MICAH comments on the USDA proposal to eliminate Categorical Eligibility, Sept 13, 2019
The Metropolitan Interfaith Council of Affordable Housing (MICAH) opposes the elimination of broad-based categorical eligibility in the Supplemental Nutrition Assistance Program(SNAP) for the following reasons:
Broad-based categorical eligibility has enabled working families who work in low-wage jobs and have high housing and childcare costs, to stretch their dollars so that they can adequately feed their families and move up the wage scale before losing this important food benefit.
The current poverty scale was based on one parent staying at home to care for their children, thus no allowance for childcare costs. As wages have stagnated and housing costs soared, families with low-wages have struggled to pay their rent, utilities, transportation, child care and food costs. Categorical eligibility helps families put food on the table so that their children can learn well in school and they can do well in their jobs.
Categorical eligibility addresses a sharp cliff in food benefits, where even a 50 cent raise per hour in wages could result in a severe drop in food resources. This has a perverse impact by forcing some families to refuse the raise so that they can continue to feed their families, thus limiting their upward mobility.
It is much more cost-efficient to allow families to account for all their expenses in determining SNAP benefits. By that, we mean families making up to 200% or more of poverty are only eligible for SNAP benefits if their expenses exceed their income. Under categorical eligibility, as their income rises, SNAP benefits go down, making it a smoother transition once they no longer qualify for benefits.
Our work here at MICAH to create more affordable housing and address racial disparities has put us in touch with many families who struggle to make ends meet, as rents rise and the building stock shrinks. As we work towards building more affordable housing, we are struck by the importance of categorical eligibility for many working families.
Categorical eligibility helps to assure families have a means to provide enough food for their families, one less worry as they work to provide for their families and move up the wage scale. It is penny-wise and pound-foolish to take this benefit away and could result in families needing more medical services and other social services.
Further-more, with the lack of affordable housing, the impact on Seniors and people with disabilities, on fixed or with no incomes would likely also increase medical and other costs.
In closing, broad-based categorical eligibility helps to address the inequity in the actual cost of living versus the poverty level. All of us are better off when families, seniors, and people with disabilities have access to good nutrition and a chance to work and learn well.
Please rescind this rule and keep broad-based categorical eligibility in place.
MICAH policy coordinator
Sue Watlov Phillips
Executive Director, MICAH