Empire Justice Center is grateful for the addition of Perkins educational programs to the allowable SNAP employment and training offerings.  In New York, this will allow for greater SNAP utilization among households that are working to better themselves and increase their earnings by attending technical education programs at community colleges around the state.  Granting a State agency flexibility in determining which “career and technical education programs” are suitable for SNAP recipients, without requiring those programs to be Perkins-funded, will best meet the varied needs of the communities and the local workforce in different parts of New York.

Further, Empire Justice recognizes the value of setting uniform standards for data used to determine SNAP eligibility and generally supports the proposed regulation concerning data verification as written.  As New York is already using the Systematic Alien Verification for Entitlements (SAVE) database to process SNAP applications, existing state level guidance for the role this data plays in the application process is already available to the social services districts here.  We urge USDA to follow New York’s lead and further clarify that a delay in receipt of data from the SAVE system is no basis for a delay in the need to timely issue SNAP benefits when all other aspects of eligibility have been previously established.

However, there are three specific areas where the proposed regulations require additional clarification from FNS prior to implementation for continued smooth operations in SNAP and to preserve the due process protections.  These are described in detail below.

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