LiveOn NY Public Comment Opposing Proposal to Eliminate SNAP Broad-Based Categorical Eligibility

The following comments were submitted to The Food and Nutrition Service. The FNS is housed within the US Department of Agriculture (USDA) and is the federal agency responsible for administering the Supplemental Nutrition Assistance Program (SNAP).

LiveOn NY would like to respectfully express our strong opposition to the proposed rule to eliminate the broad-based categorical eligibility (BBCE) provision in the Supplemental Nutrition Assistance Program (SNAP). LiveOn NY is a nonprofit membership organization representing 100 community-based organizations serving older adults in New York City. We also provide direct assistance to older New Yorkers through our Benefits Outreach Program, in which our team screens individuals for eligibility and assists through the entirety of the application process.

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Currently, SNAP is one of our nation’s most effective anti-poverty programs, helping more than 38 million people in the United States meet their basic nutritional needs every month. This dangerous proposal would cause immediate harm, taking food assistance away from 3 million people nationwide — nearly 660,000 of whom are seniors 60 years and older. By revoking a state’s right to ensure their SNAP program caters to its local communities, this proposed rule would also negatively impact those who were able to retain their SNAP benefits past the initial purge of benefits. Through the freedom to customize eligibility guidelines, a state is able to ease rules that would punish older adults for their modest savings, as well as increment the otherwise looming benefit cliff that affects Social Security recipients when receiving a Cost of Living Adjustment.

Through LiveOn NY’s benefits outreach work, we see the impact nutrition assistance programs have in the lives of older New Yorkers every day — many of whom are forced to choose between food, rent, and medication. In just one example of a typical case for our team, we met Ms. K, a 75 year-old widow, after losing her husband of over 40 years. She received approximately $2,100/month in Social Security benefits and from a small pension, and had modest savings of only $2,000. Ms. K owned her home in Queens where she and her husband brought up their children. Although her mortgage was paid off, she still had considerable housing-related expenses such as water, heat, and electricity. She also had property taxes and homeowners insurance to pay. Because of these expenses, coupled with her limited income, Ms. K found it extremely difficult to afford healthy food, and reported that there were times when she could only afford to eat two small meals a day.

LiveOn NY’s staff met Ms. K at the senior center she attends two to three times a week and talked to her about applying for SNAP. Initially, Ms. K was skeptical, believing she may be ineligible. However, because New York State employs Broad Based Categorical Eligibility, the guidelines allow adults over 60 years old or those who are disabled to have a higher income and a modest savings, improving Ms. K’s chances of eligibility. After walking Ms. K through the application process, she was approved for SNAP; and today, she is able to afford much-needed fresh fruits and vegetables as a result of this critical program.

If this proposed change to BBCE were actualized, it would undercut the ability of seniors — namely low-income seniors, immigrants, and communities of color — to afford food.

Ms. K’s situation is not unique; our team assists older New Yorkers like her every day. If this proposed change to BBCE were actualized, it would undercut the ability of seniors — namely low-income seniors, immigrants, and communities of color — to afford food. Consequently, many individuals like Ms. K would find themselves at a greater risk of hunger, inevitably posing a threat to their health and housing stability. Additionally, instead of fostering overall wellbeing, removing the BBCE system actively discourages low-income individuals from taking a job with better pay and accumulating savings for emergency expenses. 

At LiveOn NY, we uphold that we all have the ability to continue to thrive, contribute, and find meaning in our later years, especially when afforded the basic tools necessary to do so. For many older adults, the SNAP program is one of these tools — a tool that we encourage the Federal government to continue to support.

As a result of our forty years of experience working with older New Yorkers, we believe that this proposal is the antithesis of what is needed to ensure that the United States is a great place to age, and we encourage the Federal government to withdraw this proposal in its entirety. It is critical that each state retains the right to determine eligibility guidelines for this program as it has such a profound impact on our local communities, including the economic viability of the very shops that accept SNAP. Finally, we remain resolved in our continued efforts to advocate for policies that will safeguard against hunger, ensure housing, promote health and address economic inequality; and we are hopeful that a similar resolve will compel the Federal government to conclude that this proposal is not worth further pursuing.