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    "ocrText": "PPI Intern1 - feb29fsregs_immig.doc\nPage 10\nC.F.R. § 273.4(c)(2)(iii)) eliminates the $1,500 reduction. This reduction should be\nretained. In fact, comments should argue that it should be increased to $2,000, the\ncurrent allowable resource limit under the food stamp program for non-elderly\nhouseholds. This reduction -- which recognizes that the sponsor needs some assets\nfor his or her own household -- was set at $1,500 when the general food stamp asset\nlimit for non-elderly households was $1,500. Now that this limit is $2,000, the reduction\nalso should be $2,000.\nThe proposed rules retain a provision of the current rules that limits the amount\nof deemed income and resources to the sponsor's income and resources divided by the\nnumber of immigrants sponsored by the sponsor who apply for or participate in the food\nstamp program (proposed 7 C.F.R. § 273.4(c)(2)(iv)). Although this provision is\npositive and deserves support, it should be modified to eliminate the requirement that\nthe other sponsored immigrants must apply for or participate in the food stamp\nprogram. This limitation no longer makes sense given that most sponsored immigrants,\neven if otherwise eligible for food stamps based on their income and resources, are no\nlonger eligible for the food stamp program because of their status as immigrants.\nComments should urge that the final rules provide for the division of the sponsor's\nincome by the total number of immigrants that he or she has sponsored.\nOn another matter related to deeming, current rules provide that sponsor\ndeeming does not apply to an immigrant who is participating in the food stamp program\nas a member of his or her sponsor's household or to an immigrant whose sponsor is\nparticipating in the food stamp program separate and apart from the sponsored\nimmigrant. 7 C.F.R. § 273.11(j)(3)(i). The proposed rules retain the exemption for\nimmigrants who are participating as a member of their sponsor's household (proposed\nrule 7 C.F.R. § 273.4(c)(3)). But the proposed rules delete the exemption for\nimmigrants whose sponsors are participating as part of a household separate from that\nof the sponsored immigrant. Commenters should urge USDA to retain this additional\nexemption, since sponsors who are participating in the food stamp program are unlikely\nto have income that could lawfully be made available to the sponsored immigrant for\nsupport.\nFinally, USDA proposes to eliminate references to deeming under the pre-\nPRWORA section of the Food Stamp Act. This is a positive change that deserves\nsupport because it should help avoid unnecessary confusion in an already-complex\narea.\nC.\nTreatment of Income and Resources of Aliens Made Ineligible Under\nPRWORA\nThe proposed rule includes an important state option (proposed 7 C.F.R. §\n273.11(c)(3)(ii)(B)) that allows states to not count the income of immigrants ineligible\nunder PRWORA in determining the food stamp eligibility and benefits of U.S. citizens\nand eligible immigrants in the same household. Applying these favorable income-\n10"
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