PUMP opposes the USDA’s proposed revision of broad based categorical eligibility in the Supplemental Nutrition Access Program, because it would deny an estimated 3 million people in the United States access to SNAP. On September 23rd, PUMP submitted an official comment to the USDA opposing the proposed rule change and asking that it be withdrawn.
The USDA’s 60-day public comment period on this rule closed on September 23rd. Review the proposed rule and comments here.
Read the comment PUMP submitted to the USDA below.
September 23, 2019
SNAP Program Design Branch,
Program Development Division
Food and Nutrition Service
3101 Park Center Drive
U.S. Department of Agriculture
Alexandria, VA 22302
Dear Secretary Perdue and SNAP Program Design Branch:
On behalf of PUMP, a 501(c)3 nonprofit in Pittsburgh, Pennsylvania, we appreciate the opportunity to comment on USDA’s Notice of Proposed Rule Making on a Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP). We submit this letter in opposition to the proposed rule and ask that it be withdrawn.
Founded in 1996, PUMP’s mission is to make the Pittsburgh region the most dynamic and diverse place by engaging, educating, and mobilizing all young people to create change in our community. Each year, we serve nearly 30,000 individuals, primarily under the age of 40, through our advocacy, civic, and social programming.
In 2017, our constituents helped design our advocacy and public policy agenda, which reflects our vision for regional equity and includes a focus on efforts that support equitable access to health and wellness, as well as equitable opportunities, for everyone. We believe that everyone should have access to affordable, healthy food, because it is essential for the wellbeing and success of people and families.
The proposed rule change would take essential SNAP benefits away from over 3 million Americans by enforcing stricter income and asset requirements. The lower income limits will particularly hurt older adults (age 60+), people with disabilities, and working families. Pennsylvania’s Department of Human Services estimates that 200,580 people in Pennsylvania, including 83,789 households with elderly or disabled individuals and 22,588 households with kids, would no longer qualify for SNAP under this rule. In Allegheny County, an estimated 16,577 people (11.3% of SNAP recipients) would lose their benefits. Our region is striving to end food insecurity – how can we do this if the federal government chooses to abdicate its responsibility to low-income Americans?
The stated goal of this rule change, according to the USDA, is to ensure SNAP is a “temporary safety net” (1). Yet, denying SNAP working families runs counterproductive to this goal. The USDA’s own estimates show that “the proposed rule may also negatively impact food security and reduce the savings rates among those individuals who do not meet the income and resource eligibility requirements for SNAP or the substantial and ongoing requirements for expanded categorical eligibility” (2).
Because of the high cost of childcare and housing, families may still not be able to meet their basic needs even if they have an income that exceeds the proposed gross income limit of 130% of the federal poverty line. They may be less able to save money for homes or retirement. Some may even choose to work less in order to qualify for SNAP and avoid the “benefits cliff,” which describes what many low-income people experience when their income increases enough to disqualify them from benefit programs but not enough to make up the difference (3).
Families simply cannot achieve long-term financial independence if they are not even able to put food on the table for their kids.
The proposed rule would also impact kids who depend on free school meals. Kids who qualify for SNAP are automatically qualified to receive free school meals. Under this proposal, families who lose access to SNAP will need to apply separately for school meals, creating additional administrative burdens for families and school districts. It is estimated that 500,000 children nationally are at risk of losing access to free school meals, according to the Food Research & Action Center (4).
Beyond the impacts on the day-to-day lives of Americans described above, removing people from SNAP will be detrimental to our economy. Based on research from the Center on Budget and Policy Priorities, it is estimated that $9 of economic activity is generated by every $5 in SNAP (5). The Pennsylvania Department of Human Services estimates that our economy would lose $100-125 million per year in SNAP benefits under this rule. This loss of economic activity would harm local businesses and, in turn, their employees.
Broad-Based Categorical Eligibility is an important policy option that empowers states to make the best decision for their residents and communities. In Pennsylvania, this option has allowed us to support some of our most vulnerable residents, especially older adults, children, and people with disabilities. Implementing this rule in Pennsylvania would require additional paperwork and bureaucracy, creating more barriers for those trying to access benefits as well as additional costs for the Commonwealth.
Ultimately, any savings the USDA anticipates from this rule change would be offset by the enormous cost to the livelihoods of millions of Americans who depend on SNAP to feed themselves and their families. We believe that investing in community members, especially children, is essential to ensuring that our region can thrive now and in the future.
We strongly oppose the proposed rule that would harm people in Pittsburgh, Allegheny County, Pennsylvania, and throughout the United States. Thank you for your time and consideration.
(1) Washington Post, Trump proposal would push 3 million Americans off food stamps
(2) United States Department of Agriculture, Regulatory Impact Analysis 7 CFR 273; Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)
(3) Center on Budget and Policy Priorities, SNAP’s “Broad-Based Categorical Eligibility” Supports Working Families and Those Saving for the Future
(4) Food Research and Action Center, Broad-based Categorical Eligibility and School Meals
(5) Center on Budget and Policy Priorities, SNAP Boosts Retailers and Local Economies