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SNAP Program Undergoes Funding Changes and Policy Revisions Amid Government Shutdown and Judicial Rulings

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The Supplemental Nutrition Assistance Program (SNAP), which provides food assistance to over 42 million Americans, has recently been subject to significant changes. These developments stem from a government shutdown, federal court orders, and new legislative requirements, impacting benefit distribution, payment calculations, and introducing new work mandates. The changes have drawn varied responses from state officials, policy experts, and advocacy groups.

Initial Impact of Government Shutdown and Emergency Funding

An ongoing government shutdown, which began on October 1, led to a lapse in federal funding for the Supplemental Nutrition Assistance Program (SNAP). Initially, the U.S. Department of Agriculture (USDA) indicated it would not distribute food assistance funds starting November 1 due to a lack of available funding.

This position prompted lawsuits from half of the U.S. states, the District of Columbia, cities, and non-profit organizations, arguing for the program's continuation.

Federal judges in Massachusetts and Rhode Island subsequently issued rulings against the administration's plan to suspend benefits. A Massachusetts federal judge ordered the administration to access an emergency contingency fund for SNAP, estimated at approximately $6 billion, and mandated a report back to the court regarding the authorization of at least partial benefits.

A Rhode Island judge issued a temporary restraining order, stating the plan to suspend SNAP was "likely unlawful."

In response to these orders, the USDA announced it would provide half of the normal monthly SNAP benefits to recipients by utilizing $5.25 billion in emergency funding. This decision aimed to facilitate at least partial payments for November. President Trump had previously stated he instructed government lawyers to seek court guidance on legal methods to fund SNAP.

A family of four typically receives an average of $715 per month in SNAP benefits, meaning recipients would receive approximately half of this amount under the new directive. States, which administer the benefits using federal funds, were expected to receive clarity on distribution details.

Challenges for States and January Benefits

The implementation of revised payment calculations for January SNAP benefits presented procedural complexities for states. The USDA's plan for partial payments utilized a contingency fund, with the Center for Budget and Policy Priorities (CBPP) estimating an allocation of approximately $3 billion from this fund. This amount was less than the $4.65 billion that two federal judges had indicated should be used to maintain SNAP entitlements following the funding lapse.

State officials expressed concerns regarding the administrative burden. Tikki Brown, head of Minnesota's Department of Children, Youth and Families, stated that the process necessitated a complete recalculation and recoding of their system, with no immediate timeline for payments in her state. Danny Mintz of Code for America noted that some states utilize older systems, which could complicate the rapid implementation of extensive calculation changes and raise concerns about potential system malfunctions. Pennsylvania requested permission to use a simpler, faster method for distribution, similar to one approved for pandemic-related aid.

According to a CBPP analysis, approximately 40% of households receiving the maximum SNAP benefit level could experience a reduction of about half their usual payment in January. Households with other income sources were projected to face a larger proportional decrease. Some one-to-two-person households were projected to receive as little as $12, and an estimated 1.2 million households (totaling nearly 5 million individuals) could receive no benefits.

Proposed Program Changes and Allegations of Fraud

Agriculture Secretary Brooke Rollins indicated that recent attention on SNAP during the government shutdown provided an opportunity to reassess the program. Rollins has advocated for modifications, citing findings of "massive fraud" based on state data requested by her agency. She presented statistics alleging misconduct without providing detailed underlying data.

Rollins stated the objective of these changes is to ensure benefits reach "vulnerable Americans" while protecting taxpayers from "fraudsters and corrupt individuals."

Rollins cited statistics from data provided by 28 states and Guam, reporting 186,000 deceased individuals receiving benefits, 500,000 Americans receiving benefits twice, and over 120 arrests for SNAP fraud. She also stated that these figures did not include 'blue states,' where she believes more fraud exists, and noted a "40% increase" in SNAP benefits under the 'last administration,' indicating a need for 'right-sizing.'

Food policy experts have expressed concerns regarding Rollins' statements, suggesting they may overstate the prevalence of fraud among SNAP recipients and could conflate fraud with various payment errors. Experts noted that some deceased individuals may remain on the program temporarily due to verification processes, with households typically required to repay erroneous benefits. They also indicated that legitimate reasons can exist for double payments, such as supplemental payments issued to correct errors. The USDA has not publicly presented data to corroborate the specific statistics cited by Rollins. USDA data indicates SNAP payments expanded by approximately 40% in April 2020 during the pandemic, under the Trump administration.

Initial comments from Rollins suggesting a new reapplication process for all SNAP recipients caused confusion. The USDA later clarified its intention to utilize existing recertification protocols, which typically occur every six or twelve months, rather than implement entirely new application processes. The department affirmed its goal to address "fraud, waste, and incessant abuse" using standard recertification, state data analysis, regulatory work, and state collaboration. Earlier, the USDA had requested personal data of SNAP recipients from states; most Democratic-led states declined, and a federal judge in San Francisco blocked the USDA from withholding funding from non-compliant states, ruling the data demand likely unlawful.

A draft regulation submitted by the USDA to the Office of Management and Budget last month suggests a potential change to narrow "broad-based categorical eligibility" for SNAP, a rule currently used by over 40 states to allow welfare recipients to receive benefits. Researchers at the American Enterprise Institute have argued for ending this eligibility rule, noting it allows individuals with incomes above the statutory SNAP limit to receive benefits. The Center on Budget and Policy Priorities estimates such a policy change could result in nearly 6 million people losing SNAP benefits.

New Work Requirements and Projected Impact

New work requirements for the Supplemental Nutrition Assistance Program are scheduled to take effect on February 1, potentially impacting millions of beneficiaries. These requirements stem from legislation signed into law in July.

Key changes include:

  • The upper age limit for able-bodied adults without dependents (ABAWDs) to meet work requirements has been raised from 54 to 64.
  • Exemptions for parents or family members caring for a dependent have been lowered to children under 14 years old, previously under 18.
  • Exemptions have also been removed for homeless individuals, veterans, and young adults who were in foster care when they turned 18.

According to August 2025 estimates from the Congressional Budget Office (CBO), approximately 1.1 million people are projected to lose SNAP benefits between 2025 and 2034. This figure includes 800,000 ABAWDs up to age 64 and 300,000 parents or caregivers up to age 64 with children aged 14 and older. An additional 1 million ABAWDs aged 18 to 54 (or 18 to 49 starting in 2031) who do not live with dependents and would have received a waiver from work requirements could also lose benefits. The CBO estimates indicate that while there will be reductions in SNAP participation among these groups, these will be partially offset by increases in participation among American Indians, who received exemptions under the new legislation.

Supporters of the work requirements assert they are necessary to combat waste, fraud, and abuse within the program. Agriculture Secretary Rollins stated that SNAP benefits are intended to be temporary.

The USDA has affirmed its commitment to assisting state agencies with implementation and supporting eligible recipients in transitioning to work, education, or training opportunities.

Other perspectives suggest potential negative impacts. Joel Berg, CEO of Hunger Free America, stated that millions of people may lose necessary food, potentially increasing hunger and straining food banks. He also noted that vulnerable populations, such as homeless individuals, veterans, and young adults leaving foster care, could face particular difficulties in securing jobs and providing documentation. Data from the 2023 American Community Survey indicates that a majority of American families receiving SNAP benefits had at least one family member working in the past 12 months. A 2021 report from the National Bureau of Economic Research found that SNAP work requirements could lead up to 53% of eligible adults to exit the program within 18 months.