The Safety Maze: Inconsistent and Unpredictable Rules in the Public Benefits System

Last week at the National Anti-Hunger Policy Conference, I attended a roundtable about SNAP outreach to veterans and military families. Over the past few years, SNAP sales at commissaries have grown considerably. At the same time, the 2008 Farm Bill permanently excluded combat pay from service members’ countable income for SNAP purposes. It’s clear that there is growing recognition that military members and their families are vulnerable to hunger. Nevertheless, certain policies serve as barriers to access by this population—specifically, the allocation of the Base Allowance for Housing (“BAH”) to income. And in many ways, the policy is emblematic of larger gaps in equity and transparency in the public benefits system. 

Many military families who would otherwise qualify for SNAP benefits are found ineligible because of the BAH. For purposes of SNAP eligibility, the BAH is treated as countable income, despite the fact that it commonly goes directly to the recipient’s landlord. By contrast, military families who live in base housing are not required to include the value of their housing as income. Military members have the option of participating in an alternative food assistance program, the Family Subsistence Supplemental Allowance (“FSSA”), which was created specifically to prevent significant military participation in SNAP (and the resulting public outcry). However, it’s even more difficult to be eligible for FSSA than SNAP because all income is counted, including the value of base housing and military bonuses. Furthermore, service members must apply for the FSSA through their commanders, which often operates as an additional deterrent due to the shame involved in admitting one’s family is going hungry, particularly in the proud military culture.

This policy serves as but one example of how receipt of one government benefit may offset or preclude another. This in turn relates to the larger issue of the complex set of decisions that navigating the public benefits system often requires. For participants in this system, the financial consequences of any particular decision—such as enrolling in a new program or starting a new job—are rarely intuitive.

Furthermore, the BAH income rule reveals how incongruence in policy often contributes to inequitable outcomes. For example, Section 8 housing vouchers are generally treated as excluded unearned income for the purposes of determining TANF or SNAP eligibility. Yet for military families whose incomes would qualify them for SNAP without their government housing subsidy, the BAH tips the scales and renders the household ineligible. Thus, as elsewhere in the public benefits system, similarly situated families—in this case, those with low incomes and receiving government housing assistance—are subject to different rules and varying levels of access. The result is an inequitable distribution of benefits and general frustration with accessing services.

The variation among what different states count as resources for the sake of their asset tests further illustrates these types of inconsistencies. For example, Virginia has eliminated its TANF asset test, while its neighbor North Carolina only excludes vehicles, retirement accounts, burial and life insurance, EITC refunds, and income-producing property. These types of disparities result in not only inequity, but also a high prevalence of misinformation that deters saving even in states that have eliminated or substantially liberalized their asset tests. As documented in a prior NAF publication, even though there is no TANF asset test in Virginia, the presence of such a test in Maryland deters Virginia residents from saving or even maintaining bank accounts. In other words, asset rules are not intuitive, and the lack of predictability discourages both applying for benefits and saving money.

A truly effective safety net would offer the same level of support to those with the same level of need. It would also provide participants with a reasonable basis to feel confident in the system. Unpredictable and inconsistent rules pose a barrier to both of these goals. With respect to the asset tests, one response would be to eliminate the tests altogether, particularly since the vast majority of families applying for benefits don’t come close to the asset limit in the first place. Alternatively, asset limits could be standardized across programs and states. For a more thorough exploration of these types of interventions please click here.


Aleta Sprague is a program fellow with the Family-Centered Social Policy program at New America. Sprague's work focuses on promoting financial inclusion in public assistance programs. She is a member of the California and New York state bars and currently works as a Legal Analyst at the WORLD Policy Analysis Center at UCLA.