FR 2024-29072

The recently published final rule from the U.S. Department of Agriculture (USDA) details changes to the Supplemental Nutrition Assistance Program (SNAP) as mandated by the Fiscal Responsibility Act of 2023. This rule introduces new work requirements and expands exemptions for certain groups of people, which are expected to have both administrative and economic impacts.

Overview

The rule expands the SNAP work requirements to include individuals aged 50 to 54, effectively broadening the scope of who must satisfy certain employment criteria to receive benefits. Simultaneously, it introduces exemptions for homeless people, veterans, and young adults leaving foster care, acknowledging the unique challenges faced by these groups. With these changes, SNAP is aligned more closely with initiatives to encourage work and self-sufficiency, aiming to reduce dependency on government assistance.

Significant Issues

The document's technical language might be challenging for some audiences to fully grasp, as it relies heavily on policy references and specific legislative terms. An inconsistency or lack of clarity in defining terms like "imminently homeless" might lead to varied interpretations by State agencies, resulting in unequal application of rules.

Financially, the rule is expected to increase administrative costs significantly for both State and federal levels. This includes expenses related to implementing and managing the new provisions, which may result in additional taxpayer burden over time. The reduction in discretionary exemptions—from 12% to 8%—could affect SNAP beneficiaries in transitioning circumstances and should be monitored to avoid unintended consequences.

Broad Public Impact

The rule could lead to fluctuations in SNAP eligibility and participation. On one hand, individuals ages 50-54 might lose benefits if unable to meet the expanded work requirements, creating potential hardship for older adults struggling with employment. On the other hand, the new exemptions could provide essential support to vulnerable populations, ensuring food security for those who might otherwise fall through the safety net.

Stakeholder Impacts

Positive Impacts: For specific stakeholders such as veterans, homeless individuals, and foster youth transitioning to independence, the rule's exemptions provide crucial support, potentially improving their quality of life by maintaining or extending SNAP benefits during challenging times.

Negative Impacts: Conversely, older adults without dependents might find the new work requirements particularly onerous, especially if they face age-related barriers in the job market. This group’s reduced access to benefits could exacerbate existing struggles with poverty and insecurity. Additionally, State agencies might experience implementation challenges, requiring more resources to navigate the complexities of these rule changes, potentially leading to administrative overload.

Conclusion

The USDA's final rule reflects an effort to balance SNAP's role in promoting work with providing support to vulnerable groups. Despite potential benefits, the rule raises concerns over administrative costs and the equitable application of its provisions. Stakeholders, including State agencies and the affected populations, will need to closely watch how these changes unfold to ensure that the program continues to meet its objectives effectively without creating new disparities or burdens.

The document discusses financial implications arising from changes to the Supplemental Nutrition Assistance Program (SNAP), as dictated by the Fiscal Responsibility Act (FRA) of 2023. The financial elements include spending estimates, administrative costs, and analysis related to adjustments in exemptions for eligible individuals.

Overall Spending and Transfers:

The implementation of these rule changes is expected to result in an increase in federal transfers related to SNAP benefits. The estimated total increase is approximately $3.5 billion over nine fiscal years, from 2023 to 2031, averaging $393.1 million per year. This increase is the net result of several factors: a reduction in transfers of $5.1 billion due to the termination of benefits for about 1.8 million individuals, a reduction of $149.1 million affecting 123,000 individuals who see decreased benefits, and an increase of $8.7 billion associated with approximately 2.6 million individuals meeting new exceptions from the time limit.

Administrative Costs:

The document highlights significant administrative costs associated with these changes. Over the same nine-year period, federal administrative costs are estimated to be $283.9 million, or approximately $31.5 million annually. Similarly, state agency administrative expenses are projected to tally another $283.9 million total, or $31.5 million annually. Additionally, costs related to the administrative burden on individual SNAP participants are estimated at $358.3 million over the nine-year horizon, equating to about $39.8 million annually.

Sunsetting Costs:

Another notable financial element is the one-time cost associated with sunsetting these rule provisions by 2031, projected to involve an administrative burden of 575,583 total hours, costing approximately $14.3 million after state reimbursements. The imposition of a one-time burden on affected SNAP participants due to the sunsetting of rule provisions is estimated to cost about $2.8 million.

Issues and Financial Implications:

The anticipated financial allocations and their effects relate to various identified issues. For instance, the significant administrative costs suggest a need for more thorough oversight and justification to ensure these expenditures are necessary and efficiently managed. Additionally, the document addresses public concerns about increased administrative costs, reflecting in comments on increased state expense burdens, needing careful evaluation of whether these changes deliver intended efficiencies.

The reduction in the annual allotment of discretionary exemptions from 12% to 8% raises concerns about how this might impact access to SNAP benefits for those in transition, necessitating a closer look at potential unintended outcomes.

The regulatory impact analysis estimates an increase in SNAP participation due to new exceptions—estimated at 367,000 individuals retaining eligibility and around 29,000 new participants in FY 2026. This apparent contradiction with the stated aim of curbing SNAP spending invites further examination of both fiscal expectations and policy objectives to ensure alignment.

In summary, while the financial allocations reflect an increase aimed at accommodating broader eligibility exceptions and administrative demands, they prompt questions about the efficiency of these strategies in achieving their core goals of reducing overall SNAP spending and improving administrative efficacy.