Systemic Barriers to SNAP Benefits for
Able-bodied Adults Without Dependents (ABAWDs)
ABAWDs
Background Information onABAWDs
ABAWD Policy
The federal Able Bodied Adults Without Dependents (ABAWD) Time Limit Rule places a
limit on how long certain individuals are eligible to participate in SNAP benefits formerly known
as food stamps. SNAP recipients considered “ABAWDs” may only receive SNAP benefits for a
total of three full months within a 36-month period.1
ABAWD Waiver
Illinois currently holds a statewide waiver to this rule that expires December 31, 2017. Illinois is
unlikely to qualify for statewide waiver in 2018 but will likely qualify for geographic waivers in
areas of high-unemployment or high labor surplus. To receive the waivers, the Governor must
apply to the Food and Nutrition Service (FNS) and there is no guarantee that he will do so.
Can ABAWDS still lose their benefits
under the current waiver?
Yes, despite the 2017 statewide waiver,
Illinois operates a mandatory SNAP
Employment & Training program in 29
counties.2 ABAWDs in these counties are
currently being called into local offices to
be enrolled in the program. If the client
does not comply, they will be
sanctioned and lose their benefits. For
more details please visit ILHunger.org.
Who is at risk?
SNAP Recipients who:
-are between the ages of 18 and 49
-are mentally and physically able to work
-do not have children under 18
-are not working at least 20 hours a week
For information about exemptions,
please visit ILHunger.org.
Exemptions
Time limits and mandatory SNAP E&T do not apply to individuals who meet the
following:1
o Under age 18 or 50 years or older
o Working 20 hours or more per week, including self-employment or in-kind
work
o Receiving a disability-based benefit from a government or private source*
o Physically or mentally unable to work 20 hours a week
o Participating in a drug or alcohol treatment program and unable to work 20
hours per week
o Receiving/applied for unemployment benefits
o Attending high school or a GED program, enrolled at least half-time
o Attending training or college at least half-time and meeting the student
eligibility criteria to receive SNAP
o Living with a child under 18 who is part of the same SNAP household
o Pregnant—at any stage of pregnancy
o Caring for a person with a disability or a frail senior
o Living in a waived city or county**
*All individuals receiving VA disability compensations, regardless of percentage,
are exempt.
**Illinois has a statewide waiver at least through December, 31 2017, which
exempts ABAWDs from time-limits, but does not exempt them from mandatory
SNAP E&T.
Work Requirements
Individuals who do not meet any of the above exemptions can remain eligible
for SNAP benefits past 3 months if they participate in a qualifying work activity
and document the number of hours worked each month with their SNAP office.
Qualifying work activities include:1
o Working at least 20 hours/week, which includes working for goods and
services, or volunteering
o Participate in an eligible work training program for 20 hours/week.
Contact your local Family Community Resource Center (FCRC)
o Any combination of the above for 80 hours/month, or volunteering with
private or public non-profit to “work for benefits” referred to as
EARNFARE in Illinois. You can find out more at your local FCRC.
Systemic barriers for ABAWDs: An introduction to race,
class and ability
The following pages utilize the intersections of race, class and ability to introduce the concept of
systemic barriers for ABAWDs (through identified key barriers) as well as to discuss key barriers for
ABAWDs identified based on ABAWD policy. It does not include all possible marginalized identities
of ABAWDs.
Key Concepts
Oppression- “The systemic and pervasive nature of social inequality woven throughout social
institutions as well as embedded within individual consciousness. Oppression signifies a hierarchical
relationship which dominant or privileged groups benefit, often in unconscious ways, from the
disempowerment of subordinated or targeted groups.”3
Race
Racism- “a system of advantage based on race. A system of
oppression based on race. A way of organizing society based on
dominance and subordination based on race. It penetrates every
aspect of personal, cultural, and institutional life. Includes prejudice
against people of color, as well as exclusion, discrimination against,
suspicion of, and fear and hate of people of color. Racism=
Prejudice + the POWER to implement that prejudice.”4
Class
Classism- “attitudes and beliefs that result in, and help to justify,
unfair treatment of individuals or groups because of their
socioeconomic grouping. Classism can also be expressed as public
policies and institutional practices that prevent people from breaking
out of poverty rather than ensuring equal economic, social, and
educational opportunity.”5
Ability
Ableism- “the practices and dominant attitudes in society that devalue
and limit the potential of persons with disabilities.” “An ableist society
is said to be one that treats non-disabled individuals as the standard
of ‘normal living’, which results in public and private places and
services, education, and social work that are built to serve ‘standard’
people, thereby inherently excluding those with various disabilities.6
Race, class and ability barriers: a few facts & figures
In Illinois, there are
500 statutory
barriers to getting
employed for people
with a felony
offense7
In 2011,
48% of
federal
prisoners
were in
prison for
drug
crimes10
Poverty
Rates are 2
to 3 times
higher for
Illinoisans
of color12
U.S. households
of color are 2
times more likely
to be food
insecure12
People of color are
disproportionately targeted by
police. Black men have a 1 in 3
chance of going to prison in their
lifetime versus 1 in 7 chance for
Latino men and 1 in 17 for white
men8
While black students made up
40% of Chicago’s public
school district in 2013, they
made up 88% of those
affected by public school
closures9
Race
Class
Lower-wage occupations
experienced
21% of the losses during
the 2008-2009
recession, but 58% of
the recovery growth over
mid-wage and higherwage occupations14
Ability
Nationally, if you’ve
been jobless for a
year or more, you
have less than 1 in
10 chances of finding
a job10
A 2004–2005
survey found
there were “more
than three times
more seriously
mentally ill
persons in jails
and prisons than
in hospitals”11
In 2013, 6 of
the 12 public
mental health
clinics in
Chicago were
closed13
By the late 1990s,
people with serious
mental illness were
reported to be 10 to 20
times more likely than
the general population
to become homeless16
Systemic vs. Individual: Barriers to SNAP for ABAWDs
When ABAWDs do not comply with work requirements or the
SNAP Employment & Training (E&T) program, it can often
be viewed as a personal problem rather than being viewed
as a systemic issue or an implementation challenge. In
reality, there are larger systems and structures in place such
as generational poverty and racism, which are outside of the
individual control of ABAWDs, but that greatly impact the
ability of ABAWDs to comply with program requirements
under the current mandatory program putting them at risk of
losing their SNAP benefits.
Race, Class and Ability Barriers for ABAWDs trying to access or
maintain their SNAP Benefits
Below is an initial list of how systemic barriers manifest for each marginalized identify (in these
examples: race, class, ability) for ABAWDs trying to maintain SNAP benefits under ABAWD
policy. It is not a complete list, but a starting point for understanding the intersection of race,
class, ability and hunger.
•
Race
•
•
•
•
Class
•
•
•
•
For people of color, their language, dialect, culture, or other
characteristics might not be considered “appropriate” in the current
work place culture dominated by a white workforce and white
leadership. In addition, they face the stress of pressure to adapt and
change to these often-unwritten rules.
SNAP E&T training programs are mainly available in English although
some information is available in Spanish.
As shown earlier, people of color are disproportionately targeted by the
police, particularly for minor drug charges. While there are training
programs available to ABAWDs who are ex-offenders, the options are
limited. Additionally, ex-offenders will likely have longer time away from
the job market, less work experience, and have a tougher time getting
hired. Ex-offenders face other statutory barriers to housing, getting ID’s,
etc.
Heavily segregated neighborhoods mean that people of color may live
in areas with less available jobs and underfunded schools impacting
their level of experience when they come to SNAP E&T, and they will
have farther to travel to get to jobs and opportunities, which is an extra
cost and time burden.
ABAWDs who are homeless will be less likely to receive the letter
notification about ABAWD Status because they might not have a
consistent mailing address. Homelessness is not a guaranteed exemption
under ABAWD policy.
Low literacy or less experience with the work force means that ABAWDs
with low socioeconomic status background might not understand the
paperwork or the possible exemptions
ABAWDs might not have parents or grandparents with work experience or
industry specific experience meaning they might not understand
workplace expectations such as appropriate clothing.
Participants face the stress and challenge of being expected to change to
fit into the work place culture that is currently deemed as “appropriate”
work culture. These are often unwritten rules that are understood by
people with embedded knowledge of the workforce passed down through
generations.
ABAWDs face the stress of participating in a program in order to maintain
their food benefits in addition to a multitude of other stressors such as
housing instability, health issues, and transportation etc.
Mental and physical barriers to work are classified as exemptions under ABAWD policy.
This does not mean that people with these characteristics can’t work or shouldn’t work.
Seeking an exemption is a safeguard against time-limits and strict requirements that could
result in the loss of SNAP benefits, particularly for ABAWDs at the intersection of race
and class oppression. An analysis of the origins of ABAWD policy and its connection to
ableism is out of the scope of this document, which seeks to introduce the concept of
systemic barriers for SNAP recipients under current ABAWD policy. This document is
based on current ABAWD policy implementation and consequences as seen on a national
and local level.
•
Ability
•
•
•
•
ABAWDs are likely to be misclassified as “able-bodied” and thus be
subject to time-limits on SNAP benefits. Screening for mental and
physical work barriers is relatively new because IL has held an
ABAWD waiver for several years. This means that a work barrier
would likely not have been documented for ABAWDs who enrolled in
SNAP during the years when ABAWD policy was not being enforced.
While physical barriers to work are an exemption for time-limits,
ABAWDs may struggle with more invisible physical barriers such as
chronic back pain that might be difficult to prove or demonstrate, but
that causes real daily pain as well as a barrier to work.
Many ABAWDs may struggle with mental health challenges that have
gone underreported. Mental health barriers to work do classify as an
exemption under ABAWD policy, but accessing this exemption can be
difficult. A mental health exemption often requires ABAWDs to selfreport on their mental health challenge or to have an advocate who
can assist the SNAP recipient in pursuing this exemption. It requires
that ABAWDs follow through on multiple appointments and paperwork
as well as have access to health services.
There is general lack of understanding around trauma, psychology of
unemployment, and re-entering the work world.
There is a general lack of understanding and research around trauma
associated with racism and poverty and other forms of oppression.
Intersectionality: A Possible Scenario for ABAWDs
Clients face considerable challenges under one marginalized identity (i.e. low socioeconomic status
or class barriers), and complex challenges for each additional marginalized identity. On the
previous pages, we looked at barriers for race, class, and ability separately, but they are very
interwoven. Below is an example of how these intersections might manifest for a SNAP Recipient
who would be classified as an ABAWD and would like to access an exemption to the work
requirements based on mental health status.
Class
Ability
Client Barriers
An ABAWD at the intersection of ability and class oppression might qualify for a mental
health exemption that would allow them to keep their SNAP benefits for more than 3
months in a three-year period. Due to a lack of accessible communication (such as a
focus on written communication and sending notification letters) it is possible that the
client will not know that they qualify for an exemption. To receive a mental health
exemption, clients must present proof, but the lack of access to resources, such as
mental health clinics, health insurance, and transportation present considerable barriers.
Due to class and educational background, paperwork might present an additional
barrier. Overall, the client may be dealing with significant stress such as housing
instability or homelessness. The SNAP recipient’s mental health status might create an
added challenge for completing the specific steps as they are required by offices.
From a provider’s standpoint
-The client might not show up for their initial appointment
-The client might be difficult to reach via phone or mail
-The client might enroll in a SNAP Employment & Training program, but
be unable to complete the program
-A client might drop out of the program without communication to staff
at local SNAP offices or the workforce training provider
-If any of the previous occur, the client will be sanctioned and be
at risk for losing their SNAP benefits
Race
Class
Ability
Client Barriers
Adding race to this scenario along with class and ability barriers introduces another
layer for the client. Clients may have an extra challenge accessing mental health
resources if they live in a segregated neighborhood with fewer resources. They may
need to travel outside of their community to find resources, and it may be a challenge
to find mental health resources that won’t be oppressive and racist. When seeking
the mental health exemption to the ABAWD time-limits, the client may face staff with
internal racial biases that are difficult to pinpoint or name, particularly given the
unequal power dynamic for the client trying to maintain their benefits, but operating
from a low-socioeconomic background. Language accessibility presents another
barrier as English is currently the dominant language available.
From a provider’s standpoint
-The client might not show up for their initial appointment
-The client might be difficult to reach via phone or mail
-The client might enroll in a SNAP Employment & Training
program, but be unable to complete the program
-A client might drop out of the program without communication to
staff at local SNAP offices or the workforce training provider
-If any of the previous occur, the client will be sanctioned and
be at risk for losing their SNAP benefits
The Impact: Loss of SNAP Benefits for ABAWDs
For states newly implementing the
ABAWD time-limits, there have
been significant drops in SNAP
participation after the three-month
mark. Some states report that over
half of their ABAWD population
lose SNAP benefits.
What can you do?
Visit ilhunger.org for more information about
ABAWD Time-Limits and Policy
SNAP Employment & Training Options in Illinois
EPIC: A USDA Pilot Project in Illinois
Checklist for Social Service Providers
If your client loses benefits:
Call IHC’s hunger hotline to report, 1-800-359-2163
We are collecting information and stories through a google form
Call IHC’s hunger hotline to get involved in additional advocacy efforts
Attend IHC’s community quality council meetings (CQCs) in local Illinois
Department of Human Services (IDHS) offices to learn more about the processes
at IDHS offices as well as to build relationships and support. E-mail
[email protected] to learn more and to sign up for e-mail alerts.
Works Cited
1. New York Hunger Solutions. “SNAP ABAWD Time Limit Desk Guide.” Updated Jan. 2017.
2. Illinois Department of Human Services. “Participation.” Self-Sufficiency Activities, June, 2016.
3. Adams, Maureen, Lee Anne Bell, and Pat Griffin, Eds. Teaching for Diversity and Social Justice: A
Sourcebook. New York: Routledge, 1997.
4. National Multicultural Institute. “Diversity Terms.” 2003. Available at:
https://our.ptsem.edu/UploadedFiles/Multicultural/MCRDiversityTerms.pdf
5. Ibid
6. Stop Ableism Inc “What is Ableism?” 2017. Available at: http://stopableism.org/what.asp
7. American Bar Association. Online database of collateral consequences for each U.S. Jurisdiction.
Search: https://niccc.csgjusticecenter.org/search/?jurisdiction=18
8. Bonczar, T. Prevalence of Imprisonment in the U.S. Population. Washington, DC: Bureau of Justice
Statistics. 1974-2001
9. Cohen, M. Rachel. School Closures: A Blunt Instrument.” The American Prospect, April 2016.
10. Black, Rachel, Sprague, Aleta. “Give the Unemployed a Second Chance.” New America, 2015.
11. Torrey, E.F., Zdanowicz, M.T., Kennard, A.D., Lamb, H.R., Eslinger, D.F., Biasotti, M.I., Fuller, D.A.
“The treatment of persons with mental illness in prisons and jails: A state survey.” Arlington, VA:
Treatment Advocacy Center, 2014.
12. Heartland Alliance. “Racism’s Toll on Poverty.” Social Impact Research Center, 2016.
13. Ballout, Dana. “Chicago’s mental health clinic closings: 20 months later.” Aljazeera America, 2013.
14. National Employment Law Project. “The Low Wage Recovery and Growing Inequality.” 2012.
15. Susser, E., Valencia, E., Conover, S., Felix, A., Tsai, W., Wyatt, R. Preventing recurrent
homelessness among mentally ill men: a “critical time” intervention after discharge from a shelter.
American Journal of Public Health, 87(2), 256—262.1997.
Additional Sources
Phone conversation with Rachel Gragg from the United States Department of Agriculture
Phone conversation with David Kaz from the Seattle Jobs Initiative
Phone conversation with Donna Dumond from Arkansas DHS
Phone conversation with Kathy Grunewald from Florida Legal Services
Phone conversation with Nikki Newsome from Fresno Bridge Academy SNAP E&T Program in Fresno,
County in California
Phone conversations with Steve Ovel and Andrew Schramm from Kirkwood Community College in Iowa
Conversations with SNAP E&T providers in IL
Community Quality Council Meetings in local Illinois Department of Human Services Offices
USDA SNAP Toolkit
USDA Best Practices Report
House Committee on Agriculture-Subcommittee on Nutrition- Public Hearing Re: Past, Present, and Future
of SNAP: Improving Innovation and Success in E&T Programs
University of Chicago- Chapin Hall, Inside the Black Box: What Makes Workforce Development Programs
Successful?
University of Chicago- Chapin Hall, Chicago’s Labor Force in Context
Wilder Research Foundation- Perceptions of SNAP’s Mandatory Work Provisions on Adults Without
Dependents
A Comprehensive Assessment of Able-Bodied Adults Without Dependents and their participation in the
Work Experience Program in Franklin County, Ohio
Created by the Illinois Hunger Coalition
Anne Marie Buron, Emerson Hunger Fellow
Call our Hunger Hotline at 1-800-359-2163
Se habla Español
Last updated 2/14/2017