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Statement on Most Recent Proposal to Cut SNAP Food Benefits via the Standard Utility Allowance

If implemented, the third proposed SNAP rule change of 2019 could result in $4.5 billion in cuts to food assistance over five years

Anti-hunger advocates are once again preparing to respond to another round of proposed cuts to the Supplemental Nutrition Assistance Program (SNAP), known as CalFresh in California.

Just one week after the public comment period closed for the second set of the Trump administration’s proposed rule changes to SNAP, which would take food away from approximately three million hungry Americans, the United States Department of Agriculture (USDA) has announced another proposed rule change. The 60-day period to respond to this third proposed rule will end December 2nd.

SNAP, which is administered by the USDA, is recognized as the nation’s most important anti-hunger program. If enacted, these three rules combined are estimated to negatively impact over a million Californians, more than a quarter of the SNAP recipients in our state. What’s more, these proposed cuts to SNAP are among the dozens of other safety net cuts targeting low-income families proposed by the Trump administration this year alone.

“The Trump administration’s newest proposal will be touted as streamlining and standardizing, but no one should be fooled.” said Jessica Bartholow of the Western Center on Law & Poverty and chairperson of the Lifting Children Out of Poverty Task Force Safety-net Committee. “It’s simply another ploy to take food help away from people who turn to SNAP to prevent hunger. This is coming from a President who has never had to wonder where his next meal is coming from or worry about his kids going to bed hungry. It is disgraceful. I’m proud to know that the anti-hunger community and our allies will, once again, show up in force in opposition.”

Current law requires the SNAP program to recognize the utility expenses of each SNAP applicant household and adjust the benefits issued based on the Standard Utility Allowance (SUA) calculated by the State and approved in the State plan. The current policy allows variances in SUAs to accommodate for differences in utility costs and rates, and allows states flexibility in how they calculate those costs. The proposed changes would standardize those calculations across the country and set the SUA to an amount lower than what would be needed to meet the costs of utilities for many Californians. Nationwide, the proposed change is estimated to result in cuts to food assistance by $4.5 billion over a five-year period.

“It is unconscionable that for the third time this year, the Trump administration is proposing to cut vital food assistance for low-income families, seniors, and people with disabilities,” said Jared Call of California Food Policy Advocates. “In the wealthiest country in the world, no one should have to go hungry or face the impossible choice between feeding their family and keeping their electricity on and home heated. CFPA and our anti-hunger partners are committed to working together to prevent cuts to SNAP and to insist that our national policy makers renew their commitment to end hunger and food insecurity.”

SNAP recipient households have uneven protections from hunger as a result of some states under-calculating the SUA; the only appropriate policy response is to bring those states up-to-par with other states by improving their SUAs. Instead, the administration is proposing a race-to-the-bottom solution by cutting SUAs and removing state flexibility, which will undermine our ability to help low-income Americans in every state prevent hunger and keep their electricity on at the same time. The USDA estimates that 20 percent of the national SNAP caseload will be impacted, though it is unknown what percentage of those impacted live in California.

“California food banks are on the frontlines of hunger and know first-hand the inhumane trade-offs that low-income families make between food and paying for basic needs like high utility bills,” said Andrew Cheyne, Director of Government Affairs for the California Association of Food Banks. “We’ve said it during every proposed cut to SNAP, and we’ll continue to raise awareness during this public comment period, that for every meal the charitable sector provides, SNAP delivers 12. Food banks and our partners cannot make up the difference: if this rule is enacted, people will go hungry just to keep cool during scorching summers and warm in winter.”

Leveling the SUA amounts across the country down rather than up, despite the well-documented fact that benefits for all recipients are currently inadequate, means fewer people will be able to afford the food they need to last them through the month. We urge the administration to abandon this proposal and instead join our organizations in supporting H.R.1368 (Adams, D-NC-12) to make SNAP benefits more responsive to our nation’s unacceptable levels of hunger, not less.

The previous two proposed administrative changes received a combined 200,000 comments from food banks, policy advocates, legal services, faith based organizations, unions, business leaders and government officials from across the country. The final rules for those proposals remain pending. Our organizations expect a similarly robust response to this harmful proposal and, if the barrage of comments in opposition to these proposed rules fail to discourage the administration from publishing detrimental final rules, we will take whatever next-steps are necessary to prevent hunger and protect the rights of low-income Californians.

 

For more information about our opposition to this proposed rule, contact us at: 

Jessica Bartholow, Western Center on Law & Poverty

Email: [email protected]

Phone: (916) 282-5119

 

Jared Call, California Food Policy Advocates

Email: [email protected]

Phone: (510) 560-6485

 

Andrew Cheyne, California Association of Food Banks

Email: [email protected]

Phone: 510-350-9915

Western Center Submits Comments Opposing SNAP Categorical Eligibility Rule Proposal

The comment period has ended for the USDA’s proposed rule to end a long-standing and widely used rule that eases the application and retention burden for families in need of food assistance. If implemented, the change could impact over 120,000 California households, most of whom are working, by making them newly ineligible for SNAP food assistance.

An excerpt from Western Center’s comments:

The Western Center on Law and Poverty is deeply concerned by attempts to restrict food assistance to the individuals whom we and our partners serve in California. We strongly support the twin goals of preventing hunger and supporting economic mobility, both of which are best achieved when states can account for high housing, child care and health care costs, and help SNAP participants save money to weather financial setbacks. We believe that the Administration’s proposed changes to categorical eligibility will work in opposition to these goals. If the proposed rule goes into effect, it will cause an estimated 250,000 to 345,800 Californians, who are already struggling to meet their basic needs, to lose their SNAP benefits. Hunger does not help anyone exit poverty and, in fact, has been proven to do the opposite: to leave children and adults alike to experience long and short-term consequences of poor nutrition that undermines their wellbeing and economic security. We respectfully request that the Administration consider the comments in our letter and the information in the attached appendices, and that the Administration withdrawal the proposed rule from consideration.

Western Center’s full comments can be read here.

County’s poor and immigrants are hard hit by a cluster of Trump administration benefit cuts

Policy advocate Jessica Bartholow of the Western Center on Law and Poverty had a question for U.S. Secretary of Agriculture Sonny Perdue on June 27, at a town hall meeting hosted by Rep. Jimmy Panetta, D-Carmel Valley, in Watsonville. After pointing out that the Trump administration was proposing to cut Supplemental Nutrition Assistance Program, previously known as food stamps, to “able-bodied adults without dependents” – despite bipartisan support of the 2018 Farm Bill outlining such benefits – she asked if Purdue “had a sense” whether he would proceed.
 
“My intention is to pursue the changes,” Purdue said, even though the USDA was supposedly still reviewing public comments, many of which were highly critical of the cuts.
 

PROPOSED FOOD STAMP ROLL-BACK TO AFFECT A QUARTER MILLION CALIFORNIANS

Roughly a quarter-million Californians might not qualify for food stamps under a new proposal by the Trump administration, opponents of the proposal said the move will affect families who already struggle financially.

…Jessica Bartholow is the lead Anti-Hunger Policy Advocate at the Western Center on Law and Poverty, she said about 250,000 Californians will lose their Cal Fresh assistance.

“They will experience hunger,” Bartholow said. “The most recent proposal by the Trump administration would make the program more difficult to reach people who are working, people who have children in their household.”

Read more 

How Will Tightening Eligibility Standards For Food Stamps Affect Californians?

The U.S. Department of Agriculture has a new proposal that would change SNAP eligibility requirements — and some argue that it may have an outsized impact on Californians…

GUESTS:

Angela Rachidi, research fellow in poverty studies at the American Enterprise Institute (AEI) whose expertise includes the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) programs

Jessica Bartholow, policy advocate for the LA-based Western Center on Law and Poverty, an advocacy organization for low income Californians; chair of the California Asset Building Coalition, a non-profit that aims to help Californians achieve economic self-sufficiency

Listen here 

“We’re not going to be able to survive:” Why Californians could bear the brunt of Trump food stamp cuts

A Trump administration proposal would cut food stamps to 3.1 million Americans—largely working families with high housing, childcare and medical costs. That could hit hard in California, a state where both the cost of living and the minimum wage are on the rise.

…“It’s clear that states like California are a target on this,” said Jessica Bartholow, a policy advocate for the Western Center on Law and Poverty.

Read more

If the U.S. economy is strong, why is the Trump Administration proposing to let people go hungry?

By Jessica Bartholow, Western Center Policy Advocate 

In the Trump Administration’s efforts to scale back the federal safety net, it has proposed new work requirement rules for Able-Bodied Adults Without Dependents (ABAWDs) in need of SNAP food assistance – an estimated three million Americans.

For low-income individuals, both those who work and those who don’t or can’t, SNAP offers an essential support for preventing hunger. People looking for work need access to food, because unsurprisingly, hunger undermines employment goals.

At Western Center on Law & Poverty, we advocate for the health and dignity of people in poverty, and we see the proposed ABAWD rule as a hardhearted and misguided manipulation of welfare reform. In an economy as strong as the President claims, allowing people to go hungry is immoral and short-sighted.

Congress created a time limit in the Food Stamp Program, now known as SNAP, in 1996 for unemployed, underemployed, and job-seeking childless adults — deemed ABAWDs. Unless exempt due to disability or pregnancy, ABAWDs are limited to receiving food benefits for three months out of any 36-month period unless they satisfy a 20 hours-per-week work requirement.

In the time since 1996, the USDA approved California’s requests to waive ABAWD time-limits, but that changed last year. The statewide waiver of the ABAWD time limit expired on August 31, 2018, with all counties except San Francisco, Santa Clara and San Mateo receiving area waivers until August 31, 2019. The intent of the original 1996 regulations, and the reason California received waivers in the two decades since, is to protect people from hunger.

Many Californians struggle with unemployment, underemployment, and low-wages, and as a result, are forced to rely on public safety net programs. ABAWDs may be able to find low-paying service jobs, but those jobs are increasingly part-time and lack fair scheduling, making it difficult to guarantee 20 hours a week on a regular basis. That kind of involuntary part-time work has doubled between 2007 and 2012 — 43 percent of part-time workers say they wish they were given more hours.

The proposed ABAWD rule also ignores the fact that numerous ABAWDS are classified as such by a slim margin. Many struggle to hold work because of circumstances beyond their control – undiagnosed mental and physical health barriers, inaccessible job markets, and unstable living conditions.

While the time limit includes protections for people with disabilities, proving that one is unfit for work is difficult. States are not obligated to help individuals find providers to diagnose or treat impairments, which means those with significant illnesses risk being unable to comply with verification rules.

Western Center joined the California Secretaries of Agriculture and Health and Human Services in calling for the complete repeal of the ABAWD rule. If the rule isn’t repealed, lawmakers should, at minimum, protect long-established waivers that prevent hunger for people in communities impacted by high unemployment and underemployment.

California’s temporary ability to exempt individuals from the ABAWD rule is important, but it’s insufficient. We cannot afford to weaken protections from the ABAWD time limit, especially since there is no evidence that it will result in people working more. Additionally, the proposed rule directly undermines legislative intent; negotiations for the 2018 Farm Bill included a consideration for work requirements, but those requirements were left out.

The comment period for the proposed rule came to a close this week — it was extended after Western Center brought attention to errors in the submission system. We submitted comments encouraging the USDA to abandon the proposed rule change for the ABAWD time limit, but ultimately, we are working for the elimination of the time limit altogether to ensure that every American who wants to work can, and that no one goes hungry due to lack of a job.