How Does Household Food Assistance in Puerto Rico Compare to the Rest of the United States?

Puerto Rico receives a block grant with a fixed amount of federal funding to provide basic household food assistance through the Nutrition Assistance Program (NAP, or PAN for its name in Spanish, Programa de Asistencia Nutricional). This block grant structure differs from that of the Supplemental Nutrition Assistance Program (SNAP), the food assistance program operating in the 50 states and some territories.^[2] SNAP’s entitlement structure enables the program to serve all eligible people who apply, which in turn allows it to expand and contract to accommodate changing need. Thus, while other major federal nutrition programs — including the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and child nutrition programs including school meals programs — operate the same in Puerto Rico as in the states and territories, the Commonwealth is disadvantaged with respect to household food assistance.

Like SNAP, NAP includes specific eligibility criteria; determines benefit levels based on income, expenses, and household size; and issues benefits on electronic benefit transfer (EBT) cards. SNAP serves all applicants who meet the program’s eligibility criteria, which are based on poverty levels, and can provide consistent benefits to all participants based on the cost of food. But NAP’s capped funding structure forces the program to set eligibility and benefit levels to stay within its budget rather than base them on need or the price of food, which means it cannot serve all residents who might be eligible in SNAP or provide the same level of benefits as SNAP does. And while SNAP’s funding structure enables it to respond to changes in demand, including those due to natural disasters or recessions, NAP, with its limited funding, cannot, at least not without further lowering benefits.^[3]

NAP and SNAP share many similarities — and some differences — with regards to administration and oversight. Puerto Rico administers NAP through the Department of the Family’s Administration for Socioeconomic Development (ADSEF), and states and territories administer SNAP. Under both SNAP and NAP, states and territories split the cost of administration with the federal government. The Agriculture Department’s Food and Nutrition Service (FNS) provides oversight to states and territories in their administration of SNAP, as well as to ADSEF in its administration of NAP, though Puerto Rico implements some functions that the federal government carries out in SNAP such as certifying retailers, among other differences in administration and oversight.

Puerto Rico’s Need

Puerto Rico participated in SNAP’s predecessor, the Food Stamp Program, from 1974 (when the program went nationwide) until 1982. Congress and President Reagan replaced Puerto Rico’s food stamp program with a block grant that became NAP — with funding levels set well below what Puerto Rico had been receiving under the Food Stamp Program — through the Omnibus Budget Reconciliation Act of 1981.^[4] Block granting NAP was part of a larger package of cuts to food stamps and other income security programs in the President’s budget proposal and this legislation.^[5]

The transition to the block grant resulted in a program that served many fewer people, despite significant poverty and hardship in the Commonwealth. The block grant capped funding at about 25 percent below what households in Puerto Rico would have received under the Food Stamp Program and did not include automatic annual adjustments for inflation, resulting in a greater gap over time.^[6] Meanwhile, poverty and unemployment rates remained far higher than in the states. To keep NAP spending within the new funding limitations, Puerto Rico targeted benefits to households with the lowest incomes and set benefit levels below levels in the Food Stamp Program.^[7] By 1984, for example, income eligibility limits were about 40 percent lower than they would have been in the Food Stamp Program, and eligibility and benefit restrictions contributed to NAP participants having fewer resources available for food.^[8]

Providing resources to buy food is especially important in Puerto Rico, given the Commonwealth’s high rates of poverty and fewer programs available to help low-income families meet basic needs.

Over two-fifths of all residents of Puerto Rico (43 percent) and over half of children in Puerto Rico (57 percent) lived in poverty in 2018, according to the most recent U.S. Census Bureau data.^[9] In 2015, about one-third of Puerto Rico’s adult residents experienced food insecurity, which is a lack of consistent access to adequate food, a recent study found.^[10] While not directly comparable due to methodological differences, this rate was more than twice a similar rate for adults in the United States in 2015.^[11] This same study found that people with low incomes (under $25,000 annually) were more than three times as likely to experience food insecurity than households with higher income.^[12] Puerto Rico has never recovered from a recession that began in 2006, and events including two devastating hurricanes, delays in rebuilding aid, and population decline have contributed to Puerto Rico’s economic challenges and made it more difficult to alleviate poverty.^[13]

Despite these challenges, Puerto Rico receives lower funding for some key economic security programs than other states or territories, making these programs less available to meet its residents’ basic needs, and underscoring NAP’s importance in providing basic support. (Puerto Rico fully operates other programs, such as Social Security and some federal nutrition programs such as school meals.) For example, federal Medicaid funding for Puerto Rico is limited by law, resulting in Medicaid serving fewer people, covering fewer health services, and directing lower payment rates to providers than it would if Puerto Rico fully participated in the program.^[14] Some low-income seniors in Puerto Rico also receive less assistance with Medicare premiums and prescription drug costs than they would in the states.^[15]

And rather than the federal Supplemental Security Income (SSI) program that provides benefits to people who are disabled or elderly with low income and assets in the states and some territories, Puerto Rico has a capped grant called Aid for the Aged, Blind, and Disabled (AABD). Limited funding for AABD results in much lower eligibility and benefit levels than SSI. If Puerto Rico were fully eligible for SSI in 2011, over 300,000 individuals would have received an average of over $400 in monthly federal benefits under SSI, compared to 34,000 individuals receiving an average of $58 per month under AABD, the Government Accountability Office estimated.^[16]

As states do, Puerto Rico receives a Temporary Assistance for Needy Families (TANF) block grant to provide direct financial assistance to families to meet basic needs. But in the Commonwealth and other territories, the block grant has some limits that states don’t, such as an overall federal funding cap for the programs that are funded by the grant.^[17] As a result of that and limited funding that affects all states and territories, Puerto Rico is able to provide TANF assistance to only a tiny share of families in poverty, just 4 out of 100 in 2017.^[18]

Puerto Rico residents also cannot access the Earned Income Tax Credit (EITC) or the Child Tax Credit, as residents of the states and the District of Columbia can. The federal EITC is not available to people who live in Puerto Rico, while the Child Tax Credit is only available to families there with three or more children. In 2019, Puerto Rico introduced its own, locally funded EITC, but it is very modest and provides low-income working families with just a fraction of what the federal EITC provides on the mainland, because Puerto Rico lacks the resources to make its EITC more adequate.^[19]

Funding Structure

SNAP is an entitlement program, which means that anyone who qualifies under program rules can receive benefits. As a result, SNAP can respond quickly and effectively to support low-income families and communities during times of increased need. Enrollment expands when the economy weakens or disaster hits and contracts when the economy recovers and poverty declines, without additional action from Congress or the President. In this way, SNAP helps families bridge temporary periods of unemployment or family crisis. SNAP food benefits are funded with federal dollars, and administrative costs are shared evenly between the state and federal governments.

NAP is a capped block grant, which means Puerto Rico receives a fixed level of annual funding for food assistance from the federal government regardless of need. As a result, NAP cannot automatically expand to meet increased need when the economy stumbles or natural disaster strikes. Instead, the Commonwealth has historically controlled program costs by imposing income and benefit limits below those in SNAP. The U.S. Department of Agriculture (USDA) determined in a comprehensive 2010 assessment that if Puerto Rico participated in SNAP, it would spend approximately 23 percent more on household food assistance as a result of serving more individuals and providing more robust benefits.^[20]

The federal block grant covers all NAP food benefits and 50 percent of administrative costs, and Puerto Rico covers the remaining administrative expenses.^[21]

Initially, the block grant was funded at $825 million per year, an amount about 25 percent less than funding for Puerto Rico under the Food Stamp Program, and it did not include regular annual adjustments for inflation, which further eroded program funding. Federal policymakers raised funding by about 3 percent annually between 1987 and 1990^[22] and provided some additional modest increases in the early 1990s. These increases did not always keep up with food inflation, however, leading the real value of the block grant to fluctuate in those years. The 1996 farm bill adjusted funding annually between 1996 and 2002 to reflect anticipated inflation, and the 2002 farm bill provided for ongoing annual adjustments to reflect food price inflation.^[23]

Federal funding for NAP in fiscal year 2018 was about $1.92 billion.^[24] Besides temporary increases following natural disasters and COVID-19 (described below) and as part of the 2009 Recovery Act, funding for NAP has remained flat since then, after adjusting for food inflation. (See Figure 1.)

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States and territories participating in SNAP that experience natural disasters can request disaster SNAP benefits from USDA, which include benefits available for new households affected by the disaster that can apply with a simplified application, as well as replacement or supplementary benefits for participating households that lost food due to the disaster. This process does not require congressional action, and the USDA approval process is straightforward. These programs have generally begun operating within months of a disaster, and often within days or weeks.

In contrast, NAP does not have an automatic mechanism to provide disaster benefits (see box). As the recent experience with Hurricanes Irma and Maria demonstrated, additional funding is contingent on congressional action, and requires Puerto Rico to submit and USDA to approve a comprehensive plan outlining the use of those funds, which can significantly delay the process. A recent report from USDA’s Office of the Inspector General described how Puerto Rico’s lack of disaster authority prevented the Commonwealth from adequately planning for and providing disaster benefits in a timely fashion after the 2017 disasters. Puerto Rico did not receive approval for and begin operating a disaster nutrition assistance program until nearly six months after the disaster. In contrast, the Virgin Islands, which participates in SNAP and can provide assistance through the Disaster SNAP program, was able to provide assistance in November 2017, only 47 days after Hurricane Maria.^[25] Puerto Rico has also recently received additional funding to help the Commonwealth serve more people and boost benefits to respond to increased need from COVID-19.

Eligibility

SNAP eligibility rules are, for the most part, set at the federal level and uniform across the nation. Under federal rules, a household must meet three criteria to qualify for SNAP benefits: (1) gross monthly income at or below 130 percent of the poverty line, or $2,353 for a three-person family in fiscal year 2021;^[26] (2) net monthly income (income after eligible deductions are applied) at or below 100 percent of the poverty line, or about $1,810 a month for a three-person family in fiscal year 2021; and (3) assets below certain limits, which in fiscal year 2021 were $2,250 for households without an elderly or disabled member and $3,500 for those with an elderly or disabled member. States have the flexibility to ease these limits, and many do.^[27]

NAP eligibility is based on net income and asset limits.^[28] NAP has no gross income test. The Commonwealth sets specific eligibility criteria and other program parameters in its annual state plan, which the USDA approves. For example, as of March 2019 and continuing unchanged, a household of three had to have net income at or below $1,706 to qualify. Original program rules established a much lower income level of $599 for a family of three for 2019, in line with recent years, but Puerto Rico raised income limits after receiving additional NAP funding in response to Hurricanes Irma and Maria. (This increase in the income limits led to a rise in participation of about 10 percent.) While participant benefits were cut to previous levels when this funding expired in March 2019 (with increases following receipt of subsequent relief funding as described in the box), Puerto Rico kept higher qualifying income limits.

Additionally, to qualify for NAP, households must have assets (such as money in a bank account but not including the value of most vehicles or most participants’ homes) less than or equal to $5,000, or $15,000 for families with elderly members, though the vast majority of participants likely have assets far below these levels.^[29]

SNAP eligibility levels are set based on poverty levels, and all eligible people who apply can receive benefits. But ADSEF must set NAP’s eligibility levels to fit the confines of fixed funding.

In both programs, applicants must meet limited non-financial requirements in addition to income and asset limits. Both programs have similar rules regarding non-citizen eligibility, but other eligibility rules differ. For example, SNAP eligibility is more limited for most individuals enrolled in higher education than in NAP,^[30] while in NAP, families must show that school-age children are enrolled in school or are receiving home instruction, which is not required in SNAP.

Under a particularly harsh SNAP rule, adults without dependent children in their household and without documented disabilities are limited to three months of SNAP out of every three years unless they are working at least 20 hours per week or participating in a qualifying workfare or job training program. They may also be eligible if they meet certain exemptions or live in an area with a temporary waiver of the time limit due to elevated unemployment.^[31] Under this policy, states are not required to provide work slots or training program opportunities to individuals subject to the time limit, and as a result, SNAP participants are cut off after three months regardless of whether they are looking for work or would be willing to participate in a qualifying training program.^[32] NAP has not had this restriction.^[33]

Application Process

In SNAP, states and participating territories (and in some states, counties) administer the program according to federal rules, but with many state options. In most states, households can apply in person at a local human services office or submit an online application. In some states, applicants can also apply over the phone. Households in most states usually have an option to fill out and mail or fax in an application. Applicants must participate in an eligibility interview, which can be on the phone in most states. They must also document numerous aspects of their eligibility, including their identity, residency, immigration status, household composition, income and resources, and deductible expenses. Once households are determined eligible and are receiving benefits, they must also reapply for SNAP at intervals determined by the state called certification periods, typically every six to 12 months for most families and every 12 to 24 months for seniors and people with disabilities. They must also report certain changes such as changes in income. (The Families First Coronavirus Response Act of March 2020 allowed states to temporarily modify SNAP procedures; for example, almost all states received a waiver to temporarily process applications without conducting an interview, and most states received waivers to extend certification periods for households who were due to renew their SNAP benefits during the pandemic period.^[34])

In NAP, households face a similar application process. Households apply, typically in person at a local office; complete an interview, also usually in person; and submit verifications of their circumstances such as income. Applicants can provide information to determine their eligibility online or by calling a hotline, through which their information will be shared with the local office, which will contact them to schedule an interview. (NAP also made some temporary changes due to COVID-19 beginning in March 2020, including developing an online and phone application process and allowing households to submit documents through email or in physical dropboxes.) Households are also certified for similar periods (six to 12 months for most families and 12 to 24 months for households with elderly individuals or those with disabilities) and must report similar changes in income or circumstances between those periods. Similar to SNAP, NAP also temporarily extended certification periods in response to COVID-19 so that households would not need to renew benefits during the pandemic.

Benefit Calculation

Both SNAP and NAP determine benefit levels based on household size and other characteristics. Very poor households in both programs receive larger benefits since they need more help affording an adequate diet. SNAP benefits have generally been more generous than benefits in NAP.^[35]

SNAP’s benefit formula assumes that families will spend 30 percent of their net income for food; SNAP makes up the difference between that 30 percent contribution and the cost of the Thrifty Food Plan (TFP), a minimal-cost, nutritionally adequate diet that USDA establishes according to household size and updates each year for inflation. Households with no net income receive the equivalent to the TFP for their household size, known as SNAP’s maximum benefit, and benefits decline as net income — and therefore a household’s expected contribution for food (30 percent of that net income) — increases. In SNAP, benefits are therefore theoretically based on the cost of food, though recent evidence suggests they don’t meet the needs of many households.^[36] SNAP benefit calculation is based on federal rules, but states have options that influence several aspects of benefit calculation, such as flexibility to customize some of the deductions used to determine net income.^[37] SNAP’s funding structure guarantees that participants receive benefits based on these rules regardless of the size of the caseload.

NAP benefit amounts are based on a benefit schedule developed by Puerto Rico that sets benefits low enough to ensure that this spending stays within the program’s funding levels. Unlike SNAP, NAP may not have sufficient funding to provide benefits based on estimated food needs to everyone who is eligible for the program, and therefore must determine benefits based on available funding. For example, if during a crisis more people apply for the program than funding allows at current benefit levels, ADSEF must decide to reduce participation, benefits, or some combination to stay within available funding. SNAP, in contrast, can guarantee consistent benefits to all newly eligible households that apply. Most NAP households would likely receive higher benefits under SNAP than under NAP. For many households, those benefits would be significantly higher.^[38]

ADSEF develops a table of base maximum benefits that participants receive each month according to household size and income, and benefits decline as net income increases. Each elderly individual also receives 20 percent more than the standard benefit, one of several features that target benefits to this group.^[39] As described in the box, benefit levels have risen in recent months due to additional temporary disaster and emergency funding approved by Congress.

In addition to these base benefits, participants also receive regular benefit adjustments. If the total cost to provide these base benefits for participants that month falls below the allocated budget, the program distributes the remaining funds to participants based on a formula. This means that most months, participants’ benefits include this adjustment, the amount of which varies each month, in addition to the base allotment. For example, as Table 1 shows, in March through June 2019, the base maximum benefit for a household of three people (such as for households with no or very low net income) was $315 in those months without temporary benefit increases, but final benefits for households of three receiving the maximum averaged $381 including the adjustment.^[40] In comparison, a household of three receiving SNAP’s maximum benefit would have received $505 in SNAP in fiscal year 2019, and more in Alaska, Hawaii, Guam, and the Virgin Islands (for example, $650 in the Virgin Islands.)^[41]

In some regions of the Commonwealth, about 4 percent of benefits are taken out of this monthly benefit adjustment and given in vouchers that participants can redeem at farmers markets called Family Markets. In addition, participants may also receive an annual benefit adjustment as funds remaining at the end of the fiscal year allow.

Benefit Redemption and Retailers

SNAP households receive an EBT card, which is loaded with benefits once a month. (States can choose whether to issue the benefits to all participants on the same day, or stagger benefits so that different households receive benefits on different days of the month; most states stagger benefits. Households must receive benefits on or about the same day every month, with law requiring that issuance be no more than 40 days apart.^[42]) Household members may use the card to purchase food at any of the over 250,000 retailers authorized to participate in the program nationwide, including grocery stores, superstores, corner stores, convenience stores, specialty stores, and farmers markets. Convenience stores make up the largest category of SNAP retailers, but participants redeem over 80 percent of benefits at superstores and supermarkets.^[43] SNAP EBT cards can be used for eligible purchases in any state, regardless of where benefits are issued. SNAP participants can generally buy food for home preparation; SNAP cannot be used to purchase alcoholic beverages, cigarettes, vitamin supplements, non-food grocery items such as household supplies, or hot foods.

NAP participants also receive benefits on EBT cards (called the Family Card) once a month, and NAP benefits can only be redeemed at certified retailers within Puerto Rico to buy eligible foods, defined similarly as in SNAP as food for consumption at home, prohibiting items such as hot prepared foods, alcohol, and tobacco. Like most states in SNAP, NAP issuance is staggered over the month. About 3,000 retailers participate in NAP. Participants spend about 75 percent of benefits at superstores and supermarkets, a 2015 study found.^[44]

Unlike in SNAP, in the past, a small portion of the NAP benefit could be redeemed as cash at automatic teller machines within the Commonwealth to buy food, though this feature has ended and all NAP benefits now must be redeemed for food. This allowed participants to buy eligible foods from retailers and farmers markets that do not have electronic payment equipment..^[45]

Program Integrity

SNAP has strong systems in place to ensure payment accuracy and program integrity. SNAP has a rigorous payment error measurement system to determine unintentional payment errors. Each year states take a representative sample of SNAP cases (totaling about 50,000 cases nationally) and thoroughly review the accuracy of their eligibility and benefit decisions. Federal officials re-review a subsample of the cases to ensure accuracy in the error rates. States are subject to fiscal penalties if their error rates persistently exceed the national average.

While fraud, or intentional misuse of benefits, represents a very small share of SNAP costs, states and USDA also designate significant resources to monitoring and eliminating fraudulent redemption of benefits by retailers or participants. For example, states run database checks to verify program information, and states operate fraud units that can investigate suspected instances of fraud. USDA also has a rigorous authorization and re-authorization process for retailers, and continuously monitors SNAP transactions at retailers, alerting investigators of potentially fraudulent redemption patterns.^[46]

NAP also operates payment error and fraud prevention and detection systems, though in some cases with less support from the federal government than states receive under SNAP. NAP administrators take a sample of cases and review the accuracy of eligibility and benefit determinations and report the findings to USDA, though USDA does not do a re-review of a sample of those cases as it does for the states. NAP staff authorize and inspect new retailers, monitor transaction data, conduct investigations into inconsistent data or other evidence of potential fraud, and sanction retailers who are out of compliance with regulations — functions the federal government performs under SNAP. NAP staff also investigate and pursue claims against the small number of participants who intentionally deceive the government, which states and territories participating in SNAP do as well.

Federal Oversight and Support

In SNAP, program rules are generally set through federal legislation and rulemaking, and eligibility rules and benefit levels are generally uniform across the states. States administer the program, splitting the cost with the federal government, and have many options to tailor aspects of the program. The federal government, through FNS, provides oversight for states in many ways, such as reviewing and approving state operational plans, providing evaluations and reviews, and approving waivers or pilot projects to change aspects of state administration. The federal government also performs other functions, such as certifying retailers.^[47]

In addition to this oversight, the federal government and its regional offices provide states with support related to SNAP administration, such as providing technical assistance, offering competitive grants for technology improvement, and conducting and sharing research with states on best practices. States track participant data and costs and send FNS regular reports, and FNS posts data such as monthly participation reports for all states.

The federal government also provides oversight and support to NAP. As in SNAP, the federal government splits the costs of administering NAP with Puerto Rico. Puerto Rico submits and FNS reviews and approves a state plan each year, and FNS reviews regulations that Puerto Rico submits. Puerto Rico certifies retailers, a function that the federal government does in SNAP. FNS provides technical assistance and monitoring, but the Commonwealth does not appear to have the same access to some resources, such as competitive grants, that states and territories that participate in SNAP do.

In addition, FNS provides less public information about NAP. This relative lack of information is notable given NAP’s size: NAP is one of the largest nutrition programs in the United States. The nearly $2 billion the federal government spends on NAP each year puts the program behind only SNAP, child nutrition, and WIC in federal spending on nutrition programs. The number of people participating in NAP is the tenth largest if considered among states and territories participating in SNAP, equivalent to the number of participants in states such as North Carolina and Michigan. FNS only recently began posting NAP data, such as participation, on its website, and the data are less comprehensive than data posted about SNAP.^[48] Further, FNS requires the public to submit records requests to obtain basic information about the program, which contrasts to the more readily available information about other nutrition programs.

Other Program Components

Both states through SNAP and Puerto Rico through NAP operate nutrition education programs, through which they inform participants about how to use benefits towards a healthy diet.^[49]

SNAP requires states to operate employment and training programs for participants, and states receive additional funding to administer them.^[50] States have significant flexibility in defining these programs and the types of services offered, and often contract with third parties such as community-based organizations and community colleges to provide training opportunities. NAP does not receive funding, nor is it required to administer these programs.

Additional Resources

For more background on SNAP, see Center on Budget and Policy Priorities, “Policy Basics: Introduction to the Supplemental Nutrition Assistance Program (SNAP),” updated June 25, 2019, https://www.cbpp.org/research/policy-basics-introduction-to-the-supplemental-nutrition-assistance-program-snap.

For more resources on NAP, see Center on Budget and Policy Priorities:

• Introduction to Puerto Rico’s Nutrition Assistance Program, https://www.cbpp.org/research/food-assistance/introduction-to-puerto-ricos-nutrition-assistance-program
• The Nutrition Assistance Program Helps Over Half of Puerto Rico’s Children, https://www.cbpp.org/research/food-assistance/the-nutrition-assistance-program-helps-over-half-of-puerto-ricos-children
• Puerto Rico’s Nutrition Assistance Program Helps Seniors, https://www.cbpp.org/research/food-assistance/puerto-ricos-nutrition-assistance-program-helps-seniors

For further detail on the differences between SNAP and NAP, see USDA, “Implementing Supplemental Nutrition Assistance Program in Puerto Rico: A Feasibility Study,” June 2010, https://www.fns.usda.gov/snap/implementing-supplemental-nutrition-assistance-program-puerto-rico-feasibility-study.