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above the poverty line, often lack economic security.31 Treasury determined the AMI threshold <br />for moderate income by maintaining the same ratio of FPG multiplier to AMI multiplier as in the <br />definition of low income. This anchors the threshold to the existing definitions of moderate <br />income from the literature while taking into account geographical variation in income and <br />expenses in the same manner as the definition of low income. <br />Eligibility Presumptions <br />Public Comment: Many commenters believed that a broader range of groups should be <br />considered presumptively impacted and disproportionately impacted, arguing that many <br />households had been affected by the pandemic and that broader presumed eligibility would help <br />recipients provide assistance quickly and effectively. <br />Treasury also received many comments on the presumption that families living in QCTs <br />or receiving services from Tribal governments were disproportionately impacted by the <br />pandemic. While many commenters supported the interim final rule's recognition of <br />disproportionate impacts of the pandemic on low-income communities, many commenters <br />disagreed with treating QCTs as the only presumed eligible group of disproportionately impacted <br />households, apart from households served by Tribal governments. While acknowledging a <br />potential increase in administrative burden, commenters recommended that Treasury presume <br />other households or geographic areas, in addition to QCTs, were disproportionately impacted; <br />suggestions included all low- and moderate -income households, geographic areas designated as <br />31 For instance, households earning between 200 and 300 percent of the FPG have significantly higher rates of food <br />and housing insecurity than those earning above 300 percent of the FPG. Table 1, Kyle J. Caswell and Stephen <br />Zuckerman, Food Insecurity, Housing Hardship, and Medical Care Utilization, Urban Institute (June 2018), <br />https://www.urban. org/sites/default/files/publication/98701/2001896_foodinsecurity_housinghardship_medicalcareu <br />tilization_finalized.pdf. <br />35 <br />