September 23, 2019
Program Design Branch
Program Development Division
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, Virginia 22302
RE: Proposed Rule: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program [FNS-2018-0037]
Dear Program Design Branch:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Program Design Branch at the SNAP Program Development Division of the U.S. Department of Agriculture related to its proposed rule, "Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (RIN 0584-AE62)," published in the Federal Register originally on July 24, 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 limit state options for Broad Based Categorical Eligibility (BBCE). We oppose this rule for the following reasons:
- by USDA's own estimation, 3.1 million people will lose access to SNAP benefits including seniors and children
- the rule jeopardizes access to free school meals for 500,000 children
- it takes state flexibility away from administering the program and creates greater economic instability for struggling families and communities
- 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 Academy that systematic and sustained action is needed to achieve food and nutrition security in the United States. To achieve food security the following is needed:
- adequate funding for, and increased utilization of food and nutrition assistance programs
- inclusion of nutrition education in such programs
- strategies to support individual and household economic stability
- and research to measure impact on food insecurity and health related outcomes2
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.6 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 percent13 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 For example, 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 percent lower over 12 months, including those paid by private or public insurance, than similarly situated adults not participating in SNAP.
SNAP improves child, adult and senior health outcomes, including physical and mental health.19 The program increases the probability of self-reporting "excellent" or "good health,"20 lowers the risk of poor glucose control for people with diabetes21 and has a protective effect on mental health.22 SNAP also helps reduce stress for struggling individuals and families worried about finances, which is significant given the high correlation of stress with poor health outcomes.23
C. Proposed Rule Would Hurt Children and Seniors
In its Regulatory Impact Analysis (RIA) of the proposed rule, USDA reports that 3.1 million people – or approximately 9 percent of SNAP households – will lose access to benefits.24 According to data released by Mathematica, some states will be impacted more than others including Wisconsin, Delaware, North Dakota, Iowa, Nevada, Oregon, Washington, and Texas, where 15 to 18 percent of households will lose program eligibility.25 The Academy is especially concerned about the disproportionate impact of the proposed rule on two of our most vulnerable populations: children and seniors.
According to USDA,26 the proposed rule would result in 7.4 percent of SNAP households with children losing access to SNAP because they no longer meet the income or asset requirements. An estimated 1.9 million children and the adults they live with will no longer have access to SNAP benefits, representing 61 percent of the projected 3.1 million people who will lose their SNAP benefits.27
Furthermore, children who qualify for SNAP through BBCE also receive direct certification for free school meals. The proposed rule jeopardizes not only the receipt of SNAP benefits but also access to free school meals for 500,000 children; USDA failed to include this critical data point in its RIA.28> The impact of this proposed rule is at a time where unpaid meal debt and lunch shaming are challenges that school districts and communities are faced with on a daily basis.29,30,31 Evidence shows that the health of students is linked to their academic achievement32 and that dietary quality of school meals is better than students' overall dietary quality.33 The Academy supports efforts to strengthen and expand access to free school meals so children have access to nutritious food and are ready and able to learn.
SNAP plays a critical role in addressing hunger and food insecurity in our community and is the first line of defense against hunger 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.The cut outlined in the proposed rule falls disproportionately on households with seniors. More than 600,000 SNAP households with members over age 60 would be cut from SNAP food assistance, according to USDA’s estimates of the effect of the proposed rule.34 This number represents more than one-third of the 1.7 million households estimated to lose SNAP.
Approximately 71 million people in the United States are age 60 and older. Many live on fixed incomes and have limited financial means to afford expenses such as food, medical or housing costs. Unfortunately, food insecurity among seniors is all too common a problem. In 2018, approximately 30 percent of all U.S. households included individuals aged 65 and older. Of this group, 7.5 percent were food insecure, meaning that these households had difficulty affording nutritious, adequate food.35
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. Compared to other adult age groups, seniors are particularly vulnerable to the health consequences of food insecurity.36 Malnutrition is a leading cause of morbidity and mortality for older adults and as many as 50 percent of older adults are at risk for malnutrition.37
D. Proposed Rule Hurts Economic Stability and Limits State Flexibility
The proposed rule would greatly reduce states’ flexibility to deliver SNAP in a way that is best for the residents (or citizens) of that state. It would eliminate SNAP asset test waivers and the use of a higher income test to serve more working households that have significant expenses for other basic needs like shelter and child care. In doing so, it will produce a "cliff effect" that abruptly takes food support away from low-income families who are working their way up the economic ladder. By USDA’s own estimates, the proposed rule would cut SNAP benefits over five years by $10.543 billion, while increasing SNAP administrative costs by $2.314 billion.38
The 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 recession.39 USDA's Economic Research Service has also reported that SNAP spending has effects on manufacturing and trade and transportation sectors. These sectors impact 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.40 The Academy acknowledges the importance of economic stability as part of the solution to address food insecurity. This proposed rule would undermine the positive economic impact of the SNAP program on both families and communities.
E. Proposed Rule Goes Against Bicameral, Bipartisan Agreement
Congress has repeatedly rejected efforts to change the structure of categorical eligibility, including as recently as the 2018 Farm Bill enacted last December. This USDA rulemaking is an attempt to side step Congress and ignore the will of those who voted for the historically bipartisan, bicameral bill undermining the intent of separation of powers among branches of government.
The Academy appreciates the opportunity to submit comments to the Program Design Branch at the SNAP Program Development Division of the U.S. Department of Agriculture related to its proposed rule, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program.” The Academy believes that USDA should be strengthening the positive impacts of SNAP for health, well-being and economic activity, not eliminating eligibility for millions of people. 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.
4 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.
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.
6 Hartline-Grafton, H. (2017). The Impact of Poverty, Food Insecurity, & Poor Nutrition on Health and Well-Being. Washington, DC: Food Research & Action Center.
7 Franklin 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.
10 Herman, 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.
19 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.
20 Gregory, C. A., & Deb, P. (2015). Does SNAP improve your health? Food Policy, 50, 11-19.
21 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.
22 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.
23 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.
24 Regulatory Impact Analysis. Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program. https://www.regulations.gov/document?D=FNS-2018-0037-0002. Accessed September 18, 2019.
25 https://www.mathematica-mpr.com/news/new-research-analyzes-state-level-impact-of-usda-proposal-to-end-snap-broad-based-categorical. Accessed September 18, 2019.
27 Estimate based on Regulatory Impact Analysis supplement to Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program, Table 4. Administration estimates assume 2020 caseload will represent roughly 87 percent of 2016 caseload.
28 Representative Bobby Scott, "Chairman Scott to Secretary Perdue: Release Internal Estimates Showing Impact of Proposed SNAP Changes on Free School Meals," United States House of Representatives Committee on Education and Labor, July 2019.
29 https://www.cnn.com/2019/05/17/us/unpaid-school-lunch-debt-trnd/index.html. Accessed September 22, 2019.
30 https://newfoodeconomy.org/school-lunch-debt-usda/. Accessed September 22, 2019.
31 https://abcnews.go.com/US/alternative-lunches-shaming-meal-debt-negative-impacts-students/story?id=63172737. Accessed September 22, 2019.
32 CDC. https://www.cdc.gov/healthyschools/health_and_academics/pdf/health-academic-achievement.pdf. Accessed September 22, 2019.
33 USDA. School Nutrition and Meal Cost Study. https://fns-prod.azureedge.net/sites/default/files/resource-files/SNMCS_Summary-Findings.pdf. Accessed on September 22, 2019.
34 Regulatory Impact Analysis. Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program. https://www.regulations.gov/document?D=FNS-2018-0037-0002. Accessed September 18, 2019.
35 Hunger Among Older Adults. Food Research and Action Center. https://www.frac.org/hunger-poverty-america/senior-hunger. Accessed September 18, 2019.
36 Gundersen C, Ziliak JP. Food Insecurity And Health Outcomes. Health Aff (Millwood). 2015 Nov;34(11):1830-9.
37 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.
38 Regulatory Impact Analysis. Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program. https://www.regulations.gov/document?D=FNS-2018-0037-0002. Accessed September 18, 2019
39 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
40 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