The Health Divide: New SNAP work rules collide with shutdown crisis

The outlook for families who rely on SNAP is quickly getting worse

As counties and states scramble to meet a surprise Nov. 1 deadline for enforcing dramatically expanded work requirements for the Supplemental Nutrition Assistance Program, the federal government is threatening to halt food benefits altogether. 

The chaos, confusion and anxiety across the country are the result of two developments in Washington, D.C. The new work requirements are the first phase of the sweeping cuts to SNAP mandated by the Republican spending bill enacted in July. 

The administration told all states last week to stop distributing food benefits for now, citing the government shutdown. Nearly 42 million Americans, including 16 million children, depend on the aid to afford enough to eat.

All this began early this month. In a memo Oct. 3, the USDA gave states just weeks to implement the new work rules, which are projected to cut benefits to 4 million people over the next decade. The deadline left county and state administrators racing to comply. 

Ten days later, the agency delivered a potentially more devastating blow: If the federal shutdown continues, there won’t be enough funds in November to pay SNAP benefits. 

According to the Center on Budget and Policy Priorities, a SNAP contingency fund has most of the money to cover a month of benefits. But the USDA said last week it can’t use the funds during the shutdown and won’t reimburse states who opt to pay on their own.

“It’s terrifying for many households,” said Ed Bolen, director of SNAP State Strategies at the center. “They will be faced with really tough choices. Do they skip paying rent so they can buy groceries? Do they cut back on medication? Do parents decide to skip meals so they can feed their kids?”

At some point the federal government will reopen, and presumably, a painful SNAP shutdown will be temporary. But the massive changes to SNAP rules and operations in the GOP spending bill will hit low-income people hard for years to come.

The bill cuts federal spending for SNAP by $186 billion over the next 10 years. The new work rules kick off the changes, but the law did not specify a start date.

That was left to the USDA, which oversees SNAP and funds the food benefits. Counties in 10 states administer the program, while the job falls to state agencies in the rest of the country. They waited all summer for guidance on implementing the new requirements.

At a September congressional hearing, Joy Bivens, deputy county administrator for Health and Human Services in Franklin County, Ohio, testified that agencies need at least a year to train staff and ramp up systems to enforce the new work rules. Agencies — many of them short-staffed and strained financially — will have to verify and track whether millions of SNAP recipients are meeting the 80-hour-a-month work, volunteer or school requirements.

Her office alone will have to assess eligibility for 17,000 recipients who have been exempt from work requirements until now.

Research shows that work requirements don’t boost employment. But they cause lots of people to lose benefits, especially Black and Latino adults, who are cut from the program at far higher rates than white adults.

Before the new law, able-bodied adults ages 18 to 54 were already subject to SNAP work requirements unless they were pregnant, had children at home or fit into certain exempt categories. The GOP bill expands SNAP work requirements in two ways:

1. The end of many exemptions

For the first time, work requirements apply to adults through age 64 and parents with children ages 14 and up. The law eliminates exemptions for veterans, people experiencing homelessness, and young adults who have aged out of foster care — populations Congress previously agreed face too many struggles to saddle with work requirements and the onerous documentation they entail.

Many recipients in these categories already work or go to school. Now they’ll have to take time off, gather the right paperwork and bring it to an interview to prove it. If they don’t, they’ll be limited to receiving SNAP for only three months in a three-year period. 

Some people may qualify for work exemptions on grounds the law left intact — for example, a mental or physical condition that makes it impossible to hold a job. Nevertheless, the Congressional Budget Office estimates that 1.4 million people who are newly subject to work rules will lose SNAP in a typical month.

2. Strict rules on waiving work requirements

The law removes the flexibility states have had to waive the three-month limit on SNAP benefits in areas without enough jobs. About 20 states have such waivers. They were set to expire at different times over the coming year, but USDA is terminating them now. 

Going forward, waivers will be restricted to areas where unemployment is 10% or higher. Not many places will qualify in today’s labor market, Bolen said. As a result, about 1 million people in a given month will no longer be eligible for food assistance, CBO estimates.

Immigrants who fled violence and live here legally under federal humanitarian protection are losing SNAP eligibility altogether. This includes refugees, people who were granted asylum and survivors of sex trafficking. 

In the arcane rules governing SNAP operations, there are other big changes that will cause people to lose benefits. Journalists can find clear explanations here and here. 

One change worth highlighting is that, for the first time, the USDA will force states that make too many payment errors to pay 5% to 15% of the cost of SNAP benefits — costs the federal government now covers. If 2024 error rates are a guide, most states will get penalized. With an error rate of nearly 9%, for example, Montana would have to pay 10% of the cost of food assistance for the 77,000 state residents now getting it. 

States won’t be penalized for a few years, but the error rate this year will still count when the bill comes due. CBO projects that these additional costs will drive some states to cut SNAP benefits, restrict eligibility, or — ominously —“leave the program altogether.”

Preventing mistakes is laudable, but the formula for calculating the error rate is not. States are penalized for overpaying or underpaying recipients or when a person gets benefits for which they are no longer eligible. But when a state denies food assistance to someone who’s eligible, the government doesn’t factor it into the error rate. This creates a huge financial incentive for states to err on the side of rejecting people in need. 

“Even a well-intentioned state might be setting up systems that would have the result of making it harder to get benefits,” Bolen said. 

The cuts to SNAP — and the threat it will shut down — come as prices for food and other consumer goods continue to rise, in no small part due to inflation and President Trump’s tariffs. Inflation climbed 3% in September over a year earlier. Coffee prices in August were 21% higher than a year earlier, ground beef was up nearly 13%, many fruits, vegetables and cereals were more expensive, the Wall Street Journal reported.

And perhaps it’s no coincidence that just as the SNAP cuts take effect, the administration is canceling the USDA’s annual Household Food Security Report. It’s a vital source of information on how low-income people nationwide struggle to put food on the table — and it would have been a great tool for measuring the impact of the unprecedented food policy changes we’re witnessing.

More than ever, we need journalists to track the fallout of these policies. Are more children and families hungry? How are food banks and other community programs coping? Is the employment rate improving? Who is hardest hit