States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges
Since March 2020, states have been using temporary SNAP (food stamp) flexibility to provide emergency benefit supplements, maintain benefits to households with children missing school meals, and ease program administration during the pandemic. These options have allowed states to deliver more food assistance to struggling families, help manage intense administrative demands, and ensure that participants maintain much-needed benefits.
How to Find Out if You Can Get Help from SNAP
If you would like help from SNAP, contact your local human services office. The staff there will work with you to find out if you qualify. You may also find information and referrals by dialing 211 in most states.
- Find the phone number for your state’s office
- Find your state’s SNAP website
- Find a local food bank if you need food immediately
Notes: SNAP is often referred to by its former name, the Food Stamp Program. Your state may use a different name.
SNAP has special rules following natural disasters.
The far-reaching health and economic effects of COVID-19 and widespread business closures to limit its spread have made it even more difficult for many low-income households to afford food and other needs. Data have shown a sharp increase in the number of families reporting difficulty affording adequate food and other basic needs compared to pre-pandemic times, which have remained high throughout the pandemic. SNAP is essential to helping these families put food on the table.
The Families First Coronavirus Response Act gave the Agriculture Department (USDA) authority to let states temporarily modify procedures to make it easier for families to continue participating in or apply for SNAP. And it temporarily suspended, nationwide, SNAP’s three-month time limit on benefits for unemployed adults under age 50 without children in their home. In addition to provisions in the law, USDA has encouraged states to use existing program flexibility. The law also included a temporary boost of emergency supplementary benefits and school meal replacement benefits. The government funding law enacted in October 2020 extended most of these options to modify administrative procedures and allowed states to use these options without waiting for USDA approval. Many states used these for the remainder of 2020 and will likely continue using them during the first half of 2021. The Families First Act also included several benefit enhancements, which have been extended and strengthened by subsequent legislation and administrative action from the Biden Administration.
Benefit Enhancements Still in Effect, Mostly Created By Families First
The Families First benefit enhancements that states are using include options to:
- Increase benefits to meet immediate rising need. Families First provided two ways for states to raise benefits for many SNAP participants and other households experiencing falling income and rising food needs.
Emergency allotment: States can give many SNAP households emergency supplementary benefits to bring a household up to the maximum benefit a household can receive; all states have used this option. SNAP benefits are determined based on a formula that estimates how much income families have available to buy food; SNAP benefits make up the difference between this amount and the maximum benefit, which is based on a USDA estimate of the cost of a nutritionally adequate diet at minimal cost. For example, in 2019, a family of three could receive a maximum benefit of $505 if the state determined they had no income available to purchase food, but the average benefit for a household of three was an estimated $365. About 60 percent of SNAP households ordinarily receive less than the maximum benefit because they have some income available to buy food under benefit calculation rules. In jurisdictions with the emergency allotment in effect, such households get the maximum benefit. (Unfortunately, under the Trump Administration, USDA’s interpretation excluded the lowest-income 40 percent of SNAP households, which already receive the maximum benefit. The Biden Administration recently directed the Agriculture Department to consider extending allotments to those households. The timing of any changes or the amount that households would receive under revised allotments is unclear.)
USDA may approve states to provide these benefits as long as the federal government has declared a public health emergency and the state has issued an emergency or disaster declaration. (The Biden Administration recently announced that the federal public health emergency will likely remain in place for the rest of 2021.) States have been providing these allotments since March. (States may actually issue these allotments in the next month, as many states began issuing March 2020 allotments in April. Many states are approved later in the month for these allotments.) Figure 1 below shows the months for which these allotments have been approved to date.
In addition to these allotments, the COVID-19 relief package enacted in December 2020 also included a 15 percent increase in SNAP’s maximum benefit for January through June 2021. This increase — which applies in all states and territories participating in SNAP and benefits all SNAP households, including those not helped by the emergency allotments —amounts to about $28 more SNAP benefits per person per month, or just over $100 per month in food assistance for a family of four. The American Rescue Plan Act, enacted in March 2021, extends this increase through September. (The Act also includes other food assistance provisions, such as resources for state administration of SNAP.)
P-EBT: Families First allowed states to submit requests to provide meal replacement benefits through SNAP, known as P-EBT, for households with children who attended a school that was closed in the spring of 2020 for at least five days and who otherwise would have received free or reduced-price meals. All states (except for Guam) selected the option and issued these benefits by mid-summer to replace meals lost during the 2019-2020 school year. Families First allowed states to provide these benefits through fiscal year 2020 (which ended September 30, 2020), and 20 states chose to extend benefits through August and September under this law.
The October government funding law extended and expanded P-EBT, and the December COVID-19 relief package included further flexibilities, clarified in recent guidance from the Biden Administration. The October law extended the program through September 2021, allowed schools to provide benefits to children when schools are operating with a mix of virtual and in-person classes, extended the program to certain low-income young children receiving SNAP benefits, and expanded the program to territories such as Puerto Rico that the program originally excluded. The law also provided for full federal reimbursement of administrative costs (states and the federal government previously shared these costs). This funding is especially significant given that many states are facing budget shortfalls due to revenue reductions in the pandemic and may face funding challenges to continue the program. The December COVID-19 relief package included further simplifications to allow states to deliver P-EBT more easily in light of complicated circumstances, such as varied and changing school schedules, and to issue benefits to children under age 6 more easily. The Biden Administration also took action recently to increase benefits offered through this program, and encouraged states to apply those increases retroactively. The American Rescue Plan Act allows states to continue their P-EBT program during the summer and through the remainder of the public health emergency for children who are missing out on school meals because of the pandemic.
USDA’s late January guidance supersedes earlier guidance on state plans to provide benefits to school-age children for the 2020-2021 school year, incorporates further simplifications and the benefit increase, and provides the first guidance on state plans to provide benefits to children under 6. Over 20 states and Puerto Rico have received approval and have begun (or will soon begin) issuing benefits for the 2020-2021 school year, including some that have been approved to issue benefits for young children. With the recent guidance simplifying administration for states, all states should now act to provide these benefits.
Table 1 shows the states that adopted P-EBT for the 2019-2020 school year, for August and September 2020, and for the 2020-2021 school year (which may include benefits for August and September if the state did not originally opt to extend for those months). P-EBT benefits may be issued retroactively once states are approved. We will update Table 1 as more states are approved. P-EBT doesn’t require a state public health or emergency declaration, but it does require a national public health emergency declaration.
For more detail on states’ implementation of P-EBT for spring 2020 benefits, see “CBPP/FRAC P-EBT Documentation Project Shows How States Implemented a New Program to Provide Food Benefits to Up to 30 Million Low-Income School Children.”
While not through the Families First Act, beginning in the spring and during subsequent months USDA also expanded access to a key flexibility:
- Pilot an online purchasing program. The 2014 farm bill created a pilot program for states to test the feasibility and outcomes resulting from allowing retailers to accept SNAP benefits for online food purchases. In 2019, New York became the first state to launch a pilot, joined by Washington State in January 2020 and three other states in early March 2020 (Alabama, Iowa, and Oregon). Since the crisis has hit, more states have been approved for expedited online purchasing pilots, and now most states have such a program, shown in Table 1. Online purchasing is limited to state-approved retailers, which in all states include Walmart and/or Amazon and in 30 states includes ALDI, as well as others, including ShopRite in Connecticut, Delaware, Maryland, New Jersey, New York, and Pennsylvania and FreshGrocer in New Jersey and Pennsylvania. This waiver allows individuals receiving SNAP benefits to get the food they require while adhering to social distancing rules. Because these programs are independent of the Families First Act, they are not subject to the same emergency declaration requirements.
Families First Act Operations Waivers (Largely Spring and Summer 2020)
USDA also approved several waivers that Families First allows for states to temporarily adjust their operations to help manage their workloads and help participants gain and maintain access to the program. States are no longer using most of these options, as the October government funding law provided states with more flexibility to implement similar provisions:
- Extend certification periods and adjust reporting requirements. SNAP participants get approved to receive benefits for a certain period of time, called a “certification period.” Every month a portion of SNAP participants ordinarily must submit paperwork and complete an interview to continue receiving benefits when the certification period ends; this is called the recertification process. Participants must also update or report certain changes in their circumstances at different intervals, depending on the state. As Table 2 shows, the vast majority of states waived these requirements or extended deadlines for several months to preserve participants’ benefits and to streamline administrative work and help deal with rising applications at a time of reduced capacity. States were originally approved for these waivers through May, and most states requested and received extensions of this waiver through June. After originally denying most requests, USDA then approved waivers through August and September for a limited number of states, and approved limited modifications to reporting requirements for households that are renewing benefits. The October law allowed states to return to the more extensive options originally offered (described below), and with greater flexibility, as states no longer had to request waivers from USDA. Table 2 shows states’ last waiver extension under Families First, generally through June 2020, or the option to extend under the October law, through June 2021.
- Adapt telephonic signature requirements. Before the crisis, many states had implemented technology to let households apply for SNAP by phone, including using a stored telephonic signature. Current regulations require states to record verbal assent in an audio file to ensure that there is a record of applicants understanding and agreeing to information gathered and used by the state worker. The waiver allows states to take SNAP applications by phone by allowing a state eligibility worker to document the household’s attestation to the collected information on the client’s behalf without requiring a recorded signature. This temporary step has helped states process applications in the current environment, where offices are closed and not all clients can access online applications. USDA has continued to allow states to extend this waiver, as shown in Table 2.
Waive other requirements, such as the application interview, to better manage new applications. In addition to taking steps to ensure participants can continue getting benefits, states have requested waivers to accommodate what in many states has been a dramatic rise in new applications. As many families have struggled with hardship, states saw large SNAP application increases in the spring. Nationally, the number of SNAP participants rose from about 37 million participants in February 2020 to about 43 million participants in May, and this number has stayed steady through September. State SNAP agencies have had to manage this rising volume at a time of office closures, staffing shortages, and potential difficulties with a remote work environment.
Over 40 states took up USDA’s temporary nationwide waiver of the interview at the application or recertification stage in order to ensure that newly eligible households can access food assistance through SNAP and others can stay on, shown in Table 2. SNAP rules require all households to be interviewed either in person or over the telephone, by a state eligibility worker at initial application and usually at least once a year thereafter. This requirement can be an important way for states to gather accurate information and for applicants to have their questions answered, but in the current environment it can be a labor-intensive task that can delay approval. USDA allowed states to dispense with the interview temporarily for many households, originally at both initial application (as long as households provide mandatory verifications, such as of income) and recertification.
As with the waivers to extend certification periods, USDA originally allowed extensions up through June 2020, and for July and August for some states meeting certain requirements and limited versions for others. USDA had indicated it would largely approve very limited versions of these waivers beginning in September 2020, described below. The October government funding law, however, allowed states to implement the original versions of the waiver that USDA approved for all states in March through June 2021 without requesting USDA approval. Given this increased flexibility, states have been using those options instead of requesting the more limited waivers. Table 2 shows the states extending this flexibility under the most recent option, either through the Families First Act (through June or in some cases August) or the October law (through June 2021).
Narrow USDA-Approved Waivers Under Families First (Largely Haven’t Been Used Since Fall 2020)
Beginning in August, USDA limited approvals of many waivers that modified SNAP procedures and began approving states for narrow versions of these waivers, though these waivers are now replaced by the more flexible options included in the October 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.
Restored Flexibility Under October Government Funding Law (Currently in Effect)
The government funding law enacted October 1 restored the more expansive versions of the following options and allowed states to implement them without USDA approval. Given that the public health and economic consequences of COVID-19 have continued and will likely continue for many months, states will continue to need flexibility to modify processes to effectively manage their caseload. Because these options provide more flexibility to states for the same procedures than the narrower options USDA had been approving, states have been using these options instead of the earlier waivers (both the original Families First Act waivers, approved in the spring, and the narrower waivers USDA approved beginning in August).
These options, shown in Table 2, allow states to:
Continue extending certification periods for households for up to six months for periods expiring up until June 30, 2021 and modify requirements for households to report changes in their circumstances. This option is consistent with guidance issued in April, which is more expansive than the limited modifications USDA had been approving for fall 2020.
Use periodic report procedures instead of the more extensive recertification process for households due to recertify through December 31, 2021. SNAP participants are required to provide certain updates about their circumstances at certain intervals; this is a much more streamlined process than the recertification process, which requires an application and interview.
Waive interviews for some new applicants applying and households recertifying through June 30, 2021. Consistent with the original waivers USDA approved, states can continue to approve households for SNAP benefits (or to continue receiving benefits) without an interview, as long as states can verify applicants’ identity and other required items.
Continue to extend two other interview flexibilities through June 30, 2021: not offering a face-to-face interview or grant one upon request, and certifying households with very low income eligible for expedited service to be approved without an interview. These interview flexibilities are also consistent with the original interview waivers USDA approved for states through June.
Other Administrative Options and Waivers
USDA has also approved and extended many other waivers under the Families First Act that temporarily suspended administrative requirements for states, not shown in the tables below. USDA continues to approve some of these waivers on a monthly basis.
In addition, USDA has approved waivers to modify aspects of states’ quality control processes. States must independently check the accuracy of household eligibility and benefit levels for a share of their cases each month. The process typically involves an in-person interview with households, often at their home. All states opted to use Families First’s flexibility to conduct quality control interviews by phone instead of in person. USDA approved state extensions of this waiver through June for 49 states, and then approved extensions of this waiver for all states through December 2020. USDA gave all states and territories participating in SNAP an extension of the deadlines for reporting findings from households that were reviewed in December 2019 or January or February 2020, and announced an extension for households selected in June 2020. USDA allowed all states and territories participating in SNAP to suspend these reviews for the months of March, April, and May; subsequent legislation suspended many requirements related to these reviews for June 2020 through June 2021.
USDA also denied many state waiver requests in the spring of 2020, some of which USDA detailed in a letter.
|Pandemic EBT and Online Purchasing Pilots
as of March 25, 2021
|State||Provide benefits for households with children missing school meals in 2019-2020 school year* (P-EBT)||Provide benefits for households with children missing school meals in August-September 2020* (P-EBT)||Provide benefits for households with children missing school meals in 2020-2021 school year (P-EBT)*||Pilot an online purchasing program|
|District of Columbia||X||X||Xc||X|
|USDA-Approved SNAP Operations Waivers Under Families First Act and Options Under October Government Funding Law
as of March 25, 2021
Listed by last month option or waiver is in effect
|State||Extend certification periods and adjust periodic reports||Waive initial/ recertification interviews||Waive face-to-face interviews||Postpone expedited interviews||Adapt telephonic signature requirements||Use periodic report procedures to recertify households|
|Alabama||Jun. 2021||Jun. 2021||Jun. 2021|
|Alaska||Jun. 2021||Jun. 2021||Jun. 2020||Jun.2020||Aug. 2020|
|Arizona||Jun. 2021a||Jun. 2020||Jun. 2020||Jun. 2020||Apr. 2021|
|Arkansas||May 2020||Apr. 2021c||Jun. 2020||Jun. 2020||Oct. 2020|
|California||May 2020||Jun. 2021||Jun. 2021||Jun. 2020||Apr. 2021.|
|Colorado||Jun. 2021b||Jun. 2020||Jun. 2020||Jun. 2020||Jul. 2020|
|Connecticut||Dec. 2020e||Jun. 2021||Jun. 2021||Jun. 2021||Sep. 2020|
|Delaware||Aug. 2020||Jun. 2021||Jun. 2020||Jun. 2020||Mar. 2021|
|District of Columbia||Jun. 2021||Jun. 2021||Oct. 2020||Jun. 2020||Jul. 2020||Dec. 2020d|
|Florida||Aug. 2020||Jun. 2021c||Jun. 2020||Jun. 2021c|
|Georgia||Jan. 2021a||Aug. 2020||Jun. 2020||Jun. 2020|
|Guam||Jun. 2020||Jun. 2020|
|Hawai’i||Feb. 2021||Jun. 2021||Jun. 2021||Jun. 2021||Mar. 2021||Dec. 2021|
|Illinois||Feb. 2021e||Jun. 2021||Dec. 2020||Jun. 2020||Mar. 2021|
|Indiana||Jun. 2021||Aug. 2020||Jun. 2021||Aug. 2020|
|Iowa||Aug. 2020||Jun. 2020||May 2020|
|Kansas||Jun. 2020||Aug. 2020||Jun. 2020||Jun. 2020|
|Kentucky||Jun. 2021||Jun. 2021||Jun. 2020||Jun. 2021|
|Louisiana||May 2021||Jun. 2021||Jun. 2020||Jun. 2020||Dec. 2020d|
|Maine||Jun. 2020||Jun. 2021||Jun. 2020||Jun. 2020||Aug. 2020|
|Maryland||Jun. 2021b||Jun. 2021||Jun. 2021||Jun. 2021||Dec. 2021|
|Massachusetts||Jan. 2021a||Jun. 2021||Jun. 2020||Jun. 2020||Mar. 2021||Dec. 2021|
|Michigan||Jun. 2020||Aug. 2020||Jun. 2021||Jun. 2020||Nov. 2020|
|Minnesota||Feb. 2021||Dec. 2020c||Mar. 2021||Dec. 2020d|
|Mississippi||Jun. 2020||Aug. 2020||Jun. 2020||Jun. 2020|
|Missouri||Aug. 2020||Jun. 2021c||Jun. 2021||Jun. 2020|
|Montana||Jun. 2020||Jun. 2020||Jul. 2020||Jun. 2020||Dec. 2020d|
|Nebraska||May 2020||May 2020|
|Nevada||Jun. 2020||Jun. 2021||Jun. 2020||Jun. 2020|
|New Hampshire||Jun. 2020||Mar. 2021|
|New Jersey||Jun. 2021||Jun. 2021||Jun. 2020||Jun. 2020||Mar. 2021|
|New Mexico||Jun. 2021||Jun. 2021c||Jun. 2021||Jun. 2020||Nov. 2020||Dec. 2021|
|New York||TBDb||Jun. 2021||Aug. 2020||Jun. 2021||Dec. 2020|
|North Carolina||Jun. 2021b||Jun. 2021||Jun. 2021||Jun. 2020||Mar. 2020|
|North Dakota||Jun. 2020||Jun. 2020||Jun. 2020|
|Ohio||Dec. 2020||Dec. 2020c||Dec. 2020||Jun. 2020||Dec. 2020d|
|Oklahoma||Jun. 2020||Jun. 2020||Jun. 2020||Jun. 2020|
|Oregon||Dec. 2020a||Jun. 2021||Jul. 2020||Aug. 2020||May 2020||Jun. 2021|
|Pennsylvania||Jun. 2021a||Jun. 2021||Jun. 2021||Jun. 2020||Dec. 2020d|
|Rhode Island||Jun. 2021||Jun. 2021||Jun. 2021||Aug. 2020||Jun. 2020||Dec. 2021|
|South Carolina||May 2021b||Jun. 2021||Jun. 2021||Jun. 2020|
|South Dakota||Jun. 2020||Jun. 2020||Jun. 2020||Jun. 2020|
|Tennessee||Aug. 2020||Jun. 2020||Jun. 2020|
|Texas||Aug. 2020||Jun. 2021c||Jul. 2020||Jun. 2020|
|Vermont||Nov. 2020||May 2020|
|Virgin Islands||Jun. 2021b||Jun. 2021||Jun. 2021||Jun. 2020|
|Virginia||Jun. 2020e||Jun. 2021||Jan. 2021||Jun. 2020||Jun. 2020|
|Washington||Feb. 2021a||Sep. 2020|
|West Virginia||Jun. 2020||Jun. 2020||Dec. 2020||Jun. 2020||Dec. 2020|
|Wisconsin||Jun. 2021||Jun. 2021|
 The original interview waivers included three major adjustments of normal SNAP requirements for state agencies. The waivers allowed states to approve new households without conducting the normally required interview; allowed states not to offer a face-to-face interview or grant one upon request; and allowed states to approve households with very low income eligible for “expedited benefits” without an interview. The original waivers included all three, but some extensions for July and beyond include just some of those components. (The options approved under the October funding law include all three of these flexibilities through June 2021.)
 Here is a brief summary of many of these waivers, all of which can be found at Food and Nutrition Service, “SNAP: COVID-19 Waivers by State,” https://www.fns.usda.gov/disaster/pandemic/covid-19/snap-waivers-flexibilities.
USDA has 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. USDA has also approved one state (California) for an extension on submitting data to USDA on claims collection.
At least 23 states have been 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.
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 has approved at least five 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, and continued to approve monthly extensions for several states.
Three states have received approval to extend the period of time granted to households that have attempted but are unable to provide a Social Security number, and USDA has approved some states to continue to extend these waivers.
At least two states have received approval to delay notices that states must issue to households with multiple EBT card replacement requests.
Three states have 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.
At least four states were approved to suspend in-person collection of applications and verification documents, some of which have continued to request and be approved for extensions.
At least two states have been approved to streamline the process to determine whether individuals are unable to meet certain work requirements. (Though the Families First Coronavirus Response Act 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, and the other streamlines this good-cause determination for individuals subject to SNAP’s general work requirements.)
 The October government funding law suspended these reviews through September 30, 2021; the December COVID-19 relief package moved up the end of this flexibility so that they are now suspended through June 30, 2021.