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household as moderate income if it has (i) income at or below 300 percent of the FPG for the <br />size of its household or (ii) income at or below 65 percent of the AMI for its county and size of <br />household. The combination of an FPG floor with AMI allows for a regional adjustment in areas <br />with substantially higher costs and incomes. Finally, Treasury also considered a range of FPG <br />and AMI thresholds above and below these levels. <br />Treasury chose the second option. Treasury believes that the higher FPG floor will ease <br />administrative burdens by making more households presumptively eligible for funds meant to <br />address negative economic impacts in a targeted manner. With respect to the low-income cutoff, <br />185 percent of the FPG for a family of four is $49,025, which is approximately the wage <br />earnings for a two -earner household where both earners receive the median wage in occupations, <br />such as waiters and waitresses and hotel clerks, that were heavily impacted by COVID-19. As <br />such, this cutoff is likely to include more workers in industries heavily impacted by COVID-19, <br />who may be most likely to face disproportionate impacts of the pandemic, than a lower <br />threshold.393 With respect to the moderate -income cutoff, many households with incomes <br />between 200 percent and 300 percent of the FPG struggle with a lack of economic security, <br />suggesting that 300 percent of the FPG was an appropriate cutoff for moderate income. <br />Treasury also considered relatively higher thresholds for both an FPG and AMI approach; <br />however, increasing income thresholds for presumed eligibility increases the likelihood that <br />higher -income workers, who generally experienced fewer economic impacts from the pandemic, <br />would become presumed eligible for responsive services. Providing services to households that <br />did not experience a negative economic impact, or experienced a relatively minimal impact, <br />393 See U.S. Bureau of Labor Statistics, Occupational Employment and Wage Estimates, <br />https://www.bls.gov/oes/current/oes_nat.htm (last visited November 9, 2021). <br />386 <br />