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    "ocrText": "PPI Intern1 - feb29fsregs_access.doc\nPage 9\nprocess.\nIn addition, the final regulations should require that the application form make clear that\nthis attestation applies only to those members of the household that are applying for food\nstamps, not to members the household identifies as ineligible immigrants or to other non-\napplicants. Households commonly will contain legal permanent resident (LPR) parents who are\nineligible under PRWORA, older LPR children whose eligibility was restored in 1998, and\nyounger children who are U.S. citizens because they were born in the U.S. The parents could not\nsign the statement required by the proposed rules because they are not eligible immigrants.\nE.\nRequests for Applications and Applications Filed at Incorrect Offices\nCurrent regulations require food stamp offices to mail an application on the same day a\nhousehold requests one by telephone. 7 C.F.R. § 273.2(c)(2)(i). They also require a food stamp\noffice that receives an application it cannot process because the applicant household resides\noutside its catchment area to mail the application to the correct food stamp office the same day\nthe form is received. 7 C.F.R. § 273.2(c)(2)(ii). USDA proposes to provide states with an extra\nbusiness day in each case, with the likely result that each affected household will lose at least\n1/30th of its benefits for the month of application (or more where a weekend or holiday\nintervenes). Proposed 7 C.F.R. § 273.2(c)(2). As one federal court noted when striking down\nearlier USDA rules that allowed delays in processing applications, \"hunger takes no holidays.\"\nHarley v. Lyng, 653 F. Supp. 266 (E.D. Pa. 1986).\nAlthough this would not be a huge loss, it is unnecessary. Food stamp applications in\nblank envelopes can and should be kept on hand at the food stamp office's reception desk. It is\nno harder for a receptionist to write down the caller's address on the envelope than on any other\npiece of paper. Even if the call comes in near the close of business, this should not take an extra\nday. Forwarding misaddressed applications should take only marginally more time. The final\nregulations could offer states the option of forwarding a misfiled application by mail the day it is\nreceived or by fax the following day. The boundaries of some food stamp offices' catchment\nareas are drawn in arbitrary ways that many households will be unable to intuit. The regulations\nalready provide that the processing time for a misfiled application does not begin until it arrives at\nthe correct food stamp office. Poor households should not have their applications further delayed\nfor reasons that are not their fault. (To be sure, some applicant households will call first to get\nthe correct address. Some poor families, however, lack telephones, and staff at some food stamp\noffices can be difficult to reach, particularly if the family does not have a telephone number at\nwhich it can receive a return call.)\nComments could suggest that the final rules allow an exception where the food stamp\noffice is open non-traditional hours to accommodate working families and receives a request for\nan application, or a misfiled application, after the last mail collection for the day.\nF.\nFiling Electronically or by Fax\nOne provision of these rules that merits favorable comment is the authorization for\n9"
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