What to Ask About New Safety Net Work Requirements

March 6, 2017

As I said last week, we’ve reasons to expect that more work requirements imposed on “work-able” adults who have — or need to have — safety net benefits. So it’s worth considering how we might assess what state governors and legislatures propose.

We have two major models for work requirements — Temporary Assistance for Needy Families and SNAP (the food stamp program), as applicable to able-bodied adults without dependents.

Both permit not only work for pay, but participation in a program that prepares for such work. Participation counts only if for a minimum numbers of hours. generally averaged over some period of time.

Assuming, as I think one can, that proposed new work requirements will include a broader range of permissible activities than work for pay, we thus have some experience to assess them. Some questions then.

Will the state ensure that all unemployed or under-employed adults who are otherwise eligible for the safety net program can get a slot in a job training program for the requisite number of hours?

Very few states do for the ABAWDs, the Center on Budget and Policy Priorities reports. The federal government provides states with some funds expressly for SNAP-related employment and training. But most states use most of those funds to move adults with children into the workforce.

Experience with TANF also makes this a relevant question. I haven’t seen a comprehensive account of slot shortages. This much we know. States spend, on average, 7% of their federal funds, plus those they must spend to get them on work activities.

The District of Columbia’s TANF program reflected a similar priority in the not-too-distant past. In 2014, parents waited up to 11 months for access to a job training program. And the clock kept ticking, so to speak, toward the date when they and their children could never have TANF benefits again.

Will the state provide the other resources many of the adults will need to work or participate in a job training program for the required number of hours?

The adults, by definition, have little, if any income. And such as they have, must often pay for rent, food (even with SNAP benefits) and other basic needs, e.g., supplies and handfuls of coins for laundry, telecommunications of some sort.

Will the state provide transportation and/or a transportation subsidy, e.g., an auto fuel allowance for those with a car, a bus pass and/or subway fare card for those on a public transit route?

And what about the adults with children not old enough to be in school during all the hours they’re supposed to work or prepare for same? They’ll need free or nearly-free child care. And it’s unrealistic, as well as potentially unsafe for the kids to expect parents to count on friends or relatives.

The affordable childcare record generally indicates a gap to fill. Last year, for example, 20 states had waiting lists for childcare assistance or had closed them, the National Women’s Law Center reports.

Virtually all states require parents to chip in some money of their own, as a co-pay. It’s generally small as a percent of income for those below the poverty line.

But in at least four states, it’s at least 10% — $250 a month for a single parent with just one child. (Some exceptions here that wouldn’t apply to every parent subject to a new work requirement.)

How will state identify adults who aren’t work-able?

SNAP rules exclude from the ABAWD requirement adults who are medically certified as unemployable due to a mental or physical condition, pregnant or otherwise already exempt, presumably because they’ve qualified for SSDI (Social Security Disability Income) or SSI (Supplemental Security Income).

The bar here is very high. Someone, for example, may be employable, i.e., able to work and get a job, but not for an average of 20 hours a week or for months at a time. One or both are common enough for people with certain chronic conditions.

So what standard will the state set? Will it ensure that all adults potentially unable to work can have the requisite medical review — and, if necessary, the legal help to surmount to notorious barriers to gaining federal disability benefits?

Consider too that adults who’ve no disabilities may have compelling, related reasons not to work — a child with severe disabilities who needs constant care, for example, or a frail, aged parent.

Most states and the District exempt TANF parents with such responsibilities from work requirements. Will states do the same if they opt for new work requirements?

Will participating adults be able to find jobs — and keep them?

No job training program lasts indefinitely. And it’s very doubtful that a state would allow a work-able adult to move from one to the next and then the next until s/he could find a job.

Yet some safety net participants have what are commonly called barriers to work, e.g. mental or physical disabilities that don’t rise to the SSI/SSDI level, functional illiteracy. Just plain long-term unemployment is a barrier too, as are common consequences—credit checks, for example.

On the other hand, many adults who rely, at least for awhile on safety net benefits had jobs no longer available in the area they live in — or elsewhere.

The jobless former factory workers and coal miners that Trump appealed to would seem to need retraining tailored to employers’ needs in their area — and others projected nationally.

Will the state do the necessary market and personal assessments? How will it provide these and other services to poor people in small rural communities, if it has them?

Where will the money come from?

Well, the state shouldn’t look to the federal government for more funds — not at least for the foreseeable.

Recall that the flexibility states would gain to impose work requirements on Medicaid beneficiaries would also shift costs to them, increasingly over time — currently estimated at $560 billion over the next 10 years.

Experience with not only TANF, but SNAP E&T offers further cautions. Congress, as you probably know, has never increased funding for the former. The latest Farm Bill restored the latter to the same maximum it had in 2004 — in real dollars, about 44% less.

And the budget Trump is trumpeting would reduce total federal spending for non-defense discretionary programs by $54 billion — not a happy prospect for the grants states receive for job training, placement help and the like.

These aren’t the only questions I’d want to ask. But they must suffice for now, lest this post swell entirely out of compass. Would any of you like to add others?