6

Conclusions and Recommendations

In its charge to the committee, the U.S. Department of Agriculture’s Food and Nutrition Service (USDA-FNS) asked the committee to consider (1) the feasibility of establishing an objective, evidence-based, science-driven definition of the adequacy of Supplemental Nutrition Assistance Program (SNAP) allotments consistent with the program goals of improving food security and access to a healthy diet, as well as other relevant dimensions of adequacy; and (2) the data and analyses needed to support an evidence-based assessment of the adequacy of SNAP allotments.

The committee developed a framework (see Chapter 1, Figure 1-2) to use as a guide in assessing the feasibility of objectively defining the adequacy of SNAP allotments. This framework links to the committee’s charge:

•   the total resources available to the household to produce meals, including non-SNAP benefits, non-SNAP income, other program benefits and resources (e.g., emergency food assistance), and time;

•   individual, household, and environmental factors that affect how resources can be used to obtain a healthy diet, including the foods purchased and consumed; and

•   SNAP program characteristics that impact the process by which households achieve (or do not achieve) the program goals of food security and access to a healthy diet consistent with the goals of the Dietary Guidelines for Americans.

The committee reviewed and assessed the evidence base for objectively defining the adequacy of SNAP allotments and the data and analyses needed



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6 Conclusions and Recommendations In its charge to the committee, the U.S. Department of Agriculture’s Food and Nutrition Service (USDA-FNS) asked the committee to consider (1) the feasibility of establishing an objective, evidence-based, science-driven definition of the adequacy of Supplemental Nutrition Assistance Program (SNAP) allotments consistent with the program goals of improving food security and access to a healthy diet, as well as other relevant dimensions of adequacy; and (2) the data and analyses needed to support an evidence- based assessment of the adequacy of SNAP allotments. The committee developed a framework (see Chapter 1, Figure 1-2) to use as a guide in assessing the feasibility of objectively defining the ade- quacy of SNAP allotments. This framework links to the committee’s charge: • the total resources available to the household to produce meals, including non-SNAP benefits, non-SNAP income, other program benefits and resources (e.g., emergency food assistance), and time; • individual, household, and environmental factors that affect how resources can be used to obtain a healthy diet, including the foods purchased and consumed; and • SNAP program characteristics that impact the process by which households achieve (or do not achieve) the program goals of food security and access to a healthy diet consistent with the goals of the Dietary Guidelines for Americans. The committee reviewed and assessed the evidence base for objectively defining the adequacy of SNAP allotments and the data and analyses needed 175

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176 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM to support this definition. Based on this assessment, the committee set the pro- gram goals of improving food security and access to a healthy diet as boundar- ies within which to identify the factors that should be examined as elements of this definition. The committee’s conclusions about the role of these factors as components of an objective definition of the adequacy of SNAP allotments are presented below. The chapter then presents the committee’s recommendations for how USDA-FNS should approach using these factors to formulate this definition, how it should monitor assessment of the adequacy of SNAP allot- ments, and what it should do to meet additional research needs. The chapter ends with a discussion of other research considerations and a brief summary. It should be noted that the committee did consider the impact of several as- sumptions of the Thrifty Food Plan (TFP), as well as aspects of how the plan is implemented, on the definition of the adequacy of SNAP allotments, but did not make recommendations for modifying these assumptions. CONCLUSIONS The committee’s conclusions derive from its findings about the evidence reviewed, as presented in Chapters 3 through 5. These conclusions formed the basis for the recommendations that follow. Conclusion 1: The Adequacy of SNAP Benefit Allotments Can Be Defined Based on the available evidence, it is feasible to define objectively the adequacy of SNAP allotments. Doing so entails identifying the factors that affect the ability of participants to attain food security and access to a healthy diet. The committee’s review of the evidence found that it is possible to identify those factors, and the committee has done so in its framework and in the following two conclusions and the findings that support them. The available evidence has some limitations, but it is possible to obtain the evidence needed for a science-driven definition of allotment adequacy. First, evidence must be taken into account on the degree to which specific indi- vidual, household, and environmental factors influence SNAP participants’ purchasing power, given a dollar value of their SNAP benefits. Second, evidence must be taken into account on impacts of factors related to the computation of the dollar value of the SNAP allotment itself, as well as other SNAP program characteristics. Conclusion 2: The Adequacy of SNAP Allotments Is Influenced by Individual, Household, and Environmental Factors Evidence obtained by the committee in its data gathering workshop and in its review and assessment of the literature revealed that the opportunity

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CONCLUSIONS AND RECOMMENDATIONS 177 for SNAP participants to meet the program goals, given a dollar value of their SNAP benefits, is influenced by a number of individual, household, and environmental factors that impact the purchasing power of the allot- ments. The committee found that a definition of the adequacy of SNAP allotments must account for these factors according to the magnitude and significance of their influence on the allotments’ purchasing power. Although SNAP allotments might be adequate in the absence of these fac- tors, the evidence suggests that these factors can act as barriers to obtaining nutritious foods and preparing nutritious meals consistent with the assump- tions of the TFP. The evidence on individual, household, and environmental factors that constrain the purchasing power of SNAP allotments is most robust for four factors: • The SNAP allotment, which is based on the TFP, assumes the purchase of many basic, inexpensive, unprocessed foods and in- gredients requiring substantial investment of the participants’ time to produce nutritious meals. The evidence shows that the time re- quirements implicitly assumed by the TFP are inconsistent with the time available for most households at all income levels, particularly those with a single working head. By failing to account for the fact that SNAP participants, like other households, need to purchase value-added foods that save preparation time, the current value of the SNAP allotment substantially limits the flexibility and purchas- ing power of SNAP benefits. • The food prices faced by SNAP participants vary substantially across geographic regions of the country and between rural and urban areas. However, SNAP benefits are adjusted only for Alaska and Hawaii. SNAP participants in locales with higher food prices are likely to find it more difficult than those in areas with lower prices to purchase the types and amounts of foods specified in the TFP as adequate to meet their needs for a nutritious diet. The evidence points further to a lack of data on the extent to which food prices influence the ability of SNAP participants to purchase nutritious foods. • There is evidence that low-income households face higher transac- tion costs in achieving food security and access to a healthy diet relative to higher-income households. For example, low-income and minority populations are more likely than other groups to experience limited access to supermarkets and other large retail outlets, such as big-box stores, that offer a broad range of healthy foods at reasonable cost. Individuals without access to such venues experience greater disparity in the availability of healthy foods, such as fresh fruits and vegetables, in their neighborhood food

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178 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM outlets. In addition, a lack of transportation infrastructure com- monly leads to limited food access in small towns and rural areas. • Nutrition education programs for low-income participants that include training in food purchasing and preparation skills appear to have some effectiveness in changing behavioral outcomes. This finding lends credence to the theory that skills are a limiting factor in the ability of some SNAP participants to maximize the pur- chasing power of the current SNAP allotments. However, existing evidence on the influence of nutrition knowledge and skills on the ability of SNAP participants to purchase and prepare nutritious foods consistent with the assumptions of the TFP is insufficient to support a conclusion about the relevance of these factors to an evidence-based definition of the adequacy of SNAP allotments. Conclusion 3: The Adequacy of SNAP Allotments Is Influenced by Program Characteristics The evidence suggests that a number of factors related to how the d ­ ollar value of SNAP allotments is calculated, as well as other SNAP pro- gram characteristics, can influence the feasibility of defining an adequate SNAP allotment. The evidence supports the conclusion that the maximum benefit, the benefit reduction rate, and the net income calculation have important impacts on the definition of the adequacy of SNAP allotments. • Maximum benefit guarantee—The maximum SNAP benefit, cur- rently based on assumptions of the TFP plus the temporary up- ward adjustment that occurred under the American Recovery and Reinvestment Act of 2009, may not always be sufficient to allow participants to purchase the food components and prepare the meals specified by the TFP for several reasons. As noted above, the time available for most households at all income levels, particularly those with a single working head, is insufficient to meet the as- sumptions of the TFP, and thus the allotments do not sufficiently account for the costs of purchasing foods that must be further prepared. Also as noted above, the TFP does not account for many types of geographic price variation. In addition, limited evidence suggests that some SNAP households with no net income as defined under the program and residing in high-cost locales with limited access to food outlets are unable to purchase the foods included in the market basket underlying the TFP. Although the committee found compelling evidence on the time costs of meal preparation and on geographic price variations, the evidence on how best to

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CONCLUSIONS AND RECOMMENDATIONS 179 incorporate these factors into the SNAP benefit formula is less compelling. The committee also identified as an issue affecting the adequacy of SNAP allotments the fact that the annual maximum benefit update occurs following a 16-month lag. The June cost of food is used to update the TFP in October, but then is not updated again until the following October, 16 months later. Because of the impact of inflation and other factors on food prices, this lag in the benefit adjustment can significantly reduce the purchasing power of SNAP allotments. • Benefit reduction rate—The original assumption underlying the benefit reduction rate is that the average U.S. household spends 30 percent of its income on food. This assumption is outdated and inconsistent with the current average spending pattern across income levels in the United States of about 13 percent of pretax income spent on purchases of all food consumed, both at home and away. Although lower-income households spend a greater portion of their income on food (e.g., 16.8 percent in 2010) compared with higher-income households (e.g., 11.7 percent in 2010), the percent- age is still substantially less than the 30 percent assumption cur- rently used or the lower effective benefit reduction rate that results after other parts of the benefit formula have been applied. Evidence suggests that a lower benefit reduction rate more closely aligned with current household spending patterns would likely give house- holds greater incentive to combine workforce participation with the receipt of SNAP benefits by reducing the penalty for working. • Calculation of the net income deduction—The committee found evidence that several program characteristics used to determine net income and the monthly allotment may not adequately capture the impact of additional extraordinary household costs that reduce the allotment’s purchasing power. Regarding the shelter deduc- tion, considerable evidence shows that a substantial proportion of SNAP households face housing costs in excess of the current cap on the shelter deduction, which results in overestimation of the net income participants have available to purchase food. Deductions allowed for medical expenses for persons older than 60 and the disabled may influence the purchasing power of the allotment for those individuals but do not address out-of-pocket medical costs for nonelderly, nondisabled participants, although more evidence is needed to understand the impact of such expenses on the adequacy of SNAP allotments. Evidence is more limited on whether the cur- rent 20 percent earned income deduction is adequate to cover the additional expenses incurred by SNAP recipients who work.

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180 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM Summary In summary, the committee concluded that, using current evidence, it is feasible to define an adequate SNAP allotment as the extent to which participants have the opportunity to attain the program goals of improv- ing food security and access to a healthy diet. Within these boundaries, certain factors need to be examined as elements of a definition of adequacy. Evidence reviewed by the committee indicates that a number of individual, household, and environmental factors can have an impact on the purchas- ing power of SNAP allotments, although more evidence is needed to fully understand the magnitude of the impact of these factors in influencing the adequacy of the current allotments. Further, evidence reviewed by the committee indicates that several features of the way SNAP allotments are calculated, such as how food prices and spending patterns are accounted for, must also be considered in defining adequacy. The committee notes that while defining the adequacy of SNAP allotments is feasible, implementing such a definition in practice would require the routine availability of data on all the elements of the definition. RECOMMENDATIONS The committee offers its recommendations in three areas. First, it rec- ommends elements that should be included by USDA-FNS in an evidence- based, objective definition and measurement of the adequacy of SNAP allotments. Second, it recommends monitoring and assessment of the ade­ quacy of SNAP allotments that is needed for evaluation and adjustment over time. Third, it recommends additional research and data needed to support an evidence-based definition of allotment adequacy. The subsequent section describes other research considerations for furthering the understanding of adequacy. Specific data and analytical challenges to the primary research effort are summarized in Chapters 3 and 4. Defining and Measuring the Adequacy of SNAP Allotments To define the adequacy of SNAP allotments objectively using currently available evidence requires consideration of a range of factors identified by the committee as likely to have an impact on the allotments’ purchasing power. As a first step, the committee established a framework for consider- ing factors that can have an impact on defining allotment adequacy. With this in mind, the committee offers the following recommendations. Recommendation 1: In defining allotment adequacy, the U.S. Depart- ment of Agriculture (USDA) Food and Nutrition Service (FNS) should in-

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CONCLUSIONS AND RECOMMENDATIONS 181 clude consideration of the influence of specific individual, household, and environmental factors on Supplemental Nutrition Assistance Program (SNAP) participants’ purchasing power, given the dollar value of their SNAP benefits. Specific individual, household, and environmental factors to consider in a definition of the adequacy of SNAP allotments are •  ime—USDA-FNS should recognize the cost-time trade-offs in- T volved in procuring and preparing a nutritious diet. The dollar value of the Thrifty Food Plan (TFP), with its strong reliance on preparation of meals from basic ingredients, does not account for time constraints faced by most households at all income levels, particularly those with a single working head of household, which necessitate purchasing value-added or prepared foods with a higher cost. USDA-FNS should examine the impact of accounting for cost- time trade-offs, for example, by — applying a time adjustment multiplier to the cost of the TFP or reviewing options for adjustments to the current cost of the plan, and —  djusting the earned income deduction to reflect more accurately a time pressures for participants who are working. •  eographic price variation—USDA-FNS should recognize the G substantial variation in food prices that exists across geographic regions of the contiguous United States and between rural and urban areas. USDA-FNS should examine possible approaches to accounting for this variation, such as through adjustments to the maximum benefit that take into account — pricing or price adjustments for food in high-cost (including urban and rural areas) as well as low-cost regions; —  hether the shelter cap should be increased, particularly in high- w cost regions; and —  lternatives to the TFP, such as the Low-Cost Food Plan. a •  ccess to food outlets—USDA-FNS should assess the impact of A limited access to certain food outlets (e.g., supermarkets) that may affect the ability of some SNAP participants to purchase a variety of healthy foods at reasonable cost. Evaluation and assessment of access barriers should include the degree to which, and for whom, they constrain the SNAP allotment that would otherwise be ad- equate to meet the program goals. Recommendation 2: In defining allotment adequacy, the U.S. Depart- ment of Agriculture (USDA) Food and Nutrition Service (FNS) should also consider evaluating specific program characteristics that affect the allotment’s actual dollar value, as well as the extent to which the

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182 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM allotment is targeted to individual Supplemental Nutrition Assistance Program (SNAP) participants. Specific program characteristics to con- sider in a definition of allotment adequacy are •  aximum benefit guarantee—USDA-FNS should evaluate the M need to —  adjust the current timing scheme for the cost-of-living adjust- ment to the Thrifty Food Plan (TFP) to reduce the 16-month lag in updates; —  pdate adjustments for economies of scale to reflect current data u on the impact of family size on family food spending; and —  correct for misalignment in the assumptions of the TFP that serve as the basis for determining the maximum benefit guaran- tee to account for current lifestyle and meal patterns that include the purchase of food products that reduce the need for in-home preparation time. •  enefit reduction rate—USDA-FNS should evaluate whether there is B a need to adjust downward the current benefit reduction rate, which is currently set at 30 percent but has a lower effective rate, to reflect the current purchasing behaviors of U.S. households. •  alculation of net income—USDA-FNS should evaluate whether C there is a need to adjust the design of the net income calculation to better reflect the ability of SNAP participants to purchase food within the boundaries of their incomes. Particular attention should be given to the adequacy of the current earned income deduc- tion; the cap on the excess shelter deduction; and the possibility of expanding the out-of-pocket medical deduction to nonelderly, nondisabled populations. Monitoring Assessment of the Adequacy of SNAP Allotments The committee’s findings suggest that an evidence-based definition of the adequacy of SNAP allotments requires ongoing monitoring of the abil- ity of SNAP participants to use the allotments to achieve the program goals. To this end, it is important to know the proportion of SNAP participants that are more food secure and consuming healthier diets as a result of the program, and within what time frame. Understanding the impacts of SNAP benefits on these outcomes would contribute to the broader knowledge base used to define the adequacy of SNAP allotments. Recommendation 3: To assess the correspondence between the def- inition of an adequate Supplemental Nutrition Assistance Program (SNAP) allotment and the attainment of the program goals, and to

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CONCLUSIONS AND RECOMMENDATIONS 183 adjust the definition of adequacy as information on influencing factors evolves, the U.S. Department of Agriculture (USDA) Food and Nutri- tion Service (FNS) should • D  evelop longitudinal datasets containing appropriate measures of food insecurity, access to a healthy diet, and SNAP participation as part of the evidence base it uses to define adequacy. • A  ssess existing and establish new evaluation protocols that can measure the impact of SNAP participation on food security and access to a healthy diet, accounting for selection biases (e.g., that SNAP participants may be more likely to be food insecure than the general low-income population). • E  valuate additional nutrition monitoring tools, including a stan- dardized measurement tool with which to monitor and assess the ability of SNAP allotments to support a dietary pattern consistent with the Dietary Guidelines for Americans. The committee identi- fied the Healthy Eating Index as one example of a measure that could be adapted to assess whether SNAP participants are meeting recommended dietary goals. Meeting Additional Research Needs The committee identified several factors related to SNAP program par- ticipation that may affect whether some SNAP participants are able to meet the program goals and for which evidence is currently inadequate to fully assess their importance. These factors may affect either directly or indirectly the definition of the adequacy of SNAP allotments. The two broad areas in which additional research is needed to further develop the knowledge base for the potential use of these factors in defining allotment adequacy are educational programs that can help participants increase the purchasing power of the SNAP allotment and access to retail outlets and foods. Recommendation 4: The U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) should conduct further research in the fol- lowing areas to support the definition of allotment adequacy: • T  o better assess how participants’ understanding of nutrition and resource management skills affect the adequacy of Supplemen- tal Nutrition Assistance Program (SNAP) allotments, USDA-FNS should —  ssess whether and how strengthening the quality (content and a delivery mechanisms) of education in nutrition and resource management skills can support allotment adequacy, for ex-

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184 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM ample, through educational outreach such as demonstration p ­ rojects, and evaluate the level of funding needed to support such programs; and — assess how effectively these educational programs align with the needs of SNAP participants and the program’s potential to enhance the purchasing power of SNAP allotments. • T  o evaluate the impact of access to retail outlets on the opportunity for SNAP participants to be food secure and to make nutritious food choices, USDA-FNS should conduct periodic regional cross- sectional surveys to gather information on the cost and availability ­ of foods that are consistent with the recommendations of the ­ ietary Guidelines for Americans. D OTHER RESEARCH CONSIDERATIONS The committee’s recommendations pertain only to the evidence needed to objectively define the adequacy of SNAP allotments and the data and analyses needed to support an evidence-based assessment of adequacy. Two factors emerged, however, that the committee wishes to acknowledge as issues that may have a secondary impact on defining allotment adequacy. Current levels of evidence are insufficient to support any recommendation for defining, measuring, or monitoring allotment adequacy based on these factors. However, these research questions were compelling enough to war- rant their consideration as areas for other research that could contribute to a fuller understanding of the range of factors that influence allotment adequacy. These factors are (1) the influence of incentivizing purchases of healthier foods on access to a healthy diet and (2) documentation and assess­ ent of the relative cost impact of ready-to-eat prepared foods on the m total cost of a market basket of healthy foods. First, the committee encourages USDA’s continued support for rigorous independent investigations evaluating the role of both incentive and restric- tion approaches to encouraging healthy food purchases in supporting the program goals. The potential for such approaches to influence program par- ticipation and attendant food security and to encourage SNAP participants to purchase and consume foods that would contribute to a healthy diet has not been established. Independent research is needed to assess the effects, both direct and indirect, including ethical, financial, and other consider- ations, associated with implementing such a policy. Second, the committee encourages research efforts by USDA-FNS to determine pricing variation among ready-to-eat prepared, partially prepared, and unprepared foods and assess the impact of this variation on the ability of SNAP participants to maximize their benefits to achieve the program goals.

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CONCLUSIONS AND RECOMMENDATIONS 185 SUMMARY The committee’s recommendations for defining, measuring, and moni- toring the adequacy of SNAP allotments within the context of participants’ ability to meet the program goals are derived from its review and analysis of a broad range of evidence. The committee concluded from its findings that the adequacy of SNAP allotments is influenced by individual, house- hold, and environmental factors, as well as program characteristics. Its recommendations are structured to (1) assist USDA-FNS in establishing an objective definition of the adequacy of SNAP allotments, taking into consideration the evidence for these factors and (2) identify specific data and analysis require­ ents to support an evidence-based assessment of allot­ m ment adequacy.

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