Date22 September 2021
AuthorBonds, Brandan

Table of Contents INTRODUCTION 25 I. BACKGROUND 26 A. What are Hunger and Food Insecurity? 26 B. Food Insecurity During COVID-19 27 C. The Federal Approaches to Food Insecurity 29 1. The CARES Act 30 2. The SNAP Approach 31 3. The Pandemic-EBT Approach 33 II. EXPANDING P-EBT TO MEET THE NEEDS OF ADULTS 34 A. Everyone has a Universal Right to Food 35 B. Broaden Eligibility from Schoolchildren to Adults 36 C. Tie P-EBT Eligibility to Higher Poverty Guideline 37 D. Automatically Enroll Adults and Families 37 who Meet the Poverty Guideline E. Develop a Strategic Communication Plan to 38 Reach Eligible Participants III. BENEFITS & CHALLENGES OF P-EBT EXPANSION 39 A. Benefits of a P-EBT Program for Adults 39 B. Challenges in Administering P-EBT Changes 40 CONCLUSION 42 INTRODUCTION

In the United States, hunger affects millions of people every day because of their inability to pay for food and lack of access to food. (1) According to the United States Department of Agriculture (USDA), in 2019, 35.2 million people lived in food-insecure households. (2) Statically, low-income people face much higher rates of food insecurity than the general population and the situation is particularly dire for poor people of color. (3) This comment will look to a solution for this hungry and somewhat neglected population.

Hunger advocates traditionally focus advocacy efforts on children through the National School Lunch Program (NSLP) (4), the poor through the Supplemental Nutrition Assistance Program (SNAP) (5), and the elderly through Meals on Wheels and SNAP (6). Although Congress grants waivers during national emergencies, some of these programs still may exclude people who do not meet certain eligibility requirements based on employment or income. (7) A solution would require including adults in programs without strings attached and, further, automatically enrolling all adults who may not normally participate in federal assistance programs but experience food insecurity because of national emergencies.

In March 2020, Congress passed the Families First Coronavirus Response Act (FFCRA) creating the Pandemic-EBT program (P-EBT). (8) This program provides "children" who receive free or reduced lunch and are unable to attend school for at least five consecutive days, food assistance for the meals they would receive at school during the COVID-19 pandemic. (9) As Congress revisits this program, they should expand P-EBT to include low-income adults. Under this scheme, adults who are normally ineligible for federal food assistance would automatically qualify for temporary emergency food assistance without needing to meet eligibility criteria of other federal programs. The benefits to such a program would be tremendous. This policy would help move people out of food insecurity, reduce the burden of local organizations who provide food assistance, and increase the overall quality of life during national emergencies.

This comment first defines the problem of food insecurity, provides an overview of food insecurity during the COVID-19 pandemic, and explains the approaches to food insecurity. The second section describes the proposed legislative solution to food insecurity during national emergencies. The third section explores the possible benefits and challenges of expanding the program. Finally, the comment concludes that expanding the P-EBT program to provide for more Americans is a viable way to reduce food insecurity and hunger during national emergencies.


    Like many social policies, hunger policy has many moving parts. This section breaks down that landscape. First, this section defines the terms "hunger" and "food insecurity" as they are used in this comment. The next subsection examines some of the latest data on hunger and food insecurity during the COVID-19 pandemic. Finally, this section briefly describes the existing federal approaches to food insecurity during the COVID-19 pandemic, namely the SNAP and the P-EBT programs.

    1. What are Hunger And Food Insecurity?

      "Food insecurity" has largely replaced "hunger" as the focus of organizing, action, and policy around food access. Thus, it's important to define both terms, what they mean, and how they are measured. In 2006, the USDA introduced new language to describe various ranges of food security in the United States. The USDA separates "food security" into two categories: high food security and marginal food security. (10) The department contrasts "high food security," defined as "no reported indications of food-access problems or limitations" with "marginal food insecurity," defined as, "one or two reported indications--typically of anxiety over food sufficiency or shortage of food in the house. Little or no indication of changes in diets or food intake." (11)

      Similarly, the USDA divides "food insecurity" into two categories: low food security and very low food security. (12) "Low food security" occurs when households "reports [...] reduced quality, variety, or desirability of diet. Little to no indication of reduced food intake.". (13) "Very low food security" refers to reports of multiple indications of disrupted eating patterns and reduced food intake." (14)

      The USDA describes "hunger" as "a potential consequence of food insecurity, that, because of prolonged, involuntary lack of food, results in discomfort, illness, weakness, or pain that goes beyond the usual uneasy sensation." (15) Thus, "'hunger' is an individual-level physiological condition that may result from food insecurity." (16)

      This comment uses both the terms "food insecurity" and "hunger." While "food insecurity" will typically describe the conditions described above as "low food security" and "very low food security," some research referenced may use other definitions and those will be distinguished as appropriate. This comment also uses the term "hunger" as described above, as the prolonged, involuntary lack of food. Because food insecurity usually, but not always, causes hunger, the proposed expansion of P-EBT in this comment only targets food insecurity and the hunger that results from it.

    2. Food Insecurity During COVID-19

      The sharp decline of the economy during the COVID-19 pandemic unsurprisingly led to an increase in the number of new individuals (both adults and children) experiencing or at heightened risk of food insecurity. Unemployment and poverty are two factors that heavily influence food insecurity rates. (17) In 2019, the overall food insecurity rate was the lowest it had been in more than twenty years. (18) The COVID-19 pandemic was the first economic recession in the United States since the Great Recession, which began in 2007. (19) By the end of March 2020, claims for unemployment insurance were at nearly seven million, a record high. (20) The unemployment rate for April rose to 14.7%, illustrating the largest monthly increase and the highest rate of unemployment since the federal government first began collecting such data in 1948. (21) Feeding America, a national hunger relief organization, "estimates that 45 million people (1 in 7), including 15 million children (1 in 5) experienced food insecurity in 2020." (22) The organization projects that figure will reduce to 42 million in 2021. (23)

      Prior to the pandemic, "significant racial disparities in food insecurity existed" and have not diminished. Economic recovery for communities of color, especially Black communities, has been even slower. (24) Feeding America estimates no significant reduction in the number of Black food-insecure individuals and expects food insecurity among Black individuals to continue to remain significantly higher than other races. (25)

      To combat food insecurity during the pandemic, many families relied on local food banks and soup kitchens for daily meals. Ja Nelle Pleasure's family in Kansas City, Kansas knows this all too well. (26)Her family once had a tradition was to spin a globe, put a finger down, and cook a dish from the country where it landed. (27) After the pandemic began and Ms. Pleasure lost her job, the tradition came to an end. (28) Ms. Pleasure's experience with food insecurity, like many, began prior to the pandemic. She suffered a stroke in 2018, which made focusing on her career as an artist increasingly difficult. (29) When her husband left her after her stroke, Ms. Pleasure was left with a single stream of income to feed her three kids, who were then sixteen, fourteen, and ten years old. (30) When she lost her job due to the pandemic, she lost the remaining income she earned as an artist. With schools closed, her kids lost access to meals. (31) Although she received $125 per month through the P-EBT program, that money barely helped feed her three boys, who she says "eat like grown men, like a football team". (32) Like most families struggling to make it through the pandemic, Ms. Pleasure doesn't waste anything; she lines her kitchen counter with jars of pickled vegetables from the garden and stacks her freezer with leftovers. (33) A self-proclaimed "coupon queen," Ms. Pleasure takes advantage of store sales when she can, adding to the stockpile of pantry items lining the walls of her garage. (34) The Pleasure family, unlike many families facing food insecurity, can rely upon their garden for fresh fruits and vegetables. The plot sits on the edge of a community garden near their home where they grow everything from herbs to greens and strawberries. (35) Every day, Ms. Pleasure uses vegetables grown in her garden to cook meals for the families. She claims that it helps saves money because fresh vegetables are expensive at the grocery store. (36) Although Ms. Pleasure takes these steps to provide for her family, it's often not enough. She still visits the local food pantry where her sons used to volunteer for assistance. While there, she told people that she was helping a friend or family member because she was too embarrassed and ashamed to experience food insecurity. (37) The...

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