April 9, 2018
Ms. Sasha Gersten-Paal
SNAP Program Development Division
Food and Nutrition Service
United States Department of Agriculture
3101 Park Center Drive, Rm 812
Alexandria, Virginia 22302
Re: "Supplemental Nutrition Assistance Program: Requirements and Services for Able-Bodied Adults Without Dependents; Advance Notice of Proposed Rulemaking" (Docket No. FNS-2018-0004)
Dear Ms. Gersten-Paal:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service (FNS) at the U.S. Department of Agriculture (USDA) related to its advanced notice of proposed rulemaking (ANPR), "Supplemental Nutrition Assistance Program: Requirements and Services for Able-Bodied Adults Without Dependents; Advance Notice of Proposed Rulemaking" (Docket No. FNS-2018-0004) published in the Federal Register on February 23, 2018. Representing over 100,000 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 accelerating improvements in global health and well-being through food and nutrition in part through ameliorating food insecurity among Americans.
The Academy welcomes the opportunity to work with the USDA as it considers revisions to regulations, noting that we oppose any harmful proposals or changes to regulations that materially change the structure of SNAP or reduce funding for SNAP. Instead, we support easing the regulatory burden of current brief time limits for beneficiaries not employed or in a work or training program In addition, to accomplish the USDA "advance its goal of addressing food insecurity by helping able-bodied SNAP recipients obtain and maintain employment," it is essential that the USDA evaluate the impact of any proposed changes in work requirements on food insecurity prior to enacting material changes. Finally, the USDA should ensure that efforts to offer meaningful employment and training opportunities does not come at the cost of cuts in SNAP benefits.
A. Academy of Nutrition and Dietetics' Position on Food Security
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
The Academy is committed to improving the health of Americans by ensuring access to a nourishing, safe and affordable food supply, and the dietetics practitioner and nutrition educators consider the health, safety, and welfare of the public at all times.3 The Academy's guiding principle that forms the basis of our recommendations is our commitment to improving health for all, especially those most susceptible to and who experience food insecurity.4
B. SNAP, Food Security, and Work Requirements
SNAP is our nation's largest and most far reaching anti-hunger program. SNAP helps put food on the table for more than 42 million low-income people each month, including workers who earn wages so low they cannot afford to purchase food, workers with unpredictable schedules, and those in-between jobs.5 Research shows SNAP is effective in preventing food insecurity, and is linked with improved health outcomes and lower health care costs.6 SNAP participation is also a critical way to reach low-income Americans, through education (both SNAP-Ed and community health initiatives) and incentives for healthy purchases. Participating in SNAP is critical to efforts to improve the diet and health of low-income households and we urge USDA to find ways to keep this vulnerable population connected to basic food assistance.
However, the time limit in place imposes a substantial regulatory burden by preventing people from accessing food assistance benefits after three months even if they want to work and are looking for a job but have not been able to find one. The restrictive time limit rule undermines the effectiveness of SNAP as a safety net;7 removing food benefits does not help workers find a better job or find work faster.8
States are allowed to suspend the three-month time limit in areas with high and sustained unemployment. During the economic recession, many states qualified for the waiver and opted to waive the rule. As the economy improved, many states dropped the waiver resulting in an estimated 500,000 to 1 million people in 22 states losing their benefits.9 The Academy notes this administration's support for regulatory reform that provides states with increased flexibility and supports states maintaining the flexibility to use the existing waiver process when needed to effectuate the goals of SNAP.
The Academy appreciates the opportunity to comment on the ANPR related to SNAP waivers for work requirements, and we look forward to an ongoing dialogue to find effective ways to accomplish the goals of ameliorating food insecurity and finding meaningful, gainful employment for beneficiaries. Please contact either Jeanne Blankenship at 312-899-1730 or by email at firstname.lastname@example.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government & Regulatory 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 Position of the Academy of Nutrition and Dietetics: Food Insecurity in the United States. Holben, David H. et al. Journal of the Academy of Nutrition and Dietetics , Volume 117 , Issue 12 , 1991 – 2002.
3 Code of Ethics for the Profession. Academy of Nutrition and Dietetics website. Available at http://www.eatrightpro.org/~/media/eatrightpro%20files/career/code%20of%20ethics/codeofethicsdieteticsresources.ashx. Accessed April 8, 2018.
4 Academy Priorities for the 2018 Farm Bill. Academy of Nutrition and Dietetics website. Available at https://www.eatrightpro.org/advocacy/legislation/all-legislation/farm-bill. Accessed April 8, 2018.
5 SNAP Supports Workers in Every State. Center on Budget and Policy Priorities website. Available at https://www.cbpp.org/blog/snap-supports-workers-in-every-state. Accessed April 8, 2018.
6 SNAP Is Linked with Improved Nutritional Outcomes and Lower Health Care Costs. Center on Budget and Policy Priorities website. Available at https://www.cbpp.org/research/food-assistance/snap-is-linked-with-improved-nutritional-outcomes-and-lower-health-care. Accessed April 8, 2018.
7 Who Are the Low-Income Childless Adults Facing the Loss of SNAP in 2016? Center on Budget and Policy Priorities website. Available at https://www.cbpp.org/research/food-assistance/who-are-the-low-income-childless-adults-facing-the-loss-of-snap-in-2016. Accessed April 8, 2018.
8 Work Requirement Proposals Would Kick Struggling Workers When They’re Down. Center for American Progress website. November 2, 2017. Available at https://www.americanprogress.org/issues/poverty/reports/2017/11/02/442052/work-requirement-proposals-kick-struggling-workers-theyre/. Accessed April 8, 2018.
9 More Than 500,000 Adults Will Lose SNAP Benefits in 2016 as Waivers Expire: Affected Unemployed Childless Individuals Are Very Poor; Few Qualify for Other Help. Center on Budget and Policy Priorities website. Available at https://www.cbpp.org/research/food-assistance/more-than-500000-adults-will-lose-snap-benefits-in-2016-as-waivers-expire. Accessed April 8, 2018.