States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges
 In July, Department of Health and Human Services (HHS) Secretary Xavier Becerra renewed the federal public health emergency (PHE) through mid-October. Recognizing the significant changes that will need to happen at the end of the PHE and the need for adequate time to prepare, HHS has promised states that it will provide 60 days’ notice before ending the PHE.
 A state in which the governor or a state agency (such as the health department) has declared a public health emergency is eligible to issue emergency allotments. States may issue allotments for one additional month following the last month the emergency declaration is in effect. As of August 2022, 16 states (Arizona, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kentucky, Mississippi, Missouri, Montana, Nebraska, North Dakota, South Dakota, Tennessee, and Wyoming) had stopped issuing allotments. Other states may also cease issuing these allotments in coming months.
 Puerto Rico, the Commonwealth of the Northern Mariana Islands, and American Samoa, which receive nutrition block grants instead of SNAP, were not originally included in P-EBT and could not issue those benefits for the 2019-2020 school year; the October 2020 government funding bill extended eligibility to them. Guam and United States Virgin Islands do participate in SNAP and have had the same eligibility as states.
 P-EBT benefits can be issued to eligible school-aged children to cover a period "in any school year in which there is a public health emergency designation" or "in a covered summer period following a school session," which means that P-EBT benefits for school-aged children could extend for some period beyond the end of the public health emergency. However, P-EBT benefits for eligible children under age 6 can only be issued for periods "during a public health emergency." See Section 1101(a) and (h) of the Families First Coronavirus Response Act (7 U.S.C. 2011 note; Public Law 116-127).
 All states except North Dakota have been approved to provide summer 2021 P-EBT benefits, but Mississippi and Idaho were only approved to provide those benefits to school-aged children.
 For a brief summary of many of these waivers, all of which can be found at the Food and Nutrition Service, see “SNAP: COVID-19 Waivers by State,” https://www.fns.usda.gov/disaster/pandemic/covid-19/snap-waivers-flexibilities. USDA has allowed state agencies to extend these through month after the month in which the federal public health emergency ends as well.
USDA originally allowed 25 state agencies to temporarily stop pursuing certain claims and not consider related payments delinquent. (When SNAP households receive more benefits than they are eligible for — for example, because the SNAP eligibility worker made a mistake, or the household misunderstood the rules or provided incorrect information by mistake or intentionally — SNAP state agencies must collect the amount overpaid, unless pursuing the claim is not cost effective.) All of these states had these waivers extended through June 2020, and some 13 states received July 2020 extensions, with smaller numbers approved for extensions past July 2020, including at least four states extending through December 2021. USDA also approved one state (California) for an extension on submitting data to USDA on claims collection. In November 2021, USDA provided options for states facing challenges in administering claims due to the pandemic; several states have been approved to adjust their overpayment policies.
At least 23 states were approved for waivers to extend the timeframe to complete fair hearings, which states are required to provide for SNAP participants to appeal a state decision that affects their participation, such as denying or terminating benefits; these hearings are an important tool for clients to exercise their rights. All of these states had these waivers extended through June 2020 and fewer states were extended through subsequent months, including at least eight states with extensions through December 2021. These waivers have now expired.
At least four states have received waivers to extend the timeline for administrative disqualification hearings, which states must provide to determine that an individual has committed an intentional violation of program rules (such as making a false statement). Fewer states were approved past June 2020.
USDA approved several state waivers to temporarily suspend use of the Income and Eligibility Verification System, a database in which states ordinarily must verify certain income and other information in spring 2020.
Three states received approval to extend the period of time granted to households that have attempted to but are unable to provide a Social Security number, and USDA approved some states to continue to extend these waivers through December 2021. As of August 2022, four states are still operating under this waiver.
At least two states received approval in spring 2020 to delay notices that states must issue to households with multiple EBT card replacement requests.
Three states received waivers to allow certain community partners that assist SNAP applicants with the application process to sign the application on the client’s behalf after obtaining consent to serve as the client’s authorized representative. USDA has continued to approve extensions of these waivers for some states.
At least four states were approved to suspend in-person collection of applications and verification documents. Some of those states had extensions up through December 2021.
At least two states were approved to streamline the process to determine whether individuals are unable to meet certain work requirements. (Though Families First suspended the time limit nationwide, states that receive funding to offer a slot in a work or training program to individuals subject to the time limit can still apply the time limit to those individuals unless they have “good cause” for not meeting the requirements. Similarly, states can determine whether an individual has good cause not to comply with more general SNAP work requirements for which they could otherwise be sanctioned. One of the waivers streamlines the process to determine whether individuals subject to the time limit who are offered slots in training programs have good cause. The other streamlines this good-cause determination for individuals subject to SNAP’s general work requirements.)
 Beginning in August 2020, USDA limited approvals of many waivers that modified SNAP procedures and began approving states for narrow versions of these waivers, though these waivers were replaced by the more flexible options included in the October 2020 government funding law. USDA approved waivers for states, called either “core verification and interview adjustment” or “periodic report flexibility for non-extended recertification cases” waivers, that give states more flexibility to streamline the renewal process for households that are due to renew in coming months, such as limiting the number of households required to complete an interview at recertification. These waivers are not shown in the tables.
 The October 2020 government funding law suspended these reviews from June 2020 through September 30, 2021; the December 2020 COVID-19 relief package moved up the end of this flexibility to June 30, 2021.