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The Agriculture and Nutrition Act of 2018 (H.R. 2), which the House is set to vote on this week, would impose harsh new work requirements on the nation’s largest and most effective anti-hunger program, the Supplemental Nutrition Assistance Program (SNAP).

Access to an adequate, healthy diet is crucial for families with children: it improves health outcomes for pregnant women and their children, helps to ensure that infants and toddlers meet developmental milestones and is essential for success in school. SNAP currently serves one in four children in the United States; it lifts almost five million children out of poverty and reduces food insecurity by one-third among children who receive it.

The House farm bill imposes sweeping new work requirements that for the first time mandate work for families with school-aged children and older adults. Under current law, states are already required to impose work requirements on “able bodied adults without dependents,” or people aged 18 to 49 who are not raising a minor child. This work requirement already has dire consequences: according to the Center on Budget and Policy Priorities (CBPP), at least half a million very poor adults lost SNAP benefits as a result of the work requirement in 2016.

The current version of the farm bill requires that parents with school-aged children and older adults between the ages of 49 and 60 also prove on a monthly basis that they are either working and/or participating in a qualifying job training program for 20 hours a week. There are limited exemptions to the proposed requirement and CBPP estimates that in 2021 up to 8 million people might be subject to it, including more than 2 million parents.

Work requirements have no place in a program meant to fight hunger and support the health and well-being of children and families. As decades of experience with work requirements under the Temporary Assistance for Needy Families (TANF) program have shown, work requirements in and of themselves do little to actually increase work or wages in the long term.

Education and training programs – not work requirements – can have lasting benefits, but the farm bill does not provide enough funding for such programs. If SNAP work programs’ per-participant costs approximated that of education and training under TANF, they would cost more than $1.2 billion per month, which translates to $15 billion per year or $150 billion over 10 years. The farm bill, by contrast, allots only $7.65 billion over 10 years in federal funding for these new work programs. States are unlikely to be able to fund the difference, even if they wanted to. The result, instead, will likely be that SNAP participants are funneled into under-resourced programs that do little to help them find good jobs.

Instead of leading to more meaningful work, the SNAP work requirement will simply result in more paperwork. To enforce the new work requirements, states will have to build expensive systems to track SNAP participants every month. The burden of proving that they meet work requirements will fall on participants. SNAP recipients who work low-paying jobs with unstable work hours might be unable to anticipate a shortage of work hours in any given month, until it is too late to add additional work hours. Workers with multiple employers, self-employed individuals and anyone who is searching for work or participating in job training will have a hard time documenting their hours.

Tracking work participation will be especially difficult for the families who need nutritional assistance most – including homeless families, families with mental and physical health problems and families with significant caregiving responsibilities. Indeed, many caregivers and people with physical and mental health conditions who should be exempt from the requirements will have trouble navigating the exemption processand effectively advocating their case if they are incorrectly assessed by a caseworker.

The result will be that families will lose much-needed assistance. As the experience under TANF shows, families sanctioned for failing to meet work requirements are disproportionately families of color and families facing multiple barriers – including homelessness, chronic illness, addiction, language barriers and physical and intellectual disabilities. If work requirements are expanded in SNAP, these same families are likely to see their benefits cut and food insecurity rise.

Indeed, communities of color that face racial discrimination and have higher rates of unemployment even when the economy is otherwise doing well, are especially likely to face sanctions under the SNAP work requirement proposal. Under current and proposed law, areas with high unemployment may receive waivers from the work requirement. But people of color are often less likely to live in the rural areas that qualify for waivers. The result will be that people of color may be more likely to be subject to work requirements than white people. We see this exact problem playing out now with the proposed Medicaid work requirement in Michigan.

All told, the farm bill may lead almost 1 million households to lose their SNAP benefits altogether or see them reduced, according to CBPP. When 60 percent of families with children receiving SNAP already work, a “work requirement” that simply makes it more difficult to put food on the table is the last thing they need.

Elisa Minoff is a policy analyst and Valery Martinez is a Emerson National Hunger Fellow at CSSP

New Public Charge Guidance Could Drive Children into Foster Care

  ·   By Alexandra Citrin

Children and their families – disproportionately children and families of color – come to the attention of the child welfare agency due to allegations of abuse and neglect. When the allegations are substantiated and ongoing intervention is deemed necessary to support the safety of the child, child welfare agencies work with the family to mitigate safety and risk concerns. While we know that children do best when they are with their families, sometimes due to safety concerns children must temporarily enter foster care. While a great deal of attention has recently been paid to the impact of the opioid crisis on driving more children into foster care, there has been a lack of awareness about the impact of current immigration policies – both real and perceived – and the resulting potential to drive children and youth from immigrant and mixed-status families into contact with the child welfare system.

Under the current administration there has been an ongoing attack through oppressive policies on immigrant and mixed-status families and their children. These policies include changes in Immigration and Customs Enforcement (ICE) activities, increased data sharing between the Office of Refugee Resettlement and ICE and leaked information on potential changes to what can be considered in public charge determinations.

As new immigration policies have been implemented, proposed and leaked, the Administration has not acknowledged the detrimental impact these policy changes have on the health, safety and well-being of families and children – and consequently, their potential involvement with child welfare. Nearly half of families (47 percent) who have their children removed from their homes have trouble paying for basic necessities, and with data showing the withdrawal of immigrant families from enrollment in critical programs due to fear of having information shared with immigration officials, the leaked proposed changes to public charge guidance may result in many more families falling into poverty.

Specifically, parents and providers are already reporting higher rates of food insecurity due to lower SNAP enrollment and renewals, lower rates of enrollment in public health insurance (e.g., Medicaid and CHIP) and lower rates of enrollment, attendance and parent participation in early care and education programs. Given that the leaked proposed changes to public charge guidance pit a family’s choice to access concrete supports and services that promote health and well-being in direct competition with their future ability to gain lawful permanent residency, we are likely to see more immigrant families struggle to meet their basic needs and finding themselves in situations where they and their children – both immigrant and citizen children – come to the attention of child welfare.

Simply becoming known to the child welfare system could have devastating impacts on immigrant and mixed-status families and their children since, simply due to their immigration status, once involved with child protective services, families may be afraid or unable to access necessary supports or services that would support their ability to remain together safely or achieve reunification if children have to enter foster care.

We know that children do best when they can safely remain with their families. However, recent policy proposals directly attack the safety net of support for immigrant and mixed-status families and may put their children at risk of experiencing circumstances of neglect. During National Foster Care Month, it is important that child welfare systems and advocates recognize the detrimental impact of these immigration policies and identify solutions for supporting immigrant and mixed-status families in accessing needed supports and services so that they can remain together and their children do not unnecessarily have to enter foster care.

CSSP is an Active Member of the Protecting Immigrant Families, Advancing Our Future Campaign organized to protect and defend access to concrete supports and services for immigrants and their families at the local, state and federal level. To learn more about the Campaign, the proposed changes to public charge guidance and what you can do to support immigrant and mixed status families, please visit this website or contact Alexandra Citrin (


Alexandra Citrin is a senior policy analyst at CSSP.

Over the last year, conservative legislators and the Trump Administration promoted work requirements across a wide range of public benefit programs. Their push for “welfare reform,” or, as administration officials sometimes refer to it, “Welfare Reform 2.0,” comes on the heels of a tax bill that offers massive tax cuts for the wealthiest Americans and corporations, but does little for everyone else.

Last month, President Trump signed an executive order directing all federal agencies to consider ways to strengthen existing work requirements and impose new ones. New or stronger work requirements have since been proposed for housing assistance, nutrition assistance and Medicaid health coverage.

Decades of evidence from the United States’ last experiment with “welfare reform” show why work requirements don’t work. Most notably, they do not accomplish their stated goal of helping people enter and maintain employment and increase earnings in the long run. Instead families who fail to meet requirements lose assistance – whether it is because they cannot find work, their jobs do not offer enough hours, they have health problems or caregiving responsibilities that interfere with work or they cannot keep up with the paperwork. Families at the lower end of the income distribution are hurt the most and extreme poverty has doubled over the last 20 years.

But there’s another problem with work requirements: they may be enforced in racially discriminatory ways and ultimately increase racial disparities. Evidence from 10 states suggests that African American parents are more likely to be penalized for failing to comply with work requirements than other parents receiving cash assistance through Temporary Assistance for Needy Families (TANF). The potential for work requirements to increase racial disparities is brought into sharp relief by recent developments in Michigan.

The Michigan legislature is currently considering a bill that would impose the harshest work requirements on Medicaid recipients yet. Currently 2.3 million Michiganders receive their health insurance through Medicaid – 1.6 million through traditional Medicaid and over 600,000 through Medicaid expansion, which covers everyone earning less than 138 percent of the federal poverty line. Despite the fact that nationally, the vast majority of adults receiving Medicaid live in working families and in Michigan the majority of people who benefited from Medicaid expansion either work or are unable to work, Michigan legislators are jumping on the bandwagon and proposing work requirements.

Michigan Senate Bill 897, which passed the Michigan Senate on April 19 and is currently before the House, imposes a 29 hour per-week work requirement – significantly higher than the approximately 20 hour requirement proposed by the three states that have received approval from the Trump Administration to institute Medicaid work requirements to date. If passed, this means that a single mother in Michigan who averages 28 hours of work per week in a given month could lose her health insurance. The draconian work requirement has attracted criticism from across the political spectrum, including from the state’s Republican Governor Rick Snyder.

Equally disturbing, however, is the revelation that the harshest features of the work requirement would be applied disproportionately to people of color. This is because the bill contains an out. Most Michiganders can only meet the work requirement if they work or are in education or training, but people living in counties with high unemployment (over 8.5 percent) can meet it by “actively seeking work.” While racially neutral on its face, in practice the provision means that people living in rural, largely white, counties with high unemployment will have an easier time meeting the requirement, while people living in majority African American cities like Detroit and Flint that have high unemployment but sit in counties where the unemployment rate falls below the 8.5 percent threshold will have a much tougher time meeting the requirement. The same holds true for Arab Americans and Muslims living in cities like Dearborn and Hamtramck.

These sorts of inequities are endemic to work requirements, and exacerbated by the Trump Administration’s decision to encourage local variation in how work requirements are applied. As George Washington University professor Sara Rosenbaum, an expert on health law and policy, has noted, the permission of local variation allows for “enormous discrimination, really racial redlining.” This is because rural areas, which often have both larger white populations and higher unemployment, are more likely to benefit from any geographic exemptions to work requirements. Urban areas, where many people of color live, will generally be subject to work requirements, despite the fact that communities of color often have high unemployment rates even within cities where unemployment rates may be relatively low.

The Michigan legislation shows how this racial redlining could work in practice. In states like Kentucky that have already received approval to institute Medicaid work requirements, similar racial redlining could go into effect as early as this summer.

Instead of imposing work requirements that do not help people find and keep good jobs, legislators should expand access to programs that do – including child care assistance, education and training, and, indeed, health care.

Elisa Minoff is a policy analyst at CSSP.

Children thrive and grow to become their best selves when they are surrounded by a safe, loving and supportive family. This year during National Foster Care Month, CSSP joins our community partners to renew our commitment to ensure that all children – including foster youth – are empowered to have the same sense of opportunity and potential as any other young person, regardless of who they are, where they come from or what their circumstances may be.

Currently, more than 200,000 children remain in the foster care system and many more age out of foster care before being placed with a family. This National Foster Care Month, we must continue to work to ensure more children find permanency so they are able to grow and flourish to the best of their potential. When we create supportive and safe environments for all young children and their families, we ensure a promise for a brighter and stronger country.

Viet Tran is the communications manager at CSSP.

Using Evidence to Advance More Equitable Outcomes

  ·   By Sarah Morrison

Last Tuesday, April 17th, CSSP hosted a symposium focused on the intersection of evidence and equity. This daylong conversation was designed to explore the relationship between evidence and achieving more equitable outcomes while also recognizing often overlooked evidence necessary for advancing equity.

We were thrilled to bring several great minds from the field together to discuss this critical notion of centering equity in the conversation about evidence.  Joining us for the discussions were:

  • Jara Dean-Coffey, Luminare Group
  • Shiree Teng, Independent Consultant
  • Tatiana Warren-Jones, Bon Secours Community Works
  • Bill Wright, Center for Outcomes Research and Education
  • Tom Kelly, The Hawaii Community Foundation
  • Cheryl Grills, Loyola Marymount University
  • Anthony Bryk, Carnegie Foundation for the Advancement of Teaching, Friends of Evidence

If you couldn’t join us, take a look at the Storify page from the day. And watch this space (and CSSP's Twitter and Facebook pages) as we begin a series of blogs that explore #Evidence4Equity.



Sarah Morrison is the director of learning and evidence at CSSP.


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