By Dillynn Buffington.
Why is SNAP Changing?
On July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) was signed into law. Subtitle A, “Nutrition,” makes substantial changes to the Supplemental Nutrition Assistance Program (“SNAP”), including how it’s run, who qualifies, and who funds the program.
Changes to How SNAP is Run
The first change made to SNAP by OBBBA is to the Thrifty Food Plan (“TFP”). The TFP is a theoretical market basket required to prepare a nutritious diet at home on a limited budget. The TFP is also the primary determinant of the amount of SNAP benefits a household receives. Prior to 2021, the only adjustments that could be made in a reevaluation were for inflation and had to remain “cost-neutral.” The Thrifty Food Plan, 2021 requires that reevaluations to the TFP market basket consider “current dietary guidance, consumption patterns, food composition data, and current food prices.” Ellen Vollinger, SNAP director, said that it was “long overdue” and “supported by a large body of research.”
The 2021 Reevaluation found a substantial increase—21%—in the cost of market baskets under the new factors. This reevaluation did not result in a cost-neutral increase in SNAP benefits, but instead reflected current dietary guidance and actual consumption trends. The OBBBA permits the reevaluation of market baskets to continue to be based on the same four factors as the Thrifty Food Plan, 2021, but requires all adjustments to remain “cost-neutral.” This means that as nutritional guidelines are updated and consumption patterns change, the amount of money received by SNAP users will only be adjusted for inflation again.
Changes to Who Qualifies for SNAP
In order to receive SNAP benefits an individual must meet work-related requirements, or be exempt. ABAWDs are required to work at least 20 hours a week, on average, in order to be eligible to receive SNAP benefits for more than three months over a 36-month period.
OBBBA has increased the number of people who must meet the ABAWD work requirements. Before OBBBA, people between the ages of 18-54 who did not qualify for another exemption were required to meet the ABAWD work requirements. OBBBA raises the age limit from 54 to 65, reflecting the administration’s desire to increase workforce participation. Additionally, OBBBA tightens the “without dependents” portion of ABAWD work requirement. OBBBA requires anyone with a dependent over the age of 14, previously 18, to meet the ABAWD work requirements.
Additionally, OBBBA has dramatically decreased what OBBBA calls “Alien SNAP Eligibility,” essentially eliminating eligibility for anyone who is not a US citizen or permanent resident. Prior to OBBBA, certain lawfully present aliens qualified for SNAP benefits, such as refugees, individuals granted asylum, certain American Indians born abroad, battered aliens, etc. They were eligible to receive SNAP benefits if they met all other SNAP benefit requirements and completed a five-year waiting period. The updated language allows only individuals who are US citizens or permanent residents (with minor exceptions) to be eligible to receive SNAP benefits, now excluding the groups listed in the prior sentence (and more). The National Immigration Law Center calls the changes “irresponsibly written.”
Changes to Funding
Finally, as OBBBA is implemented, funding will drastically shift away from the federal government to the states, decreasing federal financial involvement in the program. On October 1, 2026, the federal government reduced its federal reimbursement rate for administrative costs from 50% to 25% of the cost, effectively making states responsible for 75% of the administrative cost of SNAP.
Additionally, for the first time, states may be responsible for paying up to 15% of the SNAP benefits cost, depending on a state’s “error rate.” The definition of error rate includes both overpayment and underpayment rates determined “from data collected in a probability sample of participating households.” This will require states to invest more in SNAP operations to avoid paying for a portion of the benefits cost while simultaneously taking on more administrative costs. This has been called not only “counterintuitive,” but also a “cynical policy” by Stacy Dean, executive director of Global Food Institute’s Carbonell Family at George Washington University.
The most striking change to funding was the elimination of funding for the SNAP-ed Program at the end of 2025. Currently, the federal government emphasizes the importance of healthy meals and physical activity in reducing the risk of “obesity, type 2 diabetes, heart disease, certain cancers, and mental illness.” The SNAP-ed Program focuses on teaching individuals how to stretch their SNAP dollars, cook healthier meals, and lead physically active lifestyles. OBBBA completely eliminated federal funding for SNAP-ed, which has been helping families live healthier lives for over 30 years, essentially eliminating the program altogether.
What Does this Mean?
On October 1, 2026, there were major changes to how SNAP is run, who qualifies, and who pays for SNAP. As OBBBA is fully implemented, there may be a change to the effectiveness of enforcement, as states are asked to take on more costs while also increasing oversight to ensure accuracy. Finally, it is important to be aware of these changes and the effect they will have on certain groups of formerly eligible individuals.
I graduated from Arizona State University in 2024 with bachelor’s degrees in Economics and Urban Planning. After graduation, I worked as a Pricing Analyst at an aerospace company while preparing for the LSAT. I then returned to ASU to pursue my Juris Doctor and have thoroughly enjoyed the challenges and opportunities of law school. During my summer internship at a mid-sized law firm, I worked on matters spanning several practice areas, broadening my understanding of the legal profession and strengthening my practical legal skills.
