Houston Food Bank strongly opposes the proposed severe restrictions on Broad-Based Categorical Eligibility (or “Cat El”) that would make it difficult for people experiencing poverty to access food and other needed services.

On July 24, 2019, the USDA published a rule to the federal register that would restrict states’ flexibility to serve individuals and families experiencing food insecurity. After Congress and the Administration debated and reauthorized SNAP through the Farm Bill, the Administration is now proposing to implement, through executive action, a second SNAP benefits cut it failed to secure through legislation.

The proposal would essentially eliminate the Broad-Based Categorical Eligibility policy, which currently gives states the flexibility to:

  • Make additional low-income children eligible for free school meals. Children in households that receive SNAP are automatically eligible for free school meals without having to complete a separate application.
  • Raise SNAP’s gross income limit. Use a higher gross income limit (for example, to serve families with a gross income of up to 200% of the poverty line, versus 130%) from a TANF-funded program.Today, Cat El protects SNAP eligibility for workers as their income rises above the federal income cut-off, ensuring SNAP benefits slowly taper off rather than stop abruptly. This abrupt loss of assistance due to higher income is commonly referred to as being pushed off the “benefits cliff”—a situation in which a higher paying job or more work hours results in fewer family resources.
    • For example: If a single parent with two children, working full time at $12.75 per hour would receive about $96 a month in SNAP assistance. If the parent’s hourly wage increased by 50 cents (or $86 a month), lifting their income slightly above 130% of FPL, the family would become ineligible for SNAP under the federal income eligibility cut-off. As a result, the household’s loss of SNAP benefits would leave the family worse off after the 50 cent raise; their total monthly resources would decline by about $10 a month.
  • Lift the asset test. For example, Texas has used this flexibility to modify the eligibility requirements on SNAP households with regard to the maximum value vehicle they can own and amount of savings they may have.

The Impact
This policy change would eliminate SNAP benefits for more than 3 million people across the country by USDA’s own estimates, worsening hunger among many low-income households. If the proposed rule were to take effect, Feeding Texas estimates that 125,000 Texans would lose their SNAP benefits, and Texans who would lose their benefits currently have income somewhere between 130% and 165% of the federal poverty line. Sometimes called the “working poor,” these workers earn some wages but still struggle to make ends meet.

In Houston, according to the 2019 Houston Area Survey released in May by Rice University’s Kinder Institute, one out of every three people in the region had a hard time paying for groceries or covering the cost of housing during the past year.

“By restricting Cat El, people will have a disincentive to work more,” says Houston Food Bank President and CEO Brian Greene, “which punishes those trying to improve their situations by putting in more hours, seeking better-paying jobs, or saving money so emergencies don’t pull them closer or further into poverty,”

Restricting Cat El would also take free school meals away from hundreds of thousands of children across the country whose enrollment is linked to their families’ SNAP participation. We cannot expect our children to thrive in school when they are worried about when they will get their next meal. Any policy that results in the loss of school meals for any child who faces hunger is unacceptable.

These changes will also add administrative burdens, in both cost and complexity, thereby making programs less efficient and harming all individuals needing assistance. Two years after Hurricane Harvey, the proposed rule change would also leave disaster-prone areas like Harris County less able to cushion the blow for households whose economic circumstances are suddenly upside- down due to a natural disaster or economic downturn.

Cat El policies have been in place for more than two decades; with an estimated 588,437 SNAP eligible households in Harris County alone, there is simply no good reason to eliminate them today.

Private charity simply cannot compensate for the breadth of the impact from these harmful proposals. As with all policies that diminish SNAP, these proposed changes will increase food insecurity and force food banks nationwide to stretch beyond their capacity. Most devastating of all is the hardship for those we serve, punishing people at exactly the moment when they are making progress toward a higher income and economic stability.

These proposed changes are currently only a proposal. Once published in the federal register, the public will have 60 days to generate comments on this proposal. The clock is ticking to stop these changes, now through September 23, 2019. It is imperative that the Administration hear just how dangerous this proposal is to the health and well-being of many Americans.

We urge every member of our community to submit a comment in opposition to this proposed rule. You can use Houston Food Bank’s comment portal, post directly to the Federal Register or visit http://bit.ly/SNAPRuleCampaign2 to learn more and submit a comment.

Houston Food Bank, along with Feeding America, Food Research & Action Center (FRAC), Center on Budget and Policy Priorities, and Center for American Progress (CAP) are galvanizing individuals across the country to submit tailored comments that will count for the input that USDA must take into account before issuing a final rule.

We urge the Administration to rescind the rule, and instead work to increase SNAP participation so more families can worry less about putting food on the table and focus more on getting back on their feet.

1 United States House of Representatives. Subcommittee on Nutrition, Oversight and Department Operations. Committee on Agriculture. The Importance of Broad-Based Categorical Eligibility in SNAP. June 20, 2019. 116th Congress (statement of Elaine Waxman, Senior Fellow, Income and Benefits Policy Center, Urban Institute).