FRAC Chat

The budget reconciliation law, also referred to as H.R. 1,, marks a significant departure from the longstanding structure of the Supplemental Nutrition Assistance Program (SNAP), one of the federal government’s most effective tools for reducing hunger and promoting economic stability. The law weakens multiple components of the critical support system shifts substantial financial responsibility from the federal government to states, and fundamentally alters SNAP’s financing model. Most notably, it requires states, for the first time in the program’s history, to cover a share of SNAP food benefit costs rather than limiting their contributions to administrative expenses.

As of December 2025, the U.S. Department of Agriculture (USDA) has a notice of proposed rulemaking pending that would eliminate states’ ability to use broad-based categorical eligibility (BBCE), a policy that streamlines the administration of the Supplemental Nutrition Assistance Program (SNAP). Currently, 43 states and the District of Columbia use BBCE to help ensure that food-insecure residents have access to the nutrition they need to thrive.

The Summer Electronic Benefit Transfer (Summer EBT) Program has been a permanent program since 2024 and has found enormous success. In its second year of implementation, five Indian Tribal Organizations (ITOs) were joined by 37 states, the District of Columbia, and all five U.S. territories to serve millions of children. Still, many ITOs and states are missing out on the opportunity to leverage federal dollars to address childhood summertime food insecurity.

Supplemental Nutrition Assistance Program (SNAP) payment error rates (PER) are in the spotlight. The H.R. 1 megabill changed the way that SNAP benefits will be paid for: Starting in 2027, states will be responsible for a portion of SNAP benefit costs (5 percent to 15 percent) depending on their error rates. This is a totally new approach — while states have always been responsible for a portion of administrative costs, the actual SNAP benefits delivered to people to buy food have always come from the federal government.

June marks the return of Supplemental Nutrition Assistance Program (SNAP) time limits (i.e. work requirements). For the first time in close to three decades, SNAP participants in the District of Columbia will be required to prove they are working or volunteering at least 80 hours per month to maintain their SNAP benefits. These changes threaten to deepen hunger and economic hardship for thousands of District residents, including working families, children, older adults, and people with disabilities at a time when many households are already struggling to afford basic needs amid rising prices and economic uncertainty.