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Federal law authorizing the Supplemental Nutrition Assistance Program (SNAP, formerly known as food stamps) includes specific eligibility standards — generally requiring low income and limited savings — to ensure benefits reach households truly in need. But as Angela Rachidi explained in a previous post, current law also permits states to confer “broad-based categorical eligibility” for SNAP benefits to individuals receiving support from the Temporary Assistance for Needy Families (TANF) program, a key cash welfare program designed to assist low-income families with children.
While linking eligibility for welfare and food stamps made sense when the two programs had similar eligibility standards, the 1996 welfare reform law fundamentally changed cash welfare in ways that have increasingly undermined that linkage. Today, not only can states provide many services other than welfare checks using TANF funds, but many people who receive help from TANF never have their income or assets checked to determine eligibility for those services. Receiving a flyer or referral to a 1-800 number financed by TANF funds — a “service” provided without regard to individual income or assets — has become enough to “confer” eligibility for SNAP.
This loophole has made a growing number of individuals eligible for SNAP who otherwise wouldn’t qualify based on federal eligibility criteria. As a congressional hearing demonstrated, even millionaires and lottery winners have been able to access food stamp benefits this way. And since SNAP benefits are 100 percent financed by federal funds, many state agencies have been only too happy to use this backdoor way of extending benefits to individuals with incomes and assets well in excess of what is prescribed in federal law.
In July, the US Department of Agriculture (USDA) proposed a rule to close such loopholes that allow, by their estimate, up to 3.1 million people to qualify for SNAP benefits when federal eligibility standards say they shouldn’t.
We have submitted comments to the USDA on their proposal, generally agreeing with the thrust of the changes but also highlighting areas where it could be further refined. We agree that states should no longer be able to confer eligibility based on receipt of “token” TANF services, such as brochures or referrals to other assistance. We urge the USDA to also ensure that TANF recipients conferred access to SNAP actually receive “ongoing” support from TANF, and that such programs receive a majority of their funding from TANF. We also propose aligning the income eligibility criteria of such TANF programs with SNAP once again, preventing future loopholes from developing.
SNAP provided more than $60 billion of assistance to nearly 40 million Americans last year — well above levels in the mid-2000s when the economy was similarly strong. This program is a vital lifeline for needy families, but a notable share of food assistance goes to households that do not satisfy SNAP’s own eligibility standards. That undermines confidence in the targeting of this important program, and can and should be fixed. We applaud the USDA’s efforts to close unjustified categorical eligibility loopholes and hope they consider our recommendations for further improvements.
We applaud the Department of Agriculture’s efforts to close unjustified categorical eligibility loopholes and hope they consider our recommendations for further improvements.
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