Abstract

This study used 1999-2004 Current Population Survey data in conjunction with the Urban Institute’s Transfer

Income Model (TRIM3) to quantify the impact of the 2002 Farm Bill’s eligibility restorations. About half the estimated impact came from increases in newly eligible families, while the rest came from increases in eligible family

members within already-eligible families (usually within families with citizen children). By 2004, the restorations

had extended eligibility to roughly 1 million legal immigrants and 148,000 additional families. The extension in

eligibility reached around two-thirds of those made ineligible by the 1996 welfare reform law rules and not covered

by the 1998 restorations. The estimated participation gain over the period was 780,000 individuals and 139,000

legal immigrant families. The restorations took place in an era of large increases in food stamp caseloads overall;

even so, the share of families containing legal immigrants increased substantially.

Impact of 2002-03 Farm Bill

Restorations on Food Stamp

Use by Legal Immigrants

Contractor and Cooperator Report No. 40

April 2008

By Everett J. Henderson, Randy Capps, and Kenneth Finegold,

Urban Institute

This study was conducted by the Urban Institute under a cooperative

research contract with USDA’s Economic Research Service (ERS) Food

and Nutrition Assistance Research Program (FANRP): contract number

43-3AEM-3-80115 (ERS project representative: Constance Newman). This is

the third and final report submitted under this agreement. The authors take

full responsibility for the accuracy of material presented herein. The data

underlying the report are derived in part from the Transfer Income Model,

Version 3 (TRIM3) and associated databases. TRIM3 requires users to input

assumptions and/or interpretations about economic behavior and the rules

governing Federal programs. The views expressed are those of the authors

and not necessarily those of the Urban Institute, its trustees, ERS, or USDA.
ACKNOWLEDGMENTS

The authors would like to thank Jeffrey S. Passel of the Pew Hispanic Center and Laura Wheaton 

of the Urban Institute for their technical assistance in developing the methods for this project and 

the U.S. Department of Health and Human Services, Assistant Secretary for Policy Evaluation, 

for financial support and technical assistance for developing the TRIM3 model. Several 

reviewers from the U.S. Department of Agriculture and U.S. Department of Health and Human 

Services provided insightful comments and helpful technical edits. 

 — —ii 
CONTENTS

Summary ............................................................................................................................1

What Is the Issue? ....................................................................................................................... 1 

Major Findings............................................................................................................................ 2 

How Was the Study Conducted? ................................................................................................ 4 

Study Background.............................................................................................................5

Changes in Legal Immigrant Eligibility for the Food Stamp Program....................................... 6 

Focus on Mixed Citizenship and Mixed-Eligible Units ............................................................. 7 

Recent Increases in Food Stamp Caseloads................................................................................ 8 

Methods ..............................................................................................................................9

Data and Sample Used for Analysis........................................................................................... 9 

Classifying Units by Citizenship and Legal Status................................................................... 10 

Defining Mixed-Eligible Units................................................................................................. 11 

Baseline Simulation .................................................................................................................. 12 

Alternative Simulations ............................................................................................................ 13 

Analysis of Trends in FSP Eligibility and Participation........................................................... 13 

Decomposition of Trends in Participation Rates...................................................................... 14 

Regression Analysis of Food Stamp Participation.................................................................... 14 

Findings for 2003 and 2004.............................................................................................14

Demographics of Low-Income, FSP-Eligible and Participating Units in 2004........................ 15 

Baseline Simulation of FSP Eligibility and Participation......................................................... 17 

Alternative Simulation: PRWORA Legal Immigrant Restrictions Left in Place ..................... 22 

Alternative Simulation: All Legal Immigrant Restrictions Removed ...................................... 27 

Trends between 1999–2000 and 2003–04 ......................................................................33

Decomposition of FSP Participation Trends............................................................................. 36 

Regression Analysis of Food Stamp Participation among Eligible Units ..................37

Regression Analysis of Food Stamp Participation for 2003–04............................................... 37 

Regression Analysis Results for 1999–2000 versus 2003–04 .................................................. 42 

Conclusion ........................................................................................................................46

References.........................................................................................................................50

Appendix: Detailed Methodology ..................................................................................75

Data Sources ............................................................................................................................. 75 

Definitions and Classification of Data...................................................................................... 78 

Eligibility Simulations.............................................................................................................. 85 

Decomposition of Trends in Participation Rates...................................................................... 88 

Regression Analysis of Food Stamp Participation.................................................................... 89 

 — —iii 
FIGURES AND TABLES

Figure 1: Food Stamp Eligibility and Receipt Flowchart............................................................. 12 

Figure 2: Citizenship and Legal Status of Low-Income Food Stamp–Eligible Units, 2004 ........ 16 

Figure 3: Citizenship and Legal Status of Low-Income Food Stamp–Eligible Units with 

Children, 2004....................................................................................................................... 17 

Figure 4: Participation Rates for Low-Income Food Stamp–Eligible Units, 2003....................... 19 

Figure 5: Participation Rates for Low-Income Food Stamp–Eligible Units, 2004....................... 21 

Table 1: Number of Units (Unweighted) by Income Level, Unit Legal Status, and Presence of 

Children, March 2004–05 CPS (Calendar Years 2003–04).................................................. 52 

Table 2: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, Baseline Simulation, March 2004 CPS (Calendar Year 2003) ......... 53 

Table 3: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, All-LPRs-Eligible Simulation, March 2004 CPS (Calendar Year 

2003) ..................................................................................................................................... 54 

Table 4: Simulation of Low-Income Units Eligibility for and Receipt of Food Stamps, by Unit 

Legal Status and Presence of Children with No Legal Immigrant Restrictions Removed, 

March 2004 CPS (Calendar Year 2003)............................................................................... 55 

Table 5: Simulated Differences in Low-Income Units Eligible for and Receiving Food Stamps 

between Baseline and No-Restoration Scenarios, by Unit Legal Status and Presence of 

Children, March 2004 CPS (Calendar Year 2003)............................................................... 56 

Table 6: Simulated Differences in Low-Income Units Eligible for and Receiving Food Stamps 

between All-LPRs-Eligible and No-Restoration Scenarios, by Unit Legal Status and 

Presence of Children, March 2004 CPS (Calendar Year 2003)............................................ 57 

Table 7: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, Baseline Simulation, March 2005 CPS (Calendar Year 2004) ......... 58 

Table 8: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, All-LPRs-Eligible Simulation, March 2005 CPS (Calendar Year 

2004) ..................................................................................................................................... 59 

Table 9: Simulation of Low-Income Units Eligibility for and Receipt of Food Stamps, by Unit 

Legal Status and Presence of Children with No Legal Immigrant Restrictions Removed, 

March 2005 CPS (Calendar Year 2004)............................................................................... 60 

Table 10: Simulated Differences in Low-Income Units Eligible for and Receiving Food Stamps 

between Baseline and No-Restoration Simulations, by Unit Legal Status and Presence of 

Children, March 2005 CPS (Calendar Year 2004)............................................................... 61 

Table 11: Simulated Differences in Low-Income Units Eligible for and Receiving Food Stamps 

between All-LPRs-Eligible and No-Restoration Simulations, by Unit Legal Status and 

Presence of Children, March 2005 CPS (Calendar Year 2004)............................................ 62 

 — —iv 
 — —v 

Table 12: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, Baseline Simulation, Average of March 2004–05 CPS (Calendar 

Years 2003–04)..................................................................................................................... 63 

Table 13: Low-Income Units Eligible for and Receiving Food Stamps, by Unit Legal Status and 

Presence of Children, Baseline Simulation, Average of March 2000–01 CPS (Calendar 

Years 1999–2000)................................................................................................................. 64 

Table 14: Food Stamp Unit Eligibility Transitions, 2003 (Baseline versus No Restoration)....... 65 

Table 15: Food Stamp Unit Eligibility Transitions, 2003 (Full versus No Restoration).............. 66 

Table 16: Food Stamp Unit Eligibility Transitions, 2004 (Baseline versus No Restoration)Table 

17: Food Stamp Unit Eligibility Transitions, 2004 (Full versus No Restoration)................ 67 

Table 17: Food Stamp Unit Eligibility Transitions, 2004 (Full versus No Restoration).............. 68 

Table 18: Annual Median Benefit Difference Figures, 2003, 2004 Universe: Low-Income, Food 

Stamp–Eligible Units............................................................................................................ 69 

Table 19: Trends in Mixed Eligibility, Citizenship, and Participation, 1999–2004 Universe: LowIncome Eligible Units with Children .................................................................................... 70 

Table 20: Trends in Mixed Eligibility, Citizenship, and Participation, 1999–2000 to 2003–04 

Universe: Low-Income Eligible Units with Children........................................................... 71 

Table 21: Logistic Regression Results for Low-Income, Food Stamp–Eligible Units, March 2004 

and 2005 CPS (Calendar Years 2003 and 2004)................................................................... 72 

Table 22: Logistic Regression Results for Low-Income, Food Stamp–Eligible Units, March CPS 

1999–2000 to 2003–04 ......................................................................................................... 73 
THE IMPACT OF THE 2002-03 FARM BILL RESTORATIONS 

ON FOOD STAMP USE BY LEGAL IMMIGRANTS

Summary

This report quantifies the impact of the 2002 Farm Bill’s eligibility restorations on food stamps 

eligibility and receipt by noncitizen legal immigrants. It finds that the Farm Bill restorations 

made many legal immigrant families newly eligible for food stamps, yet the biggest impact of 

the bill was on families that had at least one eligible member before the restorations (usually a 

U.S. citizen child) but other members (usually noncitizen parents) that later became eligible. For 

these families, median annual benefits rose by several hundred dollars because of the 

restorations, and in turn higher benefits gave these families greater incentive to participate. The 

analysis was done using six years of national survey data in conjunction with computer 

simulations of various policy changes.

What Is the Issue? 

The 2002 Farm Security and Rural Investment Act—also known as the “Farm Bill”—restored 

food stamp benefits to legal permanent residents (LPRs) who were made ineligible by the 1996 

welfare reform law and met the following criteria: 

• were disabled, regardless of entry date (effective October 2002); 

• had been in the United States for five years or more (effective April 2003); and 

• were children, age 18 and under, regardless of entry date (effective October 2003). 

The reauthorization of the Farm Bill is still being considered in Congress; the House 

passed a version of the bill in July 2007 and the Senate is currently debating its own version.

Neither version contains any changes to the current provisions regarding noncitizen eligibility for 

food stamps. 

 — —1 
Major Findings

The Farm Bill restorations made a substantial number of LPR families newly eligible for food 

stamps—in other words, no one in the family was eligible before the restorations, but at least one 

person was eligible afterwards. The biggest impact of the bill, however, was on families that had 

at least one eligible member before the restorations but subsequently had one or more additional 

family members become eligible for the program. In most cases, these were families with LPR 

adults and U.S.-born-citizen children. When more family members became eligible, the benefit 

levels went up in most cases, because the benefit level is based in part on the number of eligible 

members in the family. Some more of these families participated as the higher benefit level gave 

them greater incentive to do so. At the same time, however, a nontrivial number of legal 

immigrant families actually lost eligibility for food stamps or had benefits reduced because of the 

restorations, because food stamp rules only count part of the income of ineligible members, and 

more of these members’ income became countable when they were no longer excluded by the 

restrictions based on citizenship. 

In 2004, the year following their full implementation, the Farm Bill provisions restored 

eligibility to an estimated 148,000 family units that included LPRs; about one-third of these 

families had children. The Farm Bill restored eligibility to about two-thirds as many families as 

would have been affected by a full restoration to all legal immigrants regardless of age or length 

of U.S. residency. 

The Farm Bill provisions affected participation as well as eligibility. We estimate that the 

changes in noncitizen eligibility resulted in about 139,000 more LPR families actually receiving 

food stamps. About half of these families had children. Again this was about two-thirds of the 

impact of a full restoration. 

 — —2 
At the individual level, in 2004, the Farm Bill restored eligibility to a total of about 1 

million LPRs, about two-thirds of the total (1.5 million) who would be eligible under a full 

restoration to all legal immigrants. About half (528,000) of these individuals were in units that 

became newly eligible, while 506,000 were in units that transitioned from mixed eligibility 

(some members eligible and others ineligible) to full eligibility (all members eligible). Another 

125,000 resided in units that remained mixed-eligible but where the number of eligible members 

increased on account of the restorations. A small number of LPRs (about 125,000) lost eligibility 

because the income of some newly eligible family members was counted differently and put 

families over the FSP income threshold. Some U.S. citizen children in these families also lost 

FSP eligibility. 

The Farm Bill restorations increased the number of people receiving food stamp benefits 

by an estimated 779,000 in 2004. The median benefit level for LPR families with and without 

children also increased by several hundred dollars as a result of the restorations. 

Partially on account of the restorations, the share of food stamp units headed by 

noncitizens increased from 20 to 25 percent between 1999–2000 and 2003–04. Since noncitizen 

units participated at lower rates than citizen units, their increased share of the total eligible 

population lowered overall participation. 

Regression analysis suggests that increasing FSP participation among eligible noncitizen 

families was driven somewhat by the restorations—especially among families without any 

citizen members—but also by the same factors that increased participation among other 

demographic groups. The overall participation rate among families with children increased from 

61 to 72 percent from 1999–2000 to 2003–04, and this rate includes a 13 percentage point 

increase among all-citizen families, which were unaffected by the restorations. Changes in 

 — —3 
economic conditions over the study period (1999–2000 to 2003–04) do not appear to have 

significantly affected participation, suggesting that improvements in program outreach, access 

and eligibility expansions—such as more lenient vehicle rules and categorical eligibility for 

noncash welfare program participants—had a positive impact on participation over this period, 

for both citizens and eligible noncitizens. 

How Was the Study Conducted?

This study used U.S. Current Population Survey (March Annual Social and Economic 

Supplement) data from three periods: 

• 1999–2000 (baseline that predates the 2001–02 economic slowdown); 

• 2001–02 (a period of caseload growth during the economic slowdown, eligibility 

expansions, and application streamlining); and 

• 2003–04 (during and immediately following the Farm Bill’s legal immigrant 

restorations). 

The data in their public form are generally not capable of precisely measuring how the 

Farm Bill restorations affected LPRs because they do not distinguish the legal status of 

noncitizens. Additionally, the public-use data include a considerable amount of misreporting of 

the use of food stamps and other benefits. In response to these data limitations, the Transfer 

Income Model (TRIM3) has been developed at the Urban Institute under primary funding from 

the Department of Health and Human Services, Office of the Assistant Secretary for Planning 

and Evaluation (HHS/ASPE). TRIM3 distinguishes between LPRs, undocumented immigrants, 

and other noncitizens; calculates eligibility and benefit levels; corrects for underreporting of 

Food Stamp Program participation; and allows for simulating policy changes such as the Farm 

Bill restorations. 

 — —4 
We tracked trends in food stamp eligibility and participation by the immigration status of 

units (all citizens, LPR/citizens, LPR/other noncitizens, undocumented/citizens, and refugees). 

We also conducted regression analyses comparing the restoration period with the pre-restoration 

period, to isolate changes in eligibility and participation from the Farm Bill restorations, from 

changes in economic conditions, and from other factors affecting overall eligibility and 

participation trends. TRIM3’s microsimulation capabilities allowed us to simulate LPR 

eligibility and participation for 2003 and 2004 with and without the Farm Bill restorations. 

TRIM3 simulations also allowed us to calculate the impact of the Farm Bill relative to the impact 

of a full restoration of food stamp benefits to all LPRs. 

Study Background 

This is the last in a series of three reports on legal immigrants’ food stamp use during 1999–

2004—a period before, during, and after implementation of the legal immigrant eligibility 

restorations in the 2002 Farm Security and Rural Investment Act. The purpose of the study is to 

assess the impact of the 2002 Farm Bill’s legal immigrant restorations on the FSP eligibility and 

participation of units with children that include LPRs.1

 By eligibility we mean the number of 

people or family units who meet the federal program criteria to receive benefits. By participation 

we mean the number of people or family units who actually sign up for and receive benefits. 

The first report outlined our methodology and provided baseline figures for 1999–2000, 

several years before the Farm Bill was passed. The second report updated the first report with 

figures on legal immigrants’ eligibility and participation in the FSP for 2001–02. It also showed 

trends between 1999–2000 and 2001–02, the period leading up to the Farm Bill restorations. The 

current report updates these trends through 2003–04 and captures the year during which the 

 — —5 
restorations were initially implemented (2003 for the two major restorations) as well as the year 

immediately following implementation (2004). 

Changes in Legal Immigrant Eligibility for the Food Stamp Program 

Before the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act 

(PRWORA) in 1996, legal immigrants were eligible for food stamps on the same terms as 

citizens. PRWORA effectively barred most legal immigrants from the FSP until they became 

citizens. Limited exceptions were made for some groups considered vulnerable or deserving of 

assistance: refugees, asylees, legal immigrants who had served in the military, and legal 

permanent residents (LPRs) who could prove they had worked 40 quarters (10 years) in covered 

employment (Fix, Zimmermann, and Passel 2001). 

Since PRWORA’s enactment there have been two Congressional restorations of food 

stamp benefits to legal immigrants. The first, passed in 1998, restored food stamps to LPR 

children, and disabled immigrant who entered the United States before PRWORA’s enactment 

on August 22, 1996, as well as to LPR immigrants who had reached age 65 and resided in the 

United States as of that date. The 1998 law also extended the period of eligibility for refugees 

from their first five to their first seven years in the United States. In May 2002, the Farm Security 

and Rural Investment Act introduced three major changes in legal immigrant benefit eligibility. 

First, legal (or “qualified”) immigrants who had “received a disability benefit for their condition” 

became eligible for the FSP on October 1, 2002. The second and broadest restoration enacted 

under the Farm Bill extended FSP eligibility to all qualified legal immigrants who had been in 

the United States for five or more years, effective April 1, 2003. This provision effectively 

extended eligibility to many working-age noncitizens. The third major restoration, effective 

 1

 In this report we use the terms “legal permanent resident” (LPR) and “legal immigrant” interchangeably. 

 — —6 
October 1, 2003, extended eligibility to all qualified legal immigrant children under 18, without 

regard to the length of time they had been in the country. 

In early 2003, as states were planning implementation of the Farm Bill food stamp policy 

changes, the Food and Nutrition Service (2003) estimated that “some 400,000” legal immigrants 

who lost eligibility under PRWORA would become eligible and participate as a result of the 

restorations. The purpose of our study is to estimate just how many more legal immigrants were 

eligible for and participating in the FSP in 2003–04, following the Farm Bill restorations, than in 

the years before the restoration (1999–2002). We develop these estimates using data from the 

U.S. Current Population Survey (CPS), augmented with the Urban Institute’s assignment of legal 

status to individuals and imputation of FSP eligibility and participation to units (Passel and Clark 

1998; Passel, Van Hook and Bean 2004). 

Focus on Mixed Citizenship and Mixed-Eligible Units 

Our study focuses most closely on units with children, especially “mixed citizenship” units—

those that include at least one citizen and at least one noncitizen. In most cases, the noncitizens 

are adults and the citizens are children. These mixed citizenship units often have mixed 

eligibility for food stamps—i.e., some members are eligible for the program but others are not—

because noncitizen eligibility restrictions apply to some members but not to others. As a result, 

these mixed citizenship units tend to be eligible for lower levels of benefits than comparable 

units where all members are citizens—or in some cases eligible noncitizens.2

 Thus, we assess 

not only changes in the number of noncitizen units that are eligible for food stamps, but also 

changes in the number of units that are mixed-eligible. We assume that participation among units 

 — —7 
with ineligible noncitizen members is lower because they are eligible for lower benefits t

otherwise comparable units where all members are citizens. 

han 

 

Recent Increases in Food Stamp Caseloads 

The drop in the number of people participating in the FSP during the late 1990s was particularly 

sharp among noncitizen units, but participation fell for other groups as well. Units of all types 

were affected by a strong economy, which pushed some units over income eligibility limits and 

reduced the size of the benefits for which other units would be eligible, giving them less 

incentive to participate. The combination of prosperity and welfare reform produced a steep 

decline in TANF cash assistance that carried over to FSP: many TANF leavers left both 

programs even though they remained eligible for food stamps. FSP time limits for unemployed 

able-bodied adults without dependents (ABAWDS), included in PRWORA along with the 

restrictions on noncitizen eligibility, also depressed program participation. 

After dropping to a monthly average of 17.2 million individual participants in fiscal year 

(FY) 2000, FSP participation rebounded to 26.5 million in FY 2007, an increase of over 50 

percent (Food and Nutrition Service 2007). As with the participation decline of the late 1990s, 

the economy and policy changes both contributed to the upward trend. The boom of the 1990s 

turned into the recession of 2001, followed by a relatively weak recovery. Policy changes 

included expansion of categorical eligibility to include noncash TANF recipients, up to five 

months of transitional benefits for TANF leavers, more liberal treatment of automobiles under 

FSP asset rules, longer certification periods, less frequent reporting requirements, and increased 

outreach to eligible nonparticipants. Many of these changes aimed at increasing participation 

2

 The population that is income eligible for food stamps incorporates many mixed citizenship units that include 

undocumented immigrants and citizens. We model the FSP participation of these units, even though undocumented 

 — —8 
among working units (Wolkwitz 2007). Such changes may have had particularly strong impacts 

on immigrant units, who are more likely than other eligible units to include at least one worker. 

In 2004, 79 percent of low-income eligible units with at least one noncitizen had earnings, 

compared with 49 percent of low-income eligible all-citizen units.3

Methods 

This section of the report briefly outlines the study methods. The methodology is described in 

much greater detail in the appendix to this report. 

Data and Sample Used for Analysis 

Our approach involves the use of Current Population Survey data for 1999–2004, with several 

important innovations that help us better isolate the impact of FSP participation trends and the 

impact of Farm Bill eligibility restorations on units with legal immigrants. Our analysis uses the 

Transfer Income Model (TRIM3), which has been developed at the Urban Institute under 

primary funding from HHS/ASPE. TRIM3 distinguishes among immigrants by legal status, 

determine eligibility for food stamps, and correct for underreporting and misreporting of FSP 

participation by survey respondents. We group the data into three samples: 

• 1999–2000 (baseline that predates the 2001–2002 economic slowdown); 

• 2001–02 (a period of caseload growth during the economic slowdown, eligibility 

expansions, and application streamlining); and 

• 2003–04 (during and immediately following the Farm Bill’s legal immigrant 

restorations). 

 immigrants are ineligible for the FSP and their eligibility was not changed by PRWORA or the Farm Bill. 

 

3

 Figures calculated by authors from 2004 calendar year CPS TRIM3 data. 

 — —9 
Classifying Units by Citizenship and Legal Status 

One essential component of TRIM3 is the assignment of legal status to immigrants in the CPS 

data, as some LPRs are eligible for the FSP while undocumented immigrants are entirely 

ineligible. The CPS asks whether respondents and other unit members are 

(1) U.S.-born citizens; 

(2) U.S. citizens born in the territories; 

(3) U.S. citizens born abroad to U.S. citizen parents; 

(4) foreign-born naturalized U.S. citizens; or 

(5) noncitizens. 

TRIM3 further distinguishes those in the “noncitizen” category by legal status: 

(a) refugees and asylees—immigrants admitted to the United States because of fear of 

persecution in home countries and who are therefore eligible for federal assistance upon 

their resettlement; 

(b) legal temporary residents—students, workers, and other visitors with temporary 

visas; 

(c) legal permanent residents (LPRs)—the bulk of legal immigrants, who are admitted 

for employment or because of close unit ties with U.S. citizens or legal residents; and 

(d) undocumented immigrants—immigrants who entered the United States illegally, 

overstayed a valid visa, or otherwise violated the terms of their admission. 

We use TRIM3’s assignments of legal status to calculate the number of citizen, LPR, 

undocumented, and refugee members in each unit. We then classify units into six types of units 

according to citizenship and legal status: 

1. All citizen: The largest group of units includes only citizens. We use citizen-only units as 

a control group to contrast patterns of food stamp eligibility and use with those for units 

with noncitizen members. 

2. LPR/citizen: The second largest group among units with children, these units contain at 

least one legal permanent resident and at least one U.S. citizen. They may or may not 

contain immigrants with other types of legal status. A large share of these units is mixed 

eligible, because some members are ineligible noncitizens (usually the parents) and 

others are eligible citizens (usually the children). 

 — —10 
3. LPR/other noncitizen: These units have at least one legal permanent resident but no 

citizen members; most other members of these units are either other LPRs or 

undocumented immigrants, although some may be refugees or temporary residents. This 

group is a small share of units with children but a larger share of units without children. 

Some of these units are ineligible because of LPR restrictions, while others are mixed 

eligible. Still others are universally eligible because all unit members are covered by the 

exceptions written into PRWORA or by the later restorations. 

4. Undocumented/citizen: These units contain at least one undocumented immigrant and at 

least one U.S. citizen; they may or may not contain immigrants with other types of legal 

status. None of the undocumented members of these units are eligible for food stamps, so 

all eligible units in this group have mixed eligibility. 

5. All undocumented: These units are composed solely of undocumented immigrants and 

are excluded from our analysis. No members are eligible for food stamps. 

6. Refugee: These units are composed either solely of refugees or of refugees and citizens. 

It is important to distinguish refugee units from those with LPR members because 

refugees and LPRs have been subject to different eligibility provisions. Under PRWORA, 

refugees were eligible for their first five years in the United States; this was extended to 

seven years in 1998. 

Defining Mixed-Eligible Units 

We begin by identifying family units that are eligible for the FSP; in other words, families which 

meet the criteria for program participation—including citizenship and legal status as well as nonimmigration related criteria. Within the group of family units that are food stamp eligible, some 

units face restrictions that result in some members being eligible while others are not. We use the 

term “mixed-eligible” to refer to these units. By contrast, we term units where all members are 

eligible “all-eligible units.” In general, all-eligible units qualify for higher benefits, because 

benefits are based in part on the number of eligible family members. Among both mixed- and 

all-eligible units, some participate in the FSP and others choose not to participate. We calculate 

the share of units receiving food stamps separately for mixed- and all-eligible units in order to 

explore how mixed eligibility affects participation (figure 1). 

 — —11 
LPR/citizen and undocumented/citizen units have high mixed-eligibility rates because of 

restrictions on the eligibility of their LPR and undocumented members. Usually the adults are 

ineligible noncitizens, while the children are mostly U.S.-born citizens. The PRWORA 

restrictions on LPR food stamp eligibility cause many eligible LPR/citizen units who would 

otherwise be universally eligible to be mixed eligible. Undocumented immigrants are and have 

always been ineligible for food stamps, so eligible units that contain undocumented immigrants 

are always mixed eligible. 

Figure 1: Food Stamp Eligibility and Receipt Flowchart 

Baseline Simulation 

In our “baseline simulation,” TRIM3 uses FSP eligibility rules⎯including those for 

noncitizens⎯in place at the time the data were collected to calculate eligibility, participation, 

and the amount of benefits received. Our baseline simulation for 2003 includes eligibility 

adjustments in TRIM3 for the first two Farm Bill restorations: disabled legal immigrants 

(October 2002) and legal immigrants with at least five years of U.S. residency (April 2003). The 

2003 baseline does not include eligibility adjustments for the third restoration, to all LPR 

 — —12 
children regardless of length of residency, which took place in October 2003. The third 

restoration is included in our 2004 baseline, along with the other two restorations. 

TRIM3 estimates monthly eligibility and participation for family units. We use TRIM3 to 

identify units that were eligible for and/or received food stamps during any month in the year. 

We also calculate eligibility and participation for individuals, again annually. In all of our 

simulations, the eligibility rate is the number of individuals or family units that are eligible for 

food stamps divided by the total number of low-income individuals or units. The participation 

rate is the number of people or units that receive food stamps divided by the eligible population. 

Alternative Simulations 

We also conducted two alternative simulations, using TRIM3: one that estimates eligibility and 

participation rates of low-income units had the Farm Bill legal immigrant restorations not 

occurred, and a second that estimates eligibility and participation without any of the legal 

immigrant eligibility restrictions PRWORA in place—in other words, as if a full eligibility 

restoration had occurred. 

Analysis of Trends in FSP Eligibility and Participation 

In this report we discuss trends in food stamp eligibility and participation for low-income units 

between 1999–2000 and 2003–04. We examine eligibility, mixed eligibility, and participation 

rates for low-income units disaggregated by the presence of children and the citizenship and 

legal status categories described above. Our analyses in this report capture trends in FSP 

eligibility before and after the Farm Bill restorations. 

 — —13 
Decomposition of Trends in Participation Rates 

We apply demographic decomposition techniques to changes between 1999–2000 and 2003–04 

in the participation rate among low-income units with children that are eligible for the FSP. 

Specifically, we allocate the change in FSP participation rates between 1999–2000 and 2003–04 

into the proportions due to each of the following: 

• change in the share of all citizen, LPR/citizen, undocumented/citizen, LPR/other 

noncitizen and refugee units; 

• change in the share of mixed eligible units; and 

• change in the underlying participation rate for these units. 

Regression Analysis of Food Stamp Participation 

Using logistic regression techniques, we model food stamp participation among low-income 

units that are eligible for the FSP. In this report we display findings from a regression model of 

participation in 2003–04. We also report estimates from a regression model of change over time 

in participation between 1999–2000 and 2003–04. Our models control for family unit’s 

immigration status, unit characteristics (e.g., number of adults and children), state economic 

conditions, and state of residence (only California and Texas were significant). 

Findings for 2003 and 2004 

This section of the report discusses food stamp eligibility and participation in 2003 and 2004, 

and it places these findings in the context of our earlier work on eligibility and participation in 

1999 through 2004. In some cases we present findings only for 2004, but where patterns differ 

significantly between 2003 and 2004, we discuss findings for both years. 

The changes witnessed during this period reflect both the Farm Bill restorations and the 

fact that the low-income population increasingly consists of units that contain noncitizens; this 

 — —14 
phenomenon is increasingly prevalent among units with children. In 1999–2000, all-citizen units 

composed the vast majority of low-income eligible food stamp units (nearly 90 percent), but the 

share of all-citizen units was lower among units with children (about 80 percent). A large 

majority of noncitizen units with children had mixed citizenship—either LPR/citizen or 

undocumented/citizen—but the majority of noncitizen units without children were composed 

entirely of noncitizens.4

 Among low-income units with children, LPR/citizen units were as likely 

as all-citizen units to be eligible for the FSP (with a rate of about 60 percent), and 

undocumented/citizen units were more likely to be eligible (with a rate of about 80 percent). 

About two-thirds of LPR/citizen units with children had mixed eligibility because of the 

PRWORA restrictions, and all undocumented/citizen units were mixed eligible. In contrast, only 

2 percent of all-citizen units with children were mixed eligible. About one-quarter of eligible 

undocumented/citizen units with children, and one-third of LPR/citizen units, participated in the 

FSP, compared with two-thirds of all-citizen units. Thus, the mixed eligibility of mixedcitizenship units with children appears to have driven down their participation rates. Other 

factors such as language barriers, misunderstandings about the eligibility of children, and fear of 

immigration consequences (such as deportation in undocumented/citizen units) may have also 

reduced their participation (Holcomb et al. 2003). 

Demographics of Low-Income, FSP-Eligible and Participating Units in 2004 

In 2004, noncitizen units composed a small yet significant minority of units eligible for the FSP. 

As in 1999–2000, most noncitizen units were mixed-citizenship units. Fourteen percent of all 

low-income FSP-eligible units contained noncitizens, with the two dominant groups being 

 

4

 This difference is because citizen members of immigrant units are most often children, since most children of 

immigrants are born in the United States. 

 

 — —15 
LPR/citizen units (6 percent) and undocumented/citizen units (5 percent). Units with no citizens 

present but at least one LPR accounted for 2 percent of eligible units, while units with refugees 

were 1 percent of the low-income eligible population (figure 2). The corresponding figures for 

2003 are virtually the same. 

Figure 2: Citizenship and Legal Status of Low-Income Food Stamp–Eligible Units, 2004 

Source: Urban Institute analysis of U.S. Current Population Survey data for March 2005, using TRIM3 Food Stamp 

Program eligibility simulations. 

Notes: Unit income is below 200% of the federal poverty level. LPR/other noncitizen units include at least one legal 

immigrant. 

Limiting our universe to low-income eligible units with children changes the distribution 

somewhat, but in 2004, all-citizen units still composed the vast majority (76 percent) of eligible 

units (figure 3). LPR/citizen and undocumented/citizen units each made up 11 percent of eligible 

units, while units with refugees and those composed entirely of LPRs and other noncitizens 

together accounted for the remaining 2 percent. Again, patterns were similar for 2003. 

The share of low-income eligible units with children that included noncitizens increased 

modestly between 1999–2000 and 2003–04 (from 20 to 25 percent, difference from figure 3 due 

to rounding). In both periods, the vast majority of eligible noncitizen units had mixed 

citizenship—either LPR/citizen or undocumented/citizen. Most mixed-citizenship units were 

units with children, and in most cases the U.S. citizens were children while the adults were LPRs 

 — —16 
or undocumented immigrants. As a result, the PRWORA restrictions on immigrant eligibility 

mostly affected the eligibility of adults but not the children in these units. 

Figure 3: Citizenship and Legal Status of Low-Income Food Stamp–Eligible Units with 

Children, 2004 

Source: Urban Institute analysis of U.S. Current Population Survey data for March 2005, using TRIM3 Food Stamp 

Program eligibility simulations. 

Notes: Unit income is below 200% of the federal poverty level. LPR/other noncitizen units include at least one legal 

immigrant. 

Baseline Simulation of FSP Eligibility and Participation 

Low-income units with children were far more likely than childless units to be eligible for the 

FSP in 2003 (62 percent versus 48 percent, as shown in table 2). Among units with children, 

undocumented/citizen units were by far the most likely to be eligible (85 percent), probably 

because of their relatively low income levels. Seventy percent of units with refugees were FSP 

eligible, followed by all-citizen units (62 percent) and LPR/citizen units (60 percent). LPR/other 

noncitizen units had the lowest eligibility rate (36 percent), most likely because most of these 

units only had members who were ineligible noncitizens. 

Childless units showed considerably less variation in eligibility rates. All-citizen units 

had the highest eligibility rate (50 percent), followed closely by refugee units (46 percent), 

 — —17 
LPR/other noncitizen units (46 percent) and LPR/citizen units (44 percent). 

Undocumented/citizen units lagged behind the others, with an eligibility rate of 35 percent. 

The presence of children had a large influence on mixed eligibility rates in 2003. Eligible 

units with children were four times as likely as eligible childless units to be mixed eligible (16 

percent versus 4 percent). Mixed-eligibility rates for units containing children were 100 percent 

for undocumented/citizen units, 32 percent for LPR/other noncitizen units, and 29 percent for 

LPR/citizen units. Only a negligible fraction of all-citizen units and refugee units (2 percent and 

1 percent, respectively) were mixed eligible. The corresponding figures for childless units were 

quite similar to units with children for every category except LPR/other noncitizen units; such 

childless units were only half as likely to be mixed eligible as those with children (17 percent 

versus 32 percent). Among the other childless units, all eligible undocumented/citizen units were 

mixed eligible, followed by LPR/citizen units (37 percent) and refugee and all-citizen units (both 

at 3 percent). 

As was true for mixed eligibility rates, eligible units with children were much more likely 

to participate in the FSP (70 percent) than eligible childless units (41 percent) in 2003 (figure 4). 

In examining participation patterns among units with children, we find that all-citizen units had 

the highest participation rate, at 79 percent, followed by LPR/other noncitizen units (66 percent), 

refugee units (63 percent), and legal citizen units (46 percent). Despite being the most likely 

group to be eligible (85 percent), undocumented/citizen units had the lowest participation rate, at 

32 percent. 

Patterns in eligibility, mixed eligibility, and participation in 2004 (table 7) were similar to 

those for 2003 in most respects. There were, however, some differences in our 2004 data worth 

noting due to the effects of the October 2003 restoration to LPR children. As was true in 2003, 

 — —18 
units with children were considerably more likely to be eligible, be mixed eligible, and to 

participate in the FSP than childless units were in 2004. Among units with children, 61 percent 

of all citizen units were eligible, and 60 percent of LPR/citizen units were eligible, as were 86 

percent of undocumented/citizen units. The biggest change in eligibility rates occurred among 

LPR/other noncitizen units; their eligibility rates nearly doubled, jumping from 36 percent to 68 

percent between 2003 and 2004. The eligibility rate for refugee units appear to have declined 

between 2003 and 2004 from 70 percent to 59 percent, but this single year change may be 

insignificant given the relatively small sample of refugee families in the data. Comparisons of 

baseline figures to alternate simulations assuming pre-restoration rules will be presented later in 

the paper and will better allow us to isolate the impact of the restorations on family units that 

include LPRs. 

Figure 4: Participation Rates for Low-Income Food Stamp–Eligible Units, 2003 

Source: Urban Institute analysis of U.S. Current Population Survey data for March 2004, using TRIM3 Food Stamp 

Program eligibility simulations. 

Notes: Unit income is below 200% of the federal poverty level. LPR/other noncitizen units include at least one legal 

immigrant. 

 — —19 
There were slight changes between 2003 and 2004 in the percentage of units that were 

mixed eligible. The overall mixed-eligibility rate for units with children was stable between 2003 

and 2004, at 16 percent. The mixed-eligibility rate for LPR/citizen units declined by only 3 

percentage points, from 29 to 26 percent. Mixed-eligibility rates for eligible LPR/other 

noncitizen units with children actually increased, from 32 percent in 2003 to 61 percent in 2004. 

The mixed-eligibility rate for refugees also increased, from 1 percent to 14 percent. Mixedeligibility rates for all-citizen units with children remained at 2 percent, and 

undocumented/citizen units remained 100 percent mixed eligible, again due to the presence of 

the undocumented, who are ineligible for the FSP. 

Mixed-eligibility rates remained steady for childless units as well; the overall rate only 

changed 1 percentage point, from 4 percent in 2003 to 5 percent in 2004. The biggest rate drop 

occurred in LPR/citizen units, which dropped from 37 percent to 32 percent mixed eligible. The 

biggest rate increase occurred among refugee units, which jumped from 3 percent to 17 percent 

mixed eligible. Mixed-eligibility rates for LPR/other noncitizen units (17 percent in 2003, 16 

percent in 2004), all-citizen units (3 percent in 2003, 4 percent in 2004), and 

undocumented/citizen units (100 percent for both years) all remained stable during this period. 

Overall participation rates (for all units, with and without children) increased, from 54 

percent in 2003 to 60 percent in 2004 (table 7). Units with children had an overall participation 

rate of 74 percent in 2004 (figure 5), compared with 70 percent in 2003. The biggest change in 

participation rates among units with children occurred among LPR/other noncitizen units, whose 

participation rates increased 12 percentage points, from 66 percent to 78 percent. The 

participation of LPR/citizen units with children increased from 46 percent to 49 percent, and all-

 — —20 
citizen units rose from 79 percent to 83 percent, while undocumented/citizen units jumped from 

32 percent to 39 percent. 

Increases in participation rates among childless units were even more substantial; overall, 

such units’ participation rates climbed from 41 percent in 2003 to 50 percent in 2004 and every 

group’s participation rate increased. The participation rate among childless LPR/citizen units 

rose from 45 percent to 61 percent during that period. Participation rates for 

undocumented/citizen units doubled, from 32 percent in 2003 to 64 percent in 2004. The 

participation rate for LPR/other noncitizen units increased from 53 percent to 63 percent, the 

refugee rate from 75 percent to 83 percent, and the all citizen rate increased from 41 percent to 

49 percent. 

Figure 5: Participation Rates for Low-Income Food Stamp–Eligible Units, 2004 

Source: Urban Institute analysis of U.S. Current Population Survey data for March 2005, using TRIM3 Food Stamp 

Program eligibility simulations. 

Notes: Unit income is below 200% of the federal poverty level. LPR/other noncitizen units include at least one legal 

immigrant. 

 — —21 
Alternative Simulation: PRWORA Legal Immigrant Restrictions Left in Place 

We conducted alternate simulations of food stamp eligibility and receipt in 2003 and 2004 with 

the PRWORA LPR eligibility restorations still in place, in order to estimate the impact of the 

restorations. All-citizen units, undocumented/citizen units and refugee units were not affected in 

this alternate scenario, since these unit types did not contain legal permanent residents. Both the 

baseline and alternative scenarios assumed no sponsor deeming—for reasons discussed in the 

detailed methodology appendix to this report; if deeming were taken into account, the differences 

between the scenarios discussed here could be slightly smaller. 

Simulation for 2003. In terms of eligibility rates, the two groups affected the most in 

2003 were LPR/other noncitizen units without children and LPR/citizen units with children. In 

2003, the eligibility rate for childless LPR/other noncitizen units without the Farm Bill 

restorations would have been 29 percent, a figure 17 percentage points lower than the 

participation rate in the baseline simulation (tables 4 and 5). This translates into 114,000 fewer 

units being eligible for food stamps without the restorations. The changes for LPR/citizen units 

with children were more modest and actually resulted in a net decrease in the number and share 

of low-income units eligible for the FSP in 2003; the eligibility rate in the no-restoration scenario 

was 2 percentage points higher than that in the baseline scenario, and 26,000 more units were 

eligible for the program. 

This finding initially seems counterintuitive, but it is explained by the fact that making 

more adult unit members categorically eligible for food stamps means that the incomes of 

individuals whose earnings were originally prorated for eligibility determination are now 

counted in full. This change causes some units to rise above the income eligibility threshold and 

lose their food stamp benefits. 

 — —22 
The Farm Bill had the opposite effect in LPR/other noncitizen units without children. 

Before the restorations, many of these units were composed solely of individuals who were 

categorically ineligible for the FSP. The restoration made many of these units’ LPR members 

newly eligible, and the number of units that became newly eligible far outweighed the number of 

units that might have lost eligibility because of an increase in countable income. 

The largest impact of the 2003 LPR restorations was on the number of mixed-eligibility 

units, particularly units with children. In 2003, the restorations reduced the number of mixedeligible units with children by 347,000. The primary category driving this change among units 

with children was the LPR/citizen category, in which the mixed-eligibility rate dropped by 30 

percentage points, or more than 318,000 units (from 606,000 to 287,000). The mixed-eligibility 

rate for refugee units with children dropped by a comparable 28 percentage points because of the 

restorations, but the absolute drop (28,000 units) was much lower than it was for LPR/citizen 

units because of the small relative size of the refugee population. Changes in mixed eligibility 

were more modest among units without children in 2003; the restoration reduced the number of 

mixed-eligible LPR/citizen units by 26,000 units, but the decrease was balanced out by an 

increase of 26,000 among childless LPR/other noncitizen units. 

In the end, the restoration had very little impact on the net number of units that received 

food stamps in 2003. Only 71,000 more units participated in the FSP under the baseline scenario 

than under the no-restoration scenario. All the net increase was due to childless LPR/other 

noncitizen units. 

While the restorations did not substantially increase the number of noncitizen units who 

became eligible for or received food stamps in 2003, the restorations did greatly increase the 

number of individuals who gained eligibility and participated. Overall, about 835,000 more 

 — —23 
noncitizens were eligible for food stamps in 2003 than would have been eligible in the absence 

of the restorations (table 14). About 355,000 of these newly-eligible individuals resided in units 

that became newly eligible (i.e., no member of the unit was eligible for food stamps without the 

restorations). Another 471,000 resided in units that were mixed eligible without the restorations 

but became fully eligible with them. An additional 104,000 were in units that were mixed 

eligible in both the baseline and no-restoration scenarios, but where the number of eligible 

members increased. About 95,000 people lost eligibility because of the restorations (again, 

because their units were pushed above the income eligibility threshold). About 521,000 

individuals newly participated in the FSP on account of the restorations. 

The impact of the restorations was not evenly distributed across age groups in 2003; only 

20,000 of the 835,000 new net eligible people were children. About 72,000 children lived in 

units that became newly eligible because of the restoration, 20,000 resided in units that 

transitioned from mixed to full eligibility, and another 2,000 were in units that remain mixed 

despite the restorations. The addition of these 94,000 children was heavily offset by the 74,000 

who lost eligibility because of the restorations, resulting in a net gain of only 20,000 children. 

About 57,000 more children newly participated in the FSP on account of the restorations. 

Of the net 815,000 newly eligible adults, 450,000 of them resided in units that 

transitioned from mixed to fully eligible, 283,000 lived in units that the restoration made newly 

eligible, and 102,000 were in units that remained mixed eligible despite the addition of one or 

more newly eligible members. Only 20,000 adults lost eligibility for the FSP and 464,000 more 

adults ended up participating. 

In 2003, the restorations increased median annual benefits by several hundred dollars 

among noncitizen families with children. LPR/citizen units with children were eligible for $478 

 — —24 
more in the baseline than in the no-restoration simulation (table 18). LPR/other noncitizen units 

and refugee units with children were also eligible for significantly more benefits than they would 

have been without the restoration: $410 and $472, respectively. The difference in median annual 

benefits between the baseline and no-restoration simulations was much smaller for units without 

children than for those with children. 

Simulation for 2004. Our comparison between the baseline and no-restoration scenarios 

showed similar patterns in 2004 as in 2003, but with some important differences, especially for 

children. Again, childless LPR/other noncitizen units had the largest absolute difference between 

scenarios: nearly 100,000 more units were eligible for food stamps in the baseline run than were 

eligible in the no-restoration scenario (290,000 versus 193,000), and their eligibility rate in the 

baseline scenario was 15 percentage points higher (tables 9 and 10). LPR/other noncitizen units 

with children showed the largest difference between scenarios: their eligibility rate nearly tripled, 

from 24 percent in the no-restoration scenario to 68 percent in the baseline simulation. This 

amounted to an absolute increase of 81,000 units (from 45,000 to 126,000 units) on account of 

the restorations. 

The eligibility/receipt category with the largest difference between the baseline and norestoration scenarios was the number of mixed-eligible units again in 2004. There were 305,000 

fewer mixed-eligibility units in the baseline than in the no-restoration scenario. Again, the group 

responsible for the vast majority of the change in this figure was LPR/citizen units with children: 

there were 620,000 mixed-eligible units in this group in the no-restoration simulation and 

259,000 units in the baseline, a difference of 361,000 units. LPR/other noncitizen units with 

children also contributed to the change in mixed eligibility, but this change was in the upward 

direction: 56,000 more units were mixed eligible in the baseline scenario than in the no-

 — —25 
restoration scenario (and the mixed-eligibility rate was 16 percentage points higher), but this was 

because there were far more eligible units overall in the baseline scenario than in the norestoration scenario. Many LPR/other noncitizen units with children that gained eligibility on 

account of the Farm Bill restorations—mostly through the last restoration to children—included 

some members that were still ineligible in 2004; presumably these were LPR adults with less 

than five years of residency. 

The absolute difference in the number of units receiving food stamps between the 

scenarios in 2004 was twice that in 2003. In 2004, 139,000 more units received food stamps in 

the baseline than in the no-restoration simulation. The change was evenly split between 

LPR/other noncitizen units with children and those without: both categories had net gains of 

roughly 70,000 units between the simulations. This amounted to a 13 percentage point increase 

in participation rates among LPR/other noncitizen units with children and a 5 percentage point 

increase in participation rates among those without children, due to the restorations. 

As in 2003, differences between the simulations in the numbers of eligible and receiving 

individuals were considerably greater than the corresponding figures at the unit level. About 1.03 

million more people in units containing noncitizens were eligible for the FSP than would have 

been eligible without the restorations (table 14). About half (528,000) of these individuals were 

in units that became newly eligible, while 506,000 were in units that transitioned from mixed to 

full eligibility, and another 125,000 resided in units that remained mixed eligible but where the 

number of eligible members increased on account of the restorations. This combined total of 1.16 

million new eligible noncitizens was offset by 125,000 individuals who lost their eligibility; 

779,000 individuals newly participated in the FSP. 

 — —26 
Although the majority of the newly eligible individuals were adults, the restoration of all 

LPR children made a large difference in the number of children eligible for the FSP. The net 

difference between the baseline and no-restoration scenarios in eligibility was only 20,000 

children in 2003 but jumped to 201,000 in 2004. On account of the restorations, there were 

209,000 children in units that became newly eligible. Another 48,000 children were in units that 

were mixed eligible and became fully eligible because of the restorations, and an additional 

46,000 were in units that remained mixed even with the addition of newly eligible children. 

These 303,000 newly eligible children were offset by 102,000 children who lost eligibility 

because of the restorations. Altogether 241,000 children newly participated in the FSP. 

A net total of 833,000 adults became newly eligible in 2004 because of the restorations. 

More than half (458,000) were in units that changed from mixed to fully eligible; 320,000 were 

in newly eligible units, while 79,000 were in units that retained their mixed eligibility status. 

Only 24,000 adults lost their eligibility because of the restoration. Over half a million (538,000) 

more adults participated in the FSP. 

As in 2003, the restorations resulted in significantly higher benefit levels for noncitizen 

family units, especially those with children. In 2004, LPR/citizen units, LPR/other noncitizen 

units, and refugee units (all with children) were eligible for $662, $274, and $344 more in annual 

benefits, while LPR/citizen units without children were eligible for $365 more annually in the 

baseline than they were with no restoration (table 18). 

Alternative Simulation: All Legal Immigrant Restrictions Removed 

Our other alternative simulation estimated the impact on FSP eligibility and participation of a 

full LPR eligibility restoration. Again, sponsor deeming was not modeled in this scenario. We 

 — —27 
compared the eligibility, mixed eligibility, and receipt figures from our full-restoration 

simulation to the figures from the no-restoration scenario for comparison with the partial 

restoration that actually took place under the terms of the Farm Bill. 

Simulation for 2003. In 2003, 248,000 more units would have been eligible for the FSP in 

the full restoration simulation than in the no-restoration simulation (tables 3, 4, and 6). This was 

much greater than the difference between the baseline with Farm Bill restorations and the norestoration simulation: 87,000 units. All the difference in the number of eligible units between 

the full- and no-restoration simulations occurred in two groups: LPR/other noncitizen units with 

and without children. The difference in the number of eligible LPR/other noncitizen units 

without children was 180,000 (381,000 versus 202,000) units between the full- and norestoration scenarios, and the eligibility rate rose by 26 percentage points (29 to 56 percent). 

There would have been 69,000 more LPR/other noncitizen units with children eligible in the fullrestoration than the no-restoration simulation (113,000 versus 44,000 units), and the eligibility 

rate for this group would have increased by 38 percentage points, from 24 to 62 percent. 

Making all LPRs eligible would have greatly reduced the number of mixed-eligible units 

in 2003. Over half a million (555,000) fewer units would have been mixed eligible in the fullrestoration than in the no-restoration scenario. All the change would have occurred among three 

unit types, and the vast majority of the change would be among units with children. The largest 

absolute change would have occurred among LPR/citizen units with children: 482,000 fewer 

units would have been mixed eligible in the full- than the no-restoration scenario (606,000 versus 

124,000 units); their mixed eligibility rate would have fallen by 47 percentage points (from 59 

percent to 12 percent). The number of mixed-eligible refugee units with children would have 

declined by 28,000 (29,000 to 1,000) units, and their rate decreased by 28 percentage points 

 — —28 
(from 30 to 1 percent). Childless LPR/citizen units would have accounted for the rest of the 

decrease—45,000 units (from 103,000 units to 58,000)—and their mixed-eligibility rate would 

have decreased from 51 percent to 27 percent. 

FSP participation would have increased by 204,000 units in the full- versus no-restoration 

scenario in 2003. Two unit types would have been responsible for this change: LPR/other 

noncitizen units with and without children. The largest absolute difference between scenarios 

would have occurred among childless LPR/other noncitizen units, 137,000 more of whom would 

have received food stamps under the full- than the no-restoration scenario (232,000 versus 

95,000 units); the participation rate in childless LPR/other noncitizen units would have climbed 

from 47 percent to 61 percent. The next largest participation increase (66,000—from 25,000 to 

91,000) would have occurred among LPR/other noncitizen units with children; their participation 

rate would have increased by about 25 percentage points (from 55 to 81 percent). 

Unsurprisingly, simulating a full restoration would have made an even bigger impact at 

the individual level than the actual restoration did. In 2003, 1.56 million net new individuals 

would have been eligible for food stamps that would not have been without restorations (table 

15). Of these, 838,000 individuals lived in units that transitioned from being mixed eligible to 

being fully eligible, another 761,000 resided in units that were newly eligible, and 71,000 people 

were in units that remained mixed eligible even after the full restoration. These increases in 

individual eligibility would have been offset by a loss of 108,000 individuals from differences in 

countable income. Over 1 million of the newly eligible LPRs (1,084,000) would have 

participated in the FSP had all the eligibility restrictions been removed. 

As was the case when comparing the actual 2003 figures with the non-restoration 

simulation, many more adults than children would have become eligible and/or received food 

 — —29 
stamps under the full-restoration scenario. With a full restoration, 1.37 million net new adults 

would have become eligible. Of this number, 751,000 resided in units that transitioned from 

mixed to full eligibility, 571,000 lived in units that became newly eligible, and an additional 

69,000 lived in units that remained mixed eligible. Only 23,000 adults would have lost eligibility 

with a full restoration. Of the new net eligible adults, 878,000 (64 percent) would have received 

food stamps. 

In the full-restoration simulation, 194,000 net new children would have become eligible 

for food stamps; 190,000 of them were in newly eligible units, 87,000 in units that transitioned 

from mixed to fully eligible, and another 2,200 lived in units that retained their mixed-eligibility 

status. These gains were offset by the 86,000 children who would have lost their eligibility for 

food stamps. The number of children that would have newly participated in the FSP rose more 

than the number of newly eligible children overall (206,000 versus 194,000)—most likely 

because more families would have participated as more adults became eligible. 

Simulation for 2004. The overall differences between the full- and no-restoration 

simulations were comparable at the unit level in 2003 and 2004. In 2004, 227,000 more units 

overall would have been eligible for the FSP in the full-restoration simulation than were in the 

no-restoration simulation (tables 8, 9, and 11). The bulk of this change would have occurred 

among childless LPR/other noncitizen units, 183,000 more of whom (193,000 versus 377,000 

units) would have been eligible in the full-restoration scenario than in the no-restoration 

scenario; this translated into a 28-percentage point increase in the participation rate (29 to 57 

percent). The remainder of the positive change would have occurred among LPR/other 

noncitizen units with children; the number would have increased by 70,000 units (from 45,000 to 

 — —30 
115,000 units); and the eligibility rate would have increased by more than 2.5 times, jumping 

from 24 to 62 percent. 

The number of mixed-eligibility units would have been 550,000 lower in the fullrestoration simulation than in the no-restoration simulation in 2004. The overwhelming majority 

of this change took place in LPR/citizen units with children; there was a difference of 515,000 

units (a decline from 620,000 to 105,000 units) between the two simulations, and the mixedeligibility rate declined 50 percentage points (from 61 to 11 percent). The number of units 

receiving food stamps would have increased by 220,000 units overall, and as with the changes in 

eligibility and mixed eligibility, two unit types were responsible for all the increase. About 

158,000 more childless LPR/other noncitizen units (270,000 versus 112,000 units) would have 

received food stamps in the full-restoration simulation than in the no-restoration simulation; the 

corresponding rate change was 14 percentage points (from 58 to 72 percent). Legal noncitizen 

units with children were responsible for the rest of the change: their numbers would have 

increased by 62,000 units (from 30,000 to 92,000), and their participation rate would have 

increased from 66 percent to 80 percent. 

The 2004 individual-level estimate of the change in LPR participation from a fullrestoration scenario was slightly higher than in 2003, but the change in eligibility was about the 

same. In 2004, a full restoration would have made 1.56 million more LPRs—1.36 million more 

adults and 199,000 more children—eligible than if the LPR restrictions had remained in place 

(table 17). An estimated 1.2 million additional eligible LPRs would have participated in the FSP 

had all LPR eligibility restrictions been removed in 2004; in 2003, the increase in participation 

would have been 1.1 million. 

 — —31 
Comparison between Farm Bill and full-restoration simulations. While the increase in 

food stamp eligibility and participation at the unit level from the Farm Bill restorations was 

notable, the impact still fell substantially short of the change that would have occurred had a full 

restoration been enacted. In 2003 (using the no-restoration scenario as the comparison point), at 

the unit level, the Farm Bill’s implementation only allowed 35 percent of the increases in 

eligibility and participation that would have occurred had there been a full restoration. When the 

remainder of the restoration was phased in (or at least became visible in our data) in 2004, the 

gap between simulations narrowed significantly. In 2004, the Farm Bill restorations extended 

eligibility to 65 percent of those units that would have been affected by a full restoration, while 

the effect on participation was 63 percent of that which would have occurred had there been a 

full restoration. 

At the individual level, the Farm Bill restorations filled about two-thirds of the gap in 

eligibility between the welfare reform law rules—without any restorations—and a full 

restoration to all LPRs regardless of length of U.S. residency. In 2003, the Farm Bill restored 

eligibility to 835,000 people, about half (53 percent) of all the LPRs that would have had 

eligibility restored by a full restoration (1.56 million people). In 2004, the share of LPRs with 

eligibility restored by the Farm Bill provisions rose to two-thirds (66 percent): 1.03 million 

versus 1.56 million in the full-restoration scenario. 

The full-restoration scenario also would have resulted in significantly higher median 

benefits for eligible families than did the Farm Bill restorations. In 2003, LPR/other noncitizen 

units with children would have been eligible for $1,352 more in annual food stamp benefits, 

LPR/citizen units with children for $722 more annually, and childless LPR/citizen units for $161 

more in the full-restoration scenario than they would have been without any restoration; these 

 — —32 
changes in benefit levels were all substantially larger than the changes observed when comparing 

the partial Farm Bill restorations to the no-restoration scenario (table 18). 

The same pattern held in 2004: LPR/other noncitizen units with children were eligible for 

$1,345 more in annual food stamp benefits in the full-restoration than in the no-restoration 

simulation, LPR/citizen units for $833 more, and childless LPR/citizen units for $516 more. 

These average benefit increases were all substantially higher than in the comparison between the 

Farm Bill restoration and no-restoration scenarios. 

Trends between 1999–2000 and 2003–04 

During the period of the study, eligibility rose for LPR/other noncitizen units but did not rise 

significantly for other unit types. The eligibility rate for LPR/other noncitizen units with children 

rose from 42 percent in 1999–2000 (table 13) to 52 percent in 2003–04 (table 12). LPR/other 

noncitizens are the group for which PRWORA’s restrictions on legal immigrant eligibility have 

had the greatest impact in terms of eligibility. The eligibility rate for undocumented/citizen units 

also rose, from 82 to 85 percent, over this period. Undocumented/citizen units have the lowest 

incomes of any group, and noncitizen eligibility restrictions do not apply to them since all the 

units have citizen members (who are usually children). The eligibility rate for LPR/citizen units 

with children actually declined slightly during this period (from 62 to 60 percent), a finding that 

is counterintuitive but can be explained by the fact that the restorations resulted in increased 

countable income for many adults whose eligibility was restored. 

The Farm Bill restorations had more of an impact on the eligibility of low-income units 

without children than on units with children, as measured by the changes in eligibility rates 

among the affected groups between 1999–2000 and 2003–04. In 1999–2000, 33 percent of 

 — —33 
childless LPR/citizen units were FSP eligible (table 13); this figure climbed to 43 percent by 

2003–04 (table 12), an increase of 10 percentage points. Similarly, in 1999–2000 just 28 percent 

of LPR/other noncitizen units were eligible, but this figure increased by 17 percentage points to 

45 percent in 2003–2004. The corresponding changes in eligibility for units with children were -

2 percentage points for LPR/citizen units and +10 percentage points for LPR/other noncitizen 

units during the same period. 

The Farm Bill restorations had a very large impact on mixed-eligibility rates over time, 

particularly among units with children. In 1999–2000, 60 percent of LPR/citizen units with 

children were mixed eligible; by 2003–04, this figure had dropped to 28 percent. During the 

same period, the mixed-eligibility rate for LPR/other noncitizen units with children decreased 

from 76 percent to 51 percent. The mixed eligibility rate for refugee units with children declined 

from 30 percent to 7 percent, but this change was not a result of the restorations. Changes in 

mixed-eligibility rates among childless units that contained noncitizens were more modest. The 

largest decline in mixed eligibility for childless units occurred among LPR/citizen units: from 45 

percent to 35 percent. The mixed-eligibility rate for LPR/other noncitizen units without children 

decreased more modestly (from 19 percent to 17 percent), as did the rate for refugee units (from 

13 percent to 11 percent). 

Overall, 57 percent of eligible low-income units participated in the FSP in 2003–04, up 

from 51 percent in 1999–2000. Food stamp participation rates were considerably higher for 

eligible units with children (72 percent) than those without children (46 percent) in 2003–04. 

This was also true in 1999–2000, when 61 percent of eligible units with children versus 42 

percent of units without children participated. 

 — —34 
Among units with children, all-citizen units had the highest participation rate in 2003–04 

(81 percent), followed by units without any citizen members (74 percent) and refugee units (62 

percent). Participation rates for LPR/citizen units and undocumented/citizen units were markedly 

lower, at 47 and 36 percent, respectively. All-citizen units had the highest participation rate in 

1999–2000 as well (68 percent), but this was 13 percentage points lower than the corresponding 

figure for 2003–04. Refugee units participated at a rate of 52 percent in 1999–2000, a figure 10 

percentage points lower than the 2003–04 rate. LPR/other noncitizen units had a 48 percent 

participation rate in 1999–2000, followed by LPR/citizen units (36 percent) and 

undocumented/citizen units at 24 percent. The participation rates for these three groups were 26, 

11, and 12 percentage points higher, respectively, in 2003–04 than in 1999–2000. 

Childless units had lower participation rates: only 46 percent of low-income eligible allcitizen units participated in 2003–04. This rate was only slightly higher than the 1999–2000 

participation rate of 42 percent among childless units. Refugee units had the highest participation 

rate among childless units in 2003–04 (80 percent), followed by LPR/other noncitizen units (57 

percent) and LPR/citizen units (53 percent). This was the same ordering as in 1999–2000, when 

71 percent of childless refugee units, 61 percent of LPR/other noncitizen units, and 53 percent of 

LPR/citizen units participated in the FSP.

Overall, in 2003–04 mixed-eligibility units participated in the FSP at lower rates than 

units where everyone was eligible (42 percent versus 59 percent). This finding suggests, again, 

that mixed-eligible units may be less likely to participate because they anticipate lower benefits. 

Alternatively, noncitizen units with eligible children and ineligible adults may not realize that the 

children are eligible. Noncitizen adults in these units may be deterred from participating for other 

reasons, such as fear of immigration consequences. This may explain why the participation rate 

 — —35 
is lower for mixed-citizenship units with children than for units without children, in which there 

is always at least one eligible adult. 

Decomposition of FSP Participation Trends 

Decomposition of the change in participation among eligible units with children allows us to 

separate the effects of the changes in mixed eligibility and unit type from the changes in use rates 

within each category. The unit-type effect is negative (-1.8 percent), while the mixed-eligibility 

effect is positive but extremely small (0.1 percent): the combination of both these effects reduces 

the overall participation rate (table 20). The use-rate effect, which is positive, shows the change 

in the participation rate with unit type and mixed eligibility standardized. This can be thought of 

as the “true” change in the participation rate—what the change would have been without the 

changes in the distribution among unit types and the mixed-eligibility rates. 

The most important trend is the trend toward the larger share of noncitizen units—from 

20 to 24 percent between 1999–2000 and 2003–04 (table 19). Since noncitizen units participate 

at lower rates than citizen units, their increased share of the total eligible population brought 

down the trends in participation. Without this increase in the share of noncitizen units, FSP 

participation would have increased 12.9 percentage points, instead of the actual 11.3 percentage 

points (table 20). 

The use rate effect thus accounts for 115 percent of the observed change, while the 

change in unit types accounts for -16 percent and the change in mixed eligibility accounts for +2 

percent. To put things another way, the increase in the FSP participation rate for low-income 

eligible units would have been 15 percent larger if it were not for the other two effects. Thus, 

examining changes in the participation rate without standardizing for the unit type and mixed-

 — —36 
eligibility effects may understate the impact of policy changes that have encouraged and 

increased FSP participation in recent years. Further, our decomposition results suggest that the 

growing share of units including ineligible noncitizens is significantly slowing the rate of 

increase in overall FSP participation. A full restoration of LPR eligibility, as in our alternative 

simulation, would likely further increase FSP participation overall. 

Regression Analysis of Food Stamp Participation among Eligible Units 

Regression Analysis of Food Stamp Participation for 2003–04 

We conducted logistic regression to explain the various factors affecting food stamp participation 

in 2003–04. For our regression models we limited the sample to low-income units that were 

eligible for the FSP according to the TRIM3 baseline simulations. The dependent variable in all 

models was FSP participation during any month in 2003–04. 

The regressions consisted of four models, each building on the previous model. In the 

first model, we considered only the citizenship and legal status of the members of eligible food 

stamp units. We used the same citizenship and legal status categories that we use throughout this 

report but also subdivided some categories into mixed-status versus all-eligible units. The result 

was a nine-category classification: 

1. All-citizen units where all members were eligible (the reference group) 

2. All-citizen units with mixed eligibility 

3. LPR/citizen units with all members eligible 

4. LPR/citizen units with mixed eligibility 

5. LPR/other noncitizen units with all members eligible 

6. LPR/other noncitizen units with mixed eligibility 

7. Refugee units with all members eligible 

8. Refugee units with mixed eligibility 

9. Undocumented/citizen units with mixed eligibility5

 

5

 There are no units composed of both undocumented and citizen members that are all eligible for the FSP because 

undocumented immigrants are ineligible for the program. 

 — —37 
Model 1 results suggest that noncitizen units—with the exception of refugee units—

generally had lower participation rates than all-citizen units in 2003–04 (table 21). Three types of 

units that contained noncitizens had lower FSP participation than all-citizen units where 

everyone was eligible: LPR/citizen units with mixed eligibility (odds ratio of 0.499), LPR/citizen 

units with all members eligible (odds ratio of 0.725), and undocumented/citizen units with mixed 

eligibility (odds ratio of 0.396). All-citizen units with mixed eligibility also had lower odds of 

participation (0.718) than citizen units where everyone was eligible. Thus, the lowest 

participation rate occurred among undocumented/citizen units, possibly because undocumented 

immigrants are most likely to be fearful of participating in the FSP and least likely to know about 

the program or its eligibility rules. 

By contrast, refugee units with all members eligible were more likely to participate than 

all-citizen units (odds ratio of 1.780). Mixed-eligible refugee units were less likely to participate 

than all-citizen, all-eligible units, but the odds ratio for this group was not statistically 

significant. It is not surprising that all-eligible refugee units participated at higher rates, 

considering they are resettled with government assistance and often remain linked to federally 

funded social service agencies—for instance for employment and education services—during 

their first several years in the United States. 

In model 2, we controlled for a number of unit characteristics that might influence FSP 

participation, and the inclusion of these controls further widened gaps in participation among 

units with different legal status and mixed-eligibility configurations. Our second model took into 

account such characteristics as TANF and SSI receipt, the amount of earned income, the amount 

of food stamp benefits for which the unit was eligible, the presence of children and elders in the 

unit, and whether the unit was a single-parent unit. When controlling for these characteristics, 

 — —38 
four of the six noncitizen units with statistically significant coefficients were less likely to 

participate than all-citizen fully eligible units, and by wider margins than in the first model 

without the controls. Between the first and second models, odds ratios fell for LPR/citizen units 

with mixed eligibility (from 0.499 to 0.256), refugee units with mixed eligibility (from 0.800 to 

0.263—the odds ratio in model 1 was not statistically significant), and undocumented/citizen 

units with mixed eligibility (from 0.396 to 0.239). The odds ratio also fell for LPR/citizen units 

where all members were eligible (from 0.725 to 0.410). The two remaining noncitizen groups 

with statistically significant coefficients were LPR/other noncitizen units, both the mixed- and 

all-eligible categories. Both these groups were more likely to participate than the reference group 

in model 1 (although neither coefficient was statistically significant in model 1), and they 

became even more likely than all-citizen all-eligible units to participate in model 2. The odds 

ratio for LPR/other noncitizen units with mixed eligibility increased from 1.36 to 1.61, and the 

odds ratio for all-eligible LPR/other noncitizen units increased from 1.04 to 1.466.

The results of model 2 suggest that most types of noncitizen units—including 

LPR/citizen units with either mixed or universal eligibility—are less likely to participate in the 

FSP, even when controlling for receipt of other benefits, the amount of benefits for which they 

are eligible, and other factors. These results suggest that other explanations beyond benefit 

allocations and unit economic circumstances may be driving their participation rates lower. 

These other factors may include fears about immigration consequences of benefit receipt, 

misunderstandings about program rules—notwithstanding any outreach about the restorations—

and language or cultural barriers (Holcomb et al. 2003).

In model 2, the only groups with higher participation rates than fully eligible all-citizen 

units were LPR/other noncitizen units with mixed eligibility (odds ratio 1.608), LPR/other 

 — —39 
noncitizen units with all members eligible (odds ratio 1.466), and refugee units with all members 

eligible (odds ratio 1.334). 

In model 3, we added a group of state-related variables representing whether the unit 

members resided in one of the four states with the largest immigrant populations (California, 

New York, Florida, and Texas) and interacted these four states with the legal status and mixedeligibility configurations in the previous models. The New York and Florida variables had 

virtually no impact on the model, so we omitted them from the final version.6

 

The most notable finding in model 3 was that undocumented/citizen units in California 

were considerably more likely to participate than undocumented/citizen units in the other 48 

states and the District of Columbia. The participation odds of undocumented/citizen units were 

2.8 times as high in California as in the other 48 states plus the District of Columbia.7 The 

difference in California is particularly striking because it does not seem to be due to higher 

participation across all groups: the odds of participation among the reference group, all-citizen 

units with universal eligibility, were lower in California (0.265) than in the rest of the country. 

Further, once units living in California and Texas were excluded, the odds ratio for 

undocumented/citizen units versus all-citizen all-eligible units living in the other states dropped 

to 0.149. This finding suggests that there must have been factors in the policy environment in 

California that encouraged units with undocumented adults and citizen children to participate at 

greater rates than elsewhere in the United States. The large size and relative longevity of the 

undocumented—mostly Mexican-origin—population in these two states may be part of the 

 

6

 We also introduced into the model a variable controlling for residence in a state with a state-funded program to 

provide food stamps to legal immigrants who were ineligible for the FSP because of PRWORA restrictions. The 

impact of these variables did not differ much from the impact of the set of variables for California, because 

California was by far the largest of the states that provided state-funded benefits. 

 — —40 
explanation. For instance, food stamp offices in California may have been more likely than 

offices in other states to provide Spanish-language interpretation and to explain the rules 

surrounding FSP eligibility and potential immigration consequences to their clients. 

Other statistically significant findings in model 3 were that eligible LPR/citizen units 

with mixed eligibility in Texas were 1.8 times more likely than those in the other 48 states and 

the District of Columbia to participate in the FSP. Also, LPR/other noncitizen units where 

everyone is eligible in California were considerably less likely than their counterparts in the 

other states (excluding Texas) to participate (odds ratio of 0.12). Inserting the state-level controls 

also heavily influenced the coefficient for LPR/other noncitizen units overall, making the odds 

ratio 2.5 times higher than that for all-citizen, all-eligible units. 

Finally, in model 4, we controlled for the effects of state-level economic conditions 

(unemployment and median income) and immigrant-related demographic traits (foreign-born 

population share and growth). This final step had a negligible effect on the model; the 

coefficients for each new variable were small, and the odds ratios were very close to unity. The 

coefficients and odds ratios for the unit citizenship/legal status terms and the interaction terms 

for California and Texas were barely affected by the introduction of these new controls. This 

suggests that the differences in results between California and the rest of the country were driven 

by FSP policy and program administration differences, rather than measured demographic or 

economic differences. Further, our overall results showing lower program participation among 

units with noncitizen than all-citizen members—with the exception of refugees—were not 

strongly influenced by economic differences among the states. 

 7

 The odds ratios in California and Texas were calculated using the formula exp(β2 + β12), where β2 is the coefficient 

of the state residency (CA or TX) variable and β12 is the coefficient of the undocumented citizen unit with mixed 

eligibility × state residency interaction term. 

 — —41 
In sum, undocumented/citizen status (with mixed eligibility) exerted the largest 

downward push on overall participation, but in California, such units were significantly more 

likely to participate in the FSP than their counterparts in other states. LPR/citizen units—those 

most likely to be affected by the Farm Bill restorations—were also less likely to participate than 

all citizen all-eligible units (odds ratio of 0.361 in model 4), all else equal. But this phenomenon 

was not true in Texas, where such units were more likely to participate than those in the other 48 

states and the District of Columbia (odds ratio of 1.6 in model 4). 

Regression Analysis Results for 1999–2000 versus 2003–04 

This second set of regressions (table 22) is similar but includes data from two periods (1999–

2000 and 2003–04) and a coefficient (t2) to describe differences between these two periods. 

In the first model, we considered the legal status and mixed eligibility characteristics of 

eligible food stamp units during 1999–2000 and 2003–04 and included interactions between 

these characteristics and the second period (t2). Controlling for the period did not change most of 

the participation patterns that were observed in the previous regressions. As before, 

undocumented/citizen units with mixed eligibility (odds ratio of 0.296), LPR/citizen units with 

mixed eligibility (odds ratio of 0.569) and LPR/citizen units in which all members were eligible 

(odds ratio of 0.554) were all less likely to participate in the food stamp program than all-citizen 

units where all members are eligible, with undocumented/citizen units with mixed eligibility the 

least likely to participate among these groups. Also as earlier in the single point in-time 

regressions, refugee units with all members eligible (odds ratio of 1.463) and legal/noncitizen 

units with all members eligible (odds ratio of 1.434) were more likely than all citizen, all eligible 

units to participate in the FSP in the two-period regression. 

 — —42 
The incorporation of interactions between our citizenship/legal status groups and time 

shows some significant upward trends for certain groups. For instance, undocumented/citizen 

units with mixed eligibility were much more likely to receive food stamps in 2003–04 than in 

1999–2000 (odds ratio of 1.7).8

 The same was true for LPR/citizen units with all members 

eligible, whose participation odds increased by 69 percent between the two periods. The 

participation odds for LPR/other noncitizen units with all members eligible, on the other hand, 

decreased slightly, by 6 percent. The reduction in participation among LPR/other noncitizens 

would seem to contradict the positive impact of the Farm Bill restorations; however, other 

characteristics were not taken into account in this first regression model. 

Our second model took into account various other characteristics, such as whether the 

unit received TANF or SSI and whether the unit was headed by a single parent. Once these 

factors were controlled for, the trends observed in model 1 became even more pronounced; 

positive coefficients tended to become more positive, while negative coefficients became more 

negative. The odds ratios for LPR/other noncitizen units with mixed eligibility (0.609), 

LPR/citizen units with mixed eligibility (0.365), undocumented/citizen units with mixed 

eligibility (0.244), and legal citizen units with all members eligible (0.540) all decreased; the 

odds ratio for LPR/other noncitizen units with all members eligible jumped to 2.203, up from 

1.434. The time effect also became more prominent, the odds ratio increasing from 1.293 to 

1.479. No legal status by time interaction was statistically significant (at the 5 percent level) in 

both models 1 and 2, but the odds ratio for mixed-eligible LPR/other noncitizen units in 2003–04 

increased from 1.561 to 2.994; this trend makes sense in the context of the restorations. The odds 

 

8

 This odds ratio was calculated using the formula exp(β2 + β12), where β2 is the coefficient of the second period (t2) 

variable and β12 is the coefficient of the undocumented/citizen mixed eligibility × t2 interaction term. 

 — —43 
ratio for all-eligible LPR/other noncitizen units actually decreased from 0.727 to 0.632 between 

models 1 and 2. Both model 1 terms were statistically significant at reasonable levels (11 and 8 

percent, respectively), and both terms were statistically significant at the 5 percent level or less in 

model 2. It is also worth mentioning how heavily TANF and SSI participation affected the 

tendency of a unit to participate; the odds ratios for both terms exceeded 7. 

The third model introduced terms to account for the interactions between state, legal 

status/mixed eligibility and period (t2). As in model 3 of the 2003–04 regressions, 

undocumented/citizen units with mixed eligibility in California were more likely to receive food 

stamps than similar units in the rest of the country. However, the odds ratio of 

undocumented/citizen units with mixed eligibility in California relative to undocumented/citizen 

units with mixed eligibility in other states went down considerably once the time interaction term 

was introduced. In the regressions for 2003–04 only, this odds ratio was 2.81, but when period 

was controlled for, it decreased to 1.16.9

 Texas experienced the opposite effect: in the 2003–04 

regressions, undocumented/citizen units were slightly less likely to participate than those in the 

other states (excluding California), with an odds ratio of 0.964. Once period was controlled for, 

the odds ratio for such units increased to 1.59. 

The most significant finding in model 3 was that undocumented/citizen units with mixed 

eligibility in California were much more likely to receive food stamps in 2003–04 than they were 

in 1999–2000: the odds of undocumented/citizen units with mixed eligibility in California 

receiving food stamps during 2003–04 were 6.8 times greater than the odds of 

undocumented/citizen units with mixed eligibility in California receiving food stamps in 1999–

 

9

 Both these odds ratios were calculated using the formula exp(β2 + β12), where β2 is the coefficient of the California 

resident variable and β12 is the coefficient of the undocumented citizen unit with mixed eligibility × California 

interaction term. 

 — —44 
2000.10 It could be that extensive outreach, funded during the implementation of California's 

Healthy Families/Medi-Cal for Children expansion, resulted in the enrollment of many citizen 

children in undocumented families in other benefits such as food stamps. Starting in 2001, 

California created its Certified Application Assistance program and also made numerous 

significant grants to community based organizations—including many in immigrant 

communities—to enroll people in Healthy Families (California's State Children’s Health 

Insurance Program) and Medi-Cal (Hill and Hawkes 2002). It is possible that these efforts to 

enroll citizen children in health insurance may have also helped fuel FSP enrollment. 

No such comparison could be made in Texas, since none of the three-way interactions 

between state, unit legal status, and time were statistically significant in this model. 

Another important finding was the fact that mixed-eligible LPR/other noncitizen units in 

2003–04 were considerably more likely than their 1999–2000 counterparts to receive food 

stamps (odds ratio 2.04), meaning such units participate at higher rates following the 

restorations, even after controlling for residence in California, Texas, or the rest of the country.11

As in the 2003–04 regressions, the introduction of state-level variables to control for economic 

conditions and the growth and size of the foreign-born population in model 4 had very little 

effect on the results, once again indicating that overall economic conditions did not strongly 

influence the changes in food stamp participation that we observed during 1999–2004. Instead, 

 

10 This odds ratio was calculated using the formula exp(β3 + β13 + β123), where β3 is the coefficient of the second 

period (t2) variable, β13 is the coefficient of the undocumented citizen unit with mixed eligibility × t2 interaction 

term, and β123 is the coefficient of the undocumented citizen unit w/mixed eligibility × California × t2 interaction 

term. 

11 This odds ratio was calculated using the formula exp(β2 + β12), where β2 is the coefficient of the second period (t2) 

variable and β12 is the coeffienct of the LPR/other noncitizen mixed-eligible × t2 interaction term. 

 

 — —45 
the Farm Bill restorations along with FSP policy changes to simplify procedures appear to have 

accounted for most of the increase in participation among the eligible population. 

Conclusion 

The Farm Bill restorations represented a major reversal of the policy of restricting legal 

immigrants’ eligibility for public benefits that was legislated by the 1996 welfare reform law. 

Estimates by the Food and Nutrition Service before the Farm Bill’s implementation suggested 

that about 400,000 legal immigrants would become eligible and participate in the Food Stamp 

Program on account of the restorations. Our estimates, based on eligibility simulations using 

TRIM3, are that about 1 million LPRs became eligible on account of the restorations in 2004. 

We also estimate that about three-quarters of the LPRs made eligible by the restorations 

participated in the FSP in 2004. The number of newly participating individuals (779,000) was 

almost twice the original estimate by FNS (400,000). 

At the family level, the restorations’ impact appears to be smaller—just 140,000 more 

family units were eligible under the restorations than would have been eligible otherwise. This is 

because about half the LPRs whose eligibility was restored lived in mixed-eligible units, where 

at least one family member would have been eligible even without restorations. In other words, 

about half the impact of the restorations resulted from increases in the number of family units 

that were eligible, while the other half resulted from increases in the number of eligible LPRs 

within already-eligible families. In fact, one of the most important impacts of the restoration was 

to increase the amount of benefits for which LPR families were eligible. In 2004, for instance, 

the average family with children that included both LPRs and citizens was eligible for $662 more 

in annual food stamp benefits with the restorations than without them. Thus, the restorations 

 — —46 
increased the amount of assistance to many citizen children living in families with noncitizen 

adults. 

Our simulations may somewhat overestimate the impact of the Farm Bill restorations 

because we did not model sponsor deeming rules, but the degree of overestimation is likely to be 

minimal. Deeming rules only apply to immigrants admitted to the United States after December 

1997, when legally binding affidavits of support took effect. By 2003 and 2004, very few LPRs 

had been in the country since December 1997 and accumulated five years of U.S. residency, 

enough to qualify for the largest of the Farm Bill restorations. In addition, if recent estimates by 

Mathematic Policy Research are correct, then only up to 30 percent of low-income LPRs who 

entered the United States after December 1997 are potentially subject to sponsor-deeming rules 

because they have sponsors living outside their households. If some LPRs qualified for and took 

the indigent exemption, then the potential reduction in the number of eligible LPRs due to 

deeming would be even smaller. Better understanding of how states apply sponsor deeming 

rules, and how information from the CPS and other data sources can be used to distinguish those 

subject to sponsor deeming from those exempt from it, would improve our ability to estimate the 

impact of the remaining restrictions on noncitizen eligibility for the FSP. 

Our eligibility models also did not consider state-level programs that replaced federallyfunded food stamps with comparable state-funded benefits. In 2002, before the restorations, eight 

states extended food stamps or similar benefits to all or virtually all LPRs ineligible for the 

federal FSP: California, Connecticut, Maine, Massachusetts, Minnesota, Nebraska, Washington, 

and Wisconsin. Six other states had more limited programs. California’s program alone served 

over 90,000 people and cost over $6 million monthly (Schwartz and Haywood 2002). By 2004, 

only six states still had major replacement programs, and one state had a more limited program; 

 — —47 
California’s program participation dropped to 20,000 a month (Food and Nutrition Service 

2004). Many states dropped or scaled back their programs following the restorations. As a result, 

the restorations also significantly affected the budgets of several states by lowering the number 

of LPRs receiving state-funded benefits. 

Notwithstanding the nuances of deeming rules and state-funded programs, the Farm Bill 

restorations still left a significant group of LPRs (about 500,000) ineligible for the FSP. By 2004, 

the restorations had affected about two-thirds of all the LPRs rendered ineligible by the 1996 

welfare reform law rules and not covered by the restorations in 1998. All LPR children became 

eligible for the program regardless of length of residency—a broader eligibility rule than for 

TANF, Medicaid, or State Children’s Health Insurance Program—but LPR adults who were 

sponsored or lived in the United States for less than five years remained ineligible unless they 

entered as refugees, were granted asylum, had military service, worked 40 quarters, or met other 

limited exceptions. 

A full restoration to all LPR adults would thus result in a substantial further increase in 

FSP participation. A full restoration would also, like the Farm Bill restoration, further increase 

the benefit amounts available to support U.S. citizen children in many immigrant families. In 

fact, our estimate is that a restoration to all LPR adults would have increased the average annual 

benefit for families with LPR adults and U.S. citizen children by $833, versus $622 for the Farm 

Bill restorations as implemented. Thus, the Farm Bill restored about three-quarters of the average 

benefits lost by U.S. citizen children in these mixed-status families. 

Finally, it is worth noting that the Farm Bill restorations were implemented during great 

increases in food stamp participation overall. In most states, there were significant eligibility 

expansions—including transitional eligibility from TANF and reductions in vehicle and other 

 — —48 
resource limitations—between 1999 and 2004, the period of the study. There were also many 

different simplification and outreach efforts that increased participation among eligible families 

during this time (Food and Nutrition Service 2004). These efforts, alongside economic changes, 

resulted in a substantial expansion of the FSP overall: an increase in total participation of about 

50 percent between fiscal years 2000 and 2005. Our estimate is that the participation rate among 

eligible low-income eligible families increased 11 percentage points between 1999 and 2004, 

and that this increase would have been 13 percentage points had the share of noncitizens among 

FSP-eligible families not been growing so quickly. In this context of a rapidly growing caseload, 

the Farm Bill restorations had an even greater impact than anticipated. 

 — —49 
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Requirements in the Food Stamp Program” (Letter to Food Stamp Program Regional 

Directors). Washington, DC: U.S. Department of Agriculture. Available at 

http://www.fns.usda.gov/fsp/rules/Legislation/2002_farm_bill/memo_non_citizen_elg03.

htm. 

———. 2004. Food Stamp Program State Options Report. 4th ed. Washington, DC: U.S. 

Department of Agriculture. 

———. 2008. “Food Stamp Program Participation and Costs” (Data as of March 26, 2008). 

Washington, DC: U.S. Department of Agriculture. Available at 

http://www.fns.usda.gov/pd/fssummar.htm. 

Giannarelli, Linda, Paul Johnson, Joyce Morton, and Laura Wheaton. 2001. “The TRIM3 

Microsimulation Model.” In Estimating Eligibility and Participation for the WIC 

Program, Phase I Report, edited by Michele Ver Ploeg and David M. Betson. 

Washington, DC: National Academy Press. 

Hill, Ian, and Corinna Hawkes. 2002. Congressionally Mandated Evaluation of the State 

Children’s Health Insurance Program Site Visit Report: The State of California’s 

 — —50 
Healthy Families Program. Washington DC: U.S. Department of Health and Human 

Services, The Office of the Assistant Secretary for Planning and Evaluation. 

Holcomb, Pamela, Robin Koralek, Karen Tumlin, Randy Capps, and Anita Zuberi. 2003. “The 

Application Process for Public Benefits: Complexities and Challenges Facing Immigrants 

and Limited English Speakers.” Washington, DC: U.S. Department of Health and Human 

Services, Assistant Secretary for Planning and Evaluation. 

Passel, Jeffrey S., and Rebecca Clark. 1998. “Identifying Legal and Illegal Immigrants in the 

Census and Current Population Surveys: A New Technique Based on the Occupational 

Distribution of Illegal Aliens—An Example Using Data from New York State.” 

Presented at the annual meeting of the Population Association of America. 

Passel, Jeffrey S., Jennifer Van Hook, and Frank D. Bean. 2004. “Estimates of Legal and 

Unauthorized Foreign-Born Population for the United States and Selected States, Based 

on Census 2000.” Report to the Census Bureau. Washington, DC: The Urban Institute. 

Available at http://www.sabresys.com/i_whitepapers.asp. 

Schwartz, Sonya, and Brad Haywood. 2002. “Opportunities to Maximize the Effects of 

Immigrant Restorations in the Food Stamp Reauthorization of 2002 by Preserving and 

Increasing State Food Stamp Replacement Programs for Immigrants.” Washington, DC: 

Food Research and Action Center. Available at 

www.frac.org/html_new/food_stamps/legal_immigrants/Opportunities.PDF. 

Wheaton, Laura, and Linda Giannarelli. 2000. “Underreporting of Means Tested Transfer 

Programs in the March CPS.” In Proceedings of the Section on Government Statistics and 

Section on Social Statistics. Alexandria, VA: American Statistical Association. 

Wolkwitz, Karen. 2007. “Trends in Food Stamp Participation Rates: 1999 to 2005.” (Report to 

USDA Food and Nutrition Service.) Washington, DC: Mathematica Policy Research, 

Inc. Available at 

http://www.fns.usda.gov/oane/menu/Published/FSP/FILES/Participation/Trends1999-

2005.pdf. 

 — —51 
Table 1.

Number of Units (Unweighted) 

by Income Level, Unit Legal Status, and Presence of Children: 

March 2004–05 CPS (Calendar Years 2003–04)

March 2004 CPS March 2005 CPS

US Units CA Units US Units CA Units

All

Lowincome AllLowincome AllLowincome AllLowincome

All Units 78,361 25,628 5,579 2,049 77,704 25,979 6,065 2,268

Units with Children 34,695 11,478 2,664 1,071 34,046 11,514 2,777 1,155

All Citizens 29,946 8,860 1,616 436 29,385 8,982 1,683 495

LPR/Citizen 2,525 1,215 649 358 2,532 1,196 681 365

Undocumented/Citizen 1,391 916 264 187 1,303 870 257 185

LPR/Other Noncitizen 205 132 44 33 197 124 51 34

All Undocumented 408 248 60 42 425 247 80 61

Refugee 220 107 29 15 205 95 26 14

Units without Children 43,666 14,150 2,915 978 43,658 14,465 3,289 1,114

All Citizens 40,534 12,759 2,342 692 40,471 13,112 2,676 814

LPR/Citizen 1,010 295 190 73 1,008 277 207 77

Undocumented/Citizen 142 65 31 10 151 68 25 12

LPR/Other Noncitizen 782 430 188 117 795 411 218 123

All Undocumented 1,027 516 139 74 1,034 508 140 80

Refugee 171 84 25 12 199 89 22 8

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL). 

See text for definitions of unit status types and eligibility definition.

A small number of units (three in 2003 and two in 2004) were unable to be 

classified into these groups and was excluded from these totals.

Status of Unit and Presence of 

Children

 — 52 — 
Table 2.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

Baseline Simulation

March 2004 CPS (Calendar Year 2003)

Units Eligible for 

FSP

Mixed-Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

units

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 37,228 19,783 53% 1,847 9% 10,668 54%

Units with Children 14,034 8,670 62% 1,413 16% 6,063 70%

All Citizens 10,587 6,536 62% 130 2% 5,189 79%

LPR/Citizen 1,650 996 60% 287 29% 457 46%

Undocumented/Citizen 1,144 974 85% 974 100% 312 32%

LPR/Other Noncitizen 182 65 36% 21 32% 43 66%

All Undocumented 333 0 -- 0 (x) 0 (x)

Refugee 139 98 70% 1 1% 62 63%

Units without Children 23,194 11,114 48% 433 4% 4,605 41%

All Citizens 21,063 10,497 50% 269 3% 4,288 41%

LPR/Citizen 469 207 44% 77 37% 94 45%

Undocumented/Citizen 89 31 35% 31 100% 10 32%

LPR/Other Noncitizen 686 315 46% 53 17% 166 53%

All Undocumented 752 0 -- 0 (x) 0 (x)

Refugee 135 63 46% 2 3% 47 75%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 53 — 
Table 3.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

All-LPRs-Eligible Simulation

March 2004 CPS (Calendar Year 2003)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

units

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 37,228 19,911 53% 1,649 8% 10,825 54%

Units with Children 14,034 8,722 62% 1,244 14% 6,137 70%

All Citizens 10,587 6,536 62% 130 2% 5,189 79%

LPR/Citizen 1,650 1,000 61% 124 12% 483 48%

Undocumented/Citizen 1,144 974 85% 974 100% 312 32%

LPR/Other Noncitizen 182 113 62% 14 12% 91 81%

All Undocumented 333 0 -- 0 (x) 0 (x)

Refugee 139 98 70% 1 1% 62 63%

Units without Children 23,194 11,190 48% 406 4% 4,688 42%

All Citizens 21,063 10,497 50% 269 3% 4,288 41%

LPR/Citizen 469 217 46% 58 27% 110 51%

Undocumented/Citizen 89 31 35% 31 100% 10 32%

LPR/Other Noncitizen 686 381 56% 45 12% 232 61%

All Undocumented 752 0 -- 0 (x) 0 (x)

Refugee 135 63 46% 2 3% 47 75%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 54 — 
Table 4.

Simulation of Low-Income Units Eligibility for and Receipt of Food Stamps, 

by Unit Legal Status and Presence of Children 

with No Legal Immigrant Restrictions Removed: 

March 2004 CPS (Calendar Year 2003)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

Units

Number 

(000s)

Pct. of

Eligibles

Number 

(000s)

Pct. of

Eligibles

All Units 37,228 19,668 53% 2,196 11% 10,586 54%

Units with Children 14,034 8,677 62% 1,762 20% 6,055 70%

All Citizens 10,587 6,536 62% 130 2% 5,189 79%

LPR/Citizen 1,650 1,022 62% 606 59% 467 46%

Undocumented/Citizen 1,144 974 85% 974 100% 312 32%

LPR/Other Noncitizen 182 44 24% 22 51% 25 55%

All Undocumented 333 0 -- 0 (x) 0 (x)

Refugee 139 100 72% 29 30% 63 63%

Units without Children 23,194 10,991 47% 435 4% 4,531 41%

All Citizens 21,063 10,497 50% 269 3% 4,288 41%

LPR/Citizen 469 203 43% 103 51% 94 46%

Undocumented/Citizen 89 31 35% 31 100% 10 32%

LPR/Other Noncitizen 686 202 29% 28 14% 95 47%

All Undocumented 752 0 -- 0 (x) 0 (x)

Refugee 135 57 42% 3 5% 44 77%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 55 — 
Table 5.

Simulated Differences in Low Income Units Eligible for and Receiving Food Stamps

between Baseline and No-Restoration Scenarios,

by Unit Legal Status and Presence of Children

March 2004 CPS (Calendar Year 2003)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving Food 

Stamps

Units 

(000s)

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. point 

change

All Units 37,228 87 0% -347 2% 71 0%

Units with Children 14,034 -26 0% -347 4% 0 0%

All Citizens 10,587 -- -- -- -- -- --

LPR/Citizen 1,650 -26 -2% -318 -30% (z) (z)

Undocumented/Citizen 1,144 -- -- -- -- -- --

LPR/Other Noncitizen 182 (z) (z) (z) (z) (z) (z)

All Undocumented 333 -- -- -- -- -- --

Refugee 139 (z) (z) -28 -28% (z) (z)

Units without Children 23,194 114 -1% 0 0% 71 0%

All Citizens 21,063 -- -- -- -- -- --

LPR/Citizen 469 (z) (z) -26 -13% (z) (z)

Undocumented/Citizen 89 -- -- -- -- -- --

LPR/Other Noncitizen 686 114 17% 26 3% 71 5%

All Undocumented 752 -- -- -- -- -- --

Refugee 135 (z) (z) (z) (z) (z) (z)

-- Zero.

(z) Change of less than 25,000 households

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 56 — 
Table 6.

Simulated Differences in Low Income Units Eligible for and Receiving Food Stamps

between All-LPRs-Eligible and No-Restoration Scenarios,

by Unit Legal Status and Presence of Children

March 2004 CPS (Calendar Year 2003)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving Food 

Stamps

Units 

(000s)

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. point 

change

All Units 37,228 248 -1% -555 3% 204 -1%

Units with Children 14,034 69 0% -510 6% 66 -1%

All Citizens 10,587 -- -- -- -- -- --

LPR/Citizen 1,650 (z) (z) -482 -47% (z) (z)

Undocumented/Citizen 1,144 -- -- -- -- -- --

LPR/Other Noncitizen 182 69 38% (z) (z) 66 25%

All Undocumented 333 -- -- -- -- -- --

Refugee 139 (z) (z) -28 -28% (z) (z)

Units without Children 23,194 180 -1% -45 0% 137 -1%

All Citizens 21,063 -- -- -- -- -- --

LPR/Citizen 469 (z) (z) -45 -24% (z) (z)

Undocumented/Citizen 89 -- -- -- -- -- --

LPR/Other Noncitizen 686 180 26% (z) (z) 137 14%

All Undocumented 752 -- -- -- -- -- --

Refugee 135 (z) (z) (z) (z) (z) (z)

-- Zero.

(z) Change of less than 25,000 households

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 57 — 
Table 7.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

Baseline Simulation

March 2005 CPS (Calendar Year 2004)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

eligible

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 38,635 20,056 52% 1,976 10% 12,083 60%

Units with Children 14,525 8,797 61% 1,429 16% 6,500 74%

All Citizens 11,055 6,632 60% 113 2% 5,487 83%

LPR/Citizen 1,656 990 60% 259 26% 485 49%

Undocumented/Citizen 1,131 969 86% 969 100% 381 39%

LPR/Other Noncitizen 186 126 68% 77 61% 99 78%

All Undocumented 359 0 -- 0 (x) 0 (x)

Refugee 137 81 59% 12 14% 48 60%

Units without Children 24,110 11,259 47% 547 5% 5,583 50%

All Citizens 22,001 10,651 48% 387 4% 5,184 49%

LPR/Citizen 438 179 41% 57 32% 110 61%

Undocumented/Citizen 106 41 39% 41 100% 26 64%

LPR/Other Noncitizen 665 290 44% 47 16% 182 63%

All Undocumented 759 0 -- 0 (x) 0 (x)

Refugee 141 98 69% 16 17% 81 83%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 58 — 
Table 8.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

All-LPRs-Eligible Simulation

March 2005 CPS (Calendar Year 2004)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

units

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 38,635 20,135 52% 1,739 9% 12,185 61%

Units with Children 14,525 8,790 61% 1,212 14% 6,510 74%

All Citizens 11,055 6,632 60% 113 2% 5,487 83%

LPR/Citizen 1,656 994 60% 105 11% 502 51%

Undocumented/Citizen 1,131 969 86% 969 100% 381 39%

LPR/Other Noncitizen 186 115 62% 14 12% 92 80%

All Undocumented 359 0 -- 0 (x) 0 (x)

Refugee 137 81 59% 12 14% 48 60%

Units without Children 24,110 11,346 47% 527 5% 5,676 50%

All Citizens 22,001 10,651 48% 387 4% 5,184 49%

LPR/Citizen 438 179 41% 36 20% 113 64%

Undocumented/Citizen 106 41 39% 41 100% 26 64%

LPR/Other Noncitizen 665 377 57% 47 12% 270 72%

All Undocumented 759 0 -- 0 (x) 0 (x)

Refugee 141 98 69% 16 17% 81 83%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 59 — 
Table 9.

Simulation of Low-Income Units Eligibility for and Receipt of Food Stamps, 

by Unit Legal Status and Presence of Children 

with No Legal Immigrant Restrictions Removed: 

March 2005 CPS (Calendar Year 2004)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

Units

Number 

(000s)

Pct. of

Eligibles

Number 

(000s)

Pct. of

Eligibles

All Units 38,635 19,890 51% 2,310 12% 11,940 60%

Units with Children 14,525 8,746 60% 1,751 20% 6,432 74%

All Citizens 11,055 6,632 60% 113 2% 5,487 83%

LPR/Citizen 1,656 1,020 62% 620 61% 486 48%

Undocumented/Citizen 1,131 969 86% 969 100% 381 39%

LPR/Other Noncitizen 186 45 24% 20 45% 30 66%

All Undocumented 359 0 -- 0 (x) 0 (x)

Refugee 137 81 59% 29 36% 48 60%

Units without Children 24,110 11,144 46% 559 5% 5,508 49%

All Citizens 22,001 10,651 48% 387 4% 5,184 49%

LPR/Citizen 438 165 38% 71 43% 105 64%

Undocumented/Citizen 106 41 39% 41 100% 26 64%

LPR/Other Noncitizen 665 193 29% 34 17% 112 58%

All Undocumented 759 0 -- 0 (x) 0 (x)

Refugee 141 93 66% 27 29% 79 85%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 60 — 
Table 10.

Simulated Differences in Low Income Units Eligible for and Receiving Food Stamps

between Baseline and No-Restoration Scenarios,

by Unit Legal Status and Presence of Children

March 2005 CPS (Calendar Year 2004)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving Food 

Stamps

Units 

(000s)

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. point 

change

All Units 38,635 148 0% -305 2% 139 0%

Units with Children 14,525 51 0% -305 4% 69 0%

All Citizens 11,055 -- -- -- -- -- --

LPR/Citizen 1,656 -30 -2% -361 -35% (z) (z)

Undocumented/Citizen 1,131 -- -- -- -- -- --

LPR/Other Noncitizen 186 81 44% 56 16% 69 13%

All Undocumented 359 -- -- -- -- -- --

Refugee 137 (z) (z) (z) (z) (z) (z)

Units without Children 24,110 97 0% 0 0% 70 0%

All Citizens 22,001 -- -- -- -- -- --

LPR/Citizen 438 (z) (z) (z) (z) (z) (z)

Undocumented/Citizen 106 -- -- -- -- -- --

LPR/Other Noncitizen 665 97 15% (z) (z) 70 5%

All Undocumented 759 -- -- -- -- -- --

Refugee 141 (z) (z) (z) (z) (z) (z)

-- Zero.

(z) Change of less than 25,000 households

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 61 — 
Table 11.

Simulated Differences in Low Income Units Eligible for and Receiving Food Stamps

between All-LPRs-Eligible and No-Restoration Scenarios,

by Unit Legal Status and Presence of Children

March 2005 CPS (Calendar Year 2004)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving Food 

Stamps

Units 

(000s)

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. 

point 

change

Absolute 

change 

(000s)

Pct. point 

change

All Units 38,635 227 -1% -550 3% 220 0%

Units with Children 14,525 43 0% -515 6% 62 -1%

All Citizens 11,055 -- -- -- -- -- --

LPR/Citizen 1,656 -26 -2% -515 -50% (z) (z)

Undocumented/Citizen 1,131 -- -- -- -- -- --

LPR/Other Noncitizen 186 70 38% (z) (z) 62 14%

All Undocumented 359 -- -- -- -- -- --

Refugee 137 (z) (z) (z) (z) (z) (z)

Units without Children 24,110 183 -1% -35 0% 158 -1%

All Citizens 22,001 -- -- -- -- -- --

LPR/Citizen 438 (z) (z) -35 -23% (z) (z)

Undocumented/Citizen 106 -- -- -- -- -- --

LPR/Other Noncitizen 665 183 28% (z) (z) 158 14%

All Undocumented 759 -- -- -- -- -- --

Refugee 141 (z) (z) (z) (z) (z) (z)

-- Zero.

(z) Change of less than 25,000 households

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 62 — 
Table 12.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

Baseline Simulation

Average of March 2004–05 CPS (Calendar Years 2003–04)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

units

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 37,932 19,920 53% 1,911 10% 11,376 57%

Units with Children 14,279 8,733 61% 1,421 16% 6,282 72%

All Citizens 10,821 6,584 61% 121 2% 5,338 81%

LPR/Citizen 1,653 993 60% 273 28% 471 47%

Undocumented/Citizen 1,137 972 85% 972 100% 347 36%

LPR/Other Noncitizen 184 96 52% 49 51% 71 74%

All Undocumented 346 0 -- 0 (x) 0 (x)

Refugee 138 89 65% 6 7% 55 62%

Units without Children 23,652 11,186 47% 490 4% 5,094 46%

All Citizens 21,532 10,574 49% 328 3% 4,736 45%

LPR/Citizen 453 193 43% 67 35% 102 53%

Undocumented/Citizen 98 36 37% 36 100% 18 50%

LPR/Other Noncitizen 676 303 45% 50 17% 174 57%

All Undocumented 756 0 -- 0 (x) 0 (x)

Refugee 138 80 58% 9 11% 64 80%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 2003–04,

which are based on March 2004 and 2005 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

Status of Unit and Presence of 

Children

 — 63 — 
Table 13.

Low-Income Units Eligible for and Receiving Food Stamps, 

by Unit Legal Status and Presence of Children 

Baseline Simulation

Average of March 2000–01 CPS (Calendar Years 1999–2000)

Units Eligible for 

FSP

Mixed Eligibility 

Units

Units Receiving 

Food Stamps

Units 

(000s)

Number 

(000s)

Pct. of

units

Number 

(000s)

Pct. of

eligibles

Number 

(000s)

Pct. of

eligibles

All Units 35,441 18,090 51% 1,668 9% 9,210 51%

Units with Children 13,576 8,414 62% 1,396 17% 5,102 61%

All Citizens 10,802 6,706 62% 134 2% 4,538 68%

LPR/Citizen 1,428 890 62% 532 60% 323 36%

Undocumented/Citizen 794 649 82% 649 100% 156 24%

LPR/Other Noncitizen 161 68 42% 52 76% 33 48%

All Undocumented 230 0 -- 0 (x) 0 (x)

Refugee 161 100 62% 30 30% 52 52%

Units without Children 21,865 9,676 44% 272 3% 4,108 42%

All Citizens 20,013 9,249 46% 136 1% 3,856 42%

LPR/Citizen 382 125 33% 57 45% 67 53%

Undocumented/Citizen 87 33 38% 33 100% 13 39%

LPR/Other Noncitizen 629 174 28% 34 19% 105 61%

All Undocumented 576 0 -- 0 (x) 0 (x)

Refugee 178 94 53% 12 13% 67 71%

-- Zero.

(x) Not applicable.

Source: Urban Institute tabulations from TRIM3 baseline simulations for calendar years 1999–2000,

which are based on March 2000 and 2001 CPS data with Urban Institute assignments of legal status.

Notes: Low-income units are those with incomes below 200 percent of the federal poverty level (FPL).

See text for definitions of unit status types and eligibility definition.

A small number of units (less than 10,000) were unable to be 

classified into these groups and was excluded from these totals.

Status of Unit and Presence of 

Children

 — 64 — 
Table 14:

Universe: Individuals Whose Eligibility Changed due to the Restorations

Overall Figures

Eligibility Transition

Category

Total Net Newly Eligible Individuals 834,768 100%

 Individuals in units that...

Became Eligible at All 354,840 42.5%

Became Fully Eligible 470,559 56.4%

Remained Mixed 104,077 12.5%

 Individuals Who Lost Eligibility 94,708 -11.3%

Total New Recipients 520,884 62.4%

Adults (Age 18 and Up)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 814,550 100%

 Individuals in units that...

Became Eligible at All 282,823 34.7%

Became Fully Eligible 450,308 55.3%

Remained Mixed 101,673 12.5%

 Individuals Who Lost Eligibility 20,254 -2.5%

Total New Recipients 463,689 56.9%

Children (Under Age 18)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 20,218 100%

 Individuals in units that...

Became Eligible at All 72,017 356.2%

Became Fully Eligible 20,251 100.2%

Remained Mixed 2,404 11.9%

 Individuals Who Lost Eligibility 74,454 -368.3%

Total New Recipients 57,195 282.9%

Number of 

Individuals

Percent of Newly 

Eligible

Food Stamp Unit Eligibility Transitions, 2003 (Baseline versus No Restoration)

Number of 

Individuals

Percent of Newly 

Eligible

Number of 

Individuals

Percent of Newly 

Eligible

 — 65 — 
Table 15:

Universe: Individuals Whose Eligibility Changed due to the Restorations

Overall Figures

Eligibility Transition

Category

Total Net Newly Eligible Individuals 1,562,556 100%

 Individuals in units that...

Became Eligible at All 761,478 48.7%

Became Fully Eligible 838,077 53.6%

Remained Mixed 71,448 4.6%

 Individuals Who Lost Eligibility 108,447 -6.9%

Total New Recipients 1,084,050 69.4%

Adults (Age 18 and Up)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 1,368,798 100%

 Individuals in units that...

Became Eligible at All 571,400 41.7%

Became Fully Eligible 750,854 54.9%

Remained Mixed 69,269 5.1%

 Individuals Who Lost Eligibility 22,725 -1.7%

Total New Recipients 878,264 64.2%

Children (Under Age 18)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 193,758 100%

 Individuals in units that...

Became Eligible at All 190,078 98.1%

Became Fully Eligible 87,223 45.0%

Remained Mixed 2,179 1.1%

 Individuals Who Lost Eligibility 85,722 -44.2%

Total New Recipients 205,786 106.2%

Number of 

Individuals

Percent of 

Newly Eligible

Food Stamp Unit Eligibility Transitions, 2003 (Full versus No Restoration)

Number of 

Individuals

Percent of 

Newly Eligible

Number of 

Individuals

Percent of 

Newly Eligible

 — 66 — 
Table 16:

Universe: Individuals Whose Eligibility Changed due to the Restorations

Overall Figures

Eligibility Transition

Category

Total Net Newly Eligible Individuals 1,034,079 100%

 Individuals in units that...

Became Eligible at All 528,414 51.1%

Became Fully Eligible 506,180 48.9%

Remained Mixed 124,947 12.1%

 Individuals Who Lost Eligibility 125,462 -12.1%

Total New Recipients 779,049 75.3%

Adults (Age 18 and Up)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 832,597 100%

 Individuals in units that...

Became Eligible at All 319,820 38.4%

Became Fully Eligible 457,807 55.0%

Remained Mixed 78,687 9.5%

 Individuals Who Lost Eligibility 23,717 -2.8%

Total New Recipients 538,096 64.6%

Children (Under Age 18)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 201,482 100%

 Individuals in units that...

Became Eligible at All 208,594 103.5%

Became Fully Eligible 48,373 24.0%

Remained Mixed 46,260 23.0%

 Individuals Who Lost Eligibility 101,745 -50.5%

Total New Recipients 240,953 119.6%

Number of 

Individuals

Percent of Newly 

Eligible

Food Stamp Unit Eligibility Transitions, 2004 (Baseline versus No Restoration)

Number of 

Individuals

Percent of Newly 

Eligible

Number of 

Individuals

Percent of Newly 

Eligible

 — 67 — 
Table 17:

Universe: Individuals Whose Eligibility Changed due to the Restorations

Overall Figures

Eligibility Transition

Category

Total Net Newly Eligible Individuals 1,564,309 100%

 Individuals in units that...

Became Eligible at All 847,598 54.2%

Became Fully Eligible 811,427 51.9%

Remained Mixed 49,136 3.1%

 Individuals Who Lost Eligibility 143,852 -9.2%

Total New Recipients 1,204,731 77.0%

Adults (Age 18 and Up)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 1,364,908 100%

 Individuals in units that...

Became Eligible at All 630,025 46.2%

Became Fully Eligible 724,932 53.1%

Remained Mixed 45,320 3.3%

 Individuals Who Lost Eligibility 35,369 -2.6%

Total New Recipients 949,368 69.6%

Children (Under Age 18)

Eligibility Transition

Category

Total Net Newly Eligible Individuals 199,401 100%

 Individuals in units that...

Became Eligible at All 217,573 109.1%

Became Fully Eligible 86,495 43.4%

Remained Mixed 3,816 1.9%

 Individuals Who Lost Eligibility 108,483 -54.4%

Total New Recipients 255,363 128.1%

Number of 

Individuals

Percent of Newly 

Eligible

Food Stamp Unit Eligibility Transitions, 2004 (Full versus No Restoration)

Number of 

Individuals

Percent of Newly 

Eligible

Number of 

Individuals

Percent of Newly 

Eligible

 — 68 — 
Table 18: Annual Median Benefit Difference Figures, 2003, 2004

Universe: Low-Income Food Stamp Eligible Units

Actual Restoration Full Restoration

Minus No Restoration Minus No Restoration

2003

Units with Children

All Citizens $0 $0

LPR/Citizen $478 $722

Undocumented/Citizen -$4 -$4

LPR/Other Noncitizen $410 $1,352

Refugee $472 $472

Units without Children

All Citizens $0 $0

LPR/Citizen $80 $161

Undocumented/Citizen $0 $0

LPR/Other Noncitizen $271 $271

Refugee $32 $32

2004

Units with Children

All Citizens $0 $0

LPR/Citizen $662 $833

Undocumented/Citizen $0 $0

LPR/Other Noncitizen $274 $1,345

Refugee $344 $344

Units without Children

All Citizens $0 $0

LPR/Citizen $365 $516

Undocumented/Citizen $0 $0

LPR/Other Noncitizen $154 $154

Refugee $21 $21

Unit Type

 — 69 — 
Table 19: Trends in Mixed Eligibility, Citizenship, and Participation, 1999–2004

Universe: Low-Income Eligible Units with Children

1999–2000

Category Share of Units Participation Rate

Same Status 83.4% 65.7%

Mixed Eligibility 16.6% 35.3%

All Citizens 79.7% 67.7%

LPR/Citizen 10.6% 36.3%

Undocumented/Citizen 7.7% 24.0%

LPR/Other Noncitizen 0.8% 48.2%

Refugee 1.2% 52.4%

All 100.0% 60.6%

2001–02

Category Share of Units Participation Rate

Same Status 82.1% 68.1%

Mixed Eligibility 17.9% 37.6%

All Citizens 77.5% 70.4%

LPR/Citizen 11.6% 34.8%

Undocumented/Citizen 8.9% 31.7%

LPR/Other Noncitizen 0.6% 59.0%

Refugee 1.4% 57.8%

All 100.0% 62.6%

2003–04

Category Share of Units Participation Rate

Same Status 83.7% 77.9%

Mixed Eligibility 16.3% 41.2%

All Citizens 75.4% 81.1%

LPR/Citizen 11.4% 47.5%

Undocumented/Citizen 11.1% 35.7%

LPR/Other Noncitizen 1.1% 74.2%

Refugee 1.0% 61.6%

All 100.0% 71.9%

 — 70 — 
Table 20: Trends in Mixed Eligibility, Citizenship, and Participation, 1999–2000, 2003–04

Universe: Low-Income Eligible Units with Children

Standardization

Standardized Participation Rates 1999-2000 2003-2004

Unit Type, Mixed Eligibility Standardized 59.7% 72.6%

Mixed Eligibility, Use Rates Standardized 66.9% 65.0%

Unit Type, Use Rates Standardized 66.0% 66.1%

Total Participation Rate 60.7% 71.9%

Decomposition

Effects Difference Percent Distribution of Effects

Use Rate Effect 12.9% 114.5%

Unit Type Effect -1.8% -16.3%

Mixed Eligibility Effect 0.1% 1.8%

Total Trend 11.3% 100.0%

 — 71 — 
Table 21: Logistic Regression Results for Low-Income, Food Stamp–Eligible Units, March 2004 and 2005 CPS (Calendar Years 2003 and 2004

Model 1 Model 2 Model 3 Model 4

Parameter Odds Parameter Odds Parameter Odds Parameter Odds

Characteristic Estimate Ratio Estimate Ratio Estimate Ratio Estimate Ratio

LPR/other Noncit Unit with Mixed Eligibility 0.3083 1.361 0.4748 * 1.608 0.8463 ** 2.331 1.0236 ** 2.783

LPR/Cit Unit with Mixed Eligibility -0.6951 *** 0.499 -1.3642 *** 0.256 -1.1148 *** 0.328 -1.0194 *** 0.361

Refugee Unit with Mixed Eligibility -0.2235 0.800 -1.3344 * 0.263 11.8094 >999.9 11.8535 >999.9

Undoc/Cit Unit with Mixed Eligibility -0.9273 *** 0.396 -1.4297 *** 0.239 -1.9023 *** 0.149 -1.8256 *** 0.161

All citizen unit with Mixed Eligibility -0.3314 *** 0.718 -1.1381 *** 0.320 0.0582 1.060 0.0526 1.054

LPR/other Noncit Unit with all membs eligible 0.0416 1.042 0.3822 ** 1.466 0.8970 *** 2.452 1.0074 *** 2.738

LPR/Cit Unit with all membs eligible -0.3212 *** 0.725 -0.8912 *** 0.410 -0.5604 *** 0.571 -0.4462 *** 0.640

Refugee Unit with all membs eligible 0.5767 ** 1.780 0.2882 1.334 0.4980 * 1.645 0.5657 ** 1.761

Unit received TANF during the year 1.5611 *** 4.764 1.8487 *** 6.352 1.8650 *** 6.456

Unit received SSI during the year 1.9969 *** 7.366 2.1052 *** 8.209 2.1237 *** 8.362

FS benefits unit is eligible for, divided by 100 0.0193 *** 1.019 0.0203 *** 1.021 0.0208 *** 1.021

Unit annual earnings, divided by 1,000 -0.0080 ** 0.992 -0.0087 ** 0.991 -0.0087 ** 0.991

Child Present - 2 Parents -0.1585 ** 0.853 -0.1302 * 0.878 -0.1686 ** 0.845

Child Present - Single Parent 1.0700 *** 2.915 1.1287 *** 3.092 1.1060 *** 3.022

Child Present - No Parents 1.0172 *** 2.766 1.1021 *** 3.011 1.0799 *** 2.945

Elderly person in unit -1.5915 *** 0.204 -1.6240 *** 0.197 -1.6152 *** 0.199

Disabled person in unit 0.1105 ** 1.117 0.0853 * 1.089 0.0748 * 1.078

CA -1.3276 *** 0.265 -1.1174 *** 0.327

TX -0.2443 *** 0.783 -0.3292 *** 0.720

CA LPR/other Noncit Unit with Mixed Eligibility -0.0063 0.994 -0.1745 0.840

CA LPR/Cit Unit with Mixed Eligibility -0.1084 0.897 -0.2044 0.815

CA Refugee Unit with Mixed Eligibility -13.6797 <0.001 -13.7161 <0.001

CA Undoc/Cit Unit with Mixed Eligibility 2.3597 *** 10.588 2.3051 *** 10.025

CA All citizen unit with Mixed Eligibility -2.1150 *** 0.121 -2.1247 *** 0.119

CA LPR/other Noncit Unit with all membs eligible -0.7647 ** 0.465 -0.8735 ** 0.417

CA LPR/Cit Unit with all membs eligible -0.1437 0.866 -0.2480 0.780

CA Refugee Unit with all membs eligible -1.2303 * 0.292 -1.2916 * 0.275

TX LPR/other Noncit Unit with Mixed Eligibility 0.2071 1.230 0.0320 1.033

TX LPR/Cit Unit with Mixed Eligibility 0.8559 ** 2.354 0.7734 * 2.167

TX Refugee Unit with Mixed Eligibility -0.2656 0.767 -0.2868 0.751

TX Undoc/Cit Unit with Mixed Eligibility 0.2074 1.230 0.1453 1.156

TX All citizen unit with Mixed Eligibility -0.2957 0.744 -0.2920 0.747

TX LPR/other Noncit Unit with all membs eligible 0.1041 1.110 -0.0161 0.984

TX LPR/Cit Unit with all membs eligible 0.0749 1.078 -0.0287 0.972

TX Refugee Unit with all membs eligible 0.6665 1.947 0.6237 1.866

Percentage of state population that is foreign-born -0.0134 *** 0.987

percent change in foreign born population, 1990-2000 -0.0011 ** 0.999

State median income, divided by 1,000 -0.0176 *** 0.983

state unemployment rate during datayear (percent) 0.0321 1.033

N 27,742 27,742 27,742 27,742

c 0.578 0.817 0.827 0.828

-2 Log L 37,521 28,267 27,292 27,186

* p <= 0.05; ** p <= 0.01; *** p <= 0.001

 — 72 — 
Table 22: Logistic Regression Results for Low-Income, Food Stamp–Eligible Units

March 2000, 2001, 2004, 2005 CPS (Calendar Years 1999–2000, 2003–04)

Model 1 Model 2

Parameter Odds Parameter Odds

Characteristic Estimate Ratio Estimate Ratio

LPR/other Noncit Unit with Mixed Eligibility -0.1367 0.872 -0.4957 * 0.609

LPR/Cit Unit with Mixed Eligibility -0.5641 *** 0.569 -1.0079 *** 0.365

Refugee Unit with Mixed Eligibility 0.3145 1.370 -1.0478 ** 0.351

Undoc/Cit Unit with Mixed Eligibility -1.218 *** 0.296 -1.4120 *** 0.244

All citizen unit with Mixed Eligibility 0.0707 1.073 -1.3265 *** 0.265

LPR/other Noncit Unit with all membs Eligible 0.3602 * 1.434 0.7899 *** 2.203

LPR/Cit Unit with all membs Eligible -0.5915 *** 0.554 -0.6154 *** 0.540

Refugee Unit with all membs Eligible 0.3808 * 1.463 0.3960 * 1.486

in time period 2 (2001-2002) 0.257 *** 1.293 0.3913 *** 1.479

LPR/other Noncit Unit with Mixed Eligibility in t2 0.445 1.561 1.0965 ** 2.994

LPR/Cit Unit with Mixed Eligibility in t2 -0.1309 0.877 -0.2458 0.782

Refugee Unit with Mixed Eligibility in t2 -0.538 0.584 -0.3129 0.731

Undoc/Cit Unit with Mixed Eligibility in t2 0.2907 ** 1.337 0.1806 1.198

All citizen unit with Mixed Eligibility in t2 -0.4021 ** 0.669 0.1537 1.166

LPR/other Noncit Unit with all membs elg in t2 -0.3186 0.727 -0.4587 * 0.632

LPR/Cit Unit with all membs elg in t2 0.2703 * 1.310 -0.1453 0.865

Refugee Unit with all membs elg in t2 0.1964 1.217 -0.0504 0.951

Unit received TANF during the year 2.0313 *** 7.624

Unit received SSI during the year 1.9633 *** 7.123

FS benefits unit is eligible for, divided by 100 0.0252 *** 1.026

Unit annual earnings, divided by 1,000 -0.0115 *** 0.989

Child Present - 2 Parents -0.5388 *** 0.583

Child Present - Single Parent 0.7172 *** 2.049

Child Present - No Parents 0.6325 *** 1.882

Elderly person in unit -1.4229 *** 0.241

Disabled person in unit 0.1191 *** 1.127

N 45,609 45,609

c 0.612 0.821

-2 Log L 62,058 46,799

* p <= 0.05; ** p <= 0.01; *** p <= 0.001

 — 73 — 
 — —74 
Appendix: Detailed Methodology 

Data Sources 

Our approach involves the use of Current Population Survey (CPS) data for 1999–2004, with 

several important innovations that help us better isolate the impact of Food Stamp Program 

(FSP) participation trends and the impact of Farm Bill eligibility restorations on households with 

legal immigrants. Specifically, we (a) distinguish among immigrants by legal status, (b) 

determine eligibility for food stamps, and (c) correct for under-reporting and misreporting of FSP 

participation by survey respondents. Our analysis uses theTransfer Income Model (TRIM3), 

which has been developed at the Urban Institute under primary funding from the Department of 

Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation 

(HHS/ASPE). TRIM3 is used to determine benefits eligibility and receipt in ways that correct 

for the under- and misreporting of benefit use by respondents to the CPS. Our analyses use 

TRIM3’s assignment of legal status to distinguish LPRs from other immigrants (e.g., naturalized 

citizens, undocumented immigrants) in the CPS. These datasets permit us to differentiate among 

various types of mixed status and other legal immigrant families, and to analyze data for states 

and groups of states. 

Current Population Survey (CPS). The analysis uses six Annual Social and Economic 

Supplements to the CPS—March 2000 through March 2005. These CPS supplements cover 

income and food stamp participation data for calendar years 1999 through 2004. The CPS is a 

nationally representative household survey that includes information about nativity, citizenship, 

income, household composition, and self-reported benefits receipt—information we use to 

 — —75 
determine food stamp eligibility and receipt based on the TRIM3 model. We group the data into 

three samples: 

• 1999–2000 (baseline that predates the 2001–02 economic slowdown); 

• 2001–02 (a period of caseload growth during the economic slowdown, eligibility 

expansions, and application streamlining); and 

• 2003–04 (during and immediately following the Farm Bill’s legal immigrant 

restorations). 

In some of our analyses, particularly our regression models, we combine two years of 

data for each period to ensure our samples are large enough to examine different types of 

immigrant units and to disaggregate results for some key states and groups of states. In others—

particularly the alternative simulations of immigrant eligibility and participation with and 

without the Farm Bill restorations—we use single years of data. Eligibility rules are coded in 

TRIM3 extracts for entire years. As a result, the April 2003 restorations—to noncitizen adults 

with at least five years of legal U.S. residency—are applied to the eligibility rules in the 2003 

data (because April occurred less than halfway through the year). The October 2003 

restorations—to legal immigrant children regardless of length of residency—are applied to the 

2004 TRIM3 data (as the restoration only affected eligibility for the last three months of the 

year). Consequently, some of our results—particularly the number of LPR children eligible for 

and receiving food stamps—vary considerably between 2003 and 2004. 

The Transfer Income Model. The TRIM3 model provides a basis for identifying 

households that are eligible for and receive food stamps. TRIM3 is the latest version of a 

microsimulation model developed and maintained at the Urban Institute for the past 30 years, 

with primary funding from HHS/ASPE. TRIM3 is a comprehensive model of major tax, health, 

 — —76 
and transfer programs affecting the U.S. population, including the FSP. The basic data for 

TRIM3 is the March supplement to the CPS. Individual responses to the CPS tend to understate 

participation in major social welfare programs, including the FSP. Notwithstanding the 

underreporting of participation, many individuals and households in the CPS that report 

receiving Food Stamps do not appear to be eligible to participate. TRIM3 corrects for both these 

errors. TRIM3 captures most real-world eligibility details by following the same steps that a 

caseworker would take, including applying assets tests, computing gross income, subtracting 

allowable deductions to arrive at net income, and applying income tests. A key feature of TRIM3 

is the ability to simulate program participation under alternative eligibility rules and compare 

these results with the existing baseline set of current rules (Giannarelli et al. 2001). 

Food stamp eligibility and participation. TRIM3 corrects for underreporting and 

misreporting of food stamp receipt in the CPS by matching the TRIM3 caseload estimate to the 

actual caseload—as reported by state-level administrative data—in overall size and key 

characteristics. All units classified as eligible that report receiving food stamps in the CPS are 

included in the TRIM3 caseload, while those units that report receiving benefits but are 

determined ineligible by TRIM3 are excluded from the caseload. Then, a portion of units that 

have been determined eligible but did not report food stamp receipt are added to the TRIM3 food 

stamp caseload to match as closely as possible the administrative targets for the size and 

characteristics of the caseload. This last step is crucial to correct for the significant 

underreporting of transfer program benefits that has been documented in the CPS (Wheaton and 

Giannarelli 2000). 

Eligibility and participation for legal immigrants. TRIM3 explicitly considers noncitizen 

eligibility rules for FSP and other programs by differentiating among U.S. citizens, refugees, 

 — —77 
LPRs, and nonqualified immigrants (including undocumented immigrants and legal temporary 

residents). Undocumented and temporary immigrants were never eligible for food stamps, and 

the restrictions on noncitizen eligibility have no effect on eligibility among citizens, whether 

naturalized or born in the United States. For LPRs and other qualified immigrants, TRIM3 

determines eligibility based on the following factors, as specified in the Food Stamp Act: 

• status as a refugee or asylee; 

• age; 

• length of U.S. residency; 

• 40 quarters of work, including quarters worked by spouses and parents; 

• active duty military and veterans, as well as their dependents and spouses; 

• disability status, receipt of Supplemental Security Income (SSI), general assistance, 

and other disability benefits; and 

• entry into the United States before and after the passage of the Personal 

Responsibility and Work Opportunity Reconciliation Act in August 1996. 

TRIM3 also prorates the income of ineligible unit members (usually noncitizen adults in 

our analysis) by a ratio of the number of eligible unit members to all unit members, as is the 

practice in most states when determining noncitizen eligibility. Eligibility for state-funded food 

assistance programs and sponsor deeming are not modeled. The reasons for not modeling 

sponsor deeming are discussed in detail later in this appendix and in the conclusion to the report. 

Definitions and Classification of Data 

Legal Status of Individuals. One essential component of TRIM3 is the assignment of legal status 

to immigrants in the CPS data. Legal status must be known so TRIM3 can accurately determine 

program eligibility for food stamps and other benefits and so restrictions on noncitizen eligibility 

can be modeled and alternatives simulated. The Urban Institute has developed a series of 

methods and procedures to use CPS data on nativity and citizenship to assign more detailed 

 — —78 
migrant statuses to immigrants (Passel and Clark 1998; Passel et al. 2004), with funding from 

HHS/ASPE and other sources. 

The CPS asks whether respondents and other unit members are 

1. U.S.-born citizens; 

2. U.S. citizens born in the territories; 

3. U.S. citizens born abroad to U.S. citizen parents; 

4. foreign-born naturalized U.S. citizens; or 

5. noncitizens. 

For TRIM3 and our analyses, the first four categories are considered U.S. citizens, while 

those in the “noncitizen” category are further disaggregated by legal status into 

(a) refugees and asylees; 

(b) legal temporary residents; 

(c) legal permanent residents (LPRs); and 

(d) undocumented immigrants (illegal aliens).12 

Refugees and legal temporary residents are small groups that are not the focus of our 

analysis. Undocumented immigrants are a larger group but also not the focus of the study. Our 

main focus is on LPRs, who were the beneficiaries of the 2002 and 2003 Farm Bill eligibility 

restorations. In the remainder of this section, we briefly outline the procedures used to assign 

legal status to foreign-born individuals in the CPS and TRIM3. 

Naturalized citizens. The CPS data on naturalized citizens, as collected, are overreported; 

that is, there are more naturalized citizens in the CPS data than the number of naturalizations 

granted by the Immigration and Naturalization Service (INS) and its successor agencies within 

 

12 We use the term “undocumented immigrants” to encompass all those foreign-born noncitizens not in the other 

categories. This group is variously known as “illegal aliens,” “unauthorized migrants,” “undocumented workers,” 

 — —79 
the Department of Homeland Security (DHS). (See Passel and Clark 1998.) The degree of 

overreporting is especially serious for those not in the United States long enough to qualify for 

naturalization.13 For longer-term residents, overreporting is serious only among immigrants from 

Mexico and Central America. For the former group, we edit the reported naturalized citizens to 

be noncitizens. For the latter, some immigrants who report being naturalized are likely 

undocumented, and corrections for misreporting of citizenship for this group are made later when 

undocumented status is assigned. (See below.) 

Refugees and asylees. Refugees are granted legal status in the United States owing to a 

“well-founded fear” of persecution in their home countries and are granted this status before 

entry to the United States. Asylees, who meet the same criteria, claim asylum after arriving in the 

United States—usually either illegally or with a temporary visa—and must prove their case in 

court. The food stamp eligibility rules for refugees and asylees differ from those for other legal 

immigrants. Specifically, refugees and asylees are eligible for the FSP during their first seven 

years in the United States, regardless of age, disability, veteran status, or work history. Thus, it is 

important to distinguish refugees and asylees from legal permanent residents in the CPS data. 

We identify refugees and asylees in the CPS using country of birth and year of entry data, 

because refugee flows tend to be concentrated from just a few countries. Further, the major 

refugee-sending countries tend to send relatively few other immigrants while sending refugees. 

Thus, immigrants arriving during periods of entry when a majority of legal admissions14 from a 

country are refugees or asylees (versus other LPR new admissions) are designated as refugees. 

 and so on. Some individuals in this group are known to the government, and some may even have temporary work 

authorization. One trait they all share is ineligibility for the FSP. 

13 Five years in LPR status is required before most immigrants can become citizens. Spouses of U.S. citizens must 

wait only three years; children of U.S. citizens can naturalize with no waiting period. 14 We use “new arrivals” compared with refugee arrivals and ignore LPRs who were already in the country and had 

“adjusted” their status. 

 — —80 
The exact cutoff point for the qualifying percentage majority in each country is chosen so the 

total number of refugees identified is equal to a demographic estimate of the refugee population. 

Temporary legal migrants. A third group we identify among foreign-born U.S. residents 

are those admitted legally on a temporary basis, but for extended periods (usually more than one 

year); the major groups are foreign students and temporary workers. Temporary residents do not 

have the same rights as legal permanent residents: they are not eligible for the FSP, and they 

must become LPRs before they can apply for citizenship. We identify likely temporary legal 

residents among the recently arrived foreign born by matching the characteristics of CPS 

respondents with the visa requirements to identify a total of about 12 different visa categories 

including foreign students, high-tech guest workers, intracompany transfers, and au pairs. We 

use information on occupation, industry, educational attainment, and school enrollment as well 

as information about family relationships and relatives in the United States. Overall, legal 

temporary migrants make up only about 4–5 percent of the foreign born, and they are excluded 

from our analyses. 

Legal permanent residents (LPRs). Once we have identified refugees, asylees, and legal 

temporary migrants, we then distinguish LPRs from undocumented immigrants among the 

remaining noncitizens. Most LPRs are admitted to live permanently in the United State because 

they are related to U.S. citizens or LPRs already in the country. Most of the rest are admitted for 

employment purposes because the possess skills needed by employers in the United States. In 

our assignment process, LPRs are the noncitizens left unassigned after undocumented 

immigrants are identified using the methods described below. 

Undocumented immigrants. Undocumented immigrants lack valid temporary visas and 

other immigration documents, and analysts often classify them into two broad groups. First, just 

 — —81 
over half of undocumented immigrants cross the border without documents and are officially 

designated as “entries without inspection.” The rest of the undocumented population enter the 

United States with valid documents for a temporary status but stay beyond their period of 

admission or otherwise violate their terms of admission; they are usually designated “visa 

overstayers.” To identify individuals in the CPS who are likely to be undocumented immigrants, 

we first construct an estimate of the number of legal immigrants and legal temporary migrants in 

the CPS by calculating the total number of these legal immigrants based on DHS admissions 

data. We then develop a “residual” estimate of the undocumented population by subtracting the 

number of LPRs and other legal immigrants from the total number of noncitizens in the CPS 

data. We calculate residual estimates of the undocumented population for groups by country of 

birth, age, sex, period of immigration, and for six states and the balance of the country. 

At the microsimulation level, we distinguish LPRs from undocumented immigrants in the 

CPS data based on an array of characteristics, including those used for the residual estimates just 

described as well as information on educational attainment, occupation, industry, and family 

relationship. Regression analysis of data from a sample of previously undocumented immigrants 

in the 1992 Legalized Population Survey and our own estimates are used to develop probabilities 

of being either LPR or undocumented. Where necessary, we split cases in the CPS based on 

these probabilities; for example, if an individual’s probability of being undocumented is 0.7, we 

replicate the case into three LPR cases and seven undocumented cases, each case having 

one-tenth of the original weight. We perform a final set of adjustments and edits to ensure that 

legal statuses within families are consistent and that the total numbers of LPRs and 

undocumented immigrants equal the control totals set by our demographic estimates of the these 

populations in the CPS. 

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Eligibility units. Our basic unit of analysis is the TRIM3 eligibility unit, which is used to 

calculate food stamp eligibility, participation, and annual benefit levels. In most cases, the 

TRIM3 eligibility unit is the same as the CPS household. But TRIM3 subdivides some CPS 

households into smaller units, particularly when there are groups of household members eligible 

for and/or receiving TANF. (TANF eligibility units are closer to families instead of households.) 

Throughout this report, references to “units” and “family units” refer to food stamp eligibility 

units defined by TRIM3. 

Low-income units. We limit our sample for analysis to “low-income” units, which we 

define as eligibility units with incomes below 200 percent of the federal poverty level (FPL). We 

choose 200 percent of FPL to capture more income variation and include some units that are 

eligible for food stamps despite the fact that their income exceeds 130 percent of FPL, the 

income cutoff for most units in the FSP. We are missing a small fraction of food stamp–eligible 

and receiving units with incomes over 200 percent of FPL; in 1999–2000, 91 percent of eligible 

units had incomes below 200 percent of FPL.

Presence of children. We disaggregate units into those with and without children. Part of 

our emphasis in later analyses will be on units with children because of the October 2003 

restoration of food stamps to all legal immigrant children. Further, we are interested in tracking 

the eligibility and participation of units with both citizen and noncitizen members, as well as 

those with LPR and other noncitizen members. Frequently, immigrant units are composed of 

noncitizen adults and citizen children—children who are young enough that they were born in 

the United States after their parents immigrated. In fact, 80 percent of children of immigrants are 

U.S. citizens (Capps 2001). 

 — —83 
Legal status of unit members and classification of units. We use TRIM3’s assignments of 

legal status to calculate the number of citizen, LPR, undocumented, and refugee members in 

each unit. Units in which all members are noncitizens are particularly important—especially 

units with undocumented immigrants—because these units may be entirely ineligible for food 

stamps owing to noncitizen restrictions. Identification of “mixed eligibility” units—where some 

members are eligible U.S. citizens and others are ineligible noncitizens—is also critical because 

such units generally qualify for lower benefit allocations than units where all members are 

eligible. In addition to reducing benefits, the reduced benefit allocation may depress their 

participation. We use citizenship and legal status to classify eligibility units as follows: 

1. All Citizen: The largest group of units includes only citizens. Units composed entirely of 

citizens have been insulated from changes to noncitizen eligibility rules in the FSP, 

although they may be affected by a range of other policy changes such as rules for 

able-bodied adults without dependents, resource limits, certification periods, transitional 

benefits, and TANF and other sanctions. We use citizen-only units as a control group to 

contrast patterns of food stamp eligibility and use with those for units with noncitizen 

members. 

2. LPR/Citizen: These units contain at least one legal permanent resident and one U.S. 

citizen; they may or may not contain other immigrants. In most but not all cases, the 

LPRs are adults and at least one child is a citizen. These mixed units represent the 

second-largest group of low-income units with children, but a much smaller share of units 

without children. This group is perhaps the most affected by the legal immigrant 

eligibility rules, but it often is affected in terms of the number of unit members who are 

eligible instead of the entire unit’s eligibility. Many of these are “mixed eligibility” units, 

because the LPR members are ineligible but the citizen members are eligible. 

3. LPR/Other Noncitizen: These units have at least one legal permanent resident but no 

citizen members; most other members of these units are either other LPRs or 

undocumented immigrants, although some may be refugees or temporary residents. This 

group is a small share of units with children, but a larger share of units without children. 

Some of these units are likely to be ineligible owing to legal immigrant restrictions, while 

others are mixed eligible, and still others entirely eligible. This group has also been 

affected by the 2002 and 2003 Farm Bill restorations but to a lesser degree than the 

previous one. 

4. Undocumented/Citizen: These units contain at least one undocumented immigrant and 

one U.S. citizen; they may or may not contain other immigrants. Again, it is usually the 

adults who are undocumented and at least one child who is a citizen. This group is also 

relatively large for units with children, and relatively small for those without children. 

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5. All Undocumented: These units are composed solely of undocumented immigrants, so no 

members are eligible for food stamps. They are excluded from our analysis. 

6. Refugee: These units are composed either solely of refugees or of refugees and citizens. 

Because refugees are eligible for food stamps for their first seven years in the United 

States (regardless of their age, disability, veteran status, or work history), it is important 

to distinguish refugee units from those with LPR members, even though there are 

relatively few refugee units. Further, we feel it is important to distinguish them from 

citizen units because of different patterns of food stamp and welfare use between citizens 

and refugees (Fix and Passel 2002). 

Eligibility Simulations 

Baseline Simulation. TRIM3 uses FSP eligibility rules⎯including those for immigrants⎯in 

place at the time the data were collected to calculate eligibility, participation, and the amount of 

benefits received. This “baseline” simulation is aligned to reflect administrative totals for food 

stamp participation on a monthly basis. In other words, eligibility and participation are calculated 

for each month and aligned to administrative totals for that month. 

In our analyses, we use annual eligibility and participation data rather than the monthly 

data from TRIM3; that is, we identify units that were eligible for and/or received food stamps 

during any month in the year. Our annual totals are therefore considerably higher than 

administrative totals for any given month, or for any average month during the year, because so 

many units use foods stamps for only part of the year. We have opted to model annual eligibility 

and participation in order to capture the broadest sample possible and to minimize any errors in 

monthly estimates. 

Our baseline simulation for 2003 includes eligibility adjustments in TRIM3 for the first 

two Farm Bill restorations: disabled legal immigrants (October 2002) and legal immigrants with 

at least five years of U.S. residency (April 2003). The 2003 baseline does not include eligibility 

 — —85 
adjustments for the third restoration, to all LPR children regardless of length of residency, which 

took place in October 2003. The third restoration is included in our 2004 baseline, along with the 

other two restorations. We show baseline simulations for 2003 and 2004 separately in order to 

gauge the impact of the third restoration. We see the impact most clearly on the number of LPR 

children who became eligible and participated in the FSP.15 

Additionally, TRIM3 allows us to model eligibility for each individual in the unit. 

Therefore, we can identify units where all members are eligible, as well as those in which only 

some are eligible. These mixed-eligibility units are a large and important share of legal 

immigrants’ units, especially those with citizen members. 

Alternative simulations. We also conducted two alternative simulations using TRIM3: 

one that estimates eligibility and participation rates of low-income units had the Farm Bill legal 

immigrant restorations not occurred, and a second that estimates eligibility and participation 

without any of the legal immigrant eligibility restrictions in PRWORA in place—in other words, 

as if a full eligibility restoration had occurred. We tabulated and analyzed differences between 

the actual receipt and eligibility figures and the simulated receipt and eligibility figures; we also 

tabulated differences in mixed-eligibility rates and median benefits for eligible units among the 

different scenarios. We report findings from our alternative simulations for 2003 and 2004 

separately when appropriate, since the first two restorations appear in our CPS TRIM3 data in 

 

15 The TRIM3 baseline simulation does not model categorical eligibility through noncash TANF receipt because 

data on noncash benefits are not collected by the CPS. TRIM3 does not model differences across states in vehicle 

rules because there are no CPS data on vehicle values. Additionally, TRIM3 does not model the availability of statefunded food stamp replacement programs for LPRs who would be eligible if not for the citizenship restrictions, or in 

rules for treatment of the income of ineligible unit members. TRIM3 has the capacity to set different rules by state 

for alternative simulations, but state replacement programs are not modeled and the baseline simulation assumes that 

income and deductions of ineligible noncitizens are prorated by the ratio of eligible to total unit members. The 

research and programming needed to simulate state replacement programs or state-specific rules about the income 

and deductions of ineligible aliens are beyond the scope of this study. 

 — —86 
calendar year 2003, while the third restoration—to all LPR children—does not appear until the 

2004 data. 

Treatment of LPRs subject to sponsor deeming. Our baseline and alternative simulations 

for 2003 and 2004 assume that there was no sponsor deeming outside the food stamp unit for 

LPRs in these years. The new, more rigorous deeming requirements only apply to immigrants 

who were sponsored by individuals and arrived after December 1997, when sponsors had to sign 

the new legally binding affidavit of support. A significant minority of LPRs are sponsored by 

employers, churches and other institutions—and so are not subject to deeming rules at all. In 

2003 and 2004, few immigrants with five years residence had arrived after December 1997. In 

April 2003, only LPRs arriving between January and April 1998 would have been eligible under 

the restoration and subject to sponsor deeming. By December 2004, newly eligible LPRs subject 

to deeming would have included just those arriving between January 1998 and December 1999. 

Even after the legally binding sponsorship rules took effect, only a small minority of 

LPRs eligible for food stamps had sponsors living outside their units. FSP rules have always 

required the income of the sponsor to be counted whenever the sponsor is a member of the food 

stamp unit. Recent data from the New Immigrant Survey, analyzed by Mathematica Policy 

Research (MPR) for the U.S. Food and Nutrition Service, suggest that only between a quarter 

and a third of newly admitted LPRs who are not refugees or asylees have sponsors outside their 

units.16 More specifically, only 26.4 percent of nonrefugee, nonasylee LPRs had sponsors 

outside their units; when only low-income units (using a threshold of 200 percent of the federal 

poverty level) are considered, this rate rises slightly to 30.6 percent. Based on these data, MPR 

 

16 Alison Barrett, “The New Immigrant Survey and Estimates of the Percentage of Lawfully Admitted Permanent 

Residents Eligible for the Food Stamp Program–Final Memo,” unpublished memorandum to Jenny Genser, U.S. 

Food and Nutrition Service, July 26, 2006. 

 — —87 
researchers recommended randomly assigning 26.4 percent of all LPR units in the March CPS as 

subject to deeming when conducting food stamp eligibility models, although this would only 

apply to units with LPRs who arrived after December 1997. Performing this assignment was 

beyond the scope of this study. 

Food stamp eligibility rules also allow LPRs subject to deeming to claim an “indigent 

exemption,” based on economic hardship, as long as they agree to allow their names to be 

reported to the U.S. Attorney General. Further, as of 2003–04 when the Farm Bill restorations 

were first implemented, few states had begun implementing deeming procedures because 

deeming was largely unnecessary before the restoration (Capps et al. 2004). As a result of all 

these factors, we assume that no sponsor deeming took place immediately following the 

restorations. This assumption may mean that we slightly overestimate the restorations’ impacts 

by treating some people as newly eligible whom the states would have disqualified because of 

deeming. It is also likely that the share of LPR units subject to sponsor deeming has risen since 

2004, potentially muting the impact of the restorations over time. 

Decomposition of Trends in Participation Rates 

We apply demographic decomposition techniques to changes between 1999–2000 and 2003–04 

in the participation rate among low-income units with children that are eligible for the FSP. 

Specifically, we allocate the change in FSP participation rates between 1999–2000 and 2003–04 

into the proportions due to each of the following: 

• change in the share of all citizen, LPR/citizen, undocumented/citizen, LPR/other 

noncitizen and refugee units; 

• change in the share of mixed-eligible units; and 

• change in the underlying participation rate for these units. 

 — —88 
We use the decomposition method developed by Das Gupta (1993). An important 

advantage of Das Gupta’s approach, compared with other decomposition methods, is that it 

decomposes changes into additive main effects (here, changes in unit types, mixed eligibility, 

and participation rates) without the need for interaction terms, which can be difficult to interpret. 

Fix and Passel (2002) applied Das Gupta’s decomposition method to changes from 1994 to 1999 

in participation in FSP and other means-tested benefits among units of different citizenship and 

immigration status. 

Regression Analysis of Food Stamp Participation 

Using logistic regression techniques, we model food stamp participation among low-income 

units that are eligible for the FSP. In this report we display findings from a regression model of 

participation in the third period of the study (2003–04). We also report estimates from a 

regression model of participation in two periods (1999–2000 and 2003–04). The two-period 

model includes a term for the period and terms for the interaction of the period with the other 

independent variables in the model. 

Our logistic regression models treat the probability that an eligible food stamp unit 

receives food stamps as a function of citizenship and legal status of the unit, the amount of 

benefits for which the unit is eligible, other characteristics of the unit, and the characteristics of 

the state where the unit resides. The full model for analyzing changes between 1999–2000 and 

2003–04 is described below: 

Pijt =α0tij + α1Iijt+ α2Sj + β0E ijt + β1Xjt + γ0(Iijt * Sj) + γ1(Iijt * tij) + γ2(Sj * tij) + 

θ (Iijt * Sj * tij) + εijt 

where 

Pijt = probability that unit i in state j receives food stamps; 

 — —89 
Iijt = five citizenship and legal status categories for units: all citizens, mixed LPR/citizen, 

mixed undocumented/citizen, all noncitizens (at least one LPR and other members 

LPRs or undocumented), and refugees (at least one refugee). All-citizen units were 

coded as the reference group and each of the other four categories as a separate dummy 

variable. 

Sj = two major immigrant states (California and Texas), coded as dummies, with all other 

states as the reference group; 

Eijt = unit characteristics at time t: continuous variables for unit earnings and the total food 

stamp benefit for which TRIM3 estimates the unit is eligible; dummy variables for the 

presence of children, presence of adults over age 64, presence of disabled unit members, 

TANF receipt, and SSI receipt. 

Xjt = state-level characteristics at time t: unemployment rate, median unit income, 2000 

foreign-born share of total population, and 1999–2000 growth rate in foreign-born 

population; 

tij = a dummy variable denoting the two periods (i.e., set to 0 for 1999–2000 and 1 for 2003–

04). The model for our single-point-in-time regression (2003–04) excludes this variable 

and all the interactions that involve it. 

The coefficients in the regression equation represent the effects on the probability of an eligible 

unit’s food stamp participation controlling for all other factors. The alpha and beta coefficients 

represent base coefficients or the “first” level of differences: 

α0 = the overall change in the participation rate between time 1 and time 2 (this term is not 

calculated for our single-point-in-time regressions for 2003–04); 

α1, α2 = effects on participation of, respectively, citizenship and legal status categorization of 

the unit, and state policies; and 

β0, β1 = effects on participation of, respectively: demographics, earnings, benefits allocations, 

and other program receipt for units, and state economic conditions and foreign-born 

population shares. 

The gamma terms represent the “second” level of differences or changes across time in these 

factors, controlling for other factors: 

γ0, γ1, γ2 = effects on participation of changes in, respectively, the distribution of eligible 

units across states, the distribution of units over time (not included in 2003–04 

single-point-in-time regressions), and the distribution of units across states over 

time (also not included in single-point-in-time regressions). 

 — —90 
 — —91 

 

The theta term (θ) isolates the impact of various state characteristics on the change in 

participation of eligible immigrant units over time, controlling for all other factors, whereas the 

other coefficients measure the impacts at a point in time. This last term, the “triple difference” 

coefficient (Borjas 2001), can be thought of as a series of interactions among characteristics, the 

citizenship and legal status of the unit, two major immigration states (again, California and 

Texas), and the years of the survey (in this report, 1999–2000 versus 2003–04). This term is not 

calculated for our single-point-in-time regressions for 2003–04. 

We attempted several different approaches to analyzing state-level differences, but these 

approaches were limited by the small sample sizes for most states in the CPS. We considered 

grouping states by the presence of a state-funded replacement program for food stamps for LPRs 

whose eligibility was restricted by PRWORA.17 We also considered analyzing the four largest 

states separately (California, Texas, New York, and Florida). There is considerable overlap 

between the replacement-program states and California; in fact, the vast majority of state 

program cases reside in California. Because results for the replacement-program states so closely 

mirrored those for California, we excluded the replacement-program state variables in the final 

models. Instead, we chose only to use the four major states; of these, only California and Texas 

showed significant results. As a result, in our final models we only included dummy variables for 

California and Texas, along with interactions with the citizenship and legal status 

categorizations. It is unlikely that other individual states or groups of states would show 

significant results because of small sample sizes for noncitizen units. 

17 The TRIM3 baseline simulation does not model eligibility or benefits from the state replacement programs. It is 

possible that some people receiving benefits from these programs report participation in the regular federal FSP on 

the CPS. TRIM3 would treat such cases as ineligible reporters, and set to 0 both the benefits for which they are 

simulated to be eligible and the benefits they are simulated to receive. Modeling state replacement programs is 

outside the scope of this study.