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Appendix B: Summary of Public Comments
Pages 123-130

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From page 123...
... Those submitting comments were asked to outline their perceived strengths of the supplemental poverty measure (SPM) and to identify aspects in need of improvement.
From page 124...
... addressed this point as well, noting that the National Academies' panel and Interagency Technical Working Group on Developing a Supplemental Poverty Measure did not explicitly address children's developmental needs beyond food, clothing, and shelter, or the related social- and cultural-participation needs. Given changing norms of what constitutes a basic standard of living and an evolved understanding of child development and wellbeing over the past half century, the group argued that such needs should be an explicit part of a contemporary poverty measure.
From page 125...
... In his comments, Sherman suggested that future expert panels should reassess the SPM approximately every 10 years or so, to account for evolving household needs. Theme: Resource Measurement -- Treatment of Credits and Debts Several commenters raised questions about the role of tax credits in estimating consumer unit resources.
From page 126...
... They would prefer to see adoption of a simple baseline concept, such as pegging the SPM threshold to the percentile given by the official poverty rate in the initial year. An absolute standard -- and potentially a purely relative standard -- for adjusting poverty thresholds could then be updated based on the Chained Consumer Price Index for All Urban Consumers; the relative measure could update thresholds by the same percentage at which the median income changes each year.
From page 127...
... She cited figures from the Bay Area Equity Atlas indicating that 52 percent of renters in Contra Costa County are housing burdened (i.e., those households that pay more than 30% of their income to housing) , which creates a "large gap in the system of support for young children and families." Based on an alternative measure developed by FESP, the high cost of housing in the county means that acquiring the basic needs for a family of four with an infant and a toddler requires a household annual income of $141,641; meanwhile, the median household income for a family with children in Contra Costa is $103,685.
From page 128...
... However, based on published information and results from their own research, Children's HealthWatch "supports equivalence scale Option 1: Use 0.7 for all." In the same vein, to facilitate examination and interpretation of potential changes to the SPM in future reviews, the Children's HealthWatch recommended listing working papers and related materials -- especially status indications of which potential changes are under consideration and which have been discarded or postponed -- on the Census Bureau SPM website, in chronological order. Theme: Data Improvement Public commenters identified a number of weaknesses with the SPM data infrastructure, some of which overlap with themes outlined above.
From page 129...
... Replacing surveyed SNAP benefits data with state-level administrative data also helps remove statistical error introduced in the imputation process. In her comment, Wheaton pointed out that the Census Bureau and others are actively working on approaches that use linked administrative data and survey data to address the problem of underreporting of program benefits in survey responses.
From page 130...
... ASEC but which asks the relevant CE income and expenditure questions. This would allow a direct ASEC-CE correspondence." It is, he argued, important to have information on whether ASEC income data actually map into the expenditure items in the SPM threshold.


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