[The Food Stamp Act: Section 18(a)(2)]

In response to a congressional request, GAO reviewed the interpretation and implementation of section 18(a)(2) of the Food Stamp Act and made a suggestion as to how the statute could be improved by amendment. The section prohibits the use of federal funds to interfere with or impede the implementation of the provisions of the act, including the provisions authorizing workfare projects. Congress intended to prohibit the use of federal funds for the support of certain kinds of obstructive activities. Some federally supported activities were permitted even though they could, at times, hinder the implementation and smooth operation of the workfare program. These activities included: data collection, information analysis, advising and representing clients whose interests might be adverse to the workfare program, and assisting clients in the exercise of their First Amendment rights as the concern the program. Prohibited activities included: counseling clients to commit or threaten acts of violence against the program, and intimidating officials to try and terminate a workfare project. GAO has found that the lobbying activities of a legal services corporation were not in violation of the Food Stamp Act, while they were in violation of the antilobbying provisions of the Legal Services Act. GAO has found other activities to be somewhat disruptive but involving merely aggressive advocacy by recipients on the part of their respective clientele. The section has not been made the subject of implementing regulations. GAO believes that compliance could be better assured if implementing regulations specified the limits on permitted activities. If the noninterference provision is amended, GAO recommended that activities which Congress decides to prohibit be explicitly listed in the statute.