Published December 5, 2025

The nation is still emerging from the unprecedented disruption of the November government shutdown, during which the Trump administration refused to issue Supplemental Nutrition Assistance Program (SNAP) benefits despite having both statutory authority and sufficient contingency and reserve funds to do so. As a result, millions of Americans, including children, older adults, and people with disabilities, went weeks without the nutrition assistance they rely on to meet basic needs. Multiple courts ruled that U.S. Department of Agriculture (USDA) was required to issue these benefits, yet the administration continued litigating while families experienced hunger, financial distress, and prolonged uncertainty. Public polling found that a large percentage of Americans blame the administration for this failure. 

Against this damaged landscape, USDA  has revamped its effort to seek unprecedented access to five years of personally identifiable information (PII) on SNAP applicants and participants, and threatened to withhold not only administrative funding but, as stated by Secretary Rollins a few days ago, SNAP benefit payments themselves if states don’t comply. What is at stake is profound: the privacy of millions of households, the program trust among mixed-status households, the integrity of federal–state cooperation, and the foundational trust necessary for basic needs programs to operate during crises.  

USDA’s Data Collection Push: How We Got Here 

USDA’s data demand follows a March Executive Order directing federal agencies to eliminate “information silos” and obtain broad access to state-held data. Although framed as an administrative modernization effort, the order’s practical effect has been to support expanded immigration enforcement. Reports indicate that agencies, including the Department of Health and Human Services — Medicaid, Social Security Administration, and Internal Revenue Service, have shared sensitive beneficiary data with the Department of Homeland Security for purposes unrelated to program administration in order to target immigrants. 

Now, USDA seeks to develop a national SNAP information database, despite previously acknowledging that misuse of SNAP data would erode trust and depress participation. 

Litigation Timeline: A Rapid Escalation 

May 2025 — Initial Request and First Lawsuit: Palleck v. Rollins 

USDA issued its first directive ordering states to transmit extensive SNAP household data warning that failure to comply could trigger noncompliance procedures under 7 U.S.C. § 2020(g), including freezing or withdrawing administrative funding. 

SNAP participants and nonprofit organizations immediately challenged the order, arguing that it violated the Privacy Act and other federal protections. The court recognized serious concerns, including that USDA could face liability for misuse of the data.  

June 2025 — System of Record Notice 

USDA was forced to pause its request and issued a Systems of Record Notice, or SORN, for the proposed new data set, a step required by the federal Privacy Act of 1974 that allows the public to comment on the agency’s plan. 

July – October 2025 — Revised Guidance and Multistate Litigation 

In July, USDA issued new guidance reiterating its data demand, giving states a week to comply.  

Twenty-one states and the District of Columbia filed suit in State of California et al. v. Rollins, arguing that USDA had failed to follow mandatory privacy protocols. In October, the court granted a preliminary injunction (PI) blocking enforcement of the July demand and from instituting or continuing noncompliance proceedings against them. 

November 24 — USDA Targets Governors Directly 

Despite the injunction, USDA sent a new letter to the 21 governors instructing them to provide full data sets. USDA claims this November letter is a new action not covered by the PI. 

December 2 — Threat to Withhold SNAP Benefits 

During a Cabinet meeting, Secretary Rollins announced that USDA would withhold SNAP benefits from states that do not comply with the November directive — an extraordinary and legally questionable escalation. 

December 3 — Administrative Warnings 

A USDA spokesperson clarified on Wednesday that states must receive a formal warning before administrative funds are pulled. To date, USDA has issued no such warning. It is important to note that the noncompliance procedures under 7 U.S.C. § 2020(g) apply only to administrative funding, not to SNAP benefit amounts. As the nation saw in November, issuing benefits is a complex, multistep process that cannot be easily stopped or reversed. Setting aside the constitutional and legal flaws in Secretary Rollins’s argument, withholding benefits would require USDA to direct states not to transmit their monthly case files because USDA would refuse to approve the corresponding federal funding. This would be an unprecedented action. 

December 8 — Pending Response on Extending the PI 

Plaintiffs’ deadline to respond to USDA’s most recent letter has been extended until noon on December 8, 2025. 

What USDA Is Demanding 

USDA’s guidance requires states to provide nearly all PII they maintain on SNAP households, including: 

  • Social Security numbers 
  • dates of birth 
  • home addresses 
  • immigration-related codes embedded in case files 
  • application and participation histories going back five years 
  • data on individuals who applied but never received benefits 

USDA threatened sanctions for noncompliance. Moreover, half of the states, primarily those led by Republican administrations, have already submitted this information, meaning millions of records are now in federal hands despite ongoing litigation and unresolved questions about legality, privacy protections, and data security. 

Why the Demand Is Unprecedented 

In over 60 years of federal-state partnership, USDA has never required such a sweeping disclosure of personally identifying information. Federal law restricts USDA’s access to PII, and for decades, the agency has relied on anonymized data or small samples to perform oversight. In fact, USDA itself has long cited SNAP’s rigorous quality control system as one of the strongest among federal benefit programs. 

At the same time, advocates nationwide report a growing “chilling effect” as SNAP households, particularly mixed-status families, fear that personal information may be shared with immigration enforcement or misused for non-program purposes.  

Why This Matters for SNAP and Public Governance 

1. Data Security Risks

Centralizing sensitive data dramatically increases vulnerability to hacking, unauthorized access, and identity theft.

2. Undermining Program Integrity

USDA’s justification rests on “program integrity,” yet this approach contradicts decades of oversight practice and introduces new administrative risks. SNAP already maintains one of the strongest integrity systems in federal benefits administration.

3. Eroding Public Trust and Participation

Threats to privacy discourage eligible households from seeking assistance. This is especially harmful for families with children, older adults, immigrants, and people with disabilities.

4. Threatening Cooperative Federalism

SNAP’s success depends on federal–state partnership. Threatening benefit funds to compel data surrender destabilizes this structure and raises constitutional concerns. 

What Advocates Should Do Now 

1. Stay Informed and Share Accurate Information

  • Follow developments in Palleck v. Rollins and the multistate litigation. 
  • Provide families with timely updates from trusted advocacy groups, legal services organizations, and state agencies. 
  • Correct misinformation quickly, especially around eligibility, data sharing, immigration concerns, and confidentiality protections.

2. Support Households With Clear and Respectful Guidance 

  • Acknowledge that fear is real and valid. The administration’s actions have created genuine uncertainty, and families may make decisions based on their own risk assessments. Advocates must respect these decisions while providing accurate information. 
  • Individuals applying for benefits must provide Social Security numbers or immigration status for themselves, but non-applicants (such as undocumented parents applying on behalf of their children) do not need to disclose their own information. 
  • Household composition rules remain unchanged, including requirements for spouses and children under age 22 living with parents. 
  • Federal law restricts USDA’s use and disclosure of SNAP data, though recent federal actions raise concerns about whether these safeguards will be honored. 
  • Current participants should not feel pressured to withdraw; however, advocates should offer nonjudgmental support and help households weigh their food security needs alongside their safety concerns. 
  • New applicants, especially those whose information is already known to federal agencies, may face little additional risk by applying. Even so, the decision must remain with the household, grounded in their own circumstances and comfort level. 
  • Current public charge rules do not count SNAP. However, on November 19, DHS issued a Notice of Proposed Rulemaking that, if enacted, would rescind a rule put in place in 2022 that defines what could be considered in making a public charge.

3. Encourage Safe and Informed Practices

  • Apply online when possible and retain copies of all documents submitted. 
  • Double-check application details to reduce errors that could trigger unnecessary follow-up or verification. 
  • Share personal information only with official state SNAP offices or trusted community organizations. 
  • Because fear is real, advocates should work with recipients to develop individualized safety plans tailored to their family’s needs. This may include reviewing what information is already in state systems, identifying trusted points of contact, and clarifying the household’s comfort level with participation. 

4. Provide Practical Guidance for Mixed-Status Families 

  • SNAP remains available to U.S. citizens and many lawfully present immigrants. 
  • Non-applicant household members who do not wish to provide Social Security numbers or immigration status can be excluded from the case while eligible members still receive benefits. 
  • Warn families about scams and unauthorized preparers who may misuse their information.

5. Engage Policymakers and Monitor State Actions

  • Urge policymakers to oppose unlawful data collection and defend SNAP’s longstanding privacy protections. 
  • Ask state agencies to provide transparency about how they are responding to USDA’s demands. 
  • Encourage states to issue clear, reassuring public guidance to limit confusion and fear among participants. 

Defending Privacy, Integrity, and Access 

USDA’s unprecedented demand for all SNAP participants’ and applicants’ personal information, combined with threats to withhold administrative funds and now benefit payments, poses a direct risk to privacy, program integrity, and the well-being of millions of households. While ongoing litigation will shape the legal boundaries of federal authority, advocates must act swiftly to support families, correct misinformation, and defend the essential trust that underpins SNAP. 

Families depend on these benefits for their health and survival. No federal agency should weaponize access to food assistance to compel states into unlawful or unsafe data-sharing practices.