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    "ocrText": "PPI Intern1 - feb29fsregs_immig.wpd\nPage 2\nI.\nINTRODUCTION\nThe proposed rules will have a profound effect not only on legal immigrants, but also on\ncitizen children with live in immigrant families. Between 1994 and 1997, the number of children\nreceiving food stamps who live with legal immigrants fell by 41 percent, compared to a 15 percent\ndecline for children living with native-born parents.² The proposed rules contain a number of very\ndamaging provisions that could further exacerbate this disturbing trend.\nOne of the most troubling provisions in the proposed rules would count a sponsor's\nincome in determining the benefits of citizens and non-sponsored immigrants who happen to live\nwith a sponsored immigrant, even where the sponsored immigrant is ineligible for food stamps. In\nthe vast majority of these cases, counting the sponsor's income will make the other non-sponsored\nhousehold members - including citizen children in the household - ineligible for food stamps. If\nadopted, this rule would result in the denial of food stamp benefits to thousands of citizen\nchildren and eligible immigrants. There is no evidence to suggest that Congress intended this\nresult. This proposed rule is not required by federal law. USDA clearly has discretion to craft\ndeeming rules that would not have this unintended consequence.\nIn addition to this extremely troubling provision, the rules include a number of other\nimmigrant-related provisions, some of which are very problematic and would be likely to make it\nharder for eligible immigrants and citizen children to access food stamps, and others of which are\npositive and deserve support. In particular, a number of significant changes related to verification\nof immigration status, income and other information could burden immigrant families and lead to\nfurther declines in food stamp participation by eligible immigrant households and citizen members\nof immigrant households. In contrast, the provisions related to the treatment of income of\nimmigrants made ineligible for food stamps under PRWORA are generally positive (although a\nslight modification is needed) and deserve support.\nIt is very important that FNS receive as many separate comments as possible on these\nproposed regulations. Comments from organizations and persons knowledgeable about\nimmigrant issues are crucial and could have a substantial effect in determining the outcome of the\nfinal rules. This paper provides an analysis of the immigrant provisions in the proposed rules\nwhere public comment is most clearly needed. Comments must be received by USDA on or\nbefore May 1, 2000.\n2\nUnited States Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition, and\nEvaluation, Who is Leaving the Food Stamp Program? An Analysis of Caseload Changes from 1994 to 1997,\nMarch 1999."
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