Published November 7, 2025

The country is facing an unnecessary, self-inflicted emergency: the Trump administration’s refusal to provide food assistance via the Supplemental Nutrition Assistance Program (SNAP) to millions of Americans despite clear legal authority and available funding. States, municipalities, nonprofits, courts, and advocates have had to step in to protect the nation’s most vulnerable families. 

A Crisis of Political Will 

This is not a capacity problem — it’s a choice. Three separate lawsuits (state attorneys general, a national nonprofit coalition, and a class action case) challenge the administration’s actions. Judges have affirmed that the U.S. Department of Agriculture (USDA) can and must fully fund SNAP using contingency and reserve funds. Instead of complying, USDA issued shifting, complicated guidance that forced states to recalculate benefits — delaying payments, creating administrative chaos, and heightening fear for millions. When ordered to use reserve funds for full benefits, the administration appealed. 

This fight should never have reached a courtroom. Historically, administrations of both parties have used contingency funds, carryover appropriations, and short-term accounting adjustments to maintain benefits during funding lapses. The authority exists; but for the current administration, the will does not. 

Administrative Chaos and Real-World Consequences 

State agencies are bearing the brunt of the administration’s mismanagement. Already struggling with staffing shortages and complex federal reporting requirements, they were forced to recalculate benefits multiple times based on shifting USDA instructions. Each change means new programming, new math, and new delays — all the while families wait in grocery lines with empty cards. 

Retailers, too, face mounting strain. Local grocers and farmers who depend on SNAP sales to sustain their businesses are caught in the uncertainty, unable to plan inventory or staffing. For small stores in rural areas, SNAP participation can be the difference between staying open or shutting down. 

The harm is not theoretical — it is unfolding in real time. Families who missed their benefits at the start of the month are struggling to pay for food, rent, and medication. Nonprofits and food banks have been reporting spikes in demand. All of this chaos was avoidable. 

Ongoing Legal Developments and Next Steps 

As of yesterday, the trial court denied the Department of Justice’s (DOJ) motion for a stay of the order requiring full SNAP benefit issuance. This morning, the administration appealed the ruling to the Appeals Court, asking not to fund SNAP. DOJ has asked that the court provide a decision by this afternoon. If that request is denied, or if the Appeals Court does not act in time, they could attempt to seek emergency relief from the Supreme Court. 

Time is now critical. If no stay is granted by today, USDA must direct states to transmit their issuance files to Electronic Benefit Transfer (EBT) vendors so that full benefits can be released. Any delay beyond the close of business today could put officials — mostly USDA leadership — at risk of being held in contempt of court. 

As of last night, several states submitted their case files in accordance with the court ruling and have begun issuing full SNAP benefits. Others have released only partial benefits, with timing and implementation varying by state.

This morning, states received new guidance from FNS confirming that the agency is working toward implementing full November 2025 benefit issuances in compliance with the November 6, 2025, order from the U.S. District Court for the District of Rhode Island. Later today, FNS will complete the necessary processes to make funds available so states can transmit their full issuance files to EBT processors. While this may be performative in order not be held in contempt in court, it is an important step that allows states and processors to begin the process of issuing benefits. You can view the updated timeline and state tracking here. 

Who SNAP Serves — and Why That Matters 

USDA’s most recent participation report, fiscal year (FY) 2023, underscores what advocates know well: 

  • Vulnerability: 39 percent of participants are children; 20 percent are older adults; and 10 percent are people with disabilities. 
  • Deep poverty: 73 percent of participating households have gross income at or below the federal poverty line ($27,750 for a family of four in FY 2023). 
  • Working households: Nearly one-third of SNAP households have earnings, and among those with children, 55 percent have earnings. On average, SNAP households gross monthly income is $1,059,and their net income is $527. In addition, FRAC’s analysis of the 2018–2023 American Community Survey showed that 80 percent of SNAP households in the U.S. include at least one working individual, which underscores that SNAP primarily supports working families struggling to make ends meet. 
  • Modest benefits: The average benefit is about $6 per person per day; 64 percent of households receive less than the maximum allotment. 

SNAP benefits can only be used for food, but by covering part of a family’s grocery budget, it frees up limited cash for rent, utilities, medicine, and transportation. In other words, SNAP is both a nutrition assistance program and a stabilizer of household finances. It prevents hunger and helps families meet other essential needs. 

The Larger Policy Context: H.R. 1 

While states navigate shutdown-driven confusion, they are also being compelled to implement the most sweeping SNAP cuts in history under the budget reconciliation law (H.R. 1), signed July 4, 2025. The law: 

  • Shifts costs to states and counties, reducing the federal share of administrative funding to 25 percent by FY 2027, and for the first time, requiring states to pay a portion of benefits beginning in FY 2028, tied to administrative error rates rather than fraud. 
  • Expands time limits and work requirements, including older adults up to 65, caregivers of teens, veterans, unhoused individuals, and youth aging out of foster care — despite decades of evidence that these rules do not increase stable employment. 
  • Erodes benefit adequacy by requiring future updates to the Thrifty Food Plan to remain “cost-neutral,” ensuring benefits can no longer keep pace with rising food prices. 
  • Defunded SNAP-Ed, defunding community nutrition education programs that support health, prevention, and partnerships between local agencies and schools. 

Together, these provisions shift costs and responsibility to the very governments least equipped to bear them. They multiply administrative complexity, heighten state error rates, and all but guarantee future funding shortfalls. The shutdown chaos is a preview of what is to come — a demonstration of how policy design choices translate directly into household hardship and local economic pain.  

Data Backslide: Policy by Blindfold 

At the same time, USDA’s move to terminate the CPS Food Security Supplement — the nations only annually fielded, nationally representative measure of adult and child food insecurity with state-level estimates — will prevent tracking of the impact these polices will have on hunger. Ending the CPS-FSS without a proven replacement undermines accountability just as policy changes intensify. History shows that when credible data disappears, hardship is easier to deny and ignore. 

The Cost of Inaction 

The consequences are clear and measurable. Every day of delay in issuing benefits translates into billions of dollars withheld from families and local economies. Every expansion of time limits means more working adults and caregivers losing access to food. Every cut to data and oversight makes it harder to prove what communities already know — that hunger is growing, not shrinking. 

SNAP has always been more than a nutrition program; it is a pillar of public health and economic stability. It reduces poverty, strengthens local retailers, and improves health outcomes for children, veterans, and older adults. Undermining SNAP does not save money; it shifts costs to hospitals, food banks, and city governments already stretched thin. 

During this moment of preventable crisis, the nation faces a simple question: Will we allow political gamesmanship to starve families in the wealthiest country on Earth or will we choose the moral and practical path of feeding our people? 

The courts have spoken. The money and resources (SNAP) exist. What remains to be seen is whether the administration will find the will to act.