Food Policy Action Education Fund Formal Comments on SNAP Rule Change



Food Policy Action Education Fund (FPAEF) appreciates the opportunity to submit comments in response to the proposed revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP). FPAEF is a national organization that works to change farm and food policies to balance our food system in order to provide healthy, safe, and affordable food for everyone. National and local anti-hunger groups are key partners in our efforts to ensure that federal anti-hunger programs effectively reach the millions of Americans who need help putting food on their table.

FPAEF opposes the administration’s proposed rule to eliminate the broad-based categorical eligibility option for states.  This change would have devastating results for an estimated 3 million people, making them ineligible for SNAP, according to USDA’s own analysis. Your own report states that households with incomes slightly over the poverty level, regardless of skyrocketing housing and childcare expenses, would become “not poor enough” to receive the help they need to feed their families. Older adults would be forced to tap into and use up even modest amounts of savings before getting help to stave off hunger. USDA Secretary Purdue’s staff stated to Members of Congress that 500,000 school-age children could lose access to school meal programs if their families become ineligible for SNAP.

The results of this proposed rule are far-reaching and do not only impact hungry individuals.

  • Schools in low-income areas could lose their ability to serve universal free breakfast and lunch programs due to the change in students’ SNAP eligibility. Staff will have to spend more time filling out paperwork to certify low-income kids to receive food assistance instead of focusing on building a healthy foundation for education.
  • Seniors and people with disabilities who survive on a fixed income will be at greater risk of hunger as a result of this proposed rule and, as a result, would face increased health challenges and health care costs.
  • Finally, this position not cost effective for local communities. Every SNAP dollar stimulates between $1.50 and $.180 in economic activity. The local food retailers, farmers, and economies that benefit from SNAP spending, particularly during economic downturns, will suffer sending negative ripple effects through the whole sector.

Food Policy Action Education Fund closely followed the passage of the 2018 Farm Bill and watched as Congress specifically rejected this exact change to broad-based categorical eligibility. The U.S. Department of Agriculture should not subvert Congressional intent for this crucial anti-hunger program. We urge you to listen to the state agencies, case workers, food retailers, and front-line food pantries who oppose this rule.



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