Published July 2, 2025
As the budget reconciliation process advances, Senate Democrats and a growing number of state leaders continue to raise the alarm about the devastating impacts of the proposed changes to the Supplemental Nutrition Assistance Program (SNAP). Advocates have been working nonstop, warning lawmakers, especially Republicans who are leading this bill, of the unprecedented shift and dire consequences this bill would cause.
One of the most damaging provisions is the proposed cost shift to states, which ties additional state financial obligations to their SNAP error rates. New error rate data released Monday showed mixed results: While some states have improved, 44 states had error rates at or above 6 percent, which means they are required to submit a corrective action plan and would be subject to additional financial obligations under the proposed new framework. Despite touting fiscal responsibility, Senate Republicans have added carve-outs that contradict their stated concerns about program integrity and error reduction. Here are 10 things to understand about what cost-share is and what error rates are:
1. What Is Cost-Share?
For the first time in SNAP’s history, starting in fiscal year (FY) 2028, states would be required to pay a portion of food benefit costs, not just administrative expenses. This shift fundamentally alters the federal-state partnership, where the federal government currently covers 100 percent of food benefit costs. The proposed state contributions are tied to each state’s SNAP payment error rate:
- 5 percent match for all states beginning FY 2028.
- 15 percent for states with error rates between 6 percent–8 percent.
- 20 percent for error rates between 8 percent–10 percent.
- 25 percent for error rates above 10 percent.
- 0 percent for states with error rates below 6 percent (note: most states have approached or exceeded this threshold in recent years).
- 5 percent for 6 percent–8 percent.
- 10 percent for 8 percent–10 percent.
- 15 percent for above 10 percent.
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.
2. What Changed in the Cost-Shift Provision in the Senate Reconciliation Bill?
Republicans added last-minute carve-outs to exempt Alaska from the cost-share by introducing a delay provision for states with exceptionally high error rates. If a state’s SNAP payment error rate in fiscal year 2025, when multiplied by 1.5, is 20 percent or higher, the state may delay the start of cost-sharing until fiscal year 2029. Likewise, if the state meets this threshold in fiscal year 2026, it may delay implementation until fiscal year 2030. However, this delay is a one-time option; states can only take advantage of it once, based on either FY 2025 or FY 2026 data, not both. This provision perversely incentivizes states to maintain higher error rates to postpone their cost-share obligations.
In FY 2028, based on FY2024 data, impacted states could include Alaska, Florida, Georgia, Maryland, Massachusetts, New Jersey, New Mexico, New York, Oregon, and the District of Columbia.
3. Who Benefits From These Provisions?
In reality, no one benefits in the long term. Regardless of temporary delays, all states will eventually be required to pay, including Alaska. While states with high error rates may be eligible for the delay, states are facing systemic challenges like understaffing and a lack of resources. Notably, under the House plan, even states with low error rates must pay a mandatory 5 percent match, making this carve-out more symbolic than substantive.
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.
