Timeline: Understanding the Impact of the End of the Public Health Emergency and COVID-19 Waivers on SNAP Households
The COVID-19 federal public health emergency (PHE) is ending on May 11, 2023, along with several related policy provisions in the Supplemental Nutrition Assistance Program (SNAP) and other programs. This timeline outlines important deadlines and steps during the unwinding of policy waivers and provisions that were implemented during the COVID-19 pandemic. Additional information and resources are also provided at each point on the timeline.
Click on arrows below for more information.
* February is the last month of issuances, but some states will issue the February 2023 benefits in March 2023.
SNAP’s emergency allotments (EAs) — the temporary benefit increases that Congress enacted to address rising food insecurity and provide economic stimulus during the pandemic — ended after February 2023 issuances. This resulted in a benefit cut for every SNAP household in the jurisdictions that still were paying EAs: 32 states, the District of Columbia, Guam, and the U.S. Virgin Islands. However, there are opportunities to help mitigate benefit loss for participants.
Opportunities to Mitigate Benefit Loss
Importance of deductions
The end of EAs also highlights the continued importance of ensuring households can claim allowable deductions for expenses such as rent, utilities, dependent care, child support payments, and medical expenses. This will ensure that the regular SNAP benefit households receive most accurately reflects the available resources they have for food.
- Help for families with young children
Provide school year P-EBT benefits to children under age 6.
School year P-EBT benefits for children under age 6 are available to young children in SNAP households and are intended to replace meals that these children would otherwise receive in a child care setting if not for pandemic-related closures or disruptions. States can act quickly to get a P-EBT child care plan approved for school year 2022-2023 using a relatively straightforward benefit calculation that relies on data all states currently collect.
Refer families to WIC.
Only about half of eligible individuals participate in the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), and take-up is lower for pregnant individuals and children aged 1 through 4. SNAP participants are automatically considered income-eligible, or “adjunctively eligible,” for WIC if they are pregnant, postpartum, or under age 5. Referring families to WIC or mentioning WIC eligibility in outreach messages could help connect or reconnect eligible families to additional grocery benefits and the longer-term health and developmental benefits associated with participation.
Temporary Pandemic SNAP Benefits Will End in Remaining 35 States in March 2023
CBPP and Benefits Data Trust
Toolkit: Increasing WIC Coverage Through Cross-Program Data Matching and Targeted Outreach
U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS)
In early 2020, Congress put into place protections for people enrolled in Medicaid to ensure that they were able to stay covered during the pandemic. This policy, known as the Medicaid continuous coverage requirement, ends March 31, 2023.
There are a number of challenges that Medicaid enrollees could face during the unwinding process, and millions of people are expected to lose their Medicaid coverage as a result. But community outreach, education, and enrollment assistance can help people stay covered. It’s important to understand how Medicaid unwinding may impact SNAP operations — particularly in fully integrated states. Additionally, there are opportunities to coordinate Medicaid and SNAP renewals to both reduce the workload for states and streamline the process for program participants.
States begin to initiate Medicaid renewals.
First round of Medicaid terminations begins — depending on when the state started its renewal process.
Congress gave the USDA additional flexibility during the PHE to help states manage their workloads, process new applications, and keep eligible households connected to SNAP. This authority will end after the PHE ends. However, FNS can offer states some flexibility under separate authority to support unwinding from the PHE.
It is anticipated that some states — particularly those with integrated systems where the same eligibility workers process both Medicaid and SNAP — may struggle with the increased workload associated with Medicaid unwinding and initiating Medicaid redeterminations that will come with the end of the Medicaid continuous coverage requirement, as discussed below. Additionally, many states are already struggling with backlogs of applications and/or renewals due to staffing challenges and increased caseloads. These temporary, transitional flexibilities from FNS can be used in conjunction with other workload management strategies to help states struggling with limited resources.
States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges
SNAP Extension of COVID-19 Administrative Flexibilities: January 2022 and Beyond
SNAP Temporary Administrative Waivers Available to State Agencies to Support Unwinding from the COVID-19 Public Health Emergency
All COVID-related administrative waivers for SNAP will end on this date or the waiver expiration date, whichever is earlier.
As noted above, the Biden Administration announced the COVID-19 federal PHE declaration will end on May 11, 2023. Technically, this date will put in motion the end of SNAP eligibility expansions for those otherwise subject to SNAP’s three-month time limit and for college students. In addition, certain WIC flexibilities will end, though FNS has announced opportunities for states to continue many of those flexibilities under other authority.
During the PHE, Congress provided two temporary exemptions to expand SNAP eligibility for certain college students who otherwise would not qualify for SNAP: 1) students eligible to participate in state or federal work-study programs, and 2) those whose “expected family contribution” for purposes of federal financial aid calculations is zero. Students who qualified under these temporary exemptions may have been eligible under existing rules. These temporary exemptions will remain in place for 30 days after the end of the PHE for new SNAP applicants; participating students will be reassessed at the household’s next SNAP recertification, which will likely occur over the course of the following 12 months. There is a risk that some participating students will lose SNAP benefits if the state fails to properly screen for whether the participant should be considered a student and whether they qualify for other student exemptions once the temporary rules end.
Benefits Data Trust
Benefits Access for Student Success: A Toolkit For Leveraging Data to Find Eligible Students
Preparing for Changes in Student Eligibility Following the End of the COVID-19 Public Health Emergency
End of Public Health Emergency – SNAP Student Exemptions Notice Template
SNAP Institutions of Higher Education and Student Eligibility Rules
States resume applying only regular college student exemptions to SNAP applications filed on or after this date. States should apply temporary student exemptions to any SNAP applications filed before this date.
SNAP recertifications submitted on or after this date must be processed using only regular college student exemptions. SNAP recertifications submitted before this date must be processed using the temporary student exemptions.
The SNAP three-month limit that applies to certain adults without disabilities and without children in their home — commonly referred to as “Able-Bodied Adults Without Dependents” (ABAWDs) within SNAP — was temporarily suspended nationwide during the PHE, except in limited circumstances. The end of the federal PHE in May 2023 means that the clock on the time limit will start in July. As a result, individuals subject to the time limit will lose their SNAP benefits starting in October, unless they live in a “waived” area or meet the other exemptions in place before the PHE ends.
As of March 2023, 15 states, D.C., Guam, and the U.S. Virgin Islands have statewide waivers of the ABAWD time limit, and seven additional states have waivers for some areas of their state. Some states without waivers will qualify for and apply for waivers, but others have legislation that prohibits them from applying for waivers or will not apply.
States will need to develop a comprehensive plan that includes assessing available policy options, updating applications and notices, and educating staff and stakeholders about coming changes. Advocates can play an important role in ensuring that states are aware of all options available to them and that they understand the importance of accurately screening for anyone who may be unfit for work.
Countable months begin for the three-month time limit applying to ABAWDs.
This is the first month in which people may begin to lose SNAP benefits.