The Missouri Department of Social Services resource center located in Columbia (Clara Bates/Missouri Independent).
Following the end of the federal public health emergency, around 26,000 Missourians receiving food assistance are once again subject to work requirements to maintain their benefits.
If the state does not receive the proper paperwork from participants, many could lose benefits beginning in October for the Supplemental Nutrition Assistance Program, commonly known as food stamps.
The federal government partially suspended a rule in March 2020 that sets a limit on the time adults without children can receive SNAP benefits, unless they meet work requirements or qualify for an exemption.
But those time limits were reinstated as of July 1 for all states that do not have a waiver with the federal government allowing them to keep suspending the rule. Missouri did not apply for a waiver.
Without proof of work, training or an exemption, those adults can only receive SNAP benefits for three months out of every three years.
“If the proof is not sent to [Family Support Division] by September 30, 2023, you could lose your SNAP benefit,” according to Missouri’s social services department website.
Gina Plata-Nino, deputy director for SNAP at the D.C.-based Food Research & Action Center, said she is “incredibly concerned” about the effects nationwide of the time-limit reinstatement — including for participants who cannot consistently secure 20 hours of work per week, or struggle to amass and submit the proper paperwork to prove they do.
“Time limits don’t increase economic development or the workforce, but instead are more harmful,” Plata-Nino said, “because these individuals are still struggling to meet those 20 hours [of work per week].
“The only difference is that now they don’t have SNAP benefits.”
Burden on participants to provide proof of work
The group of SNAP recipients affected is “able-bodied adults” between 18 to 49 years old who do not have dependents — around 28,000 people, according to the Department of Social Services.
They will need to prove that they work or participate in qualifying training activities for 80 hours a month, or meet an exemption, which includes disability, pregnancy and illness.
The time limit rule has been in place since the federal government enacted sweeping welfare changes in the mid-1990s, which were framed as helping move participants from government aid to work and encouraging self-sufficiency. The rule was suspended during the 2008 Great Recession and during COVID-19 public health emergency.
The public health emergency ended in May, and July is the first month the time limits for those adults on SNAP will be reinstated.
Missouri initially tried to reinstate the time limit much sooner — in the summer of 2020.
But state officials walked that back after concern about “possible penalties” from the federal government for resuming the rules before the end of the public health emergency, said Adam Crumbliss, deputy director of the Missouri Department of Social Services.
Now, 14 states and Washington, D.C., have waivers with the federal government allowing them to continue suspending the requirements, said a spokesperson for Food and Nutrition Services — but Missouri is not among them.
The Department of Social Services mailed letters to qualifying adults on SNAP in April and June of this year, Crumbliss said, notifying them of the reinstated time limit.
Some of those adults who fall under the restrictions may have joined the program since March 2020 and never dealt with the process.
“Those who enrolled in the SNAP…programs during that time are likely to be unfamiliar with these requirements,” Jennifer Tidball, then-acting director of the social services department, said in the 2020 press release.
SNAP participants in the affected group will need to contact the Department of Social Services to provide proof they are meeting the work requirements — online, in person, by fax or mail — or to prove they meet an exemption.
Individuals who believe they qualify for an exemption can call the state or go in-person to a resource center, Crumbliss said.
An applicant calling the social services call center, though — for instance, a disabled SNAP recipient seeking an exemption — could wait hours to connect with a representative.
The average time for a caller to be connected to an agent, Crumbliss said, was just under two hours in May and June for the tier that includes general SNAP-related questions. (The wait times were 1 hour 48 minutes in May and 1 hour and 55 minutes in June, up to June 27, Crumbliss said.)
Securing an exemption can be difficult, said Plata-Nino, because it requires substantial verification — potentially leaving some of the most vulnerable populations, such as disabled individuals, without benefits.
“We’ve seen time and time again, that many disabled individuals, particularly those who have mental or cognitive disabilities,” she said, “have a difficult time proving their disabilities or speaking to the agency to say ‘I’m struggling with this.'”
Participants need to gather all the relevant information, such as doctor’s notes, and submit it by a deadline, or risk losing benefits and needing to reapply.
Other SNAP participants not seeking exemptions could still lose benefits for administrative reasons.
Some low-wage workers may not have consistent hours. Some work, like fee-for-service construction work or gig economy jobs like Uber driving, may not have clearly quantified hours easy to prove to a state agency.
Participants can receive three months of benefits without meeting the requirements during the period July 2023 to June 2026.
That means Missourians currently enrolled in SNAP unable to prove their work or training 20 hours per week, or exemption, could lose benefits beginning in October.
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The last time SNAP work requirements were reinstated after a pause, in 2016 in Missouri, research found that SNAP participation fell while employment rates did not substantially change.
A study from the DC-based think tank Urban Institute in 2021 examined reinstatement of the rules after the recession, including using Missouri as a case study.
Researchers found the time limit does not substantially increase employment, but does substantially reduce SNAP participation. Four months after the limit was reinstated in Missouri, the Urban Institute found, SNAP participation in the cohort of those subject to the restrictions had fallen by 39 percentage points. There was no statistically significant effect on employment.
A study from earlier this year, in the American Economic Journal, found that instating work requirements reduces SNAP participation among that group of adults by 53% in the 18 months after being instated.
“Unlike the large effects on program participation,” those researchers found, “effects on employment are limited.”
In other social services realms, participants don’t always know of new work requirements: After Arkansas adopted work requirements for Medicaid in 2018, the majority did not report qualifying activities to the state and thousands were kicked off.
Age for time limits to be raised to 54
Other work requirements tweaks are on the horizon nationally. Later this year, a SNAP-related provision of the federal debt ceiling agreement will go into effect. Phased in over several years, that provision will raise the age of adults subject to the work requirements from 49 up to 54.
The Center for Budget and Policy Priorities estimated around 11,000 could be affected in Missouri. The Department of Social Services did not provide their own estimate and said they are working with the federal government to implement the new rule.
The debt ceiling agreement also added new exemptions — for veterans, people experiencing homelessness, and adults transitioning from foster care. But advocates worry the difficulty of navigating through the red tape to secure an exemption will continue to prove overly burdensome, or insurmountable, for those who may need the food assistance most.
“Doubling down on the existing, failed SNAP work-reporting requirement for adults aged 18-49 without children,” CBPP president Sharon Parrott said in a statement, “this provision ignores the strong evidence that it takes food assistance away from large numbers of people without increasing employment or earnings.”
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