Sharing store-level SNAP redemptions data

USDA's Food and Nutrition Service (FNS) has requested public comment on the question: Should store-level redemptions data for the Supplemental Nutrition Assistance Program (SNAP) be shared with the public?

This blog has long encouraged making public such information, which is useful to low-income communities seeking to improve access to healthy food.

In 2010, I covered the efforts of the MuckRock website to make public similar information. More recently, the Argus Leader pressed USDA to release store-level SNAP redemptions data. Tracie McMillan summarized the controversy in an article for the Food and Environment Reporting Network (FERN) and Mother Jones in April.

The public comment period is open through today. Act now if you would like your voice heard. Here is an excerpt from my comment, submitted just now.

Thank you for requesting public comment on the question: should USDA/FNS release store-level redemptions data for the Supplemental Nutrition Assistance Program (SNAP)?

The answer is “yes.”

This public information is useful

SNAP represents an increasingly large fraction of the U.S. food retail economy, now accounting for more than 10% of all food retail sales (Wilde, 2012). SNAP is the nation’s most important anti-hunger program, of course, and in recent years the program also has become a critical and central part of the food retail economy overall. To administer this responsibility transparently, in circumstances such as this one where information release is legal and ethical, USDA/FNS should make the information available.

With growing public interest in encouraging access to sufficient healthy food retail in low-income communities, these communities require good information about store-level SNAP redemptions. In a newsmagazine article this year by Tracie McMillan, James Johnson Piett explained the need: “We’re working kind of blind when it comes to empirical data” (McMillan, 2014).

It is legal and ethical to make this information public

The most important point is that SNAP redemptions data are not private confidential business information.

Section 9(c) of 7 U.S.C. 2018(c) prevents USDA/FNS from sharing information that is “received from applicant and participating SNAP retailers.” Similarly, Exemption 4 of the Freedom of Information Act (FOIA) allows FNS to hold back “trade secrets and commercial or financial information obtained from a person and privileged or confidential.” In both cases the confidential information is obtained by the government from a private party or firm.

Store-level SNAP redemptions data are not private information acquired from a private party or firm in this manner. The redemptions data show what is being paid out by USDA/FNS and the federal government, on behalf of the American taxpayers, who have committed great resources at large expense to this important public purpose. Public expenditures in contracts with businesses that provide goods and services are usually rightly public information. Think about subsidies to farmers, or the value of military contracts to arms manufacturers, or municipal expenditures on roads, all of which are public information. No roads contactor can say, “please keep the amount of this contract private, because that is valuable confidential business information.”

In the comments to FNS that have already been posted to the Federal Register docket, many retailers have expressed concern over the release of their private business information. It is good for FNS to reassure them that private information they have provided will not be released. But -- despite the repetition in the submitted comments -- the basic store-level redemptions data are not private confidential information of this type. These redemptions data should be shared.

In the comments from retailers on the Federal Register docket, retailers express concern about the feared difficulty and cost of new data collection mechanisms to provide these data. These fears are unfounded. If there were any new data collection cost or difficulty, FNS would be entirely correct to decline to collect or release these data. FOIA is about public release of existing data that FNS already collects. Certainly, the state SNAP agencies that administer the program already know the redemption amounts.

New edition of Breadlines Knee-Deep in Wheat by Janet Poppendieck

Breadlines Knee-Deep in Wheat is a classic in the history of U.S. food policy, written by sociologist  Janet Poppendieck, focused on the connections between agricultural crisis and food programs for the poor in the Great Depression.

The new edition from the University of California Press, published this month, includes a foreword by Marion Nestle and a delightful new epilogue bringing the story up to date from the book's original publication in the 1980s to the present. And by "the present," I mean the book includes material as recent as the key January 2014 compromise over the Supplemental Nutrition Assistance Program (SNAP) provisions new Farm Bill. (In terms of the publishing mechanics, how is this even possible?).

I read the new manuscript last year at the request of the publisher (and recommended republication):

The book is well-written and detailed, making bureaucratic correspondence come alive as lively argument. It has an authoritative and believable voice, while still carrying passion for the plight of the poor and hungry. I knew this already from reading Poppendieck’s more recent books on the emergency food system and on school meals reform. The pig slaughter story will stick in my head permanently now. The use of archival material adds novelty, but the book serves well even digesting and interpreting known topics.

Immediately today I will add this book to my U.S. food policy syllabus and place an order request to my university library.

Farm Bill conference proposes cutting $800 million per year in SNAP benefits

The Farm Bill conference committee report, released today, includes $800 million per year in cuts to the Supplemental Nutrition Assistance Program (SNAP), the nation's largest anti-hunger program.

The conference report likely puts to rest several years of debate between the Republican-controlled House of Representatives, which sought much steeper cuts, and the Democratic-controlled Senate, which sought less severe cuts. Both houses of Congress are likely to pass the compromise in the conference committee report this week.

The compromise is a disappointment to anti-hunger advocates. Program participants already in November faced the end of a temporary boost to program benefits. These new cuts are in addition to that change in November.

Yet, in a sense, the cuts proposed today were inevitable, and about as mild as program supporters could expect.

The actual mechanism for most of the cuts is a change to how utility costs are counted when benefits are calculated. Certain utility costs count as "excess shelter expenses," which are deducted from gross income during the computation of net income. SNAP benefits are based on net income (those with higher net income get smaller benefits), so eliminating a certain type of utility cost deduction amounts in practice to the same thing as a benefit cut.

Bob Greenstein at the Center on Budget and Policy Priorities, a leading public interest voice on nutrition assistance policy, this evening explained why this change to the utility cost computation was difficult to oppose:

The SNAP cut ... is a provision to tighten an element of the SNAP benefit calculation that some states have converted into what most people would view as a loophole. Specifically, some states are stretching the benefit formula in a way that enables them not only to simplify paperwork for many SNAP households, but also to boost SNAP benefits for some SNAP households by assuming those households pay several hundred dollars a month in utility costs that they do not actually incur. Congress did not intend for states to stretch the benefit rules this way, and longstanding SNAP supporters like myself find it difficult to defend. Moreover, a future Administration could close off this use of the rules administratively, without any congressional action.

If I were king, the social safety net would be more generous. Our society would be a better society if we treated the poor and hungry as brothers and sisters. Who among us, in speaking of a poor or hungry brother or sister, would hesitate to provide resources before offering unsolicited advice? In several ways, I would make the social safety net more respectful of the dignity of its participants.

But I am not king. I am proud instead to live in our semi-functioning democracy. This Farm Bill compromise on nutrition assistance is about as good as I expected from the current Congress. The burden lies with program supporters first to persuade more voters of the value of these programs and then second to press for more generous program benefits.

USDA Under Secretary Kevin Concannon speaks at the Friedman School

Kevin W. Concannon, USDA Under Secretary for Food, Nutrition, and Consumer Services spoke this month at the Friedman School's weekly Wednesday seminar.  He gave a broad overview of USDA's nutrition assistance programs and nutrition education initiatives.

Kevin W. Concannon has served as President Obama's and Secretary Vilsack's Under Secretary for FNS since July 2009.

He oversees the U.S. Food and Nutrition Service (FNS) which serves 1 in 4 Americans, and has lead responsibilities for promoting healthful diet through the Center for Nutrition Policy and Promotion.

Working in partnership with State and local organizations, FNS oversees the Supplemental Nutrition Assistance Program (SNAP), formerly known as the Food Stamp Program; child nutrition programs including National School Lunch, School Breakfast, and Summer Food Service Programs; The Child and Adult Care Food Program; the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC); the Commodity Supplemental Food Program; Food Distribution Program on Indian Reservations; The Emergency Food Assistance Program; and other nutrition programs.

A video of the presentation and discussion is available from iTunes.

Food stamp challenge (with abundant talent)

In my presentation at Virginia Tech last month, I mentioned the food stamp challenge, a short-term exercise in living on the food budget available to a very low-income participant in the Supplemental Nutrition Assistance Program (SNAP).

One of the students there began the challenge and documented it on a blog, posting food photography and receipts.  Although some people attempt a food stamp challenge using average benefits as the spending benchmark, I think Clara was correct to use the maximum SNAP benefit as a benchmark (this is the benefit amount received by the lowest-income program participants).

Of course, few of us have the talent to make a food stamp challenge look so good.  Please do not use Clara's blog posts for the purpose of redesigning federal food stamp policy!  Instead, just consider Clara's experience as one example of the diversity of experiences that people have with the economics of food spending, preparation, and ... clearly ... enjoyment.

South Carolina explores restriction on SNAP purchases of sugar-sweetened beverages

Economist Diane Whitmore Schanzenbach recently argued in the Christian Science Monitor against proposals to disallow purchases of sugar-sweetened beverages using SNAP benefits.

Without question, the advocates for a policy to ban the purchase of sugar-sweetened beverages using SNAP benefits have the best of intentions. But policymakers need to be careful not to let their zeal for combating obesity push them into hastily adopting policies that at best are unlikely to help fight obesity, and, at worst, can do substantial damage to the safety net.

New York City had proposed such a policy some time ago, and South Carolina was reported more recently to be considering a pilot study.  As with the SNAP policy suggestion discussed in yesterday's post, a pilot study is important, because there are serious concerns that SNAP spending restrictions could increase stigma and discourage participation by eligible potential participants.

Perhaps, a pilot study would show increased perceptions of stigma, reduced participation, and even hunger and food insecurity as a consequence of the sugar-sweetened beverage limitation.  At the same time, it is quite possible that the pilot policy would strengthen the healthy identity of SNAP benefits and reduce stigma.  The policy may be popular with low-income parents, who must manage the intense marketing environment for unhealthy beverages just as middle-income parents must.  As a practical matter, any proponents of such a pilot study should take seriously the concerns that the anti-hunger community has expressed about such policies.  As in yesterday's post, I think the views and experiences of SNAP participants should be most influential in this policy decision.

Food stamp cycle in the Washington Post

The Washington Post this weekend published a long and thoughtful feature by Eli Saslow titled: Food Stamps put Rhode Island town on monthly boom-and-bust cycle.

At precisely one second after midnight, on March 1, Woonsocket would experience its monthly financial windfall — nearly $2 million from the Supplemental Nutrition Assistance Program (SNAP), formerly known as food stamps. Federal money would be electronically transferred to the broke residents of a nearly bankrupt town, where it would flow first into grocery stores and then on to food companies, employees and banks, beginning the monthly cycle that has helped Woonsocket survive.

For research background, my dissertation in the late 1990s and the resulting article with Christine Ranney in the American Journal of Agricultural Economics provided the first nationally representative estimates of the monthly cycle in food spending and food use for food stamp program participants.  My 2002 article with Margaret Andrews in the Journal of Consumer Affairs used Electronic Benefit Transfer (EBT) data to get an even sharper view of the exact timing of food stamp and cash transactions over the course of the month.  In 2005, Jesse Shapiro provided more economic insight in the Journal of Public Economics.  In a 2012 article in the American Journal of Clinical Nutrition, Harvard researchers Cindy Leung, Walter Willett, and Eric Ding recommended further research on whether the monthly SNAP cycle could be related to risk of overweight.

One policy-relevant question is whether the federal government should ever consider providing benefits twice monthly.  Michigan considered such a policy in 2008, but I think it never came to pass.

One objection I have heard is that twice-monthly benefit delivery is paternalistic and might force low-income SNAP to conduct a potentially burdensome shopping trip.  This argument seems incorrect to me.  Let me lay out the case in an orderly fashion.

Whether benefits are delivered once or twice monthly, SNAP participants can freely choose whether to shop once or twice monthly.

• If benefits are delivered to the EBT card once monthly, then a SNAP participant who wanted to shop once monthly is perfectly satisfied, but a SNAP participant who wanted to shop twice monthly and smooth consumption over the course of the month must save half the benefits for use two weeks later.
• If benefits are delivered to the EBT card twice monthly, then a SNAP participant who wanted to shop once monthly must save half the benefits for use two weeks later, but a SNAP participant who wanted to shop twice monthly and smooth consumption over the course of the month is perfectly satisfied.

The key point is that the two policies are exactly equally paternalistic.  When middle-income speakers say that twice monthly benefit delivery is paternalistic, they implicitly assume that it is most natural for low-income people to shop once monthly and go hungry later -- a shopping pattern that the middle-income speakers would never use themselves.  I think it is the middle-income speaker's implicit assumption that really is paternalistic.

Any policy such as twice-monthly benefit delivery should be pilot tested.  The pilot should explicitly ask SNAP participants whether they had any shopping difficulties or budget difficulties, and whether they liked the new policy better than the old one.  It is possible that the new policy will reduce the occurrence of episodes of food insecurity at the end of the month.  The current policy should not be preferred based on implicit assumptions. SNAP participants deserve an influential voice in this decision.

Sound Medicine: How does farm policy affect the nation's nutrition and health?

I recently spoke with Barbara Lewis at the Indiana NPR program Sound Medicine about the Farm Bill and nutrition.  The program website has full audio.  Here is the abstract from the program.

A large piece of legislation known as the Farm Bill has been stalled on the House floor because of budgetary concerns. The Farm Bill addresses issues such as rising milk prices, nutrition assistance programs for the poor and agriculture subsidies. Without the passage of this legislation, the farming industry has been reverting to outdated policy. Parke Wilde, Ph.D., discusses policy changes that would have a positive impact on the nation and how components of the Farm Bill would effect change. Dr. Wilde is an associate professor in the Friedman School of Nutrition Science and Policy at Tufts University and the author of the upcoming book, “Food Policy in the United States: An Introduction.”