KyPolicy submitted the following comments on August 13, 2021, in response to the U.S. Department of Agriculture’s Request for Information titled “Identifying Barriers in USDA Programs and Services: Advancing Racial Equity and Support for Underserved Communities,” USDA Docket ID: FSA-2021-0006.
The Supplemental Nutrition Assistance Program (SNAP) has proven to be one of the most effective anti-hunger and anti-poverty initiatives in the U.S. and helps over 603,000 Kentuckians put food on the table.1 During the ongoing pandemic and the resulting economic downturn, the safety net including SNAP has been a critical support for families. In fact, safety net programs cut poverty in Kentucky by two-thirds this year and nationally a projected 7,945,000 Americans will be removed from poverty through the SNAP program in 2021.2
Despite the SNAP program’s success in helping people out of poverty, current SNAP benefits are simply not enough to provide families with low incomes enough food, and many Kentuckians face barriers to getting the benefits they are eligible to receive. Black Kentuckians, and Kentuckians of color in general, have higher rates of poverty and food insecurity because of historical and systematic barriers to educational and economic opportunities. These in turn worsen the disparities in health and well-being, which have only been exacerbated by the disproportionate impact the pandemic has had on these families.3 In order to ensure all Kentuckians have access to adequate food the USDA should increase the SNAP benefit amounts, improve communications and remove barriers for immigrant and refugee communities.
Nearly half of all SNAP participants remain food insecure.4 One factor contributing to continued food insecurity is that current benefit levels aren’t enough for Kentuckians to afford consistent access to healthy, culturally-appropriate and available foods. Significant research shows that SNAP benefits, which averaged $1.40 per person per meal when SNAP benefits were prorated based on income before the pandemic, are too low for SNAP households to afford enough healthy food.5 An estimated 88% of SNAP participants face barriers to getting a healthy diet and 61% cite cost as a key barrier to accessing adequate healthy foods.6
Evidence shows that increasing SNAP benefits would have a significant impact on food security, particularly for those with the lowest incomes and for families with dietary restrictions or different nutritional needs – all of which are more prevalent in Black households and households of color.7 When asked directly, people who experience food insecurity estimate they need between $10-$20 per person per week in additional benefits.8 Meanwhile, some research indicates single-person households would need an additional $107 more each week to compensate for the time cost for one person to purchase and prepare meals.9 Another study estimated food-insecure Black households participating in SNAP reported needing an average of $49 more per week to become food secure, substantially more than the $38 reported by white households.10 The amount of benefit increase needed has been projected by researchers to show that increasing SNAP benefits by 20% would result in an estimated decrease in food insecurity by 46%, while a 42% increase in SNAP benefits would roughly result in a 62% decrease in food insecurity.11
Increasing SNAP benefits is an urgent need. Temporary supports in response to the pandemic — such as the 15% increase in SNAP benefits established in the American Rescue Plan and Emergency Allotments which increase monthly benefits levels to the maximum amount for a SNAP household’s size, rather than being based on income like they are normally — have resulted in an estimated average of $210 per month in SNAP benefits for Kentucky families compared to an average of $123 per month in 2019.12 These supports have been successful in providing additional grocery money to families during the pandemic and its economic downturn and Kentuckians participating in SNAP have said it has made a real difference.13 However, the 15% increase in SNAP ends Sep. 30, 2021, and when the pandemic is no longer declared a public health emergency, Emergency Allotments will end and benefit levels will return to their inadequate pre-pandemic levels.
In addition to the inadequate amount of SNAP benefits, not everyone is able to easily access the benefits they are eligible to receive. The public charge rule created a chilling effect that scared families from applying to public benefit programs they were eligible for and resulted in one in seven adults in immigrant families avoiding participating in multiple public assistance programs in 2018 and 2019.14 Despite the ending of the public charge rule, its chilling effect remains for immigrant and refugee communities.15
Two recommendations to combat the residual impact of the public charge rule are to improve and target communications and to remove both immigrant-specific and general barriers to the application and recertification processes. The USDA should improve and target communications by training staff to provide culturally and linguistically relevant enrollment and recertification services and increasing outreach to immigrant communities with culturally relevant messaging. Also, the USDA should remove barriers to the application and recertification processes by removing immigrant status or social security requirements from all forms, simplifying forms for people with low literacy and providing forms in various languages. Improving communications and removing barriers will ensure more Kentuckians are able to access the help with groceries they are eligible to receive.
Federal nutrition assistance programs, like SNAP, play a vital role in reducing food insecurity, improving health and stimulating local economies particularly during an economic downturn.16 SNAP has a history of providing a wide range of Kentuckians with the ability to get much needed help with groceries. In order to ensure all Kentuckians get adequate food assistance, the USDA should increase SNAP benefit levels and improve access to SNAP for immigrant and refugee families.
- Dustin Pugel, “Tracking SNAP in Kentucky,” Kentucky Center for Economic Policy, July 10, 2021, https://kypolicy.org/tracking-snap-in-kentucky/.
- Dustin Pugel, “Federal Relief Programs Cut Poverty in Kentucky by Two-Thirds This Year,” Kentucky Center for Economic Policy, August 5, 2021, https://kypolicy.org/federal-relief-programs-cut-poverty-in-kentucky-by-two-thirds-this-year/. Laura Wheaton, Linda Giannarelli, and Ilham Dehry, “2021 Poverty Projections,” Urban Institute, July 2021, https://www.urban.org/sites/default/files/publication/104603/2021-poverty-projections_0_0.pdf.
- Jessica Semega, Melissa Kollar, Emily A. Shrider and John Creamer, “Income and Poverty in the United States: 2019,”Report Number P60-270, United States Census Bureau, Sept. 15, 2020, https://www.census.gov/library/publications/2020/demo/p60-270.html. Margot Nitschke, “Hunger, Poverty, Race and the Alliance’s Race Equity Project,” Alliance to End Hunger, July 27, 2017, https://alliancetoendhunger.org/hunger-poverty-race-and-the-alliances-racial-equity-project/.
- Steven Carlson, Brynne Keith-Jennings and Joseph Llobrera, “Policy Brief: Modernizing SNAP Benefits Would Help Millions Better Afford Healthy Food,” Center on Budget and Policy Priorities, July 20, 2021, https://www.cbpp.org/research/food-assistance/more-adequate-snap-benefits-would-help-millions-of-participants-better-0. Elaine Waxman, Craig Gundersen and Megan Thompson, “How Far Do SNAP Benefits Fall Short of Covering the Cost of a Meal?” Urban Institute, Feb. 2018, https://www.urban.org/sites/default/files/publication/96661/how_far_do_snap_benefits_fall_short_of_covering_the_cost_of_a_meal_2.pdf. Steven Carlson, Joseph Llobrera and Brynne Keith-Jennings, “More Adequate SNAP Benefits Would Help Millions of Participants Better Afford Food,” Center on Budget and Policy Priorities, July 15, 2021, https://www.cbpp.org/research/food-assistance/more-adequate-snap-benefits-would-help-millions-of-participants-better.
- Steven Carlson, Brynne Keith-Jennings and Joseph Llobrera, “Policy Brief.” Patricia Anderson and Kristin F. Butcher, “The Relationship Among SNAP Benefits, Grocery Spending, Diet Quality, and the Adequacy of Low-income Families’ Resources,” Center on Budget and Policy Priorities, June 14, 2016, https://www.cbpp.org/research/food-assistance/the-relationships-among-snap-benefits-grocery-spending-diet-quality-and.
- United States Department for Agriculture, “Barriers that Constrain the Adequacy of Supplemental Nutrition Assistance Program (SNAP),” Food and Nutrition Services, United States Department for Agriculture, June 23, 2021, https://www.fns.usda.gov/snap/barriers-constrain-adequacy-snap-allotments.
- Steven Carlson, Brynne Keith-Jennings, and Joseph Llobrera, “Policy Brief.”
- Craig Gunderson, Brent Kreider and John V. Pepper, “Reconstructing the Supplemental Nutrition Assistance Program to More Effectively Alleviate Food Insecurity in the United States,” Journal of the Social Sciences, no. 2, vol. 4 (Russel Sage Foundation, Feb.2018), https://www.jstor.org/stable/pdf/10.7758/rsf.2018.4.2.06.pdf.
- Elaine Waxman, Craig Gundersen and Megan Thompson, “How Far Do SNAP Benefits Fall Short of Covering the Cost of a Meal.”
- Craig Gunderson, Brent Kreider and John V. Pepper, “Reconstructing the Supplemental Nutrition Assistance Program to More Effectively Alleviate Food Insecurity in the United States.”
- Steven Carlson, Joseph Llobrera and Brynne Keith-Jennings, “More Adequate SNAP Benefits Would Help Millions of Participants Better Afford Food.”
- Dustin Pugel, “Tracking SNAP in Kentucky.” Lauren Hall, “A Closer Look at Who Benefit from SNAP,” January 12, 2021, https://www.cbpp.org/research/food-assistance/a-closer-look-at-who-benefits-from-snap-state-by-state-fact-sheets#Kentucky.
- United States Department for Agriculture, “USDA Increases SNAP Benefits 15% with Funding from American Rescue Plan,” Food and Nutrition Services, United States Department for Agriculture, March 22, 2021, https://www.usda.gov/media/press-releases/2021/03/22/usda-increases-snap-benefits-15-funding-american-rescue-plan. Kentucky Center for Economic Policy and Kentucky Equal Justice Center, “Kentuckians Struggling to Survive,” September 2020, https://kypolicy.org/wp-content/uploads/2020/10/Southern-Voices_-Kentucky-Survey.pdf.
- Hamutal Bernstein, Dulce Gonzalez, Michael Karpman and Stephen Zuckerman, “Amid Confusion over the Public Charge Rule, Immigrant Families Continued Avoiding Public Benefits in 2019,” Urban Institute, May 18, 2020, https://www.urban.org/research/publication/amid-confusion-over-public-charge-rule-immigrant-families-continued-avoiding-public-benefits-2019. Protecting Immigrant Families Campaign, “Summary of Research at the Intersection of Public Charge and Health,” June 2020, https://protectingimmigrantfamilies.org/wp-content/uploads/2020/06/Public-Charge-and-Health-Literature-Review-2020-06-16.pdf.
- Elaine Waxman, “By Targeting SNAP, the Expanded “Public Charge” Rule Could Worsen Food Insecurity,” Urban Institute, Nov. 15, 2018, https://www.urban.org/urban-wire/targeting-snap-expanded-public-charge-rule-could-worsen-food-insecurity.
- Dottie Rosenbaum, Stacy Dean, and Zoe Neuberger, “The Case for Boosting SNAP Benefits in Next Major Economic Response Package,” Center on Budget and Policy Priorities, May 22, 2020, https://www.cbpp.org/research/food-assistance/the-case-for-boosting-snap-benefits-in-next-major-economic-response.