June 20, 2019
Nancy Potok, Chief Statistician
Office of Management and Budget
Statistical_Directives@omb.eop.gov
Re: Directive No. 14
Comments to OMB 2019-0002-0001
Request for Comment on the Consumer Inflation Measures Produced by Federal Statistical Agencies
Dear Ms. Potok:
We are writing to express our concerns about potentially replacing the Consumer Price Index for All Urban Consumers (CPI-U) with another measure of inflation such as the Chained Consumer Price Index for All Urban Consumers (C-CPI-U), or the Personal Consumption Expenditures Price Index (PCEPI). Over time, the proposed use of a lower measure of inflation would reduce or eliminate critical services including health, mental health, early education, legal aid, child welfare and nutrition services for thousands of Missourians.
While we appreciate the desire to update the mechanisms used to calculate the Census Bureau’s Official Poverty Measure to make it more meaningful, neither the C-CPI-U nor the PCEPI would adequately nor accurately assess the status and well-being of lower-income Missourians.
Recent studies indicate that inflation is increasing at a faster rate for low-income households than for households overall.[1] In particular, inflation measures such as the CPI-U do not adequately account for the fact that low-income households pay a higher proportion of their incomes on necessities such as housing and child care. The costs of these expenses have risen dramatically the past several decades—much faster than wages – making it extremely difficult for working families to get ahead and be financially self-sufficient. Lowering the calculation of poverty further, using the C-CPI-U or the PCEPI, would make the assessment of need even less accurate.
We recognize that OMB has not requested comments on the impact the proposed measures could have on the official Federal Poverty Guidelines (often referred to as the Federal Poverty Level) developed by the U.S Department of Health & Human Services (HHS). However, the poverty guidelines developed by HHS take their lead from the OMB threshold and would impact numerous federal, state and local government programs including access for Medicaid, CHIP, Child Care and Early Education, SNAP, WIC, and School Meals. By using a lower measure of inflation, the calculation of need used to determine eligibility for these programs would significantly reduce over time, impacting tens of thousands of Missourians.
Any proposed change to how poverty is calculated should undergo thorough research and analysis, and solicit public comments regarding the policy’s potential impact on low- and moderate-income households. We oppose any change that would worsen the economic and health conditions of Missourians.
Please contact Amy Blouin, Missouri Budget Project at ablouin@mobudget.org with any questions.
Respectfully submitted on behalf of the following organizations:
Lisa Knoll, CEO
Aging Ahead
Lauri Massey, MSW LCSW, Director of Quality & Compliance
AIDS Project of the Ozarks
Tamara Kenny, JD, MSW, Director of Advocacy and Community Engagement
Catholic Charities of St. Louis
Maxine Clark, Chief Inspirator
The Delmar DivINe
Jill Ainsworth, Attorney and Counselor at Law
Child and Family Legal Advocacy
Bruce A. Eddy PhD, Executive Director
Community Mental Health Fund
Anne Silea, Director of Community Engagement
Delta Gamma Center for Children with Visual Impairments
Jeanette Mott Oxford, Executive Director
Empower Missouri
Shelby Butler, Community Outreach Coordinator
empower: abilities
Abby Buckhouse, Manager, Policy and Advocacy
Generate Health
Michael Meehan, Executive Director
Good Shepherd Children & Family Services
Kelley Vollmar, Director
Jefferson County Health Department
Casey Hanson, Director of Outreach and Engagement
Kids Win Missouri
Nancy J Miller & Louise T Wilkerson, Co-Presidents; and Jean Dugan, Executive Director
League of Women Voters of Metro St. Louis
Evelyn Maddox, President
League of Women Voters of Missouri
Kaitee Brown, Director, Attorney
Legal Aid of Western Missouri
Alice Kitchen
Loretto Community Kansas City
Margo Smith
Missouri Association for Infant and Early Childhood Mental Health (MOAIMH-EC)
Scott Kimble. Director of Legislative Advocacy
Missouri Association of School Administrators
Amy Blouin, President & CEO
Missouri Budget Project
Jennifer Carter Dochler, MSW, Public Policy Director
Missouri Coalition Against Domestic and Sexual Violence (MOCADSV)
Jessica Hoey, Director of Public Affairs and Community Engagement
Missouri Community Action Network
Michelle Trupiano, Executive Director
Missouri Family Health Council, Inc.
Caitlyn Adams, Executive Director
Missouri Jobs with Justice
Jessica Seitz, Director of Public Policy
Missouri Kids First
Heidi Lucas, State Director
Missouri Nurses Association
Carla Wiese, President-Elect
Missouri PTA
Dianna Fine, State Policy Advocacy Chair and Ellen Alper, Executive Director
National Council of Jewish Women-St. Louis
Kari Rinker, MPA, Senior Manager, Advocacy
Kansas, Missouri and Oklahoma National Multiple Sclerosis Society
Sister Quincy Howard, OP
Network
Sarah Swearer, Manager of Public Policy
Operation Food Search
Kim Lackey, Director of Public Policy and Advocacy
Paraquad
Mark Sanford, Executive Administrator
People’s Community Action Corporation
Brenda R. Sharpe, President & CEO
REACH Healthcare Foundation
Tom Duff, Executive Director
Saint Louis Counseling
Karen Wallensak, Executive Director
St. Francis Community Services
Jessica Adams, Executive Director
St. Louis Area Diaper Bank
Colleen Polak
St. Louis Child Abuse and Neglect Network
Michelle Schiller-Baker, Executive Director
St. Martha’s Hall
Laurie Phillips, Chief Executive Officer
St. Patrick Center
Ruth Ehresman, Advocacy Coordinator
Vision for Children at Risk
Linda Zazove, Co-President
Women’s Voices Raised for Social Justice
cc:
The Honorable Roy Blunt
The Honorable Josh Hawley
[1] Greg Kaplan and Sam Schulhofer-Wohl, “Inflation at the Household Level,” Journal of Monetary Economics, August 2017, https://gregkaplan.uchicago.edu/sites/gregkaplan.uchicago.edu/files/uploads/kaplan_schulhoferwohl_jme_2017.pdf and David Argent and Munseob Lee, “Cost of Living Inequality during the Great Recession,” Kilts Center for Marketing at Chicago Booth — Nielsen Dataset Paper Series 1-032, March 1, 2017, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2567357.
