Comment on FR Doc # 2011-14926

Document ID: FNS-2011-0021-0005
Document Type: Public Submission
Agency: Food And Nutrition Service
Received Date: August 10 2011, at 01:53 AM Eastern Daylight Time
Date Posted: September 22 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 17 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: September 15 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80edc4ab
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Based on experience and common sense, I know that many households are not approved for reduced school lunches essentially because the application/policy makes an applicant report any child support received in a household, but does not reduce the reported household income by the amount of child support paid from the household to support another child not living there (clearly unfair to those families to which it applies). Assume a family of four (2 adults, 2 school student) making $43,000 per the current application rules. The family (one of the two adults) pays $300 per month in (court ordered) child support for a child outside the household, thus reducing the income available to help feed the children in the household by $3,600 annually (down to $39,400). The application/policy either should not consider any child support (paid or received) as income or should consider both types equally (i.e., paid child support reduces income, received child support increases income). In the case listed above, the difference in cost to the family would be 180 meals x 2 students x (price difference) = well over $600 for the school year, or about 2% of the family's income during the school year. When a family is just getting by, 2% of the income is a lot to give up, simply because an unjust rule exists in a national policy. The point of recording income on the application is to gauge how much money is available to support the household's children. Child support paid to another household is not income to the paying household, and cannot be used to support the paying household. Therefore, it must be reduced from income in the application to meet the intent of the program. I realize this doesn’t fall precisely into the scope of the "School Food Service Account" document this comment attaches to, but I could find no other open School lunch related dockets to which to apply this comment. Thanks for your time, and please ensure this makes it to the right committee.

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