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Public Benefits - Comments

Empire Justice Center Comments on SNAP Income Conversion Factors
Current income conversion standards permit states to select the most efficient methodology to help simplify procedures for state eligibility workers and limit barriers to participation for families in need. A shift in this will increase state agency costs, and county workload in our county administered benefits system. Read More

Empire Justice Comments on Updated SNAP Eligibility
Empire Justice Center is grateful for the addition of Perkins educational programs to the allowable SNAP employment and training offerings. Read More

Empire Justice Comments on SNAP Employment and Training Program
Empire Justice Center comments addressing the lack of measurements for mandated participation and sanctions in SNAP interim rules. Read More

Comments on Proposed Regulation Amendments for Non-compliance with SNAP Work Requirements and Conciliation Processes
The proposed regulations will help bring New York State into compliance with federal SNAP requirements and the settlement agreement reached in Richard C. v. Proud (12-CV-5942, S.D.N.Y.), a federal class action lawsuit co-counseled by Empire Justice Center, National Center for Law and Economic Justice, Legal Aid Society and Cooley LLP. Read More

Empire Justice Comments to OTDA on the 2014 -15 HEAP State Plan
Our comments to the Office for Temporary and Disability Assistance on the proposed New York State plan for the 2014 - 2015 Home Energy Assistance Program. Read More

Empire Justice Comments on the Request for Information on SNAP High Performance Bonuses
Here in New York, there are ongoing, rampant due process violations in the fraud investigations/disqualification process. Many counties are extremely aggressive in pursuing fraud, yet it appears that the fraud and/or SNAP staff do not seem to understand SNAP eligibility rules. Read More

Empire Justice Comments to OTDA on Proposed Regulations regarding the State Supplement Program
Comments on the proposed regulations regarding the State Supplement Program (SSP), part of the monthly benefit paid to most Supplemental Security Income (SSI) recipients, which will add a new Part 398 to 18 NYCRR and which also includes an amendment to 18 NYCRR 358-5.12. Read More

Empire Justice Comments to OTDA on Needs Assessment for 2014-2015 state Home Energy Assistance Program (HEAP) plan
Our comments to OTDA on the HEAP 2014-15 Needs Assessment. Read More

Empire Justice Comments on Proposed Abolition of Local Advisory Councils
This proposed abolition would conflict with existing law and cut off local social services districts from the communities they serve. Read More

Recommendations for next steps in mental health screening
This document sets forth recommendations a group of advocates presented to OTDA concerning the use of a mental health screen tool that OTDA has recently tested and validated. Read More

Empire Justice comments on proposed regulations to end food stamp finger imaging in New York State
Empire Justice Center strongly supports the proposal to eliminate all finger imaging requirements from the Food Stamp Program in New York State, and to rely on more efficient and effective methods to detect and prevent and detect duplicate participation. Read More

Empire Justice Comments on Revised Regulations regarding Fair Hearing Defaults
OTDA Revised Regulations regarding Fair Hearing Defaults: Empire Justice Center comments support expansion of time frames for reopening but urge removal of time limit entirely; and express concern about restrictions imposed on Appellants represented by lay advocates. Read More

Empire Justice Center's Comments on New York's TANF State Plan 2012 - 14
Our comments to OTDA urging them to take leadership on a number of issues which will improve the lives of low income New Yorkers. Read More

Empire Justice Center Comments on Changes to SNAP “Fleeing Felon” Rules
Empire Justice Center filed written comments in response to USDA’s proposed changes to the SNAP “fleeing felon” regulations. Read More

Empire Justice Comments on USDA's Proposed SNAP Regulations Updating the Definition of Trafficking
The proposed rules change the definition of trafficking for SNAP (Supplemental Nutrition Assistance Program) purposes and also clarify disqualification procedures for recipients of FDPIR (Food Distribution Program on Indian Reservations). Read More

Empire Justice Comments on Proposed SNAP Regulations: Eligibility, Certification and Employment & Training
Empire Justice's July 2011 comments on USDA's proposed rules, which were issued to implement 2008 federal reauthorization changes to the certification, eligibility and employment and training provisions of the Supplemental Nutrition Assistance Program (SNAP) Read More

Empire Justice Center's Initial Reaction to Deficit Reduction Plan for 2009-10 State Budget
Reductions in services for those who have been most impacted by the recession will ultimately result in pushing more people over the edge into desperation. Read More

Empire Justice Comments on proposed OTDA regulations
Comments on proposed OTDA regulations concerning PA recipient access to educational activities Read More

Empire Justice Comment on Proposed Amendments to 18 NYCRR §§385.6 and 385.7
We strongly support these proposed modifications to the extent that they enhance public assistance recipient access to education and training activities. We also discuss our concerns with certain aspects of the regulations which we fear may hinder progress toward this crucial objective. Read More

Empire Justice Comments on New York State's TANF State Plan 2009-2011
Testimony focuses on the public assistance gross income eligibility test, the resource test as applied to automobiles, the implementation of the Family Violence Options and the education and training rules. Read More

Empire Justice Comments on 2007-2008 New York State HEAP Plan
This letter constitutes the comments of the Empire Justice Center on the 2007-2008 New York State Home Energy Assistance (HEAP) state plan. Read More

Empire Justice Comments on repealing 18 NYCRR 352.31(b)
This regulatory change will assist non-legally responsible relatives with limited means, who wish to care for relatives under the age of 18 when their parents are unable to do so. Read More