Breaking Free From Dependency: A Case For Strengthening Work Requirements
Key Findings
- There are millions of open jobs, but most able-bodied adults on food stamps do not work at all.
- More than 74 percent of able-bodied adults without dependents are exempt from work requirements because states utilize loopholes and gimmicks to waive them.
- The average entry-level wage is already more than $15 per hour nationally.
- The majority of jobs being created over the next decade will require little to no experience, education, or training.
- Work requirements are proven to help able-bodied adults move from welfare to work, breaking the cycle of dependency.
Overview
There are more than four million able-bodied adults without dependents (ABAWDs) enrolled in food stamps.1 At the same time, there are millions of open jobs across the country.2 Despite this, the vast majority of ABAWDs are sitting on the sidelines.3 Nearly 74 percent of these able-bodied adults do not work at all and only three percent work full time.4
Federal law requires working-aged, childless adults to work, train, or volunteer at least part time to maintain program eligibility.5 But states have a long history of using loopholes and gimmicks to game the system and avoid work requirements.6 These exemptions to work requirements make it more difficult for those who qualify to get back on their feet and improve their situation. When states abuse loopholes to allow able-bodied adults to bypass work, food stamp enrollment increases, siphoning resources away from the truly needy.
Congress should close the loopholes and expand work requirements to more able-bodied adults.
States use loopholes and gimmicks to waive work requirements
States have long used gimmicks and loopholes to waive work requirements for as many able-bodied adults as possible.7-10 Congress intended for these waivers to be limited to areas with unemployment rates above 10 percent or that otherwise lacked suitable job opportunities.11 However, in the final days of the Clinton administration, bureaucrats at the U.S. Department of Agriculture created loopholes that allowed states to waive work requirements for millions.12 Unsurprisingly, the Biden-Harris administration has actively encouraged states to seek these waivers and exemptions.13 According to state Employment and Training plans, nearly 75 percent of ABAWDs are exempt or waived from work requirements.14
The food stamp statute originally allowed areas to receive waivers if their unemployment rate was above 10 percent or if they lacked sufficient jobs.15 However, changes introduced during the Clinton administration expanded these waivers to include areas with unemployment rates that exceed the national average by 20 percent.16 This scheme evaluates how a region’s unemployment rate compares to the national average rather than the number of available jobs. As a result, many areas with relatively high unemployment rates consistently qualify for waivers, even during periods of economic growth and increased job availability.17 Today, areas can receive waivers if their unemployment rate surpasses the current rate of roughly four percent, well below what the U.S. Department of Labor defines as “full employment.”18-19 In 2019, out of 1,100 jurisdictions granted waivers, only 23 had unemployment rates above 10 percent, while nearly 1,000 had rates at or below six percent.20
Another loophole that states abuse is the ability to combine jurisdictions into a single “area” to qualify for waivers, even if many of these jurisdictions do not meet the criteria.21 Officials gerrymander areas to expand the reach of these waivers to as many able-bodied adults as possible.22 Illinois, for instance, grouped 101 of the state’s 102 counties into a single “area” for waiver purposes when the vast majority of these counties had low unemployment.23 Unemployment rates in some of these waived counties were even lower than in the single non-waived county.
States also utilize long look-back periods to increase waiver eligibility by using outdated unemployment rates rather than present-day figures.24 The Biden-Harris administration re-instituted guidance to allow states to use data dating back many years to calculate waiver eligibility, even if an economic crisis has long passed.25 California’s current waiver, for example, is based on unemployment data from more than five years ago.
The discrepancy between unemployment rates and job availability also plays a role in how states misrepresent true economic conditions.26 States often prioritize unemployment rates over actual job availability when arguing for waivers, which can lead to misleading perceptions about the economic outlook of an area.27
Additionally, no-good-cause exemptions allow states to exempt a certain number of ABAWDs from work requirements without providing any reason whatsoever.28
The manipulation of data and strategic exploitation of regulatory loopholes has allowed states to avoid enforcing the work requirement for millions of able-bodied adults on food stamps, trapping them in a cycle of dependency.
There are plenty of open jobs to implement work requirements
Jobs that require little to no work experience will increasingly emerge in this economy. Over the next decade, most jobs created will require no experience, a high school education or less, or one month or less of on-the-job training.29
This trend exists in every state across the country. For example, long-term occupational projections show that nearly 87 percent of jobs in Alabama and 86 percent of jobs in Illinois will require no experience.30-31 These figures demonstrate a widespread shift toward increased job opportunities, making the transition from welfare to work even more accessible.
Able-bodied adults are also exempt from work requirements if they make at least $217.50 per week.32 The average entry-level wage is already more than $15 an hour nationally, making it feasible for individuals to meet work requirements and improve their financial situation.33 In fact, a single ABAWD would only need to work roughly 14 hours per week at the average entry-level wage to be exempt from the work requirement altogether.34-35 In other words, able-bodied adults can fulfill work requirements without even reaching the 20-hour threshold simply because of high wage rates across the country.
Participation in a workfare program in exchange for receiving monthly food stamp benefits is another way to satisfy work requirements.36 These programs provide participants with job training and work experience to enhance their employability and satisfy obligations to maintain food stamp benefits. A single ABAWD would only need to participate in a workfare program for roughly six hours to satisfy the 20-hour work requirement.37 This minimal commitment fulfills the work requirement while reinforcing the principle of work over welfare.
Work requirements work
Research from multiple states shows that work requirements are a proven way to help able-bodied adults move from welfare to work. When food stamp work requirements were implemented in states, able-bodied adults left welfare in record numbers, returned to work in more than 1,000 diverse industries, and saw their incomes more than double within one year and triple within two years.38-41 Even better, their increased incomes more than offset lost welfare benefits, leaving people better off.
Work requirements are a proven way to set able-bodied adults on the path to self-sufficiency.
As dependency falls, incomes rise, and people go back to work in every corner of the economy.42
The Bottom Line: Congress should close loopholes and expand work requirements to more able-bodied adults.
Work requirements are an effective tool to set able-bodied adults on the path to self-sufficiency, yet millions of food stamp enrollees are exempt or waived from adhering to them. By reducing the number of Americans reliant on welfare, individuals are lifted out of the cycle of dependency, leading to increased incomes and job participation across the economy.
REFERENCES
1 Authors’ calculations based upon data provided by state welfare agencies overseeing food stamp employment and training programs.
2 Bureau of Labor Statistics, “State job openings and labor turnover survey: Total nonfarm job openings,” U.S. Department of Labor (2024), https://data.bls.gov/timeseries/JTS000000000000000JOL.
3 Authors’ calculations based upon data provided by the U.S. Department of Agriculture on the work status of non-disabled adults without dependents between the ages of 18 and 52 receiving food stamps in 2022. See, e.g., Food and Nutrition Service, “Supplemental Nutrition Assistance Program quality control database: fiscal year 2022,” U.S. Department of Agriculture (2022), https://snapqcdata.net/datafiles
4 Ibid.
5 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes.
6 Ibid.
7 Ibid.
8 Sam Adolphsen et al., “Waivers Gone Wild: How States Are Still Fostering Dependency,” Foundation for Government Accountability (2019), https://thefga.org/research/work-requirement-waivers-gone-wild.
9 Jonathan Ingram and Sam Adolphsen, “How the Trump Administration Can Cut Down on Waivers Gone Wild,” Foundation for Government Accountability (2019), https://thefga.org/research/community-zones-reform-trump-administration.
10 Sam Adolphsen et al., “Waivers Gone Wild: How states have exploited food stamp loopholes,” Foundation for Government Accountability (2018), https://thefga.org/research/waivers-gone-wild.
11 7 U.S.C. § 2015(o) (2021), https://www.govinfo.gov/content/pkg/USCODE-2020-title7/pdf/USCODE-2020-title7-chap51-sec2015.pdf.
12 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes/
13 Ibid.
14 Authors’ calculations based upon data provided by state welfare agencies overseeing food stamp employment and training programs on the number of ABAWDs expected to live in waived areas or exempt from work requirements through discretionary exemptions, as reported on the fiscal year 2024 Employment and Training state plans. Fiscal year 2023 figures were used in areas where complete fiscal year 2024 data was unavailable, including Arkansas, District of Columbia, Kentucky, Michigan, Nebraska, and Tennessee. States’ current and most recent waiver submissions were reconciled with Employment and Training plans to ensure accuracy.
15 7 U.S.C. § 2015(o) (2021), https://www.govinfo.gov/content/pkg/USCODE-2020-title7/pdf/USCODE-2020-title7-chap51-sec2015.pdf.
16 Sam Adolphsen et al., “Waivers gone wild: How states have exploited food stamp loopholes,” Foundation for Government Accountability (2018), https://thefga.org/research/waivers-gone-wild.
17 Ibid.
18 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes.
19 The U.S. Department of Labor defines “full employment” as “an economy in which the unemployment rate equals the nonaccelerating inflation rate of unemployment.” See, e.g., Kevin S. Dubina et al., “Full employment: an assumption within BLS projections,” U.S. Department of Labor (2017), https://www.bls.gov/opub/mlr/2017/article/full-employment-an-assumption-within-bls-projections.htm.
20 Sam Adolphsen et al., “Waivers Gone Wild: How states are still fostering dependency,” Foundation for Government Accountability (2019), https://thefga.org/research/work-requirement-waivers-gone-wild.
21 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes.
22 Ibid.
23 Jonathan Ingram et al., “How the Trump Administration Can Cut Down on Waivers Gone Wild,” Foundation for Government Accountability (2019), https://thefga.org/research/community-zones-reform-trump-administration.
24 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes.
25 Food and Nutrition Service, “Supporting requests to waive the time limit for able-bodied adults without dependents,” U.S. Department of Agriculture (2021), https://www.fns.usda.gov/sites/default/files/resource-files/snap-2021-guide-supporting-abawd-time-limit-waiver-requests.pdf
26 Jonathan Bain and Jonathan Ingram, “Waivers gone wild: Congress must crack down on food stamp loopholes,” Foundation for Government Accountability (2023), https://thefga.org/research/waivers-gone-wild-food-stamp-loopholes.
27 Ibid.
28 Alli Fick and Scott Centorino, “No good cause: How a food stamp loophole could become the next big battle in the war on work,” Foundation for Government Accountability (2022), https://thefga.org/research/food-stamp-loophole-next-big-battle.
29 Authors’ calculations based upon data provided by the U.S. Department of Labor and state workforce agencies on education, experience, and training requirements of long-term projections of job openings, disaggregated by states.
30 Ibid.
31 Ibid.
32 7 U.S.C. § 2015(d) (2019), https://www.govinfo.gov/content/pkg/USCODE-2019-title7/pdf/USCODE-2019-title7-chap51-sec2015.pdf.
33 Authors’ calculations based upon data provided by the U.S. Department of Labor and state workforce agencies on average entry-level wages in 2023.
34 Ibid.
35 7 U.S.C. § 2015(d) (2019), https://www.govinfo.gov/content/pkg/USCODE-2019-title7/pdf/USCODE-2019-title7-chap51-sec2015.pdf.
36 Ibid.
37 Authors’ calculations based upon data provided by the U.S. Department of Labor and state workforce agencies on average entry-level wages and the U.S. Department of Agriculture on the maximum monthly allotment for a single ABAWD.
38 Jonathan Ingram and Nic Horton, “Work requirements are working in Arkansas: How commonsense welfare reform is improving Arkansans’ lives,” Foundation for Government Accountability (2019), https://thefga.org/research/work-requirements-arkansas.
39 Jonathan Ingram and Nic Horton, “Commonsense welfare reform has transformed Floridians’ lives,” Foundation for Government Accountability (2019), https://thefga.org/research/commonsense-welfare-reform-has-transformed-floridians-lives.
40 Jonathan Ingram and Nic Horton, “Welfare reform is moving Mississippians back to work,” Foundation for Government Accountability (2019), https://thefga.org/research/mississippi-food-stamps-work-requirement.
41 Hayden Dublois et al., “Food stamp work requirements worked for Missourians,” Foundation for Government Accountability (2020), https://thefga.org/research/missouri-food-stamp-work-requirements.
42 Jonathan Bain, “Work requirements work: How expanding food stamp work requirements can continue to break the cycle of dependency,” Foundation for Government Accountability (2023), https://thefga.org/research/work-requirements-work-break-cycle-dependency.
