Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Supplemental Nutrition Assistance Program [22 VAC 40 ‑ 601]
Action Revise Guidelines for Counting Income Toward SNAP Eligibility
Stage Proposed
Comment Period Ended on 1/17/2014
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86 comments

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11/26/13  1:00 pm
Commenter: Pam

Revise Guidelines for Counting Income Toward SNAP Eligibility [22 VAC 40 ? 601
 

I am in strong support of this revision to snap policy. The current policy provides assistance to applicants that are in this country illegally because their income and shelter expenses are prorated to only the household members in their family that are us citizens. This counts less income overall to the assistance unit than a same size family with all us citizens and with the same exact amount of income. In most instances the family with illegal members recieves snap benefits, and the full us citizen family is denied as over income.

CommentID: 29361
 

11/26/13  1:16 pm
Commenter: Judith C. Robertson, Quality Assurance Analyst VDSS PRO

Proposed regulations regarding ineligible immigrants income
 

I have several reasons why I believe that all income should be counted in benefit determination when a non-citizen is involved.

1) The eligibility of US citizens and non-citizens should be based on the same guidelines.  Although I understand that the non-citizen households are not allowed equal needs accessment, the non-citizen's income is still available to the household in its entirety, not on a pro rata share.

2) US citizens should receive a greater needs accessment because they are US citizens.

3) Policy regarding determination of benefits when a non-citizen is a standard filing unit (SFU) household member is cumbersome and more often than not results in increased errors.

4) It is impossible to hold the non-citizen SFU member, or any other household member, responsible for purchasing and preparing foods separately based on who, within the household, is a recipient and who is not. 

5) Although it is unfortunate that citizens of another country must come to the US and request assistance in meeting day to day needs,  the US government and its citizens cannot afford to provide perpetual assistance to US citizens, much less non-citizens.  In this statement, I am referring to the able-bodied applicants without dependents (ABAWD) policy which requires a US citizen to meet an exemption or SNAP assistance will be limited within a 3 year period.  Non-citizens that apply for SNAP most often have children in the household which exempts the household from restraints under the ABAWD policy.  On the surface, this may seem "fair", but in actuality, a household with a non-citizen member is receiving assistance when a household comprised of US citizen(s) is not.

CommentID: 29362
 

11/26/13  1:55 pm
Commenter: Donna Montgomery, Roanoke County DSS

SNAP eligibility for households with ineligible or illegal immigrants - proposed regulation change
 

I am wholeheartedly in favor of the regulation change.  Under current regulations, households with ineligible or illegal immigrants are likely to receive more SNAP benefits than citizen households with the same income, expenses and number of persons in the home.  This change is needed to equalize access to food security for our citizens in Virginia.

CommentID: 29363
 

11/26/13  4:54 pm
Commenter: Deborah L. Belcher

Proposed change to handling income for illegal immigrants
 

I am in total favor of this change.  The way that income for illegal immigrants is being counted now in the SNAP program does not treat house holds equally for being ineligible for SNAP.  You are counting the entire income for the citizen and only a pro-rata share of the income for the non citizen.  This results in the citizen household  receiveing less stamps than the non citizen household.  This regulation has never made any sense.

CommentID: 29364
 

11/27/13  8:03 am
Commenter: Susie

Proposed SNAP regulation change regarding ineligible immigrants
 

I am 100% in favor of the proposed change regarding the way income is counted to a household of US citizens and non US citizens.  To deny benefits to a family consisting of all US citizens but approve SNAP for the household of US and non US citizens, using the same gross monthly income with the same household size is not correct.  This should have been changed long ago. 

CommentID: 29368
 

11/27/13  8:13 am
Commenter: Jessie

Purposed SNAP change for counting income
 

I am so glad to have the opportunity to tell you that this should absolutely be done. We deny our US citizens benefits when we are giving them to non citizens - that have as much and more income.  I don't know why this has taken so long to get this far, but I am so glad we are now at this point. This change should take place as soon as possible.
 

CommentID: 29369
 

11/27/13  8:26 am
Commenter: Tammy S. Parks - Benefits Supervisor, Westmoreland County DSS

Proposed change to SNAP regulations
 

I believe that the policy of counting income for households should be the same across the board.  It doesn't make sense to me that you would prorate the income of someone who is not a citizen in a household but that you would count it in its entirety for the same size houshold for somone who is a citizen.  Thinking logically it just doesn't make sense. 

CommentID: 29370
 

12/2/13  10:44 am
Commenter: GALAX DEPARTMENT OF SOCIAL SERVICES

SNAP INCOME FOR INELIGIIBLE IMMIGRANTS
 

INCOME FOR INELIGIBLE IMMIGRANTS SHOULD BE COUNTED IN FULL, JUST LIKE THE INCOME OF LEGAL RESIDENTS.  IT IS NOT RIGHT TO PENALIIZE LEGAL RESIDENTS FOR EXCESS INCOME AND ALLOWING ILLEGAL RESIDENTS TO BE ABLE TO RECEIVE  SNAP BENEFITS BECAUSE OF PRORATION OF INCOME.  

CommentID: 29388
 

12/2/13  10:50 am
Commenter: Rita Brown, Galax City DSS

Snap income for illegal immigrants
 

All income should be counted the same for illegal immigrants as it is for legal residents.  It is unfair to penalize legal residents for their total income that keeps them from receiving snap benefits but allows illegal immigrants to receive benefits due to proration of their income.

CommentID: 29389
 

12/2/13  11:01 am
Commenter: Pam Moore

Proposed regulations regarding ineligible immigrants income
 

I have been working these cases for a long time and have always felt we were treating the ineligible immigrants better than we did with the USA Citizens.  It was like we were awarding them benefits for being ineligible immigrants.  I can see the same situation with an Ineligible immigrants of a family of 4 with the same income as a family of 4 citizens and the results are that the ineligible immigrants are eligible but the USA citizens are not.  How fair is that?  This does not only apply to Snap but also to Tanf as I have alot of clients who's children receive Tanf but the parent does not, therefore, the parent is not put in View and there is no clock for the children.  All programs need to be looked at.

CommentID: 29391
 

12/2/13  2:25 pm
Commenter: Westmoreland County DSS

SNAP Income Calculation for Illegal aliens.
 

I feel the income should be counted the same way for all households.   There are cases when a family of 4 with 2 parents working but both parents are illegal, but are eligible for benefits because the income is prorated.  Then you have a family of 4 with 2 parents working, income is the same, all the family is legal and are over income for SNAP benefits.  This is definitely unfair, it's almost as if the illegal aliens are getting preferred treatment.  

CommentID: 29398
 

12/2/13  2:33 pm
Commenter: Tayna Bayliss, Westmoreland County DSS

SNAP change to Income Calculation
 

I an 100% in favor of this change to SNAP.  I feel the income should be counted the same way for all households.   There are cases when a family of 4 with 2 parents working but both parents are illegal, but are eligible for benefits because the income is prorated.  Then you have a family of 4 with 2 parents working, income is the same, all the family is legal and are over income for SNAP benefits.  This is definitely unfair, it's almost as if the illegal aliens are getting preferred treatment. 




 

CommentID: 29399
 

12/4/13  11:05 am
Commenter: Giles Co. Dept. of Social Services

Proposed Change for Income Evaluation for Illegal Immigrants
 

Giles Co. DSS is in favor of the proposed change in computation of income for illegal immigrants. 

CommentID: 29485
 

12/4/13  11:07 am
Commenter: Susan Clark, Galax DSS

22VAC 40-601 SNAP Regulations Regarding Counting Ineligible Immigant Income
 

The Galax Department of Social Services supports the proposed changes to uniformly treat income for all citizens and immigrant households as opposed to utilizing a "pro rata" formula for immigrant households.

This regulation would be a consistent step in aligning policies across Medicaid, SNAP, TANF Programs ensuring all of the income calculations are consistent for individuals we serve throughout our agencies.

Thank You

  

 

CommentID: 29486
 

12/4/13  11:10 am
Commenter: Carla Taylor

Consistency within SNAP income eligibility regulations
 

Shenandoah County supports the consistency and efficiency to be realized by the proposed changes.

CommentID: 29487
 

12/4/13  1:05 pm
Commenter: King William Social Services

SNAP Regulations Regarding Counting Ineligible Immigrant Income in SNAP - 22 VAC 40-601
 

This regulation is and has been supported by the League’s Financial Services committee as another step towards aligning policies across the Medicaid, SNAP and TANF programs and ensuring all of the income calculations are consistent for any individual we serve through our agencies. 

CommentID: 29496
 

12/4/13  3:03 pm
Commenter: Ellen Bittler, Bedford Co Dept of Social Services

... and justice for all
 

I'm wondering how we can proclaim "and justice for all" when our regulations do not reflect it.  I don't have different policies for races, religions, etc, I am required to take an online training each year to be sure I do not think, process or speak prejudicially.  However, I have to tell the people that are disqualified off a case - for very good reasons -  that they are not eligible for SNAP benefits because we have to count their full income amount, but their neighbor who is here illegally can receive benefits for their children just because they are illegal and we dont have to count their full income amount...  Doesn't that sound prejudice?  Why is this a difficult decision?  This is about as cut and dried as you can get and you need to act on this right away!!  There are people who need benefits that are not receiving them just because this policy has not been changed!

CommentID: 29503
 

12/5/13  12:13 pm
Commenter: Shel Douglas, Director of Prince George County Social Services

Proposed Change for Income Evaluation for Illegal Immigrants
 

 

 

Prince George County Social Services is in favor of the proposed change in computation of income for illegal immigrants. 




 

CommentID: 29522
 

12/10/13  5:45 pm
Commenter: Lisa Peacock, Culpeper Human Services

22VAC 40-601 SNAP Regulations Regarding Counting Ineligible Immigrant Income
 
22VAC 40-601 SNAP Regulations Regarding Counting Ineligible Immigrant Income
 

Culpeper Human Services supports the proposed changes to uniformly treat income for all citizens and immigrant households as opposed to utilizing a "pro rata" formula for immigrant households.

This regulation would be a consistent step in aligning policies across Medicaid, SNAP, TANF Programs ensuring all of the income calculations are consistent for individuals we serve throughout our agencies.  Thank you.

CommentID: 29580
 

12/11/13  10:25 am
Commenter: JIM BOWEN GALAX DSS

SNAP-regulations regarding ineligible immigrant's income
 

 I support the proposed changes to uniformly treat income for all citizens and immigrant households as opposed to utilizing a "pro rated" formula for immigrant households.

Thank You

CommentID: 29585
 

12/12/13  1:14 pm
Commenter: Christen Gallik, Fredericksburg Department of Social Services

SNAP Regulations Regarding Counting Ineligible Immigrant Income in SNAP - 22 VAC 40-601
 

The Fredericksburg Department of Social Services supports  the proposed changes so that income will be treated uniformly across all citizen and immigrant households instead of using a “pro rata” formula for immigrant households.  This regulation would provide consistency in the treatment of income and be more efficient because it would make the eligibility calculation less complicated.

 

CommentID: 29609
 

1/6/14  2:58 pm
Commenter: Cheryl Weaver, Benefit Supervisor, City of Roanoke DSS

22vac 40-601 SNAP Regulations Regarding Counting Ineligible Immigrant Income
 

I support the proposed change to count ineligible/illegal immigrant income the same as US citizen income. The general public would be outraged if they knew of the current policy which can allow a family with illegal immigrants receive benefits and a US citizen household with the same income be denied! In all my 26 years with Benefit Programs, this current inconsistent policy of counting income has been the most infuriating.

 

CommentID: 29861
 

1/8/14  12:50 pm
Commenter: Helen Walters, Family Benefits Supervisor, Albemarle County DSS

22VAC40-601-70. Income calculation method of ineligible immigrants. (Proposed Change)
 

As a former Eligibility Worker/Benefits Program Specialist and current Benefits Eligibility Supervisor, I support the proposed change fully as it has been submitted.

CommentID: 29894
 

1/8/14  12:58 pm
Commenter: Sharon Hardy, DSS

I am in agreement to count ALL of the income in determining benefits for ineligible immigrants.
 

CommentID: 29895
 

1/8/14  1:18 pm
Commenter: Pamela Powell, BPSII, Washington County DSS

Income of Illegal Imigrants
 

I think we should count all of the income of illegal immigrants just as we do household members who are disqualified for felony drug convictions. 

CommentID: 29896
 

1/8/14  1:24 pm
Commenter: Dennis Ashworth, Va Beach Dept of Human Services

SNAP income of ineligible immigrants
 

The income of ineligible / illegal / undocumented immigrants should be counted in full, just as the income of citizens.    It is wrong for citizens to be penalized for excess income and yet  ineligible / illegal / undocumented residents are able to receive benefits for their households because of proration of income. 

CommentID: 29897
 

1/8/14  1:29 pm
Commenter: B.J. Dove, BPRO, Frederick County Dept of Social Services

Proration of income for undocumented aliens in SNAP households
 

In order to make policy consistent for all households in the SNAP program, we should count all income of household members over 18 who eat together as a household.  If you have a 5 person household and one HH member is working it should not matter that that person is an ilegal alien and we only count part of the working person's income. That income is available to all household memebers who eat meals together just as it would be to a 5 person household if all the members were US citizens or documented aliens. Do we really think for one minute that the person not being counted is not eating the food purchased with those benefits and that that household is not benefitting from all of that person's income?  This is turly an inequality in SNAP policy that should be reviewed and corrected.

CommentID: 29898
 

1/8/14  1:32 pm
Commenter: Nicole Henrico DSS

Policy Change
 

I am in full support of the proposed changes to this law. It is unfair to count partial income for illegal alients but to count full income for US citizens. Thank you for finally looking into this policy.

CommentID: 29899
 

1/8/14  1:38 pm
Commenter: Marjie Ratliff, City of Roanoke DSS

SNAP Income Calculation of Income for Ineligible Illegal Immigrants
 

I support counting the full amount of income of Ineligible Illegal Immigrants.   

CommentID: 29900
 

1/8/14  1:41 pm
Commenter: Donna DeBoard, Scott County Social Services

Ineligible Immigrant Income Proposal
 

I support counting all income of an ineligible immigrant for SNAP purposes.

CommentID: 29901
 

1/8/14  1:48 pm
Commenter: Damita White, Arlington County DSS

Policy Change
 

I support the proposed changes to count the full income for ineligible illegal immigrants just the same as citizens. No proration  which brings uniformity to the policy.

CommentID: 29902
 

1/8/14  2:10 pm
Commenter: L A Turkowsky, Benefit Program Specalist, Clarke County DSS

Policy Change
 

I believe that all members of all household should have their income counted the same way - without any difference for citizen or non-citizen.

CommentID: 29903
 

1/8/14  2:13 pm
Commenter: Laura Brown

SNAP Income for illegal immigrants
 

INCOME FOR INELIGIBLE IMMIGRANTS should be counted the same (full amount) just aspolicy requires us to do for legal residents.  To count any less is allowing illegal residents to receive over those who are legal.  Here in the field we see many cases where a legal family would be eligible for benefits if given the prorated adjustment that policty currently affords the illegal applicants.  Our legal children are in need of this assistance too - policy needs to align equally across the board for all applicants.

CommentID: 29904
 

1/8/14  2:25 pm
Commenter: Deborah Ward, Norfolk Department of Human Services

Proposed Regulation Regarding Ineligible Immigrants
 

I support the proposed regulation to count all income of an ineligible immigrant to determine SNAP benefits.

CommentID: 29905
 

1/8/14  4:31 pm
Commenter: Myra, Henrico DSS

proposed snap countable income change
 

I support the proposed change and believe policy should apply to all straight across the board. Regardless of citzenship/Alien/Immigration status.

CommentID: 29910
 

1/9/14  6:02 am
Commenter: Norma Searcy

Revised Guidelines for Counting Income for SNAP
 

I thnkk all of the income should be counted toward the entire household.  The entire household has access to the income that is received in the home for adults over 18.  Is it the belief that the way the income is being  counted that  the person that is earning the  income is not eating the food purchased from the SNAP benefits?.

All of the income of the household is counted for US citizens and an ilegal alien has only a portion of  their income counted. Does this appear to be fair?

I think the policy needs to be the same for an alien as for a citizen.  

CommentID: 29916
 

1/9/14  7:47 am
Commenter: david Sftrode

Proposed proration of alien income.
 

I feel that this should be stopped as it is not fair for other familys that come into the agency and they may be over by just a few dollars and if their income was prorated their children would be able to benefit from the snap program  as well.  

CommentID: 29919
 

1/9/14  7:49 am
Commenter: david Sftrode

Proposed proration of alien income.
 

I feel that this should be stopped as it is not fair for other familys that come into the agency and they may be over by just a few dollars and if their income was prorated their children would be able to benefit from the snap program  as well.  

CommentID: 29920
 

1/9/14  8:16 am
Commenter: PDSS

COUNTABLE INCOME FOR INELIGIBLE ALIEN
 

ALL INCOME OF AN INELIGIBLE ALIEN SHOULD BE COUNTED.  THE POLICY SHOULD BE THE SAME FOR THEM AS IT IS FOR THE CITIZEN.

CommentID: 29921
 

1/9/14  8:17 am
Commenter: Sorchae Washburn

illegal alien income and snap
 

I support the proposal to count all illegal alien income when determining eligibility for snap the same way that citizen income is counted

CommentID: 29922
 

1/9/14  8:44 am
Commenter: Elande J.Snead

income of illegal immigrants
 

I think all of their income should be counted for all programs as it is for U.S. citizens.

CommentID: 29923
 

1/9/14  9:03 am
Commenter: Cheryl Good-Harrisonburg/Rockingham

Change of countable income for illegal immigrants
 

I am in favor of changing this policy.  All income should be counted regardless if you are a citizen or illegal.  It feels as if we discriminate against the citizens of this country in order to be poltically correct for the ailens who are here illegally.

CommentID: 29924
 

1/9/14  9:11 am
Commenter: Lourdes

Revise Guidelins for Counting Income Toward SNAP Eligibility.
 

The SNAP eligibility guidelines for U.S. citizens, legal immigrants, and illegal immigrants should be the same.   "... and justice for all",  says it all; if not it's descrimination. Please revise this policy so that all are evaluated equally.

CommentID: 29925
 

1/9/14  9:38 am
Commenter: Pat Rivers, Arlington County, BPRO

Supporter of policy change to count illegal immigrants' income
 

I am in full support of the proposed policy change to count all income of the illegal immigrant in determining household eligibility.  This is the policy for all other households and illegal immigrants should not be the exception.

CommentID: 29926
 

1/9/14  10:33 am
Commenter: Amber Thomas, Rockingham-Harrisonburg DSS

SNAP policy change regarding proration of income
 

I am in full support of this change. If our legal citizen families do not have the option to exclude household members, therefore prorating their income, our non-citizen applicants should be held to the same guideline. ALL income should be counted for ALL SNAP applicants regardless of status in this country. It doesn't seem right for citizens to be penalized and denied benefits for excess income and allow illegal or non-citizen families to receive benefits for their households based on proration of income. Thank you for addressing this policy!

CommentID: 29927
 

1/9/14  10:55 am
Commenter: lynn skidmore ldss

income for illegal immigrants should not be prorated
 

CommentID: 29929
 

1/9/14  1:47 pm
Commenter: O. Cooper, PDSS

Proposed Regulation Regarding Ineligible Immigrants
 

I agree that all income of Ineligible Immigrant's should count. No exception's, if they are part of the AU. 

As a government agency, we need to be fair across the board. What would make their income exempted?

We count it for citizen's with PWID's, ineligible immigrants should not be different. They apply, claim to be part of AU, & report income; so count it in it's entirety!

CommentID: 29931
 

1/10/14  7:56 am
Commenter: Colleen Gleason, Charlottesville DSS

Counting ineligible alien income in Snap HH
 

I support this proposal to count all income.

CommentID: 29943
 

1/10/14  8:02 am
Commenter: c. gleason

Proposed change to income inclusion for ineligible aliens
 

I support the proposal to count all ineligible alien income in a Snap HH.

CommentID: 29945
 

1/10/14  8:07 am
Commenter: Pamela Felts

agree
 

I agree that the full amount of income should be counted toward the legal immigrants or US citizens.  I also feel that the illegal parents should be made to apply for legal immigrant status in order for the household to continue to receive benefits from the state.  Even though the illegal immigrants are not included in the benefit amount that the household receives - they can still eat the food that is provided to the household.  U. S. citizens have to meet exemptions in order not to be required to participate in the SNAPET program or have their months of benefits restricted but the illegal immigrant households have not limits on the months for SNAP or TANF which is not fair to the US citizens.

CommentID: 29946