The Virginia Poverty Law Center has multiple concerns about the proposed regulatory action. On its face, the policy recommendation appears to produce no clear gains in efficiency. It would essentially replace one reporting process with another, which is more onerous to administer according to the vast majority of local DSS offices that have submitted comments thus far. In addition, the proposed policy change would likely generate increased disruptions in benefits, since the untimely filing of a re-certification application results in proration. Finally, the proposed regulatory action, as drafted, is too broad in scope. Aged, blind, and disabled households typically have fixed incomes; therefore re-certification every six months is unnecessary for this segment of program participants. In the current economic climate, SNAP households and local DSS offices alike are forced to stretch limited resources. The proposed regulatory action seems ill-suited to alleviate these burdens and therefore warrants further examination.