2025 reconciliation bill trims $186 billion through 2034; enrollment falls to 36.1 million, USDA moves to cut 6.3 million more, states take on 75% of administrative costs, and a judge blocks some penalties.
The Agriculture Department proposed a rule on November 10 that would end automatic SNAP eligibility for households that qualify through the Temporary Assistance for Needy Families program without meeting federal income limits. USDA estimates 6.3 million people, about 17.6% of everyone on the program, would lose benefits by fiscal 2029, along with automatic free school meal eligibility for 1.78 million children.
Enrollment was already 36.1 million in July 2026, the lowest in 17 years and down 5.5 million since July 2025, according to USDA data compiled by the Center on Budget and Policy Priorities. States have paid 75% of SNAP administrative costs since October 1, a federal judge in Oregon blocked some noncitizen penalties in September, and a second USDA proposal published November 10 would lock in the law's work-requirement changes. Both rules take public comment through December 10.
Why it matters
Millions of Americans have lost food aid as work requirements expand, and states now cover costs the federal government once paid.
The proposed rule would judge households by federal income and asset limits unless they receive TANF cash aid. USDA estimates 3.2 million households, about 6.3 million people, would lose SNAP by fiscal 2029, plus automatic school meal eligibility for 1.78 million children.
USDA proposes codifying expanded SNAP work requirements
Policy
A second proposed rule would set the age cutoff for the three-month time limit at 65, tighten standards for area waivers, and add temporary exemptions for Alaska and Hawaii. Comments run through December 10.
October 2026
SNAP enrollment falls to 36.1 million, lowest in 17 years
Data
USDA data compiled by the Center on Budget and Policy Priorities show participation down 5.5 million, or 13%, from July 2025, with declines in every state except Alaska. Child enrollment fell by 1.5 million across 28 states reporting data.
Michigan reports 167,000 residents dropped from SNAP
Data
About 167,000 Michiganders fell off SNAP since last summer, including 53,000 children. Michigan now pays 75% of administrative costs, expected to cost $95 million annually.
Senate Agriculture Committee proposes delaying state SNAP cost share
Legislation
The committee reported S. 5526, which would delay the first-ever state share of SNAP benefit costs by one year, to October 1, 2028, and raise the maximum state share from 15% to 20% beginning in fiscal 2031.
About 106,000 lost benefits because of work requirements, including 36,000 in Philadelphia. Children made up 29% of those cut.
USDA work-requirement page contradicts its own 2025 law guidance
Policy
The agency's consumer page says the work rule applies to ages 18-54 and lists veterans, homeless people and former foster youth as exempt, despite the law removing those exemptions.
New SNAP rules take effect for the fiscal year
Policy
Deseret News reports that expanded work requirements now apply to millions of recipients and states face new administrative and benefit costs.
States take on 75% of SNAP administrative costs
Policy
The federal share of running SNAP dropped from 50% to 25%, shifting roughly $17 billion in costs to states over five years under the One Big Beautiful Bill Act.
SNAP enrollment falls to about 36 million
Data
Participation dropped from about 42 million in mid-2025 to roughly 36 million as of June, per NPR. Most of the decline followed the 2025 law.
New SNAP asset limit takes effect for fiscal 2027
Policy
For fiscal 2027, SNAP restricts eligibility for households without an elderly or disabled member to savings or assets below $3,000, and to $4,750 for households with seniors or people with disabilities.
USDA proposes chip-enabled EBT cards in every state
Policy
The Food and Nutrition Administration proposed a rule requiring all states to issue chip-enabled EBT cards, citing card skimming that a ProPublica investigation found cost SNAP recipients $470 million in a year. Fewer than a third of states had switched or begun switching.
September 2026
Federal judge blocks SNAP penalties, clarifies immigrant eligibility
Legal
Judge Mustafa T. Kasubhai in Oregon sided with 22 states and DC, finding the USDA's October 2025 noncitizen eligibility guidance 'arbitrary and capricious.' The ruling affirms humanitarian immigrants can receive SNAP benefits once they get green cards.
February 2026
SNAP enrollment drops to 38 million
Data
Participation falls about 10% from roughly 42 million in June 2025 as eligibility restrictions and work requirements take hold.
January 2026
Utah soda ban takes effect
State Policy
Utah's House Bill 403 bars SNAP purchases of soft drinks, making Utah the first state with such a restriction.
July 2025
Reconciliation bill cuts SNAP by $186 billion
Legislation
Congress passes and Trump signs the 'Big Beautiful Bill,' expanding work requirements, restricting immigrant eligibility and cutting SNAP funding through 2034.
Scenarios
1
SNAP rolls drop below 35 million as work requirements expand
Likely
Resolves by Q3 2027
Discussed by: Congressional Budget Office and anti-hunger groups such as the Center on Budget and Policy Priorities
The expanded work requirements add roughly 5 million people to the pool of recipients who must work or train 20 hours a week to keep benefits. With waivers allowed only where unemployment exceeds 10%, more able-bodied adults hit the three-month time limit. Participation falls below 35 million by the end of fiscal year 2027.
2
States refuse the first-ever SNAP cost-sharing
Possible
Resolves by Q1 2028
Discussed by: state budget offices and the National Governors Association
In fiscal year 2028, states must begin paying a share of food benefit costs, a first in SNAP's history. Budget-strained states may delay or refuse to fund the required share, creating a standoff with USDA and forcing the agency to withhold or adjust payments. Some states may scale back their programs rather than pay.
3
Court blocks expanded SNAP work requirements
Possible
Resolves by End of 2027
Discussed by: legal challenges from civil rights and anti-hunger organizations
Advocacy groups and some states sue over the reconciliation bill's SNAP provisions, arguing USDA lacks authority to implement the expanded requirements or that the cuts violate statutory procedures. A federal court issues an injunction halting the work requirement expansion, at least temporarily, while the case proceeds.
4
Senate passes S. 5526 to delay state SNAP cost-sharing
Possible
Resolves by End of 2026
Discussed by: Senate Agriculture Committee, state budget offices
The Senate Agriculture Committee reported S. 5526 in October 2026, which would delay the first-ever state share of SNAP benefit costs by one year, to October 1, 2028, and raise the maximum state share from 15% to 20% beginning in fiscal 2031. If the full Senate passes it, states get more time to reduce error rates before paying benefit costs.
5
USDA finalizes the categorical eligibility cut
Likely
Resolves by End of 2027
Discussed by: Center on Budget and Policy Priorities, state SNAP agencies
USDA finalizes the November 10 proposal, ending automatic SNAP eligibility for households that qualify through TANF without meeting federal income and asset limits. Roughly 6.3 million people would lose benefits by fiscal 2029, and 46 jurisdictions would have to certify recipients under federal rules.
Historical Context
3 moments from history that rhyme with this story — and how they unfolded.
1 of 3
August 1996
1996 Welfare Reform (PRWORA)
President Clinton signed the Personal Responsibility and Work Opportunity Reconciliation Act, which imposed a three-month time limit on food stamps for able-bodied adults without dependents and barred most legal immigrants from receiving food assistance.
Then
Food stamp rolls fell by roughly half over the following decade as time limits and eligibility restrictions took hold.
Now
The work requirement became a permanent fixture, waived only during recessions and in high-unemployment areas.
Why this matters now
The 2025 reconciliation bill extends the same work-requirement logic to far more recipients and again restricts immigrant eligibility.
2 of 3
February 2014
2014 Farm Bill SNAP Cuts
Congress cut about $8.6 billion from SNAP over a decade, mostly by closing the 'heat-and-eat' loophole that let households use utility allowances to boost their benefit amounts.
Then
Roughly 850,000 households in cold-weather states lost an average of about $90 a month in benefits.
Now
Benefit amounts became more sensitive to actual household utility costs.
Why this matters now
The 2025 bill again reduces how utility expenses are counted, cutting benefits for roughly 600,000 households.
3 of 3
December 2018
2018 Farm Bill Work Requirement Fight
House Republicans pushed to expand SNAP work requirements to recipients up to age 59; the provision was dropped in conference negotiations to secure enough Democratic support to pass the farm bill.
Then
SNAP was reauthorized without expanding work requirements, and Congress avoided a partial government shutdown over the issue.
Now
The fight showed that work requirement expansions lacked bipartisan support under regular order.
Why this matters now
The 2025 bill achieved through reconciliation what failed in 2018, bypassing the filibuster to make work requirements the central SNAP reform.
