Foodlink, the regional food bank based in Rochester, NY, strongly opposes the USDA’s proposed rule (RIN 0584-AE62) to revise regulations related to Broad-Based Categorical Eligibility (BBCE) requirements for the Supplemental Nutrition Assistance Program (SNAP).

Our federal government should seek ways to reduce barriers for low-income Americans who are struggling to feed themselves and their families. This proposal does the opposite.

SUBMIT A COMMENT: Visit Regulations.gov

We ask that you consider the benefits and true intention of BBCE before revising it and jeopardizing 3.1 million Americans’ access to SNAP – one of the country’s most successful anti-poverty programs that, until recent years, gained support from both sides of the aisle. In New York alone, more than 87,000 people would lose SNAP solely based on income limits[i]. Many more would lose benefits due to the re-imposition of an assets test. The end result will be increased food insecurity and more families living in poverty.

There are several attributes about BBCE that have gained bipartisan support for decades. To cite a few examples, BBCE:

Encourages work and upward mobility. The working poor depend on SNAP to make ends meet. When an individual receives a modest pay increase and moves above the threshold for SNAP eligibility (130% of the poverty line), BBCE prevents that household from seeing a net decrease in funds due to what’s called the “benefits cliff.” Rather than eliminating SNAP for these hard-working individuals, BBCE reduces SNAP incrementally until the household achieves financial stability.

Helps families avoid disaster when sudden hardships arise. SNAP imposes asset limits on households enrolled in the program, meaning recipients often have little savings to guard against unexpected financial setbacks, such as medical bills or natural disaster. Rather than forcing families to spend down assets to qualify for SNAP, BBCE allows families to save money, and protect themselves against a sudden expense. Often times, when these hardships arise, the food budget is sacrificed.

Reduces administrative costs for safety-net programs. According to a comprehensive study by Mathematica Policy Research, only 3 percent of all SNAP individuals would be income ineligible if noncash BBCE were eliminated. So rather than “close the loophole” for the 3 percent, the administration is also penalizing the other 97 percent of individuals who would otherwise qualify for SNAP, resulting in additional paperwork, time and expense. In addition, losing SNAP also would require some families to reapply for free school meals – another unnecessary, bureaucratic barrier for food-insecure families. This could affect 500,000 children nationally[ii]. We don’t need our most vulnerable children falling through the cracks unnecessarily due to administrative barriers to accessing food assistance.

As one of 200 food banks in the Feeding America network, we know first-hand that charity alone cannot solve hunger in the United States. SNAP provides nearly 10 times the meals that our network of 60,000+ food pantries and meal programs provides to Americans on a daily basis[iii]. Our network could not withstand such a devastating cut to SNAP.

We ask that you also consider the true cost of this proposal. The $2.5 billion in annual programmatic savings the administration is expected to see likely doesn’t consider the cost of increasing food insecurity and poverty across the nation. Food-insecure children don’t perform well in school and are less likely to graduate. Food-insecure adults and seniors are more likely to incur higher health care costs related to diet-related illness. Yes, SNAP savings will be achieved, but the health and well-being of our communities will suffer.

Furthermore, dismantling this program will be costly for the 40 states that have adopted it. To quote the Urban Institute’s Elaine Waxman, who gave detailed Congressional testimony about BBCE in June:

“Because such a wide variety of states and territories have elected to use BBCE, it is reasonable to conclude that states find it a very important lever for responding to the challenges facing low‐income families and for streamlining their administrative processes. Because so many states have built their procedures, information systems, and training around BBCE, removing or significantly restricting it will likely be costly and disruptive.”[iv]

Finally, we are discouraged by the tactics and messaging employed by the administration in an attempt to sell this proposal as “good government” to the American public. First, labeling the entirety of BBCE as a “loophole” – as Secretary Perdue did three times within the first minute of his prepared remarks – does a disservice to the intent and achievements of the program. This rhetoric implies that people are enrolling in SNAP with little oversight, when, in fact, people still must go through the application process to receive benefits.

The rhetoric also implies that the now infamous “Minnesota millionaire” is the norm, rather than the exception. Using this man – an extreme outlier – as a mascot for a program that, in fact, helps millions of low-income Americans put food on the table, is a shameful tactic we’ve seen before with the “Welfare Queen” from the 80s and Fox News’ “Lobster Surfer” from 5 years ago.

In conclusion, the administration’s multiple attempts to weaken vital safety net programs jeopardizes the health and economic prosperity of millions of Americans. We have great concern with the dismantling of a program that would directly impact so many of the people we serve. SNAP has proven itself for decades to be one of the most effective anti-poverty programs our nation has ever seen. It should be strengthened, not slashed.

Thank you for the opportunity to submit comments on this issue.

[i] https://hungersolutionsny.org/snap-policy/snap-cat-el-rule/

[ii] https://edlabor.house.gov/imo/media/doc/2019-07-26%20Chairman%20Scott%20to%20Secretary%20Perdue%20SNAP%20Cat%20El%20Proposed%20Rule%5b1%5d.pdf

[iii] https://www.feedingamerica.org/about-us/press-room/feeding-america-statement-usda-proposal-restrict-snap-eligibility

[iv] https://agriculture.house.gov/uploadedfiles/hhrg-116-ag03-wstate-waxmane-20190620.pdf