First Focus on Children submitted the following comments urging the Office of Management and Budget (OMB) to extend or reopen the comment period on this notice until at least 30 days after the COVID-19 National Emergency had ended, ensure that any modifications to poverty thresholds capture the full breadth of resources needed to support children’s healthy development, and that the Working Group consult researchers and scientists to ensure any adjusted or alternative poverty measures released by the OMB meet these critical objectives. The proposed change was published in the Federal Register on February 14, 2020 (OMB-2019-0007-0001).


To prove meaningful, any adjusted or alternative poverty measure must capture all families without sufficient resources to prevent their children from experiencing hardship and its associated harms. Modifying the SPM without raising existing thresholds and adopting a consumption measure will only further underestimate child need and downplay the extent of economic instability facing America’s families. Accordingly, we urge the Working Group to consult with leading researchers and explore ways to improve poverty measures to include all children whose economic circumstances jeopardize their health, safety, and development.

No child in the world’s wealthiest nation should go to bed hungry or be deprived of clean air or be without the opportunities that come from having a safe, affordable place to call home.

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