Published July 11, 2025
Despite strong opposition from Senate and House Democrats — joined by governors, advocates, and constituents across the country — Republican-led changes to the Supplemental Nutrition Assistance Program (SNAP) moved forward. These provisions, embedded in the reconciliation process that approved President Trump’s and congressional Republicans’ broader fiscal agenda in H.R. 1, prioritize tax breaks for the wealthy while shifting greater burdens onto states and working families.
One of the most damaging provisions is a fundamental change to SNAP’s funding structure. For the first time since the program’s inception, states would be required to cover a share of the cost of food benefits, not just administrative expenses. This marks a dramatic departure from the long-standing federal-state partnership in which the federal government has consistently covered 100 percent of SNAP food benefits. Beginning in fiscal year (FY) 2028, state contributions will be tied to their SNAP payment error rates — a volatile and often misleading performance metric.
As of FY 2024, 44 states had error rates at or above 6 percent, placing them at risk for new and substantial financial obligations. Compounding the problem, the bill also increases states’ responsibility for SNAP administrative costs from 50 percent to 75 percent, while simultaneously reducing federal support. Although Republican lawmakers have framed this policy as a push for fiscal discipline and program integrity, it is part of a broader, well-coordinated effort to dismantle SNAP.
By pushing these unfunded mandates onto states — while linking penalties to performance metrics that many states struggle to control — this policy sets up a scenario where governors and state legislatures will bear the blame for cuts, program reductions, or even the collapse of SNAP in their states. The resulting fallout will be local, but the design is federal. This is not accidental; it is a deliberate strategy to make SNAP more expensive and politically unsustainable at the state level, allowing its federal architects to distance themselves from the consequences while avoiding accountability for its eventual weakening or demise.
Below are 10 key facts to understand about the cost-share framework and the far-reaching implications of this shift:
1.What Is Cost-Share Framework?
- For the first time in SNAP’s history, starting in FY 2028 (October 1, 2027), states will have to pay additional costs as follows:
- Error rate below 6 percent: 0 percent match.
- Based on FY 2024, Idaho, Nebraska, Nevada, South Dakota, Utah, Vermont, Wisconsin, and Wyoming would not have a cost share. However, this 0 percent match is not a guarantee; all of these states have previously approached or exceeded the 6 percent threshold, meaning even a slight increase in error rates could trigger new financial obligations.
- 6 percent–8 percent error rate: 5 percent match.
- Based on FY 2024, it would impact Hawaii, Iowa, Louisiana, New Hampshire, North Dakota, and Washington.
- 8 percent–10 percent error rate: 10 percent match.
- Based on FY 2024, it would impact Alabama, Arizona, Arkansas, Colorado, Indiana, Kansas, Kentucky, Michigan, Minnesota, Missouri, Montana, Ohio, South Carolina, Tennessee, Texas, and West Virginia. t Virginia.
- Over 10 percent error rate: 15 percent match.
- Based on FY 2024, it would impact Alaska, California, Connecticut, Delaware, Florida, Georgia, Maine, Maryland, Massachusetts, Mississippi, New Jersey, New Mexico, New York, North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, Virginia, and the District of Columbia.
These rates will be based on the most recent available data, meaning FY 2026 data will dictate FY 2028 cost-sharing, barring one exemption explained below. Many states currently on the margin could easily fall into higher-cost brackets over time, especially as administrative costs rise and federal support wanes. In addition, states will be required to make payments even if the payment error rate goes down below 6 percent in the years between the fiscal year with the error rate over 6 percent and the year payment is required.
Although states currently fall into specific cost-share brackets based on their FY 2024 error rates, these categories are not fixed. As administrative costs rise — and with the bill shifting the state share of administrative expenses from 50 percent to 75 percent — states will face even greater challenges. Reduced federal support and higher operational costs will make it harder for many states to maintain low error rates, increasing the likelihood that they will fall into higher-cost brackets over time.
This policy would dramatically increase states’ financial burdens. It will force states to absorb additional costs or cut program eligibility. This undermines SNAP’s role as a federally funded basic needs program that responds to economic need, especially during downturns. Higher state burdens would likely result in reduced access for eligible families.
2. What was the Carve-Out That Republicans Added to Get Enough Republican Votes for the Bill?
To secure Sen. Lisa Murkowski’s vote, Senate Republicans included a special carve-out designed to delay cost-sharing for Alaska, one of the states with the highest SNAP error rates. To comply with Senate budget reconciliation rules, they expanded the provision to apply to any state with exceptionally high error rates.
Under this provision, if a state’s fiscal year 2025 SNAP payment error rate, when multiplied by 1.5, equals or exceeds 20 percent, the state may delay its cost-sharing obligation until fiscal year 2029. Likewise, if the state meets this threshold in fiscal year 2026, it may delay implementation until fiscal year 2030. However, the delay can be used only once, based on either FY 2025 or FY 2026 data, not both.
While framed as a technical adjustment, the carve-out was politically motivated and structured to secure the bill’s passage. This provision also perversely incentivizes states to maintain higher error rates to postpone their cost-share obligations.
In FY 2028, based on FY2024 data, states that could avail themselves of this carve-out include Alaska, Florida, Georgia, Maryland, Massachusetts, New Jersey, New Mexico, New York, Oregon, and the District of Columbia.
3.Who Ultimately Benefits From the Carve-Out?
In reality, no one benefits in the long term. Temporary delays may offer brief relief, but states will ultimately face cost-sharing requirements. Those eligible for a delay—often the same states grappling with staffing shortages, outdated technology, and limited resources—will still confront the underlying challenges. A short-term reprieve does nothing to resolve these systemic issues; it merely postpones an inevitable fiscal reckoning.
4.Doesn’t the U.S. Department of Agriculture (USDA) Already Monitor State Performance?
Yes. SNAP has one of the most rigorous quality control systems in the federal government. Each year, states review approximately 50,000 SNAP cases for eligibility and benefit accuracy, and USDA independently re-reviews half of those to validate results. This two-tiered process ensures integrity, identifies areas for improvement, and helps hold states accountable.
5.What Are Error Rates?
Payment error rates measure how accurately states determine household eligibility and benefit amounts. It captures both overpayments and underpayments. States review their cases, and USDA validates these findings using statistical regression analysis to calculate state and national error rates, weighted by benefit issuance.
6.Are States Currently Held Accountable for Error Rates?
Yes. States with an error rate of 6 percent or more, or that fail to review 98 percent of their required sample, must submit a Corrective Action Plan (CAP). These plans outline how the state will reduce errors and improve program performance. States must also reimburse the federal government for overpayments and compensate recipients for underpayments.
7.Are Error Rates the Same as Fraud?
No. Errors are unintentional mistakes; fraud is intentional deception that breaks federal and/or state laws. In fact, fraud in SNAP is extremely rare.
8.What Are Corrective Action Plans (CAPs)?
Corrective Action Plans (CAPs) are formal strategies that state agencies must submit to the USDA Food and Nutrition Service (FNS) when their SNAP payment error rate exceeds 6 percent. These plans aim to identify and address the root causes of payment errors and must be submitted within 60 calendar days of receiving the official error rate. The CAP must include a detailed breakdown of each deficiency — its scope, causes, geographic reach, and impact — along with a description of corrective actions, timelines, monitoring methods, and expected outcomes. Agencies must also provide a root cause analysis supported by quality control (QC) data, classify and evaluate trends, and demonstrate how each intervention directly addresses one of the three primary drivers of error. The process is highly technical, time-consuming, and demands extensive internal analysis, planning, and inter-agency coordination.
The CAP process continues long after submission. FNS typically responds within 45 days, and if the CAP is denied, states have 30 calendar days to revise it. States must provide biannual updates (May 1 and November 1) until each corrective action is verified and closed by the FNS Regional Office. Closure is only granted once the agency has fully implemented each action and demonstrated measurable improvement, verified through QC data. Although states may request technical assistance, responsibility for analysis, planning, and execution rests squarely on the state agency, making CAPs a burdensome but critical tool for improving program integrity.
9.Why Are Error Rates So High Right Now?
Due to the COVID-19 pandemic, USDA paused standard error reporting for FY 2020 and FY 2021. The return to pre-pandemic policies, coupled with staffing shortages, outdated technology, a surge in caseloads, and a new QC handbook, contributed to the spike in recent error rates.
10.What Would Be the Consequences of Cost-Sharing?
In addition to state legislators from Nebraska, 23 governors have already signaled how harmful this provision would be for their state, and some may not be able to continue operating SNAP under this proposal. The combination of mandatory cost-sharing in addition to increased administrative match requirements, from 50 percent to 75 percent, places significant fiscal pressure on states. This would force them to either cut services, reduce access, or reallocate funds from other essential programs, all while managing higher administrative expectations with fewer federal resources.
The harm would not stop at SNAP. Child nutrition programs, including school meals and Summer EBT, also stand to be affected. Some states are already reacting: Texas recently announced it will opt out of the Summer EBT Program in 2027, citing concerns over future state obligations to fund SNAP as a key reason. This decision will leave thousands of children without vital summer nutrition support.
The SNAP cost-sharing plan represents a significant departure from a proven, federally funded safety net. It risks increasing food insecurity, widening administrative gaps, and undermining state capacity to serve families with low incomes, all while providing tax relief to the wealthiest Americans. State leaders, advocates, and communities must continue to raise awareness and hold accountable, through public dialogue, public oversight, and sustained civic engagement, those within their states who supported this harmful provision.
