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July 13 -- The Food and Nutrition Service (FNS) invites comments to OMB by August 12, 2022 regarding its proposed new study of state approaches to assessing SNAP participants' fitness for work.

The Food and Nutrition Act of 2008 (the Act) requires SNAP participants ages 16 to 59 to meet certain work requirements unless they are exempt or show good cause for being unable to work. In fiscal year 2019, over 37 million Americans participated in SNAP, and approximately 42 percent were between the ages of 18 and 59. Of those 18 to 59 years old, about 4 million, or 26 percent, were required to register for work and comply with work requirements as a condition of eligibility (commonly referred to as work registrants). In addition to work requirements, a subset of work registrants—adults ages 18 to 49 who are not disabled and live in households without dependents—called able-bodied adults without dependents (ABAWDs)—are subject to a time limit on receipt of SNAP benefits unless they work or participate in employment and training activities for an average of at least 20 hours per week for all but 3 months in a 36-month period.  

Studies show that many SNAP participants face health conditions that limit an individual’s ability to work that can warrant an exemption from these requirements. Recent analyses of the Census Survey of Income and Program Participation (SIPP) data found that almost half of SNAP participants report having a physical, mental, or other health condition that limits the kind or amount of work they can do, and many participants have a condition that prevents them from working at all (Mabli and Cheban 2017). Studies also suggest that some participants have health conditions not identified by States as part of the determination process. A nationally representative sample of work registrants and SNAP E&T participants found that 35 percent of work registrants and 30 percent of SNAP E&T participants cited health issues as a barrier to employment (Rowe et al. 2017).
States have broad latitude in how to determine if a SNAP participant is considered physically or mentally unfit for work and little is known about how States assess and verify health conditions that limit an individual’s ability to work during the SNAP eligibility process. The U.S. Department of Agriculture’s Food and Nutrition Service (FNS) has contracted with MEF Associates and its subcontractor, Mathematica, to conduct a study to better understand how States determine whether individuals are exempted from work requirements or have good cause for not meeting work requirements due to a physical or mental limitation. The purpose of this study is to collect data to understand how States determine which individuals are exempt from general work requirements, ABAWD work requirements, and, if applicable, mandatory E&T programs. The key project activities FNS is undertaking to answer these questions are: (1) a document review, (2) a survey of State SNAP agencies, and (3) case studies of four states that involve site visits and administrative data analysis.

The findings from this study will provide FNS with valuable insights into how States develop and implement policies and procedures for determining whether applicants or participants should be exempt from work requirements due to a physical or mental limitation. This one-time data collection will provide information that can help FNS assess States’ needs for technical assistance around issues related to exemptions and good cause due to physical or mental limitations and identify lessons learned that can be shared with other State SNAP agencies.  
State SNAP Agency Survey. The project team will conduct a one-time census of the 53 State SNAP agencies through a web-based survey to document policies, guidelines, and procedures used for exempting individuals from work requirements due to physical or mental limitations. All State SNAP Directors will receive a link to the survey, and they can enlist up to three staff to assist them in completing it. As part of the survey, the project team will also collect nonpublic documents from States for those States that have not publicly published their policy manuals and guidance. The project team estimates that all 53 State SNAP directors along with 159 policy staff will contribute to the approximately 60-minute survey (Appendix B). Participation in the survey is voluntary.  

Case studies. To provide context for the survey findings, the project team will conduct case studies of four States. The case studies will consist of site visits and analysis of the States’ administrative data. The combination of qualitative and quantitative data analysis will allow the project team to examine how the processes are implemented, how much discretion the eligibility staff have, and how much variation there is in how the program operates across the State. The project team will recruit the four States that FNS has identified as priority States representing both State- and county-administered structures. Participation in the case studies is voluntary. Should any of the four States decline to participate, the project team will recruit a replacement from the two alternative States identified by FNS.  

Case Studies: Site Visits. The project team will conduct in-person site visits to each State, meeting with staff from the State SNAP agency, two local SNAP offices (one rural and one urban), and E&T providers. The project team plans to interview a total of 28 State staff and 16 local staff for the State and Local Administrator Interviews (Appendix C), 64 local frontline staff for the State Eligibility Workers Interviews (Appendix D), and 80 SNAP E&T staff for the SNAP E&T Provider Interviews (Appendix E). The project team also plans to observe eligibility interviews using an observation guide (Appendix H).  
Case Studies: Administrative data analysis. The project team will request administrative data from the four States to explore characteristics of participants that have been exempted from work requirements due to physical or mental limitations (Appendix I). The team will analyze the data for trends by locality and any other factors. The project team will also combine SNAP administrative data from the four case study States with extant data on community characteristics to assess patterns in exemptions from work requirements due to physical or mental limitations and good cause determinations. Specifically, the team will assess patterns and variation in determinations by participant or SNAP unit characteristics and by locality and the characteristics of communities in which SNAP offices are located.   

SNAP work requirements webpage: https://www.fns.usda.gov/snap/work-requirements
FNS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202205-0584-005 Click IC List for data collection instruments, View Supporting Statement for technical documentation. Submit comments through this webpage.
FR notice: https://www.federalregister.gov/d/2022-14893

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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