On April 12^th 2018, Chairman Michael Conaway (TX-11) released H.R. 2 the Agricultural and Nutrition Act of 2018. This bill was passed out of the House Agriculture Committee on April 18th. This legislation covers a wide range of farm policy, but also the Supplemental Nutrition Assistance Program (SNAP). We are limiting our commentary to the SNAP provisions of this bill.

We recognize the important process that many hard working families and farmers have put into the overall package.

However our concerns around the SNAP provision our substantial.

Our ministry and partners pay attention to proposed changes in the social safety, which would include any proposed changes to SNAP. Many local churches and faith-based institutions serve those on SNAP and have members who are on SNAP.

SNAP plays a vital role in addressing food insecurity for families, individuals, and children. In communities throughout America, churches and houses of worship play a bridge role for those who are in need of help and a quality meal.

Many of our churches run job-training programs and therefore are uniquely qualified to give input on what works at the local level, what is needed for change that brings people back on their feet. Faith based ministries are in the business of transformation and one of the lessons from this work is the importance of flexibility and adequate and timely resources.

Many Christian groups, including society supporters from the Evangelical, Pentecostal, Mainline Christian, and Roman Catholic communities believe in the importance of work, but we remain cautious about any proposal that talks about work without a well partnered strategy for getting people to work. We are particularly concerned about the amount of hours being proposed (20 hours a week). Many SNAP recipients that we serve already work, but they work in seasonal jobs or jobs that come and go.

SNAP should be a stable and available resource, and we cannot imagine a policy that does not track with the lived experience of Americans trying to get their life in order. This policy alone will cause many to unnecessarily lose the help they need, without getting into better and more stable jobs.

We are concerned that H.R. 2 will not benefit the life of local ministry partners trying to serve those on SNAP, will burden and disqualify well meaning families and individuals, and not help people find the resources they need to thrive. Simply telling people to work will not result in everyone working more.

Many of our supporters believe in fairness and transparency, but we are skeptical about the compliance issues that can arise when states are asked to perform new roles and functions, about the compliance burden on non-profits and small businesses who are asked to take on additional roles in submitting information on who they are serving or employing, and we remain the most concerned about the lack of information and burden on families and individuals who have to meet new and changing roles just to make the basic details of their lives work.

Government programs that aim to help the vulnerable; should be at the minimum straightforward and non-burdensome, and while we have the shared goal of transformation we think that change fundamentally comes from the person and comes with time. While laws and rules are important and needed, they cannot be a fundamental catalyst for change, though they certainly can help if well designed.

H.R. 2 as written fails this test.

In particular we have a number of specific concerns.

• The penalties and lock out periods are too high. Losing benefits for 12 months on the first offense, and 36 months for the second is not fair or just. Benefits around food shouldn’t come with harsher compliance standards than paying a parking ticket.
• The number of hours worked and the timeframe- 20 hours weekly- is not well adjusted to the lived realities of every day Americans seeking work. Work in rural communities can be sporadic or even seasonal. Also small businesses or non-profits who are asked to help certify either employment or in some cases volunteer hours at the state level or being asked to do too much that is not core to their mission. This compliance burden and one-sized fits all approach is ill conceived and will cause many Americans to unnecessarily lose their benefits out of everyday compliance issues.
• Taking away the flexibility of states to help raise the standards on who can access SNAP in specific regions and locals is very unhelpful. States need to have flexibility to implement programs and reach more people. Taking away this ability is very counter productive.
• The work-study pilots from 2014 are not yet available. This proposal would benefit from a more thorough airing of what has worked locally and what simply hasn’t.
• The exemption for raising a child under 6 for participants ages 18 through 59 is too low in this proposal and throughout the existing SNAP work exemptions. If an individual or family needs to access SNAP and they are caring for children, the age should at least be raised to 18 and under. Many individuals are caring for multiple children not including them in the exemption is very problematic.

Going forward we do have some ideas and principles on helping Americans find well paying jobs.

• Greater partnership with the private sector in creating a culture of training and employment. This sort of national level leadership could very well result in millions of new private sector dollars being focused on job training and jobs for which they have need of.
• Greater funding for longer-term job training programs. Build on the Workforce Innovation and Opportunity Act (WIOA) of 2014 and expand needed investments.
• Look to solve the child-care and transportation barriers to more comprehensive work.
• Empower local entrepreneurs in rural communities. Look at issues of access to capitol on new businesses starting in economically harder hit communities.