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    "ocrText": "PPI Intern1 - feb29fsregs_immig.doc\nPage 13\ninvestigating suspected fraud could, of course, conduct their own investigations and\nsearch homes with probable cause. USDA renders its own rule meaningless if it allows\nfood stamp officials to evade its limits on home visits by renaming them or by making\nroutine referrals based only on a broadly-drawn error-prone profile.\nCommenters should urge USDA to require advance notice of home visits and to prohibit\nhome visits where a household has submitted sufficient verification 18\nB.\nRequests for SSNs and Immigration Status\nA substantial number of children eligible for food stamps live with parents or\nother household members who are undocumented or in an immigration status that\nrenders them ineligible for some means-tested programs. Food stamp agency requests\nfor immigration status information or the Social Security numbers of these ineligible\nfamily members during the food stamp application process deters citizen children and\neligible legal immigrant members of some mixed-status households from participating in\nthe food stamp program.\nSometime in the very near future, HHS and USDA are expected to issue joint\nguidance relating to state requests for SSN and immigration status information on\nMedicaid, CHIP, Food Stamps, and TANF application forms. Although these issues are\nnot explicitly addressed in the proposed rules, it is important that the final food stamp\nrules be consistent with this forthcoming joint agency guidance, which is expected to be\nquite helpful.\nThe preferred approach to food stamp agency requests for SSNs and\ninformation about immigration status should be modeled on the Medicaid application\nprocess. In Medicaid, states must allow applicants to designate specific family\nmembers as \"non-applicants\" before applicants are asked to provide immigration status\ninformation or SSNs for family members applying for Medicaid. A similar approach is\nallowable under the Food Stamp Act, and the final rules should require its use in food\nstamps as well. That would more effectively address the concerns that mixed-status\nhouseholds have about applying for food stamp benefits. Such an approach also\nshould facilitate alignment of the food stamp application process with Medicaid and\nmake it easier for states to design joint Medicaid\\Food Stamp applications.\nCommenters should urge USDA to allow food stamp applicants to designate specific\nfamily members as non-applicants before applicants are asked to provide immigration\nstatus information or SSNs for those family members who are applying.\nC.\nOther Verification Issues\nThe proposed rules raise several other significant issues related to verification,\nsome positive and others problematic. These include:\nVerification of Identity (Proposed 7 C.F.R. § 273.2(f)(1)(i)): The proposed\nrules delete language in the current rules which states that in verifying identify:\n13"
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