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Would the 2025 continuing resolution freeze SNAP benefit levels at FY2024 rates or allow cost-of-living adjustments in 2025?
Executive Summary
The 2025 continuing resolution itself does not need to be the vehicle for Supplemental Nutrition Assistance Program (SNAP) cost-of-living adjustments (COLA); USDA rules and an FY2025 COLA memorandum established increases to SNAP maximum allotments, income eligibility standards, and deductions effective October 1, 2024, meaning benefit levels for FY2025 were set to reflect COLA increases independent of a short-term funding measure [1] [2]. However, recent legal and shutdown-related developments in late 2025 introduced uncertainty about benefit delivery and emergency funding, and the continuing resolution’s language and the Administration’s use of contingency reserves or transfer authority can affect whether beneficiaries actually receive those adjusted payments on schedule [3] [4] [5].
1. Why USDA memos mean the CR didn’t have to “freeze” SNAP — the technical mechanics explained
USDA routinely issues a SNAP Cost-of-Living Adjustment memorandum each year to set maximum allotments, income eligibility standards, and deductions for the coming federal fiscal year, and the FY2025 COLA memo finalized those changes effective October 1, 2024. Those administrative COLA determinations are separate from appropriations language and are implemented by the Food and Nutrition Service under existing statutory authority, so a continuing resolution that simply extends FY2024 funding levels does not automatically erase COLA-set benefit amounts [1] [2]. The USDA’s public guidance confirms that maximum allotments and eligibility thresholds are adjusted at the start of each fiscal year based on cost-of-living changes, which is why beneficiaries saw FY2025 rates based on the COLA even absent a full-year appropriations bill [6]. That administrative separation means the correct technical answer is that COLA adjustments for FY2025 were not contingent on a clean CR vote.
2. Political and practical friction: why a CR can still affect recipients despite COLA rules
Even though COLA decisions set benefit formulas, a continuing resolution can affect the timing and completeness of payments because appropriations and cash flow determine whether USDA and states have funds on hand to make monthly issuances. During a lapse in full-year appropriations or a government shutdown, the Administration can rely on contingency reserves, legal transfer authority, or emergency appropriations to cover SNAP, but those are not automatic and have limits; recent analysis noted the contingency reserve’s availability and the Administration’s legal options to transfer funds, highlighting operational vulnerability during funding gaps [3] [7]. Reports during the 2025 shutdown described plans for partial payments and emergency measures, underscoring that even if COLA raised the statutory benefit level, actual receipt of adjusted benefits can be disrupted by funding and administrative decisions [4].
3. Court orders and emergency actions changed the landscape in November 2025
Late in 2025, federal litigation and judicial rulings directly affected SNAP delivery: a judge ordered the Administration to fully fund SNAP benefits for November 2025 amid a shutdown, and higher courts temporarily altered or reviewed such orders — developments that demonstrate judicial intervention can override or compel executive funding decisions in the short term [5] [8]. Those court actions do not amend USDA’s COLA determinations, but they do indicate that legal rulings became a decisive factor in whether beneficiaries received payments when appropriations were in dispute. Reporting from November 2025 shows that the practical outcome for recipients hinged on emergency funding moves and court timelines, not on whether the CR text explicitly allowed COLA increases [9] [5].
4. Two coherent, opposing interpretations claimed publicly — and where agendas appear
One interpretation, grounded in USDA guidance and the FY2025 COLA memo, holds that SNAP benefit levels for FY2025 reflect COLA increases regardless of a CR because the program’s administrative adjustments are set before the fiscal year and operate independently of temporary funding resolutions [1] [2]. An opposing, politically consequential interpretation emphasized by some policymakers and media focuses on appropriations and shutdown mechanics: a CR that freezes funding at FY2024 rates could create bottlenecks that delay or reduce COLA-adjusted payments in practice, a framing often used to pressure for emergency appropriations or to assign blame for benefit interruptions [4] [7]. Both positions are fact-based: one points to statutory-administrative mechanics, the other to cash-flow and operational realities; the latter framing sometimes carries a political agenda to magnify the immediate harms of a shutdown.
5. Bottom line for policymakers, advocates, and beneficiaries — what matters now
For policymakers and advocates, the crucial distinction is between statutory benefit levels set by USDA COLA memos and the funding mechanisms that ensure timely delivery. The FY2025 COLA was issued and establishes higher allotments and thresholds, but beneficiaries’ real-world receipt of those benefits in 2025 depended on appropriations actions, contingency reserves, transfer authority, and judicial interventions during funding lapses [6] [3] [5]. Observers should therefore evaluate two separate questions: whether benefit formulas were raised (yes, per USDA FY2025 guidance) and whether payments were delivered as adjusted (contingent on funding decisions and legal developments during the 2025 shutdown period) [1] [4] [9].