Comment Opposing the Proposed Changes to Supplemental Nutrition Assistance Program: Importance of Public Benefits

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April 3, 2019

On Tuesday, April 2, 2019, Legal Momentum submitted written comments opposing the Department of Agriculture’s proposed regulations, which seek to limit eligibility for the Supplemental Nutrition Assistance Program (SNAP) in light of decreasing unemployment rates.

Public benefits provide a vital lifeline for low-income women and survivors of gender-based violence. Advocating on behalf women nationwide, Legal Momentum’s comments sought to highlight the problematic nature of the Department’s narrow focus on declining unemployment rates:

“The problem with the Department’s current analysis is that it assesses self-sufficiency based solely on the unemployment rate while disregarding the myriad factors, including depressed wages; sky-rocketing housing costs; the high cost of education, which leaves many in long-term debt; and systemic and long-term gender and racial discrimination, which have created legitimate barriers to self-sufficiency even for those who are employed full-time.”

Legal Momentum’s testimony sought to shed light on the unique obstacles women face as a result of ongoing gender discrimination.

“Women face a range of obstacles including persistent gender discrimination and lack of various critical supports including education, basic job skills, specialized training to qualify for available jobs, transportation, and support to escape domestic abuse or to address addiction or stabilization needs such as finding safe and stable housing.

The proposed amendments, which would limit critical waivers and exemptions, would simply penalize many women who are seeking employment at a time when they need the benefits the most. As a result, it will have devastating impacts on low-income families, including a disparate impact on low-income women.”

The full testimony is available here for download as a PDF.

  • Workplace Equality and Economic Empowerment


Seher Khawaja
  • Women Valued Initiative



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