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).

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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.

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.

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LiveOn NY Strongly Opposes Federal Government Attacks on Older Adults in Need of Assistance

Date: August 19, 2019
Press Contacts: Allison Nickerson, Executive Director (anickerson@liveon-ny.org | 212-398-6565 x. 224) or Katelyn Andrews, Director of Public Policy (kandrews@liveon-ny.org  | 212-398-6565 x.244)

New York, NY – LiveOn NY unequivocally opposes the continued, systemic attacks on older adults in need of assistance, namely low-income seniors, immigrants, communities of color and other marginalized populations. 

We remain resolved in our continued efforts to advocate for policies that will safeguard against hunger, ensure housing, promote health and address economic inequality. 

LiveOn NY will in no way be deterred by the Federal government’s most recent attacks, specifically the institution of the Public Charge rule, which threatens older immigrants’ ability to receive assistance in the face of hunger and housing instability; and the Supplemental Nutrition Assistance Program (SNAP) proposal, which, if actualized, would undercut the ability for seniors with limited income to afford food.

LiveOn NY also looks forward to continuing to work with our locally elected officials to curb the effects of these policies and we thank all who stand as allies to our communities during this time.

In the face of these attacks, we must continue to strengthen our support for the human services organizations working to serve the very populations these proposals seek to harm – from senior centers to home-delivered meals providers we know that these community-based services are lifelines to so many older adults.

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. We are dismayed and disturbed to see the Federal government’s continued efforts to take these same tools away.

Neither the institution of the Public Charge rule nor the proposal to take SNAP away from more than 3 million Americans will break our resolve to making New York a better place to age and we encourage you to join us in doing so.

About LiveOn NY

At LiveOn NY, we believe that all people have a future. Our work is centered on making sure that New York is a great place to age. We do this through targeted advocacy, data-driven policy, direct assistance & innovative programs. As a membership organization, we represent 100 agencies from small, single-site centers to large multi-service organizations. Through our work and membership, we represent the 3.2 million older New Yorkers and their caregivers.

LiveOn NY In the News

At LiveOn NY, we work hard to make sure that the public hears about the issues affecting older New Yorkers, as well as the incredible momentum that exists as we grow old. To this aim, we are proud of each and every time we are able to share this narrative with our local communities or to comment on a topic effecting older New Yorkers.

Below are a few articles & press releases related to our work: 

June 20, 2019 “NYC’s Seniors Get Solid Wins in City’s Budget” article by Roshan Abraham in City Limits

June 12, 2019 “Finding Affordable Housing In NYC Is Hard, It’s Almost Impossible If You’re A Senior” article and video segments in CBS New York

“You shouldn’t ever have to choose between your job and caring for your loved ones”

— Andrea Cianfrani, Associate Executive Director

June 6, 2019 "New Yorkers Are Living Longer Than Ever" article by Melanie Grayce West in the Wall Street Journal

May 9, 2019 “Seniors Rally at City Hall” article and video coverage by Jarrett Murphy in City Limits

April 24, 2019 “The Distressing Math of NYC’s Future Senior-Housing Need” article by Toni Kamins in City Limits

March 26, 2019 “Opinion: It’s Time to Make NY a #FairCity4AllAges” Op-Ed by Katelyn Andrews, Director of Public Policy at LiveOn NY, and Council Member Margaret Chin, Chair of the New York City Council Committee on Aging, in City Limits

February 13, 2019 “NY Program is Uneven in Supporting Those Caring for Aging Parents” article by Roshan Abraham in City Limits

We look forward to continuing to weigh in on aging issues throughout New York City, for upcoming press inquiries, please reach out to Katelyn Andrews at kandrews@liveon-ny.org or 212-398-6565 x. 244

LiveOn NY Testifies at Final Public Hearing on FY20 City Budget!

On May 23rd, Director of Public Policy, Katelyn Andrews testified to the City Council Committee on Finance and Subcomittee on Capital on the need for additional senior service funding in the FY20 City Budget.

Watch the hearing here and listen to the inspired testimony of dozens of fellow New Yorkers
LiveOn NY testifies at the 4:22:00 minute mark in this 7+ hour hearing

Read our full, written testimony, below:

New York City Council
Committee on Finance, Chair, Council Member Dromm
Subcommittee on Capital, Chair, Council Member Gibson
May 23, 2019
Executive Budget Hearing

Thank you Chair Dromm, Subcommittee Chair Gibson, and the full committees for the opportunity to testify on how we can work together to make New York a fair city for all ages.

On behalf of LiveOn NY, at this pivotal time in our city’s budget negotiations, I would like to clearly articulate the urgent and significant need for increased funding that exists for New York’s senior service providers. I also would like to fully appreciate and thank the Council for your steadfast support of senior programs, and particularly for your inclusion of the necessary increase to meals funding in your preliminary budget response. LiveOn NY is hopeful that this recommendation will rightly make its way into the final budget.

Just this afternoon, lunch was served at senior centers in communities across the five boroughs, thousands of meals were served to seniors, the majority of whom report that this singular meal makes for more than half of their daily intake of food. However, in spite of the clear value of these meals, they have for years been funded far below their worth, with the last across-the-board increase to providers being a mere 25 cents in 2014. Today, providers of both home-delivered and congregate meals in our high-cost city are funded at a rate that is 20% lower than the national average.

The effect? Mission-driven, community-based providers are losing money on every meal they serve or, to put it another way, they are supplementing the City for its true cost of doing business. This is unsustainable and unfair. It’s time to become a fair city for all ages by investing $20 million in DFTA’s congregate meal program and $15 million in home-delivered meals, for a total new investment of $35 million in meals for seniors.

The picture I just painted of the historic and chronic underfunding of meals for seniors is not an anomaly. Across the human services sector, contracts are funded at a rate far below the cost of service provision. In many cases, the culprits behind this pervasive underfunding are inadequate indirect rates and contract reimbursement rates. For this reason, LiveOn NY, is proud to stand alongside the Human Service Council, and providers serving New Yorkers across the lifespan, to call on the city to provide $106 million in funding to begin to rectify this wrong. We are again appreciative of Council’s inclusion of this item in your budget response and are resolute in our efforts to ensure this funding is included in the final budget.

Given that the Department for the Aging (DFTA) budget remains less than ½ of 1% of the overall budget, LiveOn NY remains cognizant of the fact that there are many programs in need of funding increases, including:

• 1.3 million in new funding for NORCs;

• $5 million for services in senior housing; and

• $10 million for improved infrastructure across senior centers, an ask that we are appreciative that the Mayor took steps to fulfill in the Executive Budget, earmarking $6 million in new funds for infrastructure expenses, such as air conditioners in senior centers.

A more comprehensive listing of needs is attached to this testimony for your consideration.

As we all grow old, and as the population of older New Yorkers rapidly increases, LiveOn NY remains committed to working with our city partners to make New York a better place to age. We hope that the FY20 budget marks a firm step towards this goal.

Thank you for the opportunity to testify.

LiveOn NY Calls for Investments to Make NY a #FairCity4AllAges

LiveOn NY testimony provided for the record:

New York City Council
Committee on Finance, Chair, Council Member Daniel Dromm
March 6, 2019
Preliminary Budget and Oversight Hearing

Thank you Chair Dromm and the Finance Committee for the opportunity to testify on how we can work together to make New York a fair city for all ages. LiveOn NY also thanks Mayor de Blasio, Speaker Johnson, DFTA Acting Commissioner Caryn Resnick, Aging Committee Chair Margaret Chin and the entire City Council for their consideration of needs of older adults in the FY20 budget.

With a base of more than 100 community-based organizations, LiveOn NY’s members provide core services that allow older adults to thrive in their communities, including senior centers, congregate and home‐delivered meals, affordable senior housing, elder abuse prevention services, caregiver supports, transportation, NORCs and case management. DFTA’s network provides services to over 50,000 older adults daily. Let’s be clear, these services aren’t just nice to have: studies have shown that services such as senior centers, home delivered meals and others are key to positively affecting health impacts and preventing isolation.

LiveOn NY recognizes and is encouraged by initial investments in senior services by the de Blasio Administration and ongoing investments by City Council. That said, the DFTA budget still accounts for less than 1% of the total city budget, a point that is only exacerbated by the fact aging New Yorkers are the now fastest growing demographic. Further, New York City spends 20% below the national average on senior meals – that means they are only paying for 4 out of every 5 needed meals.  This does not reflect fairness for older New Yorkers, senior service staff and nonprofits that serve older New Yorkers. In order for New York to truly be the fairest big city, it must be a #FairCity4AllAges. Fairness does not have an age cutoff.

LiveOn NY’s priorities are attached to our testimony, and are briefly highlighted them below.  

Invest $20 million in Senior Center Meals and Kitchen Staff

WHY:

• Senior centers provided 7.6 million senior center meals in FY17

• 30,000 seniors visit seniors centers daily

• 56% of seniors report that meals eaten at the center makeup ½ or more of their daily food intake

• NYC currently funds senior meals on the average at 20% below the national average funding 4 out of every 5 meals, with nonprofits picking up the rest of the costs.  

• In 2008-2013 alone, the cost of food increased by 11% according to the Consumer Price Index while nonprofits struggle to keep pace.

• Food costs, raises for kitchen staff and kitchen equipment and maintenance costs were specifically excluded from the model senior center budget funding last year, leaving a void in budgets despite the fact that kitchens are core to a senior center.

• Over 50% of older New Yorkers are foreign born according to a recent Center for an Urban Future study, reflecting a significant need for meals that are culturally appropriate to an array of backgrounds, which brings an underfunded fiscal impact. In 2015, DFTA stated that, “in DFTA’s HDML network, each catered Kosher [meal] is on average $1.38 more than non-Kosher catered meals.” Similar to Kosher meals, Halaal, gluten free, vegetarian, vegan, or other cultural or nutritional needs have an associated cost-increase.

• A citywide RFP for senior centers is expected in the near future.

$20 MILLION WILL FUND:

• Increase for raw food costs, including funding for culturally competent meals

• Increase in costs for disposables to serve food

• Increase in funds to support fair salaries for kitchen staff and to fully staff kitchens to address numerous responsibilities including food preparation, cooking, serving meals, menu planning and submissions, inventory, ordering, accounting, managing volunteers and numerous other responsibilities required to operate a kitchen. 

• Repairs and maintenance for critical kitchen equipment including ovens, refrigerators and HVAC systems. These costs and needs are heightened in NYCHA senior centers and programs, which have critical additional infrastructure and repair needs.

• Funding for critical inspections and services that are required annually or several times a year, including extermination, grease trap cleaning and grease removal, hood cleaning, fire suppression systems, maintenance of HVAC systems and refrigerators and freezers as well as treating sewage back up problems and security alarm service and maintenance.   

• All DFTA senior centers, including the 38 additional programs were not evaluated in the “model senior center” budget process last year, should receive funding for meals.  

Expedite the Additional $10 million “Promised” for Senior Center Staff and Programs

DFTA allocated the first $10 million in model senior center budget funding late in FY19 and the second $10 million is “promised by FY21.” As noted, this funding specifically excluded meals and meal staff.  We see no reason for the city to hold this funding. It should be expedited as soon as possible.

Invest $15 Million in Home Delivered Meals

WHY:

• This year, providers will distribute over 4.6 million home delivered meals

• The majority of seniors utilizing the program are women, living alone, receiving meals that on average account for ½ or more of their total food for the day

• Nationally, 59% of meal recipients live alone – and the person delivering the meal is often the only person they will see that day

• Seniors are underenrolled in SNAP - among those living with hunger, the under-enrollment rate of SNAP benefits is around 40%

• NYC reimbursed providers 20% below the national average for home delivered meals

• A citywide RFP is expected for home delivered meals in the near future

$15 MILLION WILL FUND:

• Increase for raw food costs, including culturally competent meals

• Increase in costs for disposables to serve food

• Critical increase in funds to support fair salaries for home delivered meals staff, who are critical to the human interaction for home delivery

• Funds for equipment, kitchen needs and food preparation

Invest $10 Million for Repairs, including funding for NYCHA Senior Programs

Senior Centers have infrastructure and repair needs, often that arise in an emergency, however there is not set funding or process to request these funds and centers are often confused and unaware of how to address such needs. These issues are exacerbated in the nearly 100 DFTA programs that operate in NYCHA community spaces which offer critical programs for older adults. The city should invest $10 million to provide funding for DFTA senior center and program infrastructure needs, and for accessible funding for emergency repairs and conditions, particularly in the 100 DFTA NYCHA Senior Centers and Clubs.

Invest $5 Million for Service Coordinators in Senior Housing

87% of senior of seniors would prefer to age in their homes. Research has shown a service coordinator located in a senior building is a proven cost-effective way to support seniors in their community, reducing hospital & nursing home costs. Seniors at Selfhelp Community Services were found to have significant healthcare savings: Selfhelp residents were 68% less likely to be hospitalized compared to seniors in the same zip codes, representing an average savings of $3,937 per person, per hospitalization.

Investing $5 million in a citywide Service Coordinators Program would would provide one full time and one part time service coordinator at nearly 40 new or existing affordable senior housing buildings to provide culturally competent information and support. Promotion of overall health and wellness the interconnection of services through the co-location of services can mean the difference between successfully aging in place verses experiencing costly hospitalizations or a move to a nursing home. Service coordinators provide culturally and linguistically competent opportunities for seniors in affordable housing buildings. Qualified social workers in these buildings can help older adults to access benefits, provide referrals to other services as needed, including home care, and combats isolation by connecting residents to socialization opportunities and other local resources, all of which promote healthy aging in the community.

Invest $1 Million for Case Management

There are over 1,000 seniors on case management waitlists citywide. LiveOn NY greatly appreciates the investments in FY18 which are beginning to address waitlists, as well as funding added by Council in FY19,  but the need continues to grow. We must continually build this system to serve today’s need and the needs of the future. Additional funding is needed to reduce caseloads, which already very high at an average of  65. Funding is also needed to serve frail, homebound seniors on waiting lists so that a social worker is available to visit them at home, assess their needs and provide ongoing services. MSW compensation, as well as multilingual staff needs to be funded to ensure there is a professionally trained social worker who can work with immigrant and diverse populations and complex situations. Funding growing need and agency infrastructure are cornerstones to strengthening the case management system citywide. Case Management is a key program that services seniors that are not Medicaid eligible but still need these services, and it is vital to sustain this program.

No PEGs for DFTA

Across the board reductions through the recently announced Program to Eliminate the Gap (PEG) disproportionately and unfairly affect small agencies, such as DFTA, which receives such a small portion of the city budget to begin with. To avoid cutting direct services to older New Yorkers and the staff that serve them, DFTA should not be subject to PEGs.

Council Restorations and Investments in Senior Services Through Schedule C

City Council has long been a staunch supporter of city and district wide senior services programs through allocations in Schedule C. We thank you for your investments and advocate for full restoration for all Senior Service Programs funded in Schedule C.  These include NORCs, Support our Seniors, SuCasa, Senior Centers for Immigrant Populations, Health Aging Initiative, Social Adult Day, and others.

Age Friendly Commission

LiveOn NY sits on the Age Friendly Commission and knows the importance of the Commission and its work groups.  It is critical to convene thought leaders from across disciplines working on these critical issues. LiveOn NY supports continued funding for $100,000 for the Age-Friendly Commission to support its critical work, as well as an additional $250,000 to support the ongoing and new work groups for the commission for a total of $350,000.

Continued Investments in Human Services Sector

LiveOn NY is a member of the Human Services Advancement Strategy Group (HSASG).

The human services sector of our City is in crisis. Providers have long been sounding the alarm about the impact of the chronic underfunding of government contracts, and now we have reached a breaking point. Without a crucial investment on our current contracts, my organization will have to reevaluate how we can engage with the City to provide crucial services to our communities. As things currently stand, we can no longer carry the deficit of our City contracts.

The gap between what the City funds on human services contracts and what providers can supplement with private and philanthropic dollars has grown too wide. It is vital that no cuts are made to human service programs as part of the mandated budget reductions and the chronic underfunding of the sector is rectified.

The sector is united in asking the City Council to include in their budget response a request for the Mayor to invest $250 million dollars to fill  the gap between provider’s indirect costs and the contract reimbursement rates from the City. The new Health and Human Services Cost Policies and Procedures Manual, which was developed alongside Deputy Mayor Palacio, lays out standardized indirect costs for our sector. However, without increased funding to address the gaps this manual displays in our contracts, the fiscal crisis we are facing remains unaddressed. Based on numbers provided by the Office of Management and Budget, $250 million should cover the costs to fully implement this manual.

While we understand the driving narrative around this budget is mandated budget cuts, there is money to go around. The City has made massive investments in areas including city staff and infrastructure while the needs of the human services sector have gone largely ignored. It is time to take the state of emergency facing this sector seriously and prioritize the needs of organizations that provide an estimated 2.5 million New Yorkers annually with critical services including after-school programs, supportive housing, homeless services, job training, and mental health services.

LiveOn NY looks forward to working with Mayor de Blasio, City Council, DFTA, all city agencies to make New York City a fair city for all ages and better place to age through a strong network of community based services.