Which states have contingency plans for SNAP if federal payments are delayed?
Executive summary
Multiple outlets reported that many states prepared to delay or alter SNAP (food stamp) payments during the 2025 federal shutdown, with at least 25 states planning cuts or pauses in November 2025 [1]. The federal USDA held roughly $5–6 billion in contingency reserves that legal advocates and some courts said could be used for benefits, while the administration initially resisted tapping those funds and some states moved on their own plans to either cut, partially pay, or seek court orders to restore benefits [2] [3] [1].
1. Which states planned contingency actions — the headline picture
Reporting in Politico and aggregated trackers showed a wide geographic spread: at least 25 states signaled they would pause or cut SNAP benefits if federal payments were not provided in November 2025, affecting states “from California to Arkansas” and putting millions at risk [1]. News outlets and state bulletins during the shutdown indicated some states would follow federal guidance to delay issuance, others would try partial payments, and a few sought legal routes or state-level temporary fixes [1] [4] [3].
2. Why states took local action: federal ambiguity and legal fights
The trigger for state contingency plans was a disputed federal posture: USDA’s “lapse of funding” materials and later administration filings signaled both the existence of a multiyear contingency reserve and uncertainty about whether it would be used to pay regular monthly benefits during a shutdown. Advocates and some courts argued the contingency reserve could and should fund benefits; the administration initially declined to fully tap it, prompting lawsuits and judicial orders [5] [2] [3] [6].
3. How states’ approaches differed — partial payments, pauses, and lawsuits
States’ responses varied: some planned to issue reduced or partial benefits aligned with the administration’s contingency-calculation guidance (about 50–65% in some reports), others paused issuance pending federal clarification, and several joined or supported court actions to force distribution of contingency funds so full benefits could reach recipients [3] [7] [1]. Axios and CNN reporting noted state agencies were prepared to resume normal issuance once federal funding or court orders resolved the dispute [4] [3].
4. The federal contingency fund: size and legal dispute
Multiple fact-checks and reporting put the contingency reserve at roughly $5–6 billion coming into the shutdown, a pot Congress had set aside across years that experts said could cover some months of SNAP benefits but not all needs if the shutdown extended [2] [6] [8]. The administration argued limits on using the fund and cited other program risks; courts in Rhode Island and D.C. ordered the agency to use contingency funds at least to provide partial benefits, producing a complex legal back-and-forth [3] [9].
5. Which states explicitly offered to backfill benefits with state funds?
Available sources catalog states’ operational plans and legal positions but do not provide a definitive list of specific states that committed state funds to backfill federal SNAP gaps. Some governors and state officials discussed possibilities (for example Maryland’s governor was reported to have talked about talks to fund SNAP locally), and legislative measures were introduced in a few states (Iowa, Missouri) to protect benefits — but the reporting emphasizes plans to cut or litigate rather than widespread state-funded backstops [10] [1]. Available sources do not mention a comprehensive, publicly confirmed list of states that would use state dollars to fully replace lost federal SNAP benefits.
6. Courts, temporary orders, and the shifting operational reality
Two federal judges ordered the USDA to tap contingency funds and to issue at least partial payments in November; one judge in Rhode Island demanded expeditious action. Those rulings prompted the agency to release funds and issue reduced benefits in some jurisdictions, but the administration appealed and sought stays, creating uneven outcomes across states until federal funding was restored [3] [9] [10].
7. Local consequences and political context
Reporting framed the standoff as both a legal technicality over contingency authority and a political lever in wider spending fights: advocates said withholding contingency funds made SNAP recipients “collateral damage,” while administration officials warned of risks to other nutrition programs if contingency funds were fully shifted [11] [7] [12]. That political context helps explain why states prepared contingency plans rather than relying solely on federal assurances [1] [12].
8. Limitations and what the records don’t show
Available sources document many states warning of cuts, some court orders, and the existence of a $5–6 billion contingency reserve, but they do not provide a single, authoritative state-by-state ledger of contingency plans or a confirmed list of states that committed state funding to fully replace federal SNAP payments [2] [1] [10]. For precise, up-to-date status in any specific state, state human services bulletins or the USDA FNS notices cited by reporters are the primary records [13] [4].
If you want, I can pull together the state-level notices and court filings referenced in these articles (where available in the reporting) to produce a state-by-state snapshot of who paused, who paid partially, and who got payments ordered by courts.