What to Change: Requirements, Waivers, and Work Supports

The evidence does not point to one universal policy lever. It points to different bottlenecks: some participants may lack a realistic job or qualifying activity, some may need child care or skills, some may face a proof or exemption problem, and some may be affected mainly by the loss of access itself. This chapter compares the available responses by asking what each one changes—opportunity, documentation, or eligibility—and what it leaves unresolved. The aim is not to choose a policy by its caseload effect, but to judge whether it can improve employment without shifting the cost onto people who remain poor and unable to comply.

The comparison also needs a consistent set of outcomes. An expanded requirement, a waiver, and a child-care subsidy do not operate at the same point in the system. They should be compared on employment and earnings, but also on SNAP access, household income and expenses, who remains enrolled, administrative burden, federal spending, and the uncertainty of the evidence.

Match the lever to the bottleneck

An expanded requirement with more employment and training services tries to address a basic weakness in a sanction-only model: people may be required to work without receiving enough help to find or sustain qualifying activity. CBO’s examined SNAP option would extend the work condition to more adults while providing additional employment and training services and case management. CBO expects that this combination would probably raise employment modestly, in part because participants would receive more assistance than many current SNAP recipients do.

But the support does not erase the sanction. Under the option, some people would work more and increase their earnings, while others would fail to comply and lose benefits. CBO therefore expects average income to decline for households affected by the expanded requirement if benefit reductions exceed the earnings gains. The policy could improve the opportunity side for some participants and still worsen access for others. More services make the employment story more plausible; they do not turn a benefit loss into an income gain automatically.

This option also depends on delivery capacity. Case management can refer a participant to a job, training program, or other support, but a referral is not a job. Employment and training slots may be limited, state systems may take time to expand, and local labor markets may not supply enough suitable work. A policy that expands the legal requirement faster than the support infrastructure expands can increase exposure before it increases opportunity.

A waiver addresses a different bottleneck. When local labor demand is weak, a geographic waiver can remove the active time limit rather than trying to force a fixed hours threshold through a market with too few jobs. This protects access for people in the affected area and recognizes that the ability to comply depends partly on conditions outside the participant’s control. It does not, by itself, create employment or improve skills. Its value is defensive: it prevents a work condition from imposing a benefit loss when qualifying opportunities are unusually scarce.