Recently, the National Academies of Sciences, Engineering, and Medicine (NASEM) made a public request for input on federal policies that contribute to racial and ethnic health inequities and potential solutions. For CSPI, the opportunity was welcome; we have invested significant resources in internal reform and thinking through how to develop more equity-centered public policies. We acknowledge that racial and ethnic health inequities, or more pointedly, health disparities, are created and maintained through complex systems that perpetuate disadvantages for some.

The inequities addressed in our comments are not the result of linear causal pathways that can be solved by a single intervention. Hence, our recommendations highlighted a small number of policies that cause particular harm, but do not represent an exhaustive list. We identified the following opportunities to enhance the federal government's efforts to reduce racial and ethnic health inequities:

  • Purchasing Power for Nutritious Foods - increasing Supplemental Nutrition Assistance Program (SNAP) purchasing power and expanding program eligibility would ensure that all people in the US can obtain a nutritious diet.
  • Work Restrictions - SNAP benefits are cut off after just three months for able-bodied adults without dependents (ABAWDs) unless they work at least 20 hours per week. The time limit disproportionately impacts non-Hispanic Black and Hispanic adults and has not been found to increase employment.
  • College Student Food Insecurity - The December 2020 COVID-19 stimulus package expanded college student eligibility for SNAP to full-time students eligible for federal work-study and to students with an expected family contribution of $0. A more accessible, equitable SNAP would make this expansion permanent.
  • Felony Drug Conviction SNAP Ban – A law from the 1990s placed a lifetime SNAP ban on people who have been convicted of a drug felony. While states can waive or modify this law, many states still impose some level of restriction. A full reversal of this law at the Federal level can ensure that more families, especially Black and Latino families, have equitable access to the program.
  • US Territories – While states use SNAP, a program that automatically expands during economic downturns, some US territories use the Nutrition Assistance Program (NAP), which is a block grant with limited funds. Administrators in NAP-funded territories—American Samoa, the Northern Mariana Islands, and Puerto Rico—should have the opportunity to transition to SNAP to increase food security and economic stability. Federal policies can further allow for flexibility guided by each territory’s administration, such as allowing for local and culturally appropriate food-purchasing requirements.
  • Fair Labor Standards Act and Farmer Exclusions - According to the National Agricultural Workers Survey (NAWS), most farmworkers are Latine/Hispanic (78%), and 10% of farmworkers identify as Indigenous. Yet, these essential workers are exempt from the minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA). Given the demographics of the agricultural workforce, failure to support pay equity and a safe working environment perpetuates racial and ethnic health disparities.

CSPI appreciates the National Academies’ efforts to identify and address federal policies that contribute to racial and ethnic health inequities, and we look forward to supporting future policies and programs that apply a racial equity lens in tackling health disparities.