Congressional Black Caucus Urges Secretary Perdue To Rescind Proposed Rule to Limit SNAP Categorical Eligibility
This proposed rule threatens to kick 3.1 million people off SNAP, including children, seniors, military veterans, and persons with disabilities.
This month, the Congressional Black Caucus sent a letter to U.S. Department of Agriculture Secretary Sonny Perdue in opposition to the Department’s recently published proposed rule to eliminate the use of Broad-Based Categorical Eligibility in the Supplemental Nutrition Assistance Program. The proposed changes would harm millions of hard-working families who rely on SNAP, including an estimated 500,000 children who would lose direct access to free school meals.
The Congressional Black Caucus issued the following statement in response:
“Since taking over USDA, Secretary Perdue with the support of President Trump, has consistently attacked hard-working Americans by attempting to push struggling families and children further into poverty. According to the latest Census data, SNAP successfully lifted 3.4 million individuals out of poverty in 2017, including 1.5 million children. By pursuing this proposal, the Trump Administration will pull the rug from under millions of families who rely on SNAP to help put food on the table. It is our Congressional duty to ensure every American is provided the tools and opportunities they need to succeed. The Congressional Black Caucus is vehemently opposed to this proposed rule and we urge USDA to rescind it and finally make good on its promise to the American people to ‘Do Right and Feed Everyone’.”
A full copy of the letter can be found here and below:
October 2, 2019
The Honorable Sonny Perdue
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250
Dear Secretary Perdue:
We the members of the Congressional Black Caucus are vehemently opposed to the Notice of Proposed Rule Making (NPRM) published by the U.S. Department of Agriculture (USDA) titled, Revision of the Categorical Eligibility in the Supplemental Nutrition Assistance Program. The proposed rule will push struggling families and children further into poverty and we strongly urge USDA to rescind it immediately.
Since the Supplemental Nutrition Assistance Program (SNAP also formerly known as “food stamps”) was first established under the Food Stamp Act of 1964, it has served as a critical nutritional lifeline for many Americans, helping to ensure that they can feed their families as they work toward financial stability. A majority of SNAP participants, nearly 70 percent, are families with children. Research also demonstrates 74 percent of adult SNAP participants are working or have worked within a year of SNAP participation.
According to the latest Census data, SNAP lifted 3.4 million individuals out of poverty in 2017, including 1.5 million children, helping them to grow up healthier and stronger. Today, 20 million children rely on SNAP as the program helps them reach their full potential by:
· Helping to end child hunger and improving child food insecurity rates;
· Promoting stronger learning and academic performance; and
· Reducing the likelihood of chronic conditions such as obesity, diabetes, and the risk of anemia resulting in fewer doctor visits and hospitalizations.
SNAP is the largest and most effective nutrition program in the country, serving as the first line of defense against hunger and food insecurity for low-income families and children. Currently, over 40 states and U.S. territories successfully use BBCE to streamline and tailor the reach and effectiveness of SNAP to best serve the needs of struggling residents. Through BBCE, eligibility for SNAP is automatically extended to households receiving Temporary Assistance for Needy Families (TANF) benefits and services. This direct connection between SNAP and TANF helps participants mitigate the impact of often stagnant wages and high costs of living. BBCE efficiently increases access to, and participation in, the federal nutrition assistance programs.
BBCE allows states and territories to streamline SNAP administrative requirements through data matching and raise gross income eligibility requirements in SNAP up to 200 percent of the federal poverty line for families struggling with high costs of living associated with housing and childcare. BBCE also provides the flexibility to adjust the asset test, allowing families to accumulate modest savings and build wealth to help weather emergencies such as car repairs, illness or reduced working hours. USDA’s proposed rule will most certainly widen existing pervasive wealth and income disparities and push poor people deeper into poverty.
USDA’s Economic Research Service estimates 40 million people, including more than 12.5 million children, lived in food insecure households in the United States in 2017. That translates to 1 in 8 individuals and 1 in 6 children residing in households that lacked consistent access to adequate nutrition. For minority populations, the situation is much more dire. USDA’s report also showed the food insecurity rate for African Americans (21.2%) was more than double that of non-Hispanic White households (8.1%) in 2018. The U.S. Census Bureau reported in 2018 nearly 10% of African Americans and 7 percent of Hispanics lived in deep poverty (less than 50% of the federal poverty threshold) or earned an annual income of less than $12,732 for family of four.
Additionally, a 2016 study prepared by the Urban Institute for USDA shows households in areas using BBCE to allow higher asset eligibility limits tend to have a bank account with modest savings. However, the proposed rule may prevent SNAP households from accumulating savings or having a bank account altogether. This is particularly troubling given evidence that having a bank account is a proven, effective way to build assets and escape the cycle of poverty.
Shockingly absent from the proposed rule’s Regulatory Impact Analysis is USDA’s own estimation that over 500,000 school-aged children would lose direct access to free school meals should the proposed rule go into effect. Ninety-three percent of children impacted by the proposed rule will reportedly no longer be eligible for free school meals. As a result, restricting the use of BBCE will result in a significant increase in classroom hunger.
Lastly, the Department’s proposal is contrary to the result of the legislative process and flies in the face of the intent of Congress. During both the 2014 and 2018 bipartisan-led Farm Bill debates, Congress rejected similarly harmful proposals to restrict the use of BBCE. Passage of the 2018 Farm Bill affirmed the current program and benefit structure of SNAP and BBCE. Congress could not ignore the significant adverse impact such a policy change would have on already vulnerable working families and children—neither should USDA.
USDA’s proposed rule is cruel and reflects the failure of the Department to thoroughly consider or acknowledge the range of negative consequences such a change will have on low-income families and children. Millions of struggling Americans will be harmed if USDA moves forward with this proposal.
We urge USDA to immediately rescind this proposed rule and finally make good on its promise to the American people to “Do Right and Feed Everyone”.
 Cronquist, Kathryn et al. 2019. Characteristics of Supplemental Nutrition Assistance Program Households: Fiscal Year 2017. United States Department of Agriculture and Mathematica. https://fns-prod.azureedge.net/sites/default/files/resource-files/Characteristics2017.pdf
 Keith-Jennings, Brynne et al. 2018. Most Working-Age SNAP Participants Work, But Often in Unstable Jobs. Center for Budget and Policy Priorities. https://www.cbpp.org/research/food-assistance/most-working-age-snap-participants-work-but-often-in-unstable-jobs
 Fox, Liana. 2019. Supplemental Poverty Measure: 2018. U.S. Census Bureau. P60 – 268. https://www.census.gov/content/dam/Census/library/publications/2019/demo/p60-268.pdf
Ratcliffe, Caroline and Signe-Mary McKernan. 2010. How Much Does SNAP Reduce Food Insecurity? Urban Institute. https://www.ers.usda.gov/webdocs/publications/84336/ccr-60.pdf?v=0
 Carlson, Steven et al. 2016. SNAP Works for America’s Children. Center on Budget and Policy Priorities. https://www.cbpp.org/research/food-assistance/snap-works-for-americas-children
 Hoynes, Hilary et al. 2016. Long-Run Impacts of Childhood Access to Safety Net. American Economic Review, 106(4). https://gspp.berkeley.edu/assets/uploads/research/pdf/Hoynes-Schanzenbach-Almond-AER-2016.pdf
 Coleman-Jensen, Alisha et al. 2019. Household Food Insecurity in the United States in 2018. United States Department of Agriculture. Table 2. https://www.ers.usda.gov/webdocs/publications/94849/err-270.pdf?v=963.1
 Fox, Table B-3.
 Ratcliffe, Caroline et al. 2016. Asset Limits, SNAP Participation, and Financial Stability. Urban Institute and Orlin Research. https://www.urban.org/sites/default/files/2000843-asset-limits-snap-participation-and-financial-stability.pdf
 Tatum, Sophie. 2019. House Dem says 500,000 children could lose free school lunch under a new Trump administration proposal. ABC News. https://abcnews.go.com/Politics/house-dem-500000-children-lose-free-school-lunch/story?id=64637759
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