Original Message:
Sent: 07-24-2025 03:35 PM
From: Margo Anderson
Subject: Public comment on national SNAP fraud database (due July 23)
Thoughts on the need to rethink data stewardship in the Age of Trump.
This is a think piece for comment.
Margo Anderson
margo@uwm.edu
Original Message:
Sent: 7/24/2025 11:24:00 AM
From: Deborah Stein
Subject: RE: Public comment on national SNAP fraud database (due July 23)
There is a related lawsuit, and I'm posting below the email that was sent around about it. It included template comments. CHN submitted comments opposing this national data base using the template and adding that among other things it might mean eligible people would be reluctant to apply for benefits and states and npos that helped people apply and assured them the data was confidential might be subject to suit if people were harmed by access to their data (for example, domestic violence victims whose abusers were in law enforcement and found their address through it.) I imagine others may also have used the template.
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the latest in a joint legal advocacy effort MAZON is participating in to stop the USDA from unlawfully collecting SNAP beneficiaries' sensitive personal data. Yesterday, alongside students, SNAP recipients, and the Electronic Privacy Information Center (EPIC), MAZON filed a new motion for a temporary restraining order to stop the USDA data grab while litigation is pending.
USDA's plan to create a new system of records (SOR), known as the National SNAP Information Database, is being proposed on an incredibly short timeline without meaningful public input and with major details missing.
You can learn more about the case on the MAZON website. You can also find the motion, the full complaint and the press release on the Student Defense website and the NCLEJ website
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Deborah Stein
Deborah Stein, Coalition on Human Needs, for Count
Original Message:
Sent: 07-23-2025 01:25 PM
From: Steve Pierson
Subject: Public comment on national SNAP fraud database (due July 23)
NPR did a story on this: https://www.npr.org/2025/07/19/nx-s1-5471553/usda-snap-privacy-lawsuit
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Steve Pierson
American Statistical Association
Original Message:
Sent: 07-18-2025 03:12 PM
From: Eric Giannella
Subject: Public comment on national SNAP fraud database (due July 23)
Not sure if this simply went under the radar or if there is a good reason for the lack of input. In late June, USDA filed the System of Record Notice and the deadline for public comment is July 23 (after
a lawsuit announcement noted that they had not gone through the PRA process). As of the morning of 7/18, there are only 10 public comments on the corresponding
ICR about building a national fraud monitoring system and database. I do not think the corresponding documents with more detail are yet available on the OIRA ICR website.
USDA will leverage data-sharing across Federal and State systems to identify and rectify any ineligible, duplicate, or fraudulent SNAP enrollments or transactions. This includes verifying eligibility based on immigration status, identifying and eliminating duplicate enrollments, assisting States in mitigating identity theft, and performing other eligibility and program integrity checks using lawfully shared internal and interagency data.
CATEGORIES OF INDIVIDUALS COVERED BY THE SYSTEM:
Individuals who have received, are currently receiving, or have applied to receive SNAP benefits.
CATEGORIES OF RECORDS IN THE SYSTEM:
The system consists of records containing personally identifying information, including but not limited to SNAP participant name, Social Security Number (SSN), date of birth (DOB), residential address, Electronic Benefit Transaction (EBT) card number, and case record identifier number or other identifiers or data elements maintained by States, vendors, or contractors to identify SNAP recipients. The system also consists of information derived from and associated with EBT transactions, including but not limited to records sufficient to calculate the total dollar value of SNAP benefits received by participants over time, such as applied amounts and benefit available dates.A couple of the 12 described uses:
(5) To another Federal agency or Federal entity, when USDA/FNS determines that information from this system of records is reasonably necessary to assist the recipient agency or entity in: (1) responding to a suspected or confirmed breach or (2) preventing, minimizing, or remedying the risk of harm to individuals, the recipient agency or entity (including its information systems, programs, and operations), the Federal Government, or national security, resulting from a suspected or confirmed breach.
(8) When a record on its face, or in conjunction with other records, indicates a violation or potential violation of law, whether civil, criminal or regulatory in nature, and whether arising by general statute or particular program statute, or by regulation, rule, or order issued pursuant thereto, USDA/FNS may disclose the record to the appropriate agency, whether Federal, foreign, State, local, or tribal, or other public authority responsible for enforcing, investigating, or prosecuting such violation or charged with enforcing or implementing the statute, or rule, regulation, or order issued pursuant thereto, if the information disclosed is relevant to any enforcement, regulatory, investigative or prosecutive responsibility of the receiving entity.
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Eric Giannella
Georgetown University
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