Oppose Time Limits On Food Benefits

Hunger doesn’t watch a clock

“Human beings are created ‘in God’s image’ (Genesis 1:27) as social beings whose dignity, worth, and value are conferred by God. Although our identity does not depend on what we do, through our work we should be able to express this God-given dignity as persons of integrity, worth, and meaning. Yet work does not constitute the whole of our life. When we are viewed and treated only as workers, we tend to be exploited.”

– ELCA social statement: “Sufficient, Sustainable Living for All”

The Department of Agriculture (USDA) has proposed a Supplemental Nutrition Assistance Program (SNAP) rule that would put time limits on food benefits for unemployed and underemployed people who can’t document a designated number of weekly work hours or job training. People who cannot meet the documentation requirement would lose SNAP eligibility after three months regardless of how hard they are trying to find work or advance job skills.

Experiences in the wide network of World Hunger ministries of the ELCA teach us that lifting oneself out of poverty is both a dignified longing and hard work. Time limits complicate rather than facilitate that goal.

The proposed rule would adversely impact neighbors with circumstances like these:

  • Stringing together minimum-wage, part-time jobs may not put healthy food on the table. A job training course holds more promise for a living wage but taking time to pursue it could jeopardize vital SNAP support and the health and welfare of the individuals who qualify for food assistance.
  • Available work can come with significant stability challenges, such as schedules being posted weekly with varied hours and shifts, putting continuing education options and better job searches out of reach. The requirement of SNAP time limits pushes those struggling deeper into a cycle of insecurity.
  • Rural realities can hamper efforts to move out of impoverishment. Available work may not match up with transportation options and commute distances. Time limits may deprive a hungry person of modest SNAP benefits that would help them focus on their future and not their next meal.

Register your opposition to the Proposed Rule by the USDA Food and Nutrition Service (FNS) by making a public comment before April 2, 2019 on "Requirements for Able-Bodied Adults Without Dependents."   

Reasons to oppose the rule: 

  • Sidesteps Congress, which rejected these changes when it enacted the 2018 Farm Bill.
  • Causes serious harm to individuals who cannot afford to lose benefits on which they rely for daily bread.
  • Does not improve the health outcomes or employment outlook of those impacted by the proposed rule.
  • Harms grocery retailers and agricultural producers by reducing the amount of SNAP dollars available to spur local economic activity.

How you can help!

Submit a comment that shows your opposition to this rule. (Note: submitted comments are public). The comment below contains several key points raised by faith-based advocacy groups. But most important is sharing YOUR PERSONAL MESSAGE. Adapt the comment below to reflect your views, but please DO NOT SEND without personalizing.

  • Speak out against the SNAP draft rule at a town hall meeting hosted by your senator or representative.
  •  Read the ELCA’s Social Statement on economic life: Sufficient, Sustainable Livelihood for All.
  • Read a Research Brief from our partners at the Food Research & Action Center (FRAC) and a SNAP Fact Sheet from Bread for the World.
  •  Sign up for ELCA Advocacy Action Alerts from elca.org/advocacy/signup to receive the most up-to-date information on the SNAP rules.




  • United States Department of Agriculture


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