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    "ocrText": "PPI Intern1 - feb29fsregs_immig.wpd\nPage 12\nmixed-immigrant-status households because of the complex nature of food stamp rules that now\nrelate to immigrant eligibility for food stamps. 17 The welfare law and other recent legislation\nmakes some members of immigrant households eligible for food stamps and other members\nineligible. The complexities of determining immigrant eligibility and dealing with the treatment of\nincome and expenses of ineligible immigrants makes these households more error-prone than\nother food stamp households. Prior to the welfare law, immigrant households did not have an\nabove-average food stamp error rate. Now, the error rate for households with immigrant\nmembers is well above average. As a result, these households can be disproportionately subject\nto unannounced home visits.\nThe final rules should reduce the chilling effect that unannounced home visits have on\nimmigrants' participation in the food stamp program by applying the protections in the current\nrules on the use of home visits for verification purposes to all home visits conducted by food\nstamp agency personnel. State law enforcement officials investigating suspected fraud could, of\ncourse, conduct their own investigations and search homes with probable cause. USDA renders\nits own rule meaningless if it allows food stamp officials to evade its limits on home visits by\nrenaming them or by making routine referrals based only on a broadly-drawn error-prone profile.\nCommenters should urge USDA to require advance notice of home visits and to prohibit home\nvisits 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 other\nhousehold members who are undocumented or in an immigration status that renders them\nineligible for some means-tested programs. Food stamp agency requests for immigration status\ninformation or the Social Security numbers of these ineligible family members during the food\nstamp application process deters citizen children and eligible legal immigrant members of some\nmixed-status households from participating in the food stamp program.\nSometime in the very near future, HHS and USDA are expected to issue joint guidance\nrelating to state requests for SSN and immigration status information on Medicaid, CHIP, Food\nStamps, and TANF application forms. Although these issues are not explicitly addressed in the\nproposed rules, it is important that the final food stamp rules be consistent with this forthcoming\njoint agency guidance, which is expected to be quite helpful.\nThe preferred approach to food stamp agency requests for SSNs and information about\nimmigration status should be modeled on the Medicaid application process. In Medicaid, states\nare not implemented by states in ways that appear to target areas with high concentrations of immigrant\nhouseholds or have the effect of disproportionately reducing participation by groups protected under Title VI of\nthe Civil Rights Act.\n18\nFor an in-depth discussion of issues related to home visits in the proposed rules, see Center on Budget and\nPolicy, Analysis of Proposed Food Stamp Rules - Part One: Program Access Issues, pages"
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