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Social Programs

EPIC Regulatory Comment on the USDA Rule Implementing Fiscal Responsibility Act Changes to the Food Stamp Program

Social Programs Report PublicationJune 17, 2024 By Matthew Dickerson
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The Fiscal Responsibility Act (FRA) of 2023 suspended the statutory debt limit in exchange for spending controls and programmatic reforms. The FRA made several changes to the food stamp program, improving the program by phasing up the age-applicability of work requirements, but also weakening the work requirements by adding new exceptions for veterans, the homeless, and former foster children.

One year later, the USDA is proposing a rule that purports to simply implement provisions of the FRA.

Unfortunately, many provisions of the proposed rule would perpetuate and exacerbate problems with the food stamp program. As described by the American Federation of State, County and Municipal Employees (AFSCME) union, in this proposed rule the USDA’s “general approach is to ensure that as many people are excepted from the time limit for as long as possible.”

Many of the proposals in the USDA’s rule would undermine the newly-added statutory purpose of the food stamp program “to assist low-income adults in obtaining employment and increasing their earnings.”

EPIC submitted a regulatory comment highlighting problems with the proposed rule.

The USDA is using this rule to propose new requirements for States to provide food stamp benefits to individuals who have not been verified as eligible, which violates the law and increases the risk of improper payments.

Even the provisions that should simply implement the FRA includes errors. The rule’s proposed:

    • Definition of the term “homeless individual” does not follow the statute.

    • Definition of the term “veteran” differs from the standard definition used by the Department of Veterans Affairs.

Finally, the proposed rule’s regulatory impact analysis is lackluster, including:

    • An insufficient cost and benefit analysis that disregards the importance of work and work promotion policies, as well as the harms of dependency.

    • A flawed Federalism analysis.

    • An insufficient budgetary impact analysis.

    • A questionable estimate for the number of homeless individuals impacted.

Read the Regulatory Comment

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Author

Matthew D. Dickerson

Matthew D. Dickerson

Director of Budget Policy

Matthew D. Dickerson is Director of Budget Policy at the Economic Policy Innovation Center (EPIC). Dickerson is recognized as an expert on fiscal policy issues, including the budget, appropriations, and entitlement reform. His articles have been featured in the Wall Street Journal , the Miami Herald , National Review , the Sacramento Bee , the Washington Times , the Baltimore Sun , The Hill , the Washington Examiner , and other outlets. Prior to joining EPIC, Dickerson served as Senior Policy Advisor on the staff of the House Budget Committee, where he helped lead development of the fiscal year 2024 budget resolution. He has a dozen years of experience on Capitol Hill, including as a senior staffer with the Republican Study Committee (RSC), the caucus of conservatives in the House of Representatives. Under four different RSC chairmen, Dickerson held senior level roles including Policy Director and Senior Policy Staff. Additionally, he served as Legislative Director and other policy positions for the late Congressman C.W. Bill Young (R-FL), a former Chairman of the powerful House Appropriations Committee. During his tenure at The Heritage Foundation, Dickerson was Director of the Grover M. Hermann Center for the Federal Budget. In this capacity, he oversaw a team of budget analysts and economists researching diverse subjects including spending, entitlements, budget process, tax, labor, pensions, and infrastructure issues. He has also been a Policy Manager at Americans for Prosperity, where he supervised a team of fellows and analysts covering a variety of federal and state policy issues. Dickerson is a graduate of the College of William and Mary in Virginia and holds a Bachelor of Arts in Government and History.

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