On January 10, the Ohio Department of Job and Family Services (ODJFS) submitted a request to the United States Department of Agriculture (USDA) to update its Supplemental Nutrition Assistance Program (SNAP) work requirement waiver. The number of counties in Ohio that would be exempt from the work requirements would drop from 42 to 13 and the rule would also have a disproportionate impact on African-American Ohioans.
The rule change would impact more than 390,000 Ohioans previously exempt from the rule, and 20,000 Ohioans would lose benefits completely
As we have written about previously, current federal policy requires all able-bodied adults without dependent children (ABAWDs) to work or participate in job training for at least 80 hours each month in order to maintain their food assistance for more than three months in a 36-month time period. Ohio, as is the case with nearly all states, applies to “waive” this time limit for counties that meet the USDA’s criteria for “areas of high unemployment,” which has typically included counties with unemployment rates 20 percent higher than the U.S. average. On December 5, 2019, the Trump administration finalized a rule which would significantly reduce the number of counties for which this waiver would apply. In an analysis we conducted in March, the rule would reduce the number of counties exempt from these requirements to three (down from 42). In this latest application by the state, the exempt counties would go from 42 to 13.
It’s important to understand the impact of this potential change. First, the latest state caseload summary indicates that the rule change would impact more than 390,000 Ohioans previously exempt from the rule, and 20,000 Ohioans would lose benefits completely. And while this SNAP change is important to understand what impact the rule will have on food assistance, an overlooked impact may be how it affects access to health care in Medicaid.
Guidance from the Centers for Medicare and Medicaid (CMS) says that SNAP county exemptions must be mirrored in state applications for Medicaid work-requirement waivers. With this new application, the number of individuals exempt by county-based standards will be reduced by 91 percent – which would affect more than 286,000 Medicaid-expansion enrollees. This is nearly half of all enrollees in the Medicaid expansion population. As with SNAP, this does not mean all expansion enrollees will have to meet the work requirement, but it does mean that some other qualifying exemption will have to apply, potentially complicating the Medicaid eligibility process in the 29 counties now no longer exempt.
Recently, one of the state’s managed care plans, Paramount, ceased coverage in Southeast Ohio due in part to decreases in enrollment tied to the Medicaid expansion population. While many Appalachian counties will maintain their SNAP work-requirement exemption and, subsequently, Medicaid, many others will now require their expansion population to formally participate in work requirements, which has been shown to decrease enrollment. As a result, it’s reasonable to expect that this change, once implemented, will further Ohio’s managed care program’s challenges in that region, potentially compromising access to care and the financial stability of rural providers. This is a particularly troubling issue given the recent research suggesting that the Ohio Valley had the highest jumps in mortality rates in the United States.
A few weeks ago, Joe Burrow, Quarterback for Louisiana State University accepted the Heisman trophy and highlighted Athens County’s food insecurity stating, “I’m up here for all those kids in Athens and Athens County that go home to not a lot of food on the table, hungry after school.” And while the community and the nation responded through generous charitable donations to the local food pantry, Athens County now no longer has these waiver protections afforded more families are at risk.
| County | Under New SNAP Rule | Number of enrolled in the Medicaid expansion |
|---|---|---|
| Adams | Exemption Maintained | 2024 |
| Ashtabula | Not Exempt | 6445 |
| Athens | Not Exempt | 3421 |
| Belmont | Not Exempt | 3324 |
| Brown | Not Exempt | 2608 |
| Carroll | Not Exempt | 1193 |
| Clinton | Not Exempt | 2276 |
| Columbiana | Not Exempt | 5816 |
| Coshocton | Exemption Maintained | 2269 |
| Crawford | Not Exempt | 2495 |
| Cuyahoga | Not Exempt | 86921 |
| Erie | Not Exempt | 3665 |
| Gallia | Exemption Maintained | 2030 |
| Guernsey | Not Exempt | 2486 |
| Harrison | Not Exempt | 858 |
| Henry | Not Exempt | 783 |
| Highland | Not Exempt | 2719 |
| Hocking | Not Exempt | 1723 |
| Huron | Not Exempt | 2929 |
| Jackson | Exemption Maintained | 2240 |
| Jefferson | Exemption Maintained | 5040 |
| Lake | Not Exempt | 7622 |
| Lawrence | Not Exempt | 4328 |
| Lorain | Not Exempt | 13015 |
| Lucas | Not Exempt | 27126 |
| Mahoning | Not Exempt | 17543 |
| Meigs | Exemption Maintained | 1614 |
| Monroe | Exemption Maintained | 774 |
| Morgan | Exemption Maintained | 909 |
| Muskingham | Not Exempt | 5933 |
| Noble | Exemption Maintained | 632 |
| Ottawa | Exemption Maintained | 1634 |
| Perry | Not Exempt | 2198 |
| Pike | Exemption Maintained | 2209 |
| Richland | Not Exempt | 6499 |
| Ross | Not Exempt | 5499 |
| Scioto | Exemption Maintained | 5962 |
| Stark | Not Exempt | 18649 |
| Summit | Not Exempt | 31813 |
| Trumbull | Not Exempt | 13259 |
| Vinton | Exemption Maintained | 870 |
| Washington | Not Exempt | 2916 |
| Potentially Eligible | 286062 | |
| Percentage Increase | 0.91 |