By Duy Pham

The Trump Administration is proposing a new rule to limit nutrition assistance for unemployed and underemployed people who can’t document a set number of work hours per week. The proposed rule would restrict 755,000 low-income people—including many adult and postsecondary education students and workforce training participants—from using the Supplemental Nutrition Assistance Program (SNAP). Make your voice heard by opposing the SNAP rule with a public comment before April 2.

SNAP is our nation’s most important anti-hunger program that provides food and nutrition assistance to 39 million people with low incomes. Under federal law, non-disabled adults who are 18 to 49 and don’t have dependent children are limited to 3 months of SNAP in a 36-month period (unless they engage in work or workforce training activities at least half time).

States can choose to waive this limit in areas of high unemployment; however, the proposed rule would block states from extending SNAP beyond the 36-month time period. People of color are more likely to be affected by the time limit as are individuals who face such employment challenges as unreliable transportation, unstable housing, and/or engagement with the criminal justice system.

Students and workforce training participants enrolled at least half time aren’t subject to the time limit, and this wouldn’t change under the proposed rule. However, students and workforce training participants enrolled less than half time who aren’t otherwise exempt would risk losing their benefits if they don’t meet SNAP time-limit rules.

SNAP is crucial for adult and postsecondary students and workforce training participants

SNAP and other public benefit programs help people with low incomes persist in and complete adult and postsecondary education and training. SNAP reduces hunger and increases financial stability, both of which are shown to improve the likelihood of community college students completing a degree or certificate program.

Individuals are more likely to participate in SNAP when they are out of work, and those subject to the 36-month time limit are often in most need of quality education and workforce training. When people don’t have educational opportunities, they are more likely to be consistently out of work and under threat of losing SNAP. In fact, 85 percent of those subject to the time limit lack any postsecondary education or training, while SNAP participants subject to the time limit are more likely than other SNAP participants to lack foundational reading, writing, and math skills.

Even when employed, some low-wage workers struggle to get enough hours from their employer to make ends meet. An estimated 6.1 million workers are involuntary part-time, meaning they want to work full-time but are only offered part-time hours. Workers of color are more likely to be involuntary part-time. Black and Latinx workers together represent 41 percent of all involuntary part-time workers.

The administration’s proposal would undermine the workforce system

Non-academic support services like SNAP are crucial to the success of developing and funding quality career pathways. In fact, the Department of Agriculture operates a special program—SNAP Employment and Training (E&T)—that offers SNAP recipients training to improve their employment and earnings prospects. Many state and local leaders in adult and postsecondary education and workforce development have intentionally engaged SNAP participants in high-quality programs through SNAP E&T. However, the workforce system is chronically underfunded to provide quality services that meet the needs of those subject to the time limit. Under the proposed rule, the quality of programs will diminish as states focus on ineffective, low-intensity programs that simply provide recipients the minimum hours of participation to meet the requirements.  

Take action now

The administration is accepting public comments until April 2. All of us can fight this proposed regulation by submitting comments. CLASP has  created template comments for adult and postsecondary education and workforce development partners as well as for postsecondary students. In your comment, please add your own stories to describe why the proposal is harmful.

Additional templates can be found here. To submit your comment to regulations.gov, 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.