December 20, 2024
The bottom line: SNAP recipients will receive their January 2025 payments, even if a government shutdown occurs.
Background on 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 their 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, tonight, as the previous continuing resolution extended funding through December 20, 2024. If by December 20, 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, this includes 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 updated its contingency plan stating 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 under the continuing resolution. More importantly, Food and Nutrition Service’s updated accounting process 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, January benefits are obligated in December. Accordingly, there is no need for SNAP recipients to worry about missing their January payments if a shutdown were to occur.
Impact of a Shutdown
If a shutdown were to occur and continue past mid-January, USDA may utilize its contingency reserve funding to cover SNAP costs. If, however, USDA fails to instruct states to proceed with transmitting the necessary electronic files in order to timely issue February benefits, February SNAP benefits may be delayed or interrupted entirely. This is due to the internal processing of states that varies across the country. All states have a date they have determined when they must start the process to timely issue the upcoming month’s SNAP benefits to recipient households. If any state misses that deadline to begin the issuance process on that date, harm to households is almost certain to occur, as benefits to individual households will be delayed.
Take Action
Contact your Members of Congress now and let them know how millions of individuals with low incomes will be affected if there is a government shutdown. If there is a shutdown, engage with policymakers to urge them to quickly pass a CR so SNAP benefits will remain uninterrupted.
