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PPI Intern1 feb29fsregs_immig.wpd Page 14 the forms of acceptable verification of citizenship listed in the rule cannot be obtained and there is a reasonable explanation for the lack of verification, the agency must accept a signed statement from some other U.S. citizen which declares, under penalty of perjury, that the member in question is a U.S. citizen. 7 C.F.R. $ 273.2(f)(2)(ii)(A). This provision is deleted in the proposed rules. Commenters should insist that it be retained. Allowing Sufficient Time to Gather Required Documents: Current food stamp rules provide that in cases where verification is incomplete, the agency must provide the household with a statement of what verification is still required and allow the household at least 10 additional days to provide the "particular verification that was missing." 7 C.F.R. § 273.2(h)(1)(i)(C). The proposed rules greatly weaken this protection. They eliminate the reference to the "particular verification that was missing" and can be read to allow only 10 days for all verification to be provided, even if some additional verification is requested by the state agency during the 10-day period. Commenters should urge USDA to maintain the current practice, under which the household must receive a full ten days to provide any specific piece of verification (and longer if necessary if the household is attempting to cooperate but needs more time to come up with the documents). In addition, current rules at 7 C.F.R. $ 273.2(g)(3) prohibit denying a household's application within the 30 days after a household has applied if the application cannot be processed because some needed information is missing and the household is trying to secure the information. The proposed rules omit this protection, too. The current regulation was written in the 1970s and retained in the 1980s and 1990s to curb what had been the widespread practice of automatically denying applicants after ten days regardless of whether they were trying to obtain required verification. Finally, the proposed rules deleted an important provision that gives households a total of at least sixty days to submit necessary material without having to complete a new application. Under current 7 C.F.R. § 273.2(h)(2)(A), a food stamp office has two choices when a household's eligibility cannot be determined, despite the office's best efforts, by the end of the thirtieth day after application. One option is to hold the application pending for up to sixty days. The other is to send the household a notice of denial but to inform the household that its application will be reactivated if the household takes the required actions within thirty additional days. In either case, the household has a total of at least sixty days to submit the necessary material within 30 days of that date without having to complete a new application. (If the delay was the fault of the household, benefits are retroactive only to the date when the household provided the information.) USDA's proposed regulations repeal this requirement that denied applications be reopened. Where a food stamp office has not chosen to hold an application pending, it appears that USDA intends to require low-income households to submit a new application and restart the application process even though they have produced the verification necessary to determine their eligibility. Commenters should urge USDA to retain the requirement that a denied application be reopened where the remaining information

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    "ocrText": "PPI Intern1 feb29fsregs_immig.wpd\nPage 14\nthe forms of acceptable verification of citizenship listed in the rule cannot be obtained and\nthere is a reasonable explanation for the lack of verification, the agency must accept a\nsigned statement from some other U.S. citizen which declares, under penalty of perjury,\nthat the member in question is a U.S. citizen. 7 C.F.R. $ 273.2(f)(2)(ii)(A). This\nprovision is deleted in the proposed rules. Commenters should insist that it be retained.\nAllowing Sufficient Time to Gather Required Documents: Current food stamp rules\nprovide that in cases where verification is incomplete, the agency must provide the\nhousehold with a statement of what verification is still required and allow the household at\nleast 10 additional days to provide the \"particular verification that was missing.\" 7 C.F.R.\n§ 273.2(h)(1)(i)(C). The proposed rules greatly weaken this protection. They eliminate\nthe reference to the \"particular verification that was missing\" and can be read to allow only\n10 days for all verification to be provided, even if some additional verification is\nrequested by the state agency during the 10-day period.\nCommenters should urge USDA to maintain the current practice, under which the\nhousehold must receive a full ten days to provide any specific piece of verification (and\nlonger if necessary if the household is attempting to cooperate but needs more time to\ncome up with the documents). In addition, current rules at 7 C.F.R. $ 273.2(g)(3) prohibit\ndenying a household's application within the 30 days after a household has applied if the\napplication cannot be processed because some needed information is missing and the\nhousehold is trying to secure the information. The proposed rules omit this protection,\ntoo. The current regulation was written in the 1970s and retained in the 1980s and 1990s\nto curb what had been the widespread practice of automatically denying applicants after\nten days regardless of whether they were trying to obtain required verification.\nFinally, the proposed rules deleted an important provision that gives households a total of\nat least sixty days to submit necessary material without having to complete a new\napplication. Under current 7 C.F.R. § 273.2(h)(2)(A), a food stamp office has two\nchoices when a household's eligibility cannot be determined, despite the office's best\nefforts, by the end of the thirtieth day after application. One option is to hold the\napplication pending for up to sixty days. The other is to send the household a notice of\ndenial but to inform the household that its application will be reactivated if the household\ntakes the required actions within thirty additional days. In either case, the household has a\ntotal of at least sixty days to submit the necessary material within 30 days of that date\nwithout having to complete a new application. (If the delay was the fault of the\nhousehold, benefits are retroactive only to the date when the household provided the\ninformation.)\nUSDA's proposed regulations repeal this requirement that denied applications be\nreopened. Where a food stamp office has not chosen to hold an application pending, it\nappears that USDA intends to require low-income households to submit a new application\nand restart the application process even though they have produced the verification\nnecessary to determine their eligibility. Commenters should urge USDA to retain the\nrequirement that a denied application be reopened where the remaining information"
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