States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges

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 difficulties affording adequate food and other basic needs, which have remained high throughout the pandemic compared to pre-pandemic levels, despite recent declines. SNAP is essential to helping these families put food on the table.

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.

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 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, many of which have been extended by subsequent legislation and administrative action. 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 encouraged states to use existing program flexibility. Families First also included a temporary boost of emergency supplementary benefits and school meal replacement benefits, which have also been extended and strengthened by subsequent legislation and administrative action from the Biden Administration.

Benefit Enhancements

The Families First law included two ways for states to raise benefits for many SNAP participants and other households experiencing falling income and rising food needs:

  • Provide SNAP households with emergency allotments: States can give SNAP households emergency supplementary benefits; all states have used this option. (Originally, a Trump Administration interpretation of this Families First policy left out some of the lowest-income SNAP households from receiving these benefits when states began issuing them in March 2020. The Biden Administration reversed this policy, and beginning April 2021 all households in states with these benefits have received emergency allotments of at least $95.)

    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. Some states have begun ending or taking steps to end their state COVID-19-related emergency declarations, though so far in most cases only temporarily.[1]) 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 — amounts to about $28 more in 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.)

  • Replace lost school meals through 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 the 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 additional 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 to increase benefits offered through this program and encouraged states to apply those increases retroactively. The Rescue Plan 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. About 40 states, Washington, D.C., Puerto Rico, and the Commonwealth of the Northern Mariana Islands 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. Several states have also been approved to provide benefits in summer 2021. With the January 2021 guidance simplifying administration for states, all states should now act to provide these benefits.

    Table 1 shows the states with current or past P-EBT adoptions. P-EBT benefits may be issued retroactively once states are approved. We will update Table 1 as more states are approved for the 2020-2021 school year and summer 2021. 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 spring 2020 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 pandemic 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, in 38 states includes ALDI, and in nine states includes Food Lion. Other approved retailers include ShopRite, Publix, Price Chopper Supermarkets, and BJs Wholesale Club in at least four states, and other regional and local retailers, such as H-E-B in Texas. This waiver allows individuals receiving SNAP benefits to get the food they need 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.

SNAP Operations Waivers

Families First and subsequent legislation allowed states to temporarily adjust their operations to help manage their workloads and help participants gain and maintain access to the program. 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 stayed steady through September, before dropping slightly to about 42 million in February 2021. State SNAP agencies have had to manage this greater volume at a time of office closures, staffing shortages, and potential difficulties with a remote work environment throughout the pandemic. These temporary adjustments have been critical to help state SNAP agencies process applications and help keep participants connected to the program, as many states reported in a recent survey of state agencies.

  • Some states began transitioning off these flexibilities in the second half of 2020, as USDA began approving fewer extensions, but the October 2020 government funding law restored many of these options. USDA announced that beginning in May 2021, states can extend these flexibilities through December 31, 2021 (or the month following the end of the national public health emergency, whichever is sooner). This guidance also encourages states to use these flexibilities as needed to aid in a transition to regular operations, such as by applying the flexibility only to a portion of the caseload or reducing the number of households affected by the flexibility each month. 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.

    States were originally approved for waivers to extend certification periods for SNAP households through May 2020, and most states requested and received extensions of this waiver through June 2020. After originally denying most requests, USDA then approved waivers through August and September 2020 for a limited number of states and approved limited modifications to reporting requirements for households that are renewing benefits. The October 2020 law allowed states to return to the more extensive options originally offered without requesting USDA approval, and some states began using this option again to use this flexibility through June 2021. Under recent May 2021 guidance, states may request to extend the more extensive waivers available through December 2021. Table 2 shows the expiration of states’ most recent usage of this option.

  • Waive interview requirements. 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 it can be a labor-intensive task that can delay approval. USDA has allowed states to dispense with the interview temporarily for many households, originally at both initial application and recertification, as long as state agencies verify identification and households provide mandatory verifications, such as of income. USDA has also allowed states to approve households with very low income and resources that are entitled to shortened timelines for processing applications (known as “expedited processing”) without an interview, provided that state agencies verify the identity and attempt to contact these households, and to not offer an in-person interview if requested by a SNAP participant or applicant. There is evidence that some states apply these flexibilities only to some SNAP households; for example, a recent survey of state SNAP agencies found that most continued to conduct interviews for some households, such as when information was missing or incomplete.

    Over 40 states took up USDA’s spring 2020 nationwide waiver of the interview at the application or recertification stage to ensure that newly eligible households can access food assistance through SNAP and others can stay on. As with the waivers to extend certification periods, USDA originally allowed extensions through June 2020, and through July and August for some states meeting certain requirements and limited versions for others.[2] USDA had indicated it would largely approve very limited versions of these waivers beginning in September 2020, and as a result, many states began transitioning off the waivers. The October 2020 government funding law allowed states to implement the original versions of the waiver through June 2021 without requesting USDA approval, however, and many states began using this flexibility again. Under the May 2021 guidance, states may now continue this flexibility through December 2021. Table 2 shows the states extending this flexibility.

  • 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 pandemic environment, where offices have been closed in many states, and not all clients can access online applications. USDA has continued to allow states to extend this waiver, as shown in Table 2, and states may extend through December 2021.
  • Use periodic report procedures instead of the more extensive recertification process. SNAP participants are required to provide updates about their circumstances at certain intervals; this is a much more streamlined process than the recertification process, which requires an application and interview. This option, included in the October 2020 government funding law, allows states to extend this flexibility for households due to recertify through December 31, 2021.

Other Administrative Options and Waivers

In addition to extending approvals for states to use flexibility under existing SNAP regulations, 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 continued to approve some of these waivers on a monthly basis, and beginning in May 2021, let states request these options through December 2021.[3] USDA also had introduced some limited options in the fall of 2020 meant to transition states to regular operations, but because the October 2020 government funding law restored many flexibilities that had been previously offered, states stopped using those narrower options.[4]

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 the waiver through June 2020 for 49 states, approved extensions of the waiver for all states through December 2020, and announced that states may request this waiver through December 2021. 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 it announced an extension for households selected in June 2020. USDA allowed all states and territories participating in SNAP to suspend these reviews for March, April, and May 2020; subsequent legislation suspended many requirements related to these reviews for June 2020 through June 2021.[5]

Figure 1
 
TABLE 1
Pandemic EBT and Online Purchasing Pilots
as of June 1, 2021
State Provide benefits for households with children missing school meals in 2019-2020 school year* (P-EBT) Provide P-EBT, August-September 2020* Provide P-EBT, 2020-2021 school year* Provide P-EBT, summer 2021 Pilot an online purchasing program
Alabama X   Xb,c   X
Alaska Xa        
Arizona X   Xb,c   X
Arkansas X       X
California X X Xd   X
Colorado X   Xb   X
Commonwealth of the Northern Mariana Islands     Xb,c    
Connecticut X   Xb,c   X
Delaware X X Xc   X
District of Columbia X X Xc   X
Florida X   Xb   X
Georgia X       X
Guam          
Hawai’i X X X c X X
Idaho X   Xb   X
Illinois X X X   X
Indiana X X Xc X X
Iowa X   Xb,c   X
Kansas X   Xb,c   X
Kentucky X X X c   X
Louisiana X   Xb    
Maine X   Xb,c   X
Maryland X X Xc   X
Massachusetts X X Xc X X
Michigan X   Xb,c X X
Minnesota X   Xb,c   X
Mississippi X       X
Missouri X       X
Montana X X X    
Nebraska X X X   X
Nevada X   Xb,c   X
New Hampshire X       X
New Jersey X X Xc   X
New Mexico X X X   X
New York X   Xb   X
North Carolina X X Xc X X
North Dakota X   Xb   X
Ohio X X Xc   X
Oklahoma X       X
Oregon X X Xc   X
Pennsylvania X   Xb,c   X
Puerto Rico**     Xb,c X  
Rhode Island X X Xc   X
South Carolina X   Xb   X
South Dakota X   Xb   X
Tennessee X X X   X
Texas X   Xb,c   X
Utah X   Xb   X
Vermont X   Xb,c   X
Virgin Islands X X      
Virginia X X X   X
Washington X   Xb   X
West Virginia X   Xb,c   X
Wisconsin X   Xb,c   X
Wyoming X       X
Total 52 20 44 6 48

* The Families First law, which originally authorized P-EBT, authorized the program through September 2020 (fiscal year 2020). USDA originally approved states to provide benefits in the 2019-2020 school year for days when schools were closed, and approved extensions for states to provide benefits in August and September of the 2020-2021 school year under that law. The October government funding law extended this option through September 2021 and expanded the program by including schools using a mix of in-person and virtual learning and certain children under age 6 receiving SNAP benefits. The December COVID-19 relief package and further action from the Biden Administration allowed for further simplifications, particularly for children under age 6. States that were not originally approved to issue benefits for August and September 2020 under the Families First law may issue benefits for those months once approved for the 2020-2021 school year. The American Rescue Plan Act allows states to provide P-EBT benefits during the summer of 2021 and throughout the COVID-19 pandemic.

** Puerto Rico, which operates a SNAP-like block grant in lieu of SNAP but participates in the child nutrition programs that the states participate in, was excluded from P-EBT under the Families First law. The October government funding law extended the option to Puerto Rico to participate in P-EBT in the 2020-2021 school year. American Samoa and the Commonwealth of the Northern Mariana Islands, which operate block grants in lieu of SNAP and receive separate grants for child nutrition programs, are also eligible to implement P-EBT under the October law.

a Alaska was approved in February 2021 for an amendment to its spring 2020 plan to issue benefits to children who were previously eligible but did not receive them. See https://fns-prod.azureedge.net/sites/default/files/resource-files/Alaska-amendment-approval-schools-21221.pdf.

b These states were approved for P-EBT for the entire 2020-2021 school year after the October 2020 extension of the program, including retroactive benefits for August and/or September 2020.

c These states were approved to issue P-EBT benefits for children under age 6 in SNAP households in areas where schools or child care centers are closed or operating with reduced hours or capacity due to the pandemic.

d California was approved to issue benefits for children under age 6 in SNAP households but has not yet been approved to issue P-EBT to school-aged children in the 2020-2021 school year.

TABLE 2
USDA-Approved SNAP Operations Waivers, as of June 1, 2021
Listed by last month option or waiver is in effect
State Extend certification periods and adjust periodic reports Waive initial/ recertification interviews Not offer 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 Jul. 2021 Jun. 2020 Jun.2020 Aug. 2020  
Arizona Jun. 2021 Jun. 2020 Jun. 2020 Jun. 2020 Dec. 2021  
Arkansas May 2020 Jun. 2021 Jun. 2020 Jun. 2020 Oct. 2020  
California May 2020 Dec. 2021 Dec. 2021 Jun. 2020 Dec. 2021  
Colorado Jun. 2021 Jun. 2021 Jun. 2020 Jun. 2020 Jul. 2020  
Connecticut Dec. 2021 Dec. 2021 Jun. 2021 Dec. 2021 Sept. 2020  
Delaware Aug. 2020 Jun. 2021 Jun. 2020 Jun. 2020 Dec. 2021  
District of Columbia Dec. 2021 Jun. 2021 Oct. 2020 Jun. 2020 Jul. 2020 Dec. 2020
Florida Aug. 2020 Jun. 2021 Jun. 2020 Jun. 2021    
Georgia Jan. 2021 Aug. 2020 Jun. 2020 Jun. 2020    
Guam Jun. 2020 Jun. 2020        
Hawai’i Feb. 2021 Dec. 2021 Dec. 2021 Dec. 2021 Dec. 2021 Dec. 2021
Idaho May 2020          
Illinois Dec. 2021 Dec. 2021 Dec. 2020 Jun. 2020 Dec. 2021  
Indiana Dec. 2021 Aug. 2020 Dec. 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 Dec. 2021 Jun. 2020 Jun. 2020 Aug. 2020  
Maryland Jun. 2021 Dec. 2021 Jun. 2021 Jun. 2021   Dec. 2021
Massachusetts Jan. 2021 Jun. 2021 Jun. 2020 Jun. 2020 May 2021 Dec. 2021
Michigan Jun. 2020 Aug. 2020 Jun. 2021 Jun. 2020 Nov. 2020  
Minnesota Dec. 2021 Dec. 2020     Dec. 2021 Dec. 2020
Mississippi Jun. 2020 Aug. 2020 Jun. 2020 Jun. 2020    
Missouri Aug. 2020 Jul. 2021 Jun. 2021 Jun. 2020    
Montana Jun. 2020 Jun. 2020 Jul. 2020 Jun. 2020   Dec. 2020
Nebraska May 2020 May 2020        
Nevada Jun. 2020 Dec. 2021 Jun. 2020 Jun. 2020    
New Hampshire Jun. 2020       Dec. 2021  
New Jersey Dec. 2021 Dec. 2021 Jun. 2020 Jun. 2020 Dec. 2021  
New Mexico Dec. 2021 Dec. 2021 Jun. 2021 Jun. 2020 Nov. 2020 Dec. 2021
New York Dec. 2021 Jun. 2021 Aug. 2020 Jun. 2021 Dec. 2021  
North Carolina Dec. 2021 Dec. 2021 Jun. 2021 Jun. 2020 Dec. 2021  
North Dakota   Jun. 2020 Jun. 2020 Jun. 2020    
Ohio Dec. 2020 Sep. 2021 Sept. 2021 Jun. 2020   Dec. 2020
Oklahoma Jun. 2020 Jun. 2020 Jun. 2020 Jun. 2020    
Oregon Dec. 2020 Jun. 2021 Jul. 2020 Aug. 2020 May 2020 Jun. 2021
Pennsylvania Jun. 2021 Dec. 2021 Jun. 2021 Jun. 2020   Dec. 2020
Rhode Island Dec. 2021 Jun. 2021 Sept. 2021 Dec. 2021 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. 2021 Jul. 2020 Jun. 2020    
Utah            
Vermont Nov. 2020 May 2020        
Virgin Islands Jun. 2021 Jun. 2021 Jun. 2021 Jun. 2020    
Virginia Jun. 2020 Jun. 2021 Jan. 2021 Jun. 2020 Jun. 2020  
Washington Feb. 2021   Sept. 2020   Dec. 2021  
West Virginia Jun. 2020 Jun. 2020 Dec. 2021 Jun. 2020   Dec. 2020
Wisconsin Dec. 2021 Sept. 2021        
Wyoming            
Total 48 48 43 42 24 13

Notes: This table includes waivers under the Families First law, which require USDA approval, and were originally largely approved from March through August 2020, until USDA gave state agencies the option in May 2021 to request waivers through December 2021 or the end of their state (or the national) public health emergency. For more on states’ use of waivers, see: https://www.fns.usda.gov/programs/fns-disaster-assistance/fns-responds-covid-19/snap-covid-19-waivers. For extensions approved under the May 2021 guidance, see: https://www.fns.usda.gov/snap/extension-covid-19-administrative-flexibilities-may-2021-and-beyond. This table also includes options from the October government funding law that did not require USDA approval and that states implemented through June 2021 (or through December 2021 for the option to use periodic report procedures to recertify households). For more on states’ use of these options, see https://www.fns.usda.gov/snap/cr-state-options. States can choose how to implement these waivers, and some states extend these flexibilities for just a portion of their caseload or in otherwise limited fashion; this table only shows states’ usage of these waivers as reported by USDA. This table also shows the last month the state has opted to extend the flexibility; states may have had months without this flexibility.

Sources: USDA Food and Nutrition Service (FNS) and state agencies

Updated
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End Notes

[1] A state with a declaration of a public health emergency by the governor or agency such as the health department is eligible to issue emergency allotments.

[2] 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. USDA limited some extensions beginning in July 2020 to just some of those options, but the October funding law restored options for states to use all three of these flexibilities through June 2021, and recent USDA guidance allows states to extend all of these flexibilities through December 2021.

[3] 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 state agencies to extend these through December 2021 as well.

USDA 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 has also approved one state (California) for an extension on submitting data to USDA on claims collection.

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 six states with extensions through December 2021.

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.)

[4] 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 were replaced by the more flexible options included in the October 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.

[5] 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.