Opposition to the USDA's Proposed Rule to Revise the Supplemental Nutrition Assistance Program's Waiver Rule For Able-Bodied Adults Without Dependents
Adopted at the 87th Annual Meeting in 2019
WHEREAS, the Proposed Rule is based upon the USDA's concern that ABAWD time limit waivers continue to cover significant portions of the country and are out of step with a national unemployment rate hovering at less than 4 percent; and
WHEREAS, the Proposed Rule does not reflect the socio-economic realities facing the ABAWDs, because it is based solely on the declining national employment rate; and
WHEREAS, ABAWDs are an especially disadvantaged group, often facing substantial barriers to employment; and
WHEREAS, these barriers include lower levels of educational attainment than the general U.S. labor force. Specifically, national data indicate that half of ABAWDs have only a high school diploma or GED, and one-quarter of ABAWDs have not completed high school; and
WHEREAS, SNAP participants subject to the three-month time limit are more likely than other SNAP recipients to lack basic job skills such as reading and writing; and
WHEREAS, a substantial proportion of ABAWDs subject to the three-month time limit have a medical or physical health condition which may act as a barrier to employment; and
WHEREAS, although USDA acknowledges that the Proposed Rule has the potential for disparately impacting certain protected groups due to factors affecting rates of employment of members of these groups, the Proposed Rule does nothing to mitigate these factors or to account for the different socio-economic realities facing this vulnerable population; and
WHEREAS, the effect of the Proposed Rule's disparate impact on certain groups will be an increase in food insecurity among an already vulnerable population; and
WHEREAS, the Proposed Rule will ultimately result in food insecurity. In fact, USDA researchers found that between 17 - 34% of ABAWDs that left SNAP due to the time limit reported very low food security, meaning they had to skip meals because they could not afford food; and
WHEREAS, the Proposed Rule will also harm local economies, as it is well documented that the economic gains from public benefits are even greater than the volume of direct assistance due to a "multiplier" effect. Specifically, the USDA has estimated that during times of economic downturn, every additional $5 in SNAP benefits generates up to $9 of economic activity, and every $1 billion increase in SNAP benefits results in 8,900 full-time equivalent jobs,
NOW, THEREFORE, BE IT RESOLVED, that for the reasons noted above, the U.S. Conference of Mayors request that the USDA withdraw the Propose Rule.