USDA proposes requiring local SNAP agencies to update benefit transfer card security measures

Key Takeaways

On Oct. 23, the U.S. Department of Agriculture (USDA) Food and Nutrition Administration (FNA) released a notice of proposed rulemaking (NPRM) titled “SNAP Electronic Benefits Transfer (EBT) Card Security Measures”. The rule proposes multiple measures intended to reduce fraud, including requiring local Supplemental Nutrition Assistance Program (SNAP) agencies to upgrade EBT card with chip technology.

Background

SNAP is the largest federal nutrition program, serving approximately 42 million households annually. H.R. 1, signed into law July 4, 2025, included changes to the program reducing federal support for the administration of the program and introduced new responsibilities for state agencies to contribute to the cost of SNAP benefits. Counties are responsible for administering the program in ten states: California, Colorado, Minnesota, New Jersey, New York, North Carolina, North Dakota, Ohio, Virginia and Wisconsin. These states represent approximately 34 percent of total participants, or 14.6 million people.  

The Oct. 23 NPRM continues federal initiatives to improve the program’s security and accuracy by creating SNAP Electronic Benefit Transfer (EBT) Operating Standards, updating household training requirements for SNAP participants and requiring local agencies to update EBT cards with chip technology. So far, seven states have chip technology in their SNAP benefits cards and 11 are currently planning to implement the change.

What does this mean for counties?

County responsibilities for SNAP vary by state and can include contributing administrative funding, determining eligibility, delivering services or contracting with providers, managing program funds, meeting Maintenance of Effort (MOE) and nonfederal share requirements, collecting data and enrolling participants.

As the result of a final rule, counties responsible for administering SNAP may need to update local procedures, coordinate card replacement efforts and assist residents experiencing difficulties during implementation. 

The NPRM does not include supplemental funding to assist with the transition and comes as counties are preparing for substantial increases in our share of administrative costs as a result of H.R. 1. 

Next steps

As USDA moves forward with the rulemaking process, counties should assess how the proposed security requirements could affect local SNAP administration, including technology needs, staff training and implementation costs.

The deadline to submit comments is Dec. 22, 2026. Counties are encouraged to coordinate with their state agencies to identify potential challenges and communicate the resources needed to implement updated security standards without disrupting access to benefits.

NACo will continue to monitor the proposed rule and engage with USDA to ensure that efforts to strengthen SNAP program integrity account for the administrative and financial responsibilities of county governments.