Comments: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the proposed rule, “Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program.” Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to over three million people with Medicare, family caregivers, and professionals.

Based on this experience, we know that for many older adults and people with disabilities, food insecurity is an ongoing challenge. Too often on our National Consumer Helpline, we hear from people with Medicare who are struggling to make ends meet, and who are facing impossible choices as a result—like whether to pay rent, purchase needed medications, or buy groceries. Our callers are not alone. Over five million older adults were food insecure in 2017, 1 and adults living with disabilities experience a food insecurity rate almost three times higher than nondisability households.2 The U.S. Department of Agriculture (USDA) itself has noted this disparity, flagging disability as a risk factor for food insecurity, even among moderate-income earners.

Fortunately, there is help available. We are often able to connect qualifying individuals with programs that can help them meet basic needs, like the Supplemental Nutrition Assistance
Program (SNAP). SNAP is a critical safety net for people with Medicare, many of whom live on fixed incomes and have limited financial resources. In 2016, over 40% of SNAP households had at least one adult age 50 or older, 4 and over one in four SNAP participants, equivalent to more than 11 million individuals in 2015, had a disability.

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