DMARC Statement on Proposed USDA Rule Change to Broad-based Categorical Eligibility

The Des Moines Area Religious Council (DMARC) strongly opposes the United States Department of Agriculture (USDA)’s proposed rule change that would significantly roll back broad-based categorical eligibility (BBCE) for the Supplemental Nutrition Assistance Program (SNAP).

Iowa is one of 42 states and jurisdictions that utilizes broad-based categorical eligibility to effectively increase the threshold for SNAP benefits up from the federal income limit of 130% of the federal poverty level (FPL). Thanks to broad-based categorical eligibility, the gross income limit for SNAP eligibility in Iowa is 160% FPL ($19,984 annual income for an individual or $41,200 for a family of four).

In the past 12 months (August 2018-July 2019), the DMARC Food Pantry Network assisted 621 households comprised of 1,321 individuals who were participating in SNAP and had an income between 130-160% FPL. Looking at the demographics of this group of 1,321 individuals, we find:

• 34.3% were children and 8.9% were older adults (65+)
• 31.9% of adults were working full-time, 13.8% were working part-time, and just 7.4% were unemployed, with the remainder having another form of income like disability or social security

These individuals, along with thousands of other Iowans, will no longer be eligible to receive SNAP benefits because their income is too high, should this proposed rule be enacted. Food banks, food pantries, and other anti-hunger organizations can expect to see more people use their services to make ends meet as SNAP benefits are lost.

Additionally, this rule change would have a ripple effect on other nutrition programs. Students are automatically eligible for free lunch if they receive SNAP benefits. Were this rule change to take effect, an estimated 265,000 students across the country would lose access to those free lunches. Although effected families may still be eligible for free or reduced lunches through the regular application process, this would add an additional barrier to access.

The proposed rule change would only allow for people to be categorically eligible for SNAP through broad-based categorical eligibility if they received more than $50 worth of Temporary Assistance for Needy Families (TANF) benefits for a minimum of six consecutive months. The proposed change would impact the lives of an estimated 3.1 million people (1 in 8 SNAP participants) across the country who currently qualify for SNAP through broad-based categorical eligibility.

The federal income limit of 130% FPL for SNAP is far too low. According to the United Way’s 2016 ALICE report for Iowa, a family of four living in Polk County, Iowa, must have an income of 210% FPL to simply meet a “survival” budget. Clearly, the federal income limit for SNAP eligibility must be raised.

This proposed rule change to broad-based categorical eligibility would be damaging to the health and nutrition of millions of Americans, and would significantly increase the strain on local governments and nonprofit social services organizations to meet the needs of those who are at risk of losing access to SNAP benefits. The proposed rule would create far more problems than solutions.

DMARC encourages the public and our supporters to speak out against the proposed rule change in regards to broad-based categorical eligibility during the public comment period that ends on September 23, 2019. Feel free to use aspects of our message above, but be sure to create a personal message of your own, as duplicated comments will be discarded and will not be reviewed.