December 16, 2005

Secretary of Agriculture Mike Johanns

Farm Bill

1400 Independence Avenue, SW.,

Washington, DC 20250-3355.

<FarmBill@usda.gov>

Re: Recommendations to Improve Nutrition Titles in 2007 Farm Bill
Reauthorization

We're writing to you with our recommendations to improve the nutrition
titles due for reauthorization in the 2007 Farm Bill -- including Food
Stamps, TEFAP, Senior Farmers Market Nutrition Program and Commodity
Supplemental Food Program.

WISCAP is the statewide Association of Wisconsin's Community Action
Agencies. We're responsible for statewide ordering of TEFAP commodities
in Wisconsin. Thirteen of our sixteen member agencies coordinate food
distribution to 228 participating food pantries, meal sites and shelters
in 69 of Wisconsin's 72 counties. [Food pantries in the network
distribute 1.6 million pounds of food each month to 88,000 food insecure
people, and meal sites & shelters in the network serve 84,000 meals each
month.]{.underline}

Our agencies and their partners are seeing more and more food insecure
families every day in our communities! Over the past 5 years the number
of households seeking food assistance at food pantries has increased
45%. This is due to many things, including a sputtering economy, poor
wages, and rising costs for housing, heating and health care. As people
face tighter and tighter budgets they turn more often to food pantries
for partial relief, which as you can imagine, has greatly increased
stress on local providers. Further evidence of rising economic stress
can be seen in our poverty rate, which has increased faster than any
other state in the union.

While we understand the fiscal challenges facing Congress, families
vulnerable to hunger and poverty must have the very highest claim on our
national resources. The recommendations that follow are intended to
improve the capacity of these programs to serve food insecure families.

**Food Stamp Recommendations**

As demand for emergency food assistance has risen throughout the state
compared to 5 years ago, it is absolutely critical that Food Stamps
reach more eligible families and provide greater benefits in a more cost
effectively manner than before. WISCAP estimates that eligible
low-income families lose out on approximately \$100 million annually in
food stamps -- 4 times the value of all the food distributed each year
by all the several hundred TEFAP food pantries in Wisconsin! [Emergency
food providers simply cannot hope to meet the nutritional shortfall that
more and more families experience each month. Food stamps must play a
greater role in hunger prevention in Wisconsin and other states. And it
can if we simplify application and administration, improve benefits, and
expand eligibility.]{.underline} We also must recognize that Food Stamps
are a much more desirable way to provide nutritional support to
low-income families than the physical delivery of food. Food stamps get
families into grocery stores rather than into food pantries, are more
efficient (since money is distributed, not food), provide greater
choice, offer full client control, improve access to foods that meet
special dietary and cultural requirements, and are inherently a more
dignified way to obtain food. Food pantries should only be relied on for
families that face short-term emergencies - not expected to provide a
regular supplement to household food budgets.

**WISCAP supports APHSA's recommendations**. With one exception (noted
in the text) WISCAP supports APHSA's food stamp recommendations.
Especially important are efforts to simplify administration, to provide
provisional food stamps at food pantries, to establish a single, higher
gross income limit. USDA's own research shows nearly half of all food
insecure households have income above 130% of poverty -- which makes
them financially ineligible for food stamps in most states! WISCAP also
supports APHSA's call to raise the minimum household allotment for
elderly & disabled households to \$50 since these households have a
limited ability to increase their income through increased work. Many
SSI households receive only \$10/month, an absurdly small amount.

**Increase minimum benefit to \$30/month for ALL households.** The \$10
minimum has been in effect at least since the 1977 Food Stamp Act
(according to Art Foley, USDA). In 1977 \$10 bought significantly more
food, but is now an absurdly small amount due to inflation. USDA market
basket data
(<http://www.ers.usda.gov/Briefing/FoodPriceSpreads/basket/table1.htm>)
shows the retail price of the USDA's fixed market basket has increased
268% from 1977 to 2001 (the most recent year of data). This means in
1977 the \$10 minimum bought over 2.5 times more food than in 2001[^1].
Extrapolating further WISCAP estimates the 2005 market basket price is
now \$193 - or 292% more than in 1977[^2]. By the time the 2007 Farm
Bill is enacted the market basket price will have increased over 300%
compared to 30 years ago. WISCAP urges a minimum benefit of \$30 for ALL
households indexed to the rising annual price of the USDA market basket.
If enacted it would bring more nutrition dollars to food insecure
households and would stimulate greater enrollment by all eligible
sectors. In addition, considering that the administrative
cost-to-benefit ratio is very high in the food stamp program[^3], states
are actually spending 3 to 4 times the value of the minimum benefit each
month simply to deliver it.

**Increase overall benefit levels.** The Thrifty Food Plan is the basis
for determining the maximum food stamp benefit and was last revised in
1999. USDA data published in "*Household Food Security in the U.S.
2004*" (table 12) documents that families with income below 130% poverty
AND who received food stamps in the previous 30 days still had median
weekly food expenditures that were only 89% of the Thrifty Food Plan. So
even after incorporating food stamp benefits into household food budgets
families still had insufficient purchasing power to obtain the USDA's
most economical food plan (which is already 25% less than the national
average for what households spend on food). Furthermore, half of the
people who received food stamps in the previous month reported they were
food insecure (49%) and one third of these reported experiencing hunger
(table 11).

**Food Stamp deductibles must be revised & expanded.** APHSA notes that
the 2002 Farm Bill "has never allowed for the amount of a low-income
family's budget that is truly available for food". To correct this means
deductibles must be synchronized better to the fiscal realities of
low-income families.

-   **Vehicle costs**. The costs of owning and operating vehicles are an
    increasingly large component of household budgets -- especially in
    rural areas. This is mainly due to the increasing purchase price of
    vehicles and high gasoline costs, but is also affected by insurance
    and repair costs. Persons in urban areas without cars incur public
    transportation costs. Since transportation is fundamental to finding
    and maintaining employment, Food Stamps should have a standard
    transportation deductible for vehicle ownership and a different one
    for utilization of public transportation.

-   **Telephone costs**. The true costs of telephone service should
    include some long-distance costs - especially in rural areas where
    even calls to nearby localities, including social service offices,
    can be long-distance. In addition more households use cell phones in
    place of landlines. Cell phone customers without landlines should
    qualify for the TUA deduction if they currently do not.

-   **Child care costs.** The child care deductions (\$200 and \$175)
    have been fixed for many years. This should be adjusted to reflect
    real increases in child care costs. USDA should develop more
    reasonable estimates for the amount families are paying
    out-of-pocket for child care. This deduction (like vehicle use) is
    central to supporting employment and must be more realistic.

-   **Eliminate the shelter cap & the medical cap for non-elderly,
    non-disabled households.** Shelter and medical caps distort and
    artificially limit the true impact of the rising costs of housing,
    utilities, prescription drugs and medical bills on available income.
    As costs rise faster than caps, more and more working households
    have relevant expenses that are not fully counted - even though
    these bills directly reduce spendable income. These caps should be
    eliminated for working families. The result is that families with
    very high costs in these areas and less spendable income will get
    higher benefits.

-   **Allow an opt-out provision if the medical deduction is
    standardized.** APHSA recommends creating a standardized medical
    deduction. WISCAP agrees this would simplify administration and
    reduce potential errors and increase benefits for those who
    under-report allowable medical bills. But it would also hurt
    households with exceptionally large medical bills whose available
    income is seriously limited. WISCAP urges inclusion of an opt-out
    provision so persons with extraordinary medical bills can use their
    actual medical costs to determine their deductible amount.

**Strong support for categorical eligibility.** WISCAP strongly supports
continuation of the "categorical eligibility" provision. In Wisconsin
the provision has reduced reporting, documentation and verification for
ALL households, which partially offsets the higher cost of providing
benefits to some food insecure households whose income is above 130% of
poverty. As already noted, the USDA's report *Household Food Security in
the U.S.2004* found nearly half of all food insecure households in the
U.S. are ABOVE 130% of poverty. This is powerful justification for
strategies that extend eligibility to these families.

**Eliminate asset test.** Wisconsin DHFS data has confirmed that Food
Stamp households have extraordinarily small amounts of assets -- far
below the \$2,000 threshold. Eliminating the asset test would simplify
application and administration and save money without jeopardizing
program integrity.

**Establish a pilot to allow CBOs access to household records to
facilitate client enrollment in other self-sufficiency programs.**
Community Action Agencies and other CBOs could more effectively enroll
food stamp households into other key self-sufficiency programs if they
had "read only" access to Food Stamp household data. Federal rules only
allow agencies that directly administer Food Stamps to access client
records. However, if clients authorized limited CBO access to their
personal records, it would facilitate applications for housing, energy
assistance, transportation and asset building programs. Data sharing
would save time, simplify administration, reduce redundancy, improve
efficiency and lessen client inconvenience. Facilitated enrollment would
also improve household food security since it is well-established that
non-nutrition benefits reduce hunger by leaving more money in the
household budget for food. Food Stamp reauthorization should allow
states to carefully examine ways to appropriately and securely remove
barriers between programs and support more holistic approaches to the
provision of services. Reauthorization should give USDA authority to
establish a pilot program to test the feasibility and methodology of
regulated CBO access to client records with client permission.

**Anti-Obesity Initiatives.** Reauthorization should include funding to
test state strategies to reduce obesity. This should include a pilot to
test the feasibility of providing paper farmers market food stamp
vouchers during the summer. Similar programs for WIC and for seniors are
enormously popular with both families and farmers. If the benefits are
targeted to families with school-age children, it would provide greater
nutritional benefits to the huge majority of low-income children who
receive neither school meals nor Summer Food during the summer, while
simultaneously encouraging greater consumption of fresh fruits and
vegetables.

**TEFAP Recommendations**

**Increase funding for entitlement food.** Since 2001 there has been a
47% increase in the annual number household visits to the 220 Wisconsin
food pantries that distribute federal commodities (TEFAP) - from 364,000
visits to 536,000 visits. During this period the total TEFAP pounds
distributed in Wisconsin has dropped 8% -- from 9.491 million pounds to
8.693 million pounds. Providing more households with less food has
increased the strain on emergency food providers. WISCAP also recently
confirmed a 17% increase in the cost of 45 Entitlement commodity items
between 2001 and 2005. These price increases further erode the
purchasing power of our limited Entitlement dollars and exacerbate food
shortages. Congress should increase TEFAP Entitlement food purchase
funds by at least 30%.

**Increase funding for TEFAP administrative costs.** As storage and
delivery costs rise -- especially fuel -- there is greater financial
strain on emergency food providers (EFOs). Although Congress allows
states to transfer a portion of Entitlement food purchase dollars to
TEFAP administration, ultimately this robs Peter to pay Paul. Congress
should increase TEFAP Administrative dollars 25% to \$50 million
nationally and index funds for inflation.

**Senior Farmers Market Nutrition Program Recommendations**

**Provide administrative funding.** The Senior Farmers Market Nutrition
Program provides vouchers for 10,000 low-income Wisconsin seniors to buy
food at participating farmers markets but it does not include
administrative dollars for local agencies that coordinate applications
and distribute vouchers. Annual funding is fixed at \$15 million --
entirely for benefits. SFMNP needs adequate administrative funds so
local agencies have sufficient resources to coordinate the program
properly.

**Provide sufficient funding to offer vouchers to all counties.** Only
30 Wisconsin counties (42%) are participating due to limited funding.
Congress should provide additional funds for vouchers so seniors in all
counties can participate. The program is very popular with both seniors
and farmers and provides highly nutritious food that reduces obesity.

**CSFP Recommendations**

**Forego CSFP expansion for improved Food Stamp benefits for seniors**.
Rather than increase CSFP funding so Wisconsin seniors outside Milwaukee
can participate, funds would be better targeted to increasing the
minimum food stamp benefit to \$50 for elderly and disabled persons.
Food Stamps are a much more desirable way to provide nutritional support
to low-income families than physical delivery of food packages whose
contents are pre-determined by the USDA.

Thank you for inviting input into how to improve these vital programs to
better serve our nation's low-income and food insecure citizens.

Sincerely,

Richard Schlimm Jonathan Bader

Executive Director Food Security Director

[^1]: The USDA market basket cost \$66 in 1977 and costs \$177 in 2001.

[^2]: During the most recent 10 year period for which data is available
    (1991-2001) the market basket price increased an average of
    \$4/year. Adding this average annual increase to the 2001 price
    yields an estimated 2005 price of \$193 By 2007 the price is
    estimated to be \$201 -- a 305% increase compared to 1977.

[^3]: U.S. food stamp administrative costs from 2000-2002 average 25% of
    the value of client benefits in those years.