June 26, 2023

Thousands of Floridians at Risk of Losing SNAP Under Expanded Work Reporting Requirements

The debt ceiling agreement brokered by members of Congress in the Fiscal Responsibility Act of 2023 jeopardizes food assistance by expanding Supplemental Nutrition Assistance Program (SNAP) work requirements to “able-bodied adults without dependents” (ABAWDs) aged 50 to 54. SNAP provides vital food assistance to households with low incomes who are struggling to put food on the table. Until now, SNAP work reporting requirements only applied to ABAWDs under 50 years old.

If people subject to the work reporting requirements are unable to comply, they will lose their SNAP as a sanction and have their benefits limited to three months every three years. 

Most SNAP participants who can work, do. The new expansion, which punishes older Floridians for being out of work, will create hardship for participants who have limited employment opportunities, and it will cost the state’s economy millions in assistance that would have otherwise been spent in local communities.

ABAWDs Already Face Barriers to Economic Mobility

ABAWDs adults who are not pregnant and do not have children or an identified mental or physical health limitation that interferes with work — are more likely to live in poverty, be unhoused, and have less education than other SNAP participants. In addition, although many are ready to work, ABAWDs have higher rates of mental and physical impairments than other SNAP participants. In addition, ABAWDs of color face workforce discrimination and higher unemployment rates than Florida’s general population, making it more difficult to find stable employment and meet SNAP reporting requirements.

SNAP Work Requirements Are a Policy Failure

SNAP work reporting requirements are a failed policy that creates unnecessary hardship:

  • Many Floridians who have been sanctioned under work reporting requirements have significant and multiple barriers that cause them to lose benefits, such as medical issues, transportation problems, extremely low education levels, computer illiteracy, and language barriers.

Additionally, Florida has not opted to ensure that every ABAWD has an available slot in an education, training, or work program to meet work reporting requirements — even though the federal government provides funds to help states pay for such slots. This means that people who cannot find jobs despite their best efforts or who are working even one hour less than the required 80 hours will face sanctions and time limits.

The Majority of Floridians Impacted by the New Law Will be Unlikely to Meet the Work Reporting Requirements

Expanding work reporting requirements to older (aged 50-54) SNAP participants in the debt ceiling agreement hits Florida harder than other states. About 44,000 Floridians will be affected by this mandate, which is more than three times the nationwide per-state average (14,000). 

Of the 44,000 older Floridians who will be impacted, nearly 60 percent[1] will be unlikely to meet the work reporting requirements for a variety of different reasons, including significant barriers such as lack of transportation, undiagnosed mental illness, and bureaucratic red tape.  As a result, not only will they lose their only means of putting food on the table as a sanction, but any month in which they do not meet the work reporting requirement will also count towards their three-month time limit.

While not everyone new to the expanded reporting requirements will lose their food assistance, there is reason to be concerned about the risk. Many people who were subject to this reporting requirement in the past have had their food assistance cut off even though they were already working, had serious impediments to employment, or were exempt but fell through the cracks. Looking at the last reported quarter alone (October 2022- December 2022), the SNAP benefits of 17,000 Floridians were terminated due to work reporting requirements. Yet, during that same period, only 3,600 people were reinstated after they were able to show that they met the reporting requirements.

Floridians are also impacted by the state’s decision not to allow DCF to waive work reporting requirements when unemployment is high. Although federal law allows states to ask FNS to waive these requirements temporarily when jobs are in short supply, Florida prohibits DCF from applying for such a waiver absent express legislative authorization.  

In addition, work reporting requirements hurt Florida’s economy. Under the expanded requirements, the state stands to lose at least $4.5 million per month in federal SNAP dollars that older participants would have received to put food on the table — money that would have been spent at local grocery stores.[2] While SNAP’s administrative costs are shared among states and the federal government, every penny of SNAP benefits distributed to participating households is paid for by the federal government.

New Exemptions to Work Reporting Requirements a Step in the Right Direction

Although the new law extends work reporting requirements to older participants, it also establishes new exemptions to the requirement. Under the new exemptions, veterans, people experiencing homelessness, and former foster youth no longer have to meet the SNAP work reporting requirement. 

While these exemptions are a positive step, many of the people who are protected by them should have already been exempt, such as all veterans who are receiving Veterans Administration (VA) benefits — regardless of their disability rating — as well as many experiencing homelessness. 

Still, these exemptions do not redress either the irreparable hardship that expanding work requirements will cause older Floridians or the loss of money that local communities and the state will experience from the expansion.

Changes to SNAP Work Reporting Requirements Expected to Increase Federal Spending

The Congressional Budget Office (CBO) estimates that the SNAP deal struck by Congress will cost the country more money, not less.

According to the CBO, changes to SNAP work reporting requirements in the debt ceiling agreement will increase spending by $2.1 billion over the next 10 years. Although the agreement reduces the number of likely beneficiaries by making more people subject to work reporting requirements, it also exempts new categories of people, potentially counteracting any cost-saving impacts of increasing the work reporting age limit.  (Notably, however, the White House speculates that the savings achieved by the new work reporting requirements will counterbalance the costs of the new exemptions in their entirety.)

Cost aside, while these new exemptions are an improvement to current law, they do not neutralize the harmful new work reporting requirements, nor do they compensate the state and local communities for the benefits that older SNAP participants would have spent on groceries at neighborhood stores and farmers markets.


[1] In a 2018 analysis, Florida’s Office of Program Policy Analysis and Government Accountability (OPPAGA) found that 58 percent of new ABAWDs in Florida’s SNAP program were sanctioned. The Florida Legislature, Office of Program Policy Analysis and Government Accountability (OPPAGA), “Mandatory Work Requirements for Recipients of the Food Assistance and Cash Assistance Programs,” January 8, 2018, https://www.dropbox.com/scl/fi/tpaw90el95prhq48qsuwv/OPPAGA_SNAP_TANF_FINAL_003-2.pdf?dl=0&rlkey=3r6txbwg2l894ihtkak2lsmwz.

[2] The average monthly SNAP benefit per person in Florida of $180. Based on OPPAGA’s analysis of Florida’s work requirement sanctioning patterns (i.e., that 58 percent of new ABAWDS receive sanctions), the loss to Florida’s economy could be as much as $4.5 million or more per month ($180 × 25,520 (58 percent of 44,000)). Id.

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