The One Big Beautiful Bill Act and the Supplemental Nutrition Assistance Program (SNAP): What Counties Should Know

Counties, regardless of size, location or resources, are deeply committed to promoting the health and well-being of residents. Each day, counties deliver essential services that support vulnerable individuals and families, serving as a vital partner in the federal, state and local human services delivery system. County responsibilities vary by program and may 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, enrolling participants and more.

On February 25, NACo joined a bipartisan coalition of national organizations representing states, counties and cities in sending a letter to congressional leadership expressing concern over proposed changes to SNAP, TANF and SSBG. The letter followed recent budget reconciliation proposals that would enact significant cuts to these programs.  On May 21, NACo sent a letter to congressional leadership expressing concern over the proposed changes regarding SNAP to shift benefit and administrative costs through to counties and states. On June 5, NACo joined five state associations of counties in supporting over a dozen county leaders visiting Capitol Hill to advocate for county priorities and express concerns about the impacts on counties of proposed administrative and funding changes to SNAP.

On July 4, the One Big Beautiful Bill Act (P.L. 119-25) was signed into law, enacting major cost shifts to counties and states and making changes to how the program operates. This resource outlines the changes made to SNAP, and the anticipated impacts on county governments.

Counties and the Supplemental Nutrition Assistance Program 

As the largest federal nutrition program reaching nearly 42 million households, SNAP is a foundational part of the social safety net and has a significant impact on combating hunger and poverty in low-income households, particularly in rural communities. 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. 

In North Carolina and New Jersey, counties must meet the entire 50 percent non-federal match requirement for SNAP administrative funds, while in California, Colorado, New York, Minnesota, Ohio, Virginia and Wisconsin, the counties share this financial obligation with the state. Only in North Dakota does the state entirely fund this requirement. 

One Big Beautiful Bill Act (P.L. 119-21) Analysis

The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, and reduces federal funding for SNAP through FY 2034. Key highlights can be found below:

Benefit Cost Shift and Payment Error Rates

• Since the program’s establishment in 1964, the federal government has fully funded SNAP benefits. Under the OBBBA, states with payment error rates above 6 percent will pay a cost share that covers 5 to 15 percent, based on their payment error rate. States with a payment error rate under 6 percent will not be responsible for benefits.  
• States may use either their FY 2025 or FY 2026 payment error rate to determine their required match for FY 2028. For FY 2029 and beyond, the match is based on the payment error rate from three fiscal years prior.
• Generally, implementation will begin in FY 2028. However, if the payment error rate of a state in FY 2025 multiplied by 1.5 is equal to or above 20 percent, the implementation date will be FY 2029. If a state meets this criteria in FY 2026, implementation is pushed to FY 2030. Ultimately, states with the highest error rates will have delayed implementation.
• This provision raises major concerns for counties with the potential of states passing penalties to county governments, even when local offices are fulfilling their obligations to track and monitor recipients and benefit payments.

Administrative Cost Shift

Currently, the federal government covers approximately 50 percent of the administrative costs for SNAP. The OBBBA reduces the federal contribution to 25 percent and increases the state and local governments' share to 75 percent, starting in FY 2027. We estimate that this cost shift could increase administrative costs for counties by approximately $850 million annually.

Work Requirements

Under current law, Able-Bodied Adults Without Dependents (ABAWDs) must work at least 20 hours a week or participate in qualifying programs to be eligible for SNAP benefits and are limited to receiving SNAP benefits up to three months for failure to comply with these requirements. The OBBBA expands the definition of ABAWDs to include adults aged 18 to 64 (an increase from the current range of 18 to 54) and those with dependents ages 14 and up. Furthermore, the legislation reduces the flexibility for states to waive ABAWD work requirements in areas with high unemployment or limited job opportunities, even if local economic conditions warrant flexibility. Under the expanded definition and less flexibility for waivers, more people will be subject to work requirements, increasing the administrative burden on counties.