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The original documents are located in Box 15, folder "Food Stamps (3)" of the James M.
Cannon Files at the Gerald R. Ford Presidential Library.
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Digitized from Box 15 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
THE WHITE HOUSE
WASHINGTON
May 16, 1975
MEMORANDUM FOR:
THE PRESIDENT
FROM:
JIM CANNON
SUBJECT:
Food Stamp Reform
FORD & LIBRARY GERALD
The purpose of this memorandum is to present various actions
which can be taken to reform the Food Stamp program. We
have limited the options presented for your decision to the
key issues but information on all elements of the reform
proposals are provided in the tabs.
BACKGROUND
A description of the current program and a brief background
summary are included in Tab A. In essence the program has
grown from a $200 million program in 1968 serving 2.5 million
people to an estimated $6.6 billion program serving 21 million
people in 1976.
ABUSE OR LEGITIMATE GROWTH (Tab B)
It is difficult to determine with precision what proportion
of this growth is due to abuse of the system and what is
due to factors entirely legitimate under current law such as
Congressionally mandated outreach efforts to encourage parti-
cipation. It is clear, however, that the greater part of the
most recent growth has been related to factors outside the
program such as unemployment and increase in the cost of food.
POINTS OF NOTE
Two points should be brought to your attention:
1. The information base upon which estimates are made of
the impacts of the various options in this paper is
extremely shaky. While it is the best available it
does not enable a confident prediction of program
impact on caseload, costs, or actual benefits.
-2-
2. The U.S. Department of Agriculture study from which
this package of recommendations is developed does
not address the asset test aspects of the program.
Many of the apparent abuses which receive publicity
are caused by the existing lenient asset test (i.e.,
participants are permitted to retain multiple auto-
mobiles, large cash value insurance policies, expen-
sive houses, etc.). The specific reforms suggested,
however, tend to eliminate the higher income partici-
pants where these assets are particularly a problem.
ADMINISTRATIVE REFORM
Twelve specific legislative proposals to simplify adminis-
tration, tighten accountability and penalize and retard
abuses have been agreed upon by OMB, the Department of
Agriculture and the Domestic Council. These are largely
noncontroversial, specific actions which we believe should
be taken regardless of other decisions. They are listed
and described in Tab C.
OPTIONS FOR CONSIDERATION
The following summarize the essential options for your
consideration. Details on each are provided in the designated
tabs.
A. Group Eligibility (Tab D)
1.
Strikers - All employable food stamp recipients
are denied eligibility if they refuse to accept
employment. Being on strike, however, is not
grounds for denying eligibility
--- one possibility would be to require
strikers to wait 60 days before becoming
eligible for food stamps. Since the striker
issue affects a number of income assistance
programs, we recommend this issue not be
part of the food stamp reform.
2.
Addicts and Alcoholics - Eligibility is denied
to residents of institutions where meals are
prepared for them. Current law exempts drug
addicts and alcoholics in institutional treat-
ment programs enabling them to be the only
institutionalized individuals eligible for
food stamps
-- we have proposed eliminating this exemption.
-3-
3.
College Students - Two elements of the current law
affect eligibility of college students for food
stamps
a. current law is confused in regard to eli-
gibility for students who are claimed as
a tax deduction by families which are not
eligible for food stamps.
b. eligible students are exempt from require-
ment to accept employment
-- we recommend clarifying the tax
dependency provision but continuing
the exemption from work requirement.
B. Income Eligibility and Benefit Structure
We recommend that your reform package include con-
sideration of the eligibility determination based on
income since this is the central factor determining
caseload, costs, and the benefits people receive.
The following options are available:
1.
Include in an Overall Reform - The most logical
and effective food stamp reform would be to
consider food stamps as part of a complete
overhaul of all income transfer programs.
-- we recommend that should an overhaul of all
income transfer programs be considered, food
stamps be included. This should not preclude
taking independent action on food stamp
program now.
2.
Action Now - If you agree that action should be
taken now on the income eligibility and benefit
structure of food stamps there are two general
approaches:
a.
Eliminate Food Stamps (Tab E)
Current use of food stamps could cease and
eligible recipients would simply be mailed
a check for the cash value of the current
bonus they receive. Some sort of standard de-
duction could be used to determine eligibility.
-- overall effect would be to increase benefit
costs which are 100% Federal since more
people would participate.
-- estimates of potential additional Federal
costs in FY 76 range from $1.4 Billion to
$3.6 Billion.
-4-
b. Revise Current Eligibility System (Tab F)
If you decide to continue use of food stamps
and to recommend revisions in eligibility
determinations, you could
-- select one specific plan.
-- recommend a standard deduction type of
plan and let Congress set dollar amount.
-- offer a choice of specific plans and
let Congress select one.
The plans developed deal with:
-- deductions, currently a complex and
arbitrary system permits people to
deduct a number of items from their
gross incomes to enable their becoming
eligible even though their gross income
may be well above poverty line.
-- automatic eligibility for welfare
recipients, no matter what their actual
cash and in kind income is.
The specific plans developed:
1. Set a $100 monthly national standard
deduction for all families and eliminate
categorical eligibility.
2. Set a $100 national standard deduction
which varies by family size with special
$50 addition for aged and eliminate
categorical eligibility.
3. Set a single $100 national standard
but continue categorical eligibility and
include a special deduction for the aged
of $50.
4. Set $100 national standard deduction, deny
categorical eligibility but add $25 special
deduction for aged.
5. Create a progressive chart of income
eligibility and bonus values.
6. Put dollar limits on amounts which can be
deducted under current law.
ESTIMATED 1976 IMPACT*
CURRENT
PLAN I
II
III
IV
Total Households Participating
(Millions)
5.4
4.3
4.2
5.4
4.8
Total Annual Cost (Billions)
6.6
5.9
5.9
6.6
6.6
Number of Households with Bonus
Unchanged (Millions)
-
1.6
1.2
2.1
1.2
Number of Households With
Bonus Increased (Millions)
-
1.3
1.3
2.0
2.6
Number of Households With Bonus
Decreased (Millions)
-
2.7
3.1
1.6
1.9
*Estimates for Plans V - VI are not available
RECOMMENDATIONS
1.
Administrative Reform Package, we recommend that you
approve the package of 12 specific administrative reforms.
OMB and Agriculture agree.
Approve
Disapprove
2.
Strikers, we recommend that no change be made in current
eligibility for strikers. The Department of Labor agrees.
Approve
Disapprove
3.
Addicts and Alcoholics, we recommend legislation to
eliminate the present exemption permitting food stamp
eligibility for institutionalized addicts and alcoholics.
Approve
Disapprove
4.
College Students, we recommend legislation to clarify
tax dependency aspect of eligibility for college students
with continuation of exemption from work requirement.
Approve
Disapprove
5.
Overall Reform, we recommend inclusion of food stamps
if an overall reform of income assistance programs is
undertaken but we also recommend that independent action
be taken now to reform food stamp eligibility.
Approve
Disapprove
6.
Eliminate Food Stamps, we recommend that food stamps
continue to be used and therefore not be "cashed out"
at this time. Bill Seidman and the Department of
Agriculture also support continued use of food stamps.
Approve
Disapprove
7.
Specific Revision of Eligibility, we recommend that you
choose plan III which:
a.
replaces allowable deductions from income
with one monthly standard deduction of $100.
b.
continues automatic eligibility for welfare
recipients.
C.
provides as special additional income deduction
of $50 per month for the aged.
Approve
Disapprove
Tab A
BACKGROUND
CURRENT PROGRAM
Eligibility for food stamps and benefit levels are deter-
mined by income, assets, household size and a defined set
of allowable deductions from gross income. The allotment
is the amount of food stamps a household may purchase based
on family size. The cost to an eligible household to
purchase an allotment is based on income. The difference
between the purchase price and the face value of the allot-
ment is the "bonus." The bonus is 100% federally funded.
A food stamp household may choose to vary the level of
participation by committing once each month to purchase
25, 50, 75 or 100 percent of its allotment. Food stamps
are available automatically to all public assistance and
most SSI households.
Households with net earned income become eligible according
to the following schedule ( a more detailed schedule is
attached as the last page to this tab) :
Household Size
Monthly Income Limit
1
194
2
280
3
406
4
513
5
606
6
700
7
793
8
886
It is important to note that the net income in question
is gross income minus a number of allowable deductions
for medical costs, housing, child care, payroll taxes
and a number of other specific deductions. These deductions
have played a central role in opening eligibility to families
whose gross incomes are well above the poverty level.
The food stamp program has two objectives stated in law
in 1964:
1. Raise nutritional levels of low income households.
2. Distribute agricultural surpluses.
- 2 -
Neither of these objectives is applicable today.
-- Although in effect for 10 years, there is
still no evidence that the program raises
nutritional levels.
--- Distribution of agricultural surpluses is
not a problem.
Instead, the program has, since 1968, become a vast income
support mechanism with the largest caseload and fastest
growing costs of any major welfare program:
FY 1968
FY 1970
FY 1972
FY 1974
FY 1976 (est.)
Participants
2.5
6.5
10.5
13.5
21.0
(millions)
Cost (billions)
.2
.6
2.0
2.8
6.6
Until 1974, most of these increases were due to added
participation by those receiving some form of public assistance.
Since that time, however, the growth has been due primarily
to increased participation by those who are not eligible
for any other welfare program. Currently, participation
in food stamp program
Public Assistance:
46%
9.7 million
Non Public Assistance:
54%
11.3 million
It should also be noted that since 1972 the value of the
food stamp bonus and, therefore, eligibility for participation
has been tied to increases in the cost of food.
RECENT FACTORS
The FY 1976 budget proposal for a uniform charge (30% of
net income) for food stamps was overturned by P.L. 94-4.
Concurrently, Senator Dole initiated S. Res. 58, requiring
the Secretary of Agriculture to review the food stamp
program and to recommend by June 30 legislation to:
-- Disqualify families with adequate incomes;
-- Reduce administrative complexity;
GERALD ROND CIGNARY
--- Tighten accountability; and
-- Increase penalties for fraud.
Senate Agriculture Committee will soon hold hearings on
food stamp legislation. USDA has drafted a study and
proposed recommendations.
FOOD STAMP ALLOTMENTS AND PURCHASE REQUIREMENTS (Effective January 1)
48 States and
Number of Persons in Household:
District of Columbia
1
2
3
4
5
6
7
8
Monthly Coupon Allotment:
$46
$84
$122.
$154
$182
$210
$238
$266
Monthly Net Income
Monthly Purchase Requirement:
$
0
to
19.99
$ 0
$ 0
$ 0
$ 0
$ 0
$ 0
$ 0
$ 0
20 to
29.99
1
1
0
0
0
0
0
0
30
to
39.99
4
4
4
4
5
5
5
5
40
to
49.99
6
7
7
7
8
8
8
S
50
to
59.99
8
10
10
10
11
11
12
12
60
to
69.99
10
12
13
13
14
14
15
16
70
to
79.99
12
15
16
16
17
17
18
19
80
to
89.99
14
18
19
19
20
21
21
22
90
to
99.99
16
21
21
22
23
24
25
26
100 to 109.99
18
23
24
25
26
27
28
29
110 to 119.99
21
26
27
28
29
31
32
33
120 to 129.99
24
29
30
31
33
34
35
36
130 to 139.99
27
32
33
34
36
37
38
39
140 to 149.99
30
35
36
37
39
40
41
42
150 to 169.99
33
38
40
41
42
43
44
45
170 to 189.99
36
44
46
47
48
49
50
51
190 to 209.99
36
50
52
53
54
55
56
57
210 to 229.99
56
58
59
60
61
62
63
230 to 249.99
62
64
65
66
67
68
69
250 to 269.99
64
70
71
72
73
74
7.5
270 to 289.99
64
76
77
78
79
80
81
290 to 309.99
82
83
84
85
86
87
310 to 329.99
88
89
90
91
92
93
330 to 359.99
94
95
96
97
98
99
360 to 389.99
100
104
105
106
107
108
390 to 419.99
104
113
114
115
116
117
420 to 449.99
122
123
124
125
126
450 to 479.99
130
132
133
134
135
480 to 509.99
130
141
142
143
144
510 to 539.99
130
150
151
152
153
540 to 569.99
154
160
161
162
570 to 599.99
154
169
170
171
600 to 629.99
154
178
179
180
630 to 659.99
178
188
189
660 to 689.99
178
197
198
690 to 719.99
178
202
207
720 to 749.99
202
216
750 to 779.99
202
225
780 to 809.99
202
226
810 to 839.99
226
840 to 869.99
226
870 to 899.99
226
For each additional household member over 8 add $22 to the 8-person allotment.
2
B
TAB B
ABUSE OR LEGITIMATE GROWTH
As the background materials (Tab A) indicate there has been
substantial growth in both the numbers of people participating
and in the costs of the program. Whether this growth re-
flects legitimate increases in the number of households
eligible under the law or it is due to large scale abuses
and violations of the program is difficult to determine.
This difficulty is due in part to the structure of the
program which has the states administering the eligibility
determinations, the U.S. Department of Agriculture certifying
and reviewing the stores which accept the food stamps as
payments, banks cashing the stamps for the stores and both
the Federal and state governments handling the stamps
themselves. In sum, program control is scattered and
therefore accurate information is difficult to collect.
There are clearly areas of abuse
-- the total allowable deductions claimed now average
49 percent of a participant's gross income.
Items such as housing costs, child care and emergency
expenses are open to abuse.
-- food stamps have in a sense become an accepted
currency generally negotiable in many communities.
-- the many steps in the handling of stamps provide
opportunities for nonrecipients to avail themselves
of unused stamps by completing a recipient's pur-
chase requirement and retaining bonus stamps.
-- states pay no part of the cost of the bonus recipients
receive but pay 50% of administrative costs. Thus
efforts to improve administrative control are costly
to states and bring no dollar return.
Similarly there are factors totally legitimate which have
enabled this growth
-- increases in the cost of food raise eligibility
levels at a pace faster than wages.
--- unemployment increases participation.
-- Congress has pushed for increased participation
by those who are eligible.
- -2-
In sum, there are many explanations of the sudden growth -- -
some legal, other illegal -- but the program is so complex
and its administration so open to confusion and abuse that
it is not possible to weigh precisely the cause of this
growth. There is little question, however, that recent
trends in unemployment and in the cost of food have played
a major role in this growth.
FORD & LIBRARY GERALD
D 17 ?
TAB C
ADMINISTRATIVE REFORM
The Department of Agriculture, OMB, and Domestic Council
staff have agreed on the following legislative proposals
to deal with tightening accountability, penalizing and
retarding abuses and simplifying administration:
1. Eliminate Variable Purchase
Eliminate the option to purchase 25% and 75% of
a full coupon allotment by deleting the variable
purchase provision. This will improve administra-
tion by reducing the potential for fraud but will
leave participants the option of purchasing coupons
twice monthly if short of cash.
2. Withholding Purchase Requirement
Let State agencies decide whether to withhold
Food Stamp purchase requirements from public assist-
ance checks. This will increase State flexibility
to apply different systems where statewide or local
conditions permit.
3. Adjusting Fines
Adjust the maximum fine for misdemeanor offenses
to equal the jurisdictional limit of U.S. Magistrate
Courts. At present, the limit is $1000. This will
make it easier to prosecute Food Stamp criminal
offenders.
4. Civil Penalties
Permit the Secretary to levy civil money penalties
for certain program violations. This will add to
the available sanctions and facilitate prosecution
of Food Stamp offenders, but will not add commen-
surately to court congestion.
5. Illegal Aliens
Clarify that illegal and temporarily present aliens
are not eligible for Food Stamp participation.
This will codify present regulations and will make
Food Stamp and SSI statutory requirements more
consistent.
-2-
6. Employer Supplied Housing
Eliminate the $25 of countable income which is
imputed to employer-supplied housing. This will
simplify program administration and make the
treatment of in-kind housing consistent with the
treatment of other in-kind benefits for Food
Stamp purposes.
7. Demonstration Projects
Authorize the Secretary to approve administrative
demonstration projects which may be proposed by
the states. This will encourage state innovations
to improve local, and hopefully national program
administration.
8. State Accountability
Augment State administrative responsibilities to
include "accountability for" coupons, as well as
receipt and issuance of coupons. This will allow
states to be fully accountable for all intra-
State coupon activities, including periodic
reconciliation of coupon and cash transactions.
9. Defining Negligence
Reduce the standard of negligence applicable to
State administrative performance from gross to
ordinary negligence. This will make it easier
to seek recoupment of Federal bonus costs where
State certification practices are deficient.
10. Wrongfully Denied Benefits
Allow lump sum cash payments to participants,
equal to their "bonus" entitlement, where benefits
have been wrongfully denied. This will simplify
administration and will be more equitable than
reducing future purchase requirements, which
is the current practice.
11. Mechanical Failure
Authorize cash payments to individuals where
mechanical failure prevents State issuance of an
Authorization-to-Purchase card. This will eli-
minate the need for states to maintain redundant
computer systems and/or stand-by manual issuance
capability.
-3-
12. Age for Work Requirement
Lower the maximum age for mandatory work regis-
tration from 65 to 60 years. This will make work
registration consistent with other Food Stamp
age provisions and simplify the administration of
work registration requirements.
D
Tab D
GROUP ELIGIBILITY
Issue: Strikers and Food Stamps
Current Law
Under current law, strikers do not violate the "refusal
to accept employment" work requirement, and strikers are
eligible for food stamps based on their post-strike income.
Facts/Background
USDA and outside critics believe that providing food
stamps may tend to prolong strikes. Analysis of the
impact of food stamps on the length of labor disputes
is not available.
Alternatives
Require strikers to wait 60 days before becoming eligible
for food stamps, but retain the present exemption for
refusal to accept suitable employment.
Arguments For:
- Immediate eligibility may be unnecessary on a "needs"
basis, and my prolong labor disputes.
- Federal bonus payments may be somewhat reduced.
Arguments Against:
- Creates precedent of non-eligibility for "special"
types of unemployment which is difficult to explain.
- Likely to be unpopular with labor representatives.
- Would be treating a problem which is present in
other income transfer programs but deals only with
food stamp recipients.
Issue: Student Eligibility for Food Stamps
Current Law
FY 1975 appropriations language prohibits participation by
a student, 18 and over, properly claimed as a tax dependent
of an ineligible household. A broader prohibition against
dependent student eligibility under the Food Stamp Act was
declared unconstitutional (Murry VS. USDA). "Bona fide"
students between 18 and 65 are exempt from food stamp work
registration requirements.
Facts/Background
The food stamp program now includes participation by
individuals who voluntarily forego income in order to
attend school. Survey data indicate approximately 2 million
students participatingin the program; however, less than
10% of those would probably be affected by the tax dependency
provision. There are administrative difficulties with any
tax dependency approach. Among these difficulties are the
need for parental contact and the technicalities of a tax
dependency claim.
Alternative A
Amend present law (a) to make the tax dependency prohibition
currently in appropriations language a permanent part of
the Food Stamp Act, and (b) to extend work requirements
to all post-high school students.
Arguments For
- Dependent students of ineligible families should clearly
be ineligible for food stamps.
- Present eligibility provisions need to be clarified to
assure this result.
- "Voluntarily poor" food stamp participants should not
be exempted from work registration requirements.
Arguments Against
- Students from "involuntarily poor" families should be free
to study and improve themselves without having to work.
- Extending work registration requirements complicates
program administration.
Alternative B
Amend present law to prohibit eligibility as above, but
continue to exempt all otherwise eligible and bona fide
students from work registration requirements.
Arguments For
- Poor students should not be required to work to get
food stamp benefits because it could inhibit their
educational development and ultimate economic independence.
- New requirements are not placed on states.
Arguments Against
- There are other better mechanisms for financially
assisting poor students.
Issue: Eligibility of Addicts/Alcoholics
Current Law
Treatment centers are now authorized to act as retailers,
thereby enabling the centers to redeem coupons received from
residents or non-residents for cash.
Facts/Background
Center personnel are in the unique position of having
legitimate access to both a large volume of coupons and a
method for direct conversion of those coupons into cash.
The Department has no assurance that the coupon allotments
are being used for the food purposes provided and are not
being misused. There is currently no data available on
the number of addicts and alcoholics certified and, due to
the nature of the potential abuse, it may be impossible
to document such losses adequately.
Alternative
Repeal the 1973 amendments to (a) make addicts and alcoholics
who live in treatment institutions ineligible for food
stamps, and/or (b) remove the authorization of such centers
as retailers so they cannot accept coupons from residents
or non-residents or redeem the coupons for cash.
Arguments For:
- Adequate alternative programs exist for meeting the
nutritional needs of institutionalized persons, including
direct funding by HEW or the state government.
- Eliminates a unique opportunity for bad faith program abuses.
- Present special eligibility requirements complicate program
administration.
Arguments Against:
- Addicts and alcoholics seeking rehabilitation should be
eligible for food assistance to maintain them during the
rehabilitation process.
- Non-resident addicts and alcoholics should be able to use
coupons or buy meals from the center the same as the
elderly can from communal dining facilities.
LIBRARY
FORD
3
TAB E
"CASH-OUT" OF FOOD STAMPS
The concept of replacing food stamps with direct cash
assistance has been raised before in general terms. In
order to include the "cash-out" concept in this review of
alternative courses for food stamp reform we have suggested
that the concept of Plan I, a standard deduction of $100
a month to replace current allowable deductions be coupled
with
1. elimination of the requirement that participants
pay a purchase price for their stamps.
2. direct distribution of the value of the food
stamp bonus as a cash payment.
RATIONALE
Cashing out food stamps would change the program to a pure
income maintenance program. Some data indicate that food
stamp recipients spend 50 to 65 percent more on food than
they would if they received the bonus in cash but others
have questioned this statistic and have also asked whether
increased expenditure for food means increased nutrition.
Whatever the actual facts, many who are now eligible do
not participate because of the purchase requirement.
This cash-out option would increase the number of parti-
cipants and would allow them the flexibility to purchase
whatever they want instead of being constrained to food as
they now are under the Food Stamp Program.
IMPACT
There are three important areas of impact of this proposal:
(1) the number of households who would participate and
consequent costs; (2) administrative simplification; (3)
acceptability at this time.
PARTICIPATION AND COSTS
Because this plan would eliminate itemized deductions and
implement a standard deduction, the redistributional effects
are the same as they are for Plan I (see Tab F). That is,
households who currently claim deductions in excess of $100
would either become ineligible or would have their benefits
reduced, and those households who currently cannot afford
deductions up to $100 would become eligible or would have
their benefits increased. Thus, some higher or "adequate"
income households would no longer be in the program, but
more poorer households would be better off than they are
now.
-2-
Total eligibility under this plan would be reduced by 11
percent (the same as Plan I), with about 63 percent of
households with reduced benefits being above the poverty
line and with no elderly member. These statistics are the
same as for Plan I. Thus maximum potential program costs
under this plan would be reduced in comparison to the
present Food Stamp Program as a result of eligibility
being reduced in the upper income classes.
However, one sure effect of eliminating the purchase
requirement is that participation will increase greatly.
Currently, only about 33 percent of all eligible house-
holds (based on income only) participate in the Food Stamp
Program, compared to the 94 percent participation rate of
the AFDC program. Participation in SSI falls somewhere in
between, although it is still a relatively new program.
Elimination of the food stamp purchase requirement and its
replacement by cash will doubtless make the program more
attractive to eligibles who now either cannot accumulate
the cash to buy the stamps or who prefer not to earmark
so much of their income for food. Thus, program costs
would increase greatly if participation climbed to 90 or
100 percent rates. If 90 to 100 percent of the 16 million
households (about 41 million persons) who would be eligible
under this Plan actually participated costs would be between
$8.5 and $9.4 billion annually. However, participation
rates that high may not be achieved for some time. If the
participation rate were 75 percent of the eligible population,
the costs would be around $7.9 billion annually, $2.1 billion
more than the current 1976 level of the Food Stamp Program.
ADMINISTRATIVE CONSIDERATIONS
Elimination of itemized deductions and implementation of a
standard deduction would provide the same administrative
simplification as would Plan I without the cash-out provision.
In addition, the cash-out would reduce the administrative
aspects of the current program that include printing, dis-
tributing, and issuing stamps, redeeming the stamps, and
certifying and monitoring grocery stores.
However, the administrative aspects of determining eligibility
for the new cash program and of issuing the checks to
participants should be carefully studied and coordinated
with existing cash and in-kind transfer program. The
following issues would have to be resolved:
-3-
1. Eligibility determination -- the options are:
a. maintain the current food stamp structure
requiring a separate determination for bene-
fits under this new cash program from benefit
determination under AFDC and SSI;
b. turn eligibility determination over to HEW
to be included with either AFDC or SSI.
2. Separate distribution of benefits -- the options are:
a. deliver the benefits as a separate check;
b. since about half of current participants receive
AFDC or SSI benefits, include the new benefits
in those checks;
C. withdraw the Federal share of AFDC, making it a
State program and federally distribute the new
program benefits, which would include the Federal
share of AFDC.
ADDITIONAL CONSIDERATIONS
Since a cashed-out program would have no direct relationship
to a nutritionally adequate diet, an important statutory
objective of the Food Stamp Program would be eliminated.
The nutrition aspect of the Food Stamp Program is a popular
concept and many food stamp supporters would be opposed to
a cash-out. Furthermore, there is evidence of support for
a program that allows taxpayers to have their tax money
earmarked for "good" expenditures on the part of the poor,
but which would not exist for a cash program which allowed
recipients to spend it as they see fit.
$100 standard deduction;*
30 percent Reduction Rate;
No Categorical Eligibility
or minimum bonus
Eligibles,
Participants,
and Costs
Eligible Households (thousands)
16,007
Percent Change from Current
-11%
Total annual cost
$ 9.4
assuming 100 percent
participation of
eligibles (billions)
Percent Change from Current 1/
+62%
Participating Households
14,406
if 90 Percent of Eligibles
Participate (thousands)
Percent Change from Current 2/
+112%
Total annual cost
$ 8.5
if 90 Percent of
Eligibles Participate (billions)
Percent Change from Current 1/
+47%
Participating Households
12,005
if 75 Percent of Eligibles
Participate (thousands)
Percent Change from Current 2/
+76%
Total annual cost
$ 7.9
if 75 Percent of
Eligibles Participate (billions)
Percent Change from Current 1/
+36%
1/ Costs for June 1975, annualized, are $5.8 billion.
2/ Assumes June 1975 participation of 6.81 million households (21.8 million
individuals).
* In addition, mandatory tax withholding and expenses due to casualities
or disasters are allowed.
F
Tab F
Plans For Reforming Income Eligibility Determinations
If you decide to act now on Income Eligibility there are a
variety of strategies available.
Option 1. Recommend a specific change in eligibility and
income tests.
Arguments For:
- It is the only proposal which will yield significant savings
(up to $1 billion) in 1976 and 1977.
- Reducing eligibility and benefits to higher income families
will have the greatest effect in restricting long-term
program growth.
- While data on which the size of benefit changes are estimated
have substantial deficiencies, it is the best that could be
available to the Administration or the Congress for nine
months to a year. There is no current indication that a
national survey is being planned.
- Can provide a redistribution of benefits by which 1.3 to
2.6 million families (mostly the poorest) gain benefits.
- A standard deduction, as proposed in several of the plans,
will do the most to simplify program administration.
- The proposed eligibility and income test changes are not
inconsistent with comprehensive welfare reform.
Arguments Against:
- Moving now on a major change in the benefit structure could
complicate and possibly impede comprehensive welfare reform
by:
Setting a negative tone for ultimate welfare reform to
the extent that it proposes a net reduction in benefits.
Proceeding piecemeal in a fashion which does not provide
a change integrated with other welfare programs, including
even school feeding.
Resulting in higher benefits which would have to be
"bought up" in welfare reform, if the Congress uses
this opportunity to expand benefits.
- 2 -
- From 1.6 to 3.1 million participating families will lose
benefits abruptly.
- Because of limited and aged data, the benefit loss impact
on families could be understated. Precise estimates on
the range of error are not available.
- During the current economic conditions, Congress is unlikely
to accept any plan which has significant benefit reductions,
even if many poorer families would gain.
- Opening up the basic benefit structure of food stamps at
this time could lead to substantial liberalization of the
program.
Option 2. Recommend legislation to establish a standard
deduction with no categorical eligibility, with a special
deduction for the elderly but with the specific deduction
levels subject to negotiation with the Congress.
Arguments For:
- Advances the basic reform of a standard deduction.
- Avoids vulnerability to criticisms of specific benefit
loss impact or uncertain knowledge of that impact by in-
volving the Congress in those sensitive decisions.
- Is quite defensible as a response to Senate's request
for recommendations.
Arguments Against:
- Fails to stake out a firm initial position from which to
negotiate.
- Could provide more leeway for the Congress to liberalize
the program (standard deduction could be easily increased).
- Introduces an inequity that is difficult to justify on
anything other than political grounds.
Option 3. Offer the Congress a discussion of several options
on eligibility and income tests, together with legislative
proposals for administrative reform.
- 3 -
Arguments For:
- Avoids the problems cited in arguments against Option 1.
- Partially responds to Senate Resolution and places the
burden on the Congress to address the problem.
- Could be coupled with a recommendation to seek better data
on which to base subsequent proposals.
- Facilitates reform as a part of comprehensive welfare reform.
Arguments Against:
- The Administration could be criticized as being nonresponsive
on the income and eligibility issue.
- Does not propose basic limitations on program growth.
- Fails to seek budgetary savings.
- Does not successfully avoid the criticism that the plans all
result in benefit losses to a substantial number of families.
- Would initiate a debate that the Administration should control.
Choosing a Specific Plan
If you elected Option 1, it is necessary to choose among the
alternative plans outlined in the following section.
Alternative Plans for Changing the Eligibility and Income Tests
There are six alternative plans for eligibility and income
tests from which you can select for use as discussion items
or a specific legislative recommendation. The plans are
outlined in Table 1 followed by individual discussions.
Data on the benefit impact of the last two plans is being
produced, but will not be available for two weeks.
Major Components
There are four components in most of the alternatives:
- 4 -
Standard Deduction: In lieu of the current computation of
net income by allowing numerous itemized deductions from gross
income, a standard deduction is proposed. This could vary
with family size, but would not vary with income or family
circumstances.
Effects
Simplifies administration.
Eliminates eligibility or reduces benefits for persons
with high income and large deductions and is more
liberal for those with low deductions.
Does not reflect particular family circumstances, e.g.,
medical bills, work expenses.
Added Aged Deduction. A higher standard deduction could be
proposed for households with persons over age 65. This is
not in the current program.
Effects
Minimizes the losses for a large and vocal beneficiary
group.
Creates inequities because income needs are not higher
for aged compared to non-aged persons.
Would establish a precedent for special treatment of
an interest group.
Minimum Bonus. By law, the bonus must not fall below set
minimum levels by family size (e.g., $24 per month for a
family of four) so long as a family remains eligible. If
the minimum bonus were eliminated, benefits would scale down
to zero, based on net income.
Effects
Equity goals are furthered by similar treatment.
Removes the present "notch" -- substantial loss of
benefits due to a small income increase.
Costs are reduced by scaling benefits to income.
- 5 -
Participation would decline among households now
receiving minimum bonus amounts.
Elimination of the minimum bonus by regulation was
attempted and was overridden by intense Congressional
pressure in 1972.
Categorical Eligibility. All AFDC and 71% of SSI households
are now eligible for benefits without regard to their income.
Effects
Equity suggests abandoning this provision to achieve
like treatment of families in same (income and size)
circumstances.
Benefits would be abruptly cut off for non-low income
eligible aged, disabled, and AFDC recipients.
To the extent that alternatives incorporate these components,
some plan for phasing, to avoid abrupt changes in benefit
levels, needs to be developed.
PLAN I - STANDARD DEDUCTION
A. Description: This plan provides a $100 monthly
standard deduction to all households, regardless of
age or family size. It eliminates categorical
eligibility for public assistance recipients.
B. Rationale: Treats all participants of a given income
level in the same way.
C. Impact: Overall participation would be about 20% lower
than it is now, and so total bonus costs would drop by
15% ($1.0 billion). At the same time, this plan makes
about 132,000 households eligible who are currently
ineligible, of which 13% are below the poverty line
and 87% are above.
1. 15.5 percent (109,000) of currently participating
households below the poverty line and including
an elderly member would be "worse-off" than they
are now because they currently claim itemized
deductions in excess of $100.
-- About 9 percent, or 9,000 households, in
this group would actually become ineligible.
-- 100,000 households would have their bonuses
reduced.
2. 39 percent of currently participating poverty
households with an elderly member actually have
their bonuses increased.
3. 7,600 households become eligible who aren't now
because they do not claim deductions.
LIBRARI
PLAN I
Impact Assessment
1/
Thousands of families losing/gaining $5 to $24 per month
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
5
0
7
3
4
1
0
0
100-199
200
79
179
15
81
21
26
6
200-299
232
134
65
124
88
107
19
11
300-399
0
51
36
115
96
204
24
9
400-599
0
16
6
121
96
209
82
53
0
1
600-799
0
29
12
209
44
51
0
0
0
800+
24
0
370
36
59
1/
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
Plan I
Impact Assessment
Thousands of families losing/gaining more than $25 per month
1
/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
0
0
0
0
0
2
0
0
100-199
0
3
0
7
6
6
6
0
200-299
0
22
0
11
17
19
8
5
300-399
0
10
0
28
7
19
7
5
400-599
0
0
0
22
11
85
24
18
600-799
0
0
0
0
0
72
2
32
800+
0
0
0
0
0
108
0
154
1/ Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN II - STANDARD DEDUCTION
A.
Description: This plan is based on a $100 monthly
standard deduction varied by size of household plus
$50 monthly if the household includes an elderly
member. The actual standard deduction varies by
household size so that one-person households have
a standard deduction of $36 monthly while seven-
person households have a deduction of $137 monthly
Automatic eligibility for public assistance recipients
is eliminated.
B.
Rationale: Designed to vary the deduction so that
it would be small for small households and large for
large households. Special treatment for the elderly
is included for three primary reasons:
1. Current deduction rules are designed SO that the
elderly are treated preferentially by allowing
large deductions for small families with high
incomes.
2. There is considerable precedent for special
treatment for the elderly in other Federal programs,
including the double deduction allowed for persons
over 65 on their Federal income.
3. The $50 extra for the elderly was added as a
partial compensation to the elderly who live in
small households and would be made worse off
because of the size adjustment in this plan.
C.
Impact: This plan reduced eligibility by 16% and
participation by 23%. In spite of the special
deduction for the elderly, 40% of currently par-
ticipating households with an elderly member would
lose benefits, and 25% of participating elderly
households below the poverty line would lose
benefits. Adjusting the amount of the deduction
for family size would provide greater benefits to
the larger households, who already have larger
allotments.
Plan II
Impact Assessment
Thousands of families losing/gaining $5 to $24 per month:
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
3
24
7
15
4
5
1
0
100-199
105
200
71
88
67
36
28
3
200-299
15
185
96
176
73
135
34
8
300-399
0
51
40
98
86
202
35
7
400-599
0
16
3
122
108
191
66
26
600-799
0
1
0
29
37
197
53
38
800+
0
0
0
24
2
233
52
48
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN II
Impact Assessment
Thousands of families losing/gaining more than $25 per month1/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
0
0
0
3
0
0
0
0
100-199
0
35
2
8
14
6
17
0
200-299
0
49
3
37
31
22
17
3
300-399
0
9
0
53
24
31
20
2
400-599
0
0
0
33
39
90
90
14
600-799
0
0
0
0
2
67
30
15
800+
0
0
0
1
0
102
23
119
1/
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN III - STANDARD DEDUCTION
A.
Description: Provides $100 monthly standard deduction
to all households plus $50 monthly if the household
includes an elderly member. This plan retains auto-
matic eligibility for AFDC and SSI recipients so
that they are eligible even if their income is higher
than the limit that pertains to all others. Also,
the current minimum bonus is retained, so that no
participating household ever receives less than $24
monthly in bonus (free) stamps.
B.
Rationale: Retention of categorical eligibility is
desirable in the sense of maintaining the status
quo and recognizing that eligibility for public
assistance is indicative of the need for food
assistance.
This plan also retains the minimum bonus feature of
the current program which is intended to increase
participation of eligible households who might
otherwise consider the amount of their bonus not
to be worth the time and effort.
C.
Impact: Addition of automatic eligibility for public
assistance recipients and the minimum bonus to a
standard deduction plan adds greatly to costs and
caseloads. This plan would increase program costs.
by 11% over Plan I, of which 6% is a result of the
$50 extra deduction for the elderly, and 5% is a
result of categorical eligibility and the minimum
bonus. However, it maintains the status quo for
the 13% of currently participating households who
are eligible because of this special treatment for
public assistance recipients.
PLAN III
Impact Assessment
Thousands of families losing/gaining $5 to $24 per month 1/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
5
0
7
3
4
3
0
0
100-199
287
50
110
14
81
19
22
6
200-299
244
81
192
94
87
99
22
11
300-399
12
43
119
58
121
196
24
9
400-599
0
13
60
65
134
164
84
49
600-799
0
0
0
1
116
119
36
50
800+
0
0
0
0
0
29
20
43
1/
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN III
Impact Assessment
Thousands of families losing/gaining more than $25 per month
1/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
0
0
0
0
0
0
0
0
100-199
84
3
25
5
11
5
10
0
200-299
15
16
31
8
26
19
9
3
300-399
0
9
9
21
15
19
7
3
400-599
0
0
2
14
20
71
27
18
600-799
0
0
0
0
12
56
10
27
800+
0
0
0
0
2
31
25
55
1/
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN IV - STANDARD DEDUCTION
A.
Description: Provides $125 monthly standard deduction
to all households plus $25 monthly if the household
includes an elderly member.
B.
Rationale: The standard deduction for all households
in this plan is larger than in the other plans in
order to minimize the number of current participants
who would be worse off by moving to a standard deduc-
tion. However, the $150 maximum for households with
an elderly member is retained by providing them $25
extra per month.
C.
Impact: The higher standard deduction of $125 aids
mainly non-elderly households in poverty. This plan
produces a 3% decrease in the cost of the program,
but would increase the number of participants by 2%,
and the total number of eligible households would in-
crease slightly. Thus, this plan, compared with the
others, has a minimal impact on the level of program
operation.
Plan IV
Impact Assessment
Thousands of families losing/gaining $5 to $24 per month:
1
/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
5
0
7
3
4
3
1
0
100-199
330
23
155
12
145
12
32
3
200-299
233
68
223
43
145
30
34
11
300-399
3
45
127
61
127
64
33
6
400-599
0
16
46
116
167
163
69
27
600-799
0
1
0
29
52
199
52
42
800+
0
0
0
24
2
239
43
51
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
PLAN IV
Impact Assessment
Thousands of families losing/gaining more than $25 per month 1/
Family Size
1
2
3-5
6 or more
Gross
Income Class
Gain
Lose
Gain
Lose
Gain
Lose
Gain
Lose
0
0
0
0
0
0
0
0
0
1-99
0
0
0
0
0
0
0
0
100-199
86
0
42
3
34
2
12
0
200-299
15
8
43
3
58
16
14
5
300-399
0
5
13
17
58
11
12
3
400-599
0
0
2
20
46
51
79
14
600-799
0
0
0
0
3
58
20
19
800+
0
0
0
0
0
100
11
140
1/
Zero indicates either no measurable data or no impact. USDA
will categorize each cell before memo goes to the President.
LIBRARY
PLAN V - VARIABLE TAX PLAN
A.
Description: Under this plan itemized deductions
would be allowed only for payroll withholding,
medical expenses over $10 per month, and housing
up to a maximum based on BLS low budget housing
figures. Purchase requirements would then be estab-
lished on the basis of rates that vary, so that low
income households would pay a low percentage of net
income, and higher income households would pay a
higher rate. Conceivably, these rates could range
from zero to 99 percent.
B.
Rationale: The primary aim is a more progressive
redistribution. Furthermore, it somewhat masks
the percentage of income paid, since the percent
would vary.
C.
Impact: The impact of this type of plan can be very
much the same as the impact of any given level of a
standard deduction in that some households would
become ineligible, some would have reduced bonuses
while others would become eligible and still others
would have their bonuses increased. How many
participants fall into these categories would depend
on the maximum eligibility income level and the
income level at which the purchase requirements
became so high that participation would be discour-
aged.
Computer analysis of benefit impact will be completed
for this plan within two weeks.
GERAL, FORD LIBRARY
PLAN VI - DEDUCTIONS FOR NECESSITIES
A. Description: This plan is similar to the current program
in that it allows the current itemized deductions, except
those for educational fees, work-related expenses, and
payroll deductions, except Federal and States taxes.
However, the primary differences is that for each deduc-
tion, there would be a maximum limit placing a cut-off
point on the deductions. The limits would be:
- Shelter up to the BLS low budget shelter cost.
- Day care up to one-third of a parent's earned
income.
- Medical in excess of 10% of monthly income, or
$10, whichever is greater.
B. Rationale: This plan is a "middle ground" approach
because, while it would curtail benefits to upper
income participants, it would not improve benefits
or equity to lower income households. It would not
be perceived as a major program overhaul, but would
remove some households with "adequate incomes" from
eligibility.
C. Impact: This plan would moderately simplify program
administration. Computer analysis of benefit impact
will be available within the next two weeks.
Document source description
This file includes material relating to the efforts attempting to reform the Food Stamps program administratively and legislatively, and court cases challenging those reforms.
Page data
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Document data
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"ocrText": "The original documents are located in Box 15, folder \"Food Stamps (3)\" of the James M.\nCannon Files at the Gerald R. Ford Presidential Library.\nCopyright Notice\nThe copyright law of the United States (Title 17, United States Code) governs the making of\nphotocopies or other reproductions of copyrighted material. Gerald Ford donated to the United\nStates of America his copyrights in all of his unpublished writings in National Archives collections.\nWorks prepared by U.S. Government employees as part of their official duties are in the public\ndomain. The copyrights to materials written by other individuals or organizations are presumed to\nremain with them. If you think any of the information displayed in the PDF is subject to a valid\ncopyright claim, please contact the Gerald R. Ford Presidential Library.\nDigitized from Box 15 of the James M. Cannon Files at the Gerald R. Ford Presidential Library\nTHE WHITE HOUSE\nWASHINGTON\nMay 16, 1975\nMEMORANDUM FOR:\nTHE PRESIDENT\nFROM:\nJIM CANNON\nSUBJECT:\nFood Stamp Reform\nFORD & LIBRARY GERALD\nThe purpose of this memorandum is to present various actions\nwhich can be taken to reform the Food Stamp program. We\nhave limited the options presented for your decision to the\nkey issues but information on all elements of the reform\nproposals are provided in the tabs.\nBACKGROUND\nA description of the current program and a brief background\nsummary are included in Tab A. In essence the program has\ngrown from a $200 million program in 1968 serving 2.5 million\npeople to an estimated $6.6 billion program serving 21 million\npeople in 1976.\nABUSE OR LEGITIMATE GROWTH (Tab B)\nIt is difficult to determine with precision what proportion\nof this growth is due to abuse of the system and what is\ndue to factors entirely legitimate under current law such as\nCongressionally mandated outreach efforts to encourage parti-\ncipation. It is clear, however, that the greater part of the\nmost recent growth has been related to factors outside the\nprogram such as unemployment and increase in the cost of food.\nPOINTS OF NOTE\nTwo points should be brought to your attention:\n1. The information base upon which estimates are made of\nthe impacts of the various options in this paper is\nextremely shaky. While it is the best available it\ndoes not enable a confident prediction of program\nimpact on caseload, costs, or actual benefits.\n-2-\n2. The U.S. Department of Agriculture study from which\nthis package of recommendations is developed does\nnot address the asset test aspects of the program.\nMany of the apparent abuses which receive publicity\nare caused by the existing lenient asset test (i.e.,\nparticipants are permitted to retain multiple auto-\nmobiles, large cash value insurance policies, expen-\nsive houses, etc.). The specific reforms suggested,\nhowever, tend to eliminate the higher income partici-\npants where these assets are particularly a problem.\nADMINISTRATIVE REFORM\nTwelve specific legislative proposals to simplify adminis-\ntration, tighten accountability and penalize and retard\nabuses have been agreed upon by OMB, the Department of\nAgriculture and the Domestic Council. These are largely\nnoncontroversial, specific actions which we believe should\nbe taken regardless of other decisions. They are listed\nand described in Tab C.\nOPTIONS FOR CONSIDERATION\nThe following summarize the essential options for your\nconsideration. Details on each are provided in the designated\ntabs.\nA. Group Eligibility (Tab D)\n1.\nStrikers - All employable food stamp recipients\nare denied eligibility if they refuse to accept\nemployment. Being on strike, however, is not\ngrounds for denying eligibility\n--- one possibility would be to require\nstrikers to wait 60 days before becoming\neligible for food stamps. Since the striker\nissue affects a number of income assistance\nprograms, we recommend this issue not be\npart of the food stamp reform.\n2.\nAddicts and Alcoholics - Eligibility is denied\nto residents of institutions where meals are\nprepared for them. Current law exempts drug\naddicts and alcoholics in institutional treat-\nment programs enabling them to be the only\ninstitutionalized individuals eligible for\nfood stamps\n-- we have proposed eliminating this exemption.\n-3-\n3.\nCollege Students - Two elements of the current law\naffect eligibility of college students for food\nstamps\na. current law is confused in regard to eli-\ngibility for students who are claimed as\na tax deduction by families which are not\neligible for food stamps.\nb. eligible students are exempt from require-\nment to accept employment\n-- we recommend clarifying the tax\ndependency provision but continuing\nthe exemption from work requirement.\nB. Income Eligibility and Benefit Structure\nWe recommend that your reform package include con-\nsideration of the eligibility determination based on\nincome since this is the central factor determining\ncaseload, costs, and the benefits people receive.\nThe following options are available:\n1.\nInclude in an Overall Reform - The most logical\nand effective food stamp reform would be to\nconsider food stamps as part of a complete\noverhaul of all income transfer programs.\n-- we recommend that should an overhaul of all\nincome transfer programs be considered, food\nstamps be included. This should not preclude\ntaking independent action on food stamp\nprogram now.\n2.\nAction Now - If you agree that action should be\ntaken now on the income eligibility and benefit\nstructure of food stamps there are two general\napproaches:\na.\nEliminate Food Stamps (Tab E)\nCurrent use of food stamps could cease and\neligible recipients would simply be mailed\na check for the cash value of the current\nbonus they receive. Some sort of standard de-\nduction could be used to determine eligibility.\n-- overall effect would be to increase benefit\ncosts which are 100% Federal since more\npeople would participate.\n-- estimates of potential additional Federal\ncosts in FY 76 range from $1.4 Billion to\n$3.6 Billion.\n-4-\nb. Revise Current Eligibility System (Tab F)\nIf you decide to continue use of food stamps\nand to recommend revisions in eligibility\ndeterminations, you could\n-- select one specific plan.\n-- recommend a standard deduction type of\nplan and let Congress set dollar amount.\n-- offer a choice of specific plans and\nlet Congress select one.\nThe plans developed deal with:\n-- deductions, currently a complex and\narbitrary system permits people to\ndeduct a number of items from their\ngross incomes to enable their becoming\neligible even though their gross income\nmay be well above poverty line.\n-- automatic eligibility for welfare\nrecipients, no matter what their actual\ncash and in kind income is.\nThe specific plans developed:\n1. Set a $100 monthly national standard\ndeduction for all families and eliminate\ncategorical eligibility.\n2. Set a $100 national standard deduction\nwhich varies by family size with special\n$50 addition for aged and eliminate\ncategorical eligibility.\n3. Set a single $100 national standard\nbut continue categorical eligibility and\ninclude a special deduction for the aged\nof $50.\n4. Set $100 national standard deduction, deny\ncategorical eligibility but add $25 special\ndeduction for aged.\n5. Create a progressive chart of income\neligibility and bonus values.\n6. Put dollar limits on amounts which can be\ndeducted under current law.\nESTIMATED 1976 IMPACT*\nCURRENT\nPLAN I\nII\nIII\nIV\nTotal Households Participating\n(Millions)\n5.4\n4.3\n4.2\n5.4\n4.8\nTotal Annual Cost (Billions)\n6.6\n5.9\n5.9\n6.6\n6.6\nNumber of Households with Bonus\nUnchanged (Millions)\n-\n1.6\n1.2\n2.1\n1.2\nNumber of Households With\nBonus Increased (Millions)\n-\n1.3\n1.3\n2.0\n2.6\nNumber of Households With Bonus\nDecreased (Millions)\n-\n2.7\n3.1\n1.6\n1.9\n*Estimates for Plans V - VI are not available\nRECOMMENDATIONS\n1.\nAdministrative Reform Package, we recommend that you\napprove the package of 12 specific administrative reforms.\nOMB and Agriculture agree.\nApprove\nDisapprove\n2.\nStrikers, we recommend that no change be made in current\neligibility for strikers. The Department of Labor agrees.\nApprove\nDisapprove\n3.\nAddicts and Alcoholics, we recommend legislation to\neliminate the present exemption permitting food stamp\neligibility for institutionalized addicts and alcoholics.\nApprove\nDisapprove\n4.\nCollege Students, we recommend legislation to clarify\ntax dependency aspect of eligibility for college students\nwith continuation of exemption from work requirement.\nApprove\nDisapprove\n5.\nOverall Reform, we recommend inclusion of food stamps\nif an overall reform of income assistance programs is\nundertaken but we also recommend that independent action\nbe taken now to reform food stamp eligibility.\nApprove\nDisapprove\n6.\nEliminate Food Stamps, we recommend that food stamps\ncontinue to be used and therefore not be \"cashed out\"\nat this time. Bill Seidman and the Department of\nAgriculture also support continued use of food stamps.\nApprove\nDisapprove\n7.\nSpecific Revision of Eligibility, we recommend that you\nchoose plan III which:\na.\nreplaces allowable deductions from income\nwith one monthly standard deduction of $100.\nb.\ncontinues automatic eligibility for welfare\nrecipients.\nC.\nprovides as special additional income deduction\nof $50 per month for the aged.\nApprove\nDisapprove\nTab A\nBACKGROUND\nCURRENT PROGRAM\nEligibility for food stamps and benefit levels are deter-\nmined by income, assets, household size and a defined set\nof allowable deductions from gross income. The allotment\nis the amount of food stamps a household may purchase based\non family size. The cost to an eligible household to\npurchase an allotment is based on income. The difference\nbetween the purchase price and the face value of the allot-\nment is the \"bonus.\" The bonus is 100% federally funded.\nA food stamp household may choose to vary the level of\nparticipation by committing once each month to purchase\n25, 50, 75 or 100 percent of its allotment. Food stamps\nare available automatically to all public assistance and\nmost SSI households.\nHouseholds with net earned income become eligible according\nto the following schedule ( a more detailed schedule is\nattached as the last page to this tab) :\nHousehold Size\nMonthly Income Limit\n1\n194\n2\n280\n3\n406\n4\n513\n5\n606\n6\n700\n7\n793\n8\n886\nIt is important to note that the net income in question\nis gross income minus a number of allowable deductions\nfor medical costs, housing, child care, payroll taxes\nand a number of other specific deductions. These deductions\nhave played a central role in opening eligibility to families\nwhose gross incomes are well above the poverty level.\nThe food stamp program has two objectives stated in law\nin 1964:\n1. Raise nutritional levels of low income households.\n2. Distribute agricultural surpluses.\n- 2 -\nNeither of these objectives is applicable today.\n-- Although in effect for 10 years, there is\nstill no evidence that the program raises\nnutritional levels.\n--- Distribution of agricultural surpluses is\nnot a problem.\nInstead, the program has, since 1968, become a vast income\nsupport mechanism with the largest caseload and fastest\ngrowing costs of any major welfare program:\nFY 1968\nFY 1970\nFY 1972\nFY 1974\nFY 1976 (est.)\nParticipants\n2.5\n6.5\n10.5\n13.5\n21.0\n(millions)\nCost (billions)\n.2\n.6\n2.0\n2.8\n6.6\nUntil 1974, most of these increases were due to added\nparticipation by those receiving some form of public assistance.\nSince that time, however, the growth has been due primarily\nto increased participation by those who are not eligible\nfor any other welfare program. Currently, participation\nin food stamp program\nPublic Assistance:\n46%\n9.7 million\nNon Public Assistance:\n54%\n11.3 million\nIt should also be noted that since 1972 the value of the\nfood stamp bonus and, therefore, eligibility for participation\nhas been tied to increases in the cost of food.\nRECENT FACTORS\nThe FY 1976 budget proposal for a uniform charge (30% of\nnet income) for food stamps was overturned by P.L. 94-4.\nConcurrently, Senator Dole initiated S. Res. 58, requiring\nthe Secretary of Agriculture to review the food stamp\nprogram and to recommend by June 30 legislation to:\n-- Disqualify families with adequate incomes;\n-- Reduce administrative complexity;\nGERALD ROND CIGNARY\n--- Tighten accountability; and\n-- Increase penalties for fraud.\nSenate Agriculture Committee will soon hold hearings on\nfood stamp legislation. USDA has drafted a study and\nproposed recommendations.\nFOOD STAMP ALLOTMENTS AND PURCHASE REQUIREMENTS (Effective January 1)\n48 States and\nNumber of Persons in Household:\nDistrict of Columbia\n1\n2\n3\n4\n5\n6\n7\n8\nMonthly Coupon Allotment:\n$46\n$84\n$122.\n$154\n$182\n$210\n$238\n$266\nMonthly Net Income\nMonthly Purchase Requirement:\n$\n0\nto\n19.99\n$ 0\n$ 0\n$ 0\n$ 0\n$ 0\n$ 0\n$ 0\n$ 0\n20 to\n29.99\n1\n1\n0\n0\n0\n0\n0\n0\n30\nto\n39.99\n4\n4\n4\n4\n5\n5\n5\n5\n40\nto\n49.99\n6\n7\n7\n7\n8\n8\n8\nS\n50\nto\n59.99\n8\n10\n10\n10\n11\n11\n12\n12\n60\nto\n69.99\n10\n12\n13\n13\n14\n14\n15\n16\n70\nto\n79.99\n12\n15\n16\n16\n17\n17\n18\n19\n80\nto\n89.99\n14\n18\n19\n19\n20\n21\n21\n22\n90\nto\n99.99\n16\n21\n21\n22\n23\n24\n25\n26\n100 to 109.99\n18\n23\n24\n25\n26\n27\n28\n29\n110 to 119.99\n21\n26\n27\n28\n29\n31\n32\n33\n120 to 129.99\n24\n29\n30\n31\n33\n34\n35\n36\n130 to 139.99\n27\n32\n33\n34\n36\n37\n38\n39\n140 to 149.99\n30\n35\n36\n37\n39\n40\n41\n42\n150 to 169.99\n33\n38\n40\n41\n42\n43\n44\n45\n170 to 189.99\n36\n44\n46\n47\n48\n49\n50\n51\n190 to 209.99\n36\n50\n52\n53\n54\n55\n56\n57\n210 to 229.99\n56\n58\n59\n60\n61\n62\n63\n230 to 249.99\n62\n64\n65\n66\n67\n68\n69\n250 to 269.99\n64\n70\n71\n72\n73\n74\n7.5\n270 to 289.99\n64\n76\n77\n78\n79\n80\n81\n290 to 309.99\n82\n83\n84\n85\n86\n87\n310 to 329.99\n88\n89\n90\n91\n92\n93\n330 to 359.99\n94\n95\n96\n97\n98\n99\n360 to 389.99\n100\n104\n105\n106\n107\n108\n390 to 419.99\n104\n113\n114\n115\n116\n117\n420 to 449.99\n122\n123\n124\n125\n126\n450 to 479.99\n130\n132\n133\n134\n135\n480 to 509.99\n130\n141\n142\n143\n144\n510 to 539.99\n130\n150\n151\n152\n153\n540 to 569.99\n154\n160\n161\n162\n570 to 599.99\n154\n169\n170\n171\n600 to 629.99\n154\n178\n179\n180\n630 to 659.99\n178\n188\n189\n660 to 689.99\n178\n197\n198\n690 to 719.99\n178\n202\n207\n720 to 749.99\n202\n216\n750 to 779.99\n202\n225\n780 to 809.99\n202\n226\n810 to 839.99\n226\n840 to 869.99\n226\n870 to 899.99\n226\nFor each additional household member over 8 add $22 to the 8-person allotment.\n2\nB\nTAB B\nABUSE OR LEGITIMATE GROWTH\nAs the background materials (Tab A) indicate there has been\nsubstantial growth in both the numbers of people participating\nand in the costs of the program. Whether this growth re-\nflects legitimate increases in the number of households\neligible under the law or it is due to large scale abuses\nand violations of the program is difficult to determine.\nThis difficulty is due in part to the structure of the\nprogram which has the states administering the eligibility\ndeterminations, the U.S. Department of Agriculture certifying\nand reviewing the stores which accept the food stamps as\npayments, banks cashing the stamps for the stores and both\nthe Federal and state governments handling the stamps\nthemselves. In sum, program control is scattered and\ntherefore accurate information is difficult to collect.\nThere are clearly areas of abuse\n-- the total allowable deductions claimed now average\n49 percent of a participant's gross income.\nItems such as housing costs, child care and emergency\nexpenses are open to abuse.\n-- food stamps have in a sense become an accepted\ncurrency generally negotiable in many communities.\n-- the many steps in the handling of stamps provide\nopportunities for nonrecipients to avail themselves\nof unused stamps by completing a recipient's pur-\nchase requirement and retaining bonus stamps.\n-- states pay no part of the cost of the bonus recipients\nreceive but pay 50% of administrative costs. Thus\nefforts to improve administrative control are costly\nto states and bring no dollar return.\nSimilarly there are factors totally legitimate which have\nenabled this growth\n-- increases in the cost of food raise eligibility\nlevels at a pace faster than wages.\n--- unemployment increases participation.\n-- Congress has pushed for increased participation\nby those who are eligible.\n- -2-\nIn sum, there are many explanations of the sudden growth -- -\nsome legal, other illegal -- but the program is so complex\nand its administration so open to confusion and abuse that\nit is not possible to weigh precisely the cause of this\ngrowth. There is little question, however, that recent\ntrends in unemployment and in the cost of food have played\na major role in this growth.\nFORD & LIBRARY GERALD\nD 17 ?\nTAB C\nADMINISTRATIVE REFORM\nThe Department of Agriculture, OMB, and Domestic Council\nstaff have agreed on the following legislative proposals\nto deal with tightening accountability, penalizing and\nretarding abuses and simplifying administration:\n1. Eliminate Variable Purchase\nEliminate the option to purchase 25% and 75% of\na full coupon allotment by deleting the variable\npurchase provision. This will improve administra-\ntion by reducing the potential for fraud but will\nleave participants the option of purchasing coupons\ntwice monthly if short of cash.\n2. Withholding Purchase Requirement\nLet State agencies decide whether to withhold\nFood Stamp purchase requirements from public assist-\nance checks. This will increase State flexibility\nto apply different systems where statewide or local\nconditions permit.\n3. Adjusting Fines\nAdjust the maximum fine for misdemeanor offenses\nto equal the jurisdictional limit of U.S. Magistrate\nCourts. At present, the limit is $1000. This will\nmake it easier to prosecute Food Stamp criminal\noffenders.\n4. Civil Penalties\nPermit the Secretary to levy civil money penalties\nfor certain program violations. This will add to\nthe available sanctions and facilitate prosecution\nof Food Stamp offenders, but will not add commen-\nsurately to court congestion.\n5. Illegal Aliens\nClarify that illegal and temporarily present aliens\nare not eligible for Food Stamp participation.\nThis will codify present regulations and will make\nFood Stamp and SSI statutory requirements more\nconsistent.\n-2-\n6. Employer Supplied Housing\nEliminate the $25 of countable income which is\nimputed to employer-supplied housing. This will\nsimplify program administration and make the\ntreatment of in-kind housing consistent with the\ntreatment of other in-kind benefits for Food\nStamp purposes.\n7. Demonstration Projects\nAuthorize the Secretary to approve administrative\ndemonstration projects which may be proposed by\nthe states. This will encourage state innovations\nto improve local, and hopefully national program\nadministration.\n8. State Accountability\nAugment State administrative responsibilities to\ninclude \"accountability for\" coupons, as well as\nreceipt and issuance of coupons. This will allow\nstates to be fully accountable for all intra-\nState coupon activities, including periodic\nreconciliation of coupon and cash transactions.\n9. Defining Negligence\nReduce the standard of negligence applicable to\nState administrative performance from gross to\nordinary negligence. This will make it easier\nto seek recoupment of Federal bonus costs where\nState certification practices are deficient.\n10. Wrongfully Denied Benefits\nAllow lump sum cash payments to participants,\nequal to their \"bonus\" entitlement, where benefits\nhave been wrongfully denied. This will simplify\nadministration and will be more equitable than\nreducing future purchase requirements, which\nis the current practice.\n11. Mechanical Failure\nAuthorize cash payments to individuals where\nmechanical failure prevents State issuance of an\nAuthorization-to-Purchase card. This will eli-\nminate the need for states to maintain redundant\ncomputer systems and/or stand-by manual issuance\ncapability.\n-3-\n12. Age for Work Requirement\nLower the maximum age for mandatory work regis-\ntration from 65 to 60 years. This will make work\nregistration consistent with other Food Stamp\nage provisions and simplify the administration of\nwork registration requirements.\nD\nTab D\nGROUP ELIGIBILITY\nIssue: Strikers and Food Stamps\nCurrent Law\nUnder current law, strikers do not violate the \"refusal\nto accept employment\" work requirement, and strikers are\neligible for food stamps based on their post-strike income.\nFacts/Background\nUSDA and outside critics believe that providing food\nstamps may tend to prolong strikes. Analysis of the\nimpact of food stamps on the length of labor disputes\nis not available.\nAlternatives\nRequire strikers to wait 60 days before becoming eligible\nfor food stamps, but retain the present exemption for\nrefusal to accept suitable employment.\nArguments For:\n- Immediate eligibility may be unnecessary on a \"needs\"\nbasis, and my prolong labor disputes.\n- Federal bonus payments may be somewhat reduced.\nArguments Against:\n- Creates precedent of non-eligibility for \"special\"\ntypes of unemployment which is difficult to explain.\n- Likely to be unpopular with labor representatives.\n- Would be treating a problem which is present in\nother income transfer programs but deals only with\nfood stamp recipients.\nIssue: Student Eligibility for Food Stamps\nCurrent Law\nFY 1975 appropriations language prohibits participation by\na student, 18 and over, properly claimed as a tax dependent\nof an ineligible household. A broader prohibition against\ndependent student eligibility under the Food Stamp Act was\ndeclared unconstitutional (Murry VS. USDA). \"Bona fide\"\nstudents between 18 and 65 are exempt from food stamp work\nregistration requirements.\nFacts/Background\nThe food stamp program now includes participation by\nindividuals who voluntarily forego income in order to\nattend school. Survey data indicate approximately 2 million\nstudents participatingin the program; however, less than\n10% of those would probably be affected by the tax dependency\nprovision. There are administrative difficulties with any\ntax dependency approach. Among these difficulties are the\nneed for parental contact and the technicalities of a tax\ndependency claim.\nAlternative A\nAmend present law (a) to make the tax dependency prohibition\ncurrently in appropriations language a permanent part of\nthe Food Stamp Act, and (b) to extend work requirements\nto all post-high school students.\nArguments For\n- Dependent students of ineligible families should clearly\nbe ineligible for food stamps.\n- Present eligibility provisions need to be clarified to\nassure this result.\n- \"Voluntarily poor\" food stamp participants should not\nbe exempted from work registration requirements.\nArguments Against\n- Students from \"involuntarily poor\" families should be free\nto study and improve themselves without having to work.\n- Extending work registration requirements complicates\nprogram administration.\nAlternative B\nAmend present law to prohibit eligibility as above, but\ncontinue to exempt all otherwise eligible and bona fide\nstudents from work registration requirements.\nArguments For\n- Poor students should not be required to work to get\nfood stamp benefits because it could inhibit their\neducational development and ultimate economic independence.\n- New requirements are not placed on states.\nArguments Against\n- There are other better mechanisms for financially\nassisting poor students.\nIssue: Eligibility of Addicts/Alcoholics\nCurrent Law\nTreatment centers are now authorized to act as retailers,\nthereby enabling the centers to redeem coupons received from\nresidents or non-residents for cash.\nFacts/Background\nCenter personnel are in the unique position of having\nlegitimate access to both a large volume of coupons and a\nmethod for direct conversion of those coupons into cash.\nThe Department has no assurance that the coupon allotments\nare being used for the food purposes provided and are not\nbeing misused. There is currently no data available on\nthe number of addicts and alcoholics certified and, due to\nthe nature of the potential abuse, it may be impossible\nto document such losses adequately.\nAlternative\nRepeal the 1973 amendments to (a) make addicts and alcoholics\nwho live in treatment institutions ineligible for food\nstamps, and/or (b) remove the authorization of such centers\nas retailers so they cannot accept coupons from residents\nor non-residents or redeem the coupons for cash.\nArguments For:\n- Adequate alternative programs exist for meeting the\nnutritional needs of institutionalized persons, including\ndirect funding by HEW or the state government.\n- Eliminates a unique opportunity for bad faith program abuses.\n- Present special eligibility requirements complicate program\nadministration.\nArguments Against:\n- Addicts and alcoholics seeking rehabilitation should be\neligible for food assistance to maintain them during the\nrehabilitation process.\n- Non-resident addicts and alcoholics should be able to use\ncoupons or buy meals from the center the same as the\nelderly can from communal dining facilities.\nLIBRARY\nFORD\n3\nTAB E\n\"CASH-OUT\" OF FOOD STAMPS\nThe concept of replacing food stamps with direct cash\nassistance has been raised before in general terms. In\norder to include the \"cash-out\" concept in this review of\nalternative courses for food stamp reform we have suggested\nthat the concept of Plan I, a standard deduction of $100\na month to replace current allowable deductions be coupled\nwith\n1. elimination of the requirement that participants\npay a purchase price for their stamps.\n2. direct distribution of the value of the food\nstamp bonus as a cash payment.\nRATIONALE\nCashing out food stamps would change the program to a pure\nincome maintenance program. Some data indicate that food\nstamp recipients spend 50 to 65 percent more on food than\nthey would if they received the bonus in cash but others\nhave questioned this statistic and have also asked whether\nincreased expenditure for food means increased nutrition.\nWhatever the actual facts, many who are now eligible do\nnot participate because of the purchase requirement.\nThis cash-out option would increase the number of parti-\ncipants and would allow them the flexibility to purchase\nwhatever they want instead of being constrained to food as\nthey now are under the Food Stamp Program.\nIMPACT\nThere are three important areas of impact of this proposal:\n(1) the number of households who would participate and\nconsequent costs; (2) administrative simplification; (3)\nacceptability at this time.\nPARTICIPATION AND COSTS\nBecause this plan would eliminate itemized deductions and\nimplement a standard deduction, the redistributional effects\nare the same as they are for Plan I (see Tab F). That is,\nhouseholds who currently claim deductions in excess of $100\nwould either become ineligible or would have their benefits\nreduced, and those households who currently cannot afford\ndeductions up to $100 would become eligible or would have\ntheir benefits increased. Thus, some higher or \"adequate\"\nincome households would no longer be in the program, but\nmore poorer households would be better off than they are\nnow.\n-2-\nTotal eligibility under this plan would be reduced by 11\npercent (the same as Plan I), with about 63 percent of\nhouseholds with reduced benefits being above the poverty\nline and with no elderly member. These statistics are the\nsame as for Plan I. Thus maximum potential program costs\nunder this plan would be reduced in comparison to the\npresent Food Stamp Program as a result of eligibility\nbeing reduced in the upper income classes.\nHowever, one sure effect of eliminating the purchase\nrequirement is that participation will increase greatly.\nCurrently, only about 33 percent of all eligible house-\nholds (based on income only) participate in the Food Stamp\nProgram, compared to the 94 percent participation rate of\nthe AFDC program. Participation in SSI falls somewhere in\nbetween, although it is still a relatively new program.\nElimination of the food stamp purchase requirement and its\nreplacement by cash will doubtless make the program more\nattractive to eligibles who now either cannot accumulate\nthe cash to buy the stamps or who prefer not to earmark\nso much of their income for food. Thus, program costs\nwould increase greatly if participation climbed to 90 or\n100 percent rates. If 90 to 100 percent of the 16 million\nhouseholds (about 41 million persons) who would be eligible\nunder this Plan actually participated costs would be between\n$8.5 and $9.4 billion annually. However, participation\nrates that high may not be achieved for some time. If the\nparticipation rate were 75 percent of the eligible population,\nthe costs would be around $7.9 billion annually, $2.1 billion\nmore than the current 1976 level of the Food Stamp Program.\nADMINISTRATIVE CONSIDERATIONS\nElimination of itemized deductions and implementation of a\nstandard deduction would provide the same administrative\nsimplification as would Plan I without the cash-out provision.\nIn addition, the cash-out would reduce the administrative\naspects of the current program that include printing, dis-\ntributing, and issuing stamps, redeeming the stamps, and\ncertifying and monitoring grocery stores.\nHowever, the administrative aspects of determining eligibility\nfor the new cash program and of issuing the checks to\nparticipants should be carefully studied and coordinated\nwith existing cash and in-kind transfer program. The\nfollowing issues would have to be resolved:\n-3-\n1. Eligibility determination -- the options are:\na. maintain the current food stamp structure\nrequiring a separate determination for bene-\nfits under this new cash program from benefit\ndetermination under AFDC and SSI;\nb. turn eligibility determination over to HEW\nto be included with either AFDC or SSI.\n2. Separate distribution of benefits -- the options are:\na. deliver the benefits as a separate check;\nb. since about half of current participants receive\nAFDC or SSI benefits, include the new benefits\nin those checks;\nC. withdraw the Federal share of AFDC, making it a\nState program and federally distribute the new\nprogram benefits, which would include the Federal\nshare of AFDC.\nADDITIONAL CONSIDERATIONS\nSince a cashed-out program would have no direct relationship\nto a nutritionally adequate diet, an important statutory\nobjective of the Food Stamp Program would be eliminated.\nThe nutrition aspect of the Food Stamp Program is a popular\nconcept and many food stamp supporters would be opposed to\na cash-out. Furthermore, there is evidence of support for\na program that allows taxpayers to have their tax money\nearmarked for \"good\" expenditures on the part of the poor,\nbut which would not exist for a cash program which allowed\nrecipients to spend it as they see fit.\n$100 standard deduction;*\n30 percent Reduction Rate;\nNo Categorical Eligibility\nor minimum bonus\nEligibles,\nParticipants,\nand Costs\nEligible Households (thousands)\n16,007\nPercent Change from Current\n-11%\nTotal annual cost\n$ 9.4\nassuming 100 percent\nparticipation of\neligibles (billions)\nPercent Change from Current 1/\n+62%\nParticipating Households\n14,406\nif 90 Percent of Eligibles\nParticipate (thousands)\nPercent Change from Current 2/\n+112%\nTotal annual cost\n$ 8.5\nif 90 Percent of\nEligibles Participate (billions)\nPercent Change from Current 1/\n+47%\nParticipating Households\n12,005\nif 75 Percent of Eligibles\nParticipate (thousands)\nPercent Change from Current 2/\n+76%\nTotal annual cost\n$ 7.9\nif 75 Percent of\nEligibles Participate (billions)\nPercent Change from Current 1/\n+36%\n1/ Costs for June 1975, annualized, are $5.8 billion.\n2/ Assumes June 1975 participation of 6.81 million households (21.8 million\nindividuals).\n* In addition, mandatory tax withholding and expenses due to casualities\nor disasters are allowed.\nF\nTab F\nPlans For Reforming Income Eligibility Determinations\nIf you decide to act now on Income Eligibility there are a\nvariety of strategies available.\nOption 1. Recommend a specific change in eligibility and\nincome tests.\nArguments For:\n- It is the only proposal which will yield significant savings\n(up to $1 billion) in 1976 and 1977.\n- Reducing eligibility and benefits to higher income families\nwill have the greatest effect in restricting long-term\nprogram growth.\n- While data on which the size of benefit changes are estimated\nhave substantial deficiencies, it is the best that could be\navailable to the Administration or the Congress for nine\nmonths to a year. There is no current indication that a\nnational survey is being planned.\n- Can provide a redistribution of benefits by which 1.3 to\n2.6 million families (mostly the poorest) gain benefits.\n- A standard deduction, as proposed in several of the plans,\nwill do the most to simplify program administration.\n- The proposed eligibility and income test changes are not\ninconsistent with comprehensive welfare reform.\nArguments Against:\n- Moving now on a major change in the benefit structure could\ncomplicate and possibly impede comprehensive welfare reform\nby:\nSetting a negative tone for ultimate welfare reform to\nthe extent that it proposes a net reduction in benefits.\nProceeding piecemeal in a fashion which does not provide\na change integrated with other welfare programs, including\neven school feeding.\nResulting in higher benefits which would have to be\n\"bought up\" in welfare reform, if the Congress uses\nthis opportunity to expand benefits.\n- 2 -\n- From 1.6 to 3.1 million participating families will lose\nbenefits abruptly.\n- Because of limited and aged data, the benefit loss impact\non families could be understated. Precise estimates on\nthe range of error are not available.\n- During the current economic conditions, Congress is unlikely\nto accept any plan which has significant benefit reductions,\neven if many poorer families would gain.\n- Opening up the basic benefit structure of food stamps at\nthis time could lead to substantial liberalization of the\nprogram.\nOption 2. Recommend legislation to establish a standard\ndeduction with no categorical eligibility, with a special\ndeduction for the elderly but with the specific deduction\nlevels subject to negotiation with the Congress.\nArguments For:\n- Advances the basic reform of a standard deduction.\n- Avoids vulnerability to criticisms of specific benefit\nloss impact or uncertain knowledge of that impact by in-\nvolving the Congress in those sensitive decisions.\n- Is quite defensible as a response to Senate's request\nfor recommendations.\nArguments Against:\n- Fails to stake out a firm initial position from which to\nnegotiate.\n- Could provide more leeway for the Congress to liberalize\nthe program (standard deduction could be easily increased).\n- Introduces an inequity that is difficult to justify on\nanything other than political grounds.\nOption 3. Offer the Congress a discussion of several options\non eligibility and income tests, together with legislative\nproposals for administrative reform.\n- 3 -\nArguments For:\n- Avoids the problems cited in arguments against Option 1.\n- Partially responds to Senate Resolution and places the\nburden on the Congress to address the problem.\n- Could be coupled with a recommendation to seek better data\non which to base subsequent proposals.\n- Facilitates reform as a part of comprehensive welfare reform.\nArguments Against:\n- The Administration could be criticized as being nonresponsive\non the income and eligibility issue.\n- Does not propose basic limitations on program growth.\n- Fails to seek budgetary savings.\n- Does not successfully avoid the criticism that the plans all\nresult in benefit losses to a substantial number of families.\n- Would initiate a debate that the Administration should control.\nChoosing a Specific Plan\nIf you elected Option 1, it is necessary to choose among the\nalternative plans outlined in the following section.\nAlternative Plans for Changing the Eligibility and Income Tests\nThere are six alternative plans for eligibility and income\ntests from which you can select for use as discussion items\nor a specific legislative recommendation. The plans are\noutlined in Table 1 followed by individual discussions.\nData on the benefit impact of the last two plans is being\nproduced, but will not be available for two weeks.\nMajor Components\nThere are four components in most of the alternatives:\n- 4 -\nStandard Deduction: In lieu of the current computation of\nnet income by allowing numerous itemized deductions from gross\nincome, a standard deduction is proposed. This could vary\nwith family size, but would not vary with income or family\ncircumstances.\nEffects\nSimplifies administration.\nEliminates eligibility or reduces benefits for persons\nwith high income and large deductions and is more\nliberal for those with low deductions.\nDoes not reflect particular family circumstances, e.g.,\nmedical bills, work expenses.\nAdded Aged Deduction. A higher standard deduction could be\nproposed for households with persons over age 65. This is\nnot in the current program.\nEffects\nMinimizes the losses for a large and vocal beneficiary\ngroup.\nCreates inequities because income needs are not higher\nfor aged compared to non-aged persons.\nWould establish a precedent for special treatment of\nan interest group.\nMinimum Bonus. By law, the bonus must not fall below set\nminimum levels by family size (e.g., $24 per month for a\nfamily of four) so long as a family remains eligible. If\nthe minimum bonus were eliminated, benefits would scale down\nto zero, based on net income.\nEffects\nEquity goals are furthered by similar treatment.\nRemoves the present \"notch\" -- substantial loss of\nbenefits due to a small income increase.\nCosts are reduced by scaling benefits to income.\n- 5 -\nParticipation would decline among households now\nreceiving minimum bonus amounts.\nElimination of the minimum bonus by regulation was\nattempted and was overridden by intense Congressional\npressure in 1972.\nCategorical Eligibility. All AFDC and 71% of SSI households\nare now eligible for benefits without regard to their income.\nEffects\nEquity suggests abandoning this provision to achieve\nlike treatment of families in same (income and size)\ncircumstances.\nBenefits would be abruptly cut off for non-low income\neligible aged, disabled, and AFDC recipients.\nTo the extent that alternatives incorporate these components,\nsome plan for phasing, to avoid abrupt changes in benefit\nlevels, needs to be developed.\nPLAN I - STANDARD DEDUCTION\nA. Description: This plan provides a $100 monthly\nstandard deduction to all households, regardless of\nage or family size. It eliminates categorical\neligibility for public assistance recipients.\nB. Rationale: Treats all participants of a given income\nlevel in the same way.\nC. Impact: Overall participation would be about 20% lower\nthan it is now, and so total bonus costs would drop by\n15% ($1.0 billion). At the same time, this plan makes\nabout 132,000 households eligible who are currently\nineligible, of which 13% are below the poverty line\nand 87% are above.\n1. 15.5 percent (109,000) of currently participating\nhouseholds below the poverty line and including\nan elderly member would be \"worse-off\" than they\nare now because they currently claim itemized\ndeductions in excess of $100.\n-- About 9 percent, or 9,000 households, in\nthis group would actually become ineligible.\n-- 100,000 households would have their bonuses\nreduced.\n2. 39 percent of currently participating poverty\nhouseholds with an elderly member actually have\ntheir bonuses increased.\n3. 7,600 households become eligible who aren't now\nbecause they do not claim deductions.\nLIBRARI\nPLAN I\nImpact Assessment\n1/\nThousands of families losing/gaining $5 to $24 per month\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n5\n0\n7\n3\n4\n1\n0\n0\n100-199\n200\n79\n179\n15\n81\n21\n26\n6\n200-299\n232\n134\n65\n124\n88\n107\n19\n11\n300-399\n0\n51\n36\n115\n96\n204\n24\n9\n400-599\n0\n16\n6\n121\n96\n209\n82\n53\n0\n1\n600-799\n0\n29\n12\n209\n44\n51\n0\n0\n0\n800+\n24\n0\n370\n36\n59\n1/\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPlan I\nImpact Assessment\nThousands of families losing/gaining more than $25 per month\n1\n/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n0\n0\n0\n0\n0\n2\n0\n0\n100-199\n0\n3\n0\n7\n6\n6\n6\n0\n200-299\n0\n22\n0\n11\n17\n19\n8\n5\n300-399\n0\n10\n0\n28\n7\n19\n7\n5\n400-599\n0\n0\n0\n22\n11\n85\n24\n18\n600-799\n0\n0\n0\n0\n0\n72\n2\n32\n800+\n0\n0\n0\n0\n0\n108\n0\n154\n1/ Zero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN II - STANDARD DEDUCTION\nA.\nDescription: This plan is based on a $100 monthly\nstandard deduction varied by size of household plus\n$50 monthly if the household includes an elderly\nmember. The actual standard deduction varies by\nhousehold size so that one-person households have\na standard deduction of $36 monthly while seven-\nperson households have a deduction of $137 monthly\nAutomatic eligibility for public assistance recipients\nis eliminated.\nB.\nRationale: Designed to vary the deduction so that\nit would be small for small households and large for\nlarge households. Special treatment for the elderly\nis included for three primary reasons:\n1. Current deduction rules are designed SO that the\nelderly are treated preferentially by allowing\nlarge deductions for small families with high\nincomes.\n2. There is considerable precedent for special\ntreatment for the elderly in other Federal programs,\nincluding the double deduction allowed for persons\nover 65 on their Federal income.\n3. The $50 extra for the elderly was added as a\npartial compensation to the elderly who live in\nsmall households and would be made worse off\nbecause of the size adjustment in this plan.\nC.\nImpact: This plan reduced eligibility by 16% and\nparticipation by 23%. In spite of the special\ndeduction for the elderly, 40% of currently par-\nticipating households with an elderly member would\nlose benefits, and 25% of participating elderly\nhouseholds below the poverty line would lose\nbenefits. Adjusting the amount of the deduction\nfor family size would provide greater benefits to\nthe larger households, who already have larger\nallotments.\nPlan II\nImpact Assessment\nThousands of families losing/gaining $5 to $24 per month:\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n3\n24\n7\n15\n4\n5\n1\n0\n100-199\n105\n200\n71\n88\n67\n36\n28\n3\n200-299\n15\n185\n96\n176\n73\n135\n34\n8\n300-399\n0\n51\n40\n98\n86\n202\n35\n7\n400-599\n0\n16\n3\n122\n108\n191\n66\n26\n600-799\n0\n1\n0\n29\n37\n197\n53\n38\n800+\n0\n0\n0\n24\n2\n233\n52\n48\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN II\nImpact Assessment\nThousands of families losing/gaining more than $25 per month1/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n0\n0\n0\n3\n0\n0\n0\n0\n100-199\n0\n35\n2\n8\n14\n6\n17\n0\n200-299\n0\n49\n3\n37\n31\n22\n17\n3\n300-399\n0\n9\n0\n53\n24\n31\n20\n2\n400-599\n0\n0\n0\n33\n39\n90\n90\n14\n600-799\n0\n0\n0\n0\n2\n67\n30\n15\n800+\n0\n0\n0\n1\n0\n102\n23\n119\n1/\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN III - STANDARD DEDUCTION\nA.\nDescription: Provides $100 monthly standard deduction\nto all households plus $50 monthly if the household\nincludes an elderly member. This plan retains auto-\nmatic eligibility for AFDC and SSI recipients so\nthat they are eligible even if their income is higher\nthan the limit that pertains to all others. Also,\nthe current minimum bonus is retained, so that no\nparticipating household ever receives less than $24\nmonthly in bonus (free) stamps.\nB.\nRationale: Retention of categorical eligibility is\ndesirable in the sense of maintaining the status\nquo and recognizing that eligibility for public\nassistance is indicative of the need for food\nassistance.\nThis plan also retains the minimum bonus feature of\nthe current program which is intended to increase\nparticipation of eligible households who might\notherwise consider the amount of their bonus not\nto be worth the time and effort.\nC.\nImpact: Addition of automatic eligibility for public\nassistance recipients and the minimum bonus to a\nstandard deduction plan adds greatly to costs and\ncaseloads. This plan would increase program costs.\nby 11% over Plan I, of which 6% is a result of the\n$50 extra deduction for the elderly, and 5% is a\nresult of categorical eligibility and the minimum\nbonus. However, it maintains the status quo for\nthe 13% of currently participating households who\nare eligible because of this special treatment for\npublic assistance recipients.\nPLAN III\nImpact Assessment\nThousands of families losing/gaining $5 to $24 per month 1/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n5\n0\n7\n3\n4\n3\n0\n0\n100-199\n287\n50\n110\n14\n81\n19\n22\n6\n200-299\n244\n81\n192\n94\n87\n99\n22\n11\n300-399\n12\n43\n119\n58\n121\n196\n24\n9\n400-599\n0\n13\n60\n65\n134\n164\n84\n49\n600-799\n0\n0\n0\n1\n116\n119\n36\n50\n800+\n0\n0\n0\n0\n0\n29\n20\n43\n1/\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN III\nImpact Assessment\nThousands of families losing/gaining more than $25 per month\n1/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n0\n0\n0\n0\n0\n0\n0\n0\n100-199\n84\n3\n25\n5\n11\n5\n10\n0\n200-299\n15\n16\n31\n8\n26\n19\n9\n3\n300-399\n0\n9\n9\n21\n15\n19\n7\n3\n400-599\n0\n0\n2\n14\n20\n71\n27\n18\n600-799\n0\n0\n0\n0\n12\n56\n10\n27\n800+\n0\n0\n0\n0\n2\n31\n25\n55\n1/\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN IV - STANDARD DEDUCTION\nA.\nDescription: Provides $125 monthly standard deduction\nto all households plus $25 monthly if the household\nincludes an elderly member.\nB.\nRationale: The standard deduction for all households\nin this plan is larger than in the other plans in\norder to minimize the number of current participants\nwho would be worse off by moving to a standard deduc-\ntion. However, the $150 maximum for households with\nan elderly member is retained by providing them $25\nextra per month.\nC.\nImpact: The higher standard deduction of $125 aids\nmainly non-elderly households in poverty. This plan\nproduces a 3% decrease in the cost of the program,\nbut would increase the number of participants by 2%,\nand the total number of eligible households would in-\ncrease slightly. Thus, this plan, compared with the\nothers, has a minimal impact on the level of program\noperation.\nPlan IV\nImpact Assessment\nThousands of families losing/gaining $5 to $24 per month:\n1\n/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n5\n0\n7\n3\n4\n3\n1\n0\n100-199\n330\n23\n155\n12\n145\n12\n32\n3\n200-299\n233\n68\n223\n43\n145\n30\n34\n11\n300-399\n3\n45\n127\n61\n127\n64\n33\n6\n400-599\n0\n16\n46\n116\n167\n163\n69\n27\n600-799\n0\n1\n0\n29\n52\n199\n52\n42\n800+\n0\n0\n0\n24\n2\n239\n43\n51\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nPLAN IV\nImpact Assessment\nThousands of families losing/gaining more than $25 per month 1/\nFamily Size\n1\n2\n3-5\n6 or more\nGross\nIncome Class\nGain\nLose\nGain\nLose\nGain\nLose\nGain\nLose\n0\n0\n0\n0\n0\n0\n0\n0\n0\n1-99\n0\n0\n0\n0\n0\n0\n0\n0\n100-199\n86\n0\n42\n3\n34\n2\n12\n0\n200-299\n15\n8\n43\n3\n58\n16\n14\n5\n300-399\n0\n5\n13\n17\n58\n11\n12\n3\n400-599\n0\n0\n2\n20\n46\n51\n79\n14\n600-799\n0\n0\n0\n0\n3\n58\n20\n19\n800+\n0\n0\n0\n0\n0\n100\n11\n140\n1/\nZero indicates either no measurable data or no impact. USDA\nwill categorize each cell before memo goes to the President.\nLIBRARY\nPLAN V - VARIABLE TAX PLAN\nA.\nDescription: Under this plan itemized deductions\nwould be allowed only for payroll withholding,\nmedical expenses over $10 per month, and housing\nup to a maximum based on BLS low budget housing\nfigures. Purchase requirements would then be estab-\nlished on the basis of rates that vary, so that low\nincome households would pay a low percentage of net\nincome, and higher income households would pay a\nhigher rate. Conceivably, these rates could range\nfrom zero to 99 percent.\nB.\nRationale: The primary aim is a more progressive\nredistribution. Furthermore, it somewhat masks\nthe percentage of income paid, since the percent\nwould vary.\nC.\nImpact: The impact of this type of plan can be very\nmuch the same as the impact of any given level of a\nstandard deduction in that some households would\nbecome ineligible, some would have reduced bonuses\nwhile others would become eligible and still others\nwould have their bonuses increased. How many\nparticipants fall into these categories would depend\non the maximum eligibility income level and the\nincome level at which the purchase requirements\nbecame so high that participation would be discour-\naged.\nComputer analysis of benefit impact will be completed\nfor this plan within two weeks.\nGERAL, FORD LIBRARY\nPLAN VI - DEDUCTIONS FOR NECESSITIES\nA. Description: This plan is similar to the current program\nin that it allows the current itemized deductions, except\nthose for educational fees, work-related expenses, and\npayroll deductions, except Federal and States taxes.\nHowever, the primary differences is that for each deduc-\ntion, there would be a maximum limit placing a cut-off\npoint on the deductions. The limits would be:\n- Shelter up to the BLS low budget shelter cost.\n- Day care up to one-third of a parent's earned\nincome.\n- Medical in excess of 10% of monthly income, or\n$10, whichever is greater.\nB. Rationale: This plan is a \"middle ground\" approach\nbecause, while it would curtail benefits to upper\nincome participants, it would not improve benefits\nor equity to lower income households. It would not\nbe perceived as a major program overhaul, but would\nremove some households with \"adequate incomes\" from\neligibility.\nC. Impact: This plan would moderately simplify program\nadministration. Computer analysis of benefit impact\nwill be available within the next two weeks."
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