Last time, we talked about three main areas of a policy where things can go wrong: drafting a written policy to match the envisioned goal or mission of the policy (articulation), creating an administration or structure to carry out the policy (implementation), and making sure that people are actually following the policy (enforcement). These three areas are extremely complicated when everyone involved has a common view of what the policy is trying to achieve. When there’s no clear agreement on the intended goal of the policy, things get even more confusing. For an example of that kind of confusion, let’s look at a recent policy proposal in New York State to prohibit the use of food stamps to buy soda. To understand what’s really going on here, we’ll need to take a closer look at a couple of things: what the intended goal and policy of the food stamp program is, what the proposed policy is, and how the two interact.
Let’s start with food stamps. The United States food stamp program started in 1939. Although it currently functions as an anti-poverty program, it started as a subsidy for American farmers administered by the U.S. Department of Agriculture as a way to help American food producers by making it easier for consumers to buy their goods. Originally, consumers bought coupons that could be used for food and were issued additional coupons that could be used for “surplus” food – food that was being produced but not purchased because of the problems in the economy. Even now, changes to the food stamp program take place in congressional “Farm Bills” that primarily focus on agricultural issues.
The food stamp program is also one of the primary anti-poverty programs administered by the federal government. Over time, eligibility for the stamps has been narrowed to include only low-income individuals and families. Unlike some other anti-poverty programs, eligibility is based on more than just an individual’s or household’s income and includes a calculation for how much they are paying for housing costs to determine the amount of income considered available for purchasing food. (You can go through the pre-screening on the federal food stamp website if you want to estimate your eligibility – if you’re from outside the U.S., just pick a random state.)
Although a person is approved for a certain dollar amount of food stamps per month, the benefit is not given to them as cash. Instead, they get that dollar amount of “food stamps” on an electronic debit card that can be spent only on food — it can’t be used for rent, gas money, diapers, clothing, vitamins, medicine, toiletries, or any other non-food items. There are also restrictions on the food that can be bought with food stamps: no hot or pre-prepared food (like a deli sandwich) and no alcohol or cigarettes. These rules get somewhat complicated – pumpkins can be bought if they’re edible, but not if they’re a decorative gourd.
So, given that framework, we can now understand what New York state is proposing: a demonstration project for New York City that would “bar the use of food stamps to buy beverages that contain more sugar than substance — that is, beverages with low nutritional value that contain more than 10 calories per eight-ounce serving. The policy would not apply to milk, milk substitutes (like soy milk, rice milk or powdered milk) or fruit juices without added sugar.” And the stated goal of the policy: “bring[ing] us closer to stemming the wave of obesity and diabetes in New York.”
The question of how much and whether these drinks do or do not contribute to an increase in diabetes and obesity (obesity which may or may not be a health issue) is a whole other question – for the purposes of this analysis, let’s just pretend we live in a world where that connection has actually been proven. Even if we accept that very tenuous connection, a big problem with this proposed policy is both overbroad and underbroad. Policies that are overbroad change more things than they need to in order to reach their intended goal. This policy is overbroad because there are surely people who use food stamps to buy some of the prohibited drinks who are neither obese nor have diabetes – so the policy would be prohibit purchases that do not contribute to the harm we are trying to prevent. It is underbroad partly because of what’s excluded – the sugar in fruit juice or chocolate milk is just as sugary as the sugar in soda. But it’s also underbroad because there are surely people purchasing these drinks with their own money – earned, inherited, or otherwise gotten not through food stamps – to buy these drinks that will contribute to their obesity and/or diabetes.
If we were this convinced that these sugary drinks were the root cause of an obesity epidemic, there would be a lot more effective ways to target this policy – by banning the sale of those drinks in the state, to anyone, using any method of payment. Or selling them only to adults. But this isn’t what’s being proposed. Partly because the soda companies would create a huge stink in protest and partly because the population would complain that they have the right to spend their money how they like and would likely vote out any politician that made such a policy. Instead, this is a “demonstration project” that New York promises the “effects [of which] would be rigorously evaluated.” This is really an experiment to find out if limiting purchases of these drinks makes any difference at all, either to the amount of sodas sold or any eventual health outcomes. And it’s a pretty bad experiment, because even with the tight control we have over how poor people spend their money, they could still buy a Coke with their non-food stamp income.
So what’s the real goal of this proposed food stamp policy? To further restrict the purchasing power of people low-income enough to receive food stamps in order to find out if this idea they have has any effect at all on what they want to try to change: the health of the overall population. And this kind of implementation is not at all unusual – these half-baked policy ideas that don’t have a firm scientific underpinning for their presumed causal effect are often tested out on vulnerable populations that don’t have the political power to resist them. If this was implemented on the entire population of New York City or state, there would be a giant backlash. But the poor aren’t nearly as well organized or politically active, so it’s safe to practice on them, for the good of everyone’s overall “health.”
- New York Times story on the proposed ban
- National Public Radio story on the proposed ban
- New York Times editorial from the health commissioners of New York City and state discussing the proposal
- Marion Nestle discusses the proposal
- US Department of Agriculture FAQ about the food stamp program
- A New York Times article on the increasing number of people who have food stamps as their only income