December 2, 2019
SNAP Certification Policy Branch
Program Development Division
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, Virginia 22302
RE: Notice of Proposed Rule Making Regarding Supplemental Nutrition Assistance Program (SNAP) Standardization of State Heating and Cooling Standard Utility Allowances [RIN-0584-AE69]
Dear SNAP Certification Policy Branch:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the SNAP Certification Policy Branch at the Food and Nutrition Service Program Development Division of the U.S. Department of Agriculture related to its proposed rule, "Standardization of State Heating and Cooling Standard Utility Allowances (RIN 0584-AE69)," published in the Federal Register originally on October 03, 2019. Representing more than 107,000 registered dietitian nutritionists (RDNs);1 nutrition and dietetic technicians, registered (NDTRs); and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition.
The Academy opposes the proposed rule that would standardize the heating and cooling standard utility allowances for SNAP and remove states' flexibility to calculate state-specific standard utility allowances. We oppose this rule for the following reasons:
- Although the rule increases benefits for SNAP households in some states, it reduces benefits for households in others; this rule is ultimately a national net reduction of benefits and disproportionately impacts seniors and people with disabilities;
- It takes state flexibility away from administering the program and creates greater economic instability for struggling families and communities in states that will see a decrease in benefit allocation; and
- It seeks to circumvent the bipartisan, bicameral effort of Congress to review and reauthorize SNAP in the 2018 Farm Bill—a Farm Bill that had historical bipartisan support.
A. Academy Position on Food Insecurity
The Academy is committed to improving the health of Americans by ensuring access to a nourishing, safe and affordable food supply. The dietetics practitioner and nutrition educator consider the health, safety and welfare of the public at all times. The Academy's guiding principle is our commitment to improving health for all, especially those most susceptible to food insecurity. It is the position of the Academy2 that systematic and sustained action is needed to achieve food and nutrition security in the United States. The following items are needed to achieve national food security:
- Adequate funding for, and increased utilization of food and nutrition assistance programs;
- Inclusion of nutrition education in food and nutrition assistance programs;
- Strategies to support individual and household economic stability; and
- Research to measure impact on food insecurity and health related outcomes.
B. SNAP Reduces Food Insecurity and Improves Health Outcomes
Research shows that SNAP is an effective and efficient program at reducing food insecurity.3,4,5 Given the improved health and reduced health care costs associated with reductions in food insecurity, the Academy encourages initiatives that ensure more eligible people are connected to and are benefitted by the program. Food insecurity significantly impacts the health and well-being of individuals, and is a risk factor for negative psychological and health outcomes. It also increases the prevalence and severity of diet-related disease, such as obesity, type 2 diabetes, heart disease, stroke and some cancers.7,8,9
Additionally, because of limited financial resources, those with food insecurity may use coping strategies to stretch budgets in a manner harmful for health, such as engaging in cost-related medication underuse or non-adherence,10,11,12 or postponing or forgoing preventive services or needed medical interventions. According to one estimate, SNAP reduces food insecurity by approximately 30%13 and nearly one in nine American households experience food insecurity during the year.14
Research demonstrates that SNAP reduces health care utilization and costs.15,16,17 A national study reveals that SNAP participation is associated with lower health care costs.18 On average, low-income adults participating in SNAP incurred health care costs nearly 25% lower over 12 months, including those paid by private or public insurance, than similarly situated adults not participating in SNAP.19
SNAP improves child, adult and senior health outcomes, including physical and mental health.20 The program increases the probability of self-reporting "excellent" or "good health"21 lowers the risk of poor glucose control for people with diabetes22 and has a protective effect on mental health.23 SNAP also helps reduce stress for struggling individuals and families worried about finances, which is particularly significant given the high correlation of stress with poor health outcomes.24
C. Proposed Rule Would Hurt Seniors and People with Disabilities
States have flexibility when setting standard utility allowances. The proposed rule would set a national standard that all states would have to follow when determining SNAP benefit levels. The impact in each state would vary based on current administration of the program. In its regulatory impact analysis (RIA) of the proposed rule, USDA reports that approximately 16% of SNAP households would see an increase in benefits in some states, and an additional 19% of SNAP households would lose benefits in other states, resulting in a national net reduction of benefits, while approximately 8,000 households will lose eligibility altogether.25 The Academy opposes the proposal to set a national standard that would reduce benefits to current SNAP recipients, even though it may benefit others, knowing that current benefit levels are reported to be insufficient and that, in fact, a higher benefit could support healthier eating.26
Older adults and people with disabilities will be disparately impacted by the proposed rule.27 SNAP plays an important role in supporting the food security, nutrition and health of older adults, allowing them to maintain their independence while also reducing their health care utilization and costs.28> People with disabilities experience high rates of food insecurity, making SNAP a critical support for this vulnerable population as well.29>
SNAP plays a critical role in addressing hunger and food insecurity for senior citizens struggling to get by with limited means. The Academy opposes any rule change that would put low-income seniors at greater risk for food insecurity, malnutrition and poor health outcomes.
Many seniors live on fixed incomes and have limited financial means to afford expenses such as food, medical or housing costs.30 In 2018, approximately 30% of all U.S. households included individuals aged 65 and older. Of this group, 7.5% were food insecure, meaning that these households had difficulty affording nutritious, adequate food.31
Research indicates that food-insecure seniors have less nutritious diets, have worse health outcomes and are at higher risk for depression than food-secure seniors.32 Compared to other adult age groups, seniors are particularly vulnerable to the health consequences of food insecurity.33 Malnutrition is a leading cause of morbidity and mortality for older adults and as many as 50% of older adults are at risk for malnutrition.34
People with Disabilities
In standardizing the way states calculate utility allowances, the proposed rule would decrease SNAP benefits for nearly one quarter of SNAP households that include people with disabilities.35 Individuals with disabilities have many risk factors requiring nutrition interventions, including growth alterations (e.g., failure to thrive, obesity) metabolic disorders and poor feeding skills.36 Furthermore, these individuals are also more likely to develop comorbid conditions, such as obesity or endocrine disorders that require nutrition interventions.37 Poor nutrition-related health habits, limited access to services, and long-term use of multiple medications are considered health risk factors.38> The Academy is concerned that a reduction in SNAP benefits and access to healthy food would put this population at an even greater risk for poor health outcomes.
D. Proposed Rule Hurts Economic Stability and Limits State Flexibility
The proposed rule would standardize and cap SUA calculations across the country based on survey data. The Academy requests that USDA further explain the rationale for capping the largest of the SUA components. The is particularly concerning given research documented that households in 22 states would lose benefits if a standardized SUA methodology were to be implemented.39>
Cuts to SNAP benefits will reduce the positive economic effect of SNAP. According to recent studies, it is estimated that $1 of SNAP benefits leads to between $1.50 and $1.80 in total economic activity during a recession40 USDA's Economic Research Service has also reported that SNAP spending has a positive impact on manufacturing and trade and transportation sectors. These sectors effect a variety of businesses, such as food and beverage manufacturers, packaging manufacturers, grocery stores, food and other wholesalers, as well as trucking and rail freight industries.41 The Academy acknowledges the importance of economic stability as part of the solution to address food insecurity and is concerned that this proposed rule would undermine these positive economic impacts in the states where SNAP allocations would decrease.
E. Proposed Rule Goes Against Bicameral, Bipartisan Agreement
The Academy supported the historically bipartisan, bicameral 2018 Farm Bill where issues like changes to the standard utility allowances were discussed in great detail and rejected. The Academy is concerned that these continued proposed rule changes to SNAP threaten the separation of powers among branches of government.
The Academy appreciates the opportunity to submit comments to the SNAP Certification Policy Branch related to the proposed rule to standardize the state heating and cooling utility allowances. The Academy believes that USDA should be strengthening the positive impacts of SNAP for health, well-being and economic activity for all recipients, not reducing the amount of benefits for already vulnerable populations.
We oppose the proposed rule and request it be withdrawn. Please contact either Jeanne Blankenship at 312/899-1730 or by email at firstname.lastname@example.org or Liz Campbell at 202/775-8277, ext. 6021 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Liz Campbell, MA, RD
Legislative & Government Affairs
Academy of Nutrition and Dietetics
1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2 Holben, D. (2010). Position of the American Dietetic Association: Food Insecurity in the United States. Journal of the American Dietetic Association. 110(9), 1368-1377.
3 Mabli, J., & Worthington, J. (2014). Supplemental Nutrition Assistance Program participation and child food security. Pediatrics, 133(4), 1-10.
4Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.
5 Nord, M. (2012). How much does the Supplemental Nutrition Assistance Program alleviate food insecurity? Evidence from recent program leavers. Public Health Nutrition, 15(5), 811-817.
6Hartline-Grafton, H. (2017). The Impact of Poverty, Food Insecurity, & Poor Nutrition on Health and Well-Being. Washington, DC: Food Research & Action Center.
7Franklin B. Jones, A., Love, D., Puckett, S., Macklin, J., & White-Means, S. (2012). Exploring mediators of food insecurity and obesity: a review of recent literature. Journal of Community Health. 37(1), 253-264.
8 Berkowitz, S., A., Karter, A., J., Corbie-Smith, G., Seligman, H. K., Ackroyd, S. A., Barnard, L. S., Atlas, S. J., & Wexler, D. J. (2018). Food insecurity, food "deserts," and glycemic control in patients with diabetes: a longitudinal analysis. Diabetes Care, 19, 171981.
9 Gregory, C., A., & Coleman-Jensen, A. (2017). Food insecurity, chronic disease and health among working-age adults. Economic Research Report, 235. Washington, DC: U.S. Department of Agriculture, Economic Research Service.
10Herman, D., Afulani, P., Coleman-Jensen, A., & Harrison, G. G. (2015). Food insecurity and cost-related medication underuse among nonelderly adults in a nationally representative sample: American Journal of Public Health, 105(10), 48-59.
11 Afulani, P., Herman, D., Coleman-Jensen, A., & Harrison G. G. (2015). Food insecurity and health outcomes among older adults: The role of cost-related medication underuse. Journal of Nutrition in Gerontology and Geriatrics, 34(3), 319-343.
12 Knight, C. K., Probst, J. C., Liese, A., D., Sercy, E., & Jones, S.J. (2016). Household food insecurity and medication "scrimping" among US adults with diabetes. Public Health Nutrition, 19(6), 1103-1111.
13 Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.
14 Coleman-Jensen, A., Rabbit, M. P., Gregory, C. A. & Singh, A. (2019). Household food insecurity in the United States in 2018. Economic Research Service Report, 256, Washington, DC: U.S. Department of Agriculture, Economic Research Service
15 Gregory, C. A., & Deb, P. (2015). Does SNAP improve your health? Food Policy, 50, 11-19.
16 Berkowitz, S. A., Seligman, H. K., Rigdon, J., Meigs, J. B., & Basu, S. (2017). Supplemental Nutrition Assistance Program (SNAP) participation and health care expenditures among low-income adults. JAMA Internal Medicine, 177(11), 1642-1649.
17 Seligman, H. K., Bolger, A. F., Guzman, D., Lopez, A., & Bibbins-Domingo, K. (2014). Exhaustion of food budgets at month's end and hospital admissions for hyperglycemia. Health Affairs, 33(1), 116-123.
18 Berkowitz, S. A., Seligman, H. K., Rigdon, J., Meigs, J. B., & Basu, S. (2017). Supplemental Nutrition Assistance Program (SNAP) participation and health care expenditures among low-income adults. JAMA Internal Medicine, 177(11), 1642-1649.
20 Hartline-Grafton, H. (2017). SNAP and Public Health: The Role of the Supplemental Nutrition Assistance Program in Improving the Health and Well-Being of Americans. Washington, DC: Food Research & Action Center.
21 Gregory, C. A., & Deb, P. (2015). Does SNAP improve your health? Food Policy, 50, 11-19.
22 Mayer, V. L., McDonough, K., Seligman, H., Mitra, N., & Long, J. A. (2016). Food insecurity, coping strategies and glucose control in low-income patients with diabetes. Public Health Nutrition, 19(6), 1103-1111.
23 Leung, C. W., Epel, E. S., Willett, W. C., Rimm, E. B., & Laraia, B. A. (2015). Household food insecurity is positively associated with depression among low-income Supplemental Nutrition Assistance Program participants and income-eligible nonparticipants. Journal of Nutrition, 145(3), 622-627.
24 Juster, R-P., McEwen, B. S., & Lupien, S. J. (2010). Allostatic load biomarkers of chronic stress and impact on health and cognition. Neuroscience and Biobehavioral Reviews, 35(1), 2-16.
25 Regulatory Impact Analysis. Supplemental Nutrition Assistance Program: Standardization of State Heating and Cooling Standard Utility Allowances. https://www.regulations.gov/document?D=FNS-2019-0009-0002. Accessed November 22, 2019.
26 Center for Budget and Policy Priorities. More Adequate SNAP Benefits Would Help Millions of Participants Better Afford Food. https://www.cbpp.org/research/food-assistance/more-adequate-snap-benefits-would-help-millions-of-participants-better. Accessed November 26, 2019.
27 Urban Institute. Estimated Effect of Recent Proposed Changes to SNAP Regulations. https://www.urban.org/sites/default/files/publication/101368/estimated_effect_of_recent_proposed_changes_to_snap_regulations.pdf. Accessed November 26, 2019.
28 Food Research & Action Center. Hunger & Health: the Role of the Supplemental Nutrition Assistance Program in Improving Health and Well-Being. https://frac.org/wp-content/uploads/hunger-health-role-snap-improving-health-well-being.pdf. Accessed November 22, 2019.
29 Position of the Academy of Nutrition and Dietetics: Nutrition Services for Individuals with Intellectual and Developmental Disabilities and Special Health Care Needs. J Acad Nutr Diet. 2015;115:593-608.
30 Hunger Among Older Adults. Food Research and Action Center. https://www.frac.org/hunger-poverty-america/senior-hunger. Accessed September 18, 2019.
32 Gundersen C, Ziliak JP. Food Insecurity And Health Outcomes. Health Aff (Millwood). 2015 Nov;34(11):1830-9.
34 Academy of Nutrition and Dietetics. Spotlight on Malnutrition. https://www.eatrightpro.org/news-center/in-practice/dietetics-in-action/adult-and-senior-malnutrition. Accessed on September 18, 2019.
35 Urban Institute. Estimated Effect of Recent Proposed Changes to SNAP Regulations. https://www.urban.org/sites/default/files/publication/101368/estimated_effect_of_recent_proposed_changes_to_snap_regulations.pdf. Accessed November 26, 2019.
36 Position of the Academy of Nutrition and Dietetics: Nutrition Services for Individuals with Intellectual and Developmental Disabilities and Special Health Care Needs. J Acad Nutr Diet. 2015;115:593-608.
39 Methods to Standardize State Standard Utility Allowances (Summary), USDA Food and Nutrition Service, august 2017, available at https://fns-prod.azureedge.net/sites/default/files/ops/methods-standardizes-uas-summary.pdf
40 New Estimates of the SNAP Multiplier, USDA Economic Research Service, July 2019, available at https://www.ers.usda.gov/webdocs/publications/93529/err-265.pdf?v=8010.7
41 The Supplemental Nutrition Assistance Program (SNAP) and the Economy: New Estimates of the SNAP Multiplier, USDA Economic Research Service, July 2019, available at https://www.ers.usda.gov/webdocs/publications/93529/err-265.pdf?v=8010.7