Academy Comments to USDA re Proposed Rule: ABAWDs

March 13, 2019

Brandon Lipps, JD
Acting Deputy Undersecretary
Food, Nutrition and Consumer Services
c/o Certification Policy Branch
SNAP Program Development Division
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, Virginia 22302

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

Dear Mr. Lipps:

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Certification Policy Branch at the SNAP Program Development Division of the U.S. Department of Agriculture related to its proposed rule, "Supplemental Nutrition Assistance Program (SNAP): Requirements for Able-Bodied Adults Without Dependents (ABAWDs) (RIN 0584-AE57)," published in the Federal Register originally on February 1, 2019. Representing over 104,000 registered dietitian nutritionists (RDNs);1 nutrition and dietetic technicians, registered (NDTRs); and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation’s health through food and nutrition.

The Academy strongly opposes the proposed rule that would limit state flexibility regarding area waivers and individual exemptions impacting an estimated 755,000 people. We oppose this rule for two reasons: 1) it seeks to circumvent the bipartisan, bicameral effort of Congress to review and reauthorize SNAP in the 2018 Farm Bill — a Farm Bill that had historical bipartisan support and 2) it takes state flexibility away from providing waivers without any real investment or plan to support and encourage work.

A. Academy Position on Food Insecurity

The Academy is committed to improving the health of Americans by ensuring access to a nourishing, safe and affordable food supply. The dietetics practitioner and nutrition educators consider the health, safety and welfare of the public at all times. The Academy's guiding principle is our commitment to improving health for all, especially those most susceptible to food insecurity. It is the position of the Academy that systematic and sustained action is needed to achieve food and nutrition security in the United States. To achieve food security, effective interventions are needed, along with adequate funding for, and increased utilization of, food and nutrition assistance programs; inclusion of nutrition education in such programs; strategies to support individual and household economic stability; and research to measure impact on food insecurity and health related outcomes.2

B. SNAP Reduces Food Insecurity and Improves Health Outcomes

SNAP is an effective and efficient program, and given the improved health and reduced health care costs associated with reductions in food insecurity, the Academy encourages initiatives that ensure more eligible people are connected to and are benefitted by the program. Food insecurity significantly impacts the health and well-being of individuals and is a risk factor for negative psychological and health outcomes.3 It also increases the prevalence and severity of diet-related disease, such as obesity, type 2 diabetes, heart disease, stroke and some cancers.4,5,6

Additionally, because of limited financial resources, those with food insecurity may use coping strategies to stretch budgets in a manner harmful for health, such as engaging in cost-related medication underuse or non-adherence;7,8,9 postponing or forgoing preventive services or needed medical interventions.

Overall, research shows that SNAP is effective at reducing food insecurity.10,11,12 According to one estimate, SNAP reduces food insecurity by approximately 30 percent13 and nearly one in eight American households experience food insecurity during the year.14

Research demonstrates that SNAP reduces health care utilization and costs.15,16,17 For example, a national study reveals that SNAP participation is associated with lower health care costs.18 On average, low-income adults participating in SNAP incurred health care costs nearly 25 percent lower over 12 months, including those paid by private or public insurance, than similarly situated adults not participating in SNAP.

SNAP improves child, adult and senior health outcomes, including physical and mental health.19 It increases the probability of self-reporting "excellent" or "good health,"20 lowers the risk of poor glucose control for people with diabetes21 and has a protective effect on mental health.22 SNAP also helps reduce stress for struggling individuals and families worried about finances, which is significant given the high correlation of stress with poor health outcomes.23

C. The Academy Supports Evidence-based Programs to Encourage Work

The Academy supports efforts to help low-income individuals develop the skills necessary to acquire steady, reliable work and recognizes that promotion of work is an integral piece of the puzzle to address food insecurity. However, we oppose making food access more difficult by penalizing individuals who are having difficulty accessing and documenting sufficiently meaningful work or employment and training opportunities, as such penalties do not align with the research showing what actually helps people gain the employment and skills that can help lift them out of poverty.24

Rather than finalizing the flawed provisions of this proposed rule that would eliminate food assistance for a cohort of struggling Americans and fail to achieve its intended purposes, the Academy supports efforts to gather best practices, invest in and provide assistance on how to actually and effectively get people back to work. In fact, the 2014 Farm Bill established and funded—and the 2018 Farm Bill further invested in—ten pilot programs to examine best practices for SNAP employment and training. It would surely be a more prudent use of time, money and other federal resources for USDA to consider the data, best practices and lessons learned from these pilot programs before seeking to make policy and programmatic changes. Moreover, delaying any finalization of this proposed rule until actionable results from the pilot programs are available is more likely to achieve the USDA's desired policy goal of fostering self-sufficiency and encouraging more ABAWDs to engage in work or work activities.

Some state and local leaders in the adult education and workforce development sectors have worked hard over the past decade to intentionally engage SNAP participants in high-quality programs and develop partnerships for SNAP Employment and Training (E&T). These efforts, which are still in early stages, require substantial resources and capacity to deliver outcomes. Investment in these quality high-intensity programs will likely shift as some states seek to spread limited SNAP E&T resources thinly to help more people meet time limit rules. However, low-intensity SNAP E&T programs have proven to be ineffective in moving SNAP recipients into jobs that will allow them to achieve economic security.25

Unlike work reporting requirements in most public assistance programs, states have no obligation under the SNAP time limit rules to offer any skills training, employment services or transportation assistance to individuals before cutting them off assistance. Most states lack adequate funding to serve all individuals subject to the time limits, regardless of the quality of programming offered26. Historically, many states have chosen not to offer work or training opportunities to individuals subject to the time limits.27 We therefore expect that a large number of people will lose their SNAP benefits, resulting in significant increases in food insecurity, worsened health outcomes and fewer SNAP funds injected into the economies of low and middle income communities across the nation.

D. Conclusion

The Academy appreciates the opportunity to submit comments to the Certification Policy Branch at the SNAP Program Development Division of the U.S. Department of Agriculture related to its proposed rule regarding "Supplemental Nutrition Assistance Program (SNAP): Requirements for Able-Bodied Adults Without Dependents (RIN 0584-AE57)." We urge USDA to amend the this proposed rule to better assist low-income individuals back to work without limiting access to nutritious food, or at minimum to delay finalizing the rule until actionable results are available from the aforementioned pilot programs. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Liz Campbell at 202-775-8277 ext. 6021 or by email at ecampbell@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Liz Campbell, MA, RD
Senior Director
Legislative & Government Affairs
Academy of Nutrition and Dietetics


1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.

2 Holben, D. (2010). Position of the American Dietetic Association: Food Insecurity in the United States. Journal of the American Dietetic Association. 110(9), 1368-1377.

3 Hartline-Grafton, H. (2017). The Impact of Poverty, Food Insecurity, & Poor Nutrition on Health and Well-Being. Washington, DC: Food Research & Action Center.

4 Franklin B. Jones, A., Love, D., Puckett, S., Macklin, J., & White-Means, S. (2012). Exploring mediators of food insecurity and obesity: a review of recent literature. Journal of Community Health. 37(1), 253-264.

5 Berkowitz, S., A., Karter, A., J., Corbie-Smith, G., Seligman, H. K., Ackroyd, S. A., Barnard, L. S., Atlas, S. J., & Wexler, D. J. (2018). Food insecurity, food “deserts,” and glycemic control in patients with diabetes: a longitudinal analysis. Diabetes Care, 19, 171981.

6 Gregory, C., A., & Coleman-Jensen, A. (2017). Food insecurity, chronic disease and health among workingage adults. Economic Research Report, 235. Washington, DC: U.S. Department of Agriculture, Economic Research Service.

7 Herman, D., Afulani, P., Coleman-Jensen, A., & Harrison, G. G. (2015). Food insecurity and cost-related medication underuse among nonelderly adults in a nationally representative sample: American Journal of Public Health, 105(10), 48-59.

8 Afulani, P., Herman, D., Coleman-Jensen, A., & Harrison G. G. (2015). Food insecurity and health outcomes among older adults: The role of cost-related medication underuse. Journal of Nutrition in Gerontology and Geriatrics, 34(3), 319-343.

9 Knight, C. K., Probst, J. C., Liese, A., D., Sercy, E., & Jones, S.J. (2016). Household food insecurity and medication "scrimping" among US adults with diabetes. Public Health Nutrition, 19(6), 1103-1111.

10 Mabli, J., & Worthington, J. (2014). Supplemental Nutrition Assistance Program participation and child food security. Pediatrics, 133(4), 1-10.

11 Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.

12 Nord, M. (2012). How much does the Supplemental Nutrition Assistance Program alleviate food insecurity? Evidence from recent programme leavers. Public Health Nutrition, 15(5), 811-817.

13 Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.

14 Coleman-Jensen, A., Rabbit, M. P., Gregory, C. A. & Singh, A. (2018). Household food insecurity in the United States in 2017. Economic Research Service Report, 256, Washington, DC: U.S. Department of Agriculture, Economic Research Service.

15 Gregory, C. A., & Deb, P. (2015). Does SNAP improve your health? Food Policy, 50, 11-19.

16 Berkowitz, S. A., Seligman, H. K., Rigdon, J., Meigs, J. B., & Basu, S. (2017). Supplemental Nutrition Assistance Program (SNAP) participation and health care expenditures among low-income adults. JAMA Internal Medicine, 177(11), 1642-1649.

17 Seligman, H. K., Bolger, A. F., Guzman, D., Lopez, A., & Bibbins-Domingo, K. (2014). Exhaustion of food budgets at month’s end and hospital admissions for hyperglycemia. Health Affairs, 33(1), 116-123.

18 Berkowitz, S. A., Seligman, H. K., Rigdon, J., Meigs, J. B., & Basu, S. (2017). Supplemental Nutrition Assistance Program (SNAP) participation and health care expenditures among low-income adults. JAMA Internal Medicine, 177(11), 1642-1649.

19 Hartline-Grafton, H. (2017). SNAP and Public Health: The Role of the Supplemental Nutrition Assistance Program in Improving the Health and Well-Being of Americans. Washington, DC: Food Research & Action Center.

20 Gregory, C. A., & Deb, P. (2015). Does SNAP improve your health? Food Policy, 50, 11-19.

21 Mayer, V. L., McDonough, K., Seligman, H., Mitra, N., & Long, J. A. (2016). Food insecurity, coping strategies and glucose control in low-income patients with diabetes. Public Health Nutrition, 19(6), 1103-1111.

22 Leung, C. W., Epel, E. S., Willett, W. C., Rimm, E. B., & Laraia, B. A. (2015). Household food insecurity is positively associated with depression among low-income Supplemental Nutrition Assistance Program participants and income-eligible nonparticipants. Journal of Nutrition, 145(3), 622-627.

23 Juster, R-P., McEwen, B. S., & Lupien, S. J. (2010). Allostatic load biomarkers of chronic stress and impact on health and cognition. Neuroscience and Biobehavioral Reviews, 35(1), 2-16.

24 Ladonna Pavetti, Work Requirements Don't Cut Poverty, Evidence Shows, Center on Budget and Policy Priorities, June 2016.

25 Ibid.

26 Nune Phillips, SNAP and Work, Center for Law and Social Policy, January 2018.

27 Ibid.