Comment Letters & Testimony – Policy

Guide Rails to Our Legislative & Regulative Work

  • APHSA will not take a formal position on legislation that has not been introduced
  • When there is a difference in opinion on legislation or regulation, APHSA will reach an agreement on how these positions will be communicated through consultation and approval of the Leadership Council
  • Changes in bill language after APHSA has taken a position may, upon agreement with the Leadership Council, require a revised position statement
  • When legislation or regulation is pending that APHSA members have agreed they have an active interest in, it will be a standing item on the Leadership Council monthly agenda

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Read comment letters and testimony written with and through our members that are submitted to Congressional Committees and the Federal Administration.


Final Rule: SNAP Requirements for Able-Bodied Adults Without Dependents (ABAWD) - 10/19/20
A federal judge formally struck down the ABAWD final rule on October 18, 2020. This summary is an update including key points of what the final rule does, including Core Standards for Considering Waiver Requests, Criteria for Establishing Geographic Areas for Consideration for ABAWD Waivers, and Additional Implementation Requirements.

Comment Letter - 10/02/20
Comments to the Federal Interagency Council on Economic Mobility in response to the Request for Information (RFI) on Federal Coordination to Promote Economic Mobility for All Americans. APHSA’s comments reinforce the structure and approach the Council should take to creating structures and areas of investment that can achieve the greatest impact through interagency collaboration.

Letter to Congress - 08/7/20
This letter on SNAP Implementation Considerations outlines priorities and technical considerations for human services agencies in the next COVID relief package. The letter addresses the need to increase the minimum and maximum SNAP benefit levels, to simplify, extend, and expand Pandemic EBT (P-EBT), to provide fiscal relief for both SNAP implementation and P-EBT, and to establish waivers to support SNAP implementation for the duration of the pandemic.

Letter to Congress - 6/24/20
This letter highlights the key policy priorities that child care administrators recognize are needed to ensure the availability of safe and stable care, and to urge Congress to prioritize child care in negotiations for the next stimulus package. The recommendations cover policy issues focused on supporting child care operations, instituting effective health and safety protocols, and supporting the education system and working parents.

Comment Letter – 6/17/20
Comments in response to proposed rule: Employment and Training Opportunities in the Supplemental Nutrition Assistance Program, Docket ID Number [FNS-2019-0008]. APHSA affirmed its commitment to providing pathways to economic mobility for SNAP recipients and acknowledged the progress that has been made in recent years by states with the support of USDA.

Letter to Congress – 6/3/20
Building on our members’ prior recommendations to address rapid response issues caused by the COVID-19 pandemic and to meet urgent community needs and stabilize the underlying human services infrastructure, this letter provides additional recommendations to Congress to adopt specific policies that invest in people and communities to drive an economic resurgence.

Letter to Congress – 4/10/20
Based on feedback from our members across the nation, this letter identifies the most urgent legislative tools needed to support human services agencies during the COVID-19 pandemic and its immediate aftermath including investment in the infrastructure needed to create economic opportunity, keeping children safe and mitigating the trauma families are experiencing, ensuring access to basic nutritional supports, and reinforcing the ability of our child care system to provide quality care to families impacted by the pandemic.

Letter to Congress – 3/25/20
Based on feedback from our members across the nation, this letter provides priority recommendations that are vital to support human services agencies and their partners. APHSA will continue to work with Congress in order to delve into more nuanced issues to support the immediate, interim, and long-term needs of communities responding to and recovering from COVID-19.

Comment Letter – 01/31/20
Comments in Response to Proposed Rulemaking: Rules Regarding the Frequency and Notice of Continuing Disability Reviews.


Summary of Final Rule – 12/11/19
SNAP Requirements for Able-Bodied Adults Without Dependents.

Comment Letter – 11/27/19
Response to USDA's proposed rule for Standard Utility Allowance.

Comment Letter – 09/19/19
As a coalition of member organizations representing the nation’s governors, state legislatures, counties, cities, and state and local health and human services agencies, we urge the House Committee on Ways and Means to provide a one-year extension to the Temporary Assistance for Needy Families (TANF) program.

Comment Letter – 09/12/19
Response to the Notice of Proposed Rulemaking (NPRM) entitled "Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)", Docket ID Number (FNS-2018-0037).

Comment Letter – 06/21/19
Response to the Office of Management and Budget’s (OMB) request for comments on Changes to the Census Bureau’s Official Poverty Measure (OPM), (FR Doc. 2019-09106) published on May 7, 2019.

Comment Letter – 06/11/19
APHSA and our affinity group, the National Association of Public Child Welfare Administrators (NAPCWA), on behalf of the state child welfare administrators, submits comments in response to the notice regarding the Adoption and Foster Care Analysis and Reporting System (AFCARS) by the Children’s Bureau within the Administration for Children and Families (ACF) on April 19, 2019.

Comment Letter – 04/01/19
APHSA and our affinity group, American Association of SNAP Directors (AASD), responds to the USDA Food and Nutrition Service’s (FNS) Request for Comments on Proposed Rule entitled "Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults Without Dependents (FNS Docket No. FNS-2018-0004)" posted in the Federal Register on February 1, 2019.

Comment Letter – 01/07/19
Response to the Administration for Children and Families (ACF) request for comment on aspects of a planned Data Exchange Standards Regulation entitled, "Data Exchange Standards for Improved Interoperability of Multiple Human Service Programs" posted in the Federal Register on November 8, 2018.

If you are looking for documents published prior to 2019, please contact Jessica Garon, Director of Communications.