In a recent report, The Center for Community Solutions presented data that illustrates how rural Appalachian counties, which are predominately made up of white families, disproportionately benefit from Ohio’s waiver of work requirements for the Supplemental Nutrition Assistance Program (SNAP, formerly “food stamps”). When looking at the 26 counties where able-bodied childless adults were granted exemptions from SNAP work requirements:

• Families in the exempt counties were 97 percent white.
• 95 percent of Ohio’s African American families lived in counties where the work requirements were in effect.[1]

Monday, Community Solutions learned that the Ohio Department of Job and Family Services (ODJFS) has updated the number of exempt counties for Federal Fiscal Year 2019 (Oct. 1, 2018 – Sep. 30, 2019), extending the work requirement exemption to a total of 38 counties. Importantly, two of the newly exempt counties, Cuyahoga and Lucas, are urban counties encompassing the cities of Cleveland and Toledo. These two counties are home to a sizable portion of the state’s racial minority families, meaning this change helps to mitigate the disparate impact of SNAP work requirements on low-income African-Americans. Before to October 1, 2018, only 5 percent of Ohio’s African-American families lived in a county where the work requirement was waived. Now, about 41 percent live in an exempt county, according to the most recent five-year census estimates.

This new distribution of exemptions appears to effectively reduce racial disparities in the populations living below the federal poverty level. As of October 1, the percentages of families living below poverty who are located in an exempt county are:

• 42 percent white families
• 43 percent African-American families

These figures appear to show that work requirement exemptions are now evenly reaching both white and black families where they are likely to experience poverty.

The expansion in counties exempt from the work requirement does not represent a real change in policy.

Policy Implications Moving Forward

While this apparent reduction in racial disparities in SNAP eligibility is a positive step, it is important to note that the expansion in counties exempt from the work requirement does not represent a real change in policy. The exemption is still granted on the basis of county unemployment rates relative to the U.S. average. In order to qualify for the exemption, counties must have unemployment rates higher than 120 percent of national unemployment over a recent 24-month period, as measured by the Bureau of Labor Statistics (BLS). These rates fluctuate year-to-year, meaning urban areas like Cleveland, where city-wide unemployment is consistently high, cannot be certain of their exempt status in the coming years because the broader county unemployment rates are not as stark.

Cuyahoga County appears to just barely meet the threshold for exemption.

In fact, when looking at BLS estimates for the most recent 24-month period available, Cuyahoga County appears to just barely meet the threshold for exemption, 120 percent of the national unemployment rate. Cuyahoga County’s unemployment rate of 5.66 percent puts it at 132 percent of the national rate (4.3 percent). The county’s 24-month unemployment rate is virtually unchanged from a year ago, when it was 5.63 percent. But last year, this number represented 118 percent of the national average – just under the threshold for exemption. In other words, the current criteria for exemption means Cuyahoga County may continue fluctuating between exempt and not exempt from year to year. But if the exemption were granted at the municipal level, rather than the county level, Cleveland would likely be much more secure in its exempt status. Cleveland’s average unemployment for the past 24 months, according to BLS, was about 7.10 percent, or 165 percent of the national average – safely above the threshold.

What Does this Change Mean for Medicaid?

Ohio is one of several states considering implementing work requirements for its Medicaid expansion population through the use of an 1115 waiver. As we noted in our public comment to the Centers for Medicare and Medicaid Services, the exemption process would have a disproportionate impact on enrollees, potentially raising some civil rights concerns associated with the proposal.

Specifically, Ohio’s application, consistent with federal guidance, would align these work requirements with those of the SNAP program. At that time, residents in the 26 exempted counties would not have to comply with the requirement. Outside of foregoing the waiver altogether, Community Solutions recommended that this level of exemption be changed to a municipal level to minimize this disparate impact.

First, the number of individuals who would be exempt increases from 100,000 (16 percent of the expansion population) to nearly 270,000 (40 percent). Lucas and Cuyahoga counties represent 72 percent of this change.

It’s important to note that this change, while positive, still means 380,000 Ohioans are subject to the work requirement. What’s more, given the size of this change, it’s important to recognize this shift is temporary and depends on policy decisions around SNAP moving forward – an issue which would not exist at all without a waiver.

[1] American Community Survey Five-Year Estimates, 2012-2016