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What specific SNAP funding changes were included in the 2025 continuing resolution?
Executive Summary
The 2025 continuing resolution included targeted changes to SNAP funding that Congress and the administration framed as both a short-term contingency and a policy shift: it added a roughly $3 billion contingency reserve for SNAP on top of fiscal year 2024 appropriations, and legislative changes accompanying the package tightened work requirements for able-bodied adults without dependents (ABAWDs) that take effect in November 2025. Legal and administrative moves amid a November 2025 shutdown produced disputes over how much of the contingency could be used for regular benefits, producing partial funding decisions and court interventions that altered planned benefit levels [1] [2] [3].
1. How much cash was set aside — the contingency reserve that reshaped short‑term SNAP math
The continuing resolution established a contingency reserve of about $3 billion for SNAP, which when combined with prior FY2024 appropriations created a reported pool of roughly $5–6 billion available depending on earlier administrative draws. Analysts and USDA legal memoranda debated whether the contingency language authorized using those funds for routine monthly benefit payments during a shutdown; previous administrations historically treated contingency funds as available for benefits, and congressional language in 2025 followed that precedent though precise availability fluctuated with state administrative-cost allocations in October [1]. The continuing resolution’s contingency fund became central to executive decisions in November 2025 about whether to pay full allotments, half allotments, or rely on judicial orders to compel full payment to states [4] [5].
2. What beneficiaries actually received in November 2025 — partial payments, courts, and USDA memos
The administration initially signaled a 50 percent maximum allotment approach for November 2025, then revised that to 65 percent after court rulings and internal memos from the USDA Food and Nutrition Service. A November 5 memorandum announced a drop to 65 percent of typical maximum allotments effective immediately, while federal judges ordered the administration to make full November payments to states in some cases, rejecting gambits to provide partial payments during a lapse in appropriations [6] [4] [7]. Independent reporting and agency statements documented an unprecedented partial-funding plan—using billions from contingency funds to cover only a share of monthly SNAP costs—and subsequent legal pushback that altered how much states could distribute to households [5] [4].
3. Policy shifts tied to the funding bill — work rules and eligibility changes in the One Big Beautiful Bill Act
Beyond immediate emergency funding language, the 2025 legislative package incorporated substantial policy changes tightening ABAWD work requirements, requiring roughly 80 hours per month of work, volunteering, or approved training for continued eligibility and narrowing exemptions. The reconciliation language removed some prior exemptions, added new definitions tied to Indian populations, and set stricter waiver thresholds tied to local unemployment metrics; proponents framed this as promoting “self‑sufficiency,” while critics warned it risks large-scale benefit losses for vulnerable low‑income adults, particularly in rural areas with scarce jobs [8] [3]. The work‑requirement provisions were enacted as part of the broader One Big Beautiful Bill Act and were slated to be enforced nationally beginning November 1, 2025, affecting an estimated 700,000–900,000 people [9].
4. Competing legal and administrative narratives — who can use contingency funds and how much
Legal reports and court rulings emphasized conflict between the administration’s interpretation and past practice: the USDA under the Trump administration initially argued contingency funds could not be used for routine benefits, prompting partial payments; legal analyses and a judge’s order reinstated prior understandings that contingency reserves could fund regular benefits, citing plain statutory language and historical precedent from prior administrations. This produced a tug‑of‑war where administrators sought to conserve contingency balances while courts and advocates argued statutory text and precedent permitted using the reserve to ensure full monthly allotments [1] [4]. The practical result was a shifting set of allocations—official memos, planned $5.25 billion draws, and judicial directives—that changed what households actually received in November 2025 [5] [2].
5. The political and operational fallout — states, food banks, and long‑term uncertainty
States and non‑profits faced immediate operational strain: some governors declared emergencies and redirected state funds to stabilize food assistance, while food banks braced for increased demand as federal benefit levels fluctuated. The partial‑funding plan and the enforcement of stricter work rules created administrative burdens—system changes, verification processes, and outreach—that could delay or reduce benefits for eligible households, particularly in states needing weeks to update systems to reflect new allotment tables or work‑verification rules [2] [9]. The continuing resolution solved near‑term appropriation gaps but embedded structural policy changes and legal ambiguity that guarantee ongoing debate and litigation over SNAP funding rules and benefits beyond November 2025 [1] [3].