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Federal Poverty Measure Sign On Letter

PDF Version of Comments Submitted by MO Organizations re Proposed Change to Federal Poverty Level Calculation – June 2019

June 20, 2019


Nancy Potok, Chief Statistician
Office of Management and Budget
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 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


Sarah Swearer, Manager of Public Policy
Operation Food Search


Kim Lackey, Director of Public Policy and Advocacy


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



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, 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,

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