With a note on the impact on WIC
Published September 27, 2025
The bottom line: SNAP recipients should receive their October 2025 payments, even if a government shutdown occurs.
Background on SNAP EBT Payments
The Supplemental Nutrition Assistance Program (SNAP) is a delicate partnership of public and private entities. While it is a federal program, each state agency works with its own Electronic Benefit Transfer (EBT) vendor and decides its own disbursement date. Each month, states must transmit an electronic file with the information about each eligible SNAP household’s benefit amount to the EBT vendor by mid-month, so that the EBT vendor can process the data and load individual EBT cards with the next month’s SNAP benefits for that household.
Funding the Government
Congress must enact interim or full-year appropriations by October 1, the beginning of the federal fiscal year, for agencies and programs whose continued operation depends on annual appropriation acts. When Congress fails to enact interim or full-year appropriations, it may enact short-term measures, known as “continuing resolutions” (CRs), to keep the government funded for a few days, weeks, or months at previous levels until final budgeting decisions are made.
Current government funding is set to expire at midnight on September 30. If by then, Congress fails to pass either full-year appropriations bills or a continuing resolution, the federal government will shut down all programs dependent on annual appropriations, including SNAP. This is due to the Antideficiency Act, which dictates that federal agencies cannot spend or obligate any money without an appropriation from Congress. This means that federal agencies must cease all non-essential functions until Congress acts, which would entail the furlough of nonessential personnel and curtailment of agency activities and services, as we saw in 2019.
Impact on USDA
The U.S. Department of Agriculture (USDA) has not provided a 2025 contingency plan. The 2024 plan stated that SNAP operations could continue during a lapse in appropriations based on multiyear carry-over funds, contingency reserves, and quarterly apportionment of funds by the Office of Management and Budget (OMB) under the continuing resolution. More importantly, the Food and Nutrition Service’s updated accounting process also considers the upcoming month’s benefits to be “obligated” in the prior month when issuance files are sent to the EBT vendor and extends the current federal fiscal year’s appropriations to cover the benefits for the first month of the next federal fiscal year. In this case, October benefits are obligated in September.
Accordingly, there is no need for SNAP recipients to worry about missing their October payments even if a shutdown were to occur.
However, in February 2025, the U.S. Government Accountability Office (GAO) raised concerns with USDA’s accounting practices. Until September 19, 2023, the USDA recorded daily obligations equal to benefits issued. On that date, the agency shifted practice and obligated fiscal year (FY) 2023 funds for October 2023 benefits due in FY 2024. GAO concluded that both approaches violated the recording statute and that the September 19 change also violated the bona fide needs statute by using FY 2023 funds for FY 2024 needs. USDA has not commented, and some legal experts argue GAO’s findings are not binding. For now, this is best viewed as an informational flag rather than an immediate concern.
Impact of a Shutdown
Under the Trump administration, the approach to shutdowns may look markedly different. Early in the week, OMB instructed agencies to identify programs where discretionary funding will lapse on October 1 without alternative resources. For those programs, OMB ordered agencies to draft reduction-in-force (RIF) plans that would permanently eliminate jobs rather than impose temporary furloughs. This directive represents a sharp break from past shutdown practices, when employees were furloughed but reinstated once Congress restored funding. OMB Director Russ Vought is leveraging the threat of permanent job losses to heighten pressure in the spending standoff with Democrats in Congress.
If a shutdown extends beyond mid-October, USDA could technically tap its contingency reserve funding to cover SNAP costs. Under the prior administration, this reserve stood at $6 billion, but it is unclear how much remains available or whether the current administration would choose to use it.
Equally concerning, if USDA fails to instruct states to transmit the necessary electronic files on time, November SNAP benefits could be delayed or interrupted entirely. Each state operates on its own internal processing schedule to ensure the timely issuance of benefits. If a state misses its deadline to begin that process, delays are almost inevitable, leaving households without access to the food assistance they rely on.
A Note On WIC In a Shutdown
Historically during a shutdown, the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) has remained operational allowing participants to apply for the program and receive its benefits. This was possible for the shutdown in 2018 as it happened after the start of the fiscal year and states had already received some of their annual funding.
In this current situation, states would not have received any funding for fiscal year 2026 making this a more challenging situation. Even still, WIC does have some ability to draw on funding to ensure consistent service even during a shutdown including a contingency fund and the ability of states to keep and use a percentage of the previous year’s funding.
Any distruptiondisruption in benefits for WIC would put the health and well-being of young chidlrenchildren and their families at risk and put in jeopardy the trust in this critical program.
Take Action:
Keep raising the alarm about how harmful cuts to SNAP are. Document the harm and keep sharing the pivotal role that SNAP plays in communities.