The Trump administration has proposed a rule change that would lead to about 3 million people losing Supplemental Nutrition Assistance Program (SNAP) benefits. Under the proposal by the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service, automatic qualification for SNAP benefits — formerly known as Food Stamps — would become more restrictive.
The proposed rule would change the definition of “broad-based categorical eligibility” for SNAP. Currently, if a family is eligible for Temporary Assistance for Needy Families (TANF), they automatically qualify for food assistance through SNAP. Not only do people receiving TANF cash benefits automatically qualify for SNAP, but households that receive similar benefits that are paid for with TANF funds also qualify. The Trump administration wants to limit the automatic SNAP eligibility to just those people who receive TANF cash benefits.
In addition, the proposed rule would tighten up the asset test for SNAP. The government not only looks at income when people apply for SNAP benefits. It also looks at assets when considering program eligibility, such as property or savings. Currently, SNAP households cannot have assets greater than $2,500. Senior and disabled households cannot have assets of no more than $3,500.
Poor children will be harmed twice over because children in households that receive SNAP automatically qualify for free meals in the National School Lunch Program (NSLP). If their households are no longer eligible for SNAP, these children may no longer qualify for free school meals.
USDA estimates that as many as 982,000 children could be affected by the rule change. Of these, 497,000 children would shift from free to reduced price meals. About 40,000 would lose their eligibility for the school lunch program and would have to pay regular meal prices.
Using broad-based categorical eligibility has brought a number of benefits to the SNAP program. Many low-income working families are living right on the edge of poverty, and SNAP serves households with income less than 130% of the federal poverty level. But TANF can serve households between 130% and 185% of the poverty level. Having food assistance and free school meals helps children do better in school, and gives families the cushion they need to get on their feet. Extending the reach of SNAP can extend crucial food benefits to more children at risk of poverty.
Broad-based categorical eligibility also streamlines the administration of the SNAP and school lunch programs. It means that states do not have to re-certify families twice, reducing paperwork and staff time. It also means that states are better able to reach the greatest number of low-income children more cost-effectively. It also means that parents do not have to fill out form after form with the same information, saving them time to pursue jobs and care for their children.
Many low-income households go on and off of SNAP as their incomes fluctuate. Program administrators call this “churn.” If households are also receiving TANF-funded benefits, they are more likely to continue receiving food assistance because of the slightly higher income limits. This not only reduces administrative costs, but takes a burden off of families who otherwise must constantly reapply for SNAP. Research has shown that using broad-based categorical eligibility reduces program churn by 26%.
Finally, many school systems provide free school lunches to all children. They are able to get reimbursed by the NSLP for the portion of their students that would qualify for free meals. Since the proposed rule would reduce the number of children eligible for free school meals, these school districts will find it harder to continue providing free meals to all their students.
The SNAP program changes would affect millions of people. But the program savings would be small. Only 4% of SNAP program costs are due to broad-based categorical eligibility according to the administration itself.
The original proposal generated a lot of opposition from child welfare and affordable housing advocates, including the Children’s Defense Fund (CDF) and National Low-Income Housing Coalition (NLIHC). USDA received over 127,000 comments on the original proposal, and advocates are calling for more organizations to oppose taking food assistance from our most vulnerable neighbors during the extended comment period.
