On September 23, IATP submitted a comment to the U.S. Department of Agriculture (USDA) about its latest proposed rule to change eligibility criteria for the Supplementary Nutritional Assistance Program (SNAP). These funds are spent in supermarkets and farmers markets to purchase approved classes of food and beverages. (Republicans in the House of Representatives had tried and failed to cut SNAP and other federal nutritional assistance programs in the 2018 Farm Bill.) USDA Secretary Sonny Perdue said that the new eligibility requirements would prevent “abuse of a critical safety net” by households whose income could be as much as pretax $50,000 for a family of four, double the federal poverty definition. (Two adults working forty hour weeks for 50 weeks a year at the federal minimum wage of $7.25 earn $29,000 pretax.)
USDA forecasts that 3.1 million of a current 40.3 million SNAP users will lose their benefits if the rule takes effect. Additionally, 500,00 children could lose access to free school lunches. According to the Congressional Research Service, another 17.2 million households could lose SNAP benefits because of additional paperwork requirements for each household or individual to verify eligibility. In 2018, SNAP benefits averaged $126 per person per month or $1.40 per meal. IATP’s comment noted that the eligibility requirements derive from a federal definition of poverty that has not been substantially revised for a half century. The USDA estimates that 12 percent of the U.S. population is “food insecure,” i.e. it lacks consistent access to adequate and nutritious food. Given the out-of-date U.S. government definition of poverty, this figure is surely an under-estimate.
IATP urged USDA to withdraw the rule, which is both legally and substantively defective. USDA failed to provide legally required cost and benefit analysis, and other required analyses before proposing the rule. To exemplify, we cited a 2011 study according to which “[t]he combined cost of hunger for poor education and adverse health outcomes and the opportunity costs of contributions to emergency food organizations were $125.5 billion in 2007, rising to $167.5 billion for 2010.” The proposed rule does not estimate the health costs and benefits of SNAP nor the educational benefits of free school lunches. Nor did USDA carry out the required Civil Rights Impact Analysis, despite the much higher rates of food insecurity in African American and Hispanic households reported by USDA’s Economic Research Service (ERS). The proposed rule misleadingly claimed that USDA consulted with Native American tribes about the proposed rule, but had received no comment, despite the National Congress of American Indians comment in April opposing yet another eligibility criterion change for receiving SNAP benefits.
A New York Times article noted that 75,000 comments had been submitted, including 17 from governors and 70 from mayors, nearly all opposing the proposed rule. However, it also noted that massive public opposition to other proposed rules, e.g. 800,000 comments against weakening the Endangered Species Act, did not deter the Trump administration from finalizing and implementing the rule. Despite the well-documented Republican opposition to SNAP and the Trump administration’s indifference to public comments on its anti-regulatory agenda for public and environmental protections, we believe it is still important to register opposition to this unwise and heartless proposal. In addition to the lack of proper analysis or consultation, we noted that:
The Trump proposed budget for Fiscal Year 2020 would eliminate ERS data collection and research into food insecurity, nutrition and federal food assistance. Even though Congress is unlikely to approve this budget proposal, Secretary Perdue’s relocation of ERS to the Kansas City area has resulted in the staff and research cuts that the Trump administration could not achieve in past budget proposals. By eliminating these ERS research areas, USDA would lose its capacity to estimate the effects of its food assistance programs, possibly leading to further cuts.
Rural people are more food insecure than their urban counterparts on a per capita basis and would be more negatively impacted by cuts to SNAP benefits. The Fiscal Year 2020 budget proposal would eliminate all ERS research into rural economies, so it would be impossible to estimate the multiplier effects of SNAP spending in rural towns. What Senator Debbie Stabenow called the “demolition” of ERS through forced relocation, dismissal or retirement of most of its employees would hit rural communities and persons disproportionately.
IATP’s Farm to School, Farm to Early Care and Farm to Summer initiatives help farmers provide horticulture and other agricultural products to supplement federal food assistance programs in Minnesota. SNAP cuts would increase the burden on these and other larger private food assistance programs to compensate for the reductions in federal programs.
USDA has defended the proposed eligibility criteria in the name of “program integrity” and a savings to USDA of “approximately $9.386 billion over the five years 2019–2023.” Since the savings are insignificant relative to the Congressional Budget Office estimate of a $1 trillion budget deficit for the current fiscal year, there is no persuasive budgetary argument for the SNAP cuts. In the name of “program integrity,” USDA is cutting not just the SNAP benefits, but the collateral education, health and economic multiplier benefits that are well-documented.
President John F. Kennedy’s first Executive Order was to start work on a pilot food stamp program that eventually became the Food Stamp Act of 1964 signed by President Lyndon B. Johnson. Former IATP Board member Rod Leonard worked to develop that program in both administrations. Though the Congressional appropriations for federal food assistance has grown with the growth in the numbers of food insecure people, the purpose of the Food Stamp Act and subsequent amendments to it are undermined by this proposed rule.