Labor market areas are not necessarily the best measure of whether there are sufficient jobs in a particular region. While labor market areas may provide a reasonable view of commuting flows in urban and metropolitan areas, rural counties are too often considered their own independent labor market areas. Nearly 82 percent of the 2,274 labor market areas reported by the Bureau of Labor Statistics (BLS) contain just a single county.
In order to deal with this problem, USDA researchers developed a different method of delineating economic regions, called “commuting zones,” which connected rural areas with nearby employment centers to reflect actual and possible commuting flows. Rather than considering each rural county as its own disconnected economic region, USDA researchers used commuting patterns to identify 709 commuting zones. Fewer than seven percent of these commuting zones contain just a single county.
USDA should consider amending their proposed rule and make commuting zones, rather than labor market areas, the basis for work requirement waiver evaluation. These zones present a more realistic view of where individuals are likely or able to travel to work and would serve as a better proxy for determining whether or not there is a true lack of sufficient jobs in a given area.