June 3, 2019
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, Virginia 22302
RE: Agency Information Collection Activities: The Role of Job Search as a Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) Component
Dear Ms. Deemer:
The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit comments to the Food and Nutrition Service of the U.S. Department of Agriculture related to its information collection activities, “The Role of Job Search as a Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) Component,” published in the Federal Register originally on April 8, 2019. Representing more than 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 applauds the efforts of the Food and Nutrition Services of the U.S. Department of Agriculture to determine which job search activities are most effective in leading SNAP participants to self-sufficiency and believes these efforts may provide practical utility to administering the E&T component of SNAP.
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 vital to achieve food and nutrition security in the United States. To achieve food security, effective interventions are needed, including those that will support SNAP recipients attain long-term, sustainable employment. 2
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. Specifically, we support programs that have been shown to help people gain the employment and skills that can help lift them out of poverty rather than just provide them with immediate employment.3
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. 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.4
Considerations for Enhanced Quality, Utility, and Clarity of the Information to be Collected
After review of the information collection objectives, the Academy presents three points for consideration: 1) how will the change to the job search component requirement outlined in the 2018 Farm Bill impact this data collection; 2) will sanction/termination rates be collected as part of the documentation process for impact; 3) will USDA publish an annual report that demonstrates how each state has utilized E&T funding to help support SNAP recipients find work.
The Agriculture Improvement Act of 2018 calls for a significant change in the structure of the job search component of E&T. This will require that states replace current job search activities with those that are ‘supervised’. Consideration should be given to the timing of the proposed data collection in order to meet the intent of the study objectives and to reflect the shift in the program’s structure.
The third study objective outlines the intent to capture short-term and long-term effects of job search activities on SNAP participants. In order to represent the complete impact of job search activities on a SNAP participant, the Academy suggests collecting sanction/termination data related to the job search component of E&T. The Academy is concerned that any component of SNAP that may result in a disruption in food access, such as sanctions through E&T, could impact long-term health outcomes.
The Academy urges that USDA publish annual data describing how each state utilized the E&T funding to support work for SNAP recipients. Providing best practices and sharing the effectiveness of state E&T programming will help providers better determine the most appropriate strategies to employ while developing state E&T plans.
The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit comments to the Food and Nutrition Service of the U.S. Department of Agriculture related to its information collection activities, “The Role of Job Search as a Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) Component”. We urge USDA to consider the timing of the data collection and its impact on the study objectives, the inclusion of sanction rates to the short and long term outcome measures and distribution of annual state SNAP E&T expenditures. Please contact either Jeanne Blankenship at 312/899-1730 or firstname.lastname@example.org, or Liz Campbell at 202/775-8277, ext. 6021 or email@example.com, with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN Liz Campbell, MA, RDN
Vice President Senior Director
Policy Initiatives and Advocacy Legislative & Government Affairs
Academy of Nutrition and Dietetics Academy of Nutrition and Dietetics
1The 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.
2Holben, 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 Ladonna Pavetti, Work Requirements Don’t Cut Poverty, Evidence Shows, Center on Budget and Policy Priorities, June 2016, https://www.cbpp.org/research/poverty-and-inequality/work-requirements-dont-cut-poverty-evidence-shows.