If the Trump Administration has its way, 755,000 very poor people could lose SNAP benefits. These are working age people without dependents. Under current law, these individuals are subject to the harsh time limit of only three months of assistance every three years if they cannot document enough work hours. However, states can waive this time limit for the Supplemental Nutrition Assistance Program (SNAP, popularly known as food stamps) if unemployment is high in parts or all of the state. In fact, every state but Delaware has asked for a version of these waivers over the past twenty years.
But the Trump Administration has been fighting to make it harder for states to give struggling workers a break. Congress doesn’t agree: it just passed a farm bill rejecting the harsher time limit and the President signed it. Now the Administration is trying to go around Congress by forcing these rigid time limits through a rule change, circumventing Congress altogether. But they cannot implement their proposed rule without first taking into account the public comments the law requires it to seek.
The Coalition on Human Needs’ members at the Center for American Progress, Feeding America, and FRAC have each created sample comments against this unfair rule change. Your comment, either on behalf of your organization or as an individual, can make a big difference. The government is compelled to take every unique comment under consideration when assessing a rule change like this; the more comments, the more roadblocks to slow or stop harmful changes. (Note: “unique” is understood to mean that about 30 percent of the comment’s text is different from other submissions.) Furthermore, judges deciding cases challenging such rule changes can refer to these comments in their own rulings.
Here’s how to take action:
1. Organizations:
Use FRAC's comment portal here. FRAC also has a helpful template with suggestions for customizing your comments. A basic template is here.
Specific templates for organizations that have a focus on children, health or a faith perspective are on the campaign page: http://bit.ly/SNAPRuleCampaign.
You can also upload or cut and paste your comments into the online submission tool here. Or, if you prefer, you can mail comments to: Certification Policy Branch, Program Development Division, FNS, 3101 Park Center Drive, Alexandria, Virginia 22302.
2. Individuals:
In addition to the organizational comments, it is vital that we generate a significant volume of comments in opposition to the rule. If you don’t represent an organization, you can comment as an individual. Feel free to use any of the options below:
Here is some information about who would be affected that you can use for your comment: https://fns-prod.azureedge.net/sites/default/files/snap/nondisabled-adults.pdf
Or use the Center for American Progress comment platform at handsoffsnap.org
Remember, comments are counted individually. So, please don’t do a sign-on.
