Branch Chief, Certification Policy Branch
Program Development Division
3101 Park Center Drive, Room 812
Alexandria, Virginia 22302
RE: Docket ID: FNS-2017-0011
Request for Information on Supplemental Nutrition Assistance Program (SNAP)
Income Conversion Factors for Anticipated Income
Dear Chief Gersten-Paal:
I write on behalf of Empire Justice Center, a statewide, multi-issue, multi-strategy public interest law firm focused on changing the systems in which poor and low income New York State families live.
We appreciate the opportunity to comment in response to the Request for Information: Supplemental Nutrition Assistance Program (SNAP) Income Conversion Factors for Anticipated Income, published in the Federal Register on March 15, 2017. In response to concerns by the U.S. Department of Agriculture’s (USDA) Office of the Inspector General, the Food and Nutrition Service (FNS) has solicited views on changes to income conversion factors. Specifically, this includes proposals to: (1) change the current factors used to convert weekly and biweekly income to anticipated monthly income from 4.3 to 4.33 and from 2.15 to 2.17, respectively; and (2) eliminate states’ ability to conform SNAP with its Temporary Assistance for Needy Family (TANF) income conversion methodology.
The Empire Justice Center opposes any change in regulation that would either restrict the specific income conversion factors or curtail state options by establishing a single conversion methodology.
Under current regulation, state agencies have several options for converting weekly and biweekly income into anticipated monthly income for the purposes of determining a household’s SNAP eligibility and benefit level. For cases in which a household’s exact monthly income cannot be anticipated, a state may calculate anticipated monthly income by using its public assistance (PA) conversion standard or by multiplying weekly income by 4.3 or biweekly income by 2.15 (specific conversion factors). The current standards permit states to select the most efficient methodology to help simplify procedures for state eligibility workers and limit barriers to participation for families in need.
The current standards have been in place for approximately 40 years. A change to current rules would put a greater administrative burden on state agencies, and create unnecessary confusion for SNAP beneficiaries and applicants, including a decrease in benefits for some.
New York already uses its public assistance conversion factors of 4.333 for weekly income and 2.1666 for biweekly income in its SNAP program. A shift in income conversion standards will increase state agency costs, and county workload in our county administered benefits system. The current standards minimize administrative burden by permitting a single shared income projection calculation between TANF and SNAP, while ensuring adequate access to needy households. The implementation of new standards would require states to change systems and procedures for SNAP cases, including re-training eligibility workers, educating SNAP participants and applicants, adjusting eligibility systems accordingly, and issuing mass re-budget notices to hundreds of thousands of New York households receiving SNAP. This will divert resources and energy from more important efforts to reduce food insecurity, including work to increase SNAP participation among eligible individuals not currently enrolled in the program. In addition, changing the conversion standards that have been in place for so long would inevitably result in increased error rates as states work to re-educate front line providers.
Furthermore, a change in the rules on income conversion would not only create unnecessary confusion for eligibility workers but also for SNAP participants and applicants. Some current participants would experience a downward adjustment in their already modest SNAP benefits. There is no strong rationale for a change to a 40-year-old policy that would trim benefits for families already struggling to put food on the table. Additionally, Empire Justice is deeply concerned that the changes to the SNAP income conversion factors could cause reductions in non-SNAP benefits should the state adopt a modified SNAP income conversion factor into other programs like public assistance, which is issued through the same, arcane computer system.
We oppose a change to the existing options for converting weekly and bi-weekly income into monthly income for the purposes of SNAP eligibility and benefit determination, including any alteration to the specific conversion factors. These long-standing options have allowed states to implement simplified income determination procedures. Imposing new standards would unduly burden state agencies, strip flexibility that permits program efficiency, introduce a potential source of error to the process, and create additional hurdles for SNAP participants, to obtain only modest savings in a large state like New York.
Thank you again for the opportunity to comment on these proposed changes, and for your careful consideration of these comments.
For more information, please contact:
Empire Justice Center
119 Washington Avenue
Albany, NY 12210