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Center on Budget and Policy Priorities Founder and President and past U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) Administrator Robert Greenstein, Center for Law and Social Policy Executive Director Olivia Golden, Georgetown University Law Center Professor of Law and a Leg
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USDA Proposes Rule Tightening SNAP Eligibility Via TANF Link

The US Department of Agriculture on Tuesday proposed a sweeping rule that would sharply tighten who can qualify for food stamps through state welfare programs, a change critics warn will push millions off the Supplemental Nutrition Assistance Program, or SNAP.[1]

The proposal, published Tuesday, Nov. 10, would largely end states' use of so-called "broad-based categorical eligibility," which now lets many households qualify for SNAP automatically if they receive certain non-cash benefits funded by Temporary Assistance for Needy Families (TANF), such as childcare or job training.[1] USDA estimates that by the first full year in 2029, about 3.2 million households including 6.3 million people would lose SNAP because their income or assets exceed federal limits, cutting enrollment by roughly 17 percent and reducing federal benefits by $44.6 billion over five years.[1] The agency says the goal is to ensure SNAP serves "eligible Americans who need it most," but anti-hunger groups and congressional Democrats blasted the move as a fresh attack on food aid that will deepen food insecurity.[2]

Under current law, households that receive benefits from a state program funded by TANF are automatically eligible for SNAP, a linkage Congress wrote into the 1996 welfare overhaul that replaced Aid to Families with Dependent Children. As states began using TANF to fund non-cash services like informational pamphlets or referrals, USDA allowed those non-cash benefits to confer SNAP eligibility too, and starting in 2009 many states formalized this into broad-based categorical eligibility, or BBCE, often raising gross income limits up to 200 percent of the poverty line and dropping asset tests.[1] USDA says it actively encouraged BBCE under the Obama administration, and the number of state agencies using it grew from 18 to 43 between fiscal 2008 and 2011; as of December 2025, 46 of 53 agencies used BBCE and 41 did not check resources at all.[1]

The Trump administration tried in 2019 to narrow BBCE by requiring that households receive "ongoing and substantial" TANF benefits, but the Biden administration withdrew that proposal in 2021 and left the Obama-era policy in place.[1] The new rule goes further than the 2019 attempt by limiting automatic SNAP eligibility only to households getting TANF "assistance" as defined in federal regulations, meaning recurring, means-tested cash or certain ongoing benefits, not short-term non-cash help.[1] USDA argues that as BBCE expanded, the share of SNAP participants in households with income or assets above statutory limits rose from about 4 percent in 2010 to 10 percent in 2018 and 17.6 percent today, and it cites a 2012 Government Accountability Office finding that such households had much higher payment error rates than others.[1]

The proposal lands amid a broader shift in SNAP policy. A July 2025 budget fast-track law known by supporters as the "One Big Beautiful Bill" expanded SNAP work requirements and began shifting more administrative costs to states on October 1, with states also slated to take on a share of benefit costs tied to their payment error rates.[2] USDA figures cited by CBS News indicate that more than 5 million people have lost SNAP benefits since that law took effect, and House Agriculture Committee Democrats warn that adding the 6.3 million projected losses under the new rule would bring total cuts to about 11.8 million people.[2] USDA, by contrast, projects that the categorical-eligibility change would reduce state SNAP benefit transfers by $6.2 billion over five years while raising their administrative costs by about $928 million, a net $5.2 billion cut in state spending as states start bearing more financial risk for overpayments.[1]

Beyond loss of grocery benefits, USDA acknowledges the rule would ripple through other nutrition programs that piggyback on SNAP eligibility, estimating that about 1.78 million children would lose automatic free school meal eligibility starting in the 2028-29 school year, though it says roughly 97 percent would still qualify for free or reduced-price meals if their families submit applications.[1] About 42,000 children could lose Summer EBT benefits and 5,500 participants could lose Women, Infants, and Children (WIC) eligibility.[1] Katie Bergh, a food assistance analyst at the Center on Budget and Policy Priorities, argued on social media that more people would be cut off under this proposal than under the 2019 version because more states, including conservative ones like Ohio, have adopted or expanded BBCE as a way to ease benefit cliffs and encourage work rather than trap families in poverty. Conservative commentator Eric Daugherty welcomed the move, calling BBCE "a massive SNAP loophole" that lets people above income and asset limits, including possible millionaires, collect food stamps, while House Agriculture Committee Democrats and Rep. Angie Craig, the panel's top Democrat, say the administration is ignoring voters' post-election focus on affordability and rising grocery prices.[2]

USDA will take public comments on the proposed rule through Dec. 10 and expects any final version to take effect in 2029, giving states several years to rebuild asset tests and more stringent income checks that BBCE allowed them to bypass.[1] The agency highlights that in 2024 more than 840,000 one- and two-person households received only the minimum SNAP benefit through BBCE and says 94 percent of them would otherwise have been ineligible, framing that as a misdirection of limited aid.[1] Opponents counter that removing BBCE will add paperwork for families and states, increase churn as people cycle on and off benefits, and make it harder for state agencies to keep error rates and costs down just as Congress is penalizing them more heavily for mistakes.

  1. Federal Register
  2. CBS News
Federal Social Policy SNAP and Food Assistance U.S. Economy and Inequality
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📊 Relevant Data

USDA's regulatory impact analysis estimates that about 16.9% of participating SNAP households (17.6% of participants), or 3.2 million households with 6.3 million people, would lose SNAP in FY 2029, the first full year, because their income or resources exceed federal statutory limits. It projects $44.6 billion less in federal SNAP benefits over FY 2027-2031 and a net $5.2 billion cut in state SNAP spending.

Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility (proposed rule, 2026-22936) — Federal Register (USDA Food and Nutrition Service)

Per USDA, the number of states using broad-based categorical eligibility (BBCE) rose from 18 to 43 between FY 2008 and FY 2011. The share of SNAP participants in households over federal income or resource limits went from about 4% (FY 2010) to 8% (FY 2013) and 10% (FY 2018), and is now 17.6%. As of December 2025, 46 of 53 state agencies used BBCE, and 41 states did not assess resources at all.

Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility (proposed rule, 2026-22936) — Federal Register (USDA Food and Nutrition Service)

USDA estimates 1.78 million children would lose automatic (categorical) eligibility for free school meals, but about 97% would still qualify for free or reduced-price meals by applying: about 1.66 million would still get free meals, 93,000 would move to reduced-price and 28,000 to full price. It also estimates about 42,000 children could lose Summer EBT and 5,500 WIC participants would lose eligibility.

Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility (proposed rule, 2026-22936) — Federal Register (USDA Food and Nutrition Service)

USDA says more than 840,000 one- and two-person households received the minimum SNAP benefit in 2024 only through BBCE, and 94% of them would otherwise have been ineligible, about $214 million that year. It cites a 2012 GAO finding that BBCE households with incomes above federal limits had payment errors at 17.2%, versus 6.7% for other households (FY 2010).

Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility (proposed rule, 2026-22936) — Federal Register (USDA Food and Nutrition Service)

📌 Key Facts

  • On Tuesday, November 10, 2026, USDA published a proposed rule to restrict "broad-based categorical eligibility" for SNAP tied to non-cash TANF benefits.
  • USDA projects the change would reduce national SNAP enrollment by roughly 17% once implemented.
  • The rule would bar households above SNAP income thresholds from qualifying based solely on receiving non-cash TANF aid such as childcare or job training, with an effective date in 2029 after the rulemaking process.
  • More than 40 states currently use broad-based categorical eligibility to ease SNAP access and streamline administration.
  • Anti-hunger advocates say the proposal follows the July 2025 "One Big Beautiful Bill," which expanded SNAP work requirements and shifted more administrative costs to states, leading to more than 5 million people losing benefits.

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