If I Ran the Nevada Health Authority... We Would Stop Experimenting on Poor People

A Rural Health Transformation Program Deep Dive You Did Not Ask For, But Absolutely Need

By: Matt Brandenburg, OTD, OTR/L

If you’ve been following the NVHA’s Rural Health Transformation (RHT) Program as intensely as I have, we should hang out. If you’re new to the game, the program outlines Nevada’s plan to revitalize rural health in the state with $180 million in federal funds. The proposal has become my late-night obsession. The kind where you tell yourself “I’ll just read one more page” and suddenly it’s 2 a.m. and you’re cross-referencing USDA policy memos like you’re prepping for a finale of The Amazing Race: Bureaucracy Edition.

And in the middle of my late-night RHT document spelunking (NVHA Application, Summary and Narratives linked for your spelunking here), somewhere between the “federal expectations” and the “state policy actions”, I hit Section B.3: SNAP (Supplemental Nutrition Assistance Program) Waivers and nearly fell out of my chair.

Here it is, in the Nevada Health Authority’s own words:

“Nevada has prepared a USDA SNAP Food Restriction Waiver that prohibits the purchase of non-nutritious items and plans to submit this waiver, with Nevada Governor support, to USDA on or before October 31, 2025. This proposed regulatory action will lower healthcare costs in rural communities by decreasing diet-related diseases, easing pressure on limited medical infrastructure, and promoting long-term public health.”

No details. No citation. No justification. No transparency. No community voice.

Just: “Let’s lower healthcare costs by restricting what poor people can buy at the grocery store.”

My immediate reaction?

Certainly, there is a better way to lower healthcare costs, decrease diet-related diseases, and promote long-term public health. And certainly, there are policies and protections in place that allow for public comment and approval before drastically altering SNAP… right?

️ ️ Let’s Talk About SNAP and Dignity

The first food stamp program in the United States was implemented in 1939. There have been many updates to the program since its inception, but the purpose has stayed true to the definition provided by thecongressional declaration of policy in the Food, Conservation, and Energy Act of 2008: “to alleviate hunger and malnutrition, a supplemental nutrition assistance program is herein authorized which will permit low-income households to obtain a more nutritious diet through normal channels of trade by increasing food purchasing power for all eligible households who apply for participation”

SNAP is not a luxury. It is not a dietary boot camp. It is not a public-health science fair where the government gets to “pilot” new restrictions on food choice like America’s most vulnerable families are test subjects in an IRB-free laboratory.

SNAP exists for one reason: so people can eat.

Roughly42 million Americans, includinglow-income workers, children, older adults, and people with disabilities rely on SNAP. In Nevada, over 505,500 people participated in the program last year. 10.4% of rural Nevadan families rely on SNAP not because they “make bad choices” but because wages here don’t match the cost of living andhealthy food access is geographically limited.

The new food restriction waivers (that have been approved by 12 states already!) shift SNAP from an antihunger income support program to a dietary health experiment through new nutrition standards limiting the foods and beverages covered by benefits.

The American Journal of Public Health warns that “The Imposing nutritional restrictions will interfere with the primary function of SNAP—reducing hunger by increasing purchasing power—without addressing the root causes of chronic disease disparities.” 

AJPH sums it up stating “SNAP restrictions reduce autonomy and ignore the root causes of health disparities while critiquing the purchasing and dietary decisions of low-income individuals seeking support for hunger.”

If only there was a profession with history ofadvocating for vulnerable populations, a research base shown toimprove health and well-being for people with chronic conditions (and evenreverse certain chronic diseases), and a workforce willing to mobilize in support of improving health access, equity, and outcomes for Nevadans...

Despite the lack of recognition occupational therapy receives in health initiatives I know we’re not the only medical professionals who care. But while reading approved SNAP restriction waivers I couldn’t stop asking myself, “Did an actual clinician approve this?”

When you dig into USDA’s own documents and the public-health literature (rather than the political press releases) a consistent story emerges: policing poor people’s grocery carts does not deliver the health gains that incentive programs have shown, and restrictions reliably ramp up shame and barriers. In fact, there is robust evidence that SNAP restrictions

• Do not improve population health

• Do not reduce obesity or Diabetes rates

• Do not reduce healthcare spending

• Do not change long-term dietary patterns

• Do increase shame, Stigma, and Food access barriers

If this were a public-health intervention being proposed for any other population, conclusions would be: there is weak or speculative evidence of benefit, clear evidence of harm through stigma and access barriers, and strong alternative strategies with far better evidence already exist. 

If this were a research study submitted through a scientific institution, it would:

• Fail IRB review

• Violate principles of informed consent

• Target a vulnerable population with no safeguards

• Be flagged as unethical within 30 seconds

Tuskegee exists to prevent exactly this type of coercive “public health experiment.”
Yet here we are proposing to roll it out statewide.

 Let’s Look at What Other States Are Doing With their SNAP Restriction Waivers

Twelve states have already had food-restriction waivers approved. While most states are satisfied with prohibiting candy and soda (stealing candy from babies), Iowa displays a grinchy greed that redefines “food” for SNAP users as “all nontaxable items,” which is a fancy bureaucratic way of saying: “You can buy whatever the Iowa Department of Revenue thinks you deserve.”

Here is a copy and pasted list of what they prohibit:

Food Items:

• Seeds for food producing plants and food producing plants

• Candy, candy-coated items, and candy products, including gum, candy primarily intended for decorating baked goods, and hard or soft candies including jelly beans, taffy, licorice, and mints and breath mints.

• Dried fruit leathers or other similar products prepared with natural or artificial sweeteners

• Sweetened baking chocolate in bars, pieces, or chips

• Fruits, nuts, or other ingredients in combination with sugar, chocolate, honey, or other natural or artificial sweeteners in the form of bars, drops, or pieces

• Caramel wraps, caramel or other candy-coated apples or other fruit; sweetened coconut, marshmallows; Granola bars, unless they contain flour.

• Mixes of candy pieces, dried fruits, nuts, and similar items when candy is more than an incidental ingredient in the product

• Ready-to-eat caramel corn, kettle corn, and other candy-coated popcorn

Beverages:

• Carbonated and noncarbonated soft drinks, including but not limited to colas, ginger ale, near-beer, root beer, lemonade, orangeade

•  All other drinks or punches with natural fruit or vegetable juice which contain 50 percent or less by volume natural fruit or vegetable juice; a typical example is Hi-C

• Beverage mixes and ingredients intended to be made into taxable beverages; liquid or frozen, concentrated or non-concentrated, dehydrated, powdered, granulated, sweetened or unsweetened, seasoned or unseasoned

• Concentrates intended to be made into beverages which contain 50% or less by volume natural fruit or vegetable juice

• Sweetened naturally or artificially sweetened water

This list is massive. Sure, most of the food items and beverages aren’t “healthy”, but the fact that this waiver is approved with no proposed alternatives to these products, no price protections to make healthier items more affordable, no penalties for the manufacturers of cheap and unhealthy products, no community supports or initiatives to improve health behaviors, and no public comment or input makes me wonder if Dr. Evil runs the Iowa Health Authority.

 This Isn’t Health Promotion. It’s Health Coercion

And it sets a precedent we should all be terrified of:

If the government can prohibit a low-income family from buying a soda or a birthday cake for their child today…

…what can they prohibit tomorrow?

Choice used to be an American value. Now we’re treating it like a privilege for the wealthy.

One SNAP user,

Natalie Kiyah, told NPR:

“The more choice I have, the more dignity I feel.”

Dignity is not a “nice to have.”
It directly affects health behaviors, mental health, family participation, and community belonging.

Where Was This in the Public Presentations?

Here’s what terrifies me most as a Nevada resident, healthcare provider, and RHT enthusiast:

This was not transparently shared with the public.

It wasn’t on the slide deck.
It wasn’t in the public-facing webinars.
It wasn’t highlighted in stakeholder meetings.

It was buried on page 18 of the NVHA application that was sent to CMS with no public review and no opportunity for accountability.

Remember in November (ironically just days after this RHT application was submitted by the NVHA) when state senatorsUNANIMOUSLY voted to extend and protect SNAP benefits through a state-supported public assistance program? What do our senators think now that we’re doing the exact opposite while calling it “rural health improvement”?

Someone needs to explain this. Preferably before re-election season.

The Part Where I Reveal the Inconvenient Truth

Despite how important, spicy, and perhaps enraging this blog is…

I do not run the NVHA.
Neither do you.
Neither do the rural Nevadans whose grocery carts are about to be policed by federal demonstration projects.

CALL TO ACTION: Nevada Deserves Transparency, Ethics, and Community Voice

But what if I did run the NVHA?
I wouldn’t need to experiment on poor people to improve health outcomes.

I’d build with communities, not on them.
I’d fund empowerment, not enforcement.
And I’d put occupational therapy providers, public health professionals, and community members at the same table BEFORE submitting policies that affect how families feed themselves. I would:

1. Withdraw the SNAP food-restriction waiver immediately.

2. Release all details publicly, with citations and evidence.

3. Hold statewide listening sessions with rural communities.

4. Invite SNAP recipients, OT practitioners, physicians, dietitians, social workers, universities, state associations, and additional healthcare pros to co-design alternatives and supplements.

5. Request an ACLU review of any policy restricting lawful access to food.

6. Enshrine protections preventing future coercive health policy experiments on vulnerable populations.

7. MakeJoel Berg’s How Hungry is America required reading for everyone in the office

If the Nevada Health Authority and Joe Lombardo’s Office Actually Want Rural Health to Improve…

…they could invest in things that actually work:

• Nutrition education led by trusted community agents
• Community gardens and mobile markets
• Food desert innovation and grocery access expansion
• Subsidies for healthy food producers
• Penalties for ultra-processed food manufacturers (hey, Big Food, we see you and we know your tactics)
• OT-led kitchen skills programs, sensory-friendly cooking classes, and chronic disease self-management groups
• Family meal events where recipes are shared and culture is honored
• Expanded child tax credit (shown to improve healthy food purchasing)

And here’s my personal favorite action they could take:

• Stop treating low-income families as the problem and treat them as partners.

Nevada deserves better than policy experiments disguised as public health.

Nevada deserves dignity.
Nevada deserves autonomy.
Nevada deserves ethical governance.

Occupational Therapy Has Known This for Decades

Nevada OTP work every day with:

• rural families

• older adults

• individuals with chronic conditions

• people living in poverty

• people navigating food insecurity

• people living in food deserts

• individuals with limited transportation and access

We do not coerce behavior change.

We empower it.

We do not restrict participation.

We expand it.

We do not shame people into “better health.”

We build capacity, teach skills, and cultivate community supports.

And we always include the individual’s lived experience as the center of the plan.

This SNAP waiver does the opposite. 

-Matt Brandenburg

OT, Advocate, Professional Buzzkill to Bad Policy

Still Not Running the NVHA

Absolutely Running My Mouth Until This Gets Fixed