On May 6th, the U.S. Office of Management and Budget (OMB) issued a request for comments on changing how poverty is measured in the United States.
The proposed change would lower the already low income-eligibility cutoffs for federal assistance programs such as Medicaid, the Children’s Health Insurance Program, and SNAP, reducing or eliminating assistance for many individuals and families.
This means many low-income New Yorkers would no longer qualify to participate in these essential public assistance programs.
Poverty guidelines help determine eligibility for many safety-net programs and are currently adjusted each year for inflation. The Trump Administration is proposing to use a different way to calculate inflation that would result in fewer and fewer people qualifying for benefits, even though their financial situation hasn’t improved. The Trump Administration claims that this new method would be more accurate, but we know that the current method for measuring poverty already underestimates what is needed to support a family.
The impact of this proposal would be small at first, but would grow each year, affecting a wide range of federal assistance programs.
The Center on Budget and Policy Priorities (CBPP) estimates that within 10 years of the policy’s implementation, in the U.S. more than 300,000 children would lose comprehensive coverage through Medicaid or CHIP, millions of ACA marketplace consumers would receive lower premium tax credits, and significant numbers of low-income households would lose eligibility for federal nutrition assistance programs like SNAP, WIC, and free school meals. Other essential programs like Head Start, family planning assistance, and legal services for the poor would also be impacted.
Go here to submit comments to OMB to stop this latest plan to deny assistance.
How to frame your comments on proposed federal poverty line changes.
Please note the framing recommendation below from the Coalition on Human Needs: The framing of these comments is important.
OMB’s notice specifies that it is not seeking comment on how its proposal would affect the poverty guidelines that HHS develops and that govern the eligibility limits in programs like Medicaid. This shows that the agency is considering making a change that would affect millions of people without even considering those effects. So instead of giving OMB the comments it directly said it doesn’t want, we have framed this comment in a way that addresses OMB’s request that comments not discuss how the proposal would affect eligibility limits in programs: “Because you said you were not seeking comment on the impact of changing the HHS poverty guidelines, we are not commenting on that issue. However, were you to consider moving forward with a change to the thresholds that affects the guidelines, it would be imperative to first undertake in-depth research and analysis, and solicit public comments, regarding …” We strongly suggest your comment stick to this framing.
Important Issues to emphasize in your comments:
- Include background on who you are and why you are commenting. Your expertise and experiences are important, particularly if you are someone who would be directly affected by a rule change or work with those who would.
- Directly address the OMB’s claim that the current Federal Poverty Level accurately measures poverty, and that the measure should grow more slowly than it currently does. See CCC’s infographic that discusses how the current Federal income guidelines already underestimate what is needed to support a family. Shrinking the Federal poverty line will redefine many low-income people as nonpoor, denying them badly-needed assistance.
- Urge OMB to do extensive research and analysis before making any change to the poverty income threshold. Issues that OMB should consider include: How many individuals would lose assistance over time; The demographic profile of those who would lose assistance; How service providers will be affected; How the impacts would change over time; Any other impacts you expect to see among the communities and families you serve.
- The OMB is considering making this dramatic change without researching its impact first. Your comments should underscore that you expect these rules to have major repercussions, and should call on the federal government to do the necessary analysis and research before undertaking any changes.
- Address the programs or communities that matter the most to you. Below are templates and resources that you can use for your comments: