Strategies for State SNAP Agencies to Mitigate the Hunger Cliff when Pandemic-Era Flexibilities End

By: Jillian Humphries, Policy Manager

Beginning in March, more than 25 million people began receiving less food assistance as the pandemic-driven temporary boost in Supplemental Nutrition Assistance Program (SNAP) benefits came to an end. Meanwhile, state agencies administering SNAP are preparing to revert to other pre-pandemic policies with the expiration of the federal COVID-19 public health emergency on May 11.  

The consequences of these changes stand to be enormous. Many SNAP households will experience a loss between $95 and $258 per month; some college students may lose access to food assistance entirely; and work requirements will be reinstated for eligible adults without dependents to maintain eligibility for SNAP beyond three months.  

There are ways that state agencies can help minimize the negative impacts of these changes, including by using strategies to streamline SNAP access during what will be a complicated and challenging time for many people receiving assistance, as well as the public servants who administer the benefit programs. BDT has been working closely with states nationwide to determine best practices, and below we share some of those strategies. 

Ease the Transition for Recipients and Staff 

During the public health emergency, the U.S. Department of Agriculture (USDA) provided many waivers and flexibilities, while also increasing the benefit amount in response to both inflation and a re-evaluation of the thrifty food plan used to determine appropriate allotment amounts. In addition to these USDA actions, states have had the option to provide households with a temporary, supplemental allotment of $95 or more, with 32 states utilizing this option. This flexibility expired Feb. 28, likely to cause surprise and hardship at a time when grocery prices have seen the largest 12 month increase since 1979. SNAP agencies can take actions to mitigate the impact of the decrease in SNAP benefits on participants by: 

  1. Evaluating all possible deductions and providing multiple avenues for SNAP participants to provide deduction verifications to make sure they receive the maximum amount of benefits they are eligible for. (See “Streamlining SNAP for the Gig Economy” for how to simplify self-employment deductions.) 
  2. Requesting the four waivers to support unwinding from the public health emergency, such as the option to adjust standard follow-up procedures when an enrollee’s address changes but they do not report a change to their shelter costs. This option could help decrease staff workload at an extremely busy time and keep the individual’s SNAP allotment at its current amount if shelter deductions after a move are unable to be verified right away.  
  3. Providing clear notices that explain the decrease in SNAP benefits to participants, which will also help reduce the number of phone calls to agency staff about the change.  

Help college students access food assistance 

After the end of the public health emergency (PHE), college students will no longer be able to qualify for SNAP based on the temporary rules, which include a $0 Expected Family Contribution or work study eligibility. Many will continue to qualify under regular rules that are returning, but those rules have proven complex for students and colleges to understand. To help eligible students maintain SNAP benefits, state agencies that administer SNAP can: 

  1. Ensure regular rules are not implemented too soon. States should continue applying the temporary rules to students submitting initial applications for SNAP or recertifying until June 10 (30 days after the end of the PHE on May 11.) Students are not required to report if they lose eligibility under the temporary rules mid-certification, so some may retain their benefits for up to several months after the PHE is lifted until they must recertify. 
  2. Provide additional staff training on all regular rules for students. Students who meet one of these rules can retain SNAP benefits even after the pandemic flexibilities end. The federal government has encouraged states to screen students who enrolled under the temporary rules to determine if they still qualify under the regular rules to ensure they don’t miss out on benefits they are eligible for.  
  3. Collaborate with colleges, advocates, and students to ensure they understand SNAP eligibility. Benefits Data Trust recently released a toolkit to help colleges identify students who are eligible for untapped public benefits, including SNAP and Medicaid. The toolkit shows colleges how to leverage the data they hold to find students who may continue to qualify for SNAP under the regular student rules, helping to mitigate the potential impacts of the end of the PHE.  

Help adults meet work requirements  

Before the pandemic, adults who do not have a disability nor children who are minors in their household could receive no more than three months of SNAP benefits over three years, unless they worked or volunteered for a specific number of hours per week. The Families First Coronavirus Response Act suspended the time limit rule in 2020, and it will be reinstated beginning June 30 with the end of the public health emergency. SNAP-administering agencies can take the following steps to support those looking for work: 

  1. Follow USDA guidance to “reset the clock.” These SNAP recipients can start fresh when the PHE ends.
  2. Waive the time limit in areas of high unemployment or low unemployment.
  3. Consider additional pathways for individuals to meet the work requirements necessary to receive benefits beyond three months. For example, individuals who lack access to adequate transportation to employment can be considered for a “discretionary exemption,” staying within the state’s individual discretionary allotment.