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Proposed SNAP Changes Will Increase Hunger for Nearly 40,000 Arizonans

On July 24, 2019, the US Department of Agriculture published a proposal to change eligibility criteria for the Supplemental Nutrition Assistance Program (SNAP, formerly “food stamps”). These changes would effectively eliminate food assistance for an estimated 40,000 Arizonans, including more than 12,000 working families (roughly 32,000 people, more than 50 percent of them children) and nearly 7,000 seniors and people with disabilities in Arizona.  The Association of Arizona Food Banks (AAFB) strongly opposes this proposed rule, which would increase food insecurity for Arizonans struggling with hunger, impact grocers and overwhelm local food banks with increased demand.

In Arizona, nearly 1 in 6 individuals and more than 1 in 4 children struggle with food insecurity. AAFB and its five member food banks--Community Food Bank of Southern Arizona, HonorHealth Desert Mission Food Bank, St. Mary's Food Bank Alliance, United Food Bank, and Yuma Community Food Bank--served an average of 450,000 Arizonans in need each month in 2018, including children and seniors. In collaboration with our members and nearly 1,000 partner organizations across the state, we distributed more than 175 million pounds of food statewide, or roughly 145 million meals.  For every meal our emergency food network provides, however, SNAP can provide up to 12. In 2018, SNAP helped an average of 850,000 Arizonans access food each month, and 50 percent of them were children.  SNAP is critical to making sure Arizonans have access to healthy foods that allow them to work and play.

Current Eligibility Criteria & Proposed Changes: Currently, states have the option to provide SNAP to households that receive benefits under the Temporary Assistance for Needy Families (TANF) program under the “broad-based categorical eligibility” provision (BBCE). Along with more than 40 other states over the past two decades, Arizona has chosen to implement this option, thereby allowing additional low-income working families, seniors, and people with disabilities to qualify for SNAP. In Arizona, this means that households with a gross income level of 185 percent of the federal poverty line—roughly $39,000/year for a family of three—instead of capping the gross income threshold at 130 percent of the federal poverty line—roughly $27,000/year for a family of three. Low-income families often struggle to make ends meet because housing and childcare expenses take up a large share of their income. BBCE allows people to make ends meet, with SNAP benefits tapering off gradually as household incomes improve, thereby rewarding work without a harsh cutoff. BBCE also allows states to impose less restrictive asset tests for SNAP participants; by waiving the asset limit, families, seniors, and people with a disability can accumulate modest savings for use in emergencies while continuing to afford groceries.
 In the proposed rule, the USDA aims to restrict SNAP access through BBCE to include only those households receiving TANF benefits that are (a) ongoing and substantial cash assistance  or (b) non-cash benefits that focus on employment and childcare.  Because children in SNAP households are automatically eligible for free school meals through the National School Lunch Program, the proposed rule will also eliminate access to nutritious school meals for thousands of Arizona schoolchildren.

AAFB Position on Proposed Rules: The Association of Arizona Food Banks (AAFB) opposes the changes proposed by the USDA in the proposed rule "Revision of Categorical Eligibility in SNAP Regulatory Impact Analysis" on July 24, 2019, because the proposed changes would eliminate access to critical food assistance for up to 40,000 Arizonans. SNAP is a lifeline for working families, seniors, people with disabilities, and other individuals struggling to make ends meet.

By its own estimates, the USDA states that its proposed changes could result in increased food insecurity, especially for seniors. We find this unacceptable. SNAP participation among eligible seniors is already low in Arizona; we should be providing more nutritional support to older adults—who often suffer from dietary diseases like diabetes and hypertension—not less.

The proposed SNAP eligibility changes would also take free school meals away from thousands of children across Arizona whose enrollment is linked to their families’ SNAP participation. Increasing access to school meals has been proven to reduce childhood food insecurity and improve children’s health and academic performance.  Instead, this proposal goes in the opposite direction by restricting children’s access to nutritious school meals and jeopardizing health outcomes.

To see this statement with citations and endnotes, download the PDF here.

Resources: To read the USDA's official proposed rules, visit FNS-2018-0037. To submit a comment by the deadline of 11:59pm (Eastern Time) on September 23, 2019, click SUBMIT A FORMAL COMMENT. AAFB will be submitting formal comments and sharing templates for Arizona-focused comments with our network and partners, so please stay tuned.

Questions? Please contact Ashley St. Thomas at ashley@azfoodbanks.org or 602-775-5035.