For example, in March 1998, Pennsylvania received approval for waivers for Fulton and Sullivan Counties, based on the 24-month period from January 1996 through December 1997. Similarly, in December 1997, Illinois received a waiver for several counties, cities, and smaller communities based on the 24-month period from September 1995 through August 1997. In creating its LSA list, DOL calculates unemployment rates for all counties and for all cities with populations of at least 25,000. Where there are partial-county LSAs, the entire county may meet the LSA definition if the county as a whole is examined. This often occurs when one or more cities in the county are LSAs and these cities are big enough that their labor conditions have a large influence on the county as a whole.
States can apply for a waiver for the entire county in such cases.
Since states generally administer the food stamp program by county, they may find county-wide waivers more administratively practical. In addition, since local labor markets typically include both cities and their surrounding suburbs, measuring labor market conditions for the county as a whole may provide a more accurate representation of job prospects for residents than a measurement just of the areas of the county that lie outside the city boundaries. In March 1997 guidance, FNS described two sets of criteria it considers in approving waivers of this type. FNS has approved several waiver applications on this basis. It approved a Florida request for a waiver for several full counties that included both areas that were on the DOL list and areas that were not.