The comment period for this request for comments on the proposal to change the inflation adjustment for the Official Poverty Measure has now ended. Thank you to everyone who took action and submitted a comment.

A link to CHN’s comment on this proposal is here. 

Every year, eligibility for programs including Medicaid, Affordable Care Act insurance premium subsidies, SNAP and school meals, and home heating and cooling assistance is determined relative to the federal poverty line. That measure is adjusted annually for inflation. The Trump Administration’s Office of Management and Budget (OMB) is now considering changes to the ways inflation is calculated. They appear to be supportive of an inflation measure that would increase more slowly over time. If implemented, fewer people would be eligible for assistance, because their incomes would be higher than the allowable guidelines. Over time, millions of people would be affected, including children, seniors, people with disabilities, and others who are poor or near poor.

This request for comments is not part of an official rule-making proposal, so the required steps in taking public comments into account are not the same, and it is not clear how bound OMB will be to respond to the comments. However, it is quite important that diverse comments are part of the public record. Comments can achieve these ends:

• Publicize the impact on people: loss of health, nutrition or other assistance. Comments can show who would be denied assistance, such as children, minorities, seniors, or people with disabilities.
• Question the validity of proposed changes to the inflation index: The Trump Administration has highlighted a specific alternative inflation adjustment, called the Chained Consumer Price Index for Urban Consumers (C-CPI-U). It rises about three-quarters of a percentage point more slowly than the measure now used to adjust the annual poverty measure. You’ll see more details about this below, but research has indicated that the Chained CPI may not be valid for people who are poor or near-poor.
• Point out that any attempt to measure poverty accurately needs far more than a change in the inflation adjustment; it should take into account current estimates of income and expenditures. It should also take into account the evidence that people with incomes now defined as above the poverty threshold suffer considerable hardship (food insecurity, little or no savings, falling behind in rent or other bills, etc.)
• Raise questions that can be influential either with important policy-makers or with courts: Key members of Congress may weigh in with the Trump Administration to persuade them of the harm of such a change or work to prevent it via legislation. If there is litigation around changing the inflation adjustment, comments may guide court decisions.

Programs that would be affected by shrinking the poverty measure include, in part:

Medicaid; Medicare; subsidized prescription drug coverage; CHIP; Community Health Centers; Migrant Health Centers; AIDS Drug Assistance Program; Health professions student loans and scholarship; Family planning services; Community Services Block Grant; Head Start; Preschool Development Grants; LIHEAP; Job Opportunities for Low-Income Individuals; SNAP; WIC; School meals programs (free and reduced price breakfast, lunch); Child and Adult Care Food Program (free and reduced price meals); Weatherization Assistance; Job Corps; National Farmworker Jobs Program; Senior Community Service Employment Program; WIOA Youth Training; Low-Income Taxpayer Clinics (Dept. of Treasury); Foster Grandparent and Senior Companion Programs, Corp, for National and Community Service; and the Legal Services Corporation.

If you/your organization work with any of these programs, or work with people who utilize them, you can make important comments about how these programs benefit people and the danger of gradually reducing the number of needy people who would qualify for them. It is not necessary to estimate how many people would lose assistance in order to make these comments.

(Note: Many means-tested programs do not establish eligibility by a comparison to the poverty measure. They may calculate based on area or state median income or to a fixed benefit level. That is why housing assistance, Supplemental Security Income, child care, the Earned Income Tax Credit and refundable Child Tax Credit would not be affected by this proposed change. Some programs, such as Temporary Assistance for Needy Families (TANF), have eligibility set by states.)

Comment portals and sample comments:

The comment period for this proposal has now ended. CHN created a range of portals and comment guides to facilitate sending effective comments to OMB on this proposed change.

• A comment portal for the general public.
• A comment portal for organizations and experts.
  • A general comment guide is located here.
  • The following is a list of comment guides by specific issue area:
    • Children
    • Disabilities
    • Domestic Violence
    • Health
    • Nutrition (SNAP, school meals)
    • Service Providers
    • Women’s issues
  • Another sample comment, by the Center on Budget and Policy Priorities, is located here.
  • A draft comment by the National Women’s Law Center is located here. The Center encourages you to pick and choose draft language for your comment from this draft.

More Resources:

• A captioned recording of a webinar CHN cosponsored with the Center on Budget and Policy Priorities, “The Latest Plan to Deny Assistance: Shrinking the Poverty Line” is available at this link here.
• Center on Budget and Policy Priorities:
  • The CBPP’s comment to the Office of Management and Budget

  • Administration’s Poverty Line Proposal Would Cut Health, Food Assistance for Millions Over Time

  • Reducing Cost-of-Living Adjustment Would Make Poverty Line a Less Accurate Measure of Basic Needs

  • Poverty Line Proposal Would Cut Medicaid, Medicare, and Premium Tax Credits, Causing Millions to Lose or See Reduced Benefits Over Time

  • Trump Administration Floating Changes to Poverty Measure That Would Reduce or Eliminate Assistance to Millions of Lower-Income Americans

• On The Economy: Jared Bernstein Blog
  • The Trump administration’s proposed “update” to the poverty threshold is a wolf in sheep’s clothing
• Center for American Progress:

  • Trump’s Plan to Lower Poverty by Redefining It, Explained

• National Women’s Law Center:
  • Twitter thread by Melissa Boteach, VP of Income Security, Child Care, and Early Learning

  • Redefining Poverty Doesn’t Put Food on the Table or Pay for Critical Health Care

• Georgetown University Health Policy Institute Center for Children and Families:

  • Trump Administration Proposes to Make Many Fewer Low-Income Individuals and Families Eligible for Medicaid and CHIP Over Time

• The Urban Institute
  • Proposed Changes to the Poverty Line Would Reduce SNAP Participation Over Time
• In the Media:
  • CNN article with quotes from CBPP, American Action Forum, and NWLC
  • New York Times article with quotes from CBPP
  • Washington Post article with quotes from CAP and Economic Policy Institute,
  • Newsweek article with quotes from the Economic Policy Institute, NWLC, and the National Organization for Women
  • Bustle article with quotes from the American Action Forum, NWLC, and CAP
  • Philadelphia Inquirer article: Trump administration mulling change to how poverty is calculated, possibly cutting aid for those in need
• A letter from Senate Democrats to President Trump, led by Senator Robert Casey, is available here. This letter calls on the OMB to continue respecting the poverty guidelines used by Congress to enact eligibility standards based on HHS guidelines.
• Further resources for writing comments:
  • Alternative measures of poverty
    • United Way of Northern New Jersey: The ALICE Threshold (Asset Limited, Income Constrained, Employed)
    • The Center for Women’s Welfare (CWW): The Self-Sufficiency Standard
  • NEADA: LIHEAP Selected Recipient and Eligibility Data (FY 2017) and Allocations Data (FY 2019), by state