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The design and delivery of public assistance programs comprise some of the biggest consumer protection issues facing low-income households today. Low-income consumers can be harmed in three ways: through an overall design flaw within the program, by specific rules and regulations within the program shown to be irrational or unreasonable (either facially or on application), or by program mismanagement. Program design and implementation decisions are often made in response to budget constraints. In addition, state and federal agencies often respond to program challenges by claiming that it would be fiscally impossible to provide the requested remedies. Fiscal impossibility defenses to program challenges must be carefully reviewed.
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