Three proposed rule changes by the Trump administration could cause millions of poor people to lose access to food stamps and decrease the size of the benefit for millions more, a new study has found.

Over the past year, the Department of Agriculture proposed three changes to the Supplemental Nutrition Assistance Program, known as SNAP or food stamps. The new rules create stricter work requirements for program eligibility, cap deductions for utility allowances and “reform” the way 40 states automatically enroll families into SNAP when they receive other forms of federal aid.

A study by the Urban Institute released this week examined the three rules in combination for the first time and found that 3.7 million fewer people would receive SNAP in an average month, 2.2 million households would see their average monthly benefits drop by $127, more than 3 million others would see an average drop of $37 per month, and 982,000 students would lose access to free or reduced lunches.

“What we found is that overall the three proposed changes would reduce the number of households participating in SNAP by about 11 percent if this was implemented in 2018," said Laura Wheaton, a senior fellow at the Urban Institute who conducted the study. "It’s about a 9.4 percent reduction in the number of people participating and about an 8 percent reduction in overall benefits.”

Critics and experts say that would be antithetical to the program's goals to address food insecurity in the United States.

Craig Gundersen, an agricultural and consumer economics professor at the University of Illinois at Urbana-Champaign, who has studied the program for more than two decades, said that about a million people could become food-insecure because of the change. He added that 50 percent of those 3.7 million SNAP beneficiaries were already food insecure despite the assistance.

The changes, he said, would put many Americans in a worse position, increasing hunger and health issues. Each additional adult who becomes food-insecure sees an additional $2,000 in healthcare costs, Gundersen explained.

"The essential goal of the program is to mitigate hunger and its consequences in the United States,” he said. "Anything that impedes SNAP of doing that is very problematic as it leads to food insecurity in our country."

The USDA, meanwhile, estimates that the changes would reduce the SNAP budget by about $4.2 billion.

Secretary of Agriculture Sonny Perdue defended the work requirements in a USA Today column, emphasizing that it would save taxpayer dollars.

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“At USDA, our informal motto is ‘Do Right and Feed Everyone,’” Perdue wrote. “With these proposed improvements, we will ‘do right’ by the taxpayers and restore the dignity of work to the able-bodied who receive SNAP benefits. And, we will ‘feed everyone’ by ensuring the health and stability of SNAP for those who truly need it.”

All of the new rules have gone through a comment period with the changes to utilities currently taking feedback until Monday. Tens of thousands of people have already responded, with most providing negative responses.

The latest rule change proposed by the Trump administration would cause millions of people to take smaller deductions for shelter and utility costs, which are considered when a person applies for SNAP benefits. Critics say that would force people to choose between buying food and paying for housing.

Gundersen said this change will prove to be a major cost for those living in metropolitan areas with high living costs.

It could also create a steeper financial cliff for some beneficiaries. Those in danger of losing access to SNAP might be discouraged from working because the new calculation would put them in a higher income bracket, causing them to lose access, Gundersen explained

Harlem residents choose free groceries at the Food Bank For New York City in 2013. John Moore / Getty Images file

“On the one hand they want to encourage people to work, but on the other they would be taking away that incentive,” Gundersen said.

But the main issue is that SNAP is not intended to be a work program in the first place, Gundersen said, but is instead intended to address food insecurity within the United States.

As it operates now, SNAP does not discourage people from participating in the labor market, he said.

"There are some assistance programs that do discourage people to work, but this is not one of them," Gundersen said, adding that what lawmakers should be asking is: "What makes this program work so well and why does it work well as compared to other programs?"

These new rules also have advocates in states like Nevada worried. Nevada could see up to 22 percent of recipients lose access to food stamps, which could be devastating in a place where 12.3 percent of households face food insecurity, according to the USDA.

“SNAP is related to hunger and getting people the nutrition they need,” said Jocelyn Lantrip, the communications director at Food Bank of Northern Nevada. “Food shouldn’t be a luxury.”

With a tech boom raising income levels but not enough to cover rising housing costs, Lantrip said that these changes could create further food insecurity issues, which remain close to the levels that the Food Bank of Northern Nevada saw during the recession.

At the height of the recession, Lantrip said her food bank helped 103,000 people per month. Now, during a period of perceived economic stability, she said they are helping 91,000.

Food banks like hers wouldn’t be able to accommodate for the needs of an additional 196,000 people, which is the number in Nevada who would likely need help accessing food if these rules were to go into effect, Lantrip said.

“That’s really hard for food banks to keep up with if you have that kind of decline in benefits,” she said. “We support people if they fall outside of the safety net, but we can’t replace the safety net as a food bank. We’re spinning our wheels already, because when unemployment is low people assume hunger is low, but we’re just helping more working poor than before.”