In July, the Trump administration proposed significant changes (PDF) to some eligibility criteria for the Supplemental Nutrition Assistance Program (SNAP). The proposal would limit states’ ability to increase SNAP’s income limits and remove or relax SNAP asset limits set at the federal level, a policy known as broad-based categorical eligibility (BBCE).

Thirty-nine states and the District of Columbia, as well as Guam and the Virgin Islands, now use BBCE, and many have done so for several years. BBCE helps SNAP reach households that may have slightly higher income and assets and very significant expenses, like high housing costs (in excess of 50 percent of income) and medical out‐of‐pocket expenses.

The people and families who gain access to SNAP through BBCE can also gain valuable stability, and BBCE helps simplify the outreach and eligibility process for supporting them.

Recent Urban Institute briefs detail how the administration’s proposal would affect working families and those households with children, seniors, and adults with disabilities who may fail the proposal’s income and asset tests and lose access to SNAP.

The proposal erodes work incentives

BBCE prevents the possibility that SNAP benefits decrease or cease because of a marginal increase in earnings that puts a household just above 130 percent of the federal poverty level. Without BBCE, the extra earnings made from work may not make up for lost SNAP benefits, creating a disincentive to work or increase work hours.

Under the administration’s proposal, 2 million people in working families would lose SNAP benefits. These people would lose an average monthly SNAP benefit of $150 per household, reducing benefits by about $130 million a month.

Many of these families will experience greater food insecurity and face trade-offs between food and other basic expenses. These trade-offs can be particularly acute in areas with higher costs of living, an issue BBCE has allowed states to address.

The proposal increases the risk of food insecurity for households with children

More than 2 million people in households with children would lose SNAP benefits. These people would lose an average monthly SNAP benefit of $240 per household, reducing benefits by just under $165 million a month.

Any accompanying increase in food insecurity among children is likely to have both short-term health outcomes and long-term economic consequences.

There are also more indirect consequences. Children in these households could also lose automatic certification for free and reduced-price lunches through the National School Lunch Program, which is linked to SNAP benefits. Though not explicitly written in the proposed rule, the administration has verbally estimated that 500,000 school-age children could lose automatic certification if the rule is implemented. 

The proposal makes it difficult for those living on fixed incomes to access SNAP

More than 750,000 people in households with seniors would lose SNAP benefits. About 2.9 million households with seniors, including approximately 1.3 million seniors living alone, already reported being food insecure in 2018.  

Under the proposal, households with seniors would lose an average monthly SNAP benefit of $68 per household, reducing benefits by more than $42 million a month.

About 320,000 people in households with an adult living with a disability would also lose access to SNAP, losing an average monthly SNAP benefit of $53 per household, further reducing benefits by $10 million a month.

SNAP provides a particularly important resource for seniors and adults with disabilities who live on fixed incomes. Without SNAP benefits, more seniors and more adults living with disabilities would be food insecure. Any increases in food insecurity among both populations would exacerbate health challenges and health care costs.

The rationale for removing BBCE doesn’t align with the evidence

Proposals to eliminate or restrict BBCE reflect concerns that the policy allows too many people outside of the lowest-income Americans to access SNAP.

Although BBCE helps SNAP reach households that may have slightly higher incomes, they often belong to the critical populations highlighted in the briefs, for whom there is a clear rationale for relaxing the income test and eliminating the asset test.

Data about who would become ineligible for SNAP if BBCE were eliminated indicate that states are reaching households that are a high priority for SNAP.

Although the vast majority of those receiving benefits under BBCE fall under SNAP’s formal eligibility rules, BBCE provides a simplification mechanism for states to reduce unnecessary “churn,” where recipients leave the program and then reapply a short time later, often because their earnings fluctuated, recertification notices were sent to the wrong address, or recipients did not respond in time. BBCE also reduces SNAP’s administrative costs.

BBCE also promotes savings, a critical goal given the economic insecurity faced by many American families, even in the middle class. Reimposing SNAP asset limits may negatively impact families’ finances.

A recent study by our Urban colleagues examined the impact of relaxing or eliminating SNAP asset limits through BBCE and found that this policy increases low‐income households’ savings (8 percent more likely to have at least $500) and participation in mainstream financial markets (5 percent more likely to have a bank account).

Allowing for state flexibility in determining eligibility for SNAP allows this critical program to better support low-income American families who are struggling to make ends meet. As our colleagues at Urban have shown, SNAP reduces poverty, including for the populations who would see the most notable declines in benefits under the administration’s proposed rule.

SNAP benefit losses under the proposed rule would increase the risk of food insecurity for households with kids, with a senior or disabled member, or with a working member. Because so many states have built procedures, information systems, and training around BBCE, removing or significantly restricting it will likely be costly and disruptive. The federal comment period for the proposed rule ends on September 23, 2019.