The Big Beautiful Bill has a SNAP Poison Pill

How states will get the blame for massive cuts to food stamps

There’s a poison pill in Trump’s “Big Beautiful Bill”, which will leave millions of Americans hungry. Changes to the Supplemental Nutrition Assistance Program (SNAP), colloquially known as food stamps, are projected to cause 4 million people to lose benefits—with 19 million more facing benefit cuts. And ominously, the Trump Administration just eliminated a survey of SNAP beneficiaries that would tell us the impact on these families’ access to food.

Why will so many vulnerable Americans lose their benefits? In short, both beneficiaries and states will be overwhelmed with new administrative burdens. In addition to cuts in the value of SNAP benefits, many beneficiaries will lose coverage because of added work requirements—which have been repeatedly shown to push eligible people off the program, but not improve labor force participation.

Others, however, will lose benefits because *state administrators* are facing new administrative burdens, which will push them to reduce their SNAP caseloads. The bill, by design, is forcing state governments to take the blame for millions of Americans going hungry.

What is the poison pill? Weaponizing an obscure administrative metric: error rates.

States will lose billions of dollars for making mistakes processing SNAP applications. Why? John Boozman (R-AR) and U.S. House Committee on Agriculture Chairman Glenn “GT” Thompson (R-PA) argue that states lack “accountability measures hardworking taxpayers deserve” and these changes ensure states “have a real incentive to improve oversight and stop improper payments before they happen.” It’s one example of the drumbeat of fraud that Republicans have been building to rip holes in the safety net.

In fact, Congress is punishing states for a problem it caused. Error rates are inevitable because Congress designed a policy that’s impossible to administer perfectly. Nevertheless, states will now pay between 5-15% of the costs of their SNAP budget if their error rates go above 6%. This will be enough to sink SNAP as a program in some states.

Eligibility guidelines are complicated—and especially so now with new work requirements. Beneficiaries’ incomes and work patterns are also complicated—their employment is unstable and often intermittent given how low-wage labor markets function. Moreover, their expenses, like childcare costs, are highly variable, but also critical to determining eligibility and benefit levels. The interaction, inevitably, leads to mistakes. Importantly, error rates also include procedural mistakes—like a missing form—even if the benefit is correct.

If Congress were serious about reducing errors it would help states manage the administrative costs required to reduce them. It also wouldn’t punish them for procedural mistakes that don’t impact actual outcomes. Instead, Congress is cutting states administrative budgets by 30% even as it made the program more complicated to administer. This is on top of the enormous administrative costs states are facing with Medicaid work requirements—and federal funding cuts—looming in the background.

State officials are being asked to do more with less, with catastrophic punishments if they fail. And many feel that they are being set up to fail.

Here’s a primer on what’s happening, and what it will mean for millions of vulnerable Americans.

SNAP is a critical support

To better understand the consequences for low-income families, it’s important to understand the scope and impact of the program. About 1 in 2 children will receive SNAP benefits at some point in their childhood and 1 in 4 children are receiving benefits in a given month. Program beneficiaries are largely either low-income families with children or disabled elderly adults. Nearly every SNAP beneficiary will risk facing drastic benefit cuts.

Drowning under a tsunami of new burdens and financial costs

States are being asked to absorb around $160 billion dollars in new spending to keep SNAP benefits stable. This is on top of the administrative costs—estimated to be around $65 billion over 10 years—that states will need to absorb with Medicaid work requirements.

First, states are being asked to pay considerably more for SNAP administrative costs—even as Congress has made the program more complicated to administer. States will now pay for 75%, instead of the current 50%, of overall program administrative costs. The addition of new work requirements, for parents with children aged 14 and older, homeless populations, veterans, and people aged 55 to 64, will add new administrative work for state SNAP agencies. Verifying employment is onerous and administratively costly. This new requirements expands the numbers of people that states must verify by the millions.

Second, states are being threatened with large penalties for administrative mistakes processing SNAP applications. Based on existing error rates, 43 states are expected to face these penalties. Two thirds of states are facing an increase to the tune of over $100 million a year.

SNAP error rates capture administrative mistakes, not just payment errors

You might be wondering: are errors a big problem? What do they really mean?

The federal government has a rigorous system to ensure SNAP payment integrity. It calculates an ‘error rate’ for each state, which also captures administrative errors.

How does this work? Each state draws a random sample of its SNAP beneficiaries, and then reevaluates their eligibility documentation. The federal government then reviews 50% of those cases. In part, the error rate captures how frequently, based on these reevaluations, states had made erroneous SNAP payments—too much or too little, including payments to people who didn’t qualify for benefits.

Importantly, the error rate also captures procedural errors—meaning it includes cases where the benefit was, in fact, correct, but where other mistakes were present, such as a missing signature or form. Starting in 2022, cases where beneficiaries were in fact deemed still eligible or were paid the correct benefit, were nonetheless deemed an ‘error’ if any of the paperwork was incomplete or included mistakes. Even if the state gets the outcome right, it can still be penalized for imperfect processes.

Traditionally, the federal government has been clear that these mistakes don’t reflect fraud or abuse. SNAP eligibility and benefit rules are highly complex, and it’s easy to make mistakes when policies are this complicated. For example, many states have complex rules for how the value of a car is calculated in the asset test, or what documentation is required to demonstrate employment for a work requirement. As noted on the SNAP federal website:

Payment errors are largely unintentional and may be on the part of the state agency or the SNAP household. For example, the state agency incorrectly calculates a household’s expenses, or a client forgets to provide the state with an update on their income.

A good rule of thumb for administrative processes is that every extra step or requirement is an extra opportunity to make a mistake. The complexity of how SNAP eligibility—and payment rates—are calculated inevitably leads to errors, especially given the highly variable income and expenses of low-income households.

The figure below provides a *simplified* overview of how benefits are calculated. Each box requires additional information and steps. For example, each deduction category (e.g. medical expenses) needs to be documented—and like earnings—is also highly variable. Eligibility guidelines include significantly more complexity—on top of determining income eligibility.

The figure below is just one additional part to the eligibility process for many beneficiaries, determining whether households are ‘categorically eligible’. More policy complexity, more administrative steps, more errors.

Which states will be hit hardest?

Most states have error rates that exceed the 6% threshold that Congress set. The map below shows the range of current error rates. Only 7 states have error rates that would protect them from paying for SNAP benefits. For those with error rates between 6-8%, 8-10%, and over 10% will pay a 5%, 10%, and 15% match rate for their SNAP benefits.

For example, Arizona would need to pay 15% of total SNAP benefits, which is around $24 million. Oregon is facing a $500 million dollar penalty over the biennium 2029-2031, as well as $150 million in new administrative costs. Arizona is estimating that it will need around $87 million to implement both the SNAP and Medicaid eligibility changes, just for new administrative costs.

Another way to look at this is how much state spending on SNAP will increase? The short answer: a lot. The slightly longer answer: a lot, to the point states will be pushed to curtail SNAP. The Georgetown Law Center on Law and Inequality ran an analysis that found that “states will have to spend two to three times more of their budgets on SNAP, with a median increase of about 202 percent. In 15 states, the share of the state budget required to fund SNAP will increase more than 300 percent.”

States will increase burdens for beneficiaries to manage their new financial costs

So what will states do? North Carolina’s Department of Health and Human Services told the New York Times that if the state did not provide the additional $14 million for new administrative costs and $420 million for benefits related to payment errors, they would “have to stop offering the SNAP program altogether.” Roughly 13% of North Carolina residents receive SNAP benefits, most of whom are either children, the disabled, or older adults with low incomes.

Other states will likely manage costs in other ways, particularly in ways that increase burdens for beneficiaries. In short, if you make it harder for people to receive benefits fewer people will receive benefits. Alabama is considering eliminating simplified applications for older adults—older adults are particularly likely to qualify for SNAP, but not receive benefits. The fraction of older adults eligible, but not receiving benefits, is typically between 35-40% in Alabama counties.

States have long tried to address error rates in SNAP programs, but a lack of sufficient staffing has been a key impediment. Notably, insufficient staffing and frequent re-certifications appear to increase error rates in the SNAP program. Given the complexity of SNAP eligibility guidelines, this is hardly surprising.

It’s unlikely, due to the budgetary pressures that states are facing given massive federal cuts, that most (or any) states will be willing to absorb meaningful increases in their SNAP spending.

Most states will instead, almost certainly, increase the burdens that beneficiaries face. The biggest new burdens will likely be substantial delays in processing applications. States will work very hard to avoid application errors—and they simply lack sufficient staffing to process applications quickly and correctly. Current rules require SNAP applications to be processed within 30 days. Very few states actually currently meet this standard—with rates as low as 48% in the District of Columbia and 39% in Alaska to mid-range performance such as 70% in Tennessee and 82% in California. Only two states process nearly all of their applications on this timeline.

Hiding the data

While we will be able to track how many people lose SNAP benefits, the federal government recently made sure that we won’t know the impact of these changes on SNAP’s primary programmatic goal: to ensure poor Americans have enough to eat.

The Trump Administration announced that it is terminating an annual survey to track food insecurity in the United States. The survey has been a critical tool to evaluate whether the SNAP program is actually meeting its programmatic goal.

By all accounts, SNAP has reduced food insecurity. The figure below provides an example of the evidence we have, from this survey, to document the program’s effectiveness.

The announcement for the cancellation of hunger data collection from the USDA reads like a Truth Social post. Labeling data as “subjective, liberal fodder” comes awfully close to Stephen Colbert’s “reality has a well known liberal bias” aphorism.

If you want to learn more about how this data is collected, and why the Trump claims are bogus, check out this post by Chris Dick and Beth Jarosz, who note that “there simply is no other source that provides comparably robust data on hunger and ability to afford food.” The reality is that without these data it will be very difficult to track how Trump administration changes actually affect the key statutory goal of SNAP— which seems to be the point.

Policymaking by other means, or how to blame states for child hunger

One way to think about President Trump’s “Big Beautiful Bill” is that it creates massive cuts to the safety net. Another way to think about it is that it reflects an effort to shift the blame for the effects of those cuts to state governments. The bill ensures that state governments will implement these policies in a way that is all-but-guaranteed to result in failure.

This is by design: H.R.1 is in one respect a very sophisticated piece of legislation: it uses administrative burdens strategically to worsen access to public services. A great deal of legislative ingenuity was directed towards making sure your government becomes more dysfunctional.

State governments, even those that want to protect their citizens, are left to engage in harm mitigation, choosing between the least worst among a series of bad options. They simply lack the administrative capacity and funding to ensure an outcome that doesn’t leave millions of people without the benefits to which they’re eligible and desperately need.