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September 16, 2019

Proposed Trump Rule Changes to Food Assistance Would Eliminate Flexibility for States

No one should have to choose between putting food on the table and making a rent payment. The Supplemental Nutrition Assistance Program (SNAP) helps families afford healthy food without sacrificing other necessities. The federal SNAP rules allow states to raise income limits for families with high child care or housing costs so they can still get help paying for food, while also allowing states to raise asset limits to let families save for the future. This state flexibility is allowed through a current policy known as “broad-based categorical eligibility.” Unfortunately, the Trump administration is proposing to severely restrict this state flexibility, taking food assistance away from approximately 3 million people, and hundreds of thousands of children would lose automatic eligibility for free school meals that help them get the nutrition they need to thrive in the classroom. With about a week left to submit public comment, it’s important to understand what this means for families in Virginia.

Virginia is one of just 11 states that does not currently use broad-based categorical eligibility to increase either income or asset limits. If the proposed Trump administration rule change that severely restricts state flexibility is finalized, Virginia will not have the opportunity to use this flexibility in the future. This is particularly concerning because it would eliminate a tool that policymakers could use as they seek ways to help make sure families don’t suddenly lose assistance just because they earned a little more. SNAP is generally structured to have food assistance amounts phase out as family income increases. However, without broad-based categorical eligibility, there is a “cliff” when the family reaches 130% of the poverty line, which is just $21,330 for a family of three. If the current flexibility in the federal rules remains, broad-based categorical eligibility could be used to eliminate this benefits cliff and make sure families are better off when they are earning more money. 

Broad-based categorical eligibility also simplifies program administration and reduces costs by streamlining the application process. Virginia currently struggles to properly administer its SNAP program, in part due to high staff turnover and vacancies. Using broad-based categorical eligibility to simplify administration would not solve all these problems, but it could reduce them. And, conversely, severely restricting broad-based categorical eligibility will increase administrative costs by $2.3 billion over the next five years nationally according to the U.S. Department of Agriculture’s own estimates, all while helping fewer families make ends meet.

SNAP is the most important food assistance program in the United States, and Congress has repeatedly considered and rejected legislative proposals that would roll back broad-based categorical eligibility. Now, the Trump administration is seeking to use the regulatory process to accomplish what Congress rejected. The good news is that the proposed rolling back of broad-based categorical eligibility is not yet final. Through September 23, individuals and organizations can submit public comments about how this change would impact them and their communities, and the administration is legally required to review every comment. A number of organizations, including the Center for American Progress and Coalition on Human Needs, have set up public comment portals to make it easy to submit comments, or it can be done directly through the Federal Register. Virginia is not yet using the important flexibility offered by broad-based categorical eligibility to eliminate benefit cliffs, allow families to save for the future, and reduce administrative burdens, although in recent years state lawmakers have explored doing so. It would be a shame if federal rule changes take away that opportunity.

Economic Opportunity

Levi Goren

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