In this week’s Field Report, the conservative playbook proposes sweeping changes to the USDA that would impact both SNAP and WIC. Plus, California considers banning food dyes in school food, and Kamala Harris aims to stop grocery-store price gouging.
August 28, 2024
A sign alerting customers about SNAP benefits is displayed at a Brooklyn grocery store on December 5, 2019 in New York City. Earlier that week, the Trump administration announced stricter requirements for SNAP benefits that would have cut support for nearly 700,000 poor Americans. (Photo by Scott Heins/Getty Images)
Project 2025, the right-wing playbook for the executive branch, has gained feverish political attention in recent weeks as a central talking point of Vice President Kamala Harris’ presidential campaign and many speakers at the Democratic National Convention. The sweeping, 920-page document calls for drastic overhauls of federal agencies as well as the erosion of civil rights and the expansion of presidential powers. It’s an agenda many have described as authoritarian.
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While the ultraconservative vision has received much scrutiny, its proposal to sharply cut the federal nutrition safety net—and the devastating impacts this could have on food security and hunger—has largely flown under the radar. These plans are detailed in the project’s chapter on the U.S. Department of Agriculture (USDA), which calls for drastically narrowing the scope of the agency to primarily focus on agricultural programs. This would involve radically restructuring the USDA by moving its food and nutritional assistance programs to the Department of Health and Human Services (HHS).
“Proposing to reduce benefits to millions of people who are counting on food assistance for their basic well-being is alarming.”
Criticizing the USDA as “a major welfare agency,” the agenda takes issue with the agency’s long-standing nutrition programs that help feed millions of low-income Americans every year, including pregnant women, infants, and K-12 school children. It outlines policies that would substantially cut the Supplemental Nutrition Assistance Program (SNAP), formerly known as food stamps, and the Supplemental Nutrition Program for Women, Infants, and Children (WIC). It would also shrink federal support for universal school meal programs.
“We have really effective federal food assistance programs that are evidence-based, and there’s just a long history of seeking to continuously improve them,” said Stacy Dean, the former deputy undersecretary for food, nutrition, and consumer services at the USDA under the Biden administration. Project 2025’s plan would reverse that trajectory. “Proposing to reduce benefits to millions of people who are counting on food assistance for their basic well-being is alarming,” she said.
The proposal to restructure the USDA builds on a previous Trump-era proposal to consolidate federal safety net programs. This included moving SNAP and WIC–which it rebranded as welfare programs, a term often used pejoratively–from the USDA to HSS. It’s a move that experts pointed out would likely make these programs easier to cut, including by designating them as welfare benefits, often deemed unnecessary by conservatives.
“I think the effect would be to make [nutritional programs] more vulnerable to a kind of annual politics on Health and Human Services issues,” said Shawn Fremstad, a senior advisor at the Center for Economic and Policy Research, who researches food assistance programs. He notes that the level of vulnerability would partially depend on whether these programs are mandatory or discretionary spending programs in HHS.
As Project 2025 has gained scrutiny, Trump has publicly distanced himself from the proposal. The project was assembled and published by the Heritage Foundation, a think tank that has long helped set the conservative agenda and informed previous Trump policies. For instance, Trump’s 2018 proposal to restructure the federal government and move nutritional programs to the HHS was originally proposed by the Heritage Foundation.
Many of the policies in Project 2025’s USDA chapter are a continuation of the Trump’s administration’s previous efforts to dismantle the federal nutrition safety net. This agenda stands in sharp contrast to Robert F. Kennedy, Jr.’s recent endorsement of Trump as a president who will “make American healthy again.” Instead, as Trump’s former administration assumed its duties, guided by a transition team that included 70 former Heritage Foundation officials, it repeatedly targeted food and nutritional programs without any sign of changing this policy directive.
This agenda includes another conservative policy goal that was pushed for by the previous Trump administration and has been gaining traction on a state level: imposing stricter work requirements as a condition for receiving SNAP benefits. The plan references a Trump-era rule—which was challenged in court and abandoned—that would make it more difficult for states to waive SNAP’s work requirement for able-bodied adults without young children in regions of the country with high unemployment rates or a lack of jobs.
While Project 2025 doesn’t specify how it would tighten work requirements, re-introducing the Trump-era rule is one avenue alluded to in its agenda. The USDA estimated that this rule would have forced 688,000 recipients, unable to meet the work requirement of at least 80 hours per month, to leave the federal assistance program. It’s a rule that experts have pointed out can be challenging for gig workers with inconsistent schedules, people with undocumented health conditions, and people simply struggling to find work.
“You’re taking a vulnerable group of people, and you’re removing their one critical access point to food, which is SNAP,” said Dean. The group of adults affected by this policy “might be unemployed, temporarily unemployed, or they might be in jobs where the hours fluctuate dramatically, or they might have medical conditions that make it harder for them to work but not access to health care to document their health condition,” she added.
The tightening of SNAP work requirements is often proposed under the assumption that receiving SNAP benefits disincentivizes work, but this isn’t supported by existing academic research.
“These rules basically penalize people who are in need of food assistance for no economic gain,” said Pia Chaparro, a public health nutritionist and researcher at the University of Washington who has studied the program. “Research shows that SNAP participation reduces food insecurity but does not act as a disincentive to work. Moreover, research shows that the work requirements don’t lead to increased employment.”
The amount of supplemental assistance people receive on SNAP can stretch a food budget, but isn’t enough to disincentivize working, noted Ed Bolen, the director of SNAP state strategies at the Center on Budget and Policy Priorities (CBPP), a progressive think tank. “The theory is that if you get $6.20 a day in SNAP, you’re not looking for work enough or not working enough hours. But $6.20 a day, it’s not going to pay your rent,” he said.
The Trump-era rule was struck down in 2020 by U.S. District Judge Beryl Howell, who determined that it “radically and abruptly alters decades of regulatory practice, leaving states scrambling and exponentially increasing food insecurity for tens of thousands of Americans.”
Since the rule was blocked, employment levels have improved, but food insecurity has not. In fact, the USDA found that levels of household food insecurity soared to nearly 13 percent in 2022, exceeding both 2021 and 2020 levels. This has been attributed to both inflation and the end of pandemic food assistance. In 2022, 44 million people lived in homes without enough food, including 7.3 million children.
“I see these [proposals] as really doing a lot of harm to working-class communities, rural communities, urban communities alike.”
The proposal to tighten SNAP work requirements is one of many that would collectively chip away at federal food assistance programs that have supported low-income Americans for decades. It would also eliminate some of the streamlined processes that allow participants in other social benefit programs to more easily receive SNAP benefits, including a cash-assistance program for low-income families and a program that helps low-income households with the often steep costs of energy bills.
The plan also calls for reforming the voucher program for infant formula under WIC, which provides nutritional benefits to pregnant and postpartum women, infants, and children under 6 years old. Currently, states award contracts to whichever infant formula manufacturer offers the lowest net cost in a competitive bidding process. Project 2025 proposes to regulate this process (though it doesn’t specify how), claiming it’s driving monopolies in the marketplace. At the same time, the plan calls for weakening regulations on infant formula labeling and manufacturing to, in theory, prevent shortages.
“Upending this process could result in a funding shortfall, jeopardize access to WIC for millions of parents, infants, and young children, and result in higher formula prices for all consumers,” said Katie Bergh, a senior policy analyst at the CBBP. “WIC’s competitive bidding process for infant formula saves the program between $1 billion and $2 billion each year.”
Bergh pointed to a recent report from the National Academies of Sciences on supply chain disruptions in the U.S. infant formula market. It concluded that the “competitive bidding process is not the driver of industry concentration at the national level,” while also finding that eliminating the program would lead to higher WIC costs and higher formula costs for all consumers.
In yet another cut to food assistance for children, Project 2025 would also threaten the future of some universal school meal programs. This plan specifically calls to eliminate the Community Eligibility Provision, which was established in 2010 to allow schools in districts with high poverty levels to provide free meals for all students. This provision is widely used across all 50 states, providing over 19.9 million school children with free breakfast and lunch. The alternative, used in schools without CEP or another universal meal program, is to individually assess each student’s eligibility for free meal tickets.
Fremstad, of the Center for Economic and Policy Research, points to how CEP reduces the stigma of students being sorted into a different lunch line based on their family’s income, which can be a source of shame and behavioral issues. It also removes the penalties that low-income parents face when they can’t provide their child with money for school meals.
“We have a situation where there literally is something called ‘school lunch debt collection,’ where some schools have been sending debt collectors after very low-income parents to pay for their [child’s] lunch,” he said. It’s one of the many nutrition program cuts in Project 2025 that would further hurt working families, he continued.
“I see these [proposals] as really doing a lot of harm to working-class communities, rural communities, urban communities alike,” said Fremstad. “And I also see them as bad for middle-class people, who are often insecure in the middle class themselves.”
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