P&P April Issue 2018

for adults without disabilities. 4 Eight states have pending waivers (AR, AZ, IN, KS, ME, NH, UT, and WI). CMS has granted waivers to Kentucky and Indiana. 5 There is no differing opinion among states that employment for those who can work is both economically and socially beneficial. Existing health and human services programs support the elderly, people with disabilities, and children, and they comprise the majority of program caseloads. The majority of work-eligible adults in public benefit programs already work, but there is a concerning and not insignificant percentage of nondis- abled, nonworking adults enrolled in public benefit programs. As a matter of public policy, they need our atten- tion. The numbers could be as high as nine million or more, but estimates tend to be point in time, subject to some dispute and are likely to count duplicate beneficiaries across several programs. Our member states must be both intentional and cautious in properly designing programs to help this population achieve success through various approaches that combine expectations and consequences. What are the potential opportunities and pitfalls of expanding work require- ments in all programs, particularly Medicaid and public housing? General Arguments in Favor of ExpandedWork Requirements The idea of reciprocity, where public agencies provide benefits through multiple programs based on certain expectations that work-capable adults make reasonable efforts to improve their situations, has become more widely accepted. As one of the social determinants of health, employment may not only improve economic conditions, it may also build social capital by connecting adults to colleagues and other contacts. It can also prevent social isolation and improve both physical and mental health outcomes. In Medicaid, recent state and federal government efforts have somewhat reduced the previously soaring growth in costs to a more manageable level. But the program remains a huge

While work-eligible adults must register for work in SNAP E&T, states currently have leeway to define their SNAP E&T programs as voluntary or mandatory except for a population known as able-bodied adults without dependents (ABAWDs) ages 18–49. ABAWDs are required to find work or participate in defined work-related activities for 20 hours weekly, or receive benefits for only three months in a 36-month period. The administration’s budget looks to expand SNAP work requirements in general and make them manda- tory in most instances. As part of this effort, the U.S. Department of Agriculture Food and Nutrition Service issued an Advance Notice of Proposed Rulemaking in the February 23, 2018 issue of the Federal Register (Vol. 83, No. 37, p. 8013), soliciting comments from states and other organizations on further expansion of ABAWD work requirements. Similarly, as of this writing, legislation expected to emerge from the House Agriculture Committee as part of Farm Bill reauthorization was to be introduced no later than April and have a stronger focus on SNAP work requirements. Limited programs to promote work at public housing authority discre- tion have existed for those receiving direct subsidies or having housing choice vouchers since 1985, but they have been extremely small and experi- mental. A January 2018 study by the Urban Institute details the limited information available on the efficacy of such efforts. 1 The administration’s budget proposal for FY 2019 would require as many as 32 hours weekly of work or other activities as a condi- tion of eligibility for the 26 percent of nonworking, nondisabled residents of public housing. 2 The inclusion of Medicaid in the panoply of programs with work/ community engagement require- ments is the newest proposal from the administration. A January 11, 2018 Guidance Letter to States from the Centers for Medicare and Medicaid Services (CMS) encourages states to apply for Section 1115 waivers 3 to, at their option, implement work and/or community engagement requirements in Medicaid as a condition of eligibility

This stronger emphasis on work accelerated in 1996 with the enact- ment of the Personal Responsibility and Work Opportunity Reconciliation Act and the creation of the Temporary Assistance for Needy Families Program (TANF). Experiments by states through federally granted waivers to require or encourage work for able- bodied adults in the previous Aid to Families with Dependent Children program set the stage for the 1996 legislation creating TANF, which made work a condition of eligibility for benefits, with sanctions imposed for failure to comply. It required states to place 50 percent (90 percent of two-parent families) of those classified as able bodied either into a job or one of 12 federally defined qualifying activities for 30 hours weekly (20 hours for those with young children and 35 hours for two- parent families). The administration’s focus on work was reinforced through the president’s fiscal year (FY) 2019 budget proposal, which would expand these requirements and demand that states spend 30 percent of their TANF Block Grant and their state-required maintenance-of-effort funds on work- related activities. The concept of work in return for benefits found its way into the Supplemental Nutrition Assistance Program (SNAP) in 1998, when the Employment and Training Program (SNAP E&T) was initiated. Current federal funding since 2002 comes through two avenues, a limited pool of 100 percent federal funds for states and a 50–50 percent match pool of federal and state (including private/ philanthropic) funds.

Russell Sykes is a Senior Fellow at the American Public Human Services Association.

Policy&Practice April 2018 22