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States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges [1]

['October', 'April', 'March']

Date: 2023-02

Since March 2020, states have been using temporary SNAP (food stamp) flexibility to provide emergency benefit supplements, maintain benefits to households with children missing school meals, and ease program administration during the pandemic. These options have allowed states to deliver more food assistance to struggling families, help manage intense administrative demands, and ensure that participants maintain much-needed benefits.

How to Find Out If You Can Get Help From SNAP SNAP eligibility is complicated. If you think you need help, the best thing to do is apply. Find your state’s online application and telephone number

Find a local food bank for immediate food help Notes: Sometimes states use a different name for SNAP, like the Food Stamp Program, CalFresh, or food benefits. All states offer the program. SNAP has special rules and resources following natural disasters.

The far-reaching health and economic effects of COVID-19 and widespread business closures to limit its spread made it even more difficult for many low-income households to afford food and other needs. Data have shown a substantial number of families have reported difficulties affording adequate food and other basic needs at some point during the pandemic. SNAP is essential to helping these families put food on the table.

The Families First Coronavirus Response Act of March 2020 gave the Agriculture Department (USDA) authority to let states temporarily modify procedures to make it easier for families to continue participating in or apply for SNAP. Many of those temporary changes were extended by subsequent legislation and administrative action. Also, Families First temporarily suspended, nationwide, SNAP’s three-month time limit on benefits for unemployed adults under age 50 without children in their home. In addition to provisions in the law, USDA encouraged states to use existing program flexibility to improve access to SNAP, such as by using online or telephone SNAP applications if they weren’t already, or allowing participants to stay on SNAP without reapplying for the maximum amount of time allowed under program rules. Families First also included a temporary boost of emergency supplementary benefits and school meal replacement benefits, which were also extended and strengthened by subsequent legislation and administrative action from the Biden Administration.

Benefit Enhancements

Families First included two ways for states to raise benefits for many SNAP participants and other households experiencing falling income and rising food needs:

Provide SNAP households with emergency allotments. States can give SNAP households emergency supplementary benefits; all states have used this option. (Originally, a Trump Administration interpretation of this Families First policy left out the lowest-income SNAP households from these benefits when states began issuing them in March 2020. The Biden Administration reversed this policy, and beginning April 2021 all households in states with these benefits have received emergency allotments of at least $95.) USDA may approve states to provide these benefits as long as the federal government has declared a public health emergency and the state has issued an emergency or disaster declaration. The Biden Administration has stated that the federal public health emergency will remain in place through at least October 2022. [1] Some states have taken steps toward ending or have ended their state COVID-related emergency declarations, and a number of states have ceased issuing allotments. [2] Households experience a significant benefit cut when these allotments end. Figure 1 below shows the months for which these allotments have been approved through August 2022. In addition to these allotments, the COVID relief package enacted in December 2020 included a 15 percent increase in SNAP’s maximum benefit for January through June 2021; the American Rescue Plan Act, enacted in March 2021, extended that increase through September 2021. This increase — which applied in all states and territories participating in SNAP — amounted to about $28 more in SNAP benefits per person per month, or just over $100 per month in food assistance for a family of four. Separately, and not related to the pandemic, in August 2021 USDA announced it had completed the congressionally mandated revision of the Thrifty Food Plan (TFP), the basis for SNAP benefits, which raised benefits for SNAP households in October 2021 (and for future years). This update, which will enable the program to provide benefits that more accurately reflect the cost of a healthy diet, raised the maximum SNAP benefits by 21 percent compared to what they would have been. Because the 15 percent SNAP benefit increase ended at the same time, in October 2021, households received a modest increase in their SNAP benefits. For example, a household of three receiving the maximum benefit (all households in states that are continuing to distribute emergency allotments) saw a $42 increase in October compared to September 2021, from $782 to $835.

Replace lost school meals through P-EBT. Families First allowed states to provide meal replacement benefits through SNAP, known as P-EBT, for households with children who attended a school that was closed beginning in the spring of 2020 for at least five days and who otherwise would have received free or reduced-price meals. Spring 2020 through September 2020: All states and territories eligible to provide these benefits (except for Guam) selected the option and issued these benefits by mid-summer 2020 to replace meals lost during the 2019-2020 school year. Families First allowed states to provide these benefits through fiscal year 2020 (which ended September 30, 2020), and 20 states chose to extend the benefits through August and September 2020 under this law. 2020-2021 School Year and Summer 2021: The government funding law enacted in October 2020 extended P-EBT through September 2021 and included some expansions, including extending the program to pre-school-aged children and to some territories originally left out of P-EBT.[3] The December 2020 COVID relief package included additional simplifications. The American Rescue Plan allowed states to continue their P-EBT program during the summers and through the remainder of the public health emergency for children who miss out on school meals because of the pandemic, as well as clarifying that the expansion to certain children under age 6 applies to all territories as well as states.[4] Also, the Biden Administration strengthened P-EBT benefits and issued guidance incorporating further simplifications. Nearly every state, Washington, D.C., Puerto Rico, the U.S. Virgin Islands, and the Commonwealth of the Northern Mariana Islands received approval and issued benefits for the 2020-2021 school year; most states were also approved to issue benefits for pre-school-aged children in addition to school-aged children. Almost every state was approved to provide benefits for summer 2021 to both school-aged children receiving free- and reduced-price school meals and children under age 6.[5] 2021-2022 School Year and Summer 2022: The Biden Administration also provided guidance for states to provide benefits for students in the 2021-2022 school year for students learning virtually due to COVID. Developing 2021-2022 state plans for school-aged children has been challenging for some states because they have to determine whether absences are COVID-related. USDA also issued updated guidance for child care plans that makes their approval fairly straightforward. For more detail on states’ implementation of P-EBT for spring 2022 benefits, see “States Have an Important Opportunity to Address Childhood Hunger This Summer.” Table 1 shows the states with current or past P-EBT adoptions. P-EBT benefits may be issued retroactively once states are approved. States can submit plans for approval at any time. P-EBT doesn’t require a state public health or emergency declaration, but it does require that a national public health emergency declaration related to the COVID pandemic be in effect during the school year.

While not through Families First, USDA also expanded access to a key flexibility for households to use their SNAP benefits. The 2014 farm bill created a pilot program for states to test the feasibility and outcomes resulting from allowing retailers to accept SNAP benefits for online food purchases. In 2019, New York became the first state to launch a pilot, joined by Washington State in January 2020 and three other states in March 2020 (Alabama, Iowa, and Oregon). All 50 states and the District of Columbia now have such a program. USDA lists the retailers that accept SNAP online.

SNAP Operations Waivers

Families First and subsequent legislation allowed states to temporarily adjust their operations to help manage their workloads and help participants gain and maintain access to the program. Nationally, the number of SNAP participants grew from about 37 million in February 2020 to about 43 million in June 2020. The number of participants has fallen since, but in March 2022, the most recent data available, more than 41 million people participated — 12 percent more than the number of participants in February 2020. State SNAP agencies have had to manage this greater volume through office closures staffing shortages, and other challenges due a remote work environment during the pandemic. These temporary adjustments have been critical to help state SNAP agencies process applications and help keep participants connected to the program, as many state agencies reported in a 2021 survey.

Some states began transitioning off these flexibilities in the second half of 2020, as USDA began approving fewer extensions, but the October 2020 government funding law restored many of these options. USDA has allowed states to extend these flexibilities through the month following the end of the national public health emergency, though states must confirm that their state public health emergency declaration remains in effect every three months. This guidance also encourages states to use these flexibilities as needed to aid in the transition to regular operations, such as by applying the flexibility only to a portion of the caseload or reducing the number of households affected by the flexibility each month.

Extend certification periods and adjust reporting requirements. SNAP participants get approved to receive benefits for a certain period, called a “certification period.” Ordinarily, every month a portion of SNAP participants must submit paperwork and complete an interview to continue receiving benefits when their certification period ends; this is called the recertification process. Participants must also update or report certain changes in their circumstances at different intervals, depending on the state. Most states requested and received this waiver through the initial months of the pandemic; some states stopped requesting waivers in the summer of 2020. Under December 2021 guidance, states may request to extend waivers available through the month after the month in which the federal public health emergency ends. Table 2 shows the expiration of states’ most recent usage of this option.

Waive interview requirements. SNAP rules require all households to be interviewed either in person or over the telephone by a state eligibility worker at initial application and usually at least once a year thereafter. This requirement can be an important way for states to gather accurate information and for applicants to have their questions answered, but it can be a labor-intensive task and delay approval. USDA has allowed states to dispense with the interview temporarily for many households, originally at both initial application and recertification, as long as state agencies verify identification and households provide mandatory verifications, such as of income. USDA also has allowed states to approve, without an interview, households that are entitled to shortened timelines for processing applications (known as “expedited processing”) due to their very low incomes and resources, provided that state agencies verify the households’ identity and attempt to contact them. Finally, USDA has allowed states to not offer in-person interviews and to waive the requirement that state agencies provide in-person interviews upon request from SNAP participants and applicants. There is evidence that some states apply these flexibilities only to some SNAP households. For example, a 2021 survey of state SNAP agencies found that most continued to conduct interviews for some households, such as when information was missing or incomplete, even when they waived the interview requirement. Over 40 states took up USDA’s spring 2020 nationwide waiver of the required interview at the application or recertification stage to ensure that newly eligible households can access food assistance through SNAP and that those already participating can remain enrolled. Many states began transitioning off the waivers, but the October 2020 government funding law allowed states to implement the original versions of the waiver through June 2021 without requesting USDA approval, and many states began using this flexibility again. Under the December 2021 guidance, states may continue this flexibility through the month after the month in which the federal public health emergency ends. Table 2 shows the states extending this flexibility.

Adapt telephonic signature requirements. Before the crisis, many states had implemented technology to let households apply for SNAP by phone, including using a stored telephonic signature. Current regulations require states to record verbal assent in an audio file to ensure that there is a record of applicants understanding and agreeing to information gathered and used by the state worker. The waiver allows states to take SNAP applications by phone by allowing a state eligibility worker to document the household’s attestation to the collected information on the client’s behalf without requiring a recorded signature. This temporary step has helped states process applications in the pandemic environment, where offices have been closed in many states and not all clients can access online applications. USDA has continued to allow states to extend this waiver, as shown in Table 2.

Before the crisis, many states had implemented technology to let households apply for SNAP by phone, including using a stored telephonic signature. Current regulations require states to record verbal assent in an audio file to ensure that there is a record of applicants understanding and agreeing to information gathered and used by the state worker. The waiver allows states to take SNAP applications by phone by allowing a state eligibility worker to document the household’s attestation to the collected information on the client’s behalf without requiring a recorded signature. This temporary step has helped states process applications in the pandemic environment, where offices have been closed in many states and not all clients can access online applications. USDA has continued to allow states to extend this waiver, as shown in Table 2. Use periodic report procedures instead of the more extensive recertification process. SNAP participants are required to provide updates about their circumstances at certain intervals; this is a much more streamlined process than recertification, which requires an application and interview. This option, included in the October 2020 government funding law, allows states to extend this flexibility for households due to recertify through the month after the month in which the federal public health emergency ends.

Other Administrative Options and Waivers

In addition to extending approvals for states to use flexibility under existing SNAP regulations, USDA has approved and extended other waivers under Families First that temporarily suspended administrative requirements for states, not shown in the tables below. USDA has continued to let states request these options through the month after the month in which the federal public health emergency ends.[6] USDA also had introduced some limited options in the fall of 2020 meant to transition states to regular operations, but because the October 2020 government funding law restored many flexibilities that had been previously offered, states stopped using those narrower options.[7]

In addition, USDA has approved waivers to modify aspects of states’ quality control processes. States must independently check the accuracy of household eligibility and benefit levels for a share of their cases each month. The process typically involves an in-person interview with households, often at their home. All states opted to use Families First’s flexibility to conduct quality control interviews by phone instead of in person, which USDA made available through June 2022. USDA approved state extensions of the waiver through June 2020 for 49 states, approved extensions of the waiver for all states through December 2020, and notified states in April 2021 that they could request this waiver through December 2021. Also, in March 2020 USDA gave all states and territories participating in SNAP an extension of the deadlines for reporting findings from households that were reviewed in December 2019 through February 2020. USDA subsequently allowed all states and territories participating in SNAP to suspend these reviews for March, April, and May 2020. Later legislation suspended many requirements related to these reviews for June 2020 through June 2021, when they resumed.[8]

TABLE 1 Pandemic EBT, as of August 16, 2022 State Provided benefits for households with children missing school meals in 2019-2020 school year1 (P-EBT) Provided P-EBT, August-Sept. 20201 Provided P-EBT to school-aged children, 2020-2021 school year1 Provided P-EBT to children under age 6, 2020-2021 school year2 Provided P-EBT, summer 2021 Provided P-EBT to school-aged children, 2021-2022 school year Provided P-EBT to children under age 6, 2021-2022 school year Provided P-EBT, summer 2022 Alabama X X X X X X Alaska X X X X Arizona X X X X X X Arkansas X X X X X X X California X X X X X X X X Colorado X X X X X X X Commonwealth of the Northern Mariana Islands3 X X X Connecticut X X X X X X X Delaware X X X X X X X X District of Columbia X X X X X X X Florida X X X X X Georgia X X X X X Guam X X Hawai’i X X X X X X X Idaho X X X* Illinois X X X X X X X Indiana X X X X X X X X Iowa X X X X Kansas X X X X X X Kentucky X X X X X X X Louisiana X X X X X X X Maine X X X X X Maryland X X X X X X X Massachusetts X X X X X X X X Michigan X X X X X X X Minnesota X X X X X X X Mississippi X X X* X X Missouri X X X X X Montana X X X X X X X Nebraska X X X X X X Nevada X X X X X X X New Hampshire X X X X New Jersey X X X X X X X New Mexico X X X X X X X X New York X X X X X North Carolina X X X X X X X X North Dakota X X X X Ohio X X X X X X X X Oklahoma X X X X X X X Oregon X X X X X X Pennsylvania X X X X X Puerto Rico3 X X X X X X Rhode Island X X X X X X X South Carolina X X X X X X South Dakota X X X X Tennessee X X X X X X Texas X X X X X X X Utah X X X X X X X Vermont X X X X X X X Virgin Islands X X X X X Virginia X X X X X X X Washington X X X X X X West Virginia X X X X X X X Wisconsin X X X X X X X Wyoming X X X X X Total 52 20 55 51 54 33 36 37

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[1] Url: https://www.cbpp.org/research/food-assistance/states-are-using-much-needed-temporary-flexibility-in-snap-to-respond-to

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