Why Are SNAP Benefits So Confusing that Even Social Workers Can't Figure Them Out?

Crystal Ortiz, a master’s student studying social work at the University of Chicago School of Social Service Administration, has been receiving Supplemental Nutrition Assistance (SNAP) benefits since 2017. The $200 a month she received made it possible for her to buy more fresh produce, especially bagged salad kits that made it easier for her to eat a healthy lunch when she didn’t have a lot of food prep time.

This January, that was threatened when she received a letter stating that her benefits would be cancelled if she did not fulfill a 20-hour-a-week work requirement. When I first met with Ortiz, she stated that “I would have to make major cuts to the food that I get” if she lost her SNAP benefits.

This letter came at the same time that the United States Department of Agriculture finalized the Able-Bodied Adults Without Dependents (ABAWDs) rule in December 2019. “Able-bodied adults” — defined as not receiving SSI or SSDI, without children, or who are not the caretaker for an adult — are required to work or volunteer 20 hours a week, or participate in an approved workplace training program, in order to maintain their SNAP benefits. Previously, states had been able to apply for waivers to ease those requirements, but the new rule would take that flexibility away and cost up to 700,000 people their benefits.

The ABAWDs rule is not the only restriction on eligibility requirements for SNAP — according to a spokesperson at the Illinois Department of Human Services, students enrolled in undergraduate or graduate programs “more than half-time” are not eligible for the program without a special exemption. Additional restrictions ban SNAP benefits for people who are undocumented, have a drug felony, or have more than $2,250 in assets. Some of these restrictions are established by states, and may vary.

Not having enough food to eat was already a public health emergency.

In theory, a social worker like Crystal should be uniquely positioned to navigate this bureaucracy. However, social workers who use SNAP can have just as difficult of a time understanding the requirements to keep their benefits as the clients they assist. Crystal said that in class discussions about policy changes around SNAP eligibility, there wasn’t always an understanding that students were current or former SNAP recipients who were personally affected by these changes. She also said some professors would broadly mention that resources were available if students needed additional support, but specific resources were not mentioned in course materials. “I would like to see acknowledgement from the school…because if we’re not talking about it, we can’t come together,” she said, adding that this lack of discussion means students are “struggling silently.”

Even with her understanding of the SNAP requirements, Ortiz ultimately lost benefits for two months. To get them reinstated, she set up multiple meetings and phone calls with the Illinois Department of Human Services, which included taking public transit in the middle of a pandemic, waiting outside since the office was only admitting one person at a time, offering to translate for another person in line because another staffer was not available, and then meeting with a caseworker and manager to advocate for herself. The root of the issue, it seems, was her unpaid internship — she was under the impression that it counted as work, but her caseworker believed it did not since it was for class credit.

Crystal’s experience highlights the many different restrictions that already existed in the SNAP ruling even before the proposed expansion of the ABAWD requirement, and how challenging it is trying to parse conflicting information from multiple agencies. But still, even in the midst of the coronavirus, many of the restrictions hold.

Currently, the Families First Coronavirus Response Act only partially suspends the ABAWD rule: If recipients are offered a slot in a designated workfare program, they must participate in the program in order to maintain benefits. A representative from the Illinois Department of Human Services stated that all ABAWD requirements, including the requirements in FFCRA, and eligibility requirements for students receiving SNAP, are suspended until a month after the U.S. Department of Health and Human Services lifts the Public Health Emergency declaration. Navigating these mixed messages from different agencies can be frustrating for a social worker, but can be downright impossible for the average person unfamiliar with public benefits agencies. A page on the IDHS website states that current SNAP recipients will receive the maximum benefit starting the week of April 6.

The framing around these reversals in policy is focused on maintaining food access “during a public health emergency.” However, not having enough food to eat was already a public health emergency before COVID-19, as demonstrated by the patchwork of food pantries and soup kitchens that had challenges meeting the needs of the communities they serve. As we work to ensure that everyone has enough to eat during the immediate crisis of COVID-19, we can’t lose sight of that basic fact. If the USDA and state agencies can recognize how devastating a lack of food is during COVID-19, to the point where they suspend restrictions on one of their most aggressively means-tested programs, then they should be able to recognize this when there isn’t a pandemic magnifying the hunger crisis that existed before it.

When prospective pro bono clients call a lawyer about domestic violence or divorce, their legal problems are usually connected to other needs. Clients have worries about eviction, prescription drugs, and child care, not just their legal proceedings. “They’re reaching out to me and the firm for necessities,” said Todd Spodek, who offers pro bono services to first responders working during the pandemic.

Legal services organizations and law firms that provide free or reduced fee representation often work closely with other service providers to secure transportation, food, housing, clothes, and other necessities. But legal organizations can’t typically pay for those things directly, thanks to an obscure rule that exists in many states. They can cover filing fees and some required medical exams, but cannot pay for many of the basic things that would prevent clients from getting to court for their cases.

“Human services often have client emergency funds, so it seems like a false distinction that legal services can’t do that,” said Amy Barasch, executive director of Her Justice, an organization focused on representation for women living in poverty. “If you can’t come to court because you don’t have enough money to pay for child care while you are coming to court, that’s going to be an access issue.”

The problem lies with the American Bar Association’s Model Rule 1.8(e), which prohibits lawyers from loaning or giving clients money for anything not directly tied to litigation. At least 11 states, including Louisiana, Alabama, California, and Minnesota, have made efforts to loosen their own versions of Rule 1.8(e) so certain lawyers, mostly those working pro bono or in legal services for low-income clients, can pay on behalf of clients for things that fall outside direct litigation costs.

New York is the latest state to alter Rule1.8(e) in favor of providing aid to poor clients. Changes proposed by a committee at the New York City Bar were approved by the Administrative Board of New York courts on June 18. The push to refine Rule 1.8(e) began two years ago, but was interrupted by the COVID-19 pandemic and its accompanying state of emergency. In March, the bar modified their ask to request an immediate “humanitarian exception” to the rule for the duration of the coronavirus crisis.

The economic fallout from the pandemic may have pushed the courts to take action on the proposal. The modified rule will allow some lawyers to offer “humanitarian assistance to their clients in dire need,” according to the news advisory released by the New York State Unified Court System.

“New Yorkers are experiencing severe financial consequences as a result of the COVID-19 pandemic,” writes a previous letter from two New York City Bar committees to members of New York State’s Supreme Court. “Lawyers throughout the state have answered the call to provide pro bono assistance to those dealing with the repercussions of the pandemic.”

Everything you’re supposed to do to get out of poverty ends up costing money.

Indigent clients — those living in poverty who cannot afford to pay a lawyer nor court-related fees — have always needed more than volunteer lawyers are currently able to provide. Now, with job losses ballooning, more clients could enter that indigent category, and it’s likely that more people will be seeking pro bono services for eviction. The amended rule means that pro bono lawyers across New York preparing to take on cases caused or exacerbated by the pandemic now have one more resource open to them.

“Legal aid programs intersect with so many of these issues, unemployment, increased family violence, family separation or unification, eviction, foreclosure, debt problems, elder abuse. And all the things that come from a dip in the economy,” said Don Saunders, vice president of policy at the National Legal Aid & Defender Association (NLADA).

The coronavirus pandemic, like natural disasters of the past, has had a catastrophic effect on human lives and human systems. “It’s kind of like what happens after a hurricane, after you have immediate first responders, then a host of legal needs come up. We’re worried about housing, homelessness, food and nutrition and healthcare. These are all issues that people have legal rights around.”

These issues are especially pressing for people of color. The pandemic is infecting and killing New York’s residents of color at higher rates than white people, and the inequities will likely continue through the disease’s aftermath. Assistance from lawyers could also help clients who are ineligible for state supports, including undocumented people who are excluded from the stimulus and unemployment benefits. Hamra Ahmad, Her Justice’s director of legal services expects that clients who could benefit the most are those who are undocumented, minors, and/or victims of human trafficking.

Andrew Kent, Fordham Law professor and the primary author of the bar’s report, explained that clients in a financial bind will sometimes settle claims for less than they deserve. For example, “say there is someone who’s been beat up in jail at Rikers Island. If that client is getting pro bono legal help for their case, and let’s suppose that they have a good claim which might be expected to get decent money, maybe $20,000 or $40,000.”

“But if the city or the state comes to them and says we can give you a check for $2,000 today and that person has rent due, or needs costly medical treatment, or their kid needs diapers or whatever it is, that smaller amount of money might be attractive,” said Kent. If a client can’t manage their living expenses through the long court process, they may forgo a higher amount of damages in the end.

“The challenge of getting out of poverty is that everything you’re supposed to do to get out of poverty ends up costing money,” said Barasch. Good pro bono representation is a proven way to better one’s financial situation for the long term, and yet the minimum amount of participation required from clients can still be too expensive. Providing assistance to stabilize clients throughout the process could alleviate some pains and strengthen the possibility of a life-changing result.

While millions of taxpayers received CARES Act stimulus checks in the past couple of months, for many millions more, one will never arrive. That’s because undocumented immigrants and their families weren’t covered in the $2 trillion plan. That’s an estimated 6 million tax payers who help fund schools, roads, fire departments, and even the United States Department of the Treasury — the very body tasked with cutting the checks that undocumented people and their families won’t get. While there were some notable attempts to fill this gap — both through individual state efforts and bills put forward in the House and Senate — for the most part, undocumented people remain on their own.

Generally, in non-coronavirus times, undocumented immigrants pay more in taxes than they receive in benefits from the federal government, and the current social safety nets of Medicare, Medicaid, Social Security, SNAP (food stamps), and unemployment benefits don’t usually cover them. The pandemic has exacerbated the lack of governmental support and income inequality — undocumented people don’t work jobs that can be done from home, which has either left them entirely without income during the shutdown (as is the case with restaurant workers) or put them at much higher risk of coming into contact with the coronavirus (since undocumented people are disproportionately likely to be essential workers in fields with poor protections, like farmwork or meatpacking).

That means undocumented people are facing a particularly brutal choice: Either continue to work during a pandemic or lose out on money to purchase food and other necessary resources. Vera Parra, communications director and organizer with Cosecha, a grassroots movement that advocates for undocumented people, explained it like this: “There’s a choice that families are having to make between dying of hunger or dying of coronavirus.”

Now grassroots organizations and local leaders are scrambling to build a financial safety net that will help undocumented folks feed and house themselves during the pandemic because — as long as Mitch McConnell refuses to address the issue — no federal institutional support is coming.

The San Diego Immigrant Rights Consortium, a collective of over 50 organizations, has begun to create a safety net where there previously was none. Demand is high: bills still need to be paid even if there’s no way to pay them. Serrano said the consortium received over 4,000 applications for its $500 grants, and so far they have been able to award 200 of those applications. While local community members and elected officials have offered supplies and some financial support, Serrano said that “Donations are definitely one of our biggest needs: there is more need than there is funding.”

Undocumented people remain on their own.

The Cosecha fund is hoping to find some support by redistributing stimulus checks. There are a number of people who received CARES Act checks but do not urgently need the funds, either because they have not lost out on work or they would be eligible for unemployment benefits if they do lose their jobs in the future. The Cosecha fund for undocumented residents is asking individuals who are able to donate their stimulus check, either the full amount or a portion of it, to undocumented folks. Their social media campaign raised $1 million in their first round of fundraising, and they’re currently in the process of redistributing the funds to thousands of families.

Since the economy will likely continue to struggle for months, if not years, many undocumented people will continue to be reliant on donations, advocacy, and organizing to stay afloat. Parra said moving forward will require pushing the state and other governing bodies to make more funds available and “demand to be included” in future economic relief packages. Carolina Martin Ramos, the director of programs and advocacy at Centro Legal de la Raza in Oakland, California, said given the fact that the labor of undocumented folks and people of color helped to create and sustain the state’s wealth, the lack of adequate and well-funded support networks is, “just more evidence that we really treat some people as disposable and less deserving or less important.”

“It’s really hard,” said Autumn Gonzalez, an organizer with Norcal Resist, an immigrant rights organization located in the Bay Area. Because the fund relies mainly on community support and they don’t have any grant funding, “We’re going to see people evicted [and] enter that cycle of homelessness,” Gonzalez said of the worst-case scenario. “Going down that road would be a nightmare for so many thousands of families.”

Moving forward, Gonzalez said Norcal Resist will apply for grant funding, though it’s a competitive process. Other than that, they’re hoping to reach out to other folks in the area who might be sympathetic to the cause; “it’s definitely a constant worry for us.” And even as businesses start to reopen and life enters a new normal, back rent and lost wages will continue to be a concern.

Like the Norcal Resist fund, which has been supported by the local community, Serrano says that San Diego community members have stepped up. Sustaining that progress will be difficult, she said, but those with the capacity to keep donating, like private companies, should. Ramos sees a potential solution in couching mutual aid and grassroots funding work with local political advocacy. Centro Legal has been working with the City of Oakland and officials from Alameda County to negotiate a stipend for their fund and map out what rent forgiveness (as a long-term solution to housing insecurity) might look like.

Either way, Gonzalez said, “We all keep pushing because we see that there’s a need that’s not being addressed anywhere else. We know that we have to keep doing the work.”

When coronavirus started sweeping the country this March, Francine Simpson lost three jobs. The 26-year-old was apprenticing in a Los Angeles-area tattoo shop, while babysitting and working as a waiter for a caterer on the side. Like nearly one in two American adults, she survived paycheck-to-paycheck before the pandemic. Without a job, Simpson couldn’t pay her $655 share of the $1965 rent that she splits with two roommates. She quickly started receiving threats from the property management company hired by her landlord.

The leasing office at Villas Antonio Apartments in Rancho Santa Margarita, Calif., which is owned by Western National Property Management, a development company that owns more than 160 properties, called her four times asking her to sign a 120-day rent payment deferment agreement. Simpson refused, explaining that she does not know when she will return to work and that she can’t be evicted under current California law. Simpson said the manager replied, “We can’t evict you — yet.”

Deferment agreements like the one presented to Simpson are commonly used by landlords and property managers when tenants are unable to pay rent. These agreements enter tenants into legally binding contracts to pay their rent owed within the number of days designated by their landlord. In Simpson’s case, if she were to sign her contract and find herself unable to pay when the California eviction moratorium expires on July 28^th, her property owners could file an unlawful detainer case against her, which would forcibly remove her from the property and place an eviction on her record. The property owners would also have the option of suing Simpson for the amount of rent owed.

Representatives at Villas Antonio Apartments and at WNPM’s headquarters did not reply to requests for comment on the deferment agreements they are issuing to Simpson and other tenants.

Before COVID-19, these agreements were used by renters who had fallen on hard times, such as being in between jobs. With a deferment, renters could delay paying rent until they were back on their feet. But in the midst of a massive economic depression, with unemployment at over 13 percent and an estimated 21 million unemployed Americans in May, many people won’t have a steady income for months. This can leave those who sign such agreements vulnerable to eviction as the economy remains unstable for the foreseeable future.

“I’m usually ok with payment deferment agreements like the one in her (Simpson’s) case,” said Joseph Tobener, tenant lawyer and partner at Tobener Ravenscroft LLP in San Francisco. “But in a crisis situation like this, tenants shouldn’t feel forced to sign anything their landlord gives them, and they shouldn’t have an eviction on their record. Tenants have the leverage here.”

Irene Bassett also refused to sign a payment deferment plan in April. On April 20^th, her landlord issued Irene and her husband a “pay or quit” notice at their Hawthorne, Calif., apartment, which threatened them with eviction filings in three days if they refused to pay rent. Bassett responded that eviction paperwork currently cannot be filed due to pandemic emergency laws.

“A few days ago we received another letter from our landlords saying they still expect rent,” Bassett said. “Expecting rent from me in a time like this is immoral. If I have to choose between food and rent, I choose food.”

Bassett reached out to the Eviction Defense Network (EDN), where a team of lawyers like Elena Popp offer pro bono legal help to tenants in need. Popp said the three-day notice is becoming more popular with landlords.

“Some tenants see a notice like that and panic. Especially if they’re like so many Americans who have trouble accessing legal help, they leave out of fear,” Popp said. “And the court is sending false and misleading notices to tenants, notices that violate the State Judicial Council’s orders.”

We can’t evict you — yet.

Maria del Socorro Serrano received such a notice from the Los Angeles Superior Court on April 17^th, which notified her and her husband Jose Garcia that they were being evicted and had five days to respond to the court. They turned to EDN for legal assistance, and are now receiving support for their case.

“I got overwhelmed. We are already under so much pressure because my husband and I lost our jobs in March,” Serrano said. “My heart dropped to the floor.”

EDN and Popp are receiving more requests for assistance than ever, while preparing for what Popp says will be a “tsunami of evictions” when emergency protections are lifted in California. Tenant unions are also trying to keep up with renters who need assistance.

“It’s hard to keep track of the amount of renters that have reached out to us about pressure that’s being put on them to do things against their best interest,” said Jane Demian, caseworker for the Los Angeles Tenants Union. “The landlords should be approaching their lender about mortgage relief during this crisis, instead of this backlash against tenants.”

Without tenant unions and lawyer groups such as EDN, renters who find themselves in dire economic situations are often without resources to help them navigate agreements with landlords. The lawyer operated website Avvo says tenant lawyer fees typically range from $200-$500 an hour. With 58 percent of Americans having less than $1,000 in savings, hiring a lawyer is not an option for most people.

The pressure tactics by landlords can take a toll on the health of their tenants. At the beginning of April, Simpson started suffering from panic attacks. She made it through by talking out her situation with her family and friends, but is still living with the effects. As the eviction moratorium expiration date of July 28^th draws closer, she wonders what her living situation will be like in the coming months.

“It’s so upsetting. My landlords might have to wait on some money, but I could end up homeless if I have an eviction on my record,” Simpson said. “It feels like I’m stuck yelling at a wall.”

This article was supported by the Economic Hardship Reporting Project.

“You’ll hear people say, ‘that violated HIPAA.’ Actually, it violates Part 2, and it’s now gone,” lamented Zac Talbott, president of the National Alliance for Medication Assisted Recovery (NAMA Recovery) about a recent change made to addiction treatment patient privacy protections. The change took place quietly, passed as a rider to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act); or, as Talbott described it, “under cover of darkness, in the midst of a national crisis, with a stimulus bill that no one could vote against.”

The rider is named after Jessica Grubb, a Michigan woman who died at age 30 after being prescribed oxycodone for postoperative pain while only a few months into recovery from a seven-year heroin addiction. The Protecting Jessica Grubb’s Legacy Act was sponsored by Democratic Senator Joe Manchin III and Republican Senator Shelley Moore Capito, both from West Virginia, one of the states hit hardest in recent years by an influx of illicitly manufactured fentanyl. Currently, under 42 CFR Part 2, patients engaged in substance use disorder treatment programs that fall under federal purview — which essentially includes any program that utilizes opioid agonist pharmacotherapy like methadone and buprenorphine — must provide informed consent each and every time their records are shared. So when a patient authorizes a methadone program to share medication information with their primary care doctor, that provider can’t disclose the information to a specialist unless the patient signs a new, specific consent. When the act goes into effect in 2021, patients will only have to provide consent once. After that, their records can be re-shared in perpetuity by any health care entity who receives them.

The changes reflect the way privacy and consent are handled for most of health care. The act is effectively changing records disclosure consent rules to match those of the Health Insurance Portability and Accountability Act (HIPAA), except that it still preserves the initial consent required by 42 CFR Part 2.

Despite popular belief, HIPAA allows health care workers to share patient records without their consent for a number of reasons related to health care operations. “HIPAA is not a [patient] privacy protection. It’s actually an authorization to share your info as broadly as a health care payor believes they need to share it, which I will tell you is very broad,” explained Danielle Tarino, president and CEO of Young People In Recovery, who previously worked at the Department of Health and Human Services and, while there, drafted the 2017 revisions to 42 CFR Part 2.

Now, instead of special protections for patients undergoing addiction treatment, these programs will have the same privacy standards as all of health care.

The fight for privacy rights has divided key players in the addiction treatment community, many of whom are otherwise aligned. Proponents of the changes include the National Council of Behavioral Health, the American Society of Addiction Medicine (ASAM), the Substance Abuse and Mental Health Services Administration (SAMHSA), Shatterproof, and several other prominent treatment and health care voices. Those who oppose it, a group that includes the National Alliance for Medication Assisted Recovery, Legal Action Center, Young People In Recovery, and Faces and Voices In Recovery, have successfully thwarted similar proposals in the past.

“It’s just really disappointing to see that bill go through when the political will was, year after year after year, it’s not going to pass because people don’t want it to pass,” said Tarino.

Discrimination against substance use disorder patients is not a thing of the past.

Those who favor the changes say that not only will this make it easier for health care providers to share patient records, it will also allow these programs to be used in the electronic health records programs that are currently designed to meet HIPAA standards. Senators Manchin and Caputo argued that this kind of care coordination would prevent patients like Jessica Grubb from being “thrown back into the nightmare of addiction,” and insinuated that these privacy changes could have prevented Grubb’s death by ensuring all of her caregivers were informed about her addiction history. “There’s emergency glass that could be broken if someone was not able to disclose,” countered Talbott. “The notion Part 2 could cause what happened to Jessica Grubb to happen is outrageous…She disclosed [her addiction status], as most people do with their treatment providers.”

“42 CFR Part 2 said ‘if you go to treatment, we will give you the security and confidence to work on your issues,’” said Westley Clark, Dean’s Executive Professor in the Department of Psychology at Santa Clara University and the former director of the Center for Substance Abuse Treatment (CSAT) within SAMHSA. “Why would I go to treatment if they are going to blab my business all over town? We have a conundrum: We want people to go to treatment, but we are going to discourage people from seeking treatment by telling them ‘your privacy is irrelevant.’”

Part of what made these protections so strong was the re-disclosure rule eliminated by the Jessica Grubb’s Legacy Act. If a patient signed a consent so that their treatment provider could share pertinent care records with their insurance — a requirement in order to have insurance pay for treatment — then those records could only be shared with the insurance provider. Now, a patient’s insurance can re-disclose those records in perpetuity for a number of reasons, including for the vague and effectively ubiquitous use of “health care operations.” This likewise applies to anyone to whom a patient has granted consent.

The language of the new law explicitly states that patients have the right to revoke consent at any time. The problem is that patients must know they need to do this, and also, once records have been shared widely enough, it becomes virtually impossible to communicate and enforce that revocation. Privacy proponents worry that this re-disclosure license will deter patients from seeking treatment, and could lead to harm for those who decide to engage anyway.

“Some insurers have discriminated against substance use disorder patients, and substance use disorder patients have not gotten life insurance or other key insurance like that because they found out,” said Deborah Reid, senior health policy attorney with Legal Action Center, emphasizing the fact that discrimination against substance use disorder patients is not a thing of the past, but a very real problem her office deals with regularly. She argued that lessening privacy regulations for these patients is likely to increase the problem. Other examples of potential bad case scenarios resulting from the relaxed consent rules that she and her co-worker Jacqueline Setz provided were child custody cases, information spread through small town communities, and law enforcement gaining access to the records.

The new law includes anti-discrimination language, which proponents like Shatterproof say is a big win. “Certainly the illegal nature of using drugs should never be a barrier to someone accessing emergency help or medical care when they need it. That’s something we should hopefully all be working toward. This legislation is consistent with existing federal protections around the treatment of addiction,” said Kevin Roy, chief public policy officer at Shatterproof. Currently, the Americans with Disabilities Act (ADA) covers discrimination against substances use disorder patients — but only if they are not currently using illegal substances. If a patient is engaged with treatment but struggling to maintain total abstinence or does not seek total abstinence as a goal, they are not protected against discrimination by the ADA. But opponents say that the new anti-discrimination language won’t be enough to offset the dangers caused by allowing this sensitive information to move more freely. “It’s in there, you can’t discriminate, but if you do — who’s gonna be able to enforce that? With no patient first right of action, patients can’t stand up for themselves unless they have resources to retain counsel and sue in civil court,” said Talbott, adding, “even the parts that sound good, upon further reflection and digging, seem to be paper tigers.”

Although those who have been involved in the fight for years were disappointed that these changes were slipped through alongside the unrelated coronavirus stimulus bill, they say the fight isn’t totally over yet.

“We still have initial consent…it didn’t remove the complete foundation of Part 2, but it will be a different struggle now,” said Talbott, explaining some early-stage strategies NAMA-R and other groups are discussing in order to ensure addiction patients can still have robust privacy protections in the future.

Then, with a note of sadness, he added: “The 10 year battle to preserve privacy protections in Part 2 is over.”

“These are people’s lives we are talking about,” summarized Tarino. “There are very deep implications to people losing rights and privileges because of their participation in something that was supposed to help them.”

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