AACF Comments on Broad-Based Categorical Eligibility

Arkansas Advocates for Children and Families’ mission is to ensure that all children and families have the resources and opportunities to lead healthy lives and reach their full potential. We accomplish this by researching the needs and challenges of children, and then using that information to propose policy changes aimed at addressing those needs. All of our public policy recommendations are supported by research and data. Our efforts are centered on the needs of the children and their families, with an emphasis on those who are most vulnerable.

Arkansas Advocates submitted the following comments, in writing, to strongly oppose the Trump Administration’s proposed rule to change Broad-Based Categorical Eligibility (BBCE) in the Supplemental Nutrition Assistance Program (SNAP):

The Administration’s proposal to end BBCE would strip SNAP eligibility from millions of people in working families across the United States. The consequences for children and families would be substantial, leaving more than 3 million people without access to food necessary to living a healthy life. The two primary groups of people losing access to SNAP would be those working, but still near poverty and those saving modestly in order to become more economically independent.

By eliminating BBCE, the Administration is harming children and families. Children whose families receive food stamps are automatically enrolled in a federal program that offers free breakfast and lunch at school. However, the new proposal would eliminate eligibility for this program for more than 500,000 children. Free school meals are vital to addressing food insecurity across the U.S.

Under the current program, Broad-Based Categorical Eligibility allows states to consider cost of living, wages, and other local economic conditions when determining people’s eligibility for SNAP benefits. With BBCE, SNAP applicants have greater opportunity to receive food assistance when costly housing or childcare expenses consume their income. SNAP allows states to more effectively support low-income working families and promote asset-building among those households. Costs like childcare and housing are not optional expenditures for families, they are critical for economic security and mobility.

Arkansas does not participate in BBCE. It is one of the lowest ranked states in food security, with more than 15.1 percent of households experiencing food insecurity. Our state would have the opportunity to better serve its residents if these federal options remain in place.

BBCE supports families’ ability to work, save, and escape poverty. When children and their families have access to SNAP and school lunch, they are healthier and more economically secure.

As experts in the challenges faced particularly by children in poverty, and the impact of policy in addressing those challenges, Arkansas Advocates for Children and Families opposes the proposed changes to BBCE. We request that the Administration withdraw the proposed rule immediately.