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In December 2019, the Trump administration finalized changes to a new rule limiting states’ ability to obtain waivers from strict time limits and work requirements for participants considered able-bodied adults without dependents (ABAWDs) in the Supplemental Nutrition Assistance Program (SNAP). While the new rule is currently blocked by a federal injunction, our analysis demonstrates the important role of SNAP ABAWD waiver flexibility in ensuring SNAP access for vulnerable populations, not only during the immediate COVID-19 public health crisis, but also in the subsequent recovery period, when economic distress is likely to affect some local areas more than others.

The new rule would have curtailed the ability to waive SNAP work requirements for participants considered ABAWDs living in areas (counties, parishes, or cities) whose broader Labor Market Areas (LMAs) have a 24-month average unemployment rate of 20 percent above the national average that is at least 6 percent.

Using data from the recent past (2016, 2018, and 2020) for six LMAs, we find that using LMA unemployment rates could mask significant variation in the availability of jobs across counties and cities within the same LMA without considering the barriers to transportation faced by low-wage workers. We find that this change may also adversely affect waiver eligibility for urban areas with high shares of Black and Hispanic residents, areas with significant immigrant populations, and rural areas across the US.