Avinash Kumar - Aug 9, 2019

Are meal kits eligible to buy from SNAP benefits?

Meal kit services are not just for wealthy, in fact, they could be the key to curbing hunger and food
insecurity among low-income households. Meal kits in its present format is not ideal for SNAP
recipients, and the industry must undergo a significant transformation in its product offering and
strategy. Today, the average cost of meal stands at approximately $10 per meal per person for
restaurant-quality meal kits. According to the FY2017 Characteristics of USDA Supplemental
Nutrition Assistance Program Households report, the average SNAP household received $245 in
monthly benefits, about 37% of SNAP households received the maximum benefit of $650 for their
family size. Most SNAP households were small with 53% of SNAP households comprised of single
person, and the average SNAP household size comprised of 2 persons (Cronquist & Lauffer, 2019).
Thus, the average cost of meal for SNAP participants stands at approximately $4 per meal per
person. As evident, there is an enormous gap between the current prices of meal kits and the
average food consumption budget of SNAP households. An intensive market research needs to be
carried out to understand the needs, taste and preferences of low-income households. This is a huge
market opportunity for meal kit companies, large and small grocery brands, and restaurants to
diversify their customer base and increase their market share. The fundamental question that stands
here is – Are SNAP recipients eligible to buy meal kits from SNAP benefits?

Food and Nutrition Service (FNS) agency of U.S. Department of Agriculture (USDA) issued a Request for Information for enhancing retail food store eligibility for SNAP authorisation (Federal Register, 2013). This notice requested information from any interested parties on opportunities to enhance retailer definitions and requirements such that it improves the access to healthy food choices for SNAP recipients as well as program integrity, and ensures that only those retailers that further the purpose of SNAP are authorised to accept benefits. The agency put forward 14 questions, with attention to impacts of each on program integrity, healthy food choices, access to food, and retailer operations. An interesting question marginally concerning to meal kits was - How should prepared foods with multiple ingredients, such as chicken pot pie or other frozen dinners, or single serving meat jerky packages, be treated with regards to “staple foods” categories?

FNS in its proposed rule of “Enhancing Retailer Standards in the Supplemental Nutrition Assistance Program (SNAP)” amended the definition of “Staple Foods” – multiple ingredient food items (Federal Register, 2016). The proposed rule excluded multiple ingredient food items from being counted towards any staple food category. However, widespread opposition from various interest groups led to removal of this provision from the final rule. Currently, as per the final rule of “Enhancing Retailer Standards in the Supplemental Nutrition Assistance Program (SNAP)” multiple ingredient food items are assigned to the staple food category of their main ingredient. The policy states that the packaging label may be read to determine the main ingredient in a multiple ingredient food item. The label referenced here is the ingredients list as per the U.S. Department of Health and Human Services (HHS) Food and Drug Administration (FDA) mandated nutritional facts label, where the ingredients are listed in descending order of weight. The first listed ingredient, therefore, makes up the largest share of the food product’s composition.

For example: a product such as frozen pizza, with bread as its listed main ingredient, is considered as a variety in the bread or cereals staple food category; or another product such as canned spicy beef chilli, with tomato puree listed as its main ingredient, is considered as a variety in the fruits or vegetables staple food category. If the main ingredient of a multiple ingredient food item is an accessory food item (e.g., spices, condiments, etc.) then that multiple ingredient food item is considered as accessory food item, and not considered into any staple food categories. However, there is an exception to this accessory food item – water. For example: a product such as canned split peas soup, with water and peas listed as its first and second ingredients, then it is considered as a variety in the fruits or vegetables staple food category. Similarly, meal kits can also be categorised as a variety of staple food category based on the largest ingredient listed on its packaging label. For example: a meal kit for beef bolognese with spinach, with ground beef listed as its main ingredient, will be considered as a variety in meat, poultry or fish staple food category; or a meal kit for roasted chicken with parmesan broccoli, with broccoli listed as its main ingredient, will be considered as a variety in fruits or vegetables staple food category. The existing policy regulations can very well categorize meal kits into one of four staple food categories – (1) meat, poultry or fish; (2) fruits or vegetables; (3) bread or cereals; (4) dairy products. Meal kits are classified in fresh foods (perishable) category rather than “hot foods” prepared for immediate consumption, therefore, no further amendments are needed to make meal kits eligible to buy from SNAP benefits.

References:

  1. Federal Register (2013). Request for Information: Supplemental Nutrition Assistance Program (SNAP) Enhancing Retail Food Store Eligibility. [online] Available at: https://www.federalregister.gov/documents/2013/08/20/2013-20244/request-for-information-supplemental-nutrition-assistance-program-snap-enhancing-retail-food-store
  2. Federal Register (2016). Enhancing Retailer Standards in the Supplemental Nutrition Assistance Program (SNAP). [online] Available at:
    https://www.federalregister.gov/documents/2016/12/15/2016-29837/enhancing-retailer-standards-in-the-supplemental-nutrition-assistance-program-snap
  3. Kathryn Cronquist and Sarah Lauffer (2019). Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2017, U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support. [online] Available at:
    https://www.fns.usda.gov/snap/characteristics-supplemental-nutrition-assistance-program-households-fiscal-year-2017

Written by Avinash Kumar