Although the details have not yet been announced, the Department of Children and Families (DCF) is pulling back some of the important safety net measures it put in place in March – measures that have ensured families who lost jobs during the pandemic can make ends meet.
DCF says that — effective July 2020 — it is reinstating work requirements for Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) participants, as well as SNAP, TANF and Medicaid recertifications. just as Floridians scramble to feed their family, pay rent, and get medical care until they get back on their feet.
Nothing about reviving work requirements or recertifications during the height of the pandemic makes sense. The reason that Florida suspended work requirements and extended recertifications in the first place was to ensure that families have the support and resources they need during the pandemic until the Sunshine State flattens the COVID-19 curve and can safely reopen.
Coronavirus has only gotten worse since the date that Florida put these special measures into place. The number of people infected with COVID-19 in Florida has grown from 563 to over 432,000, more than the population of the city of Tampa. Hospitalizations for COVID-19 have increased by over a hundredfold. Unemployment is at an all-time high and claims for Reemployment Assistance are on the rise. Deaths are climbing. Food insecurity among families with low income, particularly people of color and households with young children, is expected to increase in every county in the state. One-fifth of Floridians are behind on rent. Applications for SNAP, TANF, and Medicaid have risen by 54 percent due largely to COVID-19.
Although everyone may be tired of hunkering down, now is not the time for Florida leaders to reverse course. Continuing to extend recertification and suspend work requirements are effective strategies to mitigate against coronavirus infection and support families whose lives are particularly at risk from the disruption caused by COVID-19.
Ordinarily, SNAP and TANF participants must work, or participate in a work or training program, to qualify for assistance unless they are exempt for reasons such as having a disability. If the head of household fails to comply without “good cause,” the family’s entire assistance is terminated as a work sanction.
Many — but not all — TANF and SNAP participants are subject to work requirements. For those who are required to work, the mandates are significant. In the TANF program, work requirements demand that parents either work or participate anywhere from 20 up to 55 hours a week depending on their household composition. For SNAP, participants must work or participate in a “work activity” for at least 80 hours each month.
Reinstating work requirements puts SNAP and TANF participants, and their families, in the bull’s eye for contracting and spreading COVID-19 infection. This is because, in many cases, people who are required to work as a condition of receiving SNAP or TANF must interact with a variety of strangers in order to comply. Because they cannot control the behavior of potential employers and others who refuse to adhere to Centers for Disease Control and Prevention (CDC) guidelines, some are even forced to break social distancing rules just to maintain eligibility for SNAP or TANF.
Even if DCF decides to permit online activities to fulfill work requirements, one-third of families with very low income in Florida do not have internet access and will be unable to work or participate in this manner. Subjecting those Floridians to work requirements means that they will be forced to engage face to face with potential employers and others in the community to apply for jobs, be interviewed, and eventually, go back to work if they find employment. For families relying on TANF, it forces parents who cannot work or participate from home to send young children back to brick-and mortar schools instead of having them engage in distance learning — or risk loss of benefits for noncooperation, even if they have a family member whose age or health puts them at risk of becoming critically ill from exposure to an asymptomatic child.
Just complying with work requirements is an uphill battle that participants often lose due to red tape under the best of circumstances. A 2018 study by the Florida Legislature’s Office of Program Policy Analysis & Government Accountability suggests that many families in Florida are terminated from SNAP and TANF assistance when significant barriers, such as transportation problems that should confer good cause, keep them from being able to follow through with work requirements. These barriers are only exacerbated by the pandemic, where, for example, occupancy on public transportation in many communities is limited in order to adhere to social distancing guidelines.
Work requirements also perpetuate a harmful myth about the work ethic of families with low income.
The truth is that most Floridians receiving SNAP have strong work histories. Even though they may have challenges finding a job, most adults without disabilities who received SNAP in Florida before COVID-19 already worked, or would work in the near future, regardless of work requirements. For them, SNAP has always been a critical support — one that helps about 1.27 million Floridians with low income who already work get by each month.
Sadly, though, it is unlikely that enough jobs exist for the SNAP and TANF participants who will be up against a work requirement during the COVID-19 recession.
Even when jobs were more plentiful, SNAP and TANF participants who were required to participate in work faced a more difficult time finding full-time jobs than other Floridians. While some are ready and able to work and possess the skills that potential employers are looking for to fill job openings, many SNAP and TANF participants have education levels that make it difficult for them to find work, even in the best of times. For example, only about 7 percent of adult TANF recipients in Florida have more than a high school education, and 32 percent did not finish the 10th grade. Although both SNAP and TANF’s Employment and Training (E&T) programs have education and training components, few participants in either TANF or SNAP are provided skills training or education activities that lead to real jobs.
With rampant unemployment, many safety net participants are even less likely to find jobs now. Most of the jobs that SNAP participants in Florida hold, such as food service and grounds maintenance, are in the service industry, which is one of the industries losing the most jobs in the state and having one of the highest claims for Reemployment Assistance during the pandemic. Work requirements particularly disadvantage Floridians of color, who already have an unemployment rate roughly 53 percent higher than the state average.
Recertification is a process in which SNAP, TANF, and Medicaid participants periodically renew their eligibility to continue to receive benefits. Ordinarily, families in the SNAP and TANF programs must be recertified every 6 or 12 months while Medicaid participants must be recertified every 12 months. Recertification requires families to be vigilant for notices arriving in the mail so they can quickly respond with requested paperwork and other documentation.
When recertifications are not completed on time, benefits are terminated and otherwise-eligible families face food insecurity, inability to pay their rent or mortgage, and periods of uninsurance and delays in getting needed medical care.
For most of the pandemic, DCF has extended recertifications by 6 months. This means, for example, that if a family was due to recertify in June 2020, DCF pushed back their recertification to December 2020, which ensured that the family continued to get needed help without bureaucratic red tape or interruption in assistance. Extending recertification periods during COVID-19 does not mean that families who become ineligible are able to keep getting assistance anyway. Although they may not have to recertify right away, participants in safety net programs still have a duty to report certain changes, like an increase in income or change in their household composition, depending on the program.
Reinstating recertification is especially risky for Floridians who are unable to submit their recertification applications online because they do not have internet service at home or are not technologically savvy, particularly those who cannot get outside help from a library or community partner because their age or health condition requires them to stay at home during the pandemic. While DCF’s call center may be able to help some participants recertify by phone in limited cases, call centers are not equipped to handle mass recertifications by phone, even for families that have the minutes on their phones to spare.
Not only will reinstating recertification harm families, it will also cause significantly more work for the state, which has to process each recertification application. The state is already struggling with an insufficient number of staff and the challenges of broader implementation of remote work. Adding recertifications to DCF’s to-do list defies logic.
Reinstatement of recertification requirements for Medicaid is particularly puzzling considering the “continuous coverage” requirements under the Families First Coronavirus Response Act. Those requirements prohibit terminations of Medicaid coverage during the federal public health emergency to prevent unnecessary health insurance disruptions. The only exceptions are for individuals who voluntarily terminate their coverage and those who no longer reside in the state or die. Especially with widespread job and income loss due to the recession, most of those protected by these provisions are likely to be eligible for coverage. Continuous coverage keeps those families from losing eligibility because of outdated data or difficulty obtaining and producing documentation during the public health crisis.
As businesses continue to shut down or scale back and families exhaust savings on everyday necessities, safety net programs are more in demand than ever in Florida. Instead of diverting staff time to processing recertifications or forcing families into a dangerous hunt for non-existent jobs, Florida officials should be doing everything possible to enhance the state’s capacity to support the growing number of SNAP, TANF, and Medicaid applications and enrollment.
Anything less is unsound and unsafe.