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    "ocrText": "PPI Intern1 feb29fsregs_access.wpo\nPage 6\ncontaining at least a name, address, and signature. This still counts as filing an application, but the\nright to do so is unlikely to mean much if households are unaware of it. PRWORA gave USDA\nflexibility about how households would be informed of that right. In the preamble to these\nproposed regulations, USDA notes that \"it is very important to notify households through some\nmeans of these rights because benefits are provided to eligible households retroactive to the date\nof application.\" 65 Fed. Reg. 10864.\nUnfortunately, the proposed regulations severely undercut that goal. They would delete\nexisting provisions for informing households of this right without providing an effective\nsubstitute. The likely result is that many households will postpone applying until they have time\nto complete the entire application form. Some states' applications can exceed twenty pages.\nUSDA originally added these requirements to the food stamp rules because in their\nabsence, many households did not submit applications until their interview, which in some food\nstamp offices was not scheduled until two or more weeks after the household first visited the food\nstamp office. Among the requirements in current regulations that would be deleted are:\nthat there be a place on the front page of the application where the applicant can\nwrite his or her name, address, and signature (current 7 C.F.R. § 273.2(b)(1)(iv));\nthat \"plain and prominent language on or near the front page of the application\"\ninform households of their right to file the application immediately as long as it\ncontains the applicant's name, address, and signature, of the availability of\nexpedited service for households in particularly dire need, and of the fact that food\nstamp benefits are provided only from the date of application (current 7 C.F.R. $\n273.2(b)(1)(v));\nthat signs be placed in food stamp offices explaining the processing standards and a\nhousehold's right to file an application on the first day it contacts the food stamp\noffice (current 7 C.F.R. $ 273.2(c)(4));\nthat the food stamp office advise households they do not need to be interviewed\nbefore filing an application and may file an incomplete form SO long as it contains\nthe applicant's name, address, and signature (current 7 C.F.R. $ 273.2(c)(1)).\nComments should urge that each of these requirements be retained.\nProposed section 273.2(b)(2) contains a list of requirements for state application forms,\nbut these do not include information about the availability of, and importance of, the right to apply\nwithout delay. Instead, the proposed rules would merely require states to \"make available\nadvisory materials\" with this information. Proposed 7 C.F.R. § 273.2(b)(2). This information\ncould be buried in the middle of long, detailed pamphlets or hand-outs that also cover numerous\nmatters involving food stamps and other programs. Even for the few households that may read\nsuch materials, the clear message likely will often be lost. Comments should urge that the final\nrules require that this information be provided on the application form or on a single-page"
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