Fact check: Which 2023–2025 federal policy changes (including benefit recalculation rules) directly changed SNAP payment formulas or eligibility for fiscal year 2024 and 2025?

1. How routine cost‑of‑living updates immediately reshaped FY2025 benefits

The USDA’s annual SNAP Cost‑of‑Living Adjustment process produced the concrete payment formula changes that applied to fiscal year 2025: updated Thrifty Food Plan values drove new maximum allotments, standard deductions, and income eligibility thresholds effective October 1, 2024. The August 2024 memorandum issued the FY2025 COLA tables and explicitly adjusted monthly maximum allotments and allowable deductions, including standard and shelter deductions, and updated gross and net income limits for various household compositions; these are the primary administrative actions that directly changed benefit amounts and eligibility for FY2025 ^{[1] [2] [3]}. This administrative mechanism is the immediate lever by which SNAP benefit formulas move from one fiscal year to the next, and the memos are the operative documents implementing formula changes without new legislation.

2. The Fiscal Responsibility Act and work‑requirement shifts that set the 2023–2025 policy context

Congressional policy in 2023 altered SNAP work‑requirement mechanics and age thresholds, creating a policy environment that USDA later codified. The Fiscal Responsibility Act of 2023 expanded the ABAWD time limit and phased in an upper age-limit increase, changes that the USDA then incorporated into program regulations; counties and state administrators were required to adapt waiver strategies and enforcement practices accordingly. These statutory changes did not directly change the Thrifty Food Plan calculations but directly changed eligibility for many adults—by tightening or rephasing work participation rules—which in turn affected household eligibility and caseload composition for FY2024 and FY2025 ^[6].

3. The 2025 omnibus law’s explicit recalibration of how allotments are set

The One Big Beautiful Bill Act of 2025 introduced statutory modifications that go beyond routine COLAs by altering the mechanics for updating the Thrifty Food Plan and by establishing household adjustments for maximum allotments, with several provisions effective October 1, 2025. The law also amended administrative rules around work requirements, changing age exceptions and narrowing several categorical exemptions while adding geographic exceptions for Alaska and Hawaii; those statutory changes affect eligibility pathways and future benefit calculations by changing legal parameters the USDA must use when setting allotments and exemptions ^{[4] [5]}. While many of those changes are forward‑looking for FY2026 implementation, they represent direct legal changes to payment and eligibility formulas passed in the 2023–2025 window.

4. Administrative rulemaking in 2025 that reshaped program operation and eligibility

USDA’s revised SNAP rules issued in late 2025 aimed to implement legislative directives and to refine administrative criteria that impact benefit delivery and eligibility determinations. The rules adjusted income thresholds, streamlined application processes, and changed distribution schedules, and they codified updated exemption criteria and documentation standards that influence who is eligible and how benefits are calculated and distributed. These administrative changes are the bridge between legislative text and on‑the‑ground eligibility outcomes: when statutes change, the rules set the operational formula, and the 2025 rule package captured the combined impact of legislative changes and program priorities ^[7].

5. Where the evidence agrees, where it diverges, and what’s missing from these data

All sources agree that the FY2025 COLA memos (effective October 1, 2024) produced the direct technical changes to maximum allotments and income standards that constituted the payment‑formula changes for FY2025 ^{[1] [2] [3]}. They also consistently identify the 2025 omnibus legislation as the major statutory change reworking update mechanisms and work‑requirement exceptions ^{[4] [5]}. The main divergence is timing and scope: administrative memos are definitive for FY2025 allotment numbers, while the 2025 law primarily affects future update mechanics and eligibility categories, with several provisions phased in later. Notably absent in these documents are granular estimates of how many households had benefits increased or decreased purely because of statutory rule changes separate from the COLA tables, and there is limited empirical breakdown of state‑level waiver decisions post‑rule changes ^{[1] [4] [6]}.

6. Bottom line for policymakers and practitioners tracking FY2024–FY2025 changes

For FY2024 and FY2025, the immediate drivers of altered SNAP payment formulas and eligibility were the USDA’s FY2025 COLA memorandum and accompanying tables—these are the operational instruments that changed allotments and thresholds effective October 1, 2024—while the Fiscal Responsibility Act of 2023 and the One Big Beautiful Bill Act of 2025 changed statutory eligibility rules and update mechanics that reshape future allotment calculations and work‑requirement enforcement. Administrators must therefore track both annual COLA memos for immediate allotment calculations and subsequent legislation and rulemaking for structural changes to eligibility and update formulas ^{[1] [2] [3] [4] [6] [5]}.