April 3, 2012

The Supplemental Nutrition Assistance Program and Recent Exceptions for Prepared Foods

Sarah Rodman, MPH

Sarah Rodman, MPH

CLF-Lerner Fellow

Center for a Livable Future

This story by Sarah Rodman and Lainie Rutkow has been cross-posted from Corporations and Health Watch.

In August 2011, the Rhode Island Department of Human Services launched a pilot program in the Providence area that allows some elderly, homeless, and disabled households to buy “hot prepared meals” using Supplemental Nutrition Assistance Program (SNAP) benefits – but only at Subway sandwich shops.

SNAP (formerly known as food stamps) is the largest government nutrition assistance program in the United States, helping one in seven Americans pay for their food. Each month, approximately 47 million people receive SNAP benefits, and the limits on how recipients can use their benefits are few.

Benefits can be used at any retail establishment that accepts them in order to purchase any brand of food items. The only limitation on eligible food items is that they cannot be “hot foods” or “foods that will be eaten in the store” (i.e., prepared foods).

Recognizing that certain groups of people may find it difficult or impossible to prepare foods for themselves, several states, including Rhode Island, have passed exceptions to the prepared foods restriction.

Now, Rhode Island SNAP recipients who are homeless, disabled, or elderly may use their benefits to purchase prepared foods at federally-approved restaurants in the pilot program. Thus far, however, the only establishments that have been approved are five Subway restaurants.

A chain like Subway probably recognizes the financial advantage of accepting SNAP benefits. The potential revenue from the prepared foods exception is large. Approximately half of the individuals in the U.S. receiving public assistance due to disability (Supplemental Security Income) reside in households receiving SNAP benefits. Add homeless and elderly SNAP recipients to that mix and the magnitude of new customer dollars is substantial.

Given the general lack of restrictions in the SNAP program, some might find it surprising that a state sub-program of SNAP has only approved one restaurant chain to do business with. The decision will potentially funnel a large amount of public funds to one business, which may cause pause in the public policy community. In addition, the pilot program’s options for participating individuals are limited, which may seem counter to the general spirit of SNAP.

But a look at the history of food stamps reveals the program’s long-standing ties to specific food producers and food products.

Unmarketable food surpluses coupled with widespread unemployment in the late 1930s gave birth to the first Food Stamp Program (FSP). In this initial incarnation, recipients would receive an extra 50 cents for each dollar they spent on food. But the fifty cents in benefits could only be used to purchase what the U.S. Department of Agriculture (USDA) determined to be surplus items. Federal funds, via the FSP, went toward supporting farmers who could not sell enough goods.

When the FSP became a permanent program in 1964, its official purposes were “strengthening the agricultural economy and providing improved levels of nutrition among low-income households.” At this time, the main restriction on eligible foods was that they could not be imported – the U.S. food industry, therefore, continued to be supported by the policy. To this day, SNAP is funded through the USDA, which also approves retailers for the program.

It is important to note that SNAP is not the only government nutrition program with ties to specific brands. Women, Infants and Children (WIC) is a federally-funded program that provides supplemental nutrition assistance to low-income pregnant women, new mothers, and children up to age five. WIC is generally more restrictive than SNAP in its categories of eligible foods, but also in that only certain brands of those eligible foods are approved by the program.

For instance, women in New York who would like to use their WIC benefits to purchase breakfast cereals may only purchase cereal from a limited number of brands, including: General Mills, Kellogg’s, Post, Quaker, and Malt-o-Meal.

Given the history of food stamps being used to support American food industries, and given the brand specifications of WIC, the Rhode Island prepared foods exception that uses only the American franchise of Subway Sandwiches might seem less shocking. And, if the state’s pilot program is deemed a success, it’s possible that Rhode Island will add other restaurants to its prepared foods exception.

Of note, Subway is the second largest global restaurant operator in the world, next to YUM! Brands. Interestingly, YUM! Brands has also entered the SNAP arena. In September 2011, the Louisville-based corporation—which owns Taco Bell, KFC, Long John Silver’s, and Pizza Hut—was lobbying to make it easier for SNAP participants to use their benefits at restaurants. Since 2009, Arizona residents who are disabled, elderly, or homeless can use their SNAP benefits to purchase prepared foods from certain fast food restaurants, including YUM! Brands’ Pizza Hut and KFC.

Although ties between the U.S.-based food industry and federal nutrition assistance programs are long-standing, choice of foods has typically been a heavily guarded characteristic of SNAP. For instance, proposed public health interventions to remove sodas from the list of eligible foods under SNAP caused an uproar among anti-hunger advocates (including, among others, the soft-drink industry), who claimed that the government should not “micromanage” how low-income people shop. Soda bans in SNAP have been thus far unsuccessful.

Given the program’s emphasis on choice, it is somewhat surprising that the state-level specific-brand-restricted prepared meals exceptions within SNAP have not received greater attention. They highlight an on-going tension within the SNAP program, between respecting participating individuals’ autonomy relative to food choices and giving preferential treatment to specific food vendors. If prepared foods exceptions within SNAP continue to proliferate, the public health community should be prepared to bring an additional perspective to the debate, namely the need to ensure that healthy (or at least healthier) eating options are available and easily accessible for SNAP recipients. This is the surest way to truly respect the program’s traditional emphases on choice and nutrition for participating individuals.


To see citations and sources, please see the article in Corporations and Health Watch. USDA food coupons image by NCReedplayer via Flickr, Creative Commons license.



  1. Posted by Margaret

    Thank you for your last point: making healthy choices accessible not only could improve the health of SNAP recipients, but save the government big money on healthcare costs. Think of all those Medicaid dollars going towards the treatment of preventable diseases like type 2 diabetes, atherosclerosis, and hypertension. Why shouldn’t everyone have the right to eat healthily from the start, save ourselves the pain and costs of contracting certain chronic diseases, and improve our quality of life to boot?

  2. I am involved with a new food program at a family-run lakeside lodge in the mountains. Cure Cottage Cuisine provides for take-out broth-based soups from farm-raised chicken and grass-fed beef bones particularly for Seniors and Convalescents in our area.

    Providing a truly healthy and locally-sourced food for several communities in several small towns sprinkled here at the edge of the Adirondack State Park, would we be able to participate in SNAP? Or would the hassle and paperwork be out of proportion to the benefit?

    I want to point out, too, that good nutrient-dense food is costly. We have priced our broths out to $3.00 per oz. retail, and it’s only that low because we have a terrific source for good chicken bones fairly priced. So SNAP coupons exchanged for clean, health-giving food might not seem to go very far. The solution to this problem eludes me.

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