Thursday, September 19, 2019

CLIP Just Submitted Comments on the Trump Administration's Proposal to Gut Broad Based Categorical Eligibility in the SNAP Program

With thanks to CLIP Steering Committee members Peter Zurflieh and Sheila Forrester for offering reality based scenarios to strengthen CLIP's comments, the following have been submitted today:

The Coalition for Low Income Pennsylvanians (CLIP), writes to strongly oppose the Administration’s proposed rule to gut broad-based categorical eligibility in the Supplemental Nutrition Assistance Program (SNAP). CLIP is the only statewide coalition in Pennsylvania that focuses its advocacy and grassroots organizing entirely on poverty related issues. We have 24 member organizations that include: faith based groups involved in direct service to the poor, as well as advocacy; legal services organizations that represent low income clients; community action organizations; SEIU local 668 that represents caseworkers; groups that work with victims of domestic violence and rape; and local and statewide anti-hunger organizations. 

Under rules proposed by the Trump Administration, the most families across the country could earn and still receive SNAP would be reduced from 160% to 130% of poverty ($2,252 per month, barely over $27,000 per year for a family of three). If the working members of a family receive a raise or are able to work more hours, the family would be pushed over the income limit and would lose all of their SNAP benefits. They could be worse off than if they had not tried to improve their economic situation. While this might not be the intent of the proposed rule, it would be an inevitable consequence of it. 

Restricting broad-based categorical eligibility so severely in the SNAP program would cause great hardship, taking food assistance away from approximately 3 million people in America annually…200,000 in Pennsylvania…and likely stripping hundreds of thousands of hungry kids of the school meals that help them get the nutrition they need to thrive in the classroom. 

Gutting categorical eligibility in this way would significantly weaken SNAP by removing states’ flexibility to make sure their SNAP programs help workers and families get ahead, making it harder for people to apply and receive benefits.

Under the new rule, states like Pennsylvania would no longer be able to eliminate the SNAP “asset test” and families, including seniors, with savings and assets above the federally set limits would not qualify for SNAP. This would punish families, seniors and people with disabilities who save for the future and push them into…or deeper into…poverty. And it means that seniors and families who need SNAP to help put food on the table may need to spend their limited savings before they can qualify for assistance, leaving them vulnerable to financial emergencies and to hunger. 

The proposal would also penalize workers for getting a raise, by creating a sharp benefit cliff that leads to sudden loss of food assistance when wages go up even slightly.

The following profiles provided by CLIP member organizations are a small but poignant sampling of harm this proposed rule change would cause to their clients and families they serve:

1. Grandparents who are raising their grandchildren due to the children’s parents’ addiction or mental health issues.  There are more and more grandparents raising their grandchildren. Many of them live on fixed incomes and receive SNAP for themselves and their grandchildren.  Among these grandparents are a good number who have retirement accounts or savings that they accumulated over many years as part of their financial planning. Currently, because Pennsylvania has opted to eliminate the SNAP asset test, these grandparents are eligible despite assets accumulated to see them through their retirement years. But under the proposed SNAP policy the asset test would disqualify them from receiving SNAP for themselves and their grandchildren.

2. Single parents with children working part-time and attending education or training programs.  This is the epitome of people who are working to improve their lives and those of their children.  Many of these parents, with whom our member organizations work, are pursuing degrees in   occupations, such as the health field, that are in demand and will put them on a career path to true self-sufficiency. The proposed rule would reduce the income limit for SNAP to the point that the starting wage of these parents, upon completing their education programs, could result in termination of their SNAP before they have actually begun to earn enough to adequately support their families without food assistance. Rather than being rewarded for their efforts toward self-sufficiency, they would lose their SNAP benefits, putting their families at risk of hunger.

SNAP is one of our nation’s most effective anti-poverty programs, helping more than 38 million people in the United States put food on the table every month. This proposed rule will cause more hunger and hardship for millions, rather than alleviating it, as is the intent of the SNAP program. The proposed policy change should be withdrawn.