The Institute for Agriculture and Trade Policy (IATP)ii appreciates this opportunity to comment on this Proposed Rule (PR).1 IATP commented on the “Proposed Rule: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)”.iii IATP has a professional interest in USDA nutrition programs. As we wrote to the FNS on September 23, “IATP works to help enable Minnesotan farmers to provide healthy foods to schools and early child care education programs.”iv The rural and urban partners of our Farm to Head Start initiatives report economic, educational and health benefits, all of which will be in jeopardy if the rule is finalized as proposed. IATP’s Farm to School and Farm to Early Care initiatives have observed the health and educational benefits of healthy foods for a decade.v IATP is also a partner in Farm to Summer, an initiative to incorporate local foods into free Summer Food Service Program meals provided to Minnesota children during non-school months.vi The reduction of SNAP benefits resulting from the revision of eligibility criteria will place an additional burden on private food shelves and small non-profit initiatives, such as that of IATP, to try to compensate for the reduction.
As a result of the PR we comment on today, FNS has determined that "29 States are expected to see a net loss of SNAP benefits (about $1.54 billion annually) and 22 are expected to see a net gain (about $540 million annually)."( Federal Register (FR) Vol. 84, No. 192, October 3, 2019, p. 52812) The USDA’s Economic Research Service (ERS) has estimated "$1 billion in new SNAP benefits would raise GDP by $1.54 billion, implying a GDP multiplier of 1.5.”vii IATP assumes that this economic multiplier still applies negatively when SNAP benefits are reduced. The anticipated reduction of net $1 billion SNAP benefits that USDA estimates to result from this PR will add to the difficulty of compensating for the loss of SNAP benefits from the eligibility criteria PR.