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PPI Intern1 - Food Stamp Reg. Comments due by May 1 (Part 1 of 2 from CBPP)
Page 1
From:
"Martin Taylor" <[email protected]>
To:
"Waller, Margy- PPI" <[email protected]>
Date:
4/13/00 1:06PM
Subject:
Food Stamp Reg. Comments due by May 1 (Part 1 of 2 from CBPP)
On February 29, 2000 the U.S. Department of Agriculture issued the most important set of proposed food
stamp rules in almost 22 years and among the most troublesome in the history of the Program. The
regulations are published at 65 Federal Register 10856 - 10912, and can be found on the web at
http://www.fns.usda.gov/fsp/Regulations/FSPReg.htm. Public comments must be filed no later than May
1, 2000. This e-mail and included attachments are designed to assist you in analyzing and submitting
comments.
These proposed regulations open up many of the most important and controversial areas of food stamp
policy, including rules on applying and establishing eligibility for food stamps, procedures for determining
the continued eligibility of families leaving cash assistance, the eligibility of legal immigrants and their
families, and exclusions from income and resource calculations.
The most disturbing aspect of the proposed rules is the wholesale changes they would make in many of
the procedures that low-income households must navigate to obtain food stamp benefits. USDA is
proposing to eliminate literally dozens of provisions that protect low-income households' access to the
Program, many of which originated in the Nixon and Ford Administrations. These protections, codified
and enlarged in the 1978 regulations implementing the Food Stamp Act of 1977, survived the Reagan
and Bush Administrations largely unscathed. If these rules become final, they will represent a very major
set-back to households' access to the Food Stamp Program.
You should receive two e-mails today. They include as attachments the first two parts of our lengthy and
detailed analysis of the proposed regulations. These two parts cover the most important aspects of the
regulations: Part 1 addresses the very problematic application processing and other access issues
discussed above; Part 2 discusses the provisions that affect eligibility and access to food stamps for
low-income noncitizens. A Part 3 will contain analyses of the provisions that affect eligibility and
benefits, including the commendable proposal to exclude from the resource test those vehicles in which
a household has little or no equity. Each part begins with a table of contents.
We will distribute Part 3 and a shorter analysis by early next week, but did not want to postpone
distributing this analysis because of the breadth of the proposed changes and the limited time remaining
before the comment period ends. Unfortunately, it is not easy to distill the scores of troubling provisions
of the proposal into just a handful of issues. However, the cumulative effect of these numerous revisions
would greatly weaken many critical longstanding protections of households+ access to the Program.
States are under immense pressure to achieve and maintain low Quality Control error rates. It is all too
likely that if the regulations are not changed, many states would use the additional latitude they provide
to impose additional procedural hurdles on applicants and recipients, especially those whose
circumstances are more -error-prone,- such as working families and families with immigrant members.
In the past when states or local welfare offices have instituted policies that are either patently unfair or, in
a more subtle manner, present procedural barriers for needy households, the food stamp regulations
have been an important tool for program applicants or participants and their advocates to use to remedy
these situations. If the final regulations are not improved, that tool will be lost.
It is crucial that as many separate individuals and organizations submit comments as possible and that
the comments covers as many areas as possible. Persons who may have difficulty getting comments
approved by their organizations should not hesitate to submit their views as individuals. On the other
hand, not that much is added by having multiple signatories to a single set of comments. The crucial
policymakers at USDA and elsewhere in the Administration generally work from summaries that describe
the number of separate, non-identical letters received and the issues those comments raise. These
summaries tally the number of separate comments received on various sides of a controversial issue. A
letter on plain paper from an individual previously unknown to USDA staff will count as one comment.
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"ocrText": "PPI Intern1 - Food Stamp Reg. Comments due by May 1 (Part 1 of 2 from CBPP)\nPage 1\nFrom:\n\"Martin Taylor\" <[email protected]>\nTo:\n\"Waller, Margy- PPI\" <[email protected]>\nDate:\n4/13/00 1:06PM\nSubject:\nFood Stamp Reg. Comments due by May 1 (Part 1 of 2 from CBPP)\nOn February 29, 2000 the U.S. Department of Agriculture issued the most important set of proposed food\nstamp rules in almost 22 years and among the most troublesome in the history of the Program. The\nregulations are published at 65 Federal Register 10856 - 10912, and can be found on the web at\nhttp://www.fns.usda.gov/fsp/Regulations/FSPReg.htm. Public comments must be filed no later than May\n1, 2000. This e-mail and included attachments are designed to assist you in analyzing and submitting\ncomments.\nThese proposed regulations open up many of the most important and controversial areas of food stamp\npolicy, including rules on applying and establishing eligibility for food stamps, procedures for determining\nthe continued eligibility of families leaving cash assistance, the eligibility of legal immigrants and their\nfamilies, and exclusions from income and resource calculations.\nThe most disturbing aspect of the proposed rules is the wholesale changes they would make in many of\nthe procedures that low-income households must navigate to obtain food stamp benefits. USDA is\nproposing to eliminate literally dozens of provisions that protect low-income households' access to the\nProgram, many of which originated in the Nixon and Ford Administrations. These protections, codified\nand enlarged in the 1978 regulations implementing the Food Stamp Act of 1977, survived the Reagan\nand Bush Administrations largely unscathed. If these rules become final, they will represent a very major\nset-back to households' access to the Food Stamp Program.\nYou should receive two e-mails today. They include as attachments the first two parts of our lengthy and\ndetailed analysis of the proposed regulations. These two parts cover the most important aspects of the\nregulations: Part 1 addresses the very problematic application processing and other access issues\ndiscussed above; Part 2 discusses the provisions that affect eligibility and access to food stamps for\nlow-income noncitizens. A Part 3 will contain analyses of the provisions that affect eligibility and\nbenefits, including the commendable proposal to exclude from the resource test those vehicles in which\na household has little or no equity. Each part begins with a table of contents.\nWe will distribute Part 3 and a shorter analysis by early next week, but did not want to postpone\ndistributing this analysis because of the breadth of the proposed changes and the limited time remaining\nbefore the comment period ends. Unfortunately, it is not easy to distill the scores of troubling provisions\nof the proposal into just a handful of issues. However, the cumulative effect of these numerous revisions\nwould greatly weaken many critical longstanding protections of households+ access to the Program.\nStates are under immense pressure to achieve and maintain low Quality Control error rates. It is all too\nlikely that if the regulations are not changed, many states would use the additional latitude they provide\nto impose additional procedural hurdles on applicants and recipients, especially those whose\ncircumstances are more -error-prone,- such as working families and families with immigrant members.\nIn the past when states or local welfare offices have instituted policies that are either patently unfair or, in\na more subtle manner, present procedural barriers for needy households, the food stamp regulations\nhave been an important tool for program applicants or participants and their advocates to use to remedy\nthese situations. If the final regulations are not improved, that tool will be lost.\nIt is crucial that as many separate individuals and organizations submit comments as possible and that\nthe comments covers as many areas as possible. Persons who may have difficulty getting comments\napproved by their organizations should not hesitate to submit their views as individuals. On the other\nhand, not that much is added by having multiple signatories to a single set of comments. The crucial\npolicymakers at USDA and elsewhere in the Administration generally work from summaries that describe\nthe number of separate, non-identical letters received and the issues those comments raise. These\nsummaries tally the number of separate comments received on various sides of a controversial issue. A\nletter on plain paper from an individual previously unknown to USDA staff will count as one comment."
}