More than 25 government programs that provided benefits and services to low-income families in 1994—such as food stamps, Head Start, Legal Services, Medicaid—linked their need standard for determining eligibility for some or all applicants to the U.S. Department of Health and Human Services poverty guidelines, which are derived from the official poverty thresholds. The use of the proposed measure would improve the targeting of benefits to needy families, and we encourage program agencies to consider adopting it as an eligibility criterion in place of the current measure. In doing so, program agencies should consider whether the proposed measure may need to be modified to better serve program objectives. For example, the proposed definition of family resources may add administrative burdens in programs that currently obtain crude measures of applicants' gross money income to assess eligibility because more information is needed to determine applicants' disposable income. In these instances, it may be preferable to implement a less detailed definition.

Program agencies should also consider the implications of the recommended method for updating the poverty thresholds. There may be consequences for program caseloads or waiting lines and costs if, over time, thresholds developed under that method rise at a faster rate than thresholds that are simply adjusted for inflation. With constrained budgets, the relationship of program need standards to the poverty thresholds may need periodic adjustment.

In the Aid to Families with Dependent Children (AFDC) program, for which we were asked to consider issues of a national minimum benefit standard, federal law currently defines "countable income." The definition is similar in concept, if not in specifics, to the proposed disposable income definition of family resources. However, a unique feature of AFDC is that the states establish need standards for eligibility but are allowed to and often do pay benefits below that standard. Most state need standards and, even more so, most state benefit standards are considerably below the poverty thresholds, and the level varies widely across states—more widely than can be explained by differences in living costs.

Currently, more than a dozen states link their need standard in some way to the current poverty guidelines. Again, the proposed measure would be an improvement for this purpose. We encourage the states to consider the use of the proposed measure, which includes an adjustment to the thresholds for geographic differences in housing costs, in setting their need standard for AFDC.

It would also seem reasonable to consider the thresholds that are developed under the proposed measure as a goal or benchmark in any debate about

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