Today, Secretary of Agriculture Sonny Perdue announced that his Department would “propose regulatory reforms to ensure that those who are able to work do so in exchange for food benefits. This restores the dignity of work to a sizeable segment of our population, while it is also respectful of the taxpayers who fund the program.” The proposed rule would limit state’s capacity to waive work requirements and retain unused exemptions, heretofore routine processes meant to ensure that the Supplemental Nutrition Assistance Program (SNAP) functions at times and in places of economic hardship. Work requirements, and changing the manner in which waivers to these requirements are implemented, are meant to increase labor force participation and hours worked among program participants. In practice, my analysis suggests strict enforcement of work requirements will sanction not only those who are able to work but are choosing not to, but those who are unable to work and those who are unable to find work or prove that they have met the requirement. This piece clarifies exposure to sanction by looking at labor force characteristics of SNAP program participants and the reasons that workers and labor force nonparticipants give for why they experienced a period of not working. The population in question are SNAP participants between the ages of 18 and 49 without dependents, so called “Able-Bodied Adults without Dependents” or ABAWDs, who are currently exposed to work requirements and who would be affected by the regulatory changes proposed by the Trump Administration. The evidence presented suggests that:
- A plurality of ABAWDs experience labor force status transitions over an extended period of time that would expose workers to benefit loss even though they are in the labor force;
- More than a third of workers who experienced a period of not working said that it was due to a work-related reason, such as failure to find work or being laid off while less than one half of one percent of ABAWDs were not working due to lack of interest; and,
- Four out of five ABAWDs who are out of the labor force are not in fact able-bodied: while they do not receive disability income, they report health or disability as the reason for not working.
First, labor force status transitions among those exposed to work requirements are described using the Survey of Income and Program Participation (SIPP). I compare what the labor force status of ABAWDs looks like in December 2013, a snapshot, versus over 24 consecutive months, January 2013–December 2014. This analysis addresses employment status transitions among 18 to 49 year-olds without dependents regardless of whether the SNAP participants lived in state in which waivers were implemented during 2013 and 2014. As the economy recovered from the Great Recession, some states stopped implementing waivers from work requirements over the time period covered in these data, either fully (8 states) or partially (10 states) [1]. 
Figure 1 shows that most ABAWDs who participated in SNAP are labor force participants; with just 25 percent consistently not in the labor force even as the economy was still recovering. While 58 percent worked at least 20 hours per week in at least one month over two years, 25 percent were over the threshold at some point but fell below the 20-hour threshold during at least one month over two years. Very few are always working less than 20 hours a week or always unemployed (less than 2 percent in either case), and 14 percent move across these categories. This leaves just one third of participants who would consistently pass the requirement despite the fact that three-quarters are in the labor force at some point. Over two years, the evidence suggests that frequent movement between labor status categories over time increases the number of people exposed to losing benefits for failing to consistently meet a work requirement. The picture of labor force participation among ABAWDs over two years is markedly different if one were to look at a snapshot, in this case December 2013. In particular, the snapshot gives an impression that more people are entirely out of the labor market than really are. In December 2013, more than 40 percent of ABAWDs were not in the labor force, but over two years less than 25 percent of ABAWDs were out of the labor force. Next, I report the reason for not working in months they were not working (Figure 2). Those in solid shades of green were in the labor force but experienced at least one spell of unemployment or labor force nonparticipation while those in the horizontal green hatch consistently worked. Those in the blue were out of the labor force for the entire two-year period. Each person is assigned to their most frequent reason for not working. 
Almost 85 percent of ABAWDs persistently out of the labor force reported that the reason that they were not working was poor health or disability, or about 20 percent of all ABAWDs. Among labor force participants who experienced a spell of not working, more than a third reported that a work-related reason, such as not being able to find work or being laid off, was their reason for not working. As Hamilton Project work over the past few months has shown, the vast majority of working-age SNAP participants are in the labor force and health conditions keep many SNAP participants out of the labor force. This evidence suggests that those who are most at risk to losing benefits under the proposed rules are workers experiencing normal labor market fluctuations and those who should be eligible for exemptions but often fail to receive them. Furthermore, the proposed rules would limit and politicize routine, long-standing, and bipartisan waiver processes, putting the food security of Americans at risk in times of economic hardship.
[1] Removed from the analysis are all those who have a categorical exemption: those outside the targeted age range, those in the targeted age range with dependent children, full- or part-time students, and those reporting disability income.
