OH, SNAP! Federal Policy Changes Threaten the Stability of Florida's Supplemental Nutrition Assistance Program
Executive Summary
Administered by the United States Department of Agriculture’s (USDA)’s Food and Nutrition Service (FNS), the Supplemental Nutrition Assistance Program (SNAP) provides funds to help low-income households afford low-cost, nutritious meals. In July 2025, President Trump signed the One Big Beautiful Bill Act of 2025 (the OBBB Act), tightening SNAP policies that determine eligibility, benefits, and program administration. Florida TaxWatch undertakes this independent research project to better understand how the upcoming changes in SNAP requirements will impact Florida’s budget and its ability to provide much needed food assistance to needy Floridians.
Before the OBBB Act, households equal to or below the 200 percent Federal Poverty Level were eligible for SNAP benefits. Certain groups, including non-citizens without legal status and postsecondary students enrolled at a college half-time or more, were excluded. Non-citizens with legal status must meet additional eligibility requirements, such as maintaining legal residency for at least five years. All benefit allocations are based on a low-cost, nutritious food plan designed by the USDA, referred to as the “Thrifty Food Plan.” The amount received by household varies by household size and income. Benefits are disbursed on Electronic Benefit Transfer (EBT) cards and are only accepted by certain grocery and convenience vendors.
Intended as a pathway to self-sufficiency, SNAP requires most recipients to meet established work requirements. Before the OBBB Act, the General Work Requirement required individuals aged 16 to 54 to participate in the SNAP Employment and Training Program or work at least 30 hours per week. Able-bodied adults without dependents (ABAWDs) aged 18 to 54 must also meet the Additional Work Requirement to continue receiving benefits after the initial three months. Both work requirements exempt certain populations.
In Florida, SNAP is administered by the Office of Economic Self-Sufficiency (ESS), housed within the Department of Children and Families (DCF). The guidelines for SNAP are flexible, allowing states to tailor the program in a way that best serves its residents. For example, the State of Florida opted out of a provision that disqualifies convicted felons from receiving SNAP benefits, in hopes of reducing recidivism rates, and adopted stricter work requirements than other states, mandating certain individuals participate in the SNAP Employment and Training Program and disqualifying entire households if one household member fails to satisfy their work requirements.
Over the past ten years, Florida’s participation rate has mostly hovered between 1.5 million and 2.0 million households. The counties with the most participants are typically the counties with the highest population count. Nationwide, Florida ranked 18th in SNAP reliance, with a participation rate of 12.7 percent of the total population (roughly one-in-eight Floridians).
In FY2023, Floridians received more than $6 billion of issued SNAP benefits, with the average benefit per person providing $191.06 per month. In the same year, Florida’s total administrative cost was $273 million; however, it is worth noting that the COVID-19 pandemic temporarily increased the demands upon SNAP and states received extra federal funding through the American Rescue Plan Act. In FY2019, before the pandemic, Florida’s administrative cost was almost $100 million less at $178 million. This cost was divided equally between the federal and state governments.
The FNS provides oversight to state activities by measuring four quality control indicators: (1) SNAP payment error rate; (2) the timeliness of application processing; (3) program accessibility; and (4) case and procedural error rates (CAPERs). In the most recent year with data, the SNAP payment error rate was above 15 percent, mostly due to overpaying SNAP recipients. Florida’s application processing rate was 64.38 percent, one of the lowest rates nationwide (47th). Florida scored 86 percent on the Program Accessibility Index, which is middling compared to other states. The state’s case and procedural error rate (CAPER) was 54.99 percent, which is higher than the national CAPER of 43.81 percent and results in Florida earning one of the lowest ranks nationwide (42nd).
The OBBB Act resulted in the following changes to SNAP:
- Limited the USDA’s ability to unilaterally change SNAP benefits by re-evaluating the Thrifty Food Plan and associated allotments;
- Removed and amended certain exemptions from the General Work Requirement;
- Created a tiered matching fund requirement for SNAP benefits that, for the first time, could require a state with a SNAP payment error rate higher than six percent to pay a portion of the SNAP benefits cost;
- Increased the state share of administrative costs from 50 percent to 75 percent;
- Ended mandatory (automatic) federal funding for the Supplemental Nutrition Assistance Program Education (SNAP-Ed); and
- Amended the list of non-citizens eligible for SNAP benefits.
The new OBBB Act requirements will cause a dramatic increase in state spending on SNAP, especially if Florida does not reduce its SNAP payment error rate. Florida is now responsible for 75 percent of its administrative cost, and it will be obligated to pay up to 15 percent of SNAP food benefits if the state does not reduce its SNAP payment error rate. If this policy were in effect in FY2023, the state would have paid more than $1 billion in SNAP benefits and administrative costs. These projected increases come at a particularly bad time. Although state budget estimators project a $3.8 billion surplus for FY2027, deficits of -$1.5 billion and -$6.6 billion are projected for FY2028 and FY2029, respectively.
On January 31, 2025, President Trump issued Executive Order 14192, entitled “Unleashing Prosperity Through Deregulation.” This order made it the policy of the executive branch to authorize greater flexibility in staffing arrangements for SNAP. Florida now has the opportunity to hire private contractors and non-profits to improve the administration of SNAP. Private contractors often have expertise, superior technology, greater staffing flexibility, and better risk management, all of which could enhance the quality of SNAP.
Without bringing in outside assistance, it is highly unlikely that the state of Florida can reduce the SNAP error rate to sufficient levels as to avoid significant financial penalties. Therefore, outsourcing this work will be money well spent.
Florida TaxWatch urges the state to take immediate action to procure a contractor to assist in reforming SNAP in Florida to reduce payment error rates and implement the new federal SNAP work requirements to avoid penalties.