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Opposition to Changes in the Supplemental Nutrition Assistance Program (SNAP)

Publication date: 
Friday, September 27, 2019

The Supplemental Nutrition Assistance Program (SNAP), is the nation’s largest and most effective anti-hunger program that provides food assistance to working families with children, seniors, and individuals with disabilities. The U.S. Department of Agriculture has proposed rules that would attempt to remove nearly 230,000 Californians from being eligible for food stamp benefits. Additionally, the rule would require that students currently receiving free lunch in schools re-apply for such benefits. 

Southern California Grantmakers opposes the proposed changes to the Supplemental Nutrition Assistance Program (SNAP) eligibility criteria that would take away vital food benefits to 230,000 Californians. As a philanthropic serving organization amplifying the work of our members, we oppose the proposed changes that will limit access to necessary food stamps for our most vulnerable. As a part of the federal rulemaking process, Southern California Grantmakers — through our statewide alliance Philanthropy California — submitted our public comment for consideration by the Department of Agriculture. 

Several SCG members, including Archstone Foundation, First 5 LA, The California Community Foundation, The Eisner Foundation, The S. Mark Taper Foundation, and United Ways of California also submitted comments opposing this change that would threaten food security for families in our region. Southern California’s foundations led the sector nationwide in providing critical input in detailing the harm this proposed rule would have in our communities. You can view their letters below: 

 

What’s the existing law?

  • For the last two decades, two key components have contributed to the effectiveness of SNAP including:

  • Automatic (or “categorical”) eligibility for SNAP when a household receives cash assistance from Temporary Assistance for Needy Families (TANF) and related programs.

  • Allowing individual states to use less restrictive income and asset tests to account for differences in costs of housing, childcare, and other essentials without jeopardizing access to food assistance.

These components are known as “broad-based categorical eligibility” (BBCE). Under BBCE, California has expanded access to families earning between 130 to 200 percent of the federal poverty line. This means that, for a family of four that has an annual income between $32,630 to $50,200, the family would be able to receive food assistance. This threshold accounts for the state’s higher housing costs, thus encouraging more eligible recipients to work additional hours above the federal poverty line to offset the costs of housing and keep their SNAP benefits, so long as they earn less than $50,200 threshold. 

To receive SNAP, all households, including those eligible under BBCE, must apply, be interviewed, and document that their monthly income and expenses, such as high housing and childcare costs, leave them with too little disposable income to afford a basic, adequate diet. Children in households that receive SNAP are automatically eligible for free school meals without having to complete a separate application. Without BBCE, children whose families lose SNAP when their incomes rise above the program threshold also would lose this automatic link to free school meals.

 

What is the U.S. Department of Agriculture proposing? 

On July 24, the Administrative proposed eliminated broad-based categorical eligibility. In California, Households earning more than 130 percent and less than 200 percent of the federal poverty line ($32,630 - $50,200 for a family of four) would no longer be eligible to participate in SNAP. In California, 230,000 households would be affected. Furthermore, the proposed rule revises the BBCE policy, eliminating automatic enrollment and requiring proof that a recipient receives at least $50 of welfare benefits a month for six months.

 

Why submit a public comment? 

The federal government must summarize and consider public comments before implementing a new rule. A large number of comments forces the government to study the issue closely and explain itself—and it is the best way to show widespread public opposition. This can lead to a proposed regulation being slowed down, changed, or even abandoned. Public comments submitted by philanthropy in the past helped build a public record against the citizenship question on the 2020 Census, which the U.S. Supreme Court looked to in preventing the addition of the citizenship question that would have led to an undercount in our most vulnerable communities. Your voice is crucial to outline why this proposed rule is harmful. Additionally, philanthropy often works in partnership with the government in enhancing public programs, but this rule would misguidedly transfer the government’s social safety net role onto philanthropy and nonprofits. 
 

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