Food Stamp Program: Personal Responsibility Provisions of PRWORA [Personal Responsibility Work Opportunity Reconciliation Act] of 1996 Final Rule [binder] [2]
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OCR Page 1 of 127CENTER ON BUDGET
AND POLICY PRIORITIES
November 2, 1999
Mr. John Knaus, Branch Chief
Program Development Division
Food Stamp Program
Food and Nutrition Service, USDA
3101 Park Center Drive
Alexandria, VA 22302
Re:
Rule to Implement the Food Stamp
Provisions of the Balanced Budget Act of
1977, 64 Federal Register 48246 (1999)
Dear Mr. Knaus:
Thank you very much for the opportunity to comment on these regulations.
Section 16(h)((1)(B)(ii) of the Food Stamp Act allows USDA to supplement data
from the FY 1996 food stamp QC survey with other data that would improve the quality of
the estimates. Because of small sample sizes, the measurement of the non-exempt
population is likely to be relatively imprecise. We believe that the Department should
explore the possibility of pooling data from the 1994 and 1995 QC surveys with than from
the 1996 survey to improve the reliability of these estimates. Although that data obviously
is somewhat older, it may be that the larger sample size still would yield better estimates
since the relative shares of this population in states' caseloads probably was not changing a
great deal during this period. This comment is pertinent to both sections
273.7(d)(1)(i)(D) and 273.24(b).
In calculating the number of people living in areas where there is no waiver due to
insufficient jobs or high unemployment, the Department should take special care to avoid
overestimating the number of people in waived parts of counties that only contain only
some waived communities. For example, one few small community in Allegheny County,
Pennsylvania, has a waiver, but the bulk of the county, including Pittsburgh, does not. The
Department should develop and release a clear, reliable methodology for calculating the
fraction of Allegheny County's recipients that are covered by such a waiver. One possibility
820 First Street, NE, Suite 510, Washington, DC 20002
Tel: 202-408-1080 Fax: 202-408-1056 [email protected] http://www.cbpp.org HN0026
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