How a Rule Aimed at “Childless Adults” Can Harm Mothers and Children

By Parker Gilkesson

On February 1, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) proposed a regulation that would take away food from about 755,000 unemployed or underemployed people without children. The Federal time limit in the Supplemental Nutrition Assistance Program (SNAP) already limits SNAP eligibility for childless adults aged 18-50 (with some exemptions for people with disabilities or other specific reasons). But due to the complex nature of low-income households and extended families, mothers and children are at risk of being harmed by the rule as well.

SNAP plays a major role in the defending against child food insecurity—significantly reducing child poverty and increasing children’s health and educational outcomes. Furthermore, nutrition assistance is associated with healthy birth outcomes—including fewer babies with low birth weight. Low-income pregnant mothers and households with children are usually exempt from the time limit because SNAP is vital to their wellbeing. However, the time limit exemptions do not always account for the complex structures of low-income households—such as children with noncustodial parents, or children receiving crucial support from other relatives. Nor does it account for pregnant mothers who do not yet know they are pregnant.

Poverty complicates childrearing for custodial and noncustodial parents raising. Custodial parents in poverty often use child support from the noncustodial parent and SNAP to make ends meet. Unlike custodial parents, however, noncustodial parents with low incomes aren’t exempt from the SNAP time limit. Therefore, if noncustodial parents lose their SNAP benefits due to unemployment or working fewer hours, they may struggle to feed their children when or if they have visitation. In addition, they may have to divert money used to pay their child support payments to other basic needs in order to stay afloat. This can be devastating to a custodial household that uses child support as an income supplement to provide for their children.

Although pregnant women are exempt from the SNAP time limit, the proposed rule would be particularly harmful for women who don’t yet know they are pregnant or don’t yet have medical documentation of their pregnancies. Cutting off nutrition assistance during early pregnancy can have  significant negative outcomes that could harm the mother and unborn child—including impaired health and fetal brain development.

Nationwide, one in six children are at risk for not having access to consistent meals. Therefore, the health and wellbeing of over 13 million children in America are threatened by food insecurity. Without access to healthy food, children are at a greater risk of stunted development, hospitalization, and poorer quality of life.

Because SNAP is an essential component of helping to improve the health and wellbeing of mothers and children, we must fight efforts to further restrict access to it. The proposed rule posted on February 1 is only a proposal. We can fight back by submitting public comments, which FNS must take into consideration before finalizing the rule.

Join us in the fight against this harsh proposed regulation. Click here to use the  template comment from First Focus. In your comment, we encourage you to add your own stories to describe why the proposal is harmful to children.

Please make your voice heard before the April 2 deadline.

Additional templates can be found at To submit a comment directly to, click here. Our partners at the Food Research & Action Center have also set up an action page where you can learn more and submit a comment using their template.