As Congress moves forward with its consideration of the 2018 Farm Bill in the weeks ahead, the U.S. House and Senate will have to reconcile their differences on a range of agriculture, nutrition, conservation, and forestry policy issues contained within the landmark legislation. However, many observers believe the most contentious farm bill issue still on the table is whether to further expand the work requirements on those receiving Supplemental Nutrition Assistance Program (SNAP; formerly the Food Stamp Program) benefits.
The House version of the legislation proposes to sanction with benefit loss certain SNAP recipients who fail to work or participate in training more than an average of 20 hours per week in any month that they receive SNAP. Due to volatility in the labor market, a large number of individuals may be sanctioned due to fluctuations in hours worked or short spells of unemployment. In fact, our research finds that over the course of 16 months, one in five adults ages 18 to 59 without a child under the age of 6 at home switches between working more than 20 hours per week and a different employment status: less than 20 hours per week, seeking employment, or being out of the labor force. We obtained this evidence by examining the Current Population Survey (CPS), which enables researchers to observe employment status transitions in two separate four-month periods over two years.
Using an additional data source, the most recent Survey of Income and Program Participation (SIPP), we were able to identify the frequency of employment status transitions over the course of a single year. In the SIPP, we found patterns similar to our initial findings from our original CPS analysis, for example:
In 2013, approximately 18 percent of adults 18 to 59 without a child under the age of 6 switched between working more than 20 hours per week and another employment status. This represents about a quarter of those who at some point work over 20 hours per week in a month.
Among SNAP recipients not receiving disability payments, about 21 percent switched between working more than 20 hours per week and another employment status. This represents about half of those who at some point in the year worked more than 20 hours per week.
With the SIPP, we can also describe how the reasons for not working differ by employment status. The composition of reasons given is distinct between labor force nonparticipants and participants. For those who reported being out of the labor force for the entire year, non‑temporary health condition(s) or disability was the predominant reason given for not working. This is a much larger group than those who receive disability-related income. For those in the labor force, work-related reasons – not being able to find work, being laid off, or working for more than 15 hours for no pay at a family business or farm – were the most frequent explanations for not working for at least one week during the year.
Employment status transitions over one year
Using the Survey of Income and Program Participation (SIPP), we describe the distribution of employment status stability and transitions. We categorize each individual in each month into one of four categories: (1) employed and worked more than 20 hours per week, (2) employed and worked less than 20 hours per week, (3) unemployed and seeking employment, or (4) not in the labor force. The SIPP surveyed respondents in each month of 2013, which allows us to calculate the frequency of employment status transitions for 12 contiguous months. One is considered to have a stable employment status if she does not change categories over the course of the year. If she changes categories for at least one month, she has made an employment status transition.
Because the SIPP includes information about whether the respondent received any income from benefits programs due to a disability or health condition during the year, we are able to further limit our analysis to adults 18-59 not receiving disability payments without a child under the age of 6 at home—the group identified in the House work requirements proposal. We additionally show employment status transitions among adults 18-59 without a child under the age of 6 at home who do not receive disability benefits who reported receiving SNAP at some point during the year.
Figure 1 describes the distribution of stable and changed employment statuses for the three samples.
As illustrated in the figure above, there is little difference between the overall and the group that is not receiving disability benefits. This occurs, in part, because there are few who received any income due to having a disability or health condition during the year. Consider the following statistics:
In general, more than half were employed for the entire year at more than 20 hours per week.
Approximately18 percent transition between employment at more than 20 hours per week and a different employment status;
80 percent of transitions were between working more than 20 hours per week and working less than 20 hours per week.
In contrast, the distribution of employment status transitions among adults not receiving disability income who received SNAP is quite different, for example:
More than 60 percent of SNAP recipients in this groups were in the labor force, but about half did not work stably: more than 30 percent made at least one employment status transition over the course of the year.
Almost the same share transitioned between more than 20 hours per week and a different employment status (21 percent) as were employed stably at more than 20 hours per week (22 percent).
Almost 40 percent of SNAP beneficiaries among this group did not work or seek work during 2013.
When the Congressional Budget Office offered its cost analysis, they found that 31 percent of this group would work sufficient hours in an average month to satisfy the House bill’s work requirements. But, an average month would not be sufficient to satisfy monthly verification requirements and an average month does not account for employment volatility. We find that only 21 percent of this population work sufficient hours every month of the year.
Because only those working more than 20 hours per week every month would be eligible to retain their SNAP benefits, we estimate that nearly 80 percent of adults without children under 6 at home who do not receive disability benefits would be exposed to potential SNAP benefit loss under the House work requirements proposal.
Why did SNAP beneficiaries say they did not work?
Many who are targeted by work requirements are already working. As shown in these data, more than 60 percent of those in the targeted group and receiving SNAP were labor force participants during the year; but, of those in the labor force, two-thirds worked less than 20 hours per week at some point. Another 38 percent of those in the targeted group and receiving SNAP were not in the labor force at all during the year. When they were not employed, what reasons did these individuals give for not working?
As shown in Figure 2, those consistently out of the labor force, meaning that they did not seek work and were not employed for pay at all during the year, offer very different reasons for not working than those who were not stably employed (Figure 3). About 65 percent said they were not working because of their health or a disability. To be clear, none of these SNAP beneficiaries reported receiving any disability- or health-related income. Only 5 percent of those who did not work the entire year said it was because they were retired or not interested in work.
As shown in Figure 3, among those in the labor force who did not work more than 20 hours per week stably, the most frequent (41 percent) reason given for a week of not working was work-related (light blue): not being able to find work, being laid off, or working for more than 15 hours for no pay at a family business or farm; only about 2.5 percent of said that they were retired or not interesting in working. 12 percent of this group cited a health-related reason for not working, far less than those not working at all.
Some of these reasons given fall into categories that could potentially qualify the beneficiary for an exemption from the work requirements, including unfitness to work without receiving disability benefits, pregnancy, certain types of caregiving, or for good cause. Some of those citing work-related reasons for not working may live in an area that qualifies for a waiver due to prolonged high unemployment, though those criteria are stringent under the House bill. The CBO estimate relies heavily on such exemptions to further reduce the share of those exposed to work requirements.
It is likely that both those who participate in the labor force and those who do not could have trouble navigating the administrative requirements to obtain an exemption, and many workers would likely be at risk of sanctions due to fluctuating employment. Because these exemptions are likely more heavily concentrated among labor force non-participants, the punitive aspect of work requirements – losing benefits for a period of one to three years or until one obtains employment at least 20 hours per week monthly – may be borne by labor force participants and their households.
Over the course of a year, about one-in-five adults 18-59 without a child under the age of 6 at home who do not receive disability benefits transition between working more than 20 hours per week and less than 20 hours per week, seeking employment, or being out of the labor force. As we wrote, while this is evidence of significant exposure to sanctions under the additional work requirements proposed by the House, it nevertheless represents a low estimate of those who might lose or fail to obtain SNAP benefits for which they are currently eligible due to the work requirements.
Given the nature of exemptions and who would qualify, it is likely that those who would be most affected by the punitive nature of the work requirements are those who are working in the volatile low-wage labor market, not those whom we are seeking to draw in from the sidelines.
Unlike those permanently out of the labor force who might receive a health- or disability-related exemption (one-quarter of all SNAP participants in the sample and almost two-thirds of those not in the labor force), those who transition from more than 20 hours to a different employment status are more frequently not working due to a work-related issue. They are far less likely to receive an exemption. If work-related exemptions are only for high unemployment areas, workers who face idiosyncratic shocks – their place of employment closes or their hours are reduced, for example – will face more difficulties qualifying for exemptions.
The vast majority of those who transition between more than 20 hours a week and a different employment status are working every month but with varying hours, have a work-related reason, or are a student for part of the year. Instituting monthly work requirements for SNAP recipients – with frequent exposure to employment verification processes and the attendant likelihood of administrative error – will impose sanctions on a large share of workers because they experience normal labor market fluctuations.
 The statistic calculated from the CPS – that 20 percent switch between working more than 20 hours a week and a different employment status – is a conservative estimate of the extent of employment status switching because we allow usual hours to replace actual hours for those who are employed but not at work and we only observe work statuses for those eight of the sixteen months where the respondent is surveyed. For additional detail, please see Employment status changes put millions at risk of losing SNAP benefits.
 If she switches jobs but does not switch employment categories, she is considered to be stable in that category.
 For respondents who made multiple transitions over the course of the year, they are coded as between 20+ and <20 if that was one of their transitions, followed by 20+ and unemployment or not in the labor force, and then other transition.
H.R. 2 states that the sanction for a first violation of work requirements is benefit loss of 12 months after the individual is declared ineligible or until the individual obtains employment at more than 20 hours per month, 25 hours after 2026. For a second or subsequent violation, the sanction is benefit loss of 36 months or until the individual obtains employment at more than 20 hours per month, 25 hours after 2026. In the House Agriculture Committee summary of H.R. 2, only the benefit loss of one to three years is noted as the sanction for failing to work 20 hours per week. Though eligible household members would retain SNAP benefits if adult(s) were to lose their benefits, sanctions would affect children because resources available to purchase food for the household would be reduced during periods of benefit loss. Once employment is again obtained, those under sanction would be eligible to reapply for benefits, a process that requires knowing that they are eligible to apply and successfully navigating the process.