State and local groups focused on food insecurity are speaking out about a proposed federal rule change that would cause millions of people to lose their food stamps, and could subsequently result in children losing automatic eligibility for free school meals.

The rule change, proposed by the U.S. Department of Agriculture last month, would close what the department has called a “loophole” in the federal Supplemental Nutritional Assistance Program (SNAP), more commonly known as food stamps.

Currently, families in New Hampshire and 38 other states that receive benefits or services from a federal welfare program called Temporary Assistance for Needy Families (TANF) are automatically eligible for food stamps, and children in those families are automatically eligible for free meals through the National School Lunch Program.

But the eligibility requirements for the TANF program vary by state, and in some cases are less stringent than the requirements for SNAP, the department said in its proposal.

The rule change would limit automatic eligibility for SNAP to TANF recipients who collect benefits valued at a minimum of $50 per month for at least six months in an effort to weed out recipients who would not otherwise meet income and asset requirements for SNAP. It would also limit the kinds of non-cash TANF assistance that would confer automatic eligibility for SNAP to aid such as job training and childcare benefits.

“For too long, this loophole has been used to effectively bypass important eligibility guidelines. Too often, states have misused this flexibility without restraint,” said U.S. Secretary of Agriculture Sonny Perdue in a news release last month, stating that the goal of the change is to prevent abuse within the system.

The USDA oversees SNAP and the National School Lunch Program, while the U.S. Department of Health and Human Services is in charge of TANF.

But local advocates and organizations have questioned who the change benefits. Roughly 3.1 million people would lose their food stamps, according to the proposal. And The New York Times reported that more than 500,000 children would lose automatic eligibility for free school meals.

That doesn’t necessarily mean those children don’t qualify for the school meals program. But their families would now be required to reapply for assistance, a process that can be an obstacle for people of low income.

“So it’s just another barrier that’s put in front of people who probably have enough barriers, to be quite honest,” said Phoebe Bray, executive director of The Community Kitchen in Keene.

Elaine VanDyke, board chairwoman of the Concord-based nonprofit organization N.H. Hunger Solutions, said the change could also undermine the “direct certification” system that was designed to streamline the application process and cut down on redundant paperwork by cross-referencing eligibility for different federal assistance programs.

More than 8 million children were directly certified for free school meals through the program in 2016-17, according to the USDA. But losing automatic eligibility would mean families would need fill out separate applications, requiring additional time and resources not just for those families, but the agencies that assist them, as well.

“It just goes back to the historical dinosaur age when we didn’t have the ability to use a technological rigor to ensure that these families were meeting a strict criteria,” VanDyke said.

The change could also discourage families from applying at all, she said.

“Now that they’ve been kicked off the food stamps, do you honestly think they’re going to go and reapply for school meals? It’s not going to happen. I mean, we know — first of all, the demoralization of that action is going to be enough to say to most families, why bother?” VanDyke said. “What chance do I have?”

The USDA and others have cited the case of a Minnesota man named Rob Undersander as an example of how the loophole allows people who don’t truly need benefits to qualify for them. Undersander says he was able to collect food stamp benefits for 19 months despite being a millionaire because his state’s program doesn’t use a person’s assets to determine food-stamp eligibility.

Jonathan Butcher, a senior policy analyst for the Heritage Foundation, a conservative think tank, said the proposed change would help ensure the government is “providing resources to the children who are in need and not providing resources to those who are not in need,” The New York Times reported.

But some question whether this type of abuse is widespread.

“The idea is that this new regulation would curtail the abuse of the system. But what it’s doing is it’s purging the entire system and literally throwing the baby out with the bathwater,” said Ann Henderson, president of Monadnock Understands Childhood Hunger, a coalition of area organizations and volunteers. “So those that really need it are being punished for those that are abusing the system.”

Bray similarly described the proposed change as a way of “punishing poor people.”

“In the scheme of things, when you think of how much free and reduced meals and food stamps make up of the budget, it’s like a drop in the ocean,” she said.

The proposed change is estimated to result in a net reduction in federal spending of nearly $9.4 billion over five years, the proposal says.

Jake Leon, director of communications for the N.H. Department of Health and Human Services, said in an email Friday that the state agency is in the process of reviewing the proposed change to understand the potential impact on New Hampshire residents.

Especially coupled with recent national attention on cases of “lunch shaming” — in which students and parents have been singled out for not being able to pay school lunch bills — Henderson said the proposed rule change is significant cause for concern.

“All of these things should not be happening in a system that is working to take care of students and kids. They just should not be happening,” Henderson said. “The fact that all this stuff is happening points to the system not working as well as it could.”

The open comment period for the proposed rule change ends Sept. 23. Comments can be submitted online at

Meg McIntyre can be reached at 352-1234,

extension 1404, or Follow her on Twitter @MMcIntyreKS.