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Commentary

SNAP is About Nutrition: My Response to Zycher

COSM Commentary

May 2, 2025

In a recent blog post, my AEI colleague Benjamin Zycher took issue with a letter to the editor I published in the Wall Street Journal, in which I agreed with columnist Allysia Finley’s argument to place further restrictions on what Supplemental Nutrition Assistance Program (SNAP) dollars can be used to purchase. My point was simple: SNAP’s legislative intent is to improve nutrition among low-income households and therefore, non-nutritious products should not be included in the program. Zycher made some points that are worth addressing.

Firstly, Zycher claims that nutrition-based restrictions would come at the cost of a “substantial increase in coercion, including enhanced government monitoring of private individual behavior.” However, it is not obvious what Zycher means by “coercion” here. Certainly these restrictions won’t force recipients to buy any particular product, they will only prevent them from using SNAP benefits to purchase products that are contrary to the program’s goals. If, as Zycher suggests, all nutrition-based restrictions in SNAP are inherently coercive, then SNAP’s longstanding prohibitions on purchasing alcohol or prepared foods (including Frappuccinos, which Zycher mistakenly cites as a future possible target) are already coercive. But they are not coercive. Instead, restrictions should be viewed as furthering the primary goal of the program: improving nutrition.

Mr. Zycher goes even further by questioning that the primary intent of the Supplemental Nutrition Assistance Program is about improving nutrition. Instead, he contends that SNAP is a “classical political bargaining equilibrium” between farmers and low-income households, implying that it isn’t truly about helping low-income households afford nutritious foods. He asks: “Why else would the food stamp program have been housed from the beginning in the Department of Agriculture rather than the earlier Department of Health, Education, and Welfare or the later Department of Health and Human Services?”

While it is true that the original Food Stamp Program, created in 1939, was a voluntary commodity-based program meant to transfer farmers’ surpluses to low-income households, that program ended in 1943. Today’s Supplemental Nutrition Assistance Program is far different in its intent with its roots in legislation from the 1960s and 1970s, and its focus is squarely on nutrition. Just take a look at Congress’s Declaration of Policy for SNAP, which hasn’t changed much since the original 1964 Food Stamp Act, and outlines the goals of the program (provided in full to allow the reader to make their own determination, emphasis mine):

“It is declared to be the policy of Congress, in order to promote the general welfare, to safeguard the health and well-being of the Nation’s population by raising levels of nutrition among low-income households. Congress finds that the limited food purchasing power of low-income households contributes to hunger and malnutrition among members of such households. Congress further finds that increased utilization of food in establishing and maintaining adequate national levels of nutrition will promote the distribution in a beneficial manner of the Nation’s agricultural abundance and will strengthen the Nation’s agricultural economy, as well as result in more orderly marketing and distribution of foods. To alleviate such hunger and malnutrition, a supplemental nutrition assistance program is herein authorized which will permit low-income households to obtain a more nutritious diet through normal channels of trade by increasing food purchasing power for all eligible households who apply for participation. That program includes as a purpose to assist low-income adults in obtaining employment and increasing their earnings. Such employment and earnings, along with program benefits, will permit low-income households to obtain a more nutritious diet through normal channels of trade by increasing food purchasing power for all eligible households who apply for participation.”

Obviously, SNAP is about nutrition. Therefore, nutrition-based restrictions are not beside the point of the program, they are central to it. Mr. Zycher claims that imposing nutrition-based restrictions in SNAP is no different in principle than Medicaid and Medicare requiring (or coercing) beneficiaries to “adhere to government diktats on lifestyle choices” as a condition of their benefit receipt. But again, coercing households to do something (i.e. eat a particular diet or engage in a certain amount of exercise to avoid the loss of health insurance coverage) is inherently different than preventing beneficiaries from using benefits directly contrary to the program’s goals.

A better analogy would be to assume that Medicaid and Medicare covered a procedure or treatment that was shown to be harmful or ineffective to beneficiaries, such as supplements with unproven claims for weight loss that caused harmful side effects. If the goal of Medicare and Medicaid is to improve beneficiaries’ health, then the government is fully within their charge to disallow the coverage of ineffective procedures or treatments. Yet this is exactly what we tolerate in SNAP. A large portion of program benefits go towards foods and drinks that contribute negatively to recipients’ health, despite the fact that the primary goal of the program is to improve nutrition.

Mr. Zycher next raises the question of the fungibility of SNAP benefits. In my letter to the editor, I noted that SNAP recipients would still be free to purchase unhealthy foods if they wished, but they would have to do it with their own money. Mr. Zycher responded by noting that the fungibility of SNAP benefits would likely have a “net dietary/health effect…on the order of zero.” Firstly, that issue is far from settled. In fact, evidence shows that SNAP benefits are not fungible, and recipients do not spend SNAP dollars the same as cash, suggesting that they might make different choices when using their own money. Moreover, if as Zycher suggests, SNAP benefits are fully fungible, then why worry that such restrictions constitute an increase in “coercion”? If you believe that SNAP recipients will just buy junk food anyways, then you can’t also believe that they will be coerced to not buy junk food through restrictions.

Again, imagine if Medicare/Medicaid beneficiaries wanted a treatment with proven negative health effects. They should be free to seek that treatment on their own dime, but not use taxpayer-supported benefits that are explicitly earmarked for providing effective treatments. Perhaps the availability of Medicare/Medicaid frees up money for the individual to be able to afford the ineffective treatment they want, essentially turning federal funds into indirect support of ineffective treatments. But it is far from clear that households respect the fungibility of money in this way when it comes to public health insurance and SNAP.   

Finally, and perhaps most importantly, Zycher raises a question about my contention that American taxpayers have a reasonable expectation that SNAP dollars will support nutrition as Congress has repeatedly legislated. He writes: “Actually, they have no such “reasonable expectation.” Certainly, during the policymaking process, public opinion is not the only consideration. But taxpayer’s should not only expect Congressionally-authorized funding to meet an established law’s stated purpose; they must demand it. Undoubtedly, grocers and beverage companies will strongly oppose SNAP restrictions, but their bottom line shouldn’t be the concern of Congress when it comes to SNAP policy. Congress’s concern should be ensuring that SNAP dollars achieve their intended aim. Again, the Declaration of Policy is useful here: nutrition is mentioned repeatedly, farmers are mentioned only once, and soda companies are mentioned zero times.

We can learn something from President Trump’s administration and DOGE efforts here. The administration has rightfully spent their early days scrutinizing federal funds and ending funding deemed inconsistent with authorizing legislation (example: USAID). Though imperfect, their efforts reflect a principled approach to rein in spending that is inconsistent with the purpose of Congressionally authorized programs. The same is true when it comes to SNAP. The priority must be to ensure that federal funds earmarked for a specific purpose, actually fund activities aimed at achieving that purpose.