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How did SNAP eligibility rules change during COVID-19?
Executive summary
During COVID-19 federal and state actions temporarily broadened access to SNAP by suspending certain work requirements, issuing emergency allotments that raised benefit amounts, and creating temporary student exemptions — all implemented through waivers, statute, or administrative guidance [1] [2] [3]. States also used operational flexibilities (remote interviews, expedited processing, online purchasing pilots, and Pandemic EBT) to reach more people and simplify enrollment [4] [5] [6].
1. Suspension of work rules: a fast, nationwide safety net reset
Early in the pandemic the Families First Coronavirus Response Act and related federal actions effectively paused the SNAP time-limits and work-reporting rules for able-bodied adults without dependents (ABAWDs), allowing people who had “timed out” previously or could not meet work requirements to remain or become eligible during the emergency [1] [7]. State agencies reported this as a key change that removed administrative barriers and avoided immediate benefit losses while unemployment spiked [1].
2. Emergency allotments and benefit increases: money that changed the math of eligibility
Federal emergency allotments and temporary increases in maximum monthly benefits were issued during FY2020–FY2021 and drove a sharp rise in SNAP spending even beyond increases in participation; USDA economists attribute the spending surge largely to those benefit boosts and emergency allotments [2]. These changes meant eligible households received larger monthly allotments, with some states also providing supplemental or pandemic-related child supports through P-EBT [4] [2].
3. Student eligibility: temporary statutory exemptions expanded access
A federal law change made more postsecondary students temporarily eligible for SNAP during the COVID public health emergency; guidance noted the exemptions were effective during the emergency and would end within 30 days after the PHE is lifted, signaling these were explicitly temporary expansions tied to the emergency [3] [8]. USDA’s Food and Nutrition Service later issued memoranda preparing states for the end of those temporary student exemptions after the PHE ended [8].
4. Operational flexibilities: removing paperwork and in-person barriers
States and the federal FNS adopted many administrative flexibilities — such as telephonic signatures, remote interviews, expedited processing after income loss, relaxed verification or “good cause” provisions for missed child-support cooperation, and pilots for online SNAP shopping — to speed enrollment and recertification and limit in-person contacts [1] [5] [4]. Advocates and practitioners highlighted interview waivers, simpler recertification, and remote signatures as reforms that improved access and should be considered for permanence [5].
5. Pandemic EBT and categorical approaches: extending child nutrition supports
Pandemic EBT (P-EBT) was rolled out to replace school meal access when schools closed and in some cases provided substantial per-child monthly amounts; states sought approvals for P-EBT and some leveraged broader categorical categorizations to expand eligibility and support local economies [4] [9]. Policy briefs urged maintaining broader eligibility and streamlined access to child nutrition supports beyond the emergency [6] [9].
6. Variation across states and the role of waivers and guidance
While federal actions provided the legal and financial framework, states used waivers and administrative options unevenly; peer reviews and state surveys documented diverse adaptations and highlighted both successes and implementation challenges, meaning access and program experience varied by state [10] [5]. Open-source policy briefs noted states could use tools like broad-based categorical eligibility to further expand access if they chose to do so [9].
7. What changed temporarily vs. what returned to pre‑PHE rules
Sources make clear many changes were explicitly temporary and tied to the public health emergency: emergency allotments, student exemptions, and suspension of ABAWD time limits were pandemic-specific and subject to end once the PHE concluded; FNS issued guidance about ending student exemptions after the PHE ended [3] [8] [1]. Analyses recommend keeping some operational lessons (e.g., remote processes, online purchasing) but note fiscal and statutory constraints if policymakers do not make them permanent [5] [6].
8. Limits of available reporting and open questions
Available sources document the major federal flexibilities and state adaptations but do not provide a single exhaustive list of every state-by-state waiver or the precise timeline for every change; state-level program details and exact benefit dollar flows in every jurisdiction are not fully enumerated in these sources [10] [2]. For questions about current eligibility in a specific state or the status of particular temporary flexibilities after the PHE, state agencies and USDA FNS guidance are the authoritative places to check [8] [11].