Comment period to oppose another harmful rule extended to Nov. 1

Written by: Stephanie Perez-Carrillo
Date Posted: October 25, 2019

The U.S. Department of Agriculture (USDA) has extended the comment period to oppose a rule that could hurt 90,000 Coloradans annually, including families with kids, who use the Supplemental Nutrition Assistance Program (SNAP) to help put food on the table. The comment period was extended because the USDA discovered that they had dramatically underestimated the number of children who could be harmed by the rule change. Their new estimate doubled the number of kids who could be impacted, showing that nearly one million kids could lose access to free school lunches under the change, requiring the agency to extend the comment period.

The rule, announced over the summer, will make it harder for states to automatically enroll people who qualify for certain other benefits, such as TANF, into SNAP. This automatic enrollment, a policy known as broad-based categorical eligibility (BBCE), allows state to enroll individuals into SNAP based on eligibility for other programs, even if they would otherwise be ineligible because they earn too much income to qualify under federal guidelines.

BBCE is especially important for children in households that receive SNAP, because they are automatically eligible for free school meals without having to complete a separate application, a process known as direct certification. Without BBCE, children whose families lose SNAP when their incomes rise above the program threshold would also lose this automatic link to free school meals.

We know that BBCE is highly effective because it supports working families and  mitigates the impacts of the cliff effect – when families make just too much to qualify for programs, allowing low-income households prepare for the future. The BBCE process also simplifies SNAP administration and reduces the complexity of the SNAP application process for states and households that qualify.

Join us in opposing this harmful proposed rule!


The federal government is required to review public comments. Please post a comment to voice your opposition. We ask that you modify the language in the template comment to reflect your own thoughts, because the federal government only needs to respond to unique comments.

The administration has extended the comment period to November 1. Here is how you can speak up for children and families:

Step 1: Use the template comments available here to create your comments.

Step 2: Click here to submit your comments.

Step 3: Enter your information and complete the form, then click “Submit Comment.”

Spread the word on social media — Use these hashtags #HandsOffSNAP and #ProtectSNAP on social media.

Read more about the proposed rule from our national partners at the Food Research Action Center (FRAC)

If you have any questions about this issue or would like support in submitting comments, reach out to Stephanie Perez-Carrillo at


Stephanie Perez-Carrillo

About Stephanie Perez-Carrillo

Stephanie works as a Policy Analyst for the Colorado Children’s Campaign. Prior to joining the Children’s Campaign, she worked as a Public Policy Fellow at The Women’s Foundation of Colorado – where she found her love and passion for policy work. Before diving into the policy world, Stephanie served as a Teach for America Corps Member in South Carolina, teaching high school and middle school math. Early on while obtaining her degree in Marketing from Florida International University, she worked in health care as a Patient Advocate and Unit Secretary. When she is not working, you can typically find her at a coffee shop, hanging out with friends, or engaging in some type of outdoor activity.