Fact check: What is the process for terminating a federal program like food stamps?

1. How lawmakers, the White House and USDA Spar Over Who Can Pull the Plug

The first key claim is that ending SNAP requires action beyond a unilateral administrative decision in most circumstances, because SNAP is established by federal statute and ordinarily funded through congressional appropriations, with the USDA’s Food and Nutrition Service administering benefits via state agencies ^[1]. Reports from late 2025 show that when executive branch actors purport to suspend benefits—citing funding shortfalls during a shutdown or invoking contingency authority—states and advocacy groups immediately challenge the move, arguing statutory and regulatory constraints limit the USDA’s discretion and that contingency funds may or may not lawfully be reallocated ^{[3] [2]}. The political context matters: governors and attorneys general framed federal steps as policy choices with deep local consequences, while the administration defended its decisions on budget and operational grounds ^{[5] [6]}. These tensions underscore that termination involves constitutional, statutory and administrative-law issues as much as budget mechanics ^{[1] [2]}.

2. What the USDA’s Rules and Statute Actually Allow — and Don’t Allow

A central factual anchor is the Food Stamp Act and the USDA’s implementing rules, which create eligibility, benefit calculation, and administrative frameworks that states implement; those rules also limit what states may add and what the USDA may do absent clear congressional direction ^{[4] [1]}. USDA guidance explicitly says states cannot impose extra eligibility requirements or terminate cases simply because recipients did not spend benefits, emphasizing statutory protections for recipients and the federal role in setting core rules ^[4]. Recent USDA actions in 2025, including guidance and operational decisions during funding disputes, have been challenged as inconsistent with statutory intent and past agency practice, producing litigation that asks courts to decide whether the executive can suspend payments or must follow Congress’s funding priorities ^{[2] [6]}. The legal status of contingency funds and emergency authorities is therefore decisive: if available and lawfully used, they can keep benefits flowing; if not, suspension may occur, but it remains legally contestable ^[2].

3. Courts, States and Political Pressure: How Controversy Becomes Litigation

The most immediate empirical claim from late 2025 is that coalitions of states and local officials respond rapidly with lawsuits when SNAP is suspended, arguing that the administration exceeded its authority and that harm to vulnerable populations is imminent ^[2]. Coverage documents 25 states suing the administration over a SNAP freeze during a shutdown, asserting USDA had authority to use contingency funds or that statutory obligations required continued payments; these suits frame the dispute as both legal and humanitarian ^{[2] [3]}. Governors and attorneys general publicly criticized federal action, using press releases and emergency planning to mobilize state agencies and social services to mitigate impacts ^[5]. Courts are the decisive venue for resolving these disputes; precedent and statutory interpretation will determine whether the executive’s operational claims hold or whether congressional appropriations and statutory protections prevail ^[6].

4. What Ending Benefits Means Practically: Operational, Fiscal and Human Consequences

Beyond legal argument, the immediate effects reported show that suspension or termination produces sharp operational disruptions, including halted EBT disbursements, confusion at state agencies, and urgent need for alternative food supports, especially for children, seniors and people with disabilities ^{[5] [3]}. State agencies must scramble to inform recipients, adjust eligibility processes, and sometimes seek state-level emergency funding or charitable supplements; these responses highlight that program termination is not simply a legal event but a logistical crisis with fiscal ripple effects for states, nonprofits and local economies ^{[7] [3]}. Political actors frame these consequences to support their agendas: state officials emphasize constituent harm to pressure federal reversal, while proponents of cuts frame fiscal necessity or policy reform as justification for reductions or administrative changes ^{[5] [6]}.

5. Bottom Line: Legal Pathways, Political Calculus and What to Watch Next

The takeaway is that terminating a federal program like SNAP typically requires congressional action or a lawful executive funding determination, and any abrupt administrative suspension is likely to trigger legal challenges and political backlash, as seen in 2025 litigation and state responses ^{[1] [2]}. Watch for judicial rulings on the administration’s authority to use contingency funds, congressional maneuvers to restore or change funding, and state-level mitigation efforts; those outcomes will determine whether suspensions become permanent policy changes or are reversed. The evidence shows competing narratives—administrative necessity versus statutory overreach—each backed by different legal and policy claims, and resolving them will require courts, Congress, or negotiated executive remedies rather than unilateral administrative fiat ^{[6] [5]}.