The Issue:
The Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program: The Trump administration wants to replace the ways different states calculate who is eligible for food assistance through SNAP, with a single federal standard. Currently, states may raise the eligibility limit for families for low-income families whose childcare and housing costs constitute a significant portion of their monthly budgets. Under the proposed rule change, a family of four earning more than $33,475 per year anywhere in the country would be considered too wealthy for SNAP benefits. That means 3.1 million Americans, including 11,000 Connecticut residents, would be kicked out of the program.
According to the Center for Budget & Policy Priorities, SNAP kept 70,000 people in Connecticut out of poverty – including 28,000 children – each year from 2009 – 2012. The program works. Accounting for only 2% of the federal budget, SNAP is a safety net for approximately 44 million Americans, most of whom are children, the working poor, the elderly, and people with disabilities. We must not accept this callous disregard for the most vulnerable.
The Action Needed:
We ask that members of the Voices for Justice Network submit public comment in opposition to the proposed rule change. CCFJ staff have submitted a comment; click here to read. Federal agencies are required to consider each unique public comment on a proposed regulation. Including data will make your comment stronger, however this should not dissuade you from making values-based comments. Do note that your comment will be publicly available.
Submitting public comments on proposed federal regulations is a simple but important advocacy strategy. We need you to join us!
This proposed rule can be found directly here. Comments for this proposed regulation are due by 11:59pm on September 23.
Potential talking points:
Below are some sample points you could include. Remember that your comment needs to be unique in order to be counted. Some overlap of wording and data citation is fine, but the majority of the comment must be unique, so please make sure to modify the language if you use the sample points.
- Context matters when evaluating need. Geographical location must be tied to benefit level, because geographical location is intimately bound to overall cost of living. For instance, a 2018 study by Harvard’s Joint Center for Housing Studies deemed nearly half of Connecticut renting households as either moderately- or heavily burdened by their housing costs that consumed more than 30% or 50% of their monthly income respectively. Connecticut state officials should be able to consider our affordable housing crisis when determining need. The Trump administration should not punish 11,000 of our Connecticut neighbors because they managed to save a bit in case of emergency or because they managed to pick up and extra shift at work.
- SNAP is effective. In 2015 alone, SNAP lifted 4.6 million Americans out of poverty; among them were 2 million children and 366,000 seniors. Each year, SNAP keeps nearly 30,000 of Connecticut’s children out of poverty.
- SNAP benefits the poor directly, but indirectly, it benefits us all. Separate studies conducted by both the executive branch and the legislative branch have noted that in addition to lifting people out of poverty, SNAP stimulates the broader economy. A 2010 USDA study found that every $1 spent on SNAP generated $1.80 in economic activity at the height of the financial crisis.
- As people of faith, we believe that everyone deserves to live a dignified life with their basic human rights upheld. We believe that access to adequate, nutritious food is a human right. This proposed rule that would take food assistance away from millions of people is simply immoral.
- If you have used SNAP yourself, consider writing about your experience and perspective of this program’s value.
- Write from your perspective as a person of faith, faith leader, mother, teacher, other professional role, or simply a concerned community member. What do you think the impact of this proposed change would be? Why do you think the Administration should abandon this proposal?
- Comments can vary in length, so don’t let length be a barrier to you writing something. Even something short and to the point is important.
Further reading:
“Trump Proposal Would Push 3 Million Americans Off Food Stamps” Washington Post
“3 Million Could Lose Food Stamps Benefits Under Trump Administration Proposal” NPR
“Trump Proposal Would Cut Food Stamps For At Least 11k CT Residents” Hartford Courant
More background information and data on SNAP and its impacts from the Food Research & Action Center
Thank you for your advocacy efforts!
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