New SNAP Proposal Would Exacerbate the Cliff Effect and Hunger for Kids

In July 2019, the United States Department of Agriculture (USDA) proposed yet another rule that puts the health and economic security of 1.5 million Georgians at risk. The proposal seeks to end “broad-based categorical eligibility” for the Supplemental Nutrition Assistance Program (SNAP).

The proposed rule would require Georgia to use the SNAP asset and income tests to determine eligibility. Georgia currently forgoes these tests in order to serve more working households that receive help from Temporary Assistance for Needy Families (TANF), are attempting to build savings or have significant housing or child care costs. If the rule were to go into effect, nearly all of Georgia’s SNAP households would be impacted and Georgia would have to develop a new and potentially costly way to determine and redetermine eligibility for SNAP households.

This change is particularly concerning given Georgia’s governor has requested agency budget cuts beginning in the 2020 fiscal year (which began in July 2019 and ends in June 2020) and continuing to the next fiscal year. These cuts will impact capacity at the Department of Human Services, which oversees SNAP administration. In response to the governor’s order to cut the state budget, the Department—a process that would be made more complicated by this federal proposal.

The Benefits Cliff

Categorical eligibility is a policy that allows Georgia to raise income cutoffs by aligning SNAP’s income limit to that of a household’s Temporary Assistance for Needy Families-funded benefit. This option is widely used to prevent an abrupt end to benefits for households close to SNAP’s federal income thresholds. The benefits cliff is an issue that is taken seriously here in Georgia, and leaders are actively working to find solutions. In 2018, Georgia’s state lawmakers identified the benefits cliff as a key problem in the report to the legislature developed by the Georgia House Rural Development Council. This proposed rule would significantly undermine legislative efforts to help more families, particularly those in rural.

School Meals                             

The proposed rule could also have a negative impact on the ability of high-needs schools to offer free and reduced-price meals to all students. USDA’s community eligibility rule uses the number of children directly certified for free school meals to determine if a school is eligible to implement the provision and to set the federal funding for school breakfast and lunch that a school will receive. Many children are certified due to their participation in SNAP. This proposal could mean that some schools that serve high numbers of students in families that receive SNAP may no longer be eligible. The Regulatory Impact Analysis of the proposed rule failed to determine the potential impact on community eligibility.


SNAP is a vital source of assistance that helps put food on the table for 1.5 million Georgians. It is also an economic benefit to communities throughout the state, pumping $2.3 billion into the Georgia economy during the 2018 federal fiscal year. But the USDA’s proposal to eliminate the state’s use of categorical eligibility puts at risk those who use food assistance to get back on the path to economic security. The Georgia Food Bank Association estimates that about 16 percent of the state’s households struggle to afford enough nutritious food. Georgia ranks seventh nationally for food insecurity.

In addition, this USDA rule would sidestep Congress. Federal lawmakers have repeatedly rejected efforts to gut the categorical eligibility option, including as recently as the bipartisan 2018 Farm Bill enacted last December. USDA should be strengthening the positive impacts of SNAP for health, well-being and economic activity, not eliminating eligibility for people who need assistance.

The proposed rule is subject to a comment period that ends on September 23, 2019. GBPI opposes the rule and encourages advocates to submit comments against it.

The Food Research and Action Center (FRAC) is leading a comment campaign encouraging organizations and individuals to write in opposition to the proposal. Advocates can access FRAC’s comment campaign here. You can also submit comments directly through the Federal Register. Click here to access GBPI’s submitted comments.

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