The interview requirement is a particular barrier for college students with low incomes, a group that already struggles with high levels of food insecurity and difficulty accessing SNAP benefits. As Congress has affirmed, one of the stated purposes of SNAP is to “assist low-income adults in obtaining employment and increasing their earnings,” the same goal which inspires many college students and underlies the federal investment in higher education.
In the most comprehensive study of SNAP applications, 31% of all applications were denied because of a missed interview, while only 6% were denied because of substantive ineligibility. This disparity suggests that the interview requirement is more likely to result in the denial of benefits based on a procedural technicality than it is to identify applicants who are substantively ineligible for benefits. It was also found that 40% of students were denied because of a missed interview, an even greater rate than the 31% rate for the general population.
Section 553(e) Rulemaking Petition To Remove the SNAP Interview Requirement
In December 2023, Student Defense (alongside the Hope Center at Temple University, the Center for Law and Social Policy, the Institute for College Access & Success, the California Student Aid Commission, California Competes: Higher Education for a Strong Economy, and Higher Learning Advocates), submitted a Petition pursuant to 5 U.S.C. § 553(e) and 7 C.F.R. § 1.28 to request that the Department of Agriculture promptly amend its regulations to remove the requirement for an interview in the certification of eligibility for applicants to SNAP.
Student Defense’s petition submitted in December of 2023 can be found here.
The press release published after submitting that petition can be found here.
In January 2024, nearly two dozen advocacy organizations joined Student Defense — along with the Center for Law and Social Policy, the California Student Aid Commission, California Competes, the Hope Center at Temple University, the Institute for College Access & Success, and Higher Learning Advocates — in asking the U.S. Department of Agriculture to remove the interview requirement for Supplemental Nutrition Assistance Program (SNAP) applicants to receive benefits.
The coalition letter from January 2024 can be found here.
Following the Rulemaking Petition, USDA Announced an Evaluation of the Interview Requirement
In April of 2024, the Food and Nutrition Service (FNS) and USDA invited the general public and other public agencies to comment on the proposed information collection for the contract of the study titled “Evaluating the Interview Requirement for SNAP Certification.”
In June 2024, Student Defense submitted a comment in response to the Federal Register Notice, encouraging FNS and USDA to:
- Consider a variety of applicants and participants, including students enrolled in higher education;
- Interview state SNAP administrators and staff to determine what lessons can be learned from the natural experiment of the pandemic;
- Consider the particular costs and benefits of recertification interviews; and
- Consult with state agency staff members, SNAP participants, and SNAP applicants about how to create an interview structure that would better meet the needs of SNAP participants.