Farm Bill 2018: Guide to Proposed Changes to Supplemental Nutrition Assistance Program Work Requirements
  Mary Zaki  
  University of Maryland   
  Department of Agricultural and Resource Economics  
  University of Maryland Extension  
     
CURRENT LAW HOUSE BILL SENATE BILL
  Proposed Changes Proposed Changes
General Work Requirements (7 U.S.C. 2015(d)) Workforce Solutions (H.R. 2, sec. 4015) Work Requirements for Supplemental Nutrition Assistance Program (S. 3042, sec. 4103)
Who it applies to: Individuals age 16 to 59 Who it applies to: Individuals age 18 to 59  
Requirements: Must register for work, accept suitable employment if offered, not voluntarily quit job or reduce hours (below 30 hours/week), provide sufficient information to State agency to enable determination of employment status and job availability, and participate in an employment and training program if referred to one by the State agency. Requirements: Work, participate in employment and training or workfare program for a minimum of 20 hours per week in fiscal year 2021 through 2025 and 25 hours per week in fiscal year 2026 and after. Must accept suitable employment if offered, not voluntarily quit job or reduce hours (below 20 hours/week), provide sufficient information to State agency to enable determination of employment status and job availability. Employment and Training: Expands employment and training components offered by state agencies, requires state agencies to consult with outside entities in development of employment and training program, allows private employers or nonprofits to operate additional training and work programs (workforce partnership), logistically facilitates reassessment of individuals who are ill-suited to the employment and training component they are currently assigned, authorizes spending on grants for pilots of employment and training programs.
Exemptions: Individuals who are mentally or physically unfit for employment; individuals employed 30 or more hours per week (or earn equivalently); those responsible for the care of a child under 6 or an incapacitated person; students enrolled at least half time in school, training program, or institution of higher education; individuals already complying with another assistance program's work requirements (e.g., TANF or unemployment compensation); individuals participating in drug addiction or alcohol treatment programs; individuals between ages of 16 and 18 who are not head of households or who attend school or an employment training program for at least a half-time basis. Exemptions: Individuals who are mentally or physically unfit for employment; pregnant; individuals that are receiving weekly earnings that are at or above earnings received for working required hours at minimum wage; those responsible for the care of a child under 6 or an incapacitated person; students enrolled at least half time in school, training program, or institution of higher education; individuals already complying with another assistance program's work requirements (e.g., TANF or unemployment compensation); individuals participating in drug addiction or alcohol treatment programs.
Consequences of violation: a) Each violating individual is: ineligible for SNAP for 1-3 months or until compliance whichever is longer for 1st violation, ineligible for SNAP for 3-6 months or until compliance whichever is longer for the 2nd violation, and ineligible for 6 or more months (including permanently) or until compliance whichever is longer for the 3rd violation. b) If head of household violating, household ineligible for SNAP for the lesser of duration for the head of household as prescribed in a) or 180 days.  Consequences of violation:  After 1st month of SNAP benefit, an individual who violates work requirements for the 1st time is ineligible for SNAP until the date of obtaining employment sufficient for fulfilling work requirement, the date when individual is no longer subject to requirement or 12 months after date of ineligibility, whichever is earliest. An individual who violates work requirements for the 2nd time is ineligible for SNAP until the date of obtaining employment sufficient for fulfilling work requirement, the date when individual is no longer subject to requirement or 36 months after date of ineligibility, whichever is earliest.  
Employment and Training: Program components and implementation vary across states including if program is voluntary or mandatory. Employment and Training: States required to provide slots in employment and training programs so that every non-exempt individual may meet the work requirements.  
 Able-bodied Adults Without Dependents (ABAWDs) Time Limit (7 U.S.C. 2015(o)) State Exemption flexibility: States can apply to exempt individuals from these requirements if they live in areas with unemployment rates over 10%, designated as a Labor Surplus Area by the Employment and Training Administration of the Department of Labor, or  has a 24-month average unemployment rate 20 percent or higher than the national average for the same 24-month period unless the 24-month average unemployment rate of the area is less than 6 percent. State can provide exemptions to 15% of individuals that are not exempted otherwise and do not live in exempted areas.  
Who it applies to: Individuals age 18 to 49  
Requirements: Must work 20 hours a week, participate in employment and training program for at least 20 hours per week or participate in State's "workfare" program (required workfare hours vary by State).  
Exemptions: Medically certified as physically or mentally unfit for unemployment; a parent or member or a household with responsibility for a dependent child or incapacitated person; pregnant; or otherwise exempt from general SNAP work requirements as outlined in (7 U.S.C. 2015(d)).  
Consequences for violation: SNAP benefits limited to 3 (not necessarily consecutive) months per 36-month period unless 20-hour work requirements are met. ABAWD can resume SNAP benefits if lost after spending 80 or more hours working or participating in working/training activity in a 30-day. Those who gain employment after usage of 3-months of SNAP benefits without fulfilling 20 hours of work, and then subsequently lose employment can receive an additional 3 consecutive months of SNAP benefits without fulfilling the 20 hour work requirements within the same 36-month period.    
Employment and Training: States are not required to provide slots in employment and training programs or workfare programs.     
State Exemption flexibility: States can apply to exempt ABAWD individuals from these requirements if they live in areas with unemployment rates over 10% or that do not have sufficient number of jobs to provide employment. State can provide exemptions to 15% of ABAWDs that are not exempted otherwise and do not live in exempted areas. Estimated 2019-2028 Impact: −$9,190 million in benefits, +$7,650 million administrative costs. Benefits decrease due to more households becoming ineligible to receive SNAP due to requirement. Administrative costs increase due to expansions to State employment and training programs. Estimated 2019-2028 Impact: +$235 million mostly due to grants. 
Additional sources: Aussenberg, Randy Alison. (2014). " Supplemental Nutrition Assistance Program (SNAP): A Primer on Eligibility and Benefits," Congressional Research Service; Congressional Budget Office. (2018). "Cost Estimate of H.R. 2, Agriculture and Nutrition Act of 2018"; Congressional Budget Office. (2018). "Cost Estimate of S. 3042, Agriculture Improvement Act of 2018."
Highlights of major proposed changes in work requirements for SNAP
The Senate bill makes no major changes to work requirements other than directing steps to expand state employment and training programs. However, the House bill replaces the two major work requirements in current law (one that is directed generally to adult SNAP recipients and one that adds time limits to benefits for able-bodied adults without dependents) with one new requirement called "Workforce Solutions."  The House's "Workforce Solutions" would require able bodied SNAP recipients aged 18 to 59 to work or engage in employment and training or workfare programs for 20 hours a week (goes up to 25 hours a week in fiscal year 2026) in order to receive SNAP benefits. This expands current ABAWD time limit requirements to households with children over 6 years old and to adults between the ages of 49 and 59 that have no dependents. Also, the House bill only provides one month of SNAP benefits to individuals who do not fulfill work requirements while current ABAWD rules provide between 3 to 6 months in a 36-month period. However, the House bill reinstates eligibility for SNAP benefits for individuals who lost benefits on the date these individuals gain employment. In contrast, current ABAWD rules reinstates eligibility to lost benefits after individuals complete 80 hours of work within a 30-day period. Furthermore, the House bill mandates that states expand their employment and training programs and provide slots so that every non-exempt individual can meet the work requirements. In contrast, current law does not mandate that the state agencies are required to provide employment and training slots for every individual  that requests participation.