On September 23, NACo submitted comments on a U.S. Department of Agriculture (USDA) proposed rule that would implement stricter eligibility requirements for individuals and families seeking Supplemental Nutrition Assistance Program (SNAP) benefits.
As drafted, the USDA proposal would narrow broad-based categorical eligibility (BBCE) for SNAP, a process that aims to streamline the welfare application process by allowing certain individuals receiving Temporary Assistance for Needy Families (TANF) program benefits to qualify for SNAP.
Under SNAP’s current broad-based categorical eligibility rules, states are not required to review a person’s total assets and can consider program applicants with incomes above 130 percent of the federal poverty level. Current regulations allow recipients of all non-cash, in-kind and TANF services to be considered for SNAP eligibility. The proposed rule would alter these eligibility rules to apply only to individuals receiving TANF benefits for subsidized employment, work supports or child care benefits.
NACo’s comments outlined concerns about the rule’s potential to create new financial and administrative requirements without providing additional federal resources, thereby creating a new unfunded mandate for local governments. NACo’s comments also noted the proposed rule could result in increased reliance on local agencies and services as residents lose access to their federal benefits.
In general, counties support streamlining of federal programs to reduce mandates and administrative burdens on local governments. This includes supporting processes such as BBCE, which allows counties to easily consider applicants for federal assistance programs we administer.
Given the central role counties play in determining federal program eligibility and delivering services to residents, NACo encourages USDA to consider the full scope of the proposal’s potential impacts and study potential cost shifts to counties before finalizing a new eligibility threshold.
Additional resources on USDA’s proposed rule:
- Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP) (Federal Register rule text)
- Comment period open for USDA draft proposal to modify SNAP eligibility (NACo blog)
- Understanding the County Role in the Supplemental Nutrition Assistance Program (NACo legislative presentation)