SNAP, ABAWDs, and Governor Haslam’s New Work Requirements

What’s an ABAWD?

Governor Haslam’s recent decision to voluntarily end waivers of time limits for childless unemployed workers will have significant consequences for our state if not done carefully.  There seems to be a lot of misunderstanding about what this policy is and how it works, and we’d like to help clear that up.

First, here’s a little history.  In 1996, Congress implemented a policy that limited the amount of time able-bodied adults without dependents (ABAWDs) could receive help through the Supplemental Nutrition Assistance Program (SNAP), formerly Food Stamps.  ABAWDs would only be allowed to receive assistance for three months in a three-year period unless they were working or engaged in work training at least 20 hours per week or participating in workfare or compulsory community service.  The time limit requirement makes no exception for women fleeing domestic abuse, people who are working 18 hours a week and would like to work more, or the recently unemployed who need help for more than three months as they look for a job.

At the same time, Congress recognized that there would be times and places where these policies would pose an undue hardship on people struggling to find work and the communities they live in.  That is why they included a provision that would allow states to waive the three-month time limit in counties with labor surpluses (i.e. not enough jobs to go around).  A county must have high unemployment or be very bad off in relation to the rest of the nation to qualify.

Because of the economic realities of the recession, every Tennessee county qualified for the time limit waiver until 2016.  As the economy has experienced an uneven recovery, some counties, primarily in metropolitan areas, no longer qualify for the waiver.  Despite that, 80 of Tennessee’s 95 counties have not fully recovered and will still meet the criteria for waivers in 2018.  The Governor’s administration chose to use more stringent requirements than required by federal law, however, and so only sought waivers for 16 counties.  That means 64 counties could continue to receive this relief next year but will not.

So what does the new state policy mean for your community and neighbors?

Obviously, everyone who can work should have the opportunity to contribute meaningfully to the economy and to be compensated for that work.  We applaud the Governor’s efforts to bring in high quality jobs to Tennessee and get our residents ready for those jobs.  The reality is that too many Tennesseans, and especially those impacted by this decision, have yet to benefit from these gains.  The map above shows how the new state policy will disproportionately impact rural communities across Tennessee, places that have not shared in the economic recovery to the same degree as their urban neighbors.

According to the Tennessee Department of Human Services (DHS), there are about 93,000 people statewide who would be subject to time limits.   Many of these individuals are already working while on the program, and some will find employment within the time limit, but still others are facing any of a number of challenges that prevent them from maintaining employment (i.e. domestic violence, temporary disability, homelessness, etc.).

The fact is that while there’s a lot of attention being paid to the record low unemployment rate in our state, that ignores much of the data that points to the very real struggles faced by so many Tennesseans.  Even in this improving economy, nearly half a million Tennessee workers lose their jobs due to private business closures and workforce reductions annually.  While many will soon find a new job, it all too often takes more than three months especially in communities with sparse employment opportunities.  Despite low unemployment numbers, according to data from the Tennessee Department of Labor and Workforce Development, there are more unemployed workers than available jobs in counties where the time limits will soon take effect.  In half of these affected counties, there are two unemployed workers for every available job. Put simply, even low unemployment means that there is unemployment, and it doesn’t make the challenges faced by those experiencing joblessness any easier.

Additionally, for many who will be impacted by this policy change, there truly is no work to be had for their qualifications.  While we strongly support the Governor’s Tennessee Reconnect initiative that provides last-dollar scholarships for post-secondary tuition, the people impacted by this policy are often very poor to begin with and don’t even have the transportation resources to get to classes, let alone all the other costs of pursuing an education.  Similarly, the workfare/community service option might sound reasonable on its face but what gets missed is that a SNAP participant may lack even the transportation resources to be able to meet this requirement.

Further, this is an extremely complicated policy that DHS has already demonstrated difficulty in implementing on a more limited scale.  Many individuals who comply or make a good faith effort to comply with ABAWD policies are being subjected to additional burdens on their participation, some are even being erroneously terminated from the program.  It’s hard to work or find work when you’re malnourished.  Even minor snags in implementing this policy could punish many who are truly just trying to get back on their own two feet and need a little help along the way.

This policy also adds to the administrative burdens of an agency, DHS, that is already extremely under-resourced.  DHS’s administration of SNAP is reliant on a 30-year old computer system that is inadequate to the tasks it must already perform. This will almost certainly result in other SNAP households – families with children, older adults, and adults with disabilities – receiving reduced service.  It will certainly do little to support DHS’s bold, new two-generation approach of moving families from welfare to self-sufficiency.

Finally, this has implications for all Tennesseans.  Those 93,000 ABAWDs receive an estimated $183 million in benefits.  While for any one person that may not be much (about $1.80/meal), it has a big impact on our retail grocery industry and supports nearly 1,800 jobs in some of the state’s most impoverished communities.  It won’t just have economic consequences, it will place a significant burden on Tennessee’s charitable food response.  That $183 million in potentially lost

Where do we go from here?

The decision to end time limit waivers will not go into effect until 2018.  There are a number of opportunities that the Governor and DHS have between now and then to ensure that this policy is implemented with the care needed to ensure that it will achieve its intended results.  First and foremost, the 64 counties being voluntarily removed from the waiver deserve to be re-examined for inclusion.  These are truly struggling communities, many are among the worst off in the nation.

At the same time, the economy is improving, and there will be even more counties where the federal government will require time limits to be enforced regardless of the Governor’s decision as long as the economy stays strong.  These are very complex policies, and it is important that they are implemented with great care.  Otherwise, eligible people, including older people and those with disabilities, may be mistakenly cut off of the program, an issue seen in other states.  To avoid cutting eligible poor Tennesseans off critical food assistance, DHS needs policies and processes in place that assess each individual’s case to determine whether they are subject to time limits, educate them about their responsibilities, and provide them with realistic opportunities to meet the work and training requirements.  Our state is not stronger and our economy is not better when our neighbors go hungry no matter the circumstances.  Let’s move people toward opportunity and self-sufficiency, but ensure that we do it in a manner that does not result in families going hungry.

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