Nourish California Public Comment: Collection of Race/Ethnicity Data in SNAP/CalFresh

Published on Aug 31, 2022

On August 28, Nourish California submitted public comment to the Federal Register in response to a proposed rule that would revise  SNAP/CalFresh policy regarding collection of race/ethnicity data of program applicants and participants. According to USDA, “this rule would remove regulatory language that provides an example that state agencies might collect race and ethnicity data by observation (also referred to as ‘visual observation’) when participants do not voluntarily provide the information on the application form.”

As an organization that recognizes the root causes of hunger and poverty, including the historic and ongoing harms of systemic racism, Nourish California strongly believes that to eliminate consequent inequities, communities, policymakers, researchers, advocates, and other stakeholders must be able to assess outcomes across racial and ethnic identities. This requires accurate, timely data from public services such as the federal nutrition programs, including SNAP/CalFresh.

Our comments include the following recommendations to USDA Food and Nutrition Service:

  • Eliminate Visual Observation
  • Engage Directly Affected Individuals
  • Ensure that matched data sources do not rely on visual observation
  • Make clear to all applicants that they can decline to state information about their race/ethnicity
  • Emphasize the collection of disaggregated race/ethnicity data

You can read our full comments here.

Have questions? Contact Tia Shimada, Director of Programs, at

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