The One Big Beautiful Bill Act (OBBBA) (Pub. L. 119-21) has ignited a debate about its effect on the Supplemental Nutrition Assistance Program (SNAP). While some have characterized OBBA as making “cuts” to SNAP, a more detailed analysis of the legislation reveals that it does not reduce the SNAP benefit amounts themselves. Instead, it alters eligibility criteria, imposes new work requirements, and modifies the program’s funding structure, which will indirectly lead to millions of people losing their benefits.
This distinction is crucial for understanding the true nature of the bill’s impact on food assistance. The question is not whether the OBBBA cuts SNAP benefits. It does not. The question is whether all of the people presently receiving or entitled to SNAP benefits should be.
The proper understanding of the OBBBA’s impact on SNAP benefits – that’s the topic of today’s post.
What is SNAP?
SNAP is a federal program that provides food-purchasing assistance to low-income individuals and families. The program was formerly known as “food stamps.” The USDA’s Food and Nutrition Service administers the program, with the benefits distributed and managed at the state level. The goal of SNAP is to help low-income households buy the food they need to maintain good health and nutrition. Benefits are provided on an Electronic Benefits Transfer (EBT) card, which works like a debit card. Recipients can use this card to buy eligible food items at most grocery stores, convenience stores, and even some farmers’ markets and online grocery delivery services. SNAP benefits can be used to purchase a wide variety of food items for the household, including fruits and vegetables; meat, poultry, and fish; dairy products; breads and cereals; snack foods and non-alcoholic beverages; and seeds and plants to grow food for the household. But SNAP benefits cannot be used to purchase alcoholic beverages or tobacco products; non-food items like pet food, cleaning supplies, paper products, or hygiene items; vitamins, medicines, or supplements, as well as hot, ready-to-eat foods from a store.
Eligibility for SNAP is based on a household’s income, expenses, and size. The specific requirements can vary by state, but most households must have both a gross monthly income and a net monthly income that is at or below certain percentages of the federal poverty level. In essence, those eligible for SNAP benefits do not pay federal income tax because their income is either beneath the filing threshold or it is offset by the standard deduction and available credits (such as the child tax credit).
How OBBBA Impacts SNAP
OBBBA does not directly decrease the amount of money a household receives for groceries. OBBBA does not change the Thrifty Food Plan (the basis for benefit calculations), nor does it lower the maximum benefit amount. However, it implements changes that will result in a significant number of households being disqualified from the program, thereby reducing federal spending on SNAP.
The bill’s key provisions that affect SNAP include:
1. Expanded work requirements (Section 10102)
The OBBBA extends work requirements to a broader range of individuals. Able-bodied adults without dependents (ABAWDs) are now subject to work requirements until age 64, up from the previous age of 54. Additionally, parents of children ages 14 and older must now meet work requirements to maintain their benefits. The bill also removes exemptions for veterans, those experiencing homelessness, and former foster youth.
2. Changes to alien eligibility (Section 10108)
The OBBBA narrows the list of non-citizens who can qualify for SNAP by amending the Food and Nutrition Act of 2008 (part of the 2008 Farm Bill) to significantly shorten the list of non-citizens eligible for benefits. It removes eligibility for groups that were previously qualified, such as refugees and asylum seekers, who are no longer able to receive benefits unless they meet stricter criteria, such as having U.S. lawful permanent resident status. The only non-citizens who remain eligible are U.S. lawful permanent residents, certain Cuban and Haitian entrants, and citizens of the Freely Associated States (COFA).
3. Altered funding structure: (Sections 10106 and 10107)
For the first time in SNAP’s history, a portion of the benefit costs is shifted to the States. Beginning in 2028, states with high payment error rates will be required to contribute a percentage of the benefit costs, a responsibility previously covered entirely by the federal government. This change is intended to incentivize states to tighten their eligibility and verification processes, further increasing the percentage of people who legitimately receive assistance. This provision reduces the federal government’s share of SNAP administrative costs from 50 percent to 25 percent starting in fiscal year (FY) 2027. This means states will be responsible for the remaining 75 percent of administrative costs, a major financial shift that is expected to place a significant strain on state budgets.
Also, for the first time in the program’s history, the OBBBA makes states responsible for paying a portion of the SNAP benefits themselves if their payment error rates exceed a certain threshold (generally 6 percent). The specific cost share for states ranges from 5 percent to 15 percent of the benefits they disburse, depending on the severity of their error rate. This provision is set to begin in FY 2028, with delayed implementation for states with exceptionally high error rates.
The OBBBA also ends mandatory funding for the Nutrition Education and Obesity Prevention Grant Program (SNAP-Ed), which provided funds to states for nutrition education and promoting healthy lifestyles among SNAP recipients. This funding is set to be eliminated at the end of the current fiscal year. This action aligns with a broader policy philosophy that states should have more control and financial responsibility for social programs. By eliminating the federal mandate, states are given the option to fund and design their own programs based on their specific needs and priorities.
The Misleading Nature of the “Cuts” Narrative
The use of the word “cut” suggests a direct reduction in a program’s funding or a decrease in the benefits provided to current recipients. In the case of the OBBBA, the bill’s changes don’t fit this definition for both Medicaid and SNAP. With respect to SNAP, OBBBA reduces the number of eligible recipients through policy changes. This will lead to a decrease in overall federal spending on SNAP, but it does so by making it harder for people to qualify, not by directly lowering their benefits.
The Congressional Budget Office (CBO) estimates that the changes will lead to a reduction of approximately $186 billion in federal SNAP spending over the next decade. These savings will not come from reducing the amount of food assistance for those who remain eligible but from an estimated 2.9 million people losing their benefits entirely due to the new rules.
While the bill does not “cut” benefits in the traditional sense, the outcome is the same for those who lose their eligibility: a complete loss of food assistance. The distinction lies in the mechanism: it’s a policy change, not a reduction in the value of the benefit itself. This nuanced understanding is essential for a productive public discussion about the bill’s actual impact on food security in America.
Verification of Eligibility
The OBBBA, along with a related executive order, mandates that states provide the USDA’s Food and Nutrition Service (FNS) with comprehensive data on SNAP applicants and recipients. This includes:
- Identifying information: Names, dates of birth, Social Security numbers, and residential/mailing addresses for all household members.
- Income records: Data on earned and unearned income, and information on absent parents used for the eligibility determination process.
- Transactional records: Data sufficient to calculate the total dollar value of SNAP benefits received over time, with the ability to filter by date ranges. The USDA also wants data on SNAP usage and retailer information.
The stated purpose of this data sharing is to enhance program integrity and combat waste, fraud, and abuse. According to the USDA, this allows the federal government to have “unfettered access to comprehensive data” that was previously held only by states and Electronic Benefits Transfer (EBT) processors.
The legal basis for the requirements for states regarding SNAP data is rooted in the “Spending Clause” of the U.S. Constitution. The Spending Clause (Article I, Section 8, Clause 1) gives Congress the power to “lay and collect Taxes, Duties, Imposts and Excises, to pay the Debts and provide for the common Defence and general Welfare of the United States.” The Supreme Court has interpreted this to mean that Congress can attach conditions to the money it gives to states, as long as those conditions are related to the federal program being funded.
SNAP is a federal program that is administered by the states. The federal government provides the majority of the funding for SNAP benefits. Since Congress is the source of funding, it can set the terms for how that money is used.
The Supreme Court has held that Congress must provide states with “clear notice” of the conditions they are accepting when they choose to participate in a federal program. The OBBBA explicitly lays out the new requirements for data sharing and the associated financial penalties for states that fail to meet them. By continuing to accept federal SNAP funding, states are implicitly agreeing to these new terms. The conditions Congress places on federal funds must be related to the program’s purpose. In the case of SNAP, the stated purpose of the data sharing and financial penalties is to improve program integrity and reduce waste, fraud, and abuse. This is considered a legitimate and related purpose to the administration of the SNAP program.
While some provisions of the OBBBA have faced legal scrutiny and temporary injunctions, particularly those related to federal funding for certain healthcare entities, the core requirements for states to provide SNAP data for program integrity purposes are generally seen as legally sound under the Spending Clause.
Multiple state attorneys general have filed a lawsuit against the federal government, specifically targeting the U.S. Department of Agriculture (USDA), over the SNAP data requirements contained within the “One Big Beautiful Bill Act” (OBBBA). The lawsuit’s primary goal is to obtain a court order to block the USDA from its demand for data and to prevent the federal government from withholding SNAP administrative funds from states that refuse to comply. The states are seeking a court declaration that the data demands are unlawful, primarily due to alleged violations of privacy laws and the absence of a public notice and comment period before implementing the new requirements.
However, at least one state attorney general has taken the opposite approach by suing their own state’s executive branch to force them to comply with the federal request. The most prominent example is in Kansas, where the Attorney General has sued the Governor. The lawsuit argues that the Governor’s refusal to provide the requested SNAP data to the USDA is putting Kansas at imminent risk of losing federal funding for its SNAP administrative costs. He asserts that the governor is “flagrantly violat[ing] the law” by not complying with the federal data request, which he views as a lawful requirement under the OBBBA. The lawsuit seeks to compel the governor to disclose the information, arguing that her refusal is an “unlawful” and “absurd” action based on a “lawsuit of dubious merit in a distant jurisdiction” (referring to the multi-state lawsuit filed against the USDA).
Conclusion
The policy change in the OBBBA with respect to SNAP benefits is just that – a policy change in terms of who is entitled to receive the benefits. Polls show significant support for non-citizens, particularly those in the U.S. illegally, not being entitled to use taxpayer dollars.
Indeed, a December 2024 fact sheet from the Pew Research Center on “Government aid to immigrants in the U.S. illegally” provides relevant data. The poll found strong disapproval for aid to illegal aliens: 78 percent of respondents said that such persons living in the U.S. illegally should not be eligible for this type of assistance. In comparison, only 20 percent said they should be eligible. That same poll also showed bipartisan support for limiting aid to illegal aliens. A majority of both Republicans and Democrats, including 93 percent of Republicans and Republican-leaning independents and 64 percent of Democrats and Democratic-leaning independents, said that illegal aliens should not be eligible for government assistance.
Similarly, a nationwide survey conducted by the firm Excellence in Polling published on May 13, 2025, in a report titled “Voters Support Reforms to Preserve Food Stamps for the Truly Needy.” of likely voters, found that 71 percent supported “requiring able-bodied adults with no young children at home to work, train, or volunteer at least part time as a condition of eligibility for food stamps.”
This support was strong across the political spectrum, including majorities of Republicans (83 percent), Democrats (70 percent), and Independents (77 percent).
Farmdoc Daily (University of Illinois), in a 2013 poll, found that almost three-quarters of respondents (72.67 percent) supported the decision to separate the SNAP program from the rest of the farm bill, and there was high support for “paternalistic changes to the SNAP program... encouraging work.” The policy argument for these changes often relies on the belief that a temporary safety net should not create a long-term “trap of dependency,” and that requiring work or work-related activities promotes self-sufficiency, dignity, and a stronger economy.
The U.S. has a significant national debt, and tightening up SNAP so that benefits are paid to those that are present in the U.S. legally and are truly needy is a good step in the direction of trying to eliminate waste and fraud in government programs while simultaneously shifting more cost responsibility to the states to allow the programs to be better tailored to the unique needs of recipients in the respective states.
