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What effect did COVID-19-era waivers have on SNAP work participation 2020–2024?
Executive Summary
The COVID-19-era SNAP waivers from 2020–2024 largely suspended the ABAWD time limit and extended administrative flexibilities, which kept millions enrolled and reduced forced exits tied to work requirements during economic disruption [1] [2]. Evidence remains limited and mixed on whether these waivers changed recipients’ labor-market behavior: broader administrative and academic analyses show little consistent increase in employment from work mandates and significant disenrollment driven by administrative burdens when requirements are enforced [3] [4].
1. How the Waivers Changed the Rules—Emergency Tools That Kept Benefits Flowing
Federal guidance and state requests documented a near-universal use of emergency authorities to suspend the ABAWD 3-month time limit and apply other flexibilities between 2020 and 2024, including streamlined certifications, benefit issuance flexibilities, and temporary exemptions tied to local labor-market conditions. The USDA Food and Nutrition Service cataloged waiver approvals and implementation choices by state, noting that many waivers were justified by high unemployment or insufficient job availability, and that some flexibilities persisted through the unwinding period after the public health emergency ended on May 11, 2023 [1] [5] [2]. These operational changes were designed to prioritize food access over enforcement of work participation rules during a systemic labor shock, shifting administrative emphasis from sanctioning to continuity of benefits.
2. Immediate Enrollment and Participation Effects—Less Churn, More Retention
Operational reports and program tracking indicate the waivers reduced churn and prevented mass loss of benefits that would otherwise arise from strict ABAWD enforcement. By suspending time limits and easing procedural hurdles, states avoided processing large numbers of disqualifications while labor markets were unstable; the federal documentation shows extensive state-level waiver requests and approvals consistent with this effect [1] [2]. The most direct, consistent outcome of the waivers was retention of SNAP coverage for able-bodied adults without dependents during the pandemic, although USDA summaries do not compute a single national causal estimate of how many people would have exited absent the waivers [5].
3. Labor-Market Outcomes—Academic Studies Show Weak or No Employment Gains from Requirements
Recent empirical research on SNAP work requirements and labor supply provides relevant context but does not directly measure the 2020–2024 waiver window in all cases. A government study found no sharp employment discontinuity at the ABAWD age cutoff, while other work finds that enforcing work rules often produces disenrollment without raising work hours—especially when administrative burdens rise [3] [4]. These studies suggest that the presence or removal of work mandates yields limited positive effects on employment but substantial risks of increased hardship through program loss, meaning waivers likely protected livelihoods more than they discouraged work.
4. Confounding Factors and Gaps—Why Firm Causal Claims Are Elusive
Assessing the waivers’ causal impact on work participation is complicated by simultaneous policy changes: expanded unemployment insurance, stimulus payments, labor demand shifts, and state heterogeneity in how waivers were implemented. USDA materials document a patchwork of state decisions and timelines, and academic reviews note that many analyses rely on restricted microdata from a subset of states or on designs not tailored to the COVID-19 shock [5] [3]. The result is substantial uncertainty about net behavioral effects: waivers likely prevented administrative exits while any direct employment response to relaxed requirements appears small and overshadowed by macroeconomic forces.
5. Stakes, Trade-Offs, and What the Evidence Recommends Next
Policy debates frame waivers either as necessary relief to avoid hunger during crisis or as undoing incentives for work. The evidence favors the relief narrative in emergency conditions: waivers preserved access with little demonstrated employment gain from strict enforcement, and empirical work highlights disenrollment and administrative hurdles as primary harms when rules are tightened [4] [2]. Future policy should prioritize rigorous, timely evaluations tied to the unwinding of flexibilities—using multi-state microdata and designs that separate administrative from behavioral effects—to inform whether targeted, short-term waivers or redesigned, low-burden work supports best balance food security and labor-market goals [6] [3].