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 to require consultation with the Leadership Council and may, upon agreement, require APHSA to issue 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. For documents that predate 2017 or may not be found here, please contact us. We'd be happy to provide further documentation as requested.

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.


Comment Letter – 12/10/18
Response to the Department of Homeland Security’s (DHS) Request to Comment on a Notice of Proposed Rulemaking (NPRM) entitled "Inadmissibility on Public Charge Grounds" (DHS Docket No. USCIS-2010-0012) posted in the Federal Register on October 10, 2018.


Comment Letter – 11/06/18
Response to the proposed rule for the "Apprehension, Processing, Care, and Custody of Alien Minors and Unaccompanied Alien Children" (DHS Docket No. ICEB-2018-0002).


Comment Letter – 07/23/18
APHSA, the Center for Employment and Economic Well-Being (CEEWB), and our affinity group, the National Association of State TANF Administrators (NASTA) responds to H.R. 5861 - "The Jobs and Opportunity with Benefits and Services (JOBS) for Success Act of 2018".


Comment Letter – 07/21/18
Response and Appendix to President Donald Trump’s Executive Order No. 13828 on "Reducing Poverty in America by Promoting Opportunity and Economic Mobility" posted April 10, 2018.


Comment Letter – 05/02/18
APHSA, the Center for Employment and Economic Well-Being (CEEWB), the National Collaborative for the Integration of Health and Human Services, our affinity groups, the American Association of SNAP Directors (AASD), and the National Association of Program Information and Performance Measurement (NAPIPM) responds to H.R. 2 - The Agriculture and Nutrition Act of 2018 (Farm Bill) related particularly to the Supplemental Nutrition Assistance Program (SNAP).


Comment Letter – 04/26/18
APHSA and our affinity group, the American Association of SNAP Directors (AASD) respond to a request for comment entitled "Waivers Under Section 6(o) of the Food and Nutrition Act" (OMB Control No. 0584-0479) that appeared in the Federal Register / Vol. 83, No. 59 on March 27, 2018.


Comment Letter – 01/08/18
APHSA and our affinity group, the National Association of State Child Care Administrators (NASCCA), on behalf of the state child care administrators, submit comments in response to notice FY 2019-2021 CCDF Plan Preprint issued by the Office of Child Care within the Administration for Children and Families (ACF) on December 8, 2017.


Testimony – 03/28/17
Read testimony by Russell Sykes, Director of APHSA's Center for Employment & Economic Well-Being, at the U.S. House of Representatives Committee on Agriculture Subcommittee on Nutrition Hearing, on "The Next Farm Bill: The Future of SNAP".