Food Insecurity In The Disability Community: Disparities In SNAP Access

Food insecurity, defined as not having reliable or sufficient access to food, has implications for overall health, as it is associated with increased risk of mortality and additional health care expenditures. In 2019, about 10.5 percent (13.7 million) of households in the United States were food insecure, increasing to 22.0 percent of households in 2020 during the COVID-19 pandemic, suggesting that food insecurity is a rapidly accelerating public health concern.

Households that include people with disabilities are at increased risk of food insecurity. Only 8 percent of households with no disabled adult experience food insecurity, but 22 percent of households with an adult who is a recipient of federal or state disability benefits and 33 percent of households with an adult who has a disability but does not receive benefits are food insecure.

Higher rates of food insecurity may contribute to worse health outcomes among people with any disability because food insecurity is linked to a higher risk of high cholesterol, diabetes, and high blood pressure and poorer quality diets. Importantly, higher rates of food insecurity among adults with a disability may therefore be responsible for their higher rates of chronic conditions, suggesting that food insecurity contributes to disability-based health inequities. These health inequities are partly driven by income inequality between individuals with and without disabilities; the poverty rate is about 26 percent among people with disabilities and only about 11 percent among those without.

The Supplemental Nutrition Assistance Program (SNAP), formerly known as Food Stamps, provides low-income households with monthly money for food. SNAP is one of the largest public benefit programs; almost 40 million people received benefits each month in 2020, of which about 26 percent have a disability. Importantly, there is good evidence that participation in SNAP improves economic well-being and reduces food insecurity. While research examining the specific impact of SNAP on people with disabilities is needed, SNAP participation is associated with less total health care costs, and less hospital and nursing home use—suggesting that the reductions in food insecurity and poverty may broadly translate into health gains for low-income individuals.

Despite the potential benefits of the program, not all people who are eligible for SNAP participate in the program. Although it is estimated that nearly 100 percent of eligible children participate in the program, only 85 percent of eligible adults younger than age 60 and less than half of eligible adults 60 years and older participate. Non-participation is partly due to the cumbersome enrollment process, which is uniquely challenging for individuals with disabilities.

SNAP Enrollment Challenges The Advancement Of Health Equity For People With Disabilities

The SNAP Enrollment Process Is Not Always Accessible For People With Disabilities

The SNAP application, enrollment, and renewal processes are complicated, and the administrative burden on individuals with disabilities can limit access for eligible households. For example, all states have printable applications online, and all but three states now allow individuals to submit applications online, but little attention has been paid to ensuring that all information and downloadable documents are accessible for individuals with visual, physical, or cognitive disabilities. Print notices are often not adapted for individuals with visual impairment, making it very difficult for these individuals to renew their SNAP benefits or report required changes without assistance.

A report from 2018 found that nine states do not have any call centers to provide SNAP enrollment support. This support is essential for individuals with visual impairment, cognitive impairment, and other types of disabilities who may need extra assistance completing forms and navigating the enrollment process. In addition, there has been little attention paid to ensuring that call-center support is universally accessible for individuals with hearing impairments, such as through teletypewriter (TTY) support.

Innovative policy solutions to increasing SNAP access for individuals with disabilities has stalled over the past decade. For example, the Combined Application Project was created to streamline the application process for single Supplemental Security Income (SSI) recipients who are categorically eligible for SNAP because of their low-income status. However, 32 states plus the District of Columbia do not operate this program, and the US Department of Agriculture has not approved new Combined Application Projects in many years. Since 86 percent of SSI recipients have a disability, this represents a lost opportunity to not only facilitate access to SNAP for individuals with disabilities but also to reduce administrative burden for states by eliminating redundancies that occur when enrolling the same person in both programs.

Additionally, broad-based categorical eligibility intends to simplify the SNAP enrollment process by allowing states to increase or eliminate the asset test. (The asset test limits SNAP eligibility to households with the smallest amounts of saved money or vehicle assets.) The broad-based categorical eligibility raises the gross income eligibility limit and/or eliminates the asset test for low-income households; it especially benefits individuals who are older than age 60 or have a disability, who often are more financially reliant on assets because they are unable to work. However, eight states do not use any broad-based categorical eligibility. Given the barrier posed by the asset test and the higher cost of living for households with a disabled individual (discussed further in the next section), more states could use this flexibility to eliminate the asset test for households with disabled members as a way to advance health equity.

SNAP’s Definition Of Disability Excludes Many People With Disabilities

SNAP considers disability status in the determination of program eligibility and benefit amount. However, SNAP uses a narrow definition of disability, which only includes recipients of federal or state disability benefits, including SSI and Social Security disability payments, and is often referred to as “labor-force disability.” Households that include individuals with a labor-force disability are eligible to participate in SNAP based on their net income rather than gross income, thus expanding the income-eligibility cutoff for those with high shelter or medical expenses. This definition of disability excludes people who have disabilities but are not eligible for or have not yet successfully completed the lengthy application process for these federal or state disability benefits. Therefore, SNAP’s determination of disability based on labor-force criteria only creates an inequity.

Households that include members with a disability have a higher cost of living; data from the National Disability Institute indicate that on average, households that include someone with a disability need 28 percent more income, or an additional $17,690 for the US median household income, to achieve the same standard of living as a household of the same size and income where no one has a disability. Extra costs include adaptive resources needed to complete tasks of daily life, such as food preparation or transportation. Yet, the SNAP program only recognizes these extra costs for households that have someone with a labor-force disability, leaving behind all other households that include someone with a disability.

Data from the 2010 Current Population Survey Food Security Supplement indicate that among households that are food insecure and include a person with disabilities who do not fit this labor-force criteria, 8.8 percent are not enrolled in SNAP benefits. This is compared to a 2.0 percent gap in SNAP enrollment for households that include a person with a labor-force disability, and a 4.3 percent gap for households that do not include people with disabilities.

COVID-19 Is Elevating Food Insecurity And May Widen Gaps In SNAP For People With Disabilities

Feeding America estimates that 42 million people, or one in eight Americans, will experience food insecurity in 2021. As a result of this uptick in food insecurity, the March 2020 Families First Coronavirus Response Act authorized emergency increases of household SNAP allotment to the maximum amount per family size. While more than $29 billion in additional benefits have been distributed, 15 percent of households that include someone with a disability were already receiving the maximum benefit and did not receive this increase.

In March 2021, the American Rescue Plan Act was passed, intending to invest an additional $12 billion toward nutritional assistance to address the continued impact of the COVID-19 pandemic. This includes a 15 percent increase in SNAP benefits for all enrollees through September 2021, providing states with an additional $1.135 billion in SNAP administrative resources over the next three years and providing $25 million to expand SNAP online purchasing and develop mobile payment technologies.

These investments in SNAP highlight a long-overdue recognition of the key role that food access plays in achieving health and advancing health equity, but these investments will not reach many individuals with disabilities facing food insecurity without additional policy change. State SNAP agencies should be encouraged to invest new administrative funding to improve access for households facing significant barriers to participation, including individuals with disabilities, and Congress should reconsider SNAP’s narrow definition of disability.

Urgent Action Is Needed To Increase SNAP Access For People With Disabilities

Throughout the COVID-19 pandemic, there has been a sharper focus on identifying and addressing systemic causes of health equity in the United States, and the disability community cannot be left behind. One in four US adults has a disability; this equates to more than 61 million people, making disability the largest minority group in the United States. Urgent action is needed to close this food insecurity gap for people with disabilities. We recommend the following, summarized in exhibit 1:

1. Ensure states make SNAP more accessible. While Americans with Disabilities Act compliance is mandatory, to truly address inequities in the SNAP enrollment for people with disabilities, compliance alone should not be the goalpost. Efforts to partner with the disability community and stakeholders are needed to identify best practices to making SNAP websites, enrollment forms, and physical buildings accessible. Additionally, the process of enrolling in SNAP should be evaluated and flexible options offered, including via call centers with TTY, online, or in-person enrollment.
2. Broaden the definition of disability for SNAP. The SNAP definition of disability should be extended to include a larger proportion of people with disabilities. SNAP’s narrow “labor-force disability” definition creates health inequities by restricting the benefits of this program to only a fraction of the Americans with disabilities who are income-eligible and food insecure.
3. Require all states use broad-based categorical eligibility to eliminate the asset test for individuals with disabilities. Greater consideration should be given to the higher cost of living and need for increased savings among households that include members with a disability because this may be contributing to the disproportionately higher rates of food insecurity for those households. Use of broad-based categorical eligibility to eliminate the asset test for all individuals with disability, regardless of whether they have yet acquired the labor-force disability status, will likely help level the playing field to improve SNAP access and reduce food insecurity.

Efforts to address the food insecurity in the wake of COVID-19 pandemic cannot leave out the disability community. Improved access to public benefits for individuals with disabilities is an essential step in advancing health equity for all Americans.

Exhibit 1: Summary of problems and policy recommendations regarding access to SNAP among people with disabilities

Problems	Policy Recommendation
· Websites and documents are not universally adapted for individuals with visual impairment · Twelve states do not have call centers to assist with SNAP enrollment and renewal for individuals with disabilities who may require assistance navigating the enrollment and renewal processes	1. Ensure states make SNAP more accessible.
· Only 2 percent of food-insecure households that include a person with a labor-force disability do not participate in SNAP, whereas 8.8 percent of food -insecure households that include a person with disability who does not fit the labor-force criteria are not participating in SNAP · The labor-force disability status determination process is long and costly, creating a gap in SNAP access for many people who are unable to work due to their disability and food insecure.	2. Broaden the definition of disability for SNAP.
· Cost of living is 28 percent higher among households that include someone with a disability than those without · Although 86 percent of SSI recipients have a disability, thirty-two states plus DC do not operate the Combined Application Process to streamline the SNAP enrollment process for individuals receiving SSI	3. Require all states use broad-based categorical eligibility to eliminate the asset test and increase the gross income limit for individuals with disabilities.

Source: Authors’ analysis.