The Trump Administration Can and Should Take Available Steps to Ensure SNAP Participants Get November Food Benefits

Updated October 21, 2025

Agriculture Secretary Brooke Rollins has indicated, and media have reported, that the U.S. Department of Agriculture (USDA) will run out of funding for SNAP food assistance for November as a result of the government shutdown. This would leave more than 40 million low-income people, about 1 in 8 people in the U.S., without the food assistance they need, including about 16 million children, 8 million older adults, and 4 million people with disabilities. But nearly two-thirds of the funds needed for a full month of benefits are available in SNAP’s contingency fund and must be used when regular funding for SNAP runs short. The Administration must release those funds immediately as SNAP law requires, to ensure that families can put food on the table next month.

Moreover, the Administration should use the discretionary authority it used to transfer funds into WIC earlier this month, or any other available legal authority to augment the SNAP contingency funding to, fund the full amount of November SNAP benefits.

To ensure that families have food assistance benefits to use at the beginning of November, the Administration must act quickly.

In more detail:

By law, individuals and families who meet SNAP’s eligibility requirements are entitled to benefits. Despite this requirement, historically Congress has provided SNAP funding through the annual appropriations process. (This approach treats SNAP as what is known as an “appropriated entitlement.” Under some legal interpretations, SNAP may have a permanent appropriation under the Food and Nutrition Act that would fund the program during lapses in appropriations. Our analysis here focuses on the Administration’s obligations if it continues to treat SNAP as an appropriated entitlement, as it has to date.) 

Currently, there is no full-year appropriation in an appropriation bill for SNAP benefits in fiscal year 2026. USDA’s September 30, 2025 “Lapse of Funding Plan” explained that SNAP’s October benefits were funded in September, out of fiscal year 2025 appropriations. It further explained that “multi-year contingency funds are also available to fund participant benefits in the event that a lapse occurs in the middle of the fiscal year.”

These “multi-year contingency funds” are $3 billion a year that the 2024 and 2025 appropriations laws each made available for SNAP, and which are still available in fiscal year 2026. The law provides that these amounts “shall be placed in reserve for use only in such amounts and at such times as may become necessary to carry out program operations.” Under USDA’s shutdown plan, some of these contingency funds are being used to reimburse states for the federal share of their administrative expenses (50 percent in fiscal year 2026) during the shutdown, so the full $6 billion is not likely to be available for November benefits. But the federal share of state administrative expenses is less than $500 million dollars monthly, so even after those costs are paid for October and November, more than $5 billion should remain for SNAP benefits. This is a substantial share of the approximately $8 billion needed for a full month of benefits.

USDA sent a memorandum to states on October 10 acknowledging that “if the current lapse in appropriations continues, there will be insufficient funds to pay full November SNAP benefits.” (Italics added.) The agency also instructed states to hold their November issuance files, the data file that states typically would send to their Electronic Benefit Transfer (EBT) card processors in the latter half of October that lists how much each household authorized to receive SNAP in November in that state should be issued. USDA added that they would keep states “apprised with information,” suggesting that it understood that contingency funds are available for benefit costs in November. 

But no further information has been provided. At a minimum, USDA should be using contingency funds to provide partial benefits to eligible households for November.  

Moreover, the Secretary of Agriculture has discretion under the law (7 U.S.C. § 2257) to transfer funds among USDA’s nutrition programs, with certain limitations. This is the authority USDA used to transfer $300 million to WIC earlier this month from the Child Nutrition budget account (which funds school meal programs) to prevent disruption in WIC. The Child Nutrition account has carry-over funds available from 2025 appropriations and, according to USDA’s shutdown plan and Office of Management and Budget apportionment documents, more than $23 billion in transferred appropriations from another USDA account known as “Section 32.” Permanent law (i.e., no annual appropriation required) provides that 30 percent of prior year’s custom duties are deposited into Section 32, a substantial portion of which is transferred to Child Nutrition each year.

USDA should use its discretion to transfer whatever amount possible to augment the SNAP contingency funding using the same mechanism as it used for WIC, or any other available legal authority.

Finally, USDA should make clear to states that they should continue to accept and process SNAP applications during the shutdown, as SNAP regulations require. The amount of benefits SNAP households receive for the month they apply is based on the date they apply. So, any failure to accept applications will result in a cut to low-income households’ benefits when the funding lapse ends. Having states poised to quickly approve benefits at that time would avoid a substantial backlog for state staff.