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    "ocrText": "PPI Intern1 - feb29fsregs_immig.doc\nPage 11\ncounting rules not only increases benefits to immigrant families but also will enable\nstates to provide much more generous state-funded food stamp restorations than would\notherwise be possible. By increasing the amount of federally-funded food stamps that\nan immigrant family receives, this policy reduces the gap a state-funded program must\nfill.\nThis is an important provision that deserves strong support. But it also needs\nrevision. As written in the proposed rules, this provision could have the unintended\neffect of reducing or eliminating benefits for some citizen children and other eligible\nimmigrants.\nProposed 7 C.F.R. § 273.11(c)(3)(ii)(B) provides that a state adopting the option\nnot to count the income of an ineligible legal immigrant must ensure that the resulting\nbenefit level for the eligible household members does not exceed the benefit the\nhousehold would be receiving if the ineligible immigrant member were \"still an eligible\nalien.\" [emphasis added]. The intent of this aspect of the proposed rules is reasonable.\nBut if the ineligible immigrant household member is a sponsored immigrant with a Form\nI-864 Affidavit of Support, then stipulating that the eligible household members cannot\nreceive a larger benefit level than the household would receive if the ineligible member\nwere an eligible immigrant would appear to mean that the state would have to go\nthrough complex deeming procedures to determine the benefit level that cannot be\nexceeded.\nThis would have two deleterious consequences. First, the complexity of the\ndeeming procedures could reduce state interest in the otherwise-helpful option allowing\nstates not to count the income of legal immigrants made ineligible for food stamps by\nPRWORA. Second, if the state counts the income deemed from an ineligible\nimmigrant's sponsor, the result will generally be that the eligible household members --\nwho are primarily citizen children -- will have their food stamp benefits cut or eliminated\nas a result of an option that was supposed to help them. This problem can readily be\nsolved if the food stamp benefit level for the eligible household members is capped at\nthe level the household would be receiving if the ineligible immigrant members were\ncitizens, rather than if they were eligible aliens. The sole difference here is that by\nusing an \"if they were citizens\" test, the perverse and presumably unintended\napplication of deeming in these circumstances is avoided.\nIV.\nVerification Issues that May Burden Participation by Immigrant Families\nThe verification process raises special concerns for immigrant families.\nDocuments required to establish citizenship or a food stamp-eligible immigration status\nsometimes can be difficult or take a number of weeks to obtain. In addition, routine\nrequests from food stamp offices for immigration status information or the social\nsecurity numbers of immigrant household members who are ineligible for food stamps -\n- and are not applying for food stamps -- may raise concerns about whether the\ninformation will be shared with the INS and deter participation by citizens and other\n11"
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