Dear Secretary Perdue:
We write in opposition to the United States Department of Agriculture (USDA)'s Proposed Rule issued on July 24, 2019, regarding revisions to Categorical Eligibility in Supplemental Nutrition Assistance Program (SNAP). We are concerned about the harm this proposal would have on individuals across Maine who rely on the program for basic food assistance.
As USDA acknowledges, the proposed rule, if finalized, would have varying impacts on states due to differing categorical eligibility policies. The proposed rule would be acutely felt in Maine, almost more than any other state in the country. According to USDA estimates, seven states, including Maine, would see more than 15 percent of SNAP households lose eligibility. The Maine Department of Health and Human Services calculates an even larger impact, with nearly 27 percent of all SNAP participants at risk of losing benefits under the proposal.
Maine already ranks as one of top ten most food-insecure states in the country, and for this reason, the loss of food benefits for 44,068 SNAP participants would be all the more devastating. Of those who are at risk of losing eligibility, Maine's most vulnerable individuals, including children, seniors, and individuals with disabilities, would be especially hard hit. Specifically, the proposed rule could take supplemental food benefits away from 11,031 children. Even without new program restrictions, one in five children in Maine will experience food insecurity this year. Additionally, 9,598 of those at risk of losing SNAP eligibility are over age 60 or have a disability.
The proposed rule would also place an increased burden on the State of Maine in terms of program maintenance. In Maine, Broad-Based Categorical Eligibility is used to improve program efficiencies, reduce administrative costs, and, ultimately, provide better support to the state's most vulnerable individuals and families.
While we support efforts to ensure that SNAP benefits go to those who are most in need, we caution that over a quarter of Maine's current SNAP beneficiaries could lose basic food assistance under USDA's proposal. Prescriptive changes to federal eligibility rules go far beyond attempts to shore up the integrity of the program. For a state like Maine that is already struggling with food insecurity, these changes would be detrimental to the very population the program is designed to support.
Thank you for your consideration of our concerns