[Comments on NCEP (Noncitizen Eligibility and Certification Provisions) - May 2000]
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OCR Page 1 of 202COMMENTS ON NCEP - May 2000
REG.
STATE
ADVOCATES
FINAL
General
SOUTH DAKOTA: We support the Department's
CBPP: Four broad principles guided the development of our [CBPP] comments:
proposed implementation date of 180 days after
1)Regulatory changes should not result in benefit cuts
publication of the final rule. States will need as much
2)The FS regulations should make the FSP transparent to all interested parties
implementation time as possible to accurately define
3)Steps must be taken to improve food stamp program for the working poor, families
and publish the rule changes, in addition to making
leaving the TANF program and other under-served populations.
computer programming, forms, and training updates on
4)The need for payment accuracy must be balanced with the goal of ensuring and
the changes.
improving access to the FSP.
WISCONSIN: 272 We fully support the increased
Principles of amicable federal-state relations suggest that USDA should emphasize a
flexibility given to SAs in administering the FS
positive role, crafting rules that will teach EWs to the greatest extent possible to prevent
Program. In regard to assuring adequate access to the
misapplications of policy, rather than an enforcement role, criticizing what states have
FS Program by working individuals, FNS has assisted
already done.
this goal by again allowing states the option of using a
quarterly reporting waiver. Simplification of the
The final rules should more closely reflect the priority the Administration has given to
reporting requirements without risk of subsequent
preserving access to food stamps for low-income families in need and to parallel the
quality control errors allows for less frequent contact
Administration's efforts to reduce barriers to access to Medicaid.
between the working individual and the SA. Continued
improvement of the rules and regulations governing
Rural Law Center of New York, Inc.: Thank you for the opportunity to comment on
application, verification, and benefit calculation is as
these regulations. While we appreciate the reference to the special needs of rural
important as flexibility of office hours in encouraging
populations, we do not feel those needs have been taken into consideration in drafting
participation in the program.
these regulations which fail to recognize the difficulty that rural HHDs have in following
the application process, given their remoteness and isolation from the bureaucracies they
Congressional Black Caucus: In many cases, you have
need to interact with in order to complete that process. We hope that you will revise
eliminated descriptions of specific procedure for Food
these regulations to better address their needs.
Stamp offices and examples for how to apply
beneficiary protections. Because FNS's staff is so
Form Letter (Block) signed by Children's Alliance (ChAl): The complexity of the FS
small, the FSP depends heavily on local advocates to
rules already makes it difficult for workers to understand the program, and for
make sure state FSP are accessible to potential
community groups to assist families to receive the help they need The PR also removes
beneficiaries. For example, local advocates were the
numerous other key protections and clarifications from the rules, while asserting in the
first to discover FS law violations in New York City,
preamble to the rules that no policy change is intended in these areas. EWs and State
Milwaukee, and Michigan. Their concerns were later
administrators, however, do not work from preambles to regulations.
echoed by FNS and federal court judges. Without the
specific and sometimes repetitive listing of beneficiary
Federal regulations should make rules governing federal programs transparent to states,
protections, local advocates might not have realized that
clients, interested social service providers and the public. They should be clear and
the states were violating our policies.
complete so that all interested parties have full knowledge of the policies governing the
program. We already find ourselves (ChAl) in the position of doing the State's job for it
by providing clear information to community agencies and families about their rights and
responsibilities in the Food Stamp and TANF programs; further confusion due to reduced
clarity in the regulations would make our work harder.
LEGEND: FR = final rule; PR = proposed rule; SA = SA; EW = EW; HH or HHD = HHD; HHDs = HHD's;
J:/Comments side-by-side as of July 27, 2000
CBPP: Center for Budget & Policy Priorities, ChAl = Children's Alliance; MCHA = Maternal & Child Health Access; AFS = Oregon's Adult and Family Services Division
FSP = Food Stamp Program; FSB = Food Stamp benefits; FSO = Food Stamp Office; AR = authorized representative
[reg number I = external to PDD
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