Which noncitizen groups qualify for SNAP benefits under 2025 federal rules?
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Executive summary
The One Big Beautiful Bill Act of 2025 (OBBB/“H.R. 1”) narrowed federal SNAP eligibility for many noncitizen groups effective July 4, 2025 and states were required to implement changes for existing cases by November 1, 2025 (FNS memoranda and state guidance) [1] [2]. After the law, federal guidance and multiple analyses say only lawful permanent residents (green card holders), Cuban‑Haitian entrants, and Compact of Free Association (COFA) citizens generally remain clearly eligible for SNAP; refugees, asylees, parolees, trafficking survivors and many previously exempt humanitarian groups face new restrictions or state‑level confusion [1] [3] [4].
1. What the federal rule change did and when it took effect
Congress enacted Section 10108 of the OBBB which changed “alien eligibility” rules for SNAP; the USDA’s Food and Nutrition Service issued an information memorandum on September 4, 2025 explaining implementation and directing states to apply the new criteria immediately for new applicants and to review ongoing cases with a recertification deadline and a November 1, 2025 exclusionary implementation window [1]. State notices and memos confirm the law was signed July 4, 2025 and effective for eligibility determinations as of that date [2].
2. Which noncitizen groups are explicitly still eligible under federal guidance
FNS materials and other reporting indicate the post‑OBBB federal baseline for SNAP eligibility preserves eligibility for lawful permanent residents (green card holders), Cuban‑Haitian entrants, and citizens of Compact of Free Association (COFA) nations — those categories are repeatedly referenced as remaining eligible under the new statutory framework [1] [3] [4]. Multiple FNS pages that list noncitizen groups and provide tables were updated in 2025 to reflect these changes [5] [6].
3. Which groups face new exclusions or uncertainty
Advocacy groups, state memos and policy briefs report that refugees, asylees, certain parolees, survivors of trafficking and other humanitarian immigrants who previously qualified under earlier statutes are now restricted in eligibility by H.R. 1 or are being treated as ineligible in some states — even where earlier federal law (PRWORA) had exempted them from a 5‑year waiting period — producing confusion and denials in practice [3] [4] [7]. FNS’s implementation guidance notes the law “makes changes to alien eligibility,” and attachment charts illustrate removals from previously eligible categories [1].
4. How states and agencies have reacted — implementation gaps and disputes
States received FNS memoranda instructing immediate application of the new criteria to new applicants, and a 120‑day variance exclusion period was noted for misapplications through November 1, 2025 [1]. In practice, several state agencies and advocacy organizations reported divergent interpretations: some states began applying the stricter rule to refugees and asylees, while advocates say the 1996 law’s exemptions should continue to apply — creating litigation risk and implementation inconsistency [2] [3] [7].
5. What is clear and what remains contested in reporting
What is clear in official materials: OBBB changed federal SNAP alien eligibility and FNS issued implementation guidance and explanatory charts [1]. What remains contested: whether longstanding 1996 PRWORA exemptions for humanitarian arrivals still protect groups like refugees and asylees from a waiting period — legal analysts and immigrant‑rights groups say the exemptions remain but warn federal guidance and state actions are unclear, and states are already moving to restrict benefits [3] [7].
6. Practical impact on applicants and frontline workers
State operational guidance and outreach materials note that determinations now hinge on narrow, documented immigration categories and verification; agencies warn applicants may be denied if they cannot document eligible noncitizen status, and advocates warn that misapplication or overly strict state interpretations will cut off benefits and raise food‑security and economic ripple effects in local communities [8] [2] [7].
7. How to follow up and who to trust for precise answers
For case‑specific eligibility decisions, the authoritative sources are the USDA/FNS webpages, the FNS information memorandum and a state’s own SNAP office — FNS has multiple pages updated in 2025 that list groups and guidance [1] [5] [6]. Advocacy groups (e.g., NILC, USCRI) and immigrant‑rights organizations provide analysis and monitor state implementation and should be consulted for examples of denials and administrative practice [3] [7].
Limitations: available sources do not provide a single, unambiguous statutory text listing every retained or removed category in plain language; instead, FNS memos, state notices and advocacy analyses together document who remains clearly eligible [1] [2] [3]. If you need authoritative, case‑level guidance for a particular person or household, contact your state SNAP office and consult the updated FNS “Non‑Citizen Groups” table and the OBBB implementation memorandum [5] [1].