LIVEON NY PUBLIC COMMENT OPPOSING RECENT SNAP PROPOSAL, WHICH WOULD END OR DECREASE BENEFITS FOR MILLIONS OF SENIORS
The following comments were submitted to The Food and Nutrition Service (FNS) on Monday, December 2, 2019. 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). This proposed rule on Standardization of State Heating and Cooling Standard Utility Allowance would cut nearly $4.5 billion in benefits over five years, causing 19 percent of SNAP households to get lower SNAP monthly benefits, and would disproportionately impact older adults and individuals with disabilities.
LiveOn NY respectfully expresses our strong opposition to the proposed rule on the Standardization of State Heating and Cooling Standard Utility Allowances (SUA). 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, through 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. However, if this proposal passes, this would mean a reduction of $4.5 billion over 5 years in benefits. Seniors and the disabled will particularly bear the brunt of this proposal, especially those who are low income and reside in communities of color. This proposal to standardize SUA will have dire consequences for many of our clients, particularly homeowners, a population that skews older, and tenants who pay utilities separate from their mortgage or rent. It is estimated that an overall 19 percent of current recipients would see their monthly SNAP benefits decrease, making it harder to afford sustenance. For some of our clients in particular, their SNAP benefits would diminish considerably—as much as $40 to $50 per month on average. Even worse, some of our clients would no longer be eligible to receive SNAP at all.
One of LiveOn NY’s current clients receives the minimum SNAP amount of $16 per month even with the highest SUA level. Prior to the passing of his wife, he was receiving $194; but this amount was lowered to $16 after the rent reduction he received from his SCRIE redetermination. Our client is a diabetic who cannot afford the proper dosage of his medication because of the high out of pocket cost. To make his medication last longer, he splits his pills and uses his daughter’s extra blood glucose test strips. If this Standardization of State Heating and Cooling Standard Utility Allowances (SUA) passes, our client would be at risk of no longer receiving SNAP benefits. The struggles faced by our client is just one illustration of a problem plaguing countless older adults, who find themselves having to choose between food, medicine, and housing.
The SUA calculations are also tied to the eligibility for the Home Energy Assistance Program (HEAP), which helps defray the cost of heating in the winter. Standardizing SUA could have the unintended effect of making it even more difficult for older adults to pay their utility bills, because these same seniors who become ineligible for SNAP would also become ineligible for HEAP.
“It is impossible to say that older adults in our nation have the opportunity to live with dignity and respect when so many would be at risk of going hungry due to this proposed rule.”
Moreover, the proposal to cut SUA would only put even more older adults at risk of food insecurity, which could have severe repercussions to their health, such as contributing to an increased risk of falls, which can lead to significant health care complications and costs. In the case of our client mentioned above, the stress and the lack of funds for medication could aggravate pre-existing chronic conditions, and therefore be responsible for worsening health outcomes. These cuts would also negatively affect the bottom line of local businesses and farmers from whom SNAP recipients purchase their fresh foods. Therefore, this proposal will not only be economically detrimental to older adults, but for the community at large.
At LiveOn NY, we believe that older adults should have the opportunity to age in place with dignity and respect. Every city and town in America should allow for older adults to thrive given all that they have contributed and continue to contribute to their communities. The SNAP program is a core safety net that ensures that. It is impossible to say that older adults in our nation have the opportunity to live with dignity and respect when so many would be at risk of going hungry due to this proposed rule.
As a result of our forty years of experience working with older New Yorkers, we believe that this proposal will harm, instead of help, older Americans. We urge the Federal government to withdraw this proposal in its entirety. 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.