The U.S. Department of Agriculture recently proposed a rule that would that would restrict states’ flexibility to broaden eligibility for the Supplemental Nutrition Assistance Program (SNAP). Recognizing the negative impact of the proposed policy on millions of working families, seniors, and people with disabilities, NYSHealth submitted the following comments urging that the rule not be implemented:

September 12, 2019

The Honorable Sonny Perdue
Secretary
U.S. Department of Agriculture
1400 Independence Ave., SW
Washington, DC 20250

RE:  USDA ID: FNS-2018-0037-0001; Proposed Rule on Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program

Dear Secretary Perdue:

The New York State Health Foundation (NYSHealth) appreciates the opportunity to respond to the U.S. Department of Agriculture’s (USDA) Notice of Proposed Rulemaking regarding broad-based categorical eligibility for the Supplemental Nutrition Assistance Program (SNAP), published in the Federal Register on July 24, 2019. The proposal would restrict state flexibility to broaden SNAP eligibility by relaxing asset limits and using higher income eligibility thresholds.

NYSHealth believes that these changes would cause serious harm to millions of working families, seniors, and people with disabilities. We urge that the proposed rule be withdrawn.

SNAP has helped tens of millions of low-income Americans put food on their tables every year for more than 60 years. SNAP is indisputably among the most effective federal programs to combat food insecurity; it helps millions of Americans each year to stay above the poverty level.[1] Throughout its history, SNAP has also been critical in supporting national, state, and local governments in responding to unexpected food insecurity, such as in times of economic recession and major natural disasters. The proposed changes would severely undermine the program’s effectiveness.

NYSHealth is a private foundation that works to improve the health of all New Yorkers, especially the most vulnerable. Our program called Building Healthy Communities supports expanded access to and demand for nutritious, affordable foods, including nutrition incentive programs that encourage SNAP use. Our work has provided us with in-depth knowledge of how food insecurity has widespread negative ramifications on the health and well-being of not only individuals and their families, but also local and national economies.

New York is one of 40 states that effectively uses the current policy of Broad-Based Categorical Eligibility, which allows states to eliminate the SNAP asset test and to use an income eligibility threshold higher than 130% of the federal poverty level (which currently equates to $2,252 a month, or $27,020 annually, for a family of three). This current policy enables more working families, families with children, seniors, and people with disabilities who have significant housing and dependent care expenses to qualify for SNAP. More than 206,000 New Yorkers could immediately lose eligibility for SNAP if this flexibility were lost.[2]

The current policy allows families, seniors, and people with disabilities with incomes just above the SNAP income threshold to maintain modest savings without losing SNAP food assistance; it also makes it easier and more cost effective to administer SNAP in our state.[3] Building modest assets allows low-income families to avoid accumulating debt and to be better prepared financially for retirement or unforeseen events that would otherwise push them deeper into poverty.[4]

A growing body of evidence links food insecurity with a number of negative health outcomes, including diet-related diseases and other chronic physical health conditions; psychological and behavioral health issues; and higher health care costs. When those struggling with food insecurity have to decide between buying nutritious, high-quality food and paying for housing, health care, transportation, or other bills, many have no choice but to eat low-cost, low-nutrition foods, or eat nothing at all. A survey revealed that 84% of households served by Feeding America, the nation’s largest network of food banks, report buying the cheapest food available in order to provide themselves and their families with enough to eat.[5]

The proposed rule would cause severe harm to children. One in six school-age children suffer from food insecurity, and many of these children get their only meals of the day at school through reduced-price and free school lunch programs. The proposed rule could potentially take away free school lunch from 265,000 children nationwide, as students in families receiving SNAP benefits are automatically eligible for free lunch.[6] Hungry children are proven to have difficulties learning and concentrating in school, and often suffer from social and behavioral problems. Problems in early childhood development associated with hunger and food insecurity often have devastating lifelong effects on a child’s ability to grow and thrive later in life.

It is also important to note the positive economic impact that SNAP spending promotes, and the ripple effect that this proposed rule would have on the economy at the local, regional, and national levels. The USDA’s Economic Research Service (ERS) has found that SNAP spending generates $1.54 in local spending per every SNAP dollar spent. That is, ERS estimates “an increase of $1 billion in SNAP benefits in a slowing economy increases GDP by $1.54 billion and supports 13,560 additional jobs, including nearly 500 agricultural jobs (farming, forestry, fishing, and hunting).”[7] A decrease in the amount of SNAP dollars circulating in communities would reduce revenues at grocery stores and other retailers, with negative effects rippling throughout our local and national food systems.

The Administration asserts that broad-based categorical eligibility has reduced public confidence that benefits are being provided to those who are eligible and need those benefits. The facts say otherwise. A Congressional Research Service report found that in FY2016, a monthly average of 85% of SNAP recipients fell below the federal poverty line, with more than 95% having income less than or equal to 130% of the federal poverty line.[8] According to USDA’s own data, only about 0.2% of SNAP benefits in 2017 went to households above the poverty line.[9] The reality is that SNAP has some of the most rigorous program integrity standards and systems of any federal program.

The proposed rule would eliminate SNAP benefits for 3.1 million individuals, take free school meals away from children, and punish working families with too little income to afford a nutritionally adequate diet. By USDA’s own estimates, the proposed rule would cut SNAP benefits over five years by $10.543 billion, while increasing SNAP administrative costs by $2.314 billion[10]—placing increased time, effort, and cost burdens on both states and SNAP applicants. Furthermore, the USDA concedes that the proposed rule would negatively impact food security and reduce the savings rates among those individuals who would no longer be SNAP eligible, and that households with one or more elderly members would be disproportionately affected. The USDA also estimates that more than 7% of SNAP households with children would no longer be eligible. The Administration’s own analyses demonstrate the negative consequences of the proposed rule.

The New York State Health Foundation strongly opposes the proposed rule, which would cut food benefits for struggling people, take food out of hungry Americans’ mouths, and cause harm to our communities and economy.

Respectfully submitted,

David Sandman, Ph.D.
President and CEO
New York State Health Foundation


[1] United States Census Bureau. “The Supplemental Poverty Measure: 2017.” September 12, 2018. https://www.census.gov/library/publications/2018/demo/p60-265.html, accessed September 2019.

[2] Mathematica Policy Research. “State-by-State Impact of Proposed Changes to ‘Broad-Based Categorical Eligibility’ in SNAP.” https://www.mathematica-mpr.com/dataviz/impact-of-bbce-proposal-on-snap-caseloads, accessed September 2019.

[3] Hunger Solutions New York. “Proposed Elimination of SNAP Categorical Eligibility.” https://hungersolutionsny.org/snap-policy/snap-cat-el-rule/, accessed September 2019.

[4] Greenstein, R. “Misguided Trump Administration Rule Would Take Basic Food Assistance From Working Families, Seniors, and People With Disabilities.” Center on Budget and Policy Priorities. July 23, 2019. https://www.cbpp.org/press/statements/misguided-trump-administration-rule-would-take-basic-food-assistance-from-working, accessed September 2019.

[5] Feeding America. What happens when a child faces hunger? https://www.feedingamerica.org/hunger-in-america/child-hunger-facts, accessed September 2019.

[6] Brown, H. “Trump administration proposal would remove 3.1 million from food stamps.” The New Food Economy. July 23, 2019. https://newfoodeconomy.org/trump-administration-food-stamps-snap-usda-perdue/, accessed September 2019.

[7] United States Department of Agriculture. “Supplemental Nutrition Assistance Program (SNAP) Linkages with the General Economy.” Updated August 20, 2019. https://www.ers.usda.gov/topics/food-nutrition-assistance/supplemental-nutrition-assistance-program-snap/economic-linkages/, accessed September 2019.

[8] Congressional Research Service. “The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility.” Updated August 2, 2019. https://fas.org/sgp/crs/misc/R42054.pdf, accessed September 2019.

[9] Greenstein, R. “Misguided Trump Administration Rule Would Take Basic Food Assistance From Working Families, Seniors, and People With Disabilities.” Center on Budget and Policy Priorities. July 23, 2019. https://www.cbpp.org/press/statements/misguided-trump-administration-rule-would-take-basic-food-assistance-from-working, accessed September 2019.

[10] Congressional Research Service. “The Supplemental Nutrition Assistance Program (SNAP): Categorical Eligibility.” Updated August 2, 2019. https://fas.org/sgp/crs/misc/R42054.pdf, accessed September 2019.

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