Healthi Kids has spoken out in opposition to the administration’s proposed changes to SNAP. The new rule will ultimately increase food insecurity which will harm whole child health. The changes will also make it more costly for states to run their SNAP programs. 


Program Design Branch, Program Development Division

Food and Nutrition Service, USDA

3101 Park Center Dr.

Alexandria, VA 22302

September 20, 2019

RE:  Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program, FNS-2018-0037


Dear Program Design Branch,

As a coalition advocating to support whole child health and well-being, the Healthi Kids initiative would like to state our opposition to USDA’s Proposed Rulemaking on the revision of categorical eligibility in the Supplemental Nutrition Assistance Program FNS-2018-0037.

Healthi Kids is a grassroots community coalition and an initiative of Common Ground Health that advocates for whole child health in Rochester and the Finger Lakes region in New York. We advocate for policies, systems and environmental changes that nurture the physical, social, emotional and cognitive development of kids from birth to age 8. We do this by focusing on policies that promote healthy habit building and healthy relationships, create safe and secure environments and psychological safety, and cultivate skills and competencies of adults who care for children.

The proposed changes will have detrimental impacts on the physical health, academic success, and social, emotional, and cognitive development of children across the country. An increasing body of research recognizes the long-term negative impact that childhood food insecurity and related stress can have on health. A recent report from the National Institutes of Health recommended reducing barriers to food access as a key component in efforts to help children develop and thrive.[1] The proposed rule would increase food insecurity and harm children and families who rely on this critical resource to thrive.

SNAP Provides Crucial Support for Children in Our Community

In Monroe County, NY, over 100,000 people rely on SNAP (aka food stamps or EBT) to afford food each month. Many of these individuals are the children of working parents just trying to make ends meet. The SNAP program prevents these parents from having to choose between housing, medical care, and food for themselves and their kids.[2] Even with crucial programs like SNAP, recent research by Common Ground Health has shown that the cost of food is the top barrier for people who would like to eat healthier, at the same time that diet remains one of the top concerns when it comes to health.[3]

SNAP Nourishes Children’s Bodies

When kids go hungry, their physical health suffers. According to multiple studies, parents in families that experience food insecurity are twice as likely to report that their kids’ health is only fair or poor. More studies have shown that kids who are food insecure have measurable nutrient deficiencies and diseases because they are not getting enough healthy foods.[4]

We know that there are higher numbers of chronic conditions and higher rates of hospitalizations among kids who are food insecure. Studies have also demonstrated more cases of iron-deficiency anemia in young children who are food insecure.[5] [6] Anemia can slow growth, cause fatigue and increase the risk of infections. Kids who are food insecure also have lower bone-mineral content, more frequent headaches, stomach aches, and colds.[7] [8] In Common Ground Health’s 2018 My Health Story survey, residents prioritized healthy weight, diet and nutrition as top health concerns for their children.[9]

SNAP Helps Kids Succeed in School

By kicking kids off SNAP, the proposed rule change could jeopardize free breakfasts and lunches in school for more than 500,000 kids.[10] In some states, including New York, children who receive SNAP benefits are automatically eligible to receive free school meals. Children who are not automatically eligible must submit an application to qualify putting additional burden on children and families.

Losing free school meals and increasing food insecurity at home goes against what we know helps kids succeed in school. Simply put, food insecurity is bad for kids’ brains. The negative effects show up on test scores, when food insecure children are unable to keep up with their food secure peers in math and reading.[11] [12] As they get older, food insecure kids are more likely to be required to repeat grades.[13]

SNAP Is Crucial for Developing Minds and Social-Emotional Skills

As young brains grow, they forge countless new pathways and connections that will shape people for the rest of their lives. When young kids experience trauma and toxic stress, such as what they experience during food insecurity, it disrupts the brain’s ability to grow and make important connections. Without the right supports, this type of experience can make it hard for kids to develop important social and emotional skills. It can also lead to poorer health outcomes later in life.[14]

Kids who experience food insecurity can have a harder time developing relationships, and they suffer from anxiety and withdraw from social environments more often than food secure kids. Self-control can be more difficult for hungry kids, and that can lead to trouble in school and at home.[15] The negative symptoms affect kids of all ages, from adolescents (higher rates of symptoms of suicide) to toddlers (insecure attachment to their caretakers).[16] [17]

The Healthi Kids Coalition Opposes the Proposed Rule

Based on the research examining the relationship between SNAP and children’s health, the Healthi Kids Coalition strongly opposes the proposed rule that will increase food insecurity, and therefore, negatively impact the health and well-being of vulnerable children.


Dina Faticone, Director of Community Health and Engagement, Common Ground Health on behalf of the Healthi Kids Coalition


[1] National Academies of Sciences, Engineering, and Medicine (2019). Vibrant and Healthy Kids: Aligning Science, Practice, and Policy to Advance Healthy Equity. D.C.: National Academies Press.

[2] Schwarzenberg, S.J., et al. (2015). Promoting Food Security for All Children. Pediatrics, 136(5).

[3] Pennise, M. (2019). Food and Health Connection. Rochester, NY: Common Ground Health.

[4] Coleman-Jensen, A., McFall, W., and Nord, M. (2013). Food Insecurity in Household With Children. Prevalence, Severity, and Household Characteristics, 2010-11. United States Department of Agriculture Economic Research Service EIB 113.

[5] Alaimo, K., et al. (2001). Food insufficiency, family income, and health in US preschool and school-aged children. American Journal of Public Health, 91(5): 781-786.

[6] Eicher-Miller, et al. (2009) Food insecurity associated with iron deficiency anemia in US adolescents. The American Journal of Clinical Nutrition, 90(5): 1358-71.

[7] Schwarzenberg (2015).

[8] Coleman-Jensen, McFall, and Nord (2013).

[9] Pennise (2019).

[10] Scott, Robert C., House of Representatives. Committee on Education and Labor. Letter to Secretary of Agriculture, July 26, 2019.

[11] Jyoti, D.F., Fongillo, E.A., and Jones, S.J. (2005). Food insecurity affects school children’s academic performance, weigh gain, and social skills. The Journal of Nutrition, 135(12): 2831-9.

[12] Winicki, J. and Jemison, K. (2003). Food insecurity and hunger in the kindergarten classroom: Its effect on learning and growth. Contemporary Economic Policy 21(2): 145-57.

[13] Coleman-Jensen, McFall, and Nord (2013).

[14] Center on the Developing Child at Harvard University (2019). InBrief: The Foundations of Lifelong Health. Accessed 8/20/19 at

[15] Coleman-Jensen, McFall, and Nord (2013).

[16] Alaimo, K., Olson, C.M., and Frongillo Jr., E.A. (2002). Family food insufficiency, but not low family income, is positively associated with dysthymia and suicide symptoms in adolescents. The Journal of Nutrition 132(4): 719-725.

[17] Zaslow, M., et al. (2009). Food security during infancy: implications for attachment and mental proficiency in toddlerhood. Maternal and Child Health Journal 13(1): 66-80.