New rule threatens to undercount families in poverty

If the U.S. Office of Management and Budget (OMB) has its way, a new federal poverty calculation will underestimate the number of families — and children — living in poverty even more than it does today.

OMB’s Directive Number 14, “Consumer Inflation Measures,” will slow the rate of inflation adjustment when calculating the federal poverty level. If the directive goes into effect, the federal poverty level will not increase, even as the costs of housing, food and other necessities do. Over time, fewer individuals and families would be considered to be “in poverty,” despite actually living in it. They will be pushed off of a benefits cliff, deemed “not poor enough” to benefit from federal assistance, regardless of their financial struggles.


The federal poverty level, or poverty line, was established in response to evidence that low-income Americans were spending about a third of their income on food alone. The directive 14 is poised to undercut every public assistance program that has eligibility guidelines tied to the federal poverty level, such as the Supplemental Nutrition Assistance Program (SNAP or “food stamps”); the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC); the National School Breakfast and Lunch Programs; Head Start; Medicaid; Medicare and the Children’s Health Insurance Program (CHIP).

The implications for Maryland’s ability to provide its students a quality education are potentially disastrous.


This year, the Blueprint for Maryland’s Future became law and aims to bring the state a step closer to delivering a world-class education to all its students — no matter their ZIP code. Based on the recommendations of the “Kirwan” education commission, this blueprint includes investments in such areas as teacher salary increases and college and career readiness pathways, with special attention to schools in areas of concentrated poverty.

As a way of ensuring that the investments go where they are most needed, poverty measures are used — some state, others federal. For instance, two hallmarks of the blueprint are community schools and full-day pre-K. Both approaches would use poverty measures to calculate levels of financial investment. State officials will use the free and reduced-price meals (FARMS) rate — a poverty proxy — to designate individual “community schools,” which offer high-quality instruction, health, social service and community engagement to meet the needs of the whole child. For universal pre-K, families would pay a subsidized amount based on a sliding scale, with eligibility up to 600 percent of the federal poverty level for a family of four. High-quality pre-K programs offer pre-reading skills, advanced vocabulary usage and the basic math skills to give children a strong start in school.

In Maryland, more than 1 in 5 children come from families that rely on some form of federal assistance. Nearly every major policy recommendation of the Kirwan Commission assumes on some level that the federal poverty level will reliably indicate students’ economic circumstances. If the directive takes effect and that assumption fails, hundreds of thousands of Maryland’s children will lose access to the resources critical to the success of the Blueprint for Maryland’s Future over time.

This reality is not a sharp deviation for the federal government. In 2017, just 9% of the federal budget went to children, primarily through programs like school meals and Medicaid, and indirectly via the earned income tax credit. OMB Directive Number 14 is just another slow, insidious method being used by the current federal administration to further marginalize specific groups of people and force their children to suffer in silence.

Thankfully, there are steps to be taken to advocate for Maryland’s young people at the federal, state, and local levels:

  1. Provide a formal comment to the federal government by June 21st, asking them not to advance OMB Directive Number 14.
  2. And talk to your state and local representatives about committing to support sustainable, progressive methods of funding the recommendations of the Kirwan Commission as they set about revising the state’s public education funding formula.

The future of our state and its children is at stake.

Shamoyia Gardiner is an education policy senior associate at Advocates for Children and Youth. Her email is