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” Coalition of California Welfare Rights Organizations, Inc. Organizations [image: \/var\/folders\/69\/vl0ghz9w8vl4zwlvt9_64w4c0000gp\/T\/com.microsoft.Word\/WebArchiveCopyPasteTempFiles\/BE34486B-F504-4907-B822-F8220C9F5DA1.jpg]CCWRO Kevin M. Alsanian Executive Director Grace A. Galligher, Directing Attorney 1111 Howe Ave., Suite 150, Sacramento, CA 958125-8551 Tel. (916) 736-0616 Fax (916) 736-2645 Cell (916) 712-0071 [email protected] www.ccwro.org April 4, 2018 Ms. Sasha Gersten-Paal SNAP Program Development Division Food and Nutrition Service 3101 Park Center Drive Room 812 Alexandria, VA 22302 [bookmark: _GoBack]Notice of Proposed Rulemaking: Supplemental Nutrition Assistance Program: Requirements and Services for Able-Bodied Adults Without Dependents RIN 0584 AE57 Dear Ms. Gersten-Paal: Thank you for the opportunity to comment on USDA’s Advanced Notice on requirements and services for Able-Bodied Adults Without Dependents (ABAWDs). CCWRO is a statewide organization founded in 1980. Our mission is to make this a better place for all . Our organization has always paid close attention to the food stamp program for decades. SNAP is the only program in the United State of America that prevents widespread famine from happening in the USA. Any rule that would result any human being to go to bed hungry is unconscionable. Federal law limits SNAP eligibility for childless unemployed and underemployed adults age 18-50 (except for those who are exempt) to just three months out of every three years unless they are able to obtain and maintain an average of 20 hours a week of employment. This rule is cruel and unusual punishment for being poor. At least 500,000 low-income individuals nationwide lost SNAP in 2016 due to the barbaric and unconscionable time limiting food rule. While this request for comment appears to be open to suggestions on how to make the time limit less harsh via administrative action, we are concerned that the Administration seeks only to make the rule more draconian: to expand the scope of the cutoff and to eliminate the little flexibility states have to limit the damage of the rule. The Department’s stance on the time limit is not one that our organization shares and neither do most Americans. If you did a poll and ask do you think the government should let people go hungry because they are not able to find a job after three months most would say hell no . The Secretary of Agriculture has suggested that they need to remove those waivers for able-bodied adults without dependents, because it’s become a lifestyle for some people. Going to sleep hungry is not a lifestyle that our forefathers envisioned. Sentencing humans to hunger for not being able to find a job is not humane. Moreover, there is no evidence that the starving person who has or has not refused to work is a violation of the plain language of the eight amendment of the U.S. constitution that says no unusual punishment shall be inflicted upon the People of the United States. The Department of suggesting that people who do not work should not eat. That is exactly what Vladimir Lenin said in 1917. That is what USDA and the proponents of this inhumane are saying becoming the 21st century Leninists ? USDA’s budget has proposed making the time limit harsher by repealing states’ flexibility to exempt certain individuals and most high unemployment areas from the time limit and exposing more people to this punitive policy. As a result, we are deeply concerned that this request for comment is part of an administrative effort to make the time limit even more harsh. We strongly oppose any administrative action by USDA that would expose more people to severe hunger and Leninist punishment for not being able to find a job and taking away state flexibility. Under the law, states have the flexibility to waive areas within the state that have experienced elevated unemployment. The rules governing areas’ eligibility for waivers have been in place for nearly 20 years and every state except Delaware has availed themselves of waivers at some point since the time limit became law. The waiver rules are reasonable, transparent, and manageable for states to operationalize. Any change that would restrict, impede, or add uncertainty to our state’s current ability to waive areas with elevated unemployment must not be pursued. The only action we encourage USDA to take with respect to this time limit rule that impacts Able-Bodied Adults Without Dependents is to propose its elimination the humane and Christian thing to do. Restoring SNAP’s ability to provide food assistance to impoverished unemployed people would be a powerful policy improvement that would reduce food insecurity among those seeking work. We have analyzed your notice of proposed rule and would like to specifically respond to the questions posed therein: FNS Question Answer from the People Department is concerned that the number of areas waived has not decreased as much as would be expected during the continued decline in unemployment rates over this time period. For these reasons, the Department is seeking comments on how to ensure the waiver criteria best reflects economic conditions. Not true. According to President Trump \”The unemployment rate number isn’t reflective. I’ve seen numbers of 24 percent — I actually saw a number of 42 percent unemployment. Forty-two percent.\” He continued, \”5.3 percent unemployment — that is the biggest joke there is in this country. The unemployment rate is probably 20 percent, but I will tell you, you have some great economists that will tell you it’s a 30, 32. And the highest I’ve heard so far is 42 percent.\” It appears that the Department of USDA is contradicting the statement of President Trump that the UI rates asserted by the government and USDA in this notice are incorrect and it is the biggest joke and not reflective of the real unemployment rate. USDA needs to get on board with the views of the person in the White House today. The Department is reviewing how it could take action on limiting ABAWD waivers as proposed in the President’s budget proposals. In light of the Department’s interest in helping SNAP participants find and maintain meaningful employment, how could the process for requesting to waive the time limit, the information needed to support waiver approval, and the waiver eligibility parameters be changed in order to provide appropriate relief for areas of high unemployment and a clearly demonstrated lack of jobs? How could the definition of lack of sufficient jobs be revised to better support these goals? States currently have discretion to define the area they are requesting to waive. Should States maintain this flexibility? Should an economic area be limited in geographic scope, such as to a single county, metropolitan area, or labor market area? This should be a local or state decision and the federal government should be ready to help the people in the State to make decisions and not to think that one size emanating from the Washington Ivory Tower fits all. The idea that somebody should starve because there are some jobs out there is inhumane reflecting the views of the dark ages of this planet. FNS Question Answer from the People Should FNS accept data from additional sources of information that are currently not considered? If so: What data sources would that be? What review process should FNS use to verify the validity of the data? This is insulting to our partners at the local and state level operating the SNAP program implying that they are submitting bad data. It appears that the Department is more interested in building a largess of bureaucracy by creating unnecessary work just to have more bureaucrats at the federal level Waivers are typically approved for 1 year, although under certain criteria 2-year waivers are available. Should FNS consider waivers of different time periods? If so, what time period and under what conditions? ABAWDS waivers should be permanent unless FNS has verifiable data to show that the conditions have changed, and a waiver is no longer necessary. To request waiver year after year is an abuse of taxpayer dollars and should be stopped. What challenges and barriers do States face in helping ABAWDs find and maintain employment? What do States need to build or strengthen their capacity, investment, and expertise in working with this population? The lack of jobs that ABAWDS can access is severely limited. The barrier is no jobs. Moreover, ABAWDS can barely eat and stay alive. Some do not have the resources that it takes to find and maintain a job. For that one needs reliable transportation, an address and a telephone, none of which is provided by the SNAP program. What is the appropriate role of States in assessing ABAWDs for barriers to employment, job skills, and career interests in order identify appropriate opportunities for fulfilling the work requirements? At what point in the process is this most useful? During the interview? After certification. At all times. These are human being and living creatures. We know that ABAWDS are not the unborn that many are concerned about, yet those same people so concerned about the unborn could care less about the ABAWDS suffering from hunger just because there are no jobs accessible to the ABAWDS. FNS Question Answer from the People How can existing resources be leveraged by States to help ABAWDs find and maintain employment? Are there State\/local\/Federal or other stakeholders that can be leveraged to provide holistic services to ABAWDs? The federal funding for SNAP E&T is not open ended and rightly so SNAP E&T is a segregated racist employment program for food stamp recipients. If the government wants to help SNAP recipients with employment, they should look at the workforce development agency for employment services and not the food stamp agency. What do food stamp workers know about jobs? According to Newsweek Seven months into his presidency, job growth has slowed from the days under former President Barack Obama, when virtually all demographics of Americans were enjoying new job creation. Now, unemployment is ticking upward, as just 156,000 jobs were added to the American economy in August, the Labor Department reported Friday. The leadership of creating jobs should come from the Trump administration and not from the state and local governments. We are still waiting at the local level for the Trump jobs to materialize. Are there evidence-based activities that States could offer through their SNAP E&T programs that would help reduce barriers to employment among ABAWDs? What kinds of support services, job-retention services and other activities would increase success of ABAWDs moving into gainful employment? Are there additional ways that States could incentivize employers to provide jobs to ABAWDs? First make sure that the jobs are actually available before you tell people to look for jobs that do not exist. That is immoral. What is the appropriate scope of conditions and indicators of physical or mental unfitness for employment under current statutory authority, particularly in State determinations of whether an individual is obviously physically or mentally unfit for employment? What level of State flexibility is appropriate in this area? Why? It is very hard to come up with conditions and indicators that apply to every community. The federal government should allow local conditions to govern rather than this top down socialistic proposal by USDA, FNS. How do current certification processes (use of technology, lack of face-to-face interaction) affect the ability to determine exceptions or exemptions to the ABAWD time limit? How can these processes be modified or enhanced to best support these determinations, while providing any needed reasonable accommodations for individuals? Program efficiency and the wise use of our tax dollars is a primary concern for most Americans. The thought of going back to doing business in the 21st century like we did in the 20th century is appalling – wasting hard earned tax dollars. FNS Question Answer from the People Who should determine whether a participant is fit to work? What technical and information resources, or other resources, would best support States to better screen for unfitness for employment and other exceptions to the ABAWD time limit? What performance and\/or accountability measures would support this process? Today SNAP workers make that determination. There is no evidence that the current process is not working. The federal government could come up with suggested screening tools from the Academy of Science rather than from the Heritage Foundation that could be helpful as a guide and not a mandate. How can the Department\/States better engage and serve individuals determined to be unfit for employment? How can State agencies provide these individuals with services or opportunities that may increase their fitness for work? The federal government could fund a program to remove barriers that are the causes of being unfit for work. For example, people in need of dental work is one of the major barriers to some jobs because employers are not going to hire somebody with teeth looking like hell and with cavities that cause bad breath. There is a whole list of other barriers that ABAWDS have besides this simplistic Leninist illusion that ABAWDS need to be starved to get them to work. What are best practices for the use of 15 percent exemptions in supporting the appropriate application of ABAWD requirements? Let the States make that decision. [image: ] Kevin Aslanian, Executive Director CCWRO Mi liup ”

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“Sheet1 2018 California County Welfare Fraud Special Investigatice Unit (SIU) Office Designations County Who does Welfare Fraud County Who does Welfare Fraud Alameda DA Orange DA Alpine CWD Placer CWD Amador DA Plumas CWD Butte DA Riverside CWD Calaveras CWD Sacramento CWD Colusa DA San Benito CWD Contra Costa CWD San Bernardino CWD Del Norte DA San Diego CWD El Dorado DA San Francisco CWD Fresno DA San Joaquin DA Glenn CWD San Luis Obispo CWD Humboldt CWD San Mateo CWD Imperial DA Santa Barbara DA Inyo DA Santa Clara CWD Kern DA Santa Cruz CWD Kings CWD Shasta DA Lake CWD Sierra CWD Lassen CWD Siskiyou CWD Los Angeles CWD\/DA Solano DA Madera DA Sonoma CWD Marin CWD Stanislaus CWD Mariposa CWD Sutter CWD Mendocino CWD Tehama DA Merced DA Trinity DA Modoc DA Tulare DA Mono DA Tuolumne CWD Monterey DA Ventura DA Napa CWD Yolo DA\/CWD Nevada DA Yuba CWD ”

” 1 Cal-OAR Local Advocate Involvement Handbook By: Coalition of California Welfare Rights Organizations CCWRO 1111 Howe Ave., Suite 150, Sacramento, CA 95825-8551 Tel. 916-712-0071 Email: [email protected] Contact Person: Kevin Aslanian TABLE OF CONTENTS Executive Summary Page 2 CalWORKs Outcomes & Accountability Review by CDSS Partial Page 2 Local Advocate Engagement Statutes for Cal-OAR Page 4 Cal-OAR Implementation Timeline Page 5 Cal-OAR Statute Page 6 Cal-OAR Measures more county plans Page 11 Details of Cal-OAR Measures for county plans Page 12 Cal-OAR Advocate Involvement Proposed Actions Page 16 2 EXECUTIVE SUMMARY CalWORKs Outcomes and Accountability Review (Cal-OAR) CalWORKs Outcomes and Accountability Review (Cal-OAR) is a new CalWORKs county self-evaluation process done every three years to improve services to CalWORKs beneficiaries. Cal-OAR has three parts: (1) county performance measures of CalWORKs employment services, (2) a CalWORKs county self-assessment process, and (3) a CalWORKs county system improvement plan, including a peer review component that includes community participation in the process. Below is portions of the Cal-OAR instruction manual relative to advocate involvement and types of data that the county will be collecting for the CalWORKs employment program. CalWORKs Outcomes & Accountability Review Continuous Quality Improvement Instruction Manual Engage Stakeholders Select methods for stakeholder consultation; this may include, but is not limited to: large stakeholder meetings, focus groups, surveys, and interviews. Refer to Engaging Local Stakeholders section for the list of required stakeholders. Engage and collaborate with stakeholders in the meaningful discussion regarding performance measure data, client satisfaction survey results (See Client Satisfaction Survey section), and other relevant information to inform the CW- CSA. Refer to Appendix C: Stakeholder Engagement Toolkit for additional information on collaborating with local stakeholders, and the CW-CSA Reporting Requirements section for what feedback to consider in the data analysis. The county will utilize the information collected from stakeholder engagement and through the client satisfaction survey to support the CW-CSA. ENGAGING LOCAL STAKEHOLDERS As discussed previously, stakeholder engagement at the state level was statutorily required for the development and implementation of Cal-OAR. Continued stakeholder engagement and collaboration at the local level is required of CWDs for the CW-CQI process. This engagement and collaboration is critical to gain additional information and insight related to measure performance, strategies for improvement, and to better understand the impact of 3 system changes on CalWORKs clients and interrelated programs. Required local stakeholders include: County CalWORKs administrators, supervisors, and caseworkers Current and former CalWORKs clients County human services agency partners To the extent possible and relevant, local stakeholders should also include: Community College representatives Tribal organizations Local Workforce Development Board Adult Education providers Domestic abuse service providers Local housing and continuum of care programs County behavioral health departments County drug and alcohol programs Community-based service providers Organizations that represent CalWORKs clients Child care resource and referral programs Alternative payment programs Additional information and resources for engaging the local stakeholder community can be found in subsequent sections of this instruction manual and in Appendix C: Stakeholder Engagement Toolkit. Client Satisfaction Survey To promote stakeholder engagement within the Cal-OAR process, CDSS, Mathematica Policy Research, and current and former CalWORKs clients have collaboratively developed a CalWORKs client satisfaction survey. Data collected from this survey is a rich source of information available to CWDs for the CW-CQI process; for measure analysis and CalWORKs program assessment. More information on how to use survey data within the CW-CQI process can be found in the CW-CSA Section, within the Stakeholder Engagement and Feedback and Performance Measure Analysis subsections. Source: CDSS Continuous Quality Improvement Appendix C: Stakeholder Engagement Toolkit CDSS envisions this section providing information to CWDs to assist in the local stakeholder engagement process, required by Cal-OAR. This may include: A process guide on how to conduct formal and informal stakeholder convenings. Tips on how to focus discussions and make these meetings fruitful. Examples of how to best engage stakeholders (i.e. forums, webinars, online, focus groups). This information will also be addressed in training. 4 Local Engagement Statute for Cal-OAR 11523(d)(2)(B) (i) The county CalWORKs self-assessment process shall be completed every three years by the county in consultation and collaboration with local stakeholders and submitted to the department. (ii) Local stakeholders shall include county CalWORKs administrators, supervisors, and caseworkers; current and former CalWORKs recipients; and county human services agency partners. To the extent possible and relevant, local stakeholders shall also include representatives of community colleges, tribal organizations, and the local workforce board. Additional specific county human services agency partners shall be determined by the county and may include, but are not limited to, adult education providers, providers of services for survivors of domestic violence, the local housing continuum of care, county behavioral health departments, county drug and alcohol programs, community-based service providers, organizations that represent CalWORKs recipients, child care resource and referral programs, and alternative payment programs, as appropriate. (3) (A) (ii) (D) The county human services agency shall complete an annual progress report on the status of its system improvement plan and shall submit these reports to the department. The department, in consultation with the workgroup, shall develop uniform elements of the progress report. 5 CalWORKs OUTCOMES AND ACCOUNTABILITY REVIEW (Cal-OAR) IMPLEMENTATION TIMELINE TIMEFRAMES* CAL-OAR ACTIVITIES February 2019 Regular check in calls with SAWS begin – to answer questions and work out details re: data and reporting automation Feb 5-20: Performance Measures and Reporting ACL stakeholder review Late Feb: Final two-part CQI subcommittee to review Instruction Manual March 2019 Late March: CQI package ACL stakeholder review April 2019 Release Performance Measures and Reporting ACL Cal-OAR online training begins (April to include Cal-OAR 101 and measures\/reporting) – remote trainings continue regularly through July 2019 May 2019 Release CQI ACL Remote CWD training continues (May to include measures\/reporting) June 2019 Remote CWD training continues (June to include CQI) July 2019 July 1: Cal-OAR Implements (First three-year cycle: July 2019 thru June 2022) Remote CWD training continues (July to include CQI) September 2019 Monthly conference calls with counties to support CSA and SIP development to continue through December 2020 December 2019 Dec 16-18: CW Training Academy, to include Cal-OAR trainings Jan thru March 2020 In-person CWD trainings (approximate timeframe) Spring 2020 CSAs due Summer 2020 Cal-OAR Peer Review process to being (timeline will vary by county) Fall 2021 SIPs due Spring 2022 Progress Reports due 6 Cal-OAR actual statute 11523. (a) This section shall be known and may be cited as the CalWORKs Outcomes and Accountability Review Act of 2017. (b) The State Department of Social Services shall establish, by July 1, 2019, the California CalWORKs Outcomes and Accountability Review (Cal-OAR) to facilitate a local accountability system that fosters continuous quality improvement in county CalWORKs programs and in the collection and dissemination by the department of best practices in service delivery. The Cal-OAR shall cover CalWORKs services provided to current and former recipients, including those who are in sanction or exempt status or who are unengaged, and shall include the programmatic elements that each county offers as part of its CalWORKs service array as well as any local program components, and shall consist of performance indicators, a county CalWORKs self-assessment process, and a county CalWORKs system improvement plan. For purposes of this section, CalWORKs services shall include welfare-to-work, family stabilization, housing support, and post-employment job retention services. (c) (1) (A) By October 1, 2017, the department shall convene a workgroup comprised of representatives from county human services agencies, legislative staff, interested welfare advocacy and research organizations, current and former CalWORKs recipients, organizations that represent county human services agencies and county boards of supervisors, representatives of community colleges, tribal organizations, and the workforce investment system, and any other state entities that the department deems necessary. The workgroup members shall also include individuals with expertise related to domestic violence, substance abuse, and mental health. The workgroup shall establish a workplan by which the Cal-OAR shall be conducted, pursuant to the provisions described in this section, including a process for qualitative peer reviews of counties’ CalWORKs services. The workgroup shall discuss potential costs for state and county participation. (B) The department shall report annually to the Subcommittee on Health and Human Services of the Senate Committee on Budget and Fiscal Review and the Subcommittee on Health and Human Services of the Assembly Committee on Budget during the budget process with an update on the schedule for development of and future changes to the Cal-OAR. (2) At a minimum, in establishing the work plan, the workgroup shall consider existing CalWORKs performance indicators being measured, additional, alternative, or additional and alternative process and outcome indicators to be measured, development of uniform elements of the county CalWORKs self-assessment and the county CalWORKs system improvement plans, timelines for implementation, recommendations for reducing the existing CalWORKS services 7 data reporting burden in light of new requirements established by the act that added this section and the resulting Cal-OAR, recommendations for financial incentives to counties for achievement on performance measures, and an analysis of the county and state workload associated with implementation of the requirements of this section. (d) The Cal-OAR shall consist of the following three components: performance indicators, a county CalWORKs self-assessment, and a county CalWORKs system improvement plan. (1) (A) The Cal-OAR performance indicators shall be consistent with programmatic goals for the CalWORKs program, and shall include both process and outcome measures. These measures shall be established in order to provide baseline and ongoing information about how the state and counties are performing over time and to inform and guide each county human services agency’s CalWORKs self-assessment and CalWORKs system improvement plan. (i) Process measures shall include measures of participant engagement, CalWORKs service delivery, and participation. Specific process measures shall be established by the department, in consultation with the workgroup, and may include measures of engagement as shown by improvement in program participation, timeliness of service provision, rates of utilization of program components, such as vocational education, and referrals and utilization of services based upon recommendations from the Online CalWORKs Appraisal Tool. (ii) Outcome measures shall include measures of employment, educational attainment, program exits, and program reentries, and may include other indicators of family and child well-being as determined by the department, in consultation with the workgroup. (B) Performance indicator data available in existing county data systems shall be collected by counties and provided to the department, and performance indicator data available in existing state department data systems shall be collected by the department and provided to the counties. These data shall be reported in a manner and on a schedule to be determined by the department, in consultation with the workgroup, but no less frequently than semiannually. (C) (i) During the first three-year Cal-OAR cycle, performance indicator data, as reported by each county, shall be used to establish both county and statewide baselines for each of the process measures. After the first review cycle, the department shall, in consultation with the workgroup, establish standard target thresholds for each of the process measures established by the workgroup. (ii) The department, in consultation with the workgroup, shall develop a process for resolving any disputes regarding the establishment of standard process thresholds pursuant to clause (i). (D) For subsequent reviews, and based upon availability of additional data from enhancements to the Statewide Automated Welfare System or through interagency data-sharing agreements, the workgroup shall convene, as necessary, to consider whether to establish additional performance 8 indicators that support the programmatic goals for the CalWORKs program. Any additional performance indicators established shall also be subject to the process described in subparagraph (C) and include consideration of when data on the additional performance indicators would be available for reporting, if not already available. (E) If, during subsequent reviews, there is sufficient reason to establish statewide performance standards for one or more outcome measures, the department may, in consultation with the workgroup, establish those standards for each of the agreed-upon outcome measures. In making a determination as to whether there is sufficient reason to establish performance standards for any outcome measure, the department shall consider whether all counties could reasonably be expected to meet those standards given local variability in employment opportunities, availability of services, demographics, educational opportunities, and funding, among other things. (2) (A) The county CalWORKs self-assessment component of the Cal-OAR, as established by the workgroup, shall require the county human services agencies to assess their performance on the established process and outcome measures that comprise the performance indicators, identify the strengths and weaknesses in their current practice and resource deployment, identify and describe how local operational decisions and systemic factors affect program outcomes, and consider areas of focus that may be included in the county CalWORKs system improvement plan as described in paragraph (3). The county CalWORKs self-assessment process shall be designed to identify areas of best practices for replication and for system improvement at the county level, and shall guide the development of the county CalWORKs system improvement plan as described in paragraph (3). To the extent a county identifies eligibility procedures and practices that it determines, through its self-assessment, contribute to its achievement on process and outcome measures related to CalWORKs services, the county may, at its option, incorporate eligibility-related elements into its system improvement plan. (B) (i) The county CalWORKs self-assessment process shall be completed every three years by the county in consultation and collaboration with local stakeholders and submitted to the department. (ii) Local stakeholders shall include county CalWORKs administrators, supervisors, and caseworkers; current and former CalWORKs recipients; and county human services agency partners. To the extent possible and relevant, local stakeholders shall also include representatives of community colleges, tribal organizations, and the local workforce board. Additional specific county human services agency partners shall be determined by the county and may include, but are not limited to, adult education providers, providers of services for survivors of domestic violence, the local housing continuum of care, county behavioral health departments, county drug and alcohol programs, community-based service providers, organizations that represent CalWORKs recipients, child care resource and referral programs, and alternative payment programs, as appropriate. 9 (3) (A) (i) The county CalWORKs system improvement plan shall consist of uniform elements to be developed by the workgroup. It shall, at a minimum, describe how the county will improve its CalWORKs program performance in strategic focus areas based upon information learned through the county CalWORKs self-assessment process. The county CalWORKs system improvement plan shall be approved in public session by the county’s board of supervisors or, as applicable, chief elected official, and submitted to the department. (ii) The county CalWORKs system improvement plan shall be completed every three years by the county, approved in public session by the county’s board of supervisors or, as applicable, chief elected official, and be submitted to the department. (B) The county CalWORKs system improvement plan shall include a peer CalWORKs services review element, the purpose of which shall be to provide additional insight and technical assistance by peer counties for each county. (C) Strategic focus areas for the county CalWORKs system improvement plan shall be determined by the county, informed by the county CalWORKs self-assessment process, as described in paragraph (2), with targets for improvement based upon what is learned in the county CalWORKs self-assessment process. (D) The county human services agency shall complete an annual progress report on the status of its system improvement plan and shall submit these reports to the department. The department, in consultation with the workgroup, shall develop uniform elements of the progress report. (e) (1) The department shall receive, review, and, based on its determination of the county CalWORKs system improvement plan meeting the required elements identified in subparagraph (A) of paragraph (3) of subdivision (d), certify as complete all county-submitted performance indicator data, county CalWORKs self-assessments, county CalWORKS system improvement plans, and annual progress reports, and shall identify and promote the replication of best practices in CalWORKs service delivery to achieve the established process and outcome measures. (2) The department shall monitor, on an ongoing basis, county performance on the measures developed pursuant to subdivision (d). (3) The department shall make data collected pursuant to this section publicly available on its Internet Web site. (4) The department shall, on an annual basis, submit a report to the Legislature that summarizes county performance on the established process and outcome measures during the reporting period, analyzes county performance trends over time, and makes findings and recommendations for common CalWORKs services improvements identified in the county CalWORKs self- assessments and county CalWORKs system improvement plans, including information on 10 common statutory, regulatory, or fiscal barriers identified as inhibiting system improvements and any recommendations to overcome those barriers. (5) (A) The department shall facilitate the provision of, and provide as appropriate, technical assistance to county human services agencies as part of the peer review that supports the county’s selected areas for improvement as described in its system improvement plan. (B) If, in the course of its review of county CalWORKs system improvement plans and annual updates, or, in the course of its review of regularly submitted performance indicator data, the department determines that a county is consistently failing to make progress toward its strategic focus areas for improvement or is consistently failing to meet the process measure standard target thresholds established pursuant to subparagraph (C) of paragraph (1) of subdivision (d), the department shall engage the county in a process of targeted technical assistance and support to address and resolve the identified shortcomings. If, after the assistance is provided, the county continues in its failure to meet its goals or performance thresholds, the department may engage in corrective action with the county. (f) A county shall execute and fulfill components of its CalWORKs system improvement plan that can be accomplished with existing resources. (g) A county shall not be required to execute and fulfill any components of its CalWORKs system improvement plan that creates new county costs, unless funding for those costs are appropriated in the annual Budget Act. (h) Beginning in the 2019 20 fiscal year, and for each fiscal year thereafter, no more than two million dollars ($2,000,000) from the General Fund shall be appropriated in the annual Budget Act to counties to complete the requirements described in subdivision (c). 11 CAL-OAR PERFORMANCE MEASURES Below are the Cal-OAR performance measures, grouped programmatically to aid in a comprehensive analysis. Additional details on each measure follow. Programmatic Group Performance Measures Initial Engagement Orientation Attendance Rate OCAT\/Appraisal Completion Timeliness OCAT\/Appraisal to Next Activity Timeliness First Activity Attendance Rate Ongoing Engagement Engagement Rate Sanction Rate Sanction Cure Rate Supportive Services Child Care Access Homeless Assistance and Housing Support Program Access Ancillary Services Access Transportation Provision Timeliness Education Education and Skills Development Access Education and Skills Development Utilization Improved Literacy, Basic Skills and English Language Acquisition Community College Progress Rate Educational Completion Employment and Wages Employment Rate of Current CalWORKs Individuals Subsidized to Unsubsidized Employment Wage Progression Post CalWORKs Employment Rate Exits and Reentries Exits with Earnings Program Reentries Program Reentries After Exit with Income Family Well-Being Home Visiting Transitions to Welfare-to-Work Engagement Family Stabilization Transitions to Welfare-to-Work Engagement 12 APPENDIX B: QUESTIONS FOR TARGETED ANALYSIS The questions below are a resource for CWDs to use while performing the Targeted Analysis of each programmatic grouping of performance measures. This analysis is completed during the CW-CSA process. While it is not required for the CWD to answer each question listed here within the CW-CSA, the CWD should review and consider where answering the question will provide for a more robust CW-CSA. For instructions regarding these questions, please see Section 2 of the Instruction Manual (CSA Reporting Requirements Section: Targeted Analysis; page 16). If not specified, the questions below relate to all measures within the programmatic group. INITIAL ENGAGEMENT Describe the CWD’s process for and goals of Orientation. o How does the CWD adapt the Orientation process based on client needs? Describe what happens if a client misses an Orientation or Appraisal appointment. How are they contacted? How many times can clients no show or reschedule before noncompliance is initiated? Describe how clients are informed about the availability of immediate child care prior to attending Orientation and Appraisal. How does the CWD ensure transportation needs are addressed for clients to attend Orientation and Appraisal? How is the OCAT Appraisal Summary and Recommendations Report (ASR) used by case managers to determine the next activity for clients? And to inform the welfare- to-work plan? o What other resources are used to prioritize service\/activity assignment (i.e. CalMap)? o How are barrier removal recommendations discussed in the context of the client’s next activity? o What is the process for referring clients for services following Appraisal? How is the client’s long-term goals and activity preference accounted for when assigning activities following Appraisal? ONGOING ENGAGEMENT How does the ratio of engaged, sanctioned, and exempt cases compare? And, how does the demographic breakout between the engagement rate and sanction rate compare? How do the time clocks effect client activity choices? How does the CWD explain the relationship between the time clock limits and activity options to clients? 13 Is the CWD employing the CalWORKs 2.0 Strategic Initiative? If so, explain which tools are being used\/adapted, and how the initiative has impacted case management processes. Is the speed of supportive service authorization\/reimbursement\/advancement a barrier to clients’ welfare-to-work engagement? How does the CWD address this? What is the process for establishing welfare-to-work plans for exempt volunteers? How are exempt clients re-engaged into the welfare-to-work program when their exemption ends? o What strategies are employed when re-engaging adults with a barrier related exemption (i.e. related to mental health, substance abuse, and domestic abuse) or a domestic abuse waiver? How is case management for sanctioned cases structured within the CWD (i.e. is there a banked caseload, specific units that work with sanctioned cases, etc.)? Do the staff qualifications or caseload vary for those with sanctioned cases? How does the CWD outreach to and re-engage sanctioned adults? o Does the CWD utilize different strategies for different populations? (for example, assistance units with young children, long term sanction cases, etc.) o If so, identify the populations and the strategies. SUPPORTIVE SERVICES Describe the CWD’s service provision model, including service provider networks, partnerships, and contracted service providers. When and how does the CWD inform clients of the availability of supportive services? When and how does the CWD offer clients supportive services? o How and how often does the CWD revisit the need for supportive services with the client? o How do clients request supportive services, including after the welfare-to-work plan has been established? o How does the CWD inform clients of the necessary paperwork to request services and the approval process timeline? Explain the policies for approval\/authorization of services, and the average timeframe for approval. o Are ancillary and transportation services advanced, reimbursed, or both, and under what conditions for the respective methods? o Are there any ancillary items or dollar thresholds that require secondary review? If so, explain what requires secondary review, how the review process is structured, and the average timeframe for approval. o What forms of transportation services are available to clients? How does the CWD determine which type of transportation service is most appropriate for a client? What options are available to clients who request a different form of transportation service? 14 What are the most common reasons for denial of services? Are there any state or county policies that impact service delivery? What are the major limitations to serving the full need for services? Describe the CWD’s process for transferring clients from Stage One to Stage Two Child Care. What barriers exist? How does the CWD know when a client has been successfully transferred to Stage Two? What is the process for HSP referrals? How are referrals identified? Provide data on the rates of HA\/HSP re-referrals\/re-requests\/re-approvals. What are the CWDs outreach strategies for HA\/HSP? How does the CWD ensure they are serving the most vulnerable clients? Explain any large fluctuations in the HA\/HSP Access measure denominator. EDUCATION What is the CWD’s process for engaging clients in education or training activities? o When does the CWD discuss the option for education or training activities with the client (during appraisal, welfare-to-work plan development, etc.)? o What steps must a client take to participate in education or training activities? What are the main barriers to successfully engaging clients in educational activities? In what ways is the CWD’s relationship with the local community colleges successful? In what ways does the relationship need improvement? Provide the breakout of educational completions by degree\/program type. EMPLOYMENT AND WAGES Describe the CWDs process for engaging employed welfare-to-work clients. What does case management look like for employed clients, and how does it differ from case management for unemployed clients? List and compare the top five employers and top five employment sectors for the CalWORKs population and the overall county population. What percentage of employed CalWORKs clients have unsubsidized employment, subsidized employment, and self-employment? What percentage of employed CalWORKs clients are employed part time? Full time (35 hours per week or more)? Describe the CWD’s partnerships with local labor boards. Does the CWD’s subsidized employment program have goals besides transitioning to unsubsidized employment (i.e. transitioning to other welfare-to-work activities)? If so, describe the other goals. Does the CWD partner with other agencies (i.e. the local board) to provide longer subsidized employment slots, beyond the welfare-to-work funded slot? 15 How does the CWD support clients transitioning from subsidized to unsubsidized employment? What partnerships are leveraged, and what job retention services are provided during and after the transition, and after the case exits CalWORKs? How do former clients’ median earnings compare to the overall county population’s median earnings? Compare former clients’ median earnings to the federal poverty rate, the California supplemental poverty rate, and the county living wage. Describe the CWD’s post aid job retention services. EXITS\/REENTRIES Provide the range of earnings that clients have when exiting the CalWORKs program. Examine why clients return to aid after exiting CalWORKs. In the CWDs experience, what are the top five reasons that clients return to aid? FAMILY WELL-BEING Describe the Family Stabilization Program design and services offered. How does the program design impact outcomes? What aspects of the program provide the most positive outcomes? What is the process for enrolling clients in Family Stabilization Program and the Home Visiting Initiative? What is the average length of time that clients stay in Family Stabilization Program and the Home Visiting Initiative? What portion of the Family Stabilization and the Home Visiting Initiative population are engaged in other program services, respectively? Does the CWD provide other services that divert clients from Family Stabilization Program enrollment? What are the CWD’s policies for transitioning clients to welfare-to-work after successfully completing the goals outlined in the Family Stabilization plan? For clients that do not transition to welfare-to-work engagement after Family Stabilization or the Home Visiting Initiative participation: what are the reasons the transition did not occur? Do barrier removal services continue after clients exit the Family Stabilization program? 16 Cal-OAR Advocate Involvement Proposed Actions 1. Contact your county, in writing or in person, and request that you be included in the W&IC 11523(d)(2)(B)(i) workgroup as a local stakeholder representing the local CalWORKs beneficiaries; 2. Do a monthly California Public Records Act for copies of all county records produced by the county relative to the county CalAOR activities provided for pursuant to Welfare & Institutions Code section 11523. 3. Contact other stakeholders in your community and find out how you can provide them with educational materials regarding Cal-OAR. See Cal- OAR statute above for potential stakeholders. 4. Offer assistance to the county working with them to find CalWORKs beneficiaries who would participate in the process. 5. Keep a list of CalWORKs clients so when the time comes you have a list of potential CalWORKs beneficiaries for the Cal-OAR workgroup. SAMPLE Public Records Act Request – Dear county welfare director: Pursuant to the California Public Records Act, California Government Code 6250 et seq., on behalf of our public assistance clients, CCWRO asks to review and then receive copies of the writings as defined in Government Code 6253 (g) in the format provided for in Gov. Code 6253.9 as described below. If the department has concluded that the document is not available electronically, please explain why not and provide us with an opportunity to review and examine the documents in the format provided for in Gov. Code 6253.9 in response to this request so we can designate the documents in the format provided for in Gov. Code 6253.9 for the period of __\/__\/____. (NOTE: If you do not have the item in electronic form, then I will inspect said document in person. After inspection, if I still wish to have a copy thereof, then, and only then, will pay the 20\u00a2 a page fee. Please do not DEMAND money for documents in the format provided for in Gov. Code 6253.9 that you have in electronic form and documents in the format provided for in Gov. Code 6253.9 that I have not specifically inspected and requested a copy thereof.) What do we want? Copies of any and all writings relative to the county CalAOR activities provided for pursuant to Welfare & Institutions Code section 11523. We ask you for a determination on this request within ten days of receipt. If you determine that any or all of the information requested above qualifies for an exemption from disclosure. We request that you to note whether the exception is discretionary and, if so, whether it is necessary to exercise your discretion to withhold that information. If you determine that some but not all of the information is exempt from disclosure and that the agency intends to withhold it, we ask that you redact it for the time being and make the rest available as requested. If we can provide any clarification to expedite the request, please contact me at . Please email copies of any documents in the format provided for in Gov. Code 6259 in response to this PRA to: I ask that you notify me in advance of any duplication costs exceeding $20.00. Thank you very much for your time and attention. Your signature For any question CONTACT CCWRO for Assistance at 916-712-0071 OR Email [email protected] ”

” [image: ] SNAP Beneficiary Impact Statement FNS proposed regulations entitled Revision of Categorical Eligibility in SNAP JULY 24, 2019 – VOLUME 84, NO. 142, Page 35570-35581 Kevin Aslanian, Executive Director Daphne Macklin, Research Analyst Coalition of California welfare Rights Organizations 1111 Howe Ave., Suite 150, Sacramento, CA 95825-8551 Phone: 916-712-0071 Email: [email protected] Web Page: ccwro.org September 23, 2019 Executive Summary The proposed regulation herein is an attempt: \uf05b\uf020to circumvent the regular order and implement an illegal policy, rejected by Congress, that would increase administrative costs (more money for the bureaucracy); \uf05b\uf020to violate our laws in that a similar proposal was rejected by Congress; \uf05b\uf020to make it more difficult for nutritionally challenged persons to receive food assistance; \uf05b\uf020to take away state flexibility and impose a federal rule thinking that one size fits all; \uf05b\uf020to violate one of the many Trump promises for every new regulation, the Trump administration promised to repeal two (2) federal regulations. DATE: 9-23-2019Public Law 115-334- Agriculture Improvement Act of 2018 Rejection of Modifying SNAP Categorical Eligibility Rule House Report 115-661 SEC. 4006. UPDATE TO CATEGORICAL ELIGIBILITY. Section 5 of the Food and Nutrition Act of 2008 (7 U.S.C. 2014) is amended\u2014 (1) in the 2d sentence of subsection (a)\u2014 (A) by striking ”receives benefits” and inserting ”(1) receives cash assistance or ongoing and substantial services”, (B) by striking ”supplemental security” and inserting ”with an income eligibility limit of not more than 130 percent of the poverty line as defined in section 5(c)(1), (2) is elderly or disabled and receives cash assistance or ongoing and substantial services under a State program funded under part A of title IV of the Social Security Act (42 U.S.C. 601 et seq.) with an in- come eligibility limit of not more than 200 percent of the poverty line as defined in section 5(c)(1), (3) receives supplemental security”, and (C) by striking ”or aid” and inserting ”or (4) receives aid”, and (2) in subsection (j)\u2014 (A) by striking ”or who receives benefits” and inserting ”cash assistance or ongoing and substantial services” and (B) by striking ”to have” and inserting ”with an income eligibility limit of not more than 130 percent of the poverty line as defined in section 5(c)(1), or who is elderly or disabled and receives cash assistance or ongoing and substantial services under a State program funded under part A of title IV of the Act (42 U.S.C. 601 et seq.) with an income eligibility limit of not more than 200 percent of the poverty line as defined in section 5(c)(1), to have”. H. Report 115-1072 (Conference Report) (25) Update to categorical eligibility The House bill amends section 5(a) and 5(j) of the FNA such that categorical eligibility may only be used in instances where a beneficiary is receiving either cash assistance or ongoing and substantial services such as transportation, childcare, counseling, or other services funded under part A of title IV of the Social Security Act with an income eligibility limit of not more than 130 percent (200 percent for elderly or disabled) of the poverty line. (Section 4006) The Senate amendment contains no comparable provision. The Conference substitute deletes the House provision. FROM: Kevin Aslanian & Daphne Macklin of CCWRO [image: ] TO: Trump Administration, USDA,FNS SUBJECT: Docket ID Number [FNS-2018-0037] Revision of Categorical Eligibility in SNAP It is with great disappointment that we have to respond to proposed regulations from the Trump Administration after we heard Trump say: One of the very first actions of my administration was to impose a two-for-one rule on new federal regulations. We ordered that for every one new regulation, two old regulations must be eliminated. The people in the media heard me say that during the campaign many, many times. As a result, the never-ending growth of red tape in America has come to a sudden screeching and beautiful halt. The proposed regulation does not reveal which the two (2) regulations FNS would repeal for this one? Did the President LIE? As is true of many policies of this administration, the cruelty is the point. The Department proposes to substantially limit categorical eligibility for food stamps in a way that targets recipients who do not fit its definition of the deserving poor. The new rules will harm older Americans who are asset rich and cash poor, disabled Americans who cannot participate in work programs, students, and others who may need the food stamp program for short term support, such as unemployed people engaged in job hunting. In doing so, the Department ignores the high levels of food insecurity among these populations, ensuring that more Americans will fall through the cracks and go hungry because of this cruel policy. College students, for instance, experience very high levels of food insecurity. One recent study showed that up to 48% of community college students and 41% of university students have experienced food insecurity. In light of this information, the administration cannot justify excluding students who receive TANF benefits from categorical eligibility for food stamps. (Cite: https:\/\/www.insidehighered.com\/news\/2019\/04\/30\/new-research-finds-discrepancies-estimates-food-insecurity-among-college-students). Categorical eligibility (CE) was designed to reduce the bureaucracy in lieu of increasing the bureaucracy, which is what the proposed regulations do by repealing state flexibility and imposing federally imposed rules that are illegal. They are illegal because they limit the application of CE to certain AFDC\/TANF cases. When TANF was enacted, which diverted millions of dollars that under AFDC (AFDC had 70% of the funds used for payments to families) was used to feed and house poor families to the welfare bureaucracy, Congress also amended provisions of the SNAP program in the same legislation. Thus, Congress was aware of AFDC and TANF funds and its application to CE and did not limit it to certain TANF persons and exclude others when it was considering modifications of both (AFDC and the Food Stamp) programs in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Pub. L. 104 193) (PRWORA). Moreover, the Trump Administration tried to make changes to CE during the 2018 farm bill that was soundly rejected by the conference committee. So, what does the Trump administration do? Who cares what Congress did? Why would the Socialist Trump administration care about Congress and the pesty U.S. Constitution? 2018 Farm Bill Rejected Provision 7-24-19 Proposed Regulations to Enact Limit SNAP Categorical Eligibility to those who – receive cash assistance or ongoing and substantial services” Limit SNAP Categorical Eligibility to those who – receive cash assistance or ongoing and substantial services” The proposed regulations reveal the colossal failure of the TANF program. Footnote 8 states: In Fiscal Year 2017, 22.7 percent of combined TANF Federal and State MOE funds were used for basic assistance (e.g., cash); 10.5 percent were used for work, education, and training activities; and 16.1 percent were used for child care. In Fiscal Year 2017, 27 States used less than 50 percent of their TANF Federal and State MOE funds on a combination of basic assistance; work, education, and training activities; and child care. Only 23% of the TANF cash aid payments go to TANF beneficiaries that are ongoing and substantial (compared to 70% under AFDC) while in SNAP over 90% of the benefits go to SNAP beneficiaries. It appears that the Trump Administration would like the SNAP program to become the ineffective TANF program- where most of the money goes to the welfare bureaucracy and a meager 23% goes to the TANF babies and children not in foster care living in deep poverty, by making the SNAP program administratively inefficient. The current CE regulations provide for state flexibility something supported by the Trump administrations and its enablers like the Heritage Foundation and other welfare bureaucracy loving conservative swamp organizations. On page 35571 FNS states: Prior to PRWORA, categorical eligibility for SNAP was conferred by receipt of cash AFDC benefits, as noncash AFDC benefits did not exist. While PRWORA did not modify the categorical eligibility provision in Section 5(a) of the Food and Nutrition Act, the Department recognized that the changes enacted by PRWORA and the move from AFDC to TANF meant that categorical eligibility could be conferred by both cash and non-cash benefits. We fact checked this false assertion and found that it was a false statement. Under AFDC states used AFDC funds, that were matched by 50% for cash payment state expenditures and for non-cash expenditures, including noncash assistance payments in the form of vouchers and vendor payments to profit making vendors, including most likely some of the Trump properties . USDA asks Specifically, the Department is interested in comments on the processes by which TANF-funded programs actually determine applicant financial and non-financial eligibility for the conferring programs, and at what point in the TANF enrollment process this determination and delivery of benefit(s) to the household may take place relative to the SNAP eligibility determination. The TANF eligibility determination is made before Food Stamp\/SNAP benefits are issued in California and we are sure that this is true in all States. USDA asks Department is interested in public comment as to whether and how the benefits from such hourly-based programs [non-cash TANF benefits, such as education and training, job search assistance, or work experience] could be valued for the purposes of conferring categorical eligibility, or other ways to determine whether such benefits could be ongoing and substantial. The best entity to decide the value of non-cash TANF benefits, such as education and training, job search assistance, or work experience are the local entities and not big brother government in Washington Ivory Towers. Non-cash benefits have different values are different states based on the local conditions. The Trump administration officials and supporters have touted, for years, that one-size does not fit all, yet now one size fits all? What happened. Is the Trump Administration becoming socialist administration? USDA asks, The Department is interested in whether eliminating the distinction, or adjusting the 50 percent funding threshold would help streamline SNAP regulations, ensure consistency in serving households through categorical eligibility, and simplify administration. We would respectfully suggest that the percentage of funding should be dependent on the local conditions. The Trump administration officials and supporters have touted for years that one-size does not fit all, yet now one size fits all? What happened. Is the Trump Administration becoming socialist administration? We would also strongly disagree with the following finding by USDA, FNS: The Department finds it reasonable to use the estimates from OMB approved Information Collection 0054 0064 regarding household burden for providing verification and estimates that providing verification would take 4 minutes or .0668 hours per household at initial certification and 6 minutes or .1002 hours at recertification. We are not sure in what reality a household would need 4-6 minutes to provide verification of assets. This shows how removed from reality is this assertion. In California 50% of SNAP applications are denied for reasons other than failing to meet eligibility requirements. 50% of the denials are due to failure to provide verifications or meeting other bureaucratic procedural requirements or better known as barriers to participation . Generally, applicants are told to go home and come back to provide missing verification. That means they take public transportation or walk to the office that can take an hour each way. Then they have to go through security to get into the welfare office. Once in the office, they have to stand in line and check in with the receptionist. Then they have to wait for the worker to call their name. This can take several hours. By no stretch of anyone’s imagination, is this a 4 to 6-minute household burden. We were not able to comment on most of the numbers in the data table on page 35580 because it was incomprehensible for the public to comment on it intelligently. We have no doubt that the Trump Administration understands what this table means, but that does not help us to provide comments. Curiously the agency justification for the proposed changes identifies no specific states practices or numbers of participants who are now SNAP program participants that would be impacted by what is being proposed. The explanatory statements most specific example states that: Due to the broad flexibility afforded States in the construction of TANF-funded pro- grams, these households, who would not otherwise have qualified for SNAP due to their income or resources, are considered categorically eligible and therefore able to receive SNAP. As a result of these policies, it is estimated that 4.1% of currently participating SNAP households (767,000 households or 1.4 million individuals) have resources above the SNAP limit and 4.9% have incomes above the Federal SNAP gross income limit of 130% FPL (914,000 households or 1.7 million individuals). See Federal Register \/ Vol. 84, No. 142 \/ Wednesday, July 24, 2019 \/ Proposed Rules 35571-2, The report does not specify how it comes to the conclusion that 914,000 households equals 1.7 million individuals. Clearly without more credible data, this Administration’s asserted supportive documentation for the proposed change cannot be considered valid or reliable. Finally with respect to America’s senior citizens, the proposal appears to ignore the fact that older Americans are the fastest growing food insecure population in the country. Since 2007, the number of seniors facing hunger has grown by 65%. In 2014, the National Foundation to End Senior Hunger found that 16% of seniors reported experiencing food insecurity. (Cite: https:\/\/www.aginginplace.org\/the-facts-behind-senior-hunger\/.) The number of people age 60 and older is expected to swell to over 100 million by 2060. A disproportionate number of seniors facing hunger are non-white Americans, meaning that these new rules may have a disparate impact along racial as well as generational lines. According to one article ”Seniors who live in the south are far more likely to be food insecure; nine of the 10 states with the highest rates of food insecurity are in the south. Seventeen percent of African American seniors and 18% of Hispanic seniors are food insecure, compared to just 7% of Caucasian seniors. One-third of food insecure senior citizens have a disability Nearly 1 in 5 seniors living with grandchildren are food insecure. )[footnoteRef:1] [1: https:\/\/www.moveforhunger.org\/food-insecurity-among-senior-citizens-growing-population-ages\/ September 23, 2019. ] Cutting nutrition support to older Americans is exactly the opposite of what we need to do to protect our retired citizens. The Department’s own analysis concedes that older Americans will be disproportionately affected by these rules. Yet the Department does not propose any means of mitigating the negative impact and civil rights implications of these disparate impacts. In summary, the Trump Administration has already tried to change this rule the American way through legislation Public Law 115-334 and it was soundly rejected by the Republican Senate. Now that they have failed, they are trying to do it the Soviet Socialist way- the autocratic way the hell with Congress. We oppose this Unamerican Act of the Trump Administration. [bookmark: _GoBack] Page 1 9-10-19 – CCWRO Testimony on CE proposed federal regulation VOLUME 84, NO. 142, Page 35570-35581 of July 24, 2019 ______________________________________________________________________________ MWC leu ”