OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge;
1. The Pennsylvania Department of Public Welfare (DPW) seeks review of a district court order which enjoins the application of a DPW regulation1 to appellees and others similarly situated. Because the challenged regulation establishes a classification which contravenes the equal protection clause, the district court order will be affirmed.
I.
2. Pennsylvania provides general assistance welfare benefits to “all of its needy and distressed” citizens.2 DPW administers [1151] the benefit program and is authorized to promulgate rules and regulations which are consistent with the program’s goals.3 The federal government administers a program of Supplemental Security Income benefits (SSI) which aids the blind, aged and disabled. The SSI need criteria are stricter in practice than are those which govern the Pennsylvania general assistance program.4
3. The challenged regulation, P.A.E.M. § 297.1(e),5 provides that the blind, aged, or disabled must apply for federal SSI benefits prior to applying for state general assistance benefits. It further provides that if a person is found not to be blind, aged, or disabled (and hence unqualified for SSI) that person may then apply for general assistance. However, if the person is found to be blind, aged, or disabled, yet ineligible for SSI for some other reason (such as income or resources over the maximum limits) that person is barred from applying for general assistance, even if the person would still qualify as needy under the applicable general assistance criteria. Thus, P.A.E.M. § 297.1(e) bars all aged, blind, or disabled persons from receiving general assistance, including those who are in fact needy under the Pennsylvania welfare code yet ineligible for benefits under the federal program. “The incongruity arises that if [such persons] were less disadvantaged [i. e. not blind, not aged, not disabled] they would be eligible for [general assistance], but since they are more disadvantaged they are not [eligible for general assistance]”. Medora v. Colautti, No. 78-1549, slip op. at 2 (E.D.Pa. Aug. 4, 1978).
4. All of the appellees were denied SSI benefits for reasons unrelated to their recognized disabilities6 and were subsequently [1152] declared ineligible for general assistance because of that denial. The district court concluded, “It is undisputed that if plain-' tiffs were not disabled and therefore not required to apply for federal support, they would be eligible for the state assistance.” Id.
5. The district court found that the regulation promulgated by DPW was arbitrary, capricious and an abuse of discretion and that it frustrated the purpose of Pennsylvania’s welfare statute. The court concluded that in applying the regulation and denying appellees benefits which the legislature intended they receive, DPW had violated the due process rights of the appellees. While we will affirm the district court’s order, we need not reach the due process issue, since we hold that the DPW regulation establishes a classification which contravenes the equal protection clause.7
II.
6. Under traditional equal protection analysis, we ask whether the challenged classification8 is rationally related to a legitimate governmental interest. United States Department of Agriculture v. Moreno, 413 U.S. 528, 533, 93 S.Ct. 2821, 37 L.Ed.2d 782 (1973). The articulated purpose of the statute is to provide “assistance to all of [the State’s] needy and distressed.” Pa.Stat.Ann. tit. 62, § 401 (Purdon 1968). The statute does not establish any eligibility criterion other than need; if anything it exhibits a special solicitude for the disabled. See note 3 supra. The challenged DPW classification, however distinguishes between the non-disabled needy and the disabled needy, providing aid to the former and denying it to the latter. See note 4 supra. A classification such as this one “must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relationship to the object of the legislation, so that all persons similarly circumstanced shall be treated alike.” Reed v. Reed, 404 U.S. 71, 76, 92 S.Ct. 251, 254, 30 L.Ed.2d 225 (1971), quoting Royster Guano Co. v. Virginia, 253 U.S. 412, 415, 40 S.Ct. 560, 64 L.Ed. 989 (1920). We hold that P.A.E.M. § 297.1(e) falls far short of this standard. It ignores the common denominator of need, and creates a classification that bears no relation to the legislatively declared purpose of the general assistance program. Indeed, by excluding some persons from general assistance despite their undisputed qualification as needy, the challenged regulation actually frustrates the object of Pennsylvania’s welfare statute.
7. The classification would still withstand equal protection scrutiny if it rationally furthered some legitimate govemmen[1153] tal interest other than that specifically stated in the Pennsylvania legislature’s declaration of intent. United States Department of Agriculture v. Moreno, 413 U.S. 528, 534, 93 S.Ct. 2821, 37 L.Ed.2d 782 (1973); Williams v. Wohlgemuth, 366 F.Supp. 541, 547 (W.D.Pa. 1973), aff’d. 416 U.S. 901, 94 S.Ct. 1604, 40 L.Ed.2d 106 (1974). This is a two-part test: the government interest must be legitimate and the challenged classification must be rationally related to the furtherance of that interest.
8. DPW advances three governmental interests to which it claims the challenged regulation is rationally related. First, the regulation avoids the administrative inconvenience of the state having to assess independently a disabled person’s need where the federal government has already made a determination. Second, the regulation encourages parties who may be eligible for SSI benefits to apply for them, with the result that state funds are preserved. Third, the regulation establishes a two-tiered system, which leaves to the federal government the task of • supporting blind, aged and disabled citizens and allows DPW to provide for the remaining needy. It is by no means obvious that the cumulative weight of these goals is sufficient to make out a legitimate government interest.9 We need not decide the question, however, since even if the three governmental interests presented by DPW are legitimate the challenged regulation fails rationally to further those interests.
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OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge;
1. The Pennsylvania Department of Public Welfare (DPW) seeks review of a district court order which enjoins the application of a DPW regulation1 to appellees and others similarly situated. Because the challenged regulation establishes a classification which contravenes the equal protection clause, the district court order will be affirmed.
I.
2. Pennsylvania provides general assistance welfare benefits to “all of its needy and distressed” citizens.2 DPW administers [1151] the benefit program and is authorized to promulgate rules and regulations which are consistent with the program’s goals.3 The federal government administers a program of Supplemental Security Income benefits (SSI) which aids the blind, aged and disabled. The SSI need criteria are stricter in practice than are those which govern the Pennsylvania general assistance program.4
3. The challenged regulation, P.A.E.M. § 297.1(e),5 provides that the blind, aged, or disabled must apply for federal SSI benefits prior to applying for state general assistance benefits. It further provides that if a person is found not to be blind, aged, or disabled (and hence unqualified for SSI) that person may then apply for general assistance. However, if the person is found to be blind, aged, or disabled, yet ineligible for SSI for some other reason (such as income or resources over the maximum limits) that person is barred from applying for general assistance, even if the person would still qualify as needy under the applicable general assistance criteria. Thus, P.A.E.M. § 297.1(e) bars all aged, blind, or disabled persons from receiving general assistance, including those who are in fact needy under the Pennsylvania welfare code yet ineligible for benefits under the federal program. “The incongruity arises that if [such persons] were less disadvantaged [i. e. not blind, not aged, not disabled] they would be eligible for [general assistance], but since they are more disadvantaged they are not [eligible for general assistance]”. Medora v. Colautti, No. 78-1549, slip op. at 2 (E.D.Pa. Aug. 4, 1978).
4. All of the appellees were denied SSI benefits for reasons unrelated to their recognized disabilities6 and were subsequently [1152] declared ineligible for general assistance because of that denial. The district court concluded, “It is undisputed that if plain-' tiffs were not disabled and therefore not required to apply for federal support, they would be eligible for the state assistance.” Id.
5. The district court found that the regulation promulgated by DPW was arbitrary, capricious and an abuse of discretion and that it frustrated the purpose of Pennsylvania’s welfare statute. The court concluded that in applying the regulation and denying appellees benefits which the legislature intended they receive, DPW had violated the due process rights of the appellees. While we will affirm the district court’s order, we need not reach the due process issue, since we hold that the DPW regulation establishes a classification which contravenes the equal protection clause.7
II.
6. Under traditional equal protection analysis, we ask whether the challenged classification8 is rationally related to a legitimate governmental interest. United States Department of Agriculture v. Moreno, 413 U.S. 528, 533, 93 S.Ct. 2821, 37 L.Ed.2d 782 (1973). The articulated purpose of the statute is to provide “assistance to all of [the State’s] needy and distressed.” Pa.Stat.Ann. tit. 62, § 401 (Purdon 1968). The statute does not establish any eligibility criterion other than need; if anything it exhibits a special solicitude for the disabled. See note 3 supra. The challenged DPW classification, however distinguishes between the non-disabled needy and the disabled needy, providing aid to the former and denying it to the latter. See note 4 supra. A classification such as this one “must be reasonable, not arbitrary, and must rest upon some ground of difference having a fair and substantial relationship to the object of the legislation, so that all persons similarly circumstanced shall be treated alike.” Reed v. Reed, 404 U.S. 71, 76, 92 S.Ct. 251, 254, 30 L.Ed.2d 225 (1971), quoting Royster Guano Co. v. Virginia, 253 U.S. 412, 415, 40 S.Ct. 560, 64 L.Ed. 989 (1920). We hold that P.A.E.M. § 297.1(e) falls far short of this standard. It ignores the common denominator of need, and creates a classification that bears no relation to the legislatively declared purpose of the general assistance program. Indeed, by excluding some persons from general assistance despite their undisputed qualification as needy, the challenged regulation actually frustrates the object of Pennsylvania’s welfare statute.
7. The classification would still withstand equal protection scrutiny if it rationally furthered some legitimate govemmen[1153] tal interest other than that specifically stated in the Pennsylvania legislature’s declaration of intent. United States Department of Agriculture v. Moreno, 413 U.S. 528, 534, 93 S.Ct. 2821, 37 L.Ed.2d 782 (1973); Williams v. Wohlgemuth, 366 F.Supp. 541, 547 (W.D.Pa. 1973), aff’d. 416 U.S. 901, 94 S.Ct. 1604, 40 L.Ed.2d 106 (1974). This is a two-part test: the government interest must be legitimate and the challenged classification must be rationally related to the furtherance of that interest.
8. DPW advances three governmental interests to which it claims the challenged regulation is rationally related. First, the regulation avoids the administrative inconvenience of the state having to assess independently a disabled person’s need where the federal government has already made a determination. Second, the regulation encourages parties who may be eligible for SSI benefits to apply for them, with the result that state funds are preserved. Third, the regulation establishes a two-tiered system, which leaves to the federal government the task of • supporting blind, aged and disabled citizens and allows DPW to provide for the remaining needy. It is by no means obvious that the cumulative weight of these goals is sufficient to make out a legitimate government interest.9 We need not decide the question, however, since even if the three governmental interests presented by DPW are legitimate the challenged regulation fails rationally to further those interests.
9. First, in regard to the claim of administrative convenience, since the state and federal governments administer programs with different eligibility criteria, it is irrational to allow a decision based on the stricter federal law to control a decision which is supposed to be based on the more generous state code. DPW must independently assess need because it has independently (and differently) defined need. By incorporating the SSI decisions as its own, DPW is in the wholly unreasonable position of declaring disabled persons to be not needy under the Pennsylvania need criteria, while declaring identically situated nondisa[1154] bled persons to be needy under exactly the same need criteria.
10. The second governmental interest is in promoting the “exhaustion” of federal sources of aid. While it may be rational for the state to require potential beneficiaries of general assistance to first apply for federal aid, once a person has applied for federal benefits and they have been denied, the goal of promoting exhaustion of federal sources of aid has been achieved. The rule challenged here, that the blind, aged or disabled needy who have applied for federal funds and been refused will still be denied state funds, is not even triggered until it is clear that no federal aid will be available to the applicant. The rule bears absolutely no relation to encouraging the exhaustion of federal funds. Of course, any rule that withholds aid from qualified applicants preserves state funds. But the state must do more than claim that denying aid to qualified persons saves money, for “the saving of welfare costs cannot justify an otherwise invidious classification.” Shapiro v. Thompson, 394 U.S. 618, 633, 89 S.Ct. 1322, 1330, 22 L.Ed.2d 600 (1969).
11. We turn to the final justification for P.A.E.M. § 297.1(e), that it will further the establishment of a two-tiered federal-state welfare system. The standard we have applied in our equal protection analysis has been determined by reference to the nature of the right affected by the classification and the identity of the class burdened by the classification. In this case the right affected is not fundamental and the class burdened is not suspect.10
12. Nevertheless, while receipt of welfare benefits may not be a fundamental right, it is an important right. Goldberg v. Kelly, 397 U.S. 254, 90 S.Ct. 1011, 25 L.Ed.2d 287 (1970). When a state undertakes to provide welfare benefits for the needy, some degree of imprecision and inequality in the allocation of benefits may be tolerated; such discrepancies are seen as the practical cost of large-scale economic and social welfare programs. Dandridge v. Williams, 397 U.S. 471, 90 S.Ct. 1153, 25 L.Ed.2d 491 (1970). But as discrepant treatment becomes purposeful, and if it involves denial of all aid rather than allocation of amounts of aid, the courts will more closely examine the rationality of the underlying classification.11 Weber v. Aetna Casualty & Surety Co., 406 U.S. 164, 172, 92 S.Ct. 1400, 31 L.Ed.2d 768 (1972). Close examination of rationality protects the rights of both the state and the burdened class members, and is appropriate in this case.12
[1155]*115513. Pennsylvania has recognized the importance of welfare and has undertaken to provide for “all of its needy.” Having assumed this obligation, the state must discharge it fairly. Pennsylvania also wishes to distinguish between federal and state aid programs. If the state acts to realize this goal, it must do so rationally. The requirement that general assistance applicants who may be eligible for SSI must first apply for SSI is a rational means of attaining the state’s twin objectives. It assures that the needy will receive aid, and that the aid will be provided by the appropriate governmentál source. The further requirement that those denied SSI will still be denied general assistance does not rationally serve those objectives because it operates to deny aid to the admittedly needy yet adds nothing to the federal-state distinction that has not already been achieved by the exhaustion rule. We cannot say that this is a rational means to further a governmental interest,13 especially when less brutal but equally effective means of achieving its goals are available to the state.14
III.
14. We hold that P.A.E.M. § 297.1(e) discriminates among similarly situated persons and does not rationally further any legitimate governmental interests. Accordingly, the order of the district court enjoining the application of the regulation to appellee Henrich and all other similarly situated persons, will be affirmed.
[P]laintiffs Henrich and Copen were living with men who were not their spouses. Under SSI regulations, such men are considered spouses and a portion of their incomes are deemed available for the use of the SSI applicants for purposes of determining need. Accordingly, the federal rule rendered plaintiffs ineligible for SSI benefits. ... On this basis, DPW denied those plaintiffs [general assistance] benefits, even though income of nonspouse companions is ordinarily not attributable to [general assistance] applicants under the DPW scheme. It is undisputed that, had plaintiffs been able to apply directly for [general assistance] funds, they would have been eligible in all respects. P.A.E.M. §§ 151.44, 187.22, 183.64.
Plaintiff Medora lived with her husband in their family home until his death. Until that time, she received SSI benefits. Upon her husband’s death, Medora put the home— which was encumbered by a mortgage almost equal to its entire value — up for sale and moved to a less expensive residence. [1152] Thereupon, her SSI benefits were terminated because “a house that is not lived in counts towards the resource limit” and she therefore had “countable resources” greater than $1,500. Medora then applied for [general assistance] benefits, which she received for a short time until they were terminated on the basis of the regulation at issue in this case. Had plaintiff not at one time been eligible for SSI benefits because of her disability, she would have received [general assistance] benefits; under the DPW scheme, eligibility is not affected by an applicant’s ownership of nonresidential real property so long as he or she is taking steps to convert it into cash and encumbers the property to secure repayment of assistance received until conversion is completed. P.A.E.M. §§ 177.23, 179.23.
No. 78-1549, slip op. at 2-3 (E.D.Pa. Aug. 4, 1978).
At oral argument, we were informed that after this appeal was filed Medora sold her home and was declared eligible for SSI. She is receiving SSI benefits presently. Copen was also declared eligible for SSI and is receiving benefits. Henrich, however, still receives benefits only because of the district court’s permanent injunction against the application of P.A. E.M. § 297.1(e).
As to the second interest, saving state funds, we must bear in mind the important interest that welfare benefits represent. In Shapiro v. Thompson, 394 U.S. 618, 89 S.Ct. 1322, 22 L.Ed.2d 600 (1969), which involved the total exclusion of persons from a “needs” program, the Court stated that “the saving of welfare costs cannot justify an otherwise invidious discrimination.” Id. at 633, 89 S.Ct. at 1330. See Buffington v. Beal, 430 F.Supp. 1281, 1284 (W.D.Pa. 1977). While it may be true that saving state funds is a legitimate state interest, where welfare benefits are involved, it is incumbent upon the state to proceed in a manner which achieves that goal while fairly treating similarly situated persons.
As to the third interest, the creation of a two-tiered, state-federal aid system, the district court was of the opinion that Dandridge v. Williams, 397 U.S. 471, 90 S.Ct. 1153, 25 L.Ed.2d 491 (1970), permitted a state to provide for such a system even if a group of otherwise qualified needy individuals were to be permarfently excluded from participation in the welfare program. The language in Dandridge which suggests this position is:
In the area of economics and social welfare, a State does not violate the Equal Protection Clause merely because the classifications made by its laws are imperfect. If the classification has some “reasonable basis”, it does not offend the Constitution simply because the classification “is not made with mathematical nicety or because in practice it results in some inequality.”
397 U.S. at 485, 90 S.Ct. at 1161.
Dandridge was a case in which the allocation of funds amongst needy recipients was challenged. While the Court observed that the equal protection clause allows some measure of inequality to occur, Dandridge was a case in which all qualified beneficiaries received at least some benefits. Dandridge cannot be read broadly to settle the question of whether benefits may be totally denied to a class of persons who are similar in all relevant respects to a class of persons who have been granted benefits. See Buffington v. Beal, 430 F.Supp. 1281 (W.D.Pa. 1977); Morales v. Minter, 393 F.Supp. 88, 101 (D.Mass. 1975); Williams v. Wohlgemuth, 366 F.Supp. 541 (W.D.Pa. 1973), aff'd., 416 U.S. 901, 94 S.Ct. 1604, 40 L.Ed.2d 106 (1974).
The plight of appellees is similar to that of the parties in the illegitimacy and gender cases. The reasoning of those cases, that no group should be singled out and burdened because of a characteristic over which they have no control and which is not related to a legitimate goal of the regulation, is instructive in the instant case.