SNAP Enrollment Declines by 2.5 Million After 2025 Law Adds Requirements, Shifts Costs to States, Study Reports

By Jacob Fischler, Pennsylvania Capital-Star

*Published: 2026-04-09*


A study published Wednesday by the Center on Budget and Policy Priorities (CBPP), a left-leaning think tank, reports that at least 2.5 million low-income individuals stopped receiving benefits from the Supplemental Nutrition Assistance Program (SNAP) shortly after President Donald Trump signed the One Big Beautiful Bill Act into law on July 4, 2025. The law introduced new eligibility requirements for the program, which serves about 41 million Americans, and shifted a portion of benefit costs from the federal government to states.

The study, based on U.S. Department of Agriculture (USDA) data and state agency records from July to December 2025, found that 6% of SNAP enrollees — or roughly 2.5 million people — were no longer receiving benefits by the end of 2025.

Arizona experienced the largest decline among states examined, with enrollment dropping 47%, affecting about 424,000 individuals, according to more recent state data cited by CBPP alongside 2025 USDA figures.

Full-year USDA data for 2025 showed an overall national decline of 3.4 million enrollees, or about 8% of the program's total. SNAP is funded federally but administered by states. Prior to the law, the national SNAP payment error rate stood at 10.93% in fiscal year 2024, resulting in more than $10.2 billion in improper payments, according to USDA reports. The new law ties states' share of benefit costs to their error rates, a change aimed at addressing such issues.

In response to the enrollment decline, a USDA spokesperson described it positively in a late Wednesday email, stating that SNAP rolls had fallen below 40 million for the first time since the COVID-19 pandemic. "This change reflects several factors, including the most comprehensive work requirement reform since 1996, the One Big Beautiful Bill of 2025, as well as USDA initiatives that expand access to employment services, career and technical education, and case-management support through USDA’s More Than a Job campaign," the spokesperson wrote. The spokesperson added that the program would continue "to serve those with the greatest need while also strengthening program integrity."

The CBPP study did not aim to identify a single cause for the enrollment drop, according to co-author Joseph Llobrera, CBPP’s senior director of research for food assistance, in an interview. However, Llobrera pointed to provisions in the law that tie states' cost-sharing obligations to their SNAP "error rates" — the proportion of payments issued to ineligible recipients. This structure, he said, incentivizes states to limit program access without providing equivalent rewards for increasing enrollment.

"That motivates states to restrict access to the program," Llobrera said.

The decline occurred amid stable or worsening economic indicators, such as no significant drop in the national unemployment rate, according to the study. Researchers attributed the changes primarily to the law's provisions rather than improvements in participants' financial situations.

Several key elements of the law have not yet taken effect, including the error-rate-based cost penalties, which are scheduled to begin in fiscal year 2028.

Supporters of the law's SNAP provisions described the restrictions as intentional. The changes require more frequent eligibility reporting, expand work requirements, disqualify certain legal immigrants, raise the age of children at which parenting qualifies as work, and impose other eligibility limits. Proponents argued these measures would ensure benefits reach only eligible recipients and encourage states to reduce improper payments — a concern heightened by the pre-law error rate exceeding 10% and $10 billion annually.

The federal cost shifts for SNAP helped offset tax cuts and increased military spending in other sections of the bill, which Republicans passed via budget reconciliation without Democratic votes.

House Agriculture Committee Chairman Glenn “GT” Thompson (R-Pa.) defended the approach during last year's markup, stating: “It is a disservice to the truly needy to rely on SNAP. Clearly, SNAP is not working as Congress intended. We must ensure the proper incentives are in place for states to administer the program more effectively for those it serves.”

Llobrera acknowledged the arguments for tighter rules but said CBPP had warned at the time that the provisions could reduce access for eligible individuals. A spokesperson for Thompson did not respond to a request for comment Wednesday.

Arizona Case Study

CBPP's report featured a detailed analysis of Arizona, where SNAP enrollment fell more sharply than in any other state.

Economic factors did not account for the decline, the report stated. Arizona's unemployment rate increased during the study period, and grocery prices rose about 4% in 2025.

Arizona Gov. Katie Hobbs (D) and state agency officials have attributed the drop to the federal law. However, the decline exceeded what the law's immediate provisions would predict, suggesting state administrators — operating under Democratic leadership — implemented additional restrictions beyond federal minimums.

"A combination of factors, including the [law] and the state’s response to it, are contributing to the sharp decline in the number of Arizona families getting SNAP," the report concluded.

The law also reduced federal administrative funding for states, prompting some, including Arizona, to cut staff before implementation. "With the cuts to the administrative funding for states due to that [law], those are only just going to accelerate," Llobrera said.

Broader Context

The SNAP changes coincided with challenges from a record-long partial government shutdown in late 2025, during which benefits were intermittently disrupted. The Trump administration initially withheld funds, citing legal constraints, before federal courts ordered payments to resume.

SNAP enrollment had surged above 41 million during the pandemic due to expanded eligibility and economic hardship. The post-2025 drop to below 40 million marked the first time rolls returned to pre-pandemic levels, per USDA data, aligning with the agency's emphasis on work requirements and program integrity.

White House spokespeople did not respond to requests for comment Wednesday.

The CBPP study drew on USDA and state data to quantify enrollment trends, while USDA highlighted reforms as a factor in reducing what it views as over-reliance on the program. Ongoing implementation of the law's remaining provisions, including cost-sharing tied to error rates, may influence future participation rates.

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