public-policy newsletter

Proposed SNAP Reform Threatens Community Well-Being

July 31, 2019

By Marie Camino

Last week, the U.S. Department of Agriculture (USDA) and Food and Nutrition Service (FNS) announced a proposed rule entitled “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP).” SNAP is a federal program that provides nutrition benefits to families to increase well-being. It is currently the largest food assistance program in the country, serving approximately 9.5 million families. SNAP can be an essential support to lift families and older adults out of poverty and provide food security. Nearly half of all SNAP participants are children.

Federal eligibility for SNAP is currently limited to people who make at or below 130 percent of the federal poverty line (FPL), and there is a three-month time restriction during a three-year period on benefits for able-bodied adults with no dependents, unless they are working 80 hours per month. State SNAP eligibility varies, but states do have the option to use “broad-based categorical eligibility” (BBCE), which allows them to suspend federal asset tests that deny SNAP to any recipient who manages to accumulate roughly $2,000 in personal savings, and slightly raises the income threshold for eligibility. States can use BBCE to invite SNAP applications from households who earn a certain percentage over the 130 percent federal threshold, provided they receive any benefits under a Temporary Assistance for Needy Families (TANF) Program. This has increased access to SNAP as well as eased the administrative burden of processing applications to multiple programs by the same people.

For perspective, 130 percent above the FPL for a family of four is currently around $34,000 per year, even in states with significantly higher costs of living. In states that do not use BBCE, families stop receiving benefits when they make more than that amount. States with BBCE allow families to stay on benefits up to around $50,000 per year for a family of four.

The administration’s proposed rule does two things:

  1. Defines “benefits” for categorical eligibility to mean “substantial, ongoing assistance from TANF; this would mean cash or non-cash benefits valued at a minimum of $50 per month for at least six months” and;
  2. Limits the types of non-cash TANF benefits conferring categorical eligibility to those that focus on subsidized employment, work supports, and childcare.

It is estimated that benefits will be cut for over three million people, mainly working families, older adults, and people with disabilities.

School Meals

Currently, children in households that receive SNAP are automatically eligible for free school meals without having to submit an additional application. This rule would ensure that those children would lose free meals as their family income rises above the 130 percent threshold. The Chairman of the Education and Labor Committee estimates that 500,000 children would lose their free meals under the proposed rule. Notably, the rule does not include this in its regulatory impact analysis.

Take Action

The National Assembly opposes regulatory actions that make essential benefits less accessible to families, children, older adults, and people with disabilities. SNAP eases food insecurity for many Americans and helps all members of our community thrive. The proposed rule is open for public comments until September 23, 2019.  Public comments should be unique and highlight any expertise your organization has on the issue.

For more information contact Marie Camino at