The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the proposed rule, “Standardization of State Heating and Cooling Standard Utility Allowances.” 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.

Because of our focus on the needs of older adults and people with disabilities, we are very concerned to see the Food and Nutrition Service (FNS) propose a rule that would adversely impact these populations by cutting billions from the Supplemental Nutrition Assistance Program (SNAP).1 Such a change would exacerbate existing health and financial challenges for people with Medicare and put more people at risk of serious harm. We strongly oppose this proposed rule and urge the FNS to withdraw it in its entirety.