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The Dismal Economics of SNAP’s Work-Hours Test and Time Limit [1]

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Date: 2023-06

Introduction

The Supplemental Nutrition Assistance Program, or SNAP, reduces food insecurity, which in turn improves people’s health and economic well-being. Yet, SNAP’s effectiveness is limited by restrictions that target people deemed undeserving by some policymakers — undeserving, essentially, of a healthy but basic diet. This brief discusses one of the most onerous of these restrictions: a complex work-hours test and time limit, applied on top of SNAP’s other work-related requirements. The test requires adults under age 50 to clock at least 80 hours of countable work each month unless they qualify for an exemption from the test or live in an area where the test has been waived due to insufficient job opportunities. If they fail the test or cannot show they passed it to the satisfaction of local officials, they are excluded from SNAP. The federal government has waived the 80-hour work test nationwide while the COVID-19 public health emergency declaration is in place, but this declaration will be lifted in May 2023. Once this happens, people subject to the work test will start to lose SNAP food vouchers in October 2023. States and local SNAP agencies have some discretion in implementing the test, so their decisions will partly determine how many people are harmed.

This paper reviews relevant empirical research on the work-hours test. According to conventional economic theory, SNAP and other means-tested programs provide a minimum guaranteed income to very low-income households or people. That minimum income is then reduced as earnings or other income increases. In theory, this can lead people to remain out of the labor market or reduce their work hours, depending on how they value their time. This theory may hold when the guaranteed income is a monetary benefit that is large enough to afford housing, utilities, food, clothing, transportation, and other basic needs, especially if any earnings received reduce the benefit on a dollar-for-dollar basis. But SNAP only provides a modest, in-kind benefit — a food “value voucher” that people can only use to buy food to prepare meals at home — and also has benefit calculation rules that make it financially advantageous to have a job. It seems unlikely that many people will opt not to work or reduce their work hours — and forgo the money income that they receive for it — simply to receive a small, in-kind benefit like SNAP.

Taken as a whole, the empirical studies reviewed in this report provide strong evidence that the test is counterproductive — it has no or little positive impact on employment while excluding a substantial number of vulnerable people from SNAP. The test’s complexity places administrative burdens on both people receiving SNAP and officials in local SNAP offices. The collateral consequences include people who should be exempt from the test losing access to SNAP and the federal government wasting money to administer the test that could be put to better use elsewhere. The administrative burdens partly explain why the test has a negative spillover effect on homeless people and disabled people, even though disabled people are legally exempt from the test, and homeless people generally should be exempted by local officials.

Rep. Barbara Lee (D-CA) has introduced legislation in the current session of Congress that would repeal the work-hours test. Given the well-documented harm caused by the test, Congress should pass repeal legislation when it reauthorizes the Farm Bill later this year. Despite the strong evidence showing that the test is counterproductive, some conservative policymakers have called for subjecting more people to it. Sen. Rick Scott (R-FL) and Rep. Dusty Johnson (R-SD) have introduced legislation that would extend the test to more groups of people receiving SNAP vouchers, including many older people — 50- to 59-year-olds in Scott’s bill and 50- to 65-year-olds in Johnson’s — and parents and other adults living with school-age children. Both bills would also take away states’ ability to waive the test in areas with insufficient job opportunities. If legislation like this is enacted, experts estimate that more than 10 million people could lose SNAP food vouchers. Based on the evidence compiled here, these massive losses would not be offset by increased employment and earnings and would have other adverse impacts on health and well-being.

Background on SNAP and the 80-Hours Work Test

SNAP provides vouchers — in the form of an electronic benefit transfer, or EBT, card — that eligible people can use to purchase groceries. Over 42 million people — about 1 in 8 people in the United States — currently buy some or most of their groceries with SNAP vouchers. The maximum value of SNAP vouchers varies by household size. The average value of the food voucher that households receive depends on income and other factors. A person living alone and receiving the average monthly amount ($195) can use it to buy groceries amounting to $2.17 per meal. For a household of three, the average monthly amount ($577) can be used to purchase food for meals costing about $2.14 for each person in the household.

People subject to the work-hours test are conventionally called ABAWDs — short for able-bodied adults without dependents — and the test itself is called the ABAWD work requirement and time limit. The ABAWD label is problematic for a number of reasons. “Without dependents” implies that no people harmed by the test are parents. Yet, the test applies to parents who do not live regularly with their children, even if these parents provide care and support that their children depend on. “Able-bodied” is disfavored by many people in the disability rights movement. Moreover, the research discussed below suggests that many people with disabilities still end up being excluded from SNAP because of the test. Finally, there is no common ABAWD identity in the world outside of the SNAP program — it is hard to imagine anyone self-identifying as an able-bodied adult without dependents or an ABAWD. For these reasons, this brief generally uses the terms “80-hour work-test,” “work-hours test,” or just “test” instead of ABAWD requirement.

SNAP’s Standard Employment-Related Requirements

SNAP requires most unemployed 18- to 59-year-olds receiving benefits to register for work and accept almost any job they are offered. In addition, employed workers receiving SNAP may not voluntarily quit a job or reduce their work hours to less than 30 hours a week without good cause. States can also require adult household members to participate in the SNAP Employment and Training Program, except for members who are elderly, disabled, caring for young children, or who fall into certain other exempt categories. States must operate a SNAP Employment and Training Program, but they have considerable flexibility when it comes to deciding to whom to provide services and how to structure their programs. Programs typically involve various basic employment and training services, including employment assessments and job search assistance, and may also include vocational training, subsidized employment, and supportive services.

The 80-Hours Work-Test

The 80-hours work test is an additional employment-related requirement. The test is convoluted and difficult to describe in plain language, so what follows is a simplification. Over a 36-month period, adults subject to the test can receive up to three months of SNAP during months in which they work less than 80 hours. Once they have received SNAP for three months in which they did not work at least 80 hours, they are barred from receiving SNAP in any of the remaining months in the 36-month period. They can requalify by showing that they have worked at least 80 hours in a subsequent month. In addition to hours of paid work, hours spent in some types of unpaid labor and other activities count toward the test, including hours of participation in a SNAP Employment and Training Program or other approved work program. The three months that trigger the test do not need to be consecutive. Thus, if a person subject to the test works 140 hours monthly in January, March, and May but only 79 hours monthly in February, April, and June, they are barred from receiving SNAP in any of the subsequent 27 months in which they work 79 or fewer hours.

Who Has to Pass the Test

The test applies to 18- to 49-year-olds unless they are pregnant, live with a minor child, care for an incapacitated person, are determined to be physically or mentally unfit for employment or meet one of a few other narrow exemptions. If a person is not receiving temporary or permanent disability benefits, like Supplemental Security Income, they will typically need to provide certification from a doctor that they are physically or medically “unfit” for work. Depending on where a person subject to the test lives, there may be other state-specific exemptions. States can also ask the USDA to waive the work-hours test in geographic areas with insufficient jobs. The convoluted nature of the test places considerable administrative burdens — beyond those due to SNAP’s income and asset tests and standard work and training requirements — on SNAP agencies and the people who are subject to the test or trying to obtain exemptions from it. As a result, some people give up on obtaining SNAP benefits for which they are eligible, and that would improve their health and well-being, while others lose eligibility and then return a few months later.

Waivers in Areas with Insufficient Jobs

As noted above, the federal government suspended the test nationwide during the COVID-19 public health emergency. In 2009, as part of the American Recovery and Reinvestment Act, Congress also waived the work-hours test in response to the Great Recession. The national suspension ended in 2010. Some states reinstated the test statewide, regardless of job availability; others obtained permission from USDA not to apply the test in areas where jobs were insufficient.

Administrative Burdens

State and local SNAP officials have long noted the burdensome nature of the work-hours test. In a 2016 report, the USDA’s Office of Inspector General noted that state SNAP officials used terms like “administrative nightmare” and “operational nightmare” to describe the work-hours test. Officials also expressed concerns about the costs of administering the test — both in terms of time and resources — and how the convoluted nature of the test increases the likelihood that people are erroneously denied benefits for which they are eligible.

Estimated Number of People Subject to Test and Demographics

As part of a major federally funded study that examined the effects of the work-hours test in nine states after it was reinstated in the mid-2010s, researchers at the Urban Institute and Westat estimated that 4 to 9 percent of people receiving SNAP food vouchers in each of the states were potentially subject to the test. If the same share of people currently receiving SNAP are potentially subject to the test when it is reinstated later this year, about 1.6 million to 3.7 million people are at risk of losing SNAP benefits. In a 2018 analysis, Lauen Bauer and her colleagues at the Hamilton Project estimated that about 2.2 million people who reported receiving SNAP benefits nationwide in 2017 were potentially subject to the work-hours test.

The Urban Institute’s nine-state report used SNAP administrative data to examine the characteristics of 18- to 49-year-olds receiving SNAP at the time of reinstatement of the work-hours test in each state in the mid-2010s. About 50 to 60 percent of people subject to the work-hours test had a high school degree, about 20 to 30 percent had no high school degree, and very few had education beyond high school. Most people subject to the test live in single-person SNAP households and have lower total incomes than other 18- to 49-year-olds receiving SNAP. Although adult women are more likely to participate in SNAP than adult men, men are more likely to be subject to the work-hours test than women in large part because men are more likely to live in households without children. Five states in the Urban study had SNAP administrative data on homelessness. In all of these states, the percentage of homeless people subject to the work-hours test was much higher than the percentage of other 18- to 49-year-old homeless people receiving SNAP.

Literature Review

We identified 19 studies published or made publicly available since 2010 that use empirical methods to estimate the impact of the work-hours test on various outcomes, most commonly labor supply, SNAP participation, and income. Eleven of the studies are peer-reviewed journal articles. The remaining studies comprise one book chapter, one major federally funded report, one research brief, and five working papers. We did not include research published before 2010 both because it is well-covered elsewhere and generally much weaker methodologically than more recent research.

Researchers seeking to estimate the effects of the SNAP work-hours test face a number of challenges. The test has never been evaluated using a randomized controlled trial in which people are randomly assigned to a group subject to the test and a control group not subject to the test. Instead, most of the studies summarized here use quasi-experimental methods — typically to estimate the impact of the reinstatement of the work-hours test in the wake of the Great Recession. As noted above, after the national suspension of the test was lifted in 2010, there was considerable variation between states and areas within states in the applicability of the work-hours test. This variation makes it possible for researchers to control for, to some extent, measurable characteristics and other factors that influence labor supply, SNAP receipt, and health and well-being. Still, the lack of randomization means that results may be caused by factors that are not controlled for in the research.

Estimating the effect of the work-hours test is also challenging because it impacts a relatively isolated group of people who are typically unemployed or precariously employed and often have unstable housing arrangements. As a result, they may not be well-captured in household surveys. Moreover, participation in SNAP is underreported in household surveys, which increases the likelihood of selection bias and sampling errors. Many of the studies discussed in this paper rely in part on administrative data, including information collected from people as part of the SNAP eligibility process and employee wage and hour information that employers provide to Unemployment Insurance officials on a quarterly basis. Administrative data has some advantages over survey data, especially when addressing underreporting benefits in household surveys. But survey data has some advantages over administrative data, especially regarding demographic detail. Researchers have taken different approaches to address these challenges. The Appendix table summarizes the methodology and key findings for each study.

Summary of Impacts

Table 1 summarizes the findings of the 19 studies reviewed (for a full description of methods and findings, see Appendix Table A1). The growing body of research on the SNAP work test tells a relatively consistent story about its impacts. The test has little or no positive impact on employment but does reduce access to SNAP food vouchers among vulnerable people with few resources. These findings generally hold across the different methodological approaches used by researchers. There is some evidence of harmful spillover effects, including on homeless and disabled people, who generally should be exempted from the test. There is also some evidence of negative impacts on individual and community well-being indicators, including health, past-due debt, property crime, and food-pantry utilization.

Table 1

Impact on Receipt of SNAP Food Vouchers

Fifteen of the studies examined the effect of the work-hours test on SNAP participation. Not surprisingly, all of these studies found that the test reduced participation. Among the notable published journal articles, Ku et al. (2019) use administrative data from 33 states and estimate that after the reinstatement of the work-hours test in the mid-2010s, more than one-third of people subject to the test lost benefits. If representative of all US states, this would mean that about 600,000 people lost about $2.5 billion in food vouchers between 2013 and 2017 due to the test. Brantly et al. (2020) use national data from the American Communities Survey (ACS) and find a similarly large reduction in SNAP participation due to the test. They also find that the test reduced SNAP participation among disabled 18- to 49-year-olds, a group that should be exempted from the test, suggesting that the disability exemption is not consistently applied, perhaps in part due to administrative burdens involved in obtaining it.

Impact on Employment and Earnings

Of the 10 studies that examined the impact of the test on employment, seven found no positive employment impacts, and three found positive impacts. Among the notable published journal articles, Han (2022) uses national household survey data (ACS) and finds that increasing the share of people in a substate area who are exempt from the test —due to waivers or additional exemptions — does not increase employment. Similarly, Gray and colleagues (2023) use administrative data (SNAP and UI wage records) from Virginia and find no significant change in employment after the reinstatement of the test in the wake of the Great Recession.

Two published journal articles and one working paper find employment increases. Harris (2021), using the ACS, finds a small (1.3 percent) increase in employment that was limited to urban areas. Cuffey et al. (2022) also find a positive employment impact, but their methodology is among the weakest of those used in the published studies. Their sample is limited to adults without a high school diploma — even though most people subject to the test have a high school diploma — and the survey they rely on (CPS) has a much smaller sample size and much more limited geographic detail than the ACS. In fact, the authors acknowledge the “likelihood that this group [low-income adults who do not have a high school diploma] is sufficiently small and that SNAP work restrictions would not have a meaningful effect on [the larger overall group of adult SNAP participants who do not live with children] or labor market outcomes of low-income adults in general.”

Impacts on Income and Other Wellbeing Indicators

If the test reduces SNAP participation without increasing employment, people impacted by it will have lower net incomes until they can offset the benefit loss by finding other sources of income. These could include disability benefits, transfers from family members or friends, using credit cards, spending down liquid assets, or borrowing money. Using administrative data (SNAP and UI wage data) from three states, Veriker et al. (2023) estimate that the work-hours test reduces combined income from SNAP and earnings by 8 to 21 percent, but they are not able to estimate total net income. The only other published journal article to find suggestive evidence of net income loss is Coffey et al. (2023). Using food pantry data from three states, they find that food pantries in urban areas where the work-hour test was reinstated served 34 percent more households in the eight months after the reinstatement than food pantries in urban areas that did not reinstate the test.

Some of the working papers also include suggestive, if preliminary, evidence of reduced income and consumption. Using CPS data and SSA administrative data, Stith (2019) finds that the work-hours test may increase applications for Supplemental Security Income, a means-tested disability benefit, particularly among people who self-report activity limitations other than blindness. Using national consumer credit data, Dodini, Larrimore, and Trafaglia (2022) find that reinstatement of the work-hours test led to increased credit balances, including past-due balances. In theory, this could be due to increased employment, which the authors could not measure in their research. But after considering the possibility, they conclude that the results reflect “financial vulnerability” and “strongly point to consumers seeking out and using new credit in order to make up for lost SNAP benefits.” In addition to reductions in SNAP participation, Lippold and Remy (2021) find increases in property crime and homelessness.

Finally, two published journal articles document health-related impacts. Allen et al. (2023) use Medicaid and SNAP administrative data from West Virginia and finds that reinstatement of the test in nine counties increased the probability of visiting a mental health provider for a mood disorder or anxiety for both men and women. They note that the increase could be due to the loss of SNAP directly impacting mental health, increasing the likelihood of visiting a provider to address pre-existing issues, and increasing the likelihood that people with pre-existing issues visit a provider to obtain the certification needed for a disability exemption from the test. Feng (2022) analyzes data from the monthly state data from the CDC’s Behavioral Risk Factor Surveillance System and finds that, besides having no impact on employment, the test increases the likelihood of experiencing a physically unhealthy day by 14 percent.

Implications for Future Research

Taken as a whole, the research summarized here provides conclusive evidence that the work-hours test reduces SNAP participation and is very strong evidence that it does not increase employment. Even if the test has a positive effect on employment and earnings, it appears to be very small. Still, it would be helpful to have more research that examines whether the effects of the test on employment and SNAP participation vary by class, ethnicity and race, gender, age, and other categories. Researchers also shouldn’t assume that disabled people are automatically exempted from the test, especially if they are not receiving benefits like SSI and SSDI. In addition, as Dong and Feng (2021) note, the work-hours test is likely to negatively impact formerly incarcerated individuals given their high unemployment rates, but beyond suggestive small-n qualitative studies, researchers have not focused on this group. Finally, additional research is needed to estimate the impacts of the work-hour test on net income, consumption, housing stability, health, credit usage, and other outcomes.

Conclusion

Congress added the work-hours test to SNAP in August 1996 during a presidential election year when President Clinton was in the last year of his first term, and Congress was controlled by Republicans, including Rep. Newt Gingrich, then the Speaker of the House, and Sen. Bob Dole, the Senate Majority leader who was running against Clinton. As political scientists have documented, anti-Black racism and paternalism played a central role in passing legislation — the Personal Responsibility and Work Opportunity Reconciliation Act, or PRWORA — that included the work-hours test and other benefit cuts. Both crime and welfare had become “racially coded” issues that activated White people’s racist beliefs that Black people are lazy and immoral. When Congress passed PRWORA, political scientist Martin Gilens published research finding that negative views of Black people receiving “welfare” had become more politically potent than ones of White people and helped to generate opposition to means-tested programs. Other major pieces of legislation enacted during this period — including the 1994 Crime Bill and the U.S.-China Relations Act of 2000, which normalized long-term trade relations with China — are now widely viewed as missteps that harmed working-class and vulnerable people on a mass scale. The work-hours test has gotten much less attention over the years, but it should also be viewed as a counterproductive misstep that has harmed the working class.

When the work-hours test became law in 1996, the economy was strong, and unemployment was relatively low — the average annual unemployment rate was 5.4 percent in 1996 and continued downward until reaching an average annual rate of 4 percent in 2000, which was, at that point, the lowest annual rate since 1969. At the same time, these headline numbers masked underlying weaknesses. Among 25- to 54-year-old men without college degrees, labor force participation declined sharply in the early 1990s — while it stabilized for a few years in the latter half of the 1990s, it has continued to trend downward over time. In contrast to other countries with higher levels of labor force participation and employment among 25- to 54-year-old men, the United States has an extremely limited welfare state for people in this age range. SNAP is one of the few meaningful benefits they may qualify for, but there is no good reason to think that a program providing a modest food voucher plays any significant role in this long decline. Punitive policies like the work-hours test have likely intensified working-class men’s struggles in recent decades.

The empirical research summarized here suggests that the labor market and working-class people’s employment decisions are more complex than conventional theory and the thinking behind the work-hours test assumes. The test has done more harm than good. Congress should repeal it this year and expand social insurance and employment and training services for working-class people, including non-disabled people who do not live with children. Finally, the fact that so many working-class people need basic food vouchers has little to do with the people themselves and everything to do with the rules that structure the economy. Those rules need to be changed in ways that produce inclusive prosperity.

Appendix

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[1] Url: https://www.cepr.net/report/the-dismal-economics-of-snaps-work-hours-test-and-time-limit/

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