The U.S. Department of Agriculture (USDA) is proposing a rule that would require some states to reduce gross income limits for Supplemental Nutrition Assistance Program (SNAP) applicants. It also would force 42 states, including Alabama, to impose resource limits on applicants.
More than 3 million people would become ineligible for food assistance under the rule, federal officials estimate. Alabama Arise originally submitted comments in opposition to this proposal in September 2019. But the USDA later reopened the comment period after calculating that the change would leave more children at risk of losing free school meals than original estimates showed. Arise policy analyst Carol Gundlach submitted the following additional comments in response:
Re: Supplemental Nutrition Assistance Program Notice of Proposed Rulemaking: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP) [FNS–2018–0037]
Dear Program Design Branch:
Thank you for the opportunity to submit additional comments on behalf of Alabama Arise in response to the proposed changes to the categorical eligibility state option in the Supplemental Nutrition Assistance Program (SNAP).
Organizational purpose and interest
Alabama Arise is a nonprofit, nonpartisan coalition of congregations, organizations and individuals promoting public policies to improve the lives of Alabamians with low incomes. Arise believes acts of charity are vital, but they are not enough. We also must work to improve harmful policies. Arise provides a structure through which Alabamians can engage in public debates with the goal of improving the welfare of all Alabamians.
Arise envisions an Alabama where all people have resources and opportunities to reach their potential to live happy, productive lives, and each successive generation is ensured a secure and healthy future. We envision an Alabama where all government leaders are responsive, inclusive and justice-serving, and the people are engaged in the policy-making process. And we envision an Alabama where all people live with concern for the common good and respect for the humanity of every person.
Arise has engaged actively in advocacy to improve access to SNAP since our origin. In recent years, Arise has opposed state legislation restricting Alabama’s use of broad-based categorical eligibility (BBCE) and imposing other restrictions on Alabama’s election of state options.
Arise staff participated in formal and informal discussions and meetings with representatives of the Alabama Department of Human Resources (the state’s SNAP administrating agency), the Alabama Food Bank Association, Legal Services of Alabama and other organizations to improve state-level SNAP policy, staff training, outreach and client notices. Most recently, Arise and the Alabama Food Bank Association have spearheaded the creation of a Hunger Free Alabama advocacy coalition representing more than 20 diverse organizations and agencies.
Alabama has used BBCE to eliminate asset tests for working families
Alabama has elected to eliminate the SNAP asset test for applicants who are categorically eligible because they received a non-cash benefit under the Temporary Assistance for Needy Families program. Without BBCE, Alabama would be forced to reinstate a SNAP asset test.
Asset tests disproportionately affect certain types of households, including working families with small savings accounts or multiple cars. Many families at risk of losing SNAP because they exceed the asset limit will be working families with school-aged children. Because of the interaction between SNAP eligibility and eligibility for free school meals (either through direct certification or through the Community Eligibility option), children in families who lose SNAP assistance are also at risk of losing free school meals.
Restrictions on BBCE would increase child hunger and educational failure
Approximately 12,000 Alabama children live in SNAP households with “excess resources,” despite very low household incomes. Children who live in SNAP households are categorically eligible for free school meals. If these children lose SNAP assistance, they also lose automatic eligibility for school, breakfast, lunch and sometimes dinner.
Children who lose categorical eligibility would have to go through the school’s application process to receive free school meals. Some almost certainly would lose eligibility due to this additional hurdle.
Childhood hunger is strongly associated with negative educational outcomes, multiple studies have found. Hungry children have lower math scores and worse grades than do children who are not at risk of hunger. Hungry children are more likely to be absent from school or tardy. And hungry children are more likely to have to repeat a grade than are children not at risk of hunger. The proposal would create additional barriers for children who are now eligible for free school meals. In doing so, it would increase childhood hunger and fuel lower educational achievement.
Reducing availability of universal free school meals would harm children and schools
Under the Community Eligibility option, schools with more than 40% “identified students” can elect to offer no-cost breakfast, lunch and sometimes dinner to every student in the school. By far the largest category of these “identified students” are children in families who receive SNAP. As in other states, the Alabama Department of Human Resources (the SNAP administrator) routinely sends the Alabama Department of Education a list of children who are members of SNAP households. Officials use this list, along with other data, to determine whether a school can elect Community Eligibility.
A reduction in the number of children receiving SNAP assistance could tip a school below the 40% threshold necessary for the adoption of Community Eligibility. And the loss of Community Eligibility would deny no-cost meals to all children who attend the school.
Undermining Community Eligibility would increase hunger among students
Chuck Marcum, superintendent of Roanoke City Schools in east Alabama, said Community Eligibility is vital to his system’s overall success. “I can’t overstate the importance of the program and what it’s doing for our students,” Marcum told Alabama Daily News. Community Eligibility has been especially helpful at ensuring high school students can eat breakfast, he said. “I couldn’t get them in high school to turn in the forms because they didn’t want other kids to know they were free,” Marcum said. “Now, everyone is free and we’ve removed that stigma.”
Even if a school does not lose the ability to elect Community Eligibility, the reduction in the number of identified students would result in a financial loss. This is because the school’s meal reimbursement rate is based on its percentage of identified students.
The proposed rule certainly would reduce the number of identified students across Alabama. And it could reduce the percentage in some school systems so much that Community Eligibility is no longer an option. A return to the free/reduced/full-cost school meal system would increase schools’ administrative costs. Most troublingly, it would increase hunger among many of the children attending those schools.
For the reasons outlined in our previous comments and those discussed above, Alabama Arise again urges the USDA to withdraw this proposed rule. We urge the agency to work instead to ensure that all children, including those from households with low incomes, continue to have access to the nutrition they need to learn and thrive, both at home and school.
 Alaimo, K., Olson, C. M., & Frongillo, E. A., Jr. (2001). Food Insufficiency and American School-Aged Children’s Cognitive, Academic and Psychosocial Development. Pediatrics, 108(1), 44-53.
Shanafelt, A., Hearst, M. O., Wang, Q., & Nanney, M. S. (2016). Food insecurity and rural adolescent personal health, home, and academic environments. Journal of School Health, 86(6), 472-480.
 Murphy, J. M., Wehler, C. A., Pagano, M. E., Little, M., Kleinman, R. F., & Jellinek, M. S. (1998). Relationship Between Hunger and Psychosocial Functioning in Low-Income American Children. Journal of the American Academy of Child & Adolescent Psychiatry, 37, 163-170.
 Kleinman, R. E., Murphy, J. M., Little, M., Pagano, M., Wehler, C. A., Regal, K., & Jellinek, M. S. (1998). Hunger in Children in the United States: Potential Behavioral and Emotional Correlates. Pediatrics, 101(1), E3.
 Sell, Mary (Oct. 31, 2019). “Change to SNAP would impact some Alabama students’ access to free lunch.” Alabama Daily News. Available at https://www.aldailynews.com/change-to-snap-would-impact-some-alabama-students-access-to-free-lunch.