New Research Finds That Work Requirements On SNAP Don't Increase Employment

As new SNAP work requirements are going into effect across the country, advocates on the ground like Rhonda Rogombè are working to keep beneficiaries informed and avoid qualified recipients from being needlessly dropped from the rolls. Rogombè, health and safety net policy analyst for the West Virginia Center on Budget and Policy, has studied the impact of earlier work requirement increases put in place by the state and found they don’t increase employment. Spotlight spoke recently with Rogombè about her research and the work she’s doing to build awareness in her community. The transcript of the conversation has been lightly edited for length and clarity.

Why don’t we start by you telling us a bit about yourself and your organization as well as some context about Mingo County?

I am Rhonda Rogombè and I'm the Health and Safety Net Policy Analyst here at the West Virginia Center on Budget and Policy. Our organization looks at policies and advocates on behalf of low-income and working-class West Virginians. As for my role, I am primarily looking at the systems that support them, like Medicaid, SNAP, and other programs that fill in the gaps when people aren't able to make ends meet.

Mingo County is one of the southernmost counties in West Virginia. Like many places in West Virginia, its economy once heavily relied on coal and like many other parts of West Virginia, it has struggled in the years and decades since coal became a much smaller part of the economy. Almost one in three residents in Mingo County lives in poverty, which is higher than the state and national average. And between 2011 and 2021, there was an unemployment rate of just over 10%, which is also higher than the state average. So, you can imagine some of the hardship that comes with living in an environment like that.

Similarly, about one in three people in Mingo County receive SNAP benefits, so it plays a big role in their economy, not only helping people access food, but helping keep grocers open and provide jobs.

‍That’s really helpful. So, why don’t you tell us about this new research about work requirements that you’ve done.

Over the past several years, we've done research around what work reporting requirements look like, how people are able to access them, and what it means for future employment. As you know, we've seen different iterations of this over time. If we go back to 2016, West Virginia did a nine-county pilot program in which they were observing whether or not employment levels were impacted by enforcing work reporting requirements. And even though that relationship was not found to be strong, in 2018, West Virginia passed a law that would bar any county with a high unemployment level from seeking a countywide waiver from the work reporting requirements in SNAP.

So, long before HR 1 (last year’s Big Beautiful Bill) was implemented, West Virginia already started taking steps toward enforcing this policy a little bit more strictly. During the COVID public health emergency, the work reporting requirements were paused. In 2023, they were turned back on. And during that time we went to Cabell County and Mingo County to talk to people about their experiences with hunger, about the people who lost coverage and why they lost coverage, and then also talk to charitable food providers—churches, food pantries, soup kitchens—who fill in the gap when the government pushes people out of these programs.

We have based the study on one that was done in Ohio several years ago about barriers to employment. And so, we interviewed people about their experiences and just asked them, why are you unable to work? We had a variety of responses, including having a mental or physical limitation that didn't quite meet the criteria for an exemption, but still impacted a person's ability to live. Housing insecurity—people were behind on bills or experiencing homelessness. People had felony convictions, unreliable transportation, unreliable access to the internet, all these different things that meant that securing employment and maintaining employment was really difficult. But it also means those same things are also impacting their abilities to access a lot of other parts of life.

There were a lot of those barriers that were in place and that meant that not only were people not able to get work, but it also meant it was hard for people to report work or report an exemption or get an exemption documented so that they could then report it. And that meant that we lost a lot of people off of SNAP who were otherwise still qualified between September 2023 and December when the time limit went back into effect. In December of that same year, statewide, we saw about 12,000 people lose their SNAP benefits. And then in the following year, we increased the age of people who were subject to that time limit. And then HR1 expanded that even further, meaning our seniors are going to be impacted by this in a way that we haven't seen.

‍And now Medicaid enrollees will face the same requirements. If there was a single biggest barrier that people found there, was it not understanding the system? Was it that the system doesn't work? It's too complicated? All of the above?

All of the above. We looked at the reporting from the SNAP side, but also from the Medicaid side, during the so-called unwinding period when the non-renewal policy during COVID had been lifted and all of a sudden everyone had to turn that program back to normal. We spent a year ahead of that unwinding period as a coalition coming together to figure out ways to communicate that with families to make sure that as few people lost coverage as possible. And what we found during that period was that, of the people who lost coverage, 75% of them lost coverage because of a procedural denial, which is a denial because they didn't completely and correctly fill out and return their paperwork on time, not because they were actually found ineligible. Of course, you know, we're sure there are some folks that maybe were ineligible, but 75% of coverage losses being because that paperwork wasn't completed really highlighted to us that when you increase paperwork or have a change like that, then many people will fall through the cracks as a result.

And so, we're really fearful that as HR1 is being implemented, it's going to be a lot more paperwork for enrollees, both on the SNAP and Medicaid sides, and it’s going to be really harmful. In SNAP, many people have already been experiencing this, but we're going to be expanding it from age 54 to 64. Many of our older folks have never been subject to this before and are experiencing similar barriers to those of many of the people that we interviewed.

‍As a provider on the ground, obviously these work requirements are going to go into effect. Are you planning a similar sort of campaign to try to help people as much as you can?

I put together a working group during the public health emergency for Medicaid. But since I also work on SNAP and so many people in the Medicaid population also receive SNAP, we've been talking about communications for both. And that has looked like a lot of coalition work—pulling people together, other advocacy organizations, decision makers, providers, people who with lived experience on this program, all coming together to talk about how we are all going to step up to make sure that our friends and family and neighbors aren't losing access to their coverage.

We know that the intention of this legislation is to remove people from these programs; that is where the savings are generated in this legislation. And it is hard to overcome a system that is designed to fail. But we intend to do everything that we can to ensure that people stay connected to their care, because this will have such deep implications, not only for an individual's health, but their familial health, their community's health, our state economy.

‍What's a couple of examples of things that you're planning to do?

In the fall, we went around the state and had community conversations where we presented information and talked to community members about these changes and also just listened to them talk about how important their healthcare or their local hospital really was to them. Because I think that elevating people's experiences to people who are making decisions about them is really important. We've had some webinars and then the coalition meets on a regular basis to go over materials, go over communications plans from different organizations and kind of just figure out how all of our different roles can work together to create a richer tapestry of resources, so that when people go to their doctor's office, they're getting the same language as they are at this pharmacy or this community event.

‍And finally, on SNAP, do you think it’s possible to construct a work requirement that would have enough supports within it to deal with some of the issues that you’ve found in your studies so that it could possibly work?

No (laughs).  I think that work requirements and work are very separate from one another. I think the things that would bridge them would also have to address so many systemic barriers, not only to work but to poverty in general.

Ironically, programs like SNAP and Medicaid are some of the systems that we have in place to alleviate poverty and connect people to work by making sure that they're happy, they're fed, and they're healthy enough to contribute meaningfully to their communities. And so, when we disrupt that system, it makes it that much more difficult for people to access food and health and therefore contribute meaningfully to their communities.

I think instead of a work requirement, I would like to see more resources being spent on communities left behind by the coal industry and by other extractive industries. I would like to see investment in public transportation for example, or programs for people who dropped out of school that are a lot more accessible. We've lost a lot of money on broadband recently in the state and fewer people are going to have access to the internet, especially in remote places.

And then lastly, just providing sustainable jobs in these communities. Because the number one barrier that we saw in Mingo County and in Cabell County to work was the lack of jobs. You can't really require people to work in areas where there are no jobs. So yes, I think we have a lot of work to do as a nation, as a state, to address systemic poverty and inequality that creates the need for the safety net.

‍So, your argument on SNAP in particular, if I’m hearing you correctly, would be that a fully functioning, more fully funded SNAP program would do more to promote work that work requirements on SNAP benefits?

Yes. I think it's really hard to focus on work or learn or be an active family member if you're hungry. When the program itself is working, it’s promoting work.