SNAP Program Design Branch,
Program Development Division
Food and Nutrition Service
3101 Park Center Drive
U.S. Department of Agriculture
Alexandria, VA 22302
Re: Notice of Proposed Rule Making -- Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP); Reopening of Comment Period RIN 0584-AE62
Dear SNAP Program Design Branch:
I am writing on behalf of the Montana Budget and Policy Center to express our strong opposition to the United States Department Agriculture’s Notice of Proposed Rulemaking (NPRM) on a Revision of Categorical Eligibility the Supplemental Nutrition Assistance Program (SNAP) during the reopening of the comment period. The proposed rule will jeopardize free school meals for nearly one million children. The proposed rule should be withdrawn.
The Montana Budget & Policy Center is a nonpartisan, nonprofit organization that provides in-depth research and analysis on tax, budget, and economic policies in order to promote opportunity and fairness for all Montanans.
The proposed changes would cause significant harm to the health and education of Montana children by restricting their access to free and reduced-price school lunches.
The proposed rule ends Montana’s ability to eliminate SNAP asset tests and use a higher income test in order to account for working households with higher expenses such as shelter and childcare. This policy is known as Expanded Categorical Eligibility in Montana and serves to encourage work by preventing a sudden decrease in benefits if workers receive a raise or work more hours.
In Montana, the proposed rule change will result in over 2,000 households with children losing their SNAP benefits.[i] For families with children, losing access to free school meals in addition to their SNAP benefits will substantially compound their food insecurity.
Free school lunches improve children’s diets overall, and they have academic benefits well. Hungry children cannot learn. Children who experience hunger are more likely to struggle with behavior and academic problems, creating ripple effects in classrooms as teachers spend more time dealing with classroom disruptions and helping students who are falling behind.[ii]
School districts in Montana already struggle with working families being able to pay for school meals, even at reduced prices. In 2018, Helena Public Schools announced an effort to recoup $100,000 in school debt (twenty percent of which had been accumulated by families receiving free and reduced priced meals). The district initially threatened to send families to collection agencies.[iii] With hundreds of families already struggling to pay meals at reduced prices, removing free and reduced-price meals for more students will only exacerbate this problem.
Because the Department did not release the data concerning the number of children who will no longer be able to receive free school lunches during the initial comment period on the proposed rule, Montana’s school districts have not had an opportunity to grasp the extent to which this proposed rule harm Montana children. It is clear, however, that by preventing children from receiving healthy school meals, this proposal puts the health and the education of Montana’s children at risk.
We strongly oppose this rule that would reduce children’s access to healthy food both at home and at school.
Montana Budget and Policy Center
15 West 6th Avenue, 3E
Helena, MT 59601
[i] Robert Wood Johnson Foundation, “New Research Analyzes State-Level Impact of USDA Proposal to End SNAP Broad-Based Categorical Eligibility,” Accessed November 1, 2019. https://stateofchildhoodobesity.org/new-research-analyzes-state-level-impact-of-usda-proposal-to-end-snap-broad-based-categorical-eligibility/
[ii] Food Research and Action Center, “Benefits of School Lunch,” Accessed November 1, 2019. https://frac.org/programs/national-school-lunch-program/benefits-school-lunch
[iii] Loranger, erin, Helena Independent Record, “Helena Schools to Forgive Some Meal Debts, Collection Agency a ‘Last Resort’,” April 10 2018, https://helenair.com/news/local/helena-schools-to-forgive-some-meal-debts-collection-agency-a/article_da89bc9c-1ccc-5caf-b6bd-94555a0e2fa2.html
MBPC is a nonprofit organization focused on providing credible and timely research and analysis on budget, tax, and economic issues that impact low- and moderate-income Montana families.