Sustaining SNAP: Lessons Learned from Federal and State Actions 

As SNAP (Supplemental Nutrition Assistance Program) funding faced disruption during the recent prolonged federal government shutdown, emergency federal and state measures were implemented to prevent participants from losing critical nutritional support. Although SNAP typically remains operational during a budgeting freeze, in the most recent instance it continued only after a federal court on October 31 ordered the USDA to use contingency reserves for partial payments. Massachusetts Judge Indira Talwani emphasized that the USDA “is statutorily mandated to use the previously appropriated SNAP contingency reserve” when annual funding lapses, rejecting the agency’s claim that it lacked legal authority to do so. 

This mandate provided states with a total of $4.65 billion from the USDA contingency reserve to cover roughly 50% of eligible households’ November benefits, alleviating the worst impacts for program participants. Although the Supreme Court issued a temporary pause while it considered the Administration’s emergency request to stay the lower court’s ruling, Congress took intervening steps, officially reopening the government on November 12th. Despite the series of rulings, appeals, and temporary stays, SNAP was authorized for full funding across all states on November 7. 

In the absence of federal funding, and prior to the USDA’s confirmation of full SNAP funding on November 7, many states took decisive and measurable actions to safeguard SNAP beneficiaries—leveraging emergency declarations, reallocating funds, and providing supplemental support to ensure continued access to food assistance during a period of federal uncertainty: 

Declaring States of Emergency & Deploying Emergency Funds

• • Rhode Island officially declared a state of emergency under Rhode Island General Laws § 30‑15‑9(e), enabling the state to deploy resources to maintain SNAP benefits and support local food banks during federal funding shortfalls. The order authorized the use of TANF dollars to support food assistance efforts.  

• • New York declared a state of emergency through Executive Order No. 54 allowing state agencies to suspend or modify statutes and regulations, paving the way for redirecting state resources to ensure continuation of SNAP benefits.  

• • Maryland declared a state of emergency and announced the release of $62 million to ensure full November SNAP benefits for Marylanders. This sum was sourced using state resources, supplementing federal funds during the shutdown period.    

Directing Supplemental Payments to Recipients and Food Banks

• • Louisiana issued a press release stating that, in the event federal SNAP payments were eventually delayed, the state would provide emergency food assistance to vulnerable groups—elderly, disabled individuals, and households with children—starting November 1, 2025. 

• • Rhode Island authorized $200,000 to be distributed for direct emergency food bank support, ensuring continuity of benefits. 

• • Vermont authorized a transfer of $6.3 million from state reserves to cover the first 15 days of November SNAP benefits. Also, an additional allocation of $250,000 was also made to the Vermont Foodbank as a contingency measure.  

• • New Mexico offered $30 million in state funds, sourced from the state’s contingency reserves, to ensure SNAP recipients receive approximately 30% of their monthly benefits starting November 1, via existing EBT cards, amid the federal funding lapse.  

• • Maryland authorized $10 million in emergency grant funding to food assistance partners in Maryland. The Health Department utilized food security data to ensure resources were quickly dispersed to communities with the greatest needs.   

Efforts taken by states during the shutdown often required creative budgeting, with states drawing not only from emergency reserves but also reallocating funds from other social support programs. These actions reflect the commitment of state governments to protect vulnerable residents during a period of federal uncertainty. 

Now that the federal funding freeze has been lifted and full FY2026 appropriations are in place, states are no longer required to rely on emergency stopgap measures. USDA has directed agencies to resume normal operations, including full benefit issuance and standard administrative processes. These developments mark a return to greater stability for SNAP programs nationwide.