March 1, 2002

Dear Chairman Harkin, Senator Lugar, Chairman Combest and Representative Stenholm:

As you negotiate the differences between the House and Senate Farm Bills, we are writing to emphasize the need for a strong nutrition title and for significant reform of the Food Stamp Program. Governors urge the conferees to adopt the Senate-approved level of funding for food stamp reform. While the House bill includes a number of provisions that would improve the Food Stamp Program, they are only a first step toward true reform. The Senate bill offers a much more comprehensive set of reforms that could significantly improve the delivery of food stamp benefits by streamlining and modernizing the program. Simplifying the program and aligning program rules more closely with welfare reform are of great importance to the Governors, and we urge you not to miss the opportunity to bring a critical component of the federal-state human services framework into the 21^st Century.

As welfare reform has progressed throughout the country, policies within the Food Stamp Program have remained primarily stagnant. States are now working to address the needs of low-income families and individuals through a comprehensive package of supports, rather than piecemeal through individual program categories. The lack of flexibility within the Food Stamp Program, however, complicates this process. Governors believe that the program is riddled with complexities at the federal level that often make it unnecessarily burdensome for families in need to access benefits and difficult for states to administer.

We have attached a copy of the recently revised National Governors Association’s policy on food stamp reform. It outlines the nation’s Governors’ specific recommendations for reform of the Food Stamp Program and should be helpful to you as you negotiate the differences between the House and Senate versions of the Farm Bill.

In addition to the need for significant simplification of the Food Stamp Program, Governors believe that any food stamp reauthorization package must include provisions that would improve the current Quality Control (QC) system. The current QC system conflicts with the broader public policy goal of encouraging low-income individuals to maintain steady employment, and very often causes states to focus a disproportionate amount of their resources on process-oriented measures, rather than on actually improving a family’s well-being.

Both the House and Senate bills include provisions that replace the existing arbitrary standard for assessing fiscal penalties with one that takes into account states’ error rates over a three-year period. These changes, along with the program simplification, are a first step toward adopting more outcome-based measures. However, the Senate bill also includes new authority for the U.S. Secretary of Agriculture to impose significant fiscal penalties on the basis of a finding of "serious negligence" in any given program year. Governors recognize the need to maintain a high level of integrity for the program, but also believe that authorizing additional fiscal sanctions based on a new, subjectively administered standard of performance takes the QC system in the wrong direction. While we strongly oppose this provision, we would welcome the opportunity to work with the conferees to provide a mechanism to ensure that states address any serious program deficiencies in a timely manner.

We also are concerned about the potential for an unintended additional burden on states that could result from an amendment that was adopted on the Senate floor. The amendment offered by Senator Richard Durbin (D-Ill.) and Senator Richard Lugar (R-Ind.), which partially restores food stamp eligibility to legal immigrants, was amended to include a provision that excludes from the restoration those immigrants who entered the country illegally. While Governors support the restoration of benefits for legal immigrants, we are concerned that this additional provision could significantly increase the administrative burden on states and could have the effect of making food stamp caseworkers into immigration investigators. This is not an appropriate role for the state agencies administering the Food Stamp Program and we urge you to reject this provision.

We appreciate your commitment to improving the Food Stamp Program and urge the conferees to recognize the importance of these reforms by approving a significant level of funding for the nutrition title as was included in the Senate Farm Bill. Success in the Food Stamp Program relies heavily on a strong federal-state partnership, and, in that spirit, we look forward to continuing to work with you to develop solutions that will most effectively improve the lives of those in need.

Sincerely,

cc: House and Senate Conferees

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