CEEWB: The Future of SNAP

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interfere with states’ ability to conduct effective employment programs. In fact, we should be doing everything possible to create real work opportunities for ABAWDS, many of which are non-custodial fathers and/or post-incarcerated individuals, not only so they can find employment but also fulfill support obligations and not return to incarceration. Instead, ABAWD rules, because of the strict three in thirty-six-month time limit for failure to comply, ultimately diminish their ability to work and be economically productive. By quickly forcing these ABAWD recipients into activities, regardless of how superficial, simply to preserve their SNAP eligibility past the initial three months, rather than to incorporate them into a comprehensive program is counterproductive. Compounding this is the ongoing weakness in many labor markets where employment opportunities remain sparse, competition for jobs is strong and states and localities often cannot create sufficient eligible slots to meet the ABAWD compliance rules. When ABAWDS lose their benefits after three months, necessary food assistance has been severed and they are left outside the purview of the state’s efforts to skill them up and place them in stable jobs that are likely to be enduring or at least preparatory to other employment opportunities. Avenues to alleviate these problems and to maintain the strong and important work expectation message for ABAWDS would be to allow states that choose to do so, to expand the three in 36 month time limit for a longer period of time, perhaps nine months, align time limits for ABAWDS with their certification periods to make tracking easier for states, broaden allowable activities to meet work requirements including online learning and other provisions, provide new post-employment federal work support funding for transportation and other job related expenses to ensure job retention and guarantee that if no job or eligible activity is located that benefits will not be lost. Expand E&T pilots – The current E&T pilots, authorized by the 2014 farm bill, should shed important light on how SNAP can advance in this critical area, and clearly beneficial impacts from

these pilots should be implemented based on interim positive evaluation findings even before the pilots have concluded. Additional, similar pilots that can evaluate other strategies to build individual employment capacity should be promptly developed and tested. For those pilot states that demonstrate promising practices, bridge funding should be allocated to allow programs to continue pending final evaluation. The “cliff effect” – Among the most unfortunate results of multi-program disconnects is the so-called “cliff effect,” in which modest increases in income, and in turn program benefits, trigger significant reductions in other programs or even termination – a direct result of different approaches to eligibility rules and program philosophy. The cliff effect is often a significant disincentive to begin working or to increase hours and pay. While SNAP has gradual benefit phase-down provisions that make it less subject to a cliff effect than other programs, most notably child care, it could better accommodate rapidly changing household income situations by, for example, allowing states a period of one to three months in which federal SNAP benefits are held steady when employment is at a sufficiently high wage to end SNAP eligibility. Other work-related benefits such as transportation could also be extended for the same period of time in order to allow working families to adjust household budgeting post SNAP receipt. Accountability and Program Integrity APHSA and its members fully support the accountability of human services programs for results that are significant and sustainable, and that return proper value for the public’s investment. SNAP is without question one of the most highly regulated and strictly overseen programs when it comes to such metrics as benefits and timeliness, and reasonable requirements for these basic performance standards should remain in place. However, these and other equally important program results could be part of a broader and more balanced approach to assessing what SNAP accomplishes. Some ways to achieve this include the following.