Tell the Administration It’s Unacceptable to Make
SNAP’s 3-Month Time Limit Even Worse
USDA has requested public comments on whether it should reconsider certain rules that govern SNAP's 3-month time-limit
on childless adults. Under federal law, SNAP imposes a 3-month time limit on most childless unemployed and underemployed adults unless they are working 20 hours a week. Like many others, childless adults often turn to SNAP for assistance when they are no longer
able to make ends meets, especially as jobs are lost, hours are cut, or wages hover at the federal minimum. As a result of this rule, unemployed or underemployed individuals are cut off food assistance, causing hardship and increasing food insecurity. The
group impacted by this rule is extremely poor and often not eligible for other help while unemployed. You can learn more about them here.
While most of the time-limit rule is set in federal law, USDA did establish some important state flexibilities when it
wrote the regulations that govern the time limit back in 2001. These flexibilities help mitigate the unfair rule and limit its harsh impact. Most importantly, states can temporarily waive the time limit in areas with elevated unemployment. Currently the rules
are very clear which areas qualify for waivers and states have a straightforward and transparent process by which they demonstrate the areas of the state that qualify for temporary waivers. It appears that USDA wants to reconsider this process and to make
it harder for states to get waivers from the time limit for areas with elevated unemployment. Every state except Delaware has used waivers at some point since the time limit was enacted in 1996. We all have a stake in keeping this option available to states.
More information about waivers and their impact can be found here.
Before embarking on rewriting the regulation, USDA is asking the public to tell them if reworking these rules is a good
idea. We need to generate lots of comments that make clear any changes that would expose more people to the harsh 3-month time limit would be harmful, increase food insecurity, and are unwelcome.
Believe it or not, over 300 comments have already been submitted as of March 13 and many were supportive of making the
time limit harsher. It’s important that we demonstrate strong support for the current flexibility states have to waive this rule in order to try to stop USDA from pursuing a change via the regulatory process. The Center on Budget and Policy Priorities (CBPP),
Feeding America, and the Food Research & Action Center (FRAC) are working together to try to generate as many comments as possible.
Comments must be submitted by Monday April 9 -- Here’s how to take action:
1. Your organization can submit comments. We’ve
developed a template for organizations that can be easily customized. The template is here. You
can cut and paste your comments into the online submission tool here. Or,
if you prefer, there’s always USPS: Mail comments to SNAP Program Development Division, Food and Nutrition, Services, USDA, 3101 Park Center Drive, Room 812, Alexandria, Virginia 22302.
2. You can ask your networks to generate comments.
In some cases, you might want to use the organizational template that we provided. Feeding America has also created a template that’s more appropriate to individuals. They welcome you using and sharing their template
and online tool. It’s a terrific simple message that may work for a broader audience.
3. You can encourage other organizations in your state to submit comments and ask their networks to weigh in as well. Remember,
comments are counted individually. So, please don’t do a sign-on. And please ask everyone in your networks to submit individual comments. If you have any questions, please contact Ellen Vollinger (evollinger@frac.org); Ed
Bolen (bolen@cbpp.org) or Ana Hicks (ahicks@cbpp.org);
or Robert Campbell (rcampbell@feedingamerica.org).
We want to work with you.
