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C.
Denying Households Without Allowing an Opportunity to
Resolve Apparent Discrepancies
22
D.
Increasing the Risk of Improper Terminations of Households Leaving
Cash Assistance Programs or Experiencing Other Changes
23
E.
Increasing the Risk of Improper Denials of Households Applying
Jointly for Food Stamps and TANF-funded Benefits
34
1.
Denying Food Stamp Applications Prematurely
34
2.
Improperly Reducing the Benefits of Households Applying
Jointly for Food Stamps and TANF-funded Benefits
35
3.
Applying the More Restrictive Provisions of Other
Programs' Rules to Food Stamp Applications
35
F.
Denials Because of Confusion Resulting from the Organization
of the Rules
36
IV.
IMPOSING UNDUE BURDENS ON THE WORKING POOR AND OTHER
ELIGIBLE HOUSEHOLDS
38
A.
Requiring Households to Appear for Unnecessary Face-to-Face
Interviews
38
B.
Invasions of Privacy
43
1.
Home visits
43
2.
Collateral contacts
45
3.
Confidentiality of interviews
49
4.
Home interviews
50
C.
Discrimination in Setting Verification Requirements
51
D.
Unnecessary Verification Requirements
51
E.
Burdensome Forms
54
V.
REDUCING VERIFICATION BURDENS ON STATES AND HOUSEHOLDS 57
I.
INTRODUCTION
Although a few of the provisions of these proposed rules are positive, overall this is a
highly damaging set of proposed regulations in the history of the Food Stamp Program and
certainly the worst in the past quarter century. In numerous respects, they would eviscerate
longstanding protections of households' fairness and access to food stamps that survived the
Reagan and Bush Administrations largely intact. Indeed, even some protections the Reagan
Administration inserted in the regulations (to replace stronger ones that had existed previously)
are weakened or removed. The damage these rules would do to households' access to food
assistance goes well beyond anything the Reagan or Bush Administrations ever proposed.
Moreover, even where USDA is not proposing any substantive changes, by
republishing these rules for comment it is opening up these sensitive areas to change in response
to critical comments it may receive. Because the publication of these proposals gives the public
an opportunity to comment on the merits of these provisions, USDA could weaken or eliminate
2
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"ocrText": "PPI Intern1 - feb29fsregs_access.doc\nPage 2\nC.\nDenying Households Without Allowing an Opportunity to\nResolve Apparent Discrepancies\n22\nD.\nIncreasing the Risk of Improper Terminations of Households Leaving\nCash Assistance Programs or Experiencing Other Changes\n23\nE.\nIncreasing the Risk of Improper Denials of Households Applying\nJointly for Food Stamps and TANF-funded Benefits\n34\n1.\nDenying Food Stamp Applications Prematurely\n34\n2.\nImproperly Reducing the Benefits of Households Applying\nJointly for Food Stamps and TANF-funded Benefits\n35\n3.\nApplying the More Restrictive Provisions of Other\nPrograms' Rules to Food Stamp Applications\n35\nF.\nDenials Because of Confusion Resulting from the Organization\nof the Rules\n36\nIV.\nIMPOSING UNDUE BURDENS ON THE WORKING POOR AND OTHER\nELIGIBLE HOUSEHOLDS\n38\nA.\nRequiring Households to Appear for Unnecessary Face-to-Face\nInterviews\n38\nB.\nInvasions of Privacy\n43\n1.\nHome visits\n43\n2.\nCollateral contacts\n45\n3.\nConfidentiality of interviews\n49\n4.\nHome interviews\n50\nC.\nDiscrimination in Setting Verification Requirements\n51\nD.\nUnnecessary Verification Requirements\n51\nE.\nBurdensome Forms\n54\nV.\nREDUCING VERIFICATION BURDENS ON STATES AND HOUSEHOLDS 57\nI.\nINTRODUCTION\nAlthough a few of the provisions of these proposed rules are positive, overall this is a\nhighly damaging set of proposed regulations in the history of the Food Stamp Program and\ncertainly the worst in the past quarter century. In numerous respects, they would eviscerate\nlongstanding protections of households' fairness and access to food stamps that survived the\nReagan and Bush Administrations largely intact. Indeed, even some protections the Reagan\nAdministration inserted in the regulations (to replace stronger ones that had existed previously)\nare weakened or removed. The damage these rules would do to households' access to food\nassistance goes well beyond anything the Reagan or Bush Administrations ever proposed.\nMoreover, even where USDA is not proposing any substantive changes, by\nrepublishing these rules for comment it is opening up these sensitive areas to change in response\nto critical comments it may receive. Because the publication of these proposals gives the public\nan opportunity to comment on the merits of these provisions, USDA could weaken or eliminate\n2"
}