On September 23, the federal public comment period on the Trump administration’s plan to eliminate Broad-Based Categorical Eligibility closed. This proposed change to SNAP eligibility rules would kick 3.1 million Americans just above the poverty line off food stamps — 16,000 of them in Allegheny County. The rule change would also make it much harder for anyone – seniors, veterans, people with disabilities, low-wage workers – to apply for and qualify for this critical nutrition assistance program.
When they first issued the rule change in July, the USDA estimated it would also block 500,000 low-income children from accessing the national school meals program due to their family’s change in SNAP status. The USDA recently released further data that shows the number of children who face the loss of free or reduced school meals is actually closer to 1 million. Half of these children would be moved from free to reduced-price meals, while another 40,000 would lose eligibility altogether.
The USDA now reports ending categorical eligibility could reduce National School Lunch Program and School Breakfast Program funding by roughly $90 million annually. This means school districts will be left to cover the costs of continuing to provide free school meals to formerly eligible low-income children. Most likely they will just transfer those costs to parents who are already struggling to afford food.
Already 75 percent of school districts are dealing with unpaid school meals fees, according to the School Nutrition Association’s report, The State of School Nutrition 2018. Moving struggling families out of free school meals likely will result in more unpaid school meals fees for schools to contend with. And in the districts that do not provide meals to children who do not have money in their school meals account, children will be sitting in classrooms hungry.” [FRAC.org]
The Pennsylvania Department of Human Services, in their letter opposing this rule change, estimates that 22,588 school children in PA will lose direct certification for free school meals if the USDA eliminates categorical eligibility.
Due to this huge increase in the estimated impact to hungry children, the USDA reopened the window to comment on the rule change for two weeks starting Oct. 18.
What You Can Do
The time to act is now. Even if you already submitted comments on this SNAP rule change use FRAC’s comment portal here to submit a comment by November 1. But remember: Please ensure your comment is related to children and school meals. Otherwise, your comment won’t be counted.
Here are some points to consider including, in addition to explaining who you are and why you are concerned about the proposed rule (courtesy of the Coalition on Human Needs):
- The revised USDA estimates prove changes to categorical eligibility could be more harmful for kids than they previously disclosed (see above). We are still skeptical of USDA’s estimates: they believe 40,000 children would lose eligibility for benefits altogether. But this number could be much higher. By forcing parents to fill out more paperwork, many more children could be inadvertently denied access to nutritious school meals, even though they are eligible.
- Under the Community Eligibility Provision, nearly 2,000 schools across the country provide free school meals to all their students because more than 40 percent of their students participate in an anti-poverty program, such as SNAP. If fewer families receive SNAP, some communities may not qualify for the program, increasing bureaucratic hurdles and ensuring that some poor children will no longer receive free meals.
- “Lunch shaming” is a worrying trend where school districts punish children who can’t pay for lunch or have accrued lunch debt, for instance by serving them reduced-quality cold lunches, or by forcing them to wear stamps or wristbands in the cafeteria. This has resulted in national news coverage and has been met with an understandably negative backlash by the public. By forcing kids who currently qualify for free school meals to pay, or kicking off kids who pay a reduced fee for lunch entirely, change to categorical eligibility would only make this trend worse. How would school districts respond if the number of kids losing some or all of their benefits swells by 982,000 children?
You can also send your handwritten comment by mail to:
Certification Policy Branch
Program Development Division
Food and Nutrition Service – USDA
3101 Park Center Drive, Room 812
Alexandria, VA 22302
Re: Notice of Proposed Rule Making — SNAP: Standardization of State Heating and Cooling Standard Utility Allowances – FNS-2019-0009-0001