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Comments to USDA on Supplemental Nutrition Assistance Program

The Department of Agriculture (USDA) proposed revisions to eligibility for its Supplemental Nutrition Assistance Program, or SNAP. We submitted comments focusing on serious flaws in the agency’s analysis of the rule’s impacts.

Under the proposal, more than 3 million current SNAP beneficiaries would lose eligibility and hundreds of thousands of children will no longer automatically qualify for free schools meals. In its analysis, however, USDA does not identify any significant social benefits that would result from tightening eligibility requirements. The agency also fails to monetize or otherwise quantify the negative economic consequences of reduced food security and savings among individuals who no longer qualify for nutritional assistance. Our comments detail the numerous additional costs of the proposed rule that USDA failed to recognize entirely, including potential declines in public health, academic performance, and employment.