The Department of Agriculture (USDA) has begun publishing guidance outlining how states must begin implementing some of the deepest SNAP cuts from the Republican megabill enacted in July.[1] While there are still many unanswered questions, some low-income families will see their food assistance terminated or cut substantially (or will be denied benefits) this fall, though most current participants will face cuts when their SNAP eligibility is next recertified. States recertify eligibility for most SNAP households every six or 12 months.
Approximately 4 million people in a typical month will lose some or all of their SNAP food benefits once the changes are fully implemented, based on Congressional Budget Office (CBO) estimates.[2] They include families with children, older adults, people with disabilities, and veterans. Implementation decisions by both the federal and state governments could mitigate some harm from the law’s cuts or make them worse. A complicating factor in implementation is that the megabill does not include effective dates or implementation dates for its major provisions restricting SNAP eligibility and benefits, a departure from Congress’s usual practice.
The megabill dramatically expands SNAP’s harsh and ineffective[3] work requirement in two ways.
Applying the work requirement to additional, vulnerable populations. The law applies the work requirement to older adults aged 55 through 64 and parents with children aged 14 and older for the first time. It also removes exemptions for veterans, people experiencing homelessness, and young people who recently aged out of foster care; these exemptions were added in bipartisan legislation in 2023.
Unless they can document 20 hours per week of work or participation in a narrow set of work activities or prove they qualify for an exemption, these individuals now can only receive SNAP for three months in a three-year period.[4] CBO estimates that about 1.4 million of the people newly subject to the time limit will be cut off SNAP in a typical month when it is fully in effect. When these adults are cut off SNAP, benefits will be reduced significantly for their remaining household members, including children in school. We estimate that about half a million additional people will experience a benefit cut as a result, including children, people with disabilities, and older adults.
States must begin tracking this three-month time limit for people newly subject to this requirement when they are approved or recertified for benefits. The USDA guidance is not detailed, but this apparently means that people who apply or are recertified beginning in September 2025 will exhaust their three months of SNAP benefits as soon as January 1 and states will, at that time, begin cutting people off SNAP who cannot document that they qualify for an exemption or are meeting the 20-hoursper-week work requirement.[5]
The guidance appropriately reminds states that they must robustly screen individuals to determine whether they qualify for an exemption from this requirement. For example, many of the older adults who are now at risk of losing SNAP have work-limiting health conditions that should qualify for an exemption even if they are not receiving disability benefits. In addition, the megabill added new exemptions for American Indian and Alaska Native individuals who meet certain definitions under the Indian Health Care Improvement Act. Without effective screening many eligible households will lose benefits.
Participants who are found not to be exempt will have to report their work hours and states will have to track compliance for people who are subject to the 20-hour-per-week rule. States also will have to accurately calculate lower benefits for other household members who remain eligible when adults get cut off SNAP.
Dramatically limiting waivers for areas with elevated unemployment. The megabill also substantially curtails states’ ability to temporarily waive the three-month time limit in areas with insufficient jobs based on local labor market conditions. As of September 1, 2025, 20 states had previously approved waivers for certain areas of the state, and California, Illinois, Nevada, the District of Columbia, Guam, and the Virgin Islands had waivers for the entire state.[6] But under the megabill, only areas with an unemployment rate above 10 percent will be eligible for a waiver, which means very few areas will continue to qualify. As a result, many more people will be subject to the three-month time limit and cut off SNAP, especially if they live in an area with few job opportunities or if the national economy weakens.
The law is unclear on when people who live in areas with elevated unemployment will lose food assistance because these waivers expire at different times over the next year. USDA’s new guidance says only that the Administration will follow up with the states with waivers currently in effect, making it difficult for the public to understand the implementation timeline.
CBO estimates that roughly 1 million people who would have been protected by a waiver under the prior criteria will be cut off SNAP in a typical month.
It will be important for states to maximize their use of discretionary exemptions to extend benefits for individuals subject to the time limit, particularly those who face barriers in securing steady employment.[7]
The megabill ends SNAP eligibility for many immigrants who are living lawfully in the U.S. and have been granted humanitarian protection by the federal government, including refugees, people granted asylum, and certain survivors of domestic violence and sex trafficking. Only U.S. citizens, lawful permanent residents (after a five-year waiting period, if applicable), people granted Cuban or Haitian entrant status, or people residing in the United States under a Compact of Free Association will remain eligible for SNAP. (People who lack documentation were already ineligible for SNAP before the megabill was enacted.) CBO estimates that about 90,000 people will lose SNAP in a typical month as a result.
USDA has provided no information about how this requirement will be implemented. To prevent eligible low-income people from losing vital food assistance, it will be critical for states to thoroughly assess whether people who held a now-ineligible status at the time they applied for SNAP have subsequently adjusted to a status that means they remain eligible. USDA guidance needs to ensure that states do a thorough job of evaluating ongoing eligibility before any benefits are terminated.
The megabill significantly limits a long-standing SNAP simplification allowing households who receive payments over $20 from the Low Income Home Energy Assistance Program (LIHEAP) or other energy assistance to automatically qualify for SNAP’s Standard Utility Allowance (SUA). Qualifying for an SUA can increase the SNAP allotment a household receives, reflecting that resources spent on utility costs are not available to the household to purchase food. The SUA is far easier for families and states to administer than verifying actual utility expenses, which can include bills for multiple utilities that vary across the year.
Under the USDA guidance, starting immediately only applicant households with an elderly or disabled member can qualify for the SUA based on their receipt of this energy assistance. States must require all other currently participating households whose SUA is based on the receipt of energy assistance to provide documentation of their utility costs to the state no later than the next time they renew their benefits, at which time the state will reassess whether the household still qualifies for an SUA.
It will be essential for states to explain to impacted households that they will need to provide this documentation. Households who do not know or struggle to produce it will see their SNAP benefits cut or, in some cases, lose eligibility entirely. CBO estimates that about 600,000 households will lose roughly $100 per month on average due to this provision.
The guidance does not provide details about the megabill’s unprecedented structural change to SNAP, which will slash federal funding and require many states to pay a portion of food benefit costs for the first time based on their payment error rates under SNAP’s Quality Control system.[8] Most states will have to pay between 5 and 15 percent of benefit costs, a substantial sum.
If a state can’t make up for these massive federal cuts with tax increases or spending cuts elsewhere in its budget, it will have to cut its SNAP program (such as by restricting eligibility or making it harder for people to enroll, but states have limited flexibility to reduce SNAP spending), or it could opt out of the program altogether, terminating food assistance entirely in the state.
CBO estimates that state responses to this unfunded mandate will result in about 300,000 people having their SNAP benefits reduced or terminated in a typical month. However, the impact could be far greater if states cut more deeply than anticipated, or smaller if all states pay the state share and don’t take steps to cut SNAP enrollment or benefits to reduce state costs.[9]
While this requirement does not begin until October 1, 2027, it will have an immediate impact on program administration. That’s because the percentage of food benefits a state must pay in the first year the requirement is in effect will be based on a state’s SNAP payment error rate for fiscal year 2025 (which ends at the end of this month) or 2026 (which begins in October), whichever is lower. This means that states will be penalized based on mistakes they either have already made or will make in the coming months as they implement the complex, administratively burdensome new policies described above.
SNAP rules hold states harmless for errors stemming from changes in law or regulation during a 120-day grace period. The USDA guidance provides that for the megabill’s energy assistance provision, this grace period started when the bill was enacted on July 4, 2025. The same is likely true for the megabill’s other provisions, though the guidance is not clear on that. If so, states must be implementing these new policies immediately — and will be held liable for any resulting errors after November 1, 2025.
However, USDA failed to provide guidance on how states must implement these changes until half of the grace period had already elapsed, dramatically increasing the likelihood that a state’s error rate will be high enough to subject the state to the higher cost-share requirement starting October 2027. To the extent that states feel pressure to implement the changes more quickly out of concern about the potential impact of the changes on their error rates, there is a risk that more eligible people will be cut from SNAP. States face no penalty for inappropriately cutting off eligible low-income people.
USDA must also provide additional clarity on how the new cost-share requirement will be operationalized — for example, how (and how often) states will have to prove that they have met the required match — so that states have as much time as possible to plan and budget for these significant new costs.
