As the government reopens, efforts to return the Supplemental Nutrition Assistance Program (SNAP) to full funding across the country will face its own challenges.
SNAP benefits have been put through the ringer since expiring at the start of November, with back-to-back court rulings going all the way up to the Supreme Court alternately reinstating and then blocking full issuance of benefits.
Most recently, the Supreme Court allowed SNAP benefits to be paused, extending this until Thursday, with Justice Ketanji Brown Jackson publicly dissenting.
Before benefits expired, states’ preemptive actions varied, meaning full SNAP payments could take another week or more to reach people in some places.
Several states maintained full SNAP benefits by using emergency funds. Others offered partial benefits or directed funds to local food banks.
“States are, pun intended, literally all over the map with respect to how they are proceeding with respect to issuance of November SNAP benefits,” said Stewart Fried, principal attorney at OFW Law in Washington, D.C.
“Based on my review of state issuances, approximately 19 states have issued or are in the process of issuing full November benefits, and about 18 states have already issued partial benefits or they are still in the process of calculating them based on USDA guidance issued last week.”
Some states had no contingency plans in place by the time benefits expired. Fried estimates that for the remaining 13 states that have issued no SNAP benefits this month, it could take between a week and 10 days after the shutdown ends for payments to be fully issued.
But states that have issued partial benefits this month may run into more complications when the shutdown ends, as they will have to recalculate the remaining benefits for their beneficiaries. For some states, this could mean hiring third-party vendors to handle this administrative task, as many don’t have the necessary infrastructure to process the unprecedented disruption.
States that managed to maintain full benefits so far have run into roadblocks of their own.
“I can’t speak on behalf of states and legal cases, but I know the states who issued full benefits are actively working through some challenges, such as making sure they can increase their lines of credit so that retailers and processors continue to get paid and SNAP cards remain working,” said Chloe Green, assistant director of policy at the American Public Human Services Association (APHSA), which focuses on programs including SNAP and Temporary Assistance for Needy Families.
Green noted this disruption has crucial implications. Because of provisions in the One Big Beautiful Bill Act, states will have to begin paying for part of SNAP benefits beginning in 2028, with this percentage determined by payment error rates. Error rates hovered around 11 percent nationally in 2024.
“By issuing multiple benefits in a month, it messes with the system. It messes with the sampling methods for quality control,” she said.
“We’re really worried about spikes in this, in addition to states who are actively already trying to push through all these really significant policy changes from H.R. 1,” she added. “If every case you have in November is an error, you can’t even catch up in the rest of the year to lower your error rate. In addition to payment error rates, there’s also a big concern around timeliness. States also are measured for their application processing timeliness.”
Given the extraordinary circumstances surrounding SNAP, Green said it was the APHSA’s position that quality control reviews from October to December of this year should not be counted towards states’ error rates.
As beneficiaries dealt with reduced or absent SNAP payments this month, retailers have, in turn, seen the impact.
“A small number of beneficiaries still have SNAP benefits remaining on their EBT cards. However, most SNAP retailers, especially those in impoverished neighborhoods that have a large percentage of their customers who are receiving benefits, have seen a substantial reduction in sales activity as a result of November’s benefits not being issued,” said Fried, warning the longer benefits are delayed, the larger food deserts across the country could grow.
The National Grocers Association (NGA) had warned that disrupted SNAP benefits would reduce the number of hours grocery store employees work, lead to losses of perishable foods and a decline in sales.
“The disruption to SNAP benefits has presented operational challenges and confusion for many independent grocers who support their communities through their participation in SNAP. The NGA doesn’t track sales or revenue, but independent supermarket participation in this critical food access program differs from store-to-store and community-to-community, so any economic impacts will vary,” an NGA spokesperson said in a statement to The Hill.
For Fried, what has stood out to him is how this ordeal could have been avoided.
“During and prior to the litigation in Massachusetts and Rhode Island, the federal government, despite being in possession of appropriated SNAP funds for contingencies, took the position that those funds could not be used to pay November SNAP benefits,” he said. “Frankly, I cannot think of another circumstance that impacted more than 42 million Americans in need of nutrition assistance across the country.”
And he is not alone in this opinion. The Center on Budget and Policy Priorities contended soon after benefits lapsed that federal courts affirmed the Trump administration’s ability to send out full benefits by drawing funds from other food assistance programs.
The Trump administration maintained that court rulings telling it to tap contingency funds amounted to judicial overreach that was worth fighting against.
Green said she is concerned about inaccurate payments as a result of this disruption and hopes people are able to get 100 percent of the benefits for which they’re eligible.
“We still can’t say with 100 percent certainty that the bill will allow that everyone gets up to the 100 percent amount that they were eligible for this month, although we are hopeful that will be the interpretation,” she said.