By Parker Gilkesson

Food assistance helps ensure that everyone in the United States has access to the sustenance they need to live, work, and thrive. The Supplemental Nutrition Assistance Program (SNAP) is our nation’s most important anti-hunger program and is proven to reduce poverty and food insecurity. Although the Trump Administration failed to cut SNAP through legislation when the 2018 Farm Bill passed on a bi-partisan basis, it is now attempting to go around Congress and cut SNAP through regulatory changes.

Earlier this year, the U.S. Department of Agriculture (USDA) proposed a rule to limit SNAP for unemployed or under-employed adults without dependents or documented disabilities. Today, it proposed another rule that will take away states’ flexibility to eliminate asset limits and reduce the “cliff effects” that workers experience when their earnings rise. This rule will be officially published in the Federal Register tomorrow and will be open for public comments for 60 days.

Not only would this proposal take food off the tables of millions of Americans, a recent study from the United States Department of Agriculture (USDA) confirms it would increase SNAP administrative costs.This latest proposed rule would eliminate a policy known as Broad-Based Categorical Eligibility (BBCE). This policy ensures that millions of working people can access SNAP by allowing states to raise the “gross income limit” to improve the gradual phase down of SNAP benefits as earnings rise. Without this policy, people with high housing, child care, or medical costs may experience a cliff effect, meaning that a small increase in earnings could cost them their entire benefit. States can also use BBCE to raise or eliminate the asset limit for SNAP, which prevents people from losing assistance when their savings or the value of their car exceed a certain limit. Currently, 43 states—with both Democratic and Republican governors—use this option to eliminate asset tests, 33 also use it to raise the gross income limit above 130 percent of the federal poverty level, and 17 raise the income limit to as high as 200 percent of poverty.

According to the study conducted by the Manhattan Strategy Group in partnership with the Urban Institute for the USDA, state administrative costs per case are generally lower in states that use streamlining policies such as BBCE. While many factors contribute to state administrative costs—including the state’s economic conditions, policies and eligibility systems—the adoption of BBCE significantly lowered administrative costs by 7 percent. When states remove the asset test, they no longer need to collect and verify information on assets. This can be time consuming, as the asset rules are complicated. The report also notes that BBCE helps states to process SNAP applications in a timely manner, which lets hungry people buy food sooner and also ensures that states won’t have to pay fines for failing to meet the federal processing deadlines.

We already knew that the proposed BBCE rule would be harsh and harmful to many working Americans struggling to put food on the table. We now know it would also be costly, placing extra burden on both state and federal budgets. Once the proposed rule is officially published, it is important to submit a comment opposing it to ensure that the administration doesn’t succeed in restricting access to SNAP and driving up administrative costs. CLASP and our partners will be providing sample comments that you can modify to tell why this rule is so damaging. We know from other recent proposed rules that submitting comments can make a significant difference, so we urge you to speak up in opposition to this rule that would only exacerbate our country’s food insecurity crisis.