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    "ocrText": "PPI Intern1 - feb29fsregs_access.wpd\nPage 41\nComments should criticize this provision for imposing additional procedural\nburdens on persons with disabilities. Some persons with severe disabilities for\nwhom appearing at the food stamp office would be a serious burden may\nnonetheless not seek a waiver of the in-office interview to avoid being given a\nshort certification period. Others that are given shorter certification periods will be\nmore vulnerable to procedural terminations since they could have to renegotiate\nthe application process more frequently. Indeed, for a food stamp office to require\nmore frequent reapplications by households that receive accommodation for their\ndisabilities through a telephone or out-of-office interview may violate the\nAmericans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act.\nThe final rules should not invite such discriminatory practices.\nB.\nInvasions of Privacy\nRequiring families to submit to humiliating invasions of their privacy in order to obtain\nbenefits is likely to drive many away. This is particularly true of the working poor and the elderly\nand disabled, for whom the potential benefit may seem insubstantial compared with the\nembarrassment involved.\nThe Administration's July 14, 1999, initiative sought to expand food stamps' availability to\nthe working poor. The proposed rules, however, largely fail to take these concerns into\nconsideration. They continue a policy on home visits that, while superficially protective, is largely\nmeaningless as USDA has interpreted it. They would actually allow food stamp offices to call\nfamilies' friends, neighbors, and employers more freely, exacerbating existing state practices that\ninvade the privacy of working poor households and discourage them from participating in the\nFood Stamp Program. They also weaken existing protections of the confidentiality of interviews\nconducted with applicants. Because of USDA's intense pressure to reduce payment error rates,\nmany states are likely to take advantage of this license. Unless these problems are addressed, the\nAdministration's other food stamp initiatives and outreach efforts are unlikely to result in broad\nparticipation among eligible working poor families. To the contrary, the net effect of these rules\nand the USDA initiatives is likely to be further substantial participation declines.\n1.\nHome visits\nFew public actions are more inherently offensive and humiliating than having government\nagents enter one's home. The Framers of the Constitution recognized this: both the third and\nfourth amendments explicitly protect the sanctity of private homes against government intrusion.\nAs the Department notes at page 10869 of the preamble, federal courts have held these intrusions\nto be unconstitutional under some circumstances in cases such as Roberts v. Austin, 632 F. 2d\n1202 (5th Cir. 1980), cert. denied, 454 U.S. 975 (1981), and Reyes V. Edmunds, 472 F. Supp.\n1218 (D. Minn. 1979).\nIf applying for food stamps means that government agents will appear at the door, many\nneedy families will avoid the Program. This is particularly true of working poor families and those"
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