Reduce the premium subsidy rate for crop insurance.

On average, taxpayers cover about 60 percent47 of the premium cost for policies purchased in the federal crop insurance program. One of the most widely supported and bipartisan policy reforms is to reduce the premium subsidy that taxpayers are forced to pay.48 At a minimum, taxpayers should not pay more than 50 percent of the premium. After all, taxpayers should not have to pay more than the farmers who benefit from the crop insurance policies.

must demand a genuine reform process and express unwavering support for a USDA that shapes a safety net that considers the interests of farmers, while also remembering the interests of taxpayers and consumers. Any safety net for farmers should be a true safety net—one that helps farmers when they have experienced serious unforeseen losses (preferably when there has been a disaster or unforeseen natural event causing damage) and that exists to help them in unusual situations.

Separate the agricultural provisions of the farm bill from the nutrition provisions. To have genuine reform and proper consideration of the issues, agricultural programs should be considered in separate legislation distinct from food stamps and the nutrition part of the farm bill, and reauthorization of such programs should be fixed on different timelines to ensure this separation. Agricultural and nutritional programs, which are distinct from each other, have been combined together for political reasons, something which is readily admitted by proponents of this logrolling. When it comes to American agriculture and welfare programs, they deserve sound policy debates, not political tactics at the expense of thoughtful discourse. Move the Work of the Food and Nutrition Service.

The USDA implements many means-tested federal support programs, including the largest food assis- tance program, Supplemental Nutrition Assistance Program (SNAP, also known as food stamps), and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Food Program. The Food and Nutrition Service (FNS) oversees these programs and other food and nutrition programs, including the Center for Nutrition Policy and Promotion,52 which handles the USDA’s work on the “Dietary Guidelines for Americans” (Dietary Guidelines).53 Food nutrition programs include: SNAP; WIC; the National School Lunch Program (NSLP); the School Breakfast Program (SBP); the Child and Adult Care Food Program; the Nutrition Program for the Elderly; Nutrition Service Incentives; the Summer Food Service Program; the Commodity Supplemental Food Program; the Temporary Emergency Food Program; the Farmer’s Market Nutrition Program; and the Spe- cial Milk Program.

The next Administration should:

Move the USDA food and nutrition programs to the Department of Health and Human Services. There are more than 89 current means- tested welfare programs, and total means-tested spending has been estimated to surpass $1.2 trillion between federal and state resources.54 Because means-tested federal programs are siloed and administered in separate agencies, the effectiveness and size of the welfare state remains largely hidden. There are means-tested food-support programs in the USDA (specially FNS), whereas most means-tested programs are at the Department of Health and Human Services (HHS). All means-tested anti-poverty programs should be overseen by one department—specifically HHS, which handles most welfare programs.

Reform SNAP. Ostensibly, SNAP sends money through electronic-bene- fit-transfer (EBT) cards to help “low-income” individuals buy food. It is the largest of the federal nutrition programs. Food stamps are designed to be supplemented by other forms of income—whether through paid employment or nonprofit support. SNAP serves 41.1 million individuals—an increase of 4.3 million people during the Biden years.55 In 2020, the food stamp program cost $79.1 billion. That number continued to rise—by 2022, outlays hit $119.5 billion.56

The next Administration should:

Re-implement work requirements. The statutory language covering food stamps allows states to waive work requirements that otherwise apply to work-capable individuals—that is, adult beneficiaries between the ages 18 and 50 who are not disabled and do not have any children or other dependents in the home.57

Even in a strong economy, work expectations are fairly limited: Individuals who are work-capable and without dependents are required to work or prepare for work for 20 hours per week.58 The work requirements are then implemented unless the state requests a waiver from the USDA’s Food and Nutrition Services.59 Waivers from statutory work requirements can be approved in two instances: an unemployment rate of more than 10 percent or a lack of sufficient jobs.60

The Trump Administration bolstered USDA work expectations in the food stamp program. In February 2019, FNS issued a modest regulatory change that applied only to able-bodied individuals without dependents— beneficiaries aged 18 to 49, not elderly or disabled, who did not have children or other dependents in the home (ABAWD).61 The FNS rule changed when a state could receive a waiver from implementing the ABAWD work requirement.

Under the new rule, in order to waive the work requirement, the state’s unemployment rate had to be above 6 percent for more than 24 months. The rule also defined “area” in such a way that states would be unable to combine non-contiguous counties in order to maximize their waivers.62 Of

the more than 40 million food stamp beneficiaries, the Trump rule would have applied only to 688,000 individuals in fiscal year 2021.63 The Trump reform was scheduled to go into effect, but a D.C. district court federal judge enjoined the rule.64 The USDA filed an appeal in late December 2020,65 but the Biden Administration withdrew from defending the challenge, and the rule was never implemented.66

Beyond the able-bodied work requirement, FNS should implement better regulation to clarify options for states to implement the general work requirement. This requirement is an option states can apply to work- capable beneficiaries aged 16 to 59. If beneficiaries’ work hours are below 30 hours a week, states can implement the general work requirements to oblige beneficiaries to register for work or participate in SNAP Employment and Training or workfare assigned by the state SNAP agency.67 Increased clarity for states would include items like states being required to offer employment and training spots for those that request them—not simply budgeting for every currently enrolled able-bodied adult.

Reform broad-based categorical eligibility. Federal law permits states to enroll individuals in food stamps if they receive a benefit from another program, such as the Temporary Assistance for Needy Families (TANF) program. However, under an administrative option in TANF called broad- based categorical eligibility (BBCE), ”benefit” is defined so broadly that it includes simply receiving distributed pamphlets and 1–800 numbers.68 This definition, with its low threshold to trigger a “benefit,” allows individuals to bypass eligibility limits—particularly the asset requirement (how much the applicant has in resources, such as bank accounts or property).69 Adopting the BBCE option has even allowed millionaires to enroll in the food stamp program.70

The Trump Administration proposed to close the loophole with a rule to “increase program integrity and reduce fraud, waste, and abuse.”71 The regulation was not finalized before the end of the Trump Administration.

Re-evaluate the Thrifty Food Plan. In a dramatic overreach, the Biden Administration unilaterally increased food stamp benefits by at least 23 percent in October 2021.72 Through an update to the Thrifty Food Plan, in which the USDA analyzes a basket of foods intended to provide a nutritious diet, the USDA increased food stamp outlays by between $250 billion and $300 billion over 10 years.73

Although the 2018 farm bill instructed FNS to update the Thrifty Food Plan by 2023 and every five years thereafter, every previous Thrifty Food Plan has been always cost-neutral ( just an inflation update)—exactly what CBO estimated as cost of the 2018 farm bill.74

The Biden Administration may have skirted regulations and congressional authority to increase the overall cost of the program. In fact, Senate and House Republicans requested that the Government Accountability Office investigate the legal authorities and process that the USDA undertook to arrive at such an unprecedented increase.75

Eliminate the heat-and-eat loophole. States can artificially boost a household’s food stamp benefit by using the heat-and-eat loophole. The amount of food stamps a household receives is based on its “countable” income (income minus certain deductions). Households that receive benefits from the Low-Income Heat and Energy Assistance Program (LIHEAP) are eligible for a larger utility deduction. In order to make households eligible for the higher deduction, and thus for greater food stamp benefits, states have distributed LIHEAP checks for amounts as small as $1 to food stamp recipients.

The 2014 farm bill tightened this loophole by requiring that a household must receive more than $20 annually in LIHEAP payments to be eligible for the larger utility deduction and subsequently higher food stamp benefits.76 Nonetheless, states continue to inflate their standard utility allowances. Under the Trump Administration, the USDA proposed a rule, which was not finalized, that would have standardized the utility allowance.77 Reform WIC. Turning to WIC, this program distributes money through EBT cards to help low-income women, infants, and children under six purchase nutri- tion-rich foods and nutrition education (including breastfeeding support). As of August 2022, approximately 6.3 million people participated in WIC each month to purchase food.78 In 2021, WIC federal outlays were $5 billion.79 The next Administration should:

Reform the state voucher system. State agencies control WIC costs by approving only one brand of infant formula through competitive bidding for infant formula rebate contracts. Because 50 percent of baby formula is purchased through the federal WIC program, it is vital that regulation for these competitive bidding contracts does not unintentionally create monopolies.

Re-evaluate excessive regulation. As for baby formula regulations generally, labeling regulations and regulations that unnecessarily delay the manufacture and sale of baby formula should be re-evaluated.80 During the Biden Administration, there have been devastating baby formula shortages.