CBC Letter to Secretary Perdue on Proposed SNAP Revisions

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 the 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 last 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 built 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 Services 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 student 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 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".

Sincerely,

The Members of the Congressional Black Caucus