1. Background
  2. Economic Justice

USDA Releases Report on Proposed Rule That Would Implement New Time Limits on SNAP

By Andre Gobbo, December 20, 2018


On Dec. 20, just a few days after the House and Senate passed with overwhelming bipartisan support the Agriculture Improvement Act of 2018 (H.R. 2), also known as the farm bill, USDA released a proposed rule change that would force 755,000 people to lose their SNAP (Supplemental Nutrition Assistance Program) benefits.

Currently, able-bodied adults who aren’t raising children are limited to three months of SNAP benefits over a three year period. However, states can waive this strict time limit in periods and locations of high unemployment.

The proposed rule change would make it harder for states to get these waivers, preventing people from accessing much needed food assistance because they’re unable to find or keep a job. The result is the proposed rule actually makes it harder for people to find a job, limits state flexibility, and goes directly against Congress’s policy decisions in the farm bill that just passed.

The current waivers allow states to exempt people from the three month SNAP time limit if the unemployment rate rises above 10 percent. However, certain populations face higher rates of unemployment than the state-wide average, most notably people of color and older Americans. Any adjustment to the current waiver system risks putting those who already face discrimination and barriers to employment into even more hardship.

Altering the waiver system also prevents states from being able to respond to the economy or a recession. During the most recent recession, the share of the population receiving a waiver from the three month SNAP time limit increased drastically, and it has since slowly declined as the economy recovered. Because of this ability to expand and contract to meet demand, SNAP prevented millions of Americans from facing food insecurity.

This proposed rule not only subjects more people to the already harsh time limits under current law, it also goes against the congressional intent established in the farm bill that Congress just passed. After months of negotiations, the House and Senate agreed to a bipartisan bill that purposefully excluded implementing harsher time limits and reducing access to benefits. This proposed rule directly contradicts that intent.

In the farm bill, you were successful in convincing your members of Congress that taking food away from people is no way to help them find work. Instead, we should actually address barriers to employment, such as investing in affordable childcare, access to transportation, skills development, education, and job training.

Yet we knew efforts to take away food, housing assistance, and health care from people struggling in this economy wouldn’t end with the farm bill.

Your tireless advocacy, culminating in the Quaker Public Policy Institute, has been important precisely because of instances like this. Members of Congress have spoken out and helped make the congressional intent clear: draconian time limits make it harder, not easier, for people to find a well-paying job and do not belong in the farm bill. Your advocacy helped prevent these measure from being included in the final farm bill. This is important not just for the farm bill but for establishing precedent. This clear congressional intent will be extremely important as challenges to the proposed rule progresses.

Yet there’s still more you can do. Once the proposed rule is published in the Federal Register, you can submit a comment explaining your opposition to taking food away from people struggling to find work.

Without your advocacy, we wouldn’t have gotten to this point. Thank you for everything that you’ve done, and be sure to thank your members of Congress for supporting a farm bill that purposefully excludes these harsh time limits.

Andre Gobbo

  • Domestic Policy Associate

Andre Gobbo adds capacity to the Domestic Policy team by handling constituent queries, writing action alerts and sign-on letters, assisting with lobbying visits, creating informational content, supporting coalition relationships, and helping execute FCNL’s legislative strategies. He primarily works on issues relating to economic justice and gun violence prevention but also assists other domestic policy initiatives. He also serves as the co-chair of the Policy & Advocacy subcommittee within the Faiths United to Prevent Gun Violence coalition.