NLIHC Submits Comment Letter Opposing Proposed Rule Ending Broad-Based Categorical Eligibility for SNAP

NLIHC voiced opposition to a proposed rule published in the Federal Register on July 23 that would end “broad-based categorical eligibility” for the Supplemental Nutrition Assistance Program (SNAP; see Memo, 7/29). If implemented, as many as 3 million low-income people would be kicked off the program, and 500,000 children would no longer qualify for free school meals.

Under current regulatory guidance, states may adopt broad-based categorical eligibility (BBCE) standards to allow SNAP-administering agencies to consider expenses, including rent and utilities, that consume a large share of their income when determining benefit eligibility and amounts. Children in families receiving SNAP benefits automatically qualify for free school lunches, ensuring that children in low-income families can receive nutritious meals throughout the school day.

The proposed rule would end BBCE for SNAP, which would eliminate food assistance for approximately 3 million people and disqualify 500,000 children from receiving free school meals. SNAP plays a critical role in ensuring those most severely impacted by America’s affordable rental housing crisis are food secure. More than 71% of extremely low-income households spend more than half of their incomes on rent and utilities (severely housing cost-burdened), leaving an inadequate amount to sufficiently cover food expenses every month. In fact, severely housing cost-burdened households with children spend 35% less on food per month than low-income households that are not housing-cost burdened.

The Food Research and Action Council (FRAC) is leading a comment campaign encouraging organizations and individuals to write in opposition to the proposal. NLIHC stands united with our partners against the proposed revisions to BBCE for SNAP and urges advocates to submit comments against the proposed rule by September 23.

Read NLIHC’s comment letter at:

Participate in FRAC’s comment campaign at: