Dear Secretary Perdue:
We write to raise serious concerns about the U.S. Department of Agriculture's (USDA) recent proposed rule "Revision of SNAP Categorical Eligibility." Despite the agency's assertion that this rule would "fix a loophole" and ensure benefits are provided to those most in need, the proposed changes--according to USDA's own estimates--would take food assistance away from an estimated three million Americans, including 66,000 Oregonians, who are currently eligible SNAP participants.
The agency's proposed rule restricts states' ability to determine eligibility for SNAP by limiting "Categorical Eligibility," which allows individuals to be automatically or "categorically" eligible for SNAP based on being eligible for or receiving benefits from other specific low-income assistance programs that already check income, assets, and other circumstances. Categorical Eligibility ensures applicants are eligible for the benefits they are applying to receive.
The proposed rule fails to recognize the Congressional intent behind Broad Based Categorical Eligibility and circumvents Congress. We would like to remind you that Congress has on a bipartisan, bicameral basis repeatedly opposed and rejected harmful changes to nutrition assistance. Most recently, Congress passed the 2018 Farm Bill that specifically protects this key policy. We reject USDA's claims that this rule "makes things fair" and is needed to improve compliance and eligibility consistency. As you know, your own department has stated that SNAP has maintained some of the highest program integrity standards and most meticulous quality control systems of any federal program.
We are especially concerned about the number of Oregon children--many of whom receive their only meal of the day at school--who will lose access to free school meals if they are not automatically certified for school meals because of their SNAP participation. While the vast majority of these children may qualify for reduced price meals, they will have to reapply for the program and bring lunch money in order to continue to eat at school. Because schools are reimbursed at a lower rate for children who participate in reduced-price meals, this change will also mean less money for schools.
In Oregon, this proposed rule would also be a significant burden on the Department of Human Services (DHS), which administers Oregon's SNAP program. DHS has been using Categorical Eligibility for 15 years and would need to update its technical capabilities and retrain the hardworking staff who help ensure Oregonians receive their benefits. We also know that every $1 spent in SNAP benefits generates approximately $1.79 in economic activity.
Too many hardworking American families struggle with food insecurity and access to fresh and nutritious foods. We should be doing more to address hunger and end the cycle of poverty, instead of chipping away at basic assistance that families--especially children, seniors, and people with disabilities--rely on to survive.
This proposed rule is unnecessarily cruel, ignores Congressional intent, takes food away from families, prevents children from getting school meals, and makes it harder for states to administer food assistance. In the wealthiest country on earth, we can and must ensure that every family in America can keep food on their table each day and that no child goes to school or to bed at night hungry.
We urge you to immediately withdraw this harmful proposed rule. We look forward to your response.
Sincerely,