------
Total......................... 28,831 $554,981,820.71
------------------------------------------------------------------------
______
Submitted Resolution by Hon. James P. McGovern, a Representative in
Congress from Massachusetts
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[91st Annual Meeting (Columbus, 2023), Adopted Resolutions, Committee
on Children, Health, and Human Services, U.S. Conference of Mayors]
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://legacy.usmayors.org/resolutions/91st--Conference/proposed-
review-list-full-print-committee-
individual.asp?resid=a0F4N00000S4ulBUAR]
2023 Adopted Resolutions
Protect and Strengthen SNAP in the 2023 Farm Bill
1. Whereas, Mayors across the country recognize that farm bill
programs provide essential support to cities, their residents, and
their economies; and
2. Whereas, the farm bill's unique focus on eliminating hunger and
increasing nutrition security builds a stronger society for all of our
residents; and
3. Whereas, the provisions of the farm bill support both urban and
rural communities, and provide critical assistance to those facing the
devastating effects of hunger and poverty; and
4. Whereas, a key part of the farm bill, the Supplemental Nutrition
Assistance Program (SNAP), the largest anti-hunger program in the
United States, provides critical food and nutrition assistance to over
42 million low-income Americans; and
5. Whereas, SNAP has proven to be a crucial tool for mitigating
food hardship and supporting local economies especially during the
pandemic; and
6. Whereas, eligibility for SNAP is limited to households with a
gross income under 130% of the Federal poverty guidelines, which is
about $36,000 for a family of four; and
7. Whereas, 14 million children, or one in five U.S. children
participate in SNAP, and 66% of all SNAP households contain children;
and
8. Whereas, 84% of SNAP families had at least one person working in
the past 12 months, but the average SNAP household had an annual gross
income of only $10,464; and
9. Whereas, SNAP improves food security by increasing access to
nutritious food, and is linked to approximately 25% lower health care
costs; and
10. Whereas, the Thrifty Food Plan, a set of standards reflective
of the real-life costs to maintain a nutritious diet, was revised by
the USDA in 2021 for the first time in 45 years since being introduced
in 1975, increasing the value of SNAP benefits 21%; and
11. Whereas, the Thrifty Food Plan sets the maximum level of
benefits available to SNAP household by family size, and increased the
benefits by $6 a person per day; and
12. Now Therefore Be It Resolved, that The United States Conference
of Mayors calls on Congress to reauthorize the nation's nutrition and
agricultural legislation, the farm bill, before September 30th, 2023;
and
13. Be It Further Resolved, that The United States Conference of
Mayors urges Congress to protect the nutrition portion of the farm bill
that provides critical food assistance to 42 million Americans, more
than half of whom are children and seniors; and
14. Be It Further Resolved, that SNAP helps the most vulnerable in
our cities and rural communities, SNAP participation contributes to
improved nutrition and positive long-term health outcomes; and
15. Be It Further Resolved, the farm bill should modernize the
program and reduce the administrative burden on participants and state
agencies with improved technology that strengthens the integrity and
efficiency of the program; and
16. Be It Further Resolved, that Mayors strongly support all
efforts to increase the safety and security of Electronic Benefit
Cards, including chip technology and consumer protections; and
17. Be It Further Resolved, that Mayors strongly oppose proposals
to increase the work requirements on SNAP recipients, which do little
to improve employability or self-sufficiency, and actually increase
food insecurity; and
18. Be It Further Resolved, the Mayors strongly oppose limiting
SNAP eligibility to only 3 months every 3 years for Able-Bodied Adults
without Dependents; and
19. Be It Further Resolved, the Mayors support maintaining the
option for any state to choose to expand participation through the
adoption of Broad Based Categorical Eligibility for households with an
income at or below 200% of the Federal Poverty Limit, and to streamline
income and resource guidelines with other Federal benefit programs; and
20. Be It Further Resolved, that Mayors support maintaining SNAP-ED
as mandatory funding, and expanding food and nutrition education
programs; and
21. Be It Further Resolved, that Mayors support programs that
promote food security, nutrition, and health by maintaining nutrition
programs funding opportunities like the Gus Schumacher Nutrition
Incentive Program (GusNIP) providing incentives to increase the
purchase of fruits and vegetables by low-income consumers; and
22. Be It Further Resolved, that Mayors strongly support
simplifying and expanding SNAP eligibility for all students who are
enrolled in an institution of higher learning; and
23. Be It Further Resolved, that Mayors support programs that
increase equitable accesses to SNAP in historically underserved
communities, including immigrants and others impacted by the suggested
rule changes to the Public Charge policy; and
24. Be It Further Resolved, the Mayors support full access to SNAP
for Tribal communities, regardless of participation in other nutrition
programs, and the full transition to SNAP for Puerto Rico and other
U.S. Territories; and
25. Be It Further Resolved, that The United States Conference of
Mayors supports the passage of a farm bill that incorporates the
following principles: protect the value of SNAP benefits, maintain and
increase equitable access to SNAP and nutrition education, and
streamline SNAP program administration to increase cost efficiencies
while improving access to benefits, and access to nutritious, fresh,
and local food.
Copyright 2023. The United States
Conference of Mayors. All rights reserved. The United States
Conference of Mayors. 1620 Eye St. NW, 4th Floor--Washington,
D.C. 20006, Phone: (202) 293-7330, Email: info@usmayors.org.
[Sponsored by: Levar Stoney (Richmond, VA); Andy Schor
(Lansing, MI); Satya Rhodes-Conway (Madison, WI); John Giles
(Mesa, AZ); Eric L. Adams (New York, NY); Alix Desulme (North
Miami, FL); Ron Nirenberg (San Antonio, TX); Paige G. Cognetti
(Scranton, PA); Tishaura O. Jones (St. Louis, MO); Martha
Guerrero (West Sacramento, CA)].
______
Submitted Report by Hon. Abigail Davis Spanberger, a Representative in
Congress from Virginia
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
[https://trac.syr.edu/reports/705/]
A Sober Assessment of the Growing U.S. Asylum Backlog
Published Dec. 22, 2022
The latest available data reveal that the number of asylum seekers
waiting for asylum hearings in the U.S. has now reached at least
1,565,966 individuals. About half of this total, or 787,882, are
waiting for hearings before judges in the Immigration Courts housed in
the Department of Justice. The other half, or 778,084 asylum seekers,
are waiting for hearings before United States Citizenship and
Immigration Services (USCIS) asylum officers who are housed in the
Department of Homeland Security.\1\ Many other asylum seekers have been
allowed to enter the United States to go through the asylum process but
have not yet submitted an asylum application.
---------------------------------------------------------------------------
\1\ These asylum backlog figures are of individuals for both EOIR
and USCIS. While EOIR counts each individual as a case, usually USCIS
reports its backlog in terms of applications, rather than the number of
individuals covered by these applications. Thus, USCIS figures used
here of the number of individuals in its asylum backlog differ from
agency published reports (https://www.uscis.gov/sites/default/files/
document/outreach-engagements/Asylum-Quarterly-Engagement-Oct-6-22.pdf)
about its pending asylum applications.
---------------------------------------------------------------------------
These asylum applications--nearly 1.6 million--represent the
largest total number of pending asylum applications on record. Asylum
backlogs are not new (as TRAC has shown many times), since the number
of people requesting the type of protection that asylum provides has
typically exceeded the capacity of government agencies to process
applications quickly and fairly.
Yet in recent years, with political, economic, and environmental
instability in places like Mexico, Venezuela, Haiti, Central America,
Ukraine, and elsewhere, the United States has seen a growth in
migrants' needs that outpace even the growing number of Immigration
Judges and asylum officers added by both Democratic and Republican
Administrations. Even so, 1.6 million applications are a lot of
applications, and a lot of human lives represented by those
applications, many of them children. This growth has contributed to
bureaucratic pressures on government agencies and no doubt contributed
to vigorous (but not always research-informed) public debate about
asylum policies.
In this report, TRAC aims to contribute to the public's
understanding of the current state of the asylum system by providing a
detailed portrait of the nearly 800,000 cases in the asylum backlog
before the Immigration Courts. The report is based on detailed case-by-
case Court records obtained and analyzed by the Transactional Records
Access Clearinghouse (TRAC) at Syracuse University. TRAC has been
making monthly requests under the Freedom of Information Act for data
dumps of these court records for many years and has compiled an
extensive and detailed time series on the Court's growing backlog.
Unfortunately, comparable records are not yet available from USCIS on
its asylum backlog. TRAC looks forward to when similar detailed case-
by-case records become available from that agency so that a more
comprehensive portrait of the total set of asylum seekers before both
agencies can be compiled.\2\
---------------------------------------------------------------------------
\2\ Earlier TRAC reported on outcomes of asylum seekers (https://
trac.syr.edu/immigration/reports/672) in the U.S. combining results
from USCIS and Immigration Court hearings. The report demonstrated the
additional insights gained by examining asylum cases through this more
comprehensive lens.
---------------------------------------------------------------------------
Asylum Seekers Before the Immigration Court
At the end of FY 2012, over 100,000 asylum cases were pending in
the Immigration Court's backlog. A decade later, the backlog had grown
over seven-fold to over 750,000 cases in September at the end of FY
2022. Since then, in just the first 2 months of FY 2023 (October-
November 2022), the asylum backlog jumped by over 30,000 new cases and
now totals 787,882. See Figure 1.
Figure 1. Pending Cases in the Immigration Court Asylum Backlog at the
End of Each Fiscal Year, as of November 2022
Growth in Immigration Court Asylum Backlog
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
* As of Nov. 30, 2022.
TRAC 2022.
As TRAC previously reported,[1] the Biden Administration
has substantially increased the number of asylum cases completed by
Immigration Judges. As a result, even though the backlog continues to
increase, its rate of increase has been slower than the previous
Administration. See Figure 2 and Table 1.
---------------------------------------------------------------------------
\[1]\ https://trac.syr.edu/reports/703/.
---------------------------------------------------------------------------
But the situation may be changing. During October and November 2022
(the first 2 months of FY 2023), the Immigration Court's asylum case
backlog grew by more than the growth during the entire last year of the
Obama Administration in FY 2016. The termination of Title 42, a public
health policy that allows asylum seekers to be expelled without a
hearing, is likely to lead to an increase in the arrival of asylum
seekers at the U.S.-Mexico border. While projections from just 2 months
to an entire fiscal year is highly speculative, if the current pace
continues, the asylum backlog as shown in Figure 2 would jump by a
record-breaking number during FY 2023.
Figure 2. Asylum Cases Added to the Immigration Court Backlog Since FY
2012, as of November 2022
Asylum Cases Added to the Immigration Court Backlog Each Year, FY 2013-
2023
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 1. Immigration Court Asylum Case Backlog
------------------------------------------------------------------------
Fiscal Year End * Number Pending Annual Change
------------------------------------------------------------------------
2012 105,919
2013 108,398 2,479
2014 114,603 6,205
2015 136,145 21,542
2016 163,451 27,306
2017 259,871 96,420
2018 364,990 105,119
2019 489,003 124,013
2020 614,751 125,748
2021 667,229 52,478
2022 756,690 89,461
2023 * 787,882 31,192
------------------------------------------------------------------------
* The fiscal year ends on September 30; latest data for FY 2023 is at
the end of Nov 2022.
These rising case numbers, however, still underestimate the actual
total backlog of asylum seekers in the United States awaiting their
hearings. For asylum seekers who are put into the deportation process,
their deportation case begins before their asylum case begins. The
formal application for asylum is usually filed months after their NTA
is issued and after the case is added to the Immigration Court,
typically due to the time needed to get an attorney and assemble what
can often be quite complex cases. But from a data tracking perspective,
it is only with the filing of an asylum application that a case can be
identified as part of the asylum backlog. If the number of asylum
seekers are rising, the asylum backlog count lags behind the number of
asylum seekers who have entered the Court's workload.
Affirmative versus Defensive Asylum Cases in Immigration Court
There are two main types of asylum applications each decided (at
least at first) by a different Federal agency. Most asylum applications
today are considered defensive applications and filed in response to
the Department of Homeland Security (DHS) initiating removal
proceedings in Immigration Court by filing a Notice to Appear (NTA). An
individual may then claim that they are entitled to asylum as a defense
against removal (i.e., deportation)--although in most cases, the
migrants came to the U.S. for the purpose of seeking asylum in the
first place.\3\
---------------------------------------------------------------------------
\3\ As a matter of practice, asylum seekers who cross the border
unlawfully are currently typically assigned by DHS to the defensive
asylum path in the Immigration Courts, even though their sole purpose
for crossing was to affirmatively request asylum. The Biden
Administration has recently implemented a change in policy that would
provide these asylum seekers with a hearing before USCIS asylum
officers. This so-called Asylum Officer Rule calls for expedited
hearings in these cases and is being phased in currently.
---------------------------------------------------------------------------
Affirmative applications, in contrast, are those which are filed
with USCIS. However, if USCIS denies the affirmative asylum
application, the agency then generally refers the application to the
Immigration Court. Within the Immigration Court context, this is still
considered an affirmative application.\4\ Thus, unsuccessful
affirmative asylum applications can make their way to a second hearing
and decision by an Immigration Judge and become part of the Court's
asylum backlog.
---------------------------------------------------------------------------
\4\ Despite the many nuanced legal differences between affirmative
and defensive asylum, perhaps the most important practical difference
is that affirmative asylum interviews take place in an administrative,
non-adversarial (or at least less adversarial) setting with an asylum
officer and with the option of having an attorney and interpreter
present, but without an opposing counsel. In contrast, defensive asylum
hearings take place in an adversarial setting in Immigration Court with
an Immigration Judge and an opposing attorney from Immigration and
Customs Enforcement.
---------------------------------------------------------------------------
At one time in the past, these referrals from USCIS made up more
than half of the Court's asylum backlog. However, the proportion of new
affirmative asylum cases began steadily declining starting in FY 2007.
At that time, affirmative cases referred from USCIS made up 70 percent
of the Court's new asylum cases. By FY 2017 they had fallen to just 15
percent.\5\
---------------------------------------------------------------------------
\5\ See TRAC's Asylum Filings (https://trac.syr.edu/phptools/
immigration/asyfile/) web query tool.
---------------------------------------------------------------------------
The Court's affirmative asylum backlog reflects these filing
trends. It declined slowly from FY 2012, when TRAC's available data
begins, until 2017 when affirmative cases then began an upward rise.
The number of affirmative asylum cases in the Court's backlog grew
steadily from FY 2017 through FY 2021. See Figure 3.
Starting in FY 2022, affirmative cases again began to decline. The
implementation of the new Asylum Officer Rule, where asylum officers
are given new authority to hear asylum cases in place of Immigration
Judges, may change these trends once again.
In contrast, the sheer number of defensive asylum cases has seen an
unbroken rise. The growth, while slow at first, picked up speed and by
the end of FY 2015 the number of defensive asylum cases in the Court's
backlog surpassed these affirmative referrals from USCIS for the first
time. Numbers have continued a sharp upward trajectory as shown in
Figure 3.
Figure 3. Pending Affirmative and Defensive Cases in the Immigration
Court Asylum Backlog at the End of Each Fiscal Year, as of
November 2022
Immigration Court Asylum Backlog
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
* As of Nov. 30, 2022.
TRAC 2022.
Table 2. Affirmative and Defensive Immigration Court Asylum Case Backlog
------------------------------------------------------------------------
Number of Pending Cases
Fiscal Year End * -----------------------------------------------------
All Affirmative Defensive
------------------------------------------------------------------------
2012 105,919 73,676 32,243
2013 108,398 69,999 38,399
2014 114,603 64,001 50,602
2015 136,145 66,263 69,882
2016 163,451 60,553 102,898
2017 259,871 69,024 190,847
2018 364,990 105,818 259,172
2019 489,003 152,396 336,607
2020 614,751 182,778 431,973
2021 667,229 196,994 470,235
2022 756,690 185,057 571,633
2023 * 787,882 181,144 606,738
------------------------------------------------------------------------
* The fiscal year ends on September 30; latest data for FY 2023 is at
the end of Nov. 2022.
Custody of Asylum Seekers
A major political debate, one which is playing out in part in the
U.S. Federal courts,\6\ continues to rage over whether asylum seekers
should be detained while their cases are waiting to be heard. As a
practical matter, Immigration and Customs Enforcement (ICE) currently
is detaining just 29,000 immigrants.[2] Detaining everyone
in just the current Immigration Court asylum backlog would require more
than 27 times current detention numbers.\7\ If individuals in the USCIS
asylum backlog were also required to be detained, the U.S. would need
54 times its current detention level.
---------------------------------------------------------------------------
\6\ This is one of the legal issues that has been raised
challenging the Biden Administration's attempts to end the MPP program.
On remand from the U.S. Supreme Court, a Texas judge on December 15,
2022 (https://storage.courtlistener.com/recap/gov.uscourts.txnd.346680/
gov.uscourts.txnd.346680.178.0_2.pdf) issued a nationwide injunction
against ending MPP. One aspect of his ruling was a provision in the
Immigration and Nationality Act which provides: ``[If] an alien seeking
admission is not clearly and beyond a doubt entitled to be admitted,
the alien shall be detained for a proceeding . . .''
\[2]\ https://trac.syr.edu/immigration/quickfacts/detention.html.
\7\ Significant components include individuals being processed for
removal without any pending court proceedings or after proceedings have
concluded and removal was ordered, as well as individuals from
countries that refuse to allow the U.S. to deport their citizens back
to their home countries.
---------------------------------------------------------------------------
In fact, ICE now detains only a small portion--around 2,000--of
asylum seekers pending before the Immigration Court. Due in part to the
priority given to quickly scheduling hearings for detained cases, the
component of detained cases has remained generally below two percent.
Indeed, with the onset of COVID and the need to increase spacing for
health reasons among those being held, this proportion has fallen.
Today only 0.3 percent of those in the current asylum backlog are
detained. See Table 3 and Figure 4.
Figure 4. Custody Status of Pending Cases in the Immigration Court
Asylum Backlog at the End of Each Fiscal Year, as of November
2022
Immigration Court Asylum Backlog
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
* As of Nov. 30, 2022.
TRAC 2022.
Table 3. Custody Status of Individuals in Immigration Court Asylum Backlog at the End of Each Fiscal Year
----------------------------------------------------------------------------------------------------------------
Never Detained Percent
Fiscal Year End * All Pending Cases Detained ** Released Detained
----------------------------------------------------------------------------------------------------------------
2014 114,603 1,852 80,701 32,048 1.6%
2015 136,145 2,710 95,536 37,868 2.0%
2016 163,451 3,085 111,750 48,585 1.9%
2017 259,871 3,595 176,870 79,376 1.4%
2018 364,990 3,348 259,338 102,273 0.9%
2019 489,003 4,825 360,169 123,932 1.0%
2020 614,751 7,069 460,311 147,296 1.1%
2021 667,229 1,175 504,100 161,882 0.2%
2022 756,690 2,177 594,542 159,908 0.3%
2023 * 787,882 2,076 624,768 160,975 0.3%
----------------------------------------------------------------------------------------------------------------
* The fiscal year ends on September 30; latest data for FY 2023 is at the end of Nov 2022; data for 2012 and
2013 unavailable. Case totals include a small number where custody unknown.
** Only covers period after case reached Immigration Court.
While most immigrants in the asylum backlog are not detained, a
growing segment are being electronically monitored under ICE's
Alternatives to Detention (ATD) program.[3] For example, one
of the stated conditions [4] of families being assigned to
the Court's Dedicated Docket was assignment first to the ATD program.
Case-by-case internal ICE data obtained and compiled by TRAC reveals
that 26,780 families assigned to the Court's Dedicated Docket have been
monitored by ATD. For some of these, monitoring was discontinued after
a period of time--that is their cases became ``inactive.'' But as of
June 30, 2022, a total of 16,569 families were being actively monitored
while they were awaiting their hearing and decision.
---------------------------------------------------------------------------
\[3]\ https://trac.syr.edu/whatsnew/email.221128.html.
\[4]\ https://www.justice.gov/opa/pr/dhs-and-doj-announce-
dedicated-docket-process-more-efficient-immigration-hearings.
---------------------------------------------------------------------------
Given that only one member of a family and not all family members
likely are being monitored, this implies that virtually all of the
110,000 asylum seekers assigned to the Dedicated Docket [4]
are (or were) subject to ATD monitoring.
---------------------------------------------------------------------------
\[5]\ https://trac.syr.edu/reports/704/.
---------------------------------------------------------------------------
No solid figures exist as to how many in the current asylum
backlog, beyond those in the DD program, are being monitored by ATD.
However, for recent asylum applicants it is likely that their numbers
have been increasing along with the rapid growth in the ATD
program.[6]
---------------------------------------------------------------------------
\[6]\ https://trac.syr.edu/immigration/quickfacts/detention.html.
---------------------------------------------------------------------------
Representation
Without representation, many asylum seekers are unable to complete
the paperwork needed to file a formal asylum application. Hence, these
individuals never end up part of the asylum backlog and they never
receive a hearing before an Immigration Judge on their asylum claims.
Nonetheless, some unrepresented immigrants do manage to file an
application. In cases decided in FY 2022, less than one out of ten
asylum seekers were unrepresented.[7]
---------------------------------------------------------------------------
\[7]\ https://trac.syr.edu/reports/703/.
---------------------------------------------------------------------------
However, within the current asylum backlog, one in five (21%) are
recorded as unrepresented. This ratio appears to greatly overstate the
actual percentage who are unrepresented, and this could be because of
how and when representation status is recorded in the Immigration
Court's files. A record of attorney representation only occurs when an
attorney files an E-28 form [8] with the Court. Some
attorneys may register their appearance when the Court actually
schedules the case for hearing rather than when filing the asylum
application earlier. Thus, it is possible that a large number of asylum
seekers are recorded as unrepresented in the Court's files even when
the asylum application was actually prepared and submitted with the
assistance of an attorney.
---------------------------------------------------------------------------
\[8]\ https://www.justice.gov/eoir/file/639746/download.
---------------------------------------------------------------------------
In fact, 42 percent of those who filed their applications during
the last 2 months (October-November 2022) are currently shown as
unrepresented in the Court's records. Many of these asylum applications
in all likelihood had actually been prepared by an attorney. Indeed,
the longer ago the application was filed, the more show up as being
represented. This would be the pattern we would expect if delays
frequently occur before the E-28 form is filed. See Figure 5 and Table
4.
Figure 5. Current Representation Status of Immigration Court Pending
Cases by When Asylum Application Was Filed
More in Asylum Backlog Find Attorneys the Longer They Have Waited
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
* As of Nov. 30, 2022.
TRAC 2022.
Table 4. Immigration Court Pending Cases by Current Representation and Fiscal Year Asylum Application Filed
----------------------------------------------------------------------------------------------------------------
Not Represented Represented
Fiscal Year Total --------------------------------------------------------------------------
Number Percent Number Percent
----------------------------------------------------------------------------------------------------------------
2012 3,416 223 7% 3,193 93%
2013 4,718 426 9% 4,292 91%
2014 6,873 623 9% 6,250 91%
2015 12,637 1,078 9% 11,559 91%
2016 20,136 1,598 8% 18,538 92%
2017 52,634 4,346 8% 48,288 92%
2018 79,611 7,308 9% 72,303 91%
2019 113,957 14,027 12% 99,930 88%
2020 133,018 26,308 20% 106,710 80%
2021 73,393 16,104 22% 57,289 78%
2022 222,949 68,989 31% 153,960 69%
2023 * 57,733 24,333 42% 33,400 58%
----------------------------------------------------------------------------------------------------------------
* The fiscal year ends on September 30; latest data for FY 2023 is at the end of Nov 2022.
Gender and Age
There is a fairly even split between male and female asylum
seekers. About three out of ten are children under 18 years of age. The
children who make up the Court's asylum backlog almost all enter as
part of a family group. This is because for most unaccompanied children
their asylum applications are filed with the USCIS under special
provisions of the law and not with the Immigration Court.
While the gender of a significant number (24%) is not recorded,
where gender is known 48 percent are females and 52 percent are males.
Children between the ages of 0-11 are fairly evenly divided between
males and females. However, 61 percent of those between 12 and 17 years
of age are male. Adults from 18 years on up are again fairly evenly
divided between males and females. Forty-nine percent of all adults are
females. A slightly higher percentage of 51% of young adults--those
between 18 and 24 years of age--are females. See Table 5.
Table 5. Age and Gender of Individuals in Immigration Court Asylum Backlog, November 30, 2022
----------------------------------------------------------------------------------------------------------------
Percent Female
Age * Total Female Male Unknown **
----------------------------------------------------------------------------------------------------------------
All 787,882 284,168 311,862 191,852 48%
0-4 55,246 24,472 25,634 5,140 49%
5-11 73,526 32,282 34,761 6,483 48%
12-17 72,092 25,357 40,050 6,685 39%
18-24 77,658 37,096 35,019 5,543 51%
25-34 153,848 72,317 71,390 10,141 50%
35-44 112,937 49,825 57,224 5,888 47%
45-59 46,634 20,199 24,305 2,130 45%
60+ 5,687 2,846 2,606 235 52%
----------------------------------------------------------------------------------------------------------------
* All includes 190,254 individuals where age was unknown.
** Percent of persons whose gender was known.
Asylum Seekers by Nationality
Asylum seekers recorded as speaking 418 different languages from
219 different countries plus those who are stateless or from countries
that no longer exist are in the current Immigration Court's asylum
backlog.\8\ But some countries dominate the asylum roles. Indeed,
nearly six out of every ten (59%) come from just five countries.
Guatemala has the largest number of asylum seekers (111,184) in the
current Court's backlog. This is followed by Honduras with 101,195 and
El Salvador with 97,260. Together, these three countries from the so-
called Northern Triangle comprise 39 percent of the Court's asylum
backlog. Mexico with 82,837 asylum seekers and Venezuela with 71,991
complete the list of the top five.
---------------------------------------------------------------------------
\8\ A complete country-by-country and language breakdown of asylum
seekers in the Court's backlog is available from TRAC's Asylum Backlog
(https://trac.syr.edu/phptools/immigration/asylumbl/) web query tool.
---------------------------------------------------------------------------
Beyond these five dominant players, there are an additional nine
countries with at least 10,000 asylum seekers in the current backlog.
Driving the increasing asylum backlog have been the increasing numbers
not just from Venezuela which is in the top five, but from Cuba and
Brazil who are part of this longer nationality list. See Figure 6 and
Table 6 for figures on the changing composition of asylum seekers from
these fourteen countries.
As shown in Figure 6, in the midst of the growing backlog, four
nationalities have actually seen net declines. During the last fourteen
months since the end of FY 2021, declines have occurred in the number
of asylum seekers from El Salvador, followed by Mexicans, Guatemalans,
and asylum seekers from China.
The shifting composition of nationalities reflects not just the
volume of individuals arriving at our borders seeking asylum, but the
country's policies and practices of which nationalities are being
allowed to actually enter the U.S. and seek asylum. Asylum seekers from
the Northern Triangle countries and Mexico were usually immediately
turned away under Title 42 and not allowed to enter and seek asylum.
The Biden Administration has created some exceptions to this policy,
exceptions that have been structured by nationality. For instance, as
TRAC previously found, Ukrainian nationals were allowed to enter
[9] the country at ports of entry through a special program
designed in response to the war in Ukraine. Later, using that same
model, the Biden Administration allowed 24,000 Venezuelan nationals to
enter [10] the United States for humanitarian reasons. The
Biden Administration has also allowed particularly vulnerable asylum
seekers to enter the country through an exemption process, a process
that has also benefitted Haitians, though at much smaller numbers and
fewer ports of entry.
---------------------------------------------------------------------------
\[9]\ https://www.dhs.gov/ukraine.
\[10]\ https://www.dhs.gov/news/2022/10/12/dhs-announces-new-
migration-enforcement-process-venezuelans.
---------------------------------------------------------------------------
Figure 6. Top Nationalities in Immigration Court Asylum Backlog, Fiscal
Year 2021 to November 30, 2022
Change in Immigration Court Asylum Backlog Since FY 2021
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 6. Top Nationalities in Immigration Court Asylum Backlog, Fiscal
Year 2021 to November 30, 2022
------------------------------------------------------------------------
Pending Cases at End of:
Nationality * ------------------------------------------- Change Since
FY 2021 FY 2022 Nov. 2022 FY 2021
------------------------------------------------------------------------
Guatemala 119,247 113,074 111,184 ^8,063
Honduras 96,345 101,958 101,195 4,850
El Salvador 112,759 100,202 97,260 ^15,499
Mexico 94,357 84,595 82,837 ^11,520
Venezuela 30,398 60,410 71,991 41,593
Cuba 12,913 35,333 46,456 33,543
India 28,827 32,479 34,230 5,403
Ecuador 19,796 30,455 30,208 10,412
Brazil 12,092 26,128 28,810 16,718
Nicaragua 8,867 20,087 23,748 14,881
China 27,403 24,036 23,508 ^3,895
Haiti 9,493 16,163 16,837 7,344
Colombia 6,253 12,127 14,785 8,532
Russia 4,647 9,042 10,830 6,183
------------------------------------------------------------------------
* Countries with 10,000 or more pending asylum cases.
Asylum Backlogs Differ by Court Location
Historically, Immigration Courts in California and New York have
had the largest asylum caseloads and decided the largest numbers of
asylum claims. Over the years, these two states have experienced more
asylum cases filed than any other locales. During FY 2022, for example,
Immigration Courts in these two states accounted for just under half
(48%) of all asylum cases decided on their merits.[11]
---------------------------------------------------------------------------
\[11]\ https://trac.syr.edu/phptools/immigration/asylum/.
---------------------------------------------------------------------------
But the location of asylum backlogs has been undergoing change as
the location of new asylum filings has shifted. Florida has seen
explosive growth in asylum filings. So has Massachusetts. These growth
patterns have been driven in large part by shifts in the nationality
groups seeking asylum in this country. Asylum seekers from Venezuela
and from Cuba--two nationalities that have seen the largest rise--have
tended to head to Florida. Most Brazilians have sought to start their
new life in Massachusetts. And largely as a result, the asylum backlogs
in these two states have experienced the largest growth. See Figure 7
and Table 7.
Asylum seekers from Mexico, Guatemala and El Salvador have been
declining as we saw in Figure 6. California has been the largest
destination for these groups, and we have seen a decline in the asylum
backlog in California courts. Chinese asylum seekers have been another
nationality with declining numbers. New York has historically been
their primary destination, and in part as a result, as shown in Figure
7 courts in New York have experienced little increase in their backlog.
Backlogs, of course, are largely driven by having an inadequate
number of judges available relative to the volume of asylum cases
needing to be heard. So it is not surprising that as asylum seekers
from different countries locate in different regions of the country and
their relative numbers change, asylum backlogs will also reflect these
changes.
Figure 7. Top States With Immigration Court Asylum Backlogs, Fiscal
Year 2021 to November 30, 2022
Change in Immigration Court Asylum Backlog Since FY 2021
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 7. States With Immigration Court Asylum Backlogs, Fiscal Year 2021
to November 30, 2022
------------------------------------------------------------------------
Pending Cases at End of:
State * -------------------------------------------- Change Since
FY 2021 FY 2022 Nov. 2022 FY 2021
------------------------------------------------------------------------
Total 667,229 756,690 787,882 120,653
California 133,463 127,046 127,804 ^5,659
Florida 66,640 102,657 114,409 47,769
New York 110,434 111,041 110,669 235
Texas 66,967 76,718 80,587 13,620
New Jersey 37,604 45,087 46,830 9,226
Massachusetts 28,869 42,198 44,802 15,933
Virginia 37,087 35,383 35,769 ^1,318
Illinois 27,066 33,716 35,746 8,680
Maryland 20,670 22,382 21,703 1,033
Pennsylvania 14,709 17,867 18,607 3,898
Tennessee 9,781 14,934 15,882 6,101
Georgia 10,011 13,446 14,636 4,625
Louisiana 11,741 13,908 14,346 2,605
North Carolina 8,240 12,390 13,585 5,345
Nebraska 9,917 11,740 12,315 2,398
Washington 10,765 11,554 11,659 894
Ohio 7,757 8,033 8,771 1,014
Minnesota 7,904 8,468 8,702 798
Missouri 7,106 8,064 8,333 1,227
Colorado 8,040 7,010 7,309 ^731
Arizona 6,807 6,718 7,166 359
Connecticut 4,872 5,958 6,132 1,260
Oregon 6,122 6,212 6,132 10
Nevada 4,386 5,340 5,751 1,365
Utah 2,150 4,549 5,719 3,569
Michigan 3,225 3,896 4,115 890
New Mexico 93 57 98 5
Hawaii 120 71 67 ^53
------------------------------------------------------------------------
* Not all states have Immigration Courts based in them.
Wait Times and How Quickly Do Cases Get Heard?
There is no simple answer to the question of how long asylum
seekers have to wait before they can have their claims heard and
decided. Under Biden Administration initiatives, including the
Dedicated Docket and the Asylum Officer Rule initiatives, some newly
arriving asylum seekers are being moved to the head of the line and
their hearings expedited. Indeed, criticism is growing that cases are
being heard too quickly before the asylum seeker has a chance to locate
an attorney, or for the attorney to prepare adequate support for the
asylum claims.
For most others who are not detained, especially those who entered
the backlog queue a while ago, the wait can be very long. An estimate
of the average backlog wait times from when the case was filed in the
Immigration Court to when their asylum hearing will be scheduled and
their claims heard is currently 1,572 days, or 4.3 years.
Average wait times also vary by the location of the Court.
Currently the Immigration Court based in Omaha, Nebraska has the
longest wait time averaging 2,168 days. This is followed by the Court
based in Newark, New Jersey where the average wait time is also over
2,000 days. See Figure 8. Table 8 contains a complete state-by-state
listing of Immigration Court average wait times as of the end of
November 2022.
But even these estimates are subject to a number of additional
important caveats examined in the next section.
Figure 8. Estimated Days From Court Filing Until Asylum Hearing
Scheduled for Immigration Court Pending Asylum Cases, by State
Estimated Wait Times for Pending Asylum Cases
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 8. Estimated Days From Court Filing Until Asylum Hearing Scheduled
for Immigration Court Pending Asylum Cases, by State
------------------------------------------------------------------------
Ave. Wait Time (days)
Pending Asylum -----------------------------------
State * Cases (excludes
All Cases detained)
------------------------------------------------------------------------
All 787,882 1,572 1,576
Arizona 7,166 1,200 1,210
California 127,804 1,691 1,693
Colorado 7,309 1,239 1,251
Connecticut 6,132 1,315 1,315
Florida 114,409 1,376 1,377
Georgia 14,636 1,416 1,427
Hawaii 67 355 355
Illinois 35,746 1,399 1,400
Louisiana 14,346 1,896 1,933
Maryland 21,703 1,554 1,558
Massachusetts 44,802 1,521 1,522
Michigan 4,115 1,295 1,298
Minnesota 8,702 1,505 1,507
Missouri 8,333 1,985 1,985
Nebraska 12,315 2,168 2,169
Nevada 5,751 1,212 1,217
New Jersey 46,830 2,023 2,024
New Mexico 98 103 **
New York 110,669 1,393 1,398
North Carolina 13,585 1,705 1,705
Ohio 8,771 997 1,007
Oregon 6,132 1,799 1,799
Pennsylvania 18,607 1,537 1,537
Tennessee 15,882 1,454 1,454
Texas 80,587 1,557 1,566
Utah 5,719 780 780
Virginia 35,769 1,941 1,943
Washington 11,659 1,391 1,409
------------------------------------------------------------------------
* Not all states have Immigration Courts based in them.
** All pending cases involved detained individuals.
Serious Challenges to Estimating Average Wait Times
Estimating even average wait times poses serious challenges, so
that any reported values resemble more ``guesstimates'' rather than
something having a solid basis. The first problem is that even if TRAC
had information for when each asylum seeker's hearing was scheduled
(which we do not) hearings schedules often change. Hearings are not
infrequently canceled because of the unavailability of the judge, or
for other reasons. When hearings are scheduled further into the future,
the odds that circumstances may arise requiring rescheduling also
increases. A hearing can, of course, be postponed or advanced depending
upon the needs and practices of that Court, or in some circumstances
the needs of the parties.
The second challenge is that, in fact, the majority of hearings
that will be needed are not yet even scheduled. Only about four out of
ten (43%) individuals in the current asylum backlog have an actual
individual proceeding scheduled to hear the evidence on the merits of
that asylum seeker's claims.
The remaining majority of cases fall into one of two groups. For 35
percent of those waiting in the asylum backlog, the hearing scheduled
is still at the ``master calendar'' [12] stage. For these
initial hearings, a group of individuals are summoned to appear
together where they are advised of their rights and procedures, the
charges and factual allegations contained in the Notice to Appear (NTA)
are explained, and cases are sorted as to what comes next. More than
one of these master calendar hearings may occur if an individual needs
more time to find an attorney to represent them, or an attorney once
found, needs time to secure documents and obtain testimony to support
the asylum application. Only after these master calendar hearings come
to a conclusion, is an individual hearing scheduled on the asylum
seeker's claims. Only one hearing is set at any point in time. Thus,
for those scheduled for master calendar hearings, no information is
available on just when the actual merits hearing eventually may occur.
---------------------------------------------------------------------------
\[12]\ https://www.justice.gov/eoir/reference-materials/ic/chapter-
4/15.
---------------------------------------------------------------------------
Figure 9. Scheduled Hearings in Pending Immigration Court Asylum Cases,
as of November 30, 2022
Scheduled Hearing in Pending Asylum Cases
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 9. Scheduled Hearings in Pending Immigration Court Asylum Cases
------------------------------------------------------------------------
Pending Asylum Cases at End of: *
Scheduled ---------------------------------------------------------
Hearing FY 2020 FY 2021 FY 2022 Nov. 2022
------------------------------------------------------------------------
All 614,751 667,229 756,690 787,882
Individual 350,167 349,720 337,877 339,469
Master (Group) 188,282 205,178 260,648 274,583
None Scheduled 76,302 112,331 158,165 173,830
Percent None 12% 17% 21% 22%
------------------------------------------------------------------------
* The fiscal year ends on September 30; latest data for FY 2023 is at
the end of Nov. 2022.
On the remaining 22 percent of asylum seekers waiting in the
backlog, no hearing of either kind is currently scheduled. These don't
tend to be newly arriving cases. Those without any scheduled hearing
have already been waiting an average of 1,092 days, or 3 years.
The percentage of asylum seekers with no next hearing scheduled has
grown. For example, during FY 2020 only 12 percent of cases in the
backlog had no hearing scheduled as compared with 22 percent now.
However, this percentage varies a great deal. Some courts with
thousands in their backlog such as Michigan, Missouri, North Carolina,
and Pennsylvania have hearings scheduled on 95 percent or more of their
cases. In contrast, courts in New York, Virginia and Washington State
had respectively 43%, 46%, and 62% of asylum cases without any
currently scheduled hearings. For these, it appears they are avoiding
scheduling hearings too far in advance. See Figure 10 and Table 10.
Average wait times are of necessity based upon the recorded times
of the next scheduled hearing for each case. Where many cases do not
even have their asylum hearing scheduled, clearly the resulting
estimate is a mere ``guesstimate'' at best.
Figure 10. No Scheduled Hearing by State in Current Pending Immigration
Court Asylum Cases
No Scheduled Hearing in Pending Asylum Cases
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
TRAC 2022.
Table 10. Scheduled Hearings by State in Current Pending Immigration
Court Asylum Cases, November 2022
------------------------------------------------------------------------
Scheduled Hearing
State * -------------------------------------------- Percent None
Individual Master None
------------------------------------------------------------------------
All 338,165 274,023 173,618 22%
Arizona 4,933 1,169 990 14%
California 87,309 28,329 12,037 9%
Colorado 1,598 1,876 3,795 52%
Connecticut 2,107 2,930 1,094 18%
Florida 22,774 62,640 28,876 25%
Georgia 2,049 7,044 5,452 37%
Hawaii 46 15 6 9%
Illinois 8,249 15,555 11,904 33%
Louisiana 8,625 4,011 1,420 10%
Maryland 10,022 10,252 1,354 6%
Massachusetts 18,210 22,015 4,556 10%
Michigan 3,217 687 197 5%
Minnesota 3,692 1,266 3,721 43%
Missouri 4,391 3,823 117 1%
Nebraska 3,446 7,065 1,794 15%
Nevada 2,701 1,131 1,899 33%
New Jersey 22,491 18,137 6,170 13%
New Mexico 0 0 0 --
New York 48,100 15,203 47,128 43%
North Carolina 5,180 7,950 454 3%
Ohio 5,781 1,313 1,562 18%
Oregon 4,179 1,254 699 11%
Pennsylvania 10,934 6,793 880 5%
Tennessee 5,207 5,417 5,254 33%
Texas 34,041 38,170 7,895 10%
Utah 3,702 1,305 712 12%
Virginia 11,816 7,454 16,455 46%
Washington 3,247 1,157 7,182 62%
------------------------------------------------------------------------
* Not all states have Immigration Courts based in them.
Conclusion
In this report, TRAC examined half of the total (but likely
undercounted) 1.6 million pending asylum applications, specifically the
nearly 800,000 asylum applications in the Immigration Court backlog.
Regardless of the many reasons for the growth in outstanding asylum
applications, this large and growing number of applications has real
consequences for the U.S. immigration system, for public and political
discussion about asylum policy, and certainly for asylum seekers
themselves. By taking a closer data-driven look at who is affected,
where asylum cases are being heard, and how the Courts are processing
these cases, TRAC hopes to provide a sober foundation for public
understanding and debate.
TRAC is a nonpartisan, nonprofit data research center
affiliated with the Newhouse School of Public Communications
[13] and the Whitman School of
Management,[14] both at Syracuse
University.[15] For more information, to subscribe,
or to donate, contact trac@syr.edu or call 315-443-3563.
---------------------------------------------------------------------------
\[13]\ http://newhouse.syr.edu/.
\[14]\ http://whitman.syr.edu/.
\[15]\ http://www.syr.edu/.
---------------------------------------------------------------------------
______
Submitted Statute Excerpt by Hon. Abigail Davis Spanberger, a
Representative in Congress from Virginia
[https://www.govinfo.gov/content/pkg/USCODE-2021-title7/pdf/USCODE-
2021-title7-chap51-sec2015.pdf]
United States Code, Title 7_Agriculture, Chapter 51_Supplemental
Nutrition Assistance Program, Sec. 2015_Eligibility
disqualifications
* * * * *
(e) Students
No individual who is a member of a household otherwise eligible to
participate in the supplemental nutrition assistance program under this
section shall be eligible to participate in the supplemental nutrition
assistance program as a member of that or any other household if the
individual is enrolled at least half-time in an institution of higher
education, unless the individual--
(1) is under age 18 or is age 50 or older;
(2) is not physically or mentally fit;
(3) is assigned to or placed in an institution of higher
education through or in compliance with the requirements of--
(A) a program under title I of the Workforce
Innovation and Opportunity Act [29 U.S.C. 3111 et
seq.];
(B) an employment and training program under this
section, subject to the condition that the course or
program of study--
(i) is part of a program of career and
technical education (as defined in section 2302
of title 20) that may be completed in not more
than 4 years at an institution of higher
education (as defined in section 1002 of title
20); or
(ii) is limited to remedial courses, basic
adult education, literacy, or English as a
second language;
(C) a program under section 2296 of title 19; or
(D) another program for the purpose of employment and
training operated by a state or local government, as
determined to be appropriate by the Secretary;
(4) is employed a minimum of 20 hours per week or
participating in a state or federally financed work study
program during the regular school year;
(5) is--
(A) a parent with responsibility for the care of a
dependent child under age 6; or
(B) a parent with responsibility for the care of a
dependent child above the age of 5 and under the age of
12 for whom adequate child care is not available to
enable the individual to attend class and satisfy the
requirements of paragraph (4);
(6) is receiving benefits under a state program
funded under part A of title IV of the Social Security
Act (42 U.S.C. 601 et seq.);
(7) is so enrolled as a result of participation in
the work incentive program under title IV of the Social
Security Act [42 U.S.C. 601 et seq.] or its successor
programs; or
(8) is enrolled full-time in an institution of higher
education, as determined by the institution, and is a
single parent with responsibility for the care of a
dependent child under age 12.
* * * * *
(o) Work requirement
(1) ``Work program'' defined
In this subsection, the term ``work program'' means--
(A) a program under title I of the Workforce
Innovation and Opportunity Act [29 U.S.C. 3111 et
seq.];
(B) a program under section 2296 of title 19;
(C) a program of employment and training operated or
supervised by a state or political subdivision of a
state that meets standards approved by the Governor of
the state, including a program under subsection (d)(4),
other than a supervised job search program or job
search training program;
(D) a program of employment and training for veterans
operated by the Department of Labor or the Department
of Veterans Affairs, and approved by the Secretary; and
(E) a workforce partnership under subsection
(d)(4)(N).
(2) Work requirement
Subject to the other provisions of this subsection, no
individual shall be eligible to participate in the supplemental
nutrition assistance program as a member of any household if,
during the preceding 36 month period, the individual received
supplemental nutrition assistance program benefits for not less
than 3 months (consecutive or otherwise) during which the
individual did not--
(A) work 20 hours or more per week, averaged monthly;
(B) participate in and comply with the requirements
of a work program for 20 hours or more per week, as
determined by the state agency;
(C) participate in and comply with the requirements
of a program under section 2029 of this title or a
comparable program established by a state or political
subdivision of a state; or
(D) receive benefits pursuant to paragraph (3), (4),
(5), or (6).
(3) Exception
Paragraph (2) shall not apply to an individual if the
individual is--
(A) under 18 or over 50 years of age;
(B) medically certified as physically or mentally
unfit for employment;
(C) a parent or other member of a household with
responsibility for a dependent child;
(D) otherwise exempt under subsection (d)(2); or
(E) a pregnant woman.
(4) Waiver
(A) In general
On the request of a state agency and with the support
of the chief executive officer of the state, the
Secretary may waive the applicability of paragraph (2)
to any group of individuals in the state if the
Secretary makes a determination that the area in which
the individuals reside--
(i) has an unemployment rate of over 10
percent; or
(ii) does not have a sufficient number of
jobs to provide employment for the individuals.
(B) Report
The Secretary shall report the basis for a waiver
under subparagraph (A) to the Committee on Agriculture
of the House of Representatives and the Committee on
Agriculture, Nutrition, and Forestry of the Senate.
(5) Subsequent eligibility
(A) Regaining eligibility
An individual denied eligibility under paragraph (2)
shall regain eligibility to participate in the
supplemental nutrition assistance program if, during a
30 day period, the individual--
(i) works 80 or more hours;
(ii) participates in and complies with the
requirements of a work program for 80 or more
hours, as determined by a state agency; or
(iii) participates in and complies with the
requirements of a program under section 2029 of
this title or a comparable program established
by a state or political subdivision of a state.
(B) Maintaining eligibility
An individual who regains eligibility under
subparagraph (A) shall remain eligible as long as the
individual meets the requirements of subparagraph (A),
(B), or (C) of paragraph (2).
(C) Loss of employment
(i) In general
An individual who regained eligibility under
subparagraph (A) and who no longer meets the
requirements of subparagraph (A), (B), or (C)
of paragraph (2) shall remain eligible for a
consecutive 3 month period, beginning on the
date the individual first notifies the state
agency that the individual no longer meets the
requirements of subparagraph (A), (B), or (C)
of paragraph (2).
(ii) Limitation
An individual shall not receive any benefits
pursuant to clause (i) for more than a single 3
month period in any 36 month period.
(6) Exemptions
(A) Definitions
In this paragraph:
(i) Caseload
The term ``caseload'' means
the average monthly number of
individuals receiving
supplemental nutrition
assistance program benefits
during the 12 month period
ending the preceding June 30.
(ii) Covered individual
The term ``covered
individual'' means a member of
a household that receives
supplemental nutrition
assistance program benefits, or
an individual denied
eligibility for supplemental
nutrition assistance program
benefits solely due to
paragraph (2), who--
(I) is not eligible
for an exception under
paragraph (3);
(II) does not reside
in an area covered by a
waiver granted under
paragraph (4);
(III) is not
complying with
subparagraph (A), (B),
or (C) of paragraph
(2);
(IV) is not receiving
supplemental nutrition
assistance program
benefits during the 3
months of eligibility
provided under
paragraph (2); and
(V) is not receiving
supplemental nutrition
assistance program
benefits under
paragraph (5).
(B) General rule
Subject to subparagraphs (C) through (H), a
state agency may provide an exemption from the
requirements of paragraph (2) for covered
individuals.
(C) Fiscal year 1998
Subject to subparagraphs (F) and (H), for
fiscal year 1998, a state agency may provide a
number of exemptions such that the average
monthly number of the exemptions in effect
during the fiscal year does not exceed 15
percent of the number of covered individuals in
the state in fiscal year 1998, as estimated by
the Secretary, based on the survey conducted to
carry out section 2025(c) of this title for
fiscal year 1996 and such other factors as the
Secretary considers appropriate due to the
timing and limitations of the survey.
(D) Fiscal years 1999 through 2019
Subject to subparagraphs (F) through (H), for
fiscal year 1999 and each subsequent fiscal
year through fiscal year 2019, a state agency
may provide a number of exemptions such that
the average monthly number of the exemptions in
effect during the fiscal year does not exceed
15 percent of the number of covered individuals
in the state, as estimated by the Secretary
under subparagraph (C), adjusted by the
Secretary to reflect changes in the state's
caseload and the Secretary's estimate of
changes in the proportion of members of
households that receive supplemental nutrition
assistance program benefits covered by waivers
granted under paragraph (4).
(E) Subsequent fiscal years
Subject to subparagraphs (F) through (H), for
Fiscal Year 2020 and each subsequent fiscal
year, a state agency may provide a number of
exemptions such that the average monthly number
of exemptions in effect during the fiscal year
does not exceed 12 percent of the number of
covered individuals in the state, as estimated
by the Secretary under subparagraph (C),
adjusted by the Secretary to reflect changes in
the state's caseload and the Secretary's
estimate of changes in the proportion of
members of households that receive supplemental
nutrition assistance program benefits covered
by waivers granted under paragraph (4).
(F) Caseload adjustments
The Secretary shall adjust the number of
individuals estimated for a state under
subparagraph (C), (D), or (E) during a fiscal
year if the number of members of households
that receive supplemental nutrition assistance
program benefits in the state varies from the
state's caseload by more than 10 percent, as
determined by the Secretary.
(G) Exemption adjustments
During fiscal year 1999 and each subsequent
fiscal year, the Secretary shall increase or
decrease the number of individuals who may be
granted an exemption by a state agency under
this paragraph to the extent that the average
monthly number of exemptions in effect in the
state for the preceding fiscal year under this
paragraph is lesser or greater than the average
monthly number of exemptions estimated for the
state agency for such preceding fiscal year
under this paragraph.
(H) Reporting requirement
A state agency shall submit such reports to
the Secretary as the Secretary determines are
necessary to ensure compliance with this
paragraph.
(7) Other program rules
Nothing in this subsection shall make an individual
eligible for benefits under this chapter if the
individual is not otherwise eligible for benefits under
the other provisions of this chapter.
* * * * *
(Pub. L. 88-525, 6, Aug. 31, 1964, 78 Stat. 704; Pub. L. 94-339, 3,
July 5, 1976, 90 Stat. 800; Pub. L. 95-113, title XIII, 1301, Sept.
29, 1977, 91 Stat. 964; Pub. L. 96-58, 5, 9, Aug. 14, 1979, 93 Stat.
391, 392; Pub. L. 96-249, title I, 109, 110, 114, 115, 139, 140, May
26, 1980, 94 Stat. 359, 361, 370; Pub. L. 97-35, title I, 108(b),
(c), 109, 112, Aug. 13, 1981, 95 Stat. 361, 362; Pub. L. 97-98, title
XIII, 1310, 1311, Dec. 22, 1981, 95 Stat. 1284, 1285; Pub. L. 97-
253, title I, 145(e), 154-161, 189(b)(1), 190(a), (b), Sept. 8,
1982, 96 Stat. 774, 777, 778, 787; Pub. L. 98-204, 5, 6, Dec. 2,
1983, 97 Stat. 1385, 1386; Pub. L. 99-198, title XV, 1513(b), 1516,
1517(a), Dec. 23, 1985, 99 Stat. 1571-1573; Pub. L. 100-435, title II,
202(b), (c), title IV, 404(a)-(d), Sept. 19, 1988, 102 Stat. 1656,
1665-1667; Pub. L. 101-624, title XVII, 1723-1726(b)(1), (c), (d),
1727, Nov. 28, 1990, 104 Stat. 3786-3788; Pub. L. 102-237, title IX,
907, 941(3), Dec. 13, 1991, 105 Stat. 1885, 1892; Pub. L. 103-66, title
XIII, 13922(b), 13942, Aug. 10, 1993, 107 Stat. 675, 677; Pub. L.
103-225, title I, 101(a), 104(b), Mar. 25, 1994, 108 Stat. 106, 107;
Pub. L. 103-296, title I, 108(f)(1), (2), Aug. 15, 1994, 108 Stat.
1486, 1487; Pub. L. 104-193, title I, 109(b), title VIII, 813-
815(a), 816, 817(a), 818, 819(a), (c), 820-824(a), Aug. 22, 1996, 110
Stat. 2169, 2314, 2315, 2318, 2320-2323; Pub. L. 104-208, div. C, title
III, 308(g)(7)(D)(i), Sept. 30, 1996, 110 Stat. 3009-624; Pub. L.
105-33, title I, 1001, Aug. 5, 1997, 111 Stat. 251; Pub. L. 105-277,
div. A, 101(f) [title VIII, 405(d)(2)(B), (f)(2)(B)], Oct. 21,
1998, 112 Stat. 2681-337, 2681-418, 2681-429; Pub. L. 107-171, title
IV, 4109, 4115(b)(2), 4121(c), May 13, 2002, 116 Stat. 309, 315,
324; Pub. L. 110-234, title IV, 4001(b), 4002(a)(3), 4105, 4108,
4112, 4115(b)(4), 4131, May 22, 2008, 122 Stat. 1092, 1101, 1102, 1106,
1114; Pub. L. 110-246, 4(a), title IV, 4001(b), 4002(a)(3), 4105,
4108, 4112, 4115(b)(4), 4131, June 18, 2008, 122 Stat. 1664, 1853,
1862-1864, 1868, 1875; Pub. L. 113-79, title IV, 4007, 4008(a),
4009(a), 4030(d), Feb. 7, 2014, 128 Stat. 787-789, 814; Pub. L. 113-
128, title V, 512(l)(2), July 22, 2014, 128 Stat. 1709; Pub. L. 115-
334, title IV, 4005(a), (b), Dec. 20, 2018, 132 Stat. 4627-4631.)
Editorial Notes
References in Text
The Social Security Act, referred to in subsecs. (c)(3), (5),
(d)(1)(D)(iii)(II), (2), (4)(I)(i)(II), (K), (e)(6), (7), (g), (i)(2),
(l)(1), (3), (m), and (n)(2)(B), is act Aug. 14, 1935, ch. 531, 49
Stat. 620, which is classified generally to chapter 7 ( 301 et seq.)
of Title 42, The Public Health and Welfare. Part D of title IV of the
Act is classified generally to part D ( 651 et seq.) of subchapter IV
of chapter 7 of Title 42. Title IV-A of the Act (part A of title IV) is
classified generally to part A ( 601 et seq.) of subchapter IV of
chapter 7 of Title 42. Titles IV and XVI of the Social Security Act are
classified generally to subchapters IV ( 601 et seq.) and XVI ( 1381
et seq.), respectively, of chapter 7 of Title 42. For complete
classification of this Act to the Code, see section 1305 of Title 42
and Tables.
The Fair Labor Standards Act of 1938, referred to in subsec.
(d)(2), (4)(B)(ii)(I)(cc), (F)(i), is act June 25, 1938, ch. 676, 52
Stat. 1060, which is classified generally to chapter 8 ( 201 et seq.)
of Title 29, Labor. For complete classification of this Act to the
Code, see section 201 of Title 29 and Tables.
The Workforce Innovation and Opportunity Act, referred to in
subsecs. (d)(4)(M), (e)(3)(A), and (o)(1)(A), is Pub. L. 113-128, July
22, 2014, 128 Stat. 1425. Title I of the Act is classified generally to
subchapter I ( 3111 et seq.) of chapter 32 of Title 29, Labor. For
complete classification of this Act to the Code, see Short Title note
set out under section 3101 of Title 29 and Tables.
Section 212(a) of Pub. L. 93-66, referred to in subsec. (g), is
Pub. L. 93-66, title II, 212(a), July 9, 1973, 87 Stat. 155, which is
set out as a note under section 1382 of Title 42, The Public Health and
Welfare.
Codification
Pub. L. 110-234 and Pub. L. 110-246 made identical amendments to
this section. The amendments by Pub. L. 110-234 were repealed by
section 4(a) of Pub. L. 110-246.
* * * * *
Statutory Notes and Related Subsidiaries
Effective Date of 2014 Amendments
Amendment by Pub. L. 113-128 effective on the first day of the
first full program year after July 22, 2014 (July 1, 2015), see section
506 of Pub. L. 113-128, set out as an Effective Date note under section
3101 of Title 29, Labor.
Amendment by section 4008(a) of Pub. L. 113-79 inapplicable to a
conviction if the conviction is for conduct occurring on or before Feb.
7, 2014, see section 4008(c) of Pub. L. 113-79, set out as a note under
section 2014 of this title.
Effective Date of 2008 Amendment
Amendment of this section and repeal of Pub. L. 110-234 by Pub. L.
110-246 effective May 22, 2008, the date of enactment of Pub. L. 110-
234, except as otherwise provided, see section 4 of Pub. L. 110-246,
set out as an Effective Date note under section 8701 of this title.
Amendment by sections 4001(b), 4002(a)(3), 4105, 4108, 4112,
4115(b)(4), and 4131 of Pub. L. 110-246 effective Oct. 1, 2008, see
section 4407 of Pub. L. 110-246, set out as a note under section 1161
of Title 2, The Congress.
Effective Date of 2002 Amendment
Pub. L. 107-171, title IV, 4121(e), May 13, 2002, 116 Stat. 324,
provided that: ``The amendments made by this section [amending this
section and section 2025 of this title] take effect on the date of
enactment of this Act [May 13, 2002].''
Amendment by sections 4109, 4115(b)(2) of Pub. L. 107-171 effective
Oct. 1, 2002, except as otherwise provided, see section 4405 of Pub. L.
107-171, set out as an Effective Date note under section 1161 of Title
2, The Congress.
Effective Date of 1998 Amendment
Amendment by section 101(f) [title VIII, 405(d)(2)(B)] of Pub. L.
105-277 effective Oct. 21, 1998, and amendment by section 101(f) [title
VIII, 405(f)(2)(B)] of Pub. L. 105-277 effective July 1, 2000, see
section 101(f) [title VIII, 405(g)(1), (2)(B)] of Pub. L. 105-277,
set out as a note under section 3502 of Title 5, Government
Organization and Employees.
Effective Date of 1997 Amendment
Pub. L. 105-33, title I, 1005(b), Aug. 5, 1997, 111 Stat. 257,
provided that: ``The amendments made by sections 1001 and 1002
[amending this section and section 2025 of this title] take effect on
October 1, 1997, without regard to whether regulations have been
promulgated to implement the amendments made by such sections.''
Effective Date of 1996 Amendments
Amendment by Pub. L. 104-208 effective, with certain transitional
provisions, on the first day of the first month beginning more than 180
days after Sept. 30, 1996, see section 309 of Pub. L. 104-208, set out
as a note under section 1101 of Title 8, Aliens and Nationality.
Amendment by section 109(b) of Pub. L. 104-193 effective July 1,
1997, with transition rules relating to state options to accelerate
such date, rules relating to claims, actions, and proceedings commenced
before such date, rules relating to closing out of accounts for
terminated or substantially modified programs and continuance in office
of Assistant Secretary for Family Support, and provisions relating to
termination of entitlement under AFDC program, see section 116 of Pub.
L. 104-193, as amended, set out as an Effective Date note under section
601 of Title 42, The Public Health and Welfare.
Effective Date of 1994 Amendment
Amendment by Pub. L. 103-296 effective Mar. 31, 1995, see section
110(a) of Pub. L. 103-296, set out as a note under section 401 of Title
42, The Public Health and Welfare.
Effective Date of 1993 Amendment
Amendment by Pub. L. 103-66 effective, and to be implemented
beginning on, Sept. 1, 1994, see section 13971(b)(4) of Pub. L. 103-66,
set out as a note under section 2025 of this title.
Effective Date of 1991 Amendment
Amendment by section 908 [probably should be 907] of Pub. L. 102-
237 effective Sept. 30, 1991, and amendment by section 941(3) of Pub.
L. 102-237 effective and to be implemented no later than Feb. 1, 1992,
see section 1101(d)(1), (3) of Pub. L. 102-237, set out as a note under
section 1421 of this title.
Effective Date of 1990 Amendment
Amendment by Pub. L. 101-624 effective and implemented first day of
month beginning 120 days after publication of implementing regulations
to be promulgated not later than Oct. 1, 1991, see section 1781(a) of
Pub. L. 101-624, set out as a note under section 2012 of this title.
Effective Date of 1988 Amendment
Amendment by sections 202(b), (c) and 404(a)(2)-(4), (b), (d) of
Pub. L. 100-435 to be effective and implemented on Oct. 1, 1988, and
amendment by section 404(a)(1), (c) of Pub. L. 100-435 to be effective
and implemented on July 1, 1989, except that amendment by section 404
of Pub. L. 100-435 to become effective and implemented on Oct. 1, 1989,
if final order is issued under section 902(b) of Title 2, The Congress,
for fiscal year 1989 making reductions and sequestrations specified in
the report required under section 901(a)(3)(A) of Title 2, see section
701(a), (b)(4), (c)(2) of Pub. L. 100-435, set out as a note under
section 2012 of this title.
Effective Date of 1982 Amendment
Amendment by Pub. L. 97-253 effective Sept. 8, 1982, see section
193(a) of Pub. L. 97-253, set out as a note under section 2012 of this
title.
Effective Date of 1981 Amendments
Amendment by Pub. L. 97-35, except section 108(c) of Pub. L. 97-35
(which amended this section), effective on earlier of Sept. 8, 1982, or
date such amendment became effective pursuant to section 117 of Pub. L.
97-35, set out as a note under section 2012 of this title, see section
192(a) of Pub. L. 97-253, set out as a note under section 2012 of this
title.
Amendment by Pub. L. 97-98 effective on earlier of Sept. 8, 1982,
or date such amendment became effective pursuant to section 1338 of
Pub. L. 97-98, set out as a note under section 2012 of this title. See
section 192(b) of Pub. L. 97-253, set out as a note under section 2012
of this title.
Amendment by Pub. L. 97-98 effective upon such date as Secretary of
Agriculture may prescribe, taking into account need for orderly
implementation, see section 1338 of Pub. L. 97-98, set out as a note
under section 2012 of this title.
Amendments by Pub. L. 97-35, except for amendment made by section
108(c) of Pub. L. 97-35, effective and implemented upon such dates as
Secretary of Agriculture may prescribe, taking into account need for
orderly implementation, see section 117 of Pub. L. 97-35, set out as a
note under section 2012 of this title.
Pub. L. 97-35, title I, 108(c), Aug. 13, 1981, 95 Stat. 361,
provided that the amendment made by section 108(c) is effective Oct. 1,
1983.
Effective Date of 1979 Amendment
Secretary of Agriculture to issue final regulations implementing
the amendment of subsec. (b) of this section by Pub. L. 96-58 within
150 days after Aug. 14, 1979, see section 10(b) of Pub. L. 96-58, set
out as a note under section 2012 of this title.
Effective Date of 1977 Amendment
Pub. L. 95-113, title XIII, 1301, Sept. 29, 1977, 91 Stat. 958,
provided that the amendment made by section 1301 is effective Oct. 1,
1977.
Regulations
Pub. L. 105-33, title I, 1005(a), Aug. 5, 1997, 111 Stat. 257,
provided that: ``Not later than 1 year after the date of enactment of
this Act [Aug. 5, 1997], the Secretary of Agriculture shall promulgate
such regulations as are necessary to implement the amendments made by
this title [amending this section and sections 2020 and 2025 of this
title].''
Abolition of Immigration and Naturalization Service and Transfer of
Functions
For abolition of Immigration and Naturalization Service, transfer
of functions, and treatment of related references, see note set out
under section 1551 of Title 8, Aliens and Nationality.
Transition Provision For Work Requirement
Pub. L. 104-193, title VIII, 824(b), Aug. 22, 1996, 110 Stat.
2324, provided that: ``The term `preceding 36 month period' in section
6(o) of the Food Stamp Act of 1977 [now the Food and Nutrition Act of
2008, 7 U.S.C. 2015(o)], as added by subsection (a), does not include,
with respect to a state, any period before the earlier of--
``(1) the date the state notifies recipients of food stamp
benefits of the application of section 6(o); or
``(2) the date that is 3 months after the date of enactment
of this Act [Aug. 22, 1996].''
Exemption From Monthly Reporting Systems for Households Residing on
Indian Reservations
Pub. L. 102-237, title IX, 908(a)(2), Dec. 13, 1991, 105 Stat.
1886, as amended by Pub. L. 103-11, 1, Apr. 1, 1993, 107 Stat. 41;
Pub. L. 103-205, 1, Dec. 17, 1993, 107 Stat. 2418, provided that no
state agency be required to exempt households residing on Indian
reservations from food stamp program monthly reporting systems until
Mar. 15, 1994, and directed Secretary of Agriculture to issue final
regulations requiring exemption of households residing on Indian
reservations from food stamp program monthly reporting systems no later
than Dec. 1, 1992, prior to repeal by Pub. L. 103-225, title I,
104(a), Mar. 25, 1994, 108 Stat. 107.
Mandatory Monthly Reporting--Retrospective Budgeting for Food Stamp
Program; Prohibition
Pub. L. 98-107, 101(b), Oct. 1, 1983, 97 Stat. 735, provided in
part that no part of any of the funds appropriated or otherwise made
available by Pub. L. 98-107 or any other Act could be used to implement
mandatory monthly reporting--retrospective budgeting for the food stamp
program during the first 3 months of the fiscal year ending Sept. 30,
1984.
______
Submitted Letter by Hon. Andrea Salinas, a Representative in Congress
from Oregon; on Behalf of Marc Egan, Director of Government
Relations, National Education Association
June 6, 2023
Committee on Agriculture
U.S. House of Representatives
Washington, D.C.
Dear Representative:
On behalf of the three million members of the National Education
Association, who teach and support nearly 50 million students in public
schools across America, thank you for holding this hearing,
``Innovation, Employment, Integrity, and Health: Opportunities for
Modernization in Title IV.'' We submit these comments for the record.
NEA members are teachers and education support professionals in
14,000 communities nationwide. They know firsthand that hungry students
cannot focus on learning. The Fiscal Responsibility Act of 2023
included additional work requirements that place 750,000 adults at risk
of losing food assistance,\1\ * according to the Center on Budget and
Policy Priorities (CBPP), placing their families at higher risk for
food insecurity as well. Therefore, it is essential that you take steps
to protect and strengthen SNAP, our nation's largest Federal food
assistance program and the first line of defense against childhood
hunger.
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\1\ https://www.cbpp.org/research/food-assistance/debt-ceiling-
agreements-snap-changes-would-increase-hunger-and-poverty-for.
* Editor's note: references annotated with are retained in
Committee file.
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Approximately \2/3\ of SNAP households include a child, an older
person, or an individual with a disability, according to the CBPP.\2\
Millions of working-age SNAP recipients already work; in fact, a
Government Accountability Office analysis of employment data from 11
states found that 70 percent of adult SNAP recipients hold at least one
job.\3\ SNAP serves a crucial role in the lives of these workers, who
sometimes hold multiple, low-paying jobs with unreliable hours and
scant benefits, or no benefits at all. For them, any unexpected
expense, health crisis, or other unforeseen emergency could force a
choice between buying groceries, or paying a bill. Among these SNAP
recipients are approximately ten percent of education support
professionals and approximately 16 percent of the school food
professionals who serve students healthy meals.
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\2\ https://www.cbpp.org/research/food-assistance/the-supplemental-
nutrition-assistance-program-snap.
\3\ https://www.gao.gov/products/gao-21-45.
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By providing monthly benefits to eligible low-income individuals,
SNAP is crucial in reducing hunger, malnutrition, and poverty,
enhancing families' overall sense of security, and improving child and
adult health. Children living in SNAP households are automatically
certified to receive free school meals, which help fight hunger and
promote student health and lead to greater student growth, development,
and learning. But, given the expiration of both USDA waivers for free
school meals for all students and emergency SNAP allotments, many more
children and families are experiencing hunger. Congress must make SNAP
benefits more robust so that children can have healthy meals not only
at home, but also at school.
NEA members urge you to enhance Title IV and SNAP benefits by:
Ensuring that benefits reflect the economic hardships families and
individuals face. SNAP benefits should be based on the Low-Cost Food
Plan, which better aligns with household costs, permits greater food
variety, and supports healthier diets than the Thrifty Food Plan (TFP).
TFP is based on premises that do not hold true for all families and
individuals, such as the assumption that everyone has access to full-
service grocery stores that carry fresh produce and whole-grain
products. The TFP also assumes healthier foods are affordable and
similarly priced across the country, but these foods are often more
costly than foods that are higher in sodium and sugar, and therefore
less healthy.
Removing the shelter deduction cap. The current shelter deduction
cap of $623 is a fraction of the actual $2,000 cost of median rent.
This arbitrary cap does not capture the rising cost of housing and
penalizes families and individuals for our current runaway housing
market. Removing the shelter deduction cap will allow families to spend
more on food.
Eliminating the time limits on SNAP eligibility. People who are
unemployed and underemployed should not be penalized for being unable
to document sufficient hours of work each month.
Enacting a standard medical-expense deduction. A standard medical
deduction of at least $140 would increase recipients' monthly benefit.
Currently, only 12 percent of households that are eligible for the
medical deduction claim it, despite the high out-of-pocket medical
costs many SNAP families face.
Extending SNAP benefits to college students. Recent studies
estimate that as many as 50 percent of college students \4\ have
experienced food insecurity, and fewer than 40 percent earn a
certificate or degree within 6 years. The rising cost of education,
housing, and food is not only pushing more college students into food
insecurity; it makes finishing college, achieving self-sufficiency, and
entering the workforce more difficult and time-consuming. Removing the
overly burdensome work-study and minimum employment requirements on
college students would put them on equal footing with other eligible
SNAP participants.
---------------------------------------------------------------------------
\4\ https://drexel.edu/hunger-free-center/news-events/voices-blog/
2021/December/college-student-food-insecurity/.
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Strengthening food and nutrition security in our most vulnerable
communities. One in four Native Americans experiences food insecurity
compared to one in nine Americans overall, according to Feeding
America.\5\ Currently, individuals who receive benefits from the Food
Distribution Program on Indian Reservations (FDPIR) cannot also use
SNAP benefits within the same month. Congress can address this gap in
services by:
---------------------------------------------------------------------------
\5\ https://hungerandhealth.feedingamerica.org/2020/11/november-
native-american-heritage-month/.
---------------------------------------------------------------------------
Permitting the simultaneous use of SNAP and FDPIR;
Allowing Tribal nations to administer SNAP by granting the
USDA Food and Nutrition Service (FNS) the requisite 638
authority; and
Increasing funding to expand FDPIR's self-determination
projects.
Granting SNAP assistance to parents with prior drug-related felony
convictions. Parents with drug-related felony convictions have paid
their dues; they should not be ``doubly punished'' by being denied
assistance to get back on their feet. Meeting their basic food needs
with SNAP benefits will help position them--and their children--for
success.
Students' opportunity to thrive should not be limited because they
lack the nourishment needed for healthy development. All students
deserve the support to learn, and having access to robust SNAP benefits
will create the conditions for academic engagement and achievement. We
urge you to support a strong nutrition Title IV in farm bill
negotiations.
Sincerely,
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Marc Egan,
Director of Government Relations,
National Education Association.
______
Submitted Statement by Hon. Donald G. Davis, a Representative in
Congress from North Carolina; on Behalf of MAZON: A Jewish Response to
Hunger
Chairman Thompson, Ranking Member Scott, and distinguished Members
of the Committee, thank you for the opportunity to share this statement
for the record from MAZON: A Jewish Response to Hunger for this hearing
on opportunities for modernization in Title IV in the farm bill.
Inspired by Jewish values and ideals, MAZON: A Jewish Response to
Hunger is a national organization fighting to end hunger among people
of all faiths and backgrounds in the United States and Israel. MAZON is
not just a Jewish response to hunger, it is the the Jewish response to
hunger. In Jewish tradition--and across all faith traditions--there is
a fundamental value of taking care of the most vulnerable among us. In
Leviticus, we are commanded to leave the corners of our fields and the
gleanings of our harvest and vineyards for the poor and the stranger.
This commandment is a clear expression of our collective responsibility
for each other. It reminds us that we are not to judge those who are
poor, nor should we assume to know the circumstances of their lives.
Its wisdom respects the dignity of every human being, all created in
the image of God, by empowering individuals to decide what they need,
not presuming to know what is best for them.
When he founded MAZON in 1985, Leibel Fein (of blessed memory)
posed challenging questions that drew upon Jewish texts and traditions
and envisioned the possibilities for the Federal Government in
fulfilling our collective responsibility to address hunger in the
United States:
``Can we move from the language of kindness to the language
of justice? Can we move from philanthropic sensibility to
political commitment? MAZON's work is a step. It moves us from
indifference to charity, but the question is whether we can
then be moved from charity to advocacy, thence to policy?''
Leibel's questions remain relevant and urgent today as Congress
takes up the farm bill reauthorization. We will never ``food bank'' our
way to an end of hunger. Responsibility for addressing this far-
reaching and preventable crisis cannot be abdicated by the Federal
Government and passed off to a charitable sector that does not have the
capacity nor the purview to achieve the necessary systemic changes and
fully address the problem. Regardless of a person's circumstance, no
one deserves to be hungry.
This hearing takes place in the wake of proposals by some in
Congress to make cuts to the Supplemental Nutrition Assistance Program
(SNAP) and other safety net programs in the name of deficit reduction
and as a bargaining chip to raise the debt ceiling and avoid
catastrophic default. There is a stark moral deficit in such
ideologically driven proposals made on the backs of low-income
Americans. Our country and our leaders should be held accountable for
how they treat those in need. It is reprehensible that some politicians
and pundits continue to perpetuate harmful stereotypes and place blame
on the very people who face challenges.
We must prioritize policy solutions that reduce hunger and hardship
rather than policies that exacerbate stigma and struggle. The farm bill
reauthorization presents a meaningful and timely opportunity to
reinforce our collective values and strengthen our nation through fair,
just, and compassionate policies that fulfill our collective
responsibility for each other and provide life-saving support for those
who struggle with hunger. This is rightly the role and responsibility
of the Federal Government.
The rhetoric employed in recent weeks by some in Congress and the
media has been incredibly problematic and harmful. Speaking about a
safety net program as a work program, repeating myths and
misinformation about SNAP participants, and calling into question who
is ``deserving'' of assistance to justify restrictions and cuts leads
to dangerous consequences. It hurts veterans and others by reinforcing
negative stereotypes and adding to the stigma that limits SNAP
participation. It hurts older adults on fixed incomes. It hurts
families living paycheck to paycheck. It hurts women and people of
color, who disproportionately endure hunger and poverty. And this mean-
spirited and ideological agenda hurts us all--because food insecurity
is devastating at a personal level and costly for our society.
MAZON was disappointed both in the process and policy outcome of
the debt ceiling negotiations, and we remain deeply concerned about how
these will impact the farm bill. Regarding process, raising the debt
ceiling should be separate from important decisions around budget and
appropriations. It was irresponsible to bring our country dangerously
close to the brink of default and make policy changes that should have
been considered in a different context.
We have observed the carefully guarded policy of the House
Committee on Agriculture over the years not to ``reopen the farm bill''
out of cycle for legislative changes and matters within its scope. The
Committee violated this principle by allowing statutory changes to SNAP
to be included in the debt ceiling negotiations. This choice sets a
concerning precedent and raises questions about the integrity and
future actions of the Committee. Does this signal that the Committee
will now be amendable to other policy changes that would normally be
taken up in the farm bill cycle? Will this include changes to
agriculture policy and other matters under its jurisdiction, or does
this only apply to programs that serve low-income Americans? Will the
Committee now be open to considering legislation outside of the farm
bill to make improvements to nutrition assistance programs and help
remove barriers to accessing them?
In terms of the policy outcome, MAZON was disappointed that the
Committee went along with the choice to cut Federal spending on the
backs of those facing food insecurity in America. SNAP is our nation's
most powerful anti-hunger program. SNAP is not a work program. It never
was and it never should be. It is a safety net for those who fall on
hard times and need help to put food on the table. We know historically
from repeated studies that work requirements simply do not work. The
overwhelming body of peer-reviewed research and respected analysis
reflect that work requirements do not lead to long-term increases in
earnings or employment outcomes. Instead, they reduce program
participation by design, which increases hunger and hardship. This
devastating impact will be felt more acutely by certain populations,
such as older women who will now be subjected to arbitrary time limits
for SNAP while they continue to face great challenges in securing
stable employment.
Not only will expanding work requirements for SNAP be ineffective,
but this policy change signifies a historic and stunning shift in the
definition of SNAP as a social safety net program--from decades of a
values-based perspective to one that bends to political winds. This
change, and the misguided rhetoric wielded to justify it, will
exacerbate the stigma around SNAP that contributes to under-
participation by millions of Americans who need the assistance. The
judgments, stereotypes, and misinformed policy priorities for SNAP in
the debt ceiling negotiations will create real harm for low-income
Americans who struggle with food insecurity and for the farm bill
process.
The bottom line is that SNAP and other Federal nutrition assistance
programs ensure that people can feed themselves and their families with
dignity and choice, rather than forcing them to seek emergency
assistance from an overwhelmed charitable sector. This Committee should
use its power and leadership to ensure that Federal programs work as
effectively as possible and reach all those in need of assistance to
reduce food insecurity in this country. We fear that recent actions may
result in the opposite, with more people falling through the cracks and
struggling with food insecurity.
MAZON is committed to shining a spotlight on issues and populations
where the government and larger organizations have yet to turn their
focus. Blanket solutions cannot meet the needs of every community, and
our special focus has been pivotal to help remove the unique policy
barriers that overlooked and challenged communities face in accessing
adequate, nutritious food. These populations include currently serving
military families, veterans, Indigenous communities, the people of
Puerto Rico and the territories, single mothers, and LGBTQ+ older
adults.
The farm bill is one of the most transformational pieces of
legislation that Congress regularly reauthorizes. In addition to
authorizing SNAP and other Federal nutrition programs that serve tens
of millions of Americans each year, the farm bill presents a unique
opportunity to advance long-overdue policy solutions to the food
security challenges of many of the aforementioned populations.
In addition to the statement above that re-centers consideration of
Title IV programs outside of the misguided, disingenuous, and cruel
campaign to expand so-called work requirements to Federal safety net
programs, MAZON is resharing our farm bill priorities below, which were
submitted in our statement for a previous Committee hearing.
Hunger in the United States, the wealthiest country in the world,
is far too pervasive. And sadly, this crisis is preventable, but for
the lack of the political will to realize the true sense of collective
responsibility that is interwoven in the fabric of the American
experiment. MAZON's farm bill priorities cover the needs of millions of
Americans who routinely fall through the cracks and face barriers to
receiving the vital food assistance to which they are entitled. Rather
than imposing new barriers and restricting access to critical nutrition
assistance programs, this Committee must take seriously its central
responsibility to ensure that those who struggle with food insecurity
have access to affordable, nutritious food.
The farm bill must protect against hunger by strengthening and
improving SNAP and other essential Federal nutrition assistance
programs and remove barriers for struggling individuals and families;
and increase access to affordable, nutritious food for vulnerable
populations to support good nutrition and health. We urge you to
reflect on our shared values, explore effective policy solutions, and
act with compassion and humanity toward those among us experiencing
hardship who need assistance. As such, the next farm bill must:
Protect and Strengthen the Supplemental Nutrition Assistance Program
(SNAP) and Other Federal Nutrition Programs
Maintain the update to the Thrifty Food Plan benefit and
explore transition to more adequate benefit levels, including
shifting to the Low-Cost Food Plan as the basis for SNAP
benefit allotments.
Prevent the reinstatement of harmful and ineffective work
requirements/time limits for able-bodied adults without
dependents or ``ABAWDs.''
Streamline client access and eligibility standards for
individuals seeking to benefit from The Emergency Food
Assistance Program (TEFAP).
Promote Food Security Among Active-Duty Military Families
Eliminate the barrier to SNAP for low-income military
families by excluding the Basic Allowance for Housing as
counted income.
Address Food Insecurity Among Veterans
Lower the VA disability rating required for veterans for
SNAP purposes.
Support veteran access to affordable healthy foods and
expand veteran farmers market nutrition programs and produce
prescription programs through the Gus Schumacher Nutrition
Incentive Program (GusNIP).
Establish a veteran food security grant program open to
states, Tribal Nations, and territories, and formalize the
establishment of the Office of Veteran Food Security at the VA.
Establish a transition assistance pilot program to support
low-income military families as they separate from the Service
and begin the transition back to civilian life.
Empower Tribal Food Sovereignty and Address Food Insecurity in Indian
Country
Empower Tribal Nations to self-administer SNAP, the Food
Distribution Program on Indian Reservations (FDPIR), and The
Emergency Food Assistance Program (TEFAP) using Section 638
authority, if they choose to do so.
Eliminate the prohibition on dual participation in SNAP and
FDPIR.
Allow Tribal eligibility for SNAP-Ed funds.
Enable more Native-produced and culturally appropriate foods
to be purchased as part of FDPIR, CSFP, and TEFAP, and CSFP and
expand the traditional foods pilot program under FDPIR.
Improve Equity and Food Security for the People of Puerto Rico
Authorize plan for transition for Puerto Rico from the
block-granted and inadequate Nutrition Assistance Program (NAP)
back into SNAP.
Remove Barriers to SNAP for Single Mothers
Eliminate the state option in effect in several states that
requires SNAP applicants to comply with state child support
authorities.
Improve Nutrition Support for LGBTQ+ Older Adults
Expand SNAP access and participation for LGBTQ+ older adults
through targeted outreach and develop innovative approaches to
strengthen nutritional support for this community, including an
understanding of and response to the nutritional needs of those
aging with HIV or AIDS.
MAZON urges the House Committee on Agriculture to strengthen and
improve Federal nutrition programs in the 2023 Farm Bill process and
ensure that in this land of plenty, there is plenty for all to eat. We
stand ready with expertise, passion, and resolve to work together to
achieve a farm bill that endeavors to end hunger in the United States.
______
Submitted Letter by Hon. Salud O. Carbajal, a Representative in
Congress from California; on Behalf of Stephanie Johnson, RDN, Vice
President, Government Relations, National Grocers Association
June 7, 2023
The National Grocers Association (NGA) writes to provide a
statement for the record for the U.S. House Committee on Agriculture
hearing titled, ``Innovation, Employment, Integrity, and Health:
Opportunities for Modernization in Title IV.'' We request that all
Members publicly oppose any efforts that increase the administrative
costs and retailer burden of SNAP by restricting what families can
purchase in the grocery store.
NGA is the national trade association representing retail and
wholesale grocers that comprise the independent sector of the food
retail and distribution industry. An independent community grocer is a
privately owned or controlled food retail company operating in a
variety of formats. Independents are the true ``entrepreneurs'' of the
grocery industry and dedicated to their customers, associates, and
communities. Much of NGA's membership is comprised of family-owned and
family-operated small businesses. Nearly \1/2\ of NGA's members are
single-store operators, and another \1/4\ operate less than five
stores. Independent retail and wholesale grocers are an important part
of America's economy. Independent community grocers account for 33% of
all grocery sales, exceeding $250 billion, and more than 1.1 million
American jobs. We are inherently tied to the strength and vitality of
the markets we serve--at the heart of local communities and the U.S.
economy. According to USDA Economic Research Service (ERS) analysis,
independents tend to locate in the rural, low-income and underserved
areas providing critical food access to Americans who would otherwise
live in a food desert. Having often been in the business for
generations, independent grocers are dedicated to their customers,
associates, and communities.
Federal nutrition programs are an important resource to struggling
families and independent grocery stores are an indispensable partner in
these programs. Retailers take pride in participating in the SNAP
program to support their communities and local families in need.
Independent grocers are committed to advancing access to healthy food
in an equitable manner and maintaining SNAP choice is critical to those
efforts.
SNAP is a shining example of a public-private partnership. In 2020,
SNAP was responsible for nearly 200,000 U.S. grocery industry jobs
earning wages totaling more than $6.7 billion. SNAP not only works as
it is intended but it also features one of the lowest error rates of
any Federal program in existence. Independent community grocers are a
key private partner with the Federal Government to administer SNAP and
the program is critical to the health of local communities.
One of the many reasons this program is successful is the ease of
processing SNAP transactions for retailers and beneficiaries who can
make their own decisions about which food items to purchase for their
household. This choice ensures families can shop with the same dignity
as any other grocery customer. Ill-conceived proposals to restrict the
choices of SNAP participants would turn this efficient and effective
program into an untested public health intervention overrun by
bureaucracy.
Restricting the choices of SNAP customers to items approved by the
USDA will increase program implementation costs for the government and
discourage business participation in the program. The government will
need to categorize more than 600,000 products and thousands more each
year to create and maintain a food code to determine what foods can be
purchased with SNAP. Grocery store cashiers will become the food police
telling parents what they can and cannot feed their families.
Restricting SNAP choice will not create meaningful public health
outcomes. The diet of an individual on SNAP is not significantly
different than the average American diet. To improve public health,
nutrition incentives are more effective and can be targeted to high
need communities. Additionally, most SNAP transactions are split
tender, meaning they are partially paid for out of pocket. Foods not
allowed on the program will just be moved to out-of-pocket purchases
and not change an individual's purchasing habits.
The current flexibility is key to the program's success. The
dietary needs of the SNAP population are diverse and no one diet would
be appropriate for all participants leading to the need for different
meal plans and nutrition counseling for each participating in turn
increasing the cost of the program. SNAP choice allows the program to
remain flexible during a supply chain shortage and declared
emergencies. Restrictions would limit the program's ability to react to
the changing needs of the community.
Additionally, NGA strongly opposes the collection of retailer-
specific basket-level purchasing data. Collection of such data would
impose a significant burden on small businesses with no benefit to the
government. USDA has already collected troves of data from third-party
data collecting agencies on the purchasing habits of SNAP customers
without having to surveil SNAP customers and requiring retailers to
turn over highly sensitive and proprietary transaction information.
Massive data collections from the Federal Government would require
additional staffing and expertise that many small businesses do not
have. Many small businesses, especially those with small margins like
grocery stores, do not have the capacity to bring on additional
compliance staff with each new regulation.
Broad data collection is not necessary to ensure that the program
is running effectively and efficiently. USDA already receives bulk
redemption data that assists the agency to pinpoint anomalies and
investigate fraud.
Restrictions will harm participants, taxpayers, and small community
businesses. For these reasons, NGA urges you to oppose any efforts to
restrict purchases and limit choices of SNAP recipients. Thank you for
your attention to these important matters.
Sincerely,
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Stephanie Johnson, RDN,
Vice President, Government Relations,
National Grocers Association.
______
Supplementary Material Submitted by Patrick J. Stover, Ph.D., Director,
Institute for Advancing Health Through Agriculture, Texas A&M
University
Insert
Mr. LaMalfa. So, in all the existence of the SNAP Program, we
don't really have data that has been gathered yet that the
increased dollar amount per user of the program would lead to
healthier food choices in their diet?
Dr. Stover. Some of those data are available, and we can make
those available to you, but I don't have those in my
fingertips.
As discussed in detail in my response to Congressman Bost, (see
Response to Mr. Bost's Question for the Record on p. 251.) there are no
systematic evaluation metrics employed in SNAP that would include
lowering rates of diet-related chronic disease and related health care
costs. The IHA is currently conducting a systematic review of the
literature that is focused on health-related outcomes among SNAP-
eligible participants, and we anticipate a completion date in 2024.
______
Supplementary Material Submitted by Dawn Royal, Member, Board of
Directors and past President, United Council on Welfare Fraud
June 15, 2023
Hon. Glenn Thompson,
Chairman,
House Committee on Agriculture,
Washington, D.C.;
Hon. David Scott,
Ranking Minority Member,
House Committee on Agriculture,
Washington, D.C.
Dear Chairman Thompson and Ranking Member Scott,
On behalf of the United Council on Welfare Fraud, thank you for the
opportunity to provide testimony and address issues impacting the
Supplemental Nutrition Assistance Program (SNAP). I would like to offer
several points of [clarification] for the record following the June 7,
2023, hearing, ``Innovation, Employment, Integrity, and Health:
Opportunities for Modernization in Title IV.''
I was asked several questions about error and fraud rates. As I
testified, this contentious issue is problematic to answer as the two
issues are often co-mingled. The SNAP payment error rate is a
performance measure for accountability at state and county SNAP offices
and is impacted by SNAP eligibility workers and policy waivers and
options in place.\1\ *
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\1\ USDA Office of Inspector General: FNS Quality Control Process
for SNAP Error Rate. 2023 rates are expected to be released by end of
June. https://www.oversight.gov/sites/default/files/oig-reports/27601-
0002-41.pdf.
* Editor's note: references annotated with are retained in
Committee file..
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Fraud rates, conversely, include overpayments but are impacted by
the lack of fraud detection staff as discussed in my written testimony.
They can also vary from state to state and county to county depending
on many factors. Fraud is a moving target, and government agencies are
always playing catchup, which is why we encourage moving from ``pay and
chase'' to front-end fraud prevention.
A research study was ordered by the Florida state legislature and
released on November 28, 2012. It established a 7.5% SNAP fraud rate,
which is in line with my testimony.\2\ It should be noted that this
fraud rate only pertained to provable recipient eligibility fraud and
did not address fraud attempts, trafficking, or identity theft (to
include account takeover.) A copy of this report is attached. Concerns
with the 40% rate reported by the Pennsylvania Inspector General should
be directed to that agency, but this also aligns with UCOWF member
experiences.\3\
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\2\ ``Statistical Analysis of Fraud in the Florida Food Assistance
Program,'' ERS Group, November 28, 2012.
\3\ https://www.bradfordera.com/news/key-pa-budget-negotiator-
hopes-for-welfare-fraud-compromise/article_560351bf-6e3e-5beb-8177-
18282b864774.html.
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I would also like to clarify questions about the Name/Address/
Signature and Social Security Number discussions. According to 7 CFR
273.2(b)(1)(v): [Emphasis added]
``In plain and prominent language on or near the front page
of the application, notification of the household's right to
immediately file the application as long as it contains the
applicant's name and address and the signature of a responsible
household member or the household's authorized representative.
Regardless of the type of system the state agency uses (paper
or electronic), it must provide a means for households to
immediately begin the application process with name, address,
and signature;'' \4\
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\4\ https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/
subchapter-C/part-273#p-273.2(b)(1)(v).
Should a household apply for Expedited Benefits, all that is
required under current regulations is the name, address, and signature.
While well intentioned to provide maximum benefits immediately to
applicants in need, this loophole is exploited by identity thieves. A
savvy fraudster applying after the 15th of the month would receive 1\1/
2\ months SNAP benefits--up to $421.50 for a single household.\5\ After
the expedited benefit time has expired, the recipient must provide the
remaining eligibility information to continue receiving SNAP. Per FNS,
``The significant aspect of expedited service is the postponing of
verification when it is necessary to issue an allotment by the 7 day
deadline.'' \6\
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\5\ https://www.fns.usda.gov/snap/recipient/eligibility.
\6\ USDA FNS Memo dated February 17, 2006. https://
www.fns.usda.gov/snap/admin/expedited-service-and-interviews.
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Modernization of regulations to require all mandatory identity
components is a common-sense reform both sides of the aisle should
agree to--it protects the program from waste, fraud, and abuse. The
current ``EBT skimming'' epidemic impacting vulnerable recipients is a
great example that can be fixed with program modernization.
Again, thank you for the opportunity to discuss these critical
maters impacting SNAP program integrity. We remain at your disposal and
available for additional opportunities to discuss fraud and integrity
with all Committee and Subcommittee Members.
Respectfully submitted,
Dawn Royal,
Director and Past-President,
United Council on Welfare Fraud (UCOWF).
attachment
Statistical Analysis of Fraud in the Florida Food Assistance Program
Prepared for The Florida Strike Force on Medicaid & Public Assistance
Fraud
Prepared by: Charles J. Mullin, Ph.D., ERS Group, Tallahassee, FL
November 28, 2012
ERS Group was requested by The Florida Strike Force on Medicaid &
Public Assistance Fraud (the Strike Force) to (1) review information on
metrics and methodologies used to measure fraud, waste, and abuse in
government food and nutrition or other public assistance programs, and
(2) to design and implement a methodology to provide the Strike Force
with an estimate of the amount of fraud, waste and abuse leading to
overpayments in the Florida Food Assistance Program, also known as the
Supplemental Nutrition Assistance Program (SNAP). In the interest of
brevity, throughout this report we often refer to ``fraud, waste and
abuse'' simply as ``fraud.'' ERS Group staff worked closely with Strike
Force staff, the Department of Children and Families (DCF), and the
Department of Financial Services' Division of Public Assistance Fraud
(DPAF). ERS Group would like to thank the Strike Force members for the
opportunity to contribute to their efforts to reduce fraud in the State
of Florida, and to thank the numerous individuals within these agencies
for their cooperation and assistance, without whom this project could
not have been completed.\1\
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\1\ ERS Group would like to thank Jeri Flora, Yameche Madry and
Peter Bull of DCF's Economic Self Sufficiency Division; Amanda Huston,
Director of the Office of Public Benefits Integrity; Randy Burkhalter,
Director of Florida's Division of Public Assistance Fraud; and Chuck
Faircloth, Executive Director of the Strike Force. Special thanks are
due to Strike Force staff member Cynthia Godbey, Department of Children
and Families ACCESS Integrity Chief Fred Young, and Florida Department
of Financial Services' Financial Crimes Investigator Kim Harrison.
---------------------------------------------------------------------------
Executive Summary
The estimate of fraud incidence in the Florida SNAP program
is 7.5 percent. For the purpose of this estimate, fraud
includes any potential overpayment of benefits due to a
misrepresentation of information, regardless of size.
Therefore, this estimate indicates that 7.5 percent of the
discrete payments were potentially larger than justified under
the program rules.
In addition to calculating a rate of fraud incidence, we
employed two methodologies to estimate the overall overpayment
rate in dollar terms. One method, based on the benefit payments
received by those in our sample who committed fraud, yields an
estimated dollar overpayment rate of approximately 2.75
percent.
The second method, based on historical fraud overpayment
calculations provided by DPAF, yields an estimated dollar
overpayment rate of approximately 3.7 percent.
These estimates do not include vendor trafficking (purchase
of SNAP electronic benefit transfer (EBT) cards by vendors at a
fraction of their value), which cannot be detected by the
methodologies employed in this study. A recent U.S. Department
of Agriculture (USDA) report estimates the dollar cost of SNAP
vendor trafficking at one percent.
Fraud was detected by four of the nine distinct fraud
detection methodologies that were employed by investigators
during the study. The most effective methods of detection were
income verification, site visits, and desk reviews.
Over 70 percent of the fraud that was detected in our sample
was related to non-reporting or under-reporting of income.
Florida's SNAP system would benefit from routine computer
comparisons of recipient income (as reported on applications)
vs. earned income as reported to the Department of Economic
Opportunity, along with follow-up on identified discrepancies.
Similarly, routine verification of household composition
through available data may help to prevent fraud.
Logistic regression analysis of the sample revealed one
statistically significant difference in the characteristics of
those who committed fraud and those who did not: As the number
of adults in the household increased, the likelihood of fraud
increased, after controlling for other factors.
Current policy requires SNAP recipients to report changes in
income (and other living conditions) every 6 months (or every
year in certain cases). The USDA's Food and Nutrition Service
(FNS) allows states several choices with regards to how often
recipients are required to report changes. We recommend DCF
review the current 6 month change reporting policy to determine
if a shorter time threshold is in the best interest of the
State of Florida.
Per the SNAP State Activity Report for FY 2010, 87 percent
of pre-certification fraud investigations in Florida result in
a positive finding, while only 12 percent of post-certification
investigations result in a positive finding. However, only 32
percent of investigations are done on a pre-certification
basis. Florida would benefit from moving further away from a
post-certification, ``pay-and-chase'' system and towards a more
rigorous pre-payment fraud detection system.
I Background
The Supplemental Nutrition Assistance Program is implemented by the
Food and Nutrition Service, a division of the United States Department
of Agriculture. SNAP provided nearly $65 billion in benefits to
American families in fiscal year 2010, and as of September, 2011
provided assistance to 46 million people per month.2, 3
While the program's funds are provided by the Federal Government, the
program is administered by each state. Within the State of Florida, the
program is administered by DCF. In Fiscal Year 2010, Florida's share of
SNAP funds totaled over $4.4 billion, the fourth highest amount in the
nation.\4\ It is worth noting that Florida's SNAP issuance increased
from almost $1.8 billion in 2008 to $4.4 billion in 2010, a growth rate
of almost 150 percent, the second highest in the nation (only Idaho had
a higher growth rate).\5\ With sums of this magnitude, even a
relatively low rate of fraud can represent significant monetary loss.
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\2\ SNAP Quality Control Annual Report, September 2011, page i.
\3\ State Fraud Detection Efforts for the Supplemental Nutrition
Assistance Program, Audit Report 27703-0002-HY, January 2012, page 4.
\4\ SNAP Quality Control Annual Report, September 2011, page 11.
\5\ Supplemental Nutrition Assistance Program (SNAP) State Activity
Report: Federal Fiscal Year 2010. U.S. Department of Agriculture, Food
and Nutrition Service, Program Accountability and Administration
Division, December 2011, page 55.
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In consultation with Strike Force staff, we first endeavored to
define the phrase ``fraud, waste and abuse''. While similarities in
definitions exist across Federal and state entities, it does not appear
that any two units of government use exactly the same definition. For
example, the Texas health care claims studies described later in this
report, which were pilot studies for the Federal Payment Error Rate
Measurement Program (PERM) used for Medicare and Medicaid, define fraud
as ``. . . an intentional deception or misrepresentation made by a
person with the knowledge that the deception could result in some
unauthorized benefit.'' The studies defined abuse as ``. . . provider
practices that are inconsistent with sound fiscal, business or medical
practices and result in an unnecessary cost to the Medicaid program.''
\6\
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\6\ Texas Health Care Claims Study, January 2001, Section II, page
15. Texas Health Care Claims Study, March 2003, Section I, page 16.
Texas Health Care Claims Study, March 2005, Section I, page 17.
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In contrast, the current definition of fraud on the Federal
Government's FNS website is as follows:
``SNAP fraud is when SNAP benefits are exchanged for cash.
This is called trafficking and it is against the law.
SNAP fraud also happens when someone lies on their
application to get benefits or to get more benefits than they
are supposed to get.
SNAP fraud also happens when a retailer has been
disqualified from the program for past abuse and lies on the
application to get in the program again.'' \7\
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\7\ http://www.fns.usda.gov/snap/fraud/fraud_2.htm.
The above is roughly consistent with the FNS's December, 2011 statement
on the USDA's efforts to reduce waste, fraud and abuse. That document
suggests a definition that includes elements related to providing false
information connected to eligibility and benefits, trafficking, and
reducing improper payments and errors.\8\
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\8\ USDA Efforts to Reduce, Waste, Fraud and Abuse in the
Supplemental Nutrition Assistance Program (SNAP), December 2011, http:/
/www.fns.usda.gov/cga/FactSheets/Integrity.pdf.
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Lastly, The Florida Department of Children and Families indicates
that ``fraud means to commit an intentional violation of law or a
deliberate misrepresentation or concealment so as to secure unfair or
unlawful financial or personal gain''.\9\
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\9\ See for example, Cf Operating Procedure No. 180-4, Florida
Department of Children and Families, December 13, 2011.
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We have chosen throughout this report to focus first and foremost
on fraud. Within the SNAP universe and Florida DCF, this encompasses
primarily at least one of two elements. The first is trafficking, or
the exchange of benefits for cash. While direct investigation of vendor
trafficking was outside the scope of this report, we did research this
issue and have provided information related to estimates of vendor
trafficking. The second element is an intentional or unintentional
material misrepresentation provided by a SNAP applicant (or re-
applicant) that could result in the receipt of unauthorized benefits.
While other criteria, such as agency error or a misapplication of
rules, could also result in a finding of fraud, waste or abuse, for the
purposes of this report we have defined fraud in terms of such material
misrepresentation. It is important to note that we did not attempt to
differentiate between the distinct terms (fraud, waste, abuse) but
rather treated them as a single phrase which encompasses the full range
of activity associated with the receipt of improper benefit amounts due
to material misrepresentation of information. Identifying fraud, waste
and abuse as separate and distinct items would require a measurement of
intent, which was beyond the scope of these investigations.
Fraud is an ongoing and pervasive problem within the SNAP program,
both nationwide and within Florida. Of the nearly 800,000 fraud
investigations conducted nationwide during (Federal) Fiscal Year 2010,
the State of Florida conducted over 51,000, approximately 16,000 of
which were pre-certification investigations and 35,000 of which were
post-certification investigations. Of those 51,000 investigations,
18,000 resulted in a positive determination of fraud (a 35 percent rate
compared to the national average of 27 percent). Of those,
approximately 4,100 were post-certification instances involving
approximately $5.7 million in disbursements.\10\ The investigations
resulted in 291 prosecutions which led to 283 convictions and eight
acquittals.\11\ These 283 convictions involved over $900,000 of
fraudulent activity.\12\ The State of Florida also conducted 2,856
administrative disqualification hearings resulting in 2,811 waivers or
convictions and only 45 acquittals. These administrative
disqualifications involved approximately $1.8 million of fraudulent
activity.\13\ In Fiscal Year 2010, Florida collected nearly $2.4
million in fraudulent SNAP claims, about 54 percent of which was
collected through recoupment from ongoing recipients.\14\
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\10\ Supplemental Nutrition Assistance Program (SNAP) State
Activity Report: Federal Fiscal Year 2010. U.S. Department of
Agriculture, Food and Nutrition Service, Program Accountability and
Administration Division, December 2011, page 25.
\11\ Ibid., page 27.
\12\ Ibid., page 27-28.
\13\ Ibid., pages 29-30.
\14\ Ibid., pages 42-43.
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II Review of Literature and Previous Government Fraud Measures
Academic Studies
We reviewed a variety of academic literature to obtain an
understanding of how economists and statisticians (or experts in other
fields) have previously conducted studies to measure fraud rates. There
exists very limited academic literature addressing the actual rates of
fraud in programs such as SNAP. There is however a considerable body of
literature on the current methodologies used to detect such fraud. Not
unexpectedly, most academic efforts in this arena are designed to
determine the factors (demographic characteristics, education, income,
etc.) that are correlated with fraud, rather than to directly measure
incidence.
One such methodology is regression analysis. Regression is a
mathematical technique used to estimate the statistical relationship
between a dependent variable and a set of explanatory variables. This
estimate can then be used to predict the dependant, or outcome
variable, given the values of the explanatory variables. Regression
models for fraud detection are most commonly discussed in the
literature concerning automobile insurance fraud. In contrast, efforts
to detect credit card fraud and fraud in health care have favored a
variety of machine learning methods. Machine learning involves the use
of computer algorithms that improve automatically through experience.
Applications of machine learning range from data-mining programs that
discern general rules in large data sets, to information filtering
systems that automatically learn users' interests.\15\ Machine learning
in the context of fraud takes primarily two forms. One methodology
involves having the computer learn to identify potential fraud using a
training data set where instances of fraud are first identified by
human subject matter experts. The second involves the use of computers
that learn to identify suspicious transactions based on a more general
set of rules and/or identification of anomalous values in selected data
fields. These methods are worthwhile and certainly aid in the detection
of fraud; however, as noted, they do not actually measure the rate of
fraud, but rather identify transactions that are more likely to be
fraudulent.
---------------------------------------------------------------------------
\15\ Mitchell, Tom, Machine Learning, McGraw Hill, 1997.
---------------------------------------------------------------------------
Government Studies
In addition to researching the academic literature, we reviewed a
number of government studies, both state and Federal, that do measure
fraud rates. In August 1998, the State of Illinois completed what was
then believed to be ``the first ever payment accuracy review of any
state Medical Assistance Program.'' \16\ For purposes of the review,
state investigators selected a random sample of 599 records of payment
for medical services, stratified by category (physician and pharmacy
services, inpatient hospital and hospice services, and all other types
of services). Investigators found 96 instances in which payments had
been made in error. The study did not estimate a fraud rate, nor,
according to the authors, was it intended to do so. The authors state
however that 54.7 percent of the inaccurate payments were the result of
``questionable'' errors, meaning ``the provider's intention to bill
correctly is very doubtful, but no intent was proven.'' \17\ Twenty-
nine of the payments were judged to be so serious that they were
referred for additional reviews.
---------------------------------------------------------------------------
\16\ ``Payment Accuracy Review of the Illinois Medical Assistance
Program: A Blueprint for Continued Improvement''. Illinois Department
of Public Aid, August 1998, page 3.
\17\ Ibid., page 4.
---------------------------------------------------------------------------
In 2001, 2003 and 2005, the State of Texas conducted studies of
potential overpayments in the state Medicaid program using random
samples of patients and associated payments.\18\ In each case where
such a determination was made, a relatively small portion of the
overpayment errors were found to represent fraud or ``abuse''. The 2001
Texas Health Care Claims Study, for example, presented results of an
examination of a sample of 1,609 Medicaid Fee-for-Service (FFS) Claims.
Investigators found 269 potential overpayment errors, including 14 that
were classified as representing potential fraud or abuse.\19\ The 2003
Texas Health Care Claims Report was expanded to encompass a separate
study of potential overpayments in the Medicaid Vendor Drug Program
(VDP). The amount of fraud in the Medicaid VDP is not addressed in the
2003 report; however, the authors of the report found 29 instances of
potential overpayments due to fraud or abuse in the Medicaid FFS sample
of 2,122 paid claims.\20\
---------------------------------------------------------------------------
\18\ They also examined the extent of overpayment in the state
employees' workers' compensation program.
\19\ Texas Health Care Claims Study, January 2001, Section II,
pages 29-30.
\20\ Texas Health Care Claims Study, March 2003, page 2, Section I,
page 31.
---------------------------------------------------------------------------
The 2005 Texas Health Care Claims Report included a Medicaid FFS
study based on a review of 2,202 medical services' payments.\21\ The
review indicated that 28 (about seven percent) of 387 potential
overpayment errors represented potential ``fraud or abuse''.\22\ For
purposes of the Medicaid VDP study a sample of 4,036 prescriptions were
randomly selected for audit. After review, 916 were found to have
potential overpayment errors.\23\
---------------------------------------------------------------------------
\21\ Texas Health Care Claims Study, March 2005, page, 2, Section
I, page 25.
\22\ Ibid.
\23\ Ibid., section II, page 79.
---------------------------------------------------------------------------
The Texas state studies discussed above were pilots for the Federal
Payment Error Rate Measurement Program (PERM). The pilot programs were
overseen by the Centers for Medicare and Medicaid Services and covered
the period from 2002-2005. The PERM program was designed to measure
payment error rates in Medicaid and the Children's Health Insurance
Program (CHIP) in response to the requirements of the (Federal)
Improper Payments Information Act of 2002 (IPIA).24, 25 The
IPIA required Federal agencies overseeing programs susceptible to
``significant'' erroneous payments (as defined by the Office of
Management and Budget (OMB)) to estimate the amount of improper
payments each year and to report on measures taken to reduce them.\26\
An overpayment is defined as a payment for a service that is not in
accordance with the policies of the Medicaid program, and may include
fraud and abuse.\27\ Under the plan, 17 states (including DC as a
state) are reviewed each year, so that all are reviewed on a rotating
basis every 3 years.\28\ The first wave of states was reviewed in
fiscal year 2006.
---------------------------------------------------------------------------
\24\ The IPIA was subsequently amended by the Improper Payments
Elimination and Recovery Act (IPERA) of 2010.
\25\ Payment Error Rate Measurement Manual, Centers for Medicare
and Medicaid Services, 2010.
\26\ Ibid.
\27\ Texas Health Care Claims Study, March 2005, page I-17.
\28\ Payment Error Rate Measurement Manual, Centers for Medicare
and Medicaid Services, 2010, page 12.
---------------------------------------------------------------------------
Each fiscal quarter the states provide to a statistical contractor
the universe of claims data for Medicaid, CHIP FFS and managed care
that were paid by the Federal Government.\29\ The statistical
contractor then draws random samples from the claims. After receiving
supporting data for the samples from the states, the statistical
contractor forwards the data to a review contractor who sends records
requests to medical service providers represented in the sample.\30\
The review contractor employs medical personnel who review the medical
records for accuracy and consistency with the claims submitted to the
states. The statistical contractor then calculates state specific error
rates and a national error rate for FFS transactions and managed care.
These rates are calculated overall, as well as by program and by type
of error.\31\ The estimated overall Medicaid error rate for the nation
for fiscal year 2008 was 8.71 percent. The estimated overall Medicaid
error rate for Florida for fiscal year 2008 was 14.63 percent.\32\
---------------------------------------------------------------------------
\29\ Payment Error Rate Measurement Manual, Centers for Medicare
and Medicaid Services, 2010, page 10-12.
\30\ Ibid.
\31\ Ibid.
\32\ Fiscal year 2008 PERM Medicaid Corrective Action Plan,
Executive Summary, page 1.
---------------------------------------------------------------------------
III Supplemental Nutritional Assistance Program (SNAP)
Similarly to Medicaid, SNAP, formerly known as the food stamp
program,\33\ was also identified by the OMB as a ``high error
program''.\34\ The USDA first reported on improper payments in the SNAP
program in the 2004 Performance and Accountability Report (PAR), which
covered outlays for fiscal year 2003.\35\ The most recent (2011) PAR
covered improper payments in fiscal year 2010. The improper payment
error rate for the U.S. was 3.8 percent in fiscal year 2010 (consisting
of an overpayment error rate of 3.05 percent and an underpayment error
rate of 0.75 percent).\36\ For the State of Florida the reported SNAP
improper payment rate was 0.72 percent for fiscal year 2010 (consisting
of a 0.68 percent overpayment rate and a 0.04 percent underpayment
rate).\37\ The process of calculating the improper payment rate for
SNAP is described below.
---------------------------------------------------------------------------
\33\ Analysis of Florida's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0002-13, November
2011, page 1.
\34\ Improper Payments: Recent Efforts to Address Improper Payments
and Remaining Challenges, GAO-11-575T, April 15, 2011. Footnote 14,
page 8.
\35\ 2011 Performance and Accountability Report, U. S. Department
of Agriculture, page 27.
\36\ Supplemental Nutritional Assistance Program Quality Control
Annual Report Fiscal Year 2010, page 4.
\37\ Ibid., page 5.
---------------------------------------------------------------------------
Each month, states select a statistically random sample of cases
from a universe of all households receiving SNAP benefits that month
and perform a quality control review to measure the accuracy of
eligibility and benefit determinations for each sampled case against
SNAP standards. State agencies are required to report to FNS the
findings for each case selected for review. FNS then sub-samples the
completed state quality control reviews and re-reviews selected
individual case findings for accuracy. Based on this sub-sample, FNS
determines each state agency's official error rate using a regression
formula. The national payment error rate is computed by averaging the
error rate of the active cases for each state weighted by the amount of
issuance in the state.\38\
---------------------------------------------------------------------------
\38\ 2011 Performance and Accountability Report, U. S. Department
of Agriculture, pp. 218-219.
---------------------------------------------------------------------------
According to the FNS document which provides the guidelines for the
quality control audit process, the quality control review should
consist of ``a face-to-face interview for active cases subject to
review to determine the identity of the applicant and whether the
household did exist and to explore household circumstances affecting
the sample month's eligibility and allotment''.\39\ The FNS guidelines
also require income verification.\40\ These are just two of several
ways in which the quality control audit process is similar to our
methodology. However, there are several exceptions to the process which
differentiate the quality control audit process from our methodology
and may be the source of the contrast in our results, which are
detailed later in this report.
---------------------------------------------------------------------------
\39\ SNAP Quality Control Review Handbook (FNS Handbook 310), U.S.
Department of Agriculture, Food and Nutrition Services, October, 2011,
section 420--Household Interview.
\40\ FNS Handbook 310, section 1021--Wages and Salaries.
---------------------------------------------------------------------------
First, there are several case types that are not to be included in
the quality control sample per the FNS guidelines.\41\ Examples include
but are not limited to:
---------------------------------------------------------------------------
\41\ FNS Handbook 310, sections 330-338, section 442.
---------------------------------------------------------------------------
Cases pending a hearing appealing an adverse action,
Cases already referred for investigation,
Cases under active investigation or pending an intentional
program violation hearing,
Cases where household members have moved out of state,
Cases in which the household members could not be
interviewed after all reasonable efforts to do so have been
made and documented.
In several instances, these types of cases are ones in which there
is a heightened likelihood of fraudulent activity. Since these cases
are not subject to review and are removed from the FNS sampling
process, it may serve to reduce the subsequent error estimate. Second,
the quality control process is designed to determine allotment errors,
not to detect fraud per se. Accordingly, although incorrect
applications of policy, or deviations between the information that was
used and what should have been used to determine eligibility/allotment,
may exist, they do not result in a finding unless they result in an
allotment error. Lastly, the allotment error must reach a specific
monetary threshold before it is included as an error ($25 per the FNS
handbook; $50 according to quality control personnel at DCF). There may
be a significant number of instances where the threshold requirement
could reduce the overall error rate reported through the quality
control process.
The USDA Office of Inspector General (OIG) also conducts audits of
the SNAP eligibility data for selected states. The most recent OIG
audit report of SNAP in Florida found that 2,689 of the 2.6 million
average monthly recipients, or 0.1 percent, either (1) were deceased,
(2) had invalid Social Security Numbers (SSNs), (3) were receiving
duplicate benefits in Florida and in one or more nearby states, or (4)
were listed in the Electronic Disqualified Recipient System (eDRS) and
had therefore been disqualified from receiving benefits because of
intentional program violations.\42\ Similar audits of Alabama and
Louisiana found that 0.2 percent and 0.3 percent respectively of the
recipients were ineligible for benefits for one or more of the four
reasons above.43, 44
---------------------------------------------------------------------------
\42\ Analysis of Florida's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0002-13, November
2011, page 1.
\43\ Analysis of Alabama's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0004-13, January
2012, page 1.
\44\ Analysis of Louisiana's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0003-13, January
2012, page 1.
---------------------------------------------------------------------------
The OIG also reviewed state and FNS SNAP fraud control efforts in
Colorado, New York, Florida and New Jersey.\45\ A common recommendation
is that states make better use of Electronic Benefits Transfer (EBT)
Management Reports. Recipients of SNAP assistance receive debit cards
that can be used to purchase food from approved vendors. The funds are
transferred from an account monitored by a database manager to the
vendors. Anomalous transactions could suggest fraud. Using the
available EBT Management Reports, OIG identified 2,600 questionable
transactions during a 3 month period in New Jersey and Florida that had
not previously been found.\46\ The transactions could represent up to
$181,700 in fraudulent activity.\47\ These included out of state
transactions that could indicate recipients who are receiving benefits
in more than one state. They also include cases with unusual numbers of
whole-dollar transactions at a retail location and instances involving
excessive refunds by retailers to SNAP recipients. The latter may
indicate instances in which recipients are trading SNAP benefits for
cash.
---------------------------------------------------------------------------
\45\ State Fraud Detection Efforts for the Supplemental Nutrition
Assistance Program, Audit Report 27703-0002-HY, January 2012, pp. 1-21.
\46\ State Fraud Detection Efforts for the Supplemental Nutrition
Assistance Program, Audit Report 27703-0002-HY, January 2012, page 7.
\47\ Ibid.
---------------------------------------------------------------------------
Instances in which retailers excessively manually enter the
benefits card numbers may also represent fraud. Using one of the EBT
Management Reports, the Manual Transaction Report, the OIG found 122
retailers in New Jersey who processed more than 400 manual transactions
each during the review month. They note that these transactions totaled
over $4.4 million and represented 49 percent of the retailers' total
SNAP transactions during the month.\48\ The OIG also found 15 retailers
in Florida whose manual SNAP transactions totaled over $155,000 during
the month of the review.\49\ Nationwide, the USDA estimates retailer
fraud in the SNAP program occurs in 8.2 percent of stores and diverts
``about 1 of each SNAP dollar''.\50\
---------------------------------------------------------------------------
\48\ State Fraud Detection Efforts for the Supplemental Nutrition
Assistance Program, Audit Report 27703-0002-HY, January 2012, page 8-9.
\49\ Ibid.
\50\ See the March, 2011 USDA FNS report entitled ``The Extent of
Trafficking in the Supplemental Nutrition Assistance Program (SNAP):
2006-2008''. See http://www.fns.usda.gov/ora/menu/Published/SNAP/FILES/
ProgramIntegrity/Trafficking2006Summary.pdf.
---------------------------------------------------------------------------
We also reviewed the ACCESS Florida Food, Medical Assistance and
Cash program policy manual. The manual, which is available online,
contains 23 sections and 1,096 pages. The glossary alone is 27 pages.
While a complete review of the entire manual was neither practical nor
necessary, we did find one critical area of policy which may lead to
waste and abuse within the SNAP program. The FNS guidelines provide
states the freedom to choose SNAP recipient reporting requirements,
that is, when recipients must report changes to their income, expenses
or living conditions that determine their benefit levels. Choices
include time requirements (which include monthly, quarterly or semi-
annually) and threshold requirements, which require recipients to
report changes above a certain amount as soon as they occur.\51\ The
DCF policy manual indicates that Florida SNAP recipients are required
to report changes semi-annually, with certain categories of recipients
subject to annual reporting.\52\ So, for example, if a recipient were
to receive an increase in income such that they were no longer even
eligible for food stamp assistance, they would not be required to
report that change for as much as 6 months. Under these rules, a
recipient could continue to receive benefits for 6 months (or possibly
a year) and not be in violation of reporting requirements. While there
is technically no fraud, the potential for waste under these reporting
requirements is significant. It is our recommendation that DCF and
other stakeholders review this policy to determine if it is in the best
interest of the State of Florida.
---------------------------------------------------------------------------
\51\ FNS Handbook 310, section 223.1-223.6.
\52\ Access Florida Food, Medical Assistance and Cash Program
Policy Manual, l., Chapter 0800, section 0810-0200 to 0810-0400. http:/
/www.dcf.state.fl.us/programs/access/esspolicy
manual.shtml.
---------------------------------------------------------------------------
IV Our Methodology
While not all of the studies noted above included an analysis of
random samples, use of sample data sets was a common methodology,
particularly among the analyses conducted by government entities
attempting to either investigate fraud or to measure payment error
rates. Random sampling is a common technique used to measure incidence
rates of various types in large data sets where examination of all
observations is simply not economically practicable, as is the case
here (Florida's SNAP program provided assistance to roughly 2.6 million
recipients per month in fiscal year 2010).\53\ At ERS Group's request,
DCF selected a random sample of 545 payments from the universe of all
payments made during the 3 month period from May, 2011 through July,
2011. The sample data provided information on the recipient, including
but not limited to personally identifying information, residence,
income, expenses and that month's benefit amount. We also received
information on household composition, including but not limited to
personally identifying information on all individuals listed as being
in the household, their relationship to the recipient, their employment
status as of the last eligibility review, and recorded income
contributions.
---------------------------------------------------------------------------
\53\ Analysis of Florida's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0002-13, November
2011, page 1.
---------------------------------------------------------------------------
This information was then provided to Florida's DPAF, where in
conjunction with DCF, investigators conducted the following
investigations to determine whether or not the sampled payments
involved any fraud, waste or abuse.\54\
---------------------------------------------------------------------------
\54\ The investigative work was overseen by Randy Burkhalter. Mr.
Burkhalter is the Director of DPAF and has been investigating fraud for
the State of Florida in some capacity for over 35 years.
---------------------------------------------------------------------------
Household Composition/Site Visits
One of the primary factors in determining benefit eligibility and
benefit levels is the composition of the household. According to DPAF
investigators and DCF personnel, one of the common means by which fraud
occurs is through over-reporting of individuals within the household
(or conversely, by not reporting a household member who is earning
income). Verification of household composition and residency is best
done through site visits. Unfortunately, this is a very time consuming
element of fraud investigation, and it was prohibitively time consuming
to perform site visits for all of the recipients in the full sample.
Accordingly, ERS Group selected a random sub-sample of 100 recipients
from our sample population of 545 SNAP recipients and DCF personnel
conducted site visits on the sub-sample. In addition to determining
which, if any, of the recipients in the sub-sample had a household
composition that was different than what was reported at the time they
received benefits, investigators also found program violations of other
types during these visits. With regard to household composition,
violations could have consisted of either (1) over-reporting of
individuals in the household, (2) under-reporting of income earning
members in the household or (3) residency issues. Any of these
constitutes fraud, waste or abuse in that such misrepresentation could
(and likely would) materially affect SNAP benefits.
Income Verification
The other primary factor in determining both benefit eligibility
and benefit amount is household income. DPAF investigators have access
to a variety of sources for income verification purposes, including the
Florida Retirement System, Unemployment Compensation Benefits,
Interstate Unemployment Compensation Benefits, Worker's Compensation
Benefits, and earned wage information reported to the Department of
Economic Opportunity (DEO), which receives quarterly information from
Florida employers documenting income earned within the state (with the
exception of self-employment income). Each household member's income
(or absence of income) was compared to information from these various
sources to determine if there was any un-reported or under-reported
income. Any discrepancies were followed up and verified independently.
In the case of verified material differences, these generally resulted
in a determination that fraud, waste or abuse had occurred.
Identity Verification
One of the ways in which fraud can occur within SNAP is if an
individual's identity has been stolen. Investigators and computer
programmers at ERS Group, DPAF and DCF compared each recipient's
identity against a variety of databases to determine that both the
recipient's identity appeared valid and they were eligible for SNAP
benefits. The data sources for these comparisons included the U.S.
Social Security Administration's Master Death File, the Florida Bureau
of Vital Statistics database and the Stop Inmate Fraud database.
Instances in which a recipient was identified as ineligible through
these comparisons and subsequently verified were counted as fraudulent.
Electronic Disqualified Recipient System
We also requested that programmers at DCF compare the recipient
sample against the Electronic Disqualified Recipient System. The eDRS
is a national internet-based program that tracks and identifies SNAP
recipients who are found guilty of violations in other states and
therefore disqualified from receiving benefits. This is often the only
way in which violators from other states can be identified.
PARIS Match
We also requested that DCF conduct a search using the Public
Assistance Reporting Information System (PARIS) to determine if any of
the recipients in our sample were receiving SNAP benefits from any
other states. The PARIS database is an information exchange system
administered by the U.S. Administration for Children and Families and
is designed to provide state public assistance agencies with
appropriate data as a result of a Federal computer matching
initiative.\55\ This database enables agencies to determine if a
recipient is receiving funds from multiple states under a variety of
public assistance programs, including SNAP.
---------------------------------------------------------------------------
\55\ http://www.acf.hhs.gov/programs/paris/state.
---------------------------------------------------------------------------
Address Matches
In addition to the computer matches to external databases, we also
requested that DCF determine for each of the recipients in our sample,
how many SNAP payments are going to the recipient's address. One way in
which fraud or abuse can manifest itself is if many recipients receive
SNAP funds at the same address. This may indicate that a recipient is
using false information. While some multiple recipient locations are
legitimate (churches, homeless shelters, etc.), many are not. For each
recipient address, DCF determined the number of payments going to that
address during the sample month. For those addresses that were
receiving three or more SNAP payments, DCF personnel conducted follow-
up investigations to determine if the multiple payments were the result
of program violations.
Desk Reviews
Despite each of the above procedures, it is entirely possible to
commit fraud or abuse of the SNAP system which is undetectable either
by computer match or home visit. Accordingly, DPAF investigators also
conducted what is referred to as a desk review. A desk review consists
of an overall review of the benefit recipient's case file in an attempt
to identify irregularities which are undetectable by any of the means
noted above. For example, an investigator might conduct a comparison of
expenses to income over time. An investigator might also conduct a
review of Department of Motor Vehicle records and vehicle registration,
driving history, insurance information or employment records to
determine who is living at the address listed.\56\ Investigators also
review information from the Clerk of Courts, as well as birth records
and property records. While there is no specific manual or checklist
that is followed as part of a desk review, investigators report that it
is an invaluable tool in the investigation of fraud, waste and abuse of
public assistance programs. DPAF investigators conducted desk reviews
on all 545 files in our sample and conducted follow-up investigations
as necessary as part of the overall fraud investigation effort. The
results of these reviews, as well as all of the aforementioned
procedures are discussed in detail in the next section.
---------------------------------------------------------------------------
\56\ Most of this information is available through DAVID, the
Florida Driver And Vehicle Information Database.
---------------------------------------------------------------------------
V Results
On the basis of the investigations discussed above, DPAF/DCF
investigators determined the existence of fraud, waste or abuse in 28
cases from our random sample of 545. Table 1 below details the
investigator's findings by fraud type. In several instances, multiple
types of fraud were detected on a single case, and therefore the total
incidence of fraud is not equal to the sum by type.
Table 1
------------------------------------------------------------------------
Fraud Type Number of Cases
------------------------------------------------------------------------
Household Composition 4
Residency 1
Non-Reporting of Income 21
Under-Reporting of Income 1
False Reporting of Expenses 2
Identity Theft 1
------------------------------------------------------------------------
Several of the investigation methods described above resulted in
some detection of fraud. However, the PARIS database match, the SSN
Death Master File match and the match to the eDRS failed to detect any
fraud within our sample of 545 records. This is not unexpected given
the results reported in the November 2011 Audit Report of the Florida
SNAP conducted by the OIG. That report notes finding 883 instances of
multi-state beneficiaries through PARIS, 807 Death Master File matches
and 160 previously ineligible recipients through the eDRS database.\57\
These matches were conducted on over 2.6 million recipients and
consequently represent a fraud detection rate of 0.07 percent for those
three methods combined.\58\ Given this low rate of detection, it is not
surprising that those methods did not detect any fraud within our
sample.
---------------------------------------------------------------------------
\57\ Analysis of Florida's Supplemental Nutrition Assistance
Program (SNAP) Eligibility Data, Audit Report 27002-0002-13, November
2011, page 5-7.
\58\ Ibid., page 1.
---------------------------------------------------------------------------
Table 2 summarizes detected cases of fraud, waste and abuse by
detection method. As detailed in Table 2, the income matches detected a
large number of cases of fraud (20). While most of these 20 cases were
identified through comparisons to the earned wage information reported
to the DEO, matches to the Florida Retirement System also detected
fraud. Site visits to verify household composition and residency also
detected six instances of fraud. Desk reviews led to detection of five
instances of fraudulent activity, ranging from residency issues, to un-
reported or under-reported income, to identity theft. It is also worth
noting that in several cases, fraudulent activity was discovered
through multiple detection methods, which were implemented
concurrently.
Table 2
------------------------------------------------------------------------
Detection Method Number of Cases
------------------------------------------------------------------------
Site Visit * 6
Desk Reviews 5
Income Verification--Wages 19
Income Verification--Unemployment 0
Income Verification--Florida 1
Retirement
Address Matches 0
Death Master File Match 0
PARIS Match 0
eDRS Match 0
------------------------------------------------------------------------
* Site visits conducted on sub-sample of 100 only.
As noted, investigators detected 28 instances of fraud in our
sample of 545 households.\59\ Three of those cases were found solely
through the site visits conducted on the sub-sample. The remaining 25
cases were found in the course of investigations conducted on the
entire sample of 545.\60\ The overall fraud rate is based on a
combination of the results from both the original sample and the sub-
sample. We estimate the overall rate of fraud incidence in the Florida
SNAP system to be 7.5 percent.\61\
---------------------------------------------------------------------------
\59\ Information detailing the sample by county can be found in the
Appendix.
\60\ Several of the instances of fraud were detected by both the
site visits and other methodologies.
\61\ This is calculated using the 25 cases detected in the overall
sample and the three cases identified in the sub-sample (out of 97
remaining from the sub-sample that had no fraud detection prior to the
site visits). The resulting fraud rate calculation is [((3/
97)*(545^25)) + 25]/545.
---------------------------------------------------------------------------
In addition to the 28 cases of fraud noted above, we have been
asked to note that there were an additional six recipients identified
through the desk review process which DPAF investigators believe have a
high likelihood of having fraudulently received excess SNAP funds. DPAF
has opened additional investigations into those cases and the results
are pending. However, as of the date of this report, investigators have
not yet categorized those cases as fraudulent. If some or all of those
cases are eventually revealed to have been fraudulent, we would
supplement this report at the Strike Force's request to update the
calculations. If all six cases are found to have involved fraudulent
activity, the fraud rate estimate would rise from 7.5 percent to 8.6
percent.
Sampling Error
Because our estimate is based on a sample, we cannot expect it to
be perfectly accurate. The situation is akin to flipping a coin some
number of times (the sample size) to determine if it is a fair coin.
Different samples give different estimates, and few of the samples are
likely to result in exactly 50 percent heads, so each estimate comes
with a likely error due to sampling. The sampling error is determined
primarily by the size of the sample. Thus, if we flipped a coin ten
times and the results were 60% heads, we would not be concerned about
its fairness because the sample is so small. However, if we flipped a
coin 1,000 times and the results were 60% heads, we would conclude that
the coin is not fair because 60% is ``too far away'' from 50% for a
sample of that size. More precise estimates (that is, ones with smaller
sampling error and narrower confidence intervals) require larger
samples. However, they also typically incur greater time and expense in
performing the estimation.
When we allow for the likely error from sampling, we estimate that
the fraud rate for the population of all payments is between 4.2
percent and 11.7 percent with 95% confidence. The ``95% confidence''
means that, applying our methods to many different samples of this
size, the fraud rate would lie within the calculated interval 95% of
the time.\62\
---------------------------------------------------------------------------
\62\ Note that the estimated range of the 95 percent confidence
level is not precisely centered around our estimate of 7.5 percent.
This is a standard statistical effect that occurs the further away one
gets from an estimate of 50 percent.
---------------------------------------------------------------------------
Descriptive Statistics
We have detailed below a comparison of the characteristics of those
within the sample who were found to have committed fraud to those who
did not. Such a comparison may reveal differences between the two
groups. However, we caution the reader regarding any attempt to use
applicant characteristics to profile individuals regarding their
likelihood to commit fraud. The use of averages to draw conclusions
about specific individuals or groups has any number of unforeseen
complications. Table 3 below highlights a variety of descriptive
statistics for the households in our study sample. In each case, we
show the average or proportion for the households, grouped by those
whom investigators concluded committed fraud and those they concluded
did not. We performed commonly used statistical tests (t-tests or Chi-
square tests) to determine if the averages between the two groups were
statistically significantly different. Statistically significantly
differences are those that are large enough that one is not able to
attribute them to random chance. For most characteristics, the groups
were not different. Those characteristics that were statistically
significantly different relate to the size of the household, including
both the number of children and the number of adults in the household.
Table 3. Study Sample Statistics
Characteristics of SNAP Recipients by Fraud Status
------------------------------------------------------------------------
Study Sample (n = 545)
--------------------------------
Characteristic No Fraud (n =
Fraud (n = 28) 517)
------------------------------------------------------------------------
Household Composition Means
------------------------------------------------------------------------
Number in Household (Reported) * 2.79 1.87
Number in Household (Computed) * 2.93 2.02
Number of Adults * 1.71 1.28
Number of Children (17 and under) * 1.21 0.74
Number of Adult Males 0.82 0.55
Percent of Households with at least 2 0.50 0.25
Adults *
Age of Head of Household (HHH) 40.21 44.21
Age of Adults 37.70 43.63
Age of Children * 9.73 7.11
Percent of Households where HHH is 0.75 0.63
Female
Percent of Households where HHH is U.S. 0.82 0.87
Citizen
------------------------------------------------------------------------
Monthly Income & Expenses
------------------------------------------------------------------------
Gross Income $725.75 $638.82
Shelter $406.68 $339.29
Disposable Income \1\ $319.07 $299.53
Utilities $219.82 $200.69
------------------------------------------------------------------------
SNAP related
------------------------------------------------------------------------
Percent of Households with Expedited 0.14 0.15
Application
Percent of Households with Simplified 0.75 0.66
Eligibility
------------------------------------------------------------------------
* Statistically significantly different at 5% probability.
\1\ Defined as (Gross Income^Shelter Expense).
In order to further determine whether or not these variables appear
to be statistically significantly related to fraud, we conducted
additional statistical analyses. Logistic regression analysis is a
commonly used technique in which one can control for a variety of
factors to determine whether or not they are correlated with a
categorical dependent variable, in this case committing fraud or not.
We ran regressions controlling for characteristics of the head of
household (age, gender, etc.), the number of minors, number of adults,
income and expense variables, as well as eligibility characteristics
(simplified or expedited). In each of our models, the sole variable
that was statistically significantly correlated with fraud was the
number of adults present in the household. More precisely, the greater
the number of adults, the more likely that household was to have
committed fraud.
Estimated Overpayment Rate
It is important to note that the 7.5 percent figure is a rate of
fraud incidence and not a measure of the proportion of total dollars
overpaid to fraudulent recipients. In the vast majority of instances,
the elimination of fraudulent activity would likely result in a lower
payment for recipients, but not complete ineligibility and elimination
of all benefits. Only if 100 percent of the dollars associated with
these incidents are fraudulent, or alternatively, if these incidents
are for disproportionately larger dollar figures than the average SNAP
payment, could the overpayment rate in dollar terms be 7.5 percent (or
more). While we were not able to directly calculate the reduction in
payments that would occur in the absence of the fraud that was detected
in our sample, we provide here an estimated overpayment rate in dollars
using two separate calculation methods.
The first methodology involves comparing the average monthly
payment amount received by recipients who were identified as having
misrepresented information to the average monthly payment amount in the
entire SNAP universe. It is important to recognize that these 28 cases
represent a very small sample of recipients and thus the corresponding
estimate has a potentially large sampling error. It is also important
to note that we did not compare the characteristics of those who
committed fraud to the characteristics of all individuals within the
SNAP universe. Ideally, one would want to determine if these
individuals would have been entitled to greater benefits, even in the
absence of fraud, because they possessed more of the characteristics
that correlate with higher benefits than those in the SNAP universe on
the whole. If it is the case that the individuals committing fraud are
different than the average SNAP recipient (aside from the fact they
have misrepresented information), then the estimate may suffer from
sample bias. Sample bias can occur when an estimate is based on a
sample that is not representative. While our sample of recipients used
to determine the fraud incidence rate was randomly drawn and very
likely to be representative, it may not be the case that those who
committed fraud are representative of the average recipient.
Unfortunately, that determination was beyond the scope of this study.
The recipients in this study who were identified as having
committed fraud received an average benefit in the month they were
sampled of $389.14. The average Florida SNAP recipient received a
monthly benefit of $247.30 during the months from which our sample was
drawn. If we assume the difference of $141.84 is due to fraud, we would
estimate the overpayment rate among those who commit fraud to be 36.4
percent. In order to estimate the overpayment rate for the SNAP
program, we multiply the estimated rate of fraud incidence (7.5
percent) times the estimated rate of overpayment among those who commit
fraud (36.4 percent). This yields an estimated dollar overpayment rate
for the SNAP program of approximately 2.75 percent.
The second methodology involves the use of historical information
regarding fraud loss that was provided to ERS Group by the Division of
Public Assistance Fraud. At ERS Group's request, DPAF was able to
provide average overpayment amounts based on fraud cases within the
SNAP program during the 3 year period from March, 2009 to March, 2012.
During that time, DPAF was involved in the investigation of over 6,000
cases in which fraudulent activity was found. According to DPAF, those
cases resulted in an average monthly overpayment of $241.88. In
contrast, as noted above, the average monthly SNAP payment during our
sample period was $247.30. Under the assumption that those who commit
fraud are similar to other SNAP recipients in terms of the
characteristics that define eligibility and benefits (such as income,
expenses, household composition, etc.), this represents an overpayment
rate on fraudulent cases of 49.4 percent.\63\ As above, the estimated
overpayment rate for the SNAP program would be the estimated rate of
fraud incidence (7.5 percent) multiplied by the historical fraud case
overpayment rate (49.4 percent). That resulting dollar overpayment
estimate is 3.7 percent. However, as above, there are concerns
regarding this second overpayment rate estimation as well. First, as
noted above, this estimate is dependent upon the assumption that those
who commit fraud have similar characteristics to those who do not. In
addition, this estimate is also dependent upon the assumption that the
fraud cases that have been investigated by DPAF are similar to fraud
cases on average with regard to the resulting overpayment. In most
instances, the cases that are discovered, referred to and investigated
by DPAF and subsequently result in a finding of fraud are likely to be
biased toward larger overpayment amounts. This is because DCF and DPAF
are more likely to discover, refer and investigate cases where the
potential loss due to fraud is higher than the average loss due to
fraud (discovered and not discovered). Thus, there is some likelihood
that one or both of these assumptions are violated, either of which
would lead to bias. Accordingly, it is more likely that the 3.7 percent
estimate represents an upper bound on the dollar overpayment rate.
---------------------------------------------------------------------------
\63\ $241.88/($241.88 + $247.30) = 49.4 percent.
---------------------------------------------------------------------------
It is also important to note that one type of fraudulent activity,
trafficking, was not examined by our study. Trafficking of SNAP
benefits occurs when a vendor (grocery store, mini mart, etc.)
purchases the monthly SNAP benefit from a recipient for a fraction of
its worth. The recipient receives cash, which can be spent as he or she
wishes, while the vendor is reimbursed for the entire amount of monthly
benefit. This form of fraud is not detectable by any methodology we
could readily employ. In addition, it is not entirely clear that the
SNAP benefits paid to these recipients would change based on this type
of fraud, and so it may not directly impact the overall overpayment
rate to recipients. However, it is clearly a type of fraud and it is
therefore noteworthy as part of this effort. A recent study by the USDA
indicated that approximately 8.2 percent of stores trafficked in this
manner and estimates SNAP trafficking (in dollar terms) at
approximately one percent.\64\
---------------------------------------------------------------------------
\64\ See the March, 2011 USDA FNS report entitled ``The Extent of
Trafficking in the Supplemental Nutrition Assistance Program (SNAP):
2006-2008''. See http://www.fns.usda.gov/ora/menu/Published/SNAP/FILES/
ProgramIntegrity/Trafficking2006Summary.pdf.
---------------------------------------------------------------------------
VI Concluding Remarks
The Florida Medicaid & Public Assistance Fraud Strike Force
contracted ERS Group to review information on metrics and methodologies
used to measure waste, fraud, and abuse in public assistance programs.
The Strike Force also requested we estimate the amount of fraud, waste
or abuse leading to overpayments in the Florida Food Assistance
Program. There are a number of ways in which fraud is examined in
academic studies and government programs. However, the most useful
methodology for estimating fraud within Florida's SNAP was to draw a
random sample of payments and have Florida's professional fraud
investigators examine those cases for any misrepresentation of
information, (i.e., fraud). The investigators for DPAF and DCF
discovered 28 instances of fraud within the randomly drawn sample of
545 cases. Based on the various investigative methodologies employed on
the entire sample, as well as the site visits employed on a sub-sample
of 100 cases, we estimate fraud incidence within SNAP to be 7.5
percent. There were an additional six cases with pending
investigations, which could raise that estimate to as much as 8.6
percent.
Further, we employed two methodologies to estimate the dollar
overpayment rate within SNAP, both based in part on the fraud incidence
rate estimate. First, we compared the average monthly payment amount
received by recipients who were identified as having committed fraud to
the average monthly payment amount in the entire SNAP universe.
Multiplying this average overpayment rate of 36.4 percent by the fraud
incidence rate of 7.5 percent yields an estimated dollar overpayment
rate of approximately 2.75 percent.
The second method utilized historical information, provided by
DPAF, regarding average monthly overpayment amounts on cases involving
fraud. Multiplying the average overpayment rate indicated by the DPAF
data, 49.4 percent, by the fraud incidence rate of 7.5 percent yields
an estimated dollar overpayment rate of approximately 3.7 percent.
Additionally, a recent USDA report estimates national vendor
trafficking in dollar terms at approximately one percent.
It is critical to recognize that with both of these methodologies,
the dollar overpayment estimates have the potential to be unreliable
due to the relatively small number of fraud cases identified in the
sample (28), or biased by the nature of the information on fraud
overpayment provided by DPAF. Further study of the 28 identified cases
and recalculation of their monthly benefit based on additional
information would provide a more accurate estimate of the dollar
overpayment rate in Florida's Food Assistance Program.
The two most common mechanisms by which fraud was perpetrated in
the sample were through false reporting of income and/or household
composition. While investigators employed nine different methods of
fraud detection, the vast majority of the fraud uncovered in the sample
was related to one of these two reasons. Accordingly, we recommend that
DCF, the agency tasked with administering the SNAP program, institute
computer comparison of applicant's (or re-applicant's) reported income
to that found in other state databases, including Florida wage income
reported to the Department of Economic Opportunity. We also recommend
implementation of a system in which household composition and residency
are more routinely checked. This may include partnering with a vendor
who can perform these types of checks using publicly available or
privately held databases.
We also ran regression analyses to determine if there were any
characteristics correlated with a higher likelihood of committing
fraud. While an increased number of adults in the recipient household
was correlated with an increased likelihood of fraud, we caution
stakeholders against using this information proactively.
Further, it is our understanding that households are not required
to report changes in income (or other characteristics) that have
occurred within 6 months of application (or re-application). While we
did not identify any fraud based on that criteria since that is the
rule under which the system operates, the potential for waste due to
that rule may be significant. Households with meaningful changes in
financial or other circumstances can receive what could be termed
excess benefits for as much as 6 months. Accordingly, we recommend a
review of this policy to determine if it is in the best interest of the
State of Florida.
Lastly, Florida, like many states, operates primarily in the fraud
arena under what is commonly referred to a ``pay-and-chase'' system.
Many investigations, though not all, are conducted post-eligibility and
after benefits have already been received. Recovering these benefits
after they have already been paid is difficult and typically results in
a small proportion being recouped. We recommend Florida consider a more
rigorous pre-certification system, perhaps partnering with vendors who
can provide machine learning software designed specifically to detect
this type of fraudulent activity.
Appendix
Results by County
----------------------------------------------------------------------------------------------------------------
Households (2010 Census) SNAP Households (October Study Sample (Total) Study Sample (Fraud)
-------------------------- 2011) ---------------------------------------------------
County --------------------------
Number Percent Percent Number Percent Number Percent
Share Number Share Share Share
----------------------------------------------------------------------------------------------------------------
Alachua 100,516 1.35% 20,413 1.14% 13 2.39% -- --
Baker 8,772 0.12% 2,384 0.13% -- -- -- --
Bay 68,438 0.92% 16,964 0.95% 4 0.73% 1 3.57%
Bradford 9,479 0.13% 2,807 0.16% 1 0.18% -- --
Brevard 229,692 3.10% 41,171 2.31% 7 1.28% -- --
Broward 686,047 9.24% 142,139 7.97% 55 10.09% 4 14.29%
Calhoun 5,061 0.07% 1,373 0.08% -- -- -- --
Charlott 73,370 0.99% 11,248 0.63% 3 0.55% -- --
e
Citrus 63,304 0.85% 12,729 0.71% 4 0.73% -- --
Clay 68,792 0.93% 10,895 0.61% 5 0.92% -- --
Collier 133,179 1.79% 19,911 1.12% 8 1.47% -- --
Columbia 24,941 0.34% 7,543 0.42% 1 0.18% -- --
DeSoto 11,445 0.15% 3,665 0.21% 2 0.37% -- --
Dixie 6,316 0.09% 2,146 0.12% 1 0.18% -- --
Duval 342,450 4.61% 91,938 5.16% 40 7.34% -- --
Escambia 116,238 1.57% 30,803 1.73% 8 1.47% 2 7.14%
Flagler 39,186 0.53% 6,589 0.37% 1 0.18% -- --
Franklin 4,254 0.06% 960 0.05% -- -- -- --
Gadsden 16,952 0.23% 7,134 0.40% 5 0.92% 1 3.57%
Gilchris 6,121 0.08% 1,590 0.09% -- -- -- --
t
Glades 4,533 0.06% 655 0.04% -- -- -- --
Gulf 5,335 0.07% 1,309 0.07% -- -- -- --
Hamilton 4,617 0.06% 1,875 0.11% 1 0.18% -- --
Hardee 8,245 0.11% 2,971 0.17% 1 0.18% -- --
Hendry 12,025 0.16% 5,125 0.29% 2 0.37% 1 3.57%
Hernando 71,745 0.97% 15,913 0.89% 4 0.73% -- --
Highland 42,604 0.57% 9,112 0.51% 2 0.37% -- --
s
Hillsbor 474,030 6.39% 134,121 7.52% 48 8.81% 4 14.29%
ough
Holmes 7,354 0.10% 2,412 0.14% 1 0.18% -- --
Indian 60,176 0.81% 10,747 0.60% 2 0.37% -- --
River
Jackson 17,417 0.23% 4,578 0.26% -- -- -- --
Jefferso 5,646 0.08% 1,453 0.08% -- -- -- --
n
Lafayett 2,580 0.03% 481 0.03% -- -- -- --
e
Lake 121,289 1.63% 23,721 1.33% 7 1.28% -- --
Lee 259,818 3.50% 51,963 2.91% 17 3.12% 1 3.57%
Leon 110,945 1.50% 20,447 1.15% 7 1.28% -- --
Levy 16,404 0.22% 4,359 0.24% 1 0.18% -- --
Liberty 2,525 0.03% 687 0.04% -- -- -- --
Madison 6,985 0.09% 2,308 0.13% 1 0.18% -- --
Manatee 135,729 1.83% 26,774 1.50% 8 1.47% -- --
Marion 137,726 1.86% 34,389 1.93% 13 2.39% -- --
Martin 63,899 0.86% 8,338 0.47% 2 0.37% 1 3.57%
Miami- 867,352 11.69% 362,450 20.33% 94 17.25% 8 28.57%
Dade
Monroe 32,629 0.44% 5,435 0.30% -- -- -- --
Nassau 28,794 0.39% 4,866 0.27% 1 0.18% -- --
Okaloosa 72,379 0.98% 10,351 0.58% 5 0.92% -- --
Okeechob 14,013 0.19% 4,663 0.26% 1 0.18% -- --
ee
Orange 421,847 5.68% 108,594 6.09% 25 4.59% -- --
Osceola 90,603 1.22% 33,380 1.87% 14 2.57% -- --
Palm 544,227 7.33% 93,010 5.22% 22 4.04% 1 3.57%
Beach
Pasco 189,612 2.56% 40,368 2.26% 13 2.39% -- --
Pinellas 415,876 5.60% 85,889 4.82% 20 3.67% 1 3.57%
Polk 227,485 3.07% 62,197 3.49% 18 3.30% 2 7.14%
Putnam 29,409 0.40% 11,135 0.62% 7 1.28% -- --
St. 75,338 1.02% 8,224 0.46% 2 0.37% 1 3.57%
Johns
St. 108,523 1.46% 26,189 1.47% 11 2.02% -- --
Lucie
Santa 56,910 0.77% 8,081 0.45% 1 0.18% -- --
Rosa
Sarasota 175,746 2.37% 26,678 1.50% 9 1.65% -- --
Seminole 164,706 2.22% 23,976 1.34% 6 1.10% -- --
Sumter 41,361 0.56% 5,017 0.28% -- -- -- --
Suwannee 15,953 0.21% 4,589 0.26% -- -- -- --
Taylor 7,920 0.11% 2,277 0.13% 1 0.18% -- --
Union 4,048 0.05% 1,351 0.08% -- -- -- --
Volusia 208,236 2.81% 48,887 2.74% 15 2.75% -- --
Wakulla 10,490 0.14% 2,003 0.11% 1 0.18% -- --
Walton 22,301 0.30% 2,980 0.17% 4 0.73% -- --
Washingt 8,864 0.12% 2,307 0.13% -- -- -- --
on
-------------------------------------------------------------------------------------------------------
Total 7,420,802 1,783,037 545 28
----------------------------------------------------------------------------------------------------------------
______
Submitted Questions
Response from Tikki Brown, Assistant Commissioner, Children and Family
Services Administration, Minnesota Department of Human Services
Question Submitted by Hon. David Scott, a Representative in Congress
from Georgia
Question. Ms. Brown, are SNAP applicants and recipients required to
provide a Social Security Number to receive and retain SNAP benefits?
Answer. Hon. David Scott,
It was a pleasure to testify at the June 7, 2023, Congressional
Full Committee hearing, Innovation, Employment, Integrity, and Health:
Opportunities for Modernization in Title IV. Thank you for your recent
question following my testimony: Are SNAP applicants and recipients
required to provide a Social Security Number to receive and retain SNAP
benefits?
In Minnesota, applicants must provide a Social Security Number.
They do not have to provide the card, just the number, which is entered
into the eligibility system, where a data exchange occurs with the
Social Security Administration to verify the number that was entered.
If the number is verified, the system enters a ``V'' in the system next
to the Social Security Number to indicate it's been verified. If
applicants don't have a number, they must apply for one, and provide
proof they applied.
For participants, the system will generate a message after 60 days
if the Social Security Number has not been verified. There is a process
for Supplemental Nutrition Assistance Program workers to follow up with
the participants. If the workers receive no response, after follow-up,
the participants will be removed from the SNAP grant.
I hope this fully answers your question.
Tikki Brown,
Assistant Commissioner,
Children and Family Services.
Response from Patrick J. Stover, Ph.D., Director, Institute for
Advancing Health Through Agriculture, Texas A&M University
Questions Submitted by Hon. Glenn Thompson, a Representative in
Congress from Pennsylvania
Question 1. Dr. Stover, your testimony mentions nutrition
education; what is your take on programs like the Expanded Food and
Nutrition Education Program (EFNEP) and SNAP-Ed, and do you have ideas
for carrying out a systematic evaluation to see where they are
impactful versus not?
Answer. Nutrition education programs provide individuals who
participate in assistance programs with strategies to meet nutrient
needs and reduce the risk of diet-related chronic diseases. The largest
nutrition education programs in terms of investment and reach are SNAP
Education (SNAP-Ed), the WIC (Women, Infants and Children) program
(that contains an educational component), and the Expanded Food and
Nutrition Education Program (EFNEP). For some programs, the education
component is voluntary (SNAP-Ed and EFNEP) whereas others are not
(WIC). Each of these programs has a different level of rigor in the
program evaluation of the education component and in scientific
evaluations that have been carried out on these programs, some of which
has been quantified in terms of return on investment. I believe that
given the expense of these programs that a systematic program and
scientific evaluation remains as a key need, recognizing that SNAP-Ed
and EFNEP, but not WIC, are under the House Committee on Agriculture's
jurisdiction.
SNAP-Ed, WIC nutrition education, and EFNEP are administered by
state and local government agencies who subcontract with implementing
agencies including nonprofits, health departments and hospitals,
daycare centers and schools, community centers, food banks, land-grant
universities, and cooperative extension services. This distributed
network of agencies enables innovation in designing programs tailored
to the needs of local communities, but the distributed implementation
framework presents challenges for systematic program evaluation due to
variability in delivery, content, data collection, and reporting
measures, which are sometimes due to policy constraints at the
institutional or state level.1-3 When asked to evaluate the
effectiveness of USDA nutrition education programs in 2019, the
Government Accountability Office (GAO) concluded that data on state-
administered program effectiveness, reported at the state level, are
not sufficient for aggregation and review at the Federal level.\4\
While innovation and consideration of local and cultural contexts
should be encouraged in the delivery of nutrition education programs, a
program common evaluation framework that includes a common set of core
measures, such as the RE-AIM \5\ (Reach, Effectiveness, Adoption,
Implementation, and Maintenance) framework, is needed for robust
evaluation of program effectiveness. There is an additional need for
rigorous scientific evaluations of these programs outside of
programming evaluations. Collection of common and impactful outcome
measures is needed to allow data aggregation, comparison of program
learning outcomes and systematic evaluation of the impact and cost
effectiveness of all Federal nutrition education programs. It would
also permit the identification of best practices and innovations in the
delivery of these education programs.
Scientific Evaluation: Scientific evaluations should be performed
by investigators external to these educational programs yet working
hand-in-hand with program administrators to allow for more rigorous
study designs, use of gold-standard and rigorous assessments, and the
mitigation of program biases that all promote potentially stronger
evidence. Such evaluations could be optimally funded through
competitive funding processes that support creative approaches and
collaborative teams comprised of researchers and program
administrators. Currently no mechanisms for external scientific
evaluations for these programs exist. The scientific evaluations that
have been completed, including the few studies on program impact on
program goals (e.g., improving diet and food security), have been
investigator driven proposals awarded from a variety of general funds,
none of which were specifically marked for nutrition education
evaluations.
Program Evaluation: There are opportunities to harmonize approaches
and program evaluation of all nutrition education programs for public
benefit and to develop consensus on the intended and desired outcomes
of these programs. Currently, SNAP-Ed programs are evaluated through
the SNAP-Ed Evaluation Framework, which provides 51 indicators each
with multiple outcome measures and data collection methods. State
agencies select from this list of indicators to evaluate their
nutrition education programs at the individual, organizational, and
sectoral levels with metrics for readiness and capacity, changes,
effectiveness and maintenance, and outcomes. Seven of the indicators
are prioritized by the USDA, but none are mandatory, and the data are
often not comparable even if the same indicators are used because each
indicator includes multiple data collection methods and outcome
measures. WIC education programs are periodically evaluated through
state-developed reports, national surveys, and pilot studies.\6\ EFNEP
programs have the most consistent evaluation standards, and every EFNEP
intervention collects demographic data, food questionnaire data, and
behavior change data captured in 24 hour dietary recalls when
individuals enter and exit a nutrition education program to track
behavior change. EFNEP data is reported through an integrated data tool
called the Web-based Nutrition Education Evaluation and Reporting
System (WebNEERS), which can be used for program management and impact
assessment. Data from this system can be aggregated to estimate program
effectiveness across state programs and at the national level. Data to
date suggest that WIC and EFNEP have a large ROI, with less consistent
evidence available for SNAP-Ed. This may be largely driven by the
heterogeneity of content delivery and the lack of systematic evaluation
of program effectiveness. Some means to address this gap are underway
https://snaped.fns.usda.gov/sites/default/files/documents/N-
PEARS_Memo_508_0.pdf. *
---------------------------------------------------------------------------
* Editor's note: items annotated with are retained in Committee
file.
---------------------------------------------------------------------------
Consistent, rigorous, and nationally-harmonized evaluation of
nutrition education program effectiveness may be best performed through
the Land-Grant universities and cooperative extension services. They
have the knowledge, experience, expertise, and community relationships
to monitor data collection and conduct common dissemination and
evaluation of nutrition education programs across states or
territories. Land-grant institutions are also ideally positioned to
carry out external scientific evaluations as they usually house
researchers representing the many important disciplines necessary for
effective rigorous scientific evaluation, for example, nutrition,
statistics, agriculture economics, family studies, data science, and
health sciences, among many others. These evaluations could employ
common data models, evaluation frameworks, and data harmonization,
allowing comparison and review at the Federal level through the USDA,
who in turn could quickly update nutrition education program guidelines
and policies with the latest empirical evidence.
Notes
1. Yetter D., Tripp S. SNAP-Ed FY2019: A Retrospective Review of LGU
SNAP-Ed Programs and Impacts.; 2020. https://www.nifa.usda.gov/sites/
default/files/resource/LGU-SNAP-Ed-FY2019-Impacts-Report-12-16-
2020_508.pdf.
2. Atoloye A.T., Savoie-Roskos M.R., Guenther P.M., Durward C.M.
Effectiveness of Expanded Food and Nutrition Education Program in
Changing Nutrition-Related Outcomes Among Adults With Low Income: A
Systematic Review. J. Nutr. Educ. Behav. 2021; 53(8): 691-705.
doi:10.1016/j.jneb.2021.03.006
3. Rivera R.L., Maulding M.K., Eicher-Miller H.A. Effect of
Supplemental Nutrition Assistance Program--Education (SNAP-Ed) on food
security and dietary outcomes. Nutr. Rev. 2019; 77(12): 903-921.
doi:10.1093/nutrit/nuz013
4. Nutrition Education USDA: Actions Needed to Assess Effectiveness,
Coordinate Programs, and Leverage Expertise. United States Government
Accountability Office; 2019. Accessed December 20, 2022. https://
www.gao.gov/assets/gao-19-572.pdf.
5. Glasgow R.E., Vogt T.M., Boles S.M. Evaluating the public health
impact of health promotion interventions: the RE-AIM framework. Am. J.
Public Health. (1999) 89: 1322-7. doi: 10.2105/AJPH.89.9.1322
6. U.S. Department of Agriculture, Food and Nutrition Service,
Office of Policy Support. WIC Nutrition Education Study: Phase II Final
Report WIC Nutrition Education Study: Phase II Final Report, by Sheryl
Cates, Jonathan Blitstein, Linnea Sallack, Karen Deehy, Lorrene
Ritchie, Nila Rosen, Shawn Karns, Katherine Kosa, Gina Kilpatrick,
Stacy Bell, Caroline Rains. Project Officer: Karen Castellanos-Brown.;
2018.
Question 2. Dr. Stover, I have long been frustrated by the current
Dietary Guidelines for Americans process and outcomes, especially
because they underpin most Federal nutrition programs. What are we
doing wrong, and how can we get it right?
Answer. Briefly, every 5 years a scientific committee (Dietary
Guidelines Advisory Committee; DGAC) is formed to evaluate the
scientific literature and deliver a report to HHS and USDA, who in turn
develop the Dietary Guidelines for Americans (DGA). While I stand
behind the DGA, there is always room for improvement. My major concerns
are consistent with those raised by the National Academies of Sciences,
Engineering and Medicine (NASEM) that are highlighted below. Chiefly,
there are serious conflict of interest (COI) concerns in the Systematic
Review process and the need for a tripartite committee model (discussed
in the NASEM report)--neither of which is being fully addressed in the
current cycle.
NASEM recently conducted a study evaluating the process to develop
the DGA, 2020-2025. Two reports were generated from this study. In
2022, a midcourse report was published for which I served as an
external reviewer,\1\ and the final report that was published in
2023.\2\ The reports focused on progress made in meeting the previous
recommendations from a 2017 NASEM report ``Redesigning the Process for
Establishing the Dietary Guidelines for Americans.'' \3\
The reports 1, 2 evaluated how effectively the seven
recommendations from the 2017 report were implemented. The 2017
recommendations related to: (1) reorganizing the DGAC structure and
responsibilities; (2) increasing transparency in articulating the
inclusion/exclusion of DGAC recommendations into the final DGA
guidelines; (3) the need to separate the roles of the Nutrition
Evidence Systematic Reviews (NESR) from the DGAC; (4) ensure NESR
systematic reviews align with best practices including continuous
training and technology infrastructure to conduct reviews; (5) improve
food patten modeling; (6) standardize the methods and criteria for
establishing nutrients of concern; and (7) implement systems approaches
into the DGA. I will focus my comments on the organizational structure
of NESR (#3 above) and the NESR systematic review methodology (#4
above) as these two elements are critical to ensuring transparent,
objective and science-informed policy.
The importance of having a rigorous and transparent scientific
process to establish the DGAs cannot be overstated, and it is critical
that the concerns raised regarding the creation of the DGAs, which
emerge every cycle, be addressed. The appreciation of the importance of
food, nutrition and nutrition science in public health has never been
greater, as diet-related chronic disease is a major driver of health
care costs. Now more than ever we need to ensure the rigor of the
science that underpins the DGAs engenders confidence and public trust
in the DGAs, leading to public acceptance and adherence to the
recommendations. Scientific integrity is key to achieving these goals.
The government scientists involved in the current process are committed
to improving public health, but there are both methodological and
structural limitations to the current processes. There continues to be
a need to increase adherence to rigorous and transparent processes used
to conduct the systematic reviews that are the scientific underpinning
of the DGAs.
The methods used to evaluate and grade the strength of the
scientific evidence in support of the DGA recommendations, which have
recently been published,\4\ should be improved. The methods and grading
rubric used by NESR differ from the gold standard method in other areas
of health, which is GRADE (Grading of Recommendations, Assessment,
Development, and Evaluations). Furthermore, DGAC members assign the
evidence rating with guidance from NESR, and then make recommendations
based on that same evidence. This is a potential source of bias because
the same people who are rating the evidence are then turning around and
using that same evidence for recommendations.
The second concern relates to the intrinsic conflict of interest of
having the same institution (i.e., the USDA) oversee both the conduct
of the evidence synthesis by NESR and be responsible for policy
decisions (i.e., DGAs) based on the evidence review. The 2017 NASEM
report called for greater differentiation between NESR and DGAC.
Fundamental to evidence-based policy is a firewall between those who
generate the systematic review and those who use the systematic review
as evidence for decision making; otherwise, you run the risk of bias
and ``policy informed evidence'' (see above). Best practices for
science integrity and science-informed policy include having a distinct
third party conduct the scientific evidence synthesis. Similarly,
better processes are needed regarding the selection of the specific
questions the DGAC is asked to address, especially when there are not
sufficient high-quality data available to make assessments and
recommendations.
Finally, federally-funded scientific research should be prioritized
to strengthen the evidence base for establishing both nutrient and
food-based guidance for the public and investments made in data-science
technologies that allow more rapid translation of scientific evidence
into nutrition policy, practice and guidance. This would allow for
regular updates for the Dietary Reference Intake values for nutrients,
which are a foundation of the DGAs.
Notes
1. National Academies of Sciences, Engineering, and Medicine. 2022.
Evaluating the process to develop the Dietary Guidelines for Americans,
2020-2025: A midcourse report. Washington, D.C.: The National
Academies Press. https://doi.org/10.17226/26406.
2. National Academies of Sciences, Engineering, and Medicine. 2023.
Evaluating the process to develop the Dietary Guidelines for Americans,
2020-2025: Final report. Washington, D.C.: The National Academies
Press. https://doi.org/10.17226/26653.
3. National Academies of Sciences, Engineering, and Medicine. 2017.
Redesigning the process for establishing the Dietary Guidelines for
Americans. Washington, D.C.: The National Academies Press. doi: https://
doi.org/10.17226/24883.
4. Spill, M.K., English, L.K., Raghavan, R., Callahan, E., Gungor,
D., Kingshipp, B., Spahn, J., Stoody, E., and Obbagy, J. 2022.
Perspective: USDA Nutrition Evidence Systematic Review Methodology:
Grading the Strength of Evidence in Nutrition- and Public Health-
Related Systematic Reviews. Adv. Nutr.; 13: 982-991; doi: https://
doi.org/10.1093/advances/nmab147.
Question Submitted by Hon. Mike Bost, a Representative in Congress from
Illinois
Question. Dr. Stover, you mentioned that through your research, you
have documented health outcomes among SNAP participants. Can you
discuss the metrics that you used to quantify those health outcomes? Do
you believe there is a benefit to utilizing these metrics in nutrition
programs and particularly SNAP, to evaluate participants' health and
nutrition, so that once they reach a certain metric they can begin to
transition off the program?
Answer. SNAP is a supplemental nutrition program whose purpose is
to provide food to address instances of hunger and food insecurity. As
currently designed and administered, it is not intended to be a health
promotion program; there are no systematic evaluation metrics employed
that would include lowering rates of diet-related chronic disease and
related health care costs.
The IHA, an entity of the Texas A&M University System, is currently
conducting a systematic review of the literature that is focused on
health-related outcomes by comparing people who are eligible and
participate in SNAP to people who are SNAP-eligible participants but do
not participate in SNAP. The outcomes to be evaluated include household
food insecurity; food insufficiency; diet quality; and dietary intake
of fruits, vegetables, whole grains, meat/meat alternatives, milk and
dairy, sodium, added sugars, saturated fat and fiber.
The review will also evaluate health outcomes including
anthropometrics (e.g., weight status, BMI), cardiovascular disease
markers and outcomes, and Type 2 diabetes outcomes. The analyses are
now in progress, and we anticipate a completion date in 2024.
Response from Angela K. Rachidi, Ph.D., Research Fellow in Poverty
Studies, American Enterprise Institute
Question Submitted by Hon. Mike Bost, a Representative in Congress from
Illinois
Question. Dr. Rachidi, you mentioned that through your research,
you have documented health outcomes among SNAP participants. Can you
discuss the metrics that you used to quantify those health outcomes? Do
you believe there is a benefit to utilizing these metrics in nutrition
programs and particularly SNAP, to evaluate participants' health and
nutrition, so that once they reach a certain metric they can begin to
transition off the program?
Answer. In my study with Thomas O'Rourke ``Promoting Mobility
Through SNAP: Toward Better Health and Employment Outcomes'', we used
data from the nationally representative National Health Interview
Survey (NHIS). We explored the following health outcomes (all self-
reported): health limitations to work, ever diagnosed with a diet-
related disease, obesity, ratings of health status (poor to excellent),
and reports of feeling hopeless or worthless. However, it would be
challenging to use these measures directly in administering or
assessing SNAP because many other factors contribute to these health
conditions. Rather, I would recommend metrics that reflect consumption
while people are receiving SNAP--the quantity and quality of foods
people purchase and eat. The Healthy Eating Index is one useful metric.
Also, data on the types of foods SNAP participants purchases with
benefits would be useful. Finally, reports of what people eat would
also be helpful.
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