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While returning home from work today, I saw a sign advertising Gatorade on a store window and next to this sign was another noting that the store accepts food stamps. While the signs were not linked, their juxtaposition prompted a desire to learn more about the details of what items food stamps are permitted to be used to purchase. A quick internet search found the USDA’s rules on the “Supplemental Nutrition Assistance Program” (SNAP) – the bureaucratic name for the food stamp program (https://www.fns.usda.gov/snap/eligible-food-items).

According to this site, food stamps are eligible for use to purchase “any food for the household,” including “seeds and plants which (sic) produce food for the household to eat.” Items that are not eligible include alcohol, tobacco products, pet foods, paper products, vitamins and prepared and hot foods. So far, no particularly obvious flaw in the permissible and verboten items – clearly “food” for humans is what the program is intended for while beer, cigarettes and pet food are not. The challenge though is how to define “food.”

What is “food”? – We all might have different concepts as to what is a “food,” and the USDA’s website acknowledges the challenges inherent in defining the term with any perfect precision. Recognizing the need to create a definition, the Food and Nutrition Act of 2008 (the Act) unfortunately takes the decision that anything that can be digested is food. The USDA’s website thus notes that “soft drinks, candy, cookies, snack crackers, and ice cream … and bakery cakes” are food. Also included are “energy drinks that have a nutrition facts label”. Ice cream?! Who doesn’t love ice cream, but it certainly is not “food” that should be purchased with the use of food stamps designed to provide nutrition for those in need of supplemental nutrition.

The definition of “food” in the New Shorter Oxford English Dictionary (1993 edition) includes “Substance(s) (to be) taken into the body to maintain life and growth, nourishment, provisions, victuals. … Solid nourishment, as opp. to drink.” By that definition, clearly soft drinks (or any drinks) are not food, and almost as clearly neither would be candy – but let’s even forget dictionary definitions and revert to common sense. Mountain Dew and Snickers bars are “food” that should be eligible purchases for people with limited resources who are being provided funds from the rest of the community to supplement their nutritional needs?

The mysterious definition of food proferred by the government is openly motivated by the desire to avoid “stigmatizing” benefit recipients who might be embarrassed by trying to purchase items that are ineligible for the program. In its discussion of “Junk Food & Luxury Items,” the USDA acknowledges that “[s]everal times in the history of SNAP, Congress had considered placing limits on the types of food that could be purchased with program benefits.” The USDA then provides a link to a short report that only a very progressive bureaucrat could read without shaking his or her head in disbelief (http://www.fns.usda.gov/ora/menu/Published/snap/FILES/ProgramOperations/FSPFoodRestrictions.pdf). This report provides the USDA’s arguments as to why such limits are neither desirable nor practical.

USDA’s reasons not to limit use – The report lists the following reasons as to why limits on food stamp use are not desirable:

1. the absence of clear standards for defining a consumible item as healthy or not,

2. the use of such limits would add to the program’s cost and complexity,

3. such limits may be ineffective in changing the purchases of food stamp participants, and

4. there is no evidence that food stamps contribute to poor diet or obesity.

While not without some seeds of truth, these four reasons are largely incorrect or irrelevant. Taking each in turn:

the absence of clear standards for defining a consumible item as healthy or not – It is undeniably true that there exists no bright line test for whether a food is healthy, and even widely-regarded healthy foods that can be eaten in unhealthy quantities or foods that are reasonably argued by some as being unhealthy (e.g., eggs, bananas, fruit juice, milk). Be that as it may, there are clearly consumibles that are not healthy (or really have any nutritionally redeeming qualities) in any common sense analysis – candy corn, Twinkies, donuts, colas, bubble gum and freeze pops come rapidly to mind. There are numerous other items, such as ice cream, that perhaps could be argued to have some nutritional value due to their dairy or other nature, but common sense would again make clear that these are not “healthy” (tasty and desirable yes, healthy no) and that, even if of some marginal nutritional value, are among the least efficient providers of nutrition. Lastly, there is a group of consumibles, such as cheese puffs, Pringles and heavily-sugared cereals, that might even reasonably be called “food” in some circles but are undeniably not healthy. Clearly the USDA’s statement that “there are no bad foods, only bad diets” is wrong – candy corn is a bad food (that is, assuming that candy could even be considered to be a food).

The fatal flaw in the USDA’s report is that it makes the clearly factual statement that there are no “widely accepted standards to judge the ‘healthfulness’ of individual foods” but then extrapolates that into finding that it is thus impossible to identify any food as unhealthy. While certainly there is no foolproof test for marginal items such as granola bars, there are clearly items that are not healthy by anyone’s definition – in fact, let’s use the government’s own list of acceptable items as examples of what should not be acceptable (“soft drinks, candy, cookies, snack crackers, and ice cream … and bakery cakes”). The inability to classify all consumibles does not mean that it is impossible to identify the items that clearly are not healthy – and every one of the items in the government’s list should certainly be considered to be unhealthy and ineligible for supplement nutrition purposes.

the use of such limits would add to the program’s cost and complexity – This is another true statement, and the one for which I have the most sympathy as it is a practical question as opposed to a subjective and moralistic one. Clearly distinguishing between the acceptable and the not would add burdens to both the government regulators and the stores that have to implement these rules. Another risk not identified by the USDA for obvious reasons is that while the additional costs for the government would likely be small, giving bureaucrats such decision-making powers would also introduce a strong element of lobbying and risks of favoritism and corruption.

In acknowledgment of these facts, the proposed solution suggested below would greatly minimize these disadvantages.

Worth noting is an additional consideration that the USDA report identifies, which is that “food stamp recipients would face … potential for embarrassment” if they end up bringing a cashier an item that is not eligible for food stamp use. This manipulative argument is such a frightening reminder of the mindset of committee-driven bureaucrats that it deserves particular scorn – how dare anyone dare cause food stamp recipients harm by prohibiting them from buying cotton candy with taxpayer money provided to assist with supplemental nutrition!

such limits may be ineffective in changing the purchases of food stamp participants and there is no evidence that food stamps contribute to poor diet or obesity – These last two arguments have been combined as they are essentially addressing the same topic – arguments by some that the food stamp program should be used as a means to promote healthy food choices. While clearly true that imposing limits “may” (in fact, even “would likely”) not change the habits of food stamp beneficiaries, and perhaps there is no evidence that food stamps contribute to poor dietary decisions, these are not remotely relevant to the question as to whether food stamp beneficiaries should be using others’ money to purchase candy, colas and other junk foods. If the beneficiaries wish to use their own funds to do so and use food stamps (which, we must remember, are for “supplemental nutrition” purposes) to purchase just the eligible foods, then they are free to do so. The argument that something might happen anyway is not sufficient reason for society to thus shrug its shoulders and say “Ok, we’ll pay for their gummi bears.”

Suggested action – As the USDA’s ability to implement some reasonable standards is limited by the Act, Congress needs to obtain a healthy dose of common sense and adopt a rule that puts reasonable limits on what food stamps can be used to purchase. Since it is indeed impractical to classify each and every consumible available for sale in the country, Congress needs to do what they have already done for alcohol and tobacco and expand the list to cover all beverages (other perhaps than milk and unsweetened fruit juices), candy, cookies, ice cream and similar frozen treats, cakes and pastries and potato, corn and other chips.

This suggestion thus maintains both the existing structure and the existing approach and simply lengthens the list of items for which food stamps cannot be used. Not only does this eliminate the clearly unhealthy consumibles from the list of eligible items but it creates simple categories that can be managed by the USDA bureaucracy, retailers and food stamp beneficiaries with some ease – adding candy to the list of alcohol and tobacco would not be a stretch for retailers or beneficiaries to understand!

Is it really that impossible for society to place reasonable limits on how taxpayer funds are used? While lobbyists for the affected industries (such as candy and cola manufacturers) would continue to exert their influences to oppose these reasonable limits, society should demand that government use our resources with some modicum of reason – particularly where the program is a transfer of money from one citizen to another and is, in fact, intended to provided “nutrition.”

A topic for another day is using food stamps for luxury spending, whether on upscale foods or expensive brands or in expensive stores. Should food stamps be eligible for the purchase of caviar, fancy cheeses, steaks and lobster? Should food stamps be eligible to purchase Kellogg’s Corn Flakes instead of the much less expensive store brands? Should food stamps be eligible for use in Whole Foods instead of Aldi? While the answer to all of these would clearly in theory be no, the practicalities of these decisions are much more difficult to address than those described above for the classification of unhealthy “foods.”