This page provides an overview and explanation of provisions included in the 2025 budget reconciliation bill that are related to the Supplemental Nutrition Assistance Program (SNAP). It includes information about the implementation of these provisions, state-specific approaches, deadlines and effective dates, arguments, reform proposals, and relevant state-by-state datasets.
The One Big Beautiful Bill Act (OBBBA), was a federal budget reconciliation bill that Congress passed and President Donald Trump (R) signed in July 2025.[1] It included a number of provisions related to the Supplemental Nutrition Assistance Program (SNAP). SNAP is a federally-funded public assistance program that provides monthly payments to low-income households to help them afford groceries. States administer their SNAP programs with funding from both the state and federal governments.
Among the changes to SNAP enacted as part of the One Big Beautiful Bill Act were: a reduction in the federal match for SNAP administrative costs, the establishment of a performance-based state cost-share formula for SNAP benefits tied to payment error rates, making the 2021 Thrifty Food Plan the permanent baseline for SNAP benefits, an expansion and standardization of SNAP work requirements for able-bodied adults, the removal of federal funding for the SNAP education and obesity prevention grant program after FY2025, and the tightening of noncitizen eligibility rules under SNAP.
The performance-based state cost-share formula marks a major shift in the way the program is funded. Historically, the federal government has paid for the entirety of SNAP benefits nationwide and has paid half of administrative costs for each state. The majority of the program's cost is the price of benefit payments rather than administrative costs.[2] The OBBBA reduced the federal match for administrative costs from 50% to 25% beginning in 2027 and requires states with payment error rates above 6% to begin paying up to 15% of benefit costs beginning in 2028.[3]
Because states are incentivized to quickly lower their error rates, arguments and reform proposals have developed as to the best ways to achieve that goal.
Click on one of the tiles to the right to skip to one of these sections.
For more detailed information about the budget reconciliation process and an overview of the OBBBA, click here.
To be directed to one of Ballotpedia's other topic-specific OBBBA pages, click one of the following links:
- Overview of SNAP provisions in the OBBBA
- Timeline and deadlinesKey effective dates and deadlines for compliance for states.
- State responses
- Arguments and reform proposals
- Full text and CRS summary of SNAP provisions in the OBBBA
- Federal guidance documents
- Key terms and definitions
- How does budget reconciliation work?
Overview of Supplemental Nutrition Assistance Program (SNAP) provisions in the OBBBA
The One Big Beautiful Bill Act included SNAP policy changes that shifted financial responsibilities for the program, made changes to eligibility requirements for recipients, and changed conditions regarding certain utility payments. These changes are listed under three different categories below. They are as follows:[1]
- The OBBBA made four funding changes:
- Established a performance-based state cost-share formula for SNAP benefits, which is tied to payment error rates and increases state financial exposure, or potential loss, beginning in FY2028 (Section 10105).
- Reduced the federal match for SNAP administrative costs from 50% to 25%, shifting greater responsibility for program costs on to states, starting in FY2027 (Section 10106).
- Codified the 2021 Thrifty Food Plan as the permanent baseline for SNAP benefits and prohibited cost increases in future reevaluations, limiting USDA discretion (Section 10101).
- Removed federal funding for the SNAP education and obesity prevention grant program after FY2025, reducing federal involvement in state-level nutrition education (Section 10107).
- The OBBBA made two changes to eligibility requirements:
- Expanded and standardized SNAP work requirements for able-bodied adults, limiting state flexibility to waive rules except under exemptions for noncontiguous states—Alaska and Hawaii—until 2028 (Section 10102).
- Tightened noncitizen eligibility rules under SNAP, narrowing federal eligibility definitions and limiting states' ability to provide benefits to broader categories of immigrants (Section 10108).
- The OBBBA made two changes related to utility payments:
- Eliminated categorical eligibility for the HCSUA for households receiving certain energy assistance benefits that do not contain a member who is elderly or disabled (Section 10103).
- Previously, eligibility for certain energy assistance programs automatically made households eligible for a Heating and Cooling Standard Utility Allowance (HCSUA). If a household is eligible for the HCSUA, it is deducted from their income when determining the amount of SNAP benefits the household is eligible for.
- Prohibited deducting internet service fees as part of housing and utility costs when determining SNAP benefits (Section 10104).
- Households receiving SNAP benefits may deduct some of their housing and utility costs from their income when determining the amount of SNAP benefits they are eligible to receive.
Funding changes in the OBBBA
States have been required to track payment errors since the early 1980's. Payment errors are reported by states and checked by the USDA. Historically, state agencies have been required to develop corrective action plans when their error rates exceed 6%. States have also been required to pay damages to the USDA and/or invest in correcting the determined cause of the state's high error rate when it exceeds the national error rate.[4][5] The OBBBA established another quality control system, which will require states with error rates above 6% to pay up to 15% of the costs of SNAP benefits in the state.[1]
A payment error occurs when SNAP benefits are issued incorrectly, either to an ineligible household, in the wrong amount, or based on misapplied eligibility rules. Common causes include incorrect reporting of income, household size, or allowable expenses. Sections 10102, 10103, 10104, and 10108 of the OBBBA changed who is eligible for SNAP benefits. Section 10105 of the OBBBA established a performance-based cost-share system that ties state financial responsibility to payment error rates.[1]
Beginning in FY2028, states will be required to pay a share of SNAP benefit costs if their error rate exceeds 6%. States with error rates from 6 to 8% will pay 5% of benefits, states with 8 to 10% will pay 10% of benefits, and states with error rates over 10% will pay 15%. For states with error rates under 6%, the federal government will continue to pay all of SNAP benefits. For states with exceptionally high error rates (where the rate × 1.5 exceeds 20%), implementation of this section can be delayed until FY2030.
Error rates are determined through federally required quality control reviews on sampled cases. States submit their rates to the USDA, which verifies the data, and works with states to locate the source of errors or implement corrective action plans.[4]
For fiscal year 2028, states will be able to choose to use their 2025 or 2026 error rate to determine their cost-share. Starting in FY2029, the cost share will be calculated using the rate from three years prior (e.g., error rate from 2026 determines cost-share in 2029).[1]
States that may be eligible to pay no cost-sharing of benefits, or eligible to delay cost-sharing
Similarly, if payment error rates remain unchanged from 2024 through FY2025-FY2026, then nine states and the District of Columbia would be eligible to delay the start of cost-sharing from FY2028 to FY2030. These states and D.C. all had error rate that when multiplied by 1.5 was greater than 20. If cost-sharing is delayed, then the share of benefits they begin paying in FY2030 will be based upon their error rate in FY2027, and follow the same formula as for other states. These states are: Alaska (24.66% error rate in FY2024), Florida (15.13%), Georgia (15.65%), Maryland (13.64%), Massachusetts (14.1%), New Jersey (14.33%), New Mexico (14.61%), New York (14.09%), and Oregon (14.06%). As of November 2025, this group included one state with divided government, two Republican trifectas, and six Democratic trifectas.
Based on FY2024 data, twelve states were less than a 1% decrease in their error rate from qualifying for a lower cost-share bracket, and four additional states were within a 1% decrease of having no cost-share obligation. Eighteen states were within a 1% increase in their error rate from moving to a higher cost-share bracket, including five states that would have no cost-share obligation based on their 2024 error rate. A lower bracket means the state will be required to pay a smaller percentage of the cost of benefits in their state, while a higher bracket means the opposite.
As of November 2025, five states with a Democratic trifecta, seven with a Republican trifecta, and four states with divided governments were within a 1% decrease in error rate from a lower cost-share bracket. As of the same date, one state with a Democratic trifecta, 13 with a Republican trifecta, and four states with divided governments were within a 1% increase in their error rate from a higher cost-share bracket.
Federal administrative cost match
SNAP involves both administrative costs and the costs of benefit payments. Historically, the federal government has paid states half of the costs of administering their SNAP programs. Section 10106 of the OBBBA reduced the federal match for SNAP administrative costs from 50% to 25%, shifting greater responsibility for program costs on to states, starting in FY2027.[1]
Thrifty Food Plan baseline for SNAP benefit payments
Since 1894, the USDA has been producing food plans to demonstrate ways to eat a healthy diet across different cost brackets. The USDA produces thrifty food plans, low-cost food plans, moderate-cost food plans, and liberal food plans, with the thrifty food plans being the lowest-cost and the liberal food plans being the most expensive.[7]
The Thrifty Food Plan is based on current food prices, food composition data, consumption patterns, and dietary guidance and is used to determine the maximum SNAP benefit allotments for each fiscal year. The plan made in 2021 allocates $835.57 per month for groceries to a reference family of four that consists of two adult parents and two children. Under Section 10101 of the OBBBA, the Thrifty Food Plan's market baskets cannot be reevaluated until after Oct. 1, 2027, meaning that the prices set in 2021 will be used through FY2028. The OBBBA also requires future reevaluations of the Thrifty Food Plan to be cost-neutral, meaning that the primary adjustment is for inflation.[7][8][1]
Removal of SNAP-Ed funding
Section 10107 of the OBBBA ended required funding for the SNAP Nutrition Education and Obesity Prevention Grant Program (SNAP-Ed). This program was administered by state and local agencies using federal grant money. The program was intended to promote healthy food choices and physical activity. The USDA released a memo that directed state agencies to either submit state plans for the continuation of their SNAP-Ed programs or give notice of their intent to close their program and return any unexpended funding.[9][10][1]
Eligibility changes in the OBBBA
Work requirements changes
SNAP work requirements are activities that certain recipients must complete in order to remain eligible for food assistance. SNAP has two types of work requirements:
- 1. General work requirements, which apply to most adult recipients, including able-bodied adults without dependents (ABAWDs), and
- 2. ABAWD work requirements, which apply to ABAWDs in addition to general rules and restrict benefits to three months in a 36-month period for those who are noncompliant. After reaching this time limit, they lose eligibility for benefits unless they start meeting the work requirement.[11][12]
Exemption changes
The One Big Beautiful Bill Act (H.R.1) includes significant changes to the exemptions to program's ABAWD work requirements, as outlined in Section 10102 of the Act.[13] These changes are as follows:
- Changes to the exceptions to the ABAWD work requirements under Section 6(o)(3) of the Food and Nutrition Act of 2008:
- Exemptions were removed for individuals who are:
- currently homeless,
- veterans,
- 55 to 64 years of age,
- responsible for a dependent child who is older than 13 years of age,
- 24 years of age or younger who were in foster care under the responsibility of a State on the date of attaining 18 years of age (or such higher age as the State has elected).
- Exemptions were added for individuals who are defined as Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act.
- Current status of exceptions to the ABAWD work requirements:
- An individual is exempt if they are:
- under 18 or over 65 years of age,
- medically certified as physically or mentally unfit for employment,
- responsible for a dependent child under 14 years of age,
- exempt from general SNAP work requirements,
- pregnant, or
- an Indian, Urban Indian, or Californian Indian as defined by the Indian Health Care Improvement Act.
Work requirement waivers
ABAWDs who are non-compliant with SNAP work requirements are restricted to 3 months of benefits within a 36-month period.[11] States can request temporary waivers for the time limits associated with the ABAWD work requirements in areas where unemployment is high, allowing these recipients to continue collecting benefits.
Section 10102 of the OBBBA narrowed the criteria for these waivers:[14]
- States can no longer apply for waivers based on “lack of sufficient jobs.”
- Waivers are now only allowed if:
- The unemployment rate exceeds 10%, or
- Alaska and Hawaii: unemployment is at least 1.5 times the national rate (through 2028).
As of the third quarter of the 2025 fiscal year, three states had full ABAWD time limit waivers, and 25 states had waivers for specific counties with high unemployment.[15]
Noncitizen eligibility changes
Certain noncitizens who are lawfully present in the U.S. are eligible for SNAP benefits if they meet program requirements, such as Lawful Permanent Residents (LPRs). Section 10108 redefined eligibility for certain lawfully present noncitizens. The USDA released a guidance document for state agencies regarding these changes on October 31. On Nov. 26, 2025, a group of 22 attorneys general filed a lawsuit against the Trump administration regarding the guidance document. They argued that the guidance document, "wrongly declares several groups of legal immigrants ineligible for food assistance, including permanent residents who were granted asylum or admitted as refugees."[16]
OBBBA Section 10108 text
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Congressional Research Service summary of Section 10108
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Guidance regarding Section 10108 from the USDA as of October 31, 2025
The USDA guidance document states that eligibility was removed for 11 groups and remained unchanged for nine groups. These changes are as follows:[18]
- Eligibility was removed for individuals with the following statuses:[18]
- Deportation withheld,
- Certain Native Americans that were born abroad, who are not also Lawful Permanent Residents (LPRs),
- Hmong or Highland Laotian Tribal Members, who are not also LPRs,
- Conditional entrants, who are not also LPRs,
- Battered aliens, who are not also LPRs,
- Victims of severe trafficking and certain family members, who are not also LPRs,
- Refugees,
- Individuals granted asylum,
- Parolees,
- Certain Afghan Nationals that were granted parole between July 31, 2021, and September 30, 2023, and
- Certain Ukrainian Nationals that were granted parole between February 24, 2022, and September 30, 2024.
- Eligibility was not changed for individuals with these statuses (although the definition of SNAP-eligible alien group was changed, see above):[18]
- Noncitizen U.S. Nationals,
- Cuban and Haitian Entrants,
- Compacts of Free Association (COFA) Citizens,
- Children under the age of 18 in any SNAP-eligible alien group,
- Lawful Permanent Residents (LPRs) with 40 qualifying work quarters,
- Individuals in any SNAP-eligible alien group who are blind or disabled,
- Individuals in any SNAP-eligible alien group who were 65 years of age or older on August 22, 1996,
- Individuals in any SNAP-eligible alien group with a military connection, and
- Amerasians.
Typically, Lawful Permanent Residents (LPRs) who meet the SNAP eligibility requirements are permitted to begin receiving benefits after a five-year waiting period. Before the enactment of the OBBBA, LPRs could bypass this waiting period by meeting one or more of the following criteria:[18]
- Are under the age of 18,
- Have 40 qualifying work quarters,
- Are blind or disabled,
- Were lawfully residing in the U.S. and 65 or older on August 22, 1996, or
- Have a U.S. military connection.
The OBBBA added three more criteria to this list. LPRs who do not meet any of the criteria above can now still bypass the five-year waiting period if they:[18]
- Are admitted to the United States as an Amerasian immigrant,
- Are certain American Indians born abroad, or
- Are certain Hmong or Highland Laotian tribal members.
Elimination of categorical eligibility for utility allowances for certain energy assistance recipients
State agencies make certain deductions from households' income when determining the amount of benefits recipients are eligible to receive. One type of deduction is a standard utility allowance (SUA). States create different types of SUAs, including the Heating and Cooling Standard Utility Allowance (HCSUA), which can be applied to households that have heating and cooling expenses. Before the enactment of the OBBBA, families receiving a certain level of assistance through the Low Income Home Energy Assistance Program (LIHEAP) or another similar energy assistance program were automatically eligible for the HCSUA. The OBBBA removes this categorical eligibility for the HCSUA for households that do not include an elderly or disabled member. Households that do not contain an elderly or disabled member can still be eligible for SUAs, including the HCSUA, by meeting regular program requirements, but are no longer automatically eligible on the basis of receiving energy assistance.[19][1]
Removal of internet expenses from approved utility costs
Households receiving SNAP benefits may deduct some of their housing and utility costs from their income when determining the amount of SNAP benefits they are eligible to receive. Section 10104 of the OBBBA prohibited internet service fees from being included as part of housing and utility costs when calculating these deductions. Because households with higher reported income receive less benefits, this provision may decrease the benefits a household receives if they were previously including internet costs in their utility allowances.[1]
Timeline and deadlines
Below is a timeline showing the dates that the SNAP provisions from the OBBBA became effective and the end date of the hold harmless period for provisions that became effective on the date of the OBBBA's adoption. Next to each date is a short description of the provisions associated with that date. Hover over a point on the timeline for the provisions that become effective, as well as obligations for states and SNAP recipients associate with that date.
State responses
Arizona House Bill 2206 (2026)
On Feb. 20, 2026, Governor Katie Hobbs (D) vetoed House Bill 2206, which would have required the Arizona Department of Economic Security to lower the state's SNAP payment error rate to 3% or lower by December 30, 2030. The bill sought to lower the SNAP payment error rate to by creating financial incentives for the department. The bill states that if the department failed to meet interim or final targets, the department would be required to:
- pay half of any federal liabilities that may be imposed due to the payment error rate,
- submit a corrective action plan to the legislature that explains why the targets were not met and proposes timelines for corrective action, and
- implement a corrective plan.
HB 2206 also would have created a penalty for failing to implement a corrective plan, stating that administrative funding for the department would be reduced by 10% until a plan has been implemented. The bill also states that if the department lowers the error rate ahead of schedule, the legislature may allocate more funds to the department for program improvements.[20]
Governor Hobbs also vetoed Senate Bill 1334 on Feb. 20, which would have prohibiting state from applying for SNAP work requirement waivers.
Attorneys General Lawsuit regarding Noncitizen Eligibility Rules (2025)
On November 26, 2025, the District of Columbia and 21 states filed a lawsuit against the USDA, claiming that the agency released guidance that excludes certain noncitizens from SNAP eligibility that the OBBBA does not. The lawsuit also notes that the guidance document was released the day before the end of the hold harmless period for implementing these provisions. That means that incorrect applications of the OBBBA's noncitizen eligibility rules now count towards state error rates and may affect how much money the state may have to pay for SNAP benefits in 2028. The lawsuit states:[21][22]
| “ | USDA waited nearly four months before it issued implementing guidance to States on October 31, 2025, that directed them to limit eligibility for non-citizens, purporting to implement the changes made by the Act. But, the guidance in reality goes beyond the Act, arbitrarily excluding from SNAP many lawful permanent residents who remain eligible under the statutory scheme established by Congress. At the same time, USDA announced that on the very next day, November 1, 2025 (a Saturday), the period during which State payment errors are waived for the purpose of calculating their payment error rate would end, in violation of the agency’s own regulations that require a 120-day period in which those errors are excluded.[17] | ” |
The states and territories listed as plaintiffs include: New York, Oregon, California, Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, North Carolina, Rhode Island, Vermont, Washington, and Wisconsin.
On December 15, 2025, the U.S. District Judge in Oregon issued an injunction that required the USDA to extend the hold harmless period for the relevant provisions until April 9, 2026.[23]
Colorado Proposition MM (2025)
On November 4, 2025, Colorado voters approved Proposition MM, which proposed to reduce state income tax deductions and allocate the revenue to the Healthy School Meals for All Program (HSMA) and SNAP. The measure reduced state income tax deductions for taxpayers earning $300,000 or more from $12,000 to $1,000 for single filers and $16,000 to $2,000 for joint filers. This is expected to generate about $95 million in revenue for the Healthy School Meals for All Program (HSMA) and, once the program is funded with reserves, to provide funding for the Supplemental Nutrition Assistance Program (SNAP).
Lawsuit regarding ABAWD work requirement waivers (2025)
On October 30, eight cities and several other groups filed a lawsuit against the USDA regarding certain actions the agency took during the October 2025 government shutdown and after the enactment of the OBBBA. The lawsuit stated that the defendants took issue with USDA guidance regarding the ABAWD work requirement waivers that was released on October 3. The guidance announced that all waivers granted under the now-repealed insufficient jobs clause would be terminated by the agency on November 2. The defendants argued that, “USDA also prematurely terminated waivers of certain SNAP work requirements in states and areas with insufficient jobs, acting without any statutory authorization or consideration of the effects on people trying to keep up with those requirements.”[24][25]
On October 31, The District Court of Rhode Island granted a restraining order which, among other provisions, directed the USDA to temporarily stay the early termination of the ABAWD work requirement waivers that was scheduled to occur on November 2.[26][27]
The USDA later sent guidance to state agencies on February 26 announcing that, “Due to ongoing litigation and a order from the District Court of Rhode Island, the time limit waivers that were terminated will remain in effect through their original expiration date.” The original expiration dates for these 18 waivers can be found in the table below:[28]
In some states, such as Nevada, the USDA guidance was received after some ABAWDs had already lost benefits. The Nevada Registry reported that approximately 43,000 ABAWDs lost benefits on March 1. On March 3, the state reinstated SNAP benefits for these individuals and began backpaying benefits that were not issued on March 1. The state said it will allow ABAWDs to continue receiving benefits through April 30 in response to the USDA’s February 26 guidance.[29]
Arguments and reform proposals
As discourse has developed surrounding the implementation of the SNAP-related provisions of the OBBBA, Ballotpedia has been tracking relevant arguments and reform proposals.
Arguments are claims that are made in scholarly articles, state and federal legislative proposals, model legislative proposals, policy white papers, and other sources. These claims can be about what states, agencies, or other entities should do, about what sort of effects certain policies may or may not have, about the legality of certain decisions, etc. Reform proposals are concrete, proposed policy changes. An example of a reform proposal is Section 10105's implementation of the state cost-share system for SNAP.
So far, Ballotpedia has identified arguments related to the following sections:
- Section 10105: State cost-share system
So far, Ballotpedia has identified policy proposals related to the following sections:
- Section 10102: ABAWD work requirements
- Section 10105: State cost-share system
- Section 10108: Noncitizen eligibility
Beginning in 2028, states may be responsible for funding the cost of SNAP benefits in their state. Because the share of benefit costs a state may be responsible for funding is tied to states' payment error rates from 2025 and 2026, some states have begun seeking ways to lower their payment error rates. To learn more about what a payment error is, see above.
Some proposals to lower error rates include:
- Abolishing broad-based categorical eligibility (BBCE),
- Cross-checking application data more frequently or thoroughly, and
- Stopping the use of geographical waivers for able-bodied adults without dependents (ABAWDs).
Broad-based categorical eligibility
Broad-based categorical eligibility (BBCE) allows households receiving certain state-funded Temporary Assistance for Needy Families (TANF) benefits to qualify for SNAP without full asset testing, while still requiring them to meet SNAP income rules. In states with BBCE policies, families that do not qualify for SNAP through BBCE can still qualify for SNAP by meeting the income and asset requirements according to regular program rules. As of August 2025, 45 states had BBCE policies in effect.[30]
To qualify for SNAP under regular program rules, a household's gross income must be at or below 130% of the federal poverty line, their net income must be at or below the federal poverty line, and they must have less than $3,000 in assets if none of the household members are elderly or disabled or less than $4,500 in assets if someone in the household is elderly or disabled.[31]
Under BBCE, some households that exceed regular SNAP asset limits may still qualify depending on state policy. Payments to families that are eligible for SNAP through BBCE are not errors and do not count towards state error rates. The debate presented below is about whether these policies indirectly contribute to increased fraud and higher error rates or not.[30]
Claim: Broad-based categorical eligibility is a loophole that contributes to fraud in the SNAP program.
Critics of BBCE say that it is a loophole that contributes to fraud, abuse, and waste in the SNAP program. Paige Terryberry, writing for the Foundation for Government Accountability, said:[32]
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She further argued that eliminating BBCE, among other reform proposals, might lead to higher program integrity and therefore lower incidents of fraud and lower error rates:
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Claim: Broad-based categorical eligibility helps the truly needy receive assistance and there is a lack of evidence that it increases fraud.
Jou Chun Lin, writing for the National Taipei University's Department of Economics, argues that BBCE increases the number of eligible households receiving benefits and reduces administrative costs because caseworkers do not need to verify every applicant's income and assets. He argues that BBCE may increase participation among eligible households by simplifying the application process. He suggests that the more complicated application necessitated by regular program rules may be difficult for an individual under the stresses associated with poverty to complete. He writes:[33]
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He argues that while BBCE is known to increase the incidence of needy families receiving assistance, it is not necessarily known to increase the incidence of fraud:
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Cross-checking procedures
State agencies periodically check SNAP recipients' qualifications to determine if they are still eligible to receive benefits in a process known as recertification.
Claim: Reducing recertification periods can help states reduce their error rates.
Proponents of reducing recertification periods say that doing so would help states lower their error rates. Leslie Ford, writing for the Alliance for Opportunity, in her article What states can expect with the new SNAP match: Options to reduce state error rates, argued that longer certification periods contribute to increased fraud and higher error rates:[34]
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She further argued that states can lower their error rates by reducing their recertification periods.
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Ford also argued that states can reduce their error rates by other means such as cross-checking applicant income and deduction information against in-state or third-party data, eliminating broad-based categorical eligibility, and discontinuing the use of simplified reporting. Simplified reporting policies limit which interim changes recipients are required to report to state agencies.[35]
Claim: Recertification processes are imperfect and often deny eligible families benefits by mistake.
Others argue that modifying recertification processes are not the right way to reduce payment error rates. Jou Chun Lin, writing for the National Taipei University's Department of Economics, claimed that recertification processes are inefficient. He writes that:[33]
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The paper written by Homonoff, Rino, and Somerville for the American Economic Journal, which Lin cites in the quote above, argues that the recertification process is an imperfect screening device and that often recipients are denied benefits due to factors beyond just eligibility:[36]
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Simplified reporting policies
State agencies certify SNAP recipients periodically and require them to report certain changes in income and other circumstances between recertifications. When a household is certified or recertified, their eligibility is checked and their benefit amount is set, although agencies can change recipients' benefit amounts between recertifications if their income or circumstances change.[37] How reporting frequency and procedures affect the accuracy of SNAP benefit payments is the subject of some debate.
States are allowed to certify households in which all members are elderly or disabled for a maximum of 24 months and all other households for a maximum of 12 months. Some states certify households for four or six months. Agencies track recipient income because households with higher income receive less benefits than lower-income households and because households with a gross income above 130% of the Federal Poverty Level (FPL) are not eligible to receive any SNAP benefits.[37][38]
Under simplified reporting policies, households have minimal reporting requirements and agencies are not required to adjust households' benefit amounts as often. Households that are assigned simplified reporting are required to report to state agencies if their gross household income rises above 130% of the FPL, if able-bodied adults without dependents (ABAWDs) in the household are working less than 20 hours per week, or if the household receives significant lottery or gambling winnings.[38][37]
As of 2024, 28 states used only simplified reporting policies, 20 states used a combination of simplified reporting policies and other, stricter reporting policies, and two states did not use simplified reporting at all or were actively reviewing and considering changes to their reporting policies.[38] Simplified reporting has been associated with conflicting claims about its effect on SNAP payment error rates.
Claim: Simplified reporting procedures have contributed to increased error rates and states should end these practices.
Critics of simplified reporting argue that it has contributed, at least in part, to higher error rates. Leslie Ford, writing for the Alliance for Opportunity, argues that eligibility streamlining, which includes simplified reporting alongside other policies, has contributed to higher error rates in the SNAP program. She writes:[34]
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She then explains that simplified reporting was implemented to decrease administrative burden and costs and argues that the money saved by decreasing administrative costs is insignificant compared to the costs states will be subject to if they do not lower their error rates to below 6%:[34]
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Claim: Simplified reporting procedures have reduce error rates in the past.
A report about the effects of simplified reporting on food stamp payment accuracy, that was released by the USDA in October 2005, stated that the overall, simplified reporting had caused a decrease in payment error rates since the 2002 Farm Bill. The report states:[39]
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The report further states that if more states had adopted simplified reporting policies, error rates could have been even lower:[39]
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ABAWD time-limit waivers
Able-bodied adults without dependents (ABAWDs) who do not meet the SNAP work requirements can only receive benefits for three months in a 36-month period. After reaching this time limit, they lose eligibility for benefits unless they start meeting the work requirements.[11][40]
States may waive ABAWD time limits in areas with high unemployment. The OBBBA eliminated the prior option allowing waivers based on a lack of sufficient jobs.[41]
Claim: The OBBBA's waiver criteria change is good for recipients.
Supporters of limiting waiver usage argue that the OBBBA's tightening of the ABAWD waiver criteria is good for recipients. Angela Rachidi, writing for the Center on Opportunity and Social Mobility, argued that the decreased usage of waivers will encourage more individuals to work, reducing dependence on SNAP:[42]
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Claim: The OBBBA's waiver criteria change is bad for recipients.
Others argue that these waivers offer protection for recipients and that states should use discretionary exemptions to extend benefits to individuals subject to the time limit. Katie Bergh and Dottie Rosenbaum, writing for the Center on Budget and Policy Priorities, argue the OBBBA's waiver changes were negative and that states should step in to help:[43]
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Section 10102 of the OBBBA removed exemptions from the ABAWD work requirements for individuals who are currently homeless, veterans, 55 to 64 years of age, responsible for a dependent child who is older than 13 years of age, or 24 years of age or younger who were in foster care under the responsibility of a State on the date of attaining 18 years of age (or such higher age as the State has elected). The section added exemptions for individuals who are defined as Indian, Urban Indian, or Californian Indian by the Indian Health Care Improvement Act. This section also narrowed criteria for ABAWD work requirement waivers.
Alternative programs to assist individuals newly subject to the ABAWD work requirements
Connecticut Senate Bill 401 (2026)
This bill would require the Commissioner of Social Services in collaboration with several other state agencies to design a plan for a bridge program that would provide state-funded medical, food, housing, and employment assistance to what the bill defines as vulnerable persons. The bill defines vulnerable persons as, "veterans, homeless persons or persons at risk of homelessness, adults diagnosed with autism spectrum disorder, young adults aging out of the foster care system and persons age fifty- five to sixty-four who are at risk of losing benefits under the Medicaid and supplemental nutrition assistance programs and permanent supportive housing assistance due to changes in work requirements pursuant to P.L. 119-21 and proposed changes to United States Department of Housing and Urban Development regulations." This definition includes certain groups of people newly subject to the ABAWD work requirements under the OBBBA. As of March 24, 2026, this bill was still in its chamber of origin.[44]
Beginning in 2028, states may be responsible for funding the cost of SNAP benefits in their state. Because the share of benefit costs a state may be responsible for funding is tied to states' payment error rates from 2025 and 2026, some states have begun seeking ways to lower their payment error rates. To learn more about what a payment error is, see above.
Financial incentives for state departments
Arizona House Bill 2206 (2026)
On Feb. 20, 2026, Governor Katie Hobbs (D) vetoed House Bill 2206, which would have required the Arizona Department of Economic Security to lower the state's SNAP payment error rate to 3% or lower by December 30, 2030. The bill sought to lower the SNAP payment error rate to by creating financial incentives for the department. The bill states that if the department failed to meet interim or final targets, the department would be required to:
- pay half of any federal liabilities that may be imposed due to the payment error rate,
- submit a corrective action plan to the legislature that explains why the targets were not met and proposes timelines for corrective action, and
- implement a corrective plan.
HB 2206 also would have created a penalty for failing to implement a corrective plan, stating that administrative funding for the department would be reduced by 10% until a plan has been implemented. The bill also states that if the department lowers the error rate ahead of schedule, the legislature may allocate more funds to the department for program improvements.[45]
Governor Hobbs also vetoed Senate Bill 1334 on Feb. 20, which would have prohibiting state from applying for SNAP work requirement waivers.
Certain noncitizens who are lawfully present in the U.S. are eligible for SNAP benefits if they meet program requirements, such as Lawful Permanent Residents. Section 10108 redefined eligibility for certain lawfully present noncitizens.
Alternative programs to assist newly ineligible non-citizens
New Mexico state funded food assistance for non-citizens
The New Mexico Legislature appropriated $12 million in October 2025 to provide one-time benefit payments to non-citizens who lost their SNAP benefits after January 1, 2026 due to the non-citizen eligibility provisions of the OBBBA. The one-time lump-sum payments were a percentage of newly ineligible households' SNAP benefit payments. The New Mexico Health Care Authority stated that about 19,485 lawfully present non-citizens in the state were projected to lose benefits under the OBBBA.[46]
Full text and Congressional Research Service summary of SNAP provisions in the OBBBA
Full text of the SNAP provisions in the OBBBA
Below is the official text of Sections 10101 through 10108 of the One Big Beautiful Bill Act. These are the sections that made changes to the SNAP program.[47]
Congressional Research Service summary of the SNAP provisions in the OBBBA
Below is the text of the summary of Sections 10101 through 10108 of the One Big Beautiful Bill Act, as provided by the Congressional Research Service.
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Federal guidance documents
Below are the documents published by the USDA to provide state agencies with guidance regarding the implementation of the OBBBA's SNAP provisions. Each collapsible section contains the full memo text and a short summary.[48]
This memo provided the cost-of-living adjustments for the 2026 fiscal year. These changes were affected by the adjustments to the Thrifty Food Plan in Section 10101 of the OBBBA. The memo included attachments that detail income eligibility standards, maximum monthly allotments, minimum allotments, deductions, maximum asset limits, and the threshold for required reporting of changes in household income.[49]
Below is a list of key terms in the approximate order that they appear on the page. Each term is accompanied by a short definition and links to the most relevant section.
- Payment errors: Payment errors occur when SNAP benefits are issued incorrectly, either to an ineligible household, in the wrong amount, or based on misapplied eligibility rules.
- Error rates: Error rates are the percentage of incorrect payments a state makes and are determined through federally required quality control reviews on sampled cases.
- State cost-share: Beginning in FY2028, states will be required to pay a share of SNAP benefit costs if their error rate exceeds 6%.
- SNAP benefit costs: The costs of the SNAP program are divided into benefit costs and administrative costs. Benefit costs are the price of the money paid to recipients each month and make up the majority of the cost of the program.
- SNAP administrative costs: The costs of the SNAP program are divided into benefit costs and administrative costs. Administrative costs are the price of running the program, such as paying case workers and other SNAP employees.
- Thrifty food plan: The USDA produces food plans to demonstrate ways to eat a healthy diet across different cost brackets. The thrifty food plan is the lowest-cost food plan the USDA produces.
- SNAP-Ed: SNAP-Ed refers to the SNAP Nutrition Education and Obesity Prevention Grant Program, which was run by state and local agencies using federal money and was intended to promote healthy food choices and physical activity.
- ABAWD: Able-bodied adults without dependents.
- Work requirements: SNAP work requirements are work-related conditions that recipients must meet in order to maintain eligibility for the program. SNAP has two types of work requirements: general work requirements and ABAWD work requirements.
- General work requirements: General work requirements apply to most adult recipients, including ABAWDs. They require individuals aged 16 to 59 to register for work, participate in SNAP Employment and Training (E&T) programs, take a suitable job if it is offered, and not voluntarily quit a job or reduce work hours below 30 hours a week without cause once they are employed.
- ABAWD work requirements: ABAWD work requirements apply to ABAWDs in addition to the general work requirements. They require individuals to work, volunteer, or participate in a work program for 80 hours per month.
- ABAWD time limit: ABAWDs who do not meet the work requirement can only receive SNAP benefits for three months in a 36-month period. After reaching this time limit, they lose eligibility for benefits for the next three years.
- ABAWD time limit/work requirement waivers: States can request temporary waivers for the time limits associated with the ABAWD work requirements in places with an unemployment rate above 10%.
- SNAP eligibility rules: Individuals must meet certain requirements to be eligible for SNAP. These include things such as immigration status, income, and asset requirements.
- Heating and Cooling Standard Utility Allowance (HCSUA): State agencies make certain deductions from households' income when determining the amount of benefits recipients are eligible to receive. One type of deduction is a standard utility allowance (SUA). The HCSUA is a type of SUA for households with heating and cooling expenses.
- Hold harmless period: The time for which misapplications of certain OBBBA provisions would not have counted against states.
- Categorical eligibility: Individuals can be eligible for SNAP benefits on the basis of receiving certain other types of public assistance.
How does budget reconciliation work?
- See also: Budget reconciliation in U.S. Congress
Budget reconciliation is a legislative process that can be used to override the filibuster and expedite the approval of a package of legislation in Congress that changes spending, revenues, or the debt limit. Usually, a three-fifths majority (60 votes) is needed in the Senate to bring bills to a vote. Budget reconciliation bills require a simple majority (51 votes) instead of the three-fifths majority in the Senate because of the time limit on debate.
This section provides information about the budget reconciliation process, what can and cannot be included in a budget bill, and policy initiatives that have been passed through past budget bills.
What is the budget reconciliation process?
What can and cannot be included in a budget reconciliation bill?
Budget reconciliation can provide for changes in federal spending, federal revenue, the federal debt limit, or some combination of the three. Changes to social security through the reconciliation process are prohibited.
The restrictions on reconciliation are enforced through the Byrd Rule, through which senators claim provisions are extraneous and should be removed or excluded from the omnibus reconciliation bill. The Byrd Rule states that any provision that meets one of the following criteria can be excluded as extraneous through a point of order made by a senator and sustained by the presiding officer of the Senate (the Vice President):[59]
- it does not make any changes to spending or revenue or to the terms and conditions under which spending or revenues are accomplished;
- it does make changes to spending or revenue but not in compliance with the reconciliation instructions given to the committee in the budget resolution;
- it is not in the jurisdiction of the committee that submitted the provision;
- the changes in spending or revenue are merely incidental to the nonbudgetary policy changes of the provision;
- it increases the deficit for a fiscal year after the fiscal years (a 10-year window) covered by the specific budget resolution and reconciliation instructions; or
- it makes changes to Social Security.
The three most common reasons that points of order have been sustained and provisions removed as extraneous according to the Byrd Rule are:
- no change in outlays or revenues,
- budgetary changes merely incidental to non-budgetary components, and
- outside committee’s jurisdiction.
What are policy initiatives that have been passed through past budget bills?
Democrats used reconciliation to pass the Health Care and Education Reconciliation Act of 2010 -- including the final version of the Affordable Care Act (Obamacare) -- and the Inflation Reduction Act of 2022 -- including funding for environmental and climate-related policies and projects, increased corporate taxes, and the extension of Medicaid expansion.
Republicans used reconciliation in 2018 to pass the Tax Cuts and Jobs Act, including decreased individual income and corporate taxes and allowances for oil and gas drilling on certain federal land.
Democrats tried to enact gun control measures and increase the federal minimum wage to $15 per hour through reconciliation bills in 2015 and 2021, respectively, but Republican senators filed points of order against the amendments according to the Byrd Rule, and the provisions were removed.
Republicans proposed cutting certain Social Security, Medicare, or Medicaid benefits as part of a reconciliation bill in 2017, but Democrats filed points of order against the amendments according to the Byrd Rule, and the provisions were removed.
See also
- Work requirements policies in the 2025 budget reconciliation bill (One Big Beautiful Bill Act)
- Supplemental Nutrition Assistance Program work requirements
- Federalism-related policies in the 2025 budget reconciliation bill (One Big Beautiful Bill Act)
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 Congress.gov, "H.R.1 - One Big Beautiful Bill Act," accessed July 3, 2025
- ↑ usafacts.org, "How much does the federal government spend on SNAP every year?" accessed December 3, 2025
- ↑ The implementation of the state cost-share for benefits costs can be delayed for states with exceptionally high error rates.
- ↑ 4.0 4.1 U.S. Department of Agriculture Food and Nutrition Service, "SNAP Quality Control", accessed October 30, 2025
- ↑ Center on Budget and Policy Priorities, "SNAP Includes Extensive Payment Accuracy System," accessed December 12, 2025
- ↑ This includes data for Guam and the U.S. Virgin Islands
- ↑ 7.0 7.1 USDA Food and Nutrition Service, "USDA Food Plans," accessed December 12, 2025
- ↑ USDA Food and Nutrition Service, "Thrifty Food Plan, 2021," accessed December 12, 2025
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program Nutrition Education and Obesity Prevention Grant Program (SNAP-Ed) Questions and Answers"
- ↑ USDA Food and Nutrition Service, "About SNAP-Ed," accessed October 24, 2025
- ↑ 11.0 11.1 11.2 USDA, "SNAP Work Requirements," accessed May 16, 2023
- ↑ HHS, "SNAP ABAWD work requirements," accessed June 2, 2023
- ↑ Congress.gov, "H.R.1", July 1, 2025
- ↑ Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," July 4, 2025
- ↑ USDA Food and Nutrition Service, "ABAWD Waivers," accessed July 1, 2025
- ↑ New York State Attorney General, "Attorney General James Sues to Stop Trump Administration’s Attempt to Cut Off SNAP Benefits for Permanent Residents," November 26, 2025
- ↑ 17.00 17.01 17.02 17.03 17.04 17.05 17.06 17.07 17.08 17.09 17.10 17.11 17.12 17.13 17.14 17.15 17.16 17.17 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 18.0 18.1 18.2 18.3 18.4 USDA Food and Nutrition Service, "OBBB Implementation Memo SNAP Eligibility," October 31
- ↑ [https://fns-prod.azureedge.us/sites/default/files/resource-files/snap-updating-hcsua-summary-031023.pdf USDA Food and Nutrition Service, "Research Summary March 2023 Updating Standardized State Heating and Cooling Utility Allowance Values,"]
- ↑ Billtrack50, "AZ HB2206"
- ↑ New York State Attorney General, "new-york-et-al-v-brooke-rollins-united-states-department-of-agriculture-complaint-2025.pdf," November 26, 2025
- ↑ New York State Attorney General, "Attorney General James Sues to Stop Trump Administration’s Attempt to Cut Off SNAP Benefits for Permanent Residents," November 26, 2025
- ↑ reuters.com, "USDA must give states more time to implement new food aid restrictions, judge rules"
- ↑ democracyforward.org, "Press Release: Nationwide Coalition Sues to Protect Food Security for Millions as Trump-Vance Administration Refuses to Use Available Funds"
- ↑ democracyforward.org, "RI-Council-of-Churches-v.-Rollins-Complaint-with-attachments.pdf"
- ↑ democracyforward.org, "Press Release: Federal Court Blocks Trump-Vance Administration’s Attempt to Cut Off Food Assistance for 42 Million People in America"
- ↑ democracyforward.org, "3-TRO-w-mem-and-exhibits-1.pdf"
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program (SNAP) – Waiver of the Time Limit– Status Update"
- ↑ nevadaregisty.org, "Nevada Restores SNAP Benefits for Approximately 43,000 Individuals"
- ↑ 30.0 30.1 USDA Food and Nutrition Service, "Broad-Based Categorical Eligibility (BBCE)," accessed November 7, 2025
- ↑ cbpp.org, "A Quick Guide to SNAP Eligibility and Benefits," updated October 3, 2025
- ↑ FGA, "Food Stamp Program Integrity Measures Will Lower Costs For States and Preserve Resources for the Truly Needy," published October 3, 2025
- ↑ 33.0 33.1 papers.ssrn.com, "Designing Efficient Welfare Programs: Evidence from SNAP’s BBCE Expansion," posted October 27, 2025
- ↑ 34.0 34.1 34.2 Alliance for Opportunity, "What states can expect with the new SNAP match: Options to reduce state error rates," published October 20, 2025
- ↑ USDA Food and Nutrition Service, "The Effects of Simplified Reporting on Food Stamp Payment Accuracy," page updated December 4, 2024
- ↑ American Economic Journal: Economic Policy 13 (4): 271–98. "Program Recertification Costs: Evidence from SNAP." 2021
- ↑ 37.0 37.1 37.2 USDA.gov, "Simplified Reporting and Transitional Benefits in the Food Stamp Program--Chapter 1,"
- ↑ 38.0 38.1 38.2 USDA Food and Nutrition Service, "2024 State Options Report 16th Edition," June 2024
- ↑ 39.0 39.1 USDA Food and Nutrition Service, "THE EFFECT OF SIMPLIFIED REPORTING ON FOOD STAMP PAYMENT ACCURACY," October 2005
- ↑ HHS, "SNAP ABAWD work requirements," accessed June 2, 2023
- ↑ Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," July 4, 2025
- ↑ Center on Opportunity and Social MobilityCenter on Opportunity and Social Mobility, "Perspective on the OBBBA’s SNAP Cuts," published August 7, 2025
- ↑ Center on Budget and Policy Priorities, "Many Low-Income People Will Soon Begin to Lose Food Assistance Under Republican Megabill," published September 10, 2025
- ↑ billtrack50.com, "CT SB00401"
- ↑ Billtrack50, "AZ HB2206"
- ↑ New Mexico Health Care Authority, "New federal SNAP rules prompt state-funded food assistance"
- ↑ 47.0 47.1 Congress.gov, "H.R.1 - One Big Beautiful Bill Act"
- ↑ USDA Food and Nutrition Service, "FNS Documents & Resources," accessed October 23, 2025
- ↑ USDA Food and Nutrition Service, "SNAP Fiscal Year 2026 Cost-of-Living Adjustments"
- ↑ USDA Food and Nutrition Service, "About SNAP-Ed," accessed October 24, 2025
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program Nutrition Education and Obesity Prevention Grant Program (SNAP-Ed) Questions and Answers"
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program (SNAP) – Simplified Process for Fiscal Year 2026 Standard Utility Allowance (SUA) Values"
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program (SNAP) Implementation of the One Big Beautiful Bill Act of 2025 – Treatment of Energy Assistance Payments"
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program Provisions of the One Big Beautiful Bill Act of 2025 – Information Memorandum"
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program (SNAP) Provisions of the One Big Beautiful Bill Act of 2025 - ABAWD Exceptions - Implementation Memorandum," accessed October 8, 2025
- ↑ HHS, "SNAP ABAWD work requirements," accessed June 2, 2023
- ↑ Congress.gov, "H.R.1 - 119th Congress (2025 - 2026)," July 4, 2025
- ↑ USDA Food and Nutrition Service, "Supplemental Nutrition Assistance Program Provisions of the One Big Beautiful Bill Act of 2025 – ABAWD Waivers - Implementation Memorandum," accessed October 23, 2025
- ↑ Congressional Research Service, "The Budget Reconciliation Process: The Senate’s 'Byrd Rule.'" December 12, 2024
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