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WriteaLetter

Last week, Allies for Children submitted comments to the U.S. Office of Management and Budget proposal to change how the Census Bureau’s Official Poverty Measure (OPM) is adjusted annually for inflation. To view these comments in their entirety, click here.

As our blog last month noted, this is no minor procedural change. If enacted, this would have a wide impact and cause significant damage to the social safety net in our country. The proposed lower annual adjustment would, in effect, impose automatic eligibility cuts on a wide range of programs, from nutrition services to health insurance, harming low-income children. Allies for Children is encouraging organizations and concerned citizens to submit comments here by the June 21, 2019 deadline.

Our comments focus on the following three points:

  1. Switching from the Consumer Price Index for All Urban Consumers (CPI-U) to one of the suggested alternatives, such as chained CPI (C-CPI-U) would not result in a more accurate measure of poverty.
  2. No federal law or regulation requires OMB to review or change the measure currently used. This potential change is entirely discretionary and yet the Request for Comment includes no detailed legal and policy analysis justifying such a change from the longstanding use of CPI-U. Moreover, Congress has exhibited a strong intent favoring the use of CPI-U.
  3. The administration has conducted no analysis on the impact such a change would have on federal low-income programs. Here in Allegheny County, individuals enrolled in Medicaid comprise a total of 240,243, including 97,097 children, while 13,706 receive health insurance through CHIP. In addition, 146,951 of the most vulnerable residents in Allegheny County participate in SNAP to lift themselves out of poverty and alleviate food insecurity, and 12,664 women, infants, and young children rely on the WIC program. By lowering the poverty line, the proposed change would, in effect, result in automatic cuts to vital programs children and families need in order to remain healthy, nourished, and poised for success in life. Moreover, the severity of these cuts would sharpen each year. The Center on Budget and Policy Priorities, for example, found that using chained CPI to adjust the OPM would result in more than 300,000 fewer low-income children enrolled in Medicaid and CHIP by 2029, compared to current law.

For these reasons, Allies for Children’s comments strongly recommend the current inflation adjustment, CPI-U should continue to be used to measure poverty. We encourage others concerned about preserving vital programs for children to submit comments.