Medicare and Medicaid Programs; Repeal of Minimum Staffing Standards for Long-Term Care Facilities
Comment: Submitted to Centers for Medicare & Medicaid Services
Policy

In November 2025, during the 2025 federal government shutdown, LDI Senior Fellow Senbagam Virudachalam, MD, MSHP testified before Philadelphia City Council’s Committee on Public Health and Human Services on threats to the Supplemental Nutrition Assistance Program (SNAP) and SNAP-Ed.
Her written testimony highlighted the level of need in Philadelphia, the myriad local resources that support those experiencing food insecurity, and opportunities for the City to strengthen the local food system and support the diets and wellbeing of children and families in Philadelphia.
You can watch her testimony here.
Views expressed by the researchers are their own and do not necessarily represent those of the University of Pennsylvania Health System (Penn Medicine).
November 5, 2025
Good morning, Council President Johnson, Chairperson Ahmad, and members of the Committee on Public Health and Human Services,
My name is Dr. Senbagam Virudachalam, and I am an Assistant Professor of Pediatrics at Children’s Hospital of Philadelphia and University of Pennsylvania. I am also a member of The Food Trust Board of Directors and City Council’s Food and Nutrition Security Task Force.
I’d like to begin by applauding Mayor Parker and Governor Shapiro for their recent efforts to combat food insecurity during this unprecedented time of need. Governor Shapiro recently declared a state emergency and is channeling $5 million to food banks with more than $1 million for the “SNAP Emergency Relief Fund.”
Furthermore, Mayor Parker has committed $14 million to a “One Philly SNAP Support Plan” in response to the lapse in federal funding for food assistance benefits. This money will be used to support food banks, promote the Philadelphia Food and Meal Finder, provide rental assistance, and support small businesses throughout the city.
I have been a pediatrician for nearly twenty years, more than 15 of those in Philadelphia. I am also a scientist who studies nutrition, health, and the systems that reach children and families. In my clinic this week, nearly every family I have seen has shared that they do not have enough money for food. I have never before seen this level of need. SNAP and other nutrition assistance programs play a crucial role for children, families, and their communities. We must ensure that everyone in this city has access to enough fresh, healthy food, both during this emergency and going forward.
The lack of SNAP funding will also have an enormous impact on the local food economy, with tens of millions of fewer dollars being spent on groceries. This lost revenue will strain farmers and vendors who produce and sell food, eventually making it economically untenable for them to continue to provide food as they currently do. Ultimately, everyone will be impacted, not only those who depend on SNAP.
Tragically, this is an emergency of our own making. The last several years, including the COVID-19 pandemic, have shown that our food system is fragile, and periodic emergencies may be the new normal. To weather this crisis and those that follow, we must ensure that every Philadelphian is connected to a strong and resilient local and regional food system. What does this mean, practically speaking, and why is it important?
In order to thrive, adults and children must eat mostly whole, plant foods, meaning vegetables, fruits, grains, and beans. Americans do not eat anywhere near the recommended amounts of these foods. In 2021, for instance, half of 1- to 5-year-olds were not eating even a daily vegetable. Instead, whole foods have been replaced with high-fat, high-sugar, high-salt foods that cause illness instead of supporting health. The current food system, which contributes to 25-30% of all greenhouse gas emissions, offers abundant processed, highly palatable, and cheap foods and simultaneously makes fresh, healthy foods inaccessible and unaffordable, ultimately affecting eating habits over generations.
Yet there is reason to hope. Philadelphia and Pennsylvania have an abundance of natural resources and the capacity to grow food nearly year-round. There is a thriving grassroots network of farmers markets, urban farms, and community gardens in this city. The people and non-profit organizations who have built this network have worked hard to ensure that it reaches all Philadelphians, especially those with low income. We need city-level and institutional support to strengthen and expand the breadth and reach of this system, both during this crisis and going forward. Philadelphians deserve to eat fresh food that tastes good and nourishes their bodies and minds. Regardless of income, every Philadelphian should be afforded the dignity of choosing fresh foods that meet their preferences.
For example, The Food Trust offers vouchers, called Food Bucks to low-income residents that can be redeemed at farmers markets and stores throughout the city. When SNAP is operational, Food Bucks subsidize the purchase of fruits and vegetables for SNAP recipients. Now, the Food Bucks program is being scaled up to meet emergent demand, putting fresh food into the hands of people who need it while simultaneously ensuring that local, small farms maintain sales and remain economically viable. The city should support farmers markets that bring local and regional produce to every neighborhood in the city, year-round and provide subsidies to low-income residents to purchase this produce.
We must also ensure that families feel they are able to make use of available fresh, whole foods. At CHOP, we have developed a program called Home Plate that uses shared cooking to build community connectedness and practical skills to support food security and healthy eating habits, especially among populations with limited financial resources. Home Plate is an informal, experiential, 6-week program. Weekly themes include basic cooking skills, incorporating fresh and whole ingredients (including locally grown produce), planning and convenience, stretching food dollars, and cooking creatively. Initial findings have been promising, with improvements in young children’s diet quality and household food security in two randomized trials.
To further strengthen the local food system and support the health of its citizens, the city and its anchor institutions should source sustainably grown, local and regional produce to be served in schools, hospitals, universities, and other institutions. Philadelphia’s Urban Agriculture Plan, called Growing from the Root and published in 2023, provides a 10-year roadmap to enact such policies. I encourage every member of Council to support actualizing this plan through allocation of funds and coordination across city agencies. Stronger local coordination between the city, nonprofits, hospitals, and schools could reduce reliance on federal programs.
One argument I often hear in a crisis such as this one is that it doesn’t matter what food we provide to hungry people, we just have to give them something. I posit that especially in a crisis like this one, the type of food we provide and where it comes from matters a great deal. We must meet this moment with every tool at our disposal and ensure that we are better prepared for future emergencies. We need a long-term strategy to ensure food and nutrition security for all Philadelphians that centers people and the Earth that sustains us. Despite the crisis we now find ourselves in, I remain hopeful that we will find our way through this moment and emerge stronger and more connected to one another.
Views expressed by the researchers are their own and do not necessarily represent those of the University of Pennsylvania Health System (Penn Medicine).
Comment: Submitted to Centers for Medicare & Medicaid Services
Comment: Delivered to the Centers for Medicare & Medicaid Services (CMS)
Memo: Response to Request for Analysis
Testimony: Delivered to Philadelphia City Council’s Committee on Health and Human Services
Testimony: Delivered to Philadelphia City Council’s Committee on Labor and Civil Service
Comment: Delivered to the National Center for Complementary and Integrative Health